ML18025A705

Amendments to the Petition for Leave to Intervene Filed by the Environmental Coalition on Nuclear Power

ML18025A705
Person / Time
Site:	Susquehanna
Issue date:	01/15/1979
From:	Johnsrud J H Environmental Coalition on Nuclear Power
To:	Atomic Safety and Licensing Board Panel
References
Download: ML18025A705 (13)

Text

ENVIRONMENTAL COALITION ON NUCLEAR POWER I/P4 UNITED STAT"" QF Al&RlCA NUCMK REGULATORY CQQCESSION

+u6 and Lic Board~<r 1 6')CP)Docket Na~O-387 Before the Atomic Safe~r-Xn the>htter of PENNSYLVANIA PO'dER AND LIGHT CQHPANX and AILiKiFENX ELECTRXC COOPERATIVE~

INC.2)5.88'262 lt/Etrecutlve Oirectorst George Boomsma-R.O.

rt I, peach Bottom.pa.17563 717 5e8 2836 r 3udi Johnsrud-433 Orlando Avenue.Stote College, pa.16801 814 237 3900 (Susqaehanna Steam Electric Station, Units 1 and 2)5O-388 A?KNDK2ZS TO THE PETITXON FOR LEAVE TO INDENE FILED HX THE ENVIRONMENTAL COALITION ON NUC~+P(MKR.I The Envtronmenta1 Coalition on Nuclear Power (ECNP)submits the fallowing supplement to its September 58 1978~Petition for Leave to Intervene in the captioned proceeding to"address three matters-Notice of Appearance B.Clarification of Petnitioners'nterest-and Standing C, Statement of Contentions and Their Bases Notice of A earance r Drse Chauncey Kepford arid Judith H, Johnsrud3 Zhcecutive Board member and Co-Director~

respectiv~3 of the Environmentaal Coalitian on Nuclear rower~havtng been d~authorized by the Executive Board of that organization to represent members'nterests in any'nd all

<<2>>administrative and legal proceedings~

her+6.td enter their notice of i$",~appearance as representatives of these Petitioners in the proceedings related to the matter captioned above, Clarification of Petitioners'nterest and Standin In the September 5~1978~Petition for Leave to Xntervene~

the Petitioners'ECHP) representative~

Dr, Johnsrud~advised that an affidavit setting forth interests of BCHP members on the basis of residence near Susquehanna Steam KLectric Station~Units 1 and, 8 (Susquehanna) would be'fi1ed separate, Such an affidavit was filed on September 8~1978~by Dr~Cliver J.Larmi, R,D, Q~Bloomsburg~

1'ennsylvania; Dr, 4mB.is a member of the Executive Board of the Environmental Coalition on Nuclear Powers to the best of my knowledge.

other signators of his affidavit are also members of ECNPi Xn addition>Dr Johnsrud is employed at Lewisburg~

Pennsylvania>

within a forty mi1e radius of Susquehanna+

Statement of Contentions and.Their Bases 1.Petitioners contend that the ana3gsis of the effects of the uranium fuel cycle on human health from the berg to the very end of the fuel cycle~have been seriou~mis-represented and underestimatedi Xn particular, the health consequences of the long-lived isotopes (long compared, Mth plant lifetimes) have yet to be considered for the"full detmcLfication period" of each and every long-lived isotope released, or caused to be re1eased to the environment, by the operation of Susquehanna (See NHDC v HRC~$47>2d 633~639 at n, 12)~Isotopes such as Tc-99~Se-79~X<<129~Cs-135~and the alpha-particle emitters have~to date~eluded full environmental an~sis by those responsible for such an~sisi 2.Petitioners contend that the cost-benefit an~sis performed b7 the Staff and Applicant is who~falsified This cost-benefit an~sis does not represent an an~sis"conducted fu~and in good faith~(See Calvert Cliffs'oordinating Committee v USAZC~D.C'.Cir~1971~slip opinion~pi 11)~Instead~the analysis conducted was designed to arbitrari+

