ML19031A233

List of Reasons Opposing Operating License for Salem Unit 2

ML19031A233
Person / Time
Site:	Salem
Issue date:	01/18/1979
From:	Zitzer P Committee for Application of Nuremberg Principles to U.S. Nuclear Power Production
To:	Igne E Advisory Committee on Reactor Safeguards
References
Download: ML19031A233 (9)

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• Committee for pplication of Nuremberg Principles to U.S. Nuclear Power Production CHAIRMAN Bi 11 Garner, Esq.

Scottsboro. AL MEMBERS Mr. Elipidio G. Igne Dr. John W. Gofman A1visory Committee on Re~ctor San Francisco, CA Dr. Chauncey Kepford Nuclear' Reg 1 1l,q,~.o'.'y Comr.ission State College, PA Wqshington; ~.c. 20555 Dr. Bruce von Zellen DeKalb, IL Re; Operatin~ License for Salem lJ :i ~. :2 0 Dr. Judith Johnsurd State College, PA J:=m. 24, 1979 Sidney J. Goodman. PE f'. atnrnus, NI De"'r :*Ir. Igne:

Helen Mills Atlanta, GA Marilyn Shineflug He strorn;ly OTJpose <;he issuance of qn op~~1"=:.t i.:L; l 1cense DeKalb, IL for Sslen Cnit 2 for the followin~ reqs~ns:

Larry Bogart Allendale, NJ Virginia Southard

1) We arP in e,greement *:iith Jr. Kepford' s s!.>1!;~,:n *c, to Harrisburg, PA Dr .. Greenwocd, Of fie~~ of Scie:nc;e & 'rechnc,10.=1;y Fnliey 7 Anna Mayo Execut.ive Oftice of t.he President. 11 *11 he rcijw,:t~:;t.:* prr,L*l.""1:1 is New York, NY a prod.uction problem. Human action alone oroci_;,ced Phillis Zitzer Salford, PA r"l.dioactive waste; h~:man :w::;ion A.lDne c::n1 h~'lll . t:he prc-

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T~ " P ... s " See enclosed lett*:.:r).

2) *rne applic,,,,nt h,qs ~lre=v:ly re*:_ues:-.ecl perrnis~?ioi-1 for i:r:-

crer.tsecl spent nucle:1.r fy:l rod stor**.-:e on ~.~1e. S*ile'.Tl site. Hope creek r *,n'.1 II '-1.re nn t.h::: s-*~mc: si*:..:

g,pnroxima::-.~:1:-r 10;';; i~1t.o cons*~ructior1.

3) The inability to dL:;:!O'-'e of exis~:iq~ W"l.~;f:r-~s, *is evidf~'J: **:l in the recent I.R.G. re~Jor::-, ::1";.l-ct;s it imp"'r~1.~~*1i-~ t*v-* 1: ;*~"*

"limit the: problemn new by f'.J:"":**:cing Lhc f:n*t.fier t1:;e ,~c nucleqr reac:tors until :Ct!ld imL~::;s p;:-~rr1'l:!e~1t :.*r=*,.;:;"-:e 'iir>-

r;os::;l f0r *_;~:P f*;ll pi:riocl of t.oxL~i:.y h,1s b 'en :1er='nn-sr~rqted tr..: *1;0rk.

4) Le;dslqtion introcln(':ec~ o!1 J~.:n. 16,1979 by u.,**w Jer(::'.::y ler~isl:::1tors wo'..i.ld pr:~lfent 8.ny n~1cle;:;r 1:il*-m'.-, n-Jt y::t operati~1p; from sta.rtin::.r, up un-.:.il '.~he ri:..1c..:le::;_r \'n.ste dispo~::n.l prc;ble:n is solved. *l'nis bill wo*,ld 'lr'fect SRlem 2 qnd Hooe Creek 1 ~nd 2 ( see enclosed ar~icl *)

I':..1is sho .;tl::l incHc;:J..te strong public opnosi::. ion.

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5) Ther2~ is :i.n unusu.:-tl concentra::ion of nucleqr po:*1t:r pl,c:n .~-;

in ~hi~ 'a.Pe~'t~* undc-::r ;r::i,rious s~qges of construe ~-.i cm ::i.nd.

