ML20040E325

Package of Three Ltrs Supporting Continued Operation of Facilities

ML20040E325
Person / Time
Site:	Indian Point
Issue date:	01/28/1982
From:	Arnold N, Short J, Todorovich M AFFILIATION NOT ASSIGNED
To:	Atomic Safety and Licensing Board Panel
References
ISSUANCES-SP, NUDOCS 8202040183
Download: ML20040E325 (10)

Text

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,~ c w BrooHyn ChamberofCommerce .g, 26 Court Street /2g Brooklyn,NewYork11242 (212) 8751000 PgIO January 12, 1982 Atomic Safety and Licensing Board Nuclear Regulatory Commission of the U. S.

Civic Center Westbrook Drive Town of Cortlandt Peekskill, New York Gentlemen:

Please enter the attached testimony In the Matter of CONSOLIDATED EDISON COMPANY OF NEW YORK, INC. (Indian Point, Unit No. 2) and the POWER AUTHORITY OF THE STATE OF NEW YORK, INC.

(Indian Point, Unit No. 3) , Docket Nos. 50-247 SP and 50-286 SP for the hearing scheduled for 1/14/82. f 'LbD e Q'

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John Short A Acting President '7 (h JS:G Enc.

cc - Of fice of -the Secretary U. S. Nuclear Regulatory Commission Washington, D. C. 20555 q)5 d s

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BrooHyn ChamberofCommerce 26 CourtStreet *g Brooklyn, NewYork11242 January 14, ld'dQ (212) 8751000 Pa g STATEMENT OF JOHN SHORT, ACTING PRESIDENT, BROOKLYN CHAMBER OF COMMERCE, AT HEARING BEFORE THE ATOMIC SAFETY AND LICENSING BOARD, NUCLEAR REGULATORY COMMISSION, UNITED STATES OF AMERICA "My name is John Short and I am here to speak as Acting President of the Brooklyn Chamber of Commerce in support of the petition of Con Edison and the Power Authority of New York State to continue operation of, and to oppose the shutdown of, Indian

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Point Units No. 2 and No. 3.

"The Brooklyn Chamber of Commerce is an organization which counts among its membership over 1,000 community and business leaders in the Borough of Brooklyn. These leaders come from close to 700 individual Brooklyn firms. They range in size from Mom-and-Pop stores to the Borough's largest employers.

"They have banded together to initiate programs and take public positions on economic issues which affect the business cli-l mate and job market within Brooklyn and affect its residents as l

l well.

l l " Speaking as their appointed representative, I can say l

l there is one thing on which they are in total agreement -- The last thing Brooklyn business and residents need is an increase in energy cost, particularly since they already pay the highest rate in the nation.

"There is no question in our mind that a decision to shut down Indian Point Units No. 2 and No. 3 would:

e Increase our dependence on foreign oil supplies; e Decrease the reliability of electric service in downstate New York; - over -

e e Increase fuel bills immediately by at least the amount experienced during the recent shutdown of Unit No. 2; e Provide additional long-range construction and use cost increases to users when these pland or their substi-tutes are forced to convert to oil; e Have a devastating effect on the business and job cli-mate, for any raise in energy costs will, without doubt, result in a decision to close or move by those businesses already on the brink of closing or moving because of the present high cost of energy.

" Efficient and cheap, not more expensive, energy is one of Brooklyn's major needs if its economic revitalization is to become a reality. While it is by no means the entire answer, we ask you to recognize the continuance of Indian Point Units No. 2 and No. 3 is an important part of the whole answer. That is why we strongly urge at this point in Brooklyn's history that rather than shutting down Units 2 and 3 you grant the petition of Con Edison and the Power Authority of New York State to continue operation of these 3 Units."

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CHAMBER OF COMMERCE OF THE BOROUGH OF,.QMEENS L. .:

CITY or NEW Yong NED R. ARN 24-16 QUEENS PLAZA SOUTH W

.@ yLOp'lSL6MGCI'TY,

' N.Y. Ii101 RAYMOND J. KRASINSKI '

Trmw Teleph e JAMES J. THORNTON [ O Executive Vice-Presideat 2 er, . .-

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'V January 20, 1982 cN/N cc Ils II Mr. Louis J. Carter pac "I

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Atomic Safety and. Licensing Board c/o Office of the Secretarf-United States Regulatory Commission Washington, D.C. 20555

Dear Mr. Carter:

The Queens Chamber of Commerce representing the business community.as'well as the well being of its two million residents se'eks your support of the continued operation of Indian Point nuclear units 2 and 3.

