ML20199K958
| ML20199K958 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 07/02/1986 |
| From: | Bellotti F MASSACHUSETTS, COMMONWEALTH OF |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| CON-#386-878 OL, NUDOCS 8607090283 | |
| Download: ML20199K958 (49) | |
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UNITED STATES OF AMERICA DOCMETED NUCLEAR REGULATORY COMMISSION oetore the JM. -7 P2 :06 ATOMIC SAFETY AND LICENSING BOARD OFFICE OF SECpt_ u,qy 00CKEIlNG & SL.4VICi' BRANCH
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In ti!e matter of
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Docket Nos. 50-443-OL-1 PUBLIC SERVICE COMPANY OF
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50-444-OL-1 NEW HAMPSHIRE, et al.
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On-site Emergency Planning
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and Safety Issues (Seabrook Station, Units 1 and 2) )
Dated:
July 2, 1986
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PETITION OF ATTORNEY GENERAL FRANCIS X. BELLOTII TO REVOKE REGULATION 50.47(d) OR IN THE ALTERNATIVE TO SUSPEND ITS APPLICATION IN THE SEABROOK LICENSING PROCEEDING Attorney General Francis X. Bellotti, acting pursuant to 10 C.F.R. $2.758, hereby petitions the Commission to revoke the regulation appearing at C.F.R.
S50.47(d), or in the alternative to suspend its application in the present proceeding, and as grounds therefor states the following:
(1)
Section 189a of the Atomic Energy Act, 42 U.S.C.
S2239(a) (1982), provides a right to a prior hearing on all issues material to issuance of an operating license.
Union of Concerned Scientists v. NRC, 735 F.2d 1437 (D.C. Cir. 1984).
(2)
Regulation 50.47(o) permits the issuance of an operating license authorizing fuel loading and/or low power 70gh h 3
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operation at up to 5% of rated power before any findings or determinations are made "concerning the state of off-site emergency preparedness or the adequacy of and capability to implement state and local off-site emergency plans."
10 C.F.R.
S50.47(d).
(3)
Insofar as Regulation 50.47(d) allows issuance of an operating license, even at less than full power, prior to a hearing on all issues relevant to licensure, including off-site emergency planning, it violates the statutory right to a hearing provided by section 189a and must be held invalid.
(4)
Ho nearing nas yet been held in the instant case on off-site emergency planning issues, and regardless of any economic or safety justifications for Regulation 50.47(d) or the fact that a hearing on emergency preparedness issues will be held prior to full-power authorization, operation of the Seabrook nuclear power plant at 5% of rated power will create significant irreversible consequences.
Among these irreversible consequences will be irradiation of tne plant, significant fuel irradiation, and worker exposure.
See Affidavit of Albert Carnesale; Affidavit of Dale G.
Bridenoaugn and Gregory C. Minor (prepared for Shoreham licensing proceeding but relevant hereto).
None of these consequences q can be mitigated by a later hearing, and thus application of Regulation 50.47(d) will effectively deny interested parties their right to a prior hearing on all issues relevant to licensure.
(5)
Regulation 50.47(d) wnich, together with Regulation 50.57(c), authorizes temporary low-power operation prior to a hearing on all issues relevant to licensure is furthermore in violation of the Atomic Energy Act's statutory scheme which twice, on an emergency basis, authorized the issuance of temporary low-power operating licenses prior to completion of a full hearing on all issues relevant to licensure but no longer authorizes such temporary low-power licenses.
See 42 U.S.C.
S2242 (expired Decemoer 31, 1983).
Even if there did exist statutory authority for Regulation 50.47(d) special circumstances warrant an exception to its application in the instant proceeding:
(1)
No emergency response plans have been submitted to FEMA or the NRC for that portion of the Seao' rook Station's plume exposure EPZ or ingestion exposure EPZ within Massachusetts.
See Affidavit of Secretary of Public Safety Charles V.
Barry (attached hereto).
(2)
Five of the six Massachusetts communities within the plume exposure pathway have voted not to participate in emergency planning and not to participate in any exercise of emergency response plans for Seabrook.
See Affidavit of Charles V.
Barry.
(3)
The Governor of Massachusetts has not to date indicated any intention to submit, or implement in the event of an emergency, compensatory plans for the five Massachusetts communities not participating in emergency planning.
See Affidavit of Charles V.
Barry. t
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(4)
Furthermore the Governor of Massachusetts has not to date indicated any intention to submit state emergency response plans for the Commonwealth of Massachusetts or to commit state resources to tne exercise or implementation of emergency response plans for Seabrook.
Indeed, he has ordered the planning process suspended while he attempts to gather information on tne Chernobyl accident.
See Affidavit of Charles V. Barry.
(5)
Regulation 50.47(a)(1) provides that "no operating license for a nuclear power reactor will be issued unless a finding is made by NRC that there is " reasonable assurance that adequate protective measures can and will be taken in the event of a radiological emergency."
(6)
Without participation oy the Massachusetts state and local governments in emergency planning, it is unlikely that the requisite section 50.47(a)(1) finding for licensure can ce made for the Seabrook plant or that the regulatory emergency planning standards set fortn in section 50.47(o) can be met, thus raising a strong likelihood that the Seaoroox nuclear power plant may never receive a license to operate at full-power, or that if it does receive such license it will not do so until after several years of litigation.
- See, e.g.,
Long Island Lighting Co.
(Shoreham Nuclear Power Station, Unit 1)
ALAB-88, 22 NRC 651 (1985).
(7)
The purpose of low power operation is to allow testing of plant systems prior to full-power operation, which testing 4-
s 4
can typically be accomplished in a period of a few months.
- See, e.g., Notice of Proposed Rulemaking, Emergency Planning, 46 Fed. Reg. 61132, 61133 (December 15, 1981).
(8). No Denefit can be derived from low-power operation if the reactor does not receive a license to operate at full-power and little, if any, benefit can be derived from continuing low-power operation beyond the several months required for testing.
See Dale G.
Bridenbaugh and Gregory C. Minor.
(9)
Nevertneless, operation at low-power does produce significant irreversible consequences, such as plant irradiation, fuel irradiation and worker exposure, which a
consequences only increase the longer a plant operates at lower-power.
See Affidavit of Albert Carnesale and Affidavit of Dale G.
Bridenbaugh and Gregory C.
Minor.
(10)
In promulgating Regulation 50.47(d) the Commission contemplanted that low-power operation would oe conducted only for a period of short duration.
See Notice of Proposed Rulemaking, sup;a at 61133; Statements of Consideration, Emergency Planning, 47 Fed. Reg. 134 (July 13, 1982).
(11)
It is therefore Attorney General dellotti's contention that Regulation 50.47(d) should be waived in tne instant case where tnere is no assurance that operation at full-power will ever occur and if it does occur will not occur
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for nearly a year, or possibly years, and thus any possible O
benefits to be attained from commencing low-power testing at this time will be far outweighed oy the significant and i.
4 irreversible adverse environmental consequences of such operation.
See Affidavit of Dale G.
Bridenbaugh and Gregory C.
Minor.
(12)
In its Statement of Consideration for Regulation 50.47(d), the Commission asserted as basis for its determination that off-site emergency planning was not required for low-power operation that there would be little off-site risk oecause "the fission product inventory during low power testing is much less than during higher power operation due to the low level of reactor power and short period of operation."
See, Statements of Consideration, Emergency Planning 47 Fed.
Reg. 30232 (September 1, 1982).
(13)
Nevertheless operation at 5% of rated power for a longer period of time will at some point lead to the accrual of waste products in tne fuel sucn that core melting could occur in the event of the interruption of the core cooling.
See Affidavit of Gordon R.
Thompson.
(14)
If Applicants presently receive their license to operate at low-power, such operation is very 11xely to continue for a period of time much longer than that contemplated by the Commission in promulgating Regulation 50.47(d), thereby raising a risk of off-site consequences not intended oy the Commission in adopting Regulation 50.47(d).
See Affidavit of Gordon R.
Thompson.
