ML19254B272
| ML19254B272 | |
| Person / Time | |
|---|---|
| Site: | La Crosse File:Dairyland Power Cooperative icon.png |
| Issue date: | 07/31/1979 |
| From: | Hiestand O DAIRYLAND POWER COOPERATIVE, MORGAN, LEWIS & BOCKIUS |
| To: | |
| Shared Package | |
| ML19254B267 | List: |
| References | |
| NUDOCS 7909270039 | |
| Download: ML19254B272 (23) | |
Text
.
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter of
)
Docket No. 50-409
)
Amendment to DAIRYLAND POWER COOPERATIVE
)
Provisional Operating
)
License No. DPR-45 (La Crosse Boiling Water Reactor)
)
(Spent Fuel Pool)
STATEMENT OF MATERIAL FACTS AS TO WHICH THERE IS NO GENUINE ISSUE TO BE HEARD In accordance with 10 C.F.R.
S 2.749(a), Dairyland Power Cooperative (Dairyland or DPC) submits the following Statement of Material Facts As To Which There Is No Genuine Issue To Be Heard in support of its Motion for Sumnary Dispo-sition of all of the Coulee Region Energy Coalition's (CREC) contentions in the above-captioned proceeding:
Contention No. 1 1.
The structural components of the LACBWR spent fuel pool storage racks will all be fabricated out of stain-less steels.
(Raffety Affidavit at 1; SER at 8-9).
2.
The fuel assemblies presently stored in the LACBWR spent fuel pool and to be discharged from the reactor in the foreseeable future utilize stainless steel as the cladding material.
(Raffety Affidavit at 2; SER at 8-9).
1045 078 SnoCiEb 3999
-2 3.
Fuel assemblies with stainless steel cladding have been safely stored in spent fuel pools for the last 12 years.
(Raffety Affidavit at 3).
4.
The low temperatures and favorable water chemistries which exist in the pool environment inhibit the degradation of fuel cladding.
(Raffety Affidavit at 3).
5.
There are no obvious degradation mechanisms which operate on the cladding under pool storage conditions at rates which are likely to cause failures in the time frame of probable storage.
(Raffety Affidavit at 3).
6.
Corrosion or accelerated corrosion of spent fuel assemblies is not likely to occur and is not a significant factor in the storage of fuel assemblies in the LACBWR pool.
(Raffety Affidovit at 3: SER at 8-9).
7.
There 19 no indication that stress corrosion cracking of LACBWR spent fuel pool cladding could ever occur.
(Raffety Affidavit at 4-6).
8.
It is highly unlikely that intergranular stress corrosion cracking will occur or be a significant factor with respect to LAC 3WR spent fuel components.
(Raffety Affidavit at 4-6).
9.
The mechanical properties of cladding material and stainless steel components remain essentially unchanged in the pool environment.
(Raffety Affidavit at 6).
1045 079
-3 10.
Hydrogen absorption and precipitation does not affect stainless steel components.
(Raffety Affidavit at 6-7).
11.
The existing spent fuel pool monitoring pro-cedures at LACBWR are adequate to detect spent fuel leakage or disintegration.
(Raffety Affidavit at 7).
12.
There is no significant additional degradation of defective fuel assemblies once they are placed in storage in spent fuel pools.
(Raffety Affidavit at 8).
13.
Damaged fuel assemblies can be safely stored without encapsulation.
(Raffety Affidavit at 8).
14.
The deposition of crud on fuel assemblies occurs during reactor operations.
(Raffety Affidavit at 8).
15.
The thickness of the crud does not increase during storage.
(Raffety Affidavit at 8).
16.
There is no indication that crud increases corrosion or adversely affects the long term integrity of cladding materials or spent fuel pool components.
(Raffety Affidvait at 8).
17.
Damaged fuel assemblies can be safely handled and transferred to and from the LAC 3WR spent fuel storage pool.
(Raffety Affidavit at 8-9).
18.
Spent fuel transfers at the LAC 3WR spent fuel pool are conducted with the water level in the pool at the 700 foot level.
(Raffety Affidavit at 9).
1045 080
-4 19.
No fuel handling problems are expected to arise from the loss of integrity of spent fuel pool components.
(Raffetv Affidavit at 9).
Contention No. 5 1.
