ML20115B128

Forwards L Bogart Ltr Requesting Permission to Intervene W/ Encl Statement,For Info of Commission

ML20115B128
Person / Time
Site:	Indian Point
Issue date:	09/13/1966
From:	Mccool W US ATOMIC ENERGY COMMISSION (AEC)
To:	US ATOMIC ENERGY COMMISSION (AEC)
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AEC-R-135-2, NUDOCS 9210150285
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Text

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Sy t" ember 13, 1966_

AEC-R 135/2 COPY NO.

50 Tif 5 /q c,,,q) i f2-E.

ATOMIC ENERGY COMMISSION 6 $/1; / 3, Z,1 i@

CONSOLIDATED EDISON COMPANY OF NEW YORK (INDIAN POINT 2) -

DOCKET NO. 50-247 REQUEST TO INTERVEWE_FROM-THE CONSERVATION CENTER l

Note by the Secretary The attached letter requesting permisolon to intervene, with enclosed statement, from Larry Bogart,, Director of'The Conservation Center, New York, is cin:ulated for the information of the Commission.,

W. B. McCool Secretary 00fY NO.

DISTRIBUTION 0

Secretary 1,50-66 7 - 8,67 2-6 Commicsioners General Manager 9

Deputy Gen. Mgr.

.10 - 12 Dir. of Regulation Deputy Dir. of Regulation 13 Asst. Gen. Mgr.

-14 Exec. Asst. to GM 15-Asst. GM for Admin.

16 Asst. GM for Operations 17-Asst GM for Reactors 18 General Counsel 19 - 24 Complian:e 25 --30 Congr. helations 31.- 32 921oisonso % 32o Inspection 33 PDR ORG NRCHIST Naval Reactors 34 - 35 POR Operational Safety-

'36=--37

. a9 am.As -- m e n es ea

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pu v u,,own n a wu u em v.n p'ot;c by the _ Sec re tcry The attached letter requesting permission to intervene, with encloced statcment, from larry Bogart, Director of The Conservation Center, New York, is circulated for the information of the Commission.

W. B. McCool l

Secretary 1

i DISTRIBUTIOli

_ COPY NO.

Secretary 1,58-66 Commissioners 2-6 General Msnager 7 - 8,67 Deputy Gen. Mgr.

9 Dir. of Regulation 10 - 12 Deputy Dir. of Regulation 13 Asst. Gen, Mgr.

14 Exec. Asst, to OM 15 Asst. OM for Admin.

16 Asst. OM for Operations 17 Asst. GM for Reactors 18 General Counsel 19 - 24 Compliance 25 - 30 Congr. Relations 31 - 32 Inspectic.

3 Naval Reactors 34 3 35 (perationc1 Safety 36 - 37 11ans & Reports 38 - 39 lublic Information 40 - 41 RTactor Dev. & Tech.

42 - 51 Reactor Licensing 52 - 53 Safety Standards 54 - 55 State & Lic. Relationr.

56 - 57 N

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j "66 UNITED NAT;ONS PLAZA NEW YORX. N. Y. t uol7 1

l Septer.cce 5,_1906 I

i Secretary United itates Atomic Energy Commission Unshington, D. C. C0545

Dear Sir:

i The -Conservation Center requests permission to interven: in the Matter of Consolidated Edison Company

{

of Scw York, Inc. (Indian Point Station Unit No. 2),

i Docket No. 50-247.

The Conservation Center, a non-4 4

profit corporation, is dedicated to the' preservation of j

a good environment in the East, particularly New York City and the Hudson diver Yalley.

From t. review of_the Safety Evaluation by the Divi-sien of :'cactor Eicensing, we believa unducirisks to.

l-public health, lif e and property arc -entailed should _ a i

license to build and operate this plant,- as presently-j specified, be issued.

4 i

h'c have. prepared a statement of _ objections to the Safety Evaluation, which we would like to have made a i

part of the_ record at the_ public hearin'g. _ In entering l

these objections, we wish to state that we' are not opposed j

to' experimental atomic energy plants where proper safe-guards can be provided.

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Sincerely your,

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-c 3 ugu Larry _Logart:

Director r

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m;a: To. /.JC Public He.ra;g Indian Poinc Unit no. :.