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4 (16)
Regulation 50.47(d) should further be waived until such time as there is conducted a full investigation and assessment of the recent nuclear accident at Chernobyl, its causes and the implications of such accident for off-site planning (nased upon available information, that accident required the evacuation of all persons within an 18 mile radius of the plant even though the Chernobyl reactor was only operating at approximately 6% of rated power when the accident occurred).
Respectully submitted, FRANCIS X. BELLOTTI ATTORNEY GENERAL By:
Carol S.
Sneider Assistant Attorney General Environmental Protection Division Department of the Attorney General One Ashburton Place, Room 1902 Boston, MA 02108 (617)727-2265 DATED:
July 2, 1986 '.t
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board In the Matter of
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Docket No. 50-443-OL-1 PUBLIC SERVICE OF NEW HAMPSHIRE
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50-444-OL-1
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(Seabrook Station Units 1 and 2)
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AFFIDAVIT OF ALBERT CARNESALE 1.
My name is Albert Carnesale.
I am Professor of Public Policy and Academic Dean of the John F. Kennedy School of Government, Harvard University, located at 79 John F. Kennedy Street, Cambridge, Massachusetts 02138.
I received a Ph.D. degree in nuclear engineering from North Carolina State University in 1966 (a copy of my curriculum vitae is attached).
I am currently serving on a voluntary basis as an advisor to Massachusetts Governor l-Michael S. Dukakis on nuclear power issues, specifically the implications of the Chernobyl nuclear power plant accident for emergency planning at the Saabrook nuclear power plant. (See pertinent press release, attached.)
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In_ my capacity as advisor, I have considered the impact of low-power operation of a nuclear reactor.
Based on my examination, I have formed the following opinions.
3 Before a nuclear reactor core achieves criticality, neither the uranium fuel nor the reactor components are significantly irradiated or contaminated by radiation. However, low-power testing.of a reactor necessarily entails achievement of criticality and operation of the reactor, thus creating irreversible changes to the core, the remainder of the reactor, and some supporting systems. These changes would increase the cost of removal of the reactor fuel and structures, as well as of any potential coversion of the plant facilities to other uses.
Furthe rmo ra, the increased levels of radioactivity necessarily raise the health and economic risks to the surrounding communities.
l 4
The nuclear fissions occurring during low-power testing result in the irreversible accumulation within the fuel elements of radioactive materials.
The levels and types of fission products and other radioactive nuclides within the fuel elements depend upon the specific operating history of the reactor during the testing program. This increasing inventory of radioactive materials also affects the severity of potential accidents that might occur during the testing program. The consequences include both contamination within the plant and, in the event of a breach of conteinment, exposure of the public to radioactivity.
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Neutrons from the fission reactions induce radioactivity within the structural components of the reactor. Again, the resulting types and levels of radioactivity induced depend on the operating history of the reactor. Such indu,ced radioactivity increases the riska and costs associated with disassembly or entombment of the reactor.
6.
Operation of the reactor over time also degrades the integrity of the fuel elements, making them more susceptible to leaking. Such leaking elements release radioactive materials into the primary cooling system of the reactor and contaminate it, which could further complicate disassembly or emtombment.
7.
In summary, operation of the reactor, even at low power, increases the levels of radioactivity within the nuclear fuel and other portions of the primary cooling system, thereby increasing the risk to public health and safety and the cost of potential conversion, disassembly, or entombment of the nuclear facility.
Signed under the pains and penalties of perjury.
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l' Albert Carnesale o
Date: July 2, 1986
o ALBERT CARNESALE
(
N Professor of Public Policy and Academic Dean John F. Kennedy School of Government Harvard University 79 Kennedy Street, Cambridge, MA 02138 (617) 495-1189 Home Address: 3 Malt Lane, Lexington, MA 02173 (617) 861-7267 Education:
B.M.E. (Mechanical Engineering)
The Cooper Union 1957 M.S.
(Mechanical Engineering)
Drexel Ir.stitute 1961 Ph.D.
(Nuclear Engineering)
North Carolina State University 1966 A.M.
(Honorary)
Harvard University 1979 Sc.D.
(Honorary)
New Jersey Institute of Technology 1984 Present Position:
1974-Harvard University. Professor of Public Policy, and, since 1981, Academic Present Dean at the John F. Kennedy School of Government.
Research and teaching interests in international security, with emphasis on policies associated with nuclear weapons and strategies for their use and non-use, and on the impact of technological change on defense and arms control policy.
Previous Positions:
1972-74 North Carolina State University, Raleigh, N.C.
Professor and Head, Division of University Studies, and University Coordinator for Environmental Studies 1969-72 U.S. Arms Control and Disarmament Agency, Washington, D.C.
Chief, Defensive Weapons Systems Divison, and Senior Advisor to head of U.S. Delegation to Strategic Arms Limitation Talks (SALT) 1962-69 North Carolina State University, Raleigh, N.C.
Instructor, Assistant Professor, and Associate Professor of Nuclear Engineering 1957-62 Martin Marietta Corporation, Baltimore, MD.
Senior Engineer, Nuclear Division Other Professional Activities:
Consultant to U.S. Arms Control and Disarmament Agency and to Departments of Defense, Energy, and State Head of U.S. Delegation to International Nuclear Fuel Cycle Evaluation, 1978-80 Recent Publications:
~~
Hawks, Doves, and Owls: An Agenda for Avoiding Nuclear War,icoauthor and coeditor with Graham T. Allison and Joseph S. Nye, Jr.
W. W. Norton, 1985.
"The Strategic Defense Initiative," in American Defense Annual, 1985-86, G. E. Hudson and J. J. Kruzel, eds.
Lexington Books, 1985.
Living with Nuclear Weapons, coauthor with other members of the Harvard Nuclear Study Group. Harvard University Press, and Bantam Books, 1983.
"The Utility Director's Dilemma: The Governance of Nuclear Power," coauthor with Graham T. Allison.
In Uncertain Power, ed. Dorothy S. Zinberg, pp. 134-53.
Pergamon Press, 1983.
" ICBM Vulnerability: The Cures are Worse than the Disease," coauthor with Charles Glaser.
International Security, Summer 1982, pp. 70-85.
NEWS RELEASE.
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FROM THE OFFICE OF GOVERNOR MICHAEL S. DUKAKIS May 29, 1986 CONTACT:
James Dorsey 727-2759 COMMONWEALTH OF MASSACHUSETTS Karen Schwartzman EXECUTIVE DEPARTMENT Tom Hubbard 727-1130 STATE HOUSE BOSTON, MA 02133 Nationally known nuclear expert to help state gather, study Chernobyl accident data Albert Carnesale, a nationally known expert on nuclear issues and President Carter's nominee in 1980 to chair the Nuclear Regulatory Ccenission, has agreed to assist the. comr:enwealth in gathering and evaluating information about the Chernobyl nuclear power plant accident, Gov. Michael S. Dukakis announced today. Dukakis is currently evaluating emergency evacuation plans for the Seabrook nuclear power plant.
"Al Carnesale has agreed to take time from a very busy schedule to assist the members of my administration as we try to draw appropriate lessons from the Chernobyl accident, in order to make a responsible decision on Seabrook," Dukakis said.
"This is a very inportant task. I don't think we can make a responsible decision on seabrook without understanding what happened at Chernobyl and what that accident says about our ability to protect people here from a nuclear plant accident. I have asked Al to help in two ways: to reach out to outside experts as needed, and to help interpret the information that is now becoming available about the Chernobyl accident," the governor added.
Carnesale holds a doctoral degree in nuclear engineer and was President Carter's nominee for chairman of the NRC in 1980. Carter's election loss and Carnesale's opposition to the Clinch River Breeder Reactor led to the withdrawal of his nomination.
- more -
James R. Dorsey, Press Secretary, Room 265, State House, Boston, MA 02133 (617) 727-2759
o 3
. Previously Carnesale had served as a member of the U.S. team which '
negotiated the first Strategic Arms Limitation Treaty (SALT I), and as head of the U.S. delegation to the International Nuclear Fuel Cycle Evaluation (1979-80), a 66-nation study of the relationship between civilian nuclear power development and the proliferation of nuclear weapons.