reduce environmenta1 and hea1th costs while simultaneou~

inflating al1eged benefits, In particular~

radiation exposure from various isotopes~both short-and long-lived~

is compared with various back-ground sources of radiation exposure Yet no justification has thus far been advanced for comparing any cost attributable sole3g to the operation of Susquehanna with costs attributable to background radiation sources which exist independen~

of the Susquehanna.reactorsi In addition~this comparison of radiation attributable to Susquehanna with background, radiation distorts completely the cost-benefit an~sis of Susquehanna because the benefit side of the an~sis receives no such comparison.

No comparison of the energy generated by Susquehanna is made~for example, with the solar energy incident on the United States.Further~tne an~sis is faulty.because it neglects complet~the health costs due to all of the long-lived radioactive isotopes released~or caused to be released~to the environment by the operation of Susquehanna.

After aLL~"The Commission's prime area of concern in the licensing context~~~is public health and safety'P.(Vermont Yankee v NRDC~U S, slip opinion, p 28~1978).Petitioners assert that known and assured reserves of uranium are insufficient to supp~the lifetime fuel required for Susqueharuxa 1 and 2 in a growing nuc1ear economy The historic growth rate for nuclear generated electricity'~

a measure of uranium consumption, is about 32,o annu~~,for the y'ears 1961 through 1977.Eren if this growth rate drops more than in half to 155~ale.of the estimated reserves of uranium wi11 have been consumed prior to the end of the thirty'ear life of Susquehanna 1 and 2, As a result~much higher fuel prices wLLL result~and environmental damage will increase greatly'ith the mining of ever lower grade ores.The problems of disposal of mill tailings~now deem'ed trivial by'ome~will.rapi~

mount.Yet no environmental impact assessment has been made of the interrelated fuel supply-mill tailings problems as uranium is consumed, as these problems pertain to the entire operational lifetime of Susquehanna., ho Petitioners contend that there is no need for Susquehanna.

The information supplied by the Applicant shows that, with very modest increases in electrical energy conservation efforts~all of the need for Susquehanna 1-and 2 will disappear complete~.

Applicant's Qxvironmental Report (ER, p.1.1-2)gives load growth ranges, Table 1.1-15 of the ER shows that at the~ere Low Growth rate scenario, the entire output of Susquehanna 1 and 2 will be avai1able for sale outside the service area of the Applicant as the units come on line, The conservation programs suggested by the Applicant are not designed to encourage either meaningful energy'onservation or efficient energy use.instead, these programs are aimed at encouraging continued electrical energy.usage, regardless of whether electricity's the most efficient form of energy for the gob at hand or not, The Applicant has not considered the alternative to Susquehanna, as required by N-""Z4~of more strict energy conservation measures For example~there is no comparison of cost for upgrading the thermal insulation in existing residences and commercial buildings in the service area of the AppU.cant with the cost to complete the Susquehanna plant.The discussion of the Applicant's anticipated load growth is based on increased~e of electricity for space heat in residences and commercial establishments~

together with the continued practice of over-use of electric 3.i.ghting, both for indoor use and for ad-vertising and display.In addition~the Applicant presents no discussion of the'egative impact of increased electrification of industrial opera-s 0 tions (through"modernization," to become more"efficient")upon:r employmenta This impact is readily seen by comparing the number of workers needed to achieve a given'.output of an"inefficientF plant with the employ'ees needed inmodern~

efficient, mechanized plant to achieve the same output, The Applicant thus gross+,"..

