ML19337B528
| ML19337B528 | |
| Person / Time | |
|---|---|
| Site: | Callaway  |
| Issue date: | 07/16/1980 |
| From: | MISSOURI, STATE OF |
| To: | |
| Shared Package | |
| ML19337B510 | List: |
| References | |
| NUDOCS 8010020709 | |
| Download: ML19337B528 (140) | |
Text
,
=
r
=
M
~
O.f...
? 1, ;: ^=
.g.
s -
,.9 ; ; o. ',
. -.... s. -.- w
- r...
.a.
s
.w.
w l' * -., a
-wh [T.;,
,
- 7[. J' v[
' ge
- - ~ - *
..q.,:,
~.,.:-
y,.,
9 g...
.3 E
a I
g
- - w
.-.&..~.
~
BEFORE THE MISSOURI DEPARTMENT OF
~
A n.,;t..: L.
s, i
NATURAL RESOURCES COMMISSION i.
, 1
- TRANSCRIPT OF PROCEEDINGS w
~ ~ ~
July 16, 1980 u.
=
.c
- 7...
e$,E N )
~ ~,
s
.f s,...
., t c -
., -. 4 e
ci.e..
I ' P, -
ri.: -
u.
3,.,. _, '
~
.A 4'
gig,..
... c.,
ri x
.c,;
p.
WALLER REPORTING REGISTERED PROFESSIONAL REPORTERS
~
l 621-2571 7 NORTH SEVENTH STREET ST. LOUIS, MO. 63101, 8010020707
=
l 1
2 3
4 BEFORE THE MISSOURI DEPARTMENT OF 5
NATURAL RESOURCES COMMISSION 6
7 TRANSCRIPT OF PROCEEDINGS 8
9 July 16, 1980 10 11 12 13 A g g e,a r a n c_ e_ s_:
14 15 ROBERT J. SCHREIBER, JR.,
P.E.,
Staff Director, Air Pollution 16 Control Program, Division of Environmental Quality a
17 ROBERT H. HENTGES, Chief, Permit Section Water Quality Program 18 i
j 19 ALSO PRESENT:
i l
20 Audience 21 t
E 22 23 24 25 I
7, 1
BE IT REMEMBERED, that on the 16th day of July,1980 2
the herein described parties met at the Parkway Junior High 3
School, Highway 270 and Ladue Road, in the City of Creve Coeur; 4
State of Missouri, and the following proceedings were had, 5
to-wit:
6 7
A g g e a r a n c e s:
8 9
Mr. Dean L. Kothmann.
. Page 5
8 Ms. Lenore Loeb
")
Mr. Chris Wallace.
10 Mr. Gary Hughes 17 11 Ms. Nancy Jane Weaver.
17 Mr. David Harris 23 12 Mr. David Wilson.
26 Ms. Claudia Spencer.
30 13 Mr. Ronald F. Tuttle 33 Mr. Allen Karcher.
38 14 Ms. Bobbie Silverblatt 42 Ms. Marjorie Reilly.
46 15 Ms. Rose Levering.
51 Dr. J. William Hirzy.
58 16 Mr. Byron Clemens.
62 3
Mr. Robert L. James.
68 17 Mr. Gary Adams 73 2
Ms. Paula J. Ayers.
75 18 Mr. Dan I. Bolef..
77 y
Mr. George Sabre.
87 j
19 Mr. Doug Ziegler.
88 e
i I
j 20 J*
21 i:
22 23 24
)-
25.
i MR. SCHREIBER:
Good afternoon, I am Bob Schreiber, 2
Director of the Divistor. of Environmental Quality which is part 1
3 of the Department of Natural Resources.
I will be the Hearing 4
Officer for today's Hearing.
5 The purpose of the Hearing is to receive public comments 6
on the proposed Wastewater Discharge Permit for Union Electric 7
Company's Callaway County Nuclear Power Plant.
The proposed 8
Permit addresses the conventional water pollutants that will 9
be discharged from the plant; radioactive discharges are under 10 the control of the U.S. Nuclear Regulatory Commission and are 11 beyond State jurisdiction.
12 Af ter the Department received the Company's Permit appli-13 cation, a paid legal notice announced the application.
Copies 14 of the June 16 legal notice and the Affidavit of Publication 15 are available at the registration table.
Also available for 16 review are a fact sheet on the application; the public notice;
[
17 and the application itself.
A copy of all these documents will h
18 be part of the public record.
a j
19 At a recent meet with the Governor Forum in South St.
i
[
20 Louis, citizens expressed concern about the effect discharges 3
21 from the nuclear power plant would have on downstream drinking 3
22 water supplies.
Reacting to these concerns, Governor Teasdale 23 called this Hearing to provide an opportunity for the voicing i
24 of these concerns.
)
25 Your facts and comments relating to the conventional pol-l 1
lutants will be taken into consideration as the Department de-2 cides to issue or deny this Permit.
The State's Clean Water 3
Law requires that I reach a decision as' expeditiously as possi-4 ble.
Any decision may be appealed to the Clean Water Commis-s sion.
6 The Governor will personally make sure that the U.S 7
Nuclear Regulatory Commission receives any facts or comments 8
relating to radioactive discharges.
9 L
- purpose of this Hearing is to accept public testimony l
to This is not an adversary Hearing.
There will be no cross-exam-1 11 ination of those who testify.
Neither will 'the staff respond 12 to questions.
13 I must ask t'.at each person's comments be donfined to a 14 maximum of 15 minutes.
Before beginning your statement, please 15 clearly state and spell your name for the Court Reporter.
16 Written comments may be submitted up to the close of the 17 Hearing tonight.
18 g
Representatives from the Union Electric Company and the 2
19 U.S. Nuclear Regulatory Commission have been invited to be here ij 20 to accept your testimony.
My staff is also in attendance.
f 21 Transcripts of today's proceedings may be ordered from i'
22 the Court Reporter, Ms. Georganne Baker.
23 I would appreciate it if everyone attending the Hearing signs an attendance card.
I would also appreciate it if there 24 25 was no smoking..
This Hearing, which is being held in accordance with Sec-2 tion 204.051-4 of Missouri Statutes, will now proceed.
3 The first person that has requested to be heard is a 4
Mr. Dean L. Kothmann.
5 MR. KOTHMANN:
I am Dean,'D-e-a-n, Kothmann, K-o-t-h-6 m-a-n-n.
My educational background is in engineering.
I am 7
here as President of the Missouri Voice of Energy.
My state-8 ment reflects the views of Missouri Voice of Energy and of many 9
of my fellow citizens on the permitting of~the waste water 10 treatment facility for the Callaway County Nuclear Power Plant.
11 The Missouri Department of Natural Resources Hearing of 12 testimony today is inconsistent with its conservation policies, 13 not relevant to the Water Act and is simply a platform for a 14 media event for those trying to stop a badly needed energy 15 facility.
16 First, I wish to comment on the need for this facility.
I g
Hundreds have died from the heat wave we are experiencing, and 17 g
this facility is our only insurance that relief will be avail-18 2
l 19 able in 1983.
Despite the high bills we will experience be-i 4
l 20 cause the Public Service Commission has restructured our rates, d;
21 high bills from air conditioning are better than the alterna-i' 22 tive - death or severe discomfort.
23 But I am here to comment on this Hearing.
Your announce-24 ment states this Hearing is to determine if the non-radiological 3
25 discharges from the Callaway Plant are consistent with State 9
codes and if these co' des would cause problems with the drinking 2
water supply for the Metropolitan area of St. Louis.
This 3
should not be a Hearing to provide a platform to discuss 4
radiological information.
The Nuclear Regulatory Commission 5
provides these Hearings.
The requirements you have placed on 6
this plant exceed both Federal and State codes and Union Elec-7 tric accepts them despite their excessiveness.
Stated bluntly, 8
the water discharge will be safe for the Metropolitan area of 9
St. Louis as proved by past experience in the use of these cede s.
10 For this reason, I don't see why Governor Teasdale has called 11 for this Hearing.
12 The job of the Department of Natural Resources is to 13 review and issue permits in a timely manner.
I believe the statutory requirements call for 60 days under the Missouri 14 15 Water Law for you to do your job and issue a permit.
Since 16 Union Electric has met your requirements, why is there a need 17 to have citizens wasting our most precious fuel, petroleum, to g
18 travel here and testify for or against a facility which could j
19 save enough gas to fuel a half a million cars each day.
I i
l 20 figure each individual here will drive at least 30 miles.
That f
is two gallons of gasoline wasted per person because our Gover-21 3
3 22 nor called this Hearing.
23 If we as a nation are to survive, we must get off petro-chemicals and ctop being wasteful.
Our petroleum bill for im-24
-)-
ported oil this year will be nearly 90 billion dollars.
That 25.
D
e 1
is 10 million dollard an hour.
Assuming today's prices cnd e
2 today's oil importation rates, in 12 years the value of the 3
entire New York Stock Exchat,a will have been spent on tmported 4
oil.
5 These type of wasteful meetings and protesting must stop, e
and people must spend their time conserving oil and helping 7
others conserve oil by car-pooling or converting away from oil 8
as a fuel if we are to survive.
We must all start taking con-9 structive actions to solve our oil importation problems.
to We must use more coal and nuclear, and your agency must
{
ii do its part by issuing permits in a timely fashion.
Your delay l
12 in issuing this Permit could cost the citizens of Missouri mil-l 1
13 lions of dollars.
For instance, if permitting on a nuclear i4 plant could be reduced and subsequent start-up would occur four 15 years earlier, the plant would cost half a billion dollars less.
16 Why did the Governor order this Hearing?
Was it to raise 2
h 17 our rates or waste petroleum?
As a ratepayer, a concerned citi is zen and President of the Missouri Voice of Energy, I plead for 5
ig you to issue this Permit because 1) the water this plant will discharge is within State and Federal codes and is safe, 2) we 20 d
need insurance of an adequate energy supply in 1983 and this 21 i
lP ant is our only method of insurance, and 3) you issuing this r
22 Permit on a timely basis will help the rate payers from suffer-23 ing fr m rate increases which would be caused by your delayed 24
)-
acti ns.
25.
-.4.4
e b
1 MR. SCHREIBER:
Thank you, Mr. Kothmann.
Mrs. Lenora 2
Loeb.
3 MS. LOEB:
My name is Lenore Loeb, L-e-n-o-r-e, Loeb, 4
L-o-e-b.
I'm speaking in behalf of the League of Women Voters 5
of Missouri, Our membership numbers approximately 2,000 in 6
the State.
7 League members believe that special attention must be 8
given to health and safety problems associated with nuclear 9 lltission.
We must be assured that radioactive discharges do to not contaminate our drinking water.
11 When the League of Women Voters evaluates any government 12 policy or program, we believe that certain criteria must be 13 met.
Particularly relevant to the government permit program being addressed at today's Hearing, is our firm belief that':
14 15 1.
There must be coordination among agencies and levels 16 of government, and that 17 2.
There must be well-defined cbannels for citizen in-e 18 put and review.
j 19 We are today discussing a program where a Federal agency, ij 20 the Nuclear Regulatory Commission sets standards for radio-3 21 active discharges and issues an operating permit, a private 22 company (Union Electric) produces the radioactive discharges 23 and is also responsible for monitoring same, and non-radioactive 24 discharges are the responsibilities of the State Department of 25 Natural Resources.
The State also administers the National '
~
Pollutant Discharge Elimination System Permit Program, although 2
the discharge includes radioactive components which are a 3
responsibility of the NRC.
Federal and State responsibilities 4
and coordination of efforts are not clear.
In addition, it 5
is not clear to the citizen where in the Permit process he has-
)
6 the opportunity to express his views regarding the potential 7
health hazards of radioactivity and he is not assured by gov-8 ernment that adequate monitoring and reporting of any radio-9 active discharges into his drinking water will take place.
10 The League of Women Voters requests that the Nuclear 11 Regulatory Commission establish clear lines of authority for 12 monitoring radioactive discharge from the Callaway County 13 nuclear power plant.
We recommend that when an operating per-
.)
14 mit is granted, liquid wastes ae independently monitored and 15 regularly reported.
It must also be clear to the citizen which 16 agency will be responsive to his concerns if he questions the g
17 monitoring program.
g The League wishes to thank DNR for providing citizens wit 18 1
a j
19 this opportunity to express our views on the wastewater permit 20 for the Callaway County Nuclear Plant, as well as the Depart-l 21 ment's commitment to forward testimony to the NRC.
22 MR. SCHREIBER:
Thank you.
Chris Wallace.
23 MR. CHRIS WALLACE.
My name is Chris Wallace and I am a 24 graduate student in the Nuclear Engineering Department at the
]-
25 University of Missouri at Columbia.
I received my undergraduate
_9 t
degree in chemistry from Central Methodisc College in June of f - -
2 1979 and I expect to receive my Masters in May of 1981.
3 I would like to examine the health and safety aspects of 4
electric power generation in the context of this particular 5
Hearing; in other words, with respect to.the choices we, as
~
6 citis. ins of the State of Missouri, have in generating base load 7
electrical power for the next thirty years, namely coal and a
nuclear power.
This is the same conclusion reached by the Na-9 tional Academy of Science and Engineering Committee on Nuclear to and Alternative Energy Systems.
11 The attached letter of transmittal from Harvey Brooks and 12 Edward L. Gintzon to Dr. Philip Handler, Chairman of the Na-13 tional Research Council, serves effectively as an executive
)
14 summary of the final report and should elimina.te any confusion 15 or questions as to the rationale of the comparison to be made 16l here.
Unfortunately much of the analysis of nuclear safety 17 issues has not been presented in the broad context of the al-18 ternative choices.
Frankly, it's necessary that we examine g
a j
19 these two alternatives in comparison with one another and for-i l
20 tunately for this consideration a number of such analyses have l
21 become available particularly in the last ten years.
An at-22 tempt will be made here to bring a number of these analyses 23 together and summarize them for your review.'
24 One of the more recent documents examining nuclear power 25 health and safety in the context of the coal aternative is D
I t
1 Nuclear Power Issues and Choices.
Quoting from this report of 2
the Ford Foundation Nuclear Policy Study Group, "The use of 3{ nuclear power to generate electricity inevitably results in i
4 risks to human health.
The extent of these risks is uncertain s
' and the subject of considerable controversy.
To be meaningful-6 in connecting the public policy decisions, these risks cannot 7
be considered in isolation but must be compared With the risks 8
associated with coal-fired power plants which are the principal I
9 alternative for electric power generation for the rest of this to century.
11 The potential means of electrical power generation have 12 to be examined-from four different perspectives:
first, tech-13 nical feasibility within and time-frame in which the added generating capacity is required; second, reliability of the 14 15 technically feasible means; third, cost of generation by the various means; fourth, the future availabilit9 of fuels for the 16 a
g 17 feasible means; and fifth, the health and safety impacts.
Here is we will limit our examination to the first and fifth points.
E ig Historically, fossil fuels including coal, oil and natu-ai cal gas offered the technically feasible means of providing 20 a
f 21 anergy and generation of elemtrical power.
A recent addition i:
22 the technically viable means of electric power generation Lncludes nuclear fission.
Because of increasingly severe 23 ahortages of supply and government mandate, it seems likely 24 25 : hat natural gas and oil will in fact no longer be available for..
O
6 added electrical generating capacity.
2 Coal is the fuel used in generating the major fraction of 3
electrical power in the U.S.
today.
Larger capacity coal-fired 4
systems employing advanced combustion systems in an attempt to 5
achiave improved overall efficiency and reduced emissions are -
6 being designed and constructed.
Che questions of the technical 7
viability of coal concern the practicality of achieving ac-a ceptable emission by-product centrols and containment, estab-9 lishing the necessary t>.ansportation system between the mines 10 and generating stations, and locating, opening and operating N
l 11 the necessary mines.
Emission and by-product control, and con-s 12 tainment will be discussed in detail here.
13 With respect to the control of emissions from fossil plants the primary objectives of controls up to this time has 1-4 15 been directed at relatively large sizes of particulates and is sulfur dioxide.
Particulates are removed from the stack gases 17 using various types of filters or precipitators.
The use of g
18 filters is generally limited to small generating stations, 100 y
j 19 megawatts or less with the electrostatic precipitators used on i
l 20 large stations.
The devices used are generally effective with l
21 routine operating efficiencies over ninety percent on coals with i
22 high sulfur contents (greater than one percent).
With low sul-23 fur (less than 017 percent) coals which also have higher ash 24 contents, precipitators are inefficient.
High ash and low sul-25 fur content cor'eined with reduced precipitator efficiency sig-.
O
Wy nificantly increase the cost of handling the particulates or
')
2 fly ash for plants fired with low sulfur coal.
3 Once the precipitator collected particulates are removed 4
from the stack gases, they must still be disposed of.
For a 5
1000 megawatts station particulate disposal may amount to a 6
volume of 30 or more 100 ton (nominal) coal cars each day.
Thi i
7 material contains lead, telerium, antimony, cadmium, selenium, 8
Zinc, vanadium, arsenic, nickel, chromium, sulfur, berrylium 9
and manganese, concentrated in the smallest particle,1zes, all 10 of which are known to be toxic to man at some low level.
How-11 ever the tolerable body burdens for each of these elements are
'2 unknown.
Disposal of coal wastes will be discussed in :aore de-13 tail later but it would seem prudent that these materials shculd be disposed of in some type of permanent disposal site that 14 15 would prevent release of these materials to the biosphere (a 16 clay pit or other disposal site that would prevent leaching of 17 the toxic materials into the biosphere would be required).
The 18 volume of the material to be disposed of in the 30-year life of i
a 2
19 the plant would be 15,500 acre feet (26 million cubic yards).
i l
20 The State of Illinois is sufficiently concerned with this prob-4l 21 lem that State laws controlling solid waste disposal are being i
22 interpreted to prevent non-contained discharge of fly ash and
~
23 bottom ash to the biosphere.
The cost and design of tne neces-24 sary contained disposal sites are just beginning to be estimated.
25 It should be noted that if precipitators are used they l
l 1
will not prevent significant dissemination of the volatile 2
~-
toxic metals, mercury, lead, arsenic, cadmium, vanadium, seleni-um, antimony, zine and others to the biosphere.
The potential 4
health effects of these materials will be discussed later, It might be expected that the use of a flue gas scrubber ~
6 system would reduce both sulfur and trace element emission from 7
fossil fueled power stations as compared with plants fitted with 8
precipitators only.
However, the lack of proven scrubber tech-8 nology, is preventing the determination of what reductions in "3
trace element emissions might in fact be realized.
The efflu-il ent from scrubbers still has a similar potential for biosphere 12 contamination-as does fly ash.
For a 1000 MWe power plant 13 burning 2 to 2.5 percent sulfur coal over a 30-year life, 6100 14 (9.5 square miles) of storage pit five feet deep would t '
acres 15 required unless effective means of water drainage can be de-16 Veloped.
This acreage would be required in addition to those 17 l
approximately four acres that would be necessary for the coal 18 i
inventory typical of e 1000 megawatts coal-fired station.
' 2 "3
Coal-fired power stations will also yield sulfur and
$j 20 other volatil'e trace elements that can be partially controlled aj 21 with precipitators but the ultimate disposal problem of the c
22 precipitated waste still remains.
Most analyses of the total 23 impact of fossil fueled electrical power generation stations 24 to date have neglected the environmental impact of disposing of 25 precipitated or scrubbed waste.
At the same time extensive,
efforts have been made to evaluate the impact of nuclear elec-
')
2 tric power generation including the total fuel cycle.
3 Much has been written about the potential public health 4
consequences of the improbably nuclear meltdown accident but 5
relatively little attention has been paid to a comparison of 6
the health effects accompanying the routine operation of com-7 mercial fossil fueled stations with the routine operation of 8
nuclear stations or for that matter with the non-routine acci-9 dent situation attending the operation of a nuclear power 10 plant.
Several studies of this type, completed by 1973, indica te 11 that a substantial additional cost should be' levied against the 12 operation of fossil stations to account for health and environ-13 mental effects accompanying routine operation.
Following in
,)
Exhibits 1, 2 and 3, are EPA 1970, estimates of the damages re-14 15 sulting from air pollutants.
In terms of the cost of damage 16 alone, it is expected that the 1970 costs noted would have to 17 be increEsed by a ratio of about 234/126 (ratio of cost indexes in 1979 to 1970) to account just for price increases since 1970 18 j
19 Using the national costs of Exhibit 2 for pollution damage
-20 caused by stationary source fuel combustion, the price index f
21 corrected value is 11.3 billion dollars in 1979.
This estimate 22 does not take into account possible expansion in the number of 23 Pollution sources since 1970 or improvements that might have 24 accurred in pollutant control since 1970.
An estimate published 1
>^
25 by EPA in 1974 shows that damage due to S02 and particulates.
amounts to 11.2 billion dollars per year in 1974 dollars (or 2 14.9 billion dollars in 1979 dollars).
3 In Exhibit 4 following is a comparison between the en-4 vironmental and health effects resulting from the routine opera-6 tion of coal and nuclear power systems based on analyses avail-6 able prior to 1975.
The results for the coal plants assume no 7
control of gaseous and particulate emissions.
Under these con-8 ditions t.he results show substantial costs in both dollars and 9
lives if coal is substituted for nuclear power systems.
These 10 costs should be accounted for in evaluating the total costs of 11 using fossil fuel systems.
Replacing nuclear power capacity 12 with coal-fired systems would cost the lives of about 10 to 100 13 persons each year over those that would be lost if nuclear gen-14 erating systems were used.
These additional deaths would con-15 tinue for the lives of the coal-fired plants, or about 30 years is In addition there would be significant economic losses if the g
17 coal alternative were selected.
It is also worth noting that 18 many of the fatalities and economic losses would occur to per-g:
j 19 sons who derive no direct benefit from the electric power gen-Yj 20 erated; in other words, the pollutants would be carried beyond d;
21 the service area of the persons using the electrical power.
22 In Exhibit 5 are presented results for several model coal--
23 fired electrical ~ generating plants.
These model plants are as-24 sumed to conform to the 1977 EPA source standards through the
-)-
25 use of 99.5% efficient electrostatic precipitators to remove Wk 1
particulates and 907. efficient S02 scrubbers.
In comparing the
~
')..
2 results in Exhibits 4 and 5 unless the coal plants are always 3
shut down when precipitator and/or cerubber efficiency drop be-4 low their respective assumed values of 99.5%-and 90%.
Such 5
shut-downs based on present experienca with scrubber systems 6
would be expected to significantly increase electrical power 7
costs.
8 I would just like to say that in light of what I've just 9
stated here, that waste permit for the Callaway Plant should be 10 issued since I think it should be obvious that the possible
)
11 health effects, if any, are much, much less than the coal al-12 ternative that-would have to be built.
13 Thank you.
14 MR. SCHREIBER:
Mr. Gary Hughes.
15 MR.* GARY HUGHES:
My name is Gary Hughes, G-a-r-y 16 H-u-g-h-e-s.
I've had approximately 11 years of Naval Nuclear e
17 ! training in Nuclear Power Programs, and approximately two years I
18 ~in the commercial end.
I appreciate this time to speak in g
j 19 favor for the Callaway Permit.
Since it's waste water and not a
nuclear we're talking about here, many people have gotten up 20 a
8 21 talking about the pollutants and situation we have here in s:'
22 Missouri, and the necessary power is necessary for us in the 23 next few years.
The alternatives that we have to face is the 24
- oal issue or whatever.
It's estimated that approximately 20
)
25 to 100 deaths each year attribute directly to coal-fired plants
-e
1 ce fcr as the pollutants and the health effects that a person 2
') -
being exposed to a coal-fired plant, and that's only the 3
limited knowledge we know right now.
4 We're doing preliminary studies and trying to find out, 5
at the University of Missouri, what is the effects of acid rain 4
6 and some of the other pollutants.
But that's not known right 7
now.
The nuclear power industry, itself, has done a lot of a
studies both in my experience in the Navy and the commercial 9
nuclear power plant, and the effects are known with some degree of accuracy as far as the standards, the water situation.
10 l
I've operated plants for a long period of time, and the 11 12 waste water is.usually not that stringent of a problem to con-13 sign as long as you know what the standards are, and as the
)
14 standards change, the engineering will comply to filter out any 15 of the environmental waste products.
I don't think it's any 16 real problem in that respect, and I dua't think it's really evea 17 a hazard as to the people of St. Louis.
18 And my conclusion is, that I'm for the Permit and I wish j
19 that they would, you would, quickly approve the Permit so that a
they can go about getting the plant on line and producing power 20 a
8 21 for air conditioning.
i 22 Thank you.
23 MR. SCHREIBER:
Thank you.
24 Ms. Nancy Jane Weaver.
25 MS WEAVER:
My name is Nancy Weaver, N-a-n-c-y W-e-a-v-e-r..-_-
l
I'm e greduate stud:nt of M dical Physica at the Univsrsity of 2
)'-
Missouri, Columbia.
3 I believe that a rather broad con ~sensus does exist that 4
coal produces generally greater health and environmental im-pacts than does nuclear power.
5 6 I This consensus also indicates that there are large un-certainties about the effects of coal and that possibly, in our 7
8 present efforts at controlling the health effects of coal, we i
9 are not attacking the most significant problems at all.
10 The large scale combustion of fossil fuels for energy 11 production has been common practice in the industrialized na-12 tions of the world for many years.
Today's public views the 13 by-products of combustion (soot, smog and ashes) more as a 14 nuisance, not as a real problem.
We know that the by-products 15 of combustion are harmful, but we accept them to a large degree 16 because we are simply used to the problem. we believe that we
?
l 17 can tolerate the situation.
The evidence that I will present 18 here,however, will show that this nuisance has, on a number of i
a
}
occasions, had catastrophic results. We have yet to develop the 19 j
20 reliable technological tools to deal effectively with the prob-J:
21 lem.
22 While many informed persons realize that, under routine 23 operating conditions, nuclear power plants have a lesser en-24 vironmental and health impact than coal, critics have argued 25 that nuclear plants are uniquely subject to major catastrophes. 1 I
This is simply not true.
No deaths have been attributed
)
2 to nuclear power accidents.
However, a number of incidents 3
stemming from the burning of fossil fuels have been recorded.
4 In October, 1948, a cloud of pollution settled over Donora, 5
Before it lifted, 20 people were dead and 6000 -
6 were ill.
Almost half of Donora's population, 43%, were 7
stricken.
In 1952, a similar event occurred in London, and in 8
this case, thousands died and many thousands were made ill.
9 How can we ignore such events?
10 In each of these cases, the culprit was a combination of 11 combustion gaces and particulates; a combination we call smog 12 or in scientific terms an aerosol.
These small particles by-13 pass scrubbers or electrostatic precipitators in coal-fired
.)
14 power plant stacks; and the volatile gases are unaffected or 15 can bypass both types of devices.
This problem has not yet 16 been solved.
17 Information on particle sizes and concentration of ele-g g
ments found in air samples taken in the vicinity of the Univer-18 j
19 sity of Missouri-Columbia power plant included many elements ij 20 classified as carcinogenic or toxic, including arsenic.
The 21 health impacts of breathing these particles is yet to be de-i' 22 termined.
23 Most clinical studies indicate that arsenic is a human 24 carcinogen.
Arsenic is a component of coal and recent measure-25 ments indicate that aan-made air pollution is the primary source.
4
of arsenic in the air.
It is known that traces of the carcino-
') -
2 genic agent, benzopyrene are present in the stack gas effluent, 3
as are dioxins (which include PCE's).
The health impacts of 4
these compounds is yet to be determined.
Also present are 5
small amounts of radioactive materials including uranium, 6
thorium and the'ir radioactive decay products, which would also 7
be present in the bottom ash and precipitator fly ash.
These a
materials can eventually find their way into surface and 9
ground water supplies.
4 10 The future health impacts of these amounts of materials l
11 could be anything from insignificant to catastrophic.
12 Critics of the nuclear power industry have claimed that 13 the nuclear industry has deliberately introduced a hazard into 14 the workplace and general environment wichout adequate public 15 health monitoring.
No references or other support at all is 16 offered to support this assertion.
The assertion flies in the 17 face of the historical facts that the development of a commer-18 cial nuclear industry was preceeded by years of research in g
s j
19 national and federal laboratories, as well as work by literally Yj 20 hundreds of investigators in all areas of science, medicine, 21 and engineering working in this country's universities.
