ML19329D426
| ML19329D426 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  |
| Issue date: | 04/16/1973 |
| From: | Stebbins E COALITION FOR SAFE NUCLEAR POWER |
| To: | US ATOMIC ENERGY COMMISSION (AEC) |
| Shared Package | |
| ML19329D415 | List: |
| References | |
| NUDOCS 8003060801 | |
| Download: ML19329D426 (8) | |
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UNITED STATES OF AMERICA V
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ATOMIC DIERGY CCMMISSION in the :mittor or
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I'01.Do ED iDON CO. nnd
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i'I.l.WIAt!D EIECTHIC ILLUMINATING CO.
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Docket No. 50-3!#>
(Divic-Eecce ITuclear Power Station T:r; CO/MTION F0lt SAFE NUCLEAR PCWER, on its own behalf and on behalf of its nembers, cupporting individuals and organizations, others similarly situated, nni the public, hereby lists its contentions with respect to the forthcominc Environmental Hearing en the Davis-Desse Nuclear Power Station.
The COALITICN, its member individuals and organizations have by their past activitirs and conduct exhibited and now assert a special interest % the pro-tection of the nctural resources of the Lake Erie Area and in the conservational, recreational, econcaic, aesthetic and community impact of nuclear power plant lavelopment in the Lake Eric Area, and are first and foremost concerned that such nuc]eir power plants not be built or operated vbere to do so would be inimical
' v the health, safety and welfare of the publio. We are concerned with the pr.nervntion of the ecology of Lake Erie, its marine and plant life, their wntic hnbitat and supporting eco-systems, and in preserving the usefulness
/ tn: marine environment of Lake Eric for recreational and other beneficial
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l' COALITION BELTEVES:
That the Atomic EnerCy Commission's natienwide objective of promoting r.uclear plants has not, in the area of licensin3 of nuclear reactors, adequately dir -l.:.rged its obligations under the Atomic Energy Act and other federal legis-1 tion. The Commission has failed to be objective and failed to consider the po:Jalbility that its promotion objectives are inconsistent with its regulatory hjectives. The Co = iscion has not satisfied a legal accceedation of these f r'onnictencies regarding the Environmental Report isat.ed for these proceedings.
The Atomic Energy Commiccion's obligation under the Uational Environmental Ialicy itet in not properly implemented by their Environmental Report on the. Davis-fe ce Nuclear Power Station.
GFff'"AI, Eh'VI!10NMENTAL EFFECTS DEFINITION:
Whenever the COALITION speaks of the envihonment or environmental effects, we acan any or all part of the environment '-. air, land, water, man, anicals, plimtn, finh, vildlife.
g TPF COALITTON CONTFNDS THAT:
(1) T1.0 Environmental Report prepared by the'Atchic Energy Commission is totally inndequate, incomplete cnd not a true evaluation of possible environmentcl effect 8003060 M of t!a Davis-Decse Nuclear Power Staticn.
( )
It la impncaible to. determine whether or not the hi;; hest and best acccmeda-t! n betwen the propoced plent and Prin's environtient hss becn made unincs and
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O of the Environmental report are incorrect as they are baceT ina qu1 inforkation.
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Th" land, air, water, people, anicalo, floh and vildlife, the total environ-mor.t, can be much more ceriously affected than has been assumed in the Environmental
'9 port 01' the Atomic Energy Ccanission.
(4) The total environmental impact of the propcoed Davis-Besse Plent vill be letrimental to itu and the pablic's interest and to the Lake Erie Area, and not properly accesse.1 in AFC Environmental Report.
(S) There ic very serious possibility th'at pecple vill be killed, a3ricultural Janda contaminated and unusable, the N.E. Ohio area vill become a vaste land which hac to be evacuated, and Lake Erie, which is a water supply for over 11 crillion people will be contaminated and unusable.
(6) There is presently insufficient knowledge or operating experience with preccurized water reactors of the size and type of the proposed Davis-Besse Plant to justify citin; of such reactor at Oak Harbor, on Lake Erie, close to nearby p 4ulction centers. Such citing represents a serious threat to the environment, to the people of this area, to Lake Erie, to the fish ard wildlife, and to the public water supply of over 11 tillion people, and is a serious breach of the r W;e Energ Cocaliccion's own cuidelinen on the siting of large nuclear reactors (ICCFH Part lpp and TID 146 4).
