ML19318A300

Affidavit in Support of D Springer 800415 Petition Alleging That Neither NRC or ASLB Has Fully Considered Potential for once-through Cooling & Tower Cooling.Supporting Documentation & Certificate of Svc Encl

ML19318A300
Person / Time
Site:	Perkins
Issue date:	05/21/1980
From:	Springer D AFFILIATION NOT ASSIGNED
To:
References
NUDOCS 8006190189
Download: ML19318A300 (15)

Text

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,R 8/ DOCKETED UNITED STATES OF AMERICA usnac ,,

NUCLEAR REGULATORY COMMISSION (p_ MAY 2 71960 > @

BEFORE THE ATOMIC SAFETY AND LICENSING B A cf Etuch

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In the ,a :ter of ) <E m

) Docket Nos. STN 50-48 DUKE POWER COMPANY ) STN 50-489

) STN 50-490 (Perkins Nuclear Station )

Units 1, 2 and 3) )

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AFFIDAVIT Enclosed for filing is Petitioner's Affidavit in support of his Petition of April 15, 1980.

In regard to the conservation of energy, water, avoiding overbuilding and holding rates down, Petitioner suggest that staff has developed only ways it can't be done.

It is hoped that the enormous long range consequences of a cooling tower only site as compared to a cooling tower /once through site on energy, and water conservation and on avoiding unnecessary building and rate escalation will persuade the Board on its own motion to re-open the record and end this unfortunate controversy.

It appears almost certain that in the near future we will be granting, if needed, thermal standard waivers and trading fish for energy, water and lower electric rates. The State and I

FederalRegulationsallowingthisumgpwithheldfromtheBoard by Staff permits this trade. We feel certain the Board will opt for action protecting the public interer.t.

Comes now David Springer and deposes and says:  ;

1. That he filed Petition dated April 15, 1980, alleging that Staff misrepresented to this Honorable Board the 8 0 0 619 0/89 ' h ._

position of the State of North Carolina regarding the availability of once.through cooling and failed by design or imcompetence to present to the Board facts that would put in issue the viability of sites with potential for once through cooling and tower cooling; that failure to consider sites with both cooling tower and once through potential is against the public interest in that:

(a) Once through cooling would save at peak at the Perking Plant in excess of one hundred megawatts; and (b)' Conserve the b.t.u.s. of energy necessary to generate in excess of one hundred megawatts; and (c) Raise the price of thermal generated electricity to the average North Carolina consumer by a significant amount estimated in 1977 dollars as ranging from $5.40 per month to $2.25 per month; and (d) Require the overbuilding of a new thermal generating units needed to supply the base and reserve for the above approximated one hundred megawatts; and (e) Conserve water capable of sustaining a domestic-industrial complex of approximately 6,000,000 perons.

That further details of this public interest are contained in Petitioner's Petition to Intervene dated April 22, 1977, and Affidavit of Basis for Contentions Raised in Petition to c

and Affidavit of Basis for Contentions Raised in Petition to Intervene and Request for Hearing on New Issues Raised by the National Energy Police and Appalachian Power v. Train dated May-3, 1977; that said- documents ~are on file -in 'this - '

proceeding and incorporated by reference herein:

2. That neither Staff nor this Board has fully considered the substantive issues hereinabove posed in paragraph (1) but rather have disposed of them on proceedural grounds of, among others, standing of Petitioner to raise these issues; the basis for the present Petition alleging misrepresentation to the Board of material facts and by design withholding others requires no standing nor in fact raises any issues of quasi-estopel for failure to uncloak them by '

formal parties at any prior time in the proceedings; staff r

and applicant confuse the remedy of Intervention or appoint-ment of new Staff with the substantive grounds alleged for I

the Board to reopen the record in tne public interest; I intervention is c.11y one of the remedies suggested to correct a substantive c V Yo V. 8 4

3. Staff did in fact knowingly misrepresent the position of the State of North Carolina to this Board; in the Supplementary NRC Staff Testimony Reg 3& ding the Criteria Used to Select Site Alternatives to the Perkins Site and the Examination of Site Alternatives to Perkins Sworn to by Staff on October 30, 1978,on page 8 and on file herein Staff swore that:

"2. The only cooling option available to the applicant at this time is closed cycle (i.e. cooling towers). This has been confirmed by Staff consulta-tion with tho State _of North Carolina which assures the staff that tho Stato will not license once through cooling due to its greater heat discharge into receiving State waters.

