ML20236N286

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Petition of Jj Forster & L Valentine for Leave to Intervene
ML20236N286
Person / Time
Site: Diablo Canyon  Pacific Gas & Electric icon.png
Issue date: 11/20/1973
From: Forster J, Valentine L
AFFILIATION NOT ASSIGNED
To:
US ATOMIC ENERGY COMMISSION (AEC)
Shared Package
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References
FOIA-87-214 NUDOCS 8708110434
Download: ML20236N286 (4)
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Office of the Secretary of the Commiss %I United States Atomic Energy Commission Washington, D.C. 20545 attn: Chief, Public Proceedings Staff '

As individuals and members of the Ecology Action Club of California Polytechnic State University, San Luis Obispo, I, John J. Forster, and I, Lonnie Valentine, hereby request full intervention rights in the licensing hearings for Diablo i l

Canyon Units 1 and 2 (herearter referred to as Diablo Canyon.)

j The Ecology Action Club has been motivated by a deep, honest, and long-standing conviction that the proposed operation of Diablo Canyon would pose grave and l

irreversible threats to the health and satety of our members and the public at large.

As early as March 1970, the club picketed the applicant's (Pacific Gas, and Electric-P,G.+E) San Luis Obispo office over the issue of power lines and rock quarrying for Diablo Canyon. Since that time, our conviction has encouraged us to sponsor three seminars on the hazards of thermal and radioactive pollution, with speakers re- 3 presenting both sides of the issue. These were in the Spring of 1970, February l of 1971 and Fall of 1971. In the Spring of 1972, we aponsored a talk by Ed Koupal i of the People's Lobby, on the hazards of nuclear power. Since then, we have l formed an extensive library at school to inform other students of the hazards of i nuclear power. Numerous nembers have written columns and letters to the editor l in many newspapers on the same subject.

As individuals equs1 to others, we fool that there is a threat to our lives and health if Diablo Canyon is allowed to operate. As citizens with the inalienable constitutional right to 14 fe, we believe that our fears should be heard by the l Atomic Energy Commissio.., (A.E.C.), and that our questions regarding the safety i of nuclear power production need to be answered.,

i We have come to perceive this threat to life from two causes. One, the A.E.C. and P.G.+E have not in the past revealed all that they know witn regard to the problems of nuclear power generation. Second, nany experts dispute the claims of the A.E.C.

and P.G.+E. in the safety of atomic energy.

There are many questions that we have which we feel warrant our full intervention to participate completely on the licensing hearings for Diablo Canyon. Our' club's interest will also be affected by the outcome of the proceedings.

We believe that the applicant has not shown: 1).. that the health and safety of the public will not be endangered with the proposed licensing and operation of Diablo Canyon,2) that the national security will not be endangered with the proposed l

licenzing e.d cperette of Mahlo Canyon, and 3) that the applicant is technically g and financially able to run the Diablo Canyon Units.

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@ " Fission energy is safe only if a number of critical devices work as tMyche"1h l

! g, if a number of people in key positions follow all their instructions, if there is

- no sabotage, no hijackin6 of the transports, if no reactor fuel processing plant M or reprocessing plant or repository anywhere in the world is situated in a region ggg of riots or guerrilla activity, and no revolution or war-even a (conventional onel

- u. o- takes place in these regions. The enormous quantities of extremely dangerous E@ material must not get into the hands of ignorant people or desperados. No acts of R$$ God can be pernitted." from Dr Hannes Alfven, Nobel Laureate in Physics, writi ,

g con.uf in NAy,1972.su11ctin of Atomic Scientists, g a

l 1 .

6 We have tuenty questions that concern us:

1) During a credible loss of coolant accident, with a failure of emergency cooling, steam or chemical explosions might occur thet could release harmful nuclidos to the atmosphere that would severly endanger the health and safety of the public in large portions of San Luis Obispo County. Mon much radioactivity l

'- would be released to the environment? Are the assurances of untested Emergency Core Cooling Systems (ECCS) reliability adequate? The ECCS may not be capable of doing the ,,ob assigned to it vith sufficient assurances to provide a clear basis for licensing. An array of design difficulties is present in the ECCS that might lead to a gross disaster in San Iuis OH mo County. Is it not true that the release of even a small fraction of~a reactor's inventory of radioactive materials could cause lethal injuries at distances up to several dozen miles from Diablo Canyon 7 i

2) The seistic question at Diablo Canyon has never been fully answered to our satisfaction. Is there new information that should reopen the question of the suitability of the Diablo Canyon location for an operating nuclear power plant?

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3) We believe the Environmental Statenent of Unitt 1 and 2 was grossly inadoquate in the follouing arect:

a) Diablo Canyon as a growth inducing factor was not properly pyrsued.

l b) The biological effects (cancor, leukemia, heart disease) of ~ 1ow-level radiation releases were inadequately developed.

c) The adverso environmental impact on the urine environment of the heated water release was inadequately studied by the applicant, as was'the question of citernate cooling methods.

d) Alterne.tive energy sources were not sufficiently studied. Nhat are the possibilities as seen by a non-biased entity?

I

4) The public is not rdoquately protected by insurance in the event of the meximum credible accident, nor is it aware of it. - To what degree are the citizens of Son Luis Obispo County covered? If the power plant were licensed and the Price -

Anderson Act was repoaled, what would be the affect on Diablo Canyon and the general public?

