ML19259B173
| ML19259B173 | |
| Person / Time | |
|---|---|
| Site: | Perkins  |
| Issue date: | 12/22/1978 |
| From: | Pfefferkorn W PFEFFERKORN & COOLEY, P.A. |
| To: | |
| Shared Package | |
| ML19259B174 | List: |
| References | |
| NUDOCS 7901170043 | |
| Download: ML19259B173 (6) | |
Text
,
e,,
\\
of
.c]e,:hd}\\
- }
-a i
3' UNITED STATES OF AMERICA kl nG E '
)f NUCLEAR REGULATORY COMMISSION
- ,;. T $. s,>%p e
s nrs Gojsy In the Matter of
)
)
DUKE POWER COMPANY
)
DOCKET NOS. STN 50-488
)
50-489 (Perkins Nuclear Station,
)
50-490 Units 1, 2 and 2)
)
)
PRELIMINARY RESPONSE TO PROPOSED SUPPLEMENTAL NRC STAFF TESTIMONY REGARDING THE CRITERIA USED TO SELECT SITE ALTERNATIVES TO THE '"RKINS SITE AND THE EXAMINATION OF SITE ALTERNATIVES TO PERKINS The Intervenors respectfully submit as previously mentioned in a letter dated December 13, 1978, that the proposed supplementary tettimony of the NRC Staff is completely in unacceptable for many reasons,which will be brought out the hearing of this matter and in the testimony to be offered by the Intervenors which is being developed at this time by the Intervenors.
However, until the Intervenors have been able to full; develop their own testimony and analysis in detail, they are in a position to comment generally on the proposed supplementary testimony.
The proposed testimony is too superficial and too It does not of fer a careful cost benefit analysis incomplete.
of any of the proposed sites.
It obviously allowed one of the obviously superior sites, that which is designated in 6
7 90117 0 0 g
the north end of Lake Norman on the Catawba 1973 as N-18 at River, to fall out of consideration at the early stages of Other inadequacies the first stages of the selection process.
will be pointed out in this preliminary response.
it is stated On page 2 of the proposed testimony, 1978 study is given more emphasis than the 1973 that the study, which is an indication of the misconceived analysis in this proposed testimony.
The information from 1973 is not tainted by the assumption that the Perkins plant is going to be built.
As in 1973, the Perkins site is still an unsatis-such as Lake factory alternative and the Lake Norman sites, D and E and Lake Norman N-18, stand out as obviously Norman superior in that Lake Norman N-18 does not recuire a Carter Creek reservoir a,nd the unnecessary extra expense of millions the for the construction of such a reservoir at of dollars By relying on the 1978 study to a greater extent N-18 site.
than the 1973 study, the proposed testimony on its second page indicates that it is not going to end up with any con-clucions different from those of the applicant.
The screening methodology and candidate site selection, which begins on 3 and starts with the course screening followed by the page intermediate screening, is obviously flawed when on considers that N-18 apparently drcps out of the running in the course screening.
It is not clear from page 4 and 5 of the proposed None testimony as to why this particular site dropped out.
listed on page 5 would apply.
One must of the reasons to sites D and E assume that N-18 was considered redundant at Lake Norman.
There is no reason for this to be so considered and no analysis is shown to so consider it.
In addition to the light shed on the proposed testimony by a consideration of site N-18, it should be pointed out that neither the study of 1973 or the study of 1978 and the attachments sent in August of 1978 by the appli-contain all of the background information which applicants cant were using.
Particularly, they do not contain the hydrological information which makes N-18 and sites D and E obviously superior to Perkins and the other sites.
Again, none of the reasons listed on page 5 and 5A would apply to N-18.
- Thus, the conclusion on page SA that the remaining 38 sites are
,f representati've of all the resource areas in the region interest is clearly unsupportable.
The analysis at the top of page 6 is simply incom-prehensible.
The study is less valuable, nuc more valuable, because of the assumption that Perkins vould pass muster.
The use of the 1978 document means that Perkins does not get exposed to the careful scrutiny that is required at this stage of the proceedings.
Obviously, the applicant's study in 1978 subjects Perkins to no scrutiny.
For that reason, the Phase I siting study dealing with a slate of thirty-eight potential sites is flawed from the beginning.
On page 7 the failure to consider dollar costs as aspect of site suitability and environmental factors does an comply with proper cost benefit analysis under the not National Environmental Protection Act.
For the above reasons, as well as others to be developed, the conclusions beginning on Page 8 are not supported by the evidence or by the attempted analysis.
More specifically, conclusion number 2 indicates that it is supported by a single letter by one state official in North Carolina.
At the present time the intervenors have peti-tioned for the environmental management commission of North Carolina to state the position of North Carolina on the subject and certainly the letter relied on in this conclu-sion cannot be taken as the truth of the state of the law and the environmental facts as to the availability or unavailability of a cooling option available to the cooling towers proposed at the presently proposed Perkins site.
Conclusion number 2 is an attempt to use one letter by one state official to eliminate the obs,ous This letter superiority of the Lake Norman sites D and E.
and the conclusion are not supported by the evidence which Intervernors have obtained from the applicant and the studies which have been done at Lake Norman which indicate that once through cooling is and will be available for additional plant sites on Lake Norman at both sites D and E.
The visits of the Staff to the candidate sites were obviously flawed by the failure to visit N-18,which the other Lake in a cooling tower site, and by visiting at Norman sites with the assumption that once-through cooling could not be used.
Detailed analysis of the proposed testi-mony beginning at page 10 and 11 has not been completed by the Intervenors at this tbme.
_4
The attempt at a hydrologic analysis which concludes on page 20 is so sketchy and incomplete that anyone familiar with these proceedings can plainly see that the water problems the Perkins site are not accurately presented and the advan-at tages in terms of hydrology of the Lake Norman E site and other sites is not adequately evaluated or appreciated in this analysis.
Intervenors intend to supply and clarify the hydrologic aspects of the site alternative question.
We are confident that a full and fair analysis on this questioon along will result in tae Perkins site being the least desirable site of all.
Intervenors are also confident that the Perkins site is least desirable in terms of water quality as that attempted analysis begins on page 21 of the proposed testimony.
is particularly interesting that at page 22 the statement It is made that none of the river systems involved are part of the Wild and Scenic River System without referring to the fact that the Yadkin River at the Boone State Park near the Perkins site has been proposed as part of the Wild and Scenic River System.
The conclusions in the middle of page 24 are not even supported by the Final Environmental Impact Statement.
Certainly, the conclusions at the bottom of page 24 and page 25 can only be said to agree with the newspaper accounts of the visits of the testifiers to North Carolina in September of 1978 when they were quoted as saying that they did not believe that the trip would change anything.
Certainly, the trip and the proposed testimony does not come to grips with the significant problems raised at the Perkins site and with the fact that the three sites on Lake Norman are obviously superior in all of the important criterion of an environmental and cost benefit analysis.
Intervenors are continuing their legal and f actual research in this matter and are contacting expert witnesses.
Intervenors expect to deal thoroughly, adequately, and properly with the site alternative questions when it receives the additional information from applicant and files it pre-filed testimony in. January.
Y This the M day of December, 1978.
l1 k
f Yh A
T William G.
Pfeffeb:cM1 Attorney for Intervenors OF COUNSEL:
PFEFFERKORN & COOLEY, P.A.
Post Office Box 43 202 West Third Street Winston-Salem, N.C.
27102