ML19330B208
| ML19330B208 | |
| Person / Time | |
|---|---|
| Site: | La Crosse File:Dairyland Power Cooperative icon.png |
| Issue date: | 07/17/1980 |
| From: | Morse A, Nygaard G AFFILIATION NOT ASSIGNED |
| To: | NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| References | |
| ISSUANCES-FTOL, NUDOCS 8007310101 | |
| Download: ML19330B208 (19) | |
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UNITgD OTATES OF AMERICA DOC 8EE i
USNRC Sh NUCLEAR REGULATCRY C0t.*. MIS 3 ION 4:
JUL 2 3500
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Office of the 4 c)
% ting & Servic*
EEFORE THE ATO*iTO SAFETY AND LTORN3ING BOARD Sratich 8
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1 In the Matter of
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Docket No. 50 '409 DAIRYLAND POWER COOPERATIVE
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Full-term' Operating License (La Crosse Boiling Water Reactor) )
TNPERVENORS' 31TPPI,T.*RNTAL RE3PONSE TO STATP INTERROGA?ORTE9 1
1.
Intervenors intend to present the following individuals as witnesses in support of their contentions A.
- a. Ernest Stern $ lass
- c. Russell Bentley
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manager of Windfree, Oregon, WI, sales and installation of wind machines
- d. Tom Galazen writer, Turtle Lake,.WI
- o. Jeffrey Littlejohn field researcher, Another Mother Fund study Stevens Point,'fI
?.
The desired information will be provided in the notes to these answers.
C.
Intervenors have made no such independent calculations.
and can no t speak to those that' may be used by others.
2.
To answer this question intervenors must refer back to the Final Environnental Statement which assures us, as members of the public, that LAC 32R is and will continue to comply with App.andix I, Part 50.
Also, we wera assured in the Dcart Environmental S tatenent tha t lac 3WR wau in compliance with App. I, thus complying with the AL M A ctandard which takes into consideration the site technical cpecifica% ions.
Yet some undeniable violations of ALA7A have occurred in the intervening years that hava not been addressed.
In this annwer we nake reference to an accident that occurred at i,4C3 IR du. ing Cycle 4, and was made public in an ACR3 hearing of Jan.
l 800 7310 \\ C) \\
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0 1978, not more than 3-4 months prior to intervenors' original petition in this FTOL proceeding.
Tne accident to which we refer is perhaps the best example of our.understaading of the ineffectiveness of App. I restrictions, and how we reached the conclusion that App. I can and no doubt is often violated by LACBWR.
It is intervenors' understanding that ALARA can by no means be correlated to an operating condition that could ever be termed " safe" in an absolute sense, but rather relates to the capability of each reactor on an individual basis, as outlined in their tech. specs.
A nd during Cycle 4, in the year 1978, LACBWR was operating under ar, administrative limit, or what they construed.to be a tech. spec. of 1,000 curies per day, which effectively meant both stack raleases and off-gas.
This exceedingly high limit was set in 1973 after Cycle 2, when LACBWR staff committed never to exceed what at that time was felt to be an acceptable fuel condition.
The 1,000 curies per day was established not as a protection for the public, but as an indicator of fuel condition.1 And quite rightly so, for if the NRC had been primarily concerned with the safety of the pu'olic, this un'oelievable level of radioactive releases would never have been tolerated, and the plant would have been shut down immediately.
In the opinion of the intervenors, the operation of LACBWR with such levels of off-gas is a clear violation of the ALARA guidelines, which require that radiation. exposures be kept "as low as reasonably achievable".
Yet is is clear that LACBWR personnel knowihcly used' less ecuinment than they were canable of usine at that time.
Dairyland j
had had a hold-up system on-site for years that they had been bypassing which when hooked up for Cycle 5 reduced the curies out the stack.by anywhere from a factor'of 5 to 16.2 The cost of effectively utilizing the. gas storage' tanks supplied; with the original system was negligible in comparison to the great i
reduction in releases to'the public, and'as such constituted non-compliance with the ALARA. principles' outlined in App. I of Part 50.
Intervenors' assertion that App..I was violated by this accident
,is corroborated by those within.the Nuclear Regulatory _ Commission as 3
well.
According-to Mr. Lake Barrett,, Division of Operating Reactors, "when all is said and done, 'it is corre~ t that
- t. hat Appendix I might c
c j '. be more limiting.than the 1,000 curie per day administrative limit".3
.Moreover, responsible individuals within Dairyland were unaware of -
./t
- these critical considerations of Appendix I.4 DPC was thus able to operate LACBWR in clear violation of ALARA
+ ' :for manyhmonths, yet no mention was ever made ofcthis fact in the FES.
s.,t; The. dangerous and reckless.act of poor judgement on the part of LACBWR d
Jpersonnel to complete Cycle 4 before shutting down for an analysis of
../,7;^l.the problem was of no major concern to,the.LACBNR safety review com-T-
i, mittee.
Operation was. continued on'the justification that they had.
7 7.1
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sk$, never had gross fuel failure before, and certainly.did not expect it
.then.5
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And in this instance, what has'been' termed the worst accident in-CQ.'
lthe history of BWR's was allowed to' continue at our local reactor for
- r. M 6 months 1on'end, because ALARA,.as a regulatory guideline, has.no. teeth...
%Y M onsthis basis it becomes logical forimembers of.the public to conclude d9 'd =that1ALARA and concomitant tech. specs. really provide no. assurance,.of 3D l' }the' safe' operation of LACBWR, and thus = are totally inadequate ~as. -
'P EJprotective or safeguard measures for'the public.
All parties concerned-Nh4'Vadmit.thattheyhavenoideaastothecalculationexposureofthe 4,
3n W
r i
nearest inhabitant to the plant with an off-gas and stack release rate of 1,000 curies per day.
Dose calculations depend on the meteorological assumptions used, and neither the industry nor the NRC had yet ddfined those models or assumptions.
According to Mr. Barrett, however, estimates have ranged anywhere from neveral millirads to 100 millirads, dependina upon meteorological conditions.
And,10 millirads for a gamma air'. dose would". correspond".to 5 milliremsJwhole body.' A figuresof.10 millirads per year is close to the Appendix.I limitations. tThe' actual relsases may wellehave,been some ten times the: Appendix I guidelines.6 The shock, anger and dismay of local residents with regards to this accident are feelings not easily fcrgotten or assuaged.
