ML20010F735
| ML20010F735 | |
| Person / Time | |
|---|---|
| Site: | La Crosse File:Dairyland Power Cooperative icon.png |
| Issue date: | 08/21/1981 |
| From: | Caruso R Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20010F722 | List: |
| References | |
| ISSUANCES-FTOL, NUDOCS 8109110257 | |
| Download: ML20010F735 (5) | |
Text
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l UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC FAFETY AND LICENSING BOARD In the Matter of
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DAIRYLAND POL'ER COOPERATIVE
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Docket No. 50-409
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(FTOL Proceeding)
(La Crosse Boiling Water Reactor)
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AFFIDAVIT OF RALPH CARUSO I, Ralph Caruso, NRC Staff project manager for the La Crosse Boiling Water Reactor (LACBWR), do hereby swear and attest under oath to the truth of the following Staff responses to the Intervenor CREC requests for admissions.
1.
As response to Intervenot 's request for admission that off-gas emissions from LACBWR are inimical to Coulee Region regardless of compliance with 10 CFR Part 50, Appendix I, the Staff denies the truth of the assertion.
2.
The Staff denies the assertion that off-gas emissions from LACBWR are inimical to the health and safety of the coulee Region, no matter how minimal, in response to request number two.
3.
The Staff denies the truth of request number three which states that doses to workers from LACEL'D off-gas emissions are inimical to them and their off-spring regardless of compliance with 10 CFR Part 20 limits.
4.
The Staff denies that the LACBWR monitoring program is inadequate. The Staff asserts that the hypothetical raised by request number four stating that a monitoring program would be unnecessary "if LACBWR had zero releases" is irrelevant.
i 8109110257 810909 PDR ADOCK 05000409 G
PDR 5.
The Staff denies that scientific evidence exists to show greater harm from a synergism of coal and nuclear effluents than the separate effects in response to Intervenor request number five.
6.
In re'sponse to request number six, the Staff agrees with the Intervenor statement that the references in Contention 19 to LACBWR's small size, low operating efficiency, low megawatt hours of cumulative output, low unit capacity factor, substantial downtime, costs of spent fuel storage, and ccsts of fuel maintenance " refer to an economic drain on DPC's system" as characterized by the Intervenor.
The Staif asserts that the remainder of request number six which states that the above listed items of " economic drain" preclude DPC from putting the environment and safety as "the highest priority" and that DPC does not "want" to install a dewatering system or to comply with TMI-2 Category B requirements is irrelevant to this proceeding.
The Staff asserts also, in response to the second statement in request number six, that whether or not the plant is cost effective is irrelevant to this proceeding, l
7.
The Staff neither denies nor admits request number seven which states l
l that environmental costs of LACBWR are increased due to economic restraints caused by the " poor performance of LACBWR" since the Staff has no knowledge of the subject of this statement.
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8.
The Staff denics the truth of request number eight which states that DPC's total system rate structure, "as viewed from the rate payers point of view," is not flat.
9.
The S'taff denies that higher peak use rates in the DPC time-of-use program encourages only load shifting and not a decrease in total demand.
10.
The Staff asserts that request number ten is irrelevant since it alleges that DPC promotes production of large central station thermal plants with attendant increase in electrical consumption whereas this proceeding concerns only safety and environmental matters concerning LACBWR.
11.
The Staff asserts that request number eleven is irrelevant sinse the cost effectiveness of LACBWR is outside the scope of this proceeding.
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4 RalphCfuso' NRC Project Manager Division of Licensing Office of Nuclear Reactor Regulation Subscribed and sworn to before me thisJ,/ff day of August, 1981 T/Y Not6ry Pub /ic g
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My Commissica Expires:
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Dg UNITED STATES OF AMERICA C
F bdkl NUCLEAR REGULATORY COMMISSION e
s Ei' 101981 *~ Y BEFORE THE ATOMIC SAFETY AND LICENSING BOARD ion 3
In the Matter of
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DAIRYLAND POWER COOPERATIVE
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Docket No. 50-409 op
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(FTOL Proceeding)
(La Crosse Boiling Water Reacto'-)
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CERTIFICATE OF SERVICE I hereby certify that copies of "NRC STAFF AMENDMENT TO ITS MOTION FOR
SUMMARY
DISPOSITION"; " STATEMENT OF MATERIAL FACTS AS TO WHICH THERE IS N0 GENUINE ISSUE TO BE HEARD" and "NRC STAFF ANSWER TO REQUEST FOR ADMISSIONS FILED BY COULEE REGION ENERGY C0ALITION" in the above-captioned proceeding have been served on the following by deposit in the United States mail, first class, or, as indi-cated by an a<.terisk, through deposit in the Nuclear Regulatory Commission's internal mail system, this 9th day of September,1981:
Charles Bechhoefer, Esq., Chairman *
- 0. S. Hiestand, Esq.
Administrative Judge Kevin Gallen, Esq.
Atomic Safety and Licensing Board Morgan, Lewis & Bockius U.S. Nuclear Regulatory Commission 1800 M Street, N.W.
Washington, DC 20555 Washington, DC 20036 Dr. George C. Anderson Fritz Schubert, Esq.
Administrative Judge Staff Attorney Department of Oceanography Dairyland Power Cooperative University of Washington 2615 East Avenue, South Seattle, WA 98195 La Crosse, WI 54601 Mr. Ralph S. Decker Atomic Safety and Licensing Board Administrative Judge Panel
- Route 4, Box 190D U.S. Nuclear Regulatory Commission Cambridge, MD 21613 Washington, DC 20555 Mr. George R. Nygaard Atomic Safety and Licensing Appeal Mr. Mark Burmaster Panel (5)
Ms. Anne K. Morse U.S. Nuclear Regulatory Commission Coulee Region Energy Coalition Washington, DC 20555 P.O. Box 1583 La Crosse, WI 54601 Mr. Frank Linder General Manager Dairyland Power Ccoperative 2615 East Avenue, South La Crosse, WI 54601
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.. Docketing and Service Section*
Office of the Secretary U.S. Nuclear Regulatory Comission Washington, DC 20555 Senator Allen R. Carter, Chairman Joint Legislative Comittee on Energy P.O. Box 142 Suite 513 Senate Gressette Building Columbia, SC 29202
!ak NA4 Colleen P. Wo6dhead Counsel for NRC Staff k
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