ML19269E717
| ML19269E717 | |
| Person / Time | |
|---|---|
| Site: | Zimmer |
| Issue date: | 05/18/1979 |
| From: | Heile W, Luebbers T CINCINNATI, OH |
| To: | |
| References | |
| NUDOCS 7906290520 | |
| Download: ML19269E717 (9) | |
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BEFORE THE ATOMIC SAFETY AND LICENSING BOARD Docket No. 50-3580L IN THE MATTER OF CINCINNATI GAS & ELECTRIC COMPANY, et al.
'41111am H. Zimmer Nuclear Station INTERVENOR CITY OF CINCINNATI'S MOTION FOR LEAVE TO AMEND ITS PETITION FOR LEAVE TO INTERVENE AND ADD ADDITIONAL CONTENTIONS Intervenor, City of Cincinnati hereby moves the Board for leave uc rend its Petition for Leave to Intervene and admit additional contentions regarding continuous radiological air monitoring, pursuant t> 10 CFR 2 714.
Respectfully submitted, n.7 V N 41:
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'_.s-m THOMAS A.
LUEEEERS City Solicitor
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Assistant City Solicitor Attorneys for Intervencr City of Cincinnati Room 212 - City Hall Cincinttti, Ohio 45202 Telephor.e : (513) 352-3337 2148 165 s p o e, a 9 a f 0
A.
STANDING AND INTEREST The City of Cincinnati, a duly organized and existing Charter Municipality in the State of Chio, is located in part within a distance of approximately 20 miles from the Zimmer Nuclear Power Station.
A cal-culation of the wind rose made by Applicants and submitted to the Com-mission as a part of their filing in this proceeding establishes that a substantial percentage of air currents flow in the direction of the City of Cin;innati from the plant locativn.
The City has a clear interest in obtaining from the Applicants the best available protection in the interest of the health and safety of its citizens.
The accident at the Three Mile Island indicates that indeed an accident involving air releases can, and did occur and that the Applicants' ability to limit or avoid contaminated releases into the air may be severely hampered by conditions beyond the control of the plant operators; that depending on the air masses and type of wind vectors involved, plumes of radioactively contaminated air are capable of traveling considerable distances from the plant in relatively concentrated forms and that in the confusion surrounding the Three Mile Island accident, the public remains uninformed as to the actual amount of radioactive contaminants released frem the plant or the amount of exposure which local residents may have sustained.
The City, therefore, in the interests of a large pcpulation within close proximity of a nuclear reactor capable of emitting radicactive contaminants into the air surrounding the plant has the necessary s anding and interest to advance these contentions.
3.
A?.GTMENT The accident at the Three Mile Island provides convincing evidence
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that reactor =alfunctions can occur in nuclear pcwer plants which result in discharges of radioactive contaminants into the air with the potential of a serious risk to the surrounding population.
The City of Cincinnati, pricr to the accident at Three Mile Islar.d, had con-centrated upon the protection of its water supply, having accepted statements advanced by the nuclear industry the probability of an acci-dent such as occurred at Three Mile Island involving the potential for air contamination was so remote that it was virtually nonexistant.
Equally alarming as the fact thct the accident occurred, however, was the divergence between statements attributed to company officials, and those attributed to NRC employees at the time of the accident re-garding the nature of the problem.
It was considerably after the accident occurred that statements were reported in the local news media indicating that control room personnel at Three Mile Island had informa-tion that the reactor's fuel core was seriously damaged two days before it was formally reported, and that officials were not aware of the significance of the event even though a pressure spike was clearly monitored as it occurred by control room instruments.
Any population in the vicinity of a nuclear reactor now =ust be concerned that its air could be contaminated without advance warning frem plant per-sonnel.
Yet the Applicants persist in arguing that while it is true that control room personnel at ~immer will have indicaters avail-able to continuously v.onitor the three known potential sources of radicactive emissions into the air, and while the technology exists to transmit that continuous scnitoring data cf plant emissions to local air pc11ution er civil defense agencies, to do so is an unnecessary requirement which is not needed for the protection and safety of persens
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located in proximity of the plant, and, Applicants assure us, plant personnel will make the necessary emergency contacts as they dee= appro-priate when their instruments tell them that there is a problem.
After the single most serious and costly accident in the history of the U.S. nuclear. industry, and the only real evidence we have of the suffi-ciency of this type of early warning and detection system, the fact is that we now have proof of the ineffectiveness of any system which leaves the sole decisions of emergency communication in the hands of plant personnel.
When responsible control room personnel at Three Mile Island didn't seem to be aware of the seriousness of what was signaled on the monitering devi:es before their va"y eyes, Applicant's argument that local populations do not need direct automatic com= uni-cation of air monitoring data becomes hollow.
Any system which fails to provide the factual data recorded by continuous monitoring instru-ments for air releases, but rather, provides only the company's inter-pretation of that data, has proven itself to be clearly insufficient to protect the safety and health of local inhabitants, if for no other reason than the total lack of any independent checks of that interpre-tation by the continuous supply of factual data to public agencies responsible for making decisions as to e=ergency procedures for the protection of local inhabitants.
10 simply is net good judgment to accept an interpretation of the data when the data itself is readily accessible, but for the Applicants' refusal to supply it.
Additionally, the City contends that the Zi=mer Statien cannet be operated safely in the absence of continucus monitcring instruments b etween the City ind the plant with the capacity of detecting radic-active ai" plumes carriet by air currents in the direction of the City's pcpulation.
