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Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEARML20054F5991982-06-14014 June 1982 Response Supporting Util 820419 Motion to Withdraw CP Application W/O Prejudice & Opposing Award of Costs & Attys Fees to Intervenor.Expenses Resulted from Intervenor Actions.Certificate of Svc Encl ML20053D2351982-05-28028 May 1982 Reply Opposing Intervenor 820429 Response to Util 820419 Motion to Withdraw Application for Cps.Application Should Be Dismissed W/O Prejudice & Util Should Not Be Required to Pay Intervenor Costs & Atty Fees.Certificate of Svc Encl ML20052F9151982-05-10010 May 1982 Response Opposing Applicant Motion for Leave to File Reply. No New Issues Raised in Response & Mere Fact Motion Superficial Not Valid Reason for Allowing Reply ML20052E5541982-05-0606 May 1982 Motion for Leave to File Reply to Intervenor 820429 Response to Util Motion to Withdraw Application for CPs W/O Prejudice.Factual & Legal Arguments in Intervenor Response Could Not Be Anticipated.Certificate of Svc Encl ML20052C7221982-04-29029 April 1982 Response to Applicant Motion to Withdraw.Proceeding Should Be Dismissed W/Prejudice & Costs,Fees & Expenses Paid by Applicant.Certificate of Svc Encl ML20054E1661982-04-21021 April 1982 Notice of Appearance in Proceeding.Certificate of Svc Encl ML20054E0491982-04-19019 April 1982 Motion to Withdraw Application for CPs W/O Prejudice. Intervenors Failed to Meet Compelling Burden of Justification to Establish Demonstrated Injury in Order to Dismiss Applications W/Prejudice.Certificate of Svc Encl ML20042B2391982-03-19019 March 1982 Motion for Leave to File Reply to Intervenor 820311 Response to Motion to Withdraw Applications.Intervenor Response in Requesting Dismissal Be W/Prejudice Is in Fact Motion for Addl Relief.Certificate of Svc Encl ML20041F7821982-03-11011 March 1982 Response to Applicant Motion to Withdraw.Motion Should Be Granted & Proceeding Terminated W/Prejudice.Applicants Should Pay All Intervenor Costs Including Atty Fees. Certificate of Svc Encl ML20069B9541982-03-0202 March 1982 Motion to Withdraw W/O Prejudice CP Applications.Board of Directors Voted to Withdraw Applications on 820223. Proceedings Should Be Terminated as Moot.Certificate of Svc Encl ML20041C3451982-02-19019 February 1982 Point of Information Notifying All Parties That Any Attempt by Applicant to Salvage Findings Produced by Incomplete Info,Studies & Misleading Pressure & Haste Should Be Rejected.Certificate of Svc Encl ML20040F3761982-02-0303 February 1982 Notice of Appearance in Proceeding ML20040A8261982-01-11011 January 1982 Opposition to Matl in Intervenors' 820106 Response to Aslab 811229 Order & Request to Strike.Info Comparing Lake Level of Lake Norman W/High Rack Lake in Fall 1981 Should Not Be Received by Aslab.Certificate of Svc Encl ML20039E9941982-01-0505 January 1982 Response to Order.Motion to Consider New Evidence & Reopen Record Designation for High Rock Lake Association,Inc Was Incorrect.Info Listed Re Lake Level.Certificate of Svc Encl ML20039C2371981-12-23023 December 1981 Response Opposing Intervenors' 811208 Motion to Consider New Evidence & Reopen Proceeding.Motion Fails to Meet Stds for Reopening Proceeding.New Evidence Is Unsupported Allegation of Recreational Use.Certificate of Svc Encl ML20062M2061981-12-0808 December 1981 Motion to Consider New Evidence & Reopen Proceedings.New Evidence Consists of Extensive Use of High Rock Lake During Fall & Lack of Any Rule Re Curve Protection.Certificate of Svc Encl ML20008G1181981-05-0505 May 1981 Response Transmitting Replies to ASLB 810428 Order Which Inquired Into Impact Conclusions in 810402 Nucleonics Week Rept Might Have on