ML20010F729
| ML20010F729 | |
| Person / Time | |
|---|---|
| Site: | La Crosse File:Dairyland Power Cooperative icon.png |
| Issue date: | 09/09/1981 |
| From: | Woodhead C NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| To: | Atomic Safety and Licensing Board Panel |
| Shared Package | |
| ML20010F722 | List: |
| References | |
| ISSUANCES-FTOL, NUDOCS 8109110248 | |
| Download: ML20010F729 (2) | |
Text
09/09/81 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
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DAIRYLAND POWER COOPERATIVE Docket No. 50-409 (La Crosse Boiling Water Reactor)
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STATEMENT OF MATERIAL FACTS AS TO WHICH THERE IS N0 GEN IIh2 ISSUE TO BE HEARD As required by 10 CFR 9 2.749, the Staff submits this statement of mate-rial facts which the Staff contends have no underlying issues which require litigation.
1.
The off-gas emissions from LACBWR comply with 10 CFR Part 50, Appendix I, aad Part 20.
(Contentions 2Aand28) 2.
LACBWR off-gas emissions are not inimical to the health and safety of the public or plant employees.
(Contentions 2A and 28) 3.
The methodology of testing, and the size, distribution and frequency of the samplee for the radiological environmental monitorir.g program l
at LACBWR is adequate to comply with 10 CFR Parts 20 and 50 and the Staff Branch Technical Position 4.8, Rev. 1.
(Contention 8) 4.
There is no scientific basis to support a theory that the combined effluents from LACBWR and Genoa 3 are inimical to the public because of synergistic health effects.
(Contention 9) 8109110248 810909 PDR ADOCK 05000409 1
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l l 5.
The environmental costs of operating LACBWR in minimal and do not outweigh the demonstrated benefit of the power produced.
(Con-tention 19) l 6.
Energy conservation cannot eliminate the need for LACBWR.
(Con-tention22)
Respectfully submitted,
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f-t/ \\j' Conieen P. Woodhead Counsel for NRC Staff Dated at Bethesda, Maryland this 9th day of September, 1981
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