ML20039D020

Contentions of Friends of the Earth & Ny City Audubon Soc

ML20039D020
Person / Time
Site:	Indian Point
Issue date:	12/02/1981
From:	Ryan G, Salzman L AFFILIATION NOT ASSIGNED, FRIENDS OF THE EARTH
To:	Atomic Safety and Licensing Board Panel
References
*RS-28, *RS-31, CONTENTION, NUDOCS 8112310222
Download: ML20039D020 (5)

Text

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NUCLEAR REGULATORY C019ilSSION

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BEFORE THE ATOMIC SAFETY AND LICENSING BOARD . ' 2-

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! In the Matter of '

) i CONSOLIDATED EDISON COMPANY OF NEW YORK ) l (Indian Point Unit 2) ) Docket Nos. i

) 50-247 POWER AUTHORITY OF THE STATE OF NEW YORK ) 50-286 (IndianPointUnit3) ) g c

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i CONTENTIONS OF THE DEC3 01937s F l

FRIENDS OF THE EARTH, INC., AND 7

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NEW YORK CITY AUDUBON SOCIETY ,

j l .fW The Friends of the Earth, Inc., (F0E), and the New York City Audubon Society (NYC Audubon) have similar concerns in this safety investigation before the Board, and herein jointly submit contentions in order to facilitate an orderly presentation of issues and avoid NI duplication. F0EandNYCAudubonintendtohaveasingYespokesperson to represent their interests at the hearings, but reserve.the right to have separate spokespersons when and if the situation requires.

The rules of the Nuclear Regulatory Comission, afl0 CFR 50.47(a),

require that emergency planning give reasonable assurance that the public health and safety can and will be protected in the event of radiological emergencies. It is the position of F0E and NYC Audubon that the radiological consequences of serious reactor accidents at the 3, Indian Point Units can extend to pose imediate and long-term health" ~S threats to the greater New York metropolitan area, and that the health- / , b 8112310222 011202 /

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a and safety of the public will not be adeqJately protected in the event of a radiological emergency unless and until reasonable assurance can be given that these immediate and long-term health threats can and will be adequately mitigated.

CONTENTION I:

The consequences of an accident at the Indian Point reactors can include substantial and irreparable harm to the health and safety of the public in the New York City area, and in other areas which are in the vicinity of the reactors. Immediate radiological threats to the heal.th of the public in the event of a serious radiological- energency will include prompt and early fatalities, illnesses, latent fatal or non-fatal. cancers, thyroid nodules, or genetic defects. Long-term health threats can be posed by contaminated soils, buildings, food and water supplies in addition to the long-term health threats posed by releases of radiation during accident conditions. Present snergency planning

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is inadequate to mitigate these health effects, and there are no intprim or future protective measures which could feasibly protect the health of the public.

L Basis for Contention I:

o Accident scenarios which must be considered in detennining doses to the public at risk must include those accidents which are beyond the -

design basis of the reactors, in accordance with the Commission's Order .

of January 8,1981.

o Within two weeks of the releases of radiation from an accident, some 10% of the expelled radioactive matter may be spread by winds and gj

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waters far beyond .the original area of contamination to endanger other regions and their inhabitants. Many radioactive particles remain in a transportable state to pose a threat to the health of people and wildlife, in addition to the threats posed by contamination from the reactor releases directly.

o New York City receives its potable water supply from reservoirs in the imediate' area of the Indian Point reactors.

o The medical and hospital facilities in the area, and the entire nation are inadequate to care for the numbers of potentially contaminated j or irradiated victims, which may be hundreds of thousands of persons because of the sheer density of the population. . Some 17 million people i live within fifty miles of Indian Point.

o Particularly vulnerable persons who are at risk during nuclear l emergencies include young children, the aged, persons who are especially

! susceptible to radiation, the handicapped, and persons who are less able to take shelter or other protective actions or to obtain sufficient 1

medical. diagn'osis or treatment due to financial constraints.

o Radioactive particles released from serious accide'ts n includeg isotopes such as cesium and strontium which have long half-lives and ,

which will remain in the environment for decades and enter the food I chain and water supply. #

o There are no emergency plans for the New York City area to protc?.t

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the public at risk from plume exposure and inhalation exposure, either from releases during an accident or from re-deposition of radioactivity <

after initial releases. .

o The topology of the Hudson River Valley is such that under some

'n _ common meteorolgical conditions, especially rain, very hazardous amounts l

of radiation can be deposited on Ne < York Cit; from serious accidents. -

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CONTENTION II:

The consequences of an accident at Indian Point can include substantial and irreparable hann to the environment, to wildlife, aquatic life in the Hudson and other waterways, to agricultural ~ lands, private proterty, and public recreationala lands. The areas that are directly contaminated during an accident and many surrounding areas may have to be abandoned for decades or even centuries in the event of a se'rious accident at the Indian Point reactors. Consideration must be given to these societal and individual consequences of an accident (which are completely avoided by shuting down the reactor) in considering the environmental consequences of shutdown, as Ordered by the Consnission at Question 6.

Basis for Contention II: -

o New York City. New York State, and the Unites States maintain thousands of acres of land for recreational and conservation purposes within a 50-mile radius of Indian Point. These areas would be rendered unusable for the gamut of recreational and educational purposes whic71 are associated with such facilities for decades after contamination by radiation releases from an accident at Indian Point. -

o There are extensive agricultural lands-- producers of dairy products, meats, and fruits and vegetables--in the fifty-mile radius of the Indian Point reactors. These lands would be rendered unusable for de::ades if contaminated by cesium and strontium or other long-lived isotopes which enter the food chain through contaminated soils.

• e o The loss of use of these agricultural or recreational lands would be an individual and societal consequence which cannot be. mitigated through M,i.

any feasible (present or future) means or through any emergency protective actions.

o Contaminat. ion of the lands and waterways in the Indian Point area would result in long-term threats to the health of people and domestic animals or wildlife if the areas are not abandoned.

December 2,1981 ,

Respectfully submitted, bD VS Lorna Salzman, Mid-Atlantic Director Friends of the Earth, Inc.

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Geoffrey Cobb Ryan, Director l

New York City Audubon Society .

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