\a underestimates the unemployment created by the"Applicant in its service areaa e*, I~)1 g l'a~I 5.Petitioners contend that th'e models used to calculate individual and population doses are inaccurate and obsoletea These deficiencies are compounded by the arbitrary selection of data for the purpose of underestim'ating radiation doses particular, the milk transfer coefficient for iodine has been underestimated (See Health PhZsi~cs 35, p.413-16'978)

~addition, these models use factors which convert alpha-particle.

dose in rads to rems which are far'top low (See Health Phtsicsp~4 p.353-60>1978)~and which underestimate the radiation effect, on a per rad basis~for the very low energy beta and gamma radiations~

as from H-3 and C-14 (See Health~sics,~h, p 433--.8~1978)a Furthermore, the entire set of radiation standards is based'primar~on the data from Hiroshima and 1iagasaki~

where the doses received by survivors were essential>

instantaneous.

For radiation effects from the entire uranium fuel cycle, as will be caused by the opera-tion of Susquehanna 1 and 2, the doses received both by workers and by members of the public vill-be low doses daUvered at, in general, low dose rates.The bomb blast data have no demonstrable t relevance to this chronic~low dose situation See'Health~s~ics~33 a, 369A5, 1977, and Brdadan Jonrnal or~Cancer~7 p.44C-51, 1978 ala .6., Petitioners, contend that the analysis of alternatives~

as required by'EPA and the Commission's rules, is woeful~inadequate and incomplete~

'l'his analysis does not consider serious efforts at energy conservation~

end use efficiencies~

or what have come to be known as 4 Second Law Zffi.cienciesi" ln addition~no discussion has been presented concerning the health benefits of energy conservation in conjunction with the conservation alternative to Susquehanna~

There has also been no comparison of the health costs attributable to the operation of Susquehanna with thase of'not operating Susquehanna~

~with these types of comparison can the true health cost of Susquehanna be evaluated.

Solar energy'n any of its various forms is not considered as an alternative to Susouehanna.

By ignoring this commonly'sed alternative energy source, the Applicant is hoping to'prevent home use of solar heating and hot water applications.

Further encouragement

'of reliance on expensive electrically'perated mechanical heating and cooling devices, lance heat pumps~in the name of energy conservation, seems to defeat not only energy'onservation~

but alsa the development of solar ener@ri The pr1auLry beneficiary'f this defiance of NEPA is the Applicant.

7~Petitioners contend, that emergency response and evacuation planning by'he Applicant~

the Director and.Staff of the Office of Radiological Health of the Penns73vania Department of Environ-mental Resources~

the State and County Civil Defense Agencies, and others responsible for protection of the health and safety'f the public in the event of a radiological emergency'ffecting the population beyond the site boundary of Susquehanna is not complete and sufficient to assure prompt notification and, evacuation of a1l areas in which persons.may be exposed to radiation doses in excess of those permitted by'xisting radiation exposure standards for the general public and Protective Action Guides.The recent Planning Basis Report of the MRC and Emvironmenta1 Protection Agency' (EEEG-0396/EPA 520/1-'78-016~

December~3.978~p.'5)notes that'more specific guidance with respect to accidents whose consequences would be more severs than the design basis accidents sxplicit3y'onsidered in the licensing process[isj appropriate

" In view of the Nuclear Regulatory Commission's'expressed reservations about the reliability and validity'f the probability estimates in the Reactor Safety'tudy'~

WASH-1/00 (See~e,gi~:.!'Mls/CR-0400 and NUIUXi-.0396/EPA 520/1-78-016~

pp, IA through I-10~including notes at pp'-8 and I-9;see also transcript of the December 21~1978, and subseouent NRC Commissioners'eetings and Comvd.ssioners'raft policy statements.on MASH-1400)~

and in view of the, explicit limitation of the validity of'he Reactor Safety!Stu+'s analyses through the year'980~prior'to tne operationa1 lifetime of Susquehanna 1 and 2~Petitioners contend: that'no probability ana3ysis exists to)ustify the AppU.cant's and Staff's failure to address the, full consequences to the plant and, to the genetic and somatic health and the safety'f the public~and the full long-term costs of property damage of the design basis accident (including sensitivity analyses)and of accidents more severe than the design basis accident.Petitioners contend that no operating license for Susquehanna 1 and 2 should issue until, the Applicant, Commonwealth, Luzerne County, Salem Township officials and any others sharing responsibility for public health and safety have prepared and tested-<<with drills that include participation I of 811 of the potentially'ff ected public->>emergency preparedness and evacuation plans for the design basis accident and for worst-, case (Class 9)accidents,.Risk analysis is incomplete and inadequate to comp3jr with iiPA and the Commission's mandate under the Atomic Energy'ct of-1954, as amended, in the absence of full an~sis of.both the probability and consequences of worst-case accidents.

