ML19305D459
| ML19305D459 | |
| Person / Time | |
|---|---|
| Site: | 07001308 |
| Issue date: | 03/19/1980 |
| From: | Rorem AFFILIATION NOT ASSIGNED |
| To: | |
| References | |
| NUDOCS 8004150106 | |
| Download: ML19305D459 (7) | |
Text
y
/
h
//
DOCKETED USNFC 21980 > }f y;
APR UNITED STATES OF AMERICA 01 j
e s
g NUCLEAR REGUIATORY COMMISSION g e5 ro In the matter of
)
Docket No'. 70-1308 m
)
General Electric Company
)
Renewal of Material
)
License No. SNM1265 (Morris Fuel Storage Installation)
)
19 March 1980 t
i RE-AMENDED CONTENTIONS OF ROREM ET AL. (INTERVENORS) l 1.
Intervenors contend that under the present license held by General Electric, no account is taken of the possibility of an acciden't to the storage pools which might result in large releases of radioactive gases.
Intervenors further contend that such an accident is possible, due to earthquake, t
tornado, fire, flooding, acts of sabotage, acts of war, i
human error, or massive electrical power failure.
i Int,ervenors contend that before a renewal license is f
issued, the folicwing conditions should be met:
A.
There should exist a comprehensive evacuation plan for the area, including the whole of two large metro-politan areas to the northeast (Joliet) and to the southeast (Kankakee) of the facility.
These plans should include detailed information as to how hospitals, nursing homes, schools, and prisons are to be evacuated.
i B.
Hospitals within a 50-100 mile range of the facil-i
'ity should be equipped to handle large numbers of people 1
exposed to radiation or contaminated by radiation.
At j
present there is no hospital or other facility within such a distance which could take proper care of more i
1 l
(b/
8004150/06
)
2 t
than several such people.
C.
Applicant should take responsibility, both fin-arcial and otherwise,'for informing residents of the area that the possibility of such an accident does exist, and informing them of evacuation plans and/or measures to be taken in case of a radioactive accident eitherat the facility or during transport of spent fuel l
to or from the facility.
D.
Applicant should take complete financial responsi-bility for formation of evacuation plans, for equipping hospitals and training personnel, and for maintenance of any equipment needed.
The basis for this contention is testimony presented in a criminal trial held in Grundy County, Illinois, begin-ning on 1 October 1979, in which 12 defendants were accused of criminal trespass to the G.E. Morris Operatio'n, the fac-ility for which renewal of license is being sought by Gen-eral Electric.
i During that trial, expert testimony was presented by Dr. Leo Seren and Dr. Richard Webb, both of whose creden-tials are well known to the NRC.
Both witnesses testified that an accident to the G.E. Morris Operation was indeed possible (by such occurences as earthquake,atornado, fire, i
flooding, etc. as in contention) and,that catastrophic consequences could occur.
The basis for part D. of this contention is the simple i
fact that General Electric Company, a corporation, is asking I
for the right to place the lives and livelihoods of area j
residents in some jeopardy, and that, inasmuch as rights carry with them responsibilities, should be willing to accept such financial responsibilities, rather than place them upon j
3 the citizens themselves, through state taxes, city taxes, etc.
2.
Intervenors contend that the General Electric Morris Operation is not secure from acts of sabotage, and that its current sabotage plan does not meet 10CFR73.
The Sabotage Analysis for Fuel Storage at Morris relies heavily upon such phrases as " extremely unlikely" and "not credible" to dismiss possible acts of sabotage rather than examining in depth what consequences could occur.
For i
instance, in the section on Sabotage Case Studies, under j
General Assumptions, the Analysis states, l
" Penetration of this system by a casual or spontaneous attempt is very unlikely.
If it should happen, it is very unlikely that those' making such an attempt would have the combination of technical skills, materials, and knowledge of the building and its equipment that would be required to offer even the wildest, the most l
irrational hope of success."
