ML19259D394
| ML19259D394 | |
| Person / Time | |
|---|---|
| Site: | New Haven |
| Issue date: | 10/01/1979 |
| From: | Daly H, Weber S ECOLOGY ACTION OF OSWEGO |
| To: | |
| Shared Package | |
| ML19259D393 | List: |
| References | |
| NUDOCS 7910180428 | |
| Download: ML19259D394 (7) | |
Text
p lx UNITED STATES OF AMERICA M
~
f n .N o T.
NUCLEAR REGULATORY COMMISSION h .
', /g g
In the matter of ) b D 4 New York State Electric and Gas Co. ) Docket No. STN 50-596 .
and Long Island _ Lighting Co. ) '*' / '
New Haven 1 and 2 ) October 1, 1979
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ -)
SUPPLEMENT TO PETITION TO INTERVENE CONTENTIONS BY ECOLOGY ACTION OF OSWEGO -REVISED OCT. 1, 1979 Contention 1 Applicant (and NRC Staff analysis) has failed to demonstrate that the two co-applicants (NESEG and LILCO) and/or the N.Y.S. Power Pool need the power to meet growth in total energy use and/or peak demand. Applicant's projections are erroneous because:
(1) Applicant's total energy use and peak demand predictions fail to adequately consider:
- a. impact of mandatory and voluntary electricity conservation efforts in the residential, commercial, and industrial sectors (e.g., redesign of refrigeration systems, improved building design, more efficient industrial processes);
- b. impact of substitution of alternate fuels by the residential, commercial, and industrial sectors (e.g., wood stoves and furnaces, small scale solar panels, small-scale wind mills, co-generation);
- c. impact of changes in rate structure under consideration in N.Y.S. (e.g.,
(2) Applicant's forecast methodologies are inadequate: they have proved un-reliable in the past, producing forecasts which have been consistently too high (compare the predictions of the utilities in each of the 149-b Reports will the actual peaks occurring in subsequent years);
(3) Applicant's projections are based on an incomplete data base. Examples include: current appliance and machine efficiency and potential for improvement in appliance efficiencies, saturation of alternate energy forms for individual customer use and potnetial for increase (e.g. , wood stoves, solar panels), contribution to peak load by different customer classes, electricity conservation potential by different customer classes, quantification of past and present conservation efforts, and population changes (e.g., icnigration and emigration rates, birth rates);
Contention 2 Applicant (and NRC Staff analysis) has inadequately considered alternatives to the proposed nuclear and coal plants, and statements concerning alternatives feasible in the early 1990's in the ER contradict the information released on April 1, 1979, in the N.Y. Power Pool's filing under Art. III, Section 5-112 (see in particular volume 3, ch. 2). (Co-applicants are members of this Power Pool.) The Applicant has incorrectly dismissed the following alternatives:
(1) large scale wind machines on Lake Ontario for supply of power of NYSEG, and on the Atlantic Ocean for supply of power to LILC0; (2) "Tornedo" building concept for large and small scale wind machines; (3) burning of garbage in conjunction with coal in either small scale plants or large scale plants; (4) hydroeleccric power; (5) small scale wind mills and small scale solar panels; (6) fluidized bed combustion; (7) fuel cells (8) coal liquefaction; (9) thermal gradients between " waste" heat discharge from existing power plants and the existing receiving waters; (10) wave power .
1167 356 Whbde@ P
m 8 .
2 (11) conservation of energy techniques, ranging from voluntary to mandatory measures, and from small scale to large scale efforts. Applicants should prepare a detailed study of conservation potential in their service territory; (12) supplying power, if needed, by purchase of power from other utilties within the United States and Canada.
Contentica 3 The Applicant has failed to provide the NRC with an adequate assessment, discussion, and decisions regarding alternative fuel sources. Numerous technologies are rejected (e.g., fuel cells, hydroelectric, wind, biomass) on the basis that they could not provide the total 2500 MW capacity in the year of need. In f act','
load growth does not grow in 2500 MW units, and it is incorrect to dismiss small-scale generation alternatives for that reason. The Applicant's decision concerning primary fuel mode was prematurely made.