It is significant to note that the nuclear power generated at Indian Point 2 and 3 provides about 30 percent of the electricity used in New York City and Wes tches t'er . It would take 18 million barrells of oil to produce that much electricity at an added cost of $600 million per year.

This increased cost would place a further burden on the elderly and low income families plus the substantially increased cost to the business and industry of New York.

Respectfull'y yours, OJ K SM.G NRA:br NED R. ARNOLD President 0 503 S

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C:INCr.:::1 1 SCIENTISTS AND ENGINEERS FOR SECllRE PR ENERGY'OD.f4 UT rgo Sevenrh Avenue - Suite too7 _ .. Fd-2Ed Y/3 i New York, New York toot 8 v 'G.= l

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Miro M.Todorovich, Executive Director 32 e,,,, 48 P 2,.u

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metrin conim I 7d;,',2lf,j2" ,,ch*'"" ,,, TO: Louis J. Carter, Chairman . fi I %'

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wrussRs < Partian ti. tin > - FROM: Scientists and Engineers 7 (/. k}'

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m e. et cals forma, s.rk.l .s for Secure Energy (SE 2) -

Seary B. Barschair 7 r-

,,g;<;<, ygge, ~ ~ ~ RE: Remarks Concerning the Matter of C 'solidAteK c=." = ~m . Edison Company of New York, Inc. (In Feits Bioca lI-

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Datid m .., Bodans,ky m o ~~~=

Point, Unit No. 2) and Power Authority of the .

State of New York, Inc. (Indian Point, Unit "Z'L 'an."O*I? u.. No. 3) [ Docket Nos. 50-247 SP; 50-286 SP]

D. aitan Broatey raJ. Neerss te

ds",'.d"r **'*m, . DATE: January 14, 1982

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• Ezrt Coh.n stanterd mr.rsay Thomas J. conaatty stanford me.rssev y=,c;,,T, Jr.7,,s.. As allowed for in the Atomic Safety & Licensing 9,5"/j'"."" t. ,to,r. Board's December 10, 1981 Order (Scheduled Hearings a.,n7, gi,9.,,,,m, for Limited Appearances), Scientists and Engineers ainers cord

- nn ,e.cs- for Secure Energy (SE ) hereby submits its state-viit s a= v. sa==

ment of position concerning the Board's current

.nJ*.'rO.*.07, m m ay m""'.m hearings on Indian Point Units 2 and 3 [ Docket Nos.

no rt sof.tade.,

stentard tasverssty 50-247 SP and 50-286 SP].

Benram Kersunostu case.rasty et mau L..

Rob.rt,sd sort! ' ns: vereste g g g L.ota Libby mv. et :skst:tres. L A

. John McCarthy stanford Jnsvernats Jobs P. Wadison

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General Consideration i

m eers 4 * , of c'ucase

' Thomas Pigford i

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,w..m mt. .,.u Like all questions of safety, those concerning ,

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.sa . an..ac., nuclear power plant safety can be pushed to inordi-m m ~ ~ a, N rman C. Raamussen nate lengths. All people would like to be as safe

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as possible, and thus, arises the temptation to

" .,'"Ja . = quest for an absolute assurance of safety which is,

""".'"li "f ",%.t, in reality, unattainable.

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Malco ta J. Shermu stat. t vu e. cf 5 v. A;bam

d"/jJ,* "".,. a , When such unattainable goals prove unreachable, 9603 Tf_,2;j= ^f'" some claim that the matter at hand should be 5

• 2"",d",,~ag'*l""" dropped altogether. Thus, statements such as

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• n,M,' '*"L, m ....a s ., "Since nuclear power cannot be made absolutely

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, safe, it should be banned" are often heard in the [(

Richard,

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public arena.

Werner 80tf

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. cn - s , a, u m a t *. s s e t t. . te-t s t . :s t . css :nst R.Leshe Dugan.Testern Retresentatisc Ot3 Market Street, Suite 93o San Francisco. CA 94105 - (4td 495 5669 Mark R Mtils. 5e:er.tsc Re:tesentattve

• 122519 Street NW. Suite 4t3 Washtngton, DC 2co36 - (202) 223 5381

' i* StatCO:nt of Position Subnittcd by SE2 to th3 Atomic Safety & Licanning Board Concerning Indian Point Unit Numbers 2 and 3 January 14, 1982 The way to resolve this artificial dilemma is actually quite simple:

When the safety of nuclear power technology has experiencially reached a level equal to, or better than, that of other technologies or natural phenomena which mankind finds acceptable, then nuclear power technology has also achieved a satisfactory level of acceptability. From then on, the uses of nuclear power for the good of society should be fostered -- not hindered.

