Supplementary Brief for Contention 9 Re Solar Energy.Details Geographical & Meteorological Basis to Establish Credibility & Gain Admissibility for Early Site Review.Certificate of Svc EnclML19210E858 |
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05000599, 05000600 |
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Issue date: |
11/14/1979 |
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From: |
Schwab J IOWA PUBLIC INTEREST RESEARCH GROUP |
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References |
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NUDOCS 7912130098 |
Download: ML19210E858 (3) |
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Category:BRIEFS
MONTHYEARML19320A6471980-06-27027 June 1980 Brief in Opposition to Citizens Against Nuclear Power Et Al Appeal from ASLB 800530 Order Re Denial of Contentions 1,2, 4-11 & 13.Early Site Review Need Not Include Full Review Required Under Nepa.W/Contentions & Certificate of Svc ML19210E8581979-11-14014 November 1979 Supplementary Brief for Contention 9 Re Solar Energy.Details Geographical & Meteorological Basis to Establish Credibility & Gain Admissibility for Early Site Review.Certificate of Svc Encl ML19225A6711979-06-15015 June 1979 State of Il Brief in Support of Il Opposition to Early Site Review.Review Is Unnecessary,Untimely & Unwarranted. Affidavit & Certificate of Svc Encl 1980-06-27
[Table view] Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEARML20062C2351990-10-22022 October 1990 NRC Staff & Applicant Joint Quarterly Status Rept & Motion to Withdraw Application for Construction Permit & Terminate Proceeding for Carroll County Site.* W/Certificate of Svc. Page Count Encl ML20055F5811990-07-0505 July 1990 NRC Staff & Applicant Joint Status Rept on Carroll County Site in Response to Licensing Board 900612 Memorandum.* NRC Will Rept on Status of Site in Appropriate Joint Quarterly Rept.W/Certificate of Svc ML19351A7301989-12-11011 December 1989 Applicant Response to Memorandum of Aslb.* Advises That Applicant Will Seek to Withdraw Application for CP Due to Cancellation of Plans to Build Facility.W/Supporting Info & Svc List ML20054L9521982-07-0707 July 1982 Memorandum & Order Directing Util Notify ASLB by 820730 Re Util Plans to Continue Early Site Review.Lack of Response Will Result in ASLB Sua Sponte Dismissal of Application W/O Prejudice ML19337A1911980-08-29029 August 1980 Response in Opposition to Citizens Against Nuclear Power,J J Runyon & E Gogol Petition for Review of Aslab 800729 Order Affirming ASLB 800530 Dismissal of Contentions.Const Will Not Be Allowed Prior to Environ Review.W/Certificate of Svc ML19344A7591980-08-15015 August 1980 Petition for Review of Aslab 800729 Decision Affirming ASLB 800530 Denial of Joint Petition to Intervene.Questions Whether Early Site Review Is Major Federal Action Per NEPA & Existing Case Law.Certification of Svc Encl ML19320A6471980-06-27027 June 1980 Brief in Opposition to Citizens Against Nuclear Power Et Al Appeal from ASLB 800530 Order Re Denial of Contentions 1,2, 4-11 & 13.Early Site Review Need Not Include Full Review Required Under Nepa.W/Contentions & Certificate of Svc ML19310A4451980-06-12012 June 1980 Notice of Appeal from ASLB 800530 Order Denying Petition to Intervene ML19310A4521980-06-12012 June 1980 Brief in Form of Pleading in Support of Appeal from ASLB 800530 Order Denying Petition to Intervene.Case Law Demonstrates That Early Site Suitability & Need for Power Are Warranted as Issues.Certification of Svc Encl ML19262B5531979-12-10010 December 1979 Opposes Citizens Against Nuclear Power,Inc 791123 Request to File Second Amended Petition to Intervene.Inexperience Is No Cause for Filing Late Contentions Nor Is Withdrawal of Two Proposed Findings ML19262B5631979-12-10010 December 1979 Opposes Intervenor Jo Daviess County Request to Reconsider Rejected Contentions.Contentions 1b,III & V(a)(1)(2) & Amended Contention Iii(G) Re Fuel & Radwaste Onsite Storage Should Be Dismissed.Certificate of Svc Encl ML19210E8391979-11-28028 November 1979 Requests for Reconsideration of ASLB 791010 Order Re Rejected Contentions.Requests Acceptance of Contentions I (B),Iii (2),III (C) & (G),Iv (6),V (a) (1) & (2).Submits Amended Contentions III (J) & VI