Future Plans.Replies Were Previously Submitted for Similar Requests.W/Certificate of Svc ML19343D6101981-04-30030 April 1981 Response in Opposition to Intervenor 810416 Pleading. Commission Regulations Prohibit Response,So Pleading Should Be Stricken.Item 3 of D Springer 810412 Ltr to J Buck Should Be Stricken as Addl Rebuttal.Certificate of Svc Encl ML20003F6751981-04-16016 April 1981 Intervenors' Response.Use of Site More than one-half Mile North of Other Two Sites Was Prejudicial to Site Comparison W/Facility ML19345G8841981-04-13013 April 1981 Response in Opposition to Intervenor 810401 Motion to Reopen Record.Motion Is Untimely & Lacks Showing of Good Cause. Intervenor Allegation Insignificant & Would Not Alter Result ML19345G8871981-04-10010 April 1981 Affidavit Re Maps Submitted W/Intervenor 810401 Motion for Reopening of Record.Maps Portray Same Sites Visited by Applicant,Nrc & Intervenor Representatives.Certificate of Svc Encl ML20126H5041981-03-31031 March 1981 Motion That Proceedings Be Reopened Due to Improper Identification & Portrayal of Lake Norman.Certificate of Svc Encl ML20002E1381981-01-21021 January 1981 Motion for Extension to Set Oral Argument on Alternative Site Issue for 810401.Certificate of Svc Encl ML19340D9451980-12-31031 December 1980 Brief in Opposition to Intervenor 800829 Exceptions to ASLB 800222 Partial Initial Decision 3 Holding No Obviously Superior Alternative Site Exists.Decision Should Be Affirmed.Certificate of Svc Encl ML19345B3001980-11-24024 November 1980 Request for Extension Until 801231 to File Brief Supporting 801028 Exceptions Due to Heavy Case Load.Certificate of Svc Encl ML19339B0261980-10-28028 October 1980 Exceptions & Notice of Appeal from ASLB 800222 Partial Initial Decision Approving Alternate Site Analysis. Uncontradicted Evidence of Water Defect Was Disregarded by Aslb.Certificate of Svc Encl ML19337A4761980-09-24024 September 1980 Responsive Brief in Opposition to D Springer 800902 Notice of Appeal from ASLB 800814 Order Denying Petition to Intervene.Urges Affirmation of Order Due to Unjustifiable Late Intervention.Certificate of Svc Encl ML19338E1751980-09-18018 September 1980 Motion for 30-day Extension to File Brief Re Intervenors' 800829 Exceptions to ASLB 800222 Partial Initial Decision. Counsel Involved in Serious Family Matter.Certificate of Svc Encl.Granted on 800922 ML19338C8021980-09-0202 September 1980 Brief of D Springer in Support of 800415 Petition to Hear Oral Argument Re Opposition to Location of Facilities.No Consideration Given to How Energy,Water & Financial Resources Can Be Conserved.Certificate of Svc Encl ML19338C8011980-09-0202 September 1980 Notice of Appeal from ASLB Order Denying Appellant 800415 Motion.Nrc Misrepresented to ASLB State Position Re Availability of once-through-cooling.No Consideration Given to Alternative Sites ML19331D8761980-08-29029 August 1980 Notice of Appeal from ASLB 800222 Partial Initial Decision Re Alternative Sites.Seeks Exceptions Re ASLB 780717 Order Which Limited Reopening of Record to Evidence Re Staff Analysis of Site Alternative.Certificate of Svc Encl ML19331B9871980-08-0606 August 1980 Brief in Support of 800415 Petition to Intervene.Relies on Appalachian Vs Train Re Finding That Cooling Lakes Are Best Technology Available Per Epa.Urges Participation as Matter of Discretion.Certificate of Svc Encl ML19320A6591980-06-27027 June 1980 Request for 30-day Extension to File Brief in Support of D Springer 800415 Petition to Intervene & Request for Hearing.Certificate of Svc Encl ML19318B3281980-06-23023 June 1980 Response in Opposition to Intervenors' 800606 Motion to Reconsider or Reopen Record.Applicant Has Already Opposed D Springer