ML19220A645
| ML19220A645 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 09/07/1976 |
| From: | Johnsrud J, Kepford C CITIZENS FOR SAFE ENVIRONMENT, Environmental Coalition on Nuclear Power |
| To: | |
| Shared Package | |
| ML19220A640 | List: |
| References | |
| NUDOCS 7904240039 | |
| Download: ML19220A645 (7) | |
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11T13 STAC h'JC'JJJ1 P.EG'JL'a0'iY CC:2!1SSICT l
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i Docket lio. 50-320 In the natter of M.f trepolitan Edican Ccnpany I M, Jercoy Central Tcwcr and Licht Company cp f4 Pennsylv.,nia Electric Ccrpany i
g Three Mile lciand !!cclear Generating St'atien, Units II
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PETITIC*i FOR I::TERVDITIC'i t
I The Environnental Coaliticn on !;uclear Power, an unincorporated crganizatic 1 of individuals and groaps of individualc, on behalf of its i
nenbero do hereby petition the U.S. ?!aclear Regulatory Cor.nission for leave The Luthority fcr this request is granted to interveno in this proceeding.
in the Atenic Ener;y Act of 195h, as anended, Part 2.71h of Title 10 of the f-Code of Federal Reculatiena, and decisicns 73-1776, 73-It67, 7L-13S$, nr.d i
7h-1586 of the United States Court of Appeals far the District of Colunbic.
The Environnental Coalition on 1;cclear Power is a non-profit, 1.
public interest organinstion ec= posed of individuals and croups of individuals who sharc a concern about the purpocc, magnitude, and directicn of the civilian Memberc of the Coaliticn live in the vicinity of nuclear powcr progran.
The nancs of the co-execative directors, tho Threo Mile Island, Unit II.
authorized representative of the Ccalition tefore the Ccnnicsten, and five Three Milo Island II.
are menbcrs who live within approximately 20 miloc of i.
-ll listed tolew.
I 1.
Jadith H..'chnsrad h33 Orlando Erive, State Collece, Penns)1vania 2.
Geori:e L. Doc =cnn R.D. 1, Peach Ibtten, Pennsylvania I
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Chauniy Kepford, Authorb ed Ecpresentative before the Cor.nissicn 2576 Croad Strcet, Ycrk, Penn:ylvania h.
Mary V. Southard 351L 'Jalnut Strcet, Harrisburg, Pennsylvania 5
John J. Sincn 603 Cascace Road, Mechaaicstarg, Pennsylvania Linda (Mrs. Eonald) Fertna J.
E.D. 1, Dauphin, Pennsylvania 7.
Chack Gassert 832 East Chocolate Ave.,
Hershey, Pennsylvania 8.
Hans and Rhoda Hercher 21 Westr.ont Eldg., briarcrest Cardens, Hershey, PA 17033 The nenbers who livo in the noichbcrhced of Three "ilo Island, Unit II feel that the operation of this facility poses an v.:due threat to their lives and material possessiens. Due to tne recent decisicns the United States Ccart of Appeals, District of Colunbia Circuit, 73-1776, 73-1C67, 7h-1385, and 7h-15C6, these ner.ters, and the Coalition as a whole, feel the continued cperation cf Three Mile Island II is illegal because the construction permit for the facility was issued without proper censideration of the
" alternative" of enerCy censervation, with its effect en the cost-benefit analyois, and without proper consideration of the yet unsolved, and possibly unsalvable problrn of radioactive waste disposal. This petition is based on tho contention that there are defects in the cost-tenefit analysis used by thu Applicant to justify censtruction and operation of Threo Mile Island II and approved by the Connission.
2.
The Petitioners (the Environnental Coalition on "uclear Power and its nenbers) contend that the cost-benefit analysis cf the Applicant and the Ccanissica is faulty tecause the recipienta of the " costs" and "bensfits" hnvc not been properly identified. It is clained that the sale of electricity by the Applicant constitutes the prinary benefit of the f acility, with the custoners rocciving tho benefit and, therefore, being the teneficiaries of the plant.
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No reading of a dictionary definition of either "Lcnefit" or %noficiary" can prcduco r.ach a neaning as applied by tho applicant or tho Cemission.
The true beneficiaries of a nuclear power plant are stockholderr.:ho receive profits (if any) due to tne plant's operation. Thus, the only truc tenefits frcn the operr. tion of a niclear powet plant are the dividends paid cat by a Further ore, the utility as a result of the cperation cf the pcwer plant.
" costs" are endcreatinated by the refusal of the Applicant and the Ccr.irsicn to detemine the actual r adiatica doses delivered to real peopic frcn the entire fuel cycle.
Pctiti:ncrs centend that the ctated costs of nuclear power by the 3
Applicant and the Corr.ission assanc catastrophic accident-free operation of nuclear power plants. Such c.n assumption is at odds with the revi:ed con-clusions cf "The Re:: tor Safety Study," WASH-lLOO, bs ttoc r:ncwn as the The U.S.
Raonussen Eeport, and with Section 170(b) of the Atonic Er.ercy Act.
Concress, with the passage of the 1975 exendnents to the Price-Anderson Act, has acknowledged that there nay be more than one nuclear accident requirin~,
payr.cnts under the Price-Anderson Ac't in one year. Cost-behefit analysis of nuclear power plants should include the costs of accidents.
