ML20062D693
| ML20062D693 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 11/07/1978 |
| From: | Eddleman W KUDZU ALLIANCE |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| NUDOCS 7811290059 | |
| Download: ML20062D693 (4) | |
Text
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? Um..FAC. F - N N U R 7 Novcmbcr 1978 W l1%
y NRC PUBLIC DOCUMENT ROOM S
1 g2 Op'O}cj[,N g
Atomic Safety & L'icensing Board ~~
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US Nuclear Regulatorv Conmission g
g pg 1717 H Street NW i
4ashington DC 20555 of.ade*
/
g Dear A.S.L.B.
N By postcard received 6 November 78, Kudzu Alliance and I are advised that our requests to become intervenors on the Shearon Harris Nuclear Power Plant being built near New Hill NC has been referred to you.
While we are unable to list all possible grounds for intervention (because, for example, a crucial question may never have been asked yet; we cannot be expected to predict accu-ately all. the problems that may beset a nuclear power plant) our concern for our health, safety, power bills (which nuclear power raises), water resources (which nuclear power wastes), environment, lives, civil liberties, T o.nd our right to pursue uappiness by creating safe, clean alternative energy systems with our money which will otherwise be seized by construction-work-in-progress to build nuclear plants, prompt usa (Eudzu) as an organization of several hundred persons living within 30 miles of the plant site (including one wnese farm was partly taken for the site), and I as an individual so situated, feel we must make our views on nuclear power count now before this wasteful and dangerous plant is built.
With regard to the uncoming hearings on CP & L's ability to ya properly manage and finance the Shearon Harris Nuclear Power Plant (NRC dockets 50-kon through -403), we again are unadie to predict all issues, now known or yet to be revealed, that will substantially affect #P & L's finances or the safe management of'a nuclear clant.
Therefore we (Kudzu Alliance and I individually) reouest that CP & L finance and management eersonnel including those resuonsible for the Q" of the 2nz' Brunswick 1 and 2 plants and the H.B. Robinson 2 olant, fiscal planning of the Harris plant, the actual operation and maintenance, be calledJto testify at this hearing so that we may determine exactly how they have assured themselves cf their ability to aux uroperly finance,and safely operate nuclear power plants, and so that we (Kudzu Alliance and I) :tgt may cross-examine them regarding their contention that th'ey can safely finance and operate the Shearon Harris plant as proposed.
We (KudzuK Alliance and I) wish to raise at least the following suecific issues in addition:
With ooxboro #k on line, CP&L will have a kgenera(1)Needforcower. ting cauacity 50% above its alltime ceak demand.
Power cales o by CP & L grew only 1.9% in the last year recorted (ending 9/30/78)
O and no new summer peak was reached.
Thus, with no nuclear plants M operating, CP & L would have adequate generating capacity and reserve.
N We will raise further argumenra, on this issue also.
(2) Imoroper design, verification, construction and maintenance of the electrical systems at the,3runswick reactors, and the Robinson reactor.
(3) Setting tric setpoints of instruments outside the safe crerating!
l ranges antroved by the N"C for those instrunents.
(h) Failure to prenare safety analyses and proper plans for maintenance work cerformed at reactors.
(5) Inadecuate verffication of uipe cracks in the reactor systess,
Kuded Allieu & W. AccJ.eman to am, a i uovemwr J.7iv puso c and the NRC's granting variances.to verification requirem:nts, insnection requirements, safety standards, insuection by independentz persons and agencies not prof.itin6. from, the nuclear reactor, and any other exceotions which the NRC has-made to'its nornal rules, regulations and procedures at the reouest of CP & L.
(6)
Emnleyment of unqualified and underqualified versonnel as workers, supervisors, safety inspectors and xx use of such personnel in other resconsible cositions.
(7)
Financial responsibility to the CP & L stockholders (I, Wells Eddleman, own 92 shares of CP & L common stock) including dilution of stock to finance the plant in the face of mounting evidence that it will not be needed; assumotion of unwarranted and excessive debt to finance a plant which, if not used, will be perhaps an untenable loss to a heavily mortgaged company such as CP & L, and unich, if used, will necessitate such higher cower rates that many customers will tend to generate their own power (particularly office complexexs, malls and industries) thus reducing power sales while the rate base, inflated with $4.2 billion (CP & L estimat.e) of nuclear power (compared to $3 billion or less total investment in all CP & L's current generating cauacity) is more than doubled,
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thus causing ever-higher power prices which will uause ever more conservation and cogeneration measures which will reduce demand for electricity still more, leading to furtner rate increases to maintain the company's rate of return on investment, or to no rate increases and substantini losses tc the company, or possibly to legislate of utilities commission action to remove CP &L's franchise as a oublic utility due to mismanagement and excessive power rates.