ML19210E8761979-11-26026 November 1979 Brief in Lieu of Pleading in Support of E Gogol Standing & Rejected Contentions.Urges Reinstatement of Rejected Contentions 1,2,4,5,7,8,10,11 & 13 Per NEPA Requirements ML19210E8701979-11-26026 November 1979 Second Amended Petition to Intervene.Applicants Failed to Establish That Plum River Fault & Proximity to Stansky Airport & Savanna Army Depot Will Not Affect Site Geologic & Safety Suitability ML19210E8691979-11-26026 November 1979 Memorandum in Support of Motion to File Second Amended Petition to Intervene.Petitioner Standing Was Confirmed by ASLB Following 790919 Prehearing Conference ML19210E8671979-11-26026 November 1979 Motion to File Second Amended Petition to Intervene ML19290B8721979-11-26026 November 1979 Petition for Reconsideration of Intervenors 791107 Oral Motion to Defer Further Consideration of Applicants' Request Re Early Site Review Until President'S Commission Results Are known.Radiation-related Issues Should Be Insured ML19253D0561979-11-26026 November 1979 Request for Reconsideration of ASLB 791010 Order for Enlargement of Hearing Scope & for Acceptance of Previously Filed Contentions.Aslb Should Consider Modified Adjudicatory Procedures & Facts in Case ML19211A0051979-11-23023 November 1979 Response to ASLB 791010 Memorandum & Order Re Special Prehearing Conference.Requests Dismissal or Mod of Some of Intervenors' Contentions Due to Noncompliance W/Regulations. Certificate of Svc Encl ML19276H6411979-11-23023 November 1979 Notice of 791123 Filing of Motion to File Second Amended Petition,Memorandum in Support of Second Amended Petition Filing,Second Amended Petition,Brief in Support of E Gogol Standing & Petition for Reconsideration of Motion to Defer ML19210E8581979-11-14014 November 1979 Supplementary Brief for Contention 9 Re Solar Energy.Details Geographical & Meteorological Basis to Establish Credibility & Gain Admissibility for Early Site Review.Certificate of Svc Encl ML19291B8951979-11-14014 November 1979 Supplementary Brief in Lieu of Pleading Re Contention 9. Submits Detailed Geographical & Meteorological Basis for Contention Re Feasibility Studies of Solar Energy. Certificate of Svc Encl ML19210E1371979-11-0606 November 1979 Motion for Extension Until 791123 to File Brief in Support of Contentions Rejected at 790919 Prehearing Conference. Intervenor Atty Unable to Perform Duties Due to Illness & Another Commitment.W/Affiidavit & Certificate of Svc ML19254F8121979-10-22022 October 1979 Brief Per ASLB Order on Special Prehearing Conference. Requests Reinstatement of Contentions 3(a) & 3(c).Also Requests Advance Notice of Applicants' Negotiations for Property & right-of-way.Certificate of Svc Encl ML19259D2891979-09-10010 September 1979 Response to Supplemental Contentions Filed by State of Il, IA Pirg,Jo Daviess County Ad Hoc Committee on Nuclear Energy Info,Ia Socialist Party,Catholic Worker & Other Petitioners. Certificate of Svc Encl ML19253B3441979-09-10010 September 1979 Suppl to Petition to Intervene Per ASLB Order.Applicant Failed to Meet Environ & Safety Aspect Requirements,Failed to Consider Alternative Sources of Energy & Other Pertinent Factors & Did Not Demonstrate Financial Qualifications ML19209C5091979-09-10010 September 1979 Amended Petition to Intervene & Request for Hearing. Applicant Did Not Adequately Account for Decreased Need for Electricity Due to Use of Alternative Energy Sources by Customers.Unsigned Affidavits & Certificate of Svc Encl ML19209C3801979-09-0404 September 1979 Contentions Submitted as Suppl to Petition to Intervene. Safety & Environ Issues Are Not Resolved or Investigated Fully.Certificate of Svc & Notices of Appearance of Sn Sekuler & Jv Vranken Encl ML19312B6411979-09-0303 September 1979 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 ML19275A3041979-08-13013 August 1979 Answer to IA Pirg 790806 Motion Advising of Schedule Conflict W/Second Day of Special Prehearing Conference,On 790920.Urges ASLB to Maintain Schedule;Ia Pirg Interests Can Be Concluded on First Day.Certificate of Svc Encl ML19209A2151979-08-0606 August 1979 Motion to Defer 790919-20 Special Prehearing Conference Because of Conflicting Commitment.Requests Postponement or Changing Second Day of Conference to 790921.Certificate of