ML20062A557

Protests NRC Slowness in Issuing CP for Facility.Delay Violates Due Process & Leads to Environ & Public Health Hazards

ML20062A557
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Site:	05000471
Issue date:	09/15/1978
From:	Kline R HARVARD UNIV., CAMBRIDGE, MA
To:	Hendrie J NRC COMMISSION (OCM)
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Text

e f HARVARD UNIVERSITY i

OtPanfutNT OF PHysacs LYM AN LAeCR ATORY OF PHYelCS CAussioct. MassacMustTTs 02138 t

15 September 1978 s

Dr. Joseph Hendrie Nuclear Regulatory Commission 1717 H Street N.W.

Washington, DC 20006

Dear Dr. Hendrie,

On behalf of Scientists and Engineers for Secure Energy, hereinafter called SE2, I write to protest the extre=e slowness of NRC in proceeding toward a con-struction permit for the proposed nuclear power plant Pilgrim II. SF2 have many >

members who live in areas served by the New England Power Pool, others in adjacent power pools and several customers of Boston Edison Co., including myself. SE2 has therefore concern for public health, environmental and financial aspects of any decision.

There are important societal reasons for proceeding at once with Pilgrim II. Firstly, by 1986 the legitimate demand for electric power in the New England

region, coupled with phasing out of some older power plants, is likely to lead to ,

a need for more baseload generating capacity. The best device is likely to be nuclear because it is cheaper and less polluting than coal. Secondly, there is considerable national interest in switching f rom use of oil to other fuels. Even if the anticipated increase in electricity de=and fails to =aterialize, the new power station will enable us to reduce dependence on i= ported oil.

SE2 supports fully the need for co= paring alternatives and exploring them fully in a public hearing process as mandated by the Atomic Energy Act as amended and the National Environmental Policy Act. However, these Acts do not envisage unnecessary delay. Indeed SE 2 maintains that unnecessary delay violates the i funda ental legal requirements of due process and can lead to increased environ- '

mental and public health hazards. SE2 maintain that prcept action is a funda-mental require =ent which should bind NRC. ,

The Pilgris II hearing proceeds with excruciating slowness. It appears that the NRC staff are considering alternate sites and reconsidering the financial status; no hearing in' public has been held for a year and it appears that none are scheduled. SE2 :sintains that this is an unconscionable and unacceptable delay.

W/c/60ci3

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t Dr. Joseph Hendrie [

15 September 1978 l Page Two ,

1 It is possible that NRC do not have adequate staff to cope with the workload. If this is the case it would seem that the laws demand that NRC l hire more. If a policy of the U.S. administration prevents such hiring, this would seem invalid and in any case contrary to the publicly expressed intention of the administration to speed up the hearing process. '

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SE 2 , therefore, urge yc4 to speed up this process and request that you take into account the adverse consequences of delay. Enclosed with this re-quest is a paper entitled "The Environmental Consequences of Delay," shortly t to be published in the referred journal Energy, which describes these in more -

detail.

Yours sincerely, ,

R AT V X Y l l

Robert V. Kline dr Enclosure k

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THE EINIRCNME: CAL AND PUBLIC HEALTH CCNSEQUENCES OF

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REPLACE.'GNT ELECTRICITY SUPPLY gg q p Richard Wilson *\ 3.w Harvard University + t The fclicuing paper contains topics presented by Dr. Wilson at the EPG i ucrkshop and ha.t.keeruirsiuded for h!m"~'~n! . ~;c u a.--

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ABSTRACT l The usual problem discussed by environmentalists is the total environmental impact  !

of an electricity generating plant while it is generating electricity. However, a plant is part of a system and cannot be treated in isolation. Provided no generat-i ing shortage develops, almost the same amount of electricity will be generated in any case, but in different ways. Although a goed case can be made for spending money on reducing electricity demand instead of on generating capacity, this is not j well discussed in the context of an individual pcwer station.  ;

i THE LOGIC OF ENVIRCNMENTAL IMPACT STATEME!CS The Naticnal Enviren= ental Policy Act of 1969, and in particular its Section 102, i is the most important energy legislation of the decade. It enjoins each federal agency to consider the enviren= ental consequences of both the proposed decisien and di possible alternatives before making a decision. This has been interpreted very widely by the courts.

