ML19326A861
| ML19326A861 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  |
| Issue date: | 11/18/1970 |
| From: | Stebbins E COALITION FOR SAFE NUCLEAR POWER |
| To: | US ATOMIC ENERGY COMMISSION (AEC) |
| References | |
| NUDOCS 8003050764 | |
| Download: ML19326A861 (26) | |
Text
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., l; Uli1TED STATES OF AMERICA AT0li1C EtiERGY C0:itiI S S 10N In't5c matter of
)
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i TOLtro e.DISON C0. and
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l CLEVLLAND ELECTRIC
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Docket No. 50-346 l
ILLUMINATINC CO.
)
)
(Davis-hesse Nuclear
)
Power Station
)
PETITION FOR INTERVENTI0ii The Coalition for Safe iluclear Power, on its own be-half and on behalf of its nembers, supporting individuals and organizations, others similarly situated, and the public, hereby petitions the Atomic Energy Commission for leave to intervene in this matter, pursuant to the Commission's Regulations, and in particular, 10 CFR 62.714.
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I THIS DOCUMENT CONTAINS
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POOR QUALITY PAGES 800g05
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I.
INTEREST OF Tl:E PETIT 10NLR A.
Identification of Pdtitioner.
Petitioner is a non-profit association of persons, corporations, groups and associations formed partially for the purp se
>f this intervention and consisting of, among others, the.ollowing:
1.
Citizens for Clean Air and Water, Inc.
an environnental group of approximately 400 citizens in the Greater Cleveland Area.
2.
United Auto Workers, Cleveland Region a labor organization representing 50 locals and approxinately 55,000 members.
3.
Area Councils Association a group of nbmerous neighborhood associations in the Greater Cleveland Area representing approximately 20,000 members.
4.
Ohio Division of The Issac Ualton League of America, Inc.
5.
Consumers League of Ohio representing 250 nembers and organizations.
6.
Southwest Action Group on Environment (SAGE) a citizens' organization in Beren, Ohio.
7.
Living In a Finer Environment (LIFE) an organization of students at Bowling Green University.
8.
Canpaign Against Violence to the Environment (CAVE) an organization of students and faculty at Bowling Green University.
9 Project Survival an organization of students at Case Western Reserve University..
10.
C o n.m i t t e e Opposed to the Pollution of an Gnvironnent (COPE) organization of students at Cleve2and nn State University.
11.
Lake County Citizens Organization for Clean Air Lake County, Ohio.
12.
Citizens Opposed to Pollution Fairport Harbor, Ohio.
13.
Citizens for a Safe Environment
!!cn t o r, Ohio 14.
David Citlen, M.D.
llerea, Ohio.
15.
Irwin 1.
Oster, Ph.D.
Professor of Biology and Itadiation Cenetics, Bowling Creen University, Ohio.
16.
Ilcs. llelen D.
I!c Cuc,
Mother, housewife and Chairwoman of Mothers March on Pollution North Olmstead, Ohio.
17.
Mrs. l'e r ro Knox Coordinator of the Acadenic Council on Environmental Problems, Shaker lleichts, Ohio.
16.
Eugene V.
Perrin, M.D.
Shaker lieigh ts, Ohio.
19.
Paul Olynyk, Ph.D.
Professor of Chemistry Cleveland State University.
20.
Samuel Cross, II. D.
Shaker lleights, Ohio.
21.
Amasa B.
- Ford, M.D.
Chagrin Fa}1s, Ohio.
22.
Rev. Earl 11. Cunningham, Ph.D.
Cleveland,' Ohio.
23.
George Kundtz j
Chagrin Falls, Ohio.
O In addition, Petitioner includes amont, its membership persons who reside, own property, work, do business, pay taxes, ennage in rrrroation, in, or visit, the Lake Eric Arca, in the immediate vicinity of or within a radius of 150 miles to the proposed Davis-ile s s e Nuclear Power Station.
