ML19207A460

Opposes NRC Recommendation That Ulster County,Ny Be Allowed to Intervene on Discretionary Basis Limited to Alternate Site Issue.County Affected by TMI Radiation.Amends Petition to Intervene

ML19207A460
Person / Time
Site:	New Haven
Issue date:	05/11/1979
From:	Egemeier S KINGSTON, NY
To:	Wenner S Atomic Safety and Licensing Board Panel
References
NUDOCS 7908170639
Download: ML19207A460 (5)

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COUNTY OF ULSTER 244 FAIR STREET BOX 1800 @:., WSEa KINGSTON. NEW YORK 12401 FiiCD g gi% F E R d N D

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ENVIRONAIENTAL ofANAGE31ENT COUNCIL

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300 flJ! bush Avenue Annex (9143319300 Ext. 230 re,; 6 2 J .vC

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May 11, 1979 fj

• _.] 1 S e y..'o u r W e n n e r , Esq.

Chairman, Atomi c Safety & Licensing Board k! -y M j cs2 0 , ;p3 '

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U.S. flucl ea r Regul at ory Commission est/;

Washington, D.C. 20555  ;,- /

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Dear Mr. Wenner,

In light of recent s cienti fic reports , the Ul ster County Environmental fianagement Council is obliged not to concur with t h e f1R C S t a f f 's recommendation that it be allowed to intervene on a discretionary basis limited solely to the alternate site issue. The Council is chargcd with the maintainance of the quality of the environment of Ulster County. In light of new evidence related to the recent Three Mile Island incident, injury to the environment of Ulster County and the natural resources on which it's residents depend, and inj ury to the health of it's residents can result from a plant located at fl e w Haven.

The incident tr '. a t occurred at Three Mile Island as well as the past record of plant mal functions or accidents resulting in the release ci radio inotopes into the envi ronment establishes in our opinion the seeJ to consider such mal functions as envi ron-mental hazards that wi'l occur during the routine operation o f a nuclear facility. The Three Mile Island plant, located about 240 miles f r:m Al bany , flew Yo rk increased the backround level o f radiation the re, as recorded by t h e fl Y S Dept. o f Health.

In our opinion, this new evidence requires a change in the flRC's policy regarding a show of standing based on di s t an ce s averaging 50 miles. The Ulste r County line is located about 130 miles from flew Haven and therefore would definately be e f fe cte d in t h e e v e r: t of a plant malfunction at ?lew Haven.

This new evidence, in our opinion, establishes our ri gh t to intervene as a direct participant rather than be limited only to issues o f alternate siting in a discretionary way as set fo rt h in 10 CFR g2.714(f).

In accordance with the flRC's Rules o f Practice, 10 CFR $2.714(a)(3) the Ulster County EMC respect fully amends it's petition to intervene in the matter o f flew Haven 1 & 2, Docket nos. S T fl 50-595 and ST1 50-597.

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page 2 The EMC, mandated to advise the Ulster County Legislature on environmental matters ef fecting the county and to manage and protect the natural resources of Ulster County sees it's interest as being injured by:

a) operation of nuclear power plants located in New Haven NY.

b) the construction and operation o f nuclear power plants located at Stuyvesant, NY, the alternate site location.

c) the construction and operation of nuclear or coal-fi red plants at Gardiner, NY, the second alternate site.

d) the construction and operation of ancillary facilities (i . e . pumped storage f a cili ti es , 765KV lines) for any of the plant locations listed above.

There are no other means in the proceeding by which the EMC's interests are protected or will be represented by other parties.

The EMC is thoroughly acquainted with the quality o f the natural resources of Ulster County and the quality levels that need to be maintained in the interests of Ulster County residents. The EMC is also acquainted with the deterioration of natural resources caused by radio isotope polluti on. More speci fically the EMC is o f ficially required to comment on the envi ronmental impact of Drojects as they will effect the natural resources o f the county.

This expertise would help in developing a sound record in the proceeding. The siting and licensing procedure must take into consideration all envi ronmen tal e f fects of the project. The EMC would speci fically address the topi c of envi ronmental impact o f '.h e p roj e ct , making it a valuable party in the proceeding.

Also, as an agency of county government, the EMC wishes to maintain it's right to intervene under 10 CFR 2.715(c). Since our right to intervene under 10 CFR 52.714 as well as the admissibility of our contentions as stated below has not as yet been ruled on, the ri g h t for a reasonable opportunity to participate and to introduce evidence, interrogate witnesses and advise the Commission must be guaranteed, i f we are to discharge our chartered obligations to Ul cer County.

In accordance with 10 CFR 2.714(b) the EMC herewith submits a supplement to its petition to intervene, including a list of contentions it seeks to have litigated in the matter and the bases for these contentions . ,

The impact of the proposed nuclear plants as sited in Dockets nos. 50-596 and 50-597, New Haven 1 & 2, located at New Haven, New York on the envi ronment and health of the residents of Ulster County is potentially large.

The bases o f this contention are: In the event of a plant malfunction leading to the escape of radio isotopes into the environmeit, or in the event of a nuclear meltdown, the impact on the en vi ronmen t of Ulster County and the residents o f Ul ster County would be damaging. The present record a f plant mal f uncti ons

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-N page 3 is evidence enough that this must be taken into consi deration when reviewing the environmental hazards of the operation of a nuclear facility. The Office of Radiological Health of the New York State Department of Health has reported a detectable increase in backround levels of radio isotopes in sample taken in Albsny after the Three Mile Island in cident. Albany is 240 miles from Three Mile Island. Ulster County is only 130 miles from New Haven. Also, although the health hazards of low level radiation are already documented, scientists and doctors are becoming even more concerned about the seriousness of the health effects of low level radiation. A plant malfunction would increase the backround levels of radiation in Ulster County s i gni fi cantly.