........" (emphasis added)

On page 25 of NRC Staff Proposed Findings of Fact and Conclusions of Law in the Form of A Partial Initial Decision dated March 19, 1979, and on file herein, Staff reiterated the exact same paragraph hereinabove quoted; that Staff was fully cognizant that this representation as to the position of the State was false is established by ARC answer to a letter from Honorable Stephen L. Neal, United States Congressman, to Chairman, Hendrie of NRC; the Congressman wrote to the Chairman as follows:

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"Mrs. Barth, as you can see from the correspondence, had written to an Assistant Attorney General of the State of North Carolina. He received a reply, not from the Attorney General's office,-but from Mr. Benton in the Environmental Operations Section of the North Carolina Department of Natural Resources in which Mr. Benton says that it is his personal opinion that technology other than once through cooling would be required. Mr. Barth is now using the personal opinion of one State government employee as the official

. i position of the State of North Carolina before the Nuclear Regulatory Commission. The fact is that the State of North Caroina has not yet developed an official position on this issue, although they have been requested to do so and we anticipate some action relatively scon.

...." (emphasis added)

In a letter dated November 28, 1979, Lee V. Gossick, acting as Deputy for the Chariman responded; (Petitio t*'is informed and believes and therefore states as a fact that this response was'either prepared ny Staff or Staff signed off on the draft) .

"... however, you should be assured that neither Mr. Barth nor.anyone else in the NRC has represented the letter from Mr. Benton is other than the position of the Chief of the Environmental Operations Section of the North Carolina Department of Natural Resources and Community Development ...". (emphasis added)

4. By the most elementary inquiry to the North Carolina Attorney General's office Staff would have known that the State through its. authorized agency, the Environmental Protection Commission, had been formally requested to-inform NRC Staff the position of the State in response to Staff's inquiry of October 11, 1978; that Petitioner is informed and believes and therefore states that Staff had actual knowledge I

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of the pendency of this request at the time it swore to .

the alleged position of the State. (See Exhibit A, attached hereto).

5. If Staff did not actually know that their representation to the Board was false prior to on or about December 1, 1979, they conclusively knew it when they received the letter dated November 18, 1979, from Neil S. Grigg, Director of North Carolina Department of Natural Resources and Community Development written on the direction of the Environ-Management Commission; as a result of a formal proceeding held to answer NRC's request of October 11, 1978l(see ExhibitBattachedhereto);thatuponreceiptofthisletter Staff willfully failed to take steps necessary to see that the official position of the State was. incorporated into the d

official hearing record of this proceeding to correct their misrepresentation to this Board as to the position of the l

State or to advise this Board that the thermal standards 1 l

could be waived by the Environmental Management Commission.

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6. That the reliance of this Board upon the representations of Staff re the position of the State is found on page 21 of the Board's Partial Initial Decision of l

February 28, 1980, where Staff's misrepresentation as to the l position of the State is repeated verbatim as in paragraph 3,  ;

i supra; that the probability of the availability of once  !

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through cooling mandates consideration by the Board of cooling l tbwer/once through cooling sites as opposed to restricting  !

consideration to cooling tower only sites, j

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7. That Staff through design or incompetence has not presented to this Board all facts material to the availability of sites suitable for a combination of closed cycle and once through cooling that were known to them or should have been known to them in the following particulars:

(a) That in his formal presentation before the Environmental Management Commission, L. P. Benton, source of Staff's representation re position of the State, on November 8, 1979, indicated that his letter spoke to cooling a single 4,000 megawatt thermal generating unit because that is what Staff asked in their letter of October 11, 1978, in the following word; "... for a facility of approximately 4,000 MWe."; the official record of the hearing states; "Mr. Benton stated the evaluation (speaking of his letter) is for a 4,000 Mw electric unit ... "If anyone anywhere can find data to the effect that water quality standards can be protected with that waste heat load, he would withdraw his letter to Mr. Barth ....". That is common knowledge that there are numerous sites in North Carolina capable of handling once through cooling for a 1,280 Mw unit.