Ifany of Petitioner's menbership are c"=ro~nrn, and sone may be stockholders, of the applicant utilities.
P-t..i :cr'c me.nbership also includes o r raay in the future include orar*trations representing conservation, scientific, academic, sportsuen's, f ishe rracn 's, recreational, civic and environmental interests, with a total ruenbe r ship of thousands of people.
Peti-tioner also asserts herein the interests of all other persons sinilarly situated and of the public in general.
U.
Sgecial Interests of Petitioner.
The member individuals and organizations of Petitioner have by their past activitics and conduct exhibited and now assert special interest in the protection of the natural resources of a
the Lake Eric Area and in the conservational, recreational, econcric, aesthetic and community impact of nuclear power plant Javnlopment in the Lake Eric Arca and are first and forenost con-
. e r tw d that such nuclear power plants not be built or operated where to do so would be ininical to the health and safety of the public.
personal Petitioner, its rac mb e rs and the public have a
rignt to live in and enjoy an environment free from improvident
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., c :. i n u t t i s. n, pollution, or unnecessary nadiation, and tne" have a right to the ownership, use and enjoynent of property Ire-from unnecessary luvasion or impairment.
C.
ihi t u a l Interests with Power C o m p a n_i c,s.
The applicant pouer coupanics, in r e c o t;n i t i o n of their i.ls.'llon to rect the increasing demands for electric power in
....: s t e Area have carefully planned the Davis-nesse lucicar
.m rom. r Station over an extended period of time.
Petitioner recog-l nizes that their planning uns necessarily guided by the then known safety, standards and that to date there has been no serious ques-tien raiced as to the willingness of these two power companics to nect such standards.
liove ve r, during the lengthy p l a n n i n t; oeriod required and taken by these power companies, additional scientific investination and inquiry has raised serious and legitimate chal-len: es to the safety standards used in the planning of the proposed facility and under which it is to be constructed and operated.
Petfrioner contends that such standards will not continue for lone to be acceptable particularly for a plant to be located so '. o and between densely populated urban areas, it is there-t' o r - i r. the best interests of the power companies, as well as toc.eneral public served by them, that the construction pernit ne i: e n i e d at least until nuch time as safety standards can be e.. t. t l i s h eti and built into the plans for this power station that
.i.... r i y adequate to stand the test of the extended period of
.tved in the useful life of such a facility. !
It seems obvious that a substantial delay in the con-
... r.a c t i o n of this nucicar power station will upset the long
- ]anninr, timetable of these two power companics to supply
..n This may very well result in peopic thuic 'ustomers with power.
perfectly convenient style of aaving icos electric power than a 1;i. in uld require.
liu t this is far better than permitting the
.sm.,
tino of a power station which could substantially con-
> i...
to the destruction of the environment.
Tnis very difficult choice may well be between short rang,e trouble with air conditioners in periods of peak power de-wandn or long range damage to the environment forcing us to live in shelters with air conditioned comfort as the only way to be covatortab1c at all.
' lith the sometimes conflicting demands of the public for pouer and safety, this situation requires governmental action by this Commission to make the necessary accomodation between i h r t.
Jenands. the safety of the public including the preserva-healthful environment is necessarily the paramount 1 Ion cf c ation.
11.
Co s.'I SS 114 ' S ACT In,I
'J I L L A F E (: T Pl!. Y I Y I '
'l;" ' S 1.iY :. E;YS If t h.' Conmission permits construction of the propoacd facility, as it has stated it intenda to do, and later licenses its operation the e n v i ro n t e n t.,1 offect:
resulting t he re f rora vill adversely affcct L'
h.:llth,
- afety and e c o n orai c interest of tac PetitInnar, it. !ac. etc, othera
- i cill a r ly situated and t to >ublic.
i'u c co n:: L r u c t i on and opsration of t-p ro no : d incility..ould also caunc irreparabic damage to and would
'a'o r i d n e the personal and property rights of the Petitioner's neubers, othern similarly nituated and tia c pu?lic Wiich rights are protected by the Tifth Amendment of
- t. n Jnited States Constitution.