Petition & Affidavit,On Which Intervenors' Motion Was Based,As Untimely & Unsupported.Certificate of Svc Encl ML19318A7801980-06-18018 June 1980 Response in Opposition to Intervenors' 800611 Motion for Addl Time to File Exceptions to ASLB 800222 Partial Initial Decision Re Alternate Site Issue.Motion Is Based on Springer Affidavit Which Was Opposed by Util.W/Certificate of Svc ML19312F0081980-06-11011 June 1980 Motion for Extension Until 800825 or After to File Exceptions to ASLB 800222 Partial Initial Decision.Awaited Resolution of Petition to Reopen Record Based on D Springer Affidavit May Make Appeal Unnecessary.W/Certificate of Svc ML19316B0951980-06-0909 June 1980 Response in Opposition to D Springer 800415 Affidavit Re 800415 Petition Requesting 60-day Extension to File Documents Supporting Allegations.Adheres to 800509 Position. Certificate of Svc Encl ML19316B1261980-06-0606 June 1980 Motion to Reconsider ASLB 800222 Decision or to Reopen Record Due to Reasons Stated in D Springer Affidavit. Certificate of Svc Encl ML19318A3001980-05-21021 May 1980 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 ML19323G7751980-05-0909 May 1980 Response in Support of D Springer Petition to Intervene.Addl Info May Be Helpful in Reaching Proper Decision.Certificate of Svc & Supporting Documentation Encl ML19316B1871980-05-0909 May 1980 Response in Opposition to D Springer 800415 Petition to Intervene.Intervenor Advanced Grounds That Have Been Previously Rejected in 1976-77 Petitions.Petition Untimely & Unsupported by Facts.Certificate of Svc Encl ML19323F4911980-04-30030 April 1980 Request for Extension Until 800509 to Respond to D Springer 800415 Petition to Intervene.Petition Was Served at Old Address of Counsel.Certificate of Svc Encl ML19309G5561980-04-15015 April 1980 Petition to Intervene Requesting Appointment of Special Staff to Represent Public Interest W/Integrity.Alleges That Position of State of Nc Was Willfully & Knowingly Misrepresented.Certificate of Svc Encl ML19254F8701979-10-16016 October 1979 Reply in Opposition to Applicant 791009 Response.Nrc re-examination of 790924 Pleading Issues Requires Full Hearing.Decision on Alternate Site & Generic Safety Matters Is Premature.Certificate of Svc Encl ML19210B7691979-10-0909 October 1979 Response to NRC 790924 Motion for Prehearing Conference.No Prehearing Conference Needed Until Completion of TMI Investigations.Certificate of Svc Encl ML19254E0611979-09-27027 September 1979 Motion Requesting Opportunity to Respond to NRC 790924 Pleading Directed to Intervenors' Motion to Dismiss or to Stay Proceedings.States Commitment to File Response on or Before 791009.Certificate of Svc Encl ML19209D2621979-07-26026 July 1979 Affidavit Attesting That Purpose of 790615 Testimony Was to Discuss Util long-range Const Schedules & Plans. Ascertains That No Changes Have Occurred in Util Willingness to Build Facility ML19249E9161979-07-25025 July 1979 Applicant Opposition to Intervenor Motion to Dismiss Proceedings Or,In Alternative,To Stay Action.Draft Affidavit by Wh Owen & Certificate of Svc Encl ML19289E9281979-04-18018 April 1979 Opposes Intervenors' 790305 Motion to Reopen Record & Defer Indefinitely Issuance of Initial Decision on Generic Safety Issue Considerations.Certificate of Svc Encl ML19289F0341979-03-21021 March 1979 Opposes Intervenors 790305 Motion to Reopen Record for Addl Hearing.Requests Initial Decision Be Issued. Certificate of Svc Encl 1982-06-14
[Table view] Category:PLEADINGS