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7) See enclosed Individ*. 1.c.1.l .SiLe R:-3.tL1f: for Pe:=H~h 2o .:.c.r~,

Docket .50-277 April 1978 : 11 Leas:.* ss.f~; si >.? in £'.e:~L:r~ .L.

Poorest Ma~qgem~nt

• 11

8) See enclosed Ind.ivid:..lal Site E::i.tillf; for- S"-_lem I, ~Jocke;*; '-/)-

272 April, 1978: 11 The plant con~,rol .room i,1: :.s d~:si:,ned0 in-house- it is a disaster waitin< to ha.pnen."

9) The excess ~eneratin~ cqpacity OI,, ~c.~"

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of S"'.lem 2 is approachirn; 50;,6. There is no need for power.

10) Rqdon releases and associated he~lth effects resul~in~

from the onera~ion of s~lem 2 must be considered in terMs of the cosi benefit bal3nce. Docket 50-354 & 355 "Licensees' Answer to ~otion to Consolidate Proce*Jin~s to receive new evidPnce with regard to rqdon rele~ses qnd associated heal~h effects". M3y 9, 1978:

" It must be remembered th~t , at least for the Hope Cref:k and Peqch Bot tom proceedings, '.__.hp Appe:1 l Boar:1s have alreq,dy corJ.sidered. the :1'1estion of whether the cost-benefit baLmce for the f::1cility or unit in question tips or might tip in fqvor of ab~ndonment of Ghe facility, in li~h~ of the in:erim f'~el cycle. 11 In view of the above, is is evident th.~t public sentirr:-2nt run 8 counter to further licensing of r.uclear pow~r pl.qn"'.:s.

Cre~tion of more waste is morally indefensible. Involuntary exposure to d.qma.;sinsrRdi~.tion is iri viol3tion of civil ri~ht-.s, c;::i.usinr; heqlth effects (deaths) to ~he general popv.1-=i.tion, as t.horoiu;shly exposed in the Honicker vs. Hr::ndrie Petit i.on.

We see no re::i.::;on why r.:he le;r,:i.l pr inc i pl es of indi v id.q*1l rP-sponsibility est:tblL~hecl at*. the Nurembnrg l~rials sho*il:i no~ also apply to the Officiqls of ~he u.s.Govern~Rnt who bet.rq,y thP public trust qnd sqf~ty.

S incerely1 __

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Phyllis Zitzer Box 207 Salford, Pa. 18957 cc: Commissioners 215-287-7459 nenctrie Kennedy Br8.df ord Gilinski AheA.rn

e Committee for Application of e

Nuremberg Principles to U.S. Nuclear Power Production Route 4, Box 332

• Scottsboro, Alabama 35768 *Telephone 2 CHAIRMAN Bill Gamer, Esq.

Scottsboro, AL MEMBERS Dr. John W. Goiman San Francisco, CA Jr. Ted Greenwood Dr. Chauncey Kepford Office of Science and Technology Policy State College, PA Dr. Bruce von Zellen Executive Office of the President DeKalb, IL Washington, D.C. 20500 Dr. Judith ) ohnsurd State College, PA Sidney J. Goodman. PE P:ar~~us. NJ

Dear Dr. Greemrnod,

Helen Mills Atlanta, GA This letter contains a very brief summary of r:1y Marilyn Shineflug DeKalb, IL comments, observe.tions, and opinions concerning the "Subgi")Up Larry Bogart Heoort on Alternative Strate~ies for the Isolation of Nuclear Allendale, NJ Wa~tes, 11 .TID-28818. The reasons for this brief summary ar0 Virginia Southard due to the distressingly short comment period, the shortet*

Harrisburg, PA Anna Mayo period yet during which the Sub;s-rcnJ.p ::teport \'F.ts :1va.J. L.:.t.,-;_e, New York. NY and the volume of my notes on the report. These n0tes ~ill Phillis Zitzer be digested, transcribed, snd forewarded as soon as is Salford, PA possible.

