ML20147F372
| ML20147F372 | |
| Person / Time | |
|---|---|
| Site: | 07002623 |
| Issue date: | 10/02/1978 |
| From: | Bloch J SAFE ENERGY ALLIANCE |
| To: | |
| References | |
| NUDOCS 7810190194 | |
| Download: ML20147F372 (4) | |
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UNITED STATES OF AMERICh
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NUCLEAR REGULATORY COMMISSION In the Matter of
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U.'OilhiM A N #
DUKE POWER COMPAlpt (Anendment to Materials License
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Docket No. 70-2623 SIM-1773 for Oconee Nuclear Sta-
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f tion Spent Fuel Transportation
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and Storage at McGuire Nuclear
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gj CONTEliTION3 0F SAFE ENERGY ALLIANCE 9
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,c, In a Board Order, dated September 22, 1978, the Board required pa b
-4 file supplement to petitions for leave to intervene a list of' contentions sought to be litigated in the above captioned matter.
SEA makes the following contentions:
The applicant's proposed action is an environmental hazard requiring an en-vironmental impact statement which thoroughly investigates alternatives te the pro-posed action and thoroughly explores the enviromnental implications of the proposed action and all alternatives. Such an enviromnental impact statement has yet to be prepared by applicant, and accordingly the proposed action lacks responsible and legal evaluation and justification.
Transportation of spent nuclear fuel from the Oconee facility to the McGuire facility is an environmental hazard which threatens the health and safety of inter-venor's members and citizens of the entire region between the two facilities, in that it increases the routine radiation dosage to the population, and makes real the possibility of a transport accident involving'an off-site radiation release of catastrophic consequence. The number and frequency;of spent fuel shipments, the distance covered, the traffic densities and roadway hazards on the route, the pop-ulations proximal to the route, and the potential breach of containment, are all variables related to enviromnental hazard that will be unfavorably effected by the applicant's proposed action. The NRC should seek to limit radiation dosage to the population and the possibilities of accidental release and their consequences, and should therefore deny the requested permit.
The Oconee facility occupies a large site, and therefore on-site spent fuel storage, either in e::isting or newly constructed facilities, is possible. We con-tend that there is no need for transportation at all, and that keeping ihe spent fuel at Oconen is certainly preferable to moving it off-site, as this avoids the many hazardo presented by the proposed action,.
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If transportation of Oconee spent fuel off-site is required a number of factols arise whose environmental impact should be thorouahly evaluated, and the proposed action should be restricted and amended in light of these factors.'
If transportation from the Oconce site is r61uired, an alternative site should be selected close to Oconec, it being preferable that the materials travel the short-est poccible distance proximal to a minimal number of persons.
If transport is re-quired, applicant should be required to move only its oldest spent fuel, in that older fual is less radioactive than newer spent fuel.
If transportation is required, then the times of travel should be specified so that there are a minimum of other vehicles on the road, lessening radiation dosage to the population.
If transportation is required a study should be made to determine the route which.best avoids centers of population and hazardous intersections. Applicant's action as presently proposed will send spent nuclear fuel within Charlotte city limits through areas of relatively dense population, on a route that includes the intersection of Interstate I-85 North to In-terstate I-77 North, which on information and belief is characterized as a particularly hazardous intersection. Intervenor contends that applicant's action as proposed will generate new and real threats to public health and safety, and that a thorough process of identification and evaluation of such threats has not taken place, and that alternative routes similarly have not been identified and evaluated.
Intervenor furthur contends that the cask and truck packages have not been thorough-ly and rigorously tested for purposes of determining reliability in highway accidents.
We further contend that no thorough study has been made of the radiation dosage from the cask and truck enroute to persons in close proximity for extended periods.
The very necessit'y of identifying a new site. for 'the storage of Oconee spent nuclear fuck and of devising a method and route fof fuel transport, is occasioned by the continuing operation of Oconee's three nuclear reactors.
Intervenor contends that the slow-down or shut-down of Oconee's reactors is a preferable alternative to the transport,and storane of spent fuel off-site. For one, the clear and precent hazards of such transport would be avoided entirely. Secondly, the clear and present hazards associated uith the operation of large nuclear reactors, such as routine radiation release, the possibility of accidental release, worker health and safety, the long-term storace of spent fuel, and the possibility of the virtually irreversable radioactive pollution of the biosphere and the genetic framework of living organisms, would all be happily avoided.
