ML20053A565
| ML20053A565 | |
| Person / Time | |
|---|---|
| Site: | Big Rock Point File:Consumers Energy icon.png |
| Issue date: | 05/17/1982 |
| From: | Oneill J O'NEILL, J. |
| To: | |
| References | |
| ISSUANCES-OLA, NUDOCS 8205260239 | |
| Download: ML20053A565 (7) | |
Text
..
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 77 d
Ul D BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of CONSUMERS POWER COMPANY Docket No. 50-155-OLA (Spent Fuel Pool (Big Rock Point Nuclear Power Plant)
Modification)
/
JOHN O'NEILL'S DISCUSSION OF NEPA NEPA 102.
2.C.
The proposed Spent Fuel Pool modification is in itself a major federal action, and thus an Environmental Impact Study must be made, including a cost / benefit and need for power study.
There are three arguments I wish to forward.
First the proposal to expand the Spent Fuel Pool is a direct and absolutely predictable consequence of the federal decision not to reprocess and at the same time, provide no "away from reactor" storage of spent fuel.
By analogy, if the government builds a dam, it decides to flood the valley.
We are dealing with the flood, and it is pure legal fiction to pretend that this Spent Fuel Pool proposal is not part and parcel of the major federal action on spent fuel.
Secondly, perhaps the most significant action of the federal government in hisotry has been to engage in a nuclear arms race with the U.S.S.R.
The nature of this arms race is that it is mutual.
The actions of one nation trigger a response from the other, with the USA nearly always initiating the next buildup.
pe$
8205260cM
l Part of the the f ederal action to build a new system is the dogged Russian response.
Dr. Kosta Tsipis and Steven Fetter have recently written in Scientific American that the fallout from a reactor and Spent Fuel Pool hit by an H-bomb would be far more severe and long lasting than that from an H-bomb alone. (See attached photocopy from " Reflections" by Jonathon Schell, printed in the New Yorker and later published as the noted book " Fate of the Earth".)
Physicians For Social Responsibility say that the Rus-sians will very shortly announce that the American Reactors have been targeted.
Any expanded storage capacity would make Big Rock a more tempting target and make the possible fallout that much more devasting.
The Russian targeting and the greater possible f allout is a direct result of the federal government's engaging in the arms race, and its refusal to seriously negotiate arms control.
Thirdly, the great amount of money spent by the federal government in this licensing procedure weighs in favor of understanding the expanded Spent Fuel Pool project as a major federal action. The extensive review of the project, the calculations and the studies have in a major way, involved the federal government.
(I am not here granting the accumcy of the NRC staf f 's review. )
If the project is approved, NRC personnel will be involved in supervising the ALARA program on site inspectors judging the rack's installation.
I said earlier that Spent Fuel Pool expansions are part of a federal, policy. Indeed, the positions taken by the NRC staff in this pro-ceeding have favored the licensee 99.9% of the time.
What stronger -.
argument exists that the Big Rock Spent Fuel Pool modification alone, without considering continued operation, is a major federal action.
My fif th argument also considers the licensing procedure.
l The Prarie Island and Trojan decision required that the NRC must study the prospects for long-term storage of the spent fuel, leaving to the NRC the decision to review this on a case by case basis or in a generic hearing.
The NRC chose the later, but if it had not, the issue as it concerns Big Rock, would have to have been decided in this proceeding.
There is only one issue: How is the highly toxic spent fuel to be stored?
This proceding governs its storage until Big Rock's license runs out.
The rulemaking governs it thereafter.
This proceeding is bound by the generic rulemaking, and as I under-stand it, if the rulemaking finds that no prospects for safe long-term storage exist, this proceeding can be reopened even after the granting of a license amendment.
The issue is waste management, and it is futile and untrue to pretend that the waste management study underway, and the federal waste management policy is not a major federal action.
CONFLICT OF RESOURCES.
NEPA 102.2.e.
When considering the use of stainless steel and other materials, the judges must consider that these will become highly rd 4ioactive and cannot be recycled at the expiration of the license.
The effect is not just to remove in 1982, in pounds of stainless steel from the national reserves, but to remove it from available re-sources each and every time it might otherwise be recycled.
Over a period of time this greatly multiples the amount of stainless steel lost. >
Resources cannot be narrowly drawn.
Resources include the water and the air of the Charlevoix area that will be more contaminated by increased low level emissions as a result of the expansion, and the resultant damage to the food chain and the top of the chain predators, Charlevoix fishermen, hunters farmers and consumers.
Resources also include the materials and energy needed for eventual and permanent storage of water with resultant loss to and therefore damage to the environment.
" Commitment of resources" in reality also includes the surrounding land, 100 miles in diameter by NRC reasoning, that would be affected by a possible accident made more severe by an expanded spent fuel pool.
In a very real sense, this land end water is "put in hock" until the spent fuel pool is safely emptied.
These are resourses committed to the possible-effccts of a pool LOCA and breach of containment, and though this may be considered unlikely, the reasons that such possible damage must be considered in unresolved commitment of resourses analysis are the same that the. Board pointed out motivate the requirement for an evacuation p lan.