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. 3 L :.fet-T " w r ::n y e.he Dtvi t en of T-: :- L' c TS.

1.no -ne.j,,Goe..: c cion in t ao mattor o f Const.i c cn GIWll,".'.

nd R.n ?oint !acicar Ocncrating b* nit

o. 2, ?cckskill, L.Y.

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'c.b"7:To~fa loc:.tcd 2.5 n;1cc fron the c ontor of ?cckcaili, ;.l*.,

end :.pproxin toly 24 niloc north of 1:cw '.ork City." (?ago 3)

"The indian Point "2 ft.cility in the larcoct reactor that hac becn concidered for licensing to da to." ( Appondir. A: r.dvicory Connittcv on Acactor Safeguar.is, lotter) tbf etient; l

";n view of the relatively high population density necr the cito

.;.nd the larac cica of the roactor, the de$ign objcotivo of the

~

containnont vossoi is to havo negligible outicakago under accidcnt conditions.

Thic is cchioved by a penetration prosaurination cysten, a weld channel prescurisation cysten, and a fluid lino seal water systen."

(Paso (-fi)

After 2.tatin.~, sinilarity in " general design and oporn';ing obj ectivos" of Indian Poir!t Il to Brookwood and Connecticut Yankoo facilitios, "Howevor, there are a nunbor of respoots in which this facility differs fron Brookwood cnd Connecticut Yankco, the more inportant of wnich are the following:

"1. Oho population distribution in the vicinity of the eito far the Indian Point 2 f acility is higher than that of tho-other facilitioc.

To conpencato,' the :.pplicant has proposed a containment and ongineered cafeguards cystens which aro noro extensive than that erovided at facilities in less populated areas.

N. 2he design objectivo of the containnent vosoci is to havo negligible outleakago under accident conditions.

To neot this objective, the tenctration Proccurization Syster,. (PPS) cnd the Icolation Valve boal Water 1,ysten (IVSWS)' have been provided to preclude outlecucco at all containnent loc ations where leakago could be expectoc.... "

(Page 10)

Tho e,ucction: Since the Indian Point-f acility 2 would be - the " largest roc.ctor considered for licensing to dato", according to AChS-abovo, and cinco it differ fron Brookuood and Connecticut Yankoe in noeting tho objectivo of " negligible outlockage" by providing a ?enetration

'.roccuriaation Systen and Icolation Valve Seal Water Sycten, do c:.n i t thic tako Indian Point E 2 an "oxperimental" plant, so for tha ??S nnd XVPM nra conccrn007

,c L'oto ctatenent or. Pago 47: "A cysten of this type in which the penetration in continuoucly preocurised has not been previously proposed for uso in other licenced f acilities."

Alco, ?csc hS, with regard to IVSWS: "This design fonture chould dinin:.to this-potential courco of Icakage."

What experienco nac-been garnered to cupport this clain?

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-Objections to Snf ety Eveluttien Fago 2 2

"The Indian Point fuel rods will o l

specific power (up to 20.7 kw/ft) perato at sonowhat higher and central fuel temperaturo (up to 4250' F) than tho, other facilities. " (Paso 11)

This raises the samo que., ion about tho experimental noture of Indian Point II.

3 "The american Standards Association and the Inc titute of Aloctronic and slectrical Engineers are netively enunced in the development of standards covernine the cetirn, testinn, and installation or l

_reac tor o rotec t un.vnte nt.

soms and staff memoers are participating cir.stly in tais effort to ensure the creation of quality standards and the propor implementation thereof, n'voluation_of the Indien.

Point Unit No. 2 retoter protection tystem will bo basen on ruch j

stnnanras, ce they cre urocosca or coop ted. " (rage 25)

The wisdom of even concidoring a construction licen o for-a large nuclear reactor, approxi.mately 24 miles from New York City, when

" standards governin i

protection systems"g the design, testing rind ins tallation of reactor hevo not yet been fully, developed, and tho i

fact that the lives, nealth, ano property of mil H ons of peoplo

~

depend on,such standards, makes it clear that there is no "ressonable assuranco' of public health and safety in constructing Indian Point II.