As a reault environ: ental damnge has not been
,r.? rly acceccc'1 in the AEC's Environ: ental Report.
' f) TheanalyciabytheApplicantandtheAtomicEnergyCc==isaicnRehtlatory
- v2f!' of the Maximum Hypothetical Accident ("MFA") that can be acouted to occur
..r the Davic-Besce reactor is inadequate and insufficient, and therefore, the mt.:equent potential damage to the environrent iu completely underenticated.
(B) The MHA cet forth in the Davis-Besso Preliminary Safety Analysis Report and n vironmental Report assu=es that the emerdency core coolin; system is of a cize M.d capacity sufficient to prevent an rncontrolled celtdown of the majority of Lae nuclear fuel; the C0ALITION centends that there is no such reasonable mmurunce that the emer6ency core cooling syaten can function as quickly as o.". cnry or with the reliability that is demanded if such celtdown is to be
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There would be serious danace to the environment in case of such an necident, and such accident and consequent environ =catal' damage has not been properly acccoced in the AEC Environmental Repcrt.
(9) The MHA cet forth in the AEC Environmental Report does not even approach the t rue rmx*num hypothetical accident that can be assumed for one of these rcactors; nam.l';, a celtdown of the entire fuel core, with subsequent breach!".3 of the contaismot due to the penetration of the talted fuel and subsequent interaction vitb a.rnundwater, releasing ruiioactivity in quantities many onders of na5nitude obvv; the releases set forth in the Environmental Report.
There bas not been any concideration of the true environmental effects which vould be caused by meh t.n accident, and the AEC Envircrz_cntal Report is incorrect and much more u"r'o m har: to the environment is poscible then has been asan=ed.
(10) The MHA cet forth fails to c0nci er the generation of large quantities of hydecCen cac within the containment after a loss-of-cool $nt accident, and raux for avoidance of a subcequent explosion that would rupture the conta.inre'nt nrd release Inrge quantities of rcdioactivity into the er.viron=ent in an unco'1-t:ciled ennner. There would be much more serious damage to the er.vironment then a
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- (11)- The c*vnluation of accidents and consequences 10 completely underatated a inndequate in the AEC Environmental Report. The asseccment of environmental errectn in th refore not correct.
(l;.) A CJann ') Accident is posoible, and the concequencea of nuch an accident haa not been concidered in the AEC Environmental Report.
The nacenc=ent or environmental effecto is, therefore, completely inadeqvate and incorrect.
(13) There has been no consideration of an accident, which is entirely possible, inich could contaminate Lake Erie as a public water supply.
The AEC Environ:cental If port in thornfore inadrquate and incorrect in its evaluation of environmental effectc.
(14) The components and engineering of'safeguartis' of the Davis-Besse Plant vill be e:: posed to radiation that will lead to deterioration of thece ccaponents, nnd there is no ansurance that the integrfty of these ccmponents or their syste=s tii:1 :,e mointaineri over the enpected life of the proposed plant. There is no nncerance tnat there are adequate procedures for inspection and replacement of these critic 11 components. This could lead to the release of additional quantitics of radiocctivity into the environment, which has not been considered in the AEC Fnvironmental Report.
(l5) The qunlity control, and quality assurance procedurec and programs are Inicquate to assure that the Davis-Ecsse Plant vill be built in conforcance ilth design. Therefore, it is questionablo that.the plant can meet the criteria
'h9, unn nnsumed in preparin3 the Envircn !ntal Haport. Envi.roncental effecto mye not hemn properly assessed in view of this, and concequences could be = ore cr >un than ucc ausumed in the AEC Environmental Report.
(1(d Emersoney Plans and procedures have not been adequately developed or con-e<<.v. J uith respect to an accident uhich wouM require irrediate evacuation in
'he vicinity of the plant, the schools in the arca, and possibly the cities of "on t Clinton, Sandushy, Toledo, Lorain, Greater Cleveland, or Detroit, Michica.?.
':he poccible environ = ental effects and ham to the public would be much greater ti.nu has been anticipated in the Environmental Report.
il'() The schoolo listed in the AEC Environmental Repcrt is incomplete and j
therefore any assumption of pocaible environmental harm is incorrect.
(IC) There has been no concideration of the fact thct it could be impossible to e.nr.'nte people, an evidenced by the November,1972, atora in that area, and conrequent damage to the public vould be much greater than pootulated in the AEC Erivironta2ntal Befort.