Dairyland does not plan to store freshly discharged fuel assemblies on top of one another in both tiers of the spent fuel storage racks.
(Raffety Affidavit at 9).
2.
The fuel handling movements associated with the use of the two-tier spent fuel storage racks will be essentially the same as those associated with the existing racks.
(Raffety Affidavit at 9).
3.
The potential consequences to the public health and safety associated with a fuel handling accident will not be significantly affected by the use of the two-tier design.
(Raffety Affidavit at 9; SER at 10-11).
4.
Existing monitoring procedures are adequate to detect any problems in the spent fuel assemblies stored in the lower tier or the lower tier itself.
(Raffety Affidavit at 10).
5.
The level of water coverage over the spent fuel will be greater for the two-tier racks than it is for the existing LACBWR rack configuration.
(Raffety Affidavit at 10).
6.
The potential incremental heat load associated with the additional storage capacity does not alter the safety 1045 08f
-5 considerations of the spent fuel cooling from those pre-viously reviewed and found to be acceptable by the NRC.
(SER at 4-5).
7.
The incremental occupational exposures associated with the increased frequency of resin sluicing and filter changing resulting from the additional pool capacity are negligible.
(Raffety Affidavit at 10; SER at 9).
Contention No. 6 1.
The size of the cask drop area itself does not affect the number of fuel handling movements, the probability of the occurrence of a cask drop accident, nor the magaitude of the potential consequences associated with such an event.
(Raffety Affidavit at 11; SER at 7-8).-
2.
The magnitude of the potential consequences associated t..h a cask drop accident primarily depends upon the number of freshly discharged fuel assemblies that are in-volved.
(Raffety Affidavit at 11; SER at 11-12).
3.
The expansion of the spent fuel pool capacity does not increase the number of fuel assemblies that will be discharged from che reactor at any one time.
(Raffety Affidavit at 11; SER ar. 11-12).
4.
The potential consequences of a cask drop accident involving the number of fuel assemblies associated with a normal refueling at LACBWR is well within the exposure guide-lines set forth in 10 C.F.R. Part 100.
(Raffety Affidavit at 11; SER at 11-12).
1045 082
-6 Contention No. 7 1.
Prior industry experience indicates that the storage of damaged fuel assemblies does not involve excessive radiation exposures, shorter storage life or increased storage costs.
(Raffety Affidavit at 12).
2.
The incidence of failed fuel being discharged from the re. actor to the spent fuel storage pool at LACBWR has been reduced.
(Raffety Affidavit at 12-13).
3.
There is essentially no additional degradation
/
of defective fuel assemblies once they are placed in spent fuel storage poc's.
(Raffety Affidavit at 12).
4.
There are no additional costs associated with the storageoffailedhuelassembliesversusnon-failedfuel
' assemblies.
(Raffety Affidavit at 13).
/
5.
The storage life for failed fuel assemblies can be expectea to bd the same as that for non-failed fuel assemblie3.
(Raffety Affidavit at 12-13).
6:
The additional exposures associated with the storage of failed feel at LACBWR will be negligible in light of the increase in uster level above the spent fuel and the de-crease in the rate of radioactive emissions from failed fuel over time.
(Raffety Affidavit at 13; EIA at 14).
Respectfully submitted, t
(W l \\
W U h.WA%
0.
S.' Hiestand Attorney for Dairyland Power Cooperative 1045 083
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter of
)
Docket No. 50-409
)
Amendment to DAIRYLAND POWER COOPERATIVE
)
Provisional Operating
)
License No. DPR-45 (La Crosse Boiling Water Reactor)
)
(Spent Fuel Fool)
AFFIDAVIT OF DR. SEYMOUR J. RAFf2TY State of Wisconsin:
County of Vernon:
Dr. Seymour J.
Raffety being first duly sworn, on oath says as folle.'s:
My name is Dr. Seymour J.
Raffety.
I am employed by Dairyland Power Cooperative (Dairyland), 2615 East Avenne South, La Crosse, Wisconsin, as Reactor Engineer.
I have been directly involved in the preparation and review of the applica-tion for a license amendment submitted by Dairyland in this proceeding as well as the various other technical analyses and reports submitted by Dairyland in connection with this pro-ceeding.
A statement of my piufessional qualificatiens is attached L;- this affidavit.
1045 384
-2 CREC Contention No. 1 1.