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P T.T I T I O;i C P ' S Co. T!2;TI'U?S A.
General Cnvironnental Effects.
The Petitioner contends that the total environnent.il inpact of t i. c proposed facility will be detrimental to its and the pualic's interest and to the Lake "rie Area.
In this connection, Petitioner contendn that the analicants have n;o t, proven ti.a t.
1.
The proposed facility can be countructed and oncrated without rinh to the healt: and safet" of the public; 2.
Tac proposed faci 13ty can be co n s t ru c t e.d and operated without adverse effect on t L ie cuality of air and teater in the vicinity, natural resources, aesthetics, existin;; or proposed private developments, and the adequacy, reliability and cost of electric service; 3.
The alleged bencr:it to the Lahc Eric Area and the public from the proposed facility justifica the risk of injury or damage, which v.' o u l d be created by such facility, to the health, t, c i f a r e, safety and property of the public, and to the quality of the unique environnent of the Lake Eric Area.
1 Petitioner contends that if the Conniscion pernits construction and licennes operation of the proposed facility:
1.
T.ic occurrence of an accident or t~e d i r c h a r;,e of radioactive effluents and heat into Lake Eric, nearby streams, underground unter tabic, 1
and the atmosphere, durinr, t'ic onoration of tc facilitj, would e n d a n ;',e r t '. c h e a l t 'i, safrty, lives and property of the pu' l ic u so reside, uork, visit or engage in recreational activities in the vicinity of, or area affected ;i. the facility; 2.
In viec of the prevailing ph"sical characteristics of the cite, including prevailitig mat corologic al the area, the and hydrological conditions 1.-
operation of the proposed facilitf by itself, or in combination uith other pn er facilities in the Lake. Eric Area presentiv in operation, under construction, or planned, may cr.iate extensive fog and inversions and other atnospheric and environmental conditions hazardous to t't e enornous number of aircraft which overfly the area, fly a holding pattern, take off, or land, in its various airports, and detrinnntal to the te pubile, health, safety and activitien of i
includinn Petittoi.cr's mnmfie r s.
Another consequence of inversionn and f o g,n,i n g eould n
u
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t :. e :4 p r e a d i n g out, ov.: t a l a r o. r.
ar~a, o r an -
radioactive gases released fron t.s e 'Javin de mn facility, under normal and a'e n o rma l operation.
3.
In vieu of the prevailin6 littoral dri f t, the proposed project will cause serious crosion of the Lake Eric snoreline and damage to shorefront property owned by Petitionar's menbers and other members of the pu':lic.
T io Petitioner further contends t !' a t :
1.
T.i e accidents and incidents involving radiation in atonic energy activities and radiation exposure exnerience within the AEC, indicate that a significant danger exists of operational accident at the proposed llavis-Besne station:
2.
The radiological emission standard = of la C7f. 2 0 regarding emission of lo: levn1 radioactive vastes to the cooling '.ater and air are inadequate, unnafe and 111ctal; 3.
The Al;C har violated the standards of the International Commi;nion on 'adiological l' ro t e c t i o n, in that the Al:C -
a.
assumes a safe threshold and that there is a level below which radiat.fon cannot cause cancer and other damage. and h.
annunes that s l o '.' delivery of radiation vill rai t i g a t e cancer ris' and'ot'.r health risks.
4.
/.d e q u e t c safety standards n.2 e.l e d pronerly to d e n t :;n, construct and operate s uc' a plact are lackinn; 5.
The facility lachs design featur n roruirid to c.c a r d it ag a in.9 t s a!.o t anc at;d t e rn.ultant danner to tiin nation-
's.
Countruction of t : <' propoted f a c ili t.y 1Jl have an adverac e co n o.:i c eff ct na t:.e custoners of t'.s e ap3licants 7.
