ML19210B396

Petition to Intervene in TMI-1 OL Proceedings.Certificate of Svc Encl

ML19210B396
Person / Time
Site:	Three Mile Island
Issue date:	08/07/1972
From:	Goldstein H CITIZENS FOR SAFE ENVIRONMENT
To:	US ATOMIC ENERGY COMMISSION (AEC)
Shared Package
ML19210B395	List: ML19210B394 ML19210B396 ML19210B397
References
NUDOCS 7911070717
Download: ML19210B396 (21)

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• UllITED S 2ATES ATO:4IC EER3Y Col &ISSIGH In the matter of Doc!:e t do. 50-289 Zdetropolitan Edison Company Pennsylvania Electric Co. -

and o o

Jersey Central Power and Light Company #'

C30iEiED Three 14ile Island Nuclear Station > O IO O

Unit 1 2 AUG 91972 *

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PETITI0l! FOR II!TER72:iTION , 4 The Citizens for a Safe Environment, an unincorporated organization consisting of individuals who reside in Harrisburg and the surrounding townships and boroughs and o ther political sub-divisions, and York - and the Environmental Coalition of Euclear Power, on their behalf and on behalf of their, members, supporting individuals and organizations hereby petition the Atomic Energy Commission for leave to intervene in this proceeding pursuant to the Commission's rules of practice and state:

1. Petitioner, Citizens for a Safe Environment, is an unincorporated association comprised of citizens and residents of the Harrisburg area whose membership includes residents of said area, all .of whom are interested in the dissemination of information and stimulation of public awareness and involvement in the study of nuclear power. Said organization, by its past ac tivities and conduct, has exhibited a special interest in the protec tion of the natural resources of the Susquehanna Valley 391107" 7 / 7

2 particularly in the area of the City of Harrisburg, in the conservational, recreational, economic, aesthetic and community impact of nuclear power plant dcVelopment in said area. Said group and the members thereof are first and foremost concerned-with the safety of the operation of ~ said nuclear plant, the .

radiological and operational effect 'n the public health, welfare and saf e ty . Petitioner further assarts that it and its members will be directly affected by the issuance of an operational permit in that its members are residents of the area directly affected by the operation of the proposed nuclear. plant.

2.

The Environmental Coalition on liuclear Power is an unincorporated association comprised of twenty-nine organisations in the Pennsylvania and How Jersey area. Its membership includes residents of both the S tates of Pennsylvania and Hew Jersey, including residents of the Harrisburg-York area. Said organization and its members are concerned with the same interests and set forth for the Citisens for a Safe Environment. To taat extent, the same is herein incorporated by reference and part hereto.

3. Petitioners are concerned and involved with the following contentions concerning the application herein for an operating '

license.

Tne l{st of contentions herein is not a full and complete list hereof since petitioner has not been afforded an ample and reasonable opportunity to review fully the application herein for an operating license and the Atomic Energy staff Safety evaluation neport, particularly, because of the trasi384 350

3 D**D "D Tl ao a 2. .k _a and devastating flood of June 22 - 24 witich has directly affected petitioner and its acmbers. retitioner had served notice on the Atomic Energy Commission through its counsel requesting an extension of time to file tais-petition. Accordingly, the petition herein is not an exhaustive sthtement of all cententions of petitioner and petitioner again, hereby, seeks 1 ave to file further contentions within a reasonable period of time h7 rein.

(a) Petitioner contends that no operating license may be and should be granted until such time that the AEC or the applicant can demonstrate that the high level radioactive vaste arising from the operation of said plan t will be transported from said plant and reprocessed in a manner assuring the complete protection of the public health and safety.

(b) -The releases of radioactive materials to unrestricted areas during normal operation, particularly tritium releases, shall be in violation of Commission's rules, particularly the low as practicable standards and the proposed Appendix 1 Part 50.

(c) Plant has not been designed and constructed to meet the requirements of Fart 100 of the Commission's rules, particularly with respect to releases that might occur during a maximum ,

credible accident. It is further asserted tnat applicant's e

analysis of tne maximum credible accident and releases therefrom is in violation of the Commission's rules in that the worst maximum credible accident would be an accident that would release radicac tive effluents greater than those set forth by the applicant in it i 84 351 Safety Analysis Report.