SE9's professional membership (and that of all other pertinent -

professional organizations) contends that such a satisfactory and -

acceptable level of safety for properly run and maintained nuclear sower plants has long been attained. Comparative risk studies save established this point beyond reasonable doubt.

Conseduently, the Ate of probing currently being undertaken by the Atomic Safety & Licensing Board seems to address the wrong issue from the wrong vantage point.

Indeed, most of the serious problems, like those that occurred at Browns Ferry or Three Mile Island, though initiated by mechanical malfunctions, were exacerbated by human inadequacies.

Consequently, SE2 would be very supportive of an effort by the Atomic Safety & Licensing Board to study this situation and search for ways in which to assure for better human execution of necessary and required, well-designed, nuclear power plant opera-tional procedures. SE2 would also fervently applaud efforts by the Atomic Safety & Licensing Board to study the conclusions i offered by the Kemeny Commission and attempt to avoid the per-petuation of interminable progressions of hearings and what could be labeled " paperwork safety."

I Recommendations issued last Fall by the President's Nuclear i Safety Oversight Committee could represent a good starting point

! for the reform of regulatory procedures; the Atomic Safety &

Licensing Board's voicing of its favor for such a reform would be most welcome. Regretfully, the instant hearing still seems to be no more than a replay of tired and worn-out arguments and scenarios and will not add much to the safety of the Indian Point plants -- a power-producing enterprise which, in SE2's judgement, is already acceptable and poses no undue safety risk to the surrounding population.

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Statement of Po3iticn Sub2itt&d by SE2 to tho Atomic Safety & Licensing Board Concerning Indian Point Unit Numbers 2 and 3 January 14, 1982 .

I l

In summary, questions which should be raised and discussed should not probe whether we should operate all or some nuclear power plants: scientifically, technically, and from the thirty-year record, the answer is already a resounding yes. What we should expend our forces on, though, are efforts to make such plants work properly and efficiently for the good of our society. Such constructive agendas would earn the applause and support of all persons of good will.

Specific Remarks Question #1: Every conscientious writer of examinations would be able to inform the Licensing Board that the question's first sentence, ay is meaningless and unanswerable. A com-parative ana!logue stated,to Question il would be: "What risk may be posed by serious accidents (in a city to a city dweller],

including accidents not considered in the [ rubrics of the New York Times] pending and after any improvements [in the transit system, police, fire fighting, and other municipal departments]."

Without prior definition of " risk" and " serious accident", the question can only lead to a debate over the meaning of " risk" and

" serious accident."

Pursuing this sound guidance of logic, SE2 notes that question il would become somewhat more tractable if it read something like:

"What unacceptable risk may be posed..." This leads us to the

, question: what risks does the public view as acceptable? In the wake of the January 14 aircraft accident in Washington, D.C.,

l passengers are still flying planes, despite the fact that the l

accident resulted in the death of at least 78 people.

SE2 reasons that the overwhelming majority of the public finds that air travel poses an acceptable risk even though it often causes known fatalities. In contrast to this is the reality that commercial nuclear power plant operations have never caused any known fatalities. Thus, using the same yardstick to assess risk, the commercial uses of nuclear power should be viewed as even more acceptable than air travel.

Some claim that the risk of flying is deemed acceptable precisely because it is viewed as being a necessary component of modern life. Thus, people are willing to face the extremely small

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Stat; ment of Po2ition Subnitt;d by SE2

. , to tho Atomic Safoty & Lican31ng Board Concerning Indian Point Unit Numbers 2 and 3 January 14, 1982 probability of a fatal accident in exchange for the " essential" service provided by air travel. The same can be claimed for nuclear power since it is but one of several, varied, but essen-tial, methods of electrical generation that must be employed if this nation's technological society is to survive. Electrical power, which nuclear power plants help to produce as well or better than other power sources, in terms of environmental acceptability and assurance of human safety, is as important to the society's physical and psychological well-being as any mode of transportation. (In fact, without it, modes of transportation available today, and the quality of life they both represent and help maintain, would cease to exist) . In other words, the ser-vices provided by electricity, and particularly nuclear power-generated electricty, are essential for the maintenance of modern life. When all the factors are weighed, the small amount of risk associated with nuclear power -- when balanced against its necessity -- should be viewed as wholly acceptable.