4

4. Criterion 1 (b) states; a

"Performanco standards that will enable the f acility to 'withs tand with iut loss of the capability to protect the public, the additional forces imposed by the most covere earthquakes, flooding concitions, winds ive, and-other natural phenomena antig,1oated at the proposed t

site.3 (Page 16)

What about unnnticincted natural phenomena, such as the floods which threatened to knock out niduest utilities, as reported in the New York Times, april 25, 1965.

Philip Sporn was quoted in i

this N.Y. Times report as saying: "nothinn within-a tenth of this severity ever harpened before.

The devastation hooonned because we cidn't dronn it could over be tnnt bnd."

If Kr. Sporn, one of our leading utility engineer-executives could make an adi.ission liko this,- can we afford to samble with the lives of nillions of people, and the imposeible problem of evacuating New York City $ndian Point II site?should sometning " ten timos as severe" a occur at the 5-W" Oho applicant intends _ to continue ctudies of auch Further exoerimental informetion thould be j.

available from the Sen

. Onorre and G o_nnecticu t icngee facilities by the cine tne.t ndia n Point -11 ?acility is to o?iera te. '

are we to understcnd f rom this that the safety of our population will depend in part "on experinental information" being available s.

from atoni.c plants in California.and Connecticut Yankee-facility, "by the: time the Indian. Point II facility is to operate??

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Cb3catione to Safetv UVe19ntion POCC 3

6. "At the orecent tine, there is 'littl3 e W rience on M e??t)~!.

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or ec t.u-1:e a wa ter rea c tors 'tita nositive o r Oro te nD CF";UP9 cocrfic ien ts of rcr,c tivit".

Ano linitcG cxp ort on0 0 to c h t c.13 0 f

been abrivca Lt tn: ono.?f~r c ac tor.

thic cxpcricnto h:c providtd

npport of the cnolyticci techniquet used to predic t nodcreter i

temocrature coefficionts in plants of this type.

In cddition, j

prior to s tartup of the indicn Point 11 fccility, detailed 1

information to verify antilyticci techni fron the ban Onofre reactor," (rago 23)quer should to availabic i

Again, we find referenco to "little enperience" and depcndency en the California reactor to provido information on a criterica j

of safety for Indian Point II.

i 7

"The appliccnt originally stated in the Report tha t a $% circonium-l water renntor could occur if two of tho three dioscla provid a.tero

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available to power the pumps of the safety injoetion systcm..

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Kowever, more recent colculations have indicetcd tatt a zirconiun-s water reaction:of about 109 might occur under the cano condi tiona.

i Vnder theso circumstcncec, about 20s of the fuel pellets would be exposed and could fall to the bottcm of the recctor vossol.

In our opinion, this amount of coro ~ dcmage would appetr. to be execccive,

)

oven though calculations indicate thct the integrity of tho j

prer.sure vessel would not be jeopardized.

}

In consideration of the foregoing, the ACRS has recommended, and the staff agrees, that the flow c apac.ty of the safety injection

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system should be increased and/or ia.provements should be nado in j

other system characteriatics,-such as pump discharge pressure.

In addition, the forces to be expected within the reactor vessel i

in the event of primary systen failures nust be c arefully examined to ensure that - the capability of the-s afety inj oction systcm is j

not impaired under these extreme conditions, 1lo believe t ha t these natters can be resolved durinc conttruction of the racilit?!

(from tage 30 of tac Safety Avaluation of Andian roint II) i l

It should be noted here that.the Advisory Committeo on-Reactor l

Safeguards startled the nuclear 1 industry, according.to !!uelconier, i

Janua ry, 1966 by recommending"that sudden, catastrophic iailure of a pressure, vessel--since tne start of the power reactor progran L

classified ~ as nn-incredible accident, one that ne ed not be taken into acccanL in reactor ssfety cnalyses, be reclassified as t possible accident; and that futuro nuclear power station plans-design against the possible con =equences of such an accident."

l Has thic possibility jor suddon, catastrophic failure of a pressure vossol) beta taken into 60 count in the taxitum credible accf. dent i

considere'. in this Safety Lyaluation report by AEC's Division of Reactor Licensing?

-js To the public interest being served by.the belief of the AEC, as stated on Page 30 of this report, that "these matters can be j

resolved during construction of the facility"?