This I
22 statement does not conform with fact.
It is a propaganda state-23 ment.
24 There are models available that predict the environmental 25 and health impact of fossil and nuclear power plants.
Also
I much public health evidence exists on the relative impact of 2
fossil and nuclear fuels.
3 Critics of the nuclear power industry claim that the 4
level of radiation has been increased recklessly, offering 5
no references to substantiate such claims.
Available informa -
a tion indicates that about 89% of the radiation dose that citi-7 Zens of this country receive other than background radiation a
is from medical exposures.
In the period from'1964 to 1970, 9
medical exposure increased from per capita doses of 61 to 72 to millirem per year.
If some profession is to be accused of it reckless exposure of the population to radiation, it would i:t seem that it should be the redical profession.
13 Critics of nuclear pot.er continually refer to a " nuclear
.)
14 industry", and a forecast of health effects.
" Nuclear industry 15 is never defined but, if in fact this is industry in the cormor 16 use of the term in the United States, it is certainly not in g
17 charge of setting medical radiation dose levels or in insuring 18 that these leve'.s are observed.
g 2
19 The recent BIER (1979) report is one of the most sig-i l
20 nificant documents on the effects of low-level radiation.
One 4
21 disease in particular that is allegedly associated with low-22 level radiation is leukemia.
The incidence of leukemia in 23 both U.S. males and females reached a peak in 1965 and has 24 been declining since.
This data 7tovided by the American Can-T 25 cer Society does not conform with what critics of the nuclear
indu'stry would Icad us to believe.
1 2
With respect to leukemia, it must also be noted that an
}-
3 independent review of the Mancuso data shows in fact that there 4
was a decrease in leukemia incidence among Hanford radiation 5
workers as compared with the general U.S. population.
- Thus, 6
the Mancuso study provides no support for critics' assertions t
7 regarding incidences of leukemia within allowed radiation doses.
8 Critics have claimed that plutonium is much more toxic 9
than is commonly concluded.
These claims hava been examined 10 time and again by the National Academy of Science including 11 the BIER Committee and the International Commission on Radia-t?
tion Protection.
No justification for these claims has been 13 determined by these competent peer review groups, 14 I have presented here today several comparisons to show 15 the relative health impacts of the use of coal versus nuclear 16 power.
A well-supported scientific consensus exists that shows
[
17 coal-fired power stations (under the best of circumstances) 18 produce significantly greater negative health impacts than do 2
19 nuclear power plants of the same size.
i l
20 Thank you.
21
!!R. SCHREIBER:
Mr. David Harris.
I 22 MR. HARRIS:
Good afternoon.
My name is David Harris, 23 and I'm seeking on behalf of Citizens for a Radioactive-Waste 24 Policy.
Citizens for a Radioactive-Waste Policy is a statewide
-)'
25 organization which is very concerned about radioactive waste;.
I about the productfon of large quantities of such hazardous ma-
')..
2 terial in our State without first knowing how to properly dis-3 pose of it.
4 The Missouri Clean Water Commission is responsible for f
l 5
the quality of our drinking water and therefore responsible for i
6 preventing radioactive contami~ nation of the Missouri River.
We 7
who 1,1ve downstream from the Callaway Plant feel there should a
be a guarantee that no radioactive waste will be emitted into 9
the Missouri before that plant is allowed to operate.
Because 10 all of the drinking water for the St. Louis ares comes from the 11 Missouri, we feel that the Clean Water Commission and the 12 Governor hav an obligation to mak'e sure that water is safe to 13 drink.
14 W. therefore urge you to deny Union Electric a permit to 15 discharge the radioactive wastewater from the Callaway Plant 16 into the Missouri River.
17 j
Admittedly, Federal agencies like the Nuclear Regulatory
(
g 1{ Commission and the Environmental Protection Agency are primaril y j
19 responsible for regulating radioactive waste storage and treat-l j
20 ment.
However, the State can, and must, play a powerful role l
l 21 in these determinations.
When the Department of Energy pro-
- s 22 posed to dump 20,000,000 gallons of radioactive water from I
23 Weldon Springs into the Missouri River, it was decisive action 24 by Governor Teasdale and DNR Chairman Fred Lafser, among others
}
that prevented that potential health disaster from taking place 25 l.
i
A similar action is warranted in this case.
2 For years, the utilities, the nuclear industries and even 3
the Federal government have assured us that there is no problem 4
with radioactive waste, that everything is under control.
Wow 5
we are finding out that this is simply not the case, that we 6
have been misled.
7 More than 158,000 Missourians signed the CRP Initiative e
Petition which would prohibit the operation of a nuclear power 9
plant in Missouri until there is a permanent Federal repository 10 for the storage of radioactive waste, and until the owner of 11 the plant has posted a bond to insure that the plant will be 12 shut down and_the area cleaned up at the end of the plant's 13 useful life.
The people of Missouri are no longer willing to 14 gamble with the health and safety of themselves or their famili es 15 simply because industry spokesmen say that everything is fine.
16 The large number of signatures gathered by CRP is a strong in-dication that Missourians favor a conservative "Show-Me" ap-17 j
18 proach.
And they expect their public officials to support this a
j 19 position.
4 I
[
20 Once again, we ask you to exercise your authority and den: r i
Union Electric's request for a permit to discharge radioactive 21 22 aastewater into the Missouri River.
23 Thank you for the opportunity to speak.
However, we hope 24 that another public Hearing, with more advanced notice than 25 this one to give more time to prepare testimony, at a better '
I time of year and in front of the entire Clean Water Commission, 2
can be held.
That would be a more appropriate forum to address
]-
3 the important issue of radioactive wastewater and its proper 4
disposal.
5 Thank you.
6 MR. SCHREIBER:
Thank you.
David Wilson.
7 MR. DAVID WILSON:
I am David Wilson, D-a -v-i-d W-i-1-s-o-n, 8
and I'm the Executive Director of the Coalition of the Environ-9 mental St. Louis Region.
Our president, Dan Bolef, will be to giving testimony this evening for the organization, which al-11 lowed me to make some off-the-cuff offhand, unprepared testimony 12 of remarks today.
13 By way of opening, I would like to let Dean Kothmann know
/
14 that six of us arrived in one car together, so, we're at least 15 trying to save some petroleum.
It's been interesting that we've 16 heard a lot of testimony so far today about the dangers of coal g
fired plants, and particularly, it's particularly interesting 17 g
to me, because the Coalition for the Environment for the last 18 j
19 ten years has been pushing the Air Conservation Commission, 20 which of course, you know pretty well, Bob, to try that Union f
Electric clean up the smog from its own coal-fired ~Jortage Des 21 i
22 Sioux, Meramec Bottoms.
And over those ten years, Union Elec-23 tric has constantly gotten ariances from the State, been al-24 lowed to pollute beyond the State's own levels.
In order to 25 prevent health and safety accidents, the same industry is now
~
proceeding to open up a nuclear power plant.
2
).
I would say, based on the experience just with its coal-fired plant, we can't rely on that company to protect health, 4
public health and safety.
There are scrubbers available to 5
clean up the coal.
They have argued cost as a reason not to 8
clean it up.
I'm afraid we're going to run the same bind with 7
nuclear power.
We've seen that elsewhere, and we'll probably 8
see it with Union Electric as well.
9 It's always difficult when you are dealint with a company 10 when you are dealing with a company to make a profit, to define 11 the guarantees that are going to be there to provide public 12 health and safety, because there is no profit even put on that, 13 and it's pretty hard to set a dollar value on human life.
)
14 We're concerned about this wastewater discharge permit.
15 largely because of radioaccive waste that may end up in that 16 Water, and we understand the restraints that you have and the l
17 disclaimers that you have put into the announcement in the per-18 g
mitting process.
But we feel like you are the people who repre 1
19 sent we the citizens in this State, and it's really up to you
$j 20 to be out there hustling to protect our health and safety, and i
21 where there are concerns, where there are potential dangers, t
22 where there are real dangers, you are the agency that we have to 23 turn to, and it's therefore that we have, of course, requested 24 a public Hearing before the Missouri Clean Water Commission.
25 And it's also why we're glad to have an opportunity today _
to speak with you.
I wrote a letter a little while 'ago to 2
Richard Rankin of the Clean Water Commission staff, pointing 3
out that subsequent to previous Hearings before the Clean h eer 4
Commission, NRC was present, at which time in that Hearing 5
many citizens testified about particular concerns with the 6
different permit, different plant action was taken by the 7
plant where, or by the NRC to correct some of the deficiencies 8
in that plant.
9 I think that that indicates in one sense the imporcance 10 of public Hearings and the development of public testimony, 11 because the public sometimes does point out crucial things.
12 In this instance, the Coalition did not act to prepare a major 13 in-depth research of public testimony, largely because of time 14 considerations and the fact there was so many people who we 15 rely on to do that were not available, also because we were 16 not fully informed at that point as to whether or not this g
17 Hearing would be nearly appropriate format a Clean Water Com-j 18 mission Hearing for hearing such testimony.
j 19 And my general feeling is that we still need that Clean
- l l
i 20 Water Commission Hearing as the official body to act on the 1
21 Permit and questions related to it.
Moreover, we need that 22 format because, as I read the State law, it's required by State 23 law when citizens express concern, and certainly large numbers 24 of citizens have expressed concern about this, specifically in 25 terms of things we would like to see this State do, We want to.
~------T--
M I
see your department doing a great deal more monitoring of radio -
'}..
2 active waste than may end up in the Missouri River.
3 We drink that water, and my son drinks that water, and I 4
want him to grow up.
I don't want to see him die of cancer at s
age three or five or fifteen.
And frankly, I'm scared, and I'm 6
not just pulling your leg.
I really think that we are on a 7
hell-bent course to destruction in this society using nuclear a
technology in very primitive forms.
9 My father is a nuclear physicist.
I've grown up knowing to a great deal about nuclear power.
I also know its hazards and 11 I also know without Federal government subsidies of Federal 12 nucler.r energy'of 15 to 17 billion dollars to prepare a tech-13 nology that is really not ready for producing energy, we would 14 not have a Hearing today.
I think that we can correct that 15 course and we need to correct it, and we need to take all the 1
18 safety precautions we can to guarantee public health and public j7
- safety, j
is A number of questions that I would pose to you at D and a
j 19 R would be:
What happens if there is a Three-Mile-Island-type a
20 or even worse, some kind of meltdown?
What kind of provisions a
?
8 do you have to prevent large amounts of radioactive waste from 21 2*
22 entering into our drinking water stream and contaminating the 23 Missouri River?
What kinds of methods will you have for con-24 trolling unplanned discharges of radioactive substances into 25 the drinking water?
What kinds of calculations have been done E,h 1
to determine what the long-term buildup over years of drinking 2
of water with vell amounts of radioactivity in it may be?
).
3 Those are a few questions that I think need fully to be address ed 4
by the D_
isement of Natural Resources before granting this 5
Permit.
It's possible to do, as you've done in your disclaimer 6
on the Permit announcement to say, we can't touch it, but if 7
you don't touch it, then, we have to rely on the Nuclear,Regu-s latory Commission.
9 The subsequent, what is it, the successor to the AEC, and to we don't have to look too far back to find the kind of ites tha t 11 were told to the public about nuclear power ten, fifteen years 12 ago.
We also. don't have to look far, we only have to look last 13 ' year with radioactive emissions, exposure to the general popu-14 lace to see tremendous disparities between two government agen-15 cies, the Environmental Protection Agency, the EPA, or the NRC.
16 We're dealing with real health factors here, and I don't expect g
17 Union Electric to deal with those, it's not their business, h
18 It's not their job.
It is your job to protect us, and I would j
19 like to see you do that.
I 20
- Thanks, a
21 MR. SCHREIBER:
Claudia Spencer.
i 22 MS. CLAUDIA SPENCER:
My name is Claudia Spencer, S-p-e-n-21 c-e-r.
1980 has been designated by Federal and State agencies 25 as The Year of the River and the river they have in mind is one
')
25 of the country's greatest, the Missouri River, 553 miles of.
whic'h flow through our State and gives it its name.
It is
').
2 without a doubt the single most important topographical feature 3
of our State.
4 Yet, despite its importance to us as a water source, 5
transportation avenue, habitat for wildlife and recreational 6
resource it has been badly abused.
Channelization has changed 7
it from a wildlife paradise to a barge canal and industry and 8
communities along its banks have polluted its once clean waters 9
However, an attempt is being made to develop the wildlife 10 and recreational potential of this beleaguered stream by various 11 agencies and conservation groups. The Army Corps of Engineers, 12 the U.S. Fish and Wildlife Service, the Missouri Departments of 13 Natural Resources and Conservation are all investigating the 14 possibilities available to the Corps for the development and 15 preservation of fish and wildlife habitat and the recreational 16 potential of the Missouri River.
17 But, it seems that the right hand doesn't know what the l
left hand is doing.' At the same tin.e that we are trying to 18
{
19
" restore the chemical, physical and biological integrity of 5
j 20 our nation's water by 1985" as required by the Federal Water 21 Pollution Control Act we are allowing new sources of pollution 22 to take the place of the old.
In this case the radioactive 23 materials to be discharged by Union Electric's proposed waste-24 water treatment facility into the Missouri River not only 25 threatens St. Louis's only source of drinking water but also.
I threatens fish and wildlife that use the river.
2 Radioactive substances discharged from the plant will 3
accumulate in bottom sediments downstream from the point of 4
entry.
The potential for high concentrations of these toxic 5
substances to be stirred up by dredging operations, flooding 6
and by the natural turbidity of the Missouri River and to be 7
re-suspended in the water could result in their entry into the 8
biological food chains where they will undergo magnification 9
through different food chain steps.
This could seriously af-10 feet fish attracted to the warm water discharge and lead to 11 mortality, impaired reproduction and even a ban on fishing if 12 tolerance limits for tissue concentrations are exceeded.
Do 13 we want to promote such an area as fish and wildlife habitat
.)
14 when such a serious threat exists?
Furthermore, in periods of 15 drought such as we are currently experiencing, these materials 16 will be even more concentrated and the potential for such dae-17 age even greater.
g 18 But the real danger to the people of the St. Louis Metro-g a
i 19 politan area lies in the threat to our drinking water.
Many of i
l 20 these substances have half-lives of thousands of years.
Once we 5
21 make the decision to deposit these lethal substances in the i*
22 river they will remain t.cre forever contaminating our water 23 and our ancestors virtualiv forever.
There is no way to undo t ae 24 damage once the decision is made.
It is irreversible.
It is
-)-
irretrievable.
Theee are not naturally occurring substances --
25.
meny'of these isotopes didn't even exist until man created them 2
Now, '; hey are out of Pandora's box and we don' t know what to do 3
with them.
4 Unfortunately, the Missouri River is already contaminated 5
with radioactivity.
It is already carrying runoff from uranium 6
mining upstream.
Two reactors in Nebraska dump their radio-i 7
active discharge into the Missouri River.
How much more can 8
the river carry?
And what if there is an accident?
In 1979 9
there were 2000 reportable accidents to the NRC and many in-10 volved spillage of radioactive water.
11 It is for these reasons that regular monitoring of the 12 discharge from.this waste water treatment plant be conducted 13 by an agency charged with the protection of the public.
The 14 NRC requires monitoring only twice a year and then only gross 15 alpha determination.
This is not enough.
Isotopic monitoring 16 before dilution on a regular basis is vital to the protection g
17 of our water supply and to the fish and wildlife on the Mis-18 souri River.
g 8
2 19 Thank you.
[
20 MR. SCHREIBER:
Mr. Ronald F. Tuttle.
4 j
21 MR. TUTTLE:
My name is Ronald F. Tuttle, T-u-t-t-1-e.
22 I'm a graduate student of the University of Missouri.
I am 23 working on my Ph. D. in Nuclear Engineering, also assigned to 24 the United States Air Force.
And this view that I present is
).
25 my own.
I would like to say that we need to issue this Permit..
O
g.3..
1 Tharo is two reasono why.
Tha main reasono why I scy tha 2
Permit needs to be issued, first one is, the energy needs of 3
the State.
I won't bore you with a lot of details, but let's 4
juct talk about what's going on in our State.
5 First of all, as you know, we are under a heat wave and 6
that both residential and industrial demands are putting a 7
stress on our system.
The growth of the State, we hope, will a
continue as far as the growth of population and growth as jobs 9
and so forth.
As such a thing takes place, more electricity 10 surely will be needed.
When we're talking about growth, let's in talk about industrial growth, because the health of the nation 12 and you look right now at some disease like Cleveland that are la under a sever'e depression because of the layoffs in the auto-
)
14 mobile dealers -- workers, that there is increased crime.
If n;
we are going to have increased minimal stress, minimal health is problems and so forth, we're going to provide our citizens with 17 the industry to gainfully employ them, we're going to have at-la tract, continue to attract and keep the industry that we have i
j u) here in the State of Missouri.
a:j 20 Potential growth is great in this State.
We have the ij 21 electrical energy.
We certainly have the transportation system 2:
22 here in the State of Missouri, and we also have a water supply.
23 These are key elements in any development of industrialized 24 State.
We also have the agricultural demands.
As you know, industrial' companies provide the farmers with both the fuel they 25.
l I
nt:d to opsrato on end also the fertilizers and posticides to 2
insure a good crop.
3 At present as noted, that with nuclear power, it is 4
slightly cheaper than the closest competitor, that's coal.
So s
that would give us as a State, a beneiit over other industrial-6 ized States.
The next point I would like to make under this 7
issue of Permit is the health benefits.
I won't belabor the 8
point about coal, because it was certainly addressed in detail l
9 earlier.
But coal has a significant, as you know, impact on to the air, water and land quality.
And to utilize it, you have 11 to make a significant investment, a capital investment and 12 maintenance investment.
A capital investment in initially 13 building that power plant and capital maintenance investment
)
i 14 in maintaining the associated equipment over the life of the is plant.
16 As far as the other health benefits, you can see sig-17 nificantly that over the last, say, month I guess, we've, in g
18 this part of the country, five states, over 630 persons have g
a j
19 been killed because of the severe heat.
That's, there is no i
20 excuse for this to take place.
The problem won't get better a
f 21 if we have less energy.
Here in our own State, we've had to a
22 emergency airlif t in the necessary air conditioning equipment, 23 fans, in order to protect our citizens from the severe heat.
24 I don't think any person should have to suffer or lose a life
.)
25 because of the fact that there is insufficient electricity..
w e.
g Right now, there is insufficient air conditioning capa-2 bility and that, hopefully is being dealt with.
Luckily, we have the energy to power these units, and luckily today, we're 4
in an air conditioned building like this.
That's vital.
No 5
windows around that I can.see, that's using a lot of power.
8 I'm not saying that's entirely correct, the way they built 7
this building, but certainly, we're all comfortable and this is a
due to the energy coming into this building.
9 Mr. Wilson addressed the fact that the citizens like to 10 express a concern over the quality of water, so, I certainly 11 have a concern over the quality of water of this State.
I en-12 joy water sports and recreation.
I take my son out fishing, I 13 enjoy doing that.
So, I express concern that we do indeed need 14 to monitor and insure to the best of our ability that water is 15 kept clean.
But as a citizen, also, I express my feelings that 16 I also would like to see that my son has the ability some day 17 to stand up and speak before you concerning possibly some other 18 matter.
Let's give him the energy that he can indeed be here.
g 2
19 Mr. Wilson also, I would like to address the fact that Union
$j 20 Electric had former abuses in the coal-fired unit.
Well, I 21 don't think Union Electric is the culprit.
I think, it's just i
22 a matter of technology and public or lack of information on 23 the part of public officials concerning the use of coal and 24 implementation of the coal-powered plants that were built ten
)
25 to twenty years ago.
Certainly, I can point out or wanted to g=>
, m ew s g
1 secto hsrc ths misinformation and the abuses of environmental 2
groups that have gone on previous to that, and I would not say, 3
well, they are going to continue their practice in the future.
4 They are going to be as fair and upright as possible in 8
the future.
I think that Union Electric is going to be, try to 6
do, to meet their citizens' needs in meeting regulations and in 7
a fair, upright manner in the future, and they certainly aren't 8
trying to abuse their position.
Also, it was mentioned about 8
the fact that radiation in the water somehow getting into our 10 body.
Well, I would contend first of all, that the radiation 11 in our body has been here a long time, possibly supporting 12 natural occurring isotope of 40, it's been in the environment, 13 it's in our bodies.
.h 14 If you were to be cremated in the State of Oregon, your 15 body would have too much radiation, according to their regula-16 tions, to be buried in the ground.
The problem of the idea of l
17 the radiation being addressed by Dr. Don Lucky, at the University 18 of Missouri, he has a new book coming out by C.R.C. Rubber Com-2 19 pany called Radiation.
It's an interesting contention he has Yj 20 there which indicates that if you were to shield an individual
\\
l l
21 from all radiation in the environment that his body functions i*
22 would not perform as well.
23 If you go and give him too much radiation, then, his body 24 functions are indeed impaired.
Again, or if he's in a certain
)
25 window, his body functions are operating properly.
He has 5
4 w
w ~
~
1 cctdslly done this with radiation, radiation experimants, Ha's 2
a well-noted scientist, and has done such with chemical sun-3 light, all kinds of factors that affect a person's physical and 4
mental capabilities.
Finally, I guess I would like to state 5
that the individuals that somehow speak with concern toward the 6
environment, it's noteworthy, if they offer no alternatives for 7
our State to meet the needs of our citizens, certainly, we cannot 8
ask our elderly citizens to use the soft energy approach.
They 9
are just not capable of doing that.
I think you are all aware 10 of Amory's Soft Energy Approach, and I won't go into detail.
11 So, I, myself, believe that the Permit should be issued 12 and that the plant should continue to progress toward comple-13 tion.
)
14 Thank you.
15 MR. SCHREIBER:
Allen Karcher.
16 MR. ALLEN KARCHER:
My name'is Allen Karcher, K-a-r-c-h-e -r, I
g 17 and I'm a former student at the Washington Univeristy Depart-18 ment of Technology and Human Affairs.
I'm affiliated with j
19 Green Peace and Friends of Research.
i 8
20 MR. SCHREIBER:
Would you speak up?
g 21 MR. KARCHER:
What I guess I'm probably here to talk 22 about is kind of extemporaneous 1y, is one of the things is, 23 one of the functions of a river is which, I guess, falls under 24 the Missouri Department of Natural Resources.
It seems like
-)-
25 there is a lot of different uses that could be put to such as.
F
.,-. ee
.+me.
-w
a s
drinking, sewage disposal, recreation, irrigation, certain 2
esthetic values that are there.
3 It seema that it would fall to the Department of Natural 4
Resources to determine the best usage which is what we're con-5 fronted with now, is issuance of water or treatment of waste 6
from the Callaway Nuclear Plant.
It seems, in looking over the 7
materials that I have, that this would be the same type of, 8
some type of emissions of sewage plants, there is going to be 8
suspended solid, there is going to be some sort of radioactive 10 waste, which I'll get back to, and also, temperatu.:e increase H
in the water.
12 The one thing that I did want to first address is the 13 issue of the temperature increase.
It's pretty well establishe d
)
14 that slight temperature increases do have a fairly profound ef-15 feet on natural systems.
One example that I have is from a H3 plant in, I guess, it's Colorado, which is called the Cheyenne 17 l
Peak Plant.
A study was done by students of the University of "3
i Colorado on the issuance of their Permit, so that they were allowed five degree temperature rise in the water at point of 18 ij 20 discharge, and the study that was conducted by a class. averaged 5
21 3
over a two-month period, seven degree increase, and that's an 1:
22 average, which means that at times that was extended and other 23 times it was less.
24 That makes me question the capability at Callaway to meet 25 the regulations that are proposed in here.
Another issue is.
n
,. ~
G
e
.[
thct' when you hevo an increase in temperature in. water, you arc 1
2
).
increasing the solubility which probably also would have a 3
profound effect on any suspended ~ solids that are there.
In 4
other words, they retain assertion longer.
The other issue is s
when you are releasing heated water, it tends to evaporate 6
quicker, it's more prone to evaporation, and consequently, 7
there might be some localized temperature effects, which I
8 don't see addressed in any of the matter that I have read to 9
date.
10 Thermal pollution is an issue that hasn't really been
$1 seriously addressed in. coo much publications.
Nuclear plants, 12 due to the fact that they do produce electricity at a very high 13 temperature, release water at a very high temperature and use 1-4 water at a very high effective levels.
I think they are talk-15 ing about billions or millions of gallons per day, that might 16 be an amount of water that could have a severe localized tempera-17 ture effect, 18 I haven't seen anything in any of the data that deals y
j 19 with that, Another issue that comes to mind is probably the a
radioactive waste disposal issue.
Now, from what I've read to 20 a
21 date, is that the radioactive waste issue is kind of the prob-i 22 lem of the Nuclear Regulatory Commission and really isn't sup-23 Posed to be addressed at this Hearing at all.
It does seem 24 that it's responsible of government agencies such as Missouri
).
Dep~artment of Natural Resources to protect the public, however, 25.
3 t
it's the slight where there is a slightest issue or doubt that 2
this could be public, this seems to be a governmental issue, 3
but it does seem that the State should protect their populace.
4 That would be something I would like to see the Missouri Depart-5 ment of Natural Resources.have more Hearings.
6 Also, see Governor Teasdale get behind that issue and get 7
more of the citizens in this State involved.
In another area 8 'that seems intriguing to me, is the necessity for the nuclear 9
plant.
When one examines past history of rate estimates versus 10 what actually has been required as far as heat demand.
Washing -
11 ton State estimates for years have run as high as 35% over what 12 actually.has been demanded, and you get into the issue of
)
whether or not unlimited growth is worthwhile.
.o 14 It seems like the governments are constituted to dictate
'S policy.
One of the policies that the government can control is j
'6 how much electric usage is required by the populace, and it I
'7 seems to fall under your jurisdiction, as the Department of Natural Resources, to determine what.those resources are going to be used for, be it electrical generation or some other form
'S Ij 20 such as recreation, irrigation It comes back to the issue of i
h temperature.
I've noticed the water table in Missouri has been 21 i
22 dropping yearly and for, I think, in the last two years, if I'm 23
.Tot mistaken, there has been decrease in the northern part of 24 l iichigan in water table.
If you are going to use a nuclear 25 power plant such as the one proposed at Callaway, which is goin i
I to p'ut that excessive demand of water on the Missouri system, 2
that maybe an effect that would be felt later on when you are 3
talking about an agricultural state.
4 It's a fairly high agricultural area, what water will be 5
there for use.
I know one of the speakers or one of the per-6 sons that have given testimony has given the possibility of 7
giving alternatives.
That seemed in the past that governments 8
and also people and industry have responded to switches in the 9
technological input fairly well if it's decided that nuclear 10 power is not an efficient means of electrical generation than 1'
it seems that a sufficient form will be found, meaning possibly 12 that funds that have been allocated for it, the development of nuclear power may be available for alternative forms, it may 13
')
14 have less effects dcwn the road.
is I guesa, basically, that's all I wanted to say.
I thank 16 you for the opportunity to testify.
I would like to see more 17 Hearings on this issue throughout the State, also in Callaway g
18 County where it seems that it would be a good issue for them to g
a j
19 find about.
20 Thank you very much.
- j 21 MR. SCHREIBER
Thank you.
Bobbie Silverblatt.
22 MS. BOBBIE SILVERBLATT:
I am concerned about the fact 23 that radioactive wastes will be released into the Missouri 24 River from the Callaway plant during its routine operations and
)
25 as the result of accidents.
I am particularly concerned about l
the' possibility that pregnant women who live downstream from 2
this plant would be drinking this water or eating farm products 2
or fish contaminated by this water - thereby affecting the 4
health of >.hcir yet-to-be-born children.
Tritium, for example, 5
which is to be ieleased by the Callaway Plant night and day, 6
has been demonstrated to kill oocytes (oh-oh-cytes) (precursers 7
of egg cells) in laboratory animals.
8 The final Environmental Impact Statement related to the 9
Callaway Plant says in Chapter 5, Pg. 2, and I quote:
" routine 10 power generation by the plant will result in the release of small 11 quantities of fission and activation products to the environ-12 ment.
