UNITED STATES OF AMERICANUCLEAR REGULATORY COMMISSIONBEFORE THE SECRETARY OF THE COMMISSIONIn the Matter of: ))Union Electric Co. ) Docket No. 50-483-LR)(Callaway Plant Unit 1) )
MISSOURI COALTION FOR THE ENVIRONMENT’S HEARING REQUESTAND PETITION TO INTERVENEIN LICENSE RENEWAL PROCEEDINGFOR CALLAWAY NUCLEAR POWER PLANTI. INTRODUCTION
In accordance with the U.S. Nuclear Regulatory Commission’s (“NRC’s”) hearingnotice, 77 Fed. Reg. 11,173 (Feb. 24, 2012), and pursuant to 10 CFR 2.309(f), MissouriCoalition for the Environment (“MCE”) files this Request for Hearing and Petition to Intervenein the license renewal proceeding for the Callaway nuclear power plant (“Callaway.”) Asdiscussed below, MCE contends that the Environmental Report submitted by Union Electric Co.d/b/a Ameren Corp. (hereinafter “Ameren”) is inadequate to satisfy the National EnvironmentalPolicy Act (“NEPA”) and the U.S. Nuclear Regulatory Commission’s (“NRC’s”) implementingregulations.
II. DEMONSTRATION OF STANDING
MCE is the State of Missouri’s independent citizens’ environmental organization forclean water, clean air, clean energy, and a healthy environment. MCE works to protect andrestore the environment through public education, public engagement, and legal action.
Seehttp://www.moenviron.org/about/who-we-are/ .
MCE seeks a hearing on the proposed re-licensing of the Callaway nuclear power plant in order to protect its members’ interest in a clean
2and healthy environment, including the elimination or mitigation of the hazards posed by theoperation of the Callaway nuclear power plant.MCE has standing to intervene in this case because many of its members live, work, andown property within 50 miles of the Callaway reactor, and their interests may be affected by theresults of the proceeding.
Virginia Electric and Power Co.
(North Anna Nuclear Power Station,Units 2 and 2), ALAB-522, 9 NRC 54, 56 (1979). Their health, safety, property value, andmeans of livelihood could be adversely affected if the NRC permits Callaway to continue tooperate for an extended period in a manner that is unsafe or harmful to the environment. Forinstance, if an accident and consequent offsite radiation release were to occur at Callaway, thehealth, safety, property value, and means of livelihood of neighbors of the plant, includingmembers of MCE, could be seriously harmed. MCE has attached declarations from individualMCE members who have authorized it to bring this legal action on their behalves.
See
Declarations of Ruth L. Schaefer (Exhibit 1A), Mary E. Mosley (Exhibit 1B), Mark Haim(Exhibit 1C), Carla T. Klein (Exhibit 1D), and Patrick J. Wilson (Exhibit 1E).
III. CONTENTIONSContention 1: Environmental Report Lacks Information Regarding ProposedModifications to Callaway Facility1. Statement of the Contention:
The Environmental Report fails to satisfy 10 C.F.R.§ 51.53(c)(2) because it does not include information about Ameren’s plans to modify theCallaway facility in response to post-Fukushma enforcement order EA-12-049 (March 12, 2012),Order Modifying Licenses With Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Effective Immediately) (“Order EA-12-049”) (ML12056A045).As also required by 10 C.F.R. § 51.53(c)(2), the Environmental Report must include a discussion
3of a reasonable array of alternative measures for modifying the facility in accordance with OrderEA-12-049.
2. Brief Summary of Basis for the Contention:
This contention seeks compliancewith 10 C.F.R. § 51.53(c)(2)’s requirement that an environmental report must contain “adescription of the proposed action, including the applicant’s plans to modify the facility or itsadministrative control procedures as described in accordance with § 54.21 of this chapter.”Modifications “directly affecting the environment or affecting plant effluents that affect theenvironment” must be described “in detail.” The contention also seeks compliance with 10C.F.R. § 51.53(c)(2)’s requirement for the discussion of a reasonable range of alternatives.On March 12, 2012, the NRC issued Order EA-12-049, requiring Ameren and otherreactor licensees to: “develop, implement and maintain guidance and strategies to restore ormaintain core cooling, containment, and SFP [spent fuel pool] cooling capabilities in the event of a beyond-design-basis external event.” As the Order explains, although the NRC believes thatcontinued operation and licensing of reactors do not pose an “imminent threat to public healthand safety,” it has acquired “new insights from the events at Fukushima Dai-ichi” leading it toconclude that “additional requirements must be imposed on Licensees or CP holders to increasethe capability of nuclear power plants to mitigate beyond-design-basis external events.”
Id.
at 3-4. The NRC considers these requirements essential for the protection of public health and safety.
Id.
at 4.The NRC anticipates that the “strategies and guidance developed by licensees such asAmeren in response to Order EA-12-049 “will provide the necessary capabilities to supplementthose of the permanently installed plant structures, systems, and components that could becomeunavailable following beyond-design-basis external events.”
Id.
at 6. The order instructs that
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