ML20010H576
| ML20010H576 | |
| Person / Time | |
|---|---|
| Site: | Callaway  |
| Issue date: | 09/17/1981 |
| From: | Chackes K CHACKES & HOARE, JOINT INTERVENORS - CALLAWAY |
| To: | UNION ELECTRIC CO. |
| References | |
| ISSUANCES-OL, NUDOCS 8109250265 | |
| Download: ML20010H576 (14) | |
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~ Usur c UNITED STATES OF AMERICA g SEP2 1193[ , 3 NUCLEAR REGULATORY COMMISSION -
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UNION ELECTRIC COMPANY )
Docket No. STN 50-483-OL. s Z jf/l4 (Callaway Plant, Unit 1) -)
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RESPONSE TO APPLICANT'S INTERROGATORIES AND//s REQUESTS FOR DOCUMENT PROD'iCTION (SET. NO. 2) A3/g p-TO JOINT INTERVENORS ON THEIR CONTENTION NO. 2 NL.
Joint Intervenors submit the following Response to Applicant's Interrogatories and Requests for Document Production (Set No. 2) to Joint Intervenors on their Contention No. 2. All documents identified, unless otherwise indicated, are in the possession and/or control of Kenneth M. Chackes, Attorney for Joint Intervenors and will be made available for inspection and/or copying upon reasonable request. Joint Intervenors are unable to answer completely many of the questions pertaining to Contention No. 2 because of the unavailability of the technical specifications, and the FES and SER.
2A-1 The following is a list of inadequacies of currently available systems for monitoring the radionuclide levels in liquid effluent streams at commercial nuclear power generating facilities:
(1) There is a need for monitoring equipment sensitive enough to detect the low release rates permitted by regulatory organizations from relatively local sources of radionuclide emission. (NCRP Report No. 50, Environmental Radiation Measurements, p.193,. See also Joint Intervenors' Response to Interrogatory A-1(1) at
- p. 5).
In the case where population dose measurement is needed following j [
a release of radionuclides, instruments of the required sensitivity are not available as 0109250265 810917 d,PDR ADOCK 05000483 PDR
the extensive monitoring capabilities required are so expensive that the EPA has recommended substituting the use of calculational techniques for assessing the resulting population dose (EPA, A Computer Code (RVRDOS) To Calculate Population Doses from Radioactive Liquid Effluents and an Application to Nuclear Power Reactors in the Mississippi Rivg Dasin, Technical Note ORP/EAD-76-4, October 1976, p. 3). EPA's suggestion both admits and presumes that in-plant liquid effluent monitoring systems will not be able to adequately detect 'and respond to various forma of unplanned radionuclide releases resulting froct nuclear plant operation.
(2) Current monitoring technology has been found to allow the release of radionuclides, as measured at liquid effluent release points, that either decay rapidly (into stable or radioactive daughters) or that are not able to be readily detected by the preferred method of gamma-ray spectrometry (EPA, Radiological Surveillance Study at the IIaddam Neck PWR Power Station, EPA-520/3-74-007, Cincinnati, December 1974, p. 1. See also Joint Intervenors' Response to Interrogatory A-1(1) at p. 5).
(3) It is possible to miss critical radionuclides if detection systems monitor only the obvious efflue.:.ts and the easily measured radionuclides, or are not able to adjust to changes in the operating cycle of the plant (EPA, Rndiological Surveillence Study at the IIaddem Neck PWR Nuclear Power Station, EPA-520/3 007, December 1974, p.118. See also Joint Intervenors' Response to In ._ +. .m c
- 1(1) at p. 6).
(O Radionuclides which have no gamma rays and relatively weak beta radiation (e.g. Fe-55, Ni-63, etc.) are not easily detected by currrent monitoring technology. As such, it may be necessary to calculate the releases of such radionuclides, rather than depend on available monitorir.g systems for their detection and measurement.
(NitC Regidatory Guide 1.2!, pp.1.21-4 and 1.21-G. See also Joint Intervenors' Response to Interrogatory A-1(1) at p. 6). -
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S (5) Although rather sophisticated versions of radionuclide monitoring and warning systems are not under consideration, the systems in currently operating plants are relatively primitive and may not be adequate to provide sufficient warning (with suffielent detail on release size) for implementation of the most effective measures for protecting surrounding populations. (Nero, A.V. and Wong, Y.C., "Itadiological llcalth and Itclated Standard; for Nuclear Power Plants," Lawrence Berkeley Laboratory, LBL-5285, Jamunry 1977, p. 61).