Specific persons will receive higher or lower doses, 13 depending upon their age, living habits, food preferences, or 14 recreational activities."
15 In the U.S. Nuclear Regulatory Commission Regulatory 16 Guide #8.13 entitled Instruction Concerning Prenatal Radiation 1
17 j
Exposure it is stated "that the sensitivity of cells to radia-18 g
tion damage is related to their reproductive activity.
It fol-a j
19 lows that children would be expected to be more radiosensitive ij than adults, fetuses more radiosensitive than children, and 20 21 embryos even more radiosensitive."
I 22 The NRC Guide claims that this principle has long been a 23 factor in the development of radiation exposure standards. How-24 aver, although it is stated that a special situation arises when
)
25 an occupationally exposed woman is pregnant and a woman in the.
~
I first three months after conception may not be aware that she 2
is pregnant, the National Council on Radiation Protection and 1
3 Measurements recommended in its report No. 39 that special 4
precautions be taken to limit exposure when an occupationally i
exposed woman could be pregnant, 5
)
6 The NCRP recommendations state that fertile " women should 7
be employed only in situations where the annual dose accumula-8 tion is unlikely to exceed two or three Rems.
According 9
to the NCRP, with such a dose limit, exposure to the fetus 10 would probably not exceed one half Rem before a woman recognized 11 that she was pregnant.
Thic is stated even though according to 12 the (then) Atomic Energy Commission's own data, 11.8'/. of all 13 monitored workers in 1973 were exposed to levels of radiation
)
14 in excess of two Rems.
The AEC did not state how many of these 15 3,435 individuals were women workers.
16 The NRC Regulations have added an Appendix to Regulatory 3
[
17 Guide 8.13 which offers two neat solutions to this problem by 18 i
- 1) requiring employers to tell employees about the biological i
19 risks of radiation exposure to the fetus or embryo and 2) by ij asking that licensees "should make particular efforts to keep 20 l
21 the radiation exposure of an embryo or fetus to the lowest t*
22 practicable level during the entire gestation."
The first solu -
23 tion is to put the burden of deciding whether or not to work at 24 a potentially dangerous job directly on the woman herself.
25 Whereas it is admitted that such an exposure is potentially
ha::a'rdous, yet 1: does not require that such exposure be for-2 bidden.
In fact, in the summary of the same NCRP document 3
which lists the warnings to be given to the woman employee, it 4
is stated soothingly that "since this one half Rem dose is 5
lower than the dose generally permitted to adult workers, women 6
may want to take special actions to avoid receiving highertex-7 posures just as they might stop smoking during pregnancy or 8 might climb stairs more carefully to reduce possible risk to 9
their unborn children."
I am here today to ask if this is a 10 truly satisfactory way of giving information s,out such profouna 11 risks as radiation damage to fetuses or embryos.
The second 12 solution is unsatisfactory in that the state of technology as 13 well as the costs of lowering the dose levels are allowable 14 considerations in determining the " lowest practicable levels" 15 in both the current and amended regulations.
16 In an article by Joan Beck which appeared in the Miami g
Herald on Friday, April 6, 1979, she stated "that the period of 17 greatest hazard is from two to six weeks after conception and 18 5
j 19 that effects can include death, malformation, brain damage (the i
8 20 brain and central nervous system are particularly vulnerable g
f 21 to radiation) spina bifida, bone abnormalities, hydrocephalus 22 and microcephely.
Radiation can also produce mutations in 23 reproductive cells that may not show up as a genetic disorder 24 for generations."
Nowhere in the NRC Regulatory Guide is there 25 an adequate explanation of the risks to embryos and fetuses such' as this.
2 Any increased exposure to radioactive material increases 3
a person's risk of cancer and other life-shortening diseases.
4 If the Eissouri Clean Water Commission were to indicate its 5
approval to Union Electric's proposal to release radioactive 6
wastes into the Missouri River.- no matter how small an amount-7 the Commission would be approving the increased risk of added a
health hazards and particularly genetic and health damage to 9
fetuses and embryos.
10 Thank you.
11 MR. SCIIREIBER:
Thank you, Ms. Silverblatt.
Could you 12 please spell your last name?
13 MS. SILVERBLATT:
I'm sorry?
Would I what?
14 MR. SCliREIBER:
Could you please spell your last name for 15 the Court Reporter?
16 MS. SILVERBLATT:
S-i-1-v-e-r-b-1-a-t-t.
g 17 MR. SCHREIBER:
We're done with going through the list of 18 people who have made a request to be here.
Is there anyone g
l c
j 19 else present that would like to be heard at this time?
Y j
20 MS. REILLY:
I'm Marjorie Reilly.
I submitted written ij 21 testimony.
i t
22 MR. SCHREIBER:
Written testimony?
23 MS REILLY:
The only reason I'm speaking, is because I 24 didn't hear anybody else mention some of the concerns that we
)
25 had had.
I'm a member of a number of organizations, including df the' League of Women Voters of University City.
2 I want to thank the Missouri Department of Natural Re-3 sources for holding these public Hearings.
I would also like 4
i to ask whether and to what extent the Missouri Clean Water Com-5 mission is participating in these Hearings.
I would like to 6
urge that the Missouri Clean Water Commission also hold public 7
Hearings on this matter.
8 Because Callaway Plant is Missouri's first nuclear power 9
plant, I feel that the public interest requires independent and to continuous monitoring of effluent from Callaway Plant at the 11 points of discharge and at various points downstream.
Many of 12 us get our drinking water from the Missouri River and many of 13 us also buy or catch fish from this River.
We are, therefore,
^)
concerned about what is put into our water supply.
14 15 Because the Environmental Protection Agency sets stand-16 ards for water pollutants, including radiological pollutants, I 17 g
urge that rhe Missouri Department of Natural Resources or the 18 y
Missouri Clean Water Commission, as a'ents of the EPA, monitor g
e i
19 chemical, rr.diological and thermal effluents into the Missouri Yj 20 River from Callaway Plant and determine the combined effects of 21 these pollutants with other chemical, radiological and thermal i*
22 pollutants discharged, deliberately or inadvertently, into the 23 Missouri River upstream from the i-'take points for drinking 24 water for the St. Louis area.
25 I also request that the Missouri DNR identify alternative
I
~
sotrces and supplies of drinking water for those of us down-2 stream from Callaway Plant wno depend on the Missouri River for 3
some or all of our drinking water in case of a dangerous or potentially dangerous release of radiological, chemical or 5
other substances into the River from Callaway Plant.
6 Finally, I'm asking that the Missouri DNR ensure that
'7 there are readily available, thorough and effective means for a
alerting the public about measures to take and alternative 9
water supplies to use in case of a dangerous or potentially 10 dangerous discharge into the Missouri River from Callaway Plant.
11 Thank you.
12 MR. SCHREIBER:
Thank you.
Talk to the Court Reporter.
13 I have not heard any requests to be heard at this time.
Is 14 there anySody else who would like to make a comment?
If not, 15 we'll take, we are scheduled to go until 5:09 o' clock, and it 16 is about 3:00 o' clock.
Some more people might show up, so, i
17 why don't we take about a half an hour break and we'll reconvene j
18 in about a half an hour.
Thank you.
a 2
19 (Whereupon a 30-minute recess took place.)
Ij 20 (The followinj; was as follows :)
j 21 MR. SCllREIBER:
The meeting is convened at 3:45.
There 22 being no one in attendance to wish to make any more statements, 23 the meeting is recessed until 7:30 this evening.
24 (Whereupon the meeting was recessed until 7:30 P.M. this 16th 25 day of July, 1980.) '
1 (Whereupon the meeting before the Department of Natural Resourc es Committee began at 7:30 P.M. this 16th day of July, 1980 as 2
i follows:)
3 4
MR. SCHREIBER:
Good evening.
I am Bob Schreiber, Di-rector of the Division of Environmental Quality which is part -
5 6
of the Department of Natural Resources.
I will be the Hearing 7
Officer for tonight's Hearing.
8 The purpose of the Hearing is to receive public comments 9
on the proposed wastewater discharge Permit for Union Electric 1
Company's Callaway County Nuclear Power Plant.
The proposed 10 j
11 Permit addresses the conventional water pollutants that will 12 be discharged from the plant; radioactive discharges are under 13
~)
~
the control of the U.S. Nuclear Regulatory Commission and are beyond State jurisdiction.
14 15 After the Department received the Company's Permit ap-16 plication, a paid legal notice announced the application.
Copi es 17 of the June 16 legal notice and the Affidavit of Publication 18 are available at the registration table.
Also availabel for g:
2 19 review are a fact" sheet on the application, the public notice, ij 20 and the application itself.
A copy of all these documents will Jj 21 be part of the public record.
22 At a recent meet with the Governor Forum in South St.
23 Louis, citizens expressed concern about the effect discharges 24 from the nuclear power plant would have on downstream drinking 25 water supplies.
Reacting to these concerns, Governor Teasdale l
a g-uy, w
at.WW.+
w e*-
4
=
called this Hearing to provide an opportunity for the voicing 2
of these concerns.
3 Your facts and comments relating to the conventional 4
pollutants will be taken into consideration as the Department 5
decides to issue or deny this Permit.
The State's Clean Water' 6
Law requires that I reach a decision as expeditiously as pos-7 sible.
Any decision may be appealed to the Clean Water Commis-8 sion.
9 The Governor will personally make sure that the U.S.
to Nuclear Regulatory Commission receives any facts or comments 11 relating to radioactive discharges.
12 The purpose of this Hearing is to accept public testimony,
13 This is not an adversary Hearing.
There will be no cross-exam-14 ination of those who testify.
Neither will the staff respond 15 to questions.
16 I must ask that each person's comments be confined to a 17 maximum of 15 minutes.
Before beginning your statement, please g
clearly state and spell your name for the Court Reporter.
18 a
q 19 Written comments may be submitted up to the close of the ij 20 Hearing tonight.
4" I
Representatives from the Union Electric Company and the 21 22 U.S. Nuclear Regulatory Commission have been invited to be here 23 to accept your testimony.
My staff is also in attendance, 24 Transcripts of tonight's proceedings may be ordered from
-)-
25 the Court Reporter, Ms. Georganne Baker, i
l e,g.
I would appreciate it if everyone attending the Hearing
]-
signs an attendance card.
I would also appreciate it if there 2
3 were no smoking.
4 This Hearing, which is being held in accordance with Sec-5 tion 204.051-4 of Missouri Statutes, will now proceed.
6 The first person who requested to be heard tonight is 7
Ms. Rose Levering.
8 MS. ROSE LEVERING:
First of all, I would like to say 9
that I did write and ask for a Hearing in front of the full 10 Commissic a rather than just staff members, and I would like to 11 request that.
Okay.
The concern I would like to address to-e night is the stress that a nuclear power plant would add to our 13 River, combined with the facts of the future diversion of waters
)
14 from the River.
15 I found some really interesting facts in the Missouri 16 IRiver Basin Commission Report, Status of Electric Power in the 17 Missouri River, published in '78.
It predicted serious short-18 ages of Missouri River water for irrigation, drinking water, g
a j
19 navigation, and industrial purposes by the year 2,000.
The 20 nuclear industry relies on principle of dilution for its claimed f
21 radioactive waste discharge as part of normal planned operations, 22 it has no significant health impact.
23 While the fact is that radioactive waste or radioactive
\\
\\
24 substance can be determined regardless of its surroundings.
T
/
25 MR. SCHREIBER:
Could you speak up a little bit so the 1
Court Reporter can catch it?
2
)
MS. LEVERING:
Sure.
Regardless of its surroundings, 3
even if dilution were a realistic process, this report pub-4 lished about three or four years after the Callaway Environ-5 mental Impact Statement would be as follows:
"Only one fourth' 6
of the water withdrawn for cooling purposes at Callaway will 7
be returned to the River.
An increased concentration and 8
cumulative impact of radioactive waste suspended solids, and 9
thermal pollution."
10 And what water is returned, I think, will be dramatically 11 magnified by the projected increases and water consumption and 12 diversion.
The Missouri Rivar Basin Commission is made up of 13 representatives from ten states:
Missouri, Kansas, Colorado, 14 Iowa, Nebraska, Wyeming, Minnesota, North and South Dakota, and 15 Montana.
Most of these states upstream from us.
The Federal 16 agencies who are concerned with water problems of man in the
[
17 Basin, and that report the status of the report in the Missouri h
18 River Basin puts our present generating capacity for the Mis-1 j
19 souri River Basin at 23,611 megawatts, an additional 21 and ij 20 121 -- excuse me -- 21,121 megawatts is planned by 1985, almost l
21 double.
E 22 Callaway would, the Callaway Plant would provide the 23 largest in one case.
The report considers the effect of these 24 increases in c.apacities through the year 2,000.
In 1975, about
)
25 3,500 million gallons a day were withdrawn for use in the y.
1 Missouri River for power generation, and of this 73 million 2
gallons a day were consumed, they were not returned to the 3
River.
4 By the year 2,000, they project that about 4,900 million 5
gallons a day will be withdrawn, and that is 637,000,000 gal-6 lons a day will be consumed.
Robert Duncan said, the then 7
Director, I don't know if he is now, of the Water Resources 8
Planning Program Plan of the Missouri Department of Natural 9
Resources said, and I'll requote, "Although this major increase to in water consumption is highly significant in itself, with in-11 creases of this magnitude added to other such consumptive in-12 creases as irrigation, problems could develop for navigation, 13 Public water supply, and other areas dependent on the Missouri 1
14 River."
15 A large increase in consumptivo uses in the Missouri 16 River could create low flows in the River, especially in time 17 of drought, and this is the cause of rapid child death and g
18 hamper or shortening of the navigation season, lower flows j
j 19 could also cause an increase in the concentration of suspended Yj 20 solids, chemicals, and other impurities which must be removed l
21 by water treatment using the Missouri River as a source of 22 drinking water.
23 Well, apparently, we can anticipate all these things to 24 happen and more.
I found some more interesting facts.
The 25 Missouri River Basin water resource management plan in December 1
i of 79, an Appendix G under State Planning Objectives, this 2
is again for all ten states, "Seven states are all encouraging 3
and promoting irrigation and development in public and private 4
sectors."
5 They're concern with enough non-pollutant drinking water
~
6 to go around. 10n Page 52, and I quote, "While pollution may 7
be a means for controlling water quality, it does not meet the a
needs for control of man-made or man-caused pollution."
An 9
Appendix H under Water Resources, Problems and Opportunities "3
they're discussing power plant cooling and they say, and I 11 quote, " Future plants would require large quantities of cooling 12 water at times of low flow of Missouri River, the Labaddie Power 13 Plant, while their cooling operations affects the water levels for recreation at the Lake of the Ozarks, this one plant affect s 14 the water levels at a huge system of lakes, the Lake of the 15 16 Ozarks.
g 17 About navigation, the report continues, and I quote, e
18 " Drinking water - "
Let's see.
Excuse me.
"During water y
19 short. periods, 4-reasing upstream depletion may shorten the aj 20 navigation season -
the Missouri River."
About water quality, 21 water quality, if the Basin is affected by agricultural runoff, 8'
juine drainage that's suspended solids and acid waste, and that 22 23
- here is an increased treatment of sanitary waste, sewage over-24 ilows, and storm drainage.
And I found this kind of interesting fact under Legal 25 1
~
that there is a problem of reallocating water short=
- Factors, 2
)
ages, and apparently, they are considering thinking, planning 3
a River corridor along the lower Missouri to implement an en-4 dorsed plannin5 and flood management, and it's been mentioned 5
several times, future diversion to other basins concerning the-6 State of Missouri for navigational reasons and for other water 7
purposes, because of the quantity of water available in the 8
Missouri River for instream uses, such as navigation, fish, 9
Wildlife, water assimilation, and downstream energy use, de-to pends on water utilized in upstream states.
11 Certain states, agreement, water rights may be required 12 in the Missouri River.
This is all painting a pretty gloomy 13 picture to me.
In the final draft in the water management 14 plan in 1980, this is the five years after the Callaway, i.e.
Is a few more disturbing facts talking about wetlands declining
~
l 16 along the Missouri River,.they have declined over 10,000 acres j
17 since 1951.
They calculated in 1971, that the natural outflow g
18 of the Missouri River Basin was to be about 65 million 80 feet.
g a
j 19 Now, based on that and the county for state estimates of 20 depletion of 75 average and the remaining outflows were estimated 3
21 to be 49.5 million acre feet, future outflows of Hermann, Mis-22 souri, are predicted to decline to a level of 46,000 acre feet 23 by 1985, and to 42 million feet by the year 2,000.
The prin-24 ciple problem in the lower Missouri River Basin, I'm quoti..g 25 again, "Are non-source pollution potential, future demands and.
/,
1 unce'rtain water supplies for coal gasification and other po-2 tential energy developments.
Others of lesser impact include
')
3 local ground water supplies of unacceptable quality and some 4
parts of the sun basin isolated flood problems, overcrowded 5
recreational areas, declining wetlands and forests, habitat 6
impaired by continuing development.
7 I have figures on the EIS for Callaway, and what they 8
figure the low flow in the River to be and what they consider 9
the seven-year -- seven-day ten-year worst case load, flood io loads, but I don't think it's really necessary to have the it figures.
The fact is that it's been so long since they were 12 computed and they, apparently, found out so much that waters 13 upstream are going to be diverted for other purposes, low flood
)
14 loads are going to be less than planned, that I think that we have to take another look.
15 16 I'm asking you to make another assessment to reassess the l
impact of the dilution of the wastes that are going to be re-17 18 leased by this plant and in light of the facts that I just 2
19 brought up.
The. situation isn't the same now as it was then.
$j 20 And just one other interesting fact that I came across is that j
21 the Swiss Water Conservation Department, in the spring of '71, 22 ascertained that water in the Bahr and Rhine Rivers below l
23 nuclear water plant no longer conformed to the legal norm of 1
24 Grade 2 and fresh water cooling use in rivers was abc3ished for projected power plants distinctions in Switzerland.
25 -
l I
~
Thank you.
2 MR, SCilREIBER:
Yes.
Would you please state your name
~
3 for the Court Reporter?
Kind of speak into it as closely as 4
you can.
5 MEMBER OF THE AUDIENCE:
Wouldn't it be polite, I would 6
like to see the speaker.
There are only two of you.
There are 7
aboat 100 of us.
8 MR, SCHREIBER:
I understand your concern, but it's a Hearing before the Hearing Officer, and I am the Hearing Of-9 to ficer.
They should face me.
I'm sorry.
11 MEMBER OF THE AUDIENCE:
I disagree with you.
12 MR. SCHREIBER:
Okay.
Dr. J. William Hirzy.
13 DR. HIRZY:
My name is John Hirzy.
I live in St. Louis 14 County.
I'm an Environmental Scientist by profession.
I have 15 a very relatively short statement.
Il 16 P The intent i
of Congress, of the Missouri Department of l
j iNatural Resources, and of the people themselves to prevent 17 18 g
pollution of this State's waters by radioactivity is well-19 documented.
Ij 20 Section 101 (a) (3) of the Clean Water Act states that ij 21 "it is the national policy that the discharge of toxic pollutan ts e
22 in toxic amounts be prohibited".
Further, Section 301 (f) of that Act prohibits the discharge of any high level radioactive 23 24 aaste into navigable waters.
Thus the Congress clearly recog-
) -
25 aizes, even in the face of other legislation and regulatory,
I action, that the discharge of radioactivity into the Nation's 2
waterways is a hazard to human health and the environment.
3 Further to the same point, I would like to read'briefly f
4 from the following:
A letter to the Honorable Charles Duncan, 5
Secretary of Energy:
6
Dear Mr. Secretary:
7 We would like to take this opportunity to voice our 8
strong opposition to the discharge of r&dioactive waste 9
Water from Weldon Springs, into the Missouri River as 10 proposed in the Department of Energy's application for a 11 Discharge Permit for Weldon Springs Raffinate Pits.
12 Our opposition to such a discharge stems from several
)
Firstly, the proposed action is unnecessary and 13 sources.
14 thus creates a totally n idless danger for the people in is the St. Louis and St. C1 2rles areas.
At this time, there 16 is no reason to remove the water-from tle raffinate pits t
17 at Weldon Springs.
While we are in favtr of clean up and j
is isolation of the hazards present at Weld (n Springs, re-t j
19 moval of sludge from the raffinate pits is not likely to i
20 happen in the near future.
Cotter Chemical Corporation, a
f which has made a proposal to DOE to remove the sludge, 21 22 still has not received an amendment to its Colorado 23 Processing license to be able to do so.
Furthermore,
~
Cotter has not submitted its operating p,lan to DOE re-24
)
2s garding this operation.
Thus, removal of the sludge from
..er
the pits is not imminent and the need to remove the water 2
from the pits is lacking.
Given such circumstances, it 3
would be foolhardy to remove the water from the W.eldon Springs pits when rainfall will probably recreate the 4
s Problem before sludge removal opera:: ions can commence.
Ur second source of opposition to the discharge is 6
the danger such an action could cause the populace of St.
7 Louis and St. Charles metropolitan areas.
Dumping un-8 treated radioactive water into the Missouri River is a 9
senseless act.
The reasons propounded for not treating
,g the water are that treatment would be costly and would 3,
12 cause time delays.
Cost should not be placed ahead of 13 the health and safety of human beings.
Time delays, like 14 wise, are not legitimate excuse for such an action, par-15 ticularly when time is not really the essence.
16 Removal of the-water in the Weldon Springs pits may g
be necessary some day, but it is not needed now.
When 17 j
18 such an operation is needed, steps necessary to insure j
19 the health and safety'must be taken.
The people of the
[
20 St. Louis and St. Charles areas, who rely on the Missouri 21 River as a source of drinking water, deserve the best 22 protections possible.
This proposed action does not 23 adequately safeguard their interests and should not be 24
'ndertaken.
Accordingly, we urge the withdrawal of your b-25 application to discharge the Weldon Springs water into the i i
)
Miss'ouri River.
2 I would like to reiterate one sentence in that paragraph:
3 This proposed action does not adequately safeguard their in-terests and should not be undertaken.
6 It is signed by:
6 Thomas F. Eagleton 7
Charles H. Percy 8
John C. Danforth 9
Harold L. Volkmer 10 Robert A. Young 11 Bill Clay 12 Bill D. Burlison 13 Richard A. Gephardt 14 Paul Simon 15 I respectfully submit that that is a fairly strong state-16 ment of Congressional intent with regard to radioactivity in 17 the Missouri River, g
h 18 I must compliment the Missouri Department of Natural j
19 Resources in denying an application to permit the discharge of i
l 20 radioactive wastes into the Missouci River from the Weldon l
21 Springs waste storage site similarly has recognized the hazard-22 ous nature of this type of discharge.
23 I would like to point out that the total amount of radio-24 activity which was alleged to have been discharged from Weldon T
/
2s Springs is 4270 microcuries (as radium-226), while the NRC's
.._ n _
1--
n ---
1 Draf't Radiological Effluent Technical Specifications (NUREG-2
')
0472, July 1979) would permit 10,800,000 microcuries per day 3
(as dissolved noble gases) to be discharged from the Callaway 4
Plant.
And that 10,800,000 microcuries per day figure does not 5
include tritium releases.
6 There is profound irony in the fact that DNR stood on 7
its hind legs and said "no" to a 4300 microcuries (total) dis-8 charge from Weldon Spring, while it plans to tuck its tail and 9
run from a proposal that will allow over 10,800,000 microcuries 10 to be discharged into the same river every day for 30 - 40 year s.
11 It is extremely important that the people of this State, 12 and especially those of us who will have to drink the water containing this contamination, know and understand the implica-13
)
14 tions of the proposed discharges from Callaway.
Based on the 15 public reaction to the Weldon Spring discharge plan, one would 16 hope the citizens of Missouri will demand that the Callaway
't 7 g
Plant not be allowed to contaminate our drinking water -- and 18 the air we breathe and the soil which grows our food.
g 1
i 19 I respectfully request that you, the staff of the Missouri i
l 20 Clean Water Commission, discharge your obligations to protect 21 the citizens of the State and the response to their -- and the 22 Congresses' -- express rejection of the concept that they 23 should be forced to consume radioactivity in their drinking 24 water.
I request that you cite Section 301 (f) of the Clean
)
/
25 Water Act as a reason for rejection of permit application,
=
,i
/
'1 MO-6098001.
2 Thank you.
3 MR SCHREIBER:
Just give your name to the Court Reporter 4
I appreciate it.
Mr. Byron Clemens.
5 MR. BYRON CLEMENS:
It's hard to follow that one.
Well, -
6 as a citizen, I feel I have a right and a responsibility to be 7
here this evening.
8 Some of these notes may be rambling.
I hope people will 9
bear with me.
I'm concerned about Union Electric's self-moni-10 toring program.
I think that's a ridiculous state of being for 11 us.
It's not in Union Electric's best interests to detect sig-12 nificant event's and report them, even if they use a third party
.)
which would be paid by Union Electric.
13 I'm concerned about monitoring the ground water and sedi-14 15 ment.
I'm also concerned that if there were an accident similar
{
to to what happened at Three Mile Island or at several other plants, a
i 17 that the monitors go off scale.
If there is a severe enough j
is accident that there is an end of the scale there that would not a
j 19 be taken up.
Also, the state of the art monitoring equipment i
isn't keeping up with radionuclides. that are being released.
20 a
f 21 I see the tritium as a rule isn't listed as one of the greater t
22 nuclides that are monitored or under the same jurisdictions 23 that are the other one.
24 So, I wonder why that is.
I do think that the State is
.)
25 empowered and has a responsibility to protect the health and.
'I safe ~ty of the citizens of the State.
This power has not been
~
s.
2 usurped by the Federal government or the NRC who is clearly 3
delegated to the State of the people in the Tenth Amendment to 4
the U.S.
Constitution, and I always know that our State law 5
declares that, and I quote, "The public policy of this State is 6
to conserve the waters of the State and to protect, maintain 7
and improve the quality thereof for public water supplies for 8
domestic, agricultural, industrial, and recreational, and other 9
beneficial uses for the propagation of wildlife, fish, aquatic to life, et cetera."
11 I'm also curious as to whether the Clean Water Commission 12 and the Department of Natural Resources will make the NRC and
')
Union Electr.ic be in consistencies with the EPA new uranium 13 14 fuel cycle standards.
I guese, my major concern about all this is is not enough is known about low level radioactive waste that 16 you would be required to grant that Permit.
?
g Un also surprised that you chose this time to have the 17 hearing.
This is summer time, a lot of people are on vacation, 18 a
-j 19 it's particularly hot, and I would like to request that, as i
l 20 3s. Levering did, that you have another Hearing before the. full 8
21 Clean Water Commission.
If you find yourself bound to go ahead 22 and grant this permit, and I hope that in protecting our safety 23 - : hat you won't, but if you would find yourself in that case, you 24 could do further monitoring, yourself, or require Union Electric T
/
25 :o do further monitoring, that is within your rights.
And even.
Wf-1 after the Permit is granted, we could have, I understand we 2
~')
could have a Hearing, if the Permit is granted, before the 3
Commission.
I would hope that, again, that you wouldn't grant 4
the Permit.
I think if you would grant it, we would have in-5 creased incidence of career, birth defects, genetic mutations 6
can result in diseases, and birth defects such as mongolism, 7
congenital cataracts, hemophilia, cystic fibrosis, and forms of 8
muscular dystrophy.
9 I would like to have in the Permit how many cancers or defects will be produced per unit of exposure;what your predic-to 11 tion of that is.
I'm concerned with the New itdrid fault, what 12 an earthquake would do in the loss of coolant, and also, that 13 that pumping station that's on the Missouri River, I'm not --
,,)
I'm not so sure that that's in the same safety conditions that 14 15 the containment vessel, itself, is supposed to be under.
I'm also concerned about accidents in the spent fuel pool 16 g
If there would be an earthquake or a flood there beyond that, 17 it would be -- that we could protect them from that.
I would 18 g
a also like to know how long they intend to keep spent fuel in j
19
$j 20 that pool if they do.
21 I also have to agree with Ms. Levering that dilution is 1
22 not the solution for pollution.
It's going to collect in the food chain again, and I'm going to eat fish from that river, 23 24 I think, and I'm going to drink water from that river, and it 25 begins to accumulate, radiation accumulates in the bio-system.