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lh Wo (d) The applicant has failed to design and construct the said plan t in accor?.ance witn rar t 50 requirements, particularly Appendix A, and especially wi ch reference to the construc. tion of the . containment, tae fuel handling building, pumps, pipes, and valves. The petitioner lurther asserts that the A3!.:E code has not been fully compiled with, especially 1. . that petitioner has failed to design and construct the components to withstand all dynamic pressures, including hydraulic transient pressures that may occur during the lifetime of the plant.

(e) The plant cannot be safely operated in that the fuel cladding and fuel rod assembly parts are so designed and constructed as to allow radioactive releases into the reactor cooling system and subsequently to the environment that would exceed the lowest practicable scandards.

'( f) The reactor cooling systems are not designed and constructed so that they will function during an emergency. Petitioner incorporates herein the contentions set forth by the national Intervenors at the 14ational hearings before the Atomic Energy Commission concerning the emergency cooling systems.

(g) Petitpners assert that the Commission's rules and regulations for levels of radioactive releases during normal and accidental conditions are improper and contrary to the health, welfare, and safety of the public and therefore invalid as a matter of la'.v. Petitioners f: rther contend that the applican.815 4 '3 5 2 could not operate the plant 3 that the radioactive effluents during normal and accidental' operational situations and cccurrences would be at a level whereby the nublic health welfnvo - de ' t"

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a would not be adversely affected.

(h) The structures, systems, and components important to the safe ty of the reactor's construction nave not been des 1;ned, fabricated, erected, and tested crith quality s tandards commensurate with the importance of tne safety functions to be perforned and in accordance' with generally recognized cod es, especially with reference to the containment, pumps, reactor roa.n ::s is.... . energency core cooling system, pipes and valves.

(1) The structures, systems, and components important to the safe operation of the facili ty have not been designed and located to miniraise the probability and effects of fires and e:: plosions or to withstand the effects of national phenomena, particularly floods. retitioners assert that the construction and design is not sufficient and in the event of t'e worst case said structures, systems, and components would 1cce their capability to perform

.their safety functions.

(j) The instrument in control of the proposed reactor does not have sufficient redundant systems do as to be able to monitor variables and systems over their anticipated range for normal operation and accident conditions and to maintain them within the proscribed operation of ranges.

t (k) The reactor coolant pressure boundary has not been designed and constructed . i th sufficient margin to assure that-wnen stressed under operating, maintenance, testing, and practicable 1584 353 P

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D*C 6 D Pp gn WM wJud kL accident conditions that a fracture would not occur and that the boundary benaves in a non-bri ttle manner. The petitioner asserts that the construction and design of the reactor coolant pressure boundary and containacnt have not been designed and constructed -

to reflect considerations of tecperaturcs, stresses and other conditions under operating, maintenance. testing and postulated accident conditions, especially since all phases of the naterial properties, the effects of irradiation on material proporties, tne residual, steady-s tate and transient s tresses and the size of flaws have not oeen fully and adequately considered.

(1) The petitioner asserts that the applicant has not constructed and used those systems available to control fission products--the concentration and qualizy of fission products released to the environment during normal and accidental conditions.

Those systems used and constructed by the applicant for containment of fission products do not have suitable redundancies inter-connections and leak detection to assure true full containment of fission products.

(m) The applicant has failed to comply with Appendix d Part 50 of the Commission's rules ib. that applicant has not and cannot establish an' emergency plan that will assure evacuation of all environs, including the City of narrisburg during the worst postulated accident. 1584 354 (n) The available water supply for tne safe operation of the plant during normal eme ;ency and accidental condi; ions is not sufficient to supply the necessary quan tity of water for the

cafe operation and safe snut do.in of tae nuclear reactor at tne site. The applicant's meterological data and studies as precent in the r S Ait are not prepar ascumptions, especi,aly in that inv.er.sion conditicas, icing and fogging, together wita the synergistic effecto of pollutants in tne atmospnere that may occur during tnc operation of tne plant, nav e no t been fully analyzed and evaluated for calculating meterological diffusion and dispersion factorc and the low level radiation effec t of ficsion product releaces to the environment.

