ML19261A645

Suppl to 780905 Petition to Intervene.Includes Notice of Appearance,Clarification of Petitioner'S Interest & Standing & Statement of Contentions.Renews Request for Financial Help from Nrc.W/Certificate of Svc

ML19261A645
Person / Time
Site:	Susquehanna
Issue date:	01/15/1979
From:	Johnsrud J Environmental Coalition on Nuclear Power
To:
References
NUDOCS 7902050272
Download: ML19261A645 (12)

Text

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5 ' MELIC DOCU.11EST ROUM ENVIRONMENTAL COALITION ON NUCLEAR POWER 215 884 6262 isecutive Directors: George Boomsmo-R D. si. Peach Bottom, Pa.17563 717 548 7836 >vd.th Johnsrud -433 Orlando Avenue. 5 tore College. Po.16801 814 237 3900 C3 3

UNITED STATES OF AIELICA C* 4 \

NUCLEAR RfDULATOIE COMMISSION / g

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Before the Atomic Safety and Licensing Board .~ , y, Q In the Matter of

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) s.Q PENNSILVANIA POWER AND LIGHT COMPANY and 8

) Docket Nos. 50-387 ALLEGHENI ELECTRIC COOPERATIVE, INCe

) 50-388 (Susqnahnnnn Steam Electric Station, Units 1 and 2) )

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AMEND:EITS TO THE PETITION FOR LEAVE TO INTERVENE FILED BT THE BIVIRONMENTAL COALITION ON NUCLEAR POWER The Environmental Coalition on Nuclear Power (ECNP) submits the following supple =ent to its Septe=ber 5, 1978, Petition for Leave to Intervene in the captioned proceeding to address three matters:

A. Notice of Appearance B. Clarification of retitioners' Interest and StanM ug C. Statement of Contentions and Their Bases Notice of Appearance Drs. Chauncey Kepford and Judith He Johnsrud, Executive Board me=ber and Co-Director, respectively, of the Emrironmental Coalition on Nuclear rover, having been duly authorized by the Executive Board of that organization to represent me=bers' interests in any and all 7 9 0 2 0 5 0 ,2 7A

administrative and legal proceedings, herewith enter their notice of appearance as representatives of these Petitioners in the proceedings related to the matter captioned above.

Clarification of Petitioners' Interest and Standing In the Septa =ber 5,1978, Petition for Leave to Intervene, the Petitioners' (ECNP) representative, Dr. Johnsrud, advised that an affidavit setting forth interests of ECNP members on the basis of residence near Susquehanna Steam Electric Station, Units 1 and 2 (Susquehanna) would be filed separately. Such an affidavit was filed on September 8, 1978, by Dr. Oliver J. Larmi, R.D. h, Bloomsburg, rennsylvania; Dr. Larmi is a member of the Executive Board of the Emrironmental Coalition on Nuclear Power; to the best of my knowledge other signators of his affidavit are also members of ECNP. In addition, Dr. Johnsrud is employed at Lewisburg, Pennsylvania, within a forty mile radius of Susquehanna.

Statement of Contentions and Their Bases

1. Petitioners contend that the analysis of the effects of the uranium fuel cycle on human health from the beginning to the very end of the fuel cycle, have been serious 3y mis-representea and underestimated. In particular, the health consequences of the long-lived isotopes (long co= pared with plant lifetimes) have yet to be considered for the " full detox!.fication period" of each and every long-lived isotope released, or caused to be released to the environment, by the operation of Susquebanna (See NRDC v. NRC, $h7 P. 2d 633, 639 at n. 12). Isotopes such as Tc-99, Se-79, I-129, Cs-135, and

the alpha-particle emitters have, to date, eluded full environmental analysis by those responsible for such analysis.

2. Petitioners contend that the cost-benefit analysis performed by the Staff and Applicant is wholly falsified.

This cost-benefit analysis does not represent an analysis

" conducted fully and in good faitha (See Calvert Cliffs' Coordinating Cor:mittee v. USAEC, D.C. Cir.,1971, slip -

opinion, p. 11). Instead, the analysis conducted was designed to arbitrarily reduce environmental and health costs while simultaneously inflating alleged benefits.