~.
I don't want to be afflicted with that.
I don't want my child-2 ren and grandchildren to be afflicted with that.
I'm concernec.
3 about the thermal and chemical discharges.
I'm also concerned 4
when I mention children, that children are more susceptible 5
than adults, they more quickly -- they have a faster metabolis'n 8
they more quickly take in radiation, they more quickly show the 7
- damage, a
Most of the NRC statistics are based on adults.
I'm alse 8
concerned that we're told by certain people, the NRC, that these 18 are safe discharges.
People in St. George, Utah, the people 11 that live around Love Canal in New York, the people around 12 Three Mile Island, the people in the State of Missouri, are 13
,)
beginning to wonder just e:actly who says what is safe and why 14 those rules tange.
15 Why did they mill run silly and go down suddenly?
Why 16 was it said that it was safe beface to' have fallout and now it's 17 j
not safe any more?
Is this going to change again in ten years?
H3 3
Again, if you grant the Permit, I would hope that there would j
u) be further monitoring, you can require it.
I want you to know
$j 20 where the rsdior.ctivity is going.
I want to know that the T
l 21 sediment is being monitored, the ground water on site and down-22 stream.
I noticed an interesting fact in the Permit, itself, 23 that this is sort of a disclaimer to the Clean Water Commission,
24 it says they are not going to protect us as their duty says,
/
25 and I think that's pretty portinent to all this.
I would hope,
1 that you would find it within yourselves to do the responsible x.
2 thing, if you don't, please go ahead and monitor as several states do.
Some states require more specific monitoring than i
4 the NRC does.
The utility company itself, some states go 8
ahead and monitor it themselves.
If you are lacking in funds',
8 you can apply for Federal grants to do that, there is not much 7
money there, but you can give it a shot.
8 I would ask you to put in a Permit requiring frequent 8
analysis of ground water sediment seepage and the spent fuel 10 rad pools, continuous sampling of the rad pools; bio-assay of fish downstream; constant thermal temperature monitoring; a 12 bi-weekly report of occurrences report from the NRC that shows 13 constant, constant discharge of radioactive water beyond what 14 they say are normal occurrences, what we could call small ac-15 cidents.
16 I would like,aIso like to see the Permit contain the i
17 new levels of 75 millirems to the thyroid gland, 25 millirems 18 i
to the whole body, and 25 to any other organ, which is revised 19 from the old 500 millirem limit.
I would also like to see what g
20 the EPA recommended in the environmental impact statement, that ij 21 monitoring of cows and goats that are lactating animals around 22 the plant throughout the lifetime of the plant.
23 From reading the impact statement, I understand that they 24 would want to cut back on the monitoring three years after the 25 operation if everything goes well.
Well, I think that's insane. -
'I I'm also concerned why these little things about -- I 2
understand there is a five percent increase in copper coming 3
from the plant, things that aren't even in the radioactive thin g 4
that you are trying to get out of responsibility for.
Is that 5
just going to be ignored?
I mean, the phosphates and copper, -
6 are those things okay now?
I would also like to see, as the 7
EPA called for, the leukemia and other cancer death rates as a
well as congenital malformation rates pre-operation of the 9
plant in the Callaway County area and downstream so that they 10 can be compared later after the plant goes in operation, if 11 the plant were to go in operation.
12 The pre-operation health statistics could be compiled by 13 the County Health Department of Callaway and all adjacent
..)
14 counties.
15 I haven't noticed that that's taken place yet, I would 16 hope that it would.
I would like to point out that Illinois, g
17 Iova, and Kentucky mention other standards in the NRC's, and g
their Permits, Department of Public Health monitors waterways 18 a
j 19 for daily, on the Illinois River, also quarterly and require 20 specific monitoring of unplanned discharges.
There are two f
21 states more stringent monitoring than,the NRC requires.
The i*
22 four states have NPDES permits that require more reports than 23 NRC requires.
Three states have NPDES permits which state the 24 plan mum follow radiological regulations.
Six have NPDES, that
)
25 states specific radiation regulations.
So, I think.it's plain
.a E.
I that the State of Missouri can also require additional monitor-2
')
ing be included in the Permit.
3 And again, I would like to restate this:
I think there 4
should be surface water analysis, ground water sediment, fish, 5
vegetation, milk, for several different isotopes and continuous,
6 and I think Union Electric should pay for it.
And again, I 7
have to, one more time, say that if you would grant the Permit 8
which I recommend that you don't.
9 Thank you very much.
10 MR. SCHREIBER:
Would you please give your name to the 11 Court Reporter.
12 Robert L. James, Jr.
l 13 MR. ROBERT L. JAMES, JR.:
My name is Robert L. James,
)
14 Jr.
I live at 3621 Shenandoah, J-a-m-e-s.
- Okay, 15 The first thing I would like to state is, I wish there 16 had been more notice on this Hearing, because I know a lot of g
17 peeple who would nave liked to have spoke about it if they had 18 known about it, and I would like to ask that we have another 4
i j-19 Hearing before the entire Commission so that they can answer, 20 not only just hear our questions.
21 I would like to share with you tonight some of my fears 22 and worries about the Jallaway Plant.
I am particularly con-23 cerned about the concentration of radioactive particles in the 24 food chain and how this could affect the Missouri River. First, T'
25 let me define a food chain.
The transfer of food energy from 1
its' ultimate source in plants, through a series of organisms 2
each of which eats the preceding and is eaten by the following, 3
is known as a food chain.
According to the Environmental Im-4 pact Statement for the Callaway Plants, one of the " atmospheric 5
pathways that is likely to account for most of the off-site 6
radiation dose from gaseous radioactive releases is:"
7 neDeposition and inhalation' results when a release provides 8
ground-level air concentrations of radionuclides which can then 9
be inhaled or deposited and taken up into the food chain to man. '/
10 The American Nuclear Society states that " biological con-11 centrations" can occur along the food chain.
For example, 12
" dilute radioactive minerals from power plants can be taken up
)
~
by algae, thus spearating the mineral from the water and con-13 14 centrating radioactivity in the process.
The algae are then 15 consumed by zooplankton and zooplankton by small fish in turn, 16 being further concentrated at each step.
The chain continues g
through larger fish to birds and their eggs, to soil, to ground -
17 h
18 water, to vegetables, and meat animals to humans."
Therefore, a
j 19 it seems to me that radiation discharged into the rivers keeps i
l 20 building up in the aquatic food chain until the fish can harbor f
21 radiation levels thousands of times higher than the original i*
22 amounts released from a nuclear power plant.
23 The Callaway Environmental Impact Statement says that 24
" fish will receive the maximum dose from Cesium due to high bioaccumulation factors for Cesium of 2000 (picocuries per 25,
kilogram)."
At this point, I would like to refer to a report 2
3-given at the Second United Nations International Conference on 3
the Peaceful Uses of Atomic Energy at Geneva, Switzerland.
The 4
report concluded that "a fish at the top of the food chain in a 5
community living in water,with a Cesium 137 content considered ~
6 safe for drinking could accumulate radiocesium in such amounts 7
that a small serving of that fish could contain the equivalent 8
of the long term maxinum permissible body-burden for humans."
9 According to the Callaway Environmental Impact Statement, 10
" radioactive liquids will be discharged to the Missouri River 11 after dilution by cooling tower blowdown water."
However, is 12 it not possible that biological magnification with respect to 13 concentration could counteract the dilution process thus enabling
)
14 radioactive effluents to reach people not only through the 15 drinking water, but the food chain as well.
Julian McCaull in his book Water Pollution, states that "the bic4ogical concen-16 l
17 tration of these various long-lived contaminants defies the 18 g
concept of dilution upon which much of waste disposal engineer-j 19 ing rests."
An example of this phenomenon, " Cesium 137 dis-a aj 20 charged from the Zion Nuclear Power Station north of Chicago Ej 21 although diluted in the cooling water discharge, will be con-i' 22 centrated in vegetation watered by Lake Michigan and further 23 concentrated in the livestock feeding on that vegetation.
24 Minute quantities of Cesium 137 in the water will be concentrat ed 25 by some 9500 times in the bodies of sunfish and by some 3000
-~
i time's in the bodies of carp."
(McKee & Wolf, Water Quality
') ' -
Criteria, California State Water Quality Control Board, 1963.)
2 3
In the Tampa, Florida area high Cesium concentrations 4
have been found in both root and leafy vegetables and also in 5
meat.
This is most likely a result of farm produce being ir-6 rigated with contaminated water.
In the Callaway Environmental 7
Impact Statement it says that "since channelization of the 8
River, the small tributaries are considered important spawning 9
and nursery areas."
Auxvasse Creek and Big Tavern Creek are 10 five miles distant from the site; Logan Creek is on the site."
11 Will these creeks be safe for the harvesting of fish for human 12 consumption, or will they have to be potted as unsafe for fish-13 ing?
14 Cesium 137 is a dangerous cancer-causing substance.
It is emits not only beta radiation, but also gamma rays, similar to 16 x-rays, which can penetrate thick shields.
When Cesium is 17 absorbed by the body, it concentrates in muscle tissue and in 18 the ova of females resulting in birth defects and sterility.
j 19 In the Callaway Environmental Impact Statement, it says i
l 20 that " waste streams will be processed and monitored for radio-d*
21 activity within the plant to reduce quantities of radionuclides i*
22 ultimately released to the atmosphere and to the River."
In 23 the same report it states that fish will be monitored once 24 every three months.
By the time the fish show an indication of Te 25 being contaminated, there will be no turning back.
Furthermore
e 2
this is a far cry from the claims of the American Nuclear So-2
)
ciety that this monitoring will occur every week.
Is the State 3
of Missouri in a position to do this kind of monitoring?
Will 4
the monitoring be to check the fish to see if they are still 5
edible or to determine the level of emission of radionuclides 6
from the Plant?
Many of these radionuclides that will be 7
emitted into the waste streams have very long half-lives; for 8
example, Cesium 137 has a half-life of 30.5 years, that is, it 9
is expected to remain toxic for 700 years.
10 It seems to me that the dangerous radioactive potential 11 of Cesium 137 has been proven, in the case of the Zion Nuclear Power Station, to form a direct pathway to man through the 12 13 food chain.
The damaging effect of radiation received in this 14 way may not become apparent immediately.
It is the cumulative damage of latent cancers and genetic effects that pose t',e is 16 greatest threat to human life.
This possibility must be 17 eliminated if mankind and the earth are to survive.
18 Concerning the biological effects of radiation, I would j
19 like to quote Dr. Valeriote (Frederick), the head of the Cancer 20 Biology Section of Washington University School of Medicine:
f "Any increased dose of radiation over the background level 21 2*
22 would be expected to lead to an increased incidence of cancer as well as increased detrimental mutations to succeeding progery 23 24 of the exposed individuals.
The increased frequency of such 25 tumors as well as the extent of detrimental mutations produced are a function of the radiation dose received."
2 Cesium 137 is just one example of a radionuclide that 3
will be emitted from the Callaway Plant.
The list of the radio -
4 isotopes that will be discharged into the water is a long one, 5
and includes krypton-85, tritium, and carbon 14 for which 6
there are no " specific" radiation standards; and for which no 7
techniques for removal are known.
There will also'be particu-8 lates that will come out of the cooling towers and the vent 9
pipes, and will no doubt find their way into the food chain.
s.
10 Unless the Clean Water Commission can be given total as-11 surance that these radioisotopes will not reappear in circum-12 stancea likely to do harm to the people of our State, then the 13 Commission has he duty and the responsibility to deny permits.
)
Thank you.
14 15 MR. SCHREIBER:
Thank you, Mr. James.
Mr. Gary Adams.
l 16 MR. GARY ADAMS:
First of all, I would like to applaud 3
g this Hearing as involving the public in the decision-making 17 la process about the crucial, crucial decisions affecting the j
19 rights of nuclear power, and I would hope that there will be if"j 20 cpatinuing process of public involvement through Hearings such f
21 as this and through all sorts of increased things.
The reason 22 I am here and the reason I am testifying right now, is I want 23
- o see the nuclear Frankenstein, as I think of it.
24 Every process, every face of nuclear cycle involves dan-1
/
25 gers that other speakers have elaborated on and are apparent to
____ _ - __= ____
1 anyb'ody who makes a cursory reading through the New York Times, "s
2 nowadays.
There are radiation releases that are unforeseen in 3
plants throughout the country occurring on a regular basis.
4 There are accidents, fairly serious ones, such as we just heard 5
in Alabama.
There are, oh, just any one of a number of things.
6 But this Hearing is directed towards the discharge of 7
wastewater, so, I guess I will keep my comments to that.
There a
is one accident in particular that has a great bearing upon 9
this Hearing that I know of, that I don't think has been brought 10 up, and that is an accident that occurred a year ago today in 11 the Rio Puerco River down in New Mexico on July 16th.
12 Approximately 100 million gallons of radioactive water 13 and 1100 tons of contaminated debris from the United Nuclear 14 Corporation Power Plant was discharged into the River.
This u5 kind of accident is the kind of thing that one sees continually 16 when you go back and examine the nuclear industry's record,
?
\\
17 which they claim to stand on.
Okay.
g j
ul Now, the effect of this accident has been for a 60-mile a
j 19 stretch of this River to be, for practical purposes, uninhabitable.
J Imagine that happening to the Missouri River, and you have a 20 a
f 21 Pretty grim story.
You have Jefferson City perhaps being i*
22 evacuated.
You have St. Louis City's water supply being en-23' l dangered.
You have, oh, a disaster, a nuclear disaster that 24 would make anything so far seem just insigt.ificant.
Fear and T
/
25 anxiety that a person will feel has about the nuclear peril, wi4'1 radiation that one cannot see or feel is described in 2
recorts abouc the Three Mile Island as the type of psychological 3
stress that one must deal with as one deals with a disease, one 4
must alleviate it.
5 But I contend that isn't true.
I contend that tha people 6
do not feel this stress who do not feel a terror at this un-7 foreseen peril or the ones that are crazy.
That's us.
They 8
are the ones that need to be looked after, to be treated, be-9 cau'se the degree of peril in the nuclear, in the nuclear in-10 dustry's continual development is becoming more and more ob-11 vious.
And well, that's simply what I would wish to e:: press, 12
- sir, 13 Thank you.
/
14 MR. SCHREIBER:
Thank you, Mr. Adams.
Ms. Paula J. Ayers.
15 MS. PAULA J. AYERS:
What I would like to talk to you i
16 about, I would like to raise some questions about the pitfalls g
17 of using the EPA and NRC' regulations and standards for deter-18 mining the safety of this water.
g 1
j 19 Firstly, there'are vast discrepancies between the EPA a
20 standards and the NRC regulations.
On December 1st in 1979, a
21 the new EPA standards became law, and it set the maximum allowe i i
22 dosage due to planned releases at 25 millirems per person per 23 year.
The NRC regulations allowed planned releases up to 500 millirems per person per year.
This is a very big difference.
24
- )
25 And I am wondering which of these government watchdogs you be- '
1
'1 lieve and which Union Electric will follow, if they will follow
~
2 either one.
3 I am also forced to question the safety of these regula-4 tions.
In Appendix B, Title 10, Code of Federal ~ Regulations 5
20 they list the maximum permissible concentrations for 270 6
radionuclides, that is how much it would take of each isotope 7
to give the 500 millirem dosage.
A person drinking two liters 5
of water a day containing any one of these isotopes would in a 9
year's time receive the 500 millirem dosage.
10 It's frequently the case that more than one of these 11 isotopes is released at once.
Beyond that, there is no safe 12 level of radiation; there is no threshold below which radiation 13 is safe.
If I could quote Dr. John Goffman, Professor of 14 Medical Physics, University of California and former Associate 15 Director of the Lawrence Livermore Laboratory and well-known 16 Manhattan project veteran, "There never was, there is not now 3
{
17 any evidence for a safe amount of radiation."
18 g
Every responsible organization studying radiation injury a
j 19 now holds that cancer, leukemia, and genetic damage must be i
l 20 considered essentially proportionate down to dose to the variou s f
21 lowest radiation doses, Also in regards to research, very lit-22 tle is known about the biological effects of any of these 270 23 isotopes they list and virtually nothing has been researched 24 about the effects of most of them.
We must also take into 25 account how closely these standards have been followed.
In 1975', the NRC issue Title 10, Code of Federal Regulations 50, 2
Appendix I, maintaining that releases be kept as low as reason-3 ably achievable or a law you are probably familiar with.
This 4
refers to economically and technologically, that'is how much is 5
cost apparently a factor in determining how safe it is.
These-6 standards are not really binding at all.
Richard Volkmer, the 7
NRC Assistant Director for Site Analysis talks about Appendix 8
I,. Appendix I dose values are design objectives rather than 9
operating limitations, and therefore, under cer'tain anticipated 10 and operational' occurrences can be expected to be exceeded from 11 time to time.
They know they are going to go over them.
They 12 figure on it.
13 I would also like to point out, as Mr. Clemens did, moni-14 tors and alarms don't prevent excess releases; all they do is 15 alert technicians after the releases have occurred.
And as I 16 understand it, the monitors are useless in the case of a sizabl a g
17 accident.
These are very important questions.
We must take h
18 these considerations into account.
You must take them into a
j 19 account because we'100k to you for our protection.
We can't i
- l l
20 prevent the licensing; we can only ask you, you speak for us, f
21 and I have to bring to your attention that the children of the 22 future depend and~may well pay the price for your haste.
23 Thank you.
24 MR. SCHREIBER:
Mr. Dan I. Bolef.
)
25 MR. DAN I. BOLEF:
My name is Dan I. Bolef, B-o-1-e-f.
I am President of the Board of Directors of the Coalition for 2
the Environment and a Professor of Physics at Washington Uni-3 versity.
The statement I'm going to read is a joint statement 4
by myself and Kay Drey, D-r-e-y, who is a resident of Universit y
5 City, Missouri.
6 First of all, I join in the request by Rose Levering, by 7
Ron Clemens, and Robert L. James, Jr., that another Hearing be 8
held before the entire Clean Water Commission with questions 9
and answers, and the very first question I would ask in such a 10 Hearing would be:
Why doesn't the Clean Water Commission re-11 consider its present policy of not addressing the problems of 12 radiological contamination thus abdicating its responsibilities 13 to the Nuclear Regulatory Commission.
My last preliminary i
14 comment, I'm happy to say that much of our statement repeats 15 what has already been well said by others, but I persist in 16 reading the statement in the hope that such repetition will in-17 dicate the intensity of concern on the part of citizens of Mis-I g
l 18 souri affected by the pollutant discharges from the Callaway 5
a j
19 Plant.
This is the statement I want to read:
I i
j 20 In our comment on the application of Union Electric Com-g pany for a pollutant discharge permit, we address particularly 21 e
22 the dangers to the public due to the presence of radioactive 23 isotopes in the wastewater effluents from the Callaway Power 24 Plants.
The outfalls from the radwaste treatment system and
)
25 the cooling tower blowdown, which are known to contain radio-Q acti.ve material, add up to 13.5 million gallons per day or 4.9 2
billion gallons of radioactively contaminated water per year.
3 This radioactive water enters the Missouri River just one day's 4
journey upstream from both St. Louis City and County drinking 5
water intakes.
6 It is well-known that there are many pathways by which 7
the radioactive isotopes discharged thus into a river may reach 8
humans and deliver potentially harmful doses of radiation.
We 9
will mention a few of the main ones.
For example, recreational 10 use of the river; direct external irradiation while immersed 11 in the water or from deposits of radioactive materials on 12 beaches, rocks, fishing and boating gear; or internal irradia-13 tion from inhalation / ingestion of spray.
Secondly, water used 14 for agricul'tural purposes results in radioactively contaminated 15 plants used as feed for animals producing foods (eggs, meat, to milk); humans consume plants which have incorporated radioactive g
materials either directly from the irrigation water or from the 17 18 soil following transfer from the water, as well as plants which g
a i
19 have been spray-irrigated with radioactive water.
- Thirdly,
$j 20 there are the pathways associated with the use of water as a f
21 source of foods:
aquatic organisms take up the radioactive 22 material in the water, are used as food by other species, which 23 in turn transfer the radioactivity to aquatic plants, shellfish,
24 fish, and waterfowl.
The radioactive material may become highly
- )
25 concentrated in fish and shellfish.
For example, a study of r
I mall'ard ducks on the Department of Energy's Hanford Reservation 2
found Os-137 concentrations in the ducks' flesh to be 2,000 to i
3 2,500 times that in their food.
The concentration factor for 4
Sr-90 in clam shells has been found to be as much as 65,000, 5
Fourth, the contaminated water is used domestically for drink-6 ing, cooking, cleaning and bathing.
Fifth, radioactive con-7 tamination may result from industrial use and from purification 8
of the water:
for example, the radioactive materials are re-9 tained and accumulate in filters, ion exchange columns, sludge to settling basins during water and sewage treatment processes; 11 they also accumulate at various points (for example, deposits 12 in cooling towers) in industrial processes.
.)
13 We refer you, also, to the many studies which indicate that-contrary to the assumptions made concerning the effects of dilu-14 15 tion - radioactive materials deposit and accumulate in sediment 16 in the river bed, both at the bottom and along the sides of the 17 stream channel.
Not only.do some fish feed at the bottom of f
18 rivers, but dredging (such as that by the Army Corps of Engi-a j-19 neers) make the concentration of radioactive. materials in sedi-a ment of great concern to us.
Since many of the radioisotopes 20 a
21 Present in the radwaste discharge and blowdown are long-lived--
i 90 137 22 for example Sr (28 years % life) and Cs (30 years \\ life)--
73 the factors of concentration and rete,ntion that we have described 24 are of special importance.
25 Radiacion health experts, such as the National Council.
f 1
on' Radiation Protection and Measurements, have concluded that 2
when such radiation exposure pathways exist, so-called critical 3
" organs" of the human body such as the bone, thyroid gland, 4 gastro-intestinal tract and even the "whole body" may be danger-5 ously exposed.
In the case of the Callaway nuclear power pla'nt those threatened by radioactive pollutants in their water in-6 7
Clude the millions of us who live downstream on the Missouri and 8 Mississippi Rivers, as well as those affected by exposure to 9
contaminated ground water and by consumption of agricu.tural to produce irrigated with river water.
We propose that the granting of a pollutant discharge 11 1
Fermit to the Union Electric Company require that the licensee 12
)
monitor the radioactive isotope content (including levels of 13 the specific relevant radioactive isotopes) in surface water, 14 e
ground water, river sediment, fish, vegetation and milk.
Moni-15 t
toring should include isotope analysis and measurement of is I
levels of radioactive contaminants before dilution.
g 17 Similarly, evaporation pond sediment and nearby ground water should be 18 a
j 19 carefully monitored.
All samples collected should be subjected ii to isotopic ahalysis, not merely measured for gross a, 20 3
B and 3
90 21 Sr activities, i
22 As you know, a study of the monitoring requirements of 23 states, both as included in NPDES Permits and as done independ-ently by each state, was made less than two years ago by Lea 24
)
3reentree and Kay Drey.
The results of this study were sub-25
),
mitted to the Clean Water Commission in December, 1978, A num-2 ber of states set specific radiological limits in their NPDES 3
Permits, and required the licensee to meet state regulations as 4
well as NRC regulations.
In the state of Washington, for ex-ample, the required monitoring inclades pre-operational and 5
operational monitoring of surface and ground water, aquatic 6
7 biota and sediments, fish, milk, vegetation and soil.
Several 8
of the States require more frequent reporting of monitoring 9
data than required by the NRC:
Oregon and Vermont require to daily reports; Connecticut, Florida and Calir'ornia, monthly 11 reports.
Many of the states, in their independent state monitor-12 ing programs, require analysis of one to five (or more) spe-
).
13 cific isotopes in three or more media (media: surface water, 14 ground water, milk, fish, sediment, vegetation, etc.).
15 Unfortunately, it appears still to be the case, as it was 16 in 1978, that our state is'not able to conduct independent i
g radiological monitoring and regulation because of the lack of 17 y
strong legislation regarding radioactivity and of enough fund-18 2
19 ing to carry out the monitoring and regulatory programs that ij 20 state departments, agencies or commissions see as necessary.
f 21 Along these lines, we strongly support the passage of a Missouri 22 Comprehensive Radiation Protection Act, so that the Missouri 23 Clean Water lommission can act effectively to protect the 24 people of Missouri from the hazards of radiological pollution.
~
).
25 To summarize this part of our statement, we propose that y9 I
the'following minimal monitoring requirements ba included in 2
the NPDES Permit, and that such monitoring also be performed 3
independently by the Missouri Clean Water Commission:
4 (i)
Monthly or more frequent analyses of ground water 5
and of evaporation pond sediment, including an 6
isotopic analysis.
This should permit better track-7 ing of possible Seepage from evaporation ponds and 8
make it more likely that unexpected radioactive con-9 tamination would be detected; 10 (ii) Monthly bioassays of downstream fish, including 11 isotopic analysis, to determine how the radioactivit:r 12 being released is affecting the food chain; 13 (iii) Continuous sampling at the outfall, before dilution
)
14 by other water, with isotopic analysis done here als o.
15 Such monitoring should allow the Clean Water Commission 16 to have access to data which will enable the state to protect l
17 better its citizens from potentially dangerous conditions re-18 g
sulting from radioactive effluents from the Callaway Nuclear a
j 19 Power Plant.
i l
20 What standards should be utiliz9d in gauging the hazards 21 to the public of radiologically contaolinated effluents from the 22 Callaway Nuclear Power Plant?
On December 1, 1979, new EPA 23 aranium fuel cycle standards became law (Title 40, Code of 24 Pederal Regulations, Part 190 40CFR190).
The standards set the
)
25 -naximum radiation dose allowed any one person at 25 millirems.
'1 in ahy one year due to the planned releases of radioactive ma-2 terials from the nation's entire commercial nuclear power in-3 dustry.
As of June 24, 1977, also, EPA regulations took effect 4
'ahich are designed to keep man-made radionuclides in drinking 5 :aater at the tap from exceeding a 4 millirem per year annual 6
dose.
On the other hand, present NRC regulations (10CFR 20, 7 3ection 105) limit radioactive emissions from'an individual re-8 actor or other nuclear facility to an amount "not likely to cause 9
any individual to receive a dose to the whole body in any period to of one calendar year in excess of 500 millirems".
In other 11 'vords, the NRC allows each reactor to release radioactive wasten.
12
'ahich could expose a person living nearby to a 500 millirem dose 13 in one year, 20 times the EPA recommended maximum dose.
This
)
14 is significant for our discussion of monitoring, since the 15 aoint at which the monitor alarm is set and the point at which is the release is tripped at a liquid waste effluent channel (thereby 17 stopping the flow of the wastes to the environment beyond the j
18 plant) are both presently calibrated to keep releases within a
j ig the NRC limits.
We urge the CWC to adopt the new EPA radio-a Logical standards and to require in the NPDES Permit that the 20 a
Licensee set the monitor alarms in accordance with EPA limits.
21 22 By far the largest releases of radioactive materials n
23 Liquid waste from nuclear reactors are of tritium (a radioactive 24 form of hydrogen) and dissolved er entrained radioactive noble T'
25 gases such a Krypton-85.
The tritium, in particular, cannot be l
j i
separated from the water in which it is present.
An accidental 1
~)
celease of primary cooling water to the environment, therefore, 2
3'vould result in extremely high concentrations of radioactivity.
We urge that liquid effluent from the Callaway nuclear power 4
7 ant, and especially of tritium monitors in the event of an ac-5 1
6 tidental spill.
Detailed discussions of the hazards associated 7 With these radionuclides, as well as of measurement techniques, 8
are given in NCRP Reports nos. 44, 47, 57, 58, 62 and 63.
The danger to. the public from radioactive eff'.uents from 9
to the Callaway nuclear power plant is heightened by the possibility 11 of accidents leading to the release of large quantities of 12 contaminated water.
Recommendations for dealing with these 13 eventualities, in the wake of the accident at TMI, have been made by an NRC task force (NUREG-0578, July,1979), by the 14 15 President's Commission on the Accident at TMI (Kemeny Commis-16 sion, October, 1979) and more recently by a U.S. Senate Com-j 17 mittee.