Now a professor of public policy and academic dean at Harvard University's John F. Kennedy School of Government, Carnesale's primary research intereste are in international security and U.S.-Soviet relations.
Dukakis added that "our goal is not to delay a decision on Seabrook, but to make an informed decision on Seabrook. I still believe that it is appropriate and inportant that the Federal regulatory agencies, such as the Nuclear Regulatory Commission, undertake a thorough assessment of nuclear power in the light of the Chernobyl accident.
"Whether the Federal agencies act or not, however, we will use our own considerable pool of experts here in Massachusetts to evaluate this issue. We need to know, as best we can, exactly what happened at Chernobyl and why. We need to know the points of similarity and difference between the technology at Chernobyl and nuclear technology here in this country. We need to know whether the spread of radioactivity from Chernobyl in any way challenges the assumptions upon which Kmerican nuclear plant design and emergency planning is based. We need to know whether the theory which underlies'much of our American nuclear plant emergency planning has been strengthened or weakened by the f acts we derive frce the Chernobyl accident," Dukakis said..
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C, UNITED STATES OF AMERICA NtfCLEAR REGUIATORY COMNI5sION Before the Atomic Safety and Licensing Appeal Board
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In the Matter of
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LONG ISIAND LIGHTING COMPANY
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Docket No. 50-322-CL
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(Shoreham Nuclear Power 8tation,
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Unit 1)
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AFFIDAVIT OF DALE G. BRIDENBAUGE AND GREGORY C. MINOR IN SUPPORT OF MOTION FOR STAY 1.
My name is Dale G. Briden'caugh.
I am president of MHB Technical Associates ("MRB"), a technical consulting firm specializing in nuclear power plant safety and licensing mat-s ters, located at 1723 Hamilton Avenue, Suite K, San Jose, N.
California 95125.
I received a Bachel of Science degree in mechanical engineering from South Dakota School of Mines and Technology in 1953 and am a licensed professional nuclear engi-l neer.
I have more than 30 years experience in the engineering field, primarily in power plant analysis, construction, mainte-l nance and operationa.
Since 1976, I have been employed by MHB l
and have acted as a consultant to domestic and foreign govern-ment agencies and other groups on nuclear power plant safety
and licensing matters.
Between 1966 and 1976, I was employed by the Nuclear Energy Division of General Electric Company
( "GE") in various managerial capacities relating to the sale, service and product improvement of nuclear power reactora manuf actured by that company.
Between 1955 and 1966, I was employed in various engineering capacities working with gas and steam turbines for GE.
Included in my duties at GE was super-vision of startup testing of equipment in fifteen to twenty fossil or nuclear power plants.
I also was responsible for various nuclear fuel projects ranging from the remote disassembly of irradiated fuel to the supply of reload fuel for operating nuclear plants.
I have written numerous technical papers and articles on the subject of nuclear power equipment and nuclear power plant safety and have given testimony on those subjects.-
2.
Hy name is Gregory C. Minor.
I am vice president of HRB.
My education background is in electrical engineering (with a power systems option) in which I received Bachelor of Science (University of California, Berkeley, 1960) and Master of Science (Stanford, 1966) degrees.
I have over 24 years of experience in the nuclear industry, including design and testing of systems for use in nuclear power plants.
Since 1976, I have been employed by MHB and have acted as a md!
consultant to domestic and foreign government agencies and other groupe on nuclear power plant sagsty and licensing mat-tars.
Between 1965 and 1976, I was employed by the GE Nuclear Energy Division as a design engineer and manager of engineering design organizations.
My responsibilities included the design, testing, qualification and pre-operation testing of safety equipment and control rooms for use in nuclear power plants.
While with GE, I participated in the pre-startup testing of the instranentation and control systems for a nuclear test reactor
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and in numerous system tests.
3.
Our experience with the Shoreham plant starteg when we were employed by GE.
At that time we were involved with the design of reactor system components for shoreham and imple-mentation and resolution of problema related to that design.
Af ter leaving GE, we have been involved with the Shoreham case on a virtually continuous basis since 1977, when we were origi-nally retained as consultanta to Suffolk County.
As consul-l 1
l tants on the Shoreham plant, we have performed diverse assign-ments, focusing primarily on technical reviews and analysis of safety and cost issues.
Over the course of the Shoreham pro-I ceedings, we have visited the plant on numerous occasions and have testified on diverse issues before the tiRC's Atomic Safety and Licensing Board and the State of New York Public Service Commission. l 4b
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.This Affidavit is to 84 Plain the technical reasons why low power testing to 5 percent power at shoreham is of lit-tie value end. in fact, incurs several irreversible losses while producing no electrieel power.
TIMING OF LOW POWER OPERATION 5.
Every nuclear plant needs to have fuel loaded and nya-tems tested before it is permitted to operate at power levels where the turbine can be turned and electric power ganarmted.
In general, most of the testing is performed at power levels of 5 percent power or less; if the testing is completed satisfac-torily and other requirements are satisfied, then the plant is, permitted to operate at higher power levels at which sufficient steam may be generated to allow production of electricity.
6.
The NRC action to permit Shoreham low power operation at this time represente a deviation from the practice at most l
other plants.
Where nuclear plants are granted an operating l
license a.s a result of a single licensing action, fuel loading l
4 and low power test activities are then performed and integrated with the approach (" ascension") to full power.
Where plants have first been granted a low power license a a as to complete the fuel loading and low power testing by the time the full po w r license is issued, usually the low power testing and the full power licensing are relatively close together in time.l_/
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Of 15 plants licensed for low power operation between March 1979 and June 1984, and also receiving a full power
( Footnote cont' d next page)
A --
h e4 7.
In the case of Shoreham, the low power license has been requested in not one, but four separate phases
- Phase I is fuel loading and no criticality (i.e. irradiation of the fuel) is achieved; Phase II is cold criticality testing Wherein estremely low levels of criticality (.0014 power) are achieved for a very short period of timer Phase III is initial heatup and operation at up to 14 of full powerr and Phase IV is low power testing and subsequent hettups involving operation at up to 5% of full power.
LILCO obtained on December 7, 1984 a li-conae for Phases I and II only.
LILCO completed its fuel load-inq on January 19, 1985; it began cold criticelity testing on February 15, 1985 and completed it roughly 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> later, on February 17, 1985.
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TRREVERSIBLE CHANGES IN STATUS QUO RESULTING FROM LOW POWER OPERATION 8.
Before a reactor "goes critical" as it does for the first time during low power testing, neither the nuclear fuel (Footnote cont'd from previous page) license, the average time between the icw power and full power licenses was less than 5 months.
The average time from initial criticality -- which Shoreham achieved in l
February,1995 -- to award of the full power license is l
only 1/2 month ( excluding Grand Gulf which was indefi-nitely delayed).
Attachment to Letter from mtC Chairman Palladino to Congressman Edward Markey, June 15, 1984.
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nor the reactor or its components, are irradiated or contaminated by radiation.
Low power testing, however, neces-sarily causes irreversible changes to a nuclear reactor and its supporting systeme.
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.9.
There is necast criay signifier.nt irradiation of the i
nuclear fuel as a result of low power testing.
This irradiation results in the build-up of quantities of fission 4
products within the fuel which requires that the fuel subee-f quantly be handled, transported, and treated as irradiated t-fuel.
Once these fission products have been produced, they 4
I cannot be removed from the fuel by any usual means.
Thus, the irradiation from low power testing is irreversible.
During low
- k. -
I power testing other components of the shoreham plant would also 7
4 be irreversibly irradiated.
These include the 137 eentrol rods t
and control rod drives, the 31 local power range monitors, a w
_ number of source and intermediate range neutron monitors, and other reactor components, equipment, and piping.
Once contami-nated by substantial quantities of radioactive fission prod-special care would be required in handling these items.
- ucts, 1
L 10.
Because of the unavoidable irradiation and contamina-tien described above, the conduct of low power testing of no-L cessity requires some worker exposure to harmful radiation 5
6-ew,,_
k i
w during the course of the testing as well at after the testing is completed.
The amount of espesure may not be large and un-less errors were made, probably would not asceed allowable lim.
its.