(6) There is substantial evidmco that currently available monitoring systems are subject to failure from mechanical problems and human error. Documented cases are casily found in the Nuclear Itegulatory Commission's bi-weekly pintout
" reportable occurrences" and in a special printout of Licensco Event Iteports covering plant operations from 1969 to early 1981 entitled, "LEll Output on Pressurized Water llcaetor Events involvim Itcleased Activity from 19G9 to the Present." The former is sent to depository libraries and the LEll output is available from the NitC's Office for Analysis and Evaluntloa of Operational Data in Washington, D.C.
Component failure is one of the two main causes of accidents at nuclear power plants. Monitoring systems malfunction because of inadequate maintenance, aging of parts, electronic failure and even natun,1 phenomena.
In January,1977, at the Cooper plant in Nebraska, the monitor located 7500 feet downstream was damaged by ice on the river and cou i not be repaired until the weather improved.
On April 12, 1979, at Crystal itiver 3, the liquid rndfation release monitor went into high alarm. Several valves failed to cie.se because of sticking contacts within the radiation monitor by-pass switch. The contacts had to be cleaned and lubricated.
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Corrosion products at a throttle valve plugged the sample line to the radiation detector at Turkey Point 4 on August 12, 1974. The monitor system failed to alarm when needed dur~ ; a leak.
On March 11, 1976 at the Millstone plant in Connecticut, there was a monitor failure. Illgh voltage and discriminator control drift were caused by aging parts.
At Fort Calhoun l'on March 7,1975, the liquid effluent control monitor failed due to a shorted reset switch. As a result, a radioactive discharge eighteen times the allowable limit in 10 CFR 20, Appendix B, Table 2 was made into the Missouri River.
There are instances in the LER printout in which monitors are simply inoperable and no cause is provided (or known). Ten times the maximum permissible concentration for tritium was discharged into a sewer at Donald C. Cook I on August 19, 1976 because neither of the G.E. gamma spectrum analysis units was operating. A similar incident occurred at Zion 1 on September 22,1977 when a radioactive discharge was made into Lake Michigan.
Iluman error accounts for monitoring failures in a variety or ways. Sometimes samples are not counted for a sufficient length of time by technicians.
This happened at Joseph M. Farley 1 on October 21, 1977 as a discharge was being made into the Chattahoochee River, More ofiel in LER, releases are made without sampling at all, as at Zion 1 on Augue 2,1980. Staff is usually " reprimanded" or " reinstructed" when this cacurs.
On March 2G, 1976 at the Quad Cities plant in illinois, the radiat:or, protection technician miscalculated the discharge rate by a factor of 10 and the shift engineer failed to catch the mistake when using his graphical verification.
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Some reports show that personnel do not always respond correctly when moni'oring systems indicate a problem. On August 15, 1973 at the Palisades 1 plant, the operator did not stop purging iodine gas when high levels were realized.
During a release of radioactive gas, caused by component failure at Crystal Iliver 3 on September 18, 1977, personnel did not respond to a computer alarm. The release was unmonitored and lasted for 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> and 50 minutes.
Plant personnel remove monitors from service e neglect to reset them. At Oconee 1 on May 13,1974, the operator failed to follow procedures and did not return the waste gas monitor and the stack monitor back to operation efter calibration. On February 7,1971 at II.B. Robinson 2, 300 gallons of radioactive liquid waste were released from a tank after the technician inadvertently removed the monitor from service in order to clean the chamber.
The monitoring systems are susceptible to component failure and human error. There may be no redundant systems and that the data provided in incidents involving monitoring problems could be only estimates. The most chilling example is on p.111 of the LER Output. On March 28, 1979 at Three Mile Island 2, the amount of radioactivity released in an accident is inexplicably described as " greater than 100,000 curies total."
2 A-2. A 100 year drought is evaluated by a statistical study of Weather Bureau Records. As withdrawals and diversions become more important, extensive dry weather conditions can become more important in determining low flow conditions. 31ost low flow conditions have occurred in the historical record as a result of ice jams. The past is not necessarily a good guide to the future. It is the purpose of the stream dilution models to predict the future. Therefore, the possbilit!es of large withdrawals coinciding with a 100 year drought should be taken into consideration.
2 A-3. No. It is possible to estimate but r.at to absolutely, accurately predict the amount of dilution afforded by the Missouri River. To base the estimation on only 5
average conditions does not take into account the fact that the river is not a static system and is frequently not at average conditions. A range of values should be reported to cover the best and worst circumstances.
