ML18026A062

Petition for Intervention

ML18026A062
Person / Time
Site:	Susquehanna
Issue date:	01/26/2018
From:	Environmental Coalition on Nuclear Power
To:	Office of Nuclear Reactor Regulation
References
Download: ML18026A062 (8)

Text

UNITED STATES NUCLEAR REGUIA TORY COMMISSION Doc et No, 50-387 In the matter of Pennsylvania Power and LightCompany, et. al.

Susquehanna Nuclear Generating Station, Units I and II PETITION FOR INTERVENTION The Environmental Coalition on Nuclear Power, an unincorporated organization of individuals and groups of individuals, on behalf of its members do hereby petition the U.S. Nuclear Regulatory Commission for leave to intervene in this proceeding.

The authority for this request is granted in the Atomic Energy Act of 1954, as amended, Fart 2.714 of Title 10 of the Code of Federal Regulations, and decisions 73-1776, 73-1867, 74-1385, and 74-1(86 of the United Sta~es Court of Appeals for the District, of Columbia.

1.

The Environmental Coalition on Nuclear Power is a non-profit, public interest organization composed of individuals and groups of individuals who share a concern about the purpose, magnitude, and direction of the civilian nuclear power. program..'members of the Coalition live in the vicinity of Susquehanna, Units I and II. The names of the co-executive directors, the authorized representative of the Coalition before the Commission, and five members who live ~ithin approximately 20 miles of Susquehanna I and II listed below.

1.

Judith H. Johnsrud 433 Orlando Drive, State College, Pennsylvania 2.

George L. Boomsma R.D. 1, Peach Bottom, Pennsylvania

3.

Chauncy Kepford, Authorized 9epresentative before the Com~ssion 2576 Broad Street, York, Pennsylvania 4.

Irene Lemanowicz R.D,

Berwick, PA 18603 5.

Dorothy Endrizzi Box 76 R.D. 1, Sugarloaf, PA 18249 6.

Hazel Miles R.D 1,

Berwick, PA 18603 7.

John Fletcher 919 Roslyn Drive,

Berwick, PA 18603 8.

Carol Fraind R.D. 1,

Benirick, PA 18603 The members who live in the neignborhood of Susquehanna Units I and II feel that the operation of this facility poses an undue threat to their lives and material possessions.

Due to the recent decisions of the United States Court of Appeals~ Distr'ct of Columbia Circuit~ 73-1776, 73-l867~ 74-1385, and 74-1586, these

members, and the Coalition as a whole, feel the continued operation of Susquehanna I and II is illegal because the construction permit for the facility was issued without proper consideration of the "alternative" of energy conservation, with its effect on the cost-benefit

analysis, and without proper consideration of the vet unsolved, and possibly unsolva'ole problem of radioactive waste disposal.

This petitun is based on J

the contention that there are defects in the cost>>benefit analysis used by the Applicant to justify construction of Susquehanna Units I and II and approved by the Commission.

2.

The Petitioners (the Environmental Coalition on Nuclear Power and its members) contend that the cost-benefit analysis of the Applicant and the Commission is faulty because the recipients of the "costs" and "benefits" have not been properly identified.

It is claimed that the sale of electricity by the Applicant constitutes the primary benefit of the facility, with the custo-mers receiving the benefit and, therefore, being the beneficiaries of the plant.

C 5

No reading of a dictionary definition of either "benefit" or "beneficiary" can produce such a meaning as applied by the applicant or the Commission.

The true beneficiaries of a nuclear power plant are stockholders who receive profits (if any) due to the plant's operation.

Thus, the only true benefits from the operation of a nuclear power plant are the dividends paid out by a utility as a result of the operation of the power plant.

Furthermore, the "costs" are underestimated by the refusal of the Applicant and the Commission to determine the actual radiation doses delivered to real people from the entire fuel cycle.

3.

Petitioners contend that the stated costs of nuclear power by the Applicant and the Commission assume catastrophic accident-free operation o'of nuclear power plants.

Such an assumption is at odds with the revised con-clusions of "The Reactor Safety Study," MASH-1400, better known as the Rasmussen

Report, and with Section 170(b) of the Atomic Energy Act.