(o) The radioactivity released into tne Susquehanna during n o r. r '. and accidental conditions, ecpecially tritium releases, would adversely affect the health and welfare of tne public and the public's water supply.

(p) The applicant nas not es cablished that the control rod housing support structures and all components of the control rod mechanism are ' adequate and cafe, especailly that mechanism that prevents a drop of the control rod ana tne control rod guide tube and the possibility of c'ollapse thercof from prescure differentials within the reac tor. The applicant has not established that there will be ao endangerment to the public' health or safety from e

industrial sabotage or from air craft that may crash into any part of tne nuclear pJant.

(q) ine quality controls, metuca of conatruction, qualificat_ons of workmen and supervisorc, testing of materials used and quality 1584 355

-  % h-8 D**D *D ww o . \. a control progr:ut with all other relevant aspects of the construction of the plant in conformity with the applicable construction codec have not boon sufficicntly demonstrated and establisned 'o provide assurance that the plant has been construc ted to prevent-the operation of the plant fron adversely affecting the public health and safety. -lIncrefore pe titicners respectfully request that they be permitted to intervene as a pat ty in this proceeding.

PRELIEIR AaY S ?rdEI'.2:? 0F S..'lIRO:.!? 1 ?AL C01&2.'. .!IO;is

1. Applicant proposes to draw water from the Susquehanna River and pass it through the plant condensor cooling tower system.

Information presented in Applicant Environmental Report is undefined and inadequate to effectively evaluate the environmental effec ts of the aquatic thermal discnarge on the aquatic life in the Susquehanna River under all operating and shutdo In conditions.

2 '.

The environnental effec ts of release of large quantities of heat and water vapor and water vapor chemicals from the cooling tower systems on the surrounding countryside and river and streams have not been adequately considered. This could result in serious changes in local terrestrial and aquatic ecology from the cooling .

tower operation.,

3. Insufficient evidence is presen ted to justify the fogging frequencies and extent s bated in Section 5 of the environmental report. Plus there is no impiriccl information presented to verify i584 356

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o 1k .m that the mathematical r:.odels used for predicting local weather effects by cooling towers are in any clay valid.

'4. lio comprehens.:.vc estimates are t:iven of the extent of ground fogging and icing chien vill result from cooling to: er operations under average and carst operating conditions. The brief statements unich are made in Section 5 concerning possible fogging and icing are too brief and lack sufficient numerical quantification to judge whether these statements are correct or no t.

5. Ho costs are presented on the visual neathetic detriment from the cooling towers to the skyline surrounding the site.

6. 30 effects analysis is presented on possible synergiatic effec to between cooling tower, atmospheric effluent's nnd chemical pollutan ts prcduced by surrounding indus tries on plant, animal and human life forms nor between cooling tower, atmospheric emissions and plant gaseous radioactive emissions. I?or be tween plant thermal discharges into river and plant, liquid radioactive effluents and other chemical pollutants in the river from upstream industries. Nor between the chemicals from cooling tower blowdown and plant radioactive emissions and liquid thermal discharges.

Various scientists have reported on many synergistics on the health of human and other life forms from some of the possible combinations which could result from Various emissions from the plant or between particular plant caissions and chemictis from other industries.

7. A complete lack of evidence exits to back up applicant statement of no significant ti ermal racek effects on aquatic life 1584 357

N, 10 under all normal, abnormal and emergency shutdown plant conditions.

John Clark in an article on tnermal pollution in Scientific America has stated that as little as a 10 degree fahrenheit change in termperature can have a detrimental effect on aquatic fish life in a river system.

8. The total dissolved solids botn average and maximum listed in tabla 3.7 - 1 of the Environmental Report added to the average existing dissolved solids of the Susquehanna River will result in dissolved solids concentration at outlet in excess of United States Public Health Drinking 'Jater Standards of 500 ppm.

9. The effects on humans and other life forms from the

, liquid chemical effluents from the plant in terms of dissolved solids, suspended solids increased sulfates, chlorine residual, maximum and minimum PH, sodium ion, sodium hypochlorite, PO 4, spent resin filtration, alkalinity, have not been investigated under the most adverse flow conditions.