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j ob3cetiene to SnfetP at1U2 tion

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"The applicant hcs stated: 'Tho principal critorien of control l

station design tnd icyout it tht: ell centreic, in:truncnta tion -

displays and al:;rns required for the snfo oporation und shutdoun 1

i s

of the p(Pago 36)lcnt cro readily ovnilcble, to the operators in the concrcl i

roon.$

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l Sinco Consolidated Edicon personnel will be operating the propoced atonic plant Indian Point II, public health and safety is (ntiticd i

to assurance that Con-Edicon is cofficiently rocpontibic cnd efficient.

t snould be renenbered, in this connection, the.t tho i

Federal Powe.

}

Conniccion raised corious questions about tho efficioney of Con-r:dison on the night of the blackoua, Noycnber 9th.

i l

The New York Times of Decenber 12,19o$ reported tha t the F.P.C.

i blamed Con-ndison for f ailing to provido nore e::plicit inctructions I

to its engineer, end that had the Con-ulicon enginecr on duty moved quicr':17 cnough, the Uow York City area night not havc boon affcoted by the blackout.

Serious as this failure in efficiency and responsibility was, a siniinr failure in the event of an enerscncy at.Lndian Point II j

could be catastrophic.

9 "Also of concern are the potential adverco ofrects of ficca originating in the control and scroty systen uiring cnd/or within the control room itecif.

In our opinion, a dircet, snalyticc1 safety analycic relating to the notsibility of reeetivitv excursions resu) tine frem such firot is, in ornetice. !noonsible cuo to tne ErTfon nature of fire canse

• r.nd tne necr.tv infinite va rie ty of cof;nible circuit faults ttone 'uncof E. cose 'scre') which could result.

-+++

"In thic connection, a literature search was conducted with 'the

.assis tance of -the computer facilitics at the Nuclecr Saf ety Information Center (NSIC) at Oak nidsc listional -Laboratory, study the historical record of such excurcione.

KSIC has informed to un tha t thev were unt.ble to - find cny records - of incidents --involving reactor cataco as a cesult of rf y-inauc co - excurs tena." (reges 37-30)

The Safety x.valuc, tion then continues, with questionable logic since they have just ada.itted -that a cafety analysis of possible reaetivity excursions-recultins fron fires is impossibic, ghat there are no records of previous tnd Essed on the rerereine conciderationn,cxperienco with thes o, :-

we believe thnt Criterien lo it r a ti s fi ed. "

$w can the 450, ' or the public,. b'o e atisfied when potential cdverse effects of fires aro: admitted to be 7'of concern"-

when a safety cnalysis of thct. is impossible, snd when there are no records' of incidents involving' reactor' damage. as a result of fire-induced excursions, on which to baso propor saf eguardc7

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Objectionn _ to_ Sn fety venluc tion Taco 5 i

10- " As a backuo to the normal standby AC powc" supply doccribed l

above, dics'el generator sets will be provided with the capobility 3

of starting and tupplying the power requiromento of the enginecred 1

safeguerds as well as. that equipment required to ofrec t a normal facility shutdown. Thoro will bc thrco diesels that will putonatics11_I start on '.oaa of voltage to tho 400 volt bus stationn.

i thoso orin sunolv elec trAcal newer for the engineered carcNunrde, i

or equipment required for a normal ~ snutdown, l~f only tuo ciesels are assumed to operato, those safeguards required to precludo I

containment overpressurinationo and significant circonium-water l

reaction can be adequately supplied.

a normal shutdown could also j

be effected with two diesels in. operation.

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"All components end structures of the emergency nower __sunolv 1

system are vital ;o sofo snutdoun enn isolution or tne renctor,

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ano are, tnereforo, aesigneu as Glass 1 in terma-of seismic cosign."

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(pages 51, 52)

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i Sinc e I_ am not ' an ensinoer, I do. not know whethor this s ection of i

the Safety evaluation is questionablo or not.-

But in vieu of the fact tnat tne ' emergency power supply sys tem is " vital" to safe shutdovn and isolation of the renotor, it should bo remembored that following the November 9th blackout, the World-4 l

Telegram reported (Nov.13,1965): " Con Ed officials said they c_ould not explain uhy cutonntic circuit breakorn noparently did not cut out in timo to savo at least three power-crainod l

l generators in tne city from damage. 'You'll have to talk to tho j

engineers downtown. ' Noubaucr (John P. Neubauer, manager of L

system operations) said."