In particular, radiation exposure from various isotopes, both short- and long-lived, is compared with various back-ground sources of radiation exposure. Yet no justification has thus far been advanced for comparing any cost attributable solely to the operation of Susquehanna with costs attributable to background radiation sources which exist independently of the Susquehanna reactors. In addition, this comparison of radiation attributable to Susquehanna with background radiation distorts completely the cost-benefit analysis of Susquehanna because the benefit side of the analysis receives no such comparison. No comparison of the energy generated by Susquehanna is made, for example, with the solar energy incident on the United States. Further, tne analysis is raulty because it neglecte completely the health costs due to all of the long-lived radioactive isotopes released, or caused to be released, to the environment by the operation of Susquehanna. After all, "The Co= mission's prime area of concern in the licensing context

. . . is public health and safety!' (Vermont Yankee v. NRDC, U.S.

slip opinion, p. 28,1978).

3 Petitioners assert that known and assured reserves of uranium are insufficient to supply the lifetime fuel required for Susquahn"nn 1 and 2 in a growing nuclear economy. The

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historic growth rate for nuclear generated electricity, a measure of uranium consumption, is about 32% annually, for the years 1961 through 1977. Even if this growth rate drops more than in half to 15%, all of the estimated reserves of uranium will have been consumed prior to the end of the thirty year life of Susquehanna 1 and 2. As a result, much higher fuel prices will result, and environmental damage will increase greatly with the mining of ever lower grade cres. The problems of disposal of mill tailings, now deemed trivial by some, will rapidly mount.

Yet no environmental impact assessment has been made of the interrelated fuel supply-mill tailings problems as ur:mium is consumed, as these problems pertain to the entire operational lifetime of Susquehanna.

h. Petitioners contend that there is no need for Susquehanna.

The information supplied by the Applicant shows that, with very modest increases in electrical energy conservation efforts, all of the need for Susquehanna 1 and 2 will disappear completely.

Applicant's divironmental Report, (ER, p.1.1-2) gives load growth ranges. Table 1.1-15 of the ER shows that at the Very Low Growth rate scenario, the entire output of Susquehanna 1 and 2 will be available for sale outside the service area of the Applicant as the units come on line. The conservation programs suggested by the Applicent are not designed to encourage either meaningful energy conservation or efficient energy use. Instead, these programs are aimed at encouraging continued electrical energy usage, regardless of whether electricity is the most efficient form of energy for the job at hand or not. Th< Applicant has not considered the alternative to Susquehanna, as 2 equired by NEPA, of more strict energy conservation measures. For example, there is no comparison of cost for upgrading the thermal insulation in existing residences and commercial buildings in the service area of the Applicant with the cost to complete the Susquehanna plant.

The discussion of the Applicant's anticipated load growth is based on increased use of electricity for space heat in residences and co==ercial establishments, together with the continued practice of

over-use of electric lighting, both for indoor use and for ad-vertising w.d display.

In addition, the Applicant presents no discussion of the negative impact of increased electrification of industrial opera-tions (through " modernization," to become more "efficienta) upon employment. This i= pact is readily seen by comparing the number of workers needed to achieve a given output of an " inefficient" plant with the cmployees needed in a modern, efficient, mechanized plant to achieve the same output. The Applicant thus grossly underestimates the unemployment created by the Applicant in its service area.

5 Petitioners contend that the models used to calculate individual and population doses are inaccurate and obsolete.

These deficiencies are compounded by the arbitrary selection of data for the purpose of underestimating radiation doses. In particular, the milk transfer coefficient for iodine has been underestimated (See Health Physics, }$,, p. hl3-16,1978). In aMition, these models use factors which convert alpha-particle dose in rads to rems which are far too low (See Health Physics, &

p. 353-60, 1978), md which underestimate the radiation effect, on a per rad bar , for che va7 low energy beta and ga=ma radiations, as from H-3 and C-lh (See Hew g Physics, 3 , p. h33-8, 1978).

Furthermore, the entire set of radiation standards is based primarily on the data from Hiroshima and Nagasaki, where the doses received by survivors were essentially instantaneous. For radiation effects from the entire uranium fuel cycle, as will be caused by the opera-tion of Susquehanna 1 and 2, the doses received both by workers and by me=bers of the public will be low doses delivered at, in general, low dose rates. The bomb blast data have no demonstrable relevance to this chronic, low dose situation. See Health Physics,

)),, p. 369-85,1977, and British Journal of Cancer, & p. hho-51, 1978.

