ML19326B123

Coalition for Safe Nuclear Power Amended Petition for Leave to Intervene in Proceedings.Applicants' Requests for CP Should Be Denied

ML19326B123
Person / Time
Site:	Davis Besse
Issue date:	12/05/1970
From:	Stebbins E COALITION FOR SAFE NUCLEAR POWER
To:	US ATOMIC ENERGY COMMISSION (AEC)
References
NUDOCS 8003060926
Download: ML19326B123 (39)

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IINITED STATES T AletICA AN3EC EMERSY COMEISSION ,

In the matter of j; - F o I

TOLEDO EDIB M CO. and -

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ILIIBtINATIE) CO, V /

(Davis-Desse Nuclear 1 Pbwer Station )

AMENIED PETITION FCE INTERYENTION 1

i The Coalition for Safe Nuclear Power, on its otan behalf ami on

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behs1f of its membem, supporting individuals and organisations, others similsrly situsted, and the public, hemby petitions the Atomic Energy l

Cosmaission for ler.ve to intervene in this matter, pursuant to the Coamais-sion's Regulations, amt in particular,10 CTR Sec. 2 71%.

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THIS DOCUMENT CONTAINS POOR QUALITY PAGES l

t A. Identification of Petitioast.

PWtittomer is a ase-profit asseetation of persons, corporations,

, groups and associations formed partially for the purpass of this interves.

tion aat consisting of, among others, the following:

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, 1. Citineas for Clean Air and Water, Ime.

l an environmental group of appWmately 3K)0 citimens in i the Greater Cleveland Area.

l l 2. United Auto Workers, Cleveland Region l s labor organisation representing 501 seals and appreatmately  !

l 55,000 members. l l

3 Area Commeils Asseoiation l a group of ammerous neighisorhood aseceistions in the Greater l Cleveland Area representing appresetmately 20,000 meshers.  !

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k. Chio Division of the Issae Walten Imagne of Ameries, Ime.

l 5 Censumers Imagne of Chio i l

representing 250 members aan orgaminations.  !

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6. Southoest Action Greap en Entirenaeat (SAGE) i

! a sitiseas' organisation in Beres, Chio. l T. Living In a Finer Enrireemanat (LIFE)  ! i an organimation of stedents at Beeling Green University. l

8. Campaign Against Violesee to the Enviroammat (CAYE) an organisatiam of stuemats aat faemity at Bowling Green i University.

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" I 9 Projeet Survival i

il an organisation of stuesats st Case Western Reserve University

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+ 10. Comarittee opposed to the Pollution of an Eavirwament (COPE) {

j sa organisation of stadsats at Cleveland State University. I i 1

! 11. lake County Citizens Organisaties for Clean Air

! Ldte Comaty, Chie, DhSM p

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12. Citineas Opposed to pin 11stica Fairport Earbor, Otis. ,

! 13 Citimene for a Saes Envireausst i Mester, Olds.

f 14 Devia Ottles, ED.

Borsa, Okie.

15 Irwin I. Ceter, PLD.

Professor of Biology a:s1 Ra'liation Geneties, Bowling Green IIninreity, Ohio.  ;

36. Mrs. Malma D. MeCue, Mother, heapevife and Chairvanan of Nethere Marsh on Flollution North 01asteed, Ohio.

17 Mrs. Iiarro tama, coottinator of the Amada=4o Caume11 en Eurireusental Froblems, i Shaker Heights, Ohio.

18. Eugene Y. Perrin, LD.

Shaker Heights, Ohio.

I 19 Psal Olynyk, Ph.D. I i Professor of Chemistry i Clevelani State IIaiversity, f 20. Sammel Grosa, E D.

! Sheber Heights, Ohio.

21. Amasa 3. Ford, ED.

Chagria Falls, Chio.

22. Rev. Earl E. Cm aingham, Ph.D.

, claveland, Gaio.

l 23 George Kendts, i

1 Chegria Falls, Ohio.

In addities, Petittaaer includes among its membeschip persons who reside, own prwyerty, veut, do business, pay twees, orgage in recreation, in, or l visit, the Imke Erie Area, in the immediate viainity of or within a radius of D [j l D l

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i d vh . . JL __J 150 miles to the proposed Davis-Besee Amelaar PWeer Staties. Meer of

Petitioner's membership are eastaaere, aat same may be steekholders, of the applienst utilities. Petitiessr's anuberekip also imelades er any in the l

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fatan teeliste engeaisations repressattug eenservation, setentifie, needemie, ,

i sportenem's, fiskenusa's, reenettamal, civio and envireemental interests, with a tetel meshership of themsends of people. Batitioner mise asserts hemia the interests of all other persons similarly sitimated and of the  !

puR11e in general. 1 l

B. Special Interests of Petitisaar.

L? The member lativiemmia sad organizations of 7tetitieser have by l their poet activities and sentaet anhibited ame wee assert a special interest la the preteeties of the antaral researses of

' i the Lake Eria Area aat in the eenservattomai, roerestismal,  !

eseumde, asethette sat ======i47 igast of amalaar poser plant l

4eTelapseat in the Lake Erie Area ame are first amt f ressost 3 eenserand that such maalear poser plaats est be built er l

l eperated obere te de se weals be taisieal to the health aan

mafety of the publie.

2.

Petitlemer, its members and the publie have a peroomal righk to live in and enjoy an enrimassat free from taprovitent destreetica, pollatica, or unaseessaly radiation, aan they have a right to the eenership, use and enjoyanat of property free from unaseessary tavasion or impeizusat.

3 All anabore of the Coalition are interested in the dissemination (

of informaties and stimulation af public asereness aat involve-meat in the study of maalear pseer. Proceeding from this 4.

