ML20009F856

Petition to Intervene & Request for Hearing.Affidavits Encl

ML20009F856
Person / Time
Site:	Catawba
Issue date:	07/24/1981
From:	Presler H AFFILIATION NOT ASSIGNED
To:	NRC COMMISSION (OCM)
References
NUDOCS 8108030105
Download: ML20009F856 (13)

Text

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UNITED STATES OF AMERICA BEFORE THE NUCLEAR REGULATORY COMMISSION i Charlotte-Mecklenburg )

Environmental Coalition, Petitioner,

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In the Matter of:

DOCKET NOS. 50-413 DUKE PO' DER COMPANY, ET AL. ) and (Catawba Nuclear Station,. }

Units 1 and 2), ) 50-414 Applicants, PETITION TO INTERVENE AND REQUEST FOR HEARING Charlotte-Mecklenburg Environmental Coalition, on, ,

its own behalf, on behalf of its members and on behalf of

other persons who are similarly situated, hereby petitions for leave to intervene in the above-captioned license proceedings as a party of record, requests that public hearings be conducted at which it will be afforded an opportunity to be heard, and requacts this Application for Operating License be denied, or be so conditioned, as Petitioner will hereafter demonstrate in order that the operation of the facility will be consistent with the health and safety of the public, and consistent with the economic interest of people in the Applicants' service area. This relief is sought under the provisions of 10 CFR 2.714 and pursuant to Notice of Receipt of Application fprrFacility Operating Licenses, published June 25, 1981. In support of this Petition and Request for Hearing, the Charlotte-Mecklenburg Environmental Coalition would respectfully show

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1. That Charlotte-Mecklenburg Environmental Coalition, 5 943 Henley Place, Charlotte, N.C. 28207 represents, in /[

this petition, the interests of Carolina Action, the local 8108030105 810724 DR ADOCK 05000

chapter of the League of 'domen Voters of North Carolina, the Joseph LeConte Chapter of the Sier:.'a Club, the Carolina Environmental Study Group, the Davidsoa Energy Group, and the Safe Energy Alliance. Petitioner encloses herewith an affidavit from each of these groups attesting that _the .-_.

Daarlotte-Mecklenburg Environmental Coalition (hereafter, CMEC) represents it in'the matters considered in this Petition.

2. CMEC represents acout 1350 persons--the combined membership of the above six groups added to CMEC's individual members. Almost all of these 1350 persons live within 35 miles of the Catawba Nuclear Station, the great majority in Charlotte and Mecklenburg County;some live or own property within a few miles of the proposed facility. Inasmuch as the prevailing south-west wind would carry radioactive emissions, either routine or

! accidental, from the facility to Charlotte and Mecklenburg I

l county, and inasmuch as these airborne emissions are predictably precipitated into the watershed from which i

our members draw their drinking water, we believe that the operation of the facility poses a clear threat to our health on the basis of our reading of the ' Environmental Report' (hereafter ER) and the ' Final Environmental Statement' l (hereafter FES). Inasmuch as almost all our members purchase 1

l power from the Applicant, our economic interest in the Applicant's " Cost-Benefit Analysis" for the facility is clear;we find that analysis to be seriously defective.

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3. Petitioner's reading of the FES prepared by the NRC Staff l and the ER prepared by the Applicant indicate that our health and l

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-5 economic interests are not represented by either the Applicants or the Commission Staff. Indeed we find that the Applicants' interest is contrary to our own.

4 Petitioner's analysis of both the ER and the FES indicates that both documents are seriously deficient and in error in their assessments of routine releases of radionuclides from the proposed facility. For example:

a) we find the methods and models used in the ER and the FES to calculate the concentrations of radionuclides that I

will result downstream from liquid radioactive releases to most seriously underestimate the degree of concentrations ,

i that will in fact result. We are prepared to demonstrate, for instance, that liquid releases 2of tritium from the facility will result in concentrations greater than obtain at present by, minimally, a factor of 3.

b) We find no mention of the fact that with the McGuire plant in operation, the Catawba River will contain concentrations r

of radionuclides which ought to be added to the Catawba Plant's discharges in calculating resultant concentrations in the '

water that will be drawn by communities downstream from the Catawba Plant. In any case, we are prepared to demonstrate that the same errors we find in ER and FES calculations for Catawba in this respect, obtain; also for McGuire releases.

