ML19323G811

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Statement of Consolidated & Modified Contentions Re Plum River Fault Terrestrial & Aquatic Ecology,Stransky Airport, socio-economic Risks & Roads at Site.Certificate of Svc Encl
ML19323G811
Person / Time
Site: 05000599, 05000600
Issue date: 05/30/1980
From:
Atomic Safety and Licensing Board Panel
To:
Shared Package
ML19323G803 List:
References
NUDOCS 8006090055
Download: ML19323G811 (10)


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UNITED STATES OF AMERICA n.

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NUCLEAR REGULATORY CC'EISSION

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John F. Wolf, Chairman b]w[Q Dr. Robert L. Holton Glenn O. Bright In the Matter or

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COMMONWEALTH EDISON COMPANY,

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Docket Nos.

550-599 ET AL.

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S50-600

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(Carroll County Station Site)

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CONTENTIONS WHICH ARE AT ISSUE IN THE ABOVE INDICATED MATTER I.

The contentions wnich have been consolidated and modified follow:

1.

Plum River Fault Applicants have failed to show by accepted geologic standards that the Plum River fault, which runs within 5.5 miles of the site is not a capable fault in determining site geologic suitability and the safety measures that will be necessary to insure that the continued working integrity of the proposed reactors will be adequate

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Illinois Contention #5; Iowa PIRG Contention #1; fJoDaviessContention#II;

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ISP Contention pl(a)(ii).

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. 2.

Terrestrial and Acuatic Ecolozy Applicants have failed to accurately evaluate the effect of the proposed reactors on the terrestrial and aquatic life in the proposed exclusion area; the site area generally mui especially in the upper Mississippi River Fish and Wildlife Refuge.

The requirements of the

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National Environ = ental Policy Act; 10 CFR Part 20; and 10 CFR Part 51 have not been met in Applicants' Early Site Review.

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Illinois Centention #6; Iowa FIRG Contention #10; fJoDaviessContention#III.

3.

Stranskv Airport There are unacceptable risks to the public health and safety due to the difficulties concerning approach and departure from Carroll County's Stransky Memorial Field which lies 2.3 miles from the proposed site for the nuclear power plant.

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Illinois Contention #7; f

Jo Daviess Contention #IV(c).

4.

Socio-economic Risks There are unacceptable socio-economic losses for the inhabitants of the surrounding area which would result f cm using the pre:osed site to construct and operate a nuclear power plant.

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Illinois Contention #15; Iowa PIRG Contention #3 f

except 3(a) and reference to trans=issien lines.

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ISP Contention #1(b).

f Jo Daviess Contentions #IV(a);

IV(d);

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IV(e); V(a)(4) and V(b).

5.

Roads at Site There is a lack of safe and adequate roads on the site area for transportation to and from the site and for evacuation in the event of an onsite accident.

There are very limited options for away from downwind evacuation in the event of an accident requiring such action.

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ISP Contention f(a)(i);

fIowaPIRGContention#7.

II.

The State of Illinois Contentions (Ill. Contentions)

In addition to the State of Illinois Contentions which have been accepted and consolidated, as set forth in Section I above, the following Illinois contentions are accepted:

1.

10 CFR 551.20(a)(3) requires that the Applicant's Environmental Report be "sufficiently co=plete to aid the Commission in developing and exploring - pursuant to Section 102(2)(E) of National Environmental Policy Act appropriate alternatives."

Applicants, in CCS-SS-ER Ch. 9.2 have no cet the recuired standard in that they i

l have failed to provide adequate discussiens of alternative 9

sites (Ill. Cententiens a an: 4 0)'.

. 2.

In determining public health and safety, applicants have failed to adequately consider or take into account the effect on the proposed reactor of explosions which could occur at the Savannah Army Depot, which is 13.2 miles from the proposed site and is used for the storage of artillery a= munition, bombs and their cocponents, grenades, rockets, mine and engineering explosives,

riot control agents, fuses, primers, pyrotechnics, and missile warheads.

(CCS-SS-SSR 52.2.2.2).

(Ill. Contention #8).

3.

In determining public health and safety, applicants have failed to adequately censider or take into account the effects on the proposed reactors of explosions which could occur during the transportation of such ac=unitions as mentioned above on either the Burlington Northern Railway or on Illinois Route 84.

(Ill. Contention #9).

4.

Potential areas of archeological value were not investigated in Site Suitability Environment report (CCS-SS-ER 8.3-29).

The Sauk and Fox Indian Tribes occupied Carroll County along the Mississippi River until the last century and the final retreat following the l

Blackhawk War.

Many artifacts of Indian civilitation are extant.

There has been no censideration of whether urilitation of the Carroll County site will cause dis-

. turbance of Indian burial grounds and Icas or destruction of archeological knowledge and artifacts significant to past and present Native American Culture.

(Ill.

Contention #16)

III.

Jo Daviess County Ad-Hoc Comnittee on Nuclear Energv "Information" (Jo Daviess Contention)

In addition to "Jo Daviess" contentions which have been accepted and consolidated as set forth in Section I above the following concentions by said Ad-Hoc Committee are accepted:

1. [ Applicant has not adequately analyzed.]

the effect upon aquatic and avian (including bald eagles. peregrine falcens, and red-shouldered hawks) spawning, nesting, and wintering habits of keeping Pool 13 of the River open in the wintertime.

(Jo Daviess Contention III(a))

2. [ Applicant has not adequately analyted.]

the effect of displacement by construction, maintenance, and operation of a nuclear power plant at this site upon the habitats of beaver and marsh hawks known to be r

(Jo Davies's Contention III(c).

l in the exclusion area.