As discussed in the Applicant's Response to CREC's Second, Third and Fourth Sets of Interrogatories (Oct. 16, 1978), there is no need to discuss or evaluate the long-term integrity of the various components of and in the LACBWR spent fuel pool in any greater detail than Dairyland has already discussed and evaluated this subj ect, since pre-dicted material behavior, empirical evidence, and industry operating experience to dar.e all indicate that the occurrence of significant degradation of spent fuel pool components of the type proposed for use at LACBWR is extremely unlikely.
2.
The structural materials to be used in the components of the LAC 3WR spent fuel pool storage system are all stainless steels.
Existing and future fuel assemblies stored in the pool w... utilize Type 348 stainless steel as the cladding material.
These macerials were specifically selected because of their exceptional corrosion resistance.
There is a possibility that Zircaloy clad fuel may also be used at LACBWR in the future.
A relatively recent study of spent nuclear fuel stored in water pools performed by Battelle Pacific Northwest Laboratories concluded that fuel integrity could be maintained when fuel storage times were extended and fuel storage capacities were expanded.
A. 3. Johnson, Jr., Behavior of Spent Nuclear Fuel in Water Pool Storace, BNWL-2256, Battelle Pacific North-west Labs. (Sept. 1977).
The conclusion was based on examining 1045 085
-3 the behavior of fuel currently stored in water pools and examining the potential degradation mechanisms under pool storage conditions.
The study noted that a.
Zircaloy-clad fuel has been stored satis-factorily in pools up to 18 years; stainless-clad fuel has been stored in the same fashion for up to 12 years.
b.
Low temperatures and favorable water chem-istries which exist in the pool environment are not likely to promote fuel cladding degradation.
c.
There are no obvious degradation mechanisms which operate on the cladding under pool storage conditions at rates which are likely to cause failures in the time frame of probable storage.
3.
Both the Battelle Study and the NRC's Draft Generic Environmental Impact Statement on Handling and Storace of Scent Light Water Power Reactor Fuel, NUREG-0404, Vol. 2, App. H (Mar. 1978) reviewed the potential mechanisms for chemical corrosion of materials in spent fuel pools.
Both of these reports concluded that these mechanisms do not operate on the fuel assemblies at rates which are likely to cause failures, even during prolonged storage.
Since the rates ot corrosion tend to decrease with time, it is highly unlikely that corrosion 1045 086
-4 or accelerated corrosion would be a significant factor in the storage of additional amounts of spent fuel at LACBWR.
4.
Stress corrosion cracking (SCC) can theoretically manifest itself as either transgranular or intergranular crack propogation and can occur at high stress levels or in the presence of a halogen contaminant.
Transgranular SCC is not a potentially significant degradation mechanism at LACBWR for the following reasons.
a.
The halide ions in the pool water are main-tained at a very low concentration by cir-culating water through an ion exchange media so that the water is deionized and of a high purity.
The chlorides in the LACBWR pool water are routinely checked and maintained below 0.02 ppm.
b.
The residual stress levels in stored fuel assemblies are low (less than 5 to 10% of the room temperature yield strength) for the fol-lowing reasons:
(1) reactor exposure tends to relax high stresses from fabrication.
(2) pellet-clad interactions are minimized when the fuel cools down to pool tempera-cures.
(3) residual gas pressures are low, particularly in nonpressurized fuel rods such as LAC 3WR.
1045 087
-5 Intergranular propagation requires the presence of high stress levels in the material (at or above the yield stress).
While intergranular SCC can be generated by high stress levels, crack propagation is accelerated if the material is sensitized and/or if a corrosion inducing agent is present (either halide ions or highly oxygenated water).
Intergranular SCC is not a potentially significant degradation mechanism in c.,ent fuel storage pools for the following reasons:
a.
The residual stress levels in stored fuel assemblies are typically well below the yield point.
b.
The stainless steel selected for the fuel cladding is Type 348 which is a stablized grade of stainless steel developed to eliminate carbon precipitation and, consequently, inter-granular corrosion.
c.
The halide ion concentration is maintained at a very low level.
Moreover, the Battelle study indicates that there is nothing in current fuel storage experience which suggests that stress corrosion cracking is an operative degradation mechanism for either stainless steel or Zircaloy.
Zircaloy is considered to be particularly i=mune to stress corrosion cracking in an aqueous media.
