ML19210E589
| ML19210E589 | |
| Person / Time | |
|---|---|
| Site: | 05000574 |
| Issue date: | 11/13/1979 |
| From: | Alvarez R, Mattison L, Pollack R CENTER FOR DEVELOPMENT POLICY, ENVIRONMENTAL POLICY INSTITUTE, Public Citizen's Critical Mass Energy Project |
| To: | NRC COMMISSION (OCM) |
| Shared Package | |
| ML19210E586 | List: |
| References | |
| NUDOCS 7912050343 | |
| Download: ML19210E589 (2) | |
Text
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tb November 13, 1979 4
unse Nuclear Regula ary Commission IE NOV 191979 >
1717 H Street, N.W.
Washington, D.C.
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6 Re:
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to the Philippines co
Dear Commissioners:
We strongly urge the NRC to undertake a thorough and complete examination of the health, safety and environmental impacts of the Philippine reactor PNPP-1.
It is essential that this review be undertaken to comply with NRC's legal and moral obligations.
The neim:r/ question, of course, is whether the terrible risks of earth-quake or volcanic eruption have been adequately considered in the siting and deugn of the plant.
33,000 Americans at two military bases within 36 miles, 261,000 Filipinos on Bataan peninsula and 7 million Filipinos in metropolitan Manila only 60 miles to the east would be mortally endangered by a nuclear disaster at this plant.
Because of the extreme gravity of the consequences of a mistaken decision, we are particularly concerned that crucial conclusicns of the engineering con-sulting firm, EBASCO, relating to the site have been sharply challenged by international, U.S. and Philippine agencies and experts.
In fact, we under-stand, charges have been voiced that the site studies for this project were not performed with strict professional integrity but instead systematically understated the risks.
We believe you have a compelling responsibility to look into this.
Because a nuclear accident could have such deadly consequences, the American nuclear industry in its effort to export its technology has a tremendous responsibility to do its work with care and integrity.
Surely it is part of your duty in your export licensing decisions to make sure that responsibility is being met.
We believe this is fully as important as your statutory respon-sibility to ascertain whether the project poses a significant danger to nearby American bases and therefore to American security interests.
In the three years since tM filing ;f the application for export there have been increasing amounts of criticism leveled at this project both in this country and in the Philippines.
The oublic outcry in the Philippines resulted in the construction of the plant being halted as well as the appointment of a special commission to study this project.
On October 19,1979 the Nuclear Regulatory Commission ("NRC") issued an order requesting public comments on the issue of whether or not the NRC should consider the health, safety, and environmental risks of exported reactors in general and this reactor specifically.
We are writing in response to that request.
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The application for this export was originally filed by the Westinghouse Electric Corporation on November 18, 1976 and was followed by two other applica-tions for export of the component parts and the fuel.
The NRC has been charged by Congress through the Nuclear Nonproliferation Act (NNPA) with determining whether or not a nuclear export is inimical to the common defense and security of the United States or poses unnecessary risks to the public health and safety, 42 U.S.C. section 2155.
Further, the NRC as an arm of the United States Govern-ment-must " recognize the worldwide and long-range character of enviromental problems" and with " preventing a decline in the quality of mankind's world enviroment," as required by the National Enviromental Policy Act, 42 U.S.C.
section 4332(F).
These Congressional directives permit the NRC to perform the same analysis on the plant that it would perform on a domestic plant.
This position is supported by the NNPA floor debates in which Senator Gary Hart, Chairman of the Nuclear Regulation Subcommittee said, "It is cle;ar that there can be no realistic separation between the criteria for nuclear exports and the criteria for licensing domestic uses of similar materials and facilities," Cong. Rec.
S. 1099, February 2, 1979.
Of great importance is the apparent disparity between the NRC's approach to this project and that used in the domestic situation.
Since the Three Mile Island accident of March 28, the NRC has had a moratorium on the licensing of new plants.
Can there be any moral justification for failure to demonstrate comparable concern in the case of this export license?
It is imperative that the NRC review the health and safety risks to pre-vent what could very well be unnecessary.bss of life and serious injury to millions of people.
Sincerely, Center for Development Policy, Lindsay Mattison, Director Critical Mass, Richard Pollack, Director (Environmental Defense Fund)*, William Butler Environmental Policy Center, Robert Alvarez, Co-Director Friends of the Filipino People, Boone Schirner (Mennonite Central Committee)*, Janet Ruth Movement for a Free Philippines, Sonny Alvarez National Council of Churches, Washington Office, Jane C. Leeper New Directions, Philip Gibbs Nuclear Informction Resource Services, Betsy Taylor, Executive Director SANE, David Cortright United Church of Christ. (Office for Church in Society),
Washington Office, Gretchen Eick Washington Area of Clergy and Laity Concerned, David Coolridge Women's Division for the United Methodist Church, Joyce Hamlin Womerfs Strike for Peace, Edith Villistr'igo Friends Committee on National Legislation, Frances Neeley
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