As a result of this legislation and its interpretatico by the courts, and in partic-ular the Calvert Cliffs decision, federal agencies write lengthy environ = ental im-  ;

pact statements for each electricity generation station that they are called upon to  ;

i approve in any way. For a large 1000 .We pcwer station, whether coal-fired or nu- '

clear, the impact statement may go into several volumes and cover 1000 or more pages.

However, there is a deficiency of the logic of these impact statements, and this of- i ten leads to an overly pessimistic approach. The estimated environmental i= pact i

• Supported in part by a contract with the Electric Power Research Institute. '

of the proposed power station is listed in considerable detail. When its impact is j compared with the impact of not building the power stations, all too often the power station is censidered in isolation. This leads to an unbalanced comparison-- ,

i the environmental impact of generating the power ec= pared with the economic impact i

of not having the electrical power.

In fact, the pcwer statien must not be considered in isolation because it is tightly coupled to an electricity generating system. If the power station is not built, i life will still preceed. Men will be born: they will live, and die, and use elec-tricity. What will happen as they turn on the switch? Until they turn on the  ;

switch, no electricity is generated. If a particular power station is not built and t no other acticn is taken, the electricity will still be generated--by another gener-ating means if it exists. Beyond a certain point, the system will be overloaded, and there will be forced electricity shutdowns. It is the purpose of this brief dis-cussion to collect together the infor=ation required to approach the first part of  :

this question in a logical way. I will here discuss the effects only of supplying {

electricity by replacing older units in the system. This is based on personal New England experienc'e in the operating license hearings of Maine Yankee, Vermont Yankee, and Pilgrim and recent censtruction permit hearings at Seabreck.

In so limiting the discussion, it must be noted that there are other possibilities. l It is possible that the same capital that might be spent en a new power station

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might be spent upon advertising or devices to curb demand--these might include insu-

• 1ation or individual electricity generators such as windmills. In this sense, there-P fore, the discussion is not yet ecmplete, but the options usually open to a utility are covered. Another forum should be used for these discussions. l ENVIRCNMENTAL MID PUBLIC HEALTH EFFICTS CF AN ALTEFSATE ELECTRICITY SUPPLY The newer electricity generating stations, if of the same type and in the same loca-  !

i tion as those built before, will normally have an envirenmental 1. pact of the same kind but reduced. If electricity is generated by a pcwer statien of a different f type--such as nuclear replacing oil--the envircnmental impact is different.

l The environmental i= pacts of an average 1000 MWe pcwer plant have been extensively l docu=ented.(2-6) As a first approximatien of the environmental i= pact of not build- j ing a pcwer statien, we can esti= ate the i= pact frca a mix of alternate fuels. .

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P PL3LIC HEALTH IMPACT OF CPERATING A NUCLE r PLANT We can make various illustrations ,of how to approach this problem. The impact on public health is emphasized rather than the impact on the environment because this interests me most.

Firstly, in Table 1 (taken from Reference 2) the average public health effects of various methods of generating electricity are listed. This list includes all parts r of the fuel cycles.

TABLE 1 ESTIMATED YEARLY FATALITIES FROM CPERATION OF A 1000 MWe POWER STATION AT 75% CAPACITY N ATU R AL G A.S COAL OIL NUCLEAR EXTRACTION 0.1 1-8* 0.1 0.1-0.3*

TRANSPORT 0 0 0.05 0 PROCESSING 0.01 0.02 1 0.5 TRANSPORT 0.02 13 0.05 0 T '

ELECTRICAL GENERATION" 0100?*" 3 300 1-300 0.1 (AIR POLLUTION)

WASTE DISPOSAL 0 0-10 0 0.01 Ti TOTAL 0.05 100 15-310 2 300 0.7-1  !