However, it is an additional unavoidable impset which re-t f
sults from low power testing.
11.
During Phases I and II of LILCO's low power testing f
program for Shoreham, a small amount of irradiation of the fuel l
and contamination of reactor internals and components occurred.
l 1
However, the amounts of irradiation and contamination that are l
involved in Phases III and IV of LILCO's low power testitug pro-gram are greater by many orders of magnitude.
LILCO's cold criticality (Phase II) testing in February, 196$ involved crit-iemlity, at 0.001 percent of power, for roughly 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />.
The amount of fuel irradiation and resulting contamination from Phase II is insignificant when compared to that which would occur during operation at 54 power for roughly two months as
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contemplated by LILCO's low power testing program.2_/
The fuel 2,/
In fact, LILCO has predicted that the amount of time it would operate Shoreham at 54 power could be much greater l
than that necessary to complete its icw power tests.
In its Startup Test Program Evaluation for a 5 4 Reactor Power I
Limitation ( at 4), LILc0 stated:
"if a delay in receipt of a full power license well beyond the two months [of low power testing] is anticipated, frequent operation at 5%
reactor power will be necessary to reactivate startup sources."
l..
irradiation, samoured in megawatt days per ton of fuel, was 0.00036 engtr/ Tun frces the February 1985 Phase II criticality; it would be over 70 entDF/ Ton, assuming only 60 days of 5%
operation.
Furthermore, the radiation levels resulting frost the brief criticality in February for Phase II, at this time would be even lower than that stated above following initial criticality, since the minimal fission products produced have already had approximately four monthe to decay.
Even if addi-tional criticalities, subsequent to that performed in February, were performed within the Phase 11 low power license limits of
.001% power, the performance of Phases III and IV testing at Shoreham would nonetheless result in a substantial and irre-versible change.in the status quo.
12.
In addition, in its non-irradiated condition, the fuel loaded into the Shoreham core probably had a recovery (or salvage) value nearly equal to the original purchase value (about S65 million) for that fuel.
This fuel, if not irradi-ated, likely could have been sold to other nuclear plants to use as is, or, if necessary, to have it reconfigured for a dif-l ferent reactor. (For example, some bundles might have required manual disassembly and rod rearrangement or reconfiguration of i
the pellets for the necessary pattern of enrichment.)
The fuel I
still probably has a salvage value even af ter the light s-
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irradiation involved in Phases I and II.
However, once the fuel is substantially irradiated and there is a substantial build-up of fission products as would occur during Phases III and IV, it makes fuel reconfiguration, and therefore most i
opportunities for reuse of the fuel, more complicated and costly and therefore far less likely to be Laplemented.
According to LILCO, the cost to LILCO of the Shoreham fuel is h
$65 million.
Thus, we believe that positive salvage value could be realized from the fuel in its post-Phase II condition a
3 j
(although not as much as if the fuel were not irradiated at all).
There would be no such value if the fuel were used for testing up to 58 power.
\\s 13.
Phases III and IV would also result in the loss of
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potential salvage value for other plant components that would be substantially irradiated (i.e., control rods, control rod drives, local power range, source, and intermediate range neutron monitors).
We estimate the replacement value of these i
components to be at least $2 - 6 million.
These components are i
virtually identical in all BWRs and are periodically replaced.
Thus, a resale market for them should arist unless they are i
heavily irradiated.
The NRC Staff appears to agree with our opinion.
(see Affidavit of Edward G. Goodwin, dated February 20, 1985, flied by the NRC in U.S. Court of Appeals, at 10).
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Although as a result of the minimal Phase II criticality, these components have been irradiated to a minor extent, the radia-tion levels now present would not, in our opinion, preclude al.
together their transfer and installation in other reactors, al-though it would be more difficult end complicated than if they were not irradiated at all.
Additional irradiation during Phases III and IV, however, would reduce their marketability to practically nothing.
14 Additional costs resulting from a decision to perform low power testing are the costs of defueling, decontaminating, decommissioning, and disposal of the fuel as well as portions of the primary reactor system following a low power testing pe-riod in the event that a full power license is not obtained.
l The cost of necessary removel/ disposal / decontamination efforte could be tens of millions of dollars, depending on the specific I
disposal requirements.
Such efforts also carry with them the potential for additional worker radiation exposure.
The irra-diated fuel must be disposed of as high level radicactive waste.
The U.S. Department of Energy has published expected 4
costs for the receipt and ultimate disposal of irradiated fuel.
The costs are currently being collected at a rate of 5 001/ kwhr of generation for fuel exposed now to be disposed of by DOE in the future.
For fuel with a design esposure of 15,000 MWD 9 i
(t)/ ton this cost is equivalent to approzhmately $120,000 per i
i The potential cost for disposal by DOE of the 100+ tons ton.
at shoreham is therefore approximately $12,000,000, not counting transportation or possible cost increases.
In addi-tion, no disposal facility is planned or expected before about the year 2000, some 15 years in the future.
LILco would there-fore be required to store and safeguard the opent fuel on site until that time.
Assuming an operations and security staff of at least 10-15 people for this chore, an annual cost of
$500,000 to 51,000,000 is not unreasonable and is probably low.
The cost of spent fuel disposal alone thus becomes a $20 to 30 million obligation.
Reactor camponent removal, handling and disposal would be additionally required.
TESTING IN PHASES III AND IV IS VERY LIMITED 15.
Although according to LILCO $4 systems will be din service, operated and tested" during Phases III and IV testing.
41 of those systems are already operational and have Deen checked out as part of Phase I and Phase II testing.
Thus, in theory Phases III and IV provide the opportunity to check out only 13 additional systems.
However, not even that r.any sys-tems can be thoroughly or properly checked during Phases III and IV.
The main turbine would not be operated during Phases
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III and IV.
Ptr. Gunther, a LILCC employee, stated under oath thati1140 did not intend to try to operate the main tutbine during its Phase III and IV testing.
Tr. 776, 780; SCLE..gs. 2.
And, even if LILCD did intend to operate the turbine, it is I highfy unlikely that the main turbine could be operrat'ed4uc.iag Phases III and IV.
According to LILCO'a Vice President-Nuclear, John D. Leonard, Jr.s When you bring steam down the pipes at five percent, you can test every component of that plant except the main turbine...
It's conceivable we are going to look very, very careful-ly to see if we could possibly spin the turbine.
I don't think we can with that small amount of steam.
I don' t think we can overcome its inertia.
Transcript of Feb. 8, 1985 Oral Argument to the NRC, at 89.
And. in an internal evaluation of 5% power tests. LILCO stated:
Certain tests in the Low Power Testing phase, such as turbine roll and HPCI, are normally perforined at about 20% CTP [ Corn Thermal Power.l....
The modified schedule moves tests requiring nuclear steam flow to the end of 5%
testing.
These tests ( main turbine roll, HPCI fine tuning, heatup of related piping, etc.) are ordinarily conducted prior to TC-1, but with the system at about 10-15%
reactor power.
Stable operation of the nu-clear plant at 54 power may be difficult and has not been demonstrated during operation of other BWR plants.
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"A Startup Test Program Svaluation for a 54 Reactor Power Limi-tation," sR2-K71-393, Oct. 25, 1983, at p.2.
Therefore, the Turbine Generator and the turbine controi portion of the ESC systems could not be operated in Phases III and IV.
In addi-tion, the support systems, consisting of the Turbine Lube 011 Systems, Generator Seal Gil Systems, and steam Seal Systas, could not be completely or iimelly checked out until the tur-bine generator is actually run.
Thus, only 8 additional sye-tema could be checked out during Phase ZZZ and IV testing.
16 In addition, there are several tests which cannot be properly or completely performed at low power levels (54 or lesa).
These includes APRM/1RM calibration at overlap point l
Set APRM trip reference point at 554 APRM calibration (inaccurate at very low readings and would have to be repeated at higher pow levels)
Turbine roll and balance at 1800 RPM Generator exciter test Moisture seperator-raheater and drains (dynamic test)
Extraction steam (dynamic test)
Local power range monitor calibration Although there are non-standard methods available to permit partial performance of some of these tests and partial testing of some other systems at 54 power, the tests would have to be substantially repeated at higher power levels.