Contention 4 The Applicant's site selection process (and NRC Staff analysis) is inadequate and the discussion in Section 9 of the ER is not sufficiently complete for proper development of appropriate alternatives as required by the National Environmental Policy Act of 1969. The Applicant's site selection process:
(1) failed to adequately consider numerous small sites near load centers (e.g.,
eight sites with potential for one 300 MW plant, sixteen sites with potential.for one 150 MW plant), (see section 9.2.2.1, part 2);
(2) gave u rdue consideration in its identification of recommended sites to low population density by attributing too much benefit to low population considerations (see Figure 9.2-10 for example);
(3) the consideration of population in identification of sites constitutes impermissible discrimination against persons living in low population areas by restricting siting of nuclear power plants to such areas. Such otscrimination results because the additional risk imposed on residents of low population areas to the hazardous consequences of exposure to accidental release of radioactive fission products; (4) failed to adequately consider the benefits of utilizing existing spoiled unfilled sites (see N.Y. Power Pool long range planning reports for description of numerous unfilled sites with existing power plants) vs. selecting a virgin site.
Contention 5 The Applicant's site screening process (and NRC Staff analysis) to identify candidate sites was inadequate: it eliminated sites for inadequate reasons and accepted others because it was not sensitive to other important factors.
Contention 6 The Applicant (and NRC Staff analysis) has not adequately considered the adverse impacts on existing health f acilities and services (e.g., hospitals, medical personnel and equipment), within 50 miles of the proposed primary site (e.g.,
New Haven, Mexico and other towns,0swego and other cities) during conceruction and operation of the plants. The Applicant has:
(1) underassessed the adverse impact on existing facilities and services of the increased work force and their families during normal construction activities; (2) failed to adequately consider the impacts on the facilities and services if an accident not involving radiation exposure should occur (e.g., scaffolding of cooling tower collapses, resulting in numerous injuries);
(3) failed to adequately consider impacts on the facilities and services of an accident (excluding class 9) involving radiation to plant workers during operation of the plant; (4) f ailed to adequately consider the impact on the f acilities and services of an accident (excluding class 9) involving radiation releases beyond the site boundary.
1167 357
3 Contention 7 The Applicant (and NkC Staff analysis) has failed to provide adequate assurance that they can finance construction of the proposed plants as required by Part 50 (10 CFR 50.33(f)). In fact, there is evidence that LILCO is not a serious co-applicant, one reason being its inability to finance the project (see Ecology Action of Oswego Case 80008, Motion for Dismissal, March 20, 1979, and Interlocutory Appeal to Commission on Denial of Motion for Dismissal, April 26, 1979), and both NYSEG and LILCO have requasted and been denied CWIP for this project.
Contention 8 The Applicant (and NRC Staff analysis) has inadequately assessed the advarse effects of the extensive high voltage (765 KV) transmission required from the New Haven site to (a) the grid, and (b) from entrance to the grid to load centers, on:
(1) the biological health and stress of humans, animals, and plants (wildlife and agriculture), living, working, crossing, and/or playing in its vicinity, due to its electric and magnetic fieles and ozone production; (2) the psychological health of humans living, working, or playing in its vicinity (caused for example by noise, TV and radio disruption, fear of shock):
(3) the increase in number of communities and individuals impacted by its construction and operation by selection of the primary and alternate sites vs. the number impacted if the power source were located adjacent to load centers; (4) increased economic costs due to loss of electricity from the long distance transmission required (Note: more than enough power is already generated in the Oswego area for the existing nearby load centers, thus requiring that power be transmitted long distances).
Contention 9 The Applicant (and NRC Staff analysis) has underestimated the decrease in reliability of transmission because of:
(1) the long distance of the primary site to load centers; (2) the huge transmission requirements already needed for existing plants and those under construction (NM#1, NM#2, Fitzpatrick #1, Oswego #1-6), and the possibility of " bottled-up" power and system instability due to large amounts of power generated in one area; (3) the increased potential for large blackouts in N.Y.S., if human error, terrorism, or " acts of god" disrupt sections of the transmission grid, due to the huge percentage of power for N.Y.S. generated in this area.
Contention 10 The Applicant's decision process (and NRC Staff analysis) concerning site and fuel mode failed to select the cheapest, safest, and most environmentally compatible site and mode (e.g., it failed to consider all cost to society).