• THIS ASSUMES THAT EITHER THE MINE TAILINGS ARE COVERED OR THE CUMULATIVE HEALTH EFFECT OVER THE NEXT 100000 YEARS IS DISCOUNTED AT ANY RATE EXCEEDING 1%.

" THE AIR POLUTION NUMBERS ARE MULTIPLIED BY 3 FROM REFERENCE 2 TO ALLOW FOR EFFECTS OF SULFATES, ETC., TRANSPORTED OVER LONG DISTANCES.

• • • THE HIGHER FIGURE ADDED HERE IF THE ME ASURED HEALTH EFFECT OF AIR POLLUTION IS IN FACT DUE TO NITRATES. NOT SULFATES OR PARTICULATES.

I THIS FIGURE IS REDUCED FROM REFERENCE 2 TO ALLOW FOR IMPROVED HOLDUP OF 3ADIO-ACTIVITY AND LACK OF REPROCESSING TO RELEASE 85 Kr. THIS ALSO INCLUDES AN AVER *CE OVER ACCIDENT EFFECTS FROM WASH 1400. THERE IS ALSO A REDUCTION FROM CONSIDERATION OF THE i REDUCTION IN HEALTH HAZARD WHEN THE DOSE IS AT A LOW R ATE.

" THIS LOW FIGURE INCLUCES WASTE DISPOSAL ACCORDING TO B. COHEN,*REV! SED MODERN PHYSICS 7 JANUARY 1977, THIS SHOULD RESULT IN FEW F ATALITIES. t 7711-877.1 Let us consider two examples of the construc icn of a new power station taken fres New England considerations. ,W hat is the effect of building a new 1000 .We nuclear Plant, cperating at 75s capacity factor, at a site which is an average over existing sites? Since nuclear capacity is capital intensive and fuel is cheap, the nuclear l ~

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. plant will always be cperated and other plants turned off. We will then generate s

6.6 x lo Ish/yr of electricity. In the'recent past, electricity has been generated countrywide by natural gas, oil, and coal in the percentages 25, 20, and 55, respec-tively. It is assumed that auclear electricity will replace fossil-fueled electric-ity proportionately. Whether these prcportions are correct depends upon the particu-ular decision prcblen. If no alternative ba'seload pcwer is built, the electricity will be generated by " peaking pcwer"--preisably oil driven. Although oil is less polluting than coal, peaking power is less efficient, and the impact of the large amount of oil is probably ce= parable. (Hydrepower is emitted because it is also capital intensive, has a cheap operating cost, and will always be operated at full capacity.)

TABLE 2 ESTIMATED U. S. FATALITIES FROM 750 MEGAWATT. HOURS OF ELECTRIC POWER GENERATION (1967. DECEMBER 1976)*

TOTAL TOTAL REPLACEMENT NUCLEAR NATURAL GAS COAL OIL FOSSIL FUELS FUELS 6

FATALITIES (180x10 Mwh) (420x10 6 Mwh) (150x106 Mwh) (750x106 Mwh) (750x106Mwh)

EXTRACTION 2.5 60-500 2.0 52 500 11 31 TRANSPORT bek 0 1.1 1 0 Pt/Q PROCESSING 0.25 (2) + (620) 23 + (180-2500) 25 57**

TR ANSPORT (CI.- 0.6 62 190 1.1 62 190 0 ELECTRICAL (-) 185 18000 23 6750 25500 11 91**

GENERATIO.4 (AIR POLLUTION)

WASTE DISPOSAL 0 (640) 0 (640) 0 TOTAL FATALITIES 3.5 940-19000 6750 1000 27000 80-189 (REFERENCE 21 TOTAL FATALITIES 11300 (REFERENCE 4)

• FOSSIL FUELS: 55?L COAL. 20?L Oll. 25. NATURAL GAS OPERATING IN ONE HUNDRED FOURTEEN 1000 MW PLANTS WITH 1000-FT STACKS (99'E PARTICULATE SUPPRESSION) AT 75ik CAPACITY F ACTOR WITH 33?L THERMAL EF FICIENCY. NUCLEAR FUELS: U. S. DESIGN, LIGHT. WATER REACTORS OPER AT.