(19)~ The Appliennt has not made adequate provisions for either facilities or peracunel to treat radiation injuries or radiation-che.aical injuries which would renult fro::t a maximum hypothetical accident or e.ny other lesser accident, and thervfore the harm to the public vould be unich greater than has been postulated
!n the AEC L'nvironmental Report.
' OM The occurrence of an accident or the discharge of radicactivo effluents nnd P. cat into Lake Erie, nearby streace, under;rou:.d vater table, and the atacaphere, durir; the creration of the facility, in norcal or abnormal operation, vould
. n%ncer the health, safety, lives and property of the public who reside, work, visit or en;nce 1n recreational activities in the vicinity of, or area affect <.d "y the facility, and tPts has not been adequately considered or properly assesce.d uw. mu
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.(21)"ThemeterorologicaldatafortheDavis-BessePlantis.Upchi.ejg j.rke ' le3 in that the une of Toledo Airport data is too far away frca the site to be reliable in vleu of the severe otorms that occur en the lake front, and the Toledo Airport is nppror.i:nately 25 mileu inland.
The assu=ptions of possible environmental
.if:etn in the AlC Environmental Report are, therefore, incorrect and inadequate, and not a tme measure of possible environmental eficcts.
(22) The /IC Environmental Report has not properly evaluated possible effecta from atorm damage in the Environmental Report, and therefore, the asaeossent is inadequate and incorrect.
(23) The consequence of inversions and fogging would be the spreading out, over a lar7,e crea, of any radioactive cases released frcs the Davis-Besse facility, under normal and abnomal operation, and that this has not been properly anaessed, particularly in view of the fact that the meteorological data is inadequate and incorrect for the site.
(24) No consideration has been given t[the high level of Lake' Erie at this time (the highcot in history) and stated possibility that there vill be higher lake levels in the future.
The Environtental Report has not taken into consideration the possibility of flocding of the Davio-Besse site due to high lake levela, and th.e consequent environmental damage.
(P' )
In view o,f the prevailing littoral drift, the p;oposed project will cause wriors erosion of the Lake Erie shoreline and damage to shorefront property enn<.d by Petitioner's members and other members of the public, and this has nod.
teen properly assessed in the AEC Environmental Report.
('O Pith respect to radiation, there is no threshold dose, and in the AEC r.r,vironmental Report -
(a) There has been no consideration of the fact that Radiation Standarda allow the AEC to determine whether to pamit the plant to operate at a higb radiation etionion level, and that the public any be exposed to amounts of radiation conciderably in exceas of low proposed standards.
(b) Does not consider the amount of radiation doses which the public cAv receive from cources other than a particular licensee of the Commission.
(c) Does not adequately take into account,accc=ulction of emissions of radioactivity which tay be present..
- 01) Doco not provide for differences in toleratien of radiation in different houun beinau In given differing locatiope.
(e) Does not adequately provido for a tracing of emissiona of radioactivity through all pathways by which cuch radicactivity cay be transmitted to the populat. ion in a given area, as well as which may be trana:itted to each lethuay in the ecosysten in a given geographical area.
(f) There is not adequate evaluation of the factor of reconcentration of radionuclideo, nor tecsures to abate such raconcentration.
(c) Does not adequately consider illneases or irduries, which will occur from radioactive effluents reaching can cnd cccingling in whole or in part uith chenical effluents, and that the synergistic effect of radiation is
Dh o\\ \\b g rnere 1: not a proper asseas=ent of effects of radon cases on the populaLion.
(1) The radio-censitivity of fish and wildlife or;aniacc is poorb under-ntool and there to a luck of knowledge au to the effect of the peacess uhereb/ radioisotopeu of many elements becote enneentrat< d and e.'.
rri' by orcunicms that substitute these for chemically t>imilar elemento for their normal metabolic activities, and that transfers of radionuclides from one orcenism to another through the focd chain may result in radiation hazards to fish and vildlife and the food and orcanic=s on which they depend. The IIC En tiron = ental Report, has not cade an adequate assessment of this radiation problem.
(j) Any radiation emitted will cause an increace in cancer, leukemia, birth defects, infant deaths, and genetically related and metabolic dicences and this has not been properly assessed in the AEC Environmental Report.