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Considering that phases III and IV would only add a few systems to those already checked out, and that other sys-tems require higher power levels for testing, there is rela-tively little benefit te be gained by pursuing Phase III and IV operation for the sole purpose of system testing.
Furthermore, many of the tests in Phases III and IV are one time testa.
That is, they must be done at some point prior' ter higher levels of operation but exactly when they are' performed is not partic-olarly important.
However, some of the tests which involve the calibration of two ayatens at their point of overlap would need to be performed again if the approach to full power were sub-stantially delayed (assuming that at some point e full power license were authorized).
Accordingly, while it is difficult to be precise, it appears likely that at least some of the pro-posed Phase III/IV activities would have to be repeated af ter a full power license were authorized, if the Phase III/IV activi-ties were conducted soon and then followed by a delay prior to full power operation..I
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THERE IS NO PURPOSE SERVED, AND NO BENEFITS PRODUCED, BY LOIt POWEE TESTING TO OUTWEIGE THE ADVERSE Asp IRREVERSIBIE CHANGES IN THE STATU5 000 18.
The essential purpose of a low pow r license is to test reactor systems which cannat be effectively tested in non-critical conditions.
It is necessary to conduct such testing prior to operating the plant at higher power levels (i.e., greater than 5 4 power).
However, during Phase III and IV testing, the shoreham reactor would never be put in the "run" mode.
Therefore there would be no electric power supplied to the grid as a result of the testing, and there would be no displaced oil or fusi cost savings.
Instead, power from the grid would be required to run the plant during the tests.
Thus, none of the benefits assumed in the NRC's 1977 EIS for Shoreham would be achieved by low power testing; howev-er, as noted, low power operation would result in environmental l
impacts, such as plant contamination with radioactive material, the likely loss of the resale value of the fuel and other com-ponents once they become irradiated, the cost of decontamination, decommissioning and disposal, and worker expo-sure.
19 Because low power testing standing alone produces no benefits but does have serious adverse effects, it is our a <.
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4 opinion that there is no reason to conduct low power testing just for its eske alone.
Rather, low power testing can be ra-tionally justified only in circumstances where there is no sub-stantial doubt that the plant subsequently will operate at higher power love.la so that its benefits ( i.e., generation of electricity) will be available to offset the adverse effects (fuel irradiation, radioactive contamination, potential worker exposure) which cannot be avoided.
In our technical opinion, the optistaa time for performing low power testing of any nucle-ar reactor is shortly before full power operation is reliably anticipated to begin.
DALE G. BRIDmasAUGH 5NFddRY C. MINOR l
i Subscribed and sworn to before me
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day of 1985.
NOTARY PUBLIC My Commission empires: =
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i AFFIDAVIT 1.
My name is Charles V. Barry and I am the duly appointed Secretary of Public Safety for the Commonwealth of Massachusetts.
In my capacity as Secretary, I am responsible directly to the Governor of the Commonwealth of Massachusetts.
My duties include coordination and overall supervision of all emergency planning and management activities for the Commonwealth's major public safety agencies.
In particular, I exercise supervisory authority over the Massachusetts Civil Defense Agency and Office of Emergency Preparedness.
Under Massachusetts Executive Order No. 144, the Governor has designated me to serve as his chief executive officer in the event of a declaration of emergency in the Commonwealth.
2.
Radiological Emergency Response Plans required for nuclear power plants are developed, maintained and updated by the Massachusetts Office of Civil Defense with support from other agencies such as the Department of Public Health.
In the case of the Seabrook nuclear power plant, the Governor established a process whereby the Civil Defense Agency and other state officials were charged with responsibility for preparing drafts of such plans in consultation with local officials from the Emergency Planning Zone (EPZ) and Host communities. Under direction from the Governor,I was charged
AFFIDAVIT OF SECRETARY CHARLES V.
BARRY PAGE TWO with responsibility for making a recommendation to him concerning the adequacy of any such plans, the options available to the Governor and the best course of action to follow.
To date, I have not recommended a plan to the Governor which we have determined to be " adequate."
3.
On March 27, 1986, Governor Dukakis and Attorney General Bellotti announced the " Commonwealth's position" on emergency response plans for the Seabrook Nuclear Power Plant.
See copy attached hereto and incorporated herein by reference.
Among other things, the Governor declared "[wle do not believe that the evacuation plans are adequate or capable of implementation during the summer months, unless the Seabrook plant is shut down or adequate shelter is in place.
For that reason I do not believe that plans are sufficient for an exercise unless there is assurance that either condition, shutdown or shelter, is met by the Seabrook plant."
Neither condition has been satisfied.
4.
On or about April 29, 1986, in reaction to the nuclear power plant accident at Chernobyl in the Soviet Union, Governor Dukakis directed that the planning process for the Seabrook Radiological Emergency Response Plans (RERP) be put on hold until further notice.
Thereafter, on May 2, 1986, Governor l
AFFIDAVIT OF SECRETARY CHARLES V. BARRY PAGE THREE Dukakis wrote to Mr. Lee Thomas, Administrator of the U.S.
Environmental Protection Agency in his capacity as the leader of the federal inter-agency task force on the Chernobyl accident.
The Governor wrote to underscore the need to obtain the best possible information and guidance about the implications of the Chernobyl accident.
(See copy attached hereto and incorporated herein by reference).
We have received an acknowledgement letter from Mr. Thomas, but there has been no analysis of the implications of the Chernobyl accident from the task force or from any other authoritative federal source.
On several occasions, Dr. Thomas Murley of the Nuclear Regulatory Commission (NRC) staff has stated that the NRC intends to conduct a study of Chernobyl following receipt of information from the International Atomic Energy Agency (IAEA).
This information is reportedly due in late August following the issuance of a report to the IAEA by the Soviet i
Union.
This information is critical to any renewed planning effort which we might undertake.
5.
In addition, on May 29, 1986, Governor Dukakis announced that Dr. Albert Carnesale, a nationally known expert on nuclear issues, and a nominee to chair the NRC, had agreed i
AFFIDAVIT OF SECRETARY CHARLES V. BARRY PAGE FOUR to assist the Commonwealth in gathering and evaluating l
information about the Chernobyl nuclear power plant accident.
In his public statement on the matter, Governor Dukakis reported that "our goal is not to delay a decision on Seabrook, but to make an informed decision on Seabrook.
I still believe that it is appropriate and important that the federal regulatory agencies, such as the Nuclear Regulatory Commission,
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undertake a thorough assessment of nuclear power in light of the Chernobyl accident."
Dr. Carnesale is presently engaged in fact-finding and also is awaiting the IAEA report.
6.
By vote of its' Annual Town Meeting on November 18, 1985, the Town of Amesbury voted to accept the recommendation of its Radiological Response Plan Committee to reject the draft Amesbury Response Plan and terminate all further planning.
In i
the weeks following April 29, 1986, four other Massachusetts EPZ communities (the Towns of Newbury, West Newbury, Merrimac and Salisbury) voted in Town Meeting to terminate or otherwise suspend participation in Radiological Emergency Response Planning.
On June 30, 1986, an initiative petition signed by i
2,000 citizens and proposing a ban on all planning for the Seabrook plant was presented to the Newburyport, Mass. City Council.
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AFFIDAVIT OF SECRETARY CHARLES V.
BARRY PAGE FIVE 7.
On June 25, 1986, Governor Dukakis wrote to Mr. Edward Brown, President of New Hampshire Yankee Division of Public Service of New Hampshire and urged him, in the public interest, to postpone fuel loading and low power testing at the Seabrook plant.
(See copy attached hereto and incorporated herein by reference).
The Public Service of New Hampshire has elected not to agree to the Governor's request, although President Brown did respond in writing.
(See copy attached hereto and incorporated herein by reference).
{
f Charles V. Ba rbf V
s Then personally appeared the above named Charles V.