5) Wat is the effect of the maxinum credible accident et Diablo Canyon on San Lais Obispo County? The Brookhaven Report of 1957 and its revision in the mid o0's were internally inconsistent, which we feel neods clarifying. What are tre maximum casualty and property danage figures , created by an accident, at Diablo Canyon, and whct are the criteria for this decision? What are the consequences of a major accident? Does it involve an " area the size of Pennsylvania?"
6) Uhat are tho offsite hazards of Diablo Canyon that will directly or indirectly result from the proooced operation of Diablo Canyon? Nhat is the relation between the liconting of Diablo Canyon and increased dangers in transportation of all spent fuel? ?nat is thu effect of Diablo Canyon on already overburdened re-processing and disposed sites? On the transportation issue, can caskets be desipad to withstand an amaitian train 6Ap1031on?
7) Ye are concerned about non-accidental risks of the proposed licensing and i' ooerstion of Diablo Canyon. Would Diablo Canyon be' logical military target?

What would be the, affect of a plane crash directly at Diablo Canyon? ' There may ,

be gaps in A.E.C. socurity precautions, with many aress void of any standards.

Have all the aspects of sabotage been studied? Does Diablo Canyon pose a threat

' to national security due to potential diversions of plutonium to would-be bonb

]

1 makers? '. hat is the hazard and to what degree is it influenced by the proposed operation of Diablo Canyon? Are the safeguards sufficient to stop all international l blackmail and terrori m. activities? j

8) The storago and disoosal of radioactive wastes is an unresolved problem. Is there a feasable method for long-term containment of high level wastes? No more l radioactive wastes should be gen rated until a proven nethod for long-term

, storage exists. Is this not imposible? Is the present system already overloaded l and posing a severe health hazard to the public? 'ihy are these questions not l part of the Environmental statement? To what degree will the operation of Diablo Canyon endanger the public health in the Hanford, Washington area?

l 9) The cancer hazard amoung uranium miners is a hazard we feel should be given consideration in a complete review of the risks.

10) Low lovel radiation releases from Diablo Canyon are reported by total energy l content, rather than a proportional description from the different types of l particles. Is it true that some types of radiation exposure to man from a nuclear l power plant are completely filtered out by the atmosphere when coming from outer space? Could this pose a more serious health hazard than anticipated? Why are '

l different reported isotones not differentiated by ease of pathway to humans and the resultant health hazard?

11) If it is true that reactor manufacturers were hired to evaluate their own I products by the A.E.C. , could this conflict of interest situation produce results which covered up a serious public health and safety hazard? Is it not true that the applicant based most of its untested safety assumptions on data provided by the roactor manufacturers? Testimony before the Public Utilities Commission the Peoples Lobby vs. Southern California Edison (SCE) and San Diago Gas and Electric showed that SCE relied entirely on manufacturers claims for the safety of the reactors, and that the utility did not conduct any independent testing. Might this also be true at Diablo Canyon?
12) How nuch energy is consumed for uranium enrichment of Diablo Canyon's fuel?

Ynat fraction of the power production from Diablo Canyon would be needed to enrich its own fuel?

13) The evacuation and disaster plans for San Luis Obispo County are negligent in protecting the public health and safety in event of a disaster at the proposed Diablo Canyon Units 1 and 2. The county director of facilities services said that in September they did not have a plan for handling any emergency that might ariso at Diablo Canyon.
14) The growth curvo for electricity that justified the nued for Diablo Canyon was based on assumptions that are no longer true. The demand will cortainly not jump 33% by 1977 as predicted by the applicant. The implications of changing realities in the public's use of electricity and their sceeptance of conservation techniques drastically alters the immediate need for Diable Canyon. 'dhat efforts are being nade to avoid the need for Diablo Canyon Units 1 and 27

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15) Recent disclosures publishod in the Wall Street Journal on the reliability of reactors similar in design to Diablo Canyon have shown that the predicted reliability factors are far lower than anticipated. By how much will the cost of electricity increase with the operation of Diablo Canyon? Can reliable service ]<

be given fro: Mablo Canyon?

16) Are the radiation nonitoring devices used and proposed for use with the start  ;

up of Diablo Canyon sufficient to protect the public health and safety? We '

believe they are not, l

17) Are P.G.4. and the A.E.C. cdminally negligent for allowing the operation i of nuclear per,:er plants not consistent with the health, safety, and security of j the nation? 1 l

l

18) Was the location of transmission line routes from Diablo Canyon made without {

proper protec. ion of the esthetic environment? Did the applicant take all steps 1 l to mininize the impact of the routing and to what extent can lines be re-routed j l and redesigned? l

! j

19) In the event of an unplanned major catastrophe at Diablo Canyon, what would j be the short sad long-range effect on the economy of San Luis Obispo County?

"The nininum morality of man is to leave the gene-pool of I humanity intact." John Francis

20) Because ve feel the risks of a massive disaster intolerable, we faal that nuclear technology can never become safe enough to use in the real world. . With many unanswered questions still linr;erN, we feel the rapid proliferation of nuclear power pinnts should be stopped. No ono has ever made a case justifying any confidence whatsoever that we will achieve a high level o f containment at the power plants, ro?rocessing plants, abandoned plants, in transit, in transfer, I and in storage for conturies. This problem required fixes for carelessness,  !

error, and over-confidence in thousands and thousands of normal humn beings.

It is norally outrageous to create a radioactive legacy which will nortgage the I future for the next 50 generations in exchance for n little energy today. You l don't solvo ar. energy problem by croating a radiation problem. What gives anyone the ri ht 6 to build and operate nuclear power plants?

All of those cints (and many others ue are not aware of) must ba fully discussed and cnswered before the public prior to any consideration of licensing Diablo Canyon Units : and 2.. We believe that the public health and safety in San Luis Obispo Count; and the rest of the country will be jeopardized if we are not permitted full intervention.

Sincerely,

~ 9 -

Q*? l 17 / ATA John '. Forster

_ Lonnie ppt /Valentine 7 6 sww %f p',

cc: Chief Henring Cotmeil Philip A. Crane, Jr.

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