ML19207B924

Submits Revised Set of Contentions Re Nuclear Power Plants within 400 Miles of Gardiner & Threat of Plants to Safety & Health of Citizens

ML19207B924
Person / Time
Site:	New Haven
Issue date:	07/10/1979
From:	Straus D GARDINER, NY
To:	Atomic Safety and Licensing Board Panel
Shared Package
ML19207B919	List: ML19207B918 ML19207B924
References
NUDOCS 7909060093
Download: ML19207B924 (8)

Text

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REVISED CONTENTIONS, TOWN OF GARDINER, NY RE STN 50-596, STN 50-597 NEW HAVEN 1 AND 2 After consultation with Mr. Lewis of the NRC staff on June 14, 1979, we offer this revised set.of contentions. Mr. Lewis recommended that we " narrow the issues and elaborate specific contentions". He discouraged. contentions which were " general" in nature concerning threats of nuclear energy. He implied that these matters had alraady been decided by the Congress and the courts in favor of nuclear energy.

We must observe that new facts have come to light since the 1950s.

Now the perceived threat of nuclear power deserves re-examination. It is evident to us, as a basic premise to the more specific contentions which follow, that nuclear power plants within 400 miles of Gardiner are a significant threat to the safety and health of our citizens.

The burden lies with applicant to prove (and for NRC and PSC to test) that nuclear plants at New Haven, at Stuyvesant, or at any other al-ternate site are not a threat to the safety and health of citizens of Gardiner or any other community.

The list of specific contentions follow.

1. The Gardiner alternate site is inappropriate for any type of aermal electric generating plant because

a. it would seriously interfere with the wilderness ambiance of the Minnewaska State Park and the Mohonk Trust which overlook the entire northern dallkill river valley containing the Gar-diner siter

b. it is on the flight path and 10 miles from a major jetport (Stewart airport) destined..tp serve the New York metropolitan rys

> '@N area, already serving as a freightport and charter passenger port and with runway lengthening in progress allowing service

\ for the largest commercial and military planes - a plane , s f ,p . /d crash into the reactor containment might result in a nuclear ff g " incident" or similarly caused destruction of the cocling g ?;p"[ 2w secondary N ap- ,

(at8r pipeline. and/or turbine ( s) and/or cooling t cooling system), or power distribution facilities jS' 6NJ 7 would recult in a nuclear incident or power blackout of a g#; " 9# 1arge regions

, c.it contains freshwater wetlands protected by New York laws Cd d.a nuclear incident at a plant at the Gardiner site would threaten physical destruction to or radioisot' ope contamination of the Catskill aqueduct (surface) on the eastern border of the site serving nearly 40 ,4 (storage of 140 billion gallons) of the freshwater needs of over 10 million people in Orange, Westchester, Bronx, New York, Queens, Kings, Richmond, and Nassau counties and for which there is no alternates e.it is in a narrow valley (about 10 miles between Marlboro and Shawangunk rangen with site closer to latter) where subsidence ,

inversions occur almost daily which would temporarily trap gas-eous fission products and isotopic contaminants such as tritium regularly exposing the local population to significantly increasec concentrations of isotopes and associated radiation and also would temporarily prevent dispersal of the cooling tower water droplet plume causing greatly increased local precipitation f.said water droplet plume would shade and also change precip-itation patterns adversely affecting the area in the i==ediate vicinity of the plant (see e) as e region t eas and

2 north of the site in the Towns of Gardiner, Plattekill, New Palt ,

Lloyd, Esopus, and Marlborough and possibly in Dutchess County as well among the principal apple and wine producing areas of New York States

g. the plant would require all cooling water (about 100 million gallons per day wculd be consumed - more would be pumped)from the Hudson river 10 miles horizontally and 350 ft. uphill using at least - minimum-0.2 % of planned electric capacity (or enough electric energy to serve the entire needs of a population of 32,000 -the city of Pou hkeepsie, assuming average daily demand of 125 kwh per person per da ;

h. (added because of NRC requested removal of 'amongst other reasons')

the consumptive use of 100 million gallons per day of Hudson river water has not been integrated by applicant or by any government agency with other existing or planned consumptive uses of Hudson river freshwater above the salt front including power plants & water supplies such as Roseton and the 5 plants planned by Consolidated Edison at Red Hook and the Greene County Nuclear facility and Stuyvesant and the Quarry site (PASNY-planned) and Lloyd and Athens and Delmar, Hudson river tap, City of Poughkeepsie, village of Highland, Chelsea Pumping Station and others with the result that piecemeal, unintegrated planning of consumption of finite fresh water supply could result in severe environmental and socioeconomic consequences

i. (added because of NRC requested removal of "amongs other reasons")