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6. Petitioners contend that the analysis of alternatives, as required by NEPA and the Comission's rules, is woefully inadequate and incomplete. This analysis does not consider serious efforts at energy conservation, end use efficiencies, or what have come to be known as d Second Law Rfficiencies."

In addition, no discussion has been presented concerning the health benefits of energy conservation in conjunction with the conservation alternative to Susquehanna. There has also been no comparison of the health cost.s attributable to the operation of Susquehanna with those of not operating Susquehanna.

On4 with these types of comparison can the true health cost of Susquahanna be evaluated.

Solar energy in any of its various forms is not considered as an alternative to Susquehanna. By ignoring this con =only used alternative energy source, the Applicant is hoping to prevent home use of solar heating and hot water applications. Further encouragement of reliance on expensive electrically operated mechanical heating and cool b g devices, like heat pumps, in the name of energy conservation, seems to defeat not only energy conservation, but also the development of solar energy. The primary beneficiary of this defiance of NEPA is the Applicant.

7. Petitioners contend that emergency response and evacuation planning by the Applicant, the Director and Staff of the Office of Radiological Health of the Pennsylvania Department of Environ-mental Resources, the State and County Civil Defense Agencies, and others responsible for protection of the health and safety of the public in the event of a radiological emergency affecting the population beyond the site boundary of Susquehanna is not complete and sufficient to assure pro =pt notification and evacuation of all areas in which persons may be exposed to radiation doses in excess of those permitted by existing radiation exposure standards for the general public and Protective Action Guides. The recent Planning Basis Report of the NRC and Ehvironmental Protection Agency

-7 (NUREG-0396/ EPA 520/1-78-016, December, 1978, p. 5) notes that "more specific guidance with respect to accidents whose consequences would be more severe than the design basis accidents explicitly considered in the licensing process (is] appropriate."

In view of the Nuclear Regulatory Comission's expressed reservations about the reliability and validity of the probability estimates in the Reactor Safety Study, WASH-lh00 (See, e.g.,

NUREG/CR-Oh00 and NURT-0396/ EPA $20/1-78-016, pp; I-6 through I-10, including notes at pp. I-8 and I-9; see also transcript of the December 21, 1976, and subsequent NRC Comissioners' meetings and Commissioners' draft policy statements on WASH-lh00), and in view of the explicit limitation of the validity of the Reactor Safety Study's analyses through the year 1980, prior to tne operational lifetime of Susquehanna 1 and 2, Petitioners contend that no probability analysis exists to justify the Applicant's and Staff's failure to address the full consequences to the plant and to the" genetic and somatic health and the safety of the public, and the full long-term costs of property damage of the design basis accident (including sensitivity analyses) and of accidents more severe than the design basis accident. Petitioners contend that no operating license for Susquehanna 1 and 2 should issue until the Applicant, Cc=monwealth, Luzerne County, Salen Township officials and any others sharing responsibility for public health and safety have prepared and tested -- with drills that include participation of all of the potentially affected public -- emergency preparedness and evacuation plans for the design basis accident and for worst-case (Class 9) accidents. Risk analysis is incomplete and inadequate to comply with NEPA and the Co= mission's mandate under the Atomic Energy Act of 195h, as amended, in the absence of full analysis of both the probability and consequences of worst-case accidents. The existing studies of disaster response are inadequate to demonstrate, in the absence of tests involving those who would be affected, the capability of emergency response and evacuation plans to provide the protection required for the public.

Two serious contradictions additionally inhibit the effective perfor=ance of the duties of the two parties having major responsi-bility for emergency notification of the public and for the protection of the public health in the event of a radiological emergency. First, the Applicant, through various public relations efforts and the cc -mnications media, has sought to convince those residing in the vicinity of Susquehanna that the plant poses no significant threat to the public health and safety, but has offered no verifiable foundation for such claims beyond the now-repudiated Reactor Safety Study. The Applicant is the initial source of in-formation -- and the only source of data -- pertaining to the severity and scope of the radiological hazard following an accident at Susgr.ehanna. In the early stages of an accident, the Applicant may be unable or unwilling to ascertain that an offsite radiation hazard exists or will exist, and may be expected to avoid advising other responsible authorities and the public as long as tne utility officials believe that emergency evacuation -- detrimental to the utility company's interests -- is not absolutely essential. Further-more, the Applicant, having impressed upon tne public the safety of its nuclear reactors and the alleged extremely low probability of a. catastrophic accident, or other responsible officials may be unable to convince endangered residents of the necessity of emergency actions and evacuation.