Actions on the part of both LACBJR personnel and the NRC such as we have out-lined here leave little if any room for trust on the part of the public for this industry and the agency that regulates it.
For these reasons trite assertions in both the DES and the FES that LACBNR is in compliance with Appendix I, with no reference to said violation, will no longer suffice.
If ALARA guidelines have proven ineffective in the past, why should we believe that such operating guidelines will be any more effective today or tomorrow.
The burden of proof lies heavily with the NRC.
3 Intervenors ascribe to the linear theory of radiation effects, and contend that any increase in exposure results in increases in physical damage to the human body.
Since any dose to individuals is harmful, then calculated doses are unnecessary to prove harm to humans.
In support of our contention we submit citations 7-25, all of which are critical studies relating both to doce calculations to workers and the public and the health effects of low-level radiation, certain levels of which are deemed acceptable under current NRC regulations.
CREC believes that the dose calculations used by the NRC staff do not accurately reflect real doses received by the public from off-gas emissions.
For example, in the FES off-site doses are calculated assuming a flat terrain.
In light of this and the fact that the terrain surrounding LACSUR is anything but flat, the dose calculations for the general public are necessarily hopelessly inaccurate.
Intervenors also contest the accuracy of off-site calculations on the grounds that doce calculations represent a 50 yr, dose commitment which would be received by the population during only one year of exposure.
Uc realize only too well that those living around LACBWR do not stay in the area for one year's dose and then leave.
I.iany spend their entire life near the plant.
Therefore, any calculations that do not consider doses over years are completely misleading and inaccurate.
If dose commitments were correctly calculated over the many years of exposure, it is clear that such commitments would far exceed limitations set forth in 10 CFR Part 50, Appendix I.
Intervenors assert that at-the present time LACBWR is in violation of restrictions set forth in 10 CFR Part 20 with regards to exposures to the public because estimations of the radiological doses to repre-aentative individuals in the currounding area are not in the"FES, and most especially doce calculations for those in the worst receptor area,of the plume, those receiving maximum exposure.
3ee again reference 10 and 11 for a reasonable discussion of this issue.
Moreover, an asnortion that L?CBWR in in compliance with 10 CFR e
k
- 4..
Part 20 becomes quite unacceptable when one considers that population dose commitments are calculated without extending to several half-lives or 100 years beyond the period of release, and that there is no attempt made to consider either quantitatively or generi6 ally 5the world-wide impacts.
Clearly, the total environmental impact is not being fully considered.
Since the NRC ntaff itself admits that they can not possibly make such calculations, and knows of no one who could do so,26 to insist that such doses are within established limits is misleading and simply inaccurate.
It is the position of the intervenors that residents in the area surrounding LACBNR are receivin6 doses in excess of the 25 mrems whole bot allowed members of the general public, according to 40 CFR Part 190, the EPA's Environmental Radiation Protection Standards for Nuclear Power Operations, as the result of exposures to planned discharges of radioactive materials to the general environment from uranium fuel cycle operations and radiation from these operations.
Intervenors have no dose calculations for worst case public exposures as such.
However, this is in part due to the absence of both NRC and DPC calculations in this respect.
Intervenors have engaged the services of Dr. Ernest Sternglass in an attempt to make these calculations.
He will provide further testimony on tha issue
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of radiation exposure and'its effect upon humans.
4.
The number of individuals affected by LACBWR's emissions and the degree to which they are affected varies, primarily according to meteorological conditions and releases.
In that this area is both a tourist and dairy area, the numbers of individuals affected may be impossible to estimate.
Guffice it to say, we believe that far larger numbers of people are affected than those to which the NRC cares to admit.
With the assistance of our witness, Dr. Sternglass, at such time as an evidentiary hearing stage is reached, we intend to further and more fully address the issue.
At this time we are still in the process of gathering information, o
5 In that LACBUR is located in an agricultural area along a major river, this question may also be impossible to answer.
We do feel that the dose calculations arrived at by the NRC staff are unacceptably small, and the Heidelberg report will suuuort this position. Dr. Sternglass will testify on this report ^ds well.
6.
In answering this question intervenors should point out that their understanding of employee dose commitment includes any exposure occurring as a result of the off-gas system, including maintenance (routine and non-routine),
The basis for this assumption is that off-gas releases find pathways to humans through stack releases, filter and resin bed changes and other maintenance procedures.
- Again, we assert that the worker exposure calculations are insufficiently
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precise and that the effects of such exposures are far more harmful than the NRC at this point will acknowledge.
It is with a great deal of confusion and concern that CREC addresses the entire issue of worker exposure.
What exactly are the exposure limits which the NRC considers acceptable for nuclear e
' workers?
On the one hand Robert Minogue, NRC Director of Standards Development and Karl Goller, then NRC Director of Siting, Health and Safeguards have been quoted as stating that " workers must be informed that no radiation is good radiation, unere is no threshold dose, and workers must be told the truth.
Specialized workers will have to determine their individual choice."27 And on the other hand the Northeast Utilities booklet which is distributed to their workers staten that "ng danger exists as long as workers are not exposed above URC limits".20 At this point we must ask, how are nuclear workers able to make any accurate evaluation of occupational risks and." deter 61ne'thei'r individual choices" on the basis of patent lies of thic cort?
That the NRC is no better in tarms of honesty and consistency is established clearly in the Draft Regulatory Guide and Value/ Impact Statement of May 1900.
On thelissue of risk from Occupational Radiation Exposure this official document states that " genetic effects have not been observed in any of the studies of exposed humans".29 Not only does such an assertion absolutely negate previous' statements by Minogue and Goller, but it shows that what the NRC says and does are two entirely different realities.
To add further to this confusion, as though the foregoing facts were not sufficient to bring' doubt to the minda of the many, it has only rec ntly become a matter of public record that the NRC, while publicly maintairing again and again that the maximum permiccible dose for nuclear workers in 3 renc/ quarter, for a maximum of 12 renc/
year,actuallyalloujrworkerstolegallyreceiveanextra5 rems a year internal dose o.
Thus, a nuclear worker's maximum -permissible occupational exposure is really 12 rems a year, far in excess of the claims of the NRC in all official correspondence we have encountered in our readingc of 12 rems a. year.