- denuate iac d i c al facilitter and p,re-onnel i
la t.. o La c :.: v ; c Area for t'-
treattent of potential radiation victine are lacking.
11.
Ilazards to the Public Relating to the Site.
The Petitioner contends that tire construction and operation of the proponed Davis-Besce 1:uclear Pouer Station "lil 13. - inimical to t '; e h e a l t ii and safety of the nublic, and that the proposed facility cannot he constructed and o, erat.< I at nuch location vithout u n cl u e-r l:::
t<>
t h e-8.
- i11. a nei n i l. t. i of L :t e public. T-
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?0.P."l.3.t.i " n. if p n i,1,1,v oj, S f,tg irc,:1 l.
The proposed facility in locat<d noar t !i e d e n,.-
of.letrolt, Toledo, Sandusky and GleveIand nopulation-centers and explocive population g r otit:t in anticipatad for the Lake l
-Erie Area, If an accident occurred at the prn,ond auct.ar nlant f
an,ropriate and effective arrangenents could not b.- nade to i
control traffic on the hightays and railroadn to protect the r
public health and safety and to pernit ready removal and evacuation of peopic by land, sea, or air, from tbc project r
t area and nearby population centers.
i'urthernore, the transportation.of radioactive.rastes from the proposed facility to their ultimate burial ground uould I
necessitate passing through the highly congested transportation nctuork and population centers and uould present a hazard to public healtii and safety; and in the transportation of such I
uastes by v. iter, any accident would be catastronhic to the waters nf ;\\
Lake - r.ric and to the people of the Lake's bord e ri ng ter rito ri cs,
f t;te States of Ohio, Neu York, Pennsylvania and 'lichigan and the Dominion of Canada.
2.
Contign,ous tientricted Arcan Petitinner contendn tha the p res:t list i v ol li.-
i.s..o..ue I
rentricted areas uspd for ordnance tmntjne and Iaeiiity to aircraft traininn missions constitutes a un f riue and critical hazard to t '.c reactor arca in that the nuclear reactor to,
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exposed to the d a n r. c r of ai rcraf t crashes ard to the h'nnr1
- beine, shelled by ordnance t e s t i n e,.
Use of the c on t i te uou n restricted areas is determined by a larte numbe r o r s e n a v a t e.
acencies includinc the Denartment o DePenne, the H av r, the c
Air Force, the Army Corps of Encineers, the rederal Aeronautice Ad ninis tration, state and local bodies and at lnast one private corporation, T94, which is testing ordnance under a De"ense Denartment Contract.
The ordnonce being tented includes artillery piercing shells tested over Lake Erie which ncy be c ap able of penetration of 24 inches of reinforced concrete.
The boundries of the restricted areas are in dispute and the restricted area proposed by the Corps of Enr,ineers ac tu ally includes the reactor site itself.
C.
7iological Effects of Ioni zi ng Radiation and Padiological Hazards to the Public Present in fo rm ati o n ab out the radionucliden produced in nuclear nover plants and di s ch arre d into the biosnhere is insufficient to justify the risks attending the construction and coeration of the proposed facility.
Applicants h ave not demonstrated that no biolocical d n ?.ac e to any of the population of the L al e Erie Aren vill result from the r adi at i on emitted by the pronosed plant.
Applicants have failed to show that the r e d i a t. i on doso levels permitted by 10 CFR 20 are reasonable and safe as apnlied to the i t
Lake drie Area and tisat the benefits to t.i e L a i. i>
F. r i t - /s r s.'
fron the p ro p o r. e d facility justify ti e riu' o f b *. o l o g i c t. 1 danare caused by radiation to be etai t t e d therefrom, or that t'ere ill li e an-j '.ecnefits that cannot bc ::ad "I t 't ou t such rich, ba o t'.c r r.eans.
l.: e Pet it ioner contends that.
1.
The res u l t s of scientific re marc's drnoartrate a d o s e -- effect relationabin betreen radiation and cancer or 3 c u!:n n i a induction in man, and that respectable s cle r. t i f i c and nedical authoritics recommend a reduction in the Federal Radiation Council guideli10i for radiation exposure to the population at l a r <; e ;
2.
