ML18031A244

Comments on Des.Urges Denial of Ol.Facility Is Not Needed & Is Unsafe

ML18031A244
Person / Time
Site:	Susquehanna
Issue date:	08/20/1979
From:	Thompson F AFFILIATION NOT ASSIGNED
To:	Office of Nuclear Reactor Regulation
References
NUDOCS 7908270390
Download: ML18031A244 (3)

Text

REGULATORY NFORMATION DISTRIBUTION S" EM (RIOS)

ACCESSION NBR;7908270390 DOC CHOATE; 79/08/20 NOTARIZED'O DOCKET ¹ FACIL:50 387 Susquehanna Steam Electric Stationi Unit li Pennsylva 05000 87 50 388 Susquehanna Steam Electric Stationr Unit 2r Pennsylva 0

AUTHI NAME AUTHOR AFFILIATION THOMPSONrF ~

Affiliation Unknown REC IP, NAME RECIPIFNT AFFILIATION Division of Site Safety 8, Environmental Analysis SUBJECTj Comments on OKS.Urges denial of ol,Facility is not needed 8 is unsafe, DISTRIBUTION CODE!

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Director, Division of Site Safety and Znviroamenta3. Analysis Office of Nuclear Reactor Regulation U.S. Nuclem'egulatory Commission Viashington, ZC 20555 750 East Second Street Bloomsburg, PA 17815 20 August 1979 The following comments aoncern, the Dyaft Environmental Statement for PP&L's Susquehanna.

Steam KLectric Station, Units 1 an'd 5' urge the denial of'n operating License for the PP8cL nuclear power plant for the following reasons 1

Need a.- the projection of the PZM summer peak (Table 7')

shows a 6g$ increase:

the nationa1 average is, in actuality,,

slightly over 2g, a more reasonable pro)ection and one that decreases

need, pushing back the drop in reserve over summer peak.

b while needs of the PJM power grid. are a main reason iven for the need to build the PP&L nuclear power plant SS

3. & 2), those needs can be bypassed and PP8cL can sell direct to member. companies (eight, sales to GPU to replace TMI e1ectricity)

PP&I 's growth alone, with a generating capacity in excess of 41$ over peak demand (Table 7'),

does not show conclusive need for more generating capac-ity by 1981, especially if the strong conservation measures of the service area continue.

In fact, if the need were rea3.,

PP&L would be obliged to conduct a crash program to build a coal/solid waste/solar (or what-have-you) plant, since the nuclear p1ant may very well not be in operation by then.

c. the statement that "additional reserve capacity above 20$ may be desirable fox

a. system with units which are 3 arge in relation to system size (as will be the case with M the Susquehanna facility in service),"

(p 7-5) rather than showing the need for the plant, shows that the p3.ant, IKMlLMIIIIIIISI',I%7 RL< MN 2

Evaluation of the Proposed Action In reaching the conclusion that the nuclear power cycle is less harmful to man than the coal cycle, insufficient atten-tion was paid to the mounting evidence of the effects of low-level radiation; the unknown effects of radioactive waste dis-posal; and the reliability of evidence supplied almost entirely by the nuclear power industry.

Vihile measurable effects may, at present, point to the coal cTcle as more harmful, the ~oten-Cia1 for harm renders the nuclear c7cle the moze destructive+Q 0

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,2 5 ~ Benef it-Cost Analysis a.

The benefit of 11.0 - 12 9 billion KWh of electric power io the PJM interchange is based on

a. not necess-arily valid assumption of a plant capacity factor of 60-70$, when, in actu3c1ity, nuclear power plant per-formance averages less than 60$.

b. The addition of 1890 KH of generating capacity to the PJM interchange and 210 le to the cooperative is listed as a benefit when,, in reality, it might be construed as a cost since it may encourage additional electrical power users c

The "savings of'5 million (1980 $ ) in production costs ger unit per year can. be gallenged if total costs, includ-ing. government subsidies of the nuclear power industry~

are included In more concrete

terms, the "savings" would accrue only if radioactive waste disposal is not pro-rated into the costs, and if the plant operates at 60-70$ effi-ciency~ without accident, for,its pro)ected lifetime: there are no models that would lead to the belief that this will happen~

d The conclusion that there are no significant socioeco>>

nomic costs. to. be expected from, station operation does not give sufficent weight to the very real stress exper-ience6 since TMI by those living in a 20 mile radius of the plantthe constant feeling of living on the edge of a radioactive volcano will cost~'

. The economic casts are presented in absolute terms rather than as compared to not operating the plant.

Cal-culations fram sources other than the utilityhave not been taken fully into account:

Komanoff~ e.gi, prospects electricity generated from coal-fired plants as cheaper now than from nuclear->>and the difference will increase.

In summary, I urge the Nuclear. Regulatory Commission to deny an operating license to PP8cL for Susquehann Steam (Nuclear) Electric Station~ Units 1 and 2, because operating the nuclear plant will adversely affect me, as a PP8cL consumer, economicahly, environmen<<

tally and emotionally, and because, the. need for additional gener-ating capacity having diminished, there is enough "lead time to develop alternate energy sources (including the use of increased conservation and efficIency) to supply the electricity needed-in an economically, environmentally and emotionally acceptable

manner, Sine er ely, Florence Thompson (Ih's. L.F.)