ML20063M318
| ML20063M318 | |
| Person / Time | |
|---|---|
| Site: | Perry  |
| Issue date: | 09/03/1982 |
| From: | Wilt D SUNFLOWER ALLIANCE, WILT, D.D. |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| NUDOCS 8209100243 | |
| Download: ML20063M318 (4) | |
Text
,
UNITED STATES CA NUCLEAR REGULATORY COMMISS10N 82 SEp -7 p4:26 Befor_e the _ Atomic Safety and Licensitia Board y0'NI5I S KvM ggAl;Cti.
In the Matter of
)
CLEVELAND ELECTRIC ILLUMINATING
)
)
COMPANY, e,3 3,.
)
Docket Nos.
50-440 1
)
50-441 (Perry Nuclear Power Plant,
)
Units I and 2)
)
l SUNFLOWER et. al. RESPONSE TO APPLICANT'S ANSWER TO JULY 13, 1982 MOTION TO SUBMIT ADDITIONAL CONTENTION.
Although the NSC Staff has conceded reasonable specificity in Sunflower's contention, the appilcant has chosen not to.
Therefore answers to specific responses are submitted below.
The draf t environmental statement does not contain any new information, very true, that's exactly our contention. Ehough Information about the health effects of low level radiation has been amassed in the years since dose level calculations have been completed in the original environmental statement to change the DES conclusions - but they have not been changed.
The dose calculations for the PNPP are not Perry specific by appilcants own admission. The dose commitments do not take into account the wide range of different crops grown in the areas within 50 miles of Perry, not do they take in to account the significant portion that Perry EPZ fresh & preserved produce l
(vegetables, fruit, grain & meat) make up in the diet of Perry EPZ population.
Many people (an increasingly larger number in these depressed economic conditions in northeast Ohio) get the majority of their food from their own gardens and local road side markets. Also totally ignored are the doses received from 8209100243 020903 m -
m
{DRADOCK 05000440 p3 C Q
_ _ _ - _ _ __ - _, _ PD,R,
1 harvested game (deer, rabbit, etc.) fish from Lake Erie and local rivers &
streams and wild growing berries and fruits, all of which contain much higher consentrations of radionuclides than do domesticated livestock. (Methodoloales for the study of _ Low-Level Radletion in the Midwest - Huver et.al.)
Models used are also not sub-population sensitlve for age, sex & locale.
l l
Fetus, infants, children, pregnant & nursing mothers are especially sensitive to low-level emission, as much as 10 times more sensitive as a mature healthy j
" average" male.
Doses are calculated for the " average" individual within 50
(
miles of PNPP - not taking into account the relatively higher fallout nearer the l
l plant.
I I
l We cited nothing new by Stern Glass - but his conclusions have been ignorcJ t
by applicant - and newer studies (Es.
Savannah River Plant Study Report by Robert Alvarez) confirm his conclusions.
t i
Sternglass's conclusions have never been scientifically, conclusively refuted, because the effects of radiation exposure are slow to develop and are very difficult to seperate out f rom other enfironmental effects. There has never been a compre_ hens _ive, sys_tematic_, lona-term study of health effects of low-l LEVEL radiation from a nuclear reactor. The development of a sound record de demands a full comprehensive public examination of all facts from all vantage points, foreigh or domestic, industry or critics, new & old.
Including the Savannah River Plant Study (not yet complete), which is being done under the auspices of local, state and federal officials. The study, just proposed for the same plant, by the center for disease control and the recent WBritish Journal of Epidemiology and Community Health, June 1982 by Alice Stewart.
Page 25.
Detectab&e by whom, and based on what Instrumentation, for how long a time? Dose calculations do not include more that i year ingestion and deposition in human tissue of radio nuclides, doses are based on estimates -
3 the heart of the contention - they are not based on actual measured liquid or gaseous emissions.
Alpha emitters are ignored by the DES. For example N-239 a betta esitter is included, N-239 half life 2.35 days decays to Pu 239, which is an alpha emitter and is not included in dose estimates.
Ground water will be contaminated by the leaching action of rain and melting snows. Anything put on top of the land, fertilizers, chemicals, etc.
are eventually leached to ground water. The ground water table and Lake Erie are connected and Interdependant, they are not compartmentalized. There is flow back and forth and further ground water contamination will occur from radionuclides dumped into Lake Erie from II(uld effulents and gaseous effulents deposited on the surface of the lake.
The contention clearly alleged that food and oursery crops from the PNPP area will be damaged by contamination and their marketability will be damaged.
As the damaging of health by low level radioactivity becomes more aparant to the general public (as it surely will) the public will increasingly resist buying such contaminated crops. The paragraphs categorically deny damage to crops -
the truth remains, crops are conteminated.
Ocses to people who eet these crops are significant and must be studied.
l No one point of Sunflower's contention deserves a public airing, in a licensing proceeding, But taken as a whole, the concerns, questions and potential for health and economic damage demand the development of a sound record.
Neither does the applicant's refutation of one point as to untimelyness l
p,reclude the discussion in public.
The time delay incurred would be very small in comparison to construction time and the operational life span of the PNPP.
4-
)-
I '{ {
D niel D. Wilt, sq.
Attorney for Sunflower Alliance Inc., et.al.
P.O. Box 08159 Cleveland, OH 44108 (216) 249-8777 SERVICE A copy of this Motion b
sent to all persons on the Service List dayofahr.
1082.
~
on this s
n 6
QLAGAt 1AM DaplelD. Wilt,gsq'.
~
At[orney for Sunflower Alliance Inc., et.al.
l l
l l
l 2