ML17340B248

Affidavit & Testimony of G Edwards Contentions 1 & 4b Re NUREG-0743,FES for Steam Generator Repair.Related Correspondence

ML17340B248
Person / Time
Site:	Turkey Point
Issue date:	05/18/1981
From:	Geoffrey Edwards CANADA
To:
Shared Package
ML17340B247	List: ML17340B246 ML17340B248
References
RTR-NUREG-0743, RTR-NUREG-743 ISSUANCES-SP, NUDOCS 8105260657
Download: ML17340B248 (12)

Text

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United States of America C':.-

Nuclear Regulatory Commission 8 BEFORE T11E ATOMIC SAFETY Ai<D LICENSING BOARD In the >latta:r of ) Docket Nos. 50-250

) 5V-261 FLORIDA POtKR AND LIG11T COMPANY ) (Proposed Amendments to Facility I ) Operating License to Permit (Turkey Point Nuclear Generating) Steam Generator Repair)

Unit Nos. 3 and 4) )

THE AFFIDAVIT AND TESTIMONY OF DR. GORDON EDWARDS CONTENTIONS 1 AND 4b I, Gordon Edwards, being duly sworn, state as follows:

My name is Dr. Gordon Edwards. I am an applied mathematician with seven years of professional experience in dealing with matters of public policy development in Canada. hy special interest is the use of mathematical modeling techniques as applied to such diverse problems as assessing the safety of nuclear power reactors, the health and environmental impacts resulting from radioactive releases, the acceptability of proposed storage and disposal methods for nuclear waste, and the economic advantages of various energy options.

'I received a B.SC. (Gold Hedal in mathematics and physics) the University of Toronto in 1961  ; IR.S. and M.A.(Woodrow Wilson Fellow in mathematics and English literature) from the University of Chicago in 1962- and 1964; and a Ph.D. in Mathematics from Queens University in 1972.

In 1973-74, I co-ordinated and co-authored a nation wide study of the role of the mathematical sciences.in Canadian Society ( business,, industry, government, science, and education) for the Science Council of Canada.

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In recent years, I have been retained as a technical consultant by numerous government bodies in Canada, 'including the Cluff Lake Board of Inquiry into Uranium Miningin Saskathewan (1977), The <<Ontario Royal Commission On Electric Power Planning (1976-1978), The Legislative Assembly of the Northwest Territories (1981), The Energy Committee of the New Brunswick Legislature (19?9), and The Select Committee on Ontario Hydro Affairs (1979-1980).

Among my publications is "A Monograph on Nuclear Mastes,"

prepared for The House of Commons Standing Committee on National Resources and Public Horks in 1978, "A Monograph on Radiation-Induced Lung Cancers," prepared for The United Steel Morkers of America in 1978 ( based on testimony which I gave at the Elliot Lake Environmental Assessment Hearings), and a series of short monographs on "Candu Reactor Safety" prepared for the Ontario Legislature from 1978-80.

I am currently a Professor of llathematics and Science at Vanier College in Montreal, as well as the Chairman for the Canadian Coalition for Nuclear Responsibility and adjunct Professor Science and Human Affairs at Concordia University.

My complete curriculum vitae is attatched.

OUTLINE OF TESTIMONY I have reviewed the Final Environmental Statement related to Steam Generator Re air at Turke Point UnitsNos. 3 and 4 (NUREG-0743, March 1981), and have found it to be deficient in several important respects. I am prepared to give testimony about the following points, in support of the contentions that have been submitted by Mark Oncavage..

~I I. HEALTH I1IPACTS

1. The calculation of health effects among workers and members of the general public is not conservative. A recent report from the British 'Columbia "1edical Association indicates that .the number of deaths and other adverse health effects resulting from the Turkey Point steam generator repair may be seriously underestimated because of inappropriate mathematical methods.

II. OFFSITE CONSE UENCES

2. Potential offsite consequences have been largely ignored. For example, the possibility of damage to or serious leakage from the drums of radioactively contaminated materials which will be stored outside during the repair is not even addressed. This damage and resultant leakage could result from either natural disasters (hurricane) or man made problems.

III. ULTIMATE DISPOSAL

3. Delayed environmental effects may occur as a result of inadequate storage or disposal of dangerous radioactive materials. The ultimate dis osition of the primary coolant, the lower assemblies hulks of the old steam generators, and other radioactive materials produced during the repair is inadequately discussed and vague.

IV. COSTS

4. Assessment of costs is overly simplistic. Among other things, no consideration is given to the possibility that the repair may be less than a complete success and that the denting problem may reoccur. Due to the large sums of money involved, this possibility deserves closer scrutinty.