The impact of the alternate site of the plants at Stuyvesant, New Yo rk or Ga rdiner, New York on the health and environment of Ulster County and it's residents is potentially great. There are several bases for this contention. Ulster County residents would be subj ected to increases in backro und radi ation levels, a serious and undesirable health hazard. In the event of a plant malfunction the health effects or such releases as might be expected would severely undermine the health of residents of Ulster County. The natural resources of Ulster County would be contamin-ated, possibly beyond use, effecting not only the local population, but many others as well. The major water source for New York City, the Ashokan Reservoir, is located in Ulster County.

Agricultural products and lands would also be e f fected, disrupt-ing the economy o f the county as we'l .

Normal operation of the plant located either at Stuyvesant or Gardiner is potentially disruptive to the climate of the Hudson River Valley. Cooling towers release vast amounts of water vapor into the atmosphere, causing serious side e f fect s . Increased numidity, decreased sunlight caused by arti ficial cloud and fog formatio 9, and area temperature changes would cause serious problems for the fruit and corn g rowe rs in Ulster County.

Agriculture is the county's economic mainstay; the problems our fruit and corn growers would encounter could damage agri-cultural production considerably. Among the problams cooling towers could cause for growers are: a) decreased productivity due to decreases in photosynthetic processes caused by dereased sunlight, b) increased pest activity and fungus growth due to the more humio climate, c) possible damage to the fruit crop due to temperature modi fications . The dai ryin g industry, an important component o f agri culture in the region could be damaged by the increased backround levels that will result from normal plant operations. Da i ry products which concentrate levels o f radio isotopes may ccntribute to the health hazards al ready e f fectin g residents. A plant mal function woul d lead to contaminated milk products.

The cooling towers can also actually produce snowstorms. A rt i fi ci a l precipitation in the form of snow and the wetting and icing o f

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page 4 d-road ways can make oriving conditions hazardous. This would e f fect not only local roads, but also the NYS Thruway, close to both the Stuyvesant and Gardiner sites.

The Hudson River is contaminated with polychlorinated-biphenols (PCB's) which would be dispersed into the atmosphere by the plant's cooling towers. The New Haven plant, located on Lake Ontario would not affect it's environment in this way.

The large amounts of water requi red for cooling the reactors would be taken from the Hudson River, signi fi cantly e f fectin g the depth and location of the salt wedge and thus jeopardizing community water supplies .

The Hudson River is an estuary, a delicately balanced network of ecosystems and a natural resource of considerable value and importance to New York State economically. The disr;pticn of the ecosystems by the operation of a power plant located at either Gardiner or Stuyvesant causing an increas e in ambi ent water temperature, adding mo re chemi cal pollutants to the al ready seriously st ressed ecosystems and dis rupting the flow o f the Hudson and consequent shift of the salt wedge would damage the estuary considerably.

The plant site at Gardiner is several ciles from the Hudson River.

This would require signi ficant uphill pumping o f required cooling water from the Hudson with consequent energy loss. The geology o f the tunnel area from the Hudson to the Gardiner site is not well known. It would have to be carefully studied to insure the integrity o f the tunnels that must supply cooling water at all times.

The geology o f the Stuyvesant site is also not well known and ve ry little is known about the geology o f the Hudson River bed at the Stuyvesant location. This needs to be ca re fully s t udi ed to see what effects it might have on design o f the site.

The transportation of fuel requirements to the plants at either Stuyvesant or Gardiner and the transportation of radioactive wastes from the plants is a sa fety hazard to Ulster County residents, especially in the Gardiner location where narrow, back roads would have to be used.

The environmental impact of construction at Gardiner would be great. An analysis of the Environmental Impact Statement by the EMC would be requi red to s peci fically add res s our very local en vi ronment al co n ce rn s .

Construction at either Stuyvesant or Gardiner would require la rge const ruction crews , and subsequent living accommodations and services for these people for several years. The monies local government spends as population increases is documented; the a dj us tments that must be made by the community to the sub-bb

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page 5 loss of either population or jobs are less easily calculable, but " boom and Bust" operations present di f fi cult resource management problems as well as social and economic problems and are generally not de si rabl e.

The impact of ancillary facilities for any o f the three locations possible may adversely e ffect the envi ronment of Ulster County.

Ulster County has been sighted for the location of 765 KV lines running north to south. These power transmission lines are requi re d fo r an, nuclear power plant above Ulster County to get the power it produces to the major users , New York City and area. 765KV lines have associated health hazards, specifically that o f mi cro-wave ra di ati on . The size of the ri gh t of way involved, 350', as well as the visual effect of the lines on a county that depends on t o u ri sm for a major part o f it 's income, would seriously impact the environment of the county as well.

A pumped storage plant, required as an an:illary facility for the Stuyvesant or Gardiner plants could be located in Ulster County. The size of the project and it's co rres pon di n g impact on the environment would be considerable.

The above contentions are those that the Environmental Management Council feels it must address as a pa rt of it's mandated duties under law.

Lastly, due to limited staff and funding, the EMC requests that the NRC Of fice of the Secretary serve this and all further E!1C documents to all p a rti es Sincerely, SMb b mL Stepben J E g ei-e i e r Ch ai rma n SJE/slj

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