Intervenors do not feel that this is scientific proof at its best.
The Analysis also states that "N,o known bomber or i
' Terrorist' groups operate in Chicago."
Intervenors contend i
i that this is " hearsay".
Moreover, they have not noticed that j
terrorists and saboteurs are strictly homebodies, nor has
)
applicant offered any evidence to support this assumption.
As additional basis for this contention, intervenors point to the NRC's document known as the " Barrier Technology Handbook."
s 4
3.
Intervenors contend that renewal of the license should take into account the close proximity of the Morris Opera-tion to Dresden Nuclear Station, noting in particular that:
l A.
Dresden Nuclear Station has a poor safety record.
i i
B.
There is a concentration of spent fuel in the area; l
if an accident at one storage pool causes it to go critical, the other site could easily be affected.
j C.
The G.E. facility may be affected by the attempted l
decontamination of Dresden Unit One.
The basis for this contention is also contained in the trial transcript mentioned in Contention 1.
In addition, it dould be noted that when the G.E.
facility was originally licensed, no. account was required to be taken of the possibility of a Class Nine accident, nor was it required during tha licensing of Dresden Units 1,2, or 3.
In the wake of the accident at Three Mile Island, both the Kemeny Commission and the Rogovin Report urge that such catastrophic possibilities be taken into account.
.,a As to specifics of how a Class'N'ine accident could occur at Dresden, refer to Contention 1 (earthquake, tornado, fire, etc.) adding in addition that the solvent used in decontamination may structurally weaken metal in pipes and bolts.
I 4.
Intervenors contend that reliscensing the facility,
)
because of the possibility of an accident at the facility, or during transportation to it, would damage property values and the economic structure of the community.
l i
The basis for this contention is sheer, common sense.
When meeting with NRC, staff to discuss contentions, intervents were assured that relicensing the f acility would actually improve property values.
There is no basis for this claim.
t In addition, intervenors were told that unless they could show a precedent, there is no valid basis for their contention.
Intervenors stand by their contention, further conten-
[
t ding that there is always a first time.
They do not feel that an accident, and consequent econcaic problems in the Morris area should become the basis for some-similar con-tention elsewhere.
5.
Intervenors contend that mere compliance with NRC stan-dards in no way assures residents of the area that they will suffer no adverse effects from low-level radiation.
l The NRC has a copy of the Heidelberg Repcrt, which
>=
shows that =any of the calculations' 6pon which the NRC bases assessment of how much radiation is being absorbed by the population, are false and misleading.
Much of the information upon which supposedly " safe" levels of radiation are determined comes from the 1950s, i
when the Atemic Energy Commission, feeling that bomb tests were necessary, set out to justify their position that
l l
r p
6 l
fallout was safe.
The NRC frankly admits that AEC scientists j
rigged their experiments to reassure the public.
Intervenors feel that thin justifies taking a new look at what possible damage the G.E. facility may be doing, re-gardless of whether current NRC regulations are being met, if those regulations are themselves meaningless or damaging.
6.
Intervenors contend that transport of spent fuel to the facility involves substantial risk of dispursal of radio-active materials due to accident or sabotage.
Intervenors were told during the summer meeting with NRC staff that transportation was not an issue which could be discussed during relicensing procedures.
Nevertheless, intervenors feel that the storage facil-ity could not exist without transportation to it, and that this is a valid contention for a hearing on relicensing.
7.
Intervenors contend that a relicensing of the G.E. Morris Operation would facilitate a possible takeover of that op-
_.j eration by the federal government.
While this contention was not in the original petition for leave to intervene, it was discussed with the NRC staff last summer.
They claimed that there was no relationship between a license granted by the NRC, and one which would be required were the G.E. Morris Cperation to become a federal facility.
l t
7 r
i However, the DOE (Department of Energy) now admits that i
it is especially interested in the G.E. facility, because it alone, of the three possible federal si.tes, has a license.
P P
6 I
i I
\\
e$
1 I
i I
,-