ML20041B576

Rept on Charlotte-Mecklenberg Environ Coalition Contentions. Applicants Agree That Contentions 2,3 & 4 Are Proper Contentions.Agreement on Contention 1 Reached

ML20041B576
Person / Time
Site:	Catawba
Issue date:	02/19/1982
From:	Mcgarry J DEBEVOISE & LIBERMAN, DUKE POWER CO.
To:
Shared Package
ML20041B577	List: ML20041B576 ML20041B579
References
NUDOCS 8202240304
Download: ML20041B576 (6)

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION T2 ER 22 A9 33 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )

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DUKE POWER COMPANY, et al. ) Docket Nos. 50-413

) 50-414 y s (Catawba Nuclear Station, )

Units 1 and 2) ) @ R\

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APPLICANTS' REPORT TO THE BOARD ON Q #4  ?, D I' !

CHARLOTTE-MECKLENBURG ENVIRONMENTAL COALIT:[0F l>

(" COALITION") CONTENTIONS \" -

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On December 30,-1981, Applicants' informed the Bo Q , h' that, as a result of discussions with the Coalition they had no objection to the admission of the contentions advanced by the Coalition in its December 9, 1981 pleading. 1/

The Staff in its pleading of December 30, 1981 opposed the C.oalition's contentions. At the January 12, 1982 prehearing conference the Staff indicated that it might reconsider its position. See, i.e., Tr. 36. As a result of recent discus-sions between the Staff, Applicants' and the Coalition, it is Applicants' understanding that an agreement has been reached with respect to Contention 1. The Staff has not agreed that Contentions 2, 3 or 4 are proper contentions; Applicants' do.

~1/ Applicants' noted a minor clarification to the Coalition's Contention 3(a) which clarification was acceptable to the Coalition. See Tr. 30.

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To assist the Board, Applicants' are attaching a copy of the contentions of the Coalition.

Respectfully submitted,

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/J.DEBEVOISE Michael McGarr,y',

& LIBERMAN III f/

1200 Seventeenth Street, N.W.

Washington, D.C. 20036 (202) 857-9833 William L. Porter Albert V. Carr, Jr.

Ellen T. Ruff DUKE POWER COMPANY P.O. Box 33189 Charlotte, North Carolina 28242 Attorneys for Duke Power Company, et al.

February 19, 1982 l

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )

)

DUKE POWER COMPANY, --et al. ) Docket Nos. 50-413

) 50-414 (Catawba Nuclear Station, )

Units 1 and 2) )

CONTENTIONS OF THE CHARLOTTE-MECKLENBURG ENVIRONMENTAL COALITION

1. The Applicant's Environmental Report (ER) does not adequately project the radioactive emissions, both liquid and gaseous, which will result from normal operation of the Catawba Nuclear Station (Catawba) in the following respects:

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

(b) The projections set out in the Catawba ER are based on assumptions which lack proper scientific foundation in that there are wide divergences. between such projections for the McGuire Nuclear Station (as shown in the ER/and FES for the McGuire operating license) and Catawba (as shown in the Catawba ER) , notwithstanding the fact that the Catawba

reactors and the McGuire reactors are essentially similar in design.

Due to these inadequate projections, the cost / benefit balance does not support operation of the Catawba Nuclear Station.

2. The projections of radioactive emissions set out in the ER for normal operation of Catawba fail to take into account the actual accidental releases of radionuclides which have occurred at operating nuclear power plants with the United States.

3. The Applicants' ER does not adequately project the con-centrations of radionuclides which will occur in the Catawba River from normal operation of Catawba, and releases of the nature specified in Contention 2, in the following respects:

(a) The models and methods used in the ER under-estimate the resulting concentration of radio-nuclides in that they project an erroneous and overly optimistic dilution effect in the discharge canal and in the lake. We contend that the only suitable and realistic model is one that, in respect to any particular radionuclide, calculates the resulting con-centration by dividing the, e.g., annual pro-jected release into the total annual amount of water leaving the lake. The steady-state completely mixed model used in the ER results

in a lower. figure for the concentration than that yielded by the methodology described in the preceding sentence.

(b) The calculated concentrations of radio-nuclides in the Catawba River downstream of Catawba from liquid releases fail to take into account the cumulative impact of radio-nuclides released to the Catawba River from McGuire Nuclear Station during normal oper-ation of both the McGuire and Catawba Nuclear Stations. Such cumulative impact should be taken into account in calculating concentrations of radionuclides in water drawn from the Catawba River by communities downstream from Catawba.

(c) The calculated concentrations of radionuclides, particularly tritium, drawn from the Catawba River upstream of Catawba into the water supply of the City of Charlotte dcas not take into account the fact that gaseous releases from l normal operation of Catawba will be carried up to 50 miles from Catawba and will be brought back into the Catawba River waternhed through rainfall.

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, Due to these inadequate projections, the cost / benefit balance does not support operation of the Catawba Nuclear. Station.

4. The ER inadequately assesses the long-range genetic and

, somatic health effects of routine releases. of radioactivity within applicable NRC guidelines during normal operation, and releases of the nature specified in Contention 2, of the

Catawba Nuclear Station, in that it fails to take into account recent work which shows the long-term genetic and somatic health effects of such releases to be damaging to adults and extremely hazardous to the human embryo and fetus.

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