Intervenor further contends that the loss of electric generating capacity that would result from the slou-down or shut-down of Oconee's reactors would not unacceptably conflict with the need for power of the applicant's costumers. We contend that the power lost can be replaced more than amply by conventional means and by alternatives such as
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e solar power and energy conservation through increased efficiency. In addition applicant's present excess generating capacity of more than twenty-five percent will be helpful toward insuring an adequate energy supply during the period of'ad-justment to the loss of Oconee power.
future i
Intervenor contends that in the not too long term /an economic advantage would i
be incurred by the slow-down or shut-down of Oconee's reactors. Such an action would faci-litate the development of energy sources that are preferable to nuclear on the basis of cost per killowatt pay-off, technical reliability, fuel supply, job market stimulation, and economic burden of public health and safety.
In view of the foregoing contentions, Intervenor moves that the Board require applicant to prepare a full scale environmental impact statement on the problem of Oconee spent fuel storage. In the abscense of such a otatement, applicant's pro-posed action lacks responsible and legal evaluation and justifi' cation.
This matter of the safe transport and storage of spent nuclear fuel is not to be treated with poor planning and ad hoc solutions. The existance of independent com-mercial waste storage and processing facilities has been heavily relied upon by appli-cant and NRC throughout previous efforts at planning for spent fuel storage.
Such f acilities do not now exist and tL3re is no reasonable assurance that they will be available for several more years, at best.
Both. applicant
- arid NRC are therefore obligated under federal mandate to conduct a fresh and thorough evaluation of the spent fuel matter. As it stands NRC has yet to produce an acceptable Ceneric Environmental Impact Statement on the handling and storage of spent fuel, and is not in a position to endorse an ad hoc action on spent fuel, such as applicant's, unless the action is supported by a full scale EIS.
If such an action is perpetrated without proper EIS support, we contend that both applicant and NRC will have violated the legally protected rights of Intervenor members and other citizens of the area.
Dated: October 2, 1978 Respectfully Submitted, Jeremy Bloc Safe Energy Alliance, Representative 1707 Lombardy Circle Charlotte, N.C.
20203 (704) 375-8353 k
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CERTIFICATE OF SERVICE l,
I hereby certify that copies of the attached in the captioned matter have served on the following by depositing same in the United States mail this day of bC.hd
, 1978.
Robert M. Lazo, Esq., Chairman Ms. Brenda Best Atomic Safety and Licensing Board Carolina Action l
U. S. Nuclear Regulatory Comission 1740 E. Independence Blvd.
Washington, D.C.
20555 Charlotte, North Carolina 20205
.Dr. Cadet H. Hand, Jr., Director Anthony Z. Roisman, Esq.
Bodega liarine Laboratory Natural Resources Defense Council University of California 917 15th Street, N.W.
P.O. Box 247 Washington, D.C.
20005 Bodega Bay, California 94923 Dr. Emmoth A. Luebke Shelley Blum, Esq.
Atomic Safety and Licensing Board 418 Law Building U. S. Nuclear Regulatory Consnission 730 East Trade Street Washington, D.C.
20555 Charlotte, North Carolina 28202 W. L. Porter, Esq.
Mr. Jesse L. Riley, President Associate General Counsel, legal Dept.
Carolina Environmental Study Croup Duke Power Conpany 854 Henley Place 422 South Church Street Charlotte, North Carolina 28207 Charlotte, North Carolina 20242 Richard P. Uilson, Esq.
Atomic Safety and Licensing Appeal Board Assistant Attorney General U. S. Nuclear Regulatory Commission State of South Carolina Washington, D.C.
20555 2000 Bull Street Columbia, South Carolina 29201 Docketing and Service Section Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission U. S. Nuclear Regulatory Commission Usshington, D.C.
20555 Washington, D.C.
20555 J. !!ichael McCarry, III Debesoise and Liberman Suite 700 i h to 20005 Jeremy Bloch -
\\ D og Representative, Safe Energy Alliance f
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