According to the Journal-inerican of Nov. 10, 1965 i

"A spokesman for Con Edisca explained today why four of the city's boroughs... slid into darkness at approximately 5:28 i

o' clock last nignt.

"'What should have happened is -that automatic oquf pment should i

have cut us off from tne interconnected' system with upstate.

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Tho -other alternative would have been to disconnec t un manuall j

For some unexplained reason neither of these tnings happened."y.

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Would it be possible for the. " automatic" equipment and other i

components and structure of omergoney power supply system

" vital" to safe shutdown and isclution of the atomic reactor j

at Indian Point 11 to " fail" also- "for some unoxplained reason"?

11

" Criterion 23 (from Pago 55 of safety Evaluation)

"In 'dotormining the suitability of a facility for a proposed site the acceptance of the inherent and engineered safety afforded

- by. the sys tems, naterials and components, and the associated engineered saf eguards built into the facility, sdll dcoond on_

their ' demonstrated nerformoneo escability and reliability _ and the I

extent to which the operability of such systems, materials,.

3 components, and engineerod-saf eguards can be. tested and inspected during the lif e of the plant."

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_. _ _. _. _. - _ _ -.. ~.,.. -.,.., _. _. _., _ _.. _. -, - _ -, _ -,, _, _ _ _ ~..,.. _, - -

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1 Obketions to Sarotv Lvrlut n on Fago o i

i It is difficult to see how Indion Point 11 noets the criterion l

of a "demone trated perfornance capability and reliability" uhen PaSe 10 of the Safety nvaluetion states tnis f acility would differ

+

from broo'orood and Connecticut Yankcoi Page 47 state.as "A oystem of tnis ty70 in unich the ponctration a

is continuously pressuri:od hte not been troviousiv propo cd for 1

i uso in other lic ensed fricili tien. '

? age d states:

r'urtner ex; risental inforration should be j

available from the San Cnofre and Connecticut Yankee facilitios by the time the Indian Point 11 f acility is to operato",

i Pege 15 etates: " Evaluation or the I dian Point Unit No. 2 reactor n

j protection system will be based on such etandardo, as they arc proposed or adopted." (referring to work now being conducted to-i develop such standardo),

I and other safety considerations hav e been 'reforred to by statinct "We believe that of t% facility'; those matters can bo resolved during construction (Page 30)

?

i Is it fair to the Americon public to build the largest stonic plant i

to be corddered for licencing to date, without greater assuranco of M 9ent safety than thioY 12

• Solid waste will consist of miscolloneous contaminated rubbish and spent ion-exchatter resins.

These will bo packed in suitable containers of steel and concretc and shipped off-site." (Pago 58) i In view of the largo population in near-by Now York City, and tho i

record of transportation accidents involving radicoctive wastes, the additional accumulation of both solid vastos and liquid wastoa j

referred to in other sectiona of tho Safety avalunti on, raise t

additional questions to the wisdon, of builcing noien toint -Unit 2.-

l 13 "...it should be recogniced that a completo ovaluation of potentir.1

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accident consequences cannot be r. ado until tho final thermal, i

hydraulic, and physica parcneters of the core have been determined.-

The consequencos of these accidents will be evaluated by the applicant when final design details are available j

reviewed by the Staff prior to reactor operation.'g and will bo (Page 62) i l

How can a construction permit for Indian Point-II, so close to a popnlation of millions, bo justified until all such infornation la available for evaluation of potential accidert consequences?

l-Pron an econonio viewpoint c1cnc, how can the investment of millions

=

of dollars, (unether this comes from Con-Edison's stock-holders.

r cenau:;cra, or the Ancrican taxpayor, through AlC subsidies), be justified-- 3 when an operatinc licenso nay never.bo granted because of questions

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relcted to safety which have not yet been answered?

-Still another' economic injustico is the fact that insurance is not available to home and building-owners for radioactive contamination donage.

Property owncra in the area that would be affected should' a major accident at Indian Point II occur, (and tnis la admitted to bo possible) would stand to loso everything they have--their homes and businesses--in the event of such an accident, with only tho ina_dequate l

Price-Anderson Indemnity of 560. million to cover danoges which could '

exceed 17 billion dollars.