The sting studies of disaster response are inadequate to demonstrate~

in the absence of tests involvtng those who would be affected~the to ravide capabi3ity of emergency response and evacuation plans to provi the protection required for the'publici Two serious contradictions additionally inhibit the effective 1t A performance of the duties, af the two parties havtng moor responsi-bility for emergency notification of the public and for the protectian af the public health in the event of a radiological emergency~First>>the Applicant, through various public relations efforts and the covmnmications media>>has sought to convince those residing in the vicinity of Susquehanna.

that the plant poses no significant threat to the public health and safety'>>but has offered no verifiable foundation for such claims beyond the now-repudiated Reactor Safety Study The Applicant is the initial source of in-formation->>and the only source of data-pertaining to the severity and scope af the radiological hazard following an accident st Susquehanna.

Zn the ear~stages of an accident>>the Applicant map'e unable or unwilling to ascertain that an offsite radi:ation hazard exists or will~st>>and may'e expected to avoid advising other responsible authorities and the public as long as the utility'fficials believe that emergency'vacuation

-detrunental to the utility'ompaq('s interests-is not absolut~essential.

Further-more>>the Applicant>>

having impressed upon tne public the safety of its nuclear reactors and the alleged extrem~low prabab~t7 of a catastrophic.

accident>>or other responsible officials may'e unable to convince endangered residents of the necessity'f emergency actions and evacuation, A second contradiction inhibiting adequate emergency'esponse lies in statements made by'he Director of the~ennsylvania Office of Pwdiological Health, Hri Thomas XI, Geruslgr~He has stated at a public meeting that his staff would not be able to respond at all hours to an accident at a nuclear fac93.it7.

He has also>>by'ffi-davit>>denied having made such a statement.

Purthermore>>

the QCfice of RacU.ological Health has been unsuccessful in obtaining the amount of'unding required to provide adequate qualified staff and equip-ment ta be able ta expand its capabi3Lty to monitor and to respond to a radiation emergency situation at Susquehannao 8i Petitioners contend that routine, or occasional>>

use af

<<9 environmentaLLy'ersistent or inadequat~

tested herbicides to maintain clearance of transmission line rights-of-way is a somatic~teratogenic, and, potentially'utagenic threat to the health and safety'f persons living near or traversing these areasi 9i The archeological investigation of the Applicant's upland site for the Susquehanna Station~has~chosen following the 1972 flood caused by Hurri.cane Agnes, was incomplete and inadequate to determine the status of cultural antiquities in advance of th'commencement of construction Completion of archeological investi>>gation in compliance with state and federal law governing protection of antiquities should precede further construction at the sitei Petitioriers believe the Board should require an independent review-of the Applicant's archeological studiese4 Il LO~Petitioners assert that the Nuclear Steam Supply'y'tem (NSSS)of Susquehanna 1 and 2 contains numerous design deficiencies>

some of which may never be resolvable, and which, when viewed together, render a picture of an unsafe nuclear installation which map'ever be safe enough to operate.The pressure suppression containment structure may not be constructed with sufficient strength to withstand the.adamic forces realized during blowdown~The reactor pressure vessel maynot survive the thermal shock of I cool"CCS water after blowdown without cracking The cracking of stainless steel piping in B'~R coolant water environments due to stress corrosion has yet to be prevented or avoided.B~R core spray nozzles occasionally crack, a problem which reduces their effectiveness.

The ability of Susquehanna to survive Anticipated Transient"lithout Scram (ADVS~see MSH;1270)remains to be demonstrated.