Only in' March of thiS year did William 1Dircka, Acting Executive Dire'ctor for,0perations finally i
stipulate that present 10 CFR Part 20 does not preclude combined internal and external doses to workers, thereby conceding that workers could legally receive a maximum of 17 rems /yr.31
)
Are we to assume that this disparity was due to a simple over-
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aight on the part of the NRC, or was it a deliberate attempt to keep from the public factc which when generally understood, will lead'us to the inevitable concluci6n that the risks associated with nuclear nower
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are far too great for the benefits it provides for both individua13 and and the population as a whole.
The NRC's permissable occupational exposure limit is some 630 times the 25 millirems whole body allowed the general public under EPA regulations, as set forth in 40 CFR 190.
i One might understandably inquire then as to how regulators can maintain that nuclear poaer exposes the public to only a minute level of radiation compared to natural radiation, with the knowledge of the 17 ren/yr. calculation.
This apparent contradiction is resolved by the determination that " personnel"' are not lenally considered part of the public.
By definition, "any person inside plantisnolongeramemberofthepopulation".ggeboundaryofthe This preposterous legal determination is both convenient and absolutely essential to the continued existence of the domestic nuclear power industry.
711th the aforementioned facts in:sihd, which exposure limits for workers does the NRC intend to use in the FTOL proceedings?
As one can imagine, the answer makes a great deal of difference to those of un concerned with npecific limits rather than nebulous and subjective e
.G.
references to ALARA and estimations of doses to workers rather than i
roul doses, as provided by the IMG staff in its FEU.
Interestingly enough, nowhere in the'FE3 were we able to find a precise elaboration of what maximum permissiblo occupational exposures ucro.
Readers are only provided with references to to virtually indecipherable tables in Vol. 10 of the Code of Federal Regulations.
One comes to the conclusion that there is a genuine desire on the part of the regulators and the regulated to keep these facts as far from the public under-standing as possible.
NRC staff has simply " determined" that plant exposures will be ALARA, without providing what we consider a sufficient discussion of assumptions and requirements for compliance.
No doubt this avoidance is necessitated by the fact that there are no real and spqcific requirements for compliance.
However, if ALARA is to have i
any meaning to those most affected by the operation of LAC 3WR, then a public discussion of ALARA, its assumptions and the requireaants for compliance is not only, absolutely e'ssential, but merely fair to those wlu) care enough to inquire.
With specific regard to worker exposure, and the industry's ability to monitor such exposures, intervenors submit HUREG-CR-130433 as documentation that present personnel dosimetry processors are not performing with an acceptable degree of consistency and accuracy.
Thus it is indeed probable that off-gas levels at LAC 3UR result in higher doses to plant employees than those allowed by 10 CFR Part 20.
Investigators in this study on the performance of personnel dosimetry services found that the TLD's used throughout the industry to had a 775 failure rate in the first round of testing, and a 65% failure i
rate in the second round.
In our estimation assertions that TLD's i
j are sufficiently effective then in establishing worker exposures are 1
completely unfounded.
Additionally, Roger J. Mattson, former Director of NRC Division of Siting, Health & Safeguards testified before the EPA to the fact that "thero is no way to accurately determine actual doses to real people.
Current monitoring devices and procedures are so approximate l
withpreciselysetradiationreleaselimits".gganceornon-compliance that it would be impossible to determine comp I
While referring here exposures and the public, he could.as easily have been referring to worker exposure, for the conclusions of the above-cited Michigan study on personnel dosimeters states that that the dosim6ters are not performing with an acceptable degree of consistency and accuracy.
In.an article entitled Nuclear Workers & Ionizing Radiation Dr.
Rosalie Berte11 points out that so few studies have been undertaken on radiation workers as to nake the claim that there is no danger as longasworkersarengjexposedtoradiationlevelsaboveURClimits" completely unfounded Other factors which cause us to disputo the contention that worker exposure levels are being adequately monitored, so as to make compliance with 10 CFR Part 20 even possible includel a) 10 CFR 20.202 p. 190, which states that the licensee is required to have a wor"cr wear his monitoring equipment only in relatively high radiation areas.
b)
Film badges and other monitors are basically penetrated only by gamma radiation, and therfore-are not measurinc beta or alpha radiation.
c)
Radiation which does not actually hit the film badge is not registered - e.g. radiation which penetrates one's back As for LAC 3UR _ specifically, there is no standard location for e
~7-wearing of the dosimeter.
d)
Neutron radiation is not being routinely measured.
On the matter of neutron exposure at commercial power reactors, Glen Zimmer, occupational Health Standards Branch, Director, Office of Standards Development stat that workers are receiving neutron exposuresheretoforeunknown.gg~In'anothermemo'on'thesamesubject Zimmer states that " worker exposures are larger than those that are currently being calculated due to inadequacies on neutron measurement techniques, and insufficient knowledge of the field.'. Neutron exposure can not be measured by NTA film, and may well be significant to the total exposure of workers."3/
A further reference on the issue of inadequate employee monitoring techniques is a memo from E. G. Case, Director of Office of Nuclear Reactor Regulation.
This memo presents findings of a study on the effectiveness of neutron dosimeters which concluded that since NTA filmisnotsensitivetoneutronsbggowabout.7MEV,doseequivalents can thus be grossly undersensitive.
A final study relevant to the issue of worker exposures shows a rapid and inevitable rate at which exposures increase as plants age.
This article from Nuclear Engineering presents evidence that would seem to' contradict staff assertions that applicant's commitment to design features and operating practices can and will ensure that occupational radiation doses can and will be maintained within the limi;s of 10 CFR Part 20 and that plant dones will be in compliance with ALARA.39 Clearly, on the basis of all of the above-mentioned information it is impossible for the staff to state with any acceptable degree of assurance to the public and to the workers themselves that plant employee exposures comply with restrictions set forth in 10 CFP. 20.
And indeed, the burden of proof is on the staff to prove compliance.
7, 8 & 9 In support of contention 8 we have relied entirely on the Another Mother Fund for Peace study, How Radioactive is Your Milk?_ 'cle include.
. excerpts from the study at this time in the
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belief that such informatio0 may be helpful in addressing questions regarding this contention.4 It is intervenor's understanding that focmalin is used. in DFC's monitoring procedures which have the effect af masking iodine levels and thus invalidating. milk samples in whi it is used.
Also, while DPC may or may not have tammitted to a change in its monitoring program, until auch time as the new program is in effect, deficiencies of the program as it exists at present must be discussed and analyzed.
Intervonors intend to have Jeffrey Littlejohn, researcher'for this study, testify at an evidentiary hearing on this monitoring study.
10.
