ML20010G513

Supplemental Response to NRC Interrogatories & Request for Production of Documents.Certificate of Svc Encl.Related Correspondence

ML20010G513
Person / Time
Site:	Callaway
Issue date:	09/10/1981
From:	Chackes K CHACKES & HOARE, JOINT INTERVENORS - CALLAWAY
To:	NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD)
References
ISSUANCES-OL, NUDOCS 8109220084
Download: ML20010G513 (6)

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q'!alti e REIATED C6RRESPONDENC3 // DOCKEFED ,

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UNITED STATES OF AMERICA 01 EP1519811

• p NUCLEAR REGULATORY COMMISSION Offics cf th Facretary Doch&g & Senice BEFORE THE ATOMIC CAFETY AND LICENSING BOARD 0*

• 1%Q In the Metter of /

UNION ELECTRIC COMPANY ) C (Callaway Plant, Unit 1)

) Docket No. STN 50-483-OL Sgp2 21 -

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SUPPLEMENTAL RESPONSE TO NRC STAFF INTERROGATORIESY ,

2 0! L 0s C, AND REQUEST FOP. PRODUCTION OF DOCUMEN'IB TO COALITTON FOR THE ENVIRONMENT, ST. LOUIS REGION; MISSOUrdANS FOR SA'fR ENERGY: AND CRAWDAD ALLIANCL" Joint Intervenors  % nit the following Supplemental Response to NRC Staff Interrogatories and Requests for Production of Documents to Coalition for the Environment, St. Louis Region; Missourians for Safe Energy; and Crawdad Alliance. All documents identified, unless otherwise indicated, are in the possession and/or control of Kenneth M. Chackes, Attorney for Joint Intervenors and will t . made available for inspection and/or copying upon reasonable request.

Q-3. (a) A study involving the specific use of a model for radionuclide transport in a simulated river environment was reported in Gloyna, E.F., et. al., "Radionuclide Transport and Responses to Organic Stress in a Research Flume," proceedings of 5th International Water Pollution Research Conference, July - August 1970, Permagon Press, Ltd. Additianal reference is made to Shih, C.S.

and Gloyna, E. F. , " Radioactivity Transport in Water

- Mathematical Model for the Transport of Radionuclides," EHE-04-6702, CRWR-18, Technical Rep No.12, U.S., Atomic Energy goy l Commission, June,1967. Use of water and sediment routing l model was proposed to Oak Ridge National Laboratory to track th the migration of radionuclides in stream channels tributary to the (PDR ADOCK8109220084 05000483 810910 G PDR

Clinch River, Simons, Daryl B. and Li, Ruh-Ming, " Preliminary Proposal on Modeling of Radionuclide Transport from Disposal Areas at Oak Ridge National Laboratory," proposal submitted to ORNL, Colorado State University, Hydraulies Program, Engineering Research Center, Fort Collins, Colorado,1978. This 4

paper recognized the need for further investigation into sediment

transport ud the chemical interaction between sediment, organic matter, and the various types of radionuclides. Field studies of radionuclide tunsport in channel and river sediments carried downstream from nuclear generating stations include Simpson, l'

H.J., et. al., " Man-made Radionuclides and Sedimentation in the J

Hudson River Estua y," Science, Vol.194, October 8,1976, pp.

179-183, and studies made on two operati ~ reactors, one in Conneticut, Radiologicsl Su teillance Study, dPA, Haddom Neck EPA-520/3-74-007 (1974), and .Ae in Massachusetts, Radichgical Surveillance Study, EPA, Yankee Row RD77-1 (1971).

l Sorption of heavy metals, pesticides, and radionuclides onto sediments is recognized by several authors (Gloyna, E.F., et. al.,

"Radionuclide Transport and desponses to Organic Stress in a J- Research Flume," proceedings of 5th International Water Pollution Research Conference, July - August 1970, Permagon Press, Ltd.;

Shen, Hsieh Wen, ed., Modeling of Rivers, John Wiley and Sons, New York,1979; Simor.s, Daryl B. and Li, Ruh-Ming, " Preliminary i

Proposal on Modeling of Radionuclide Transport from Disposal Areas at Oak Ridge Vational Laboratory," proposal submitted to ORNL, Colorado State University, Hydraulics Program, Engineering Research Center, I' ort Collins, Colorado,1978) and )

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penetration of radionuclides to deeper depths in bed sediments is reported and modeled by Gloyna, E.F., et. al., "Radionuclide Transport and Responses to Organic Stress in a Research Flume,"

proceedings of 5th International Water Pollution Research Conference, July - August 1970, Permagon Press, Ltd. ,

l sb) Buildup or deposition of sediment on shallow banks and in protected 4

shoals is of concern due to higher rates of sedimentation. -leld '

studies, Simpson, LJ., et. al., "Maa-made Radionuclides and

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Sedimentation in the Hudson River Estuary," Science, ul.194, October 8,1976, pp.179-183, have found higher levels of activity 3 (137Cs) in shallow environment where sediment accumulates more rapidly.

(c) 134Cs,137Cs, 60 Co, 239Pu, 240Pu.

(d) The transport of bed-load sediment material is functionally related to weral hydraulic variables, -Richardson, Everat V., " Rainfall-Rumoff and Sedir.ientation," Lecture 13, unpublished lecture notes, Water Resources Planning and Management Program Colorado State University, Engineering Research Center, Fort Collins, Colorado,1980; Shen, Hsieh Wen, ed., Modeling of Rivers, John Wiley and Sons, New York,1975. One of these variables is velocity of flow, which increases with flooding. Dredging also, by definition, involves the resuspension of sediment and its likely deposition elsewhere as dredge' spoil.

(e) "High levels of contamination" refers to dangerous levels of radioactivity that could causc contamination of aquatic life and thereby potentially of the human food chain.

(f) (a) Objected to.

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- l (b) Objected to.

(c) None.

(d) No answer required. l (c) No answer required.

(f) See documents identified above.

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Kenneth M. Chackes, attorney for Joint Intervenors 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 as is presently available to Joint Intervenors.

Kenneth M.Chackes

/Ahburb2M Subscribed and sworn to before me this (D day of September,1981,

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Notary Publi() '

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7 My Commission Expires: I , bb [M CHACKES AND HOARE K'enneth M. Chackes -

Attorneys for Joint Intervenors 314 North Broadway St. Louis, MO 63102 314/241-7961 6

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

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UNION ELECTRIC COMPANY ) Docket No. STN 50-483-OL

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(Callaway Plant, Unit 1) )

4 CERTIFICATE OF SERVICE I hereby certify that copies of the Supplemental Response to NRC Staff Interrogatories and Request for Production of Documents to Coalition for the Environment, St. Louis Region; Missourians for Safe Energy; and Crawdad Alliance have been served on the following by deposit in the United States mail this lith day of September,1981.

James P. Gleason, Esq., Chairman Atomic Safety and Licensing Board 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 Panet U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Thomas A. Baxter, Esq.

Shaw, Pittman, Potts & Trowbridge 1800 M Street, N.W.

Washington, D.C. 20036 Docketing and Service Section Office of the Secretary U.S. Nuclear Regulatory Commission

• Washington, D.C. 20555 Roy P. Lessy, Jr., Esq.

Office of the Executive Legal Director U.S. Nuclear Regulatory Commission Washington, D.C. 20555

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, Kenneth M. Chackes CIIACKES AND IIOARE I

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