Barry and made oath that the above statements are true.
ld!!/ f d'yeJ Notary Public My Commission Expires: j~/ a g / /, /ff/
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e THE COMMONWEALTH OF MASSACHUSETTS h
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EXECUTIVE DEPARTMENT STATE HOUSE BOSrON 02133 MICH AEL S. DUKAKHS Govsamon March 27, 1986 Statenent of Covarnor Michael S. Dukakis on Seabrook Emergency Response Plans Attorney General Bellotti and I are,icining today to announce the Commonwealth's position on tha emergency reeporse plans for the six Massachusetts co=munities located in the evacuation zone of the Seabrook nuclear power plant.
The Attorney General and his staff have worked for many years on the legal issues raised by the siting of the nuclear plant at Seabrook. Members of D
my own administration have werked intensively for many conths on the evecuation plans which must be approved before the Seabrook plant can be licensed to operate. While there is work lef t to be done on these plans, we have come to se=e basic conclusions.
First and foremost, we believe there will be a significantly increased ha: sri posed to the public in the sun =er conths when the Seabrook plant is in operation. The area arourd the Seabrook plant is a difficult area to evacuata, particularly during these suster waeks when so many '!assachusetts resi!ents and visitors use the beaches in the vicinity.
We have worked very ha ri to reduce this increasei hazard by devaloping the best enerpency plans we cer, but we have concluded that the only prudent way to protect against this hazset is for the Seabrook plant to sbut-down during thosa s unn e r ce n t hs, u n t ' '. auch tice as adequate shelter for the public can te planned and built.
We are prepared to work expeditiously and in good fei*h to set standsris for shelters, which we would expect the Seebrook owners to corstruc t under tre Connonwealth's supervision. 'Jntil such tine as those shelters are av91'.able to the public, however, we will insist that the Seabrook plant not operste during the period of peak beach usaga.
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D We do not believe that the evacuation plans are siequate or capable of implementation during the su==er months, unless the Seabrook plant is shut-down or adequate shelter is in place. For that reason I do not balieve the plans are sufficient for an exercise unless there is assurance that either condition, shut-down or shelter, is =et by the Seabrook plant.
Let me say that I hope that the Seabrook owners will work with us so that we can put these prudent safeguards into place for the protection of the public. I think it has been clear from the start of construction at Seabrcok that the siting of the plant at that location would make the protection of the public difficult. It is unfortunate that the nuclear regulatory process regards emergency planning as almost a last step in the licensing of a nuclear plant.
This has not been an easy process for the citizens of the affected co=munities.
Their concern and their involvement in this process has been e tremendous help to me and to the Attorr.ey General.
We will continue to work closely with those affected as this process goes forward. To this end, I have instructed Public Safety Secretary Charles Barry to hold a public hearir.g within two weeks at which the evacuation plans, with this important new will be reviewed by the citizens of the affected co=munities.
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THE COMMONWEALTH OF MASSACHUSETTS g
g EXECUTIVE DEPARTMENT BOSTON o2133 STATE HOUSE e
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e MICH AEL S. OUK AKIS Govannon May 2, 1986 Lee Thomas, Administrator U.S. Environmental Protection Agency 401 M Street SW Washington, D.C.
20460 Dear Leer I am writing to you in your capacity as leader of the federal intar-agency task force on the Chernobyl nuclear accident to underscore the very real need of MassecFusetts and other states to recalve the best D
information and guidance possible on the irplications cf the Chernobyl accident for nuclear plant safety ani evacuation planning here in the U.S.
It seems apparent that nuclear safety standards in the U.S. are higher than in the Soviet Union, and that the Chernobyl reactors ere of a type much different than those we have here in New England. Nevertheless, any nuclear accident occuring at this still-young stage in the history of nuclear power is a cause for a serious reassessment.
As you are aware, the state government role in the development of nuclear power plants has been limited greatly by the A*cnic Energy Act and successo r laws and regulations. Howaver, the evacuation plannirg recui-ements created in the wake of the Three Mile Island accident have given statas an inportant responsibility for seeing that people are adeauntely protected in the evant of an accident at a nuclear plant. Thus, state government must be a part of the new reassessuent of nuclear power.
Here in Massachusetts this responsibility is heightened because of the parding licensure of the Seebrook ruclear power plant in New Hanpsnire.
Ironically, we have been fr cced to consider tre feasibili ty of safe evacuation f rom the Seabrook area only now thet the Seabrook plant has rancFed vi rtual completion of construction. Massachusetts contended from the irceptice of tre Seebrook project that it was inappropriately sited, but this contention has been consistently ruled out of order by federsi -egula* cry agencies - es recently as this very veek.
30)
Nevertheless, we have made a commit =ent to follow-through on a rigorous evacuation planning process, despite the sincere belief of nany local residents that no evacuation plan can be sufficiert. But we will not submit an evacuation plan simply for the sake of submittieg an evacuation plan. Any evacuation plan that I suhmit to the federel government will he designej to guarantee to the merimum extert possible tre realth and safety of tre people of Massachusetts.
Our current assumptions about nuclear plant evacuation planning derive from the experience of Three Mile Island. The Chernobyl accident - now the worst in history-may challenge those assumptions anew. For that reason it is vitally important that all states which are exercising their responsibility for nuclear emergency planning receive the benefit of the best information and analysis available.
I realize that the secretive pra'etices of the Soviet Union act to frustrate our need and that of other nations for accurste information. We can only hope that the force of world opinion will cause the Soviets to act re sponsibly.
Even so, there is much thet can be learned through sources available to you end the other federal agencies participatirg in the federal task force.
I would hope and expect that the efforte of tre federal task force and its D
member agencies will be directed towards belping the a'stes erencise the heavy responsibility which now faces them.
Sinc e rely,
Michael '. Dukakis l
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h THE COMMONWEALTH OF MASSACHUSETTS n] ~
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N" EXECUTIVE DEPARTMENT f
STATE HOUSE BOSTON 02133
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MICH AEL S. OUKAKM5 GovtmNom June 25, 1986 Mr. Edward Brown, President New Hampshire Yankee Division Public Service of New Hampshi re P.O. Bor 300 Seabrook, New Hampshire 03874
Dear Mr. Brown:
I am writing in regard to your intention to initiate fuel loading and low-power testing of Seabrook Station in July. Af ter careful analysis of the current status of Seabrook's application for licensure,
(']) conclusion that such testing would be a grave mistake atimpact th coupled with the is entitled to full licensure.I urge you to postpone lcw-power testing until is is det irreversible impact it could have on the current situationMy princi of health and safety, it
. Fi rs t, in the area is unwise to begin operations at any level, even
- partial, been tested. The Chernobyl disaster, among other things,before o accident can occur at low-power. It seems to me foolhardy to proceed unless remirds us that an low-power testing is absolutely essential at this stage.
for conversion of Seabrook Station to a non-nuclear use.
planning, it is clear that the interests of both shareholders will be irreparably harmed if Seabrook Station proves unlicensable for nuclear power production and, at the same time, there is no feasible alternative for preserving the plant for productive use. The loading of nuclear fuel and low-level operation will contaminate the Seabrook site and could eventually render Seabrook Station unavailable for alternative fuel sources. Suc is decidedly not in the public interest
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Mr. Edward Brown, President New Hampshire Yankee gW June 25, 1986 Page Two Thi rd, low-power operation is particularly imprudent at this point because, at the same time there is so ctuch to lose i f operation goes forwarri, there is very little to be gained. It is my urderstanding that a relatively short period is reauf red for testing prior to full operation, five months being the general estimate. You have already indicated that you do not believe full operation of the plant ta possible before the spring of 1987. At this point we simply do not know when licensure is likely to occur. Indeed, at the Shoreham site in Long Island where low-power operation began last year, the contamination process has begun and the af te may be unavailable for alternative energy, and yet licensure by the NRC is unresolved and still uncertain. This is a trap that is extremely unfortunate and still avoidable at Seabrook.
In summary, I believe that the arguments against proceeding to low-power testing at Seabrook at this time are compelling,
nd I hope that the joint owners will see fit to postpone any testing unti such time as the plant's oligibility for full licensure has become clear ff S)mee rely, g
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PENHI New Hampshire Yankee Division June 26, 1986 NHY #860905 Governor Michael S. Dukakis The Commonwealth of Massachusetts Executive Department State House Boston, Massachusetts 02133
Dear Governor Dukakis:
I want to assure you that the Joint Owners of Seabrook Station and New Hampshire Yankee will give the request contained in your letter of June 25 very serious study.