10. Using the intake and discharge temperature presented in table 3.7 - 1 of the Environmental Report under the worst conditions

'ndicated i for winter and summer, extensive thermal plumes could develop from tne plant. Emergency shutdown of the plant could then result in extensive fish kills for those fish originally attracted to the thermal plume.

1584 358

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11. It does not appear from the information presented in-3.7 that the computed total dissolved solids concentration takes into account the effect of evaporation induced increased concentration of dissolved solids. Further, no analysis are presented whicn substantiate the dissolved solids figures presented in table 3.7 - 1.

12. A complete chemical breakdown and associated concentrations on the discharge effluent is not presented. Without this it is impossible to evaluate the potential chemical impact of the plant on the Susquehanna River.

13. The diffusion and dispersion enaracteristics of the enemicals effluent are inadequately defined in the applicant's

-Environmental Report thus preventing the chemical environmental impact. from being properly evaluated.

14. No analysis is presented of the aquatic life impact under low river flow conditions of evaporating large quantities of Susquehanna River water out the cooling towers. ,

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., Applicant states that chlorine concentrations in water waste discharges;are negligible. A concentration of 1 ppm of residual chlorine has a devastating effect on plankton and aquatic-animals. The statement of the applicant that the discharge will have no adverse effect on the environment is therefore without foundation in fact.

1584 359

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15. retitioners contend that Applicant's Environmental Impa.ct Statement fails to discuss or analyze fully the environuental effects, including cost / benefit and risk / benefit considerations, of the en tire uranium fuel cycle: vig., the environmental damage from nining, strip-mining, milling, and enrichment of uranium; environmental impact of both the ga 3ous diffusion enrichment process and the generation of electricity for that process by the strip- and other mining and consumption of high sulfur coal; environmental damage attendant upon both chemical conversion of uranium hexafluoride into uranium dioxide and fabrication of uranium dioxide into nuclear fuel rods.

16. Applicant has failed to include in the Environmental Impact Statement the cost / benefit and risk / benefit analysis of

-those aspects of the complete uranium fuel cycle that follow the use of the fuel rods, particularly environmental effects associated with transportation, reprocessing and high level radioactive waste.

storage and monitoring. Neitner normal operational impact nor abnormal operations and/or accident damage to the environment are discussed or analyzed. .

l 'I . Petitioners contend that, because the Atomic Energy Commission's as-low-as-practicable formula does not apply to spent fuel reprocessing plants, it is impossible that the total amount of radioactivity that reaches the environmant as a result of the operation of Applicant's plant vtill exceed safe and tolerable limits. '

1585 001

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18. Applicant has omitted from the "Long Term Effects of. rlent Construction and Operation" in the Environmental Impact Statement ar.y analysis of the environmental or monitary costs of plant operations and radioactive waste control and storage.

19. In "Long ferm Effects of Flant Construction and Operation" Applicant has not discussed the environmental impact, costs and risks associated with a continued assured supply of uranium over the proposed life of the nuclear facility.

20. The Applicant's Environmental Impact Statement fails to discuss or analyze completely the cost / benefit and risk / benefit relationships attendant upon the development and production of fissile uranium by methods not presently in use, specifically the environmental effects of the Liquid ketal Fast Breeder Reactor,

_ designed to provide plutonium for the fueling this or other light water, reactor facilities in the event that insufficient uranium is available to operate the Applicant's plant during its projected lifetime.

21. The Environmental Impact State;cnt contains no discussion or analysis of the environmental effects of fuel failure resulting from fuel densification in a pressurized water reactor. Petitioners cont.end that the Application has not provided guarantee that t'ecnnical specification limits with recpect to radicactive emissions can be or aill continue to be met througnout the plant life.

22. Planned post-cperational surveillance programs are incompletely described and analyzed in the Environmental impact 1585 002

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14 Statement in suon manner as to preclude adequate assessment of long-term environmental effects of tne facility. Petitioners contend tnat sucn monitoring system planning for long-term, '

post-operational environmental impact or idiolog[ cal, thermal, enemical effects is an essential part of tne environmental report and of th'e cost analysis required of the Applicant.