The radiation protection standards prescribed by 19 C r ': 2d uill n e rtai t tha :)avi s -lie n s o nlant to expose the oublic to dangerous levels of radiation vi ich could cause a 11% increase in birth defects, a 11" increase in cancer and leukenia, and a general incrnane in many najor diseasen including cardiovascular diccae,
schizonhrenia and other geneticall" related diseases as uell as metabolic dineaccs nuch ac
- diabetes, in addition to the foregoing, the
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, r o no a r it p l.es t i11 p.i,,ite
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tac ser!etc in
,a l d
.! ant to
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radiation la tLanc and in nono canec ~, '
times the icvels n e r rn i t t e d for t: c nc al i
public.
A1 a c o n r. e q u e n c e, t i' e nodie:
ri 1
i to-the oorkcre, vi11 he i n c r e a r, r d n r o t, 3 r e '
- tel' 1
l ovo' thone rinks born by the nencrnl nubiie.
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3.
L.t e radiation protection atandards n re s c ri: :d
- - 10 CFR 20:
a.
do not have a sufficiently de aargia j
of safety; l
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b.
do'not assure that rnanonably forav: fable exposures to thn pub 1ic r e c u l t i n a.
fran 4
maltiple sources of radiat1or will renain nell within the desired anfet" nargin; c.
arc inadequate to protect the public against radiation L a
,rP it,~i.nn out of the activitics under the p e r :4 4 r or liconic i
applied for by t 'i c ap,1 < a ;,
to construct a
the p r o p o r. c d Davin racilltv 1
d.
pernit an unreasonably b i r;b and rad ia t ion donc level:
e.
are unreliable an a hanic upon n'i i c '. to l
cvaluat.c the biolor,ical effectn f rnii t '; c s t rin d p o i n t of the public health aad-I l
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safety of tl" peoni - of t ' ' <-
1..i'e E r i e-Area, t? at
- s o ti l d he caused t 'e c radiation eriitted b-L 'o nropa ed
~
facility.
4.
valid ncientific juct]fication for t.n alloia;le
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dose of
's.17 rads of total todv c :: e o c u r r' to.i n n i z i n -
radiation has never been n r e s' - t oci:
~.
~i n e radiation protection standards adonted t ii n
- 1:C fail to take into account ti e po: s1 : 311ty of nu l t i;.l e sou rc es of radioactive nollutton; 6.
rae allouable radiation donage to it ie pooulation ocrnitted b the recualtionn of t '. e At on i c Enerp."
Comnisston (19 C " "., Part 21) nunt 52 revi md doinvard to zero concentration, or no h i p,: e r than 2 :'.' o f current allo'ance, uu t i.1 such t i iv> a:
sufficient ncientific data in o'titned to nernit an informed judgnent on the m a :: f u.1 l' its of exposure to lou levels for l o n g, p,riodn of tire advisable for individuals or nonulations. and until appropriate consideration can '.e
- i v.e n an to " hat is the acceptah]c total n nati c ric.,
.t u d i<:t a t portion t ii c nuclear po-'o r 1 *i.l u a t r f,
a-one of many nou rc eu of Jonizing radiation exposurn (and other a;;e n t s in L.-
ervironment sh i cii :.a ve nutapanic qualiti's. including m a n:-
'e permitt9d to c o n t r i.s u '. "
c.onical4), u a,'
1' touardn Etr a p p r o p r i. a t e..' r r-of t'
nur:e' done 110 t t r., and do t !. a t t.
r-nav,- an ap.: ro p r ia t e ualanciur, and a s p a r t f am i.- ", of t: e
- a!.e Crie '. r c a ucnefits and t %: r i d <: ;'
- t ::i'. t:
fro:s te variou;
- iiu r c e s of l m i
- - i-ra d : a t i o r.