MONTHYEARML20054F5991982-06-14014 June 1982 Response Supporting Util 820419 Motion to Withdraw CP Application W/O Prejudice & Opposing Award of Costs & Attys Fees to Intervenor.Expenses Resulted from Intervenor Actions.Certificate of Svc Encl ML20053D2351982-05-28028 May 1982 Reply Opposing Intervenor 820429 Response to Util 820419 Motion to Withdraw Application for Cps.Application Should Be Dismissed W/O Prejudice & Util Should Not Be Required to Pay Intervenor Costs & Atty Fees.Certificate of Svc Encl ML20052F9151982-05-10010 May 1982 Response Opposing Applicant Motion for Leave to File Reply. No New Issues Raised in Response & Mere Fact Motion Superficial Not Valid Reason for Allowing Reply ML20052E5541982-05-0606 May 1982 Motion for Leave to File Reply to Intervenor 820429 Response to Util Motion to Withdraw Application for CPs W/O Prejudice.Factual & Legal Arguments in Intervenor Response Could Not Be Anticipated.Certificate of Svc Encl ML20052C7221982-04-29029 April 1982 Response to Applicant Motion to Withdraw.Proceeding Should Be Dismissed W/Prejudice & Costs,Fees & Expenses Paid by Applicant.Certificate of Svc Encl ML20054E0491982-04-19019 April 1982 Motion to Withdraw Application for CPs W/O Prejudice. Intervenors Failed to Meet Compelling Burden of Justification to Establish Demonstrated Injury in Order to Dismiss Applications W/Prejudice.Certificate of Svc Encl ML20042B2391982-03-19019 March 1982 Motion for Leave to File Reply to Intervenor 820311 Response to Motion to Withdraw Applications.Intervenor Response in Requesting Dismissal Be W/Prejudice Is in Fact Motion for Addl Relief.Certificate of Svc Encl ML20041F7821982-03-11011 March 1982 Response to Applicant Motion to Withdraw.Motion Should Be Granted & Proceeding Terminated W/Prejudice.Applicants Should Pay All Intervenor Costs Including Atty Fees. Certificate of Svc Encl ML20069B9541982-03-0202 March 1982 Motion to Withdraw W/O Prejudice CP Applications.Board of Directors Voted to Withdraw Applications on 820223. Proceedings Should Be Terminated as Moot.Certificate of Svc Encl ML20040A8261982-01-11011 January 1982 Opposition to Matl in Intervenors' 820106 Response to Aslab 811229 Order & Request to Strike.Info Comparing Lake Level of Lake Norman W/High Rack Lake in Fall 1981 Should Not Be Received by Aslab.Certificate of Svc Encl ML20039E9941982-01-0505 January 1982 Response to Order.Motion to Consider New Evidence & Reopen Record Designation for High Rock Lake Association,Inc Was Incorrect.Info Listed Re Lake Level.Certificate of Svc Encl ML20039C2371981-12-23023 December 1981 Response Opposing Intervenors' 811208 Motion to Consider New Evidence & Reopen Proceeding.Motion Fails to Meet Stds for Reopening Proceeding.New Evidence Is Unsupported Allegation of Recreational Use.Certificate of Svc Encl ML20062M2061981-12-0808 December 1981 Motion to Consider New Evidence & Reopen Proceedings.New Evidence Consists of Extensive Use of High Rock Lake During Fall & Lack of Any Rule Re Curve Protection.Certificate of Svc Encl ML20008G1181981-05-0505 May 1981 Response Transmitting Replies to ASLB 810428 Order Which Inquired Into Impact Conclusions in 810402 Nucleonics Week Rept Might Have on Future Plans.Replies Were Previously Submitted for Similar Requests.W/Certificate of Svc ML19343D6101981-04-30030 April 1981 Response in Opposition to Intervenor 810416 Pleading. Commission Regulations Prohibit Response,So Pleading Should Be Stricken.Item 3 of D Springer 810412 Ltr to J Buck Should Be Stricken as Addl Rebuttal.Certificate of Svc Encl ML20003F6751981-04-16016 April 1981 Intervenors' Response.Use of Site More than one-half Mile North of Other Two Sites Was Prejudicial to Site Comparison W/Facility ML19345G8841981-04-13013 April 1981 Response in Opposition to Intervenor 810401 Motion to Reopen Record.Motion Is Untimely & Lacks Showing of Good Cause. Intervenor Allegation Insignificant & Would Not