ML19341D721
| ML19341D721 | |
| Person / Time | |
|---|---|
| Site: | Callaway  |
| Issue date: | 03/24/1981 |
| From: | Chackes K AFFILIATION NOT ASSIGNED, CONNER, MOORE & CORBER |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| ISSUANCES-OL, NUDOCS 8104080491 | |
| Download: ML19341D721 (5) | |
Text
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UNITED STATES OF AMERICA g
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BEFORE THE Th
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In the Matter of UNION ELECTRIC C0f?At#
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'S Docket No. STN 50 483 OL k
N (Callaway Plant, Unit 1)
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REVISED CONTEf6 IONS OF JOINT It.TERVENORS The Coalition for the Environment, St. Louis Region, Missourians fc:
Safe Energy, Crawdad Alliance, and Kay Drey (Joint Intervencrs) submit the fellowing revisions to their Cententions filed March 6, 1981.
CONTEtJION f0MBER 1 Joint Intervenors propose to amend Contention immber 1, by interlinen-tien, in the fc11owing respects ~:
- 1. On pege 5, the first sentence is amende.d to read: Deficiencies and 1
l no.7confermances which evidence the failure of the quality assurance program l
include but are not limited to the fellcwing:
- 2. On page 7, Paragraph 2 is amended to read:
- 2. The NRC was notified by a Callaway Plant irenwc ker in Janua.mj 1978 that a Jift of the north wall of the Cont cl Building had been poured abeve a part of the w' ell which contained a crack accr=ximately 12 feet long and 8 inches deep, and which extended f cm the inside te tne outside of the wall and which apparently had oesn overicoked by the Applicant's cuality assurance persennel. (See, NRC Recert fJo. 50 483/75-01, p. 20).
- 3. On page 11, the fc11owing sentence is astdad to the end of Paragraph 1:
The picing was approved fc: shipment at the vendcr's, was accepted -
on site, and was installed despite these deficiencias.
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As CONTEP. TION MJMBER 2 Joint Intervenors submit the fellowing as a substitute for Contention Numos: 2:
INA057JATE ENVIRCtTE'(TAL PROTECTION FRCM RADICACTIVE RELEASES The Applicant cannot p:cvide reasonable assurance that the Callaway Plant will be operated in compliance with apolicable environmental stendards for radiation (L a., 10 CFR Part 50, Appendix I and 40 CFR Part 190). In the obsence of such assurance the operation of the plant cles:1y would be unlawful.
Environmental P:stecticn Agency environmental stand rds for the uranium fuel cycle, 40 CFR Part 190, provide in part that planned sleases of radio-active materials to the general enviromnent from the uranium fuel cycle, including cperations of electrical gene:ating facilities, shall nct cause an annual dose equivalent in excess of 25 nillirems to the.hcle body to any member of the public.
Union Elsetric Company plans to dischargs inte the environme: it,-both air and water, certain quantities of radicactive materials es part of the routine operation of the plant. For examcle, U.E. estimates it will discharge annually 410 curies of tritium into the Missouri River ard 1000 euries of tritium into the air.
(jag,, 5ftJPP3 FSAR Table 11.1-2).
In additien, U.E.
estimates the annual release of.17 curies of corrosion, activation and fissier. products into the Mi:souri River and 2330 curies of nocle gases anc more than E curies of halogens, carocn-14 and cther cer:csien, acti.Jtion anc fission p;cducts into the atmosphers. M.
Dissolved and entrained noble geass will also be rolessad to the river.
Due to the following circumstancas, among oths :, Intervenors contend that the Applicant cannot assure compliance with applicabla envi.-. -. Gal ~
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standards:
A. The Acplicant has not adeoustely assessed anc cannot securately predict the amount or discharge :ste of the radioactive oc11utants to be released from Callaway Plant, Unit 1, into the Misscuri River, c the astount of dilution to be affordec by ths river, which crovices drinking water for dcwnstream corvnunities including the City of St. Ch,.rles and St. Louis City and County. Anticipated water diversion projects in the Missouri River watershed and conditiens of drought and freezing (ice-jass) would lower the amcunt of dilution wets; available and this could raise the concentration of radicactive material in the river to higher levels then calculated by U.E.
