ML19323H858
| ML19323H858 | |
| Person / Time | |
|---|---|
| Site: | La Crosse File:Dairyland Power Cooperative icon.png |
| Issue date: | 04/24/1980 |
| From: | Morse A, Nygaard G COULEE REGION ENERGY COALITION |
| To: | NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| References | |
| NUDOCS 8006170125 | |
| Download: ML19323H858 (3) | |
Text
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4/24/80
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UNITED STATES OF AMERICA 7
NUCLEAR REGULATORY C0131ISSION ATOMIC SAFETY AND LICENSING 3OARD 6:
APR 2 983) > :
Citi:e of the Secretuy g
Omehr & Sml:e In the Matter of.
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Docket No. 50-409 v'
DAIRYLAND POWER COOPERATIVE
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Full Term Operating License (La Crosse Boiling Water Reactor) )
INTERVENORS' RESPONSE TO STAFF INTERROGATORIES 1.
Intervenors have not engaged any persons to appear as expert witnesses at said hearings.
5 At what point do airborne radionucledes stop?
This question seems to be based on the same assumptions that the threshhold theory of radiation are based on.
6.
The doses received by employees at LAC 3WR were discussed in the Spent Fuel Pool evidentiary hearing held in October of 1979.
12.
Within this context the words have different meanings.
Com-bined refers to airborne coal dust and radionuclides combining to cause the radionuclides to fall in a smaller radius at higher concentrations.
13 It is our opinion that very little research has been done on coal-nuclear synergisms and their effects and the burden of proof lies with the promoters and owners of the nuclear machines.
14.
Same as 13
- 16..At the time contention 19 was written two years ago intervenors were aware that several significant retrofits had been performed in the recent history of LACBNR.
Given LAC 3WR's design and operational diffi-culties, the intervenors assumed the Systematic Evaluation Program would necessitate further retrofits.
mak'e ' 5ed ral ' retrofits.
Since that time DPC has been ordered to v
The most significant retrofits thus ordered by the NRC include-liquefactio:
corrections and TMI-2 retrofits as ordered by NUREG 0578.
- 18. -
At the time that contention 19 was written.LACBWR was suffering long down time and poor operating capacity, due mainly to fuel failure.
In the past two years LACBWR'S capacity factor has remained very low.
There have been several indicators that changes required by NUREG 0578 Category 3 will require long down time to implement.
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Low megawatt hours of cumulative output refers to the low outuut
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19 (in K'.1/ hrs) produced by LACEWR as compared to its potential.'
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20.
CREC contends that spent fuel storage costs would show up as benefits in the C/B ratio' once any investments are made.
21.
Contrary to NRC staff assumptions, as stated in the Final EIS, CREC believes that LACBWR fuel and maintenance costs will rise faster than non-nuclear replacement power, especially if that replacement were conservation.
22.
Any decommissioning has a negative effect on the cost benefit
- ratio, and no specificity is required.
However, it should be noted that decommissioning is a cost that is essentially non-productive and thus taxes consumers without any benefit. Recent plans made by DPC to phase out LAC 3'iiR by 1990 only makes it more likely that future consumers will find reflected in their rates costs associated with a non-productive facility.
24.
Yes.
Power plants do not ordinarily have rate structures.
25 Intervenors presently do not possess any economic models that would allow us to hazard a guess as to how much demand would be decreased.
However, the basis for our belief is the law of economics which states that the more one pays for a commodity or service, the less one wents o'f such a service or commodity. That this law holds true can be seen only too clearly in the decreasing rate of growth of electrical consumption in the past several years.
26.
DPC still has an advertising budget and a rate structure that discriminates against small users of electricity.
The monthly REC news-l'etter chastises conservationists and environmentalists while promoting the " live better electrically" motto.
Note:
It should be assumed that any questions that remain unanswered may be supplemented in the future, but at this time are unanswerable.
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Anne K. Morse and George R. Nygaard for the Coulee Region Energy Coalition O
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BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
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DAIRYLAND POWER COOPERATIVE
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Docket No. 50-409 (La Crosse Boiling Water Reactor)
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(FTGL License Amendment CERTIFICATE OF SERVICE I.hereby certify that copies of"INTERVENORS RESPONSE TO STAFF INTER-ROGATORIES" have been served by U.S. mail, first class, this 25th day of April, 1980.
Charles Bechhoefer, Chrm.
Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, D. C. 20555 Dr. George C. Anderson Department of Oceanography University of Washington Seattle, Washington 98195 Ralph Decker Route 4, Box 190D Cambridge, Maryland 21613
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Offic-of Executive Legal Director 4,
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U.S. :4uclear Regulatory Commission 2
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APR 2 9680
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0.5. Hiestand,
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office of the Secnery Morgan, Lewis & Bockius pcting ss W 1800 M Street, N. W.
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Washington, D. C. 20036
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Docketing & Service Section
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Office of the Secretary U.S. Nuclear Regulatory 20555 i
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