ML20041C297

Revised Contention 3 Re Radioactive Releases Into Catawba River

ML20041C297
Person / Time
Site:	Catawba
Issue date:	02/22/1982
From:	Presler H CHARLOTTE-MECKLENBERG ENVIRONMENTAL COALITION
To:	Atomic Safety and Licensing Board Panel
Shared Package
ML20041C294	List: ML20041C293 ML20041C297 ML20041C298
References
NUDOCS 8203010121
Download: ML20041C297 (2)

Text

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UNITED STATES OF AMERICA m'4 "p NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD '

In the Matter of ) '82 FEB 25 NM DUKE POWER COMPANY, et al. Docket Nos -

(Catawba Nuclear Station, ) i l R ""$ p

Units 1 & 2) )

CMEC's Contention gl Revised I. Staff, Applicant and Petitioner have discussed CMEC's Contention #3 and have agreed to a rewording. Applicant is prepared to enter a stipulation to the reworded contention; NRC Staff is prepared to enter a stipulation to the reworded contention except insofar as the reworded contention mentions CMEC's contention #2 to which Staff objects. Accordin6ly, I request that.the4 Board notice and admit for consideration the following revision of CMEC's contention #3.

II. Contention #} (revised)

The Applicant's ER does not adequately project the concentrations 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 underestimate-the resulting concentration of radionuclides in that they project an erroneous and overly optimistic dilution effect in the discharge canal and in the lake. We content that the only suitable and realistic model is one that, in respect of any particular radionuclide, calculates the resulting concentration by dividing the, e.g. annual projected releases 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 yijlded g ng by the methodolgy described in the preceding sentence.

No' oc

b. The calculated concentrations of radionuclides in the gg Catawba River downstream of Catawba from liquid releases

- f ail to take into account the cummulative impact of us 38 radionuclides released to the Catawba River from McGuire o$

n Nuclear Station during normal operation of both the McGuire gg and Catawba Nuclear Stations. Such cummulative impact should be taken into account in calculating concentrations

.o of radionuclides in water dracn 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 does not take into account the fact that gaseous releases from normal operation of Catawba will be carried up to 50 miles from Catawba and will be brought back into the Catawba River watershed through rainfall.

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

Respectfully subcitted,

)'

Henry A..'Presler, Chairman Charlotte-Mecklenbur6 Environmental Coalition 945 Henley Place, Charlotte, N.C. 28207 704-333-8589 Feb. 22, 1982 cc: Service List

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