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Objections to Snfety Evaluation Page 7 14 "l'aximum credible Accident "The course and consequences of a doubic-endod failuro of tho primary coolant piping, the naximum crediblo accident, (hCA),

woro evaluated by the applicant.

No believe that this accident l

represents the maximum potential for off-site consequences." pac 0 02 There is no mention $n this Safety Evaluation of the estinatos-made by the AEC in its 1957 Brookhaven Report, "Thooretical Possibilities and Consequences of Major Accidents in Largo Nucionr

+

Power Plants" which estimated maxi =n of 3,l.00 killed, 143,000 injured, 07 billion in property damnGo, an4 150,000 square miles of land affected, as the result of _ a singlo major accluene u4 ua atomic plant of 500,000 kilowatts thernal power.

1 In a letter dated June 18, 1965, Glenn T. Seaborg, Chairman of the Atonio Energy Commission stated: "Roactors today are much larger then those in prospect in 1957, their fuel cycles are longer and their fission product inventories are largor, 1

"Therefore, assuming the same kind of hypothetical accidents as those in the 1957 study,- the theoretically calculated damagos would not be less and under some circumstances would be substantially j

more than the consequences reported in the earlier study."

What would be the consequences of a major ' accident of the kind considered in the 1957 Brookhaven acport, at Indian Point II?

(in terms of peop2.e killed, injurod, property damage, and land affected?)

A sin, the brookhaven Report stcted (Pego 9): "_ Inhabitant s of E

nortions of the arens e ffected unuld hnvo to be evncuated to avoid perious exoonure. "

Since Dr. Edward Teller has stated in an article, " Energy from Oil that a" nuclear reactor could outand from the huoleus" -(Journal of Petroleum Tec its radionotivo noison under a stoble inversion layer end concentrate it onto a few hundred i

square miles in a truly deacly' fasnion"; isn't it poThibic that a major atomic plant accident at J.ndlan Point II could create the impossible tank of evacuatins New York City--approximately 24 miles sout;b o.? the proposed site for the " largest" renotor yet to be considered -for licensing?

t Pages 65-68 n.ontion neveral " Minor Accidental Roleases of Radio-activity"s what of " major" releases, which however " improbable",

are conceded to be "possible".

Can we affo'rd to take the risks involved, when we remember the lesson of the " highly improbable" blackout of November 9, 19657

Objections to Safety Evaluation Page 6 Data on Evacuntion in_ the event of a major etonic plant accident From AEC Brookhaven Report of 1957, based on 500,000 kw thermal reactor about 30 miles from a major cityt

" Inhabitants of portions o1 the areas affected would have to be evacuated to avoid serious exposure.

Access tu various areas might be denied for different lengths of time, and the subsequent use of land for agricultural purpos s might be curtailed, with possible loss of standing crops." (P. 9, 10)

"The Volatile Release Cases Evseuntion. Maximum bl.000 persons, $205 millions (Page 12)

"Tbc 50 Percent holense Case t Evacuation, Maximum b60.000 persons

$2300 millions (Page 13)

The question must be raised:

If a major accident occurs at Indian Point II, isn't it possible that people in the New York City area could be exposed to " serious" levels of radioactivity?

Since New York City and its ten million inhabitants are merely 24 niles routh of the propo,ed site for Indian Point II, s

isn't it possible that they might have the " serious exposure" as the result of such a major accident, which would ordinarily require the evacuation referred to in the brookhaven Report quoted abovo?

If not, how many people in areas that would be affected, would require evacuation--and how great an area would remain inaccessible or uninhabitable for what length of time?

According to a report, " Planning for the Control ofEadiation Accidents" pre,ared by Donald R. Chadwick, M.D.; Donald A. Pecsok, and Donald J. Nelson Jr., for presentation at a Seminar in Geneva, Switzerland, Nov. 18-22, 1963 "If major accidents should occur at nuclear reactors, fuel reprocessing or waste disposal facilities, fallout or spill releases-to the environment may result.

Such accidents may involve relctively large geographic areas, relatively large numbers of people or relatively high exposures.

Coordinated planning is essential by all who might. be involved operationally at the time of an accident, including the administration of the installation as well as official agencies." (pag e _11)

This raises another question:

Is the coordinated planning now in effect sufficient to meet the emergency that, major accident at Indian Point II could create?