The U.S.

Congress, with the passage of the 1975 amendments to the Price-Anderson Act, has acknowledged that there may be more than one nuclear accidentr equiring payments under the Price-Anoerson Act in one year.

Cost-benefit analysis of nuclear power plants shoula i.nclude the costs of accidents.

4.

Petitioners contend that the cost-benefit analysis of the Applicant and the Commission assumes a virtually infinite supply of relatively low cost "yellow cake," or U308.

In reality, the United States is how grossly over-committed as far as the "known" and "estimated" reserves of the U308are concerned.

The fuel requirements for the 230 nuclear reactors

operable, being built, or planned (ERDA News Release, July 28, 1976), with a capacity of 237,000 MW(e) will require 1,159,000 tons of U308for their 30-year life-times at a 0.55 capacity factor.

The total estimated reserves of U308 are 640 000 tons of mineable U308 ~

(ERDA News Release, April 2, 1976).

V I

0 Neither the Applicant nor the Commission has yet faced the problem of either very high U308 prices as 4100 to 41,000 per pound of U308 or a simple unavailability of U308.

Nor has the enormous environmental impact, net energy

cost, and dollar cost of mining low grade coals,

shales, granites, or even sea water for uranium been acknowledged by the Commission or the Applicant.

Petitioners contend that availability of fuel and energy and environmental costs of its extraction are an integral part of the nuclear fuel cycle and therefore must be included in a full and proper cost-benefit analysis of this reactor.

5.

The Petitioners contend that the rate structure of the Applicant is a promotional rate structure designed to increase the consumption of electricity by offering declining rates for increased consumption.

Such a rate structure minimizes the possibility and practicality of worthwhile energy conservation efforts.

Petitioners contend that a flat rate structure one price for all levels of consumption and for all customers or a declining block rate structure would make conservation a viable and practical alternative to R

Susquehanna Nuclear Generating Station, Units I and II.

6.

The Petitioners contend that the Commission has been totally negligent in its handling of tne problem of l adioactive wastes in the granting of a con-struction permit for Susquehanna I and II, As a result, it has been impossible to determine accuse ately the costs of electricity generated by nuclear plants because the costs of solidification of spent fuel reprocessing waste solutions and storage of solidified wastes were ignored or grossly underestimated.

Estimates of the costs of solidifying and disposing of wastes from the Nuclear Fuel Services range from a low of 867,000 per year per 1000 HN(e) plant to $36~000,000 per year per 1000 MH(e) plant.

(See "Alternative Processes for iManaging Existing Commercial High-Level Radioactive Wastes,"

NUREG-0043 While the $67,000 figure may represent an insignificant addition to the annual

reactor operation costs, the $36,000,000 could easily double the annual operating costs.

If past experience for estimating costs by the AEC/NRC can serve as a guide, the high figure may prove to be the low.

Such costs should be included in the cost-benefit analys's.

7 ~

Petitioners contend that the cost-benefit analysis of Susquehanna I, II has been biased in favor of nuclear power by greatly underestimating spent fuel reprocessing costs and by the Commission offering a credit for recovered plutonium.

Since there has not yet been any successful~

economical, and com-piete reprocessing of reactor wastes to the solid stage, costs must be largely unknown.

Since the recycling of plutonium is not presently a commercial reality, the offering of a plutonium credit for yet unrecovered plutonium which may not be recycled is premature.

8.

Petitioners therefore contend that, due to the above unresolved issues regarding compliance with Sec. 102 of the National Environmental Policy Act by the Commission, the construction permit for Susquehanna, Units I and II should be rescinded immediately, and construction halted pending resumption of public hearings and resolution of these matters.

9.

Petitioners further request the Commission to grant financial assistance to the intervenors under the authority of Sec. 102 of the National environmental Policy Act.

Petitioners have made similar requests in the past, and have met with only denial or delay.

Petitioners call the attention of the Commission to the recent court decision, York Committee for a Safe Environ-ment, et al., vs. Nuclear regulatory Commission, No. 74-1923, and the comments therein regarding public interest litigants.

Petitioners request the amount necessary>- in ".order to meet legal, technical, and procedural expenses otherwise not available.