I will be able to respond after we havs had an opportunity to review your concerns thoroughly.
I have some questions about specific points contained in your letter and believe that a meeting with you to seek clarifica-hm tion is appropriate. The concerna; and the issues are of such significance that a brief meeting would be much more productive than a lengthy exchange of correspondence or discussions through intermediaries.
I must respond to one point contained in your letter regarding the impact of low power testing on public health and safety.
Tnere is no evidence of any risk to the public healtn and safety during testing at up to five percent power and, as has been demonstrated by the performance of the inductry in the United States, there is a negligible risk to the public at any power level.
Also, the Nuclear Regulatory Commission, after extensive study, does not require l
completion of offsite emergency respouse plans prior to fuel load and low power testing.
I will call your office soon to arrang'e a meeting at a mutually con-venient time; in the meantime I will discuss your concerns with the Joint Owners.
I look forward to discussing this with you.
Sincerely, a
i Edward A. Brown President EAB:bes em
e Affidsvit of Gordon Thompson 2 July 1986 pop 1 Affidsvit of Gordon R Thompson PhD I, Gordon Thompson, hereby depose and say :
My qualifications are set forth in an attached resume. This indicates that I have experience in assessing the potential for accidental releases of radioactive material from nuclear power facilities.
This affidavit concerns the accident potential associated with operation of the Seabrook nuclear power plant, Unit 1, at 5 percent of rated power.
Specifically, prolonged operation at this power level may create the potential for core damage and the release of radioactive material to the environment.
Although operation at the 5 percent level will generate a smaller inventory of waste products in the core, and therefore a lower level of decay heating, than will full-power operation for the same period, the potential for core damage may still exist. Most notably, reactor cores of the Seabrook type contain sufficient zirconium that the energy potentially available from zirconium-steam reaction is comparable with the energy needed to melt the fuel inventory. Thus, if the level of decay heating is sufficient to initiate zircontum-steam reaction following an interruption of core cooling, fuel damage may occur.
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Should fuel damage occur, and a pathway from the core region to the environment exist, radioactive material may be released to the environment. After prolonged operation at the 5 percent level, this release may be sufficient to produce offsite doses in excess of Protective Action Guides (PAGs).
1 In the particular circumstances surrounding the Seabrook plant, there l
could be a long delay, perhaps of 1 year or more, between the i
commencement of operation at the 5 percent level and the granting of a full power license. It is therefore important to determine the duration of operation at the 5 percent level which could, in the event of an accident,
i k.
Affidwit of Gordm Thompson 2 July 1986 page 2 lead to offsite doses in excess of PAGs. Current licensing practice indicates that operation for that period or longer should not occur in the absence of a radiological emergency response program. For example, NUREG-06S4 Rev.1, November 1980, states (at page 6) that : The overall objective of emetpencytispmsep/ms is toprovik kse savings (adin some cases immediate life saving) for a spectnxn of accients that could proctice offsite eses in excess ofProtective Action Guiks.
Signed under the pains and penalties of perjury, this 2nd day of July,1986 :
G& R. \\
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Gordon R Thompson PhD institute for Resource and Security Studies 27 Ellsworth Avenue Cambridge, MA 02139 cea:::nse21th of hssachusetts C:uary ter A'M 1R.ccr cubreriL+
.r.d s nrn to before mo this day o' t_b tl 19 ba c1R
( flit pub 1Ie Notary
( Joanne M. Ribeiro NOTARY PUBLIC My Commiss on Ex;; ires January 16,1992 l
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Resume for Gordon Thompson June 1986 Professional Exoertise Consulting scientist on energy, environment, and International security issues.
Education
- PhD in Applied Mathematics, Oxford University,1973.
- BE in Mechanical Engineering, University of New South Wales, Sydney, Australia,1967.
- BS in Mathematics and Physics, University of New South Wales,1966.
Current Accointments
- Executive Director, Institute for Resource & Security Studies ( IRSS ),
Cambridge, MA.
- Coordinator, Proliferation Reform Project ( an IRSS project ).
- Treasurer, Center for Atomic Radiation Studies, Acton, MA.
- Member, Board of Directors, Political Ecology Research Group, Oxford, UK l
- Member, Board of Directors, New Century Policies Educational Programs inc, Cambridge, MA.
- Member, Advisory Board, Gruppe Okologie, Hannover, FRG.
Consulting Exoerience ( selected )
- Lakes Environmental Association, Bridgton, ME,1986 : analysis of feder61 regulations for disposal of radioactive waste.
- Three Mile Island Public Health Fund, Philadelphia, PA,1983-present :
studies related to the Three Mlle Island nuclear plant.
- Attorney General, Commonwealth of Massachusetts, Boston, MA,1984-present : analyses of the safety of the Seabrook nuclear plant.
- Union of Concerned Scientists, Cambridge, MA, 1980-1985 : studies on energy demand and supply, nuclear arms control, and the safety of nuclear installations.
- Conservation Law Foundation of New England, Boston, MA,1985 :
preparation of testimony on cogeneration potential at the Maine facilities of l
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2 Great Northern Paper Company.
- Town & Country Planning Association, London, UK, 1982-1984 : coordination and conduct of a study on safety and radioactive waste implications of the proposed Sizewell nuclear plant.
- US Environmental Protection Agency, Washington, DC, 1980-1981-assessment of the cleanup of Three Mile Island Unit 2 nuclear plant.
- Center for Energy & Environmental Studies, Princeton University, Princeton, NJ,1979-1980 : studies on the potentials of various renewable energy sources.
- Government of Lower Saxony, Hannover, FRG, 1978-1979 : coordination and conduct of studies on safety aspects of the proposed Gorleben nuclear fuel center.
Other Exoerfence ( selected )
- Co-leadership ( with Paul Walker ) of a study group on nuclear weapons proliferation, Institute of Politics, Harvard University,1981.
- Foundation ( with others ) of an ecological political movement in Oxford, UK, which contested the 1979 Parliamentary election.
- Conduct of cross-examination and presentation of evidence, on behalf of the Political Ecology Research Group, at the 1977 Public inquiry into proposed expansion of the reprocessing plant at Windscale, UK.
- Conduct of research on plasma theory ( while a PhD candidate ), as an associate staff member, Culham Laboratory, UK Atomic Energy Authority, 1969-1973.
- Service as a design engineer on coal PMts, New South Wales Electricity Commission, Sydney, Australia,1966 Publications ( selected )
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- Nuclear-Weacon-Free Zones : A Survey of Treaties and proDosals ( edited l
with David Pitt ), Croom Helm Ltd, Beckenham, UK, forthcoming.
- The Source Term Debate : A Reoort by the Union of Concerned Scientists i
( written with Steven Sholly ), January 1986, Union of Concerned Scientists, Cambridge, MA.
- ' Checks on the spread" ( a review of three books on nuclear proliferation ),
Nature.14 November 1985, pp 127-128.
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- Editing of Persoectives on Proliferation. Volume I, August 1985, published by the Proliferation Reform Project, Institute for Resource and Security Studies, Cambridge, MA.
- 'A Turning Point for the NPT ?', ADIU Reoort. Nov/Dec 1984, pp 1-4, I
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University of Sussex, Brighton, UK.
- " Energy Economics", in J Dennis (ed), The Nuclear Almanac. Addison-Wesley, Reading, MA,1984.
- "The Genesis of Nuclear Power", in J Tirman (ed), The Militarization of High Technoloav. Ballinger, Cambridge, MA,1984.
- A Second Chance : New Hamoshire's Electricity Future as a Model for the Ninj.2Q( written with Linzee Weld ), Union of Concerned Scientists, Cambridge, MA,1983.
- Safety and Waste Management Imolications of the Sizewell PWR ( prepared with the help of 6 consultants ), a report to the Town & Country Planning Association, London, UK,1983.