THE ALTERNATIVE OF DOING NOTHING j
There is only one circumstance under which no consideration of alternatives makes sense, and that would be that the Board has already decided to grant Consumers Power permission to expand the spei.t fuel pool at Big Rock.
The Board may not take such a prejudicial position, and it is important that the Board know the effect of a L
s ruling against the utility.
I have argued all along that the one percent loss of powers insignificant to the utility, even if this is relatively inexpensive electricity.
Certainly the case for doing nothing has been strenghtened by the decision in Pennsylvania last week, determining that an agressive conservation campaign would elimi-nate the need for a new power plant.
(Copies of the relevant newspaper stories are being made available to me and I will for-ward them within a week with a request that they be considered a portion of this document.)
The risks of expanding the spent fuel pool cannot be fully anticipated.
Some effects, such as the documented dangers of low-level radiation (cf Mancuso study) and the bio accumulation of radionucliedes (cf testimony of Dr. Huver and Mr. Franke) are real and will increase due to an expanded spent fuel pool, whether the NRC chooses to examine these or not.
These should be considered as costs, since they are real, even though a plant may be permitted to operate at these levels.
The medical and genetic effects of low level radiation must also be considered " costs".
Accidents, by their nature and by the experience of the nuclear industry, are unpredictable so the danger of an accident being more severe with an expanded spent fuel pool must also be considered, regardless of the probability of such accidents.
Only one thing is certain:
There is no increased danger or accident or damage of a more severe ac-cident if the spent fuel pool is
'ot expanded.
Thus the possible consequences of such accidents must be weighed against the benefit of one percent of the utilities power, or about 68 megawatts.
Ccnversely.
1
]
4 loss of this power must be weighed against absence of such danger.
It is the staff's responsibility to demonstrate compliance with NEPA.
The issues above must be considered.
If as expected, the NRC staff does not consider alternatives, and does not demon-strate unequivocably that no environmental impact study is neces-sary, it will be violating the Naitonal Enviornmental Protection Act.
Alternatives must be considered, and environmental impact study of the expanded spent fuel pool should be completed.
I support the memorandum of Christa-Maria and the i
reasoning of her NEPA brief.
Respectfully submitted in the interest of Safe Energy.
/
Dated:
May 17, 1982 O'reill All parties served n
r
ouried undirground.
"Q l
~ ~ ~..~ 'T ~
'^
' To this discripti:n of redi:ti:n (9
levels around the country, an addition C uf,,,,,;,,,, called " Catastrophic Rel i
leases of Radioactivity,"in which they remains to be made. This is the fact <
that attacks on the seventy-six nuclear 4J calculate the damage frot
- one-pow;r plants in the United States megaton thermonuclear ground burst on a one-gigawatt nuclear power would produce fallout whose radiation )
plant. In such a ground burst, thec had much greater longevity than t!.at of the weapons alone. The physicist J I
facility's radioactive contents would '
Dr. Kosta Tsipis, of M.I.T., and one 1
}
be vaporized along with everything nearby, and the remains would be car-ef his students, Steven Fetter, recent-b l
ried up into the mushroom cloud, from ly published an article in Scientife O
3 which they would descend to the earth t
i
?
with the rest of the fallout. But CL__
,l whereas the fission products of the weapon were newly made, and con-t tained many isotopes that would decay to insignificant levels very swiftly, the 6
fission products in a reactor would be a collection of longer-lived isotopes (and this applies even more strongly to the spent fuel _in the reanor's.hoW-g), siace the short-lived ones would, for the most part, have had 5
enough time to reduce themselves tc harmless levels. The intense but com-l paratively sfiort-lived radiation frorr; the weapon would kill people in the first few weeks and months, but the long-lived radiation that was produced both by the weapon and by the power plant could prevent anyone from living on a va'st area of land for decades after it fell. For example, after a year an l area of some seventeen hundred square miles downwind of a power plant on i
S which a one-megaton bomb had been' ground-burst (again assuming a fif-g.
teen-mile-an-hour wind) would still i
be delivering more than fifty rems per i
year to anyone who tried to live there, and that is two hundred and fifty times the. " safe" dose established by the E.P.A. The bomb by itself would pro 9 duce this effect over an area of only twenty-six square miles. (In addition, to offerine an enemy a way of redou-bling the etfectiveness of his attackr_in a full-scale holocaust, reactors nrnride targets of unpaIaleledf nr la pos-sible terrorist nuclear attacks. In an earlier, paper, Tsipis and Fetter ob I J
serve that "the destruction of a reactor 1
with,a nuclear weapon, even of rela-tively small yield, such as a crude ter-rorist nuclear device, would represent a national catastrophe of lasting con-sequences." It can be put down as one further alarming oddity of life in a nuclear world that in building nuclear power plants nations have opened themselves to catastrophic devastation and long-term contamination of their
{~
territories by enemies who manage to
~
get hold of valy a few nuclear weap-ons. *
~
If, in a nuclear holocaust, anyone hid himself deep enough under the
,