ML20058L222
| ML20058L222 | |
| Person / Time | |
|---|---|
| Site: | Monticello  |
| Issue date: | 06/30/1972 |
| From: | Fleming F AFFILIATION NOT ASSIGNED |
| To: | US ATOMIC ENERGY COMMISSION (AEC) |
| References | |
| NUDOCS 9105130402 | |
| Download: ML20058L222 (4) | |
Text
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Frederick A. Fleming
-- i ATTORNEY A T LA W j,3 t,j{,Jij 6 h IS60 Highland Parkway June 30, 1972 gj.
~~.m tt sr. Paul, Minnesota 55116 "f
(612) 69S-6441 Directorate of Licensing
Reference:
U.S. Atomic Energy Commission Northern States Power Co.
Washington, D.C. 20515 Docket No. 50-263 4
COESNTS ON TFE DEAFT ENVIRONENTAL STATE'GNT BY THE U.S. A.E.C.
DIRECTORATE OF LICENSING 4HWONTICELLO NUCLEAR GEERATING PLANT t
I Experience with past nuclear reactors, e.g., Elk Elver, teaches that the lifetime of the installation is limited by the onset of conditions of leakage within the system which are antithetical to public health.
Experience has s hown, further, tha t a t t he time it is no longer wise to continue operations, the installation is generally contanineted so generally that restoration to non-contaminated status is difficult and expensive to accomplish.
Nowhere in the Directorate's Environmental Statement does he address the cost of either cleaning up the plant after it is once i
abandoned, or alternatively, the cost of allowing the land and plant investment to stand idle and non-productive.
Our tax laws suggest that if, let us say af ter t en years. of opera tion, the plant must be terminated due to the development of unsafe con-ditions, then USP might simply let that property revert to public ownership, through non-paynent of taxes.
Once in the bands of the S ta te of Minne s ota, the property would be non-productive of any benefit; it would produce no tax revenue; it would require naintenance to assure against accidents by interlopers, or alter-natively, it would demand dismantling and neutralization by State suthority at State expense.
I Tha t cost is a very real and important cost, one tha t will only become apparent af ter the passage of time.
Nonetheless it is a cost whicn must be evaluated as a part of the present Environental Statement, 1*
the AEC is to properly address the areas of its responsibility under NEPA.
II In the list of POSTULATED ACCIDENTS there does not appear two very real possibilities which can be expected to result in problems of for greater severity than any which have been identified.
Failure of the enerrency core cooline svstem might lead to the so-called " China problem" with ttle accompanying release of large quantitie s of radioactive poisons.
This Environnental Statement 9105130402 720630 CF ADDCK 05000263 o
4 Directorate of Licensing Docket No. 50-263 pa ge 2 June 30, 1972 Comments of F.A. Fleming properly ought to accept as finite the possibility of such an accident and enumerate in considerable detail the inpa c t of the accident upon the environment.
Where the inpact is understood inconpletely, tha t ought to be pointedly noted, and the effects of a worst possible accident ought to be spelled out.
The recent Vietnan experience nakes it abundantly clear that in times of war, power plants are prime tercets for enemy bombing.
This Environmental Statement has no section devoted to explaining the outcomo of drop a "Daisey Cutter," ping a nominal bomb or a super bomb, e.g.,
upon the installation.
The Environmental Statement pros _1y ought to assess the expected release of such poisons as plutonium from the reactor, the extent of the fall out, the property. damage and the loss of life to the human, animal and plant world.
Bombing night also be brought to bear by eneny action on the ground, as experienced in So. Vietnam in the vicinity of Saigon during the Tet offensive, where the eneny was able to infiltrate weapons to within striking distance by rocket la uncher.
The possiblity of action by a crack pot, or an organized terrorist organization ought to be carefully evaluated, and the question which this Environmental Statement must answer is not the probability of such an accident, but the effects of such an accident when it happens.
III The Environmental Statenent takes a microscopic view of this single nuclear facility and discusses the output of radioactive poisons from this ffcility as if it were the only source of insult.
The cumnulative dose of radiokctive poisons from this Monticello plant must be added to the radioactive poisons present naturally as well as those which nay be expected from additional weapons test fallout and fron all the other nuclear power plants conten-pla ted for this country and the world.
The Environmental Statement repeatedly nakes the self-serving (to the pronotion of a favorablo result) comment tha t releases are "snall" and that the chances of an accident are " highly inprobable."
The values ought to be more critically estina ted, and the outcone for this na tion as a whole ought to be evaluated.
I.e., one is not entitled to take confort fron the estimate that "such an accident has a probablity of occurring only once in 1CO ye ars," if we have 50 such plants scattered around the country, where the odds have it that such an accident is expected on the l
average, na ti on-wid e, every 2 years.
This las t point is nicely illustrated by the editoris1, "Dontt I ls ne the Environnentalists," by Gil Sciley, appearing in the
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Directorate of Licensing Docket No. 50-263 page 3 June 30, 1972 Connents of F.A. Fleming St. Paul Fioneer Press at page 8 for June 30, 1972:
"The Army Core of Engineers talks about storms in terns of how of ten a strong storn is likely to occur--a five-year storn, a 10-yearstorn, a 100-ft:
year storn.
"Any reporter who covers floods finds out that a 100-year storn is likely to occur about once every three years.
I've covered five floods called 100-year storns myself, and I'm not t ha t old. "
IV The se a re only a sanpling of my concern about the adequa cy of the Environnental Sta tement.
A more fundamental concern stens from the fact that the Statement was draf ted by the sane agency which is promoting the development of nuclear energy.
The narvelous capacity of the Agency research establishnent nay be brought to bear upon the problem of dressing up an acceptable Environnental Statenent, but one that makes light of the deficiencies and skips over relevant issues.
It is not enough to say that the Environ' ental Statenont will n
be subject to public hearing, because the public does not have the capacity equal to that of the agency to make out its case.
Thus the "public hearing" is a shan.
The public does not have full and conplete access to the information; the public does not have the investigators to delve into the issues and follow up the loose ends.
It is further dis'ressing to approach this issue with the present stance of the Agency, which is now pronouncedly intolerant of public interference in licensing natters (vis. the Schlesinger Esr Harbor speech. ).
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My infernation is tha t the AEC will have a public hearing on the Environnental Statenant as a part of the Agency environnontal i
review being conducted pursuant to the requirenents of the National Environnental Policy Act.. It is further understood that at this hearing, the AEC staff will be avAilable for testinony and cross examina tion.
l I will appear and participate fully as a party in this hearing; there fore, the above connents should not be interpreted ~ to be I
l tbc conplete statenent of the unde rtigned; these connents plus l
cther cc:.ri6erstionc will be nore fully expolred et the public 1
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Directorate of Licensing Docket :!o. 50-263 page 4 June 30,1972 Coments of F. A. Fleming bearing.
We reserve the right to take additional coments on the Environnental Statement based on the record of the Dublic hearint.
Respectfully subnitted, e
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