(h) There has not been a proper evaluation of the effects of Tritium or peccibilities of tritium buildup in Lake Erie. The AEC Environmental Fenort is therefore inadequate cnd accumptions of environmental effects are not co rrec t..
(1) The AMC Environ =cntc1 Ecport has not properly evaluated the threat of radicactivity to the agricultw'al and farmin; lando and farm animala etx1 prcducts. The assumptions of poccible environcontal effects are thereferu incorrect and inadequate.
(r.) No.acsessment has been =ade of the i= pact on Lake Erie of all the other reactors on the other Grect Lakes uhich vill drain into Lake Fric, and what the radicactove buildup may be in Lahc Erie of radioactive vastes draining from Lakes Michican, Superior and Huron, as well ao all the rivers which drain into t'.2cce lakes. The AEC Environ = ental Report in therefore inadequate in this respect.
(n) No evaluation has been made of 'the environmental effecto of the other nuclear reactors planned or proje :ted for Lake Erie along with the Davis.
Bence Nuclear Power plant. The total ~effect of all reactors on the Lake han not been considered in the AEC Environmental Report, and therefore the raport is inadequate and incorrect.
(o) No consideration has been civen to the fact t!:nt operating experiences at nuclear plants show that radioactive releases go up with aging of the r, act or.
The evaluation, therefore, of radioactivity on the environment is completely inadequate and incorrect.
i (p) No consideration has been civen to the effects of heat and radiation on metals and concrete and the effects that this cay have on nor=al and abnor:al relear>es of radioactivity frcs the plan';. The AEC Environmental report in therefore inadequate, in thio ~ respect.
j (q) Applicants radiation monitoring system is inadequate and therefore ouvirorimental effects frc= the plant vill not be able to be properly l
naaecued.
f.?'d The Daviu-Besse Nuclear Power Station vill expose workers to levels of
k D 1 A JL 1LUL rfnks of the workers. This has not been properly evaluated in the AEC Environmental Report, and the report is therefore inadequate, ard incorrect.
(T:6) In the AEC Environmental Report, with respect to the requirements of the UntLonal Environmental Report -
(a) There has not been a proper assessment of alternative sites, as re-quired, for the Davis-Besse Plant, including underground siting.
(b) All alternatives to the construction of this nuclear power plant have not been properly evaluated.
(c) No consideration has been given in the Environmental Report, even austming need for electricity as to whether the land and other resources to be eliminated by virtue of the proposed construction should be used for a higher and better use or purpose..
(d) The Toledo Eaison Company and Cleveland Electric Illuminating Co.,
cppbicants, are stimulating the growth of electric power usage. by their.
excessive adverticing and other pregrama and policies, which are contrary to needs of the NEPA.
(e) The relationship between local short-term uses of man's environment and the maintenance and enhancement of long-term prcductivity has not been properly evaluated in the AEC's Environmental Report.
(f) The cost-benefit analysis has not been properly evaluated in the AEC Environmental Report, as all the costs of nuclear power have not been conridered.
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Population crowth in this area has not been properly assessed inasmuch an
' a placing of this plant in this largely agricultural area vill probably ittmalate the Growth of industry and population. The environmental ofrects
- tunrued in the AEC Environmental Report are incorrect.
(; % The total effect of all effluents (radioactivo, heat, chemicals, disaolved
.iol243 and suspended solids, and B.O.D.) to Lake Erie as a result of all opern-
'ons of the Davic-Besse Plant (either alone or in combination with other na)intantc) vill add to the pollution of Lake Erie, endanger fish, vildlife, rr.uning crounds, aquatic biota, their habitat and supporting eco-system, ee mmtional aspecte or 9ater supplies, and vill be in violation of the Non-s ib 3.odration clause of the Unter Quality Standards of Ohio as approved by the Environmental Protection Agency. These effects have not been properly ascensed io the-f.nvironmental Report.
(30) The cooling water intake poses a potential hazard to fish recources and in particular to significant numbers of fish and small aquatic crustaceans, which are benic food items. Fish esss, larvae and other plankton are killed in their passage throuch the plant.
Such destructson cuts dovn the foed supply for laryr fish. This in not adequately assessed in the Environmental Report.
(31) The effects of the cooling tower and its discharges upon the environment have not b.:en properly assessed in the AEC Environmental Report.
(32) [nere has been no evaluation of the effect of using Plutonium as a fuel in t.he Drivis-Bosse Peactor instead of Uranium. It would appear that the AEC migM be
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cce ldyr hi:: t he une of Plutonica in reactors.