c)In respect to gaseous effluents from the facility, FES

p. 5-16 attests that measurable effluent will be carried 50 miles from the plant and that much of this radioactive effluent will predictably brought back into the Catawba River watershed (ER, Figure 5.2.1-1). The effects of this processonradionuclideconcentrations(e.g.fortritium which is released in large quantities in gaseous form from

LWRs)intheCatawbaRiverupriverfromtheCharlotte water intake has not been calculated in either ER or FES.

d) We contend that Duke and NRC projections of actual radioactive emissions from the plant (FES, table 3.10) are far too low: LWR experience demonstrates (e.g. Shippingport) that LWRs become progressively " dirtier" in this respect as they age. We question the assumptions upon which Duke and Staff made their projections of the quantity of both liquid and gaseous releases. We take as a sign of the lack of proper scientific grounding for these projections the fact that there are extremely wide divergences between such projections for McGuire on the one hand, and the Catawba Station on the other hand. Yet, the design of the Catawba reactors and the design of the McGuire reactors are r in all essentials,the same.

• ) We note that neither the ER nor the FES takes any account of recent work that shows the long term somatic and health effects of routine radiation releases from this facility to be damaging to adults and extremely hazardous to the human embryo and fetus even where such releases may be within existing guidelines.

5) We find the " Cost-Benefit Analysis" offered in support of this facility to be inadequate in many respects. For example, Applicant is aware of the infestation in Lake Wylie by the Asiatic Clam Corbicula and that densities of Corbicula have continued to increase since the first specimens were collected in 1968 (ER 2.2-11). 1973 samplings showed densities of Corbicula as high as 1,472/m2 ) at one sampling location (ER 2.2-9).

Corbicula infiltrate the cooling systems and plug up the pipes

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of LWRs cooled by river water causing the scaling back of operations, plant shutdowns and enormous added expense.

According to the Wall Street Journal (Au5ust 12,1980 p.1)

Corbicula infestation recently forced $150,000 in repairs and cost $700,000 in lost electricity at Potomac Power Electric Company; Illinois Power Co. had to close its Baldwin Ill. plant twice daily during a recent infestation. We

, understand that the Brunswick Plant in North Carolina was similarily afflicted this summer. Since there is no method of effectively controlling Corbicula, concentrations in j Lake Wylie will rise predictably and add very significantly to the operating costs of the plant and so the cost of electricity in Duke Power's service area. The " Cost-Benefit Analysis" submitted by Applicants does not address these circumstances and so is seriously compromised.

6. As an organization representing: members who, for the i most part are residents of Charlotte, we must note that 4

Charlotte is directly in the path of the prevailing south-west wind from the facility and that, consequently, Charlotte residents are et extreme hazard from airborne radioactive particulates in the case of a serious accident at the facility.

We take the Brown's Ferry, TMI and Enric , Fermi accidents-as constituting prima facie evider.ee t at 'he probabilistic

! analysis used by the NRC in licensing prc'sedings is inadequate.

Accordingly, we contest Applicants' and Staff's view that we are not at hazard. ';e contend that emergency evacuation, radiological emergency response and permanent relocation plans must be drawn up for Charlotte and the cost of these plans in the event of catastrophic accident at the facility must be included in Applicants' cost-benefit analysis.

7. Petitioner reserves the right, and hereby assarts its intention, to hereafter file a supplement to the Petition To Intervene under provisions of 10 CFR 2.714 (b) including a list of the contentions which it seeks to have litigated in the Pro-coeding together with the bases therefor. It further reserves the right, if admitted as a party to this proceeding to amend this Petition in such manner as is deemed necessary and proper.

Wherefore, having set forth its interest which will be affected in this proceedin6, having alledgedat least one litigable contention and the basis therefor with resonable specificity,.

and having annexed hereto the Affidavits of 6 of its members representing 1350 individuals who will suffer indury in fact from the operation of this facility, Charlotte-Mecklenburg Coalition respectfully begs leave to intervene in these proceedings, the conduct of hearings, and the denial of the Application for Operating License unless so conditioned as to prevent injury to l Petitioner's health, safety and economic interests.