Alter Result ML20126H5041981-03-31031 March 1981 Motion That Proceedings Be Reopened Due to Improper Identification & Portrayal of Lake Norman.Certificate of Svc Encl ML20002E1381981-01-21021 January 1981 Motion for Extension to Set Oral Argument on Alternative Site Issue for 810401.Certificate of Svc Encl ML19345B3001980-11-24024 November 1980 Request for Extension Until 801231 to File Brief Supporting 801028 Exceptions Due to Heavy Case Load.Certificate of Svc Encl ML19339B0261980-10-28028 October 1980 Exceptions & Notice of Appeal from ASLB 800222 Partial Initial Decision Approving Alternate Site Analysis. Uncontradicted Evidence of Water Defect Was Disregarded by Aslb.Certificate of Svc Encl ML19338E1751980-09-18018 September 1980 Motion for 30-day Extension to File Brief Re Intervenors' 800829 Exceptions to ASLB 800222 Partial Initial Decision. Counsel Involved in Serious Family Matter.Certificate of Svc Encl.Granted on 800922 ML19320A6591980-06-27027 June 1980 Request for 30-day Extension to File Brief in Support of D Springer 800415 Petition to Intervene & Request for Hearing.Certificate of Svc Encl ML19318B3281980-06-23023 June 1980 Response in Opposition to Intervenors' 800606 Motion to Reconsider or Reopen Record.Applicant Has Already Opposed D Springer Petition & Affidavit,On Which Intervenors' Motion Was Based,As Untimely & Unsupported.Certificate of Svc Encl ML19318A7801980-06-18018 June 1980 Response in Opposition to Intervenors' 800611 Motion for Addl Time to File Exceptions to ASLB 800222 Partial Initial Decision Re Alternate Site Issue.Motion Is Based on Springer Affidavit Which Was Opposed by Util.W/Certificate of Svc ML19312F0081980-06-11011 June 1980 Motion for Extension Until 800825 or After to File Exceptions to ASLB 800222 Partial Initial Decision.Awaited Resolution of Petition to Reopen Record Based on D Springer Affidavit May Make Appeal Unnecessary.W/Certificate of Svc ML19316B0951980-06-0909 June 1980 Response in Opposition to D Springer 800415 Affidavit Re 800415 Petition Requesting 60-day Extension to File Documents Supporting Allegations.Adheres to 800509 Position. Certificate of Svc Encl ML19316B1261980-06-0606 June 1980 Motion to Reconsider ASLB 800222 Decision or to Reopen Record Due to Reasons Stated in D Springer Affidavit. Certificate of Svc Encl ML19323G7751980-05-0909 May 1980 Response in Support of D Springer Petition to Intervene.Addl Info May Be Helpful in Reaching Proper Decision.Certificate of Svc & Supporting Documentation Encl ML19323F4911980-04-30030 April 1980 Request for Extension Until 800509 to Respond to D Springer 800415 Petition to Intervene.Petition Was Served at Old Address of Counsel.Certificate of Svc Encl ML19254F8701979-10-16016 October 1979 Reply in Opposition to Applicant 791009 Response.Nrc re-examination of 790924 Pleading Issues Requires Full Hearing.Decision on Alternate Site & Generic Safety Matters Is Premature.Certificate of Svc Encl ML19210B7691979-10-0909 October 1979 Response to NRC 790924 Motion for Prehearing Conference.No Prehearing Conference Needed Until Completion of TMI Investigations.Certificate of Svc Encl ML19254E0611979-09-27027 September 1979 Motion Requesting Opportunity to Respond to NRC 790924 Pleading Directed to Intervenors' Motion to Dismiss or to Stay Proceedings.States Commitment to File Response on or Before 791009.Certificate of Svc Encl ML19249E9161979-07-25025 July 1979 Applicant Opposition to Intervenor Motion to Dismiss Proceedings Or,In Alternative,To Stay Action.Draft Affidavit by Wh Owen & Certificate of Svc Encl ML19289E9281979-04-18018 April 1979 Opposes Intervenors' 790305 Motion to Reopen Record & Defer Indefinitely Issuance of Initial Decision