ML20087H089

Comments on Des (NUREG-1033).Assertions Re Socioeconomic Impacts from Station Operation Demonstrate Low Level of Expertise Among Study Team or Refusal to Consider Relevant Research Findings on Social Impacts

ML20087H089
Person / Time
Site:	Satsop
Issue date:	03/12/1984
From:	Freudenburg W WASHINGTON STATE UNIV., PULLMAN, WA
To:	Vietti A Office of Nuclear Reactor Regulation
References
RTR-NUREG-1033 NUDOCS 8403200238
Download: ML20087H089 (2)

Text

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WASHINGTON STATE UNIVERSITY PULLMAN,WASillNGTON 9?la i

DEPARnfENT OF SOGOLOGY/DEPARn1ENT OF R'IRAL SOGOLOGY Room 23, Wilson IIall March 12, 1984 Ms. Annette Vietti Division of Licensing U.S. Nuclear Regulatory Commission Washingten, D.C. 20555

Subject:

Assessment of Social and Economic Impacts in Draft Environmental Statement Related to the Operation of WPPSS Nuclear Project #3, Docket 50-508, Washington Pub)ic Power Supply System.

Dear Ms. Vietti After several attempts, I have just received a copy of the Draft Environmental Statement (dEIS) noted above (NUREG-1033). Partly because the document itself does not make it entirely clear what day would be the actual deadline for receiving comments on the Draft EIS, and partly because an omission noted below'is so acrious that I am certain that your study team would want to consider it in the interest of producing an adequate impact statement (regardless of the actual date of the deadline), I am writing to call your attention to a serious problem /crror in the draft statement.

Specifically, the abstract of the dEIS asserts without documentation that "the-net socio-economic effects of the projects will be beneficial," and page 5-8, after a brief description of some economic considerations, notes that "the staff antici 'a' no other significant socio-economic impacts from station op-i eration." Thes- 'atements (particularly the latter one) demo s trate either an unacceptablely a tevel of relevant expertise among the study team or else a refusal to consider . ' int research findings on the social-impacts of WNP-3.

The local social environment has changed greatly, and the social impacts of the licensing and operation of the plant are likely to be dramatically different from those that were envisioned in the original EIS on the construction permit phase of plant. An analysis by Rodney Baxter and myself has shown that attitudes toward local nuclear facilities have declined dra-matically in nuclear " host communities" across the entire nation (Freudenburg l and Baxter, 1983), for. example, and even more pointedly, as noted in a report j prepared by Robert L. Wisniewski and myself-(copies of which were shared with '

,the Washington Public Power Supply System), "there is greater local opposition to the WPPSS nuclear plants than to the nuclear facilities of any of the other

" normal" host community in the history of surveys in the U.S." The level of-opposition mear.the 'Satsop facility, inifact, is matched'only by a survey done C,00 L B40320023884b312. 2 5 '

PDR ACCCK 05000508-o b -

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.e Ms. Annette Vietti March 12, 1984 Page 2 at Three Mile Island itself, only four months after the infamous accident (Wisniewski and Freudenburg, 1981:38). These reports and others have noted further that the social consequences of permitting operation of a facility over such intense objections could be grave indeed.

I further call to your attention to the fact that the Regulations for Implementing Procedural Provisions of the National Environmental Policy Act make it explicit that " worst-case" assumptions should be utilized in situations such as these where the absence of an adequato quantitative data base nakes it difficult to predict with any precision just what specific impacts are likely to occur. I also call to your attention the fact that, as noted in a forthcoming article in The Harvard Environmental Law Review, the recent bupreme Court decision in the Nuclear Regulatory Commission vs. People Against Nuclear Energy (PANE) would not be relevant here, since that case had to do with PANE's contention that an environmental impact statement was required even though no (non-psychological) physical environmental impacts were alleged. In the current case the Nuclear Regulatory Commission has clearly decided that an EIS is required, and is merely failing (in clear violation of the Council on Environmental Quality guidelines for EISs) to make best or even " token" use of the available scientific expertise on the likely social impacts of issuing an operating license for WNP-3.

If I may provide you with any assistance in responding to the substance of these comments and/or in identifying scientists with the relevant expertise for responding to the comments, please do not hesitate to contact ne at the address on the letterhead above.

Sincerely,

/ptg b i #

William R. Freudenburg 9

Associate Professor WRF:gm