2 A-4. Both the UE Environmental Report - 1974 and the UE Environmental Report, Operating License Stage show that an extensive population study of the " fish standing crop biomass" was made, EROLS Vol. I Section 2.2.2.7 Fish, pp. 2.2 37.
Ilowever, in the sectiom " Pathways for' Exposure to Biota Other Than Man," Section 5.2.1.1 and Figure 5.2-1, EROLS Vol. II, fish are shown to be subject to radio-contamination only by " immersion" and " ingestion" while suspended in mid-stream. No mention is made of bottom-feeding fish being exposed to "redioisotopes deposited in sediments at the bottom of the river," though the existence of the radioisotopes in sediments is acknowledged (Section 5.2.1.1).
By comparison, at the Savannah River Plant (SRP) two preoperational surveys and a monitoring program include " specific radionuclide analyses of selected organ: sus" chosen for the following attributes:
"1 It efficiently concentrates radionuclides in the environment and, therefore, is used as a sensitive monitor of environmental radionuclides.
"2. It is a food item of man and, therefore, is useful in evaluating the dose receivt J by the off-plant population" (" Biological Indicators of Environmental Radioactivity" by R. S. Ilarvey, pp. 136-139 in Environmental Surveillence in the Vicinity of Nuclear Facilities, Reinig, W. C., editor. Springfield: Charles C. Thomas, publisher.
1970). Organisms accumulate radionuclides by absorption, adsorption, and ingestion.
Those organisms studied at SRP include fresh water clams which live in sediments and both bottom-feeding catfish and bluegill sunfish, a surface and bottom-feeding omnivore.
Another study, "A Statistical Study of the IIabits of Fishermen Utilizing the Columbia itiver below IIanford" (pp. 302-338 in Environmental Surveillance), covered 21 fishing sites for an entire year in 4-hour time intervals, and the fish-eating habits 6
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of the fishermen, to obtain the " incremental radiation dose attributable to this pathway which includes both the internal radiation received from consumption of the fish and the small amount of external radiation received while fishing."
Though there is some commercial fishing on the Missouri in addition to recreational fishing, and both catfish arid bluegill sunfish are present in the river and surrounding waters, there is to indication of published studics, estimates, or projections on the amount of fish eaten and the effects of sediment contamination on fish, fishermen, and fish-eaters along the Missouri River and other waterways mentioned in EROLS.
In " Evaluation of Iloman Radiation Exposure" (pp. 240-260 in Radioactivity in the Marine Environment, prepared by the Panel on Radioactivity in the Marine Environment of the Committee on Oceanography, National Research Council, National Academy of Sciences,1971) Foster, R.F., el alo emphasize that "the levels of contamination in the edible portions of marine plants and arimals may be many times higher than in the water because of biological reconcentration processes. The levels that are acceptable for any specific situation deper.d upon the rates of consumption of locally derived foods, and these rates vary widely. Statistics for countries as a whole are usuall,, of little relevance with re pect to specific regions, and only surveys of local consumption can provide the data necessary to determine permissible concen+ rations in particular dietary items (p. 241)."
"Some radioactive debris enters the water as particulates, and some radionuclides in solution are casily adsorbed to the surface of particles, The result is radioactive contamination of sand and sediments (p.143)." Plant life and sman arthrocods caten by bottom-feeding fish pick uo and concentrate the radionuclides, which are then concentrated further in the fish.
Finally, as another pathway to man related to bottom-feeding fish a .d sediment contamination, " fishing gear - and particularly commercial fishing gear - may 7
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become contaminated directly by adsorption of radioactive materials from the water or indirectly from radioact!ve particulates on the [ river} bed or in silty water (p.143)."
While pre operational studies of the environment may have been done, in " Objectives of Environmental Surveillance" (Environmental Surveillance in the Vicinity of Nuclear Facilities, pp. 21-25) the panel agrees that "we need to repeat this type of study about every five years. Peoples' (sic) habits change and the environment itself changes; you may find that a community which is cating oysters at a certain rate one year will be eating them at a quite different rate in the future."
Moreover, "we do not yet know all the possible routes by which all the materials can reach man in an cnvironment. We are not invariably and infallibly able to pick the correct route (p. 22)." No one model is enough, and no model complete enough has yet been constructed, in a study of the accumulation of radionuclides in the sediment of the lludson River estu 7, the authors have shown that " accumulation rates of sediment in the harbor approach 5-10 cm/yr over large areas, which is more than an order of magnitude greater than the long term average for the entire liudson." Simpson, II.J.,
Olson, C.It., Tribr, R.M. nad Williams, S.C. (1970) Man-made Radionuclides and Sedimentation in the liudson Estuary. Science 194, 179-183. The area of the lludson in question was the New York liarbor and the radionuclide source was from global fallout and " low-level" releases of a local nuclear reactor. This study showed that accumulation in the sediment of radionuclides occurred at a higl'. level which indicates that particular areas of river ecosystems are more susceptibM to secumulation of indionuclides than other areas. Therefore, the area at or near the outflow might be more susceptible to accumulation of radionuclides than other areas of the river in general.