Intervenors do not possess the needed expertise to properly explain the mechanisms for fly ash, ra:lionuclide synergism.
- However,
-our radiation expert, Dr. Sternslass believes very strongly that adequate evidence exists to support this contention.
Dr. Sternglass v'111 address this issue at such time as he is allowed to do so.
11.
Intervenors cubmit the following citations which, if O
w
C invoatigated, will provide staff and applicant with furthur information 41 k1 some of the individuals who have investigated this potentiality.
fro
&3, 12.
Answered in first response.
13
'Same 14 See above-cited studies.
15 Copy of Post article was provided at June prehearing conference 16.
Intervenors maintain that costly retrofits at LAC 3WR will be necessary based on NUREG-oS78.
31nce intervonors last filing it has become more apparent that DPC may have some difficulty complying with many of the Category (B requirements.in complying with 2.1 3.b 1), 2.1.4.b, 2.1 5.
DPC has expressed difficulty these requirements.
If Dairyland is not able to avoid compliance with all of these recommendations, then certain very costly (in both human and economic terms) retrofits will be necessary.4b LACBUR's Pland Superintendent Dick Ghimshack was quoted in Lte La Crosse Tribune as saying that these retrofits could price LACBWR out of business.45DPC has since said they plan to close LACBWR by 1990 in a possible attempt to avoid TMI-2 retrofit costs.
Intervenors sttempted to obtain first hand knowledge of this by attending a meeting in Washington, D.C. last January.
However, DPC cancelled said meeting.
Intervenous were not notified of subsequent meetinco.
Intervenors have also contended since the August 1978'prehearing that the SEP program would cause costly retrofits to be required at LAC 3WR.
Since that time an Order to Show Cause has been issued.as a result of the determination by the Office of NRR that LAC 3WR's continued operation was dangerous due to a potential for liquefaction.46 At the time of this writing it is intervenor's belief that a dewatering system is planned as a colution to the liquefaction problem.
3 However, the SEP is by no means completed.
CREC contends that other categories covered will ultimately require the need for more retrofits.
Another-issue that is at the recommendation stage is that of fire safety.
It appears certain that LA;1.!R must undergo more substantial retrofits in relation to the fire safety issue.47 Finally intervenors believe that no issue of fact exists relative to costly LACBWR retrofits.
LAC 3MR has experienced numerous retrofits in the past, is under to:do more at present, and in all likelihood will be required to do more major retrofits in the future.
As in the past l
they will be costly in the areas of both economics and worker exposures.4'.
17 See documents cited in answer to question 16.
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18.
CRSC's position is that two major reasons for anticipating future extended downtime exists a)
Previous operating history demonstrated that this plant is very susceptible to major problems that have required major and lengthy maintenance.; LACBUR will more than likely experience even more lengthy downtime in the future due to the plant's age and poor parts availability.
b) an increase in retrofit downtime as the NRC's tradition of 1
industry accomodation gives way.to a more stringent regulation policy.
One example of this regulatory trend that may soon be upon us is expressed in the TMI-2 Lessons Learned Task 4
Force Final Report.
Under this example, a proposed backfit would not need to provide substantial additional protection (as currently. inferred): anything required for safety would be sufficient.
Similarly, a decision to backfit would naturally precipitate the need to backfit hllanu' lear '
e plants, since it was required for safety, without agonizingovergalueimpactstudiesorcase-by-case determinations. 9 4
19.
Explained in previous question.
p 20.
CREC felt strongly that the $800,000 to $1,000,000 fuel nool reracking retrafit should not have been undertaken without the b'enefit of a FTOL and an evidentiary hearing on the cost / benefit.
Although the ASLB did order a cast / benefit hearing last fall the scope was limited by the time frame that was considered.
In essence, the ratepayers of DPC's service area were forced to accept another huge retrofit expense merely on the grounds that operating LACBUR was more beneficial than a two year cold shutdown.
The question is now moot.
21.
Intervenors still maintain that NRC staff is in error in the FES assumptions.
Uranium is probably the most critically scarce fuel resource when compared with tha cost of other fuels.
As uranium becomes more scarce the price will rice accordingly, a fact that URC staff has obviously chosen to ignore.
In fact, prices quin-tupled from 1973 - 1978 according to the Ryan Report on Nuclear Power Costs.50 That same report cited studies that proved conservation and solar i
energy much more cost effective than nuclear energy.
One study by Guffolk County, NY found that solar enerty and conservation would produce three times more energy than nuclear por dollar spent.51 The staff's FEG did not address conservation or solar energy as alternatives to LAC 3WR. Both alternatives will consume no fuel and require little maintenance once implementad, and thus are not nearly as affected by economic conditions.
Consideration of these two alternatives to LAC 3Ua would radically affect any hanest cost /'oenefit analysis of LAC 3WR, In conclusion, intervonors feel that fuel and maintenance costs e
r
should be listed on a yearly basis to support staff's fuel cost assumptions.
It is unclear to CREC whether or not the NRC is still using a spent fuel credit in their fuel cos t formula.52 CREC feels i
that these statistics would factually demonstrate the errors in staff's fuel and 0 & M assumptions in Table 8-1 of the FE3.
LACBWR's unique fuel and plant design indicate higher than average fuel and maintenance costs.
For example, LACBWR's fuel requires a higher enrichment.
22 As indicated in CREC's first submittal intervenors had no particular method of decommissioning in mind with reference to Conten-tion 19.
He believe that there is a lack of relevant information and experience with which to predict costs of any method of decommis-sioning.
However, there are certain facts that CREC believes must be taken into account that may have a negative,effect on LAC 3WR's cost / benefit balance.
a)
Dismantlement within 7 years of shutdown may be preferable from a purely economic standpoint.
b)
Storage or entombment nay become a more preferable option as decommissioning costs rise, and from a radiation exposure standpoint.
c)
The longer LACBWR operates the greater the exposures to employees involved in any phase or method of decommissioning.
d) 2/3 of the core will be lost no matter when DPC closes LAC 3UR.
Assuming that LACBUR would operate in the black for the remainder of its lifetime (which is very unlikely, especially with of cost of 40 mils /kw for 1979)$4and funds were paid into a decommissioning escrow fund, then the longer LAC 3WR operated the less the negative economic impacts would be.
However, the environmental impacts of decommissioning would then be greater because of increased radiation levels due to factors such as crud buildup, further equipment contamination, and l
operator accidents.