- art, u*
aucIcar 7.
'. t L: +: i r r' r e a l i t a t. 2 o.' t:
ouilt
!- a d2 1r e..r plant
- ou t ei
,opulated area n u cl. an t
La;m ;ri e. rear 3.
fritium and other radioactive vasten are serious nuclear contaminants to the environment and it in difficult to aenure adequate filtering or rerioving o f such "antee from the effluents of nuclear plantn; 9.
f.iil u t e d radioactive i<otopes mar he conenntrated by ari u a t i c ornaninns, enter
'e tahen un into t:ic food chain, and eventually by men and animals; 10 There have been insuff-icient a t tid i e r.
of the L a.s e Eric Area to arrive at reliable conclusions concerning the critical path"ays of the radionuclides; 11.
Data on the effect of continuous late d o r, e radiation is inadequate:,
f 12.
Environmental nonitoring for radiation effect S-utility companies in other nuclear pover nlants demonstrates the inadequacy of the principle of sel f -monito ring; 13.
The problemn and dangers incident to the renoval of high level vantes constituten an undue r i s i-to the public health and safety:
14 Dange r exis ta of radioactive effluent leakinn into ground unter tables; 13.
Procedures for naking the utilities responsible for monitoring and reporting radiological emissions are inadequate.
a.
P.a d i o l o g i c a l, Thermal, and other Effects on Fish and illi d l i f e Pursuant to Public L.]v 91-190, 91st Congress S.
- 1975,
.l a n ua ry 1, 1970 ( Tin e iiational Environnantal Policy Act of 1969),
the AEC han jurindiction of, and in under a statutory mandate to consider, any adverse environmental effects, including thermal discharge, clich may result from a nroposed nuclear pover plant.
Petitioner's membern use Lake Eric in the vicinity of, or in areas affected by, the proposed facility, for boating, f i s it i n c., h u n t i n g, bathing, and other recreational nurposes.
I.a l. e Eric supports important commercial and snort f i s h e r i e:. and extensive waterfowl use.
Fishing, waterfowl use t
and 'sunting occur in the general area of the nrnlect.
The Petitioner in concerned et th the preservation of th ecology of L a '. e dric, i t r, narine and plant life, t:w i r aquatic habitat and cupporting eco.y'stemn, and in prenervier the usefulnens of the mar 3nc environment of La' c Erle for recreational and other beneficini purposes.
The effect of sewage dincharge produces a significant i n c r e a.; c in the nutrient content of the uaters of Lake Eric.
The proposed facility vill pour billions of gallons of incated unter into Lake Erie, th us creating a n.t a t dump.
rhis eill speed up its eu t ro phi ca tion, create s'ncrnistic action on a;.n o r n t io n of radionuclides, destroy it an a suitable habitat for its recreational and commercial f in'ic rie s,
and in general change its entire ecology.
The Petitioner contends that the diccharge of radioactivn effluents and heat into Lake Erie and tM atnosnhere in the operation of the proposed facility nay advernely affect i
narine and plant life in the Lake Eric Area and dstract from t :e recreational utilization of the arca; that ti e effectn of the prononed nroject on the local ecology have not yet Sceu sufficientl" studied and determined; that the necessary environnental qualitative and quantitative studies of botton blota, plankton crustacea, floh. t e r.ip e r a t u r e, bottom comnosition and unter c'.e m! t r--
.iave not "ct been made in nufficient depth that it in not possible i )
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e.. i., e i....