In light of these recommendations, an NPDES Permit h
18 issued to the licensee should a
j 19 (i)
Require high-range radiation monitors capable of
$j 20 operation at accident levels; t
3 (ii) Require that emergency means be available for pro-21 i*
22 tecting the public against various levels and types of radiation, including appropriate medications that 23 24 can protect against or counteract radiation; (iii) Require provisions for storage and treatment of 25.
'9 1arge quantities of radioactive liquid wastes; 2
(iv) Require that the licensee develop and implement a 3
program for testing leakage rates on systems that 4
process primary coolant water which could contain s
high level radioactive materials.
6 These are only a few of the concerns for public safety 7
that have arisen in the wake of TMI.
We feel that the NPDES 8
Permit should take cognizance of all the relevant recommenda-9 tions for monitoring and handling liquid radioactive discharges
]
10 in the event of an accident.
11 Any permit aimed at maintaining water quality standards 12 and of protecting the public health must address the issue of i
13 what happens when the operating life of a nuclear reactor is i
)
14 aver.
The pollutant-discharge permit should nandate proper is dismantling of the plant and all its facilities, and'a return 16 Of the site to its initial uncontaminated condition.
If this to j
17 l1ot done, the public will be exposed to dangers of radioactive j
j effluents from the effects of rainwater, seepage, ground water 18 tnd soil contamination for thousands of years to come.
j 19 i
Y j
20 In conclusion, we want to insist on the exercise of the l
a 21 state's police power, under the Constitution, to protect the 22 bealth and safety of the citizens of our state.
This power was 23 not delegated to the Federal government, and certainly not to
- he Nuclear Regulatory Commission, but was reserved to the 24 1
25 states and to the people by the Tenth Amendment to the U.S.
l.
1 Constitution.
The State has also been granted authority by the 2
Environmental Protection Agency under the Federal Clean Water 3
Act of 1977 (33 USC 1342) and the Missouri Clean Water Law 4
(204. 026 RSMo,1973 Supp. ) to administer the National Pollutant 5
Discharge Elimination System permit program so as to accomplish 6
the objectives of both state and Federal acts.
The objective j
7 of the Federal Act is "to restore and maintain the chemical, i
l 8
physical, and biological integrity of the Nation's waters...
9 It is the policy of the Congress to recognize, preserve, and l
to protect the primary responsibilities and rights of States to 11 prevent, reduce, and eliminate pollution..."
And as you well 12 know, our State law declares it to be "the public policy of this State to conserve the waters of the State and to protect,
~13
.,)
14 naintain, and improve the quality thereof for public water 15 supplies and for domestic, agricultural, industrial, recreational 16 and other legitimate beneficial uses and for the propagation of 17 Wildlife, fish and aquatic life..."
We cannot carry out this nandate unless the State pays attention to.the radiological 18 j
19 bazards we have discussed and other speakers have discussed a
20 dere today.
j 21 Thank you.
22 MR. SCHREIBER:
Mr. George Sabre.
23 MR. GEORGE SABRE:
I'm George Sabre of 40 Forestville, 24 Chesterfield, Missouri.
I would like to petition for radio-25 active law created in Columbia, Missouri, it is full of loop-holes, and it alleged tha't it would, it's trying to place the
~-
')
2 law application under the Public Service Commission, which in 3
my viewpoint is absolutely wrong, Control and application 4
should stay with the Natural Resources.
We should only have 5
palatable water into our streams and into our ground by Union 6
Electric.
7 TheyYe radioactive waste and they are going to continue 8
with this nuclear plan should be placed in lead-lined concrete-9 proof vaults, but not allowed to discharge in the Missouri 10 River.
Your standards here for Union Electric under this NPDES 11 No. Missouri Act 0098001 is in conflict with the St. Louis 12 County Water Company's standards.
The public should be pro-
)
13 tected, and I would urge anyone reading th'e transcript or in 14 this room, that they would urge their Senators and House of 15 Representatives to attend a special meeting in September on radioactive waste and to create law that would protect the 16 17 health and welfare of the people.
g 18 3
Thank you.
t d
19 MR. SCHREIBER:
Mr. Ziegler.
i 8
g 20 DOUG ZIEGLER:
You don't mind if I sit, do you?
i 21 MR. SChREIBER:
No.
22 MR. ZIEGLER:
I feel more relaxed that way.
I want to 23 give you a little of my background.
I've been a resident of 24
- 41ssouri all of my life.
I was with Multi-Natienal Corporation 25 and I have extensive background education in the physical,.
l
o
+
1 bio' logical, and social science.
I have lived with the streams
^
N 2
and the woods and the people in the City of Missouri.
I have 3
inhabited Missouri lands and waters with laws and awareness and 4
concern for the life-reducing changes that have occurred in my 5
lifetime.
6 This is a public Hearing tonight.
It's a time for citi-7 Zens to have a chance to express and influence those people 8 whose jobs are governing and preserving the citizens.
- Today, 9 I want to exactly -- for the purpose for this Hearing is on 10 paper, it's a Hearing to reduce the wastewater in the' Missouri 11 River.
I would like to see the people who are making this de-cision and know their names and be able to come back on them 12 13 some day and time if they made the wrong decisions.
14 Since this is a public Hearing, I would first like to 15 hear some open discussim.. from those people who are making that decision, but since that's not allowed at this time, I would is g
cequest that we do have a public Hearing where we can intstract 17 with the Clean Water Commission, the people that will be making 18 g:
j 19 :his decision.
We are here to determine whether radioactive i
E 20 l wastewater would be permitted to be dumped into the Missouri a
i 21 River upstream from our drinking water.
My reasons for not al-22 lowing this are simple and clear:
radiation destroys life, and 23 Union Electric intends in the hope nuclear industry are competer t 24 to deal with all of the problems of safety and waste disposal,
)-
25 this radiation will probably be stored in a pool of water and
- 4 1
sealed in a concrete dome in Callaway, like a poison egg to be 2
cracked open for future generations to get a steady dose from 3
the drinking water.
4 U.E. has been in the top ten, has been'one of the top 6
ten in this country's polluters a lot of years and we will be '
6 depending on their integrity and responsibility not to have any 7
accidental leaks into the Missouri River.
I have a feeling a
they would not be the type to say, " Woops, we made a big mistak e 9
and a bunch of Missourians are going to suffer cancer or birth 10 defects."
11 Is U.E. responsible to come in, or is U.E. a drain on the 12 community?
They are involved in making money and keeping their 13 business alive, and truly dupe folks into believing that we nee i j
)
14 nuclear power.
Our rates go up and we are faced with a forever 15 life-taking disaster or at the least, a steady dose of low leve L 16 scheduled and unscheduled releases in the Missouri River.
17 Sure, they say it's okay, but that's their jobs, and joba 18 j
are entangled.
It seems as if we, the common people, are re-j 19 actionary, but I ask the people of the Natural Resources and 20 the Clean Water Commission to act this day with reasonable g
21 cesponsibility for the purity of our State.
The future may wel:
2*
22 3 ring our State to a nuclear disaster.
The citizens of the one 23
- hat happened in Russia or the ones at Three Mile Island, Rox-bury, or Burmey (phonetic spelling), can we simply allow Mis-24
)
25 souri's future, can we simply allow Missouri future to mistakes
1 in corner-cutting by private profit-motivated corporations?
i 2
I come with a sense of compassion and love for you as individual 3
living beings in a world of individuals whose actions seem to 4
have lost sight and responsibility for the integrated, inter-5 dependent, life cycles of things on this earth.
At a time when 6
Computers will decide the actual face in concerning the enact-7 ing of the final world war, can ne as individuals afford to be 8
less than responsible, honest, and aware of the life-destroying 9
problems that affect our community of Missouri?
10 Is it possible for us to continue to succumb to the dic-11 tates of the few powerful, who are in powerful positions, not 12 even be able to call up Missouri citizens?
Should outside in-13 fluences be our guiding light here in Missnuri to assure that we and future generations have a chance to live free of poison-14 l
ing of life and land by exploitation of our rapidly degenerating 15 16 dissouri community?
When all the trees have been cut or poisoned g
Dy" agent orange" for cattle industry, when all the land is paved 17 i
18 by concrete, and there is no more topsoil to support the divers:.-
j 19 ty of life and the Ozark Creek turns green with algae, when 20 dissouri ground and flowing waters poison life, when there is 21 nothing left to support life and we look towards the people to 22
- overnment, the corporations whose decisions have allowed this 23 to happen, when, when does knocking on the door when it's time 24 to respond by accepting the suicidal fate or by joining together 1
-)
25 as a concerned community for all life forms and cooperatively.
i I
work, love, and prod 6ce the environment of Missouri that will 2
assure quality of life for all future generations of species, 3
I ask you not to issue this Permit.
4 Thank you.
5 MR. SCHREIBER:
I don't see any other.
Is there anyone e
else who would like to make a statement at this t ne?
4 7
(No response.)
8 MR SCHREIBER:
I appreciate all the work that you've 9
done in bringing this matter to our attention and we will be 10 looking at it before a final decision is made and we will let 11 that decision be known.
I'll call this Hearing to a close 12 then.
Thank you.
13 (Whereupon the Hearing was called to a close.)
14 15 16 I
l is 3
j 19 a
j 20 21 t
22 23 24 25.
~ ~ ~ ~ ~ - ~
~
^ ' '
~ --
- E
's4 I
U N IO N Ei.ccTnic COMPANY
- 90s ORAf aOT STRE CT -.T. Louis July 16, 1980
" ' 2 'o'.". f.." ' '
.. s o u...........
Missouri Department of Natural Resources P.O.
Box 1368 201 Missouri Boulevard Jefferson City, Missouri 65102 Re:
NPDES No. MO-0098001 Callaway Power Plant Gentlemen:
The attached statement is submitted on behalf of Union Electric Company for inclusion in the record of the Public Hearing to be held concerning the above-referenced permit on July 16, 1980.
In addition, Union Electric Company respectfully requests that all comments previously submitted to the Department of Natural Resources concerning this proposed NPDES permit be incorporated into the. record by reference.
Very truly yours, de Jerrel D.
Smith Manager, Environmental Services Attachment G
9 s
e j
July 16, 1980 UNION ELECTRIC COMPANY Comments on Proposed NPDES Permit For the Callaway Nuclear Power Plant The purpose of this hearing is to provide an opportunity for public comment on the following proposed discharges from Union Electric Company's Callaway Power Plant.
Authority to issue National Pollutant Discharge Elimination System (NPDES) permits has been delegated to the Missouri Department of Natural Resources.
1.
Water treatment plant 2.
Demineralizer system 3.
4.
Oil separator system 5.
Conventional pollutants discharge from the radwaste treatment system 6.
Circulating and service water pumphouses oil separator and neutralization system 7.
Two extended aeration sewage treatment units 8.
Chemical water treatment unit 9.
Intake structure
?. request for certification of these discharges was originally filed with the Missouri Clean Water Commission on December 20, 1974, and certification of the proposed discharges, as required by Section 401, Public Law 92-500, was issued by the
. Missouri Department of Natural Resources on March 26, 1976.
This l
l
action was necessary becausa then current regulations required the state to certify acceptability of such discharges to EPA, the agency formerly responsible for issuance of permits.
Since EPA subsequently delegated this responsibility to the state, applications were filed for the NPDES permit with the Missouri Department of Natural Resources on August 22, 1979.
These discharges were described in the permit application and the Department of Natural Resources public notices of October 26, 1979 and April 11, 1980.
Essentially the same description was included in Chapters 3 and 5 cf the Callaway Plant Environmental Report, originally issued to the Atomic Energy Commission on May 30, 1974.
This document was made available shortly thereafter to federal, state and local regulatory agencies as well as the genera.1 public through the document rooms established for the project in St. Louis and Fulton, Missouri.
Union Electric has previously submitted commenta on the draft permit.
As was pointed out in that submission, we believe certain requirements proposed in the draft permit are considerably more stringent than necessary for compliance with state or federal discharge limitat; ions.
However, on June 12, j
1980 the Company informed the Dep;1rtment of Natural Resources that, in the interest of expediting the issuance of the permit, the corditions would be accepted as proposed.
o pp 4
, ' Radiological Discharges Radiological discharges are not an issue under the NPDES process.
In accordance with the Atomic Energy Act, as amended, i
and Reorganization Plan No. 3 of 1970, the authority to regulate
{
radiological discharges from nuclear facilities, such as the Callaway Plant, resides with the Nuclear Regulatory Commission.
However, since the notice of public hearing indicated that comments received expressed concern about the effects of these discharges on downstream drinking water supplies, it should be pointed out that the discharges from Callaway will fully comply with EPA regulations for drinking water.
The issue of radiological discharges was fully addressed j
j by the Nuclear Regulatory Commission, which is the responsible agency, as part of the review process that culminated in the issuance by the NRC of Construction Permits for the Callaway units.
That review process, which included not only detailed analysis by the NRC staff but also a lengthly series of public and adjudicatory hearings where all interested persons were given full opportunity to express their concerns, resulted in a conclusion that the _adiological discharges would comply with the applicable standard.
The DNR has also made an analysis of the Callaway discharge and concluded that the radiation release would not be in violation of water quality standards.
Thi? conclusion is in agreement with the conclusions earlier reached by the NRC.
O
O 8
_ ~
Additional opportunity for public input on radiological
. discharges will be afforded by the NRC in connection with their review of the application for an operating license for the Callaway Plant.
conclusion The draft NPDES discharge permit has been properly placed on public notice by the DNR and opportunity to submit comments was provided.
Those comments did not raise significant question about the effluent limitations contained in the proposed permit.
Although Union Electric Company believes the requirements of the draft permit go far beyond the requirements of federal or state discharge limitations, in the interest of expediting the issuance of the permit, the Company urges the Department of Natural Resources to promptly issue the permit as proposed.
..:.... %. : r: t:,M. U. s J
. N A f.~A N A
- 9;h* O;.
- ....;...
.t.q':-+M.d.Lt.'. u.s.t*;.;.
- e -
- ,,. /. N 6 4 ^ '. A'% ' A".s&'A"..t. *, n..
- -). v... u.n.
4 A f.^.
' t 9 ' A *A 'r. 7..Y'S 't,' ;g 6,1 /. *, '.... s. f. %
u.m. :.: n.:.'.r?.s. u.. _
A 'M y.
.i
@p,
.g AFFfDAVIT OF PUBLICATION K...
~
4::
~
- IN TIIE --
f.
4~AST. LOUIS POST-DlSPATCH
. St.htis @kbedDemomil W.,...
. ~
M ki+mercent.Nce,spaccr j.>,
[G Ar km;w men' r...vmmer
':s 1
< 7.;
4...*k STA1E Or MISSOUm C;;-
.,. s.
m; CITY OF ST. LOUIS M.
Personally appeared before the undersitined. & Natary Pt:bbc within and for the City and State D. Chesicy _ _
. who beir y duty r.e.or,. deposeth and saith t ah t the annexed N.,
f
- aforesaid..
an g+;
w printed within the said City and State, of which he is an ;inhenzed representative, for
~
MLt.D
- _.udy c f.. J. 3.GO 198 _Q and tho
)*.M,.
3>
times. the first inse* tion being un the N.33 16th day of
.!GU...as follows:
e,.-4..
J.me G
last in:,ertien on the "q4.
l_
- --- ~::: x: :-r =., :.. - -
.=~
e r,;L,*
- 3. '.[
p I
N
- M..
158:' q Junc q__16___ __ Y 0_ R11 0#.
'J * *,.
pd sm. l
}
1 f th tu.
i f*..
a
\\
i.
- .. Os l
- >' 9 1..s.t.t.t.ier st _ a. -
a i
i s.
- bt we. '
.4-.-..
! g, ;
- U*.
t' n
g-t p _,.
'.G
.ttei t r.
_l l'Hti tum*
i.,,j,
- i;t
~*
m :.t, i
l
, 2',t i t.rre
)
W; 5tt N.
g i
- 8. 7_.>
g
~~-
- ",4
_1.st.t.e.r e.r.
-._i-q I -C.
C.t. t. -. {
f I
..T >
- 4
>,: f,
(
[
- 8.* 1 tirre
- s...
. y,p
.f,. c.
7th '..e i
, [,':',,
_ c_i. t.,
I.. _
f
.-_.v._....t..,:-..
M.:>;:
3,_
e y.,,
- i
- p.;.
.,,n.t, 9
,.?..t.t'i_heno
.3.
p,.
t.,",.,. 4q, i
,a_i m.
r,
. h_ e' s
' _7 51t' t.'* * *~...I b"*J.
t Otte t.t'et.
f l
..)
- e.-
I 7* *>
t
-a..~...
e g<,.t l
l_2.(.1_1.t.e.m ;..
g.,
1ithhme l..'g:,t y-
..r.s
- 7IF b ta Q
e U" g ge tne onssone < e.ms e..e
<* ?.*.
n se ne i
n.,.
i
.? :.* -..:fr I
.cw.re,.ea.m. '
4.v c e
. ins sdw e,. s ee ee.-,.e.
e j
ww
_ t, 9.,,,.y.. J.
l
- q.
er, p
- e. : 7 ;.
,. un f.s.
- Oe.r,a e c.....,,. f., e i. v.u.. _
a i
y. f...
7 'i.--
.4 s sr.
-.th !v.ir!.
e n,
,, a..o, y.,.x,._c. i :.w a-
. s.
-4. T, e,.s 1* L
, :. d..
.,nn, tim,.
e.
u%
2 22:. = - _.... t :.': =**.= :.7:-==":.*:=.=:2, 77;.
. ~
..u,,u.. u. r.o.
s.n
~~
/
m.t.s..w.d h.,s..a i.e. rv 3.p.,.
.. y-
- e.. *' ;
r-.:
. i%,
,.g w a e,a,.
eam D. cnes1ey
( ),
gW
(,_
<?..
...u
.m L. #,<
g, s.
p.
\\
- , m n.c,,,'g;*;;~;
N. (~...
.# dl0':
.?,4.,
18th i
3;y~"
u.,y Sworn to and Lobscribed befue me. this v.,
';L."7L*', ',,l", IJ..:.,,.*.;,
,ef :.
- c:.-
-. e
-. m..u.,..
- m. g;.
..m
..i...a.,
3y oI... _e..' m.e.
i
_ 0 t
- e.-
..=.~.....n.u..
.< p.
. 4.. ~
- c. @c..
w.i.a.. i.o..,.. % m ~,
b
- . w u er,.... r,.t..,,
r.a s w.
2' *'.. '.
L g '. ~* s eu v s s.w.
n howe s Ps.tA. c4, a 8.i t t'a s
. Xp g
- s...
.(.
a* *vw can na.e u. i
- *. *e,.m
- s. a,
," d, v.e e
....s s.
a n:4 en ca
.6 h,. *..
yM.
vn n.o cew,i,nsu.m. s,,,e n.e, My ti:rm expires o..m.4"*
em* -
.,, m.
f. >s.
m.. i s.t,'m %. w..h,t.e s,
. n
- c.-.
6. :
.s a.r q.3 p%uwm. s L.
e.e..m.o.a n+mv m eser...ee.m. m.w.a Coet cf advertisement i.,i
, ~.. ;.
.. s.M.-
r n
w*=.
v e
,.. *v
- ci..se.v,.. i.,.-,n,r,.. s.e,,
1.00 e.%.?
f,f.f..
n
- au 4
g,,*?
]~@ 9$
g A!!iowit g.
{idT. E."_'. '.On. "",*o i
ua n
i,Jgp::
1 141.30 I
~.. ~.,,
. '.e ce s w v.
g
,,,,'t u
- * * * =
s.
u C 'I
- 4
.5 g
e.e u..
.s.
.y a,,,
e +t a.# h et
,e.,.,
age.*..
i c o,17 i- -
871 P%
.,p e
. - _ p, '. t. c....,.., tN.t. o,g u.J M: (t & ':...)j!.,0.0.r.N y..st..r. y 1.t..p.i.g.,y,,t1..*;;'y.3.
3
- f...t e.a s.s.-,..
. < e. ~.
I Y4 *t V Wa 1.,;M,i. WP's..v,,'a n;*.W.~ ','.'~,.L~,;.':::
kv J
e
.V,1.
...<,s.:.............e._.
....,t....,......s
=. m e, v.
s.
... u.
l
u u....,v.suu The Missouri Department of Natural Resources will conduct a public hearing regarding the issuance of a wastewater treatment facility construction and opera, ting permit to Union' Electric Co.,1901 Gratiot St., St. Louis, Missouri 63165.
The Callaway Power Plant would discharge wastewater to the Missouri River near River Mile 115, Callaway County. This project is the subject of a pub.lic notice issued by the Department of Ratural Resources on April 11, 1980, on fM0-0098001.
The hearing will be conducted on July 16,1980, frcm 1:30 p.m. to 5 p.m. and from 7:30 p.m. to 10 p.m. at the Parkway East Junice High School, Highway 270 and Ladue, Creve Coeur, Missouri 63141. The purpose of the hearing will be to address objections filed with the agency. The objections alleged that the discharge form the Callaway Power Plant would cause problems with the drinking water supply for the metropolitad area of St. Louis.
The hearing will be conducted pursuant to sections 204.026(11)and 204.066 RSMo., before the Missouri Department of Natural Resources; the rules and procedures for conduct of the hearing are specified in the Missouri Clean Water Law, sections 204.056-204.141, RSMo., and Administrative Procedure Act, Chapter 536 RSMo.
j 1
Speakers at the hearing will be lim;ted to 10 or 15 minutes of testimony.
i
~
Oral testimony may be supplemented with written testimony.
Additional infonaation and/or copies of any materials may be obtained frem the Missouri Department of Natural Resources, Division of Environmental
. uality, Water Pollution Centrol Program, P.O. Box 1368, Jefferson City, l
Q Misscuri 65102, 314-751-3241
' Persons wishing to present oral testimony at the hearing should notify the Director of the Missouri Department of Hatural Resources, F.0. Box 176, Jefferson City, Missouri 65102 by July 6, 1980.
Persons wishir.g to present written testimony may do so by submitting their testimony to the Director sometime prior to commencement of the public hearing on July 16, 1980.
m O
e 4
e S
ah-is me-D he-
es une w-
+
We g
- mm m.
P-rm w esi e e
1: Li W
&~ ws Ca~a E h.
A
, k.
, d
^ L,.,,s.+ 3/ 21aah=J A~~-~~
adaL.s//a M pf24L, M
-dll,n u ly
,LS W",A JA1.a La s.,&-6 wn -tf. A.
net,c-./ A N W A app)A ~ofe a,g^ - ef w'4 +.
a
,o3 gy p 4-.1 A h-L +,&A 4
.7
- a k Aa h_a=Lu s
= a, 4 &
4
>;. A wta h w d l -ej d a 9~ l%y~2~L, A ; L pi /i, n.
a
.,c. y W
~u kl M ld m.
e dA' zuL+ 2, 4 /9~ ML+ n"d LA at,e
.a
\\
at,
..7ha. M d&ajLnm~
,y.
yn a-d n L L~4.
e p.
,d - w x a
,9 R 9 o o YW b A &f&u a A u,s$b~ U,fa:p%~ ;t' a 4 tzf.A-I9 9L 9
da
- , M-J aw,aa a wa
,La.a3-x2 a nu-w ie~-ni PAi R4ua PLA fe d
~)
L e
l @ L J A -,-,b.. d
.x A...
y me uJ...:.J.,Aza 3-9dm
&,.,c/ ~ ' /.fi.~ c n,,.u,..
s-~/
- W L ' We a.A J s'..aacla
-l i
- e., pb g e, e/ Y
- - L-6L z.c A ~ L.,, u f 2 L /.
w C..,.A. L - s~a 7
/
m an e
~
f e - &
e,~ d' 9 c ~ gda, &,
.k l 1 x 4 2.,
.: n
--., g& 4.
M n.-
' k%. ~/ fw-,-
.cfo e,,,..at
- i,.
.< -A -6 p
,w.a-c
{,.,
yn.,,, c.. e,
Jdee 3,ne..r E-< !s Ae j
d L er -=<-es r>,
~ ' -
s / 9La u. '.e
-dl~. b : E k,.) w.J J A } i,.i lL.,.s'~'a l L D N R (%'l~ 7/
&,3..
we y
.da.L,.&.J.s.dY.cn,i-....v(
64
,,n,
=
, tf, ;, c v. a -.,{ ~. d.2d J) c nc, L~ a - J p w-w,. <./,./. c c.-, < <
t
,s. u_,
wn
,,7-&h*?g./
- 0. h*.'
,,?
.2{
a t
- -L, yd+
L nnk.A J,g z~,, n.-4 d
. b ~/'
' '_., '4,g f
.a49;a.
. /a c-
> f,7 ' '+"y y
7 0 '* 4 3').t&iu./.e afi a. e.a,
/
.l J 2..a f
L
-<-r -t
.f1,,w.h4
,... e,.,c / e. -j ~ r. y c., y jf p.
e.
e
);., "
_,_,f,jg',,,_4z f.ve 4. u.
Q, u't -" "
/
2 "- /!)~,/
ij nc.c
- b. c, t e 2 -
g i,J n c. c v-e, 3 a.;,y ju a g g. jf ' s, a /n~ ~ c.--.
^"*'
/
'r v
L.~ p'y a c.
..a. e y
- gts n
r.ve1.unsr eew r
oc 1
(+,s, h,%. d.
G. E.,u o c.jp r VEY!'
a.u
/x w/
~
ne n
o 92y 8/vek.ektet. &J 1.
,oo o
n
[. l. $.3l n:
cO c
, jau u
Exhibit 1: Contribution to Air Pollution 6,(*)(+)t by 'ruel Combustion in Stationary Sources 3
Total Tons (x10 )
Amount emitted Percent emitted emitted / year by by fuel comb by fuel corrb. in Pollutant all sources in stat. sources stat. sources Carbon Monoxide 148.7 0.8 0.54%
Particles 26.1 6.8 26.1",
S0 33.9 26.5 78.2%
x Hydrogen Chloride 34.9 0.6 1.2%
fl0 22.8 10.0 43.9%
x Total 266.4 44.7 Derived frem Table 20 " Estimates of Nationwide Emmissions 1970 from J.H. Cavender, D.S. i'ircher, and A.S. Hoffman, flationwide Air Pollution Emission Trends 1940-1978, Publ. No. AP-ll5, EPA,'
Research Triangle Park, January 1973.
+ Stationary Sources are defined as public utility and industrial power plants, commercial and institutional boilers, and residential furnances.
tThis column does not total to 100 because the values above are for each particular pollutant; the total is for all of the pollutants.
9
O Exhibit 2.
National Costs of Pollution Damage, by Source and Effect 1970
($ billion)
Stationary source Industrial Solid Agricultural Effects Transportation fuel combustion
- processes waste burning Misc.
To-Aesthetics & soiling 0.2 3.1 2.0 0.1 0.2 b'.2
,5 Human health 0.1 2.2 1.7 0.2 0.2 0.2 4
Materials 0.6 0.8 0.3 1
O Vegetation 0.2 Total 1.1 6.1 4.0
' O.3 0.4 0.4 - 12
- Negligible
- Stationary sources are defined as public ytility and industrial power plants, commercial and institutional boilers and residential furnaces.
f 0
1
^
National Costs of Air Pollution Damage, by Pollutant and Effect,1970 Exhibit 3.
($ billion)
T Effect S0 Particulate O
0 Total x
x Low High,Best Low Hi.gh Best Low High Best Best Low High Best 3.4 8.2 5.8 Aesthetics & soiling,c l.7 4.1 2.9 1.7 4.1 2.9
?
?
?
b Human health 0.7 3.1 1.9 0.9 4.5 2.7
?
?
?
?
1.6 7.6 4.6 Materials 0.4 0.8 0.6 0.1 0.3 0.2 0.5 1.3 0.9 1.0 2.4 1.7 e
0.1 0.3 0.2 0.1 0.3 0.2 Vegetation Animals
?
?
?
?
?
?
?
?
?
7 7
?
Natural environnent
?
?
?
?
?
?
?
?
?
?
?
?
?
Total 2.8 8.0 5.4 2.7 8,9 5.8 0.6 1.6 1.1 6.1 18.5 12.3 Notes:
a lso measures losses attributable to NO -
A x
D Property value estimator cAdjusted to minimize double-counting
? Unknown
- Negligible b.