Contrary to the assertion of the authors of the .Sub.~;1'()t1;1 Report (pap;e 16, first f 1 ~ll sePY.,ence), .I subnit that t11~r::an action alone will be the deter~lnin~ factor with ~eg~rd t~

the fate of radionuclides in any repository or other dump site. After qll, human action created the wastes, qnd has delayed for years the need for a solution to the problerne Human action alone now has crear:ed a climate of rnsh to d l.s-pose of them. Human action alone will determine t~A tim~,

place, medium, depth, method, ~ackaging, and soon, of r~dio active waste disposal. It must also be realized that it 1;i.\.ll also be ~1man action alone which will lead to cost-saving erosions of mar~ins of safety for whatever repository is chosen. Human action alone can ca.use the effectiveness of any or all of the barriers between any dispose*-1.-of rad*:ras:.e and the biosphere to be })arti.9.lly or f'.1lly defeated. All ('f the 11 grand;i.ose plans, promises of 11 tech:.-10logical s1wcess 11 ( :l. '~?),

pror;r.,.,mma::.ic success 11 ( p. !44), reliance on 11 re~***~iln.tory r~.'

qnirements11 (p. 45), and imitation informa~~ion (popularly referred to as nur.ibers dt;ri ved from risk asses srn.ent) in U18 end are self-deluding and self-defeating. In addition, s1u..:r1 management schenes are but compcments of a vicious shell-. *..'*ir:k~

desig;ned to keep atten~ion from bein?. oaid to ~.he onlv rele~ant questi~n, the*question of dir~tional sucuess~ can a repository be prepared ~o contai~ all radwastes nlqced in it for the duration Of the tOXl°C '""'- n~1.*1"od. Of thA~ ~*1 ::i. s t'; e* s ?. ..l r. see ::1 s anpropri::i.te to remind ~he *3. .1thors of the St~b,c;roup Report of 1

the old hospitql joke: The operHtion WRs a s~ccess, but the

_J

Committee for Application of Nuremberg Principles to U.S. Nuclear Power Production Route 4, Box 332

• Scottsboro, Alabama 35768 *Telephone 205/259-5770

1. AP i* K ¥Mttt1¥t'#2A#t¥ *MWP*il4WCU!?bffVAM1 2ff!lZ!A'?'

i i1iAA%4¥CSQ CHAIRMAN Bill Garner, Esq.

Scottsboro, AL MEMBERS Dr. John W. Gofman San Francisco, CA Datient die . d anyway. *~* *rne imp. l'icav1orrn

!or . -'- ::<,re rq--,.:.;-::i.s,.e Dr. Chauncey Kepford State College, PA ominous.It is no': what is said, pror::ised, calc'.11-~*' ~--* 1 1 *~;~:;t.i Dr. Bruce von Zellen mated, testified '.'.bn 1.it, liscensed, re,~*.J.lated, syste;"Tiatizej, DeKalb, IL l"i'lanaged, or fantasized that counts; all ths.t counts is . vh::..t Dr. Judith I ohnsurd State College, PA is actually done with the ~a~tes. This, in Gurn, is de :er-Sidney I. Goodman. PE mined by hunan action alone.

Paramus. NJ Helen Mills The real question of the possibility (or probability)

Atlanta, GA of durational success _goes comple~-,ely unans tTered in th1~ 1 Marilyn Shineflug DeKalb, IL Su_qgroup Report. *ro evade; this question and offer the p.9..t:ne-Larry Bogart tically feeble hope of but a few thousand years of ccmtaiYi-Allendale, NJ ment (p. 16, for instance) is just one of ~he many ~etreq~s Virginia Southard Harrisburg, PA from safety - and credibility - that so thorou;~r1ly per~nentes Anna Mayo this report. This attitude fSOes a long way toward. guar*:.1~t>..:(:"im~

New York. NY the report of the stupid bureaucratic blund'.::rs that cac.lsed Ph ill is Zitzer the irradiation of the entire world 1 s population throt1~h bomb Salford, PA testin~, with the subsequent tragedies: ~he uranium Miner~

deaths ~1e to lung cancer, the enhanced cancer rates qgon~

bomb blast observers (like Smokey), and. others. ?olic.v r;1u:~ t not be allowed to be a substit*1te for safe:~y ~:i.nd th~- durattonal success of any* radwaste repository, be it high-or J.ow-11.:vt:d, THU waste, or ~ill tailings.

