ML19312B641

List of Contentions.Applicant Has Not Sufficiently Examined Environ matters,long-term Local Economic Effects & Has Failed to Provide Sufficient Data Re Agricultural Concerns & Other Related Matters.Certificate of Svc Encl

ML19312B641
Person / Time
Site:	05000599, 05000600
Issue date:	09/03/1979
From:	Cox J JO DAVIESS COUNTY AD HOC COMMITTEE ON NUCLEAR ENERGY
To:
References
NUDOCS 7910150131
Download: ML19312B641 (10)

Text

V TIC

=

c.xg, :.0....t Paco. f.uitt. FAC. fd-M94rdd 3EFCRE THE LPITED STATES NUOLIAR REGLT.ATCRY COMXISSICN In the Matter of

)

)

CARRCLL OCLWTY STATICN 1

Units i and 2 h

/

No. P-559 Acplication of

/

4 4

Oommonwealth Edison Company, p

Interstate Power Comeany, and J

//

g Iowa-Illinois cas & Electric Company p

for Early Site Review J

O!

SEP 1019Z3 54 on

a. n --.

LIST CF OCNTENTICNS n

g

1. N

.I THE JO CAVIESS CCLTITY AD-HCC CCMMITTEE CN NUCLEAR ENERGY I

INFCRyATICN (hereinafter, Intervenor) is a member information grout organized for and dedicated to the search for assurance for the residents of Jo Daviess County, Illinois and, if neces-sery, of the Carroll County Station 50 mile area, that sufficient resserch, preparation, organization, and responsibility will have been devoted by the Applicant to the issues at hand in its request for Early Sita Review (hereinafter, ESR) from the U.S. Nuclear Regulatory Oommission (hereinafter, NRO) for the proposed Carroll County Station Site (hereinafter, Site). Intervenor has heretofore been granted leave to intervene in these proceedings and now files its List of Contentions pursuant to 10 CFR Part 2 71' (b). Even 4

though Intervenor's membership includes many persons of varying persuasions on the issues involved in the ESR, because of the ad-verssey nature of these proceedings, the following Ocntentions have been phrased in a manner that -sy s: pear to be adverse o Appli: ant's position. The position of Intervenor, hewever, is to be strie:17 considered as agnostic in these -stters.

I In censiderstien of the legislative and reguistory cer: erns l

l that any nuclear power plant be a safe source of electriesl energy, Intervenor :entends that Applicant in its Isvironnental and Site l

Safety Reports submitted with its ISR appli:stion has not suffi ciently examined, resear:hed, and censidered the foll: wing matters, as required by the National Invironmental Poli:y Act of *.969, as morso / 3 /

Q

2 amended, P.L.91-190 (hereinsf ter, NEPA), the Invironmental quality Improvement Act of 1970, as amended. P.L.91-224 (hereinaf ter, EGIA),

and to CFR Parts So and 51 (a) The insufficiency of distances from the nuclear power plant to the Site boundaries to safeguard the populace of the Site 50 mile area in the event of nuclear accident, terrorist activities, or armed attack.

(b) The insufficiency of emergency evacuation plans for the Site 5 mile and to mile areas in the. event of nuclear ae-cident, terrorist activities, or armed attack.

(c) The risk of illegal discharges of radiation and chemical pollutants, which risk appears to be directly proportional to Applicant's poor safety and high violation records in its other nuclear power plants.

(d) The Lnsuf.ficiency of research into the short-term and long-term effects of icw-level icnizing rsdiation from nuclear power plants upons (1) the, incidence of leukemia, bone cancer, and other hazards to human and animal hsalth within the Site 50 mile area.

(2) the absorption thereof in milk animals and aquatic food sources.

exposure thereto, caused by the addition to the Northern Illinois area of two more nuclear power plants, as Applicant contemplates at this Site.

II i

This Site, and Applicant's 2yren Station Site, are uniquely located in that each lies within six miles of the Plum River Fault j

which originates in Southern 'fiscensin, extends scuthwesterly th?cush Northern Illinois, cresses the Xississippi River at a locstion within five miles of this Site, and terninstes near Xaquokata, Iowa.

In retted to this extensive reelesie formation, Aeplicant has not suf-ficiently examined, researched, and censidered the folicwing matters, 1

l

P001 OMNR as required by the NEPA, the EQIA, and 10 0FR Part 51s (a) The insufficiency of data regarding potential engineering, safety, and geologie difficulties ;esulting from a possible shif ting of the Plum River Fault.