ING WITH 31Y. THERMAL EFFICIENCY. PARENTHESES ARE USED TO INDICATE ESTIMATES WITH LARCE UNCERTAINTY. THE FATALITIES FROM AIR POLLUTION ARISING FROM COAL AND Ott SURN-ING ARE INCREASED BY A F ACTOR OF 3 PRIMARILY DUE TO EFFECTS AT LARGE DISTANCES FROM THE POWER PLANTS NOT INCLUDED IN REFERENCE 2.

• • THIS IS PROBABLY PESSIMISTIC AND ASSUMES MAXIMUM ALLOWED RADIATION RELEASES. UNTIL FUEL IS REPROCESSED.MOST OF THE 83Kr. FOR EXAMPLE.WILL NOT BE RELEASED.

7711 877.2

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i Using these assu=ptions and the data of Table 2, it is found that, for the 1, power .

t plant, we would have between 9 and 250 fewer fatalities per year. A similar calcu- )

8 lation carried out by Van Horn for 750 x 10  :'.01 of generation indicated a decrease of between 1000 and 27000 fatalities per year. The lower figures assume that sulfur (SO 2 , SO ), nitrates (NOx ), and pa ~iculates are suppressed so that the concentra- [

, X tions are below an assumed threshold--under which there are no health effects caused in man. For existing power plants in the eastern U.S. , from Boston south to Washing-ten and as far west as Chicago and St. Louis, it seems that pollution levels are al- {

ready above a threshold for health effects (if there is one) and the higher figure  :

probably applies.

This number may yet be low for two reasons: 1) the power is now (1977 onwards) more likely to replace oil or coal than natural gas, so the figures may be increased by l 20s, and 2) the nuclear power is more likely to replace older generating capacity in f populous areas and with poorer stackgas suppression and scrubbing than to replace new plants in the .ccuntryside.  ;

r PUBLIC HIALTH IMPACT CF A NEW, WELL-SITED, CCAL PIRIT i Another illustration ecmes when we consider cperation of a coal plant in a good loca-  ;

, tion. Assuming that this has good (99%) particulate suppression, uses low-sulfur fuel, or has scrubbers, let us also assume that it is placed in a coastal site on

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the eastern seaboard, northeast of Boston (the proposed plant at Sears Island, Maine, r

could be an example).

i There are two ways in which this coal plant is an improvement over the average.

First, the prevailing wind is frem the west, so it is downwind of the U.S. (The f 2 international preblems of transfrontier pollution *o Nova Scotia and New Brunswick are ignored for this discussion.) Even in the absence of a prevailing wind, a coastal site takes the airborne pollutants over the sea half of the ti.e, and the sulfates and nitrates are probably more readily absorbed there than over land. These }

factors are discussed by Chang and Wilson. ( The reduction can be estimated to be  ;

at least a factor of 10 from the =aximum effects in Table 2. This brings the total I reduction in fatalities to between -2 and 224 per year. The negative figure cemes i from replacing oil and gas by coal which has =ajcr health problems at extraction, l

and the pcsitive figure ec=es frem a good choice of site--so that polluted air, if l indeed it causes health effects, is not over major population centers. ,

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A similar gain will come from placing a coal plant in an underpopulated western j state, 1000 miles west of the Chicago, St. Louis, Boston, Washington population i L

centers, e.g. , Kaiperowit=. This gain is greatest if it is assumed that the health j i

effects frca sulfates and nitrates are zero below a threshold and this threshold is '

3 above the existing sulfate levels (f ug/m ) in the regien.

