ML19291B895

Supplementary Brief in Lieu of Pleading Re Contention 9. Submits Detailed Geographical & Meteorological Basis for Contention Re Feasibility Studies of Solar Energy. Certificate of Svc Encl

ML19291B895
Person / Time
Site:	05000599, 05000600
Issue date:	11/14/1979
From:	Schwab J IOWA PUBLIC INTEREST RESEARCH GROUP
To:	Atomic Safety and Licensing Board Panel
References
NUDOCS 7912140034
Download: ML19291B895 (3)

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UlITED STATES OF AMERICA f:UCLEAR REGULATORY CClMISSI0fl h

[r," qEl 0.g b gy 2. 5 '.3N In the Matter of k\' cv..a

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Commonwealth Edison Company )

Interstate Power Company ) Docket flos. S-599',% . D .N Iowa-Illinois Gas and Electric ) S-600 ~"d em pd)s, Company )

Carroll County Site flovember 14, 1979 SUPPLEMEllTARY BRIEF 0F IOWA PIRG C0tlCERtlIllG C0flTEtiTIOri il0. 9 It is impossible before flovember 23, 1979, for Iowa PIRG to gather data to prove its contention in any conclusive fashion. Iowa '

PIRG assumes, however, that at this point, some d2 tailing of the geographical and meteorological basis for its contention will suffice to establish its credibility and gain its admissibility for the early site review.

Feasibility studies of solar energy in this part of the nation have tended to indicate a special effectiveness of these types of heating systems in the winter. The flat prairie states lying east of the Rocky Mountains are areas of relatively high winds during winter. They are also areas where the coldest winter days are generally cloudless, allowing the greatest amount of insolation, and thus offsetting the greater strain on solar heating systems under such~ conditions. By contrast, cloudy days in winter in the area are very frequently wanner, largely because of the atmospheric insulating effect of the cloud layer, which inhibits dissipation of the heat trapped beneath the cloud layer.

Indications are that, insofar as this relationship of solar heating effectiveness to winter weather patterns would be affected by the visible natural draft cooling tower plumes from the Carroll

~ ~ County Station, the~dstrimental effect would exceed that described.

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- --in Table- 5.1-1, CCS;SS-ER. Such plume effects are more likely to 7

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. lie induced 16 ~cold WaYtier, and so' far as Iowa PIRG can determine

~now, more'likely thanTaverage yearly figures would indicate, to impair the solar effdctifeness pattern described above. Due to the 9ack of-an-adequateroperating:codel-in Iowa or Illincis currently, ' -

'-Iowa PIRG.is still researching patterns at other reactors elsewhere,

-which map' provide a better benchmark. Iowa PIRG expects that _ .

evidence, as it develops, to be part of the process of discovery

_- and evidentiary hearings at a later time. - -

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-2 It is clear that most of the surrounding area of Carroll County consists of agricultural land. Two public schools are also nearby.

In evaluating the affected solar potential, it will be important to bear in mind the time frame for operation of Carroll County Station, a period roughly frcm 1990 - 2020, unless further delays in construction or the need for its power materialize.

President Carter has set a goal of 20% of our energy being derived from the sun by the end of the century. Many knowledgeable solar advocates believe we may achieve 33%. In any case, it is clear that the agricultural sector of our economy, due both to its sociological and technological peculiarities, and economic pressures, will often be leading the way in the conversion to solar energy.

This is already the case in much of Icwa and Illinois, with the use of solar crop drying, renewed interest in windmills, alcohol fuels, and solar heating and cooling.and cooling (including barns and feedlots). Interest in solar greenhouses is mushrooming.

Iowe PIRG's contention will be supported with careful calculation by its own staff and possible expert witnesses of the likely and feasible uses of solar energy during theaperating life of the reactors.

Iowa PIRG notes an almost total lack of awareness of such data by the Applicant, and avers that admissibility of its contention will add to the fullness and completeness of the record of the early site review. Iowa has perhaps the most advanced record in the solar energy field in the Midwest. Against that background, it is worth noting that sales of solar equipment for many manufacturers have quadrupled annually for the last five years. While such growth curves are no more likely to continue indefinitely than were the original projections for nuclear electricity, they will have a significant impact that needs to be considered via this contention.

In addition to the agricultural sector, Iowa PIRG also notes that the greatest plume drifts due to wind directions will affect potential urban uses, of some economic values, to the fiflE, flE, and flW, primarily parts of Mount Carroll and Savanna, according to Table 5.1-1,- and-the available maps. Also, directly to the northwest,

- ~~' a roximately one' kilometer,j.ies the Plum Grove School. Financially ,

~har pp'd-pressed #schobis' din'be expecMd~t6'hoyRoisM'sbiaFheh-tinir

.- in the; future-as: a: means of saving money. e "---7" -

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, Respectfully. submitted,

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• UMITED STATES OF AMERICA l.? i .

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NUCLEAR REGULATORY COMMISSION i,9

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BEFORE THE ATO.'IIC SAFETY AND LICENSIt:G BOARD N '

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'Gj U In the Matter of ) 'iW\

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COMMONWEALTH EDISON COMPANY, Occket Mos. S-599 g al. S-600 (Carroll County Site)

CERTIFICATE OF SERVICE I, James C. Schwab, hereby certify that copies of " Supplementary Brief of Iowa PIRG Concerning Contention No. 9" in the 'above-captioned proceeding have been served on the following by deposit in the United States mail, first class, this 14th days of November,1979.

John F. Wolf, Esq., Chaiman tir. Jim Dubert 3409 Shepherd Street Iowa Socialist Party Chevy Chase, Maryland 20015 129 Ash Street Ames, Iowa 50010 Mr. Glenn 0. Bright Atomic Safety and Licensing Board Atomic Safety and Licensing Board Panel U.S. Nulear Regulatory Comission U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Washington, D.C. 20555 Dr. Robert L. Holton Atomic Safety and Licensing Appeal Board Panel School of Oceanography U.S. Nuclear Regulatory Comission Oregon State University Washington, D.C. 20555 Corvallis, Oregon 97331 Docketing and Service Section Richard J. Goddard, Esq. Office of the Secretary Office of the Executive Legal U.S. Nuclear Regulatory Comission Drector,9604 MNBB Washington, D.C. 20555 U.S. Nuclear Regulatory Comission Washington, D.C. 20555 Thomas J. Miller Ai.torney General of Iowa

. Philip P~.~Steptoe, Esq..

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. . _- . . _ . State Capitol Complex ._ u. . ...

Isham, . Lincoln and BeaTe Des M61nes, Iowa 50319_

'One First National PTazi

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42nd Floor Mr.. John .W. .Cox, _Jr. .

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_ChicagoTIllinois ~~

60603 do Daviess County Ad Hoc Comittee on

-Nuclear Energy Information- -

.-- Nancy J. Bennett- 906 fampbell. Street -

Assmistant Attorney General Galena, Illinoi-s 61036 .

. Environmental Control Division . _ _ _ _ _.__

' ~~188~ West Randolph S'dfte~2315 , ~ Mr'.-~ James T. Rdnyon

- -Chicag& Illinois -60601 - - --

1316--Second Avenue- - -

P.O. Box 307 Rock Island, Illinois 61201 300]l UU [d Q']I f I[ 4 J Ae/

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