14. Petitioners contend that the cost-benefit analysis of the Applicant and the Cennission assumes a virtully. infinite supply of r elatively low cost I,
" yellow cake," or U C3 In reality, the United States is ncw grossly ove -
3 comitted as f ar as the "known" and "estinated" reserves of the 43 8 are 0
The fuel requircnents for the 238 nuclear reactors operable, concerned.
being toilt, or planned (EPOA News Release, July 28, 1976) with a capacity of 237,000 Un*(o) will require 1,157,000 tens of U c3 for their 30-year life-3 0
tir.os 6t a o.55 capacity f actor. The total estinated reserves of v3 3 are 6LO,CCO tons of raincable U 03, (EDA News Kiiloarc, April 2,1976).
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-h-Neither the Applicant nor the Comission has yet f aced the problen of cither very high U 03 3 prices -- as $1CO to $1,000 per pound of U 03 6 -- or a si.ple Lnavailability of U 05 Ner has the enorr.ous envircreental impact, net energy 3
cost, and dallar cost of nining Icw gr:te coals, dt. ales, ccanites, or even c:a water fcr traniun been acknowicdged by tnc Cor.~.icsion or the Applicant.
Fetitleners center.d that availability cf fuel and energy and envircracntal costs of its extracticn are an integral part of tho nuclear fuol cy cle and therefore rust bc jncluded in r. full and proper cost-benefit analycis of this reactor.
- 5. The Petiticners contend that the rate structure of the Applicant is a pronotional rate structure designed to increase the concurption of electricity by offering declining rates for increased consumption. Such a rate structure rininizes the possibility and practicality of teorthwhile energy conservation efforts. Petitioners centend that a flat rate structure -- one prico for all 2
levels of censa ptica and for all custcn.crs -- or a declining biock rate structure would nake conscr aticn a viable and practical alternative to g
Three Mile Island, Unit II.
6.
The Petitioners contend that the Connission has been totally negligent in its handling of the problera of radioactive wastes in the granting of a con-struction pernit for Three Mile Island II.
As a result, it has been impossible to deternir.s accurately the -costs of cicetricity generated by nuclear plants because the costs of solidification cf spent fuel reprocessing waste solutions and storage of solidified wastes were i nored cr grossly C
anderestimated. Estimates of the costs of solidifying and disposing of wastes frem the Nuclear Fuel Services rance frca a low of O'.;7,000.per year per 10C0 !Gl(c)
I plant to $35,0CO,000 per year per 10001~4(e) plant. (Sce %1temative Processes for Managing F.xisting Cors.ercial High-Level Radioactive Wastes," ::U!iG-CC!:3.)
Wnile the $67,000 figure nay represent an insignificant a&'iticn to tho annual 9
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reactor operation costs, the $36,000,000 could cacily double the annual operating If past experience for estir.ating costs ty the AICA;RC can serve as a costs.
guide, the high figure F.ny prove to be the lcv. Such costs shculd be included in the cost-bcncfit analysis.
Petitleners contend that the cost-benefit analysis of Threc Mile Island II 7.
has teen biased in faver of na:lcar power by greatly underestinating spent fcel reprocessing costs and by the Comniacien offering a credit for re:orered pla tcniun. Since there has not yet been any successful, cconemical, and con-plete reprecessing of reactor wastes to the solid stage, costs nast b: largely Since the recycling of plutonium is net prescotly a connercial anknown.
reality, the offering of a plutonium credit for yet unrecovered platonium which may not be recycled is prenature.
8.
letitioners therefore contend that, due to the above unresolved iscues regardir.c ccmpliance with sec.102 of the Naticnal Envirennental Policy Act by
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the Cor.nission, the construction pernit for Three Mile Is?and, Unit II should be rescinded innediately, and construction halted pending recunptien of public hearings and resolution of these matters.
9 Petitiene s f arther request the Conmissien to grant financial assistance to the intervenors under the authcrity of Sec.102 of the National Environmental Policy Act.
Petitioners have made similar requests in the past, and have ret with only denial or celay. Petitleners call the attentien of the Concissien to the recent court decision, York Connittee for a Safe Environ-rent, et. al., vs. Nuclear Regulator Cennission, No. 7h 023, and the connents therein regarding public interest litigants. Petitioners request the amount nocccoary in. oorder to naet legal, technical, and procedural expenses g
e otherwise not available.68-322
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I,Chauncey Kepford, a te.ber of the Ex.ecutivo Scarl of the Environ antal Coalit3e i en 2:uclear fever, do a teat-that tho tateacnta in ti>1s IITITIc:: 202 INTR.%T:' TIC:;
are true, to the best of t.J kno >ledr,c, infor._ation, and belief.
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Chauncey Kericra / '
25F.6 Broad tt.
e York, Pa. 17401 Sworn crd nub crlhed to befom r i thin /d# dny of Au;,nt, 1976, I
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UN111.D STATES MUC1J.AR REGULATORY CO:'*f1SSION In the taat ter of Docket No. 50-239 and 50-320 Hetropolitan Edison Corrany Jerr.cy Central Power an:1 1.lght Cerpany Ft I # R, Pennnylvania Electric Company p
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s 4 ltd I, Judith H. Jchnsrud, as the Co-Executive Director of the petiticner, tha Environ nental Coalition on Nuclear Power.
This non-profit public interest citizens' organization is composed of individuals and citizens' groups who reside in Pennsylvania, New Jersey, and Delaware.
On behalf of the abova-named petitioner, I do declare that the Er.vironmental Coalition en Nuclear Power has duly authorized, by approval of its c1ccted Executive Board, Dr. Chauncey R. Kepurd to eppear and act on behalf of the members of the Environ. ental Coalition en Nuclear Power in all matters pertaining to our interests before the United States Nuclear Regulatory Comnission.
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Judith H. Johnsrud 433 Orlande Avenue t
State College, Pennsylvania
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Sworn and pub.ribed before me this A tday of August, 1976.
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