I urgently request that you inform whoever it is iE this f:SOvernment that the public that was so easily (Ftnli ro1;7:ine1.y) hoodwinked and lied to in the past by the apolo~,.r;ist~:; for Lhe nuclear* industry has changed. *rhe pu.olic is increasin.~ly *.:i.m:

rapidly becoming aware of the n:i.tu.re of the re::iw:1.ste orobl.::'7!T:

and the cause of the problem: the r~.ciwaste problem i~:; a production problem. Human action alone prod.:Jces radio.:ic ti ve waste; human q~tion alone can halt the production of these wastes, I s~e*rio reason why the legal principles of indiviJ-ual responsibility established at the Nurei'.!burg trial::; shc'.1ld not also apply to the officials of the D.S. Government who.

betray the public trust and safety.

Yours sincerely, Dr. Chq,1mcey Kc pf o r>>:1 4J3 Orlando Ave.

State Colle~e, P~.

! 6E30*1

,I '

Addendum to Individual Site Ratings from the IE Employee survay on Evaluation of Licensees - April 1978 Docket No.: 50-272 Site: Sal em Answers to Question 17 (If a change to safety level occurred, please describe it briefly):*

• Relatively new plant. Still *has growing pains. Needs close attention (by IE) to assure appropriate improvements are made.

Power ascension testing revealed problems that were corrected by management, both in hardware and procedures.

Answers to Question 18 (Are there other things we should consider about the safety of this plant?):

/

The plant control room was designed in-house - it is a disaster wai.~ing to happen.

~*

In startup phase. Have had a number of problems. This can be due either to poor system or poor management or the 11 normal 11 failures when new systems are placed into service.

Design of controls with back-lighted pushbottons results in operator data assessment problems, especially when lights are burned out. Manage-ment is aware of problem and IE is following up.

New plant - recently completed full power testing' - plant still in ear1y operating phases.

__ j

~

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ATLANTIC

&: 2

• Sea.ford e Operating A Unde.,.

tLaurel ii& Construction Proposed

The hazards of nuclear power Tile Crm/('r for sc;el1L~l' Ill t/ll' P11/1/il: /nr,*ru:;( i!' ,/ ncmprot1t. ri1\-t'\t'f11; 1l ft':'{'l,1tt:l1 01p.u11/;1tion* t11:1t h:i.c.; /1r*c?'1 .,\.Ll!~iny ILH tlit> p.1 ....;t sh.: ye.us 111 .11t,'.1:' vt 1*11t*tp\1 policy.

c11vnut1t11ent;il p1otQctinr1. t1ml '.',1rious C(U1';u111er conc:c1n!-*. i..~,\t*N .1sl-.od .Ken IJ0.<'Sor19. w/10 works 011 CSP/"s µrojC'Ct 011 enmy_v. ro s11111m;m.:" tlla or9;111u:1tion*s views 011 nucle.ir power. Here is wh,1t he wrote.

The vocal and increasingly active opponents of the nation *s atomic energy programs in-variably base their opposition on the potential dangers inherent in t11e generation of power from nuclear fuels. Are they hypothesizing problems that are of the one-in-a-million-chance .

variety? Are their concerns more fantasy than fact?

A review of the safety record of domestic nuclear facilities during the past three decades reveals a history of worker deaths. plant accidents. acts of terrorism. and ot11er incredible mishaps. In tact almost every "one-in-a-million** occurrence has already occurred as well as a number of incidents whose probability was considered so statistically minute as to not be worth evaluating. ,

Whereas federal and industrial spokespersons have extolled the safety record of nuclear power. studies issued-but kept unpublicized-by the old Atomic Energy Commission. the Nuclear.Regulatory Commission. and other agencies document a f<?r different story. They report that in the previous 33 years. there have been over 10,000 disabling work injuries at domestic nuclear facilities including more than 300 fatalities. Hundreds of other workers are expected to die of radiation-induced cancers by 1990.

In the past seven years. there have been 1SO instances of threats *against nuclear instal-lations across the U.S. These have included three cases in which bombs were successfully planted on facility sites and several instances of arson in which major fire damage resulted.

On the average. NRG loses (or has had stolen) as much as 100 lb of uranium and 60 lb of plutonium every year-enough to make more than 10 atomic bombs.