Finally, some contend that the use of nuclear power may be asso-ciated with catastrophic scenarios of widespread death and massive destruction. They would rather allow the society to suffer without the benefits that nuclear power can provide than expose it to such a risk. SE2 can only point to studies such as WASH 1400 and the even better Zion Probabilistic Safety Study, which reiterate that the probability of the aforementioned, large-scale scenarios is exceedingly small. Therefore, this type of unsubstantiated and fanciful assertion, and others of its kind, should not be considered germane in a proceeding such as the one now being undertaken by the Licensing Board.

Oestions 2, 5, and 6:

SE2 believes that the Atomic Safety and Licensing Board now has at its disposal sufficient available information to answer question numbers 1,2,5, and 6 in a nationwide, even worldwide, generic manner and that repeated broad-based hearings raising points having to do with general terms like " risk" and

" accidents" and applying them to specific power plants are redun-dant, unnecessary, and a waste of taxpayer and ratepayer moneys.

, Statement of Position Submitted by SE2 to tho Atomic Safety & Licensing Board Concerning Indian Point Unit Numbers 2 and '

January 14, 1982 Questions 3 and 4:

Questions concerning emergency preparedness and evacuation can be discussed in two ways:

(1) What can past experiences under similar circumstances suggest for the future; or (2) Endless speculations about a libeggp of scenarios.

SE2 contends that the first approach is the only meaningful fruitful one. The second has shown to lead to a never-ending cascade of conjectures which prevent an orderly accomplishment of governmental regulatory functions that should be facilitating rather than inhibiting.

Consequently, we searched for experiences on which to draw. The results are as follows:

(a) Known records seem to indicate that major malfunctions in commercial power reactors of American design tend to develop gradually over a period of several days. The same time scan that was available to technical person-nel at Browas Ferry and Three Mile Island to contain the spread of malfunctions is also available to those who wish to implement emergency measures or evacuate the surrounding population. Indeed, nuclear power cri-ses compare favorably with most other technological or natural disasters -- the collapse of a dam, fuel tank

, explosions, generation and spreading of toxic fumes, appearance of tornadoes, and sudden occurrences of ocean tides. On the slower side are river floods, which as a rule offer ample time for evacuation, as do realistically-developed nuclear scenarios. In short, under any rational assumption, there should be ample time for emergency response and evacuation.  !

(b) Massive and orderly evacuations are indeed possible, and the best known example of this kind occurred in Canada in 1979. Between 11:56pm on November 10 (when a 106-car train carrying highly explosive and poisonous chemicals derailed and 11 propane tanks exploded into flames) and 4:10am on November 12, the entire city of

l -

StatOCOnt of Po2iticn Subnittcd by SE2 to tho Atomic Safoty & Lic2n3ing Bocrd Concerning Indian Point Unit Numbers 2 and 3 January 14, 1982 Mississauga - population 240,000 -- was completely evacuated: hospitals, nursing homes, and all. The lock-up of Mississauga became effective at 4:00am of that date. The evacuation was completely orderly, and there was not one single person injured or killed.

Massive evacuations are indeed feasible. There was only one known case of looting, with'the perpetrators promptly arrested and charged. The operation followed the Canadian Transportation Emergency Assistance Plan, which maintains information centers manned 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> a day and which is sponsored by the Canadian Chemical Producers Association. In Canada, any similar peace-time emergency is coordinated by Emergency Planning Canada's Regional Director.

Consequently, the full weight of regulatory bodies like the Atomic Safety and Licensing Board should be thrown behind efforts to insure proper functioning of emergency preparedness and disaster relief organs of the communities involved. For example, in view of the time span available for evacuation and the fact that millions of workers are daily brought in and out of New York City, it is not a question whether the communities surrounding Indian Point 2 and 3 can be evacuated, but rather, whether the services required for such a move will be functioning properly.

In Mississauga, the evacuation proceeded flawlessly. Whether this can be expected in the area around the plants under scrutiny will depend, in part, on the kind of job the Licensing Board does within the context of the posed questions. SE2's position is that speculative reasoning should be left to philosophers and speculative lawyers, while a prime duty of a technical board is to assess the known and real. We hope that the comments offered by SE2 will help the Licensing Board channel this inquiry towards realistic, constructive, and certifiable goals.

Respectfully submitted, t

, I i ~. o , /

s  % :s A,. t e%m, ,

Miro M. Todorovich '

Executive Director, SE2 i

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