(Po,es 6, 7)

The some report states: "Certain competencies in recognizing, reporting and initially controlling a radiation accident are required by police

.and fire department personnel who are most likely to be first on the scene."

In view of the need co transport hi from Indian Point II, over public higdays, ghly deadly radioactive wastes are our police and fire departments prepared to d.eal with accidents involvin6 the transportation 7

of radioactive wastes?

4

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Objections to Safety #ealurtion

?cgo 9

15. In vicw of the unprecedent crisis which a major atomic plcnt

}

accidont at Indian Foia, II would creato, the question of i

possible sabotwo cas.not be ignored.

At the time of the blackout, i

the Ucw Yorg A15cs reported on November 11, 1965: "hilitary sourcos said that at tho very least the blackout raised question:

of possible sabotor*e in the 'uture as a setun_ for surorir o nttac k."

4-In this instance,.a sur7rico attack would not be necessary.

As Dr. Edward Teller he's pointed out in his article, "Incrgy from Oil and from the Nuclous":

"But a powerful nucitar reactor which has functioned for nome time has radioactivity stored in it grentiv in excess of that releaced from a ovwerful nuclear bonb. _ There is one diff erence, ano tnic differenco ma,tes the nuclcar bomb look like a relatively safo a

in t,trument.. ~In cace of an atmosphuric nuclear explosion the i

redioactivitylascende into the stratosphoro.

Relatively cnall

}

anounts are deposited in the innodist,o neighborhood.

4 "A gently seeping nucicar reactor can put its radioactive poison i

under a stable inversion J ayer and concentrate it onto a few hundred square miles in a truly dcadly fashion.

To shy wo i

must be exceedingly careful in constructing nucicar

sors, by being careful and also by good luck, we have so f ar avoided all i

serious nuclear accidents."

If these facts were widely recognised by the public, would they want to take the chance this statencnt implies?

1, To return to the question of possible sabotage, it is not widely known that several attempts were made to sabotage the nuclear submar Kautilus, (as reported in "Donth of tne Throcher" by Norman Polnar.

In addition to the possibility of a major accident -at Indian Point II from human error, mechanical f ailure, fire, and -noro covero " natural

+

phenomena" such as earthquakes than has been anticipated, we nuct also add the possibility of sabotage to the risks inherent in this atomic plant.

i i

16-In his tuk, " Death of the Thresher" Norman Polmar quoted Adniral Rickover extensively on faults the Admiral had discwored in nuclear submarine construc tion.

Admiral dickover. cited sovoral instances 3b of gross. negligenc e on the part of "nearly every major electrode manufacturer in the Unit ed States".

3 he have only to consider the loss of the Threnhor, disturbin6 foots uncovsrod by tho invcatigaticr. of this locs:and the highly the EeV York Times of January 10, 1965 reported that the investigation i'

report " amounts _ to an indic tment of tne Navy 4 s technical management, for throughout the hearings. there is repeated evidence of poor-design, violation of design plant, poor fabrination, poor uorkmanship cnd incomplete inspection. "...to wonder whether American industry 'in at present c,apable of offering " reasonable assuranco" of public health and safety in the complex m:.nufacturing processes necessary to the construction and oporation of Indian Point II.

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Ob.'eetions te Nuy P'mwanen Pacc 10 17 additional objections aro based on the following quotation 1

from a statement by Dr. Theos J. Thompson ct hearings on Indemnity and hoactor safoty, (before the Subcor=ittee on descarch, uovelopment, and dadiation of the Joint Com.aitteo on atomic Lncrty, April 10, 11,19o2, published under titic "Indomnity and neactor Safety").

Dr. Thompson, a former Chairman of the Advisory Committee on Heac tor Safeguards, stated:

l "In sunmary, we are s.111 feeling our way cautiously in developing our faith in the reliability of powcr roactor cores.

Every reactor that has been operated to date, unless it hst had at least eno almost exact prototype as is - the caco with cut:..arino l

reactors, has demonstrated some small dif ferencou from expcoted behavior.