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n ENVIRONMENTAL IMPACTS I The environmental impacts are also important, particularly, of course, for Kaiporo- .

witz. The visual environmental impacts are al=ost all concerned with the construc- f tion and existence of the power plant and not its operation. The impacts of " acid .

i rain" on plants are clearly worse for existing fossil plants than for a new nuclear r plant, and a fossil fuel plant with tall stacks sited on a coast will give less im-l pact than older ones inland. Impacts on water are likely to be similar, but there  !

is usually a benefit from operating a new plant rather than an old one. The enviren-mental effects of new plants may well be different frem old ones. Wet-cooling towers ,

are replacing ence-through cooling systems. Although there is less fish entrapment I and fish-kills generally, the wet towers can cause increased precipitation dcwnwind. [

Thus, the only net negative environ = ental impact of a new pcwer plant that is impor-  ?

tant is the visual one of the existence of the plant itself and its power lines--

provided we do net allcw a shortage to develop.

i EFFECT CF DELAY r

The National Environmental Protection Act requires that all alternatives be consid- 1 ered to the preposed action and that there should be a ec=parison of the enviren- i i

mental effects of these alternatives. In application of this law, the precedures [

f are those of the U.S. District Courts, and these procedures, by their nature, lend  !

themselves to delay. In criminal cases this may well be right; better to delay than {

to execute an innocent man. Delay is also likely in an opposed hearing rarely be-cause of inertia.

In environmental and public health matters, delay is often more damaging than actien, j While the delay is going on, life proceeds. Certainly we waste energy excessively, I but the experiences of life in Europe during and fo11cwing World War II demenstrated I the human expense of an unreliable electricity supply. To oppose power stations is Probably the worst way of curtailing censumption.

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' SECONDARY EFFECTS (INCREASE CF ILECTRICITY COSTS) j Let us now consider t,ro secondary effects which have different signs. If a power station wMeh is unnecessary to maintain adequate system reliability is built, it [

will raise the cost of electricity. Since the amortization of the capital expense [

can be added to the rate base, it will also raise the price. The increase in price will reduce consumption, and this will have environmental and public health i= pacts. 3 Although the total i= pacts of reduced censumption are unknown--since the enviren-mental effects of cheap electricity are unknown--the listings in Tables 1 and 2 are proportional to electricity use so that in these ways reducing consumption reduces  :

both environmental and public health impact's proportionally. These ways are assumed i

to dominate the total.

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To i_.ke a numerical example, censider adding a new 1000 MWe power plant to a system  ;

of 10000 MWe capacity (very close to the capacity of the Boston area) . It turns out I i

to be unnecessary and therefore unnecessarily adds to the cost. It adds more than j

" l lot--perhaps 20s-- to the total. capital carried en the rate base because it is a new  !

i plant and, in *Ns of inflation, new plar.: are carried at more than old plants. r

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We can estimate, therefore, that building this unnecessary power plant raises the overall price of electricity to the consumer by lot. Assuming a long-term price elasticity of 0.5, the consu=ption of electricity will go down St, with about a '5%

direct reduction in overall, system-wide public health and environmental irpacts.

Assuming the system has pcwer plants cperating according to the average of =edern plants as discussed before, this demand reduction will further reduce the mortality rate by l i

5 10000 We i x average e ec a 000 We plant, j 100

• 1000 We or 4 to 110 fatalities per year. I I

1 REDUCING INERGY OE.WND [

There may be goed reasons for wishing, at seme time, to restrict de=and for energy.  !

Environ = ental and public health effects will eventually increase faster than the [

energy censumptien increases. Fascurce depletien is also an important facto.. 1 So far the principal way of atte=pting to reduce energy demand has been to use the  !

requirements of the Natienal Invironmental Policy Act to slow or step construction l l .

of now electrical generating capacity or other energy systems. Mcwever, if the t

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argument is logically carried out, the conclusion is reached that the increase in generating capacity should not be curtailed.  !

It is clear that if demand should be curtailed, it is better to curtail it more directly. An increase in price (by taxatien or otherwise) is the conventional way.

This is objected to because it is politically unfeasible and because it may hit the [

poor harder than the rich. Since we want to curb increases more than we want to in-crease existing de=and, an electricity price rising with demand for each individual customer has been suggested. This would be hard to implement because the price in-crease can be avoided by increasing the ' number of customers. A flat rate could, i however, be adopted, but a mere curtailment of generating capacity to cause a short-age may bring =any undesirable public ht ath and environmental impacts and possibly even have the opposite effect to that desired. , lt SECONDARY P.;m; CTS (INCENTIVES) f f

~ns' will be seen in the foregoing, the net gain to public health and the enviren=ent  ;

of building a new power plant =ay be large. Why then do environmentalists centinu-ously cppose the=? There are at least four reasons. ,.

