ML20040F302

Proposed Change to Charlotte-Mecklenberg Environ Coalition Proposed Contention 1

ML20040F302
Person / Time
Site:	Catawba
Issue date:	02/01/1982
From:	Presler H CHARLOTTE-MECKLENBERG ENVIRONMENTAL COALITION
To:	Atomic Safety and Licensing Board Panel
References
NUDOCS 8202090058
Download: ML20040F302 (2)

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UKITiJ 32A233 OF AMERICA NUCLEAR ELUZA20hY CC;;;ISSION ' ",-

BEFORE THE ATOMIC SAFITY AND LICEUSING 30AF.J-in the :stter of )

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) p'"ocket 5o. 50-41 b (Catawba le,uclear Station, ) 4W: ^ _ N Units 1 & 2) )

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-A Pronosed Chance in CMEC's Contentions t.R

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1 Introduction b *.~ar,,$$f%

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10 At the Pre-hearing conference in York S.C. on January 12, 1982, Mr. Ketchen suggested to me that the

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NRC Staff might be prepared to withdraw its objections to CMEC's first proposed contention if that contention were re-written in such a way that the difficulties indicated in "UhC. Staff response to supplemental ctatements of contentiions by Petitioners to intervene" were removed. Mr.1:etchen and I discussed these difficulties;I rewrote the contention.

cle discussed the rewritten contention over the telephone.

Accordingly, I submit the rewor'ing d to the KRC Staff for consideration.

I note that CSEC entered into an agreement with Mr. Carr and Mr. McGarry whereby CHEC undertook not to introduce any new contentions into the proceedings beyond the four-we have proposed. The re-wording of the contention is designed to meet what Mr. Ketchen understands as the specificity requirements of the rules;CMEC does not intend any introduction of new material. .I wish to state in advance that,if Mr. McGarry or Mr. Carr find any contravention of our agreement in the re-worded contention CMEC withdraws-this proposal with apologies to both!

2. The Re-worded Contention _s_1 2he cost-benefit balance does not support operation.of the Catawba Nuclear Station because of high routine emissions of gaseous and licuid radionuclides. These enissions will be higher than the Applicants' ER projects in the following two respects: E)bCD 3r Ib

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(a) The projections set-out in the 32 are understated in that they do not reflect the fact that during the operating life a LWR such releases will become progressively greater.

(b) The' projections' set out in the ER are based on assumptions which lack proper scientific foundation in that there are wide divergences between such projections for the McGuire I:uclear Station (as shown in the ER and ?Z3 for.the McGuire operating license) and Catawba (as shown in the Catawba ER), notwithstanding the fact that the Catawba reactors and McGuire reactors are essentially similar in design.

These routine emissions.will result in hiG er h concentrations of radionuclides in the air and in the Catawba Eiver than the.

Applicants project. Applicants' projections for radionuclide concentrations in the Catawba fail,'to take into -account o

(a) the cumulative effect of raionuclide concentrations b

resulting from routine emissions from McGuire upstread

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from the Catawba facility j (b) the precipitation of gaseous radionuclides into the Catawba River watershed. This precipitation of radionuclides into the watershed will be exacerbated by several factors; (i) the prevailing winds.from both the Catawba and McGuire facilities blow generally up the Catawba River Valley (ii) this area is adversely affected by lon6 periods of air stagnation which will prevent dispersal of.

Baseous radion~uclides.

I In addition, the models employed by the Applicants for calculating radionuclide concentrations in the Catawba resulting from normal operation of the facility seriously underestimate the level of these concentrations.

Finally, because of'all these factors taken together, concentrations of certain radionuclides, particularly tritium, will approach or exceed drinki ng wat,' standards.

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H,enry .

-945 Henl,esler, Chair ey Place, for CMIC D.C.

Charlotte, 28207 February 1,1982 Telephone: 704-333-8589