23 Intervenor's contend that DFC could save the equivalent energy generated by LACSNR byengaging in a rigorous program of energy conservation and alternative decentralized renewable sources of energy.
Ne base our allegation that the need for LAC 3WR can be eliminated on the following bases:
a)
Real electrical demand is and will grow ever smaller than DPC's current projections.
ilhile the entire issue of future electrical demand is a very complex matter insofar as projections are concerned, CREC has ample evidence to show that DPC's calculations in this area are greatly exaggerated, and a a consequence the need for LACBWR is nowhere near as great as DPC contends.
To date some of the best information available on this topic is found in the 1980 Visconsin Utilities Advance Plan.55 According to the EURG Forecas t compiled for the Wisc.
Public Gervice Commission for the years 1978 - 88 summer peak for the Nestern Utilities, including all of the DPC system, will vary on the high side from 3 5;; per year growth rate to 1.1 % on the low side, with with a base rate of 2.4%.
Winter peak will vary on the high side from 3.45 per year growth to 1.4% per year on the low side, with the base rate being 2 9j.
Insofar as annual energy requirements are concerned, for Western utilities the base rate is 2.0j.
e
Another important source of information in the area of electrical demand is testimony pres inted before the Nis. PSC in the same advance plan proceedings by the Wisc. Division of State Energy, Dept. of Admin-istration.56 In this testimony energy requirements for the agricul-tural sector of the state is forecasted at a constant demand of.1$
thru 1985 and a singular decline thereafter despite the increased level of agricultural output.
Specifically, demand is seen as declining larely due to increased efficiency in the use of electricity thre utilization of cost-effective efficiency improvements.
These improvements include the rapid market penetration of milk house hear exchangers and a gradual shift to naturally ventilated i
barns for animal quartering and milking, more efficient lighting i
and high efficiency motore, pumps and fans.
In general. Dept. of State'Enorgyofigdres show demand rates for West. Wisc during 1978-90 of 2.6 for both summer and winter peaks.
DPC's excessive demand projections are highly dependent on the assumption that new rural residential housing starts will continue at the rates experienced in recent years.
However, intervenors believe that rising gas prices and a genuine housing slump, precipitated by the ever more severe economic recession we are experiencing nationwide (see national economic figures and especially new housing starts),
will have a significant effect on demand figures, andrmust necessarily l
be taken into account if such calculations are to be at all accurate.
DPC's own projections for the years 1983 - 90 place demand figures at 4.6%, recently revised down from a rate of 5 7% of 2 yeare ago.57 The years 1983-1990 are used here because DPC will have an energy surplus through 1982 due to the coming on line of the John P.
Madgett facility.58 That this projection is clearly excessive can be realized for the reason that wind generation was not figured in at all, although interest in wind in this region is verv high and wind denerators are being installed despite tactics employed by DPC to discourage such a practice.
Additionally, while wood-burning was factored in to some small and traditional extent, DPC recently admitted that "it was not factored in to the extent that it is occurt'ing now".59 Moreover, for the year 1979 QPC experienced an actual reduction in demand on a system-wide basis!oO While DPC has attributed this decrease in demand to an abnormally mild winter, it reflects very poorly on their current demand projections.
As a final note, DPC is notorious for releasing different demand figures to different agencies and individuals at different times.
Por example, when attempting to sell the need for a new generating plant at Alma some two months ago, in an ad which is enclosed, DPC predicts an annual growth rate of 5 8% for the next 15 years.
This clearly contradicts figures DPC has used in other instances.
b)
DPC's program for conservation is singularly insufficient and unsupported, and will remain inef fective until DPC makes a genuine and extensivc commitment, both monetarily and psychologically to such a program.
When DPC addressed the issue of conservation, its primary sub-ctantive examples of commitment, include the load management program and home energy audits.
Yet according to a Wisc. Rural Electric Cogp Association weatherization survey of..isc. coops for-the year 19790 of which DPC coops comprise the vast majority, an average of only 11 e
L.
1
_ 1?
I home audits were made by staff members per system.
Also, only 34.6%
i either sold or installed weatherization materials.
During 1979 an average of only 41 members per system utilized the weatherization/
service programs, and projections for 1980 average on 100 per system.
Regarding the matter of weatherization loans, only 45 2% of the systems even offered such a program in 1979, with an average of 1.1 loans made to members per system.
And, it has been stated that the j
same systems expect to make an average of 2.8 loans in 1980.
The average amount of loans per system in 1979 was $770.00.
Clearly, it can be stated that there has not been even a minimal i
or passing commitment to a weatherization program in the DPC system in i
1979.- The depth of commitment is brought out all too clearly in DPC's 1980 General Manager's report, where mere lip service is paid to the concept.
Conservation is explained as primarily a concern for a reduction in foreign oil use, and its significance to DPC is disclaimed f
because DPC uses very little oil to generate electricity.62 DPC often points to the purchase of a truckload of water heatar insulators as evidence of their commitment to conservation, yet in reality there have been very few installed.
According to Larry Thorson of DPC, " sales of these insulators have been very slow and the people just don't seem to be tuned in, despite the fact that use has been encouraged in bill stuffers, etc."b3 Obviously, this fact would indicate to anyone that there is a great need for a more aggressive conservation program commitment if it is to be effective.
So far as the option of time-of -use rates are concerned, DPC hasalreadydeterminedthattheyareimpracticaland{'neffectiveas a method of conservation and have acted accordingly.0 Few are in use even when installed.
As supporting documentation for this contention regarding the inadequacy of DPC's conservation program, CREC submits testimony of Randy Freeman, member of DPC, before the House Agi'icul-ture Committee's Subcommittee on Conservation and Credit.o5As an ofDavidL.Ostendorfggmanwilltestifyog7,bothofRuralAmerica.
expert witness Mr. Fr his statement and those and David Raphael
'JIo also snclose copies of this testimony.
In direct contravention of testimony presented by Mr. Feld in Staff's Motion for Summary Disposition, intervenors insist that while their DPChasaflatrateggructureforwholesaleenergysales, member coops do not.
Intervenors contend that the member rate structure is a major determinant in electrical demand.
And, we believe DPC has both the right and responsibility to ensure that the distribution coops maintain a flat rate s tructure far their customers.
Moreover, intervenors contend that the existence o' ervice
~
charges preclude flat rate structures.
Cost of service principles
}
are not conservation principles, and as such are a disincentive.
