ML20062M627

Amend to Charlotte-Mecklenberg Environ Coalition Petition to Intervene,Per ASLB 811105 Order,Setting Forth Contentions.Affirmation of Svc Encl

ML20062M627
Person / Time
Site:	Catawba
Issue date:	12/09/1981
From:	Presler H AFFILIATION NOT ASSIGNED
To:	Atomic Safety and Licensing Board Panel
References
NUDOCS 8112170371
Download: ML20062M627 (4)

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UNITED STATES OF AMERICA UUCLEAR REGULATCRY COMMISSION

, ;qin l BEFORE THE ATOMIC SAFETY AND LICENSING BOARD ~ ;W:c "

In the Matter of ) O I DUKE POWER COMPANY, et al., Docket Nos. h-4g 14 P4:28 50-414 (Catawba Ruclear Station, S F.ET O

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Unites 1 & 2) a & EERViCE

. :.~CH CONTENTIONS OF THE CHARLOTTE-MECKLENBURG ENVIRONMEN

• COALITION .Nf In accord with the Board's Order of Nov. 5, 1981 CMEC herewith amends its petition and contends that the/-

applicant's Application for an Cperating License should d h$:

DEC161981* e be denied on.the following grounds: -

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1. The Applicant's Environmental Report (ER) does not 9, /

adequatelyprojecttheradioactiveemissions,bothliquih b and gaseous, which will result from normal operation of the "

Catawba Nuclear Station (Catawba) in the following respects:

(a) Tht, projections set out in the 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 ER ar~e 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 i4cGuire operating license) and Catawba (as shown in the Catawba ER), notwithstanding the fact that the Catawba reactors siid UN bcGui$F redt3N are ebbENicfky similar in design.

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

3 The Applicants' ER does not adequately project the concentrations l of radionuclides which will occur in the Catawb'a River from l normal operation of Catawba, and releases of the nature specified ~;

in Contention 2, in the following respects: )

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(c)~ 2ho models and methods used in the In underestimste ,

the resultin6 concentration of radionuclides _in that -

they project an erroneous and overly optimistic .j dilution effect in the'dischar6e canal and in the lake. J We contend that the only suitable and realistic model is one that, in reypect to any particular radionuclide; '

calculates the resulting concentration by dividing the e.g. annual projected release into the total' annual amount of water leaving the lake. A ' feed and bleed'u model, such as that proposed in the ER, that results in a lower figure for the concentration than that yielded by our model, can only result in much highcr concentration in the lake 4tself.

(b) The calculated concentratifono of radionuclides in the Catawba River downstream of Catawba from liquid releases fail to take into account she' cumulative impact of s radionuclides released to the Ogtawba River from McGuire .

Nuclear Station during normal operation of both the .

McGuire and' Catawba Nuclear Stations.' Such cummulative impact should be taken into,' account in calculating concentrations of radionuclides in wate'r drawn from.

the Catawba River by communities downstrgad 'from Catawba.

(c) The calculated concentrations of radioriuclides, I

particularly tritium, drawn from the Catawba River upstream of Catawba into the water supply of the' Cit'y 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 brought back into the Catawba River watershed throuGh rainfall.

4 The ER inadequately assesses the long-range geneth.c and ~~

comatic health offects of routine releases of radioactivity , ,_

within applicable NRC guidelines during normals operation, and s releases of the nature specifi'ed in Contention 2, of the Catawba Nuclear Station, in that it fails tottake i~nto account recent a(

work which shows the long-term genetic and somatic health effects of such releases to be damaging to adults and extremely c hazardous to the human embryo and fetus.

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'As pcrt'of the ' stipulation process' Perioner has had

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discussions with J. M. McGarry and A. V. Carr, attornies for .

Applicant. It.is my understanding that, on the basis of

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these discussions ~, Applicant-agrees to the above four

' contentions.being brought before the Board by CMEC.

>} Submitted, I

(3M -

Henry A.kPresler, Chairman Charlotte-Mecklenburg Znvironmental Coalition 945~Henley Place, Charlotte, H.C. 28207 Telephone: 704-333-8589 December 9, 1981 J -

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"J"ITED STATES OF AIGRICA HUCLEAE REGULATORY COMMISSION  :

'9EFORE THE ATOMIC SAFETY AND LICENSING'BOARL In the matter of ) Docket Hos. 50-413

.DUEE POWER COMPANY, et al., 50-"'"

• 1 EC 14 P4:28 (Catawba Nuclear Station OML, t Units 2 & 1) w 4 ,4 eg

. u !. unk u EW;CH Q AFFIRMATION OF SERVICE I hereby affirm that copies of " Contentions of the Charoltte-Mecklenburg Environmental Coaltion" in the above captioned s proceeding have been served on the following in the U.S. Mail, first class, this 9th day of December 1981.

• James L. Kelley, E5 airman Michael McGarry, III. Esq.

Atomic Safety and Licensing Board Panel Decevoise and Liberman U.S. Nuclear Regulatory Commissi.on 1200 17th Street, N.W.

Washington, D. C. 20556 Washington, D. C. 20036 Dr. Dixon Callihan Robert Guild, Esq.

Union Carbide Corporation Attorney for the Palmetto Alliance P.O. Box'Y 314 Pall Mall Oak Ridge, Tennessee 37830' Columbia, South Carolina 29201

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Dr. Richard F. Foster Palmetto Alliance

. P.O. Box 4263 213513 Devine Street Sunriver, Oregon 97701 Columbia, South Carolina 29205 Richard P. Wilson, Esq.

• Atomic Safety & Licensing Board Panel Assistant Attorney General U.S. Nuclear Regualtory Commission 2600 Bull Street Washington, D. C. 20555 Columbia, South Carolina 29201

• Docket and Service Section

• Atomic Safety & Licensing Appeal Panel U.S. Nuclear Regulatory Commission U.S. Nuclear Regualtory Commission Washington, D. C. 20555 Washington, D. C. 20555 William L. Forter, Esq. Jesse L. Riley Albert V. Carr, Esq.

Duke Power Company Carolina Environmental Study Group PO Box 33189 854 Henley Place Charlotte, NC ' 28242 Charlotte, t orth Carolina 28207

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Henry Prpsler for CHEC