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- e. r e i t...e enw 6 o n..... o a
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ould re4ulI frun L ;i e operation of (;.c o ro p...I faciiit 4 se-Pat j t lone r alJo bclieven t it t ' <- radin-c qiti"!t
~
of f 1:.. and riidlifc organions i-onrly u ule r t on d - t i. :i t t^r-t-
inc.; of '.antledge as en the effect of t c proc.? -
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. re radio 8 90to:
of many el.uaents becone concantrate< and ; :. o r. '
cu.stitut2 these for chenically
.~nilar e i e..a s. :
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., ' orgaai t '. L::st Eur t.e i r n o r :.s a l notabolic activitien, and that transfers of radionuclides from one organism to another through the food cl. a i n r.ay reault in radiation hazards to fiqh and illlife a: d tac food and ora.anisas on uhich t ite y denend.
l.c c o r d in e:l y, the Petitioner Enlieves t'at it tw not possi.,le at toia tine to deterninc " in t*:e r t!.c de n i g:t of conntruction of the roposed facility tnuld caren,uard f ' r, o i
and wildlife organisnn and anuAtic biota from undun radiation i
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i exposure, and ti:st it is not pensible to deternine
.:e t c r J
tac ;;ic t a b o l i c activition of the important fish a n d
- .f i l d l i f e r e n o u r c e.- in the project arca vill not b.: adversley affccted i, i tae raste clamenta contained in the effluent from t:ic 1
^
l proposed plant, o r whe ti,cr concentration of radioactivit, harmful to fin;i and vildlife is occurring.
Petitioner believen the applicantn have not demonstrated that tae proposed facilit; can coti.p ly with the annlicable federal and state ater quality standards criteria go v e rn i n t; t:>e rnal 4
lincharce and nollution control acts, and have not nhavn tbnt t.b e discharce fror the plant, either alone or in combination tith other substances or vastes, vill not be in.iuriouc t.;
rishlire and aquatic biot a or impair the waters for any o th e r best usage.
Petitioner believes th at a construction p <r r - i t should not be inn 2ed to the anp31 cants because of the possible adverse ef fects of thernal discharges and other potenti al hazards to fish snd wildlife, aquatic biota, their habitat and cunnortine eco-syster.s.
The discharce of l arge volunes o c he ated w ater into Lake Erie not only may be detrinental to fish di re ct ly,
but also nay affect these resourcen indirectly throuch ecolocical chances, particularly on the food orcanisr.s on which the fish denend.
The coolin6 vnter in t ak e poses a potential hazard to fish resources an d, in parti cu l ar, to sir,nificant numbers of fish and small aquatic crus t ace ans, which are b asi c food items.
Fish eggs, larvae and other cl ank t o n are killed in their massage through the plant.
Such destruction cuts down the food nunnly for larner finh.
E.
The Ricks to the Pub li c Health and Safety Far Outweigh the Bene fi t s Petitioner contends that the benefits cl aine d for nuclear power have not been realized; th at reliability o*
larrc
. l
reactorn aan ntill tn he demonstrated that coats far e :: c o e d estimaten, that no nuclear pouer statinn haa denonstrated t:at it is competitive in cost with conventional electric n o..> r a t a t ion:.
and that nucicar pouer plants are not clenn, safe or reliabic, insofar as the Lake Krie Area is concerned.
P.
The Public Interest Will Le Served bu Petitioner's latervention in the Proceedin E _ _ _
Creat concern r e,?,a r d i n g the advent of nuclear no*:te r in the La:c e Erin Area h a.s
'u c e n voiced in the area'n newspapern.
For exanple, the Cleveland Plain r.c a l e r has nublished a snrics of articles critten
'o y k'il li an it. ':cCann reporting the "ide nublic concern over the safetr of tbc pronos"d facility.
The Lleveland Presa, in articles written b" 1ett" Klaric, h: q concientiouily reported on the health, and safetr inp11 cations of the proposed facility.
The Sun ne"spapern have liie.' iso reported the groui n:; citizen concern over th-dangers of L: e proposed f a c ili t;'.
The concern of these major neusnapers r?r,ardin-t he p ropo;.ed facilit7 in part of a y,e n e ra l r i s i c a. national concern over radiation
.s a a: a rd s, radiation protection utandards, and tbc t..
roa1 notlutlon caused b7 nuc1 car pocer plant.