Further financial issues include imposition of construction-work-in-progress rates wni.ch force consumers to finance nuclear power which will not increase the value of their homes and buildings, instead of having the money av&ilable for insulation, conservation, waste heat recovery, solar-assist heating and coaling and other sources of energy which do increase the value of homes and buildings which incoruorate them; consistent misrepresentation of the need for newer and consistent uhderestimation of the costs of the Shearon Harris clant,
({j leading to reasonable doubt as to the accuracy of information suculled by CP & L; inaccurate or incomplete recorting of the tax credits and depreciation allowances for nuclear construction; et cetera.
(8) Fitness, responsibility and reliability (or the lack of all these) on the part of contractors Danniel International and Research-Cottrell, including Daniel's mismanagement of nuclear construction in Missouri, deaths and injuries on that job, firing of a general foreman who revealed improper construction there,and the ERC's auparent failure to have this worker reinstated, and Daniel's attempts to cover up or deny improper construction practices and other improper, unsafe, untruthful practices on any of their construction jobs.
CP & L's award of the cooling tower contract for Shearen Harris Flant to Research-Cottrell so soon af ter one of their towers collapsed killing
$1 workers is particularly suspect.
Did CP & L re-evaluate their decision in the light of tnis disturbing and grievcus news?
How will Research-Cottreal's clans and work be independently stuervised by CP & L the NRC, and local building inspectors to assure that no such tragedy I
or other serious problem occurs._in building four towers at the harris l
Plant site?
o.esearch-Cottrehl's manegen4nt, suuervisors and fcrenen on thct job that had the ecllapse should be cresent at th.'.s hearing to be cross-examined b7 the intervenors, since their. reliability is called into serious cuestien by 51 unnecessary eeaths which zcvernmen) investigators have already blamed on numercus deliberate safety"violatio:
l by 'esearch-Cottrell.
Kad'zu Allianco end W. Rddisman to ASLB, 7 Novcmber 1978 eago 3 (9) The lifetima of onoration that can bo excocted for nuclear power phants in general, and the Harris clants in earticular, due to the buildun of. radioactive. material inside the reactor and primary-coolant loops (and el sewhere), the increasi-ng radioactivity and thermal, radiation and other strees on the me'n1 in reactorz vessels, pipes and other systems; the radiation hazard to workers recatring, maintaining,x wafut refuelin6 and operating reactors, carticularly in light of recent data indicating ernosure limits should be lowered 50% to 90% in order to minimize cancer risk to werkers; failure of systems in older reactors; increasing costs of repairs; and the cost of greater downtime for recairs.
Considering steam tube leaks at the Brunswick reactors, and numerous generic issues raised in a recort by MHB Technical Associates concerning BWR's and PbiF's such as those nlanned for the Harris site, there are serious questions whether these reactors will have a lifetime of oueratinn of 30 to 40 years.
Yet many cost-benefit calculations assume such lifetimes of overation (as they formerly assumed 80% caoacity factors).
To what extent have the NFC, CP &L, the NC Utilities Commission and other responsible parties calculated the marginal costs and benefits
(])ofshorteroperatinglifetimesofreactors?
What contingsney olans are akvailable if one Harris unit must be decommissioned af ter only 15 to 20 years ' opearation?
what assurances have we that reactors will last 30 or 40 years, without extensive and expensive (and hazardous) repairs such as are being made now on certain reactors due to denting, builduo of radioactive crud, and need to reolace steam generators (and other issues requiring refits, modifications and alterations). Many other questions on these noints can be raised.
(10) The safe and sound operation of any industry today includes orotection for the enviromnent.
Considering the doubts exuressed by many resconsible authorities (see e.g. US Geological Survey Circular 779) as to the cost, safety and reliability of any prouosed method for long-term disnosal of radioactive waste, and considering the huge quantity of dangecous radionuclides (an enowmena curiage or radiation) produced in both high-level and low-level waste by nuclear nower olants, and considering the 4-reactor size of the Harris Plant as prcuosed,
(,j it is improuer and unsafe management to proceed with an investment
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of billions of dollars of consumers ' and stockholders ' money without a uroved, mass-production, guaranteed and backed-up method to totally isolate radioactive waste from the coint of uroduction to an assured safe coint of final long-term disnosal.