(b) That Staff by the most elementary inquiry would have found that the Environmental Management Commission of North Carolina can waive thermal discharge standards; that any minimal " consultation" s

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l with Mr. Raney or anyone knowledgeable in North j Carolina Regulations would have developed this fact; that Staff knowingly and willfully concealed this fact from the Board.

(c) That Staff is charged with knowledge of the contents of the Federal Register and especially those concerning thermal electric generating units; that the Code of Federal Regulations 44 CER 44846 and later amendments provides for the waiver of l

. EPA thermal discharge standards upon consideration l of most if not all of the facts alleged in Petitioner's prior filings herein as set forth in 1

paragraph 1, here3-- ' hat Staff through design or i incompetence fai_ to call this material fact to the attention of this Board.

(d) That the Clean Water Act specifically exempts existing cooling lakes from its provisions; that Lake Norman was an existing cooling lake at the time of the passage of the Clean Water Act and was specifically built by Applicant as a cooling lake; that Applicant has previously claimed and now does claim that Lake Norman has once through cooling capability for, if not all, at leasd some of the Perkin's 1,280 units; attached is a memo of Applicant's President, W. S. Lee, dated October ll, 1977, to this effect; that this memo is only one of many claims of Applicant available to Staff. (Exhibit C herein). ~ .

(e) That the decision as to the type of cooling needs to be made approximately four years prior to the time each 1,280 IN thermal generating unit goes on line; that Staff handled the licensing of Applicant's McGuire Station located on Lake Norman; that the McGuire Station was licensed by NRC with this understanding regarding the cooling tower once through cooling option; there appears no reason why

site consideration for Perkins should not have the

-aame option; that Staff is thoroughly familiar with

-this op, tion; that Staff willfully suppressed this material fact. (See Exhibit D attached herein) .

(f) That Applicant has substantial technical data undeveloped by Staff to establish that Lake Norman can once through cool at least the first of Perkins 1,280 Mw units; that Staff through design or incompetence has failed to present this data to this Board.

8. That Exhibits A, B, C and D are true and correct copies of their original and were originated as received as appears on their face.

9. That the public interest requires considerztion of the once through/ cooling tower site option.

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David Spri r g g I Sworn to and subscribed before f'J Jennifer ' . Teachay me this J7/g- day of May,- 19 80.

• M f,? J m I My Commission Expires: ) / o # l

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.. l b hock Ne &L1ociaflon, $nc, P.O. Box 159 l Southmont, North Carolina 27351 '

AuCust 17, 1979 David springer, President The Environmental Management Commission M. L Byrd, Vice President F.O. Box 27687 L W. Decker, Vice President Ra1 etch, North Carolina 27611 <

H:rold D. Green. Vice President C2therine W. Pitts, Vice President. Treasurer J:ne Bennett Itemrdine secretary Gentlemen:

Subjcct: The NRC request for the view of the State PAST PRESIDENTS of North Carolina as to the availability of conden-som L Booke ser Cooling Water for thermal electric generating Joe F. Freeman Units E. W. Fries E U' #'#"'*'" 1. The NRC has requested in the enclosed letter the h,##""s~d r ,, view of the State of North Carolina as to the avail-ability of condenser cooling water for thermal elec-tric generating units.

J. H. Banks - 2. It is respectfully suggested that the Environmen-

$,IM( tal Mcnagement Commission has the only authority to J:ne Bennett express the views of the State of North Carolina.

lienry Booke Sm L a k. 3. It is respectfully suggested that this Commission M. L Byra 7 advise the NRC as follows:

Nij$,$g.',, a. that 15 North Carolina Administrative Code R. I. Floyd . 2B.0211 (c) (3) (J) and 2B.0211 (e) (3) (F) provide Joe F. Freeman the limits of thermal pollution in North Carolina 4 Larry carrett waters; and Donald S. Graham

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b. that this Commission has the authority under  !