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a e .we.al sa.e, ims petiues.r 1., suo ,u e. an es itte, to povest the unsafe and unbridled use of amelaar pesar particularly when seek use aoes met result front the mest efficient seeemedaties between all available power sonroes ame ran and his enriroussat. This petiticaer has analvsed sat statied, to the estent inferinttion has been made availab3e, the proposed Davie-Desse Plaat, sad is oemeermed, as set forth in more specifie detail below, tht the oomstrinetion saa operation of the plant will twsuit in an unsafe ans ineffistent emoreise of the use of stasie energy, will erente talatorious sad adrersa effects whiah eaa be avoided, and will result is irretrievable and irreverstkle eamoitanats of natural and other zesources wMeh, ocasidering all of the alternatives and sirouestanzoos, imeladig the alleged need for e3 metrical power, weale not be eerantageous.

l 4. In addittom to its edmontional and other goals and interests i

esseribed abere, the Coalition is ooneerso4 aot only with j meelear eat radiological safety but also about the siting of I

a analear power plaat in a miaaner which is sontrary te zessen, legie, the eriteria presalgated by the Atemia Energy Casamf.saton ami the stenaards of the National Ravironmental Policy Aet.

5. The osalition's intereste vill be advernly affected by the issennes of a enestreetien perstit for the R ris-Besse Plant as well as the sonstrusties of the Lvposed Plant because, ss

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i l more fally set forth below, the oomstmation of the Davis-Besse Plant will proliferate nuolear power, with all its consegssat .

and attendant dangers, at a time when insufficient infomation ,

is avsilable to atteet to the es@lete safety of the operation

. O of s uselaar pseer plant. This lack of information, essestial27 ignored by utilities sad the Atomie Energy Ccumission, ami t

resulting in a position act necessarily in the public interest orj

eessistaat with the preteettom of the publie he6lth and safety, also eenserne the Coalition in that nasimar pesar is being it premeted paremmat to ineffielent aat mos.eurrent safety amt i i

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engineering data, outdated, narrow, isomeplete sne ineaegrate '

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samadarts and eriterie ooneersing radiation zwisases, and a -

1 significant if not totsi lack of understanding as4 seMstica l

to asa and his emi mament, ,

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! 6. The Coalition is fiarther eeseerned, as more spesifically set forth below, that the lih styles, oceupations, sat investments,

! both emoticasi and fissacisl of s11 moabers of the Coelition I

j will be threatened by the asestruation sne operaties of the p syc: d plaatsst Port Clinton.

7. In addition to the Coalition's oeneers over the growth and develogment of the cosasais and business eoemaities of the ,

I greater metropolitsa Toledo, Port Clinton, Cleveland area, i

the members sf the Cealities are also osacerned beesume they

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i  ! live seegraphically elese enough to the ymposed Davis.Besee 1

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i Plant to be sericasly and adversely affected by the radiometive sad gasecas affluents whiek are planned to be emitted from the ,

- Boris-Besse Plant during its mersal operation. The Coalition is therefore semanrued about the possibility er probability of hers and aanger to its members as a result of not only unsafe  !

l operation of the Proposed Plant bat the normal operation of the l

F. .; ::: Plant as ytesently defined.

8. The Coalitica is ecaeerned that the lifestyles of its members, I

in a oemplicated mas self-oontained metropolitan area, will be i i

trasties11y changed, adversely, as a result of the Proposed ,

P3aat at the proposed site, without such citizens having s j voice in the resolution of the sentroversy.

9 The Coalition members are consumers of food aat agricultural l

prodnets and rely to a large extent upon the natural ressurses, -

1312 as soarees of drinking water, which lie within the geographie area which would be adversely affected iry efflaants from the L;rri Flaat.

10. Many of the organisational members of the Coalition are affiliated with national badies, each having many skaptere er mits, with meahors residing in states other than Chio, whose health sat life styles will or esaid be adversely affected. These persons will be affected not only by the consequences of wasafe operaties of the Davis-Besse Flant, but also by the feiet that voetes and efflamata generated by and esitted from the Pii,;:ni 1

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Plant are to be traamuitted and skipped from the Davis-Besse Plant to other parts of the country. Monever, in normal opers  ;

tion of the plaat, such vastes and effinents will also be emitted generslly into the eonaystem; and, by virtue of the forces of nature, such vastes will be transmitted to all parts of the comatry directly and indirectly thrwegh products of all kiats which are predaeed in whole or la part in the Tolode, Port Clinton, Cleveland area.

11. The Coalition is Siso concerned with the ecutinuation of quality fishing, swiaating, boating sad other aqustie usage of Iake Erie, sne the effect thereon of radiological sad thermal wastes and other effluents from the Pmg::t Plant.

12. Ptetitieser is concerned with the preservetion and restorstion of envirnamental quality in the State of mio and elsewhere, and in order to proteet the interests of its members sad orgsaisstion members, wishes to assert these interests with respect to muelear safety, radiological protection and the many brosd environmental questions which must be considered and resolved under legisistion such as the National Envirnesental Policy Act. All of its members' interests, both finaasial anct non-fiasacial, will be adversely affected by issuanae of a comstruction permit and/or the eenstruction of the Proposed l Plant.

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i 13 Among the members of the Coalittom are students ensing from all parts of the State of (Stio es well as surrounding states. Maar I

of these stuesats intend to make their hans and pufossional lifei a

in the State of CRaio nas other states which are, beoense of the '

movement of wind, water and other natural ressurees, in the area of poteuttal effect fremt the pW Davis-Sesse Plant. 1 These students have an interest ta social justice and law and order thmugh established systees. Because of some of the f

national positions taken by the Atomic Energy Castisaien and publie utilities, with aspect to state and local enrimamental 1 enactments as well as the Natiemel Envirammestal Policy Aet, thsbe students wish to aseenstrate to the people of the United 8tates and Ohio, particularly the young activist osmosmity, that enriremmental protection eam be achieved through established adutaistrative and legal channels. Aeeordingly, sneh students, l thmugh asabership in the Coalition seek to intervene to make it , i

, l plaim that large ft mand al or ingrained goverusent interests any met violate any law without being called to sesomat.

14. Besed upon the interests and eoneerns of the various of the organisations and individasis identified herein, one or more of the direct interests of each of thout will be adversely affneted by the issunnes of a construction permit in '

Doeket No. 50-8M. These interests and how they may be sffected i

, 1 are as set forth in specifie detail above.