Alnoct always tncsc havo not been important, but they 3

seem to indicate that one should be very corcrul in locattnn n l

_f_i rs t of its hind (or site) reactor in a olace wncre cnginuEed safety is used exclusively. " (PC500 00, o l) (emphasis addod)

The proposed Indian Foint II atomic plant would bo the "largost reactor that has been considered for licensing to dato",,(see Appendix A of Safety Evaluction), arf, according to Page 47 of the Saf ety Evaluation, "A system of tnis type in which tho penetration is continuously pressurised has not been previously l

proposed for use in other licensed facilities."

These facts, and the few years that hr.ve passed sinco Dr. Thompson made this stattment, makes his cdditional warning pertinent

)

"Let us not loco our heads in a pellmall dcsh for economic power at the expenso of safety."

18-What syst,m has been set' up, and what system could suffico, to warn the public in tho event of a major atomic plant accident at Indian Point II?

The " highly improbable" blackout was self-evident.

But how would the evacuation of people in the surroundinr3 area of Indian Point II be effected, if this proves necessary?

In conclusion, we do not believe that the Amerionn public would be satisfied with the conclusion (3) of the Safety cycluation (Page ~71):

"Research and development as required to resolvo tho safoty cuestions with respect to the features and components uhich require research and development, will be conducted." (emphssic added)

In consideration of all tne forot;oinG we cannot agree that there is "roaaontblo assuranco" that the Indian Point Unit 2 can oc co.strue.;c and operated at the proposed site without endangering tho health c=

safety of the pcblic, as concluded on Pago 72 ol' the Screty Evalva. 't.

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Enclosed Comitte herewith c piesfor the infor the Matter e are o

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of of Cons lidatedthe following d the Joint mation o

2, Docket No., India of n Point Edis ocume ts Ir1 on Comn 50-247:helear Generating n

any of 1

New Letter Younger,to the Cornission Unit dated reply thereto frAugust fro dated om Troy B. Con, andm Mr. Irving 24, 1966 September 7,19 2

Atomic SafetyLetter to Samuel ner, Jr.,

i 66 the W. Jens h, ChaiLicensitig Board Mr Frederick and c

August J. Martin, Jr s

rma,

dated 15, 1966 n

5 Septe ber,8

, fro ad n

the

., dated m

m 3

, 1966 r ply the Hays WeikLetter to the C e

reto, datedommission fr Chairreply ther,eto f rom Samuel W. JeAugitst 4,1966 om Mis Board, man, Atomic Saf s Mary dated

, and ety and nsch, the quent letter to M 10, 1966 Licensing dated August August 25, 1966r. Jens h A subs -

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fr Letter to W. B s Weik, e

om Mis Energy Commissi. McCool, Secret Lelaney, dated on, fr reply ther to frAugust om Mr. Haroldary. Atomic 5

Chair e

om Sa 10, 1966 F.

Board, datedman, Atomic Saf muel

,ad t Septe ber 9ety andW. Jens h, he n

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, 1966 ensing M:.Qf a

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5.

Letter to Mr. Clark V. Swanson, Public Proceedings branch, from Mayor William J.

Burke, dated August 9, 1966, and the reply thereto from Samuel W. Jensch, Cheirman, Atomic Safety and Licensing Board, dated September 9, 1966.

6.'

Letter to the Commission from Miss Elizabeth R.

Hogan, dated August 12, 1966, and the reply i

thereto from Troy B. Conner, Jr., dated August 25, 1966. A subsequent letter to the Commission from Miss Hogan, dated September 2, 4

1966, and the reply thereto from Samuci W.

l Jensch, Chairman, Atomic Safety and Licensing Board, dated September 9, 1966.

4 7.

Lettet to Samuel W. Jensch, Chairman, Atcuic Safety and Licensing Board, from the Honorable Richard L. Ottinger, dated August 23, 1966, and the reply thereto, dated August 1966 29, 1

8 Letter to the Commission from Mr. Larry Bogart, dated Aegust 13, 1966, and the 4

reply thereto from Troy B. Conner, Jr.,

dated August 25, 1966 Letter to the Commission from Senator Robert F. _ Kennedy, dated August 23, 1966, enclosing a copy of Mr. Bogart'n letter af August 13, 1966, and the reply thereto from the Commission, dated September 7, 1966.

A subsequent letter to the Commission from Mr.

i

Bogart, dated September 8, 1966 Sincerely yours,.

k

/ $l Y h

Harold L. Price Director of Regulation Encicsures:

As stated i

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