$,'ii , , ge m 15 North Carolina Administrative Code 2B.209 to grant Benny Huff a variance from quality standardG when public interest -

Joe P. Marus Would be better served thereby; and  ;

Tamy Miller Bil3Y Mi**

c. that the EPA has similiar~ aut'hority* ; and I

d. that this Commission knows of no thermal elec- l i

gI,"p'hi5ip. tric generating units in North Carolina either existing l 14e Phillipe -

of planned larger than approXimately 1300 Mw. ; and '

Cctherine Pitta e. that without specific details,' no fair view '

J. f l. Plemn.-.a - of the State 'other than the applicable rules and regu-

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, l*g1" lations can be -given.

l Klynt Ripple  !

j David Springer jbr Respectfully yo s,  ;

Brcaton Young j l

Enclosures . , ,

(1) Letter of NRC dated 10/11/78 ,j9 .

ri President  !

(2) Letter of A.F. Mc. Rorie, Director Div. of Env. Management dated 7/2/79 Hi te Association l O(3) Copy of Federal Register amending 40 CFR 423 (

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\orm Carolirla .Jeaar~merr o" Na~ura Resources & Community Jeve.oamerr James B. Hunt, Jr., Governor 6 Howard N. Lee, Secretary

' DIVISION OF ENVIRONMENTAL MANAGEMENT July 2, 1979 lb *.'

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• !!r. David Springer, President High Rock Lake Association, Inc. .

P. O. Box 159 Southmont, North Carolina 27351 i t

Dear .'ir. Springe r:

In response to your request on May 10, 1979, for permission to participate in an Environmental Management Commission meeting, I am placing the matter of the State's position relative to the impact of once through condenser cooling on the waters of the State on the l Commission agenda for Augu,st 9,1979.

The policy of the Cormnission is well expressed in water quality standards water quality.

for North Carolina and other regulatory documents concerning However, in order that you be heard concerning this matter, I am placing your petition before the Commission for their cons i de ra tion. You are invited to present such evidence or information you deem appropriate.

Please be advised that this is not a public hearing, is not a rule making hearing and that it is simply an opportunity for you and other Interested parties to discuss this matter with the Commission and to '

determine whether the Commission should proceed further relative to the

, . _ matte,r of qua,11 ty,, standard),in, the . waters of the Sta te of North Carolina.

If I can be of further assistance, please advise.

Sincerely,

h. s A. F. McRorie h

Director ,

7- b 8 P. o. Box 2768 R North Carolina 27611 An EqualOpportunity Affirmative Action Employer

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October 11, 1977 I OCT 121977 */it L CINE POWER COMPA.'iy

\p j' csvlLIEnv. ouvus:ou ld John Lansche .

R3: McGuire NPDES Permit Confirming our conversation with regard to your letter of ,

October 7, I realize there are some risks involved with the  :

Icnguage of the McGuire permit as agreed to. I do not believe that it is necessary to add the words "if then legally required."

It would cause suspicion in the minds of the state agency as to

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our motivations. Even without those words, if the laws or '

regulations change between now and permit expiration, we can l make an effective argument to that point.

With respect to the other risks that we might not be able to

> dcmonstrate certain things, I and many others.are convinced that McGuire's use of Lake Norman can be proven to be less harmful to the environment than any alternative way of providing con-danser cooling. This is based upon our repeated studies beginning ,

as early as 1958. We are coing to want to underia_ke a_f.u,11 r

I ecope 316a tyoe demonstration to_not only orove this b11t Jlso carve as a foundation for considering c:6er sites __for large therma fplants on Lake Norman.

! Whan the permit comes out with the language as agreed upon, ploase take those steps necessary to accept the permit. ,  ;

Many thanks for bringing to my attention those risks tha. '

l cro involved in this step. .