The effects of accumulation of toxic compounds, such as mercury. on bottom-feeders in river ecosystems are well known. In a report in Science in 1977 the rapid uptake of methyl mercury by bottom-dwelling plants and bottom-feeding l
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aquatic animals ws documented. Fur *.her, it was emphasized that sediment dwelling microorganisms tended to concentrate the toxic compounds. Therefore, bottom-dwellers tend to incorporate high levels of bottom waste matter. Carter, L.J. (1977), Chemical Phnts Leave Unexpected Legacy for Two Virginia Rivers. Science 198: 1015-1020.
[ Although few direct data have been collected on the levels cf 1'
radionuclides in bottom-feeders and in fish in general it'seems likely that where there is an accumulation of radionuclides in river sediment, there is a further concentration of radionuclides by microorganisms and a rapid uptake of radionuclides by organisms in direct contact with the river sediment. Pentreath, R.J. and Lovett, M.B., (1976),
Occurrence of Plutonium and Americium in Plaice from North-Eastern Irish Sea. Nature I
! 262; 814-816. Cherry, R. D., and Shannon, L.V. (1974); Atomic Enctgy Rev.12; 3-45.
2A-5. See 2 A-4, above.
2 A-6. Models in biology or in any scientifie discipline Indeed are useful as predictors of parameters set forth by the modeler. However, several qualifications must be included in this summary definition of the usefulness of models in science.
R.B. Braitwaite states that "for using models we must never forget that we are engaging in as if thinking . . . to forget the limitations (of models] is to misuse the valuable aid to thought provided by the model." (p 52). TMs statement encompasses
- the philosophy behind modeling in ecology. The model exists as a predictor and as a hypothesis to be tested by direct experimental evidence. L a model is not used as a guide or base for experimentation then, according to Breitwaite, it is being misused, and the invaluable experimental stimulation provided by the model is lost. Braltwaite, R.B. (1973); "The Nature of Theoretical Concepts and the Role of Models in Advanced Science" in Theories and Observation in Science, ed. by R.E. Grandy.
E.C. Pielou, in one if the more recent reviews of biological modeling, i
defines a model in the following way:
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Modeling consists in constructing, mentally, a plausible symbolic representation of an ecosystem, in the form of mathematical equations. One then tests whether
! the behavior of the ecosystem conforms with that of f the model. (p.17, emphasis added).
She believes that most ecological models today are " constructed, refined, elaborated, l tinkered with, and displayed with little or no effort to link them with the real world."
(p. 17). Henca her appeal is to ecologists to perform experimental tests of the models they formulate. She states that "models have many uses, but as means to various ends,t. s ends themselves." (p.18). And it is with a tinge of irony, because she has spent most of her professionnal career as a mathematical model builder in ecology, that she makes the following statement: "Modeling is only a part, and a subordinate part, of ecological reuearch." (p. D). Pielou, E.C. (1981); "The Usefullness of Ecological Models: A Stock Taking." The Quarterly Review of Biology 56: 17-31 See also 2A-4, above.
2 A-7. The basis for that contention is found in Joint Intervenors' original response, in paragraphs (a) through (0, pages 10 through 17.
2 A-8. The "other factors" are Joint Intervenors' entire case on Contention 2.
See responses to both 1st and 2nd sets of interrogatories on Contention 2.
2 A-9. "Six State High Plains Ogallala Aquifer Region >.1 Resources Study," Public Law 94-587, Secta,n 193. Presented by the High Plains Study Counct and its associates at Congressional briefings in Washington on Fcriary 25, 1981.
2A-10. See 2 A-1, above, 2 A-11. Yes.
2 D-1 The inadequacies of gaur ian models, especially for predictions of dis;:.ersion have been discussed frequently in recent years. Below is a sampling of references dealing with this subject.
(1) Lectures on Air Pollution and Environmental Impact Analysis, published by the American Meteorological Society, Boston (1975).
P,
(?) R. G. Lamb, " Air Pollution as a Problem in Statistics," in Preprints of the Invited Papers to Environmetries '81, sponsored by the Society of Industrial and Applied Mathematics, New Canaan, CN (April,1981).