Because the Applicant cannot accurately predict radioactive releases it can-not accurately predict the pctential cice2ncentration of radionuclides in fish.
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E. The Applicant ccmcistely igncres the potential impact of its radio-active releases on drinking water. The Applicant's analysis cf the liouid patnway dosage includes only fisn caught witnin.05 miles cownstream from the l
l discharge cipe and shoreline reersatien activit bs.
(5m TSAR Site Adoendum, l
Tabla 11.2-4).
C. Adsc ction and acserption of sone radienuclides in sediment and the pctential resuspension of these materials in the event of dredging c: flooding could leed to high levele of contamination.
D. The Acclicant has not adec;ately assessed and cannet accu staly. pro-dict tne amount c disenarge sta of tne radioective pc11utants to be Isleased from Calloway Plant, Unit t, into tne atmosphers. Furthermore, due te sietect-ciegical considerations, U.i. is unable to predict ac-m etaly the cispersion of radioactive materials or their fallout ress.
E. There will be inaceouste monitering of the release of ::itium, nocle games, alone, beta and gamme omitters when in cuentities'below the lowel of detection of comunercial monitoring osuipment or during socioental z='
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F. Planned releases of radioactive materials from three nuclear reactors upwind and upstream f:cm the Callaway Plant en the Missouri River may alac imcact upon the local resicents. Residents of Metec==11 tan St. Louis may also be affected by gaseous emissions from a uranium fuel fabrication plant in Hematite, Missouri, 32 miles south of St. Louis.
G. U.E.'s estimates of annual emissions de net take into account releases frem the spent fuel pool, increased releases as the plant gets older and leakier (e.g., from steam generater tube deterioration) and releases from de-contamination proceduras.
H. In addition, U.E. dess not admit to the potential release of some of the majcr fissien p cducts, e.g., ceriun-144 and tech stium-99, and some of the majc: activation and cc rction products, such as neptunium-239 and nickel-63.
I. U.E.'s estimates of radiation dose from tna Callaway Plant emissions do nct adequately reflect now data on the health effects of low-levs1 radiatien, and cf tritium in particular.
Y Kenneth M. Chackes CHACKES AfD HCARE l
Atterney for Jcint Intarvenors 314 N. Sroacway St. Louis, Missouri 63102 314/241-7961 l
CERTIFICATE OF SERVICE I hereby certify that copias of the forsgcing were hand-delivered to all l
l parties in attendance et the Special Prehearing Ccnference on March 24, 1931.
l
-f-I Kenneth M. Chackes
o e,
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DOCMEND UNITED STATES OF AMERICA D
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APR 2195
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l BEFORE THE ATOMIC SAFETY AND LICENSING BOAPJ3 Dxu$.'3mie 7
l E:n:h l
l In the Matter of
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UNION ELECTRIC COMPANY
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Docket No. STN 50-483-OL i
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(Callaway Plant, Unit 1)
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CERTIFICATE OF SERVICE I hereby certify that copies of the foregoing Revised Contentions of Joint Intervenors have been served on the following by deposit in the United States mail, firs class postags prepaid this 3 4 day of March, 1981.
James P.
Gleason, Esq., Chairman Atomic Safety and Licensing Board 513 Gilmoure Drive Silver Spring, MD 20901 Mr. Glenn O.' Bright Atomic Safety and Licensing Board Panel U.
S. Nuclear Regulatory Commission Washington, DC 20555 Dr. Jerry R. Kline Atomic Safety and Licensing Board Fanel l
U.
S. Nuclear Regulatory Commission Washington, DC 20555 Gerald Charnoff,'Esq.
Thomas A.
Baxter, Esq.
Shaw, Pittman, Potts & Trowbridge 1800 M.
Street, N.W.
Washington, DC 20036 Mr. John G.
Reed Rt. 1 Kingdom City, MO 65262 Docketing and Service. Section Office of the Secretary U.
S. Nuclear Regulatory Commission Washington, DC 20555 j
Roy P. Lessy, Jr., Esq.
Office of the Executive Legal'Direetor U.
S. Nw:: lear Regulatory Commission Washington, DC'20555 MS+ 4 Kenneth M.
Chackes Checkes and Hoare m
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