ML20011A220

Affidavit Opposing Applicants Motion for Summary Disposition of Contention 17.Contests Claim That People Will Not Experience Shocks from Transmission Lines

ML20011A220
Person / Time
Site:	Susquehanna
Issue date:	09/29/1981
From:	Amory J CITIZENS AGAINST NUCLEAR DANGERS
To:
Shared Package
ML20011A219	List: ML20011A218 ML20011A220
References
NUDOCS 8110080311
Download: ML20011A220 (5)

Text

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PEIUSTLV1' IA POIR & LIGHT COMPANY

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Docket Mos. 50-387 ALLEGEINY ELECTRIC COOPERA'IVE INC.

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50-388 (Susquehanna Steam Electric Station, )

Units 1 and 2)

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AFFIDAVIT OF JAMES AMORY IU O' POSITION TO APPLIC ANTS' MOTION FOR SUMM ARY DISPOSITION OF CONTENTION 17 James Amory, being duly sworn according to law, deposes and says as follows:

1) I operate a 160 acre farm near LeRaysville, PA, about 50 miles from the proposed Susquehanna Steam Electric Station. I also have some technical background in mathematics and engineering, and have reviewed some of the lit'erature bearing on the effects to humans of the electro-magnetic and electro.tatic fields of EHV and other transmission lines, including the affidavits of Robert F. Lehman and Solomon M. Michaelson submitted in support of the Applicants' Motion. I have personal knowledge of the catters set forth herein, and believe them to be true and correct.

A summary of my qualifications and experience is attached.

2) Contention 17 says in part that the 500xv transmission lines planned for the Susquehanna facility will " create strong electrostatic and electromagnetic fields that adversely affect living organisms along the UEV transmission right-of-way and beyond,"' and that they should not therefore be built in their proposed form. The Applicants contend that the magnetic fields "have been demonstrated to produce no identifiable health effects on humans," and that the electrostatic fieldt "will have no measurable effect on the health of the public,"particularly because the population density near the lines is very low and precence of the public on the right -of-way for considerable periods of time is not anticipated. (1, p. 26) These claims are supported by two affidavits, one by Robert F. Lehman of the P. P. & L. Engineering Department, one by Solomon " Michaelson of the University of Rochester.

3) The Leh.an affidavit presents theoretical calculations of the electrcctatic and electromagnetic field strengths under the lines which leads him to assert that the - public "will have no direct perception" of the fields ( 1, p.23), by which I take it he means there will be no spark discharges from insulated objects such as rubber tired vehicles to people (1, p. 20).

The most comprehensive (14,000 pages of testimony) and recent investigations into these effects that I have been abic to find have been the New York State Public Service Commission hearings, Cases 26529 and 26559, which j

took place from 1976 ~to 1978. These hearings concerned the effects from 765Kv lines: it is worth noting that their field strengths, because

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i of diffcrant geom 2try of the conductors are somswhat smaller than the 500KV lines proposed by the Applicants, i.e. E of 9KV/M at one meter above ground, B of 0.13 g for the 765"KY lines (2, pp. II-6 an? II-7), as opposed $Y E

= 11KV/M and B

= 1 g at ground (1, p. 24).

max max Evidence was presented at these hearings by Dr. D. W. Deno of General Electric that currents as high as 3 5 to 4 ma have been measured in a person standing on wet earth touching a school bus standing on asphalt.

( 2, II-3) Perceptien thresholds for adults are in the area of 1 ma.

4 5 ma is considered to be the " release current" for children, and there are 2 cases of children being killed by currents as low as 7 to 8ma. (2,

p. III-ll). The SRI international team that reviewed the hearing testimony concluded that " people will sometimes experience uncomfortable sparks and currents if they touch a vehicle parked within about 50M of the right-of-way of a 765KV transmission line" (2, p. III-16).

There was further testimony of an Ohio farmer, a Mr. Ruggles, that grounding did not solve the problem of induced shocks for his farm near an AEP transmission line (3, p. 44).

On this basis I would contest Dr. Lehman's claim that people will not experience shocks from Applicants' transmission lines, with field strengths apparently 20% higher than the 765KV lines diserssed above.It would seem to me that, without a more ageressive grounBing and education program than Applicants are proposing, there is in fact some likelihood of gross physical damage to unwary individuals. The issue of subtle health effects, which he dismisses on p. 26, I will take up in discussing Dr. Michaelson's more extenrive testi.nony, although as a farmer living in a low-density populativa area I cannot leave Dr. Lehman's affidavit without' objecting to his inclusion of low population density as a factor protecting the publicfrom the possible health hazards of the Susquehanna i

l lines.

