ML20062B059

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Need for Power & Alternative Energy Source Contention
ML20062B059
Person / Time
Site: Byron  Constellation icon.png
Issue date: 07/30/1982
From: Whicher J
DEKALB AREA ALLIANCE FOR RESPONSIBLE ENERGY, SINNISSIPPI ALLIANCE FOR THE ENVIRONMENT (SAFE)
To:
Atomic Safety and Licensing Board Panel
Shared Package
ML20062A998 List:
References
NUDOCS 8208040303
Download: ML20062B059 (2)


Text

pp uo e 00LKETED UNITED STATES OF AMERICA LNC NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD '82 AG0 -3 NO :79 0F sa m ili;G J E:

In the Matter of ) E R M.Ori

)

COMMONWEALTH EDISON COMPANY ) Docket Nos. 50-454

) 50-455 (Byron Station, Units 1 and 2) )

DAARE/ SAFE NEED FOR POWER AND ALTERNATIVE ENERGY SOURCE CONTENTION There is insufficient need for the power to be generated by the Byron plant to justify the issuance of an operating license under the Atomic Energy Act and the National Environmental Policy Act, and there exist environmentally and economically superior alternative energy sources .

As the basis for this contention, DAARE/ SAFE incorporates herein by reference, in their entirety, the Petition of Rockford League of Women Voters for Waiver of or Exception to Need for Power and Alternative Energy Source Regulations 10 CFR 5551.23(e) and 51.53(c), the Petition of DAARE/ SAFE for Waiver of or Exception to Need for Power and Alternative Energy Source Regulations 10 CFR 5551.23(e) and 51.53(c), and all exhibits th ere to .

DAARE/ SAFE further contends that the FES submitted by the NRC staff in April, 1982 is inadequate in two respects: (1) it insufficiently considers need for the power to be generated by Byron and alternative energy sources on the basis of information therein set forth and (2) it should be supplemented to consider 8208040303 820730 PDR ADOCK 05000454 G PDR

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the newly-developed information set forth in the referenced petitions

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and exhibits.

At least the following alternative energy sources must be considered:

- non-operation of Byron

- non-operation of Byron with purchased power

- operation of only one of the two Byron units

- conservation

- cogeneration

- load management When the lack of need for power to be generated by Byron and

t. 2 environmentally and economically superior alternative energy so urce s , shown in the newly-developed information, are considered, and when all available information is considered, the cost-benefit balance required by NEPA will change significantly from that struck in the FES and issuance of an operating license for Byron will not be justified under NEPA.

DATED: July 30, 1982 Respectfully submitted, Douglass W. Cassel, Jr.

Jane M. Whicher by:  % . bM-Jane M. Whicher Attorneys for DAARE/ SAFE with respect Douglass 11 Cassel, Jr. to issues of financial qualifications, need f r Power and alternative energy 109 North Dearborn sources Chicago, IL 60602 (312) 641-5570

.