'!hile. such charges may be common throughout the industry, the j
service charges of DPC's member coops are higher than standard l
practice.
TVA'n for example is 32.00 per month.
25 Intervenors will use both testimony already referred to 1
f and Randy Freeman as a witncss to make projections as to the amount that can be saved by alternatives not considered reasonable by both DPC and the NRC staff in their projections.
e e
_ 13 -
26.
Intervenors submit tha-DPC plans for meeting future energy demand are grossly inadequate and do, if fact, promote electrical use.
Dairyland is promoting the use of electricity by entry oover the next several years into a new market area; home space heating.
According to DPC's 1979 load management study the company intends to add 57,000 new residential users to the system by 1990.
Most of the usage is targeted for home space heating with plectricity in conjunction with the company's load management system.09 This entry into a new electrical market represents a policy decision which actively must promoto energy space heating with electricity in order to ensure its success.
AffiCavits can be sub-mitted by members of the Hawkweed Architectural Group, the company coordinating construction of passive solar-heated structures in the new' downtown S61dierss Grove, and by other solar heating experts which can substantiate the contention that insulated passive solan-haated commercial and residential buildings offer the most appropriate application for solar power in the region, and is viewed by these experts as the most cost effective application of direct solar energy in the continental United States.
That Dairyland, necessarily acting through their member coops, would promote intrusion into this marketplace, represents a decision to promote conservation in traditional " peak" areas of consumption, and to encourage consumption in " load manageable" areas 'of uso, altho the end product is a threefold increase in the total amount of energy consumed in the system by the year 2000.
" Utilization of gasseous fuels by' direct combustion... will decrease and that the percent of energy utilized in the form of electricity will increase."70
- Also, "Ne, in the system, are putting much effort into load management...
If you are planning to change your heating systems, we would like to discuss 'off peaking' heatine - whether it be a stored heat system or dual fuel heating units."71These documentn are admissable as it is these media that DPC has used to communi6 ate with its membership.
According to DPC General Manager Frank Linder "DPC encourages mostofthetime".ggdentialheatingsystemswhichuselectricity installation of re Clearly, this is promotion of electrical use by Dairyland.
See also " Lines Across the Land" for a discussion of the ramifications of the encouragement of electric heat installations on peak demand.73 Intervenors submit the enclosed ad from DPC's 1979 Annual Report and a recent ad relating to power consumption as ample evidence to support our charge of promotion of electricity.
In addition to th6so promotional ads DPC has utilized a method of reverse psychology to legitimize and encourage continued uncontrolled consumption.
DPC has characterized those who promote conservation as the best means for people to reduce their cost of electricity and thug reduce the need for new generating facilities as no-growth fanatics.t*
Yet this assessment of conservation is precisely the same as that outlined by the REA in a letter to all_ electric borrowers recently./2 One of the most notable observations that can be made about DPC is that their management is deeply entrenched in the past, and as such inhibits the development of alternative energy generation systen-wide, which if allowed to flourish would reduce electrical demand sufficienti"v to call into question the need for LACBWR.- While the REA is insisting
.that all forms of alternative energy sources be encourage 476 DPC has done its best to make such use of alternatives difficult, if not impossible,77-78 to the point where some families have Given up on the b
a
Idea completely.
Intervenors intend to have Russel Bentley of Windfree, a Wisc.
wind energy contractor testify to his experiences with DFC's attempts to inhibit wind generation growth.
As can be seen by DPC's General Manager's discussion of alternativen at the 1980 Annual meeting, DPC's commitment is only as deep as inves-tigating, studying, qqnitoring and more studying, with no commitment at all of resources.r7 At present, as a result of DPC's exclusionsry contract consumers putting in a wind machine cannot sell their excess electricity to their coop.
They must instead engage in a three party contract to sell the excess electricity to'Dairyland at a less than wholesale rate, altho it enters only their coop's lines.
Coop metering charges have dis-couraged contumors from m.aking this arrangement also.
The advent of PURPA may change all this by forcing consumer coops to purchase potential power from member consumers. Instead of DPC administrative interference consumers may benefit from low interest RZA loans and higher payback potential.
PURPA's effect would no doubt be a reduced load on the Dairyland system.
But for now this stifling "all requirements contract" is in effect and is a disincentive to the development of alternative energies.
DPC has the authority to modify this contract but will not do so.80 Perhaps the best example of DPC's entrenchment in the pact took place during the 1980 DPC Annual Meeting.
A resolution presented by Randy Freeman which requested that DPC " study" alternatives to cver-iacreasing investments in new generating facilities was met by the DPC board members with much hostility and i"re finitely tabled.
'le enclose copies of this resolution and Letters to the Editor from two coop members who are very unhappy with the conservative and even reactionary attitudes on the part of DPC management.
It must be clear by now that DPC is having difficulty entering the decade of.the
'80's.
Intervenors believe the following quotation from the 1980 leneral MTnager's address, a copy of which is enclosed far your information aad enjoyment, is characteristic of the threats of Armageddon commor.ly e aployed by DPC management to discourage the development of alterna^ives.
"7elying on technologies not yet adequately developed could lead to power shortages, rising unemployment and a dangerous downward economic spiral"81 No are not now asking that DPC become no dramatically r211 ant on alternative.
Rather, we request only that a genuinc commitment be made to the development of alternatives, with the knowledge that there is no utility system better-suited to the d velopment of alternative methods of energy production, be they hydro, solar, wind, biomass, wood heat or cons >rvation.
i j
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' 'i %,:,. -
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' j7f UNITED STATES OP A?.1 ERICA 7
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NUCLEAR REGULATORY C0iGIIGSION
,. 3
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BEFOR2 THE ATO?.1TC 3AFETY AND LICEN3ING BOARD b :#,.
1 i
'~
~u i
In the matter of
)
n' ' ~ ~
Dairyland Power Cooperative
)
Docket No. $0-409 i 9' (Lacrosse Boiling *.later Reactor) 1
~
i f
i AFFIDA'/ITS OF ANNE K. i.10RSE AND GEORGE NYGAARD i
e I have read the foregoing.te'stimony and swear that it is true and accurate to the best of my knowledge and belief, and would be willing to testify to,the information.
' A 4-c M
Anne K. Morse'
.DA&ie AMO,rd G[orge 4. Nygae/f Subscribed and sworn to before me this
'# ' day of July, 1980.
_j
,9
, < : 4. o...
j_..