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C. Metual Intereste with Pbwer Companime.

f The applicaat peser onepanies, in recognition of their obligation te meet the increasias dements for electrie poser in the lake Erie Area have earefully planned the Davis-Essee Nualear Power Staties over an entended period of time. htitiener moognises that their plasming was amoessarily guided by the then kasus safety standants and that te date them has been no sortees geesties raised as to the willingness of these two power sesqpesies to ;

aset such standards. Essever, during the Imagthy planning period required sat taken by these power ocupamies, additional seientifie lavestigatiJa and inquiry has raised serious mad legitimate eh.11 mages te the safety staatsrds i l ased in the plamains of the papened facility aal under whiah it is to be '

eeastnasted amt operated. Petitioner centends that suah standevis will not 1 4

l contimes for lang to be assertable particularly for a plant to be leested so )

close te and between dense 27 populated urban areas. It is themfore in the best interests of the power acapanies, as well as the general pehlie sened  ;

by them, ht the eoastruation penait be esated at least until such time as i safety stand =4 een be established and built into the plans for this power staties ht are clearly adequate to stand the test of the extended period af l 1

time tuvelved in the useful life of such a faeilit;y.

It seems obvices ht a substantial delay in the acastrastion of r8 this an.1 mar pesar staties will upset the long range planning timetable of these two power eenpesies to supply their austeners with power. This may very will result in people having 3mes elsetris power thma a perfectly convenient 4

l style of life would require. Dat this is far better than permitting h t

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sometruction of a power statise which esaid a,abstantially ecatribute to the destruction of the environment.

This wry difficult choice may well be between short range trouble with air conditioners in periods of peak power demands or long range damage to the environment forcing us to live in shelters with air conditioned comfort, as the caly way to be aosfortsble at all.

With the sometimes conflieting demands of the public for power and safety, this situstien requires governmental action by this Commissior to make the necessary seeceodstion between these demands; the safoty of the public including the preservation of a healthful environment is necessarily the perusount consideration.

D. The Public Interest Will Be Served by Betitioner's Interrention in the Proceeding.

Great consera regsrding the advent of nuclear poser in the Lake Erie Azem has been votood in the ama's newspapers. For example, the Cleveland Plain Dealer has published a series of articles written by William D. McCann reporting the vide publie concern over the safety of the proposed facility. The Cleveland Press, in articles written by Betty Klarie, has eencientiously reported on the health, and safety implications of the proposed facility. The Sun nevepapers have likewise reported the greving i

concern over the dangers of the proposed facility, l The soneern of these major newspapers regarding the proposed fscility is part of a general rising national concern over radiation hazards, rdistion protection standards, sad the thermal pollution esused by nuclear poser plants.

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l The pahlie senseiossasas in Gnie and threagh et the United States over geostions of envireimusatal quality hes, in reeamt months, been heightened .

D W enactment of h Eatiomal navironmental Policy Act of 1969, m l

risias tide of publie.comeera over the tapaat of anelaar power plaats em the envirosseat isas manifested in the hearings before the Joint Casuotttee om i l

Atesis Energy, 91st Congrses,1st Session, ca " Environmental Effects of l Proeseing Electrie Pouer, Part 1", whteh were held on detober 28, 29, 30  !

and 31; November 4, 5, 6, mas 7,1969. Part 2 of these hearings resumed La 1 970.

l In m pues nleese, No. 684, teamed on Deeensber 22,1969, by the office of the Joint Camuittee en Atomie Raergy, Chairana Belifield stated that the publie hearings during the week of Jammary 26,19TO were a esatimestica of the Joint Constittee's sta4y of the envireamental effects resulting from the siting aan operstion of analsar, hydrolegical and fossil fteeled elastrie power plaats, and ht the final record whiek would result from these hearings .

will oeastitute an up-to-date ocupeaAites of all effinents from elsetrie power plaats.

The paryeee af the publie hearing on the instaat appliention is to determine whether or not the sonstruction aat operattee of tbn proposed famility will emuse undne rick to the publie health and safety or danese to the entireement or bisobbere.

l Petitioner's intervention and participation will aid this determina- 1 tion by asking the proceeding on the applicatica an aitversary preeeeding in whtek the applicants' evidense aos the regulatory staff's position saa be l 22

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E tested by crose-eamination, and in which intependent evidence and legal argument can be presented by the intervenor on the factual and legal issues.

The granting of fall intervener status in a contested proceeding  ?

will enable the Petitioner to artienlate the public interest and concern over 'i issues relating to health, safety sad the envirement, and will create a forua ia which members of the scientifie -1ty (with viees eontrsry to these of the applie' ant or regulatory stsff) may be brought into the proceedingf ll to testify as expert vitaneses on the isenes which must be tested by It is in the publie interest that there be in this proceeding a j fall airing ami presentation of the latest scientifie data, findings and '!

i eenalacions regarding the subMt matter of the proceeding, mas that the Commisoton seek out all evidense bearing on the issues sad call as its ora i

setentifie witnesses even those whose views may be oppeeed to the findings of the staff and the seientists zwlied upon by appliaant.

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2 PRFITICERR'S tXEFTEIRION J

A. General Enrironments1 Effects.

The Petitioner eentends that the total entireamental impact of the '

proposed fseility will be estrimeatd to its and the publie's interest and i

to the Iake Erie Ares.  ;

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15. Petitioners are coneerned that there is presently insufficient )

knoeledge or experiense with pressurised boiling vster nuclear '

remeters of the size sat type of the ympeeed Davis-Besse Plant to justify suything otbar than the moet consenstive Spyro*eh to the siting of such reactor. A consonative, prudent tyymeh to the siting of such reaetor would dictate

,. l thet it be built in an isolsted srea, sway free concentr$ted population sad underground, in order to inseen the risks to the health sad safety of the publie until such time as remeters of this oise have saised prwen operating reliability sad many years of safe operation. In view of the lack of such experte.. lee, petitioners contend that the sittag of this resetor st the ymposed leeation constitutes a 4 sager to the people of the surrounding -1t$es and represents a serious brweek of the Atamie Energy Cammission's are guidelines on the sittag of i

l 1erre uselear reestors.

