ML19254C852
| ML19254C852 | |
| Person / Time | |
|---|---|
| Site: | 05000574 |
| Issue date: | 09/28/1979 |
| From: | Mattison L CENTER FOR DEVELOPMENT POLICY |
| To: | |
| Shared Package | |
| ML19254C846 | List: |
| References | |
| NUDOCS 7910180015 | |
| Download: ML19254C852 (6) | |
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the matter of
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Application No. XR-120 WESTINGHCUSE ELECTRIC CORP.
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Docket No. 50-574
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(Exports to the Philippines)
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Application No. XCOM 0013
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Application No. XSNM0 1471 AFFIDAVIT City of Washington District of Columbia: ss:
Lindsay Mattison swears and deposes as follows.
I am the Director of the Center for Development Policy, a project of The International Center, a District of Columbia nonprofit corporation of which I am the president.
CDP monitors the flow of resources from the United States to developing nations; conducts independent nonpartisan research and analysis of U.S.
development programs and policies and their domestic and international effects; and disseminates the results of its analysis to the public ano interested public officials.
For well over one year, CDP has focused its primary attention upon United States exports of nuclear power plants.
During tnis year, most of the research in the area has centered around the Napot Point reactor project ("PNPP-1"), tne subject of tnese proceedings.
Our attention was drawn to PNPP-1 cecause cf tne serious questions it raises and the cataclysmic risks it poses.
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During the course of its research on PNPP-1, CDP has undertaken to review every available public document concerning this project.
Both the PSAR and the PSIR have been thoroughly scrutinized by CDP as well as an extensive analyis of the IAEA safety mission report on this project.
These reports have given us insight into the problems posed by PNPP-1 and the harm that may result from its construction.
I have studied the Nuclear Nonproliferation Act of 1978 and the regulations for nuclear export proceedings promulgated under the authority of that Act.
It is my understanding that the Commission when ruling on petitions for intervention vill consider among other matters (1) "whether a hearing would be in the public interest" and (2) "whether a hearing would assist the Commission in making the statutory determinations required As is already evident, CDP's intervention would be in the public interest and would certainly assist the Commission in making the requitad determinations.
CDP has retained the services of David J.
Leeds, a noted seismologist who has been a consultant on approximately 30 nuclear reactor projects in this country and abroad.
CDP has made available to Mr. Leeds copies of all the technical documents in these proceedings--e.g. the PSAR, the PSIR, tne IAEA safety mission's report--and at CDP's expense Mr. Leeds traveled to the Philippines to give testimony before the Puno Commission as well as view firsthand PNPP-l's site.
Mr. Leeds is continuing to study i189 12I 2
this project and has submitted to both the Puno Commission and the NRC a detailed report of his findings on PNPP-1.
CDP expects that if it is granted intervention and a hearing is held in this matter that Mr. Leeds would provide extensive testimony on PNPP-1, its risks and hazards, and detail the deliberate and consistent pattern of EBASCO and Westinghouse of minimizing the risks attendant to this project.
CDP has also retained Christopher G.
Newhall of Dartmouth College, a vulcanologist with extensive field experience in the Philippines.
He has had an opportunity to study the documents submitted by EBASCO and Westinghouse as to the volcanic risks posed to PNPP-1 by, among other volcanoes, Mt. Natib, and will testify that there has been a consistent pattern in those reports of downplaying of the volcanic risks.
Mr. Newhall has had experience with volcanic nonitoring systems and is expected to provide testimony concerning the minimal utility of the volcanic monitoring system suggested by the IAEA mission.
He is continually studying technical material relayed by CDP and
. vations and conclusions on an ongoing basis.
submitting his ob:
CDP has retained the services of Walter Berry, a meteorologist with substantiui experience who has studied the weather conditions around PNPP-1 and metropolitan Manila and will testify as to the hazards posed by an atmospheric leak of radiation from PNDP-1.
He is also consulting with CDP on an ongoing basis.
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CDP was responsible for bringing to the attention of the NRC as wel' as the State Department Walter Newcombe.
Dr. Newcombe was a member of the EBASCO field team in the Philippines who resigned because, in his opinion, the geologic and seismic surveys undertaken by EBASCO prejudged the situation in the Philippines and resulted in a consistent pattern of downplaying the seismic and volcanic risks attendant to PNPP-1.
CDP is presently negotiating with Dr. Newcombe's employers and attorneys in order to have Dr. Newcombe voluntarily participate in these proceedings.
CDP will provide to the Commission Dr. Newcombe's testimony through his voluntary appearance or, once granted intervention, subpoena.
CDP nas also been in close contact with several groups in the Philippines who have studied this project thoroughly and who rely upon CDP to bring these problems to the attention of the NRC.
These groups include the Bataan chapter of the Integrated Bar of the Philippines, whose attorney, Jaime Guerrero, was brought to the NRC on two occasions by CDP in order that t h_
NRC staff hear the concerns raised in the Philippines by PNPP-i.
Mr. Guerrero will be returning shortly to the Philippines and will stay in constant contact with CDP in order that further information developed by his organization can be relayed to CDP for submission to the NRC.
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CDP has also attempted to ascertain through the Freedom of Information Act the participation of other branches and agencies of the United States Government in the evaluations of this project.
CDP has had the opportunity to meet with the United States State Department on this matter, as well as supply the Department of Defense information about the risks and hazards to U.S.
defense and security posed by PNPP-1.
CDP will continue to compile information about the federal government's study and avaluation. of this proje;t as part of CDP's ongoing review of PNPP-1.
It should be noted that CDP, in its original petition filed at the 1RC, was the first to raise the argument that PNPP-l's proximity to the United States bases in the Philippines, Subic Bay Naval Station and Clark Air Force Base, threatens the " common defense and security" of the United States and the Philippines.
CDP is continuclly studying this matter and consulting with experts in the field of foreign relations and international politics to more thoroughly understand the need for the United States bases in the Philippines and the risks to U.S. common defense and security that woJ1d be posed by the emergency closing of these bases due to radioactive contamination.
CDP expects that at a public hearing in this matter testimony by experts in these fields will be produced to assist the Commission in judging whether the project is " inimical" to the common defense and security.
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CDP's intervention in this matter is very much in the public interest.
CDP is the only group other than the applicant and the NRC who has had the opportunity to thoroughly review and study PNPP-1.
CDP is the only group of interested citizens who has had the resources to retain experts to study this matter.
It is absolutely essential for the Commission to allow CDP's intervention so that a full and fair presentation of all the evidence concerning PNPP-1 can be brought before the Commission and the Commission not be faced with a one-sided presentation of the evidence by the applicant in this matter.
N Lindsay Ma t t id o n i
Subscribed and sworn t before me this dav of 1979.
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