the evaporation of 300 million gallons perAay of Hudson river water wi 1 disperse an unknown but significant amount of polychlorinated bi-ph Jis into the atmosphere ( for a report of toxicity and carcinogenicity of'PC3s see Ann.N.Y. Acad. Sci. in press - symposium held New York City 6/15 - 6/23/78 anc for atmospheric dispersal from water the symposium of NYDEC "PC3s in the Hudson River, Colonie, NY 6/11 - 6/12/79) and suoject terrestrial plants and animals (including man) to this toxic carcinogen which causes a wide variety of diseases ranging from chlor-acne to impotence and including cancers and which accumulates to high levels over time in long-lived organisms;

j. (added because NeC requested removal of "amongst other reasons")

the four 575 ft, natural draf t cooling towers would be the largest structures between midtown Manhattan and Empire State Plaza in Albany and would be easily visible from all over the northern Wallkill valley and from the Marlboro and Shawangunk mountains (see c.) on the clear days we presently have though the cooling towers plumes might reduce the proportion of clear days (see e.);

k. (added because NRC requested removal of "amongst other reasons")

The reactor containments, auxiliary buildings, cooling towers, rail ,

and highway facilities would make the plant look like a large in-dus:cial facility which would be out of place and aesthetically dis-pleasing in the agricultural areas surrounding the site s em ur:u:bvvn as

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1. (added because NRC requested removal of "amongst other things")

The current liquid fuel crisisApredicted to continue - and get worse -

it won't be possible to tap a ' native' skilled work force able to find gasoline to commute to Gardiner from as far away as Westchester County or New Jersey, or the Capitol District, and the construction force will have to live locally thus putting great pressure on Gardiner and surrounding towns to provide services for the temporary influx of workers which would wre ak havoc with local taxes, par-ticularly for schools which would have to be built, and subject us to the " boom and bust" cycle- (when construction is complete) char-acteristic of large energy projects

m. (added because NRC requested removal of "amongst other things")

There are no health care facilities within 10 miles of the proposed site and emergency health care facilities in the Mid-Hudson region are inadequate for the needs of affected plant construction or oper-ating personnel in case of an accident (such as cooling tower collapse as in West Virginia in 1978 or an ' incident' less than class 9 involving radiation or direct injury to plant workersj

n. (added because NRC requests removal of "amongst other things")

A major industry in Southern Ulster County, recreation and tourism, would be adversely affected by the presence of a nuclear plant and much more so i==ediately and for a protracted period following any

' incident's

o. ( added because NRC requested removal of "amongst other things")

There are 3 schoob totalling about 2300 students within 5 miles of tne Gardiner site ( the evacuation zone for Three Mile Island 2 ' incident' 3/28/79), 14 within 10 miles of the..shte, with approx.13,00C students and about 35 with. approx. 50,000 students witnin 20 miles of the site which would be cirectly endangered by a less than class 9 incident and which are not considered by applicant in Alternative Site Analysis -

in regard to consequences of any class of ' incident' toward -

this dependent population nor in regard to any type of emergency plan for ameliorating said consequences in event of any class of ' incident's

p. (addsc because RRC requested removal of "amongst other things" property values in Gardiner and surrounding towns would decrease as a direct result of being near nuclear plants and utilization of said property would become limited because of the nearby source and storage place of radioisotopes. ,

2 The citizens of Cardiner would have their health and safety adversely affected by atmospheric PC3s disperced into the atmosphere through operation of planned natural draf t cooling towers using Hudson river water as secondary coolant for nuclear plants at Stuyvesant.

3. The citizens of Gardiner would have their health and safety adversely affected by atmospheric pC3s dispersed into the atmosphere througn operation of planned natural draft cooling towers using Hudson river water as secondary coolant for nuclear planta at Northunterland.

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4 (added bee:iu;u o f NitC ruquest that contentions be made site spe-cific) The citizenu of Cardiner woulu have their health adveruely af fec ted by a tav.:snecie d iuperual o f mirex, PCBs, and othcr nalogenated hydrocartunu fron na tural draf t cuuling towers using Lake Ontario water au secondary coular.t for nuclear plan ts at New Haven.

5. ( added because of NaC reques t that contentions be made site s pec ifie ) The approximately 70;s of energy released in nuclear fission not recoverable as electric energy at the reactor is planned, by ap-plicant,to be released to the " ultimate heat sink' - the atmosphere -

at New Haven, at S tuyvesant, and at Gardiner, at Northumberland, at Charles ton, and at Barton which will adversely affect the citizens of Gardiner bucause their electricity (some of which will presumably be purchased from NYSEG-LILCO) will be more expensive since applicant contravenes national energy policy by not applying the principle of reverse co-generation - using the 'wante' heat in another use uuch au distric t heating ur as indus trial proceus heat - at any of the proposed nuclear plan t uiteu.