Svc Encl ML19253A7051979-07-25025 July 1979 Motion to Defer Special Prehearing Conference Scheduled on 790815-16 by ASLB 790710 Order.Deferral Is Requested Until Early Sept.Discovery of Vital Info Has Begun & Delay Will Allow Refinement of Contentions.W/Certificate of Svc ML19247B2011979-07-12012 July 1979 Applicant Answer to J Runyon,E Goge & Citizens Against Nuclear Power 790706 & Jl Priske 790625 Petition to Intervene.Suggests Limited Participation of J Runyon Et Al & Denial of J Priske.W/Certificate of Svc ML19247B2301979-07-12012 July 1979 Petition for Intervention & Request for Hearing Filed Pro Se & as Representatives of Citizens Against Nuclear Power. Affidavits Encl ML19247B2061979-07-0303 July 1979 Applicant Response to State of Il 790615 Brief Opposing Early Site Review.Urges Rejection of Il Request That Review Not Be Undertaken at This Time.Certificate of Svc Encl ML19246C0051979-06-20020 June 1979 Comm Ed Answers to Petitions to Intervene Filed by People of Il,State of Ia,J Davies County Ad Hoc Committee on Nuclear Energy Info,Ia Pirg,Et Al & IA Socialist Party. Certificate of Svc Encl ML19225A6711979-06-15015 June 1979 State of Il Brief in Support of Il Opposition to Early Site Review.Review Is Unnecessary,Untimely & Unwarranted. Affidavit & Certificate of Svc Encl ML19225A6271979-06-15015 June 1979 Notification of Filing of State of Il 790615 Brief in Support of Il Opposition to Early Site Review ML19241B0571979-06-0505 June 1979 Petition to Intervene in Hearings Re CP Application & Request for Early Site Review.Plant Would Have Negative Land Use Effort on Area & Would Harm Local Economy ML19246B4411979-06-0404 June 1979 Notice of Filing of State of Il Opposition to Early Site Review ML19246B4471979-06-0404 June 1979 State of Il Opposition to Early Site Review.Necessity of Present & Future Const Is Being Investigated by Il Commerce Commission.Affidavit & Certificate of Svc Encl ML19225A4411979-06-0404 June 1979 Notification of Appearance on Behalf of State of Il ML19269E3841979-06-0101 June 1979 Petition to Intervene Re CP Application.Seeks to Present Evidence Re Safety Issues,Geology,Hydrology,Weather Conditions,Aesthetics & Other Considerations.Affidavit & Certificate of Svc Encl ML19276G5691979-06-0101 June 1979 Petition to Intervene.Catholic Worker of Dubuque,Dubuque Fellowship of Reconciliation,Environ Coordinating Organization & Carroll County Environ Coalition Join in Petition.Affidavits & Certificate of Svc Encl ML19263E8831979-05-30030 May 1979 Notifies of Limited Appearance,Per 10CFR2 & 790501 Hearing Notice.Reserves Right to Intervene If Interests Are Adversely Affected ML19269D9891979-05-24024 May 1979 Answer by Applicant to 790504 Fr Notice Re Hearing for Early Site Review.Seeks Inclusion of Seismology,Environ & Safety Findings,Heat Dissipation Sys & Site Alternatives. Notices of Appearance & Certificate of Svc Encl 1990-07-05
[Table view] |
Text
\;w_~~ 'UNITED STATES OF AMERICA
-NUCLEAR REGULATORY COMMISSION j\In the Matter of
)Comonwealth Edison Company
).'Interstate Power Company
)Docket Nos. S-599
' '- -> _J s Iowa-Illinois Gas and Electric
)S-600 Company)Carroll County Site November 14, 1979 SUPPLEMENTARY BRIEF 0F IOWA PIRG CONCERNING CONTENTION NO. 9 It is impossible before November 23, 1979, for. Iowa PIRG to gather data to prove its contention in any conclusive fashion.
Iowa PIRG assumes, however, that at this point, some detailing of the geograph4al and meteorological basis for its contention will suffice to establish its credibility and gain its admissibility for the early site review.
Feasibility studies of solar energy in this part of the nation have tended to indicate a special effectiveness of these types of heating systems in the winter. The flat prairie states lying east of the Rocky Mountains are areas of relatively high winds during wi nter. They are also areas where the coldest winter days are generally cloudless, allowing the greatest amount of insolation, and thus offsetting the greater strain on solar heating systems under such conditions. By contrast, cloudy days in winter in the area are very frequently warmer, largely because of the atmospheric insulating effect of the cloud layer, which inhibits dissipation of the heat trapped beneath the cloud layer.