Contention 11 The Applicant (and NRC Staff analysis) has inaccurately assessed the adverse impact of the proposed plants on recreation within a 20 mile area of the site. The Applicant has:
(1) inaccurately assessed projected increases in recreation level (e.g., increases in fish stocking program, development of new marinas and harbors, development of a cross-country ski center);
(2) failed to analyze the adverse ychological impact on potential users of recreation areas of past and future " Browns Ferry" incidents and "3 Mile Island" ace'Jents, and the resultant adverse financial impact on the recreation industry when people avoid recreation aras near nuclear plants (e . g . , the numerous people who have still not returned to the 3 Mile Island area, and the even more numerous people who will now avoid the area);
(3) failed to analyze the adverse impact on the surrounding communities from the financial impact on the recreation industry should an accident (less than Class 9) occur
,(4).f.aialdd to analyze the magnitude of the adverse aesthetic impact of the ,roposed facilities on recreational sports such as: birding (e.g., at the renowned Derby Hill),
i 16/ $58
p.
4 watching sunsets over Lake Ontario, particularly from the eastern shores of Lake Ontario, e.g., Selkirk Shores State Park (their beauty is similar to those of Acapulco), hiking, horsebackriding, swi= ming, boating, camping, picnicking, cross country skiing, fishing, snowmobiling, motercycling, etc.
Contention 12 The Applicant (and NRC Staf f analysis) has underestimated the impact of the combined continuous thermal aqueous discharge from the Oswego units #1-6, NM#1, NM#2, Fitzpatrick #1 on fish, benthic, and algae populati;n and its impact on reliable cooling water (e.g., recent algae bloom secreen clogging incident at Nine Mile Point). In addition, Applicant (and NRC Staff analysis) has underestimated the impact of interaction between the operation of the intake and discharge stuctures.
Contention 13 The Applicant (and NRC Staf f analysis) has u rderestimated the adverse impact of the proposed cooling towers on:
(1) aesthetic impact on local residents and people using the area for recreation purposes; (2) hazards of chemicals released into the atmosphere and lake on terrestrial and aquatic ecology and agriculture; (3) hazards of the intermixing of the Oswego #1-6 oil fired (over 2000 MW) unit's atmospheric plume and the atmospheric plume of the proposed cooling tower (e.g.,
acid rain on agriculture, homes, Tughill and Adirondacks region);
(4) . increased icing and snow fall in the surrounding snowbelt areas.
Contention 14 The Applicant (and NRC Staff analysis) has failed to provide reasonable and economic uses for " waste" heat from the proposed nuclear plants (e.g., aqua-culture, growth of forests for wood production, co-generation), and has failed to adequately compare the advantages of use of waste heat from coal plants vs. nuclear plants.
Contention 15 The Applicant (and NRC Staff analysis) has failed to propose an adequate radiation monitoring program during plant operation because:
(1) there are an insufficient number of monitors at various distances from the proposed site; (2) the radiation monitoring system does not ensure that releases from manmade sources of radiation such as releases from the NM#1 and Fitzpatrick #1 plants will not inflate background radiation estimates, thus resulting in an underestimation of the proposed New Haven releases; (3) the radiation monitoring system will not adequately sort out the source (Nine Mile Point site vs. New Haven site) associated with the releases.
Contention 16 The Applicant (and NRC Staff analysis) has failed to adequately estimate the radiation doses received by residents along the truck routes for shipments offsite of low, medium, and high level waste, and has thus failed to assess the magnitude of the resulting health effects.
Contention 17 The Applicant (and NRC Staff analysis) has underestimated the adverse health effects (c.g., cancers, leukemias, all genetic dysfunctions) of the proposed nuclear plants on the surrounding human populaticn due to normal operation of the plant, and will not be able to adequately determine the health ef fects given the proposed monitoring system.
I 16 / jL59
5 ** .
Contention 18 The Applic% : (and NRC Staf f analysis) has underestimated the adverse '..ealth effects (e.g., cancers, leukemias, all genetic dysfunctions) of the pro; osed nuclear plants on the surrounding human population due to releases during accidents (less than class 9), and will not be able to adequately determine the health ef fects given the proposed monitoring system.