The NRC Draft EIS states that considerable ex-perience has been gained at the Savannah River Plant in the 1045 088
-6 storage of packaged fuel assemblies n Type 304L stainless steel.
By maintaining the chloride concentration of the pool water below 5 ppm (at least 250 times higher than LACBWR's pool water), stress corrosion cracking has been avoided and other corrosive effects have been found to be minimal.
Type 304L is formulated to have a low carbon content, thereby mini-mizing the potential for carbide precipitation and, in turn, intergranular SCC.
Its behavior supports the selection of Type 348 stainless as a suitable material to prevent intergranular SCC.
5.
Mechanical properties of either cladding material are essentially unchanged by the pool environment.
The principal aspect of the pool environment which has the potential to affect mechanical properties is gamma irradiation.
The additional gammt radiation to which spent fuel cladding is subj ected durir tuel storage is only a very small fraction of the gamma irradiation that the material is exposed to during its residence in the reactor.
An increase in gamma exposure of this magnitude will have no effect on the mechanical properties of the stored fuel cladding.
6.
Hydrogen absorption and precipitation is applicable only to Zircaloy since austenetic stainless steel is essentially not affected by these phenomena.
It is therefore highly un-likely that the existing LACBWR fuel, new fuel racks and pool liner could ever be affected by this problem.
Generally, Zircaloy is also not affected in the pool environment unless galvanic-1045 089
-7 induced hydriding occurs.
As the Battelle study indicates, such hydriding is not likely to occur in a spent fuel storage pool due to the a.
Relatively high purity water, b.
Absence of direct Zircaloy-aluminum
- Contacts, Oxide films on the irradiated Zircaloy c.
fuel rods, and d.
Normal pool temperatures being well below the range wnere rapid hydriding has been observed.
7.
The Battelle study indicates that leakage and disintegration of spent fuel and its cladding is highly unlikely in spent fuel storage pools.
Dairyland tests all fuel assemblies to determine their integrity prior to placing them in the pool.
Dairyland also has in place a program to monitor radioactivity (alpha, beta, and gamma levels) in the pool water.
Visual in-spections will also be conducted whenever fuel asse=blies are moved for other purposes.
Thus, the existing monitoring programs will enable Dairyland to determine if any significant leakage or disintegration occurs in the pool.
In light of the industry's extensive experience with the storage of irradiated fuel assemblies in water for long periods of time indicating that significant degradation does not occur in storage and Dairyland's own prior experience with 1045 090
-8 storage of the LACBWR fuel, no additional monitoring of the fuel assemblies in the storage pool is warranted.
8.
Given the very low solubility of UO2 in water, the water chemistry in the LACBWR pool, and prior industry ex-perience indicating that there is essentially no additional degradation of defective fuel once it is placed in a storage pool, there is simply no need for defective fuel to be encapsu-lated for storage.
The deposition of crud (primarily oxides of copper, nickel, and iron) on the fuel assemblies occurs during the operation of the reactor.
The thickness of the crud on the fuel rods when discharged from the reactor is nominally less than 1.5 mils and remains essentially the same during storage.
There is no indication that crud increases corrosion rates on cladding materials or the structural components of the pool.
9.
Dairyland's spent fuel storage rack layout and proposed rack installation plan (see Applicant's Response to CREC's First Set of Interrogatories, Oct. 5, 1978) are de-signed to reduce the number of fuel movements necessary to effect fuel transfers.
These movements all involve routine fuel handling procedures.
Prior operating experience at LACBWR in-volving the handling and moving of damaged fuel assemblies has conclusively demonstrated that such fuel assemblies can be safely handled and moved and that Dairyland's existing operating procedures are completely adequate in this respect.
l045 091
-9 Fuel handling and reloading will continue to be con-ducted with the pool water level at the 700 foot elevation.
Since i' is highly unli'<ely that there will ever be a loss of integrity of spent fuel pool components, no fuel handling prob-lems are expected to arise in this regard.
CREC Contention No. 5 1.
The two-tier storage rack design will enhance the usage of the pool floor area available for fuel storage and provide sufficient water depth for shielding during fuel transfers.
The potential consequences associated with a fuel handling accident in the spent fuel pool will not be signifi-cantly affected by the use of the two-tier design since the number of fuel handling movements associated with the transfer of fuel being discharged from the reactor will not be signifi-cantly increased at the end of each operating cycle and since it is the fuel that is actually being discharged which represents the greatest contributor to such consequences.