A second contradiction inhibiting adequate emergency response lies in state =cnts made by the Director of the Yennsylvania Office of Radiological Health, Mr. Thomas M. Gerusky. He has stated at a public meeting that his staff would not be able to respond at all hours to an accident at a nuclear facility. He has also, by affi-davit, denied having made such a statement. Furthermore, the Office of Radiological Health has been unsuccessful in obtaining the amount of fnnAing required to provide adequate qualified staff and equip-ment to be able to expand its capability to monitor and to respond to a radiation emergency situation at Susqueharma.

8. Petitioners contend that routine, or occasional, use of

9 environmentally persistent or inadequately tested herbicides W maintain clearan:o of transmission line rights-of-way is a somatic, teratogenic, and potentially mutagenic threat to the health and safety of persons living near or traversing these areas.

9. The archeological investigation of the Applicant's upland site for the Susquehanna Station, hasti3,y chosen following the 1972 flood caused by Hurricano Agnos, was incompleto and inadoquate to detemine the status of cultural antiquities in advance of the commencement of construction. Completion of archeological investi-gation in co=pliance with stato and federal law governing protection of antiquities should precodo further construction at the site.

Petitioners believe the Board should require an independent review of the Applicant's archeological studies.

10. Petitioners assert that the Nuclear Steam Supply System (NSSS) of Susquehanna 1 and 2 contains numerous design deficiencies, some of which may never be resolvable, and which, when viewed together, render a picture of an unsafo nuclear installation which may never bo safe enough to operate. The pressure suppression containment structure may not be constructed with sufficient strength to withstand the dynamic forces realized during blowdown.

The reactor pressure vossol may not survive the themal shock of cool ECCS vater after blowdown without cracking. The cracking of stainless stcol piping in Bh"d coolant water environments due to stress corrosion has yet to be prevented or avoided. BW core spray nozzles occasionally crack, a problem which reduces their effectiveness. The ability of Susquehanna to survive Anticipated Transient Without Scram (Af4S, see In'ASn-1270) remains to bo demonstrated. For this ATh'S issue, reliance on probabilistic numbers, as 10~7 per year,is unwise and unsafe. Overpressurisa-tion of the pressure vessel is a serious safety problem, especially in view of the underhanded and wholly inadequate method used to ensure that the ASME stamp was to be applied to nuclear pressuro vessels. (See Proceedings of the Annual 'dinter Meeting, ASME,

November 17-22, 197h, New York, N.Y., paper by A.J. Ackerman.)

Thmerous problens remain with the adequacy of electrical cable penetrations of the containment structure. The reduced capability of Susquehanna to scram at the end of the fuel cycle due to con-trol rod poison depletion aggravates all of the above problems, such that when all of these, and certainly others such as contairment steel liner buckling problems that have not been specifically addressed here, are combined, the conclusion of an inadequace and obsolete design is obvious. (See, for general reference materials, NUR':G-0138, NUIEG-0153, among others.)

11. Petitioners contend that excessive reliance on " single failure" events (i.e., see FSAR 6.3.2.5) leads to a false sense of security and certainty, especially when it is known that multiple failures occur (See testimony of Dr. David Okrent, ACRS, before the California Logislative Co=mittee on Energy and Diminishing Resources, October 29, 1975, p. 11. See also Joint Cc=mittee on Atomic Energy, U.S. Congress, Hearings entitled

" Browns Ferry Nuclear Plant Fire, vol.1, September 16,1975.).

12. Petitioners contend, when taken together and factored into lifetime monetary full cost determinations for Susquehanna, that plant deco =missioning and ultimate dismantling and site decon-ta=ination, interin spent fuel storage and subsequent disposal, radioactive waste management and disposal at all stages of the nuclear fuel cycle, and health costs for the full period of toxicity of radioactive materials attributable to the operation of Susquehanna vill render this nuclear facility economically non-competitive with virtually a:7 of the many alternative sources of energy or with conservation. Absent national policy deterrina-tions, federal legislation, and administrative agency regulation of these issues, Petitioners contend that no operating license should issue for Susquehanna 1 and 2.