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I. Analysis and Rulings on the Admissibility of Contentions1. Contention 8
Petitioners state in Contention 8:The COLA is inadequate because it fails to analyze fully the radiological hazardsthat will occur from operation of the STP Units 3 and 4 nuclear plants based ondischarge of water that contains radioactive particulates to the Main CoolingReservoir (MCR).
Contention 8 encompasses a wide range of topics related to alleged radioactive hazardsassociated with the planned operation of STP Units 3 and 4. First, Petitioners characterize theMCR as an unlicensed radioactive waste disposal facility that, upon receiving effluent from STPUnits 3 and 4, would cause the uncontrolled release of radioactive material.
Petitioners claimone of Applicant’s own reports
establishes that (1) “the MCR is contaminated by plant wastesthat, at a minimum, include tritium and cobalt-58 and cobalt-60;” (2) “most years the tritiumradioactivity in surface water exceeds 10,000 pCi/KG;” and (3) “[t]ritium is a pernicious problemfor STP” based on current monitoring for tritium discharges into the MCR from STP Units 1 and2.
Petitioners also claim the ER indicates that tritium has been detected in surface water, theMCR pressure relief wells, and the “shallow aquifer groundwater beneath and around theplants.”
One of Petitioners’ experts, Arjun Makhijani, Ph.D., has asserted that there are healthconcerns related to tritium exposure.
See Petition for Intervention and Request for Hearing (Apr. 21, 2009) at 32 [hereinafter Petition].
Id. at 33.
At various locations in their petition, Petitioners refer to this 2007 Annual EnvironmentalOperating Report as the “STP 2007 Environmental Operating Report,” the “2007 STPNOCRadiological Operating Report” and the “2007 STP Radiological Environmental OperatingReport.” The precise name of this report appears to be “STP 2007 Annual Operating Report for STP Units 1 and 2.”
Petition at 32 (citing STP 2007 Annual Operating Report for STP Units 1 and 2 at 6-7, 6-8,Figure 6-9).
Id. at 32-33 (citing ER p. 2.3.3-2 and 2.3.3-4).
Petition at 32 (citing Arjun Makhijani et. al., Nuclear Wastelands: A Global Guide to Nuclear Weapons Production and its Health Effects (1995) at 97).