's a c puSli.c conncinunness in Ohfo and t' ro u;;hn u t tc Unitsd '; t a t. n over qu?.stion. of e n v i. r o n a c a t a l naality aan,
- i. )
recent noat.+
en.s o i r.h t e n e d.." t i. e cractment of t'.-
.ationni
..a v i r o nn t;n t a l Policy.ic t of 196".
& r - :.-
t'c a
coacern ove r t.. c. 1: q,a c t of nuclear no r si t,
o-t z o v : r.o n-
.?o'nt
- otui! r t, - on naalfent.d la t!.e.i e a r i.7 ;. -
f ri r -
t.
.i:6 Atonic Ene r:;y,
'J i s t Congress, 1,s t Session, on " E n v i r o n:-e n t a l Effccts of Producing Electric Power, Part 1 uhich ucre iv.1 d on October 2d, 2V, 30 and 31; dovember 4, 5,
and 7,
1?f".
Part 2 of L. e se hearings resumed in 1970.
In tle preen release,.l o. 624, inaued on necember ??,
l ') 6., by the office of the Joint Connitteer on Atomic Energv, Ch ai rman iloli f ield s t ated that the public h e a r i n a,n.l u r i n t; t 'i c
'ecch of.lanuary 2>, l~)70 were a continuation of t'u
.Toint Committee's study of the environmental effect, resulting from the siting and operation of nuclear, hydrological and f o r. s i l fueled electric p o.>e r plants, and that th final racord.6ich would result fron these hearings vill countituta an un to-date compendium of all effluents from electric po"er plants.
on the instant The purpose of the public hearing application in to determine whether or not the construction and operation of the proposed facility will cause undue r i n '-
to the public health and safety or damage to the environment or biospherc.
Petitioner'n intervention and particination will aid this determination by making the proceeding on the adversary proceeding in which the applicants' application an b
evidence and the regulatory staff's po91 tion can be -
tested by crons exanination, and in which Indopendent evidence and Ic;;al a rgune n t can be presented by the intervenor on the factual and Icgal insues.
The granting of full intervonor status in a contested proceeding vill enable the Petitioner to articulate the public interest and concern over issues relating to health, safety and the environment, and vill create a forum in ubich nenbe rs of the scientific community (with Views contrary to thore of the applicant or regulatory staff) may be brought into the proceeding to testify as expert witnesses on the issues which must bc tested by the AEC.
It in in the public interest that there b>
in this proceeding a full airing and presentation of the latest scientific data, findings and conclusions regarding the subject matter of the proceeding, and that the Commission scch out all evidence bearing on the issues and call as its.own scientific uitnessen even those uhose views may be opposed to the findings of the Advisory Comnittee on P,c a c t o r Safeguards and the findings of the staff and the scientists relied upon by anplicant.
The Petitioner respectfully submits that the Comm!srion should not issun a construction permit to the applicant for all the reasons previously stated, and because the allened benefite from the proponed na v i s -- B e s s e facility to the nublic " o "ill be subjected to the risks to public health, <: a f e t y, and environnental contamination created by such facility, do not clearly override such risks.
-2h-
3 tJill;l EFO".C, Petitioner re nne c t f ul l" r e cl in e r, t =; t ':e C o ', -
mission to 1isue an order permitting its intervention as a party in this proceeding.
Dated.
- fovember 18, 1970 COALITIO: F0" SarE ;;t:CLE A' P e t.? C '
By:
g Chairman f
1 I
l
\\'e r i f I c a t i o n S *J A T L
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o!!I n
)
)
COUiTY O l' City A110C A
)
Evelyn Stebbins, being firnt dulv nuorn 01: oath, staten:
I am Chairman of t ii e Coalition fo r Safe Juclear Pouer, tbc Petitioner in this proceeding; I have read the foregoing Petition to Intervene and all natters stated therein are true to the best of my knovledge, i n f o rma t io n and bolfef.
E ve l n Steb ins Subscribed and suorn to be fore ne thi.
day of c;o v e mb e r, 1970.
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