(b) The insuffici.ency of data regarding such difficulties resulting from seismic activity related to such Fault.

(c)' The insufficiency of data regarding such difficulties resulting from the construction and erection of a nuclear 4

power plant upon Parkland Sand.

(d) The insufficiency of data regarding such difficulties resulting from the heat created by and the water used in a nuclear power plant upon the surrounding sand prairie area at said Site, including its pipeline corridor.

III This Site is uniquely located in that it lies within 2 5 miles of the Upper Mississippi River Fish & Wildlife Refuge, one of the nation's major nature preserves and the primary resting area for migratory birds and waterfowl in the Mississippi River Flyway.

The River itself has the greatest watershed in the nation, and is home to several unusual, rare, or unique species of aquatic, avian, and terrestrial wildlife. In regard to these ecclerical concerns, Aoplicant has not sufficiently examined, research, and considered the following matters, as required by the NEPA, the 30!A, and 10 CPR Part 51:

(a) The effect upon aquatic and avian (including bald eaglas, peregrine falcons, and red-shouldered hawks) spawnin g, nesting, and wintering habits of kesping Pool 13 of the River open in the wintertime.

(b) The effect of emergency operation of the I=ergency Core Scoling System (hereinaf tar, E005) upon the delicate balance of aquatic, avian, and terrestrial habitats in Pool 13 c

(c) The effect of displacement by censtruction,.aintenance, and operation of a nuclear power clant.at this Site upcn the habitats of teaver and arh hawks kncwn to be in the

I i

4 area.

(d) The effect of the operstion of the water intake and dis-charge system, and its potential fos thermal increases, upon the aquatic, avian, and terrestrial wildlife habi-

~

tats of Pool 13, its adjacent marshlands and sand and native prairies, and surrounding uplands.

(e) The effect, upon migratory flight and resting patterns and habitats, of fogging and icing, and of salt drift and deposition, from the Site's cooling towers. ~

(f) The effect of the strong River current upon the potential transportation of illegal contaminated discharges into Pool 13, which contentien must be actively considered in light of Applicant's poor safety and high violation records at its other nuclear power plants.

(g) The compounding effect of overlapping circles of low-level ionizing radiation upon the River watershed, environment, and aquatic, avian, and terrestrial wildlife habitats, caused by, the addition thereto of two more nuclear power plants, as contemplated by Applicant in its application.

(h) The insufficiency of alternative proposals for heat dis-sipetion systems and 300S at said Site, in light of the foregoing contentions.

(i) The following hydroloriesl concerns:

(1) the high potential for contamination of the uncen-solidated aquifers located under said Site.

(2) the impact upon water tables in the Site area in the event of accident or emergency operation of the 2003.

(j) The following meteroloriesl concerns:

(1) icing and foggings (2) salt drif t and depositions (3) the effect of severe snow and glaze storms (which are ecmmon in the Site area) upon aquatic, avian, and terrestrial wildlife habitats, in relatica to the foreroing meterological concerns.

e e

e 5

IV As with all locales for which a nuclear power plant site is proposed, the Jo Daviess - Carroll Counties present a vast number of unusual seeisl and demerrschie qualities for our concern. In these regsrds, Applicant has not sufficiently examined, researched, and considered the following matters, as required by the NEPA, the EQIA, and to CFR Parts 50 and 51:

(a) The effect of construction, maintenance, and operation of a nuclear power plant at said Sito upon the population and population density computations pet forth in Appil-cant's Environmental and Saf ety Reports.

(b) The proximity of said Site to overt military targets, namely the Savanna Crdinance Depot which lies seven miles to the Northwest of the Site, and th6 Savanna rallyards which lie three miles to the Northwest of the Site.

(c) The proximity of said Site to Carroll County's major air-port, namely Stansky Xemorial Field which lies two miles to the Northwest of the Site, and the incumbent diffi-culties therein concerning lines of apprcach and departure and local operations.

(d) The necessity that Applicant's pipeline corridor tempor-arily and permanently disrupt six roads, one rsilroad, one powerline, an area of native prairie, and two canals in order to be constructed, maintained, and opersted.

(e) The effect of construction, maintenance, and operation of a nuclear pcwer plant upon this Site, upon the poten-tisl for soil erosion and the replacement of prime f arm-land by more marginal land.