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3. [ Applicant has not adequately analyzed.]

l the effect of the operation of the water intake and discharge syste=, and its potential for ther=al increases,

upcn the aquatic, avian, ur.d :errestrial wildlife 5

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. habitats of Pool 13, its adjacent marshlands and sand and native prairies, and surrounding uplands.

(Contention III(d))

4. [ Applicant has not adequately analyzed.]

the effect, upon migratory flight and resting patterns and habitats, of fogging and icing, mad of salt drift and deposition, from the site's cooling towers.

(Contention III(e))

5. [ Applicant has not adequately analyzed.]

the effect of the strong river current upcn the potential transportation of centaminated discharges into Pool 13.

(Contentien III(f))

6. [ Applicant has not adequately analyzed.]

the following hydroloeical concern:

(1) the high potential for contaminatien of the unconsolidated aquifers located under said site.

l (Contention III(i))

7. [ Applicant has not adequately analyzed.]

the following meterological concerns :

(1) icing and fogging; (2) salt drift and deposition; (3) the effect of severe snew and glare scorns (wnich are cocmon in the site area) upcn aquatic, avian, and terrestrial wildlife habitats, in relation te tha foregoing neterological c:n= erns. (Centanti:n :::(j ? )*

, 8.

[ Applicant has not adequately analyzed.]

the effect of fogging and icing, and salt drif t and deposition, upon the agricultural economy.

(Contention V(a)(31)).

IV. Iowa Socialist Party Contentions (ISP)

ISP contentions which have been accepted are consolidated and are set fcrth in Section I above.

The following contentions by ISP are accepted as modified:

Section I.4, "Socio-economic Risks" based in part on ISP Contention 1(b);Section I.5, " Roads at Site" is based in part on ISP Contention 1(a)(i).

V.

Iowa Public Interest Research Grous Inc. (Iowa PIRG)

Iowa PIRG Contentions are the basis in part for Consolidated Contentions (See Section I above).

-"I.1 Plum Ritzer Fault"--cites Iowa PIRG Contention #1.

I.2 Terrestrial and Aquatic Ecology"--

cites Iowa PIRG Contention #10.

"I.4 Socio-Economic Risks"--cites j

Iowa PIRG Contention #3 except 3(a) and any reference to transmission lines.

"I.5 Roads at Site"--cites Iowa PIRG Contention #7.

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UNITED STATES.OF AMERICA NUCLEAR M GULATORY COMMISSION In the Matter of

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Commonwealth Edison Company

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Interstate fower Company

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Docket No. (s) 550-599 Iowa-Illinois Gas and Electric

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S50-600

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i' CERTIFICATE OF SERVICE I hereby certify that I have this day served the foregeing document (s) upon each person designated on the official service list co= piled by the Of fice of the Secretary of the Comission in this proceeding in

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accordance with the requirener.ts of Section 2.712 of 10 CFR Part 2 -

Rules of Practice, of the Nuclear Regulatory Coc=issierz's Rules and Regulations.

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Dated at Washington

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(Of fice of the Secretary of the Comission I

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EW UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 5EE En

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COMMONWEALTH EDISON COMPANY

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5 Docket Nos. 550-5 M l

INTERSTATE IDWER COMPANY

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IOWA-ILLINOIS GAS AND ELECTRIC

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COMPANY

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(Carroll County Site)

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[E SERVICE LIST E

John F. Wolf Esq.

Mr. Ja=es C. Schab, State coor.

55 3409 Shepherd Street Iowa PI2G

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Chevy Chase, Maryland 20015 36 Memorial Usien

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Iowa State University

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Mr. Glenn 0. Bright A=es, Iowa 50010

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Atomic Safety and Licensing Board F

U. S. Nuclear Regulatory Commission Ms. Nettie Post h--

Washington, D. C.

20555 382 East 21st street E--

Dubuque, Iowa 52001 Dr. Robert L. Holton E

. School of Oceanography Mr. Paul A. Fuerst 1

Gregon State University Dubuque Fellowship of Reconciliation Corvallis, Oregon 97331 309 Dodge stree:

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Dubuque, Iowa 52001 E

Counsel for NRC Staff Office of the Executive Legal M:. ?.ichard Wor:n, President E

Director Environmental Coordinating U. S. Nuclear Regulatory Commission Organization, Inc.

Washington, D. C.

20555 3555 Hillcrest

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Richard E. Powell, Esq.

.11 Isham, Lincoln and Beale Mr. Thonas J. sorg s!

One First National flaza Carroll County Inviron= ental Coalition

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42nd Floor 305 7est Cole "Ji Chicago, Illinoi: 60603 Mount Carroll, Illinois 61053 Co==enwealth Edison Company A3:

Mr. Cordell Reed J

Assistant Vice President

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Chicago, Illinois 60690 D**

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Board and earties - continued:

50-599, -600

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'd - Dubert j-c/o Iova Socialist Earty 2801% k'est Street A=es, Iowa 50010 Clifford E. Peterson, Esq.

j Assistant Attorney General

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State Capitol Comple:

Des Moines, Iowa SC_;9 The Joe Daviess County Ad Hoc Co==ittee on Nuclear Energy Infor=ation c/c "r. John k'.

Cox, Jr.

996 Ca:pbell Street Galena, Illinois 61036 tiancy J. Bennett, Esq.

Assistant Attorney General State of Illinois 185 West Randolph Street Suite 2315 Chicago, Illinois 60601 Jan L. Kodner, Esq.

Pitler and Mandell 230 West Monroe Street Suite 2026 Chicago, Illinois 60606 4

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