Indications are that, insofar as this relationship of solar heating effectiveness to winter weather patterns would be affected by the visible natural draft cooling tower plumes frcm the Carroll County Station, the detrimental effect would exceed that described in Table 5.1-1, CCS-SS-ER. Such plume effects are more likely to be induced in cold weather, and so far as Iowa PIRG can determine now, more likely than average yearly figures would indicate, to impair the solar effectiveness pattern described above. Due to the lack of an adequate operating model in Iowa or Illinois currently, Iowa PIRG is still researching patterns at other reactors elsewhere, which may provide a better benchmark.
Iowa PIRG expects that evidence, as it develops, to be part of the process of discovery and evidentiary hearings at a later time.
1543 240 79 m so D 9 Er G
',-2-It is clear that most of the surrounding area of Carroll County consists of agricultural land. Two public schools are also nearby.
In evaluating the.affected solar potential, it will be important to bear in mind the time frame for operation of Carroll County Station, a period roughly from 1990 - 2020, unless further delays in construction or the need for its power materialize.
President Carter has set a goal of 20% of our energy being derived from the sun by the end of the century. Many knowledgeable solar advocates believe we may achieve 33%.
In any case, it is clear that the agricultural sector of our economy, due both to its sociological and technological peculiarities, and economic pressures, will often be laading the way in the conversion to solar energy.
This is already the case in much of Iowa and Illinois, with the use of solar crop drying, renewed interest in windmills, alcohol fuels, and solar heating and cooling and cooling (including barns and feedlots) .
Interest in solar greenhouses is mushrooming.
Iowa PIRG's contention will be supported with careful calculation by its own staff and possible expert witnesses of the likely and feasible uses of solar energy oring theoperating life of the reactors.
Iowa PIRG notes an almost total lack of awareness of such data by the Applicant, and avers that admissibility of its contention will add to the fullness and completeness of the record of the early site review.Iowa has perhaps the most advanced record in the solar energy field in the Midwest. Against that background, it is worth noting that sales of solar equipment for many manufacturers have quadrupled annually for the last five years. While such growth curves are no more likely to continue indefinitely than were the original projections for nuclear electricity, they will have a significant impact that needs to be considered via this contention.
In addition to the agricultural sector, Iowa PIRG also notes that the greatest plume drifts due to wind directions will affect potential urban uses, of some economic values, to the NNE, NE, and NW, primarily parts of Mount Carroll and Savanna, according to Table 5.1-1, and the available maps. Also, directly to the northwest, approximately one kilometer, lies the Plum Grove School.
Financially hard-pressed schools can be expected to move toward solar heating in the future as a means of saving money.
Respectfully submitted, of d$fdamesC.Scnwab Director, Iowa PIRG
_1543 241
..UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
))COMMONWEALTH EDISON COMPANY,)Docket Nos. S-599 et al.)S-600 arroll County Site)
CERTIFICATE OF SERVICE I, James C. Schwab, hereby certify that copies of " Supplementary Brief of Iowa PIRG Concerning Contention No. 9" in the above-captioned proceeding have been served on the following by deposit in the United States mail, first class, this 14th days of November,1979.
John F. Wolf, Esq., Chaiman Mr. Jim Dubert 3409 Shepherd Street Iowa Socialist Party Chevy Chase, Maryland 20015 129 Ash Street Ames, Iowa 50010 Mr. Glenn 0. Bright Atomic Safety and Licensing Board Atomic Safety and Licensing Board Panel U.S. Nulear Regulatory Comission U.S. Nuclear Regulatory Comission Washington, D.C.
20555 Washington, D.C.
20555 Dr. Robert L. Holton Atomic Safety and Licensing Appeal Board Panel School of Oceanography U.S. Nuclear Regulatory Comission Oregon State University Washington, D.C.
20555 Corvallis, Oregon 97331 Docketing and Service Section Office of the Secretary Richard J. Goddard, Esq.
-Office of the Executive Legal U.S. Nuclear Regulatory Comission Drector,9604 MNBB Washington, D.C.
20555 U.S. Nuclear Regulatory Comission Washington, D.C.
20555 Thomas J. Miller Attorney General of Iowa Philip P. Steptoe, Esq.
State Capitol Complex Isham, Lincoln and Beale Des Moines, Iowa 50319-One First National Plaza 42nd Floor Mr. John W. Cox, Jr.
Chicago, Illinois 60603 'Jo Daviess County Ad Hoc Comittee on Nuclear Energy Information Nancy J. Bennett 906 Campbell Street Assistant Attorney General Galena, Illinois 61036 Environmental Control Division 188 West Randolph, Suite 2315 Mr. James L. Runyon Chicago, Illinois 60601 1316 - Second Avenue P.O. Box 307
- Rock Island, Illinois 61201.b fY ntk._4} }4}l3/ James C. Schwab