ML020510040
| ML020510040 | |
| Person / Time | |
|---|---|
| Site: | Watts Bar, Sequoyah  |
| Issue date: | 02/02/2002 |
| From: | Honicker J - No Known Affiliation |
| To: | Atomic Safety and Licensing Board Panel |
| Byrdsong A | |
| References | |
| +adjud/ruledam200506, 50-327-OLA, 50-328-OLA, 50-390-OLA, ASLBP 02-796-01-OLA, RAS 3920 | |
| Download: ML020510040 (12) | |
Text
February 2, 2002 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD DOCKETED USNRC Tennessee Valley Authority February 15, 2002 (11:37AM)
Sequoyah Nuclear Plants Docket Nos.50-327 &50-328 Unit 1 & 2 OFFICE OF SECRETARY RULEMAKINGS AND Watts Bar Nuclear Plant Docket No.
50-390 ADJUDICATIONS STAFF Unit 1 (Combined)
JEANNINE HONICKER'S RESPONSE TO NRC STAFF'S ANSWER TO REQUEST FOR HEARING AND LEAVE TO INTERVENE The NRC Staff proposed that my petition for leave to intervene be denied because I live outside the 50 mile radius of either Sequoyah or Watts Bar Nuclear Plants, and according to page 11 lines 6 & 7, "did not provide any indication that she 'frequents the area' within a 50-mile radius of either facility."
Below are 5 examples of how I frequent the area.
I will be happy to provide witnesses or affidavits to so attest.
(1) I have been a frequent participant at TVA Board Meetings, held in Knoxville.
(2)
My son, Clifford, and his wife and three sons live in Knoxville.
My husband and I visit them. Our route takes us from LaGrange, Via 1-85 to Atlanta, then 1-75 to Chattanooga, the 1-59 to 1-40 east, then to Knoxville.
We are certainly within a 50 mile radius of Watts Bar and Sequoyah Nuclear Plants while we are on the highway nearing Chattanooga, and on 1-59 between Chatanooga and 1-40 and while we are in Knoxville, or in Pigeon Forge, where we shop, or in Gatlinburg, where we visit the tourist attractions.
(3)
Another son, Russell and his wife and son live in New York City.
To drive to their home from Ga. necessitates our travelling
-vEcY-37 7 sec/- 0A.
north thru Atlanta, Chattanooga, Knoxville, and then north on Highway 81.
We are within the 50 mile radius each and every time we drive to and from their home.
(4)
Our daughter, Jan, and her husband and two children live in West
- Chester, Pa.
We take the same route thru Chattanooga and Knoxville when we drive to and from their home and are thus within the 50 mile radius of Watts Bar and Sequoyah on both legs of the journey.
Our mailing address is LaGrange, Ga.,
but since both my husband and I are retired, we are certainly "On the Road Again" frequently.
One car has over 90,000 miles, and our newer car has over 20,000.
(5)
We own rental property in Nashville.
A direct route is 1-85 to Atlanta, 1-75 to Chattanooga, 1-24 to Nashville.
We go to Nashville to do repairs whenever necessary. While in Chattanooga, we generally eat at The Chattanooga Choo Choo, a local restaurant.
As you can clearly see, I do frequesnt the area within the 50 mile radius of Watts Bar and Sequoyah,,
and I hereby request that my petition to intervene be granted.
The NRC Staff also faulted me for not specifying how I would be personally harmed should TVA 's request for a licensing amendment be granted.
First of all, I object to the statement that because other people, "all or a very large class" of people would suffer the same damages, i.e.
be just as dead as I, I should not be allowed to intervene.
That is entirely unconstitutional and irrational.
Because others would also die would not make my death any less permanent.
For the record, however, I will give you examples of how allowing the production of nuclear weapons material, tritium, the hydrogen for all of the United States hydrogen bombs, weapons of mass destruction, will personally harm me.
(l) The food that I eat, not only in Chattanooga and Knoxville, but also probably in LaGrange and Nashville, because food is
shipped great distances from its
This will cause any number of life shortening diseases, and can be prevented only by NRC's denial of the proposed license amendment.
(2)
Since I am more aware of the dangers than many other people, I will suffer emotional stress, not suffered by ostridges with their heads in the sand.
I will be constantly fearful for the lives of my children three of whom, with their families, live upwind.
I am not attempting to intervene for them. The fear of the'danger this poses to them will affect me, and is a very real fear.
I know first hand the terror of leukemia.
Our daughter, Linda, who now lives in Texas was diagnosed with acute mylogenous leukemia when she 19 years old.
She had a bonemarrow transplant and is one of the few survivors.
Leukemia is one of the first recognized diseases attributable to radiation.
