ML20151B227

Comment Opposing Proposed Rule 10CFR50 Re Licensing of Nuclear Power Plants Where State &/Or Local Govts Decline to Cooperate in Offsite Emergency Planning

ML20151B227
Person / Time
Site:	Seabrook
Issue date:	02/24/1987
From:	Dukakis M AFFILIATION NOT ASSIGNED, MASSACHUSETTS, COMMONWEALTH OF
To:	NRC
References
FRN-52FR6980, RULE-PR-50 52FR6980-00095, 52FR6980-95, OL, NUDOCS 8807200294
Download: ML20151B227 (6)

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, se i TESTIMONY PRESENTED BY in GOVERNOR MICHAEL S. DUKAKIS '87 IW? -4 R2 :09 BEFORE TEE NUCLEAR REGULATORY COMMISSION i

FEBRUARY 24, 1987 I WANT TO THANK YOU, CHAIRMAN ZECH AND MEMBERS OF THE COMMISSION, FOR THE OPPORTUNITY TO APPEAR BEFORE YOU TODAY.

I ASKED FOR THIS OPPORTUNITY, AS DID GOVERNOR CUOMO AND OTHERS, BECAUSE I BELIEVE THAT THE RULE CHANGE YOU ARE CONSIDERING WILL UNDERMINE THE PUBLIC HEALTH AND SAFETY OF THE PEOPLE OF MASSACHUSETTS, NEW ENGLAND, AND THE NATION.

BACK IN 1946 NO ONE KNEW OR FULLY APPRECIATED THE MAGNITUDE OF THE RISK THAT NUCLEAR POWER COULD POSE TO OUR CITIZENS. WHILE WE SAW WHAT 'JE BELIEVED WERE THE TREMENDOUS ADVANTAGES OF NUCLEAR POWER, THE SERIOUS DISADVANTAGES HAVE ONLY REVEALED THEMSELVES OVER TIME.

THESE RISKS HAVE POSED A CHALLENGE TO GOVERNORS AND TO STATE GOVERNMENTS. BECAUSE FOR 200 YEARS IT IS STATE GOVERNMENT IN THIS COUNTRY THAI HAS BEEN CHIEFLY RESPONSIBLE FOR THE PROTECTION OF IHE PUBLIC HEALTH AND SAFETY OF OUR CITIZENS IN THE EVENT OF MAJOR DISASTERS AND ACCIDENTS.

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's NO ONE DOUBTS THE AUTHORITY AND THE OBLIGATION OF GOVERNORS TO '

ACT IN INSTANCES WHERE THERE ARE SAFETY VIOLATIONS OR POTENTIAL DANGERS AT CHEMICAL PLANTS, OIL OR COAL-FIRED GENERATING PLANTS, OR GAS-FIRED FACILITIE3. BUT WHEN IT COMES TO NUCLEAR PLANTS THE SITUAT, ION IS DRAMATICALLY DIFFERENT.

FOR THE RULE YOU ARE DISCUSSING TODAY WOULD MAKE A GOVERNOR'S RIGHT TO PROTECT THE PUBLIC HEALTH AND SAFETY OF THE PEOPLE OF HIS OR HER STATE VIRTUALLY HEANINGLESS ONCE A NUCLEAR ACCIDENT ,

HAD OCCURRED. I I DON'T KNOg HOW MANY OF YOU ARE FAMILIAR WITH THE AREA AROUND SEABROOK. SO LET ME DESCRIBE IT TO YOU SO YOU CAN UNDERSTAND i EXACTLY WHAT I AND THE RESIDENTS OF THE SURROUNDING COMMUNITIES ARE FACING.

i THE SEABROOK AREA IS HIGHLY POPULATED AND GROWING. WE HAVE ABOUT FIFTY THOUSAND MASSACHUSETTS RESIDENTS IN THE SEABROOK ,

EMERGENCY PLANNING ZONE. THAT PERMANENT POPULATION-BALLOONS TO UPWARDS OF 150,000-200,000 DURING THE PEAK SUMMER BEACH MONTHS.