Contention 19 The Applicant's (and NRC Staff analysis) monitoring program (including their reliance on N.Y.S. monitoring programs) is not of sufficient magnitude for determining health effects and bioaccumulating factors used in determining concentration of radioactive 1sotopes in wild animals (land and water), domestic animals, dairy and beef cattle (agriculture), and humans (including mother's milk).
Contention 20 The Applicant (and NRC Staff analysis) has failed to accurately assess the incremental health risk to the surrounding population (within 30 miles) due to the addition of the fourth and fifth nuclear plant due to normal radiation releases and those resulting from an incident or accident (less than class 9).
Contention 21 The Applicant (and NRC Staff analysis) has underassessed the potential risk of a serious accident by relying on such reports as the Rasmussen Report, (less than class 9) at the proposed nuclear plants,and has thus underestimated the resulting health effects of the proposed plants.
Contention 22 The Applicant (and NRC Staff analysis) has failed to assess the economic, social, and environmental and health effects of a class 9 accident at the proposed plants.
Contention 23 The Applicant (and NRC Staff analysis) has failed to estimate the probability of a class 9 accident due to the interaction between human error, design error, contruction error, quality assurance error and sabotage (taken singly or in groups of two, three, four, or five), and has thus underestimated the economic, social, and environmental and health effects of the proposed nuclear plants.
Contention 24 The Applicant (and NRC Staff analysis) has failed to estimate the probability of a less than class 9 accident due to the interaction between human error, design error, construction error, quality assurance error and sabotage (taken singly or la groups of two, three, four, or five), and has thus underestimated the economic, social and environmental and health effects of the progsed nuclear plants.
Contention 25 The Applicant (and NRC Staff analysis), by failing to assess the probability and consequences of a class 9 accident has underestimated the impacts mentioned in Contentions 6, 11, 18, 20, 21, and 24.
Contention 26 !l6/ 360 The Applicant (and NRC Staff analysis) has failed to:
(1) determine the feasibility of developing an adequate emergency plan and evacuation plan in both the rural, urban, and recreation areas within 30 miles (including the Syracuse metropolitan area) of the site; (2) determine the feasibility of developing an adequate emergency plan and evacuation plant for the institutional population within 15 miles of the proposed site (29,996, see Table 2.1-32), including the 9,383 (see same Table) people concentrated at the State University of New York College at Oswego; p, 3 (3) determine the cost of developing an adequate emergency plan and evacuation plan for the utility, state, and local governmental agencies, and has thus f ailed to include these costs in alternate site and mode selection compatisens.
a -
- 6 Contention 27 The Applicant (and NRC Staff analysis) has failed to outline procedures to be employed to avoid computer program errors in design of the nuclear plants (e.g.,
see cause of shutdown of five nuclear reactors including Fitzpatrick #1).
Contention 28 The Applicant has failed to assess the increased risk and increased radiation exposure from a low and medium level nuclear waste incinerator constructed on or near the site to handle wastes from the proposed New Haven nuclear plants. (This contention will be withdrawn if the Applicant submits legal documents assuring it will never constact such a facility). To avoid incremental decision making, the Applicant's intention cust be determined now.
Contention 29 The Applicant has friled to accurately assess the increased risk to the surrounding population of storing spent fuel on the site. This must be done for several realistic scenarios including assumptions for shipments offsite every 5, 10, 15, 20, 25, 30, 35, and 40 years.
Contention 30 The Applicant's cost / benefit analysis (and NRC Staff analysis) is in error because it has substantially underestimated the cost >f electricity produced by the proposed nuclear pinats. Applicant's cost calculations are erroneous because it is based on inaccurate assessments of:
(1) the cost of decommissioning (too low);
(2) fuel and operating costs for the lifetime of the nuclear plants (too low);
(3) the life expectancy of the plant (too high);
(4) its assumed capacity factor (69%) (too high);
(5) the cost of replacement power when plants are not operating (has not been included in the total cost);
(6) the capital costs (too low);
(7) the escalation factor for capital costs (too low);
(8) the cost of borrowing money to build nuclear plants (too low);
(9) the cost of transmitting electricity (too low);
(10) the insurance rates (too low);
(11) the cost of guarding the plants against sabotage (too low);
(12) the cost of the on-site emergency plan (too low);
(13) the costs of onsite spent fuel storage (too low);
(14) the cost of disposal of nuclear waste (too low);
(15) cost of a core meltdown (partial or cceplete) which shuts down the proposed plants after a few months or years of operation (e.g., 3 months as in 3 Mile Island);
(16) cost of a premature shutdown of the proposed nuclear pl ants due to legal, safety, or accident related events at the New Haven plants, the Nine Mile Point site, or at any nuclear plant in the world.