All three of my grandchildren in Knoxville will be drinking milk from cows that graze within 50 miles of the Watts Bar and Sequoyah plants. Possibly the others will also, as milk is also transported far from its originating dairy. Pasturization, evaporation and condensation do not remove the radionuclides but in some cases, as in evaporation and condensation actually concentrates them.
The Cow-Milk-Child pathway has been deemed the "Critical" Pathway to man.
(Hartsville Environmental Report) Hence, it is routine emissions that concern me as well as emissions during accident conditions.
(3)
Should there by a likely terrorist attact, which NRC is well aware of the probable targeting of nuclear plants, and which I allege will be 103 times more likely at Watts Bar and Sequoyah if they are allowed to produce material for nuclear bombs than at any of the other 102 purely civilian electricity producing reactors, I very well might be in the area.
If there happened to be a football game at the University
of Tennessee, with 100,000 or so fans, escaping would be impossible. Even without the added traffic, escaping the radioactive plumb would be doubtlful.
Radiation exposure in large quantities causes death in a
short time.
Smaller doses causes leukemia, cancer, and a host of other life shortening diseases.
Younger women risks giving birth to children with birth defects.
Some mutations might not show up for another generation or so.
It is the damage to the gene pool that puts future generations at risks, as well as the risks of inciting a nuclear war because of our disreguard for the nuclear non-proliferation treaty where we pledged to reduce to zero our nuclear stockpile.
Using our electricy producing reactors to produce tritium to replinish our weapons while absolutly banning the practice by other nations will certainly fan the flames of the cold war and may very likely rekindle the arms race.
This is not in the best interest of National Security.
It is precisely because they will be "military targets" as bomb material manufacturing plants, that take Watts Bar amd Sequoyah out of the category of all other nuclear plants and refines the issue of a terrorist attack in a fully fuelled airliner to a site specific issue instead of a generic one.
Thus this issue is clearly contentionable at this hearing.
How can anyone logically question the validity of the statement that Watts Bar and Sequayah, if allowed to cogenerate tritium to refurbish all of the nuclear bombs in the U.
S. arsenal, will be more attractive targets than nuclear plants that only provide electricity?
I will be glad to bring in any number of expert witnesses to substantuate this contention.
This is a timely issue and the most important threat that the prduction of tritium at Watts Bar and Sequoyah poses.
NRC is charged with protecting the public health and protecting National Security.
To deny this contention because of a regulation written and enforced by NRC is worse than Arthur Anderson advising Enron and then auditing them.
NRC has the discretion to allow any intervenor it wishes and any contention
they choose.
If the NRC is helpless to do anything but rubber stamp TVA and DOE's request, then they are not a regualtory agency, as their name implies, but a lap dog of the nuclear industry, a waste of taxpayers money, and should be defunded and deauthorized by Congress.
In case of such an attack, or any other catastrophic accident, which can no longer be denied as too improbable to be considered since the Chernobyl accident, I will either (a) be killed, or (b) be trapped in traffic and not be able to escape.
The fact that others will likewise be harmed or killed should in no way hinder my ability to object or to be denied intervenor status.
The remedy for this harm is for NRC to deny TVA's requested license amendment.
If NRC rules that I can assist them in developing a record, they may simply grant me discretionary intervenor status.
The NRC staff's answer to my request to intervene on page 13, 5 lines from the end of text, not counting the footnote, says "she appears to have stated at least one or more aspects within the scope of the proceedings, e.g., appropriate exposure pathway and dose calculation assumptions."
I will give you further information about my history that will help you determine that my participation will indeed help NRC not only establish a record, but come to the correct decission to deny TVA's request for a licensing amendment for Watts Bar and Sequoyah nuclear plants For the past 28 years I have participated in TVA Board Meetings, the Hartsville Construction Licence Hearing, where I was an intervenor, and numerous TVA,
- DOE, and NRC conferences.
I was also a participant in the late 70's at the University of Oklahoma's Conference on World Affairs.
TVA pointed out in their response to my petition, that I was denied intervenor status at the Operating Licence stage of the Watts Bar Plant.
Since I was the only one who petitioned to intervene, there was no hearing.
TVA requested the license to operate Watts Barr in 1976 or 1977.
The TVA lawyers argued at the prehearing conference that to allow my petition and to grant a hearing would only serve to delay the licensing of Watts Bar.
I countered that my intention was not to delay the operation of the plant, but to stop it all together.
NRC subsequently did not immediately grant the operating license and the plant did not go on line for about 20 years.
I seriously question if the hearing would have lasted more than 18 years; therefore, granting a hearing would not have delayed the start up of the facility.
Had I not petitioned to intervene, would NRC have granted TVA's request for an operating licence for two reactors, units 1 and 2 at Watts Bar in 1977?