6 ( rev is ed becouue of NHC request that. contentions be made site spec ific ) A malfunc tion at nuclear plantu in Gardiner would have a deleterious effec t un the phyuical environment of Gardiner and the healtn and safe ty of its citizens and normal operations involving release of products and secondary iso-topes (e.g. djM t ,seousgradigggtivy3{isujggXe)

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I, i, also giving such dele-teriouu effec ts because

a. any ioniz ing radiation (and nuclear plants would increase said ionizing radiation in Cardiner) has the po tential. . . minimum require-ment - one nuclear decay per biological event. . .for changing cells tneluding tumurigenes is and of causing mutations in germ cells a f f ec tins the nex t generatiun; s

b. besides direct effec ts on populations near nuclear clants' radioiso topes released in a malfunc tion ( excluding class 9) or normal opera t ior: of nuclear plants can also become incorporated into the food chnin and in water uupplies indirec tly affec ting large populations away from the immediate plant site ( evidence for distant upread of radio-iso to pes was presented in our amended pe tition to in te rv ene):

c. Claus 9 malfunction would release the entire radioisotope inventory of the reactor fission produc ts to the environment to spread widely uncon trolled, bo th pnysically and biologically, threatening the very exis tence of the citizenu of Garoiner from associated ra-diation;

d. a cl, t 9 .c.alfuntion mould release the entire reactor in-v en tu ry o f 3Y.u tu the environment to spread widely, uncontrolled, both physically and biologically tnreatening the very existence of the citizens of Cardiner from chemo-toxic and carcinogenic effec ts. -

7. (revised becauce o f NRC request that contentions be made site specific) A malfunc tion at nuclear plants at S tuyvesant would release the entire radioiso tope inventory of the reactor fission produc ts to the environmen t to spread widely, uncontrolled, both pnysically and :iologically, threatening the very existence of the citizens of Carciner, from associated radiation, and from chemotoxic and carcinogenic effec ts. 'jLf }@

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8. (revised cacause of NdC request that contentions be made site specific) A malfunction at nuclear plants at New Haven would release the entire radioisotope inventory of the reactor fission products to the environment to spread widely, uncontrolled, both physically and biologically, threatening the very existence of the citizens of Gardiner, from associated radiation, and from chemotoxic and carcino-genic effects. .

9. ( revis e d because of NRC request that contentions be made site specific) A malfunc tion at nuclear plants at Barton, or at Charles-ton, or at Northumberland would release the entire radioisotope in-ventory of the reac tor fission products to the environment to spread widely uncontrollec, both physically and biologically, threatening the very existence of the citizens of Cardiner, from associated ra-diation; and from chemo toxic and carcinogenic effects.

10. ( revised to meet NRC requests for ' elaboration' and site u pec i fic ity) the health and cafety of the citizens of Gardiner and of their descendan tu will te endangered by the possibility of loss to the environment, including food, air, and water, of stored flusion productu anq ficsile materials from spent nuclear fuel which must be stured at the Now Haven site since no accepted on site ciupusal me thocs for such ma terials exist or are planned.

11. (revised to meet NRC requests for ' elaboration' and site specificity) The health and safety of the citizens of Gardiner and of their descendants will be endangered by the possibility of loss to the environment, including food, air, and water, of rtored fission products and fissile materials from spent nuclear fuul which must be stored at the Stuyvesant s'ite since no accepted on site disposal methods for such materials exist or are planned.

12 (revised to meet NRC requests for ' elaboration and site spc-c i fic i ty ) The healtn and safety of the citizens of Gardiner and of their descencants. will be encangered by the possibility of loss to the environment, including food, air, and water, of stored fis-sion products and fissile materials from spent nuclear fuel which must be stored at the Cardiner site since no accepted on site dis-posal methods for such materials exist or are planned.

13. (revised to meet NRC requests for ' elaboration' and site specificity) The health and safety of the citizens of Gardiner and

'9C) their descendants will be endangered by the' possibility of loss to C723 the environment, including food, air, and water, of stored fission

(~20 products and fissile materials from spent fuel which must be stored

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C3 14 ( revised to meet NRC requests for ' elaboration' and site spe-

"O3% cificity) Transport of nuclear fuel to or of spent fuel, including i kd 'J! fission products, from the New Haven site would endanger the health EE3l and safety of the citizens of Cardiner and their descendants due to

2 the possibility of accidental uncontrolled release of such materials r=== to the environment, including food, air, and water, in or near the town which is within 10 miles of principal north-south highway (I-o?)

and rail (Conrail), and water ( Hudson river), and east-west highway (I-64) transportation routes. Sjhi'Q9

15. ( revised to mee t NRC requests for ' elaboration' anc site spe-

6 cificity) Trancport of nuclear fuel to or of spent fuel, including fission procuc ts, from the S tuyvesant site would endanger the health and safety of the citizens of Cardiner and their descendants due to the possibility of accidental unccntrolled release of such materials to the environment, incluaing food, air, and water, in or near Gardiner since all such materials would have to pass through the town or near it (see #14).