(17) cost of all changes in design, construction practices, emnloyee trair.ing practices, operating procedures, etc., it will be required to make as a consequence of the 3 Mile Island accident.
(18) cost of redesign due to corrosion, cracking, and denting problems
, experienced at other plants.
Contention 31 The Applicant has failed to analyze or has underestimated the following costs which must be included in the final cost / benefit determination. These costs are:
(1) the health care costs to the surrounding population of the adverae effects on health due to routine and accidental radiation release from the plants; (2) the social (e.g., police state), psychological (e.g., fear, anxiety, stress),
and economic cost to the surrounding population os significantly upgrading due to the addition of two nuclear plants of the the offsite emergency plan and evacuation lJ6/ 361
7 '*-
plar. As regards required facilities (e.g., Coast guard, hospitals, schools) and serr. :es (e.g. , local and state police, fire, civil defense and preparedness, ambulance);
(3) the decrease land values around the site (especially since 3 Mile Island);
(4) the possibility of decreased expansion of industrial growth in the county due to existence of five nuclear plants, thus diminishing job opportunities and the tax base; (5) the departure or failure to expand existing industry to esetpe risks of nuclear power (e.g., Nestle's Chocolate, Miller Brewery, Schlitz orewery, Alcan),
thus diminishing the tax base and job opportunities) (Nestle is reevaluating use of of local milk);
(6) the increased cost of electricity which applicants will charge as a consequence of the plant being built; (7) the economic, social, and ecological costs on the Oswego Cou try area of two decommissioned nucl(ar plants (e.g., land loss, existence of huge guarded fence);
(8) the total number of immediate and latent human deaths and illnesses caused by all phases of the nuclear fuel cycle for the entire life of the radioactive substances produced (illness also includes an increase in the aging process);
(9) the unavailability of nuclear fuel after 5, 10, 15, 20. 25, 30 or 35 years of operation; (10) the incremental economic, social, environmental, and health impact due to the incremental threat of attack to the area in wartime, because of the increase from three to five nuclear plants in the area; Contention 32 The Applicant's oil substitution argument is false, due to the fact that Applicant has failed to accurately assess costs mentioned in Contentions 30 and 31, and has failed to adequately assess alternative strategies to decreasing oil consumption Contention 33 The Applicant's (and NRC Staff analysis) seismic analysis underestimates the potential for a large carthquake in the New Haven area during the lifetime of the proposed plants (see developments of seismic concerns in the entire area, e.g., Nine Mile Point).
Contention 34 The Applicant (and NRC Staff analysis) has failed to completely analyze the effects of a loss of coolant accident, particularly with respect to the impact of hydrogen generation.
Contention 35 The Applicant (and NRC Staff analysis) has failed to assess and include in the cost analysis, the increased cost of selecting the nuclear; reactor type and manufacture more than 14 years (probably closer te 20-25 year if ever), prior to operation of the nuclear plants (e.g., due to design changes, penalties from supplier ude to delays, cancellation of the order, modification in the order, changes in the supplier) .
Note: At the advice of the NRC Staff's attorneys, we have included in the above coctentions that the NRC Staff's analysis is either inaccurate, incomplete, etc.,
even though there has been no NRC Staff analysis issued to date. We understand that inclusion of this statemetn will not jeopardize or influence the contentions in any way.
Sutmitted by, jj{/
}{}
Service address: 't' L"" L~ '
~
Ecology Action c/o baly Suzanne Weber, Prerident, Ecology Action W. Rive Rd. RD#5 \ -'
Oswego, N.Y. 13126 *~~ -- -
Helen Daly, Ecology Action, Interventica Coordinator