1. The issues may be incorrectly perceived. 3

2. There =ay be a net local disadvantage either to a whole town or to some i individuals in the tevn. To sc=e extent, the taxes en the power station help to ec=pensate the local area. It is important that the effects of these taxes be distributed over a wide enough area to ec=pensate.

3. The environmentalist =ay wish to i=pese his will on others (and we all {

wish to impose our will on others at ti=es) by creating a shortage and i thereby reducing demand. The usual methed of reducing demand--by  ;

increasing energy prices by a tax--has repeatedly been rejected by the American people through their representatives in Washingten.

4. The enviren=entalist nay wish to further reduce public health and en-viron= ental impact by creatien of incentives for the power ce=pany.

For exa=ple, it costs nearly 3300,000 in replace =ent fuel for ever/ day ,

a large nuclear pcwer plant is off line. A power company may well ,

agree to =ake sc=e costly enviren= ental i= prove =ent =erely to get a particular intervenor off its back. .

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ht would seem that these desires (2, 3, and 4) are at least to scme extent legiti-mate and society should be able to devise means of meeting them in a more direct manner. -

CONCLUSIONS The net environmental and public health effects of building and operating a new power plant, of a type well chosen and in a site well placed, are prebably benefi-cial even if the power plant proves to be unnecessary. But in order that this may not be frustrated by interventions, several steps are necessary.

1. Improved explanation and public perception of the issues.

2. There must be proper discussion of the local versus the countryside advantages and disadvantages and, if necessary, adjustment of proce-dures of taxatien and distribution of benefits.

3. A discussion of whether and how to reduce demand is important and this discussion must be cceplete so that those who wish to use in-direct and undesirable methods (such as the creation of a shortage) can.be isolated and repudiated. In particular, it is essential to decide whether the cost of massive efforts to reduce demand is less than the ecs of increasing supply. This decision may not be the sare as the decision en individual bases; an individual usually pays an average cost of electricity whereas the cost of the last kilowatt hour may be more. Although so=e individuals will reduce demand on principle, it seems unlikely that a majority of individuals will act independently and centrary to their financial interests.

4. There must be discussion of how much to improve public health and reduce enviren= ental impact independent of a particular power plant.

When these are acec=plished, we will be in a position to demand the final improve-ment.

5. A speed-up of the legal system so that unnecessary delays should net occur. Pcssibly federal judges should be forced to write brief en-vironmental state =ents befere issuing a stay of actien. This last improvement =ay well spill over into other seg=ents of society.

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' RE7ERE' ICES -

1. Calvert Cliffs coordinating Ccesittee vs AEC, U.S. Court of Appeals for the ,

D.C. Circuit, Case No. 24, 839.

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2. "Che Health and Environmental Effects of Electricity Generation," Biomedical and Environmental Assessment Grcup, BNL Report 20582, 1974, and " Health Effects of Air Pollution," by L. D. Hanilton, BNL Report 20743, July,1975.

3. Teknekron, Inc., " Report for the Enviren= ental Protection Agency," 1973. -

4. R. Wilson and W. Jones, Enerev, Ecoloev, and the Environment, Academic Press, New York, 1974.

Hcm M 4 A d a d f.ctEscu 5[ A"Will Vw the Past Be Prologue?: The Past Health Effects of Fossil Fuel and Nu- jl clear Electricity Generation," Public Utilities Fortnichtiv, 99. 1977, pp. 3 '

and 43.

6. C. Comar, " Annual Reviews of Energy," 1975.

7. B. Chang and R. Wilsen, " Mitigation of the Effects of Sulphur Pollution,"

Center Report, Harvard University, Cambridge, Energy MA, and1976.

July, Enviren=

aMcental ctreda.G Policy / cvs GNL Mfnd- p.,qig3, i

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