16. The analysis by the Applienat sad the Atomie Energy Commission Bagulatory Staff of the mrtamm Mypothetical Aceident (" MEA")

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that can be assumed to oceur for the Dsvis-Besse resetor is ,

't immesquate sad insufflaient in at least the following nepects:

(a) The M set forth in the Davis-Besse Preliminary Saftty i

Andysis Report (*PSAR") assumes thst the emergency core ecoling l system is of a size sud capscity sufficient to pzwvent sn uncontrol1# moltAavn of the majority of the nuclear feel; '

petiticaer eontends thst there is no such masena11e assuranes that the emergency more ecoling system can function as quickly ,

I as necessuy or with the reliability that is amoanded if smeh i

meltAown is to be avoidea. l (b) The MEA set forth in the Davis-Besee PBAR 4ees not even approseh the true maximus hypothetical aseident that can be assumed for one of these remeters; nessely, a meltdeva of the estime fuel oore, with subsequent bmaching of the containment dies te genetraties of the molted fuel and subsequent interneties.. v with groum4 mater, rolessing radioactivity in quantities many ereers of magnitude above the releases set forth in the PSAR.

(e) The NBA set forth in the Davis-Desee PSAR fails to conster.y the generation of large quantities of hydrogen gas within the oestehmaat after a less-of-eoolant accident, and means for 1

sveitanes of a submetesat aury1meion thaw would rupture tb eestainment and release large quantities of rsaionativity tuto the eurimament la sn uncontrolled mawer.

(4) The M set forth in the Davis-Beese PStal f ails to take into

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, eensi4eraties the synergistie, and neunter-paduative effects l

l of various systems used to aostrol the relsams of iodias, and ,

petitieser contende that there is no assurance that todias 1svels.

• t een be reduced to meet the requirements of 10 C.F.R. 100. O c

17. The compoetats anA engineering of safe 6sards of the Davis-Besse Flaat will be exposed to zwiiation that vill lead to deteriora- I ties of theee sempeaants, and there is no assuranes that the  ;

, integrity of thsee campensats or their systems will be asistained, our the espected life of the Ihposed Plant. htitioner '

toestions whether Appliesat hw provided adequate procedures for ;

'I taspection aan replsoement of these critieel oempements. (

18. htitioner questione whether the quality eentrol and quality assunaee procedures e.nd programs described in the PBAR are adequate, semplete ud neceptable to assam that the Davis- 1 Desse Plant will be built in confotssmee with the design as set forth in the PSAR, thus ==111ag into question whether the Plant I

can meet eriteria that assure the health and saftty of the public.

19 Petitioner geestions whether usergency plans and procedures havei been adequately developed or coneeived either with respect to an ,

aceident which would require immediate evaematica of the entire tous of Port Clinton or with respect to evaematica of population azess other than hrt Clintou and contained within the greater metropalitan Talede to Cleveland area. In light of the availability of sophistiested undieel treataeat with respeet to ndiation

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't injuries, pottener trasettees whether Applicant has made adequate,

[ pavistees for either familitise or personnel to tnet restation injuries or radiation-ehemical injuries which would result from a vet- hypothetical aseident er any other lesser seeident. I

20. The ocearrease of an aseident or tt' tharge of radiesetive effluente and heat lato L4e Erie, met ,y strenene, underground h i

water tule, and the atmosphen, during the operation of the facility, would endsager the health, safety, lins sad property of the peblie who reside, work, visit or engge in normatiemal i motivities in the vicinity of, or ans affneted by the fseility... l 21.

In view of the pnvailing physical eharneteristies of the site, ;

e imelading provsiling meteorological and hydrological eoaditions l

in the area, the operaties of the proposed facility by itself, .!

or in ausbination with other power facilities in the Lake Erie l u

Area presently in operation, under cometruction, or plassed, may emete extensive fog and inversions and other stusoepherie and enginemental conditions hasardous to the enoramas atenber of aircraft 1 shish overfly the area, fly a bolding pattera, take eff, or land, in its various sirporte, sad detrimental to the health, safety and activities of the publie, instuding Petitioner's members. Another eoasequence of inversions and fogging would be the spreading out, over a large ans, of any

radiometive gases Mleased free the Davis-Besse facility, tauber normal and abaarmal oyention. '

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In view of the pwestling litters 1 drift, the proposed pmjeet  ;

i vill eense se14ous erseien of the L*e Erie shoreline and dasseee .!

to shorefront pmporty comed by Platitioner's modore ama other meWhen of the publie.

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23. Petitioner is seneerned about the techstesi qualifiestions of .'

Ayy11esnt Clevelsme Electrie Ill=4 mating Company. i 24.

e.E.I. hse had no esportenee at all with roepeet to the design, }

eonstnetion and oper-tion of auelesr poser plaats of the size l d

eat type of Dwis-Desse.

25. C.E.I. his hsd a recent history of being unable adequstely to l

hsadle eosi anst ma fly ash emissions et its Avon I.4e, Ohio  ;-

genersting pisats. Records of hearings before the F1snaing k f

Cemeission of Avon Iake, Ohio, eentsin many statements and ( ,

1 eamisotons by its emeoutives and assagement indienting that human error enA misoalaulation on the part of its empimyees hwe

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been the eense of coal duet and fly ash fall out in the Avon Imke'l 9

area.

In light of C.E.I. 's performance at its Avon Iake Flaat, j 1

Petitioner is commersed that if C.E.I. slices similar buena errerj;l l h

and misenlaulaties to eeeur during its operation af Darts.Besee ij Plant, the effteets upon the assbers of the Coalition ami all h 0

noidents c/ the area eeu14 be estastmphie. j F,

Standards For Protection Aasiast Radiation. .

26 Tks 8tenoorde For Proteetion Assinet heistion eurrently in foree, 10 C.F.R. Part 20, are inadequate,111egs1 and in contravention of the Atemte Energy Aet. I L Aoeordingly, any radioactive emissions I.