16. (revised to meet NRC requests for ' elaboration' and site specificity ) Transport of nuclear fuel to or of spent fuel, including fission products, from the Cardiner site would endanger the citizens of Gardiner and their descendants due to the possibility of accidental uncontrolled release of such materials to the environment, including food, air, and water, in or near Gardiner since all cuch materials would have to pasa through the town. .

17. ( revised to meet NRC reques ts for ' elaboration' and site spe-cificity) Transport of nuclear fuel to or,of spent fuel, including fission products, from the Barton or the Charleston, or the Northum-berland sites would endanger the citizens of Gardiner and their descendants due to the possibility of accidental uncontrolled release of such =aterials to the environmen t, including food, air, and water, in or near Gardiner since all such materials would have to pass throug.} the town, or near it ( see #14) .

la. ( revis ec to mee t NRC reques ts for ' elaboration' and site specificity) The cons truction and operation of nuclear plants at New Haven will result in the production (where none existed pre-viously) of raciaisotopes, fission' products and actinides, whose decay cannot s

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7 be stoppec or controlled in any way, the existence of which threaten the health and safe ty of the c i tizens of Gardiner and their descendants if thu .ucioicutopeu are reluaued accidentally or through purposeful action s applicantu fail to indicate means of preventing these products of their proposed process from erfering food and/or fiber and/or caterials used by man, of entering ground and /or surface waters and affecting citizens of Gardiner, or of entering the atmosphere and and affecting citizens of Gardiner for the lifetimes of these radioactive products.

'19 The construction and operation of nuclear plants at Stuyvesant will result in the production (where none existed previously) of radioisotopes, fission products and actinides, whose decay cannot be stopped or controlled in any way, the existence of which threaten the heal th and safe ty of the ci tizens o f Gardiner and their descendants lf the radioisotopes are released accidentally or through purposeful actiuns applicants fall to indicate means of preventing these products of their proposed process from erlering food and/or fiber and/or materials used by man, of enering ground and/or surface waters and af-fecting citizens of Oardiner for the lifetimes of these radioactive products.

20 The construction and operation of nuclear plants at Gardiner will result in the produc tion (where none existed previously) of radioiso to pes, fission produc ts and ac tinides., whose decay cannot be s topped or controlled in any way, the existence of which threaten the health and safety of the citizens of Gardiner and their descen-dants if the radioiso topes are released accidentally or through purposeful actions applicants fail to indicate means of preventing these products of their proposed process from entering food and/or fiber and/or materials used by man, of e6ering ground and/or surf. ace s waters and affecting citizens of Gardiner, or of entering the atmosphere and affecting citizens of 3ardiner for the lifetimes of these radio-active pr.o duc ts .

21. The construction and operation of nuclear plants at Earton, or dharleston, or Northumberland will result in the production (where none existec previouuly) of radioiso topeu, fission products and actinides whose decay cannot be stopped or controlled in any way, the existence of which threaten the health and safety of t.he citizens of Gardiner and their descendants if the radioisotopes are, released accidentally or through purposeful actions applicants fail to indicate means of preventing these products of their proposed process from entering food and/or fiber and/or materials used by man, or of entering ground and/or surface watars and af fec ting citizens of Gardiner, or of entering the atmosphere and affecting citizens of Gardiner for the life times of these radioactive proaucts.

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22. (revised for site specificity following NRG request)

For economic operation compared to fossil fuels, base-load r.uclear facilities such as those planned for New Haven, for Stuyvesant, for Gardiner, for Barton, for Charleston, for Northumberland, require ancillary energy storage facilities when the NYPP nuclear capacity rises above the minimum daily demand in New York and the construction and operation of such energy storage facilities could affect the physical environment of the town of Gardiner adversely ('see our comments on DEIS, FERC # 2829, 6/78) and the welfare of its citizens.

23. (revised for site specificity following NRC request)

Addition of base-load nuclear generating facilities at New Haven, at S tuyve s ant, at Gardiner, at Barton, at Charleston, and/or at Northum-barland will require transport of generated electric energy to points of use most of which are far from the listed sites planned (see applicant's Alternative Site Analysis) as either 345 kv or 765 kv lines and Gardiner is on the route of a 765 kv link which could affect the health and safety of Gardiner citizens .through microwave radiation generated, arcing, and interference with communications and would be a less productive use of land, considering the 350 ft. right of way, and which would not be necessary if such cited, nuclear base-load facili-ties were not added to the NYPP. ,

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.dilliam Keeping Supervisor Town of Gardiner s

i v WN 7, David S traus Gardiner Environmental Commission e'

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