?00RORGINR While it appears true that the selection of a nuclear pcwor j

elant site hersids a short-term increase in loesi economies occa-l e

sioned by the construction process, the long-tern local econcmic eff ects are of more essential concern to the residents of the Site L

6 50 mile area. In this regard Applicant has not suffielently examined, researched, and considered the following matters, as required by the NEPA, the SQIA, and 10 0FR Parts 50 and 51:

(a) Inasmuch as the major economy of t.",e Site 50 mile area is the herding of dairy, beef, and pork animals and the cultivation of crops, Applicant has failed to provide sufficient data regarding the following arricultural concerns (1) the effects upon livestock reproductive cycles and crop growth of the noise, magnetism, and electrical induction caused by the proximity of extra-high voltage transmission lines and towers, as are centem-plated for this Site by Acplicant.

i (2) the loss of prime farmland caused by the placement and ' erection of extra.nigt voltage transmission lines and, tower's, and by the general reluctance of farmers to work under or near such lines and towers.

(3) the offset of fogging and icing, and salt drif t and deposition, upon the agricultural economy.

(4) the potential in this Sito uroject for the economic-displacement of area resident, that is, farmers and their families, away from the area and toward the urban environment.

(5) the compounding effect of overlapping circles of low-level ionicing radiation, resulting frem the place-ment in Northern Illinois of two more nuclear power plants, upcn dairy animals, beef and pork animals, crop growth, and other agricultursi activities.

(b) The potential for discouragement of the transient recre-ational and tourist economy of the Site 50 mile area be-cause of the construction, maintenance, and operation of a nuclear.pewer plant at said Site.

'(c) The negative effect upon the local economy and social and de=cgrsphic quality of the Site 5 mile and 10 mile areas of any prolonged and intensive public active resistence to the construction of a nuclear power plant at said site.

9

7 VI 1,

o The foregoing contentions regarding the (ocal economy of the Site Sc mile area give rise to further concerns about the effect upon the renersi oublic welf are, safaty, and economy of the con-struction, maintenance, and operation of a nuclear power plant at I

said Site. In these reg'ards Applicant has failed sufficiently to examine, research, and consider the following matters, as required by the NEPA, the EQIA, and 10 CFR Parts 50, 51,: 71, 73, and 14a:

(a) The availability, suitability, and feasibility (in regard to financial, safety, security, environmental, and public health concerns) of electrical energy sources which pro-vide alternatives to nuclear power plant construction, maintenance, and operation at said Site, such as solar, wind, geo, thermal, hydroelectric, coal gassification, and other energy processes.

(b) The financial and technical abilities of this Applicant to construct, maintain, and operate a nuclear power plant

~

at this Site, in light of Applicant's overall financial involvement with the nuclear power plant concept, the diminishment of participation in this Site project by its partners therein, and its poor safety and high violation records at its other nuclear power plants.

(c) Ihe economic alternatives to nuclear power plant construc-tien, maintenance, and operation avsilable to Appli: ant in the form of the establishment of a system of small decentralized co-generating power plants.

(d) The insufficiency of data provided by Appli: ant regarding its future eensumer tower demands (1) its reliance ucon inaccurate surveys of such future demands, insufficiently based upon public mis-cen-ceptions about the cost and availability of future power sucplies, and generally over-esti. mating such future demands:

(2) the high : st of transmission of electrical power from this Site to Applicant's primary :ensumer arsa

8 180 miles to the East, which cost to the consumer will continue to increase as inflation, interest rates, and construction costs continue to elfsbs (3) the effect, upon the opera

• ion of a nuclear power plant at this Site, of the tapending world-wide deficiency in fissionable uranium fuel ores avail-able for such power plants:

(4) the short-term and long-term economic effects, upon construction, maintenance, and operation of a nucle r a

power plant at this Site, of the increasing education of the public toward consumer conservation, the in-creasing experimentation with and potential avail-ability of alternative energy sources, and the poten-i tial for diminishment in consumer power demands oc-casi.oned by cost increases and power supply decreases (5) the fact that Applicant's present excess genersting capacity already exceeds the Federal Power Commission standard by over 250 percent and will be further in-creased by the addition to that capacity of a nuclear power plant in operation at said Sites I

(6) the potential for present and future improvements

~

in the utilization by Applicant of its other power plants, both nuclear and non-nuclear:

(7) the potential that involuntary censumer power demand conservation will beceme ranifest thrcughout the nation throu'h various means, including the require-ment that Aoplicant institute peak load pricing On order to discourage consumer demand.