Without public opposition, has NRC ever denied a licence request from any utility?
Although TVA lawyers opposed my petition to intervene at the Watts Bar operating licence hearing, and there was no hearing, David Freeman, Chairman of the TVA Board, heard my concerns.
He created the Nuclear Safety Review Team, a group of 37 engineers and charged them with the task of going to every TVA nuclear plant under construction.
They reported back to him the many problems the employees had identified.
TVA then hired a special company to interview all employee who wished to put on the record their personal knowledge of problems at the plants.
All employees were PROMISED complete confidentiality to speak freely and voice their safety concerns.
Construction was halted for 10 years. Unit 2 was never completed.
After David Freeman's term as TVA Chairman and later board member expired, those promises of anonimity were broken.
TVA retaliated by "reducing in force" (firing) the "troublemakers" who had dared complain that the welds were painted over before they were inspected, and many other real safety concerns.
Since 1974 I have been a public citizen, concerned for the public
safety, not just my own, but for the wellfare of mankind.
My particular interest has been TVA's nuclear program.
Dr. John Gofman, in his book "Poisoned Power",
introduced me to the dangers of nuclear power plants.
Is 32,500 additional deaths a year too high a price to pay for electricity?
That, according to Dr.
Gofman would be the price we would have to pay if everyone received as much radiation as nuclear power plants were allowed to emit in "routine" operation. There would be 32,500 additional cancer and leukemia deaths per year, half from leukemia and half from other forms of cancer.
Our oldest daughter, Linda, had spent a year in the most excruiating pain I had ever witnessed.
Nine other recipiants of bone marrow transplants at the Adult Leukemia Center in Seattle where Linda had received her transplant in 1973 had not survived.
For other children to have to suffer as Linda had and to die as the other nine had, was just too high a price to pay for electricity.
When NRC's predecessor announced hearings for a construction permit for TVA to build the world's largest nuclear plant on the source of Nashville's drinking water, 37 air miles from Nashville, I joined 30 other Concerned Citizens and intervened.
A hearing that was estimated to take two weeks drug on for four years.
Instead of installino the best available technology, hepa filters, on the turbine buildings and the reactor buildings, which would have captured 90% of the radioactive pollutants that were expected to be routinely released thru the ventilation systems of those buildings, TVA recalculated the dose. Using the old calculation method, 1.42, TVA had projected a dose of 335 mrems to a one year old child drinking milk from a cow that grazed near the Hartsville Nuclear Plant.
TVA estimated the cost of the filters over the 40 year operating life of the facility would be $6 million.
To avoid putting on this best available technology to actually protect the public, TVA changed the calculation method, and reduced the dose on paper.
I believed that the NRC or whatever
alphabet soup the agency was then named, would protect the public health and force TVA to install those filters.
My faith was misguided.
The NRC, or its predecessor, abolished the old calculation method and further reduced the calculated dose down to 1.1 mrems.
This had significance for other plants as well, because Hartsville was billed as the first "standardized" reactor".
After the design was approved at the Hartsville hearing, the same reactor could be built on any other site with out a challange to the design being allowed.
- Thus, it is vitally important to examine the calculation methods used today to project the expected doses to the public and the workers, who are also members of the public.
Using the same calculation method developed during the Hartsville Hearing underestimates the dose by a factor of 300 or more compared to the calculated dose using guideline 1.42.
In the Sequoyah Operating License, NRC told TVA to either replace or repair the reactor vessel closure head (the top of the reactor vessel) because of a crack discovered in Weld WO 9-10.
TVA said that that was impractical.
They said that they would calculate the crack growth rate, and promised to inspect the faulty part at every refuelling outage.
If the crack growth rate exceeded their calculations, TVA promised to either:
(I) repair it, or (2) replace it, or (3) recalculate the crack growth rate.
At a TVA Board meeting several years after the Sequoyah plant had been operating, I asked if TVA had inspected Weld WO 9-10 as they had promised to do at each refueling outage.
Had the crack growth rate equalled or exceeded their calculations?
If so, had they replaced the top,repaired it,or recalculated the crack growth rate?
TVA could not or would not tell me if they had kept their word to NRC and ever inspected it, much less what the results of the inspections disclosed.
Has NRC ever checked to verify that TVA is inspecting the reactor vessel closure head at each and every refueling outing?
This is relevent to the current matter
before the board, because a failure of the reactor vessel head could cause an accident not previously considered. What would be its consequences?
The operating license for unit 1 at Sequoyah also revealed that the reactor vessel would be subject to briddleness fracture at its beltline after 9.2 years of operation.
That plant has been heated up and cooled down frequently, plus it has aged over the years.
