ML20032E133
| ML20032E133 | |
| Person / Time | |
|---|---|
| Site: | Humboldt Bay |
| Issue date: | 10/12/1981 |
| From: | Goldberg L REDWOOD ALLIANCE |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| NUDOCS 8111190704 | |
| Download: ML20032E133 (6) | |
Text
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, GRQ Rsdwood Allicnce
'81 iU 22 P2:03 PO Box 293 Arcata, CA 95521 p
707-822-7884 10/12/8:
OFFICE GF SECRETW.
00CXEI41G & SERVae DRANCH (kb Atomic Safety and Licensing Board (f/Q[A U.S. Nuclear Regulatory Commission g
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/6 OC(j / [4.U Attn: Docket #50-133 Washington, D.C.
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Dear Sirs,
104 p
g We are writing for the Redwood Alliance, one of s
member groups forming the Abalone Alliance in California.
We represent the Humboldt Bay region of Humboldt County and speak for a major part of the local population.
Wesley Chesbro, one of the Legal Intervenors, was elected last June to the County Board of Supervisors, in part because of his support for the de-commissioning of the Humboldt Bay Nuclear Power Plant and in part because of his concern for the well-being of the people in this community.
We support the position of the legal intervenors.
They have intervened to protect community rather than corporate interests.
As a community we have been amazed by the manner in which PG&E has been able to influence or effect the course of events in regards to their licensing application.
The utility has pro-mised complete and conclusive seismic studies yearly since 1976; PG&E's legal enterings and statements have been minimal; the com-pany's studies have been as limited as allowedly possible; And yet, PG&E has been granted extension after extension while the legal proceedings have been held in abeyance.
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While this has gone on, the evidence the utility presents g7 b
remains inconclusive, though it points up the fact that the earthquake situation is much worse than PG&E has ever been willing 8111190704 811012-PDR ADOCK 05000133 t.
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to admit.
In fact, the Woodward-Clyde report substantiates the NRC Staff's statement of August 5, 1977, that it cannot be con-cluded that shear failure displacement will~not occur during the remaining lifetime at the facility site.
As stated, potential seismic effects of surface faulting and vibratory ground motion have not been considered in facility design.
No one knows the degree of danger we face with radioactive fuel and wastes stored on site.
There has never been a real examination of this issue.
The people in this community are also dismayed by the lack of resolve shown by the NRC Staff.
In August of 1977 they stated that they planned to recommend denial of PG&E's application to be relicensed to operate.
However on June 3.rd, 1980, at the Prehear-ing Conference, their reluctance to move forward became evident as they resisted the review process relative to contentions and public hearings.
Now the staff has stated that the operating li-cense cannot be terminated and will not expire until Nov. 9, 2000.
However, 10 CFR 2.107a expressly allows the Atomic Safety and Li-censing Board to " deny the application or dismiss it with prejucice The NRC staff's lack of comment on PG&E's failure to meet the Commission's rules and orders shows further irresponsibility. The Redwood Alliance is not willing to allow the NRC staff to sidestep their responsibilities as they recommend that the status quo remain with no action being taken.
We have asked the public to comment on this situation.
We believe, however, that the Atomic Safety and Licensing Board recognizes the full gravity of the situation and will take action to the full extent of it's granted authority.
We were encouraged by the responsible manner of the Board durin; the June 3rd prehearing conference and in your Order of July 14th, 1981.
However, we have at times been frustrated by the time lags that have preceeded Atomic safety and Licensing Board rulings.
We
-3 feel they allow PG&E to be able to draw out the proceedings, rather than force them to act in a responsible manner as concerns the community living near the nuclear power plant.
The citizens of Humboldt County were astonished last January to learn that PG&E is now attempting to remove it's application and at the same time receive the protection of a ruling granted "without prejudice".
Eighteen years of living with the plant, while not knowing the degree of danger because of the inadequacies of the seismic studies, is enough.
The regulations require that the plant be sited and designed so as to be able to avoid if possible and withstand if necessary the effects of earthquakes, 10 CFR Part 50.
Further, the Atomic Energy Act itself prohibits the issuance of a license if issuance would be inimical to the health and safety of the public.