(e) The following contentions concerning the oublic safety (1) the inability of the NRO to satisfy the current public demand for assursness that nuclear pcwer plants are safe and sane scurces of electrical energy (2) the present national and international dilemma con-carning the disposal of Icw-level and high 1.avel radiation wastes:

(3) the present controversy in suit cencerning the uos of Illinois sites for the dispesal of low-level and

i 9

high-level radiation wastes:

-(4) the failure of the national government to develop and implement a national safety-security policy to safekeep plutonium and nuclear products, and nuclear production and utilization facilities, in the event of terrorist activities or armed attacks (5) the failure of the NRO to assure the public of ade-quate and safe manufacture of nuclear fuel rods, in light of the recent disclosures concerning the fail-uros of the Kerr-McGee Corcoration to comply with NRO production standards.

CCNCLUSION Application for, ESR for this Site, without the usual applica-tien for construction permit accompanying it, has the commendable effect for Applicant of reductng the high cost of the application pro,cedure in the event the Site is not approved. This separation of issues, however, also has the undesirsble effect of isolating I

certain issues that should be publicly considered in connection with a construction permit application. Additionally, Applicant l

has not included in its ESR application any data concerning cost-benefit analysis, study of transmission lines rights-of-way, or alternatives to this Site project. Intervenor therefore, in light of the foregoing contentions, suggests that ESR of this Site is not in the best interests of the residents of the Site 50 mile area.

I Reseectfully submitted, IME JO DAVIESS CCUNIY AD-HC0 CC ClITTEE CN NUCLEAR ENERGY I'fFCRVATICN CM.

}

/ JCNN 4 CCXi JR haLiman 906 Campbell S et r

Calena, Illin 61036 b

^ ^ - -

COX and SCHMADEKE Attorneys At Law JOHN W. COX, Jr*

208 NORTH MAIN STREET AREA CODE 815 PHONE 777-1101 GALENA. ILLINOIS CHARL S MADEKE

~'

RES. 215) 777-2826

?00RORISNAL i C~ "*

usWq' UNITED STATES OF AMERICA g

SEP 101973 NUCLEAR REGULATORY COMMISSION BEFORE THP. ATOMIC SAFETY AND LICENSING BOARD 8tew Q

In the matter of

)

3 COMMONWEALTH EDISON COMPANY, et al. ) Docket Nos. S50-599

/

l (Carroll County Site)

)

S50-600 CERTIFICATE OF SERVICE I, John W.

Cox, Jr., hereby certify that copies of " LIST OF CONTENTIONS" filed by THE JO DAVIESS COUNTY AD HOC COMMITTEE ON NUCLEAR ENERGY INFORMATION in the above captioned proceeding have been mailed to the following addresses by deposit in the United States mail, first class, this 3rd day of September, A.D.1979:

John F. Wolf, Esq., Chairman Nancy J. Bennett, Asst. Atty. Gen.

3409 Shepard Street Environmental Control Division Chevy Chase, Maryland 20015 188 West Randolf, Suite 2315 Chicago, Illinois 60601 Mr. Glenn O. Bright Atomic Safety and Licensing Bd. Mr. Jim Dubert U.S.N.R.C.

Iowa Socialist Party Washington, D.C. 20555 2801 1/2 West Street Ames, Iowa 50010 Dr. Robert L. Holton School of Oceanography Atomic Safety and Licensing Oregon State University Board Panel Corvallis, Oregon 97331 U.S. Nuclear Regulatory Commission Washington, D.C.

20555 Thomas J. Miller, Esq.

a *

• m n m, noneral of Iowa Atomic Safety and Licensing

~

scare 7 apital complex Appeal 9oard Panel DesMoines, Iowa 50319 U.S. Nuclear Regulatory Commission Philip P.

Steptoe, Esq.

ISHAM, LINCOLN & BEALE Docketing and Service Section One First National Plaza, 42 Fl. Office of the Secretary Chicago, Illinois 60603 U.S. Nuclear Regulatory Commission Washington, D.C.

20555 Mr. James C.

Schwab, State Coord.

Iowa Public Interest Research Group, Inc.

36 Memorial Union, Iowa State Univ.

Ames, Iowa 50010

\\

c4 _ (

~

C'ox, Jr., jifs.,Cyairman Jo g d.

THE JO DAVIESS COUNT' AIOC COMMITTEE ON NUCLEAR ENERGY INFO.