ML20039D039
| ML20039D039 | |
| Person / Time | |
|---|---|
| Site: | Indian Point  |
| Issue date: | 12/02/1981 |
| From: | Corren D GREATER NEW YORK COUNCIL ON ENERGY |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| *SD-38, *SD-39, CONTENTION, NUDOCS 8112310246 | |
| Download: ML20039D039 (5) | |
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NUCLEAR REGULATORY COMMISSION 7.
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BEFORE THE ATOMIC SAFETY AND LICENSING BOARD
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CONSOLIDATED EDISON COMPANY OF NEW YORK
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Docket Nos.
(Indian Point Unit 2)
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0 POWER AUTHORITY OF 1HE STATE OF NEW YORK (Indian Point Unit 3) s'; '
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CONTENTIONS OF THE GREATER NEW YORK CDUNCIL ON ENERSY The Greater New Ycrk Council on Energy (GNYCE) submits the following contentions which clarify car interests within the parameters of the Comission's order of Janua*y 8,1981, as amended.
It is the position of GNYCE that, in this hearing which was ordered by the Comission to investigate the safety issues raised by the Union of Concerned Scientists, that the safety issues should receive priority procedurally.
Indeed, we believe that in any case the human implications and the protection of human life and health are of primary importance, and should ~ e considered o
before any consideration is given to economic consequences referenced in the Comission's question 6.
Furthemore, in this proceeding, there is a specific reason to consider accident consequences and emergency planning 3
to mitigate heal th effects first.
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s The hearing seqdc.:a should follow the logic implied by the Commission's granting the Atomic Safety and Licensing Board the right to determ' ne interim operation for the Indian Point Units.
For this i
to be done in a timely and meaningful fashion, issues pertaining to the safety of present operation, i.e., the consequences of reactor accidents and the methods or efficacy of their mitigation, should be addressed first. -
In the case of the mitigating factors-- emergency planning to protect human life and health-- a pragmatic, realistic assessment must be made of human health consequences,.with or without the mitigating factors of emergency plans, from reactor accidents.
In addition to human health consequences of reactor accidents, there is a variety of other aspects of reactor accident consequences, including several economic considerations.
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In its Order of January 8,1981, the Commission seeks information on the economic consequences of closing the Indian Point Units.
If the Conmission indeed wishes to change its traditional position from that of not considering solely economic issues explicitly in fulfilling its chartered role of assuring nuclear safety, then this must be-done as thoroughly as is possible.
The economic consequences of closing the units must be compared to the economic consequences of operating the units.
Such consecuences involve differential costs for the fuel,,.;aintenance, capi.tal investment, along with many other costs. Of primary importance logically in this proceeding, however, are the costs of a reactor accident, the risk of which is only attendant to the continued operation of the plants.
We submit the following two contentions on the issues delineated by the
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Commission's Order which we will present evidence on.
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3-1 CONTENTIONS OF GNYCE:
CONTENTION I:
Viable alternative strategies exist to incurring the excess fuel costs associated with early and permanent shutdown of Indian Point Units 2 and 3.
Therefore the NRC would not be justified in permitting the continued operation of the units solely on the grounds of supposed economic or energy need, especially in the face of threats to the health of the public posed by accident consequences.
The failure of State agencies or the u'tilities to implement such strategies cannot be held to imply that such strategies are not viable, would not save or produce sufficient energy, or that such strategies would not limit or eliminate excess fuel costs.
o Basis for Contention I:
S'uch viable alternative stra egies would include electrical conservation through rate reform or financial incentives; institutional conservation i
strategies such as electrical conservation in large buildings or in mass j
tra'nsit systems; cogeneration; increased use of hyd'roelectric generation and increased importation of hydroelectric generation; coal conversion; se bf 4'S e
i natural gas; and the use of wind and solar electric generation.
CONTENTION II:
t The economic costs of an accident at the Indian Point reactors which involves the releases of radiation-- or solely the threat of releases--.and i
the implementation of protective actions spontaneously or as advised by authorities far outweigh the costs of the energy and economic impacts of permanent shutdown and decommissioning the reactors.
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s Basis for Contention II:
The continued operation of the Indian Point Units is not a no-ctst option; f
comparison on a net basis of the costs of imediate shutdown versus delayed shutdown must 6e consid'ered in assessing the economic risks associated with continued operation of Indian Point.
The expenses attributable to a significant release of radiation offsite would include' costs of imediate and long-term health care, costs of imple-l menting protective actions (including costs to private and public entities),
l costs of private and public property damage or the loss of use of private and public property for many years, the costs of pain and suffering, and business and employment losses which would have secondary effects throughout the United l
States and the world.
O In addition would be the considerable cultural costs resultant from the i
possible loss of the uniquely valuable educational, comercial, technological, and cultural re:ources of the New York City greater metropolitan area.
l The costs of accidents for which protective actions are taken but which 1
do not involve releases of radiation would include the costs of the implementation l
of the protective actions (including costs to private and public entities)w costs of pain and suffering, costs of the temporary loss of use of private and public property, the costs of business and employment losses, and the costs fro.m business and employment disruption.
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The costs of imediate shutdown would include the loss of use of the reactors as generation sources for a number of years, and attendant loss of revenue from capital investments.
Decomissioning of the reacto s would occur later at c
any rate.
The additional costs (or savings) due to the early decomissioning would be small compared with the costs of an accident as cited above.
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Secondary beneficial economic effects would accrue from the increased employment and advantages of decentralized energy sources from the use of alternative energy strategies to replace the energy generated by the Indian Point Units.
December 2, 1981.
Served by hand on all parties to the proceeding.
o Respectfully submitted, - '
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Dean R. Corren, Director Greater New York Council on Energy
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