(See e.g. John Gofman's paper On the Wav to the Bank, CNR 1977-7, which we would like read into the record of these hearings.)
We believe the best way jo safely disnose of the radioactive waste eroblem is not to create this deadly collutant in the first olace.
We will argue amonE other thinEs that without a concelling necessity to create nuchear waste or suffe= the sort of genetic, health, environnental and prouerty damage it can and has caused,.
any action to create more radioactive waste is irrestonsible, unwise, unsafe, immoral, and quite cossibly illegal.
(11) We mi wish to raise cuite suecifically the issue that limitatio9 on topics to be discussed, who can ask questions, when issues may be raised, etc., thougn rationalized by legal and bureaucratic principles, may of ten tend to impede s. +-5 thorou6h and accurate examination of the wisdom of construction of_ nuclear. cower clants.
Snecificallv, the suupression of Floyd Cantrell's views on C? & L's safe nanagement abilities for nuclear olants as demonstrated by their coerating reccrd shows xxxxxxxxX that the N7.C is making irnortant decisions on inconulete and dichonestly cresented information.
Similar cuestions can be raised (and will be) acout the prouer limits on citizen' intervention, on which
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< statomonts will bo included in hearing rccords, on when and how cuostions can bo raised, on the information the N70 and CP & L are recuired to make uublic, on where such information is available, on the reversibility;of. decisions..tak.en.by CP & L,.its contractors
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l and the NFC and its boards and' departments;" independent verification of such things as the uroner setting of concrete being coured now at the site (and all other matters relatinE to uroner construction),
doubts about nuclear nower (E ve to emuloyees and others who raise on the suonort the NFC will i
which the N9C is established to regulate,
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not oromote), et cetera.
(12) The work history, financial holdings, and relationshius of NRC personnel, CP & L officials, and others are clearly relevant to their current views, activities and the zeal (or lack of it) with which they verify the safety, financing, construction and all other aspects of nuclear power. IXn therefore amm villing as insMxfuinziam knoodinatamm an individual to disclose my work history, financial holdings i and contacts and relationshios with power comnany and NRC and nuclear industry personnel as part of this hearing.
Kudzu Alliance and I formally request that all other parties to this hearing, including it, all witnesses, and all NRC emoloyees
(,) the ASLB members wno conduct involved with the Shearon Harris Plant orocosal, evaluation, or any other involvement with the Carolina Power & Light Comoany make as full a disclosure as possible to their knowled e and belief, of their E
work histories, financial holdings, consulting fees paid, and personal relationshins with the nuclear industry and its emoloyees.
We will be orecared to ouestion these eersonnel about hi such matters if they i
l do not make voluntary disclosure.
We request that all parties to the hearing and all witnesses be advised of our disclosure request in advance of the'hearin6 so that they may voluntarily comply with it if they freely wish to.
(13)
Kudzu Alliance and I reserve the right to raise any question concerning any tonic that may nronerly or imoroperly come before the ASLB, the N".C, or any other government entity, at any time.
We recognize' that some of our questions may be ruled out of order, but still reserve the right to ask if they would be accepted, to anneal any decisions
) made, and to file dissenting coinions or cencu""ing ouinions.(1k) Nothing above sha C..m advance by us of the suecifics of any ruling, decision, rule, etc. of the ASL3, the N9C or anyone else.
In a democracy the oecole are entitled to know the full story of what is being uone witn their money and by their renresentatives and government agencies, and to questinn and peaceably attemot to change government policy, i
Presented by Wells Eddleman, Rt.1, Box 183 Durham NC 27705, ohone 919-383-6602; and by the Kudzu Alliance, Box 3036 Chauel Hill NC 27514 chones 919-929-21k1; 919-286-2276; 919-k67-1693 by authority of the general membershio meeting.
Please address all connunications to both Wells Eddleman and the Kudzu Alliance.
l Signed on behalf of myself, and with the general menbershiu meeting's authorization, on behalf of the Kudzu Alliance, a nonprofit organizatio n,.
HfMM -
+' Wells Eddlenan
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