Notary Public J'-
IJy Commission.h pires:
I 1
l I
NOTB -
ACRS Hearing Januar 143 Ibid., pp. 66 &i144.y 1978, p.
1.
2.
3 Ibid., p. 145 4
Ibid., p. 147 5
Ibid., p. 17 6.
Ibidl, pp. 143-45 7
Huver, Dixon, Jacobson & Dixon, MCTHODOLOGIES FOR THE STUDY OF LOW-LEVEL RADIATION IN THE MIDNEST (Land Educational Assuciates Foundation, Inc., 1979) LAND, 3368 Oak Ave. Stevens Pt. WI 8.
Dixan, Jacobson & Dixon, NUCLEAR WASTE:
THE TIME 30M3 IN OUR BONES Land Educational Associates Foundation, Inc., 1979. A summary of a portion of METHODOLOGIES 9
Ehlert, Haag, Rick, Horwich, Brooks, Zablocki, SIX CITIZEN COMPLAINT TO THE DEPARTMENT OF NATURAL RESOURCE 3 OF THE STATE OF WISC.,
April 27, 1979 10.
Franke, Kruger, Steinhilber-Schwab, van de Sand and Teufel, RADIATION EXPOSURE TO THE PUBLIC FROM RADI0 ACTIVE EMISSION 3 0F NUCLEAR POWER STATION 3*
11.
NRC translation 520:
RADI0 ECOLOGICAL A3SES3 MENT OF THE WHYL NUCLEAR POWER PLANT 12.
Hoffman, Shaeffer, Baes, Littla, Miller, et al., AN EVALUATION OF UNCERTAINTIES IN RADICE ~D' DICAL MODELS*
13 Mancuso, Stewart & Kneale,,
.fION EXP03URES OF HAUFORD WORKERS DYING FROM CANCER AIID OThda CAU3E3, Health Physics (Pergamon Press, 1977 Vol. 33) 14.
Knoale, Stewart & Mancuso, RE-ANALY3I3 0F DAIA RELATING TO THE HANPORD STUDY OF THE CANCER RI3KS OF RADIATION UORKERS.*
15 Gofman. THE QUESTION OF RADIATION CAUSATICH OF CANCER IN HANFORD NORKERS, Health Physics Vol. 37 (Perganon Press Ltd. 1979) 16.
Morgan, Karl Z., CANCER AND LOW-LEVEL ICHIZING RADIATICN*
17 Cohen, Bernard, UHAT IS THE MISUNDERSTANDINC ALL ABOUT, The
'sulletin, February 1979 18.
3ross, Irwin, HAZARDS TO PERSONS EXPOSED TO IONIZING RADIATION (AND TO THEIR CHILDREN) FROII DC3 AGES CURRENTLY PERMITTED BY l
THE NRC, presented on April 7,1978 to the IIRC at the GSA Auditorium, Vasil. D.C.
19 Bross, Ball, & Falen, A D03 AGE RESPONSE CUR 73 FOR THE ONE RAD RANGE:
ADULT RISK 3 FROM DIAGNOSTIC RADIATIOI!, AJPH, Feb.
1979, Vol. 69, No. 2.
20.
- Rotblat, J., THE RISKS FOR RADIATION NORKERJ, The 3ulletin, Sept.
1978.
21.
Itajarian, Thomas, THE CONTROVER3Y OVER THE HEALTH EFFECTS OF CADIATION, Technology Review, November, 1978.
22 Sternglass, Ernest, T33TIMONY OF DR. STERNGLA33 3EFORE THE
-MINNESOTA ENERGY AGENCY, Docket No. EA-80-001-AK*
23 Sternelacs Ernest, CAIICER M0hTALITY CHANGE 3 AROUND NUCLEAR FACILITIE3 IN CONNECTICUT, presented at a Congressional seminar on low-level radiation, Feb. 10, 1978.*
24 Sternglass, Ernest, INFANT MORTALITY CHAiiGEJ FOLLOUING THE THREE IIILE ISLAND ACCIDENT.
Presented at the 5th World Congress of Engineers and Architects, Jan. 25, 1980.
25 Najarian & Colton, MORTALITY FROM LEUKEMIA AND CANCER T: SHIPYARD l
liUCLEAR UORKERS, The Lancet, May 13, 1978.
e
I
. 26.
Telephone, Franz, EPA to V. T1 lafeew, NRC s ta ff, June 1980.
i Day, New London, Conn.
P. 7.
Lance & Trimel, RADTATION ROULETTE, T a
June 30, 1978.
28
- )rtheast Utilities Radiation Worker Training Manual, revised 1977 29 Draf t Regulatory Guido & Value/ Impact Statement, INSTRUCTION CONCERNING RISK FRC" OCCUPATI0ilAL RADIATION EXP03URE, Division 8, Task Office 902., May 1980.
30.
10 CFR Part 20 Appendix 3 Table 1.
31.
Federal Register Vol. 45, No. 56, March 20, 1980 p.
1802$
32.
Dixon, Gertrude, RADIATION EXPOSURE Ii! THE NUCLEAR POWER INDUSTRY, Presented to State of ';Iisc. Assembly Committee on Comnerce &
Consumer Affairs, I4 arch 8, 1976.
33 NUREG-CRL1304, PERFORMANCE TESTING OF PERSONNEL D03IMETRY 3ERVICES,
{
April 1980.
34.
Mattson, Roger J.
Testimony before the EPA, March 3, 1976.
35 Bertell, Dr. Rosalie, NUCLEAR WORKERS & IONIZING RADIATION, American Industrial Hvviene Association Journal, May, 1979 36.
Eimmer to Minogue, memo of 1-25-78. Director, c 'fice of Standards j
Development 37 Zimmer to Roger 3. Boyd, Director, Division of Project inanagers, Office of Reactor Regulation, memo of 1-25-78.
38.
Case, Dir. Of NRR to S. Levine, Dirc of Office of i telear Reactor l
Research, memo of 4-3-78.
Subject:
RR-NRR-78-3.
39 Ilartin, Alan, OCCUPATIONAL RADIATION EXP03URE III LUR'S INCREASING, Nuclear EncineerinF, Jan. 1977 40.
HOW RADI0 ACTIVE IS CUR MILK?
TRE URGENT NEED FOR SOUND I40NITORING AilD PUBLIC DISCLOSURE, Another I.iother Fund for Peace, 407 N.
I.iaple Drive, Beverly Hills, CA 90210.
Iday 1979 41.