(3) A. Venkatram, "The Expected Deviation of Observed Concentrations from Predicted Ensemble Means," Atmospheric En ,conment 13, 1547-1549 (1972).
(4) S. R. Hanna, " Accuracy of Dispctsion Models," (A position paper of the AMS 1977 Committee on Atmospheric Transport and Diffusion). Bulletin of The American Meteorological Society _ 59, 1025 (h id).
(5) D. Bruce Turner, " Atmospheric Dispersion Modeling - A Critical Review," Journal of the Air Pollution Control Association 29, 502 (1979).
(6) Discussion Papers in response to the above article. J A PCA, 29, 923 (1979).
(7) A. 't. Weber, " Case Studies of Horizontd Spread of 85K r at 100km Downwind," Second Jcint Conference on Applications of Air Pollution Meteorciogy, (March,1980) published by the American Meteorological Society.
(8) Several papers in Fourth Symposium on Turbulence, Diffusion and Air Pollution - January,1979, published by AMS. E i9) Several papers in Fif th Symposium on Turbulence, Diffusion and Air Pollution - March 1981, publisher 1 by AMS.
2G-1. Join intervenors hereby strike the following sentence from their answer to Interrogatory G-1(2)(a): "T'le presence of radioisotopes accelerates the corrosion rate of metallic materials." The striki: g of this sentence dces not alter the importance of the interaction of radiation with corrosion products which rertits in a considerable contribution to the burde^ of radioactive isotopes in the cooling water. There is rio disagreement among solid state physicists who are familiar with the field of radiation effects on metals that the presence of radioactivity results in defects in metals as well 11
as in the increased likelihood of fatigue in metals, and that massive irradiation of certain metals could result in damage ahich could very well result in fractures, leading to releases of radioactivity to the environment. With prolonged exposure to radiation the likelihood of such fractures occurring increases significantly. Documentation includes: (1)Dienes, G. J. and Vinyard, G. H., Radiation Effects in Solids. New York:
Interscience. (1957). (2) Internatir>nal Atomic Energy Agency, Radiation Damage in Reactor Materials Vol. I, (Proc. Symp. Vienna 1969). Vienna (1969). (3) Peterson, N.
L. and Ilarkness, S. D., editors, Radiation Damage in Metals. (Proc. Symp.1975).
American Society for Metals, Metals Park, Ohio. (1976). (4) Thompson, M. W., Defects and Radiation Damage in Metals. Cambridge: University Press, (1969).
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Kenneth M. Chackes, attorney for Joint latervenors Coalition for the Environment, St. Louis Region; Missourians for Safe Energy; and Crawdad Alliance, and authorized as their agent for the purpose of answering the above interrogatories, hereby states to the best of his knowledge, information and belief that the responses provided above are true and contain such information es is presently available to J'imt Intervenors.
- % *--- aAm Kenneth M.Chackes Subscribed and sworn to before me this / day of September,1981.
, AdlEt h Notary P0blie l
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My Commission Expires:
l0[/L-[8'-
CHACKES AND HOARE
'Kenneth M. Chackes bW Attorneys for Joint Intervenors 314 North Broadway St. Louis, MO 63102 314/241-7961
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE TIIE ATOMIC SAFETY AND LICENSING BO ' RD In the Matter of )
)
UNION ELECTRIC COMPANY ) Docket No. STN 50-483-OL
)
(Callaway Plant, Unit 1) )
CERTIFICATE OF SERVICE I hereby certify that copies of the Response to Applicant's Interrogatories and Request for Document Production (Set. No. 2) to Joint Intervenors on Their Contention No. 2 have been served on the following by deposit in the United States mail this 17th day of September,1981.
James P. Gleason, Esq., Chairman Atomic Safety and Licensing Bcard 513 Gilmoure Drive Silver Spring, MD 20901 Mr. Glenn O. Bright Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Dr. Jerry R. Kline Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Cotamiasion Washington, D.C. 20555 Thomas A. Baxter, Esq.
Shaw, Pittman, Potts & Trowbridge 1800 M Street, N.W.
Washiagton, D.C. 20036 Docketing and Service Section Office of the Secretary
, U.S. Nuclear Regulatory Commission iiashington, D.C. 20555 Roy P. Lessy, Jr., Esq.
Office of the Executive Legal Director U.S. Nuclear Regulatory Comm don Washington, D.C. 20555 7L d' d.ce Kenneth M. Chac':es CIIACKES AND IIOARE
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