"Acts of God" also have taken their toll. Lightning and cold weather have disabled plant safety/security systems. Gale force winds damaged AEC"s Amarillo. Tex .. fa-cility in 196i.

A tornado passed througl1 the site of a proposed plant in Dixon Springs. Tenn .. and another came within 10 miles of an operating reactor in Athens. Ala. Several reactors are built near or astride geological faults either known to be or suspected of being still active, including several that have experienced quakes this century. On at least two occasions. B-52 bombers have crashed within sight of nuclear facilities.

The power level of fissile systems has become uncontrollable an 26 occasions in the past three decades: that is, nuclear accidents either occurred or were just avoided. These include a core melldown at the first experimental breeder reactor in 1955 as well as a partial fuel meltdown of the Fermi I breeder near Detroit in 1966. The well-publicized 1975 Brown's Ferry fire started with a worker carelessly using a candle to test for air leaks; it ended with most of the plant's safety sy~tems rendered inoperable and more than $50 million in damages.

Thus. while nuclear supporters have glorified their industry in terms that have bordered on outright fabrication. serious mishaps have been occurring with frightening regularity.

There are alternatives. however. to continued exposure to such hazards. Nuclear power presently constitutes only 3 % of total domestic energy consumption. That is a contribution to the nation's energy budget which could be easily eliminated through simple conservation strategies or through the implementation of presently available and cost-comoetitive solar technologies. Moreover. numerous studies issued by the Energy ResP.arch & Development Administration and the Federal Energy Administration confirm that future energy needs that would otherwise be met with nuclear power can also be satisifed with consP.rvation. solar and wind technologies.

For these reasons. the U S. should immediatelv declare a moratorium on new reactor construction anrl begin a phaseout of all existing nuclear programs other than perhaps some research ef:orts.

Our experience with nuclear facilities has alrendy proven the truth of Murphy's Law: *'If anything can possibly go wrong. it will"; further test data are not needed. 0 1

One of a series of editorials on nu.clear power in °Chemic<>1 And 11 Engineering News

• Renrinted by permission c;f the 9ublishers.

The purpose of the £QALITTON FOR rIUCLEAR PO'*:-;;::::z PO'.O'.:I'PONEr.WN7' is to postpone the construction af nucJ e<tr faci;.iti.es in DeJ..aware until satisfactory answers have been pr'Jvided to a nwnber af questions, including:

1. Will radioactive material escape?

2. Has a solution been demonstr?.ted for disnosal of radioactive aste?

3. Has full insurRnce protection been provided?

4. Is there an adequa.te evacuation plan in case of *"-Ccident?

5. Are there adequate safeguards against theft and SB.bot age?

To accomplish this purpose, the COALITION focuses public attention on the dangers of nuclear technology, informs the pubJ.ic as to the availability of clean, safe and econor.i.icA.l energy "!lternatives, and takes non-violent, direct action to oppose policies which .ieopA.rdize the health and sA.fety of the enti_re human race.

JODT US IF YOU AGREE WITH OUR AIMS: CNPP 810 West 25th St.

Wilmington, DE 19802 Phone 652-2456

Addendu~o Indi vidu:il Site Ratings from the IE Employee survay on Evaluation of Licensees - April 1978 Docket No.: 50-277 Site: Peach Bottom Answers to Question 17 (If a change to safety level occurred, please describe it briefly);

(, Plant radiation levels have been increasing with time. Design and 1 staffing of plant appear to have not been capable of handling this

~ change. Management has been slow to take large step changes to correct l problems.

Back to back overhaul/upkeep periods for units 2 &3 appear to have produced a tired operating group prone to error.

Careless operations and poor maintenance.

Corrective action taken to repair core spray line cracks, feedwater spargers and nozzles and control rod drive return nozzle.

Licensee made significant effort to reduce routine radioactive release from reactor building vents through equipment repairs.

Answers to Question 18 (Are there other things we should consider about the safety of this plant?):

... \

See question 69 and 28.

( QA program not upgraded to current standards. Security not upgraded.

-. Many repeat items of noncompliance. Least safe site in Region Z!