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<epbrt la 1 md6quate and incorrect in acceocment of environ = ental effects as t. bey have i
not conaldered this possibility.
(33) The environmental effects of the entire fuel cycle have not been included lii the environnental report. There chould have been conoideration of the effectc of uroniem mining, urenium milling, UF(, Production, isotopic enrichment, fuel
.nbrication, fuel reprocessing, vaste management, and transportation, as voll as high Level vaste storage for " perpetuity". The AEC Environmental Report is there-Jar ir.cceplete and inadequate and not in the least a true evaluation of the un"imacer.tal effects.
(34) The transportation of radioactive vastes and spent ' fuel from the proposed D'ivi:,-Besse plant to their reprocessing or ultimate burial ground would probably nececcitate passing through the highly congest.ed trancportation network and pop'tL*: tion centers and would present a hazard to public health and cafety; and in the transportation of such vastes by water, any accident vould be catastrophic
!.o tLe waters of Lake Erie and to the people of the Lake's boniering territorien, the Plates of Ohio, New York, Pennsylvania and Michican and the Dominion of Car:ada. Since there has been no location of where and how the vastes will be
-hipped, there cannot be a proper evaluation of the environ = ental effects or rinha of such.shipmento. The AEC Envirorr. ental Report is therefore int.dequate.
(LS)
In the AEC Environmental Report,. there is no evaluation of the 'possible en eiron= ental effect of the fuel densification problem, although the AEC has no:.1 fled the Applicant there would probably be such problems. The AEC Environ-
.untel Report is therefore inadequate in this respect.
(70 In the AEC Environmental Report, there has been no evaluation of environ-tx.t2.1 barn which could be caused by terrorists or saboteurs at the Davis-3esce Ilii';lete r Planto. The environmental asseoscent is therefore incomplete and inade-g%- in nssunptions of environmental effects.
Respectfully submitted, COALITION FOR SAFE NUCLEAR POWER by Evelyn Stebbino, Chairman
' i *,mry 2, 1973 I, Evelyn Atebbins, baint first duly deposed sad sworn, depose an$ say that I have road the above and it is true to the b::st of my kncwledge.
, od A
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s Ev41yn.itsy61na SWDRN TO BEFOM H5 and subscribed ir,. my pressaco thio!
g[
day of April,1973. _
wB n, As, w t m A M ec u E -
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ov1 UNITED STATED OF AMERIL.
}n h,- [- {- ATOMIC ENERGY CCINISSION r..::... '...... 50 -3%
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BEFORE THE CO). MISSION in thn Na t.ter of T'h; FOL D0 rD10CN Ct IE/J.rf and the
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DOCKET NO. 50-3h6
(,L:N:I.lJh hT. CTRIC ILLUMINCt. TING CO. )
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(. ovis-Lesse f.uclear Power Station)
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CERENIC&T3 SERVICE b
I hereby certify that copies of the Coalition for Safe Nuclear Power's Amended Petition to Intervene, Letter of February 2,1973 to Office of Secretary 3
of the Commission, U.S. Atomic Energy Commission, and List of Contentions of
'obrunry ?,1973, were servo /on the following by deposit in the imited States rail, first class or air mail, this
/g day of April, 1973:
Gerald Charnoff, Esq.
,s Shar, Fittnan, Potts, Trowbridge & Madden g9
')10 Seventeenth Street, N.W.
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\\lashington, D. C., 20006 L.9
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2-Atonic Safety and Licensing Appeal Board g
, '28 ry l.S. /. tonic Energy Commission N.. -;f *2' s
b th Eachington, D. C., 205h5 If,%. A, [ #;i 7
Atomic Safoty and Licensing Board Panel i
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11.3. Atenic Enorgy Comrnission
'-lnshington, D. C.
205h5 I:r. Frank W. Karas T' h Chief, Public Proccodings Staff
.e Office of the Secretary of the Canminaion 5.
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,b t..S. Atonic r.hergy Comission
'.!ashir'C en, D. C.
205h5 7.? ',.,'
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1.r. Francis X. Davis l
Ccunsel for AEC Rogulatory Staff 37 U.S. Atomic Energy Cornission
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.lashington, D. C.
20545
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Evelynptobbins,, Chairman i
Coalitfon for Safo Nuoloar Power
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