For thirteen years the nuclear plant operated with no consideration given to fault zones in close proximity to the plant, in clear disregard for the law.
When PG&E went on line they operated under a provisional operating license.
During the sixties public concern for health and safety forced PG&E to abandon attempts to construct nuclear plants at Bodega Head and at Point Arena, because of existing earthquake hazards.
In June, 1971, the Humboldt Bay plant was termed the " dire.iest" plant in the nation by Science Magazine.
This was in reference to releases of 900,000 curies of radioactive oble gases in 1968 which was 57% of the maximum allowed for the plant at the time.
Further, when the exposure standards were re-vised from 500 to 5 millirems maximum, Harold Price, the AEC's director of regulations, said doses to individuals living near
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the plant had ranged up to 25 millirems per year.
The Advisory Committee for Reactor Safety (ACRS) of the AEC was " responsible" for the decision to change the provisional license to a full op-erating license.
From reviewing the records at the Humboldt County depository, it appears that the ACRS considered neither the seismic situation nor the radioactive releases or leakage when they recom-mended full license status.
Even with the safety and health problems, PG&E was granted a full operating license in 1969 - less than three months before seismic studies which were required by the AEC were submitted.
These studies led to the necessity for further studies (submitted in 1972) which were reviewed by the new NRC and subsequently by Tom Collins.
It was then Tom Collins' response to these studies that led to the closure of the nuclear plant.
The utility shouldnever have received a full operating license The company now admits that both the Bay Entrance and Little Salmon faults are capable along with the previously undisclosed Buhne Point fault in the immediate vicinity of the plant.
Still unsub-stantiated is the degree of probability of possible surface rupture at the plant site. PG&E has never released a study determining what would be necessary if surface rupture is possible. It has not been substantiated that PG&E would even be able to modify the plant to withstand surface rupture or meet the federal regulations. Further the costs to modify in this case is unknown or at least has not been disclosed.
In light of PG&E's full history in regards to nuclear power generation, sitings, and testimony, they have not shown the responsibility to possess ownership licensing.
When the Atomic Safety and Licensing Board granted the last i
extension, they stated that they and the intervenors "are entitled to an express committment, on the record, from PG&E regarding it's intentions to operate the plant."
The utility's response was in-stead to say they were not yet willing to make a decision as to operating the plant because potential projected costs are high when measured against the size of the facility and its remaining useful life.
The Board responded by giving the power company 30 days to provide a definite statement of intention regarding plant modifications and a proposed schedule for completing the modifica-tions.
PG&E's response was that the company would need six months af-ter the NRC establishes new backfit requirements in order to reas-ses costs.
It can only be inferred that the power company will then determine their intentions, put together schedules, and com-ply with NRC orders.
The utility stated it is now studying various alternatives to resume power operations or to decommission.
How-ever, PG&E does not state if it is considering what modifications would be necessary for the different seismic possibilities.
In fact, PG&E gives no indication as to what is actually being studied what progress the company is making, though the studies should have been two-thirds of the way completed at the time of PG&E's response to the Board's latest order.
In regards to our local area's dependence on outside sources of electricity, the utility has refused has refused to provide statistics to Rewood Alliance members as to transmission of power in and out of the county.
Most local residents support conserva-tion and co-generation rather than dependence on nuclear energy.
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We believe the nuclear plant continues to pose a threat to our
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health and safety.
The Redwood Alliance, acting with concern for the interests of the local community, calls on the Atomic Safety and Licensing Board'to rule that PG&E's application to be relicensed be denied "with prejudice".
It is time the Nuclear Regulatory Commission demand and set a reasonable but definite tbne period in which the plant is ordered to be Decommissioned.
We would like the Board.
to insist that due to PG&E's gross negligence in this hearing pro-cess, their lack of intention to complete full and conclusive seismic and economic studies, and their unwillingness to face resulting costs, that Pacific Gas and Electric Company's owner-ship license be altered with an order for the Decommissioning of the plant.
Sincerely,
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4 Larry lGoldberg
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Carl Zichella M U/d Rob Wheeler