THE AREA IS A N0TORIOUS POINT OF SUMMER TRAFFIC CONGESTION, AS ,

s ANY. BOSTONIAN WHO HAS SPENT THREE HOURS ON INTERSTATE 95 OR ROUTE 1 ON A SUNDAY NIGHT RETURNING FROM HAMPTON BEACH CAN TELL YOU.

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THE BEACHES THEMSELVES ARE SERVED BY NARROW ROADS--IN SOME INSTANCES ROADS NOT MUCH WIDER THAN THE HALLWAY OUTSIDE THIS ROOM. THE WEATHER IS TYPICAL NEW ENGLAND SEASHORE WEATHER:

CHANGEABLE, TURBULENT, UNPREDICTABLE--SO MUCH SO THAT EFFECTIVELY TRACKING A RADI0 ACTIVE PLUME FROM SEABROOK WOULD BE DIFFICULT, IF NOT IMPOSSIBLE.

THE HOUSING STOCK IS, FOR THE MOST PART, INADEQUATE FOR ANY KIND OF TEMPORARY OE LONG-TERM SHELTER. OLD WOODEN BEACH COTTAGES WITHOUT , % L t. AR S PRED0HINATE ALONG THE SHORES, INADEQUATE FOR WINTER WEATHER, MUCH LESS SHELTER FROM A RADIOACTIVE STORM.

SO WHEN I BEGAN TO APPROACH THE QUESTION vs EMERGENCY PLANNING AT SEABROOK, I DID SO AS SOMEONE WHO KNOWS ALHOST EVERY INCH OF THOSE CITIES AND TOWNS AND THAT TERRITORY--WHICH IS PRECISELY WHY GOVERNORS HAVE BEEN GIVEN THE ROLE THEY HAVE IN EMERGENCY PLANNING--UNTIL TODAY. AND BECAUSE OF THAT, MY STAFF AND I, ASSISTED BY DR. ALBERT CARNESALE, DEVOTED LITERALLY THOUSANDS OF HOURS T^ OUR REVIEW.

AFTER MONTHS AND MONTHS OF WORK, EFFORT, AND ANALYSIS I CAME TO ONE FUNDAMENTAL CONCLUSION--THE AREA AROUND THE SEABROOK NUCLEAR POWER PLANT COULD NOT BE EVACUATED IN THE EVENT OF A SERIOUS NUCLEAR ACCIDENT. THAT IS THE FUNDAMENTAL FACT OF THE MATTER--AND IT IS ONE THIS COMMISSION MUST FACE AND FACE SQUARELY.  ;

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! THIS WAS NOT AN ARBITRARY DECISION. IT FLOWED LOGICA.LLY FROH' I

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MONTHS OF' CAREFUL AND THOUGHTFUL ANALYSIS.

. FOR THAT REASON, I RESENT THE IMPLICATION.0F THE GENERAL I

COUNSEL'S MEMORANDUM TO THIS COMMISSION. NON-COOPERATION? THE i

r ONLY DEFINITION OF COOPERATION THAT WOULD FIND FAULT WITH WHAT F

j- WE HAVE DONE IS ONE THAT ASSUMED ALL THE CONCLUSIONS BEFOREHAND.

1 THE PROPOSED RULE CHANGE HAS BEEN PROV0KED, IN PART, BY MY DECISION REGARDING SEABROOK. THE FACT IS, MR. CHAIRMAN, THAT THE SEABROOK PLANT SHOULD NEVER HAVE BEEN n'UILT THERE IN THE i FIRST PLACE, AND I DOUBT VERY MUCH WHETHER THIS COMMISSION WOULD EVER CONSIDER LOCATING A NEW PLANT THERE TODAY.

i THE COMMONWEALTH OF MASSACHUSETTS HAS WARNED ABOUT THE PROBLEMS OF EFFECTIVE EMERGENCY RESPONSE AT SLABROOK FOR' TWELVE YEARS.