Dairyland does not plan to store freshly discharged fuel assemblies on top or one another in the lower and upper tiers and the racks are de-signed to reduce the likelihood of impacts among assemblies.
Given these facts and Dairyland's prior experience handling fu<.
assemblies, I do not believe that there will be any appreciable reduction in the protection afforded to the public health and safety and the Dairyland employees as a result of the use of the two-tier design.
1045 092
-10 2.
As noted previously, existing monitoring pro-cedures are adequate to detect problems in the lower tier.
If any problems occur, the affected fuel assembly can be raved to the upper tier for greater surveillance by television camera and other remote monitoring equipment without risk of any additional exposure to the public cr Deiryland employees.
3.
The water level in the pool will be maintained at least sixteen (16) feet above the spent fuel once the new racks are installed.
Since Dairyland presently maintains the water level at twelve feet above the spent fuel, the level of water above the fuel for the two-tier design will be greater and the margin of safety "so far as loss-of-coolant accidents in the SFP are concerned" will actually be enhanced.
4.
Dairyland has conservatively assumed that the frequency of resin sluicing and filter changing will double as a result of the increase in the pool storage capacity.
Based upon present occupational exposures associated with these tasks, it is therefore estimated that this increased frequency will cause an additional 1.5 man-rem per year of exposure to Dairyland's employees.
This increased exposure represents less than 17. of the average total annual occupational exposure at LAC 3WR, is well within the limits of 10 C.F.R. Part 20, and can be considered negligible.
1045 093
-11 CREC Contention No. 6 1.
While it is true that the design for the proposed modifications to the LACBWR storage pool calls for a smaller cask drop area, this does not affect the number of fuel handling movements, the probability of the occurrence of a cask drop accident, nor the magnitude of the potential consequences associated with such a highly unlikely event.
The analyses which Dairyland has performed with respect to a cask drop accident (see e.g., LAC-3187 (June 13, 1975), LAC-5341 (June 7, 1978), LAC-6356 (June 26, 1976), LAC-6404 (July 11, 1979))
all conservatively assume that all of the freshly discharged fuel assemblies from a refueling offload will be damaged in the event of such an accider.t.
Therefore, the size of the cask drop area itself does not present any increased threat to the public health and safety or Dairyland's employees.
2.
The NRC Staff Safety Evaluation Report dated October 22, 1975, for the prior modifications to the LACBWR spent fuel storage pool, concluded that the potential conse-quences of a cask drop accident involving 24 freshly discharged fuel assemblies (i.e., a normal refueling) would be well within the limits set forth in 10 C.F.R. Part 100.
Since the gaseous fission products in the older fuel assemblies in the pool decay to insignificant levels within a few months, the presence of additional older spent fuel assemblies in the pool as a result of the proposed expansion in capacity will not affect the bounding 1045 094
-12 nature of the previous analyses.
Therefore, since the prob-ability of a cask drop accident is extremely low and since it has been shown that the potential effects in the event of such an accident are not expected to be significant, the increase in storage capacity at LACBWR will not significantly " increase the risk of accidental releases to employees and the public in the event of a cask drop accident."
CREC Contention No. 7 1.
Experience at the Dairyland, CS, and NFS storage pools at LACBWR, Morris, Illinois, and West Valley, New York, respectively, with the da= aged fuel assemblies which previously exhibited leakage under operating conditions at LACBWR has shown that there has been no significant additional leakage of this fuel in the relatively benign environ =ent of these storage pools.
None of these facilities have experienced excessive radiation, shorter storage life, or increased storage costs with these assemblies.
2.
Experience during Cycle 5 operations at LACBWR indicates that the Technical Specifications introduced prior to the cycle which were designed to reduce fuel failures at LACBWR have had their intended effect.
Additional Technical Specifica-tions designed to further reduce the incidence of fuei failures at LACBWR in future operating cycles were recently i=posad pursuant to Amendment No. 16, Provisional Operating License No.
DPR-45 issued by the NRC on May 25, 1979.
The present incidence 1045 095
-13 of fuel failures at LACBWR is less than the failed fuel fraction which was permitted under the original LACBWR operating license and presents no significant risk to the public health and safety, the environment, or Dairyland's employees.
