ML20073P987

Petition of Valley Watch,Inc to Intervene in OL Proceeding, Listing Contentions

ML20073P987
Person / Time
Site:	Marble Hill
Issue date:	04/19/1983
From:	Zeller T AFFILIATION NOT ASSIGNED
To:	NRC OFFICE OF THE SECRETARY (SECY)
References
NUDOCS 8304280011
Download: ML20073P987 (3)

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VALLEY WATCH,Inc.1 P.O Box 2262 Evansvilla IN 47714 812-464 5663 .A ' % k' s

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Secretary of the Commission U.S. Nuclear Regulatory Commission Washington, D.C. 20555 BOARD OF DIRECTORS Attention: Docketing and Service Branch To The Secretary -

Dr. Hugh Spencer This letter is to notify you that Valley Watch, Inc.:

Principal investigator . . .

ORBES Study A) petitions the Commission for status as an H. Joel Deckard intervenor in the request for an O p e r a t o r's Memberof Congress License by Public Service Company of Indiana and John Blair the Wabash Valley Power Association f or the Marble Pulitzer Prize Hill Nuclear Generating Station, Units One and News Photography Two, being built under construction permits Nos nsen CPPR-170 and CPPR-171, and,

• Dr. Andrew JoSemist ISU- Evansville B) requests that a public hearing be held regarding Dr. Richard Wham, M.D. this same matter.

Radiologist- Henderson Community Hospital Valley Watch is a non-profit corporation f ormed to Fred Hauck Preserve 'the environmental quality of the Ohio River President valley. Our organization has standing in this case Save the Valley, Inc because most of our members l iv e in cities and towns Tom Zeller along the Ohio Riv e r, m any o f them in the Madison-President Louisville s tretch near the propo sed s ite. Another Valley Watcit inc large segment of our membership reside in Evansville.

Valley Watch members have interests al stake in this proceeding due to their proximity to the site, and the resultant potential impacts-of such a facility:

, on the healthful quality of their drinking water, l

most of which comes directly or indirectly from the Ohio Riv e r itself; l

on the quality of their lives, living under the l

shadow of a possible evacuation, and devalua tion of property in the event of a mishap; on the health of th em s e lv e s and their families, in the event of a rapid sequence of events precluding an orderly and timely evacuation.

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. Also. many Valley W'at ch members are rate-payers of the public utilitie s involved in this action. They are therefore economically affected by the proposalg and have.no.other mechanism to affect the decision. by the companies to proceed with operation of this costly and unnecessary facility. .

, Yalley Watch is iconcerned a b o u' t a variety of issues related to this

licensing procedu re. -

A.' Issues c o n c e r n.in g the technical qualification of the applicants to engage in the proposed activities:

Are the. companies requesting the' license capable and willing to provi'de the technical expertise required to safely operate a facility of such complexity - and to . strictly follow the detailed operational safety

regulations? PSI"is one of the smallest

• utilities in the country to attempt to operate a nuclear power plant. .The history of the construction

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of-the Marble Hill plant, . including two construction halts in safety related areas, demonstrates a lack of quality assurance capability casting- '

cerious doubts'on the ability of. PSI's management to meet the stringent-NRC standards required for minimum safety.

e When sited for violations of quality assurance requirements, PSI has repeatedly publicly refused to recognize the importance of following such procedures, stating that the problems were merely those of " paperwork". We feel that the danger to the public of operation without' strict adherence to safety regulations are too-great to grant a license to a company with~such o poor track record. -

B. Issues concerning health and safety aspects of operation of Marble Hill

Valley Watch questions the security of the Marble Hill facility. A lackluster quality assurance program which allowed the major construction

. flaws mentioned above is very likely to have allowed other serious safety-4 relat ed flaw s. We are not convinced that the testing of the concrete of the containment ves sel' at the site was adequate to in s u'r e that additional

.significant bubbles are not present'to weaken the structure. For these reasons, we feel-that operation of the plant would be inimical to the health and safety of the population living within 100 miles of the plant.

. The operation of the Marble Hill facility would significantly endanger the water supply-of the substantial population downstream which depends on the

-Ohio River as its sole source for this essential substance. Incidents similar to those which have occurred at other nuclear plants could cause a considerable economic loss to communities along the r iv e r. A more severe accident could cause long-term damage to this crucial source of drinking

! water', as well as cont amina tion of the groundwater supplies fed by the river. For these reasons, we feel that operation of the facility would be inimical to the health and safety of the population living on the Ohio River within 150 miles downstream of th e plan t.

Valley Watch contends that an O p e r a t o r's License should not be granted until a thorough plan exists for ultimate disposal of the dangerous wastes which will be generated by the facility. At this point in time, n o_

licensed facility for the disposal of high-level radioactive wastes exists, i

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or is reasonably close-to completion. Until our society decides that it is '

willing to accept the' risks involved in disposal of such long-lived and

-highly toxic wastes, no'further wastes should be allowed to be generated.

No geologic scheme has been proposed which has been videly accepted by-the scientific community as_ adequate for long-term isolation of the wastes f rom the environment. For these reasons,' we feel that operation of the facility would be inimical to.the health and safety to the populations which will in the ; future reside near whatever ultimate disposal site is chosen f or the wastes. ,

Vc11ey Watch-further' contends that an Op e r a t o r's License should not be granted until a detailed plan exists for d e c ommis s ioning of the facility. ,

No commercial-scale reactor has ever been decommissioned, and no scheme has been put forth which has been widely acewpted by the scientific community as practica11and adequate to isolate the long-lived and highly toxic radioa c t iv e species which will inextricably reside in the plant structure.

For these reasons, we feel that the operation of the' facility would be inimical to the health and saf ety of the population'11ving in the area of the plant, for generations to come.

C. Other issues:

Valley Watch has examined the Environmental Report prepared by the applicant, and have found it to be wholly inadequate. In several areas concerning important ecological impacts, unsupported statements are made that expected impacts-wouId be insignificant. Thorough and unbiased analysis are lacking in areas concerning the amount of radiation expected to be released into the environment. Valley Watch calls for a serious attempt to determine the degree of the ecological effects of wor s t-cas e release of radioactivity into the p l a n t's 'e nv i r o n s .

Vc11ey Wat ch contend s t'h a t there is not now, nor will there be f or more than a decade, sufficient electricity demand in the area served by the applicants to justify the operation of this facility. This issue was raised repeatedly during the hearings on the Construction Pe rm it , and the public was repeatedly told that the issue could be raised again during the i O p e r a t o r's License procedures. In the meantime, in spite of national controversy, the NRC regulations were changed to disallow this topic from consideration at'this stage. Thus the public has been cheated of its chance to examine the proposed benefits of a facility which presents such potentially extreme effects. We f eel that the cost / benefit ratio in the case of this plant is unacc ept able , be c ause without demand f or the power produced by the plant,- there are no benefits to be derived from its operation. An unnecessary threat to public health and safety and the environment should not be a ll ow ed.

Sincerely, Tom Zeller,

! Vice-President l

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