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to be diseberged in any fbre frem hvis-Besee e.re different I j th a whmt von 24 be persiasible by virtue of valid radidion s

stsatsrds presalgsted pursuet to the obligations of the l

t Atoute Energy Commisstem unter the Atomie Baergy Aet. A i:.

27 Seme of the laborest enfietemales which neult in the rseidies staatards betag 111sgu sp $ t (s) The Stantante do met talte into seeetat rseistion deses J vhid the pelle any reetin from seuroes other than a particular licensee of the Commission aan with respeet to this Applinest, f i-ne prese4are has been follouet or proposed te abate the j 111es=11ty of the Staatarte; i

, (b) The 8tmattres de not stegantely talte into seeeunt h q l seeWatices of emissions of rstiometivity which sty be  :

present w a wealt of eettiused emissieme of radiesetivity with respect to a licensee aan with nepest to this Appliesnt, me pneedam he been fellesed or proposed to abste the illegality of the Standants; l (e) The 8tentsrds de met mengastely yme14e fler 41ti'ereases in tolerstiam of n!tisties la different hema beings in giwa f differing leemtices sad with roepeet to this Applienat, no presseure he been fellseed or ymposed to abate the illegslity of the Standards; aan (4) The Standants de met nWately pngreide for a trueing of emissises of retteeetivity through all paths ys by which such t

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retteestivity may to trasmositted to the population in a given ases, as well as disk may be tramanitted to each pathway in the esseyeten la a given geographical area and with respect to this Applicant, no preeedure has been felleged er proposed to abate the 113mgality of the Standa24s.

28. The Standards for Protectix Against ReAiation are based upon ,

outmoded, outdated setentifie information, most of which is more than fifteen years old. Despite the fast that the Atonia Energy Ccausisaica has in recent years been provedad with updated information concernias radiation danger, including laeressing projeetions of genette diseases, and despite the feet that in 1969 the Secretary of the Department of Health, Eemaatien and Welfaxe callse upon the Atomia Energy Ceessission to revise and revise its radiation standards, the Commission has met seen fit to de so and instead is coatinuing to license and attempt to 31eense plants based upoa 113mgal standards.

29 Assuming the 3egality of the radiation standards, petitietsrs e oestead that it is illagal to issue a construction permit locking teuard operation of Davis-Besse which would permit the Davis-Besse Plant the option of operating at 100 percent of the eartent radiaties standards when all of the projeetions, as sell as publie statements, made by Applicants attempt to C.aov that the Flant's operation will not exceed more than approxi-ante 37 5 pereent of tbs radiation standards.

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30. The Appliesst has not analysed nor eoesidend what desiga changes it may have to make if prior to ocarpleties of onestmatism of the Propeeed Plant the radiation standards are declared 111agal er an weised and App 11 east amet revise deumward its projoeted liquid and gaseous radiomative emissions to as mesh as sere. Moreover, Applicant has asither considered aor analysed libat changes it would make in the Proposed Plaat, if sometrueted, and thematter the radiaties standards were revised er emelaxed illegal se that Applicant would not be l i

1**=11y permitted to disahasse any radiometivity in any form j free time propeeed Plaat.

31. Considerlag the state of the art and the inherent dangers  ;

roeulting frem any radiomettre releases, petitioners ecutead I that Applisaart is required, tender the Atemia Raergy Aet, to destga a plant whiah conteins a radiometive waste system idtiek prevente any radioattivity in a v forst from being esitted into the environment.

it. Ayett ent bss reither esmet&tMd er neg1 Fa4 thn affects on sw y.464,.* *.44 u . . =* .. 6., 4 A w e, ... ,

pertad frem the plaat site to varioca parts of tia

• uattea States in the event that such osaurwaees as aseidents or labor strikes prevent the aerural operation of such transpor.

tation es soutemplated in the propeeed transportation pro-eedure. '

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33 The Proposed F2aat is designed to emit radiation whieh would l exeoed ==mbm== permisoihle eencontration levels in the surrent i

radiation standards, even if legal, if one oomsidars the recon. ,

esatretion feeter of certain radienuelides, such es, for example,,

Costium-137 of Streatium-90. No prodedures by the Appliesnt have been imulertaken to account for and abate this ret oneestratica pheamosan regarding many of the radicanelides to be emitted from the L g r:0 Flaat in normal cperation.

34. Beither the Applicant nor apparently the Atomie Energy Commission raAtation stamaards take into Account Aangerous illneseos or injuries, if any, which will oeeny fra radiosative ,

i effluents reachtag man and casinglet in whols or in part with .

ehemical effluents.

1

35. Petitioner geostions whether the design of Applicaat's radiaties amaitorir.g system is sufficient and ecstplate ,

adequately te monitor radiation both in normal operation of the Proposed Plant as es11 as during those moments after a

==w9m== hypothetical accident or as a result of sabotage.

D. Eartremesatal Considerations.

36. The petitiseer easteads ht the ocastruction and operatica of the peepened Davie.Besse Buelear Power Station will be iniminal to the health and safety of the publie, au that the ,

propeeed facility empt be constructed and opersted at such leenties without undue rish to the twalth and safety of the

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ii t publie for.the following reasons:

(a) Penlaties Density of Site Area.

The proposed facilitte is located asar the dense popula- l tien souters of Detroit, Talada, Sandusky and Cimvetena ar.d '

esplasive population growth is antielpated for the Iaka Erie i

Amt.

If as accident oceurred at the proposed analear plant i appropriate and effnetive arrnageneste sould r,et be ande to 1 l

oestrel traffte os the higkveys and railreeds to protest the publie haalah and safety and to permit ready removal and i 1

evaamaties of people by laat, sea, or air, free the project  !

1 a2Wa and asarby peptlatten staters.

i Furthermose, tbs transportaties cf radiomative vastaa i

from the proposed facility to their ultimate burial ground would aseessitate paseias through the highly esegested  !

transportation network aat pepulation centers and would present a hasard to Pablie kalth and safety; and in the >

transportation of seek wastee by water, any aseident ven1A be esteetzepkie to the 1 paters of lake Erie and to the people of the Iake's bordering territeries, the States of Chio, ,

New Tosk, Phansylvania and MLehigan and the Dominica of Canada.