3.
The time between changes of filters and de-mineralizer resins varies according to the concentration of transportable or soluble materials which have been introduced into the storage well, the pressure drop across the filter, and the decontamination factor associated with the resin.
The pre-sence or absence of failed fuel assemblies in the pool does not appreciably affect the service life of filters or demineralizer rest ts at LACBWR.
The additional annual costs associated with storing additional spent fuel in the modified spent fuel pool are primarily associated with these resin and filter changes.
These costs are conservatively estimated over the next ten years to be under $40,000, regardless of the amount of failed fuel that is present.
See Applicant's Response to CREC's First Set of Inter-rogatories (Oct. 5, 1978).
The additional exposure associated with the storage of failed fuel is also expected to be negligible given the increase in the water level in the pool above the spent fuel and the decrease in the rate of radioactive emissions from failed fuel over time.
For all the foregoing reasons, I do not believe that the storage of failed fuel rods a' LACBWR will result in more dangerous and shortened storage life or increased storage costs.
1045 096
-14 I have read the foregoing affidavit and swear that it is true and accurate to the best of my knowledge.
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'Sey=our J. Raffety
/
Subscribed and sworn to before me this
.'4 /
day of July, 1979.
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1045 097
NAME:
Seymour J. Raffety ADDRESS:
Dairyland Power Cooperative P. O. Box 135 Genoa, Wisconsin 54632 CURRENT OCCUPATION:
Reactor Engineer EDUCATION:
Grinnell College, Grinnell, Iowas BA-1954, Physics Iowa State University, Ames, Iowa:
M.S.-1960 and Ph.D.-1964 in Nuclear Engineering Professional Engineer, Wisconsin License No. 13099 DISSERTATIONS:
Master's Dissertation:
' Thermal Neutron fduelding Measur - nts in the UTR-10 Shield
'I mk Facility", (1960).
Doctor of Philosophy Dissertation:
" Design of UTR-10 Fission Plate", (1964).
PUBLISHED WORKS:
1.
S. J. Raffety and J. T. Mihalcro,
'He cogeneous Critical Asse=blies of 2 ar.d 3% Uranium-235 Enriched Uranium in Paraffin", Nuclear Science and Engineering:
48,433-443 (1972).
2.
S. J. Raffety and J. T. Tho=as, "Experi-mental Determination of Safe Randling Procedures for High Plux Isotope Reactor Fuel Ele =ents Outside the Reactor",
U.S. AEC Report ORNL-TM-1488, (1966).
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1045 098
UNITED STATES OF AFERICA NUCLEAR REGULATORY COMMISSION In the Matter,of
)
Docket No. 50-409
)
Amendment to DAIRYLAND POWER COOPERATIVE
)
Provisional Operating
)
License No. DPR-45 (La Crosse Boiling Water Reactor)
)
CERTIFICATE OF SERVICE Service ha-on this day been effected by personal delivery or first class mail on the following persons:
Charles Bechhoefer, Esq., Chrm.
Docketing & Service Section Atomic Safety and Licensing Office of the Secretary Board Panel U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission Washington, D.C.
20555 Washington, D.C.
20555 Atomic Safety and Licensing Mr. Ralph S. Decker Eoard Panel Route 4 U.S. Nuclear Regul atory Box 190D Commission Cambridge, Maryland 21613 Washington, D.C.
20555 Dr. George C. Anderson Atomic Safety and Licensing Department of Oceanography Appeal Board University of Washington U.S. Nuclear Regulatory Seattle, Washington 98195 Commission Washington, D.C.
20555 1045 099
,. J*
-2 Colleen Woodhead, Esquire Office of Executive Legal Director U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Richard J. Goddard, Esquire Office of Executive Legal Director U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Richard Shimshak Plant Superintendent Dairyland Power Cooperative La Crosse Boiling Water Reactor Genoa, Wisconsin 54632 Fritz Schubert, Esquire Staff Attorney Dairyland Power Cooperative 2615 East Avenue, South La Crosse, Wisconsin 54601 Ms. Anne Morse Coulee Region Energy Coalition Coulee Region Energy P. O. Box 1583 Coalition La Crosse, Wisconsin 54601 P. O. Box 1583 La Crosse, WI 54601
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, Q/ O. S. Hiestand t
Dated:
July 31, 1979 1045 100