July 24, 1981 Henry Presler, Chairman CMEC 942 Henley Place Charlotte, N.C. 28207 704-333-8589 Attachments

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1. Affidavit from Lori A. Glosemeyer-Safe Energy Alliance

2. Affidavit from June M. Kimmel for the League of Women Voters

3. Affidavit from Eric Meyerson for the Central Piedmont Group i of the Joseph LeConte Chapter of the Sierra Club 4 Affidavit from Lility Quinlan Otey for the Carolina Environmental Study Group

5. Affidavit from Sarah Wilson for the Davidson Energy Group

6. Affidavit from Brenda Best for Carolina Action

7. Affidavit from Henry Presler attesting to this document.

Charlotte-Mecklenburg Environmental Coalition Audubon Society Dick Brown July 24, 1981 Carolina Action Affidavit Brenda Best To: The Nuclear Regulatory Comoission Washington D.C 20555 Carolina Environmental I, Henry Presler, resident at 943 Henley Place, Study Group Charlotte, N.C. 28207 do affirn the contents Jesse Riley of The Charlotte-Mecklenburg Environmental Henry Pressler (Chairman)

Coalition's PETITION TO INTERVENE AND REQUEST FOR HEARING in the Matter of Duke Power Company I)avidson Energy Group Dawn Wilson et al. (Catawba Nuclear Station, Unites 1 and 2)

Docket Nos. 50-413, 414 1 .

League of Women Voters June Kimmel dMD t b Safe Energy Alliance Henry A.'Presler Mike Fennell Chairman, Charlotte-Mecklenburg Environmental Coalition Sierra Club Margaret Miller O 'At A O Notary hCommissionExpires: bD-lfl-943 Henley Place

• Charlotte, North Carolina 28207

LEAGUE OF WOMEN VOTERS OF NORTH CAROLINA 2637 McDowell Street Durham, N. C. 27705 DIANE D. BROWN Telephone: (919) 493-1178 President July 2'J, 1901

'N .2 0: I t : .ay Concern:

I, Junc .:. i:i:: ucl, attest tha t th e Charlotte / . :c c t:-

IcrQurg Environuca tal Coalitica represcuts th e .. or th

arolila Leacuc of loted Joters la the Catat:ba licca sing stacc procecdings f or the Ca tat:ba ..uclear S ta tion .

' MD }. o r w n.i t June ::, lii:cccl S ta te Director League of locca 'lo t e r s yffp ff of .< orth Carolina

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SIERRA CLUB G Joseph LeConte Chapter 9%si,

. . . To explore, enjoy and prosorve the neaion's foveret, wenart, untdJifa need meldernos . . .

July 21, 1981 I, Eric Meyerson, resident of 705 McAlway Rd.,

Charlotte, North Carolina 28211; and Executive Committee Officer for the Central Piedmont Group of the Joseph LeConte Chapter of the Sierra Club, hereby attest that the Charlotte Mecklenburg Environmental Coalition represents the Sierra Club in the Operating Stage Licensing Proceedings for the Catawba Nuclear Station.

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_/ J/br 7t C f. JA' My Corunission Expires: 3/19/85 CENTRAL PIEDMONT GROUP P. O. BOX 6002 CHARLOTTE, N. C. 28207 704/376-0717 100% Recycled Paper

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I, Lilith :1uinlan Otey, resident at 726 Hartford Avenue, Charlotte, Morth Carolina, regard the licencing of Catawba Huclear Station an detrimental to my health and interesta.

I am a nember of the Carolina Environmental Study Group. The Charlotte I.:ecklenburg Environmental Coalition reprocents my interecto in petitioning to be admitted ao an intervener in licencing stage proceedings for the Catawba plant.

Signed _ ;9

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, PARK ROAD BRANCH t

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I, Lori Glosemeyer, resident at 721 Silverleaf Road, Charlotte, N.C., attest that the CMEC is empowered to represent the interest of the Safe Energy Alliance in respect tu one CMEC's particular interventions into the licensing proceedings for the Catawba Nuclear Station, Docket Numaers 50413, 50414.

Signed '/ID ' O- 8/bu4,ut,r O 6

Witnessed \ ,/ J Z /R ( f s 6[4/

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I, Sarah Wilson, residing at Rt. 2, Box 558s, Huntersville, N. C. 28078, and a member of the Davidson Energy Group, consider my health to be threatened by the proposed operation of the Catawba Nuclear Station. I attest the I

Charlotte-Mecklenburg Enviornmental Coalition is representing my interests.

i Sarah Wilson

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