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W S Lee ,

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g September 8,~197d '

W. O. Parkcr .

Attn. W. A. Haller Re: McGuire NPDES 316(a)

File Nos: MC-1444.00, F-29 MC-1415.00 A decision has been made to proceed with' development of a predictive 316(a) document for McGuire Nuclear Station. The important chronol-ogy is as follows:

April 1, 1977 - Formally file 316(a) document with the Department of Environmental Management of NCDNER.

g qq 4 Aug. 1, 1977 - NCDNER grants or denies 316 (a) .

d  !!ay 1, 197 8 - Unit No. 1 Startup.

, O May 1,1979 - Unit No. 2 Startup. <

L' July 1, 1981 -

Date upon which both McGuire units must be cquipped with cooling towers if on August 1, a

1977 NCDNER denies 316(a).

[Youwillnotethatifcoolingtowersarerequired,theabovesched- l 4 ule affords essentially four years during.which tower specifications i j can be written, a manufacturer selected, construction completed and l J

towers p.mced in service. ,

l You are aware of the recent UWAG-4th Circuit Court decision which, among othr rino ngs, could exempt McGuire from the cooling tower requirement. Unfortunately, no one can be certain what course EPA will take on these matters. To assume that a 316(a) will not be re-guired is to run a serious risk since NCDNER in the legal " jungle" -

may decide at some future date that N. C. still embraces EPA's guidelines and they, N. C., require a 316(a) and the July 1, 1981 deadline. Such a late decision could be very costly to Duke Power.

On the other hand, preparing a 316(a) document at this time is no trivial task. We have 316 (a) experiences; however, this is to be predictive and being prognostic in nature will likely require more expertise than required at Allen or Marshall.

If EPA and/or NCDNER should advise later on that McGuire is " free" from cooling towers, then our 316(a) effort will certainly not be entirely wasted. As a matter of fact, we should find the 316(a) '

effort to be of substantial value during the McGuire hearings ahead as well as in Technical Specification negotiations.

As in other NPDES proceedings, Design Engineering will take the  ;

lead"in coordination, document publication, etc.; houever, ob- ,

viously, we must depend largely upon certain very knowledgeable

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,! W. O. Parker -

Attn. W. A. Haller September 8, 1976 i Page Two ,

biologists in your group to furnish much of the expertise. Dr.

David Anderson, Ext. 4976, has been designated to head the McGuire 316(a) effort in Design. Dave will contact you regard-ing the individuals in Steam Production you choose to assign to i this effort.

If you care to discuss, please do not hesitate to call me.

L. C. Dail, Chief Engineer ,

civil-Environmental Division f I 0f '

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By: C. A. Dewey, Jr. /

Principal Environmental Engineer f

cc: R. S. Bhatnagar

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G. o. Crowell R. F. Edmonds .

D. W. Anderson '

A. Gnilka R. F. Gray T. U. Yocum .

W. D. Adair C. S. Carter ,

W. L. Porter' , I W. J. McCabe J

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CERTIFICATE OF SERVICE I hereby certify that copies of Affidavit

~in the above-captioned matter have been served on the follow-ing by deposit in the United States mail this 22 day of May , 19 80 Elizabeth S. Bowers, Esq. Charles A. Barth, Esq.

Chairman, Atomic Safety Counsel for NRC Regulatory Staff and Licensing Board Office of the Executive Legal U.S. Nuclear Regulatory Director Commission U.S. Nuclear Regulatory Washington, D.C. 20555 Commission Washington, D.C. 20555 Dr. Donald P. deSylva Associate Professor of William A. Raney, Jr., Esq.

Marine Science Special Deputy Attorney General Rosenstiel School of Marine State of North Carolina and Atmosph.eric Science Department of Justice University of Miami Post Office Box 629 Miami, Florida 33149 Raleigh, North Carolina 27602 Dr. Walter H. Jordan William L. Porter, Esq.