(b) Costia1ases Beatricted Azwes.

petitioner eestents that the preur1=1ty of the proposed N* ,

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facility to restriated areas used for ordnamoe testing and airerart training missions constitutes a unique sad critical hasard to the remeter ana in that the suelmar reactor is esposed to the danger of airenft ersehes and to the hszard of being shelled by ordannes testing. Use of the contiguous astrieted areas is deterstaed by a large number of appsrste egencies imelading the Lepsrtament of Defense, the Navy, the Air Foree, the Army Corps of Engineers, the Federal Aeronauties.

Administration, stste sad local bodies and at least one privste corporation, TRV, which is testing ordasace under s Defense Department Contract. The ordnaaet being tested includes artillery piereias shells tested over Iake Erie which any be espeble of penetration of 26 inches of reinforced comerete. The boundries of the restricted areas are in dispute and the restricted area proposed by the Corps of Engineers actually inelades the reactor site itself.

(e) Biological Effects of Ionizing Radiation and Radiological Hazards to the Publie .

Present information about the ndionuclides produced in nuelear power plaats sad disehrged into the biosphors is insuffisiest to justify the risks attending the construction and operstion of the proposed fneility.

Applienata hsve not demonstr=ted thnt no biologie31 dannge to say of the population of the I.de 3rie Aras vill 3k. ,

. 1 b

s result from the radiation emitted by the proposed plant. ,

Applicante hwve failed to show that the radiation dose levels pensitted by 10 CFR 20 are reasonable sad safe as l l

applied to the Iake Erie Area and that the benefits to the lake Erie Area frem the proposed facility justify the risk i

of bielsgical damage eensed by radiation to be emitted  ;

therefrem, or that there vill be any benefits that cannot be het without such risk, by other means.  :

The Petitioner eesteads thatt

()) The results of seiestifie reseank demonstrate a dese-effect nlatieeship between radiation aan sanser or 1mukemia indastion la man, and that nopest61e seientifie and medieal authorities reeamenad a redmetion in the Federal .

Radiaties Council guieelines for radiattom exposun to the population at large; I

(M The radiation protection standards puseribed by 10 CFR 20 vill pensit the Davis-Desse plant to empose the pehlia to tangeroam levolm et radiation which could sesse a 10 pereomt imenase in birth defects, a 10 percent increase in saneer and leukeata, and a general inersase in asay mQor diseases i==1= Mas eartieresoular disease, schizophrenia and end other genetically related diseases as well as metabolie i

diseases such as diabetes. In addition to the foregoing, the propeeed plant will be pensitted to expose the workers in said

-es- l 1

I plant to Invuls of rsdistion 1.0 ti:scs and in scus essea 50 tL -a the levels pornitted for the sane: al public. As a d

consequence, the medical risks to the vorkoris vill be

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increased proportionstely over thoso riska born by the genersi publie.

(4) Radiological, Theras1, 2:hi Other Effsets on Fish and Wildlife .

Pursumat to Public It.v 91-193, 91st Catarus S. 1075, Jammary 1,1970 (The National Environ = ental Policy Act of 1969), the ABC has Jurisdiction of, and 10 und2r a statutcry mandate to considor, any adverte envircnarantal offects, imeluding thermal dischan;o, which rny r3sult fres s proposed amelear power pisnt.

i Petitioner's a2tbora uca Lce Erio in the vicinity of, or in areas affected by, ti:o proposed facility, for boatirs, fishing, hanting, bsthirg, c,nd other reematicani purposas.

Lake Erie cupports import:nt eenercial and cporc' fiaberies sad extensive waterfovl naa. Fishin , vaterfowl use and hunting occur in the general area of the project.

The Petitioner is concerand with tha pmscriation of tha ecology of Lake Iris, its maritus and plant life, their aquatie habitat aat supporting eco. systems, and in preserrir.g the asefalaess of the marine envirocaent of laie Erie for roersetiemal and other beneficial purposes.

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l 99 a.

The effect of sewage discharge y nduces a significant ineresse in the astrient content of the waters of Iake Erie.

The propesed facility will pour billisas of gallons of heated water into Imke Erie, thus areating a heat dump. This vill speed up its outrophiestion, ervate synergistie action l os ahoorption of radionaalides, destroy it as a suitable i

habitat for its auczestional and easaartial fisheries, and ta general chegge its entire ecology.

The Petitioner sentends that the disek ,e of radio-motive effleemts and heat into Lake Erie and the atmosphere in the eyerstion of the proposed facility may adversely affect marine and plant life in the Iake Erie Area and detract from the reeresticatl utilisation of the area; that the effects of the proposed project on the 1 meal ecology have not yet been suffisient3y studied and determined; that the necessary enviremanatal vaalitative sad aptantitative studiac cf botton biota, plankton ernstaces, fish, temperature, botten eenrposi-ties and water ehmaistry have not yet been made in suffieient depth; that it is not possible at this time to detezzine what envirosse'stal radioactivity would zosalt frcus the operation of the proposed facility.

The Petittener also believes that the radio-sensitivity of fish and wildlife organisms is poorly unde 2 stood; that there is laea of kapeledge as to the effect of the process

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i whereby maietsetopes of msay elements became coneentrated and stored by organians thst substitute these for ehemiselly similar elements for their netual metabolio setivities, and that trsasfers of radio @ des frem one organism to another through the foM shain may result in radiation hasards to fish and wildlife and the food and organisms on which ttsey depend.

Aseerdingly, the Petitioner believes that it is not possible at this time to determine whether the design of  ;

eenstnetion of the proposed facility would safeguard fish end wildlife emanians sad aquatie biota frias undne strsia of rsdistion exposure, et that it is not possible to determine whether the metabolie sativities of the important fish and wildlife twoourees in the project szwa vill not be adversely affected 1ry the weste elements coatsined in the effluent from the proposed plant, or whether concentration of radioactivity hsrsurul to fish ed wildlife is oeesrring.