I
Exhibit 4: Annual Health Effects and Occupational Fatalities and Injuries Resulting from Electric Power Production of 1000 tiWe from Coal and t!uclear Fuels Cateaory of Effect or Injury Nuclear Coal 9
10 Industrial Injuries (Deaths) 0.49/ year 3.05 8
~0perations Related Injuries (non-517 days off/ year 833E' lethal industrial accidents in all parts of the program) 8 100 miners totally in-Pneumoconiosis (Black Lung Disease) capacitated at any given time with 6 new cases /
year 4.46 qillion dollars /-
HEW Payments to Black Lung Victims year lu,12 20-100 fatalities / year * '
Excess Deaths of the Public Due to Atcospheric S02 30 million dollars / year Effects due to Acid Rain on Buildings, Land, etc.
yeat-7, 8,10
- This number includes an allowance for the effect an the public of the low probability nuclear calamity, meltdown accident, as well as accidents to workers in nuclear power plants and uranium miners including radiation exposure. The majority of these deaths are mining accidents.
+ EPA research cited in reference (7) indicates that sulfur oxides and particulates cause $11.2 billion per year in danage. Rose stat ~es 61 percent ** of the sulfur. effluents come from electric power plants.8 8
D. J. Rose," Nuclear Versus Fossil Fuel _ Power _ " Massachusetts Institute of Technoloav, Cambridge, Massachusetts (1975).
D. J. Rose, "Muclear Electric Power," Science, 184, 351-359 (April 19, 1974).
10L. C. Lave and Freeburg, L. B., Nuclear Safety, 14_, 409 (September-October, 1973).
More recent information from EPA officials indicate 65% of the U.S. 502 emissions are from power plants or about 20 million tons per year (Chemical & Engineering News, p. 37, (April 23, 1979).
t n
r c>
i
?
Exhibit 5. Annual Environmental Impacts Associated with a 1000-Megawatt Coal-ed Power Plant with a Load Factor of 0.70. Located in Five llegions of the U. S Northern Soutnern fastern Intertor fastern laterior Four Pacific impacts Appalachtan Appalachlan (Illinots' Coal)
(Wyoning Coal)
Corners Northwest fatraction Coal source trable I.lJ Pittsburgh Upper Elkhorn Illinois No. 5 Anderson. Canyon Wepo Forma.
Anderson. Canyon O
Wyodak-Anderson nation (AZ)
Wyodak. Anderson (WT)
(WT)
Stu content of coal (fable 3.29 13.800 14.200 11.400 8.200 11.600 8.200 Coal ash content (5) 3.6 3.9 5.2 6.0 5.2 6.0 (Table 0.58 Sulfur content of coal (1) 1.26 0.9 2.45 0.45 0.6 0.45 trable c.0)
Annual coal requirenents 1.91 1.84 2.29 3.19 2.25 3.19 (105 tons) trable t.41 Land disturt,cd annually 165 195 190 30 100 30 by surface etning (acres) trable !.ll Occupational accidental 0.82 0.58 0,95 0.29 0.20 0.29
~
deaths (persons /yr) a trable !.SI h2515.1181 Refuse produced annually 0.69 No coal 0.69 No coal lie coal No Coal (10' tons),(fables.si processtag processing processing,
processing 1)
Land preestpted annua 11 for 16 b
refuse disposal (acres Transportation and Storage fatalittes per year 0.14 0.18 0.11 1.45 0.16 0.15 fiel.le s.lJ 4.0 3.8 4.8 6.7
- 4.7 6.7 g
tared precepted annually) fs.: coal storage (acres
(
)
(Table 10.8)
Wastes Collected frora Combus-tion and falsilon~1batenent Bottomash(tons /yr) 14.000 14.000 44.000 40.000 23.000 40.000 (w)
(Table 8.31 92.000 153.000 Flyash(tons /yr) 54.000 '
!4.0M q5.000 153^.000 g
LTable 6.31 20-30 20 30 20 30 Land preempted by ash 20-30 2U-N 20-30 b ch ponds (acres) 4.5
}
2.5 4.5 1.5 1.6 2.7 Land preempted annually)b for ash disposal (acres 7M Limestone scrubber sludge 0.24 0.10 0.46 lio scrubblag Iso scrubbing lio scrubbing (805 tons /yr) trate e.dJ U
11A. J. Dvorak et. al, "The Environmental Effects of Using Coal for Generating Electricity,"
Argonne National Laboratory, Argonne, Illinois, NUREG-0252 (June 1977).
3
,m-
,y...r * ; *e
- .. = -*
- e. a r u ne, g, y +, y g.,
..,% 3
,.,..g.p.y,,,
q.g.,
e*
- D e
0
.6 e
e r.
u==
h--
U **
O
- b e
o er 983 M =O edt e O @ r*==
eg efD O. er.t O.==.
- 0. =..=. N. s=4. to.
e.
e.
e.
s=.
8 P*
N ONODOOCOOOs=
N W
se eft e
a e
9 b
3g 1
3b Nam.
.... N. - R.
eft N*
em O
..O.
. N.
e O
O.. O. N.
u N
OOOO OOOOOO M
p e
g Pun og 3-3 I*u b
gg O m==
1
== se b g
~3 3
=.
em t C
t 8-a e.O..
. O.
.. M..,..
O.
MW WmOeh gfD N
=
==
ar '
3 On r=
O N O O O O O O O O a=
- * =
- en-t we
-e 9
b Om
==.
e go
=
e 3
b o ea C
eO 9
==
es gp E
eJ C
C e=e se 3
0 8
m m e m = eat P. M O e gge Po Ob ee =
N N. @. ** epm. et esp e. M. @. P=. ett e.
N.
tre 9 **
==
- =
ct er D C O O O N O O O O tts N
S
- =
ar.
e
- ="U e ed -
, ee -
e se e
w O
toe==e y *3 g
=
=P
.c y '**
e
- r=
b b I
.a
.c s.
o s
W C. A en s 6
{,J,j 88 W
=
J.
I =3 Le me -
1 Pm NS N
N 9
M.
e es C 3e O eft s er. t e em. N. N.
e e.. en.
e e g
OQ O
N 06 90 trl g
t 98 P4 et N
OO OOOO OOO tre N
M
- =
='*e e
D ee
& C A O
- 8 w
b 4,
S 0 ea Ce
==
i b *=
gA 8.*e
.2 48 4
O eft. qma. 4 tdt. N. #84. N. M. O. te. e.
Puh
.a=.
Gdt g t#t W 6 M @ N Pe O t
4 d e
e Pe.
W O4 M O 2h eme w
on N
OO O O O O O a= O O N
Sh we te O db e
e=
en
==
2, 3
e,.
e e.
alt g
es et 9
ed em 7
ma aun C
- b 4O Eb 4O C ee O
e8 O b db
- O ba
== g C
b see h
aan h
b en
- es e8 es a p.
amm M
p G.
D e4 Gk
- em
=
9C Cb ele C C &
W t
i O
ef O W
- in D C
h we V
J sh 9==
W h
==
Vh
== ne 4(
9 w
et O
=
C
& es C a=
9 em C==
a=
4 A
et C
es se O
ap
=* 3 0-
& 3 0==
as O
4 43 W 1>
e* A W>
ad A at CU C
O ene C
es a=
4==
g oe 4 eso e.e
== d g 3m O em O
emme m.
O bC C
* Ob C C D=
e C
- en==
ene et es ai O4S C w N
D C
DWW e4 emme d
O E * ** O
=ed e4 ef 4*
es to
-em e4 9
e se C ** O
==4840
.C se==
==
u es en es b u W
== sun we C
en g===
en=
I ed I
a" e=ue e==
C e este9 W 4=40 e
V em O $P e $
V *Eh 4%
- e to't en.
tsO g h==
b8 8%
ee
-m.,
se 2 - C O to CJ - ee. - to e-
= w e u es e u T== -C3
-e we j
= ee Ca g
es g g O
-gw O a
== to.
=
se e C
-==
as3Ce ees en O en e de=
4 <m n
i E e eC 3 3a =
a a
C 48 & Ch O wt ea a g as.C.
O b b e O 3
m en b n=4eCwe O t J aO O C 4) 8
>O OC
- t. 4 On ue g
h g mp & O e C ens en e.== or e see sh e.== ar 4.8T
& w to==**
3 ee e es e*
4 e eJ w be e.s ten am N== em
-3 4
0 1e. *e*s *eth
== e3 C
- ee O O
h Q ue t* g
- D 4
af*
- a= 4 AQ ta=
es
- tb b Q 9 43 b
- C b e*
3 N'3 ** et.
- e. M
- =
3 C se eH kM e* C C e O **
%=
n E%
- e. %.
toone
== ag O O es ta= W En tvt e e em= u o
g 3 e3 es W be e
t e
9
4 1
j Written prese1tation by Joseph P. Teostle, Governor, State of I
Missouri, for inclusion in the transcript of proceedirns for i
the Department of Natural Resources Public Hearim Regarding the issualce of a National Pollutant Discharge Elimination i
Systen Pennit for lhlon Electric Caipany's Callaway Comty Power i
Plmt near Reform, Missouri.
i j
)
4 e
i l
e
--we p --
m-
---en,
gr_ y -
~__
/
,e EVER SINCE THE ACCIDENT AT THREE MILE ISLAND FIFTEEN MONTHS AG0, PUBLIC CONCERN OVER THE CONSCIOUS DISPOSAL 0F RADI0 ACTIVE MATERIALS INTO THE WATER, AIR, AND LAND HAS GROWN ENORMOUSLY.
IT IS FRUSTRATING, YET PERHAPS NOT
~
INAPPROPRIATE THAT THE FEDERAL LAW ALL BUT ELIMINATES STATE INVOLVEMENT IN THE REGULATION OF RADI0 ACTIVE EMISSIONS FROM NUCLEAR POWER PLANTS, REGARDLESS OF THE FEDERAL LAW, WHEN THE CITIZENS OF THIS STATE ARE CONCERNED ABOUT THEIR GENERAL WELL-BEING AND THE PUBLIC HEALTH, I AS GOVERNOR, MUST DG ALL THAT IS POSSIBLE TO MINIMIZE THOSE CONCERNS, l
l
1 THIS HEARING TODAY IS THE RESULT OF A QUESTION RAISED DURING MY MEET WITH THE GOVERNOR AT WEBSTER GR0VES IN MAY.
AT THAT MEETING SEVERAL PEOPLE EXPRESSED THEIR FRUSTRA-TIONS THAT THE DEPARTMENT OF NATURAL RESOURCES HAD DECIDED NOT TO HOLD A PUBLIC HEARING ON DISCHARGE OF RADI0 ACTIVE POLLUTANTS, AS A RESULT OF THAT CONCERN I HEARD EXPRESSED,.. A CONCERN WHICH I SHARE,,, I DIRECTED THE MISSOURI DEPARTIENT 1
0F NATURAL RESOURCES TO CONDUCT THIS HEARING.
ITS PURPOSE IS TO ALLOW THE PUBLIC A FULL ROLE IN THE DETERMINATION OF OUR STATE.'S POLICY ON A SAFE LEVEL OF RADI0 ACTIVE DISCHARGE.
I WILL KEEP MY PLEDGE TO PERSONALLY DELIVER THE HEARING RECORD TO THE NUCLEAR REGULATORY COM-MISSION FOR THEIR CONSIDERATION..
l
-~
3-I WANT TO KNOW WHAT MISSOURIANS THINK ABOUT THIS.
IS ANY LEVEL SAFE 7 IF S0, WHAT LEVEL?
AND ONCE WE DETERMINE A LEVEL, WHAT PRICE D0 WE AS A PEOPLE PAY,,
A PRICE PERHAPS NOT MEASURED IN D0LLARS AS MUCH AS IN LOWER ENERGY PRODUCTION, HIGHER UTILITY RATES, AND ULTIMATELY, INSUFFICIENT POWER.
I DO NOT UNDERESTIMATE THE DIFFICULTY OF DEALING WITH THIS COMPLEX QUESTION, THIS IS A CRITICAL QUESTION, ONE WITH ARGUMENTS AND EVIDENCE ON BOTH SIDES.
BUT THE TRUE MEASURE OF A GOVERNMENT'S RESPONSIVENESS IS ITS ABILITY TO DEAL WITH JUST SUCH CRITICAL QUESTIONS
... TO WEIGH THE ARGUMENTS ON BOTH SIDES FAIRLY AND DISPASSIONATELY, TO SAFELY AND PRODUCTIVELY PROVIDE FOR THE NEEDS OF OUR PEOPLE, NOW AND IN THE FUTURE. i 1
t I DO NOT BELIEVE ANYONE CAN QUESTION MY DETERMINATION TO PROTECT THE LIVES AND PROPERTY OF MISS00RIANS.
BECAUSE I WAS CONVINCED THERE WAS A REAL POTENTIAL THREAT TO LIFE, PROPERTY AND THE ENVIRONMENT FROM PROBLEMS IN OUR HAZARDOUS WASTE LAW, I CALLED A SPECIAL SESSION OF THE GENERAL ASSEMBLY FOR NEXT SEPTEMBER.
I AM DETERMINED MISSOURIANS WILL NOT BE VICTIMS OF STATUTORY OVERSIGHT OR BUREAUCRATIC INDIFFERENCE.
LET NO ONE MISTAKE MY DETERMINATION TO PROTECT THIS AND FUTURE GENERATIONS... THEIR PROPERTY AND THEIR ENVIRONMENT.
BUT THAT DETERMINATION DOES NOT BLIND ME TO THE NEED FOR AND THE INVESTMENT IN NUCLEAR POWER. s e,
_7._
WHILE EXPERTS MAY DISAGREE ABOUT THE ECONOMICS OF NUCLEAR POWER, THERE IS NO QUESTION THAT IT IS ONE OF THE ALTERNATIVES NOW BEING DEVELOPED.
THE EASIEST WAY TO PREVENT RADI0 ACTIVE DISCHARGE IS TO DISCONTINUE CONSTRUCTION AND USE OF NUCLEA BUT NO RESPONSIBLE GOVERNMENT COULD TAKE THAT SHORT-SIGHTED APPROACH.
WHAT ABOUT MEETING FUTURE POWER NEEDS?
WHAT ABOUT THE MASSIVE FUNDS CURRENTLY INVESTED IN NUCLE PLANNING AND CONSTRUCTION?
IT MIGHT BE EASIER FOR SOME TO SAY; "THAT'S THE STOCKHOLDERS' PROBLEM."BUT IF, THROUGH STATE ACTION, WE BANKRUPT UNION ELECTRIC AND OTHER COMPANIES, WE WILL LEAVE PEOPLE WITHOUT ELECTRIC POWER, WITHOUT GAS AND WATER. -
m e s
- m m epsens e es.
h
- - * * * *-+
,4
- g m e-weg _ _ _ _ _
e
- e==-
e
...C
(
IT SEEMS TO BE THERE ARE TWO COMPELLING URGENCIES:
TO PROVIDE FOR THE SAFETY OF OUR ENVIRONMENT WITHOUT BLOCKING THE DEVELOPMENT OF NEEDED POWER SOURCES.
I ISSUED AN EXECUTIVE ORDER WHICH DESIGNATED THE DIRECTOR OF THE MISSOURI DISASTER PLANNING AND OPERATIONS OFFICE AS THE LEAD AGENCY FOR NUCLEAR EMERGENCY PLANNING IN MISSOURI.
THE DISASTER PLANNING 0FFICE WAS DIRECTED TO PREPARE A MISSOURI NUCLEAR EMERGENCY ASSISTANCE PLAN AND A MISSOURI NUCLEAR EMERGENCY TEAM COMPOSED OF RADIATION SAFETY EXPERTS FROM THE BUREAU OF RADIOLOGICAL HEALTH, THE DISASTER PLANNING OFFICE, THE UNIVERSITY OF MISSOURI, AND FROM PRIVATE BUSINESS.
THIS TEAM IS AVAILABLE TO RESPOND TO ANY EMERGENCY INVOLVING THE RELEASE OF RADIA-TION WHETHER FROM TRANSPORTATION, A NUCLEAR P0',iER PLANT, OR ANY OTHER FIXED FACILITY.
THE PRIMARY FUNCTION OF THIS TEAM IS TO ASSIST LOCAL FIRE, POLICE, AND HEALTH OFFICIALS IN ASSESSING THE EXTENT OF RADIATION CONTAMINATION AND TO RECOMMEND PROTECTIVE ACTIONS IF NECESSARY.
THIS SAME EXECUTIVE ORDER ALSO ESTABLISHED A GOVERNOR'S COORDINATING COUNCIL ON NUCLEAR ENERGY COMPOSED OF THE DIRECTORS OF THE DISASTER PLANNING AND OPERATIONS OFFICE, THE DIVISION OF HEALTH, THE DEPARTMENT OF NATURAL RESOURCES','
THE STATE HIGHWAY PATROL, THE ADJUTANT GENERAL, AND THE THE PUBLIC SERVICE COMMISSION, THIS COUNCIL IS CHARGED i
WITH REVIEWING THE SAFETY AND EMERGENCY PLANS OF THE STATE REGARDING NUCLEAR. ACCIDENTS AND HAZARDS.
ANOTHER MAJOR ACTION IN THE PAST YEAR HAS BEEN THE COMPLETION OF THE STATEWIDE NUCLEAR ACCIDENT PLAN.
THIS PLAN DETAILS STATE ACTIONS IN THE EVENT OF AN ACCIDENT AT 4
J NUCLEAR POWER PLANTS AND OTHER FIXED NUCLEAR FACILITIES.
THE PLAN INCLUDES A LOCAL OFFSITE EMERGENCY PLAN FOR ATCHISON 1
COUNfY WHICH IS ADJACENT TO THE COOPER NUCLEAR STATION.
-7 eu ww
- e ms 9
.mm
-m mm
. m e,.
r
~
i f
THE NUCLEAR ACCIDENT PLAN WAS GIVEN A PRELIMINARY TEST IN DECEMBER 1979.
THE PLAN IS PRESENTLY BEING REVIEWED BY l
THE NRC FOR FINAL CONCURRENCE.
ALSO, PRELIMINARY NUCLEAR EMERGENCY PLANNING IS UNDERWAY FOR CALLAWAY COUNTY AND WILL BE COMPLETED BEFORE THE UNION ELECTRIC PLANT IS CONSTRUCTED.
IN ADDITION THE OFFICE OF PUBLIC COUNSEL HAS HIRED AN OUTSIDE CONSULTING FIRM TO ASSESS THE NEED FOR CALLAWAY',
UNIT II.
A NUCLEAR ENGINEER AND SEVERAL STAFF MEMBERS HAVE BEEN ASSIGNED BY THE PUBLIC SERVICE COMMISSION TO MONITOR CONSTRUCTION COSTS AT THE CALLAWAY PLANT FOR THE PURPOSE OF ASSESSING RATE INCREASE REQUESTS BY THE UNION ELECTRIC COMPANY.
e e
8-
~'"
.-.r
_r_.,.
,._____,m
-, _,., _ ~
r..
...y.
SINCE THE WELDON SPRINGS INCIDENT, THE STATE HAS INCREASED TO A MONTHLY BASIS ITS SAMPLING AND MONITORING OF R DI0 ACTIVITY IN THE WATER SUPPLY OF THE CITY OF ST, CHARLES.
FORTUNATELY WE HAVE NOT FOUND ANY CAUSE FOR ALARM.'
THE NEW SAFE DRINKING WATER ACT WHICH I SIGNED TWO YEARS AGO INCREASES THE STATE'S CONTROL OVER THE MONITORING OF RADI0 ACTIVITY IN PUBLIC WATER SUPPLIES, SEVERAL COMMUNITIES HAVE BEEN ALERTED THAT THEIR WATER SUPPLIES EXCEED THE PUBLIC HEALTH STANDARDS,' OUR CITY OF HARRISBURG SITUATION
~
WAS MOST CRITICAL.
WHEN THAT CITY'S WELL SHOWED THE 111GHEST LEVEL OF RADI0 ACTIVITY AND RECEIVED AN EMERGENCY STATE GRANT TO ABANDON THE WELL AND CONNECT TO A RURAL WATER DISTRICT WITHIN MONTHS OF THE DISCOVERY, g_
_m-._
u
~.-.
- a.,.
THE SITUATION BEFORE US TODAY CONCERNS RADI0 ACTIVE DISCHARGE INTO THE MISSOURI RIVER UPSTREAM 0F THE WATER SUPPLY OF ROUGHLY I40 PERCENT OF THE CITIZENS OF MISSOURI.
WE CANNOT WRITE THIS OFF AS A FEDERAL ISSUE.
I AM EXTREMELY INTERESTED IN THE IDEAS PRESENTED AT THIS HEARING TODAY AND I AM CONFIDENT IT WILL LEAD TO GREATER ASSURANCE FOR THE PROTECTION OF THE PUBLIC HEALTH.
e i
M
M,
~
l
M.ICATION SOR DISCHARGE PERMIT f 00 NOT Nt"IEMPT TO COMPLETE THIS F0E! BEFORE READING THE ACCOMPANYING INSTRUCTIONS.
~
i FOR ACENCY USE ONLY l
A MISSOURI CLEAN WATER COMMISSION P. O. Box 1368 HD -
Jefferson City, Missouri 65101 DATE RECEIVED 1.10 Construct
.a permit application A $25.00 filing fee must accompany each application for a construccion permit.
1.20 Operating permit app *'~
an X
A $75.00 filing fee must accompany each application for an opet...ug pemit.
Fi'.ing f ees must be in the form of check, bank draf t, or money order, payable to the l
State of Missouri. Cash will not be accepted.
2.10 NAME OF FACI'LITY Discharge Line, Callaway Plant, Units 1 and 2 2.11 Thfa Mility is now in operation under Missouri Operating Permit Number 2.12 This is a new facility and was constructed under Missouri Construction Permit Number 26-432 (Complete only if this facility does not have an operating permit i
2.20 Owner Name Union Electric Company Phone (314) 6213222 Ext 2650 Address 1901 Gratiot Street (P.O. Box 149), St. Louis, Missouri 63166 Street City State Zip Code 2.30 Ooerating Authority Name Same as Cuner Phone Address Street City State Zip Code 3.00 DOMESTIC WASTE TREATMENT FACILITIES 3.10 Brief Description of Facilities (if additional space is required, attach sheet) 3.20 Population served:
Number of persons presently connected or Population Equivalent (PE) served Designed to serve a population of 3.30 Does any bypassing occur anywhere in the collection system or at treatment facility?
Yes or No If yes, attach explanation.
3.40 Ultimate Sludge Disposal: (check one)
A.
Landfill B.
Incineration C.
Liquid D.
Other (Attach explanation) 3.50 Is industrial waste discharged to the sanitary '.4ter system?
A.
Yes B.
No.
Q (,4)Q4497 If yes, see Instructions.
r Page 1 4, ve nn c2d
't,22 - 2h
NT 4.00 INDUSTRIAL - (TO BE [ 7LETED ONLY BY INDUSTRY)
{
4.10 Types of wastewater d'ischarged to surface waters:
4.11 Sanitary, average 21,600 gallons per operating day.
Percent created prior to discharge 100%
4.12 Cooling water, average 10, % 7,040 gallons per operating day. (Cooling tower Percent treated prior to discharge 100%
blowdown) 4.13 Process water, average 590,400 gallons per operating day.
Percent treated prior to discharge 22%
f d
,._-/ C
- 4, W,2 N i (,, u ( c; u n 4.14 Maximum discharge gallons per operating day.
4.20 If any of the three types of waste identified in Items 4.10 to 4.14, either treated or untreated, are discharged to places other than surface waters, indicate below as applicable.
4.21 dastewater is discharged to:
Municipal sewer systems *'- Average gallons per operating day.
Septic tank - Average gallons per operating day.
Evaporation lagoon _or pond - Average gallons per operating day.
I Other, specify
- Name if Municipality or authority receiving wastes 4.30 Brief Desetiption of Facilities (if additional spae is required, attach sheet).
i 5.5-mile discharge line, from the plant area to the Missouri River, to convey plant effluents combined w'ith the Cooling Tower and Water Treatment olant blowdowns.
4.40 Number of separate discharge points:
(check one)
I i
' A.
X 1 B.
2 C.
3 De 4
E.
5 T.
6 or more 5.0f TO BE COMPLETED BY ALL APPLICANTS:
5.10 Check all items that apply:
5.11 X Discharge occurs all year.
5.12 Discharge occurs during the following months:
January February March April May June July August September October November December 5.13 Discharge occurs 7
days per week.
5.20 Does your discharge contain or is it possible for your discharge to contain one or more of the following substances: ammonia, cyanide, aluminum, berv1 Hum, cdmium, chromium, (copperl lead, mercury, @ selenium, zinc, phenols, and @il and g Ee )a X
yes no If yes, circle those present.
5.30 Chlorine is added X yes no with a resulting residual of 0.2**
mg/1, 5.40 Location of facility: Ek, k, Sec. 14, Twp.46N, Rge. 8W, County Callaway 5.50 Name of Receiving Scr,eam Missouri River 6.00 I certify that I am familiar with the information contained in the application, that to the best of my knowledge and belief such information is true, complete and accurate, and if granted this permit, I agree to abide by the Missouri Clean Water Law and all rules, regulations, orders and decisions, subject to any legitimate appeal available to applicant er the M:tssour Clean Water Law, of the Missouri lean Water Consnission.
[.2
._M Date:
ApplTcant's Signature (owner or his legally authorized repres'entative)
/
- See attached sheets.
CWC 105 Rev. 4/74 Page 2
~
l 5.20 Chemical Discharges The plant discharge may contain any or all of the substances listed in Section 5.20, but only copper, nickel, and oil and grease will be added from plant waste sources. Most of the substances listed have been detected in Missouri River water samples. Any substances prestnt in the river water supplied to the plant will be concentrated by a factor of approximately four in the plant cooling towers and will be returned to the river in the cooling tower blowdown.
Small ascunts of copper and nickel may be added to the plant discharge due to erosion and corrosion of condenser, tubes. Quantities of these substances added to the discharge are estimated as follows:
lb/ day ag[1 j
Copper 18.0 0.15 Nickel 2.0 0.017 All wastes seeerated in the plant that may contain oil and grease are sent to :n oil separator unit. The maximum concentration of oil in the separator discharge will be 15 mg/1. Effluent volume will be so low that, when combined with cooling tower blowdown and other plant discharges, the oil content will be negligible.
5.20 Radioactive Discharges Based on conservative assumptions, the maximum calculated yearly per unit releases of radioactive liquids are as shown in Table 1.
It is expected that actual releases will only be a fraction of those given in the table.
Annual average concentrations of radioactivity prior to discharge based on the calculated releases are given in Table 2.
Processing of liquid radwaste and release (when necessary) will be done on an intermittent basis. Release rates will be controlled administrative 1y to minimize any potential environmental impact.,
All radioactive releases from the plant are directed to the discharge line from the radwaste building and are diluted with 5,000 gpm dilution flow per unit. This dilution flow insures the "as low ~as reasonably achievable" radioactive discharge criteria are met.
5.30 Biocide Treatment of Recirculating Cooling Water To prevent biological growths and condenser fouling, the recirculating cooling water is treated intermittently with sodium hypo-chlorite solution.
It is anticipated that hypochlorite will be added two times a day per unit, with a duration of one hour per treatment.
The units will not be treated concurrently. The maximum chlorine residual level in the water returning to the cooling towers will be 0.5 mg/1.
This level will be reduced when blowdown from the cooling tower being treated is combined with blowdown from the second tower. The level will be reduced even further during the one-hour transit time in the five-mile long discharge pipeline. The estimated maximum chlorine discharge to the river is 0.2 mg/l for a maximum period of two hours per day per unit.
m%
....w-a-
- m.mewe.o w e e--
e===
==.---=w+
=* - " - "
~
~*
e A
M k S4CMCC NW4Comm434NC*CCCCCCC e>
- N*N*
CCC@@@@*CCCCN4Co@mCC U%
CCCCN*
CCC**CCCCCCnom@@ Nm@N om CCCCCC CCCCCCCCCCC4CCmmCCNN HU C. C. C. C. C. C.