on Generic Safety Issue Considerations.Certificate of Svc Encl ML19289F0341979-03-21021 March 1979 Opposes Intervenors 790305 Motion to Reopen Record for Addl Hearing.Requests Initial Decision Be Issued. Certificate of Svc Encl ML20062H0131979-03-0505 March 1979 Intervenors' Motion to Reopen Record & for Addl Hearings Re Reactor Safety & Geological Study.Further Suppl Proposed Findings of Fact Proposed Conclusions of Law. Certificate of Svc Encl ML19284A6161979-02-13013 February 1979 Resolution Opposing Licensing & Const of Facility Based on Tremendous Consumption of Water by Cooling Towers & Large Increase in Electricity Rates ML19261A6551979-01-16016 January 1979 Applicant'S Response & Objections to Intervenors' Request for Production of Documents,Interrogatories, & Request to Admit.W/Encl Documents & Certificate of Svc ML19274D4341979-01-0505 January 1979 Petitioners to Intervene High Rock Lake Association Move That 790129 Hearing in Mocksville,Nc Be Continued Until Nc Environ Mgt Commission & State of Nc Determine Issue Re Lake Norman Siting.Ltr & Certificate of Svc Encl ML19259B1731978-12-22022 December 1978 Preliminary Response by Intervenors to Proposed Supplemental NRC Testimony Re Criteria Used to Select & Examine Site Alternatives.Asserts Testimony Is Vague & Incomplete ML19259B1761978-12-22022 December 1978 Request by Intervenors for Production of Documents, Interrogatories & Request to Admit.Interrogatories Concern Site Selection Criteria.Certificate of Svc Encl ML20062E1351978-11-13013 November 1978 Objects to applicant-proposed Hearing Sched & Proposes Another.Believes It Only Fair That Some Percentage of Time Created by Applicant'S Delay Should Be Used to Provide Intervenors W/Time.W/Encl Cert of Svc ML20148Q2461978-11-13013 November 1978 NRC Staff Response to Applicant'S Motion to Establish a Hearing Sched. Staff Feels It Is Premature to Set Sched as Requested.Staff Will Address non-ACRS Generic Issues at Next Hearing Session.Cert of Svc Encl ML20062D4101978-11-0707 November 1978 Applicant Dpc'S Motion to Establish a Hearing Sched in Proceedings Re Subj Facil.Dpc Maintains That Since All Evidence Has Now Been Taken & NRC Staff Analysis Issued, Matter Is Now Ripe for ASLB Consideration.Cert of Svc Encl ML20062B5011978-10-10010 October 1978 Request for Admissions & Request for Production of Documents & Interrogatories by Intervenors ML19296A0511978-10-0202 October 1978 Intervenor Appeal from ASLB Partial Initial Decision Holding That Environ Impacts from Ra-222 Releases Associated W/U Fuel Cycle Insignificant in Striking Cost Benefit Balance Re Facilities.Certificate of Svc Encl ML20147B4421978-08-28028 August 1978 Intervenors Comments on the Perkins Record as It Relates to the Problem of the Release of Radon to the Environ from Uranium Milling Oper 1982-06-14
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~ ~, &:. T '4 STATE OF NORTH CAROLINA # ,C ghg7#gk COUNTY OF MONTGOMERY g gy g hs RESOLUTION REGAR0 LNG PROPOSED PERKINS NUCLEAR STATION WE. the MONTGOMERY COUNTY COMMISSIONERS, being concerned with the welfare of our people, the economic growth of our County, the conservation of our water, the protect'~rt of the auality of our water, avoiding increases in electric rates and conservation of energy believe that:
uMEAEAS, our economic growth, our tax base and the health and welfare of every citizen is dependent on an adequate supply of pure water, the cheapest electric rates possible consistent with adequate supply and the conservation of ene r gy , and
'.NEREAS, cooling towers at the proposed Perkins Nuclear Station will:
- a. Consume up to 72 million gallons of our water sucolv a day witi resultant decrease in water quali ty.