14titioner believes the spplicants have not demonstrated that the p._, rt facility enn ocaply with the appliesble federal and stete vster quality stsnaards criteria governing thersel disehange sad pollution contml acts, and have act l l

shoes that the discharge from the plaat, either alone or in ceshinaties with other substenees or wastes, will not be l

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in,)mrimas to fisklife and squatic biota or impair the waters

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for any other best usage.

Petitioner believes that s eonstructica pemit shaaI4 act ,

be isoned to the app 11eamte because of the possible adverse effects of thems1 dischkurges sad other potential hasards to fish sat wildlife, wramtie biote, their habitat and supporting eeo-systems. The diseharge of large volumes of heated water '

into Iake Erie not only may be dstrimental to fish directly, i but slao say tffect these resources indirectly through i

ecologiesl ch3nges, psrticularly on the food organisms on which the fish depend.

I The cooling water intake poses a potential hazard to l fish resources sad, in particular, to significant numbers of fish and ===11 squatie erustseeans, which azw basic food items.

Fish eggs, larvae ani ether planktoa are killed in their passage threugh the plant. Such destruction euts down the food supply for larger fish.

l (e) The Risks to the Publie Health and Estety Far Outweigh the Benefits .

Phtitioner contends that the benefits claimed for nuelaar power have not been realized; that reliability of larger 1

reactors has still to be demonstrated; that costs far eseeed I estinstes; that no amelaar power station has demonstrated that it is campatitive in cost with conventional electric power stations, and that ==almar power plants are not clean, safs 49*

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1 or reliable, insofar as the lake Erie Area is soneerned.

E. Atomia Esergy Cennimelon.

36. Petttiener moeteads that it is ammalistie to hold a hearing for a sometastation license at a time when the final design has ;

not undergone assessary research sad develsement testing to enable adequate evidasse to be introdaeed as te reliability j d

sat assaremen. The Preit=f navy Safety Analysis Report 4 mguired by t,he cas-Emaica's Rules is in aat of itself aa

?

l insufficient doeunent mestaately to detemine whether or met i

the 1smesmee of a constreetion permit will 41seharge the a

Cesasission's obligations under the Atomia Emsw Act and particalarly its obligation to protest the kaalth, safety i and welfare of the publie. The Applienat should be requi nd prior to the initiation of a hearing to submit to the Atenie r,

Energy Cammission for review not only the PSAR but also, in ,

addition, all other infomation used, relied upon or referred to in ooaneetica with the erstting of such an application.

37 The Atomie Energy Commiss*,oa is not ymsently qualified to condent adequately the aseessary on-site eempliance inspections which must he 6 spas darias the coursa of eamstreetion of the Proposed Plamt in orda / to assare that even miniana standards will be met. This is beemase the Region of the Cospliance Staff having jurisdirtion over the P._;rri Plant is inadequately staffed maa is umahla to make more than a paper review of the 30 .

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construction as it proceeds. Such s review is tantamount to no review at an since it places the responsibility for candor E ,

too hoesvily upea participants who are eermmisany conaerned with the building and erection of the Proposed Plant. -

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38. It is impossible to detamine whether or not tha highest and  ; j best secommodation between the Proposed Plant and asn'a p environnant has been :ssde unlass and until a complete  !

environmental study hss been made which in tura dapends upea the final design of the Proposed Plent. Since both the I l

Consissica and the Applicant agree thst they are in no such position, the starting of a bearing at this juncture of i

incompleteness can only result in the utility being fseed l

t with major issues rsised against tto Proposed Plant only after Applicant has invented millions of dollars in its constmetion -

1 ama ersetion. Sush a procedure is neither fair to the 4 l

utility nor fair to the taxpayore sei clectricity users vbo will pay the major ecst of the Proposed Plant's constmetion, as well as the Atcaic Energy Comissien's cotivitics in eoammetion with such roastmetica.

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39. Useer the Atceie Energy Act, standards for the construction aat operation of a anslaar power plant denominated " experimental

• sre less stringent than those dancminated as "comaamial" reseters. Sinoe there asm be no serious questien that the Davis-Besse Plant falls in the estegory cf "ce:c:arcial," the

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2 ti l 9 Atende Energy Commission hee avoided classifying them as non-erperimental in order to aid the utilities in building 1

reteteTo at lose Stri@ab standards. l l

40. Despite the esistesse of part 100 C.F.R. aat TID 148%4, the ,

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I Commissies is apparently abrant to appresre the leention of the 7.m:--1 Flast 12 eestrwresties ef the eriteria set forth in J its osa regalatteas. l 4

41. Beemese of the Atoada Enerly Cummission's natianoids objoetive ;

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of premeting analear plante, it has met, in the area of l t

l lieematae of maansar remeters, anegantely disoberged its [, ,

obligations under the Atente Ensagy Act aa4 other federal legislaties. The Cesamissies has failed to be objective and l i

failed to consion.? the possibliity that its promotion j <

objectives are insensistent with its regalatory objectives.

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The Ceaunission has not satisfied s legs 1 me%tica of thoes incomeistenaies regarding this proceeding since even l 1

ta the oyentag sentenses of the Ceaunission's Appendises D l

of Ayrti and June 1FfD, the Commission emessed its lack of j t

speificity by suggesting that such vagueness is aseeptable ,

l beemase of a "girewing need for electrieal power throughout )

the Uatted States." ,

42. The Commissian has failed to require Applicant and the maeleer imenstry in general to move forward with all deliberate-l speed in realistie researek and development sat other testing i  !

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assessary to the safe aan effisiest operation of nuclear i

plaats, eensidering not caly saftrty but earireamental questicas, but instead has used its power and efferts to proceed with the lisensing for the esastruettom and eyeration of smalmar plaats esspite sekameledged lack of azpeatenee in all of these azwas.

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1 III.