Has an accident involving rupture of the reactor vessel caused by embrittlement been evaluated?
If not it should be evaluated, and the probability and consequenses considered at this amendment licensing hearing.
Watts Bar and Sequoyah are all Westinghouse Presurized Reactors with hydrogen igniters and ice condensor cooling systems.
Instead of a
- candle, which was used at Browns Ferry to detect air
- leaks, and nearly burned the whole plant down, TVA has gone high tech.
Hydrogen ignighters are spark plugs designed to purposely burn off hydrogen.
They were not designed for 2304 tritium producing burnable absorber rods.
How much more hydrogen will be released, and instead of a quick spark and a flicker, what kind of explosion will the hydrogen igniters cause?
Has this accident scenario been evaluated?
Will the ice buckets drop from the ceiling in case of a fire, and are ice condensors really the best available technology for 21st century nuclear reactors and weapons material cogenerators? Has NRC and TVA considered the probability that they will fail, and what the consequences of an accident with a failed fire protection system would be?
Since TVA abolished the National Electric Code from its design criteria (NRC inspection report) at the Watts Bar plant, will the electrical system be sufficient to withstand emergency conditions that may be caused by the inclusion of 2304 tritium producing burnable absorber rods?
TVA was aranted exemptions for some monitors at Sequoyah.
At Brown's Ferry, after the fire, documents in the public document room at Athens
Al. disclosed that there were higher radiation readings than expected.
TVA always had the same analysis. "The Monitors Malfunctioned."
Has NRC checked to see if TVA's monitors operate, or if they are non existant?
Have the monitors NRC exempted TVA from installing ever been installed?
Is the monitoring system adequate to detect increased radiation in the food chain and to prevent the consumption of contaminated food and milk?
Intevenors are granted the right of discovery.
The questions I intend to ask will certainly be different from any other intervenor you may qualify.
I hope that this letter has provided you with enough evidence to support a favorable rulling and grant my discretionary hearing petition.
The NRC staff recognizes, on page 13 or their response, that I have "stated at least one or more aspects within the scope of the proceeding, e.g., appropriate exposure pathway and dose calculation assumptions."
i respectfully request that you grant me either regular intervenor status or discretionary intervenor status. I sincerely hope that this response has provided you with sufficient information to so rule.
Respectfully submitted Jeannine Honicker 704 Camellia Dr.
- LaGrange, Ga.
30240 2-02-02
BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of Tennessee Valley Authority 50-327AND 50-328 (Sequoyah Nuclear Plant, Units 1 and 2)
(Watts Bar Nuclear Plant, Unit 1)
Docket Nos.
50-327 & 50-328 Docket No.
50-390 (Consolidated proceedings)
CERTIFICATE OF SERVICE I hereby certify that copies of Jeannine Honicker's response to NRC Staff's Answer to Requests for leave to intervene filed by Blue Ridge Environmental Defense League and Ms.
Jeannine Honicker in the above captioned consolidated proceedings have been served on the following by deposit in the Unived States
- mail, first class, on the day that I received it, Feburary 2, 2002.
Atomic Safety and Licensing Board Panel U.
S.
Nuclear Regulatory Commission Mail Stop: T-3F23 U.
S.
Nuclear Regulatory Commission Washington, DC 20555 Office of the Secretary Attn: Rulemakings and Adjudications Staff Mail Stop: T-3F23 U.
S.
Nuclear Regulatory Commission Washington DC 20555 Office of the Commission Mail Stop: 0-16CI U.
S.
Nuclear Regulatory Washington, DC 20555 Appelate Adjudication Commission Thomas S.
- Moore, Chairman Atomic Safety and Licensing Board U. s. Nuclear Regulatory Commission Washington, DC 20555-0001 Dr.
Peter S.
Lam Atomic Safety and Licensing Board U.
S.
Nuclear Regulatory Commission Washington, D. C. 20555-0001 Dr.
Thomas S.
Elleman Atomic Safety and Licensing Board
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U.
S.
Nuclear Regulatory Commission Washington, DC 20555-0001 Ann Pickel Harris We The People, Inc.Tennessee 341 Swing Loop Road
- Rockwood, Tn.
37854 Donald J.
Moniak Blue Ridge Environmental Defense League P.O. Box 3487
- Aiken, SC.
29802 Edward J.
Vigluicci, Esq.
Harriet A.
Cooper,Esq.
Tennessee Valley Authority 400 West Summit Hill Drive Knoxville, Tn.
37902-1499 David A.
- Repka, Esq.
Kathryn M. Sutton, Esq.
Winston & Strawn 1400 L.
Street, NW Washington, DC 20005 Jeannine Honicker 704 Camellia Dr.
- LaGrange, Ga.
30240 2/02/2002