SO ALLOW ME TO ISSUE THE WARNING ONCE AGAIN. YOU SIMPLY CANNOT EVACUATZ THIS AREA IN THE EVENT OF A SERIOUS NUCLEAR ACCIDENT.

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AS COMMISSION MEMBERS YOU ARE CHARGED UNDER THE LAW WITH'?

y REGULATING NUCLEAR POWER IN THIS COUNTRY SO AS TO PROTECT THE.

( PUBLIC'S HEALTH AND SAFETY. THE RULE CHANGE PROPOSED TODAY t

MUST MEET THAT TEST. YET THE,'ONLY REAL JUSTIFICATION OF ERED f FOR THE NEW RULE IS ECONOMIC. IN'HIS MEMORANDUM, THE GENERAL

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COUNSEL SUGGESTS THAT OFF-SITE EMERGENCY PLANNING IS TO $E l DOWNGRADED. WITH ADMIRABLE BUT CHILLING FRANKNESS HE TELLS US THAT THE REASON FOR ALL THIS IS THAT "BILLIONS OF DOLLARS.

HAVE...BEEN INVESTED," WHICH "POSE' SERIOUS FINANCIAL

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CONSEQUENCES."

[ AT SEABROOK THIS RISK AND THESE CONSEQUENCES HAVE BEEN KNOWN AND ACKNOWLEDGED BY THE PLANT'S OWNERS FOR YEARS. THEY WERE ACKNOWLEDGED WHEN THE OWNERS SOUGHT A CONSTRUCTION PERMIT FROM THIS COMMISSION, AND THEY WERE ACKNOWLEDGED WHEN THIS I

COMMISSION IMPOSED THE NEW EMERGENCY PLANNING RULES AFTER THREE r MILE ISLAND.

i IN BOTH INSTANCES MA3SACHUSETTS AND OTHER INTERVENORS RAISED THE ISSUE OF EMERGENCY PLANNING, IN BOTH INSTANCES THE NRC AFFIRMED THAT THE PLANT WOULD NOT OPEN UNLESS THESE ISSUES WERE RESOLVED, AND IN BOTH INSTANCES NEITHER THE PLANT NOR THE NRC DID ANYTHING TO RESOLVE THE ISSUES.

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NOW, YEARS LATER, THE PLANT HAS BECOME A WHITE ELEPHANT. A

,' WHITE ELEPHANT, I MIGHT ADD, THAT CANNOT MEET EXISTING

- EMERGENCY PLANNING GUIDELINES AND WOULD INCREASE THE COST OF I

ENERGY TO THE CITIZENS OF NEW ENGL ND AT A TIME WHEN THE COST OF ALT.ERNAfIVE ENERGY IS AVAILABLE AT HALF THE COST.

IN FACT, TWENTY SEVEN (27) SMALL POWER PRODUCERS HAVE ALREADY OFFERED PUBLIC SERVICE COMPANY OF NEW HAMPSHIRE THE EQUIVALENT OF THE SEABROOK PLANT OUTPUT AT LITTLE MORE THAN HALF OF THE '

COST. WHAT HAS PUBLIC SERVICE OF NEW HAMPSHIRE DONE? 0FFERED

, TO PAY MANY OF THESE PRODUCERS NOT TO PRODUCE THE POWER!!

IN SHORT, WHAT YOU ARE PROPOSING IS THE NUCLEAR EQUIVALENT OF CUTTING THE NUMBER OF LIFEBOATS FOR THE "UNSINKABLE" TITANIC BECAUSE IT WOULD REDUCE THE SPACE FOR PASSENGERS AND MAKE THE VOYAGE UNPROFITABLE.

THAT'S NOT WHAT THIS COMMISSION WAS SET UP TO D0. THAT'S NOT WHAT GOVERNORS ARE ELECTED TO D0. AND THAT'S NOT WHAT THE CONGRESS INTENDED WHEN IT GAVE YOU--AND !!E--THE RESPONSIBILITY TO PROTECT THE PUBLIC HEALTH AND SAFETY OF THE AMERICAN PEOPLE.

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