881 West Outer Drive Associate General Counsel Oak Ridge, Tennessee 37830 Duke Power Company Post Office Box 2178 Chairman, Atomic Safety Charlotte, North Carolina 28242 and Licensing Board Panel U.S. Nuclear Regulatory Mr. Chase R. Stephens Commission Docketing and ' Service Section Washington, D.C. 20555 Office of the Secretary ,

U.S. Nuclear Regulatory i Chairm'an, Atomic Safety Commission  ;

and Licensing Appeal Board Washington, D.C. 20555 j U.S. Nuclear Regulatory Commission Mr. J. Michael McGarry,.III j Washington, D.C. 20555 Debevoise and Liberman  ;

1200 Seventeenth-Street, N.W. 1 Washington, D. C. 20036 j l +

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October 11, 1978 I

Mr. William A. Raney, Jr. , Esq.

Assist;lnt Attorney General

-P.O. Cox 629 Raleigh, North Carolina 27602 In the Matter of Duke Power Company I (Perkins Nuclear Station, Units 1, 2 and 3)

Docket !!os. STf! 50-488, STN 50-4S9, and Slu 50-490

Dear Mr. Rancy:

As you are aware from the papers we have previcusly sent to you, the NRC Staff is engaged in re-assessing sites alternative to the Perkins

, site which is proposed by , Duke Power Company for a facility of approxi-mately 4000 MWe.

The type of condenser cooling to be employed is a necessary ingredient in our revicu. Therefore, we would appreciate having the view of the

- state as t'o what type of condenser cooling would be acceptable for a

- ' nuclear facility of the size of Perkins to be constructed in the future and to come on line after July 1,1983 (see section 301 FWPCA amendments of 1972 and 40 CFR 423.15(6)). ,

Sincerely,

(.b.b- l  ? f.' .7{

Charles A. Barth M Counsel for NRC Staff

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cc: Elizabeth S. Bcwers Dr. Donald P. deSylva Dr. Walter H. Jordan "

J. Michael McGarry, III, Esq. ,

William L. Porter, Esq.

William G. Pfefferkorn, Esq.

Mrs. Mary Davis '

Atomic Safety and Licensing Board Panel Atomic Safety and Licensing Appeal Board i Docketing and Service Section I l

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.+I C20ar3es B Hr.*, Jr.. Govern' o r Hcward N. Lee. Setretary -

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! DIVISION or EinEC:.".E: ITAL MA:: AGE:E;T

• Us;g"'Ofl0 -November 28, 1979 r

E, Mr. Charles Barth

,, Imgal Counsel Nuclear Regulatory Co==ission

. . Washington, D.C. .

Re: Perkins Nuclear Station

Dear Mr. Barth:

On October 11, 1978 you sent a letter to W. A. Raney, Jr., Assistant Attorney

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General, in which you requested thezview of- the State on the type of: condenser u..- . ,

. ' cooling acceptable for a nuclear facility the size of the proposed Perkins -

1. ' i,l plant. At the request of W. A. Raney, L. P. Benton responded by letter dated 3 i

f, October 19, 1978. ,

l The North Carolina, Environ = ental Management Coc=ission has requested that,I ," .

clarify- the -October 19. letter and: elaborate on its contents. ..- . 2 I

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1. There is no established procedure by which the State of North l Carolina can establish an official position on the question which is posed ~

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other than in the context of the per=it applica' tion and review process. '

- State e=ployees are encouraged to render advice and opinions outside of

+ : the official permit-application process in order to assist potential , .

. : .1 applicants; however, such advice and opinions have no official or legal I

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status under North Carolina law.

2. Any permit application for.dischstge of heated effluent would be acted unc. In :::ordance wich the te perature standards set forth in the k-

/' ' North.Ctrcaica-Ad:.inistrative Cede. Fertinent sectic:s of the Code are e- set out in the October 19,1978 letter.

I 3. C.S.143-215.3(e) provides a techanism for the Environcental Managacent Co=sission to grant variances from their rules and regulations. '

) r ' i m cThis-lettertshould.not be. interpreted-as-being in support of or rejection .of .a..

the letter of October 19, 1978. It is intended to explain the status of that letter under North Carolina law. ,

i Sincerely, W .

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.. Dr. Neil S. Crigg Director cc: David Springer Rep. Stephen Neal D g i

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, P.O. Son 27657 aateist ; horth Carolina 27611

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A00 laust Opportunoty Aff.rmeto.e A ion eclover i.a w m e n _ _ _ . ._ . .

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