ML19270H550
| ML19270H550 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 09/06/1972 |
| From: | Sager L CITIZENS FOR SAFE ENVIRONMENT, Environmental Coalition on Nuclear Power, SAGER & SAGER ASSOCIATES |
| To: | NRC COMMISSION (OCM) |
| Shared Package | |
| ML19270H551 | List: |
| References | |
| NUDOCS 7911070735 | |
| Download: ML19270H550 (8) | |
Text
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UNITED STATES ATOMIC EMERGT CCMiISSION Before the Comission Docket No. 50-289 in the matter of Metropolitan Edicon Company, et al (Three Mile Island Nuclear Station Unit 1)
_ADDEDUM TO PETITICN FOR IhTERVENTION T1.e petitioners hereby amend and add to the Petition for Intervention i
pursuant to the answer of Metropolitan Edisori Company et al and the answer
_ f the A F. C Repilatory Staff in res9ense to the Petition to Intervene filed o
by the Cititens for a Scre Envirorcent and the Envircr= ental Coalition for Piclear Power.
The designated alphabetical references the contentions shall foll nr thu ori;inal Petition for Intervention, and uhore the same lotter a
annears in thia Lddcadun, it wcn the cu: cose of the petitioners to cuper-cede the si.t= nnt of the oririnal contention.
The numarical referencea to the navarranhc hert-in do not reflect the nu:, bering ord r of the original petition.
1.
The En:3 ro:::sntal Coclitien fer Euclear Pouer ic an unincorporat A cas,cir tio: cow. priced of those organitations listed in the c:61 bit ct?.cched b
hereto n.d r.ede a cart hereof.
The membership of the varicuc orgar:ine.tions licted berc a.ndoas necr3y 10,000 individ:nle rc:o live in the Stat M ef Pennevivaniu ar.d "er Jersey, includirr recidents of the Harrisburg - York Tim w..+ rAlp dul, ne'.horirec the Er.c<ive Officers of the 67n1 7Aq area.
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2 Coalition to act on its behalf, to interver.e in these croceedings, and to raise the conter.tions set forth in the original Petition to Intervene and the Addendum hereto.
The individual members of the Coalition are grieved individuals as citizens of the States of Pennsylvaia and New Jersey.
They, collectively, agree with the allegations of injury herein.
Sbnilarly, the Citizens for a Safe Environment is an unincorporated association ecmprised of citizene and residents of the Harrisburg area.
Mary Virginia Southard ~is the Chairman of the Citizens for a Safe Environment, Her residence is 1450 Market Street, Harrisburg, Pennsylvania.
The other officers of the Citizens for a Safe Environment include John J. Simon, Co-Chairman, and Malcolm P. Northam, Secretary-Treasurer.
All the officers reside in llarrisburg or its suburbs.
At a meeting of the Citizens for a Safe Environment in July,1972, authorized the aforementioned Executives to reoresent their interests, they as individuals agreed, collectively, with the allegations of injury set forth in the Petition for Intervention.
2.
The following addendums to the Petit.sn for Intervention; (c) the olant has not been designed and constructed in acecrdance with Part ICO and Part 50 of the Commission's Pule in that the applicanto anclysis of maximum credible accidents and releacos therefrem is not the worct maximen accident
' credible accident and therefore the designed bacia/resulting from the applicarato analycis is in error, particularly because the vocat maxin.ri credible accident ueuld reach the centainment, including by airplane accidenta or ccbotage or the warc'.. rnximum credible accident would be an accident more crevious than a LCC3 or red dran accident.
The worct credible accident would be a breach of the containment and/or a l oss of coolunt accident in cethinatien with the 7n1 7rq e
.s e
3 failure of the emergency core system and/or the simultaneous drop of more than one red.
(h) add to that which has already been stated; the metals used in the construction of the reactor and primary containment vessel will not be able to with-stand such phenomena as, but not limited to, neutron bcmbardment, stress loading and unloading cycles, and corrosion so that the metals will not be either e:brittled or in any way weakened so as to endanger the public health or safety over the lifetime of the plant. Further, the plant is not designed so that the feed water control system can be safely operated over the full range of operating cenditions, especially as it relates to the inner action between the feed work control system, control valve in the reactor cooling system.
Additionally, the core scray no-zles are subject to bending which could occur through refueling operations.
It has not been established that the spray noceles will not bend under the worst conditions.
And furthermore, autocatalystic effects can occur within the reactor core affecting the safe operation of the plant.
The plant has not been designad to adequately protect against high velocity missle impact.
The nlant has not been designed to withstand the dangers, hazsards, and damages resulting frem hydraulic pressures (uater ha==crs) flying missles and other mechanical failures in the inner action of the sano on the containment, piping, valves and all other systems in an accident which may occur in combination with the same.
(i) add to the statement in the original petition; the applicant has not established adequate measures have been taken to prevent industrial cabotage or cc,tage frem those who are not cnet.cies of th3 United States.
The clant is ritu1ted on a ficod plain and has not been designed for the norst floc 1 cane.
Lack of said de icn will affect the herith and.21 fare of the public.
The d:. ming system in the vicinity cf the reactor vill-further affect the flood L-
L stage and the safe operation of the plant.