The best available system for early warning and release 7 1 3 8 1 (s R.
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detection includes a system which provides direct re e.1-out of plant emissions plus a system of monitors capable of detecting whether air-borne radiation emitted from the plant site is being carried in the direction of the City's population.
The City contends that the need for continuous air monitoring data and early warning and detection systeme in addition to those presently proposed by the Applicant has Laceme evident as a result of the Three Mile Island accident and the events surrounding that accident and is, in effect, a newly discovered deficiency in the operating plans of the Applicants and that a full hearing on the merits of the contentions proposed is necessary for a conplete review of the operational safety of the Zimmer Station and will contribute to the development of a sound record without unduly broadening the issues or unnecessarily delaying the proceedings.
The City, therefore, submits the hereinafter written contentions relating to the protection of the health and safety of its inhabitants and the protection of its air, and respectfully requests the Board grant its motion for the admission of additional contentions.
C.
CONTENTICNS Proposed _dditional Cincinnati Contention No.
1.
The Zinmer Station's radiological air monitoring program proposed b; the Applicants is insufficient to adequately safeguard the health and safety of the populaticn cf Cin-cinnati and the areas surrcunding the plant insofar as it fails to provide for adequate early warning and detectict cf potential radicactive emissions from the plart into the air, r
and, more specifically, fails to provide cenide ou.3 transmittal of monitoring data to appropriate 1] cal
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pollution agencies which data will be available through already provided for continuous monitors located on the three known pathways of the plant with the potential for contaminated release" into the air.
Proposed additional Cincinnati Contentfon No.
2.
The Zimmer Station's radiological off-site monitoring program proposed by the Applicants is insufficient to ade-quately safeguard the health and safety of the population of Cincinnati and the surrounding regions insofar as it fails to provide for a system of continuous monitoring devices and. the necessary meterological data capable of determining the direction and radioactivity of contaminated air plumes resu?. ting from radioactive emissions into the air from the plan-in excess of NRC prescribed limitations, and the conveyance of data collected by such instruments directly to the public agencies responsible for the issuance of emergency warning to local populations.
?espectfully submitted, yNW%,.., ~...., r.-G 'r%
THOMAS A.
LUEEEERS City Solicitor a
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Assistant City Solicitor Attorneys for Intervenor City of Cincinnati 3ces 212, City Hall Cincinnati, Ohio 25202 Telephone: (513) 352-3337 2148 170
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AFFIDAVIT OF WILLIAM V. DONALDSON STATE OF OHIO
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COUNTY OF HAMILTON
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WILLIAM V. DONALDSON, being first duly cautioned and sworn, hereby states the following:
I am the City Manager of the City of Cincinnati, Ohio.
I have read the foregoing Motion of the City of Cincinnati for Leave to Amend its Petition for Leave to Intervene and add additional Contentions, and the statements and Contentions contained in the attached menorandum, and find them to be true and accurate to the best of my knowledge.
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WILLIAM V.
DONALDSON Sworn to and subscribed in my presence this
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day of May, 1979
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Notary.:ublic Y/
Hamilton County, Ohio A%
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CERTIFICATE OF SERVICE I hereby certify that copies of the foregoing Motion of Inter-venor, City of Cincinnati to Amend its Petition for Leave to Intervene and Admit Additional Contentions were sent, postage prepaid, by crdinary United States Mail to the following on this day of May, 1979:
Charles Bechoefer, Esq.
William J.
Moran, Esq.
Chairman, Atomic Safety and General Counsel Licensing Board Cincinnati Gas & Electric Company U.S. Nuclear Regulatory Post Office Box 960 Commission Cincinnati, Ohio 45201 Washington, D. C.
20555 Mr. Chase R.
Stephens Dr. Frank F. Hooper, Member Docketing and Service Section Atomic Safety and Licensing Office of the Secretary Board U. S. Nuclear Regulatory Commission School of Natural Resources Washington, D. C. 20555 Ann Arbor, Michigan 48109 Richard S.
Sal man, Esq.
Mr. Glenn 0. Bright, Member Chairman, Atomic Safety and Atomic Safety and Licensing Licensing Appeal Board Board U.
S. Nuclear Regulatory Commission U.
S. Nuclear Regulatory Washington, D. C. 20555 Commission Washington, D. C.
20555 Dr. Lawrence R. Quarles Atomic Safety and Licensing Chairman, Atomic Safety and Appeal Board Licensing Appeal Board U.
S.
Nuclear Regulatory U.
S. Nuclear Regulatory Panel Commission Commission Washington, D. C.
20555 Washington, D. C.
20555 Michael C. Farrar, Esq.
Chair =an, Atomic Safety and Atomic Safety and Licensing Licensing Board Panel Appeal Ecard U. S. Nuclear Regulatory U.
S.
Nuclear Regulatory Commission Commission Washington, D. C.
20555 Washington, D. C.
20555 Charles A. Earth, Esq.
Leah S. Eosik, Esq.
Counsel for the NRC Staff Attorney at Law Cffice of the Executive 3453 Cornell Place Legal Director Cincinnati, Chio 25220
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John D. Woliver, Esq.
Troy 3. Conner, Jr., Esq.
Clermont County Co== unity Council Conner, Moore & Corber Box 181 1747 Pennsylvania Ave.,
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20006 Batavia, Ohio 45103 Washington, u.
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W.
PETER..r m Assistant City Solicitor 2148 173
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