V. ALTERNATIVES

5. Consideration of alternatives is incomplete and unimaginative. The option to delay repair for two or ttiree years to see if the Suury repair has been successful is not entertained. Honelectrical alternatives to obviate the need for 'replacing electrical power while derating the Turkey Point nuclear reactors are not considered.

CONCLUSION The final environmental statement fails to address some of the most important considerations of the environmental effects of the repair program, for the Turkey Point steam generators.

By not realistically assessiqg the potential health impacts, possible offsite consequences, ultimate disposal of radioactively contaminated materials, total costs of repair if not. perfectly successful, and realistic, cost effective nonelectrical alternatives, the Final Environmental Impact Statement has failed in its critical objective and should be redrafted. Detailed argumentation to support these points will be given during my testimony.

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't4AV 4 81981 BIOGRAPHICAL SKL'TCH Name: Gordon Edwards :larried: Karen Ro"ers...~..

Born: July 18,1940 Children: Three Boys Birthplace: Ontario ~I I >

Citizenship: Canadian J Education BS.C. in Mathematics and Physics, University of Toronto 1961 H.S. in Hathematics, University of Chicago 1962, H.A. in English Literature, University of Chicago 1964 Ph.D. in Mathematics, Queens University 1972.

Academic Awards Agnes Kelly Award in Hath and Physics Univ. o f Toronto Arthur M. Einglen Memorial Scholarship Univ. of Toronto College Gold Medal in Hathematics and Physics Univ. of Toronto Woodrow wilson Fellowship in Mathematics Univ. of Chicago College Scholarship in English Literature Univ. of Chicago Teaching Fellowship in Mathematics Univ. of Chicago National Research Council Fellowship queens University Canada Council Doctoral Fellowship Queens University Queen Elizabeth the Second Fellowship Queens University NRC Post Doctoral Fellowship Univ. Br itish Columbia (National Research Council)

Current Po s i%ion s Professor of Mathematics and Science, Vanier College, Montreal.

Adjunct Professor of Science and Human Affairs, Concordia Univ.

Chairman Canadian Coalition for Nuclear Responsibility.

Teachin Ex erience Mathematics  : University of Toronto, University of Chicago, University of Western Qntario,, Queens Univ.,

"university of British Columbia, Ottawa University and Vanier College Other University of %astern Ontario, Shakespear.

Concordia University, Chemistry in Society Biology and.Society, Environmental Issues.

Uanier College, Energy and Society.

Nonteachin L'm lo ee Inspector, Attorney General of Canada (Ontario) 1958-61.

Junior Actuary, Excelsior Life Insurance, 1964.

Assistant Director of Mathematics Study, Science Council Canadal973.

Science Advisor, Science Council of Canada 1974.

4 p Consultin Work

,Cluff Lake Board of Inquiry'Uranium -11inin-), 1977.

Royal Commission on Electric Power Planning, Ontario 1976-78.

United Steel Workers of America 1978.

Canadian Broadcasting Corp. 1977-78.

National Film Board of Canada 1978.

Select Committee on Ontario Hydro Affairs 1978-80.

Energy Committee of the New Brunswick Legislature 1978.

Legislative Assembly of the Northwest Territories 1981.

Publications An Introduction To Lie Al ebras, Queens University, 1970.

Lie Al ebra of -Infinitesimal Grou Schemes, (queens University,1972.

"Primitive Elements in Symetric Algebras," Canadian Journal of Hath.1975.

"Optimal Dynamics in Commercial Fisheries," Journal of Fisheries Research Board of Canada.

Mathematics in Toda 's Llorld: t1ath and Policy Planning Statistics and tl'>e Environment tiathematics and Technology Published by the Science Council of Canada,1974. Copies were deposited in every University Library in Canada.

translated into 5'rench,Russian and German.

It has been Back round Re ort,on Mathematics, Science Council of Canada,1976.

Nuclear Power: Fact and Fantas , -lianitoba Environmental Council,1975.

"Nuclear Power, A New Dimension in Politics," Alternatives Magazine, Trent University, 1976.

"Nuclear Wastes: What tie Worry?",.House of Connnons Standing Committee on National Resources and Public Works,1978.

"Estimating Lung Cancers," CCNR 1978.

"The Machine and the Ecosystem; a tletaphorical Framework,"

Summary Argument to the Royal. Commission on Electric Power Planning, 3.978.

"An Introduction to Candu Safety",CCNR, 1979 Television "The Great Debate with G. Edwards and Edward Teller," Global Television 1974.

"Quarterly Report; CBC Special on Energy," 1978.

"The Evolution of ".iathematical .Thought," a series of five half hour T.V. shows prepared for University of the Air, 1979,