(q) add to the statement set forth in the original petition; the construction of the containment was not in accor-dance with anplicable engineering and construction codes, particularly tdth reference to the construction, design, building of the containment including the puring of concrete. Further, petitioners contend that the quality controls and testing of penps, valves, and control systems through all operational frequencies and all possible hydraulie transients that might.arise has not been cdequately demonstrated.
41.
Applicant's cost benefit analysis fails to substantiate the monetary costa 34t forth as conclusions in Section 11 of the Envirormental Report.
Petitioners contend that all costs and figures cet forth in the Envircraental Recort muct be substantiv ted byfall & competent evidence and not cet forth as cen:1usions of analyse.s that are not made a part of the record.
42.
The cost benefit analysis is incomplete in that there is no analysis of the diff erence in the output between a. eeni. plant and a nuclear reactor unit far na the potentici cparating canacity during the lifetire of the plant cnd c
annually.
43 The applicant hcc failed to set forth the equasion:: ured in its cont banofit analy ic; and therefore, any concluciens derived frca any equastiona used not unhin the record thould be stricken ac a matter of evidence.
LA.
In the cost benorit cnalycis, the applicant has failed to tablich r$hility index to cctablich the prcbability of occurrance of the 1000 excteding the avn.12ablo cercrating c;eacity with and without the proposcl facility in ordar to full, ecconstr 'e the ncMa and benefita for the facility.
45 The applictn33 cost benefit analycis does not adequately c:ncider the envirormntalcostsresultinhfromradictioneffluents,ecpeciallyfr-nvecte r,nq
/rq u..
5 disposal, transportation, injuries to empoyes of applicant and possible mutation te plant and anical life.
46.
The applicant's low level radiation analysis is incomplete in that there is no analysis of the synergistic effect reculting frca the ec=bination of low level effluente from the plant with other radio-active and non radio-active pollutant in the environment.
L7.
The cost benefit analysis is incemplete in that the anclicant has not analysed the environmental costs of the acuatic life, and the effects on the fond chain resulting from the operation of the plant.
48.
The cost benefit analysis is incemplete in that the applicant has nnt analyzed the indirect cost to the rateonyers and taxpayers including insurance nunclementa under the Price-Anderson Act, research and technological assistance through the Atcmic Energy Commission, past, precent and in the future.
49.
The applicant's discussion of heat discipatien to the uater ia incomplete, and the applicant failed to establich by competent evidence wh:t effect, if any, there is on water used by radio-active effluento into the water, especially tritium and the concequence of the added heat to th* water resulting frca the operution of the plant.
50.
The coplicant hcc fciled to adecuately c.nalyre the environnantal corte reculting fren the operation of the plant in that the appl 3 cant hau failed to r.nalyze the additioral rrJio-active b ekgrcund rcculting frem tha eneration of thic plant in ceabination wi'i.h the eparation of prep::ed nucin r nlar.ts, including P;ach Boticm, Units 2 rnd 3 nnd the proroccd Limerich Reactert, Uc.ite 1 cnl 2.
The Envirore.: ental Report is incemplete in that no event prob.1vilig conaiderstions are cdt-blished and cr.alyr.cd, particular27 event prcbabilities
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6 various reactor accidents including loss of feed water pumps, loss of flow, primary system pipe rupture, operator error, emergency core cooling system failure, air craft crash, truck accidents, mult'.ple rod drop and rupture of the crimary containment.
51.
The cost benefit analysis as set forth in the Environmental Renort is inadequate in that it does not include the cost of the Three Mile Island Juniata and Three Mile Island Bechtelsville 500 K.V. line segments.
The anplicant has not established by competent, cdmiscible evidence that construction of those if r.es would take place even witho'tt the propoced facility being constructed and operated.
52.
The acplicant hca not establiched by competent, admi=sible evidence in Part 3 of the Envirornental Recort there vould be no cignificant thermal or fogging effects to the environm-nt through the operation of the plant.
53 The cuality casurance in the cenetruction of the plant hca not been ve: tried by the anplicant by shruing that the construction schedule and recordc,f the constructien actually conform to and ccmplied uit'/ the decign of the facility.
St.
The accumptions used by the applica..t in Pm-t 6 of the Envircnnental Rcr. ort especially concerning red cicdding integrity arc without foundation both factually cnd evidentiary.
55 The lou 13 vel relecae aralvois by the applic nt la inct clucive in that it fails to establich a probability of relences resulting frca onerational, tran;fent con!itiore.. including hi. h pesannro unter h::=ers, val.,
failures cnd v.inor onerational errors.
Furth er, the cr:.1,7:13 f,ila to fully evaluate the effects and doe tv.js frem all radic-active effluents frca the pluue,
,c, i
7 particularly tritium.
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?.e.spectfully submitted, Citi:: ens for a Safe Errrirotnent Erwirormental Coalition cn Nuclear Power
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COUhTI 0F DAUPHIN
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Before me, a Notary Public in and for said Co:=orarealth and County, personally appeared Herbert C. Goldstein, Esquire on behalf of Citizens for a Safe Enviror=ent, the petitioner herein, who being duly sworn according to law deposes and says that the facts set forth in the foregoing petition for leave to intervene are true and correct to the best of his knowledge, information and belief.
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