ML20040E433

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Affidavit of Ta Steele Re Contention 19 Supporting Util 820202 Motion for Summary Disposition.No Apparent Environ Effects Which Occurred During Retrofitting,Maint or Operation Outweigh Benefits from Operation
ML20040E433
Person / Time
Site: La Crosse File:Dairyland Power Cooperative icon.png
Issue date: 12/11/1981
From: Steele T
DAIRYLAND POWER COOPERATIVE
To:
Shared Package
ML20040E414 List:
References
ISSUANCES-FTOL, NUDOCS 8202040323
Download: ML20040E433 (3)


Text

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter of

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DAIRYLAND POWER COOPERATIVE Docket No. 50-409 (FTOL Proceeding)

(La Crosse Boiling Water Reactor)

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AFFIDAVIT OF THOMAS A.

STEELE REGARDING CONTENTION No. 19 My name is Thomas A. Steele.

I am employed by Dairyland Power Cooperative (Dairyland) as Director of Environmental Affairs.

I have been employed in this position since 1971.

My professional qualifications are attached as Appendix A to this affidavit.

The purpose of this affidavit is to present written testimony in support of Dairyland's Motion for Summary Disposition and the NRC Staff's Amended Motion for Summary Disposition.

Contention No. 19 reads as follows:

CREC Contention No. 19 CREC contends that the economic cost-benefit balance does not favor issuance of a full-term operating license due to LACBWR's small size, relative obsolescence and retro-fitting requirements; its low operating ef-ficiency as evidenced by low megawatt hours of cumulative output, low unit capacity factor, and substantial downtime; the costs of spent fuel storage; the rising costs of fuel and maintenance; and the eventual costs of decommissioning.

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I have reviewed the environmental impacts of the events enumerated in CREC Contention No. 19 There are no apparent 8202040323 820202 PDR ADOCK 05000306 O

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environmental effects which have occurred during retrofitting or maintenance or operation which outweigh the benefits derived from the operation of LACBWR.

The environmental effects of decommis-cioning would be weiFhed w$th the benefits of the plan when it is developed.

The environmental effects of the LACBWR operation are continually reviewed.

It is Dairyland Power Cooperative's policy to operate the facility in compliance with local, state, and federal laws to protect public health and safety.

Current activities do not result in radiation doses to the employees or the public in excess of the dose limits contained in 10 C.F.R. Part 20.

2.

Over the past thirteen years LACBWR has generated approximately 2,500 GWH of electricity for the Dairyland Power Cooperative system.

This compares to a 1980 need of approximately 2,719 GWH for the Dairyland Power Cooperative system.

The benefits from the use of 2.5 billion kilowatt hours by the 160,000 Dairyland Power Cooperative member consumers are far in excess of the environ-mental effects of LACBWR operation.

3 I have read the foregoing af fidavit and swear that it is true and correct to the best of my knowledge and belief.

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subscribed before me this // 75 day of

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Sworn to and 1981.

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Appendix A Thomas A.

Steele Professional Qualifications I am Director of Environmental Affairs for Dairyland Power Cooperative.

My formal education consists of a B.S.

from the Univer-sity of Wisconsin-River Falls in 1961, and an M.S.

from the University of Washington, Seattle, in 1963.

Before joining Dairyland Power Cooperative in 1968, I was employed as a Health Physicist for Argonne National Laboratory, Argonne, Illinois from 1963 - 1968.

At Argonne i

I was responsibic for radiation protection at various facil-ities including the CP-5 Reactor, Zero Power Plutonium Reac-tors, Plutonium Fuel Fabrication facility and Zero Gradient Synochron.

While at Argonne, I published papers on person-nel dosimetry and radiation protection associated with plutonium fuel fabrication.

Since joining Dairyland Power Cooperative in 1968, I was Health & Safety Engineer at LACBWR until 1971, where the LACBWR radiation protection program and environmental survey program'were developed under my supervision.

Since 1971, I have been Director of Environmental Affairs for Dairyland Power Cooperative.

I organized and developed the Environmental Department for Dairyland, which is responsible for environmental and regulatory functions associated with Dairyland Power Cooperative's generation and transmission systen.

I am certified by the American Board of Health Physics and have served on various industry and power pool commit-tees.

Thomas A.

Steele

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