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4) Dr. Michaelson's affidavit (4) addresses, at greater length, the l

problems of subtle and long term effects of transmission line radiations.

l On the basis of animal studies reported in (5) of Marino, Noval, Krueger Altman, Warnke, Goodman, Southern, Larkin, McCleave, and Moos, (5, pp 9 to 46) I believe that there in fact are effects produced by electric fields that are potentially harmful to humans. Other studies (5, pp 47 to 51) of Beischer et al, and Gibson and Moroney, demonstrate that j

magnetic fields do in fact affect humans at strengths ~ f 1 g.

o Probably the main witness at the Ucw York hearings alleging biological l

effects was Dr. Andrew A. Marino of the Veterans Administration Hospital, l

Syracuse, N.Y. Applicants' witness Dr. Michaelson spent a good part of his tine at those heerings challenging Dr. Marino's research methods and conclusions, to the peint thn t the UYPSC staff described his testimony as "more suitnble to a slander trial than a fact-finding, scientific investigatien." The NTPSC staff's conclusion, on the basis of the exten-sive evidence presented at the hearings, is essentially my own: that

" biological effects will probably be induced in humans exposed to over-head lines, and that such effects will probably be harmful." (5, p 73)

5) I will submit at the october henrings the summaries of the new York hearings that I have read that demonstrate to me, at least, A) th9 liksliho:d of harm to the public, particularly if i ~ is unaware ' of transmiscion line radiation effects;

3) the unreliable and biased nature of Dr. Michaelson's testimony at those hearings, testimony that he han partially repeated in his affidavit to this Board.

5) If this Board accepts the proposed 500xv line I would urge it to consider requiring the applicants to A) extend the rirht et-way so that the maximum field strength at the edge be limited to 0.1 KV/M;

3) that Apolicants be required to inform people living near the right of way, and especially those such as farmers who may have to use the right of way itself, of the potential ha:ards with recpect tot

1) biological effects, and problems with equipment like pacemakers;

2) sparking dangers, especially while handling vehicle fuel.

I would urge the Board to see to it' that these incues be introduced in some way into the determination of price to be paid for right-of-way acquisition. I would urge the Board to ask Applicants to recalculate their costs under these conditions to determine if undergrounding, or lower v tage line ay be in their and the public's interest.

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REFERENCES

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1). Lehman, Robert P.,(1981), Affidavit of Ecbert F. Lehman in

' Sunoort g Partial Summary Dicoosition of contention M QaDy.

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2) Scott

• dalton, Barry, et al of SRI International (1979), Potential

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Enviry.; @ l_ Effects of To5-KV Transmission Lines: Views Before the i

New Yonf t4t* Public Service Commincion, Casas 26529 and 26559,1976-197F, rieport DOS /EV-0056 t

3) State of New York Public Service Commiscion (1978), Opinion and Order Determininc Health and Safety Issues, Imponing Goeratinc conditions, and.*suth o rizine. in Case 26529, 6neration Pursuant to Those Conditions; OPINIO:: NO. 76-13. NYSPSC

4) Michaelson, Solomon M. (1981), Affidavit of Solomo M. Ilichaelcon in Sucoort of Sunmary Discosition of Contention 17

5) State of New York Public Service Commincion (1977), CASFS 26529 and 26550 - Common Record Hearin~s on Health and Safety of 765 kV Transmission Lines. STAFF'S INITIAL 33IEP. UYSPGC 9

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7 9.30?!!.L 3*CZ"M U?:D A?:P DTSC?IPTIni! OP CUALIFICATIONS James Amory R.D.2 30x 50, Leiaysville, PA, 18t29 Born 4/15/34, Boston, MA

,1c52 ' 5a It years Harvard University. Cambridge, P".

general education 1954 '56 U. S. Infantry, electronics technician

'57 t year University of Chicago, Chicage Ill. - mathematics

'5E '63 2 years University of Wisconsin - Mathe.:'.ics and Engin-eering Sciences (Honor Program); Office of *?aval Research scholarship, summer of ' 60

' 60 ' 61 It yearc, Penn East Engineering, Kutztown, PA - research assistant for design of transformers and chokes; collected data on characteri.Stics of magnetic materials;

' 61-65 4 years, International Ladies Garment Workers' Union (Central Pennsylvania District) - Organiner end Buciness Agent

'65 '66 lt years, Vest Tennessee Voters' Project - civil rights worker, commtinity organizing, legal and gev rnment programs

' 67 '70 3 years, Traditional Indian Land and Life Committee, Los angeley CA - legal research on land and treaty problems,

.American Indian affairs; prepared testimor.y and testified before U.S. Senate Interior Committee l

' 65 '72 construction work, Los Angeles area and Durango, Colo.

Presently member, Carpenters' Local 145, 'tilliamsport

' 72-pre sent Farming 160 acres, LeRaysville, PA. Custon baling business; active with Penn. Farmers' Assoc. on Energ* Park opposition campaign; later chairman, PFA Local Affa.irn Committee; Designed and'(partly) built own solar hone. Helped research t echnol ogy, economic feasibility, and regulatory problems for small cheesemaking plant (Pleasant Valley Cheese House, LeRaysville, PA) now run by small group of farmers.

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