--~~st ma!l~ell}e~~- -:::=-:.________ ==----

Qua 1i ty of people (i.e., technical educational level) that are operating a plant and the type of organizational structure they are placed in can have a significant impact on safety.

Higher number cf inspections due to proximity to regional office.

Recent management meeting with the President - e;~pect to determine by scheduled inspections in the next 30 days if significant improvements were made.

Pl ant management exhibits an appearance of attempting to contra1 N'.:.c 11 11 inspector access thru continual escort - general attitude appears to be one of compliance as required instead of an aggressive prosecution of management controls.

The problem with this plant is that it is a big BWR - by definition, they will have problems unless they have a good op. staff. PB does ...

Upgrading of requirements upon this licensee, particularly in cases of security and QA.

/ U *7'-,I

/ / 1' Legi,s'l~;tion ,may halt

$0/erf{"'jI reactor start

.~.;. t~'f~--~ f: ... ,.::~* . ..* .* . ~

. By.DAVID AUANER . . '.: ~lem*I; alr!!_~-~-~~rnJ!.Qri;~"-* .. *

• bill through l~gislature in time to stop

, .,. '.. ... :Sunbeam Staff . .~ me l:iilr,-sporisored uy Assemblyman * !he commercial operation of Salem II

. SALEM '-l"/i bill introduced Yesterday D?nald Stewart <D-3) and Donald scheduled for a mid-summer start-up'.,

~Jn 1he Assifflibly woUld prevent: any D1Fra~c.~co (~*22), would. not allo~

• He added that he thought the bill had a

• "i'tlrciear plant no~ yet operatimt.Jtq_~__;-' N.J. u111:ties to mclude costs m~urred m good chance of stopping the construction

. &tarilng up~ untii* the nuclear waste the maintenance. and operation. of a of Hope Creek I and II, if the goverri:----

a1sposal .problem,,is ~olved~*-. ,. . . . nuclear plant ~n their ~ase utility rates. menl fails to solve the waste problem.

. 'I'hts bill would ra1marently a¥fct . Stewart said yesterday that the bill's The bill's intention is not to slop r'he Salem II ~nd. Hope ~reek La,nd IL~*~' . _, :* :*sponsors would be aiming to push the . growlh of nuclear power, Stewart said,

• ---.-~ ..... :_;_~,~~~~£,.,.::.,~**;,;...:.,,,,t,:,c!.'.;,,,k,i:'~--~ solve bu1 10 force the federal government to UJe*ptoblem of ~rmanent storage.

of speiff fuel rOds and~other r~dloactive waste products. -

"We're not saying 'we want this; we wanl Iha~,' all we're saying is that somebody better come up with something,'.'. Stewart said.

Stewart added !hat he wanted to

• prevent South Jersey from becoming the "nuclear dumping ground of the nation." *

. Nuclear waste disposal js a con-troversial issue almost everywhere I here are nuclear plants. Several states

• Salem* 11

,. . <Continued from page 1)

• have passed legislation forbidding disposal on !heir land, and public firms hav~ not beell'. able lo reprocess the spent fuel ever since President Carter pul a moratorium on reprocessing probably speeded up work on this bill, shor!ly aflei: taking office.

SI ewart said, but it had been in the *.* Stewart srud he believed the solution works long before last week.. to nuclear waste was technologically But Stewart said he thought this bill feasible, and he hoped that the bill would would indi~tly help LAC':; effort to make iederal officials "put their money*

keep its money, by educating the where their mouth is."

legislators on hazards that go with its "I expect it lo gel the government millions. moving, II Stewart said.

"I think when we. talk abOut this, 75 *

• Stewart said ~e thought that "North percent of the legislators don't know Jersey media" would say that this bill what we're talking about," Stewart said. came as a direct result of Governor "This will help the, legislators realize Brendan Bryne's State of the State there are two sides to the story." message, in which he singled out Lower Public Service Electric and Gas Alloways Creek's multi-million dollar spokesman Edward Anderson said the gross receipts revenues as funds that ulilily* did not want lo comment on the should be used for urban aid.

bill at. such . an early stage 'of its The governor's remarks last week development.

<Continuea on Page 3)

But speaking generally, he warned I ha I any delay in the start-up of Salem II would cost consumers millions of dollars: '