ML20040E419
| ML20040E419 | |
| Person / Time | |
|---|---|
| Site: | La Crosse File:Dairyland Power Cooperative icon.png |
| Issue date: | 02/02/1982 |
| From: | Hiestand O DAIRYLAND POWER COOPERATIVE |
| To: | NRC COMMISSION (OCM) |
| Shared Package | |
| ML20040E414 | List: |
| References | |
| ISSUANCES-FTOL, NUDOCS 8202040312 | |
| Download: ML20040E419 (5) | |
Text
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o UNITED STATES OF AMERICA NUCLEAR REGULATORY CGiCISSION In the Matter of
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DAIRYLAND POWER COOPERATIVE
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Docket No. 50-409
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(FTOL Proceeding)
(La Crosse Boiling
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Water Reactor)
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STATEMENT OF MATERIAL FACTS AS TO WHICH THERE IS NO GENUINE ISSUE TO BE HEARD Pursuant to 10 C.F.R. 5 2.749(a), Dairyland Power Cooperative (Dairyland) submits the following Statement of Material Facts as to Which There is No Genuine Issue to be Heard in support of its Motion for Summary Deposition of all of Coulee Region Energy Coalition's (CREC) environmental contentions in the above-captioned proceeding Contention Nos. 2A and 2B 1.
Off-gas emissions from LACBWR during nornal reactor operation are lower than the limits set forth in Appendix I, 10 C.F.R. Part 50 regarding radiation exposure levels for off-site populations.
(FES 3-14, 5-11, 5-12; Tables 5.5-3, 5.5-4, 5.5-5).
2.
The annual radiation exposure to LACBWR employees is below the limits set forth in 10 C.F.R. Part 20.
(FES 5-12).
E202040312 820202 PDR ADOCK 05000409 0
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Radiation conmitments to enployees both on-site and off-site are within the limits set forth in 10 C.F.R. Part 20.
(FES 5-9, 5-14-18).
4.
There will be no measurable radiological impact on man from the operation of LACBWR.
(FES 5-12).
Contention No. 8 1.
Dairyland's radiological environnental moni-toring program for LACBUR meets all NRC Regulatory Guide requirements and the requirements of the U.S. Environmental Protection Agency, and Public Health Service, and the International Atomic Energy Agency.
(Steele Affidavit, 1 1).
2.
The methodology of testing employed in DPC's environmental monitoring program for LACBWR meets all industry and NRC standards for environnental monitoring.
(Steele Affidavit, 1 2).
3.
The size, frequency, and distribution of test samples taken in DPC's environmental monitoring program for LACBWR meet all industry and NRC standards for sampling and testing methodologies.
(Steele Affidavit, 1 2).
4.
DPC's environmental monitoring program is adequately tailored to the site-specific conditions in the LACBWR area and account for inter alla the geography of the area and the fact that it is located in a dairy region.
(Steele Af fidavit, 1 2).
. Contention No. 9 1.
There is no technical or scientific evidence to substantiate a claim of combined or synergistic health ef fects of airborne effluents released by LACBWR and the Genoa 3 coal plant.
Affidavit of Dr. Reginald L. Gotchy Regarding Intervenors Contention 9, NRC Staff Motion for Summary Disposition.
2.
The Genoa 3 coal plant attains all applicable air quality standards adopted by the U.S. Environmental Protection Agency.
1979 Annual Air Quality Monitoring Summary (Dairyland Power Cooperative).
3.
The air quality standards issued pursuant to i
40 C.F.R.
S 81.350 which apply to the Genoa 3 coal plant i
were developed in the presence of the background radiation from LACBWR.
Affidavit of Dr. Reginald L. Gotchy Regarding Intervenors Contention 9, NRC Staff Motion for Summary l
Disposition.
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Contention No. 19 1.
The benefits associated with the continued f
operation of LACBWR outweigh the costs and environmental impacts associated with its operation.
(Chait and Steel Af fidavits ; FES at 8-3 to 8-8,10-4).
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. 2.
The environmental effects associated with the continued operation of LACBWR do not affect significantly the cost-benefit balance favoring the operation of LACBWR.
(FES at 10-4).
3.
Long term operation of LACBUR at 40% of its capacity will result in no cost penalty; operation of LACBWR at 50% of s capacity will result in cost savings.
(FES at 8-8).
4.
There is a need for the energy produced by LACBUR during the period 1980-1986.
(Chait and Steele Affidavits, 11 1 and 2; FES at 8-8).
Contention No. 22 1.
DPC has instituted a comprehensive program to promote energy conservation.
(Thorson Affidavit, 1 1).
2.
DPC utilizes flat rate structures in its cooperative and wholesale schedules.
(Thorson Affidavit, i
1 2).
3.
Dairyland's wholesale rate schedules incorporate a demand charge.
(Thorson Affidavit, 1 2).
I 4.
Since 1971, DPC has not encouraged energy usage.
(Thorson Affidavit, 1 3).
5.
DPC's current advertising encourages energy conservation and better load management.
(Thorson l
Affidavit, 1 2).
. 6.
There is a need for the energy produced at LACBWR during the period 1980-1986.
(FES at 8-8).
Respectfully submitted, t
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(, j - s... k l.y...e5 O.
S.' Hiestand Irviri N. Shapell Attorneys for Dairyland Power Cooperative OF COUNSEL Morgan, Lewis f Bockius 1800 M Street, N.W.
Washington, D.C.
20036 DATED: February 2, 1982 l
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