- Utility-Scale Electrical Storage in the USA : The Prosoects of Pumoed Hydro.
4 Comoressed Air. and Batterleji, Princeton University report PU/ CEES *120, 1981.
- The Prosoects for Wind and Wave Power in North America. Princeton University report PU/ CEES
- 117,1981.
- Hydroelectric Power in the USA : Evolving to Meet New Needs. Princeton University report PU/ CEES
- 115,1981.
- Editing and part authorship of " Potential Accidents & Their Effects", Chapter Ill of Reoort of the Gorleben International Review. Dublished in German by the Government of Lower Saxony, FRG,1979 -- Chapter Ill available in English from the Political Ecology Research Group, Oxford, UK.
- A Study of (he Consecuences to the Public of a Severe Accident at a Commercial FBR located at Kalkar. West Germany. Political Ecology Research Group report RR-1,1978.
Exoert Testimony ( selected )
- International Physicians for the Prevention of Nuclear War,6th Annual Congress, Koln, FRG,1986 : Relationships between nuclear power and the threat of nuclear war.
- Maine Land Use Regulation Commission,1985 : Cogeneration potential at facilities of Great Northern Paper Company.
- Interfaith Hearings on Nuclear issues, Toronto, Ontario,1984 : Options for Canada's nuclear trade and Canada's involvement in nuclear arms control.
- Sizewell Public inquiry, UK,1984 : Safety and radioactive waste implications of the proposed Sizewell nuclear plant.
- New Hampshire Public Utilities Commission,1983 : Electricity demand and supply options for New Hampshire.
- Atomic Safety & Licensing Board, Dockets 50-247-SP & 50-286-SP, US Nuclear Regulatory Commission,1983 : Use of filtered venting at the Indian
f i
4 Point nuclear plants.
- US National Advisory Committee on Oceans and Atmosphere,1982 :
Implications of ocean disposal of radioactive waste.
- Environmental & Energy Study Conference, US Congress,1982 : Implications of radioactive waste management.
Miscellaneous
- Australian citizen.
- Married, one child.
- Resident of USA,1979 to present; of UK, 1969-1979.
- Extensive experience of public speaking before professional and lay audiences.
- Author of numerous newspaper, newsletter, and magazine articles and book reviews.
- Has received many interviews from print and electronic media.
nunun*nm
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
'fN C In the Matter of
)
E bl 82/9J4-OL PUBLIC SERVICE COMPANY OF NEW
)
Docket No (s 5
)
g lC[ or,
(Seabrook Station, Units 1 and 2)
BRlhck'"VH:f.
y CERTIFICATE OF SERVICE I, Ca rol S.
Sneider, hereby certify that on July 2, 1986 I made service of the within documents by mailing copies thereof, postage prepaid, by first class mail, or as indicated by an asterisk by express mail, to:
Helen Hoyt, Cha i rpe rson Dr. Emmeth A.
Lu ebke
. Atomic Sa fety & Licensing Boa rd Atomic Sa fety & Licensing Board U.S. Nuclear Regulatory U.S.
Nuclear Regulatory Commission Commission East West Towers Building East West Towers Building 4350 East West Highway 4350 East West Highway Bethesda, MD 20814 Bethesda, MD 20814 Dr. Jerry Ha rbou r Sherwin E.
Tu r k, Esq.
l Atomic Sa fety & Licensing Boa rd Office of the Executive Legal l
U.S. Nuclea r Regulatory Director l
Commission U.S.
Nuclea r Regulatory Commission East West Towers Building Tenth Floor 4350 East West Highway 7735 Old Georgetown Road Bethesda, MD 20814 Bethesda, MD 20814 H. Joseph-Flynn, Esq.
Stephen E.
Merrill, Esq.
Assistant General Counsel Attorney General Of fice of General Counsel George Dana Bisbee, Esq.
Federal Emergency Management Assistant Attorney General Agency Office of the Attorney General 500 C Street, S.W.
25 Capitol Street Wa shington, DC 20472 Concord, NH 03301 1
I
Docketing and Service Pau l A.
Fritzsche, Esq.
U.S. Nuclear Regulatory Office of the Public Advocate Commission State House Station 112 Washington, DC.
20555 Au gu s ta, ME 04333 Roberta C.
Pevear Ms. Diana P. Ra nda ll State Representative 70 Collins Street Town of Hampton Falls Seabrook, NH 03874 Drinkwater Road Hampton Falls, NH 03844 Atomic Sa fety & Licensing Robert A. Ba c ku s, Esq.
Appeal Board Panel Backus, Meyer & Solomon U.S.
Nuclear Regulatory 116 Lowell Street Commission P.O. Box 516 Washington, DC 20555 Manchester, NH 03106 Atomic Sa fety & Licensing Jane Doughty Boa rd Panel Seacoast Anti-Pollution League U.S.
Nuclear Regulatory 5 Market Street Commission Portsmcuth, NH 03801 Washington, DC 20555 Paul McEachern, Esq.
J.
P.
Nadeau Matthew T.
Brock, Esq.
Board of Selectmen Shaines & McEachern 10 Central Road 25 Maplewood Avenue Rye, NH 03870 P.O.
Box 360 Portsmouth, NH 03801 Ms. Sa nd ra Ga vu t i s, Cha i rperson Mr. Ca lvin A.
Ca nney Board of Selectmen City Ma na ger RFD 1, Box 1154 City Hall Rte. 107 126 Daniel Street E.
Kingston, NH 03827 Portsmouth, NH 03801 Senator Gordon J.
Hu mph rey Mr. Angelo Machiros, Chairman U.S.
Sena t e Boa rd of Selectmen Wa shington, DC 20510 25 High Road (Attn: Tom Bu ra ck )
Newbu ry, MA 10950 Senator Gordon J.
Hu mphrey Mr. Peter J.
Ma tthews 1 Pillsbu ry. Street Mayor Concord, NH 03301 City Hall (Attn: Herb Boynton)
Newbu rypo r t, MA 01950 Mr. Dona ld E.
Chick William Lord Town Manager Board of Selectmen Town of Exeter Town Ball 10 Front Street Friend Street Exeter, NH 03833 Amesbu ry, MA 01913
Brentwood Board of Selectmen Ga ry W. Holmes, Esq.
RFD Dalton Road Holmes & Ellis Brentwood, NH 03833 47 Winnacunnet Road Hampton, NH 03841 Philip Ahrens, Esq.
Diane Curran, Esq.
Assistant Attorney General Ha rmon & Weiss Department of the Attorney Suite 430 Genera l 2001 S Street, N.W.
State House Station #6 Washington, DC 20009 Au gu sta, ME 04333 Thomas G. Dignan, Esq.
Richa rd A. Ha mpe, Esq.
R.K.
Gad III, Esq.
Hampe & McNicholas Ropes & Gray 35 Pleasant Street 225 Franklin Street Concord, NH 03301 Boston, MA 02110 Beverly Hollingworth Edwa rd A. Thomas 209 Winnacunnet Road Federal Emergency Management Hampton, NH 03842 Agency 442 J.W.
McCorma ck (POCH)
Boston, MA 02109 William Armstrong Michael Santosuosso, Chairman Civil Defense Director Board of Selectmen Town of Exeter Jewell Street, RFD 2 10 Front Street South Hampton, NH 03827 Exeter, NH 03833 Robert Ca rrigg, Chairma n Mrs. Anne E. Goodman, Chairperson Board of Selectmen Board of Selectmen Town Office 13-15 Newma rket Road Atlantic Avenue Du rham, NH 03824 North Hampton, NH 03862
~
Allen Lampert Administrative Judge Civil Defense Director Sheldon J. Wol fe, Cha i rma n Town of Brentwood Atomic Sa fety and Licensing 20 Franklin Street Boa rd Pa nel Exeter, NH 03833 U.S. Nuclea r Regulatory Commission Washington, DC 20555 Jera rd A.- Croteau,. Cons ta ble 82 Beach Road, P.O.
Box 5501 Sa lisbu ry, MA 01950 W S. h elts )
Ca rol S. Sneider Assistant Attorney General Environmental Protection Division Ju ly 2, 1986
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