COIi3INED EFFECT3 0F RADI0 ACTIVE, CHEMICAL & THERi,iAL RELEASE 3 TO THE EIIVIRONi:ENT, Prococdings of a Symposium, Stockholm, Sweden June 2-3, 1975 Jointly organized by the IAFA & HEA.
Can be purchased from:
UNIPU3, 345 Park Ave.
3.,
iiY, NY. 10010.
h2.
idost, Clark, RADIATION-CHEi1ICAL INTERACTIONS: A POT 3NTIAL HAZARD TO i.iODERN SOCIETY, Delta College, University Center,seich.
August 6, 1971.
43 PROCEEDINGS OF INHALATION EXPOSURE CARCIliOGEIE.i13 SYi4PC3IUM, AED Symposium J 18, Oct. 8-11, 1969, AEC Conf. 3 691001, Library of Congress J 76-60$835 Available from: National Technical I
Information Service, Dept. of Commerce, 3pringfield, 7A 22151
- 44.. LAC - 6833 45 La Crosse Tribune, Jan.1980.
46.
Denton, ORDER TO SHOW CAUSE, Feb 25, 1980.
47 LAINAS to DPC, June 16, 1980.
48.
i'UREG - 0594, p. 34 49.
NUREG - 0585, p. 4-3 50.
Ryan Report, NUCLEAR POWER COSTS, 23rd Report by the Committee on Government Operations, April 26, 1978.
51.
Ibid., p. 71.
53. DPC to Ballard, August 9, 1978, p.1.
52.
Smith, Konzek, & Kennedy, TECHNOLOGY, 3AGETY-4 C0:1T3 0F DICOI5nI:;-
SIONING A REFERSMCS-PRE 33URIZED 'ilATER REACTOR POWER STATION, HUREG-CR 0130, Vol.
1, June, 1973 54.
Telephone call,iiorse to Linder, July 16, 1930.
55 1980 Wisc. Utilities Advance Plan, utsc. Public 3ervice Commission, Docket J 05-EP-2.
Exhibit 3 199 & related testimony, Energy gystems Research Group, FUTURE LOA" GROWTH PROJECTIONS, Neil Jalbot.
e
.-56.
Ibid., Tectimony of Greg Krol n, Wisc. Division of State Enerdy, Dept. of Administration. Jan. 2, 1980.
57 SUPPLEIENTAL INFORMATION TO '2HE REVISED 1978 ADVANCE PLAN, Wisc.
Public Service Commission, Testimony of Dairyland Power.
58 Linder, Frank, REPORT OF THE GENERAL i.lANAGER BEFORE THE 39th ANNUAL MEETING OF MEMEBER OF D.P.C., June 18, 1980, p. 3 59 Tolophone call, Morse to Larry Thorson,6, 19do. of energy conser-manarer vation and load mana$ement Report of General Manager, p.
6.,
July 1 60.
61.
Wisconsin Rural Electric Coop Association ENERGY CONSERVATION _
WEATHERIZATION ACITIVITES, Jan.4, 1980.
62.
Report of General Manager, p. 6.
63 Telephone call, Morse to Thorson, July 16, 1980.
64 Report of General Manager, p. 6.
65 Testimony of Randy Freeman before the Subcommittee on Cons >rvation
& Credit, Agriculture Committec, U.S. House of Representatives, March 19, 1980.
66.
Statement of David Ostendorf.before Subcomuittee on Conservation &
Credit, Committee on Agriculture, U.S. House ' of Rep., 3-19-80 67 Statement of David Raphael, Executive Director, Rural. luorica, before the Subcommittee on Rural Development, Committee on Agriculture, Nutrition and Forestry, U.3. Senate, Nov. 30, 1979 68.
1979 vernon Electric Annual Report, rates from service.
69 Dairyland Power Cooperative LOAD MANAGEiS T STUDY, Oct. 1979 70.
Rural 111nnesota News, Vol. 32, No. 6. June 1J'/0, p.2.
71.
I,icht Conversation, Vol. 29, No. I, May 1980, MANAGE 23 REPORT.
72.
Report of General Manager, p. 5 73 Galazon, Thomas, AN ANALY3IS OF THE COAL AND NUCLEAR DEVELOPIENT POLICIE3 0F THE DAIRYLAND PO'.lER COOPERATI'!E AND THEIR IMPACT ON COOP STRUCTURE AND MEMBERSHIP PARTICIPATION, from Linee Across the Land, Environmental Policy Institute, Wash.
D.C.
1979, p. 6 74.
Ibid'., p. 656. 52-3 75 Feragen, Rcbert, Letter to all electric borrowers, aEA,.U.s. Dept.
of Agriculture, Jan., 31, 1980.
76.
Zoller, Joe S., Letter to all electric borrowers, REA, US. Dept.
of A riculture, August 21, 1979 d
77.
1980 visc. Utilities Advance Plan, Testimony of Russell sentley.
78.
UNCOOPERATIVE COOPS DISCOURACE WIND PROJECT 3, The 3rldne, Hager City, Wisc., March 1980.
79 Report of General Manager, pp. 6-7 1
80.
Galazen, Lines Across The Land, p. 667 81.
Report ofGeneral Manager, p.
13 I
e
.v :,-
4. 3. -
i
~
UNITED STATES OF AMERICA NUCLEAR REGULATORY C0rIMISSION BEFORE THE ATOMIC SAPETY AND LICENSIllG BOARD In the Matter of.
)
)
Docket No. 50-409 DAIRYLAND PO7IER COOPERATIVE
)
-)
(FTOL Proceeding)
(La Crosse Boiling Water Reactor) )
CERTIFICATE OF SERVICE I hereby certify that copies of "INTERVENORS' SUPPLEMENTAL RESPONSE TO STAFF INTERROGATORIES" in the above-captioned proceeding have been served on the following by deposit in the United States mail, first class, or, as indicated by an astorisk, handed over to be teletyped, this 17th day of. July, 1980.
Docketing and Service Section Office of the Secretary U.S. Nuclear Regulatory Commission Nashington, D.C. 20555 Colleen.'iloodhead, Esq.
Office of Executive Legal Director U.S. Nuclear Regulatory Commission
'ilashington, D.C.
20555 0.S. Hicstand, Esq.
- Kevin Gallen,-Esq.
i.iorgan, Lewis & Bockius 1800 H-Street, N.VI.
'ilashington, D.C.
20036
,,p.
+
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