C.C. C. C. C. C. C.C.C. C.C.C. C.C.C. C. C. C. C. C.
a j
v I
a at CCCCON CCCCCCCoeecmCCCCCCCC gg >
C-CC4e CCCCCCCCCCCCCCCMCCWC Ma%
CCCCCC CCCCCCCCCCCCCCCM CCNC i
eaw CCCCCC CCCCCCCCCCCCCCCCCCCC w40 q
3w C. C. C. C. C. C.
C. C. C. C. C.C.C. C. C. C. C.C. C.C.C. C. C. C. C. C.
,nn WM k S4CmNG NN444MM43@NNmm*@mm@c Mw>
C"CNmeN CComecomCCCCNmmcemom aM%
CCC CCCCC"O CCCmmCCCCoonC~@MNm4N sew C
CCCCCCCCCCC4CCmMCONN muu C C C. C C. C.
C.C. C C C C.C. C C C C.C. C C C. C C.C.C. C.
]
9 ov e
4H i
Ae ecmmNN CCCNNCC**CC@m@mNmm44 e
CCCmC CCmmCCCCCCNCCC*m@m4 l
C.
C.
C. C.
. C. C. C.
. b...
m ou 1
W Hv 6
a W
mn I
M M e CCCCCC CCONNCCCCCCCCmemmCCC i
me CCCCCC CCCCCCCCCCCWCC4CmCCC g
CCCCCC CCCCCCCCCCCCCCCCCCCC
)
W i s 883888 88888888888888888888 mW 4
Sv mb H
WQ t
Wwm J
D MJO un
<<m ea CCCCCC CCCCCCCCCCCCCCCCCCCC HD4 9 0 CCCCCC CCCCCCCCCCCCCCCCCCCC C*
CCCCCC CCCCCCCCCCCCCCCCCCCC ob CCCCCC CC CCCCCCoCCCCCCCCCCC
\\
u3 C. C. C. C. C. C.
C. C.C.C.C. C.C. C. C.C. C.C.C. C.C. C. C. C. C. C.
00 A
mw W
)
D en U
ma CCCONC CCC44CCCCCommmememNN J
W ee CCCCCC CCCCCCCCCCCNComCCCCC j
3w CCCCCC CCCCCCCCCCCNCCCCCCCC U
h CCCCCC CCCCCCCCCCCCCCCCCCCC 1
3 C. C. C. C. C. C.
C. C.C. C.C. C. C. C. C. C. C.C. C.C.C. C. C. C. C. C.
\\
uu i
aw d
w E
a un nommmm CCCW@CC~CCCNmmCeCmnN Me CCCCCC CCCCCCCCCCCCCCCCCcmW e
CCCCCC CCCCCCCCCCCCCCCNCC~m Cm CCCCCC CCCCCCCCCCCCCCCCCCCC o6 C. C. C. C. C. C.
C.C. C. C. C. C. C. C. C. C. C. C. C. C.C.C. C. C. C. C.
u2 ou mv 5o e
w MNNmem mmmomN~"NM CCCNM Nmm4m M
CCCCCC CCCCCCCCCCCCCCCCCCCC we e
+ +++++
e +++ e + e + e s + + + e s + e + + e M e WCCCmN ONCmCmNCmbemmememCON e >
w N. m. m. m. m m.
C. W. N. N. e. o. m.4. W. m N. C. N. m. W. 4 5. m. *. N.
a wg a
u Ma u
Nmm46m u
MmmNNMmm4mmmmmeNNmen ew e
2 M
9 4
o a
w G&
b ou e
e r C
S 8
5 E
T me o
ENNmm N
4
@NN w
oo mommec m@memNNNNCmemNmmmmmm m
L W mmmmm@
m Wemmmmmmmmmmmmmmmmmm u
u%
e e e e e e a
e e e e e e e e e~e
- e mm e e e e e 3
o k ceeoo 64 oueoeee c6 ee e ae aae X
U UEbbuU b
MM6 EHHHHHmHmHmmWmWUM O
- e-.e-e--
-.e
,w
.--,e-.
e-e
i f
s I
I l
j
(
i TABLE 1 (Cont.)
CALCULATED ANNUAL EFFLUENT RELEASES LIQUID Adjusted Detergent Half-life Boron Rs Misc. Wastes Secondary Turb. Bldg. Total LWS Total (1)
Wastes Total Nuclide (Days)
(Curies)
(Curies)
(Curies)
(Curies)
(Curies)
(Ci/yr)
(Ci/yr)
(Ci/yr)
Ba-140 1.28+01
.00000
.00000
.00000
.00000
.00000
.00002
.00000
.00002 La-140 1.67+00
.00000
.00000
.00000
.00000
.00000
.00002
.00000
.00002
{
All others
.00000
.00000
.00000
.00000
.00000
.00007
.00000
.00007 l
Total l
(Except tritium)
.00603
.00317
.00000
.00107
.01027
.16027
.00623
.16000 i
I -
Tritium release 410 curies per year (1) Adjustment i,s 0.15 Ci/yr based on Regulatory Guide 1.112.
1 i
f l
i 1
i i
f
.o TABLE 2 4
AVERAGE ANNUAL DISCHARGE CALCULATED ISOTOPIC CONCENTRATIONS ASSLdING l
5,000 GPM DILUTION FLOW (PER UNIT)*
i Average Annual Discharge Concentratfon Isotope (uCi/g)
-5 H-3 5.89x10 Cr-51 2.73x10'Il Mn-54 2.01x10'II Fe-55 2.87x10'II Fe-59 1.58x10'Il
-10 Co-58 3.16x10
-10 Co-60 1.58x10 l
Br-83 2.87x10-12 Rb-86 1.01x10'II l
Sr-89 5.75x10-12
-10 Mo-99 2.73x10
-10 Te-99m 2.59x10
-12 Te-127m 4.31x10
-12 Te-127 4.31x10 Te-129m 2.01x10'II 1.29x10'II j
Te-129
-12 I-130 8.62x10
.Te-131m 2.87x10'I
~9 I-131 6.18x10 I
-10 Te-132 1.02x10
-10 I-132 2.01x10
~9 I-133 2.30x10
~9 Cs-134 4.89x10
-10 I-135 4.17x10 l
-~
~-
- ~.
t 1
TABLE 2 AVERAGE ANNUAL DISCHARGE CALCULATED ISOTOPIC CONCENTRATIONS ASSUMING I
5,000 GPM DILUTION FLOW (PER UNIT)*
Average Annual Discharge Concentration Isotope (uCi/g)
-9 Cs-136 1.36x10
~9 Cs-137 3.74x10
~9 Ba-137m 3.16x10
-12 Ba.40 2.87x10
-12 l
La-140 2.87x10 i
l i
I
- Assumption: Continuous discharge over one-year period.
bBased on total annual releases and a 70 percent plant capacity.
q, op.-ee w,,
mm.
a-
-=
._4-
~-a+-.m.---_
- - - ~, - - - *. -
==
-**- + + =
-w
W~
SUPPLEMENTAL DATA CALLAWAY PLANT WASTEWATER DISCHARGE SOURCES i
Water is supplied to the Callaway Plant site through a 5.5~-mile long pipeline from an intake structure and pumping station on the Missouri River.
Three 14,000 gpa pumps at the river transfer water through the 48-inch diameter pipeline to the site water treatment plant. Clarified water from the treatment plant flows by gravity to various systems on the site.
Most of the water is used to replace water lost by evaporation, drift, and blowdown from the plant's cooling towers.
A 24-inch diameter discharge line conveys effluents from the plant to the Missouri River. The primary purpose of the discharge line
[
is to transport cooling tower blowdown to the river. All other plant waste streams also enter the discharge line. Each of the waste sources is described below.
t 1.
Cooling Tower Blowdown Blowdown will be discharged from two recirculating water cooling towers. The blowdown will contain constituents found in Missouri i
River water concentrated by a factor of four, plus constituents added by chemical treatment of the cooling water. Chemicals added will be sulfuric i
acid for pH control, organic phosphonate dispersant for scale control, I
and sodium hypochlorite for control of biological growths. These chemicals will add the following maximum amounts of constituents to the blowdown:
1 4
f
... ~,
9
=..
.. =. -
- . = -.
.~
l f
Sodium 59 ag/l Sulfate 260 mg/l Chloride 92 ag/l i
In addition, a maximum concentration of 0.17 ag/l of copper is estimated to be added by condenser tube erosion. The pH of the recirculating i
water (and thus the blowdown) will be maintained in the neutral range (6 to 9)'by addition of sulfuric acid. Continuous automatic pH monitoring I
will be provided.
Sodium hypochlorite will be used as a biocide in the recirculating cooling water systems. The hypochlorite will be generated on-site and will be fed to each cooling system on an intermittent basis. The anticipated feeding program is two periods per day per unit, 60 minutes per period.
Automatic asalyzers will be used to continuously monitor chlorine residuals in the reeirculating cooling water and in the blowdown from each tower.
Free available chlorine in the blowdown will be limited to a maximum value of 0.5 mg/l and an average valu,e of'O.2 mg/1. No chlorine will be discharged from any unit more than two hours in any one day, and chlorine will not be discharged from both units simultaneously.
Blowdown temperature will range from 64*F (average for January) to 88*F (average for July and August). The maximum blowdown temperature at the cooling tower design point would be 95*F.
me 2
. ~.-
~~
Cooling tower blowdown is sent to the plant discharge line, which empties into the Missouri River. Blowdown flow from each tower is continuously monitored and controlled. Cooling tower blowdown flows are summarized below:
Avera ge Maximum Unit 1 5,484,000 spd 6,735,000 spd Units 1 and,2
.0,967,000 gpd 13,471,000 gpd 2.
Water Trestment Plant Sludge All water used at the Callaway site will be drawn from the Missouri River to receive clarifying treatment in the site water treatment plant. The sole purpose of treatment is to remove suspended solids, and liquid polyelectrolyte is the only chemical added. Polyelectrolyte dosage will be about 0.5 mg/1. The treated water will have a maximum suspende'd solids content of 15 mg/1. The solids removed during treatment are returned to the plant discharge line as sludge. Solids concentration in the sludge will vary according to river conditions. Average and maximum sludge suspended solids concentrations are estimated as 41,700 mg/l and 52,400 mg/1, respectively. When cooling tower blowdown flow is reduced, flow augmentation is provided from the intake line to provide conveying water for the sludge. Sludge flow entering the discharge line is continuously monitored and is es'timated as follows:
3 O
?
s
_.._ ___ _ a _ i L i-.
2
-a l*
Average Maximum Unit 1 187,000 spd 230,400 gpd 4
Units 1 and 2 374,400 gpd 460,800 gpd 1
3.
Demineralizer System Wastes 4
Gravity sand filters, activated carbon filters, and two ion exchange demineralizer trains are used to produce high-quality make-up 4
water. Sulfuric acid and sodium hydroxide are used to regenerate the i
demineralizers. The wastewater discharge from the demineralizer system will include backwash water from the sand and carbon filters, demineralizer regenerant wastes, and miscellaneous wastes such as floor drainage, sample streams, and safety shower discharge Regenerant wastes and floor drainage are collected in a 150,000 gallon neu'ralization tank for-t automatic pH adjustment prior to discharge. The pH of the wastewater will be continuously monitored, and the discharge valve will not open until an acceptable pH range is established. Waste constituents will
]
include sodium, sulfate, dissolved solids removed by the demineralizers, and suspended solids removed by the filters. Automatic flow monitoring of the demineralizer waste discharge will be provided. Demineralizer system vaste flows will be as follows:
Average Maximum Unit 1 89,000 gpd 133,500 gpd Units 1 and 2 178,000 gpd 267,000 gpd
~
D 4
_ _ ~ - -
-~ -
~.
- 9
)
I 4.
Oily Wastewater Separator Discharge Sumps in the power block and fire protection building will co'. lect equipment leakage, maintenance drainage, and washdowns. This wastewater will be pumped to the site oily wastewater separator system for treatment prior to discharge. The system will include a 23,000 gallon storage and equalization tank and an oil separator with both gravity separation and coalescing filters for emulsified oil removal. Oil removed by the system is stored for off-site reclaiming.
1 1
l The oily wastewater separator is designed to produce an average a
effluent oil content of-15 mg/l and a maximum daily effluent concentration of 20 mg/1. Flows to the separator will be intermittent and variable, and daily volume is expected to be quite low. The oil separator will treat the wastewater.as required at a flow rate of 100 gpm, which will be the maximum flow to the plaat discharge line. A means for flow monitoring or determination will be provided.
i 5.
Cooling Water Chemical Treatment System J
4 The facilities for cooling water chemical treatment include a small sodium zeolite water softener for makeup water to the sodium hypochlorite generation system. The sof tener is regenerated with brine, and the spent brine solutica is sent to the plant discharge line. The spent regenerant will include excess salt and dissolved solids removed by the softener. Discharge will be intermittent. Flow will be monitored and is estimated as follow's:
5
r.
t Average Maximum Unit 1 1,000 gpd 2,000 gpd Units 1 and 2 2,000 gpd 4,000 gpd Other wastewaters collected in the chemical treatment building will be collected in a sump and pumped to the Unit 1 cooling tower i
basin. Pump capacity is 50 epa. This discharge will include washdowns, pump seal water, hypochlorite cell cleaning wastes, safety shower discharges, and maintenance drainage. Waste constituents will include dilute sodium hypochlorite, dilute hydrochloric and sulfuric acids, and dilute brine.
j The wastewater is ultimately discharged with the cooling tower blowdown.
Flows will be variable and intermittent, and yolumes will be quite low.
4 6.
Circulating and Service Water Pumphouses Each cooling tower will have an associated pumphouse housing i
the cooling water pumps. Chemical fsed equipment and cooling water I
monitoring instruments will also be located in the pumphouses. Sample streams, washdowns, and equipment leakage will be collected by floor drains and routed to oil separator and neutralization sumps prior to discharge to the plant discharge line. Sump pump capacity is 100 gpm.
Flows will be variable and intermittent, and volumes will be quite low.
6
-. ~. -
\\
i 4
.. -. so g
~
u.
7.
Sanitary Wastes Domestic wastes are routed to a sewage treatment plant on the 4
site. The plant consists of a lift station, surge basin, and two package-type extended aeration units operated in parallel. The system is now in operation during plant construction with treated effluent being discharged to an on-site settling pond. The sewage treatment plant effluent will not be sent to the plant discharge line until Unit 2 goes into service, which is scheduled for April, 1987. The treatment plant is designed to 4
4 reduce effluent BOD and suspended solids to 30 mg/l each. Effluent flow rate is continuously monitored and recorded. Anticipated flows are i
listed below:
Average Maximum Units 1 and 2 21,600 gpd 34,200 spd 1
8.
Intake Screen Ba'ckwash Water required at the plant is pumped from the Missouri River j
by three pumps located in the plant's intake structure. Each pump has a capacity of 14,000 gpm. Associated with each pump is a fixed trash rack and a traveling screen to prevent river debris from entering the intake flow. The screens are backwashed approximately 20 minutes every hour with strained river water. There are also filters and strainers that require backwashing. These discharges are returned to the river and will consist of river water plus any solids collected during screening.
Flows are estimated as follows:
7 J
,n,n.-..mma -
--rn-.
~ ~ ~ ~~
~ ~
~~
I Average Maximum l
Unit 1 460,800 spd 691,200 gpd i
Units 1 and 2 691,200 spd 1,036,800 spd 9.
Intake Structure Discharges A sump located in the intake structure collects any leakage from piping or equipment. This water will essentially be river water
]
that has been strained and filtered. The sump has a 150-gpa capacity pump that discharges the water collected back to the river. The sump is i
baffled to retain both solids and floating materials for recovery and disposal. Flows to the sump are expected to be minimal.
10.
Liquid Radwaste Treatment System Data on this discharge were submitted with the original discharge permit application.
I l
t
)
i 8
M 44 9
4'
- O
%e
. ~. -- ---,,
e -=
=. ee *
= -.
. -.w eso, u -
April 11,1980 3
kehotice of public notice issued October 26, 1979 4
APPLICANT INFORMATION AND FACT SHEET FOR Callaway Nuclear Power Plant Application No. MO-0098001, Callaway Power Planc, Reform, Missouri 65077, owned by the Union Electric Company,1901 Graciot Street, P. O. Box 149, St. Louis, Missouri 63166, has applied to discharge to Missouri River (Missouri River Basin) at River Mile 115.4 Callaway County, wastewater resulting from Callaway Nuclear Power Planc. The discharge is a proposed discharge with a design flow of 15,802,273 gal / day. The proposed permit terms and conditions, prepared by the Jefferson City Regional Office and the Central Office, are as follows:
PROPOSED PROPOSED EFFLUENT LIMITATIONS MONITORING REQUIREMENTS Interim Final Limitations Limitations Effective Date Issuance Outfall Number and ag/l Measurement Sample Effluent Parameter (s)
(lbs/ day)
Frequency Type OutJail #001 - Radwaste System 3
Flow-m JDay (MGD) when discharge 24 hr. total occurs Total Suspended Solids
- Monthly average 30 (7.1) when discharge grab i
occurs
- Daily Maximum 45(10.7) when discharge grab occurs 011 and Grease
- Monthly Average 15 (3.6) when discharge grab occurs
- Daily Maximum 20 (4.7) when discharge grab occurs pH - Units 6.0 - 9.0 when discharge grab (Not to be averaged) occurs Outfall #002 - Cooling Tower Blowdown
' continuous 24 hr.
Flow-m / Day (MCD) recorder Total Suspended Solids once/ week grab Total Dissolved Solids once/ week grab 011 and Grease
- Honthly Average 15 (1685) once/ week grab i
- Daily Maximum 20 (2247) once/veek grab j
Dissolved Copper
- Monthly Average 1.0 (112) once/ month grab
- Daily Maximum 1.5 (169) once/ month grab Dissolved Nickel
- Monthly Average 1.0 (112) once/ month grab (continued on next page) m.-
y
~.
April 11, 1980 6
~
N0-0098001 Callaway Power Plant (continued)
PROPOSED PROPOSED EFFLUE)rr LIMITATIONS MONITORINO RE0UIREMENTS Interim Final Limitations Limitations Effective Date Issuance Outfall Number and ag/l Measurement Sample Effluent Parameter (s)
(1bs/ day)
Frequency Type Outfall #005 - continued Total Suspended Solids i
- Monthly Average 30 (36) once/ month grab
- Daily Maximum 100 (120) once/ month grab 011 and Grease
- Monthly Average 15 (18) once/ month grab
- Daily Marte n 20 (24) once/ month grab pH - Units 6.0 - 9.0 once/ month grab (Not to be averaged)
Outfall #006 - Circulating and Service Water Flow-3 / Day (MGD) once/ week instantaneous Total Suspended Solids j
- Monthly Average 30 (36) once/ month grab
- Daily Maximum 100 (120) once/ month grab t
011 and Grease
- Monthly Average 15 (18) once/ month grab
- Daily Maximum 20 (24) once/ month grab pH - Units 6.0 - 9.0 once/ month grab (Not to be averaged)
Outfall 4007 - Sanitary Waste once/ week 24 hr. total Flow-s / Day (MCD) 31ochemical Oxygen Demandy
- Monthly Average 30 (8.6) once/ month comp.****
- Daily Maximum 45 (13) once/ month comp.****
l Iotal Suspended Solids
- Monthly Average 30 (8.6) once/ month comp.****
- Daily Maximus- -
45 (13) once/ month comp.****
pH - Units 6.0 - 9.0 once/ month grab (Not to be averaged)
Outfall 4008 - Chemical Water Treatment Unic once/ month instantaneous Flow-m / Day (MCD)
Total Suspended Solids
- Monthly Average 30 (1.0) once/ month grab
- Daily Maximum 100 (3.3) once/ month grab (continued on next page)
==
e a April 11, 1980 5
110-0098001 Callaway Power Planc (continued)
~
PROPOSED PROPOSED E77tUENT LIMITATIONS MONITORING RIOUIRIMENTS Interim Final Limitations Liaications Effective Date Issuance
~~
Outfall Number and 33/1 Measurement Sample Efflu$nt Paramecer(s)
(1bs/ day)
Frequency Type Outfall #002 - continued
- Daily Maximum 1.5 (169) once/ month grab Free Available Chlorine
- Monthly Average 0.2 (22) once/ week grab
- Daily Maximum 0.5 (56) once/ week grab Temperature
'T ( C) 95'F(35 C) continuous 24 hr.
recorder pH - Units 6.0 - 9.0 continuous 24 hr.
(Not to be averaged) recorder outfall 4003 - Water Treatment Planc
~
ence/ week instantaneet Flow-s / Day (1fGD) l Tocal Suspended Solids
- Monthly Average 30 (115) once/ month grab
- Daily Maximum 100 (384) once/ month grab 011 and Grease
- Monthly Average 15 (58) once/ month grab
- Daily Maximum 20 (77) once/ month grab pa - Units 6.0 - 9.0 once/ month grab (Not to be averaged)
Ouefall il004 - Domineralizer System 3
ance/veek instantanec-Flow-3 / Day (MGD)
Tocal Suspended Solids
- Monthly Average 30 (67) once/ month grab
- Daily.W-4-_=
100 (223) once/ month grab 011 and Grease
~
15 (33) once/ month grab
- Monthly Average
- Daily Maximum 20 (45) once/monch grab pE - Units 6.0 - 9.0 once/ month grab (Not to be averaged)
Outfall 4005 - 011 Separator once/ week inscantanee-l Flow-e / Day (MGD)
(concinued on next page)
.~..
l e
MD-0098001 Cillaway Power Planc April LL.1(980 continued) 6 PROPOSED PROPOSED EFTLUENT LIMITATIONS MONITCRING REQUIREMENTS Interim Final Limitacions Limitacions Effactive Date Issuance Cucfall Number and ag/l Measurement Sample Effluent Parameter (s)
(1bs/ day)
Prequenev Troe Outfall #008 - continued 011 and Grease
- Monthly Average 13 (0.5) once/ month grab
- Daily ymv4="=
20 (0.67) once/ month grab pH - Units 6.0 - 9.0 once/ month grab (Not to be averaged)
Outfall 4009 - Intake Structure Sump once/ week 24 hr. total ylow-m / Day (MCD)
Tocal Suspended Solids
- Monthly Average 30 (54) once/ week grab
- Daily y= = 4 -"a 100 (180) once/ week grab 011 and Grease
- Monthly Average 15 (27) once/ week grab i
- Daily Maximum 20 (36) once/veek grab pH - Units 6.0 - 9.0 once/ week grab (Not to be averaged)
Monthly Average: the cocal mass or concentration of all daily discharges samoled during a calendar month divided by the number of daily discharges sampled or measured during that month.
Daily Farianne: an effluenc limitation chac specifies the total mess or average concen-tracion of pollucancs that may be discharged in a calendar day.
Monitoring requirement only.
Conposite shall consist of a sinimum of 4 grab samples in a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> period with a sinimum of 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> between each grab sample.
PROPOSED SCHEDULE OF COMPLIANCE Not applicable PROPOSED SPECIAL CONDI* IONS t
i In issuing this persic, the Missouri Clean Wacer Commission has not determined whether or not the radloactive discharges from chis planc will affect wacers of the state.
l.4-Radioactive discharges are the responsibility of the Nuclear legulatory Commission, and any discharges of these constituents will be under che NRC's regulacion.
PROPOSED OTu,gg ggggigggnr73 Discharge Limitations - There shall be no discharge of polychlorinated biphenyl compounds l.
l (9.ont,hd on next page)
,r April 11, 1980 7
- n-0098001 Callaway Power Plant (continued) 2.
Intake Structure (s)
Within 90 days of the receipt of the permit the permittee shall submit to the Department for review, =cdification and approval the design for an intake monitoring program to document the effects of the plant intake structures on the various species and life stages of fish. Sampling shall be performed veekly (unless the permittee justifies an alternative schedule to the satisfaction of the Department) on random days and shall include the number, size, weight and species of fish trapped by the present intake structure. An assessment shall also be made of other nekton which may be entrained in the water used for cooling. The sampling program must be conducted in a manner to evaluate diel and seasonal fluctuations. The program shall also include stream flow, cooling water flow, source and discharge water temperature and screen operation schedule.
The monitoring program shall be implemented within 90 days af ter approval of the monitoring program. Monthly monitoring reports shall be submitted.
Within 18 months af ter plan approval the permittee shall submit a final report to the Department. Development of the report shall be guided by the " Development Document for Best Technology Available for minimizing Adverse Environmental Impact of Ccoling Water Intake Structures" as proposed by EPA.
This report shall be evaluated with regard to Section 316(b) of the Act.
As a result of this evaluation, the Department may modify the permit to establish an implementation schedule to ensure compliance with Section 316(b) of the Act.
3.
Pesticides Any pesticide discharge from any point source shall comply with the requirements of the Federal Insecticide, Fungicide, and Rodenticide Act, as amended (7 U.S.C.
136 et,.
sec.) and the use of such pesticides shall be in a manner consistent with its label.
4 This permit shall be modified, or alternatively, revoked and reissued, to comply with any applicable affluent standard or limitation issued or approved under sections l
301(b)(2) (C), and (D), 304(b)(2), and 307(a)(2) of the Clean Water Act, if the effluent standard or limitation so issued or approved:
1.
Contains different conditions or is otherwise more stringent chan any effluent limitation in the permit; or 2.
Controls any pollutant not limited in the permit.
The permit as modified or reissued under this paragraph shall also contain any other requirements of the Act then applicable.
A fact sheet has been prepared for this permit by the Central Office, Department of Natural Resources. Copies are being sent to the applicant, to the District Engineer of the U. S. Army Corps of Engineers, the U. S. Fish and Wildlife Service, the Environ = ental Protection Agency and the Missouri Depart =ent of Conservation. Other interested persons may obtain a copy by request from Department of Natural Resources, Division of Environmental Quality, P. O. Box 1368, 2010 Missouri 31vd., Jefferson City, MO 65101.
Please include the application number of the draft permit.
The proposed NPDES permit prepared under the Missouri Clean Water Law and the Federal Clean Water Act Amendments of 1977 establishes effluent limitations and special conditions for the conventional pollutants. Radioactive dischargers are the legislative responsibility of the Nuclear Regulatory Co= mission (NRC) and any discharge of these constituents from
April 11, 1980 8
'6 0098001 Callaway Power Plant (centinurd) ' -
the Callaway Coun:y Nuclear Power Plant vill be under the legislated authority of the Nuclear Regulatory Commission.
In proposing issuance of this permit the Missouri Department of Nac2ral Resources is not granting or denying their approval for radioactive discharz.s from :his facility.
This public notice is issued under the State Regulation 10 CSR 20-6.020, Public Participation end Permit Processing and Issuance. This regulation lists the requirements for the general publi to request a public hearing and the procedures that the Department of Natural i
Resources will follow in determining if a hearing is necessary and the procedures for holding such a hearing. Section (5) states in part "Any request for a public hearing shall be filed with the Department of Natural Resources within the comment period............
and shall indicate the interest of the party filing such request and the reason why a hearing is warranted." All comments must conform to this requirement.
t a
az _. _
1 t
e Fact Sheet
- Union Electric Company NPDES No. MO-0098001 The Federal Water Pollution Control Act (" Clean Water Act" Section 402 Public Law 92-500,95-217 as amended) establishes the National Pollacant Discharge Eliminacion System (NPDES) permit program. This program regulates the discharge of pollutants from point sources into the waters of the United States. All such discharges are unlawful absent a pernic (Section 301 of the " Clean Water Act").
After a permit is obtained, a discharge not in compliance with all permit terms and conditions is unlawful. NPDES permits in Missouri are issuad by the Director of an Environmental Protection Agency approved NPDES Program, operating in accordance with federal and state laws (Federal " Clean Water Act" and " Missouri Clean Water Law" Seccion 204 RSMo cum supp.1973)
The Union Electric Company, 1901 Gratiot Screet, P. O. Box 149, St. Louis, Missouri 63166 has applied for an operating permit for their Callaway Power Plant, Reform, Missouri 65077.
The requested authorizacion' to discharge is for nine(9) wastewater discharges from units one and two of the Callaway Power Plant located in the NEk, Sec. 14, T46N, R8W. Callaway County, Missouri. The wastewater affluents will enter the Missouri River at River Mile 115.4 through a 5.5 mile long pipeline. The maximum daily combined flow from the following outfalls will be 15,802,273 gallons per day.