23. It is contended that Applicant has improperly and unrealistically forecast electric power demands upon unich the need for this nuclear facility was based in that Applicant has used dearnd data biased by tne effects of promotional advertising by a rate structure that fosters wasteful uses of electricity, by encouragement of suca inefficient uses as residential space heating, by a rate based on capital expenditures, and by inadequate attention to trends in the national birth rate indicative of a

' decreasing rate of population growth to be provided for.

2'4. Petitioners further con tend that the Applicant's economic analysis is incomplete and selective in such manner as to favor the economic position of a nuclear facility over fossil fuel or other alternative. Applicant's comparative costs analysis omits such necessary and concomitant costs as decommissioning costs, detailed analysi,s of fuel costs including indication of federal subsidies, and true costs of high-level radioactive was'te disposal.

25. It is further contended that App _icant's economic analysis lacks justification based upon empirical data of operational experience for amortization of costs over a thirty-year plant year.

1585 003

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26. retitioner con tends tnat Applicant's economic analysis lacks analysis of costs of full-liability insurance coverage.

' 27 . Petitioner contends that Applicant's analysis of future electric power demands is based upon a prior period of' abnormally high short-term growth rate for the United States economy and especially for electric power consumption; it is incorrect in contemporary American society to reject, as Applicant does in tne Environmental impact Statement tne possibility of zero growtn, eitner population or economy. It is therefore contended tnat Applicant's analysis and discussion of alternatives to construction of tne nuclear facility is incomplete in tne absence of the diminished growtn and no-growtn alternatives.

28. Petitioners additionally contend tnat Applicant's

_ demonstration of need for :his nuclear plant and of alternatives is inadequate in the absence of an analysis based upon more efficient uses of energy resources.

29. Applicant has failed to present a complete and detailed analysis of all alternatives to a nuclear fission generating station, particularly witn respect to alternative sources sucn as solar, geotnermal, fusion, fuel cells ,

MHD, methane generation, national grid, and decentralized power schemes.

30. retitioners contend tnat risks and costs to the env1.onment outweigh all alleged benefits of tuis nuclear plant.

31. Fetitioners contend tnat comparative economic costs of tne nuclear facility based upou an OUW capacity factor are 1585 004

16 unrealistically biased against fossil fuel plants; 809 capacity factor is hi,;ner tnan operacing experience of existing reactors warran co .

32. Petitioners contend tnat environment values are endangered compared with by the low reliability of nuclear power stations, fossil fuel plants.

33.

Petitioners contend, in tne absence of evidence of a tnresnold effect below which radiation damage to living organisms does not occur, tilat adequate environmental protection requires Applicant to guarantee a zeros release system in its plant and in all aspects of the fuel cycle.

34. Petitioner contends tnat tne Applicant's emergency safety plan is inadequate and insufficient to provide for tne protection or evacuation of the population of tne Greater Harrisburg metropolitan area, in tne event of an accident exceeding design basis accident; and that Applicant nas failed to evaluate tne costs of environmental recovery from an accident exceeding design basis accident.

35. Applicant assumes perfect mixing of thermal discharge waste water in York Haven pond. Perfect mixing is seldom, if ever, achieved , Throughout the " Environmental Report, Operating License Stage," the. applicant uses averages of numbers such as average do'se at site boundary, estimated dose to population in 50 mile radius, man-rem, etc. Such numbers without standard deviations or average deviations and some statement of the extreme valves encountered are of little utility. Applicant concludes 1585 005

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17 that calt and copper culfate fallout are negligible. Such a conclusion is unjustified. Applicant makes no real risk-benefiY analysia.

36. The petitioner contends that the Construction of theT(

reactor containment building and fuel handling buildings was not carried out in accordadne with construction specifications and has resulted in structures incapable of withstanding the maximum

' loadings expected.

37. The " Safety Bvaluation" by the DRL of the United States Atomic Energy Commission for Unit #1 Three Nile Island Huclear Station, Dauphin County, Pennsylvania - Docket 50-289 dated 2/5/68 on page 33 indicates failure pressures obtained by parametric analysis indicate that during loss of coolant accident pressures of 52.0 y S I G can be expected. The containment vessel is designed for 55 P S I G which is an insignificant design safety factor especially in lignt of the questionable nature of predicting failure pressures by mathematical models and not actual test results.