RESERVATIONS Petitioner hse ymysred this Amended Petition with unavoidable dearth of time, finea131 seeistance 2nd experienced legs 1 edvisors sad

! staff. N Atonio Safety and Ideensing Boerd, therefon, should be l l

mindful of this feet in the eensideration of what issues are contested ho min. In determining which issues to place before the Atomie Safety and , l

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Ideensing had, petitioner has not had the benefit of time, funds, and 1 expertise to the extent of the Appliennte, and has not kd sufrietent time "4 to therweghly eeussine and evaluate Applicant's deciseents and plans so as to  !

set forth all Possible objections that it might have. Petitioner, themfere, ,

resenes the right to rsiso objections to the following items during the '

eeurse of the hearing even though not specifiaally set forth herein:

]

1. 1Fhether the Atcaste Energy Ceemission's obligations under the National Euvinessental Policy Aat ("NEPA"), as well as under the Commission's interpretation of NEPA by virtue of its Appendix D prunnzigated in April of 19F0, have been validly imp 1mesented in this proceeding.

2. hther the Commission has nquired =n analysis ed the t Applicant has manlysed alternative available sites whether shore ground or i under greuwi for construction of the proposed Davis-Besse Plant. 4 3 hther the Cunnission has, pursuant to the obligations of  ;

NEPA, solicited eemments frees all federal, state and local egencies whose interests could be sffected by or whose speeisl expertise should be used regarding the coastnetion lisensing of the Fivgd Plant. ,

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l 4. Whether any comments which may have been received fres suek i f

agencies were impLimented or oomsidend in eonnection with either the

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Applisaat's pnposed desig or the Regulatezy Staff's evaluation of the ,

Applicant's proposed design.

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5. Whether there has been an c.nalysis and discussion of the 1

offset whiek the proposed Devis-3 esse Plant will have upon the growth and "

devolegment of the Telade, Port Cliatea, C3meland area, all other j l l

emities in the area. Whether regional er state F namias i agencies have  ; j l

been sonsulted naarding the creation of the Proposed Plant. Whether thers l has been eensiderstion of whst severse impoet, if any, the Pm,:::". Plant )

will have upon the future growth and soveleIment of these maniatyalities '

sad their geographie parts. 4

6. Whether the Cemadssion hss proceeded upon the asstamptian, #

erroneous or not, thst the prtmotion of generation of electricity by naalear power is pareount to all other eensiderationc, and, if so, whether there '

has been a valid analysis of the various of the alternatives to using nuclear sourees of generating electricity, and further, whether there hss been any ocasideration given by the Atonio Zhmergy Cemenission and utilities, such as Applienat, which support it realistiaally to investigste and develop alter-ante aan new sourees of emergy which raise no or a sint- of envirotnoontal problems.

a T. Whether Applicaat's Enviremmental Report is adegaste with roepest to radiosotive wastes, thermal effects, water supply, monitoring systems, ehemical wastes and the problems involved in expanting the generstion t

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l of electricity or steem frem the Proposed Plant or expsading in elese prart=1ty, ,

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l to the T._,z 2 Plant additiceal intestrial asere of stema energy. l l 8. Whether eensideration or analysis hse been made agarding the i

)

l serious issue Wt if, beenuse of the imposition of the Proposed Plant, many

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resteente of the surmunding ermammities decide to leste and other perseas, not vsnting to live nesr the Proposed Plant, de not move to them, resulting in s continuing doorense in populstion and depresistion of land values.

l 9 Whether eonsiderstion has been given, even assuming the need I

for electrietty, as to whether the land sat other resources to be eliminated ,,

by virtue of the proposed construction should be used for a higher and better h l'

use or purpose, considering s11 the needs of these eenmunities.

10. Whether there has been su sma3yets or esasideration of an l

dternative pisat site.

1

11. Whether there has been an analysis of what effeet, if any, the i l

Proposed Plant will have on the zeerentisesl activities currently enjoyed in l the Iake Erie Regian entending frem east of Cleveland to the Sandusky Bay area, such se sport fishing, water skiing, hunting, hiking, gutping, swimming and bonting.

12. Whether the Couaission has in sonnection with these proceedings, i

implemented the Federal Veter Pollution Centrol Act sad its amendments, -

't including the V'ter Quality Imprmement Act of 1970. .

13 Whether the operation of the Dsvie.3esee Plant will Darther espreciate and degrade the water quality of Lake Erie at a time when there has been much publie esmeers and official statements over the degenerating l

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oondition of Lake Erie, and the intemational eenestraenses of a " dead" lake.

^

hther in light of seek vide-spread ooneers and seemeent, the impeettion of the Davis-Besee Plant and its ooeling tower, adequate analysis er consideraties under NIFA has been gives. l i

14. hther peenliar atmospherto eenditions prevail in the Gnater ) {

Iake Erie Area which may eense evaporation and fogging problems and other atmospherie effects as a result of the daily operation of the .*E;:::t Plant's cooling tower.

1

15. hther the Applienst er the Cesarission has analyzed what effecti  !

if say, the proposed Dsvis-Besee Plant with all its attendant problems, imelading r41stion and other dangers, will have upon the growth of industriest la metropolitan sress e Armanding it ineluding out not limited to the possible preferssos of perseas throughout the United Ststes not to buy products which are pneused, manufactured or grewn anund or near the Proposed Plant, thenby sensing sa economie effect on such industries resulting in long range enemployment and ultimate deetmetion of pasent population centers.

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IV.

CONCIN ION AND REQUEST FGt RELIIF '

Based upon the foregoing, petitioner respectfully requests that ,

it be permitted to intervene as a party in these proceedings and that upoa ,

its intervention the somstrustica license new requested by the Applicant be .,

denied in accordance with this htitica. '

P I

L aespeetfully submitted, ii

't f hL tion r Safe ear Power i

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4 Evelya Stebbins  ;

Mman g i

Dated: Deeenber 5, Ityro e

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] EKUU.bu k 88, 5 0# $ lC .

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I 1 I certify that espies of this Amentsd Petition to Intervene have li

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,g been personally delivered to Thamme F. Engelhandt of the Regulatory Staff of the Atomie Energy Commission aat te Desaid Icaser, Counsel fer Cleveland

i Electria 111minating Oespany on Noader, Deemedper 7,17fe, with sufficient copies for Co.eeumeel of the App 11 ' l t

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,j p reer for Ws t l' h r

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_ - 4 E; DEC B 1970

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