- 001 - Radwaste treatment system (.028473 mgd) i
- 002 - Cooling cover blowdown (13.471 mgd)
- 003 - Wacer creatment plant sludge (.4608 mgd)
- 004 - Domineralizer system vastes (.267 mgd)
- 005 - 011 separator discharge (.144 mgd)
- 006 - Circulating and Service Water Pumphouses oil separator and neutralization sump (.144 mgd)
- 007 - Two 20,000 gpd Clow Aer-O-Flow Model S-200-55-5 extended aeration sewaga treatment units preceded by a 25,000 gallon aerated surge tank. (.0342 mgd)
- 008 - Chemical water treatment unit (.004 mgd)
- 009 - Intake structure sump (.216 mgd)
Union Electric Company produces electricity for sale, their Standard Industrial Classification (SIC) code is 4911.
10 CSR 20-7.031 Water Quality Scandards Missouri Department of Natural Resources (the Department) " defines the Clean Water Commission's water quality objectives in cer=s of water uses to be maintained and criteria to protect chose uses".
For che Missouri River it lists the following beneficial water uses to be maintained:
Irrigacion, livestock waterina, wildlife watering, orocaction of aquatic life, commercial fishing, boating, drinking water supply, industrial process water supply and industrial cooling water supply.
In order to protect these beneficial water uses and the water quality of the Missouri River effluent limitations are being established under federal and state laws..The current Department " Effluent Regulation" 10 CSR 20-7.020(3)(C) states I
that non-domestic waste discharges "shall meet the best practicable control technology as defined in current effluent limitation guidance documents as prepared by the EPA or the agency. Where such documents are not available or applicable, i
che limitations for specific parameters contained in section (11) of this rule l
fAppendix I. Column B), and in paragraphs 1 and 2 of this subsection, shall be used as the general efflur.nc limitations to establish permit conditions."
e Fact Sheet
.Callaway Power Plant Page 2 I
Where guidance documents are not available or applicable and srecific parameters are not listed in section (11), the reviewing engineer of the Department establishes limitations using "best engineering judgement" as defined in section 402 (a)(1) of the Federal Clean Water Act.
The general guidance document applicable to these industrial discharges is 40 CFR 423 Steam Electric Power Generating Point Source Category, Subpart A Generating Unit Subcategory. The construction of this faciliti began during 1976, it is therefore a "new source" as defined in 40 CFR 122.3.nd is subject to Standards of Performance for new sources in 40 CFR 423.15, the applicable sections are:
1 40 CFR 423.15(a) states: "The pH of all discharges, except once through cooling water, shall be within the range of 6.0 - 9.0."
Therefore all nine discharges will be limited to the range of 6.0 - 9.0 pH units as noted in the public notice.
40 CFR 423.15(b) states: "There shall be no discharge of polychlorinated byphenyl compounds such as chose commonly used for transformer fluid." This prohibition applies to all discharges from this facility and is listed on the public notice in part E - Other Requirements 91.
40 CFR 423.15(c) places limitations on " low volume waste sources" as defined in 40 CFR 423.11(h), outfalls #003, 004, 005, 006, 008 and 009 fit that definition. These outfalls have received limitations on Total Suspended Solids and Oil and Gresse "by multiplying the flow of low volume waste sources times the concen; ration listed" in 40 CFR 423.15(c). Both the resulting mass (convertec to lbs/ day) and the concentrations listed in the t ble are shown in the public notice. All conversions from metric concentrations to English mass units are made as follows:
(concentration in mg/1) x (flow in million gallons per day 4
mgd) x (8.34 lbs/million gallons /mg/1) = lbs/ day.
3 i
40 CFR 423.15(1) states "The quantity of pollutants discharged in cooling tower blowdoen shall not exceed the quantity determined by multiplying the flow of cooling tower blowdown sources times the concentration listed in 40 CFR 423.15(1). Outfall #002's limitations for Free Available Chlorine have been established using the concencrations listed in 40 CFR 423.15(1) and the formula noted above, both values are shown on' the public notice.
As no materials are to be added for e.orrtsion inhibition, corrosion of condenser tubes will occur resulting in the release of copper and nickel from outfall #002. It is also possible for this discharge to contain oil and grease. The limitations for dissolved copper, dissolved nickel and oil and grease for outfall #002 have been established using Appendix I of 10 CSR 20-7.020 for guidance. The monthly average values were set using the Column 3 values representing "the lower level at which the various elements or parameters listed can be removed in a wastewater stream economically with current technology". The daily maximum figures sere established using best engineering judgement. Mass limitations were chen established using the formula given above, both concentrations and mass limitaticas are noted on the public notice.
Outfall J002's limitation on temperature as well as the monitoring requirements for Total Suspended Solids and Total Dissolved Solids hree been established using best engineering judgement, the same is true of the limitations established for Biochemical Oxygen Demand and Total Suspended Solids for outfall #007. Both concentration and mass values (calculated as above) are shown on the public notice.
These limits and monitoring requirements are designed to ensure compliance with the
~
Fact Sheet Callaway Power Plant Page 3 water quality standards established for the Missouri River.
Outfall #001, this discharge from the Radwaste treatment system is limited for radioactive pollutants under permit from the Nuclear Regulatory Commission. The conventional (non-radioactive) pollutant limitations (Total Suspended Solids and Oil and Crease) have been established using best engineering judgement. Concentration and mass limitations (calculated as above) are both shown in the public notice.
^
The proposed NPDES permit prepared under the Missouri Clean Water Law and the Federal Clean Water Act Amendments of 1977 establishes effluent limitations and special conditions for the conventional pollutants. Radioactive dischargers are the legislative responsibility of the Nuclear Regulatory Commission (NRC) and any discharge of these constituents from the Callaway County Nuclear Power Plant will be under the legislated authority of the Nuclear Regulatory Commission. In proposing issuance of this permit the Missouri Department of Natural Resources is not granting or denying their approval for radioactive discharges from this facility.
This public notice is issued under the State Regulation 10 CSR 20-6.020, Public Participation and Permit Processing and Issuance. This regulation lists the requirements for the general public to request a public hearing and the procedures that the Department of Natural Resources will follow in determining if a hearing is necessary and the procedures for holding such a hearing. Section (5) states in part "Any request for a public hearing shall be filed with the Department of Natural Resources within the comment period.......... and shall indicate the interest of the party filing such request'and the reason why a hearing is warranted." All comments must conform to this requirement.
The monitorics requirements for all outfalls have been established by the Department's reviewing engineer in compliance with 10 CSR 20-6.050 NPDES Permit Self Monitoring.
Part 3 " Standard Conditions" are applied to all NPDES permittees. They reflect requirements of federal (40 CFR 122) and state law (10 CSR 20 - Chapter 6) with respect to NPDES permittee duties, responsibilities and liabilities.
Part D "Special Condition" - see explanation in outfall 001 Part E "Other Requirements 41 is required by 40 CFR 423.15(b) as explained above.
42 is required by section 316b of the federal Clean Water Act.
- 3 is required by the federal " Insecticide, Fungicide and Rodenticide Act, as amended (7 U.S.C. 136 et. seq.)
14 is termed a " reopener clause" and is applied to permits issued to dischargers within certain industrial categories as required by 40 CFR 124.46.
A copy of the draf t permit and a draf t public notice are being forwarded to the applicant, District Engineer of the U. S. Army Corps of Engineers, Environmental Protection Agency.
U. S. Fish and Wildlife Services, Missouri Department of Conservation, and the Nuclear Regulatory Commission.
i
4_
Fact Sheet Callaway Nuclear Power Plant Page 4 The proposed determinations of the draf t permit are centative pending the public notice process. Persons wishing to comment upon or object r the proposed determinations are invited to submit them in writing to: Department at Natural Resources, Division of Environmental Quality, (Missouri Clean Water Commission), P. O. Box 1368, Jefferson City, Missourf 65101, ATTN: Robert H. Hentges, C'.tief of Permic Section. Please include the application number of the draft pern'.c in all conument letters.
Consnent period opens April 11,1980and all commants received prior to May 11, 1980 will be considered in the formulation of all final determinations regtrding this application. If response to the public notice indicates significant public interest, public hearing may be held after due notice. Public hearing and/or issuance of the NPDES Permit will be processed according to 10 CSR 20-6.020 March 19,1976.
l l
Copies of all draft permits, comments and other information are available for inspection l
and copying at the Depart:nent of Natural Resources, Division of Environmental Quality, 1
(Missouri Clean Water Cousaission), P. O. Box 1368, 2010 Missouri Blvd., Jefferson City, Missouri 65101.
f 4
e
_ -.. yh _..
.4 STANDARD CONDIT13NS FOR NPDES PERMITS ISSUED BY THE MISSOURI DEPARTMENT OF N ATURAL RESOURCES MISSOURI CLEAN WATER COMMISSION Revised October 1,1975 PART l-G2NERM. CO NDITIO NS SECTION 5-MANAGEMENT REQUIREMENTS SECTION A-MONITORING AND REPORTING 1.
Change in oisenerge t.
4: mauve sempang Als disenarges aumonzed nerem snesi ne consistent wim me A. Tamoses and measurements taken as required herein terms and conditions of tnis permit. The disenarge of any shall De representative of me nature and volume. resceC.
pollutant not autnonzed by tnis permit or of any pollutant fivety. of the momtored disenarge. All samples snail be identified m mis permit more frequeetty man or at a revet m tamen at me outfallts), and unless soecified. Defore me excess of mat aumonzed snalt constitute a viotanon of me effluent soms or is diluted my any other Dody of water or permit. Any facihty expansions.producten mcreases.or pro.
suostance.
cess modificatens enien will result in new. different. or in.
B. Monitonng res,its snail De recorded and reported an creased disenarges of pollutants snad De reported oy suo.
forms provided my me Department. postmarked no late, mission of a new NPCES appheanon at least one nundred man me 28tn day of tne monm followmg me completed
gnty (180) days oefore such enanges, or, if they will not reporting genod. s.gned copies of tnese, and all otner re.
V'otare me effluent limitat ons soecahed m this permit, ey oorts required nerein snail be suom.tted to me fotilowing nonce to tne Oeoartment at least tturty (30) days cefore sucn address:
cnanges.
Department of Natural Aesources 2.
Noncompilence Notification Division of Environmental Quahty it. for any reason, tne permittee does not comory witn or will Water Quahty Program De unable to comoty witn any daily mammum effluent hmita.
P O. Box 1368 non specified in mis permit, me permittee snail provide me Jefferson City. Missoun 65101 Decartment wim me fotewmg mformanon m anung wimen 31a-751 3241 five (5) days of osco' mms aware of sucn condinen:
2.
Scneduas of Compliance A. a descrionon of me discnarge and cause of non.
No later 'nsa fout*een (la) calendar days following each comotiance. and date idennhed m the Scheduse of Comphance."the permit.
B. tne penod of noncomohance, ecluding enact dates and tee snail submit *o me resoective Cooertment Regional Of.
t mes or,if not corrected, tne anticipated ume me non.
hce as required enerein, eitner a rooort of progress or, m me comohance is expected to contmue. and steos comg case of spec;hc actions ceing reduired Dy identified dates, a tamen to reduce.1iiminate and prevent recurrence ut me aritten nonce of comohance or noncomotiance. In tne latter noncomptying discharge.
case. tne nonce sna6s mctude me cause of noncomohance.
3.
FacilitiSe Operstion any remecial actions tamen, and tne procacihty of meeting
.no neat scheduled reoverements. or, if tnere are no more
,ne permittee snati at all times mamtam in good norking order and ethcientty and effectively operate all treatment' senecuted reou ements wnen sucn noncomotiance will ce corrected. The egional Office address is indicated m me collection and control systems or facihties mstanled or used by me permittee to achieve comohance witn tne terms and cover letter transmimng the permit.
conditions of mis permit.
3.
Def6mtione 4,
34,,,,,,,,,,,
Cefmitions as set fortn in me Missoun Clean Water Law and Missoun C:ean Water Commission Cefmition Aegulation The permittee snail tame all necessary steos to mimmaze any (CWCAal snait acety to terms used nerem.
adverse imoset to waters of the state resulnng tram non.
comohance wem any effluent lirmtanons soecified in mis per.
- a. Test proceduree mrt or set forth m the Missoun C:ean Water t.aw and Aequia.
Test procedures for tne analysis of pollutants snell be m ac.
t ons (norematter tne Law rna Aegulations). mctudmg sucn cordance witn Section 30a(g)of tne Federal Water Pollution accelerated or additznal minitonng as necessary to deter.
Control Act thereinafter the Act) and with me Missoun Claso mine me nature and imoact d the noncomplymg disenarge.
Water Commission Efftuent Aeqular cin (CWC.A6).
g g,,
y t Recording of Results My diversion from or bypass of systems or facilities wmen is For eacn measurement or sample taken pursuant to tfie re.
necessary to maintam comohance wim the terms and condi.
auwements of mis permit, me permittee snait record me tions of mis permit is pronicited. except it) wnere unavoida.
toitowmg information-ele to prevent loss of numan his or suostantial amounts of 4 enact place, date. nme, and manner of taking; severe property damage. or (2) wnere unavoidat..e ancessive B Jares tne anaiyses of tne sarapies were cerformed:
storm dramage or runoff would damage any f acihties neces.
C. Dersontse ano performed the sample analyses or sary for comohance wim tne effluent hmitations and cronion.
measurements; -
tions of mis permit. *he oormittee snait promotty nonty me O. anaiyticai tecnniques or memods used for samosos or Ceoartment m wnring of eacn suen diversion or oypass.
measuremen's. and Notnmg nerein snalt excuse any person from any haoility E. resuits of ait sucn sampie analyses or measurements.
unless sucn rehef from issoihty is otnerwise provided my statute.
-- g, 3,,% g,,
p, If rne permittee momtors any collutant at me location (s) 8.
Removed Substances designated ne'em more troquentty man required by tnis per.
Solids, studges. filter osckwasn. or omer pollutants remcved met, usmg acoroved analyticas memods as soecified above.
in the course of treatment or con el of wastewaters snail be tne resuits of such monitorirg snail oe metuded m the disposed of in a manner sucn as to orevent any pollutants nicalsne.n and recortmq of tne values required in me from entering nators of tne state unless permitted oy tne Momformo koort :orm. Sucn meressed frecuency snail Law also oe ino Cated.
7 F.
Records Reconnon in oroer to m..ntwn compaiance wem the etttwnt inmit.aions j
All recoros and m'ormation resultmg from me monitonng ac.
and omer provisions of tnis permit.:ne permitte, snail eitner-trvities required oy tms permit mctudmg all records of A. in accordance witn me "Senecule of Comohance.* pro.
anatyses performed and caubration andwriaintenance of m.
vide an antemateve oower source sufficient to coerate tne strumentation and recoramgs from contmucus momtonng wastewater contret facitines: or, instrumentanon snait De retained for a mimmum of tnroe (3)
- 8. if sucn attematrve power source is not in existence and years, or ionger.f requested oy me Dooartment.
no date for its imolementation nopears in me Comoniance
.L t-Sched'Je. nait or otnerwise Coritrol production and all wniCn are lessened or removed. and should no other casas eschrges upon ene reduction. losa,or failure of the.pn.
esist for such permit provisens.the permit snail De modified mary f aurce of power to tne wastewater control f actisties.
after notice and opportunity for a neanng.
8.
Right of t'nery
- 13. Tosic Pollutants TN -%ttee snait allow any autnonzed representatives of Notwithstandirg Standard Coedition 811 aoove. if a tonic in OroArtmeni sie tne U S Environmental P'ot#Clion Agen.
effluent standard. limitat on or pronioition (including any cy, upon tne presentation of proper credentials:
schedule of compuant.e specified in sucn effluent star'dard.
A. to ecter upon the permittee s premises enere a potential hmitation,or pron!Diten)is $staDh$ned under Secten 307(a) or esisting water contaminant source or GScharge is 10 of the Act or the Law and Requiations for a tonic Dollutant cated or in wnscn any records required under the terms wnsen is present in the disenarge and such standard,litnata.
and conditons of this permit or the Law and Regulations tion, or pronication is more stnepnt than any limitations for are to be kept; and such pollutant in this permit.this s ermit snail. sucrect to ther.
- 8. at reasonsole times. to have access to and copy any ty (30) days notice of sucn enangre in condition and tne nght records required to be kept under the terms and cone.
of appeal as set forth in the Law, automatically se modified tions of this permit or the Law and Aequistens; to in.
to ensure comphance with the toxic effluent standard. hmita.
roect any monitonng equipment or monitonng method tion or prohibit on.
required in this permit or the Law and Regulations; and t
- 14. Civil and Criminal UsWilty sample any source of or escnarge of water contaminants Except as autnonzed by statute and provided 'n permit con.
or. in order to prevent pollution, any potential source of a citions on -9ypassing* (Standard Conditon B-5) and disenarge of water contanunants.
_% gg,,.. (Standard Con @ tion B.J. notning in this 9.
Transfer of Ownership er Control permit snail be construed to relieve the permittee from civil in tne event of any change in control or ownership of or enminal penalties for noncomotiance.
systems or facihties from wnicn there is art autnonzed dis.
g g
charge. the permittee anali notify the succeeding owner.
controlhng person, or operator of tne existence os this per.
mit by ;etter, a copy of which spall be forwarded to the stttution of any !egal action or reheve tne permittee from any g
g,,g g
Depanment.
,,,,,,, m,, 3, gy,,,c;,n,,, 3,c,,n y,, of tr e Act, and the
- 10. a-adaWety of Reports Law and Aegulations. Oil and nazardous matenais sis.
Er
.,t for data determined to ce confidential under Section cnarges must ce recor'e' in compiian:e mtn Missoun C:ean 3 J o. tne Act. and the Law and Missourt C:een Water Com.
Water Commissaun aequistion 'or Nots *1 cation of Soills and mission Regulaten for Pubhc Participation and Permit Pro.
Accidental Disenarges (CWC.R7).
cessing & Issuance (CWC.A8), all recorts prepared in accor.
18-dance witn tne terms of this permit snett be avadaele for Notn n this permet snail De construed to prectude the in.
puohc insoection at the offices of the o partment. As re.
cuired by seatute. effluent data snall not ce considered conti.
stituten of any legal action or rehove tne permmeo from any responsibilities inaosiities, or penarties estachsned oursuant cential. Knowingly maeung any faise statement en any sucn report snail be suciect to the impositen of enminel penatties as provided for m Section 309 of tne Act and Section 204 078 37, proper,y magne, of tne Law.
The issuance of tnis permit does not convey any procerty 33, p.,mitAsomfuanon ngnts in eitner resi or personal property.or any emetusive on.
After compleaSCO witn statutory requirements of the Law and VHeges.nor does d autn@ze a3y inNry to pnvate property or Aegulations. mis permit may be modified, suspended. or any nvas on of personal ngn's. nor any intnngeert 9,e revoked in wnoie or in part dunng its term for cause includ.
violation of tecerat, state or tecat iaws or regular:or's ing. Out not htmted to, the following:
A. violaten of any terms or conditions of tnis permit or the g
g, n, g S. n v g obtained this permit ny misrepresentation or peal or seen a vanance mn sophcacie.aws or mgulaties f adure to disciose fuity all relevant facts; as aHowed by law.
C. a cnange in any circumstances or conditions tnat re.
1L Se w reW uty quires either a temporsty or permanent reduction or The provisions of this permit are severacle and if any orovi.
ehmenation of tne autnonted esenarge, or son of this permit, or the apphcation of any orovision of this O. any reason set "ortn in the Law and Aegulations.
permit to any circurnstance.is neid invand.tne acciication of
- 12. Penst Asodificasson-Lees $4rtngent Requeremente suen provision to otner circumstances, and tne remaincer of if any permit provisions are Dased on legal requiremen'.
this permit, snail not ce affected tnerecy.
- u..
--v---------------------------
- 001 30 x.028473 x 8.34 = 7.1 lbs/ day 45 x.028473 x 8.34 = 10.7 lbs/ day 15 x.028473 x 8.34 = 3.6 lbs/ day 20 x.028473 x 8.34 = 4.7 lbs/ day
- 002 15 x 13.471 x 8.34 = 1685 lbs/ day 20 x 13.471 x 8.34 = 2247 lbs/ day 1.0 x 13.471 x 8.34 = 112 lbs/ day 1.5 x 13.471 x 8.34 = 169 lbs/ day 0.2 x 13.471 x 8.34 = 22 lbs/ day 0.5 x 13.471 x 8.34 - 56 lbs/ day
- 003 30 x.4608 x 8.34 = 115 lbs / day 100 x.4608 x 8.34 = 384 lbs/ day 15 x.4608 x 8.34 = 58 lbs/ day 20 x.4608 x 8.34 = 77 lbs/ day
- 004 30 x.267 x 8.34 = 67 lbs/ day 100 x.267 x 8.34 = 223 lbs/ day 15 x.267 x 8.34 = 33 lbs/ day 20 x.267 x 8.34 = 45 lbs/ day
- 005 and #006 - have the same flow amount 30 x.144 x 8.34 = 36 lbs/ day 100 x.144 x 8.34 = 120 lbs/ day 15 x.144 x 8.34 = 18 lbs/ day 20 x.144 x 8.34 = 24 lbs/ day
- 007 30 x.0342 x 8.34 = 8.6 lbs/ day 45 x.0342 x 8.34 = 13 lbs/ day 1008 30 x.004 x 8.34 = 1.0 lb/ day 100 x.004 x 8.34 = 3.3. lbs/ day 15 x.004 x 8.34 = 0.5 lbs/ day 20 x.004 x 8.34 = 0.67 lbs/ day 8009 30 x.216 x 3.34 = 54 lbs/ day 100 x.216 x 8.34 = 180 lbs/ day 15 x.216 x 8.34 = 27 lbs/ day 20 x.216 x 8.34 = 36 lbs/.'.sy lbs/ day = (concentrat,1on in ag/1) x (flow in sgd) x (8.34 lbs/nillion gallon,1 mg/1)
Note: answers are rounded off.
,7
,f p., Ljf.
..G esyy=;;.,J.
r
.'d 1
U N ION CLCCTRIC COMPANY lf j
..o o
rio, sr ccr sv.covis July 16, 1980
~=: = -
...sov...........
3 I
Missouri Department of Natural Resources P.O. Box 1368 201 Missouri Boulevard Jefferson City, Missouri 65102 Re:
NPDES No. MO-0098001 Callaway Power Plant Gentlemen:
The attached statement is submitted on behalf of Union Electric Company for inclusion in the record of the Public Hearing to De held concerning the above-referenced permit on July 16, 1980.
In addition, Union Electric Company respectfully requests that all comments previously submitted to the Department of 'latural Resources concerning this proposed NPDES permit be incorporated into the record by reference.
Very truly yours, T
O Jerrel D. Smith k
Manager, Environmental Services Attachment l
I 1
0, li l
\\
l ;4 l,'
%d
l
'i July 16, 1980 UNION ELECTRIC COMPANY Comments on Proposed NPDES Permit For the Callaway Nuclear Power Plant The purpose of this hearing is to provide an opportunity for public comment on the following proposed discharges from Union Electric Company's Callaway Power Plant.
Authority to issue National Pollutant Discharge Elimination System (NPDES) permits has been delegated to the Missouri Department of Retural Resources.
1.
Water treatment plant 2.
Demineralizer system 3.
Oil separator system 5.
Conventional pollutants discharge from the radwaste treatment system 6.
Circulating and service waten pumphouses oil separator and neutralization system 7.
Two extended aeration sewage treatment units 8.
Chemical water treatment unit 9.
Intake structure A request for certification of these discharges was eriginally filed with the Missouri Clean Water Commission on December 20, 1974, and certification of the proposed discharges, as required by Section 401, Public Law 92-500, was issued by tne Missouri Department of Natural Resources on March 26, 1976.
This
- =-------
).
action was necessary becaus< then current regulations required the state to certify acceptability of such discharges to EPA, the agency formerly responsible for issuance of permits.
Since EPA subsequently delegated this responsibility to the state, applications were filed for the NPDES permit with the Missouri Department of Natural Resources on August 22, 1979.
These discharges were described in the permit application and the Department of Natural Resources public notices of October 26, 1979 and April 11, 1980.
Essentially the same description was included in Chapters 3 and 5 of the Callaway Plant Environmental Report, originally issued to the Atomic Energy Commission on May-30, 1974.
This document was made available shortly thereafter to federal, state and local regulatory agencies as well as the general public through the document rooms established for the project in St. Louis and Fulton, Missouri.
Union Electric has previously submitted comments on the draft permit.
As was pointed out in that submission, we believe certain requirements proposed i'n the draft permit are considerably more stringent than necessary for compliance with state or federal discharge limitations.
However, on ~une 12, 1980 the Company informed the Department of Natural Resources that, in the interest of expediting the issuance of the permit, the conditions would be accepted as proposed.
.n
a c
Radiological Discharges Radiological discharges are not an issue under the NPDES process.
In accordance with the Atomic Energy Act, as amended, and Reorganization Plan No. 3 of 1970, the authority to regulate radiological discharges from nuclear facilities, such as the Callaway Plant, resides with the Nuclear Regulatory Commission.
However, since the notice of public hearing indicated that comments received expressed concern about the effects of these diccharges on downstream drinking water supplies, it should be l
pointed out that the discharges from Callaway will fully comply with EPA regulations for drinking water.
The issue of radiological discharges was fully addressed by the Nuclear Regulatory Commission, which is the responsible agency, as part of the review process that culminated in the i
issuance by the NRC of Construction Permits for the Callaway units.
That review process, which included not only detailed analysis by the NRC staff but also a lengthly series of public and adjudicatory hearings where'all interested persens were given full opportunity to express their concerns, resulted in a conclusion that the radiological discharges would comply with the applicable standard.
The DNR has also made an analysis of the Callaway discharge and conc',uded that the radiation release would not be in violation of water quality standards.
This conclusion is in agreement with the conclusions earlier reached by the NRC.
l
_4_
Additional opportunity for public input on radiological discharges will be afforded by the NRC in connection with their review of the application for an operating license for the Callaway Plant.
Conclusion The draft NPDES discharge permit has been properly placed on public notice by the DNR and opportunity to submit comments was provided.
Those comments did not raise significant question about the effluent limitations contained in the proposed permit.
Although Union Electric Company believes the requirements of the draft permit go far beyond the requirements of federal or state discharge limitations, in the interest of expediting the issuance of the permit, the Company urges the Department of Natural Resources to promptly issue the permit as proposed.
b
.m
-_.m_.
m----_----
.M
-_.=%
enri
~ ~ "
St. Cicries C,,unty liighway Department
^
'[J
~
205 NORTH SECOND STREET-ROOM 316
[
ST. CHARLES. MISSOURI. 63301 1 lj f 4 e
f r
TELEPHONE 77 A15tG 8
a l
Y3Q
- k n
'~v p.pM.
JUL 18198C i
July 15,1980 i,
Mr. Fred A. Lafser,1)irector i
Department of Natural Resources P.C. Box 176 Jefferson City, FO 65102 Re: Radioactive. Discharges into the Missouri River, Callaway County for Union Electric Ccmpany's Callaway County Nuclear Plant
Dear Mr. lafser:
Reference is unde to your letter of July 8,1980 cmccrning radioactive discharges into the Missouri River near River Mile 15 in Callaway County. Please be advised that St. Charles County Water Department has all of our wells near the.
Missouri River at approximately Mlle 49. At the present time, ue are producing seven millicn gallons of water. per day diich serves a large area in St. Charles County, Missouri. In tha near future, a new transmissicn line will be installed fran our plant near Weldc. Springs to the City of Wentzville for supplying. water to the new General Motors Plant. It is estimated that this plant will ultimately produce approximately 18 to 20 million gallons per day to serve the.St. Garles County area.
When nore supply is needed, it is anticipated that additional wells.will be installed in the vicinity of our present producing wells and a seccnd plant put into production.
We would hereby request that the regulatory agencies for the.Callaway Nuclear Plant, insure that the. water supply for St. Charles County is not endangered by any radioactive discharges.
Sincerely, J
. Nichols C
y Engineer JRN/efh cc: County Court l
..