ML20062M206
| ML20062M206 | |
| Person / Time | |
|---|---|
| Site: | Perkins  |
| Issue date: | 12/08/1981 |
| From: | Pfefferkorn W HIGH ROCK LAKE ASSOCIATION |
| To: | NRC ATOMIC SAFETY & LICENSING APPEAL PANEL (ASLAP) |
| References | |
| NUDOCS 8112170104 | |
| Download: ML20062M206 (5) | |
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W UNITED STATES OF AMERICA
- RC NUCLEAR REGULATORY COMMISSION BEFORE TliE ATOMIC SAFETY AND LICENSING APPEA$1BdKM0 P4
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MidlCH DUKE POWER COMPANY
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Docket Nos. STN 50-488
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STN 50-48 N""k' 'N (Parkins Nuclear Station
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STN 50-4 Units 1, 2 and 3)
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MOTION TO CONSIDER NEW EVIDENCE AND
- DEC15 1981
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Y c{ " N 'm e uelu REOPEN Ti!E PROCEELINGS V
l NOW COME the Intervenors through counsel and do hereby
,g move thac this matter which has been placed on hold for a period of two years be reopened at the end of said two year period and I
further, that the appeal on the question of alternate sites also j
be stayed and reopened on the grounds of the same new matters and that further, the entire proceeding oe reopened at the end of the current two year period of no action for the following reasons among others:
1.
During the fall of 1981, it has become apparent that the recreational use of liigh Rock Lake is extensive during the fall season.
Yet this is a period of time which does not even have the limited and weak protection of the rule curve which is in effect from May 15 to September 15 of each year.
This extensive use of the Lake during this time means that there are significant interests involved in this matter which have not, previously been addressed in that it has been assumed in the previous hearings of alternative sites and other issues that the recreational season endedon September 15.
The extensive amount, 8112170104 01120'8 0
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of fishing-and other boating activities between September.15, I
.1981, Land December 1, 1981, and the drawdown during these periods of tiues without-even dubious and limited protection of the. rule curve indicate that catastrophic results will-occur to all users of the Lake and property owners around the Lake during the fall-I season if a nuclear plant such as proposed at the Perkins Site B
were ever put into operation.
If Yadkin, Inc. operates High Rock Lake as it has during past years, then the !!igh Rock Lake level will drop to very low levels during the fall.and winter months without Perkins.
During this fall season it has dropped to between 10 and 15 feet below normal.
Even though this has eliminated much of the usage of docks and many other recreational benefits of the Lake it is still possible for some of the fishermen and other boat users to use the Lake.
These usages have to be made under certain hazardous conditions.
Ilowever, if the Perkins Plant.
is constructed and the water usage by the Perkins Plant is carried out during these fall, winter and spring months,then the already diminished and dangerous amount of water available in liigh Rock Lake will be drastically reduced.
There would not be enough-water left for the uses made by fishermen and boaters who were seen operating during the fall of 1981 The elimination of this fishing and other boat uses would have an additional significant effect on the recreational value of liigh Rock Lake.
The operation of thePerkins Plant during the fall, winter and spring months would t
result in castastrophic drawdowns in that the proposed water use i
by the Perkins Plant.could reduce the Lake to nonexistence during these periods of time.
It is vital that we obtain the exact I
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information on how much the Lake level will be pulled down;whsn
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the rule curve is not in effect.
Previous information indicates y
that the Lake would have virtually disappeared if the reduced l
t Lake level of this fall were further reduced by the impact of the l
Perkins Plant.
The information indicates that from September until winter or spring, the effect of the Perkins Plant would be to virtually empty the High Rock Reservoir.
Such emptying would produce a gapping ugly scar on the landscape of Piedmont North Carolina and be totally incompatible with any,use of the Reservoir.
In the light of this new evidence of ex. tensive use by the Lake during the low rain fall months of September, October, November and December, the Intervenors respectfully submit that this new evidence of extensive use during this period of time and the lack of any rule curve protection require of the Appeal Board and Licensing Board to open this matter up and go into it
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extensively before rendering any further decisions in this matter.
This the day of December, 1981.
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WILLIAM G.
PFEFFER}@RN, Ipt@pT High Rock Lake Associatidn/ y for.
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Inc.
202 West Third Street Post Office Box 43 Winston-Salem, North Car 61ina 27102 Telephone:
(919) 725-0251
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UlllTED STATES OF AMERICA
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I;UCLEAR REGt)EATORY COFSISSION
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BEFORE THE KibFlc SAFETY 'ARD LICE;!SIllG APPEAL 20ARD C
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Docket ilos. STN 5D-488 STil 50-489
' 0di(E PCl!ER' C'OMPA!!Y STN 50-490 1
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- MPctkins, Nuclear Static.o
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CERTIFICATE hF SERVICE t
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.[ I Greby certify that copies of Motion to Consider New Evidence and Reopen the Proceedings sin the above-captioned matter have been served on the following byJeposit in the United States Mail this the 8th day of, December 1981.
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t Alh,'i S. Rosenthbl, Esq., Chairnan*
Dr. Donald P. deSylva k-
./do'nic Safety and Licensing Associate Professor of 1%rine Science Appeal Board ~
o Rosenstiel School of Marine b ' * ~_
U.S. !:uclear Regulatory Comission and Atr.ospheric Science l'ashington, D.C.
20555 University of liiami liiami, Florida 33149 Dr. John H. Duck
- Atenic Sr.fety and Licensing Dr. Italter H. Jordan Appeal Board 881 W. Outer Drive U.S. !!ucicar Regulatory Comission L'ashington, D.C.
20555 Oak Ridge, Tennessee 37830 Mr. Thomas S.11oore *'"
J. Michael l'cGarry,111 Esq.
Debevoise and Liberr.an Atonic Safety and Licensing 1200 Seventeenth Street, fl.W.
Appeal:Doard
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U.S. I uclear Regulatory Comission
!!ashington, DC 20035 s
1.'eshingion t.C.
20555 D
Willian A. Raney, Jr., Esq.
Elizabeth S. Gowers, Esq., Chairman
- Special Ceputy Attorney General Ato..ic Safety and Licensing P. O.
Box 629 Feard ranel U.Si!!uclear Regulatory Comission' Raleigh, !! orth Carolina 27f02 1.c s hingt en.. D.C.
20555
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i William L. Porter, Esq.
Associate General Counsel Duke Power Company 422 South Church Street Charlotte, North Carolina 28242 Mrs. Mary Davis Route 4, Box 261 Mocksville, North Carolina 27028 Charles A. Barth Counsel for NRC Regulatory Staff office of the Executive Legal Director U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Quinten Lawson, Esq.
Federal Energy Regulatory Commission Room F611 885 North Capitol, N.E.
Washington, D.C.
20426 l
Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, D.C.
20555 j
Atomi'c Safety and Licensing Appeal Board N
U.S. Nuclear Regulatory Commission
~ Washington, D.C.
20555 s
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> Docket,ing and Service Section (Of'fi'ce of the Secretary U.S. Nuclear Regulatory Commission i'
Washington, D.C.
20555 l
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i WILLIAM G. PFEFFURKOR [
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Attorney for High-Rock ksd t
Association, Inc.
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