ML20055A365

Motion for Leave to Submit Addl Contention Re Low Level Radiation Health Effects & Economic Costs Based on Des (NUREG-0884) & DC Court of Appeals 820427 Decision.Proof of Svc Encl

ML20055A365
Person / Time
Site:	Perry
Issue date:	07/13/1982
From:	Wilt D SUNFLOWER ALLIANCE, WILT, D.D.
To:	Atomic Safety and Licensing Board Panel
References
RTR-NUREG-0884, RTR-NUREG-884 NUDOCS 8207160215
Download: ML20055A365 (3)

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UNITED STATES OF AMERICA UN ~

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v KUCLEAR REGULATORY C0!CZISSION 3

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AfW Before the Atomic S9fety and LicensinA Board O [

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h In the Matter of fiili CLEVELAND ELII:TRIC ILLUMINATING Docket I!os.

50-440 55 COMPANY, et al.

50-441 f.I:

(Ferry Nuclear Tower Plant, Units 1 and 2)

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r0 TION FOR L" AVE TC SUE!IT i

ADDITIO' tL CONTE'iTION

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Intervenor Sunflower Alliance et al. herby noves the Licensin6 ff Board to grant it leave to amend its petition for leave to intervene f

by submitting en additional contention detailed below. This conten-tien is bnsed on the Draft Environmental Statement for Ferzy, NUREG-0384, which was just issued in late flarch and the decision F

by the United States Court of Appeals for the District of Colum-I bia, Circuit (#741586 and Consilidated Cese #77-1448, 79-2110 and

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70 '.131. ) Decided April 27,1989; Therein lies the good cause for 3

this late filing.

I Low Level Radiation Health Effects ent Economic Costs Actual radintion doses fron nuclear power plcnt gaseous and l'ould effluents to real fetuces, infants, children and adults have never been measured and precisely detezcined. Computerized models based on expected releases are used by the NRC and EPA to estinate radintion doses to hypothetical individuals at the

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boundary of the Ferry Nuclear Power Plant.

b In view of:

1) The overwelming evidence that the rates of infant nortality, f.

enneer nnd birth defects resulting frc exposure to low level ra-diation e.re much higher than previously expected.

Exnaple: (Cancor Ifortality Chetnrns Around Nuclear Facilities _In,--

Ocnnecticut Ernest Sternglass 1979. )

2 ) The linear relatienchip betc een radiction and health effects 8207160215 820713 PDR ADOCK 05000440 PDR n

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1 tending of show that there is no safe level of radiation errocure. '( Et'r III Im_ byel Radiation From Hiroshima T_o, Three flile Island Ernest Sternglass 3 ) Two reports by Ger=an Scientists state that the e posures to real g

N people living in the vicinity of nuclear plants has been underestimated by factors anywhere from 10 to 10,000 times. ( " Tutoriu= U teltschut::

il An Der Universitat Heidelberg Radiologisches Gutachten Zum Eernkraftwerk

.Whyl" and " Radiation Exposure and Health Da= age Due To Nuclear Power I

Production - The Question of Standards and The Need For Co=Iaritive Health Damage Analysic " Institut Fur Energie Und Umweltfors: hung, is Heidalberg, Germany)

E Ai m the rndionuclide materials from the plant have net been consi-f dered in the dose commitment calculations (especially alpha emitters).

E 5 ) Ectimates of expected doses are calculated for radionuclides inges ed h

during that year, ignoring the long lived nuclides already stored in the f

body.

E 6 ) Radiation doses from groundwater contaminated by dercsition of air-E born radioactive naterials are ignored.

Sunflower Alliance g g. therefore contends that the THC Staff h?.s not correctly calculoted the dose levels to real human beirgs from routine E

emissions from the Ferry Nuclear Fower.Flant, rendering the long term

!!s environmental and health effect calculations iny,11d.

f Sunflower Alliance et al. also contends the cost benefit analysis has been skered in favor of licensing FNFP by the failure te include the value of locally crozn and consumed food and nurceq crcps to the local and larger N.E. Onio economy, in its analysis.

il Requirements for Late filing Under 10 CFR 2.714 j

Sunflower Alliance et al. has met the reouirements for late-filed co -

l tention under 1CSFR 2.714. This contention is based on the recently issuei Ferry DES; and.on a recent court ruling. These factors constitute abundant good cauce for late filing. Sunflower Alliance has only this proceeding in which to protect its interests; the issues considered berein are spe-cific to the Ferry facility, and therefore cannot be proper _y resolved by any other means. Sunflower in addition knows of no other par'y that is raisirg these issues. The inclusion of there contentions will certainly i

nid in the development of a sound record. Although the issues will be ai l

somewhat broadened by the admission of these contentions, the a=ount of 1.,1 h

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delay, if any, caused thereby is unknorm. The above factors clearly r

favor the ndnission of thic contention into this proceeding, and

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r Sunflower Alliance et al. prays that the Board is so moved.

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Dabiel D. Wilt, Ecq.

Attorney for Sunflower Alliance Inc.,et al.

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c; Brecksville, Ohio 44141 g.

(r16) 5?6 0350 N

i, SERVICE c

A copy of this Motion for Leave to File Additional Contention F

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,.r day of July, 1982, O <

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Danjel D. Wilt, Esq.

Attdrney for Sunflower Alliance Inc., et a1 i3 E

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