38. Failure to use proper construction techniques in placement r

W of reinforced concrete especially in the reactor containment vessels is well documented in various . reports in " Report on Containment Building King Girder Construction and Repair" such as those dated J anuary 19, 1972, July 30, 1971, november 3, 1971, and June 30, 1972.

Such reports raise grave doubts on the structural integrity of tne containment vessel to withstand the design pressure of

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1585 006

18 55 P S I G. Comments such as the sixth paragraph on page 1 Docket Su-289-48 dated J anuary 19, 1972 indicates the la'kc of

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confidence even by the design engineers themselves.

39 . The petitioner contends tnat tne hydrologic criteria employed in design of flood control dikes is completely ' inadequate, as demonstrated by the recent flood of June, 19'/2. The design storm disonarge at Three raile Island of 1,100,000 C.F.S. (estimated in excess of a 20,u00 year storm) was closely approached at Harrisburg where tne flow was estimated at 965,0u0 0.F.S (and recently re-estimated by a Penn State University Hydrologist, to be only 100 year frequency flood) . It is contended tnat required figures for tne design storm need to be drastically revised upward with a corresponding increase in dike height to adequately protect the plant from flooding., It is further contended that the ple. cement of a major energy source in sucn a vulnerable position will compound tne magnitude of any future tragedy from severe flooding.

40. It is contended tnat land use changes within the area and changes in the air composition from air pollution drastically weaken tne value of statistically analyzed rainfall and runoff figures.

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1585 007

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.. is CoiGIONWEALTH OF PENNSYLVANI A SS:

COUNTY OF DAUPHIN ) ,

Before me, a Notary Public in and for said Commonwealth anti-County, personally appeared Herbert C. Goldstein, Esquire on be-half of Citizens for a Safe Enviornment, the petitioner herein, who being duly sworn according to law deposes and says that the facts set forth in the foregoing petition for leave to intervene are true and correct to the best of his knowledge, information and belief.

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Sworn to and subscribed before me G7 this_  ?' day of ht: cwa l-o l ** /

w" NOTARY PUBLIG' MCt.u!;,,3rg;.u;,p,376,,4,;973

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1585 008

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UNITED STATES OF AMERICA ATOMIC ENERGY COMMISSION e

In the Matter of )

) Docket No. 50- 239 METROPOLITAN EDISON COMPANY )

(Three Mile Island) ,

)

CERTIFICATE OF SERVICE I hereby certify that copies of PETITI0li FOR INTERVENTION dated August 7, 1972 in the captioned matter have been served on the following by deposit in the United States mail, first class or air mail, th's 9th day of August 1972:

Jay E. Silberg, Esq. . Joseph Gallo, Esq.

Shaw, Pittman, Potts & Trowbr'dge Regulatory Staff Counsel 910 17th Street, N .W . U. S. Atomic Energy Commission Washington, D.C, 20006 Washington, D.C. 20545

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Office of the Secretary of the Commission cc: Mr. Callo V. Wilson . -

ASLBP NjReg. Files e

1585 009

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UE.CTSD STATf3 ATol!IC EIERGY CC1.~.I133 ION In the natter of Pe t.ropolit,.n Edicen Cenpany Docket I!o. 50-289 Pennsylvania L'loctric. Co.

Jorcoy Contral Pouer and Light Conpany Three Mile Island 11uclear Station Unit 1 CERTIFICATE OF SERV 1CE I hereby cortify that the original and 20 copiec of the Petition of Intervention by the Citizens for a Safo Environment have been sent by United States Mail, First Class, postago pre-p aid, this day of August, 1972, to:

Office of the Secretary

. United States Atomic Encrgy Commision Washington, D.C. 20545 Attention: Chief, Public Proceedings Branch Copies have been sent to:

A.E.C. Public Document Room 1717 H Street, li.W.

Washington, D.C. 20$45 e

Office of the General Counsel Atomic Energy Commission Washington, D.C. 20$45 4 ,

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Herbert C, uoldstein, Attorney 1585 D\D