The Nuclear Regulatory Cormission Staff found that "A flow of 830 cfs should be adequate to fulfill needs of all present downstream users of this
.ater; w ever, if future water needs for the river grow significantly critical water snortages could develop." We believe Montgomery County will grow signifi-cantly resulting in future critical water shortages.
- b. Cooling towers at Perkins nill cost around 200 million dollars more to build tnan ooen cycle cooling.
Quae Power told the Federal Court that with cooling towers the ac=er requirerents " and penalties mean that about 2% more fuel must be burned ano 3; , ore capacity must be built to supply the same amount of electricity." The Persins Station will cost approximately l+.3 billion dollars with a total cost for cooling towers of a::aroximately 200 million dollars.
- c. scolino towers at Perkins will result in a este incresse accroxi-Tati'a 10-Tre ecoling towers alone will cost rate payers well over 1.5 billion
- .;cliars over t*e life of tne station, according to Marvin Wooten, f o rme r Cha : eran ,
790315011%
o e
N. C. Utilities Commi ssion, Staf f of North Carolina utilities Commission and the Att:rre,s for '4ortn Carolina,
- d. Cooling towers waste energy.
I The proposeo Perkins Station approximately 54 of a 3800 Mw station.
2 6 more fuel must be ourned for technical vaccum proolems and 31 of the energy produced goes to oower the towers. This wasted energy over the life of the Perkins Station amounts to more energy than Duke has sold in nost of ene years l of its eAistence.
- l. Alternate site with once through cooling.
e.
The wel fare of Montgomery County, its tax base, Its water, its future is better served cy economic growth and tne electric rates its citizens must pay
- avoiding these mater and energy wasting, rate escalating cooling towers at Yaakin River Perkins. Duke has sites for a Lake Norman Perkins which Duke in the future Our intends to build using water, rate and energy saving once througn cooling.
rate payers are already paying for this coollag capacity. Duke Power Company and Johns Hopkins University in conjunction with tne N. C. Wildlife Commission 9
estaallsned Lake norman as fully capable of once through cooling the Perkins Station in multiple units of 12SCMw or otherwise.
WHEREAS. studies involving a Yadkin River Perkins Station has not taken into account the probacility of increased consumption of Yadkin River Vaters up-stream ' rom the proposed Perkins Station site which may have an adverse effect upon the operation of the proposed nuclear station if located on the Yaakin River, and whEREAS, fulfillment of the goal of energy consarvation precluding the need for an additional nuclear station is more desirable than the construction and location of the proposed Perkins Station, and WHEREAS, the econometric models used by Duke Power Company in fore-casting tne growth in energy demands have proved to be erroneous as evidenced by Dume Power Company reports to the North Carolina Utilities Commissicn. These reports reflect a lower level of power demand than the levels of cemand originally forecasted - a possible result of energy conservation measures.
\ . - .
NCW. THEREFORE, SE IT RESOLVED THAT:
- 1. The 'tuclear Regulatory Commission is respectfullr requested to fully develop the cost-oenefit analysis of open/ closed cycle cooling for a Perkins Station on Lake Norman as compared to a tower cooled Yadkin-Perkins, and
- 2. The EnvIronnental Management Comission be respectfully request 9d to hold public hearings as to the availability of open cycle cooling at one of j Duke's reserved sites on Lake florman and the cost-benefit of open cycle cooling for a Lake Norman Perkins as compared to a tower cooled Yadkin River Perkins.
This the day of Feeruary, 1979 MONTGOMERY Cout4TY
~ r SY: >
M. Page McAulay, Chairman Montgomery County Board of Commissioners
,' f ATTEST:
7'/ ,
7- // ,
U .i b'V A -y w < &
7nad cranford ~' . \
Clerk to the Board \!
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i (S E A L )
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