For this AT'JS issue~reliance on probabilistic numbers~as lO per year, is uniCse and unsafe, Orerpressuriza-

'ion of the pressure vessel is a serious safety'problem~

especi~in view of the underhanded and whoZ3g inadequate method used to ensure that the ASIDE stamp was to be applied to nuclear pressure vesseLsi (See Proceedings of the Annua1 Mnter Meeting~AGE, November 17-22~197)i~New York~N,Y,~paper by A,J, Ackern~o)Numerous problems ren~with the adequacy of electrical cable penetrations of the containment structure.

The reduced capability'f Susquehanna to scram at the end of the fuel cycle due to con-trol rod poison depletion aggravates all of the above problems~such that when all of these~and certain3g others such as containment steel linex buckling problems that have not'been specifically'ddressed here, are combined, the conclusion of an inadequate and obsolete design is obvious (See~for general x'eference materials~

NURSE-0138, NUR3K-0253~

among others.)11~Petitioners contend.that excessive reliance on"single failure" events (i.e+, see FSAR 6.3.2.5)leads to a false sense of security and certainty~

especi~when it is known that multiple failures occur (See testimony of Dri David Okrent, AORS~before the California Legislative Committee on Mergy and Mminishing Resources~

October 29~1975, p.11.See also Joint Committee on Atomic Merge~U,S~Congress~Hearings entitled"Browns Ferry'uclear Plant Fire, vol.1, September 16>1975)~14, Petitioners contend~,when taken together and factored into lifetime monetax7 ful3.cost determinations for Susquehanna, that plant decommissioning and ultimate dismantling and site decon-tamination~

interim spent fuel storage and,subsequent disposal~radioactive waste management and disposal at all stages of'he nuclear fuel cycle~and health costs for the full period of toxicity of radioactive material.s attributable to the operation of Susquehanna wQ3.render this nuclear facility economically'on-competitive with vtrtually any of the margr alternative sources of energy or with conservation.

Absent nationa1 policy'etermina-tions~federal legislation~

and.administrative agency'egulation of these issues, Petitioners contend.that no operating 1icense should issue for Susquehanna 1 and 2i For all the foregoing reasons stated in these contentions~

the Environmental Coalition on Nuclear Power contends that this Atomic Safety'nd Licensing Board should exanMe D~the public health and safety'nd envtronment'al impacts, costs~burdens~and irreversible damages which will result.from the operation of Susquehanna 1 and.2 and should dengr an operating license to the Applicant.

These Petitioners wish and intend to conduct a.full case of cross-examination of Applicant and Staff and any other witnesses~

as we11 as to present witnesses of their own in support of these contentions~

in order to assist this Board in reaching a gust determination of the matter at issue.Because of prior participation in numerous AEC and NRC administrative proceedings~

however~ECNP~a non-profit public-interest organization~

is heavily'urdened with debts for these earlier legal cases~many'f which have contributed substantially to the betterment of federal regulation of nuclear power reactors, as a reading of the records wQ.1 revea1.Petitionexs therefore, with this filing, renew their prior requests for financial assistance fxom the Nuclear Regulatory'gency in order tq maze the agency~s benefit,.from our contribution to this proceeding.

Me ask that~as an immediate and first step in financial relief~the Commission undertake hereafter the reproduction and mailing to other parties on the lengthy service list of subsequent filings by'CNP in this case.8'atei January/5 1979 Respectfu~

submitted, s,,~z,'gp&

mc W Judith H.Johnsrud Co-Director and Representative~

PCNP JQ3 Orlando Ave~State CoU.ege~Pa~

U.S.NUG.'i..~"l,".;-;(~'(COVS~ISS1ON ooc>'".!.': '.'!I~"." (chew Poslfllhl.

Copiss Pe;iivcd Add'I C-" SPOola",I~;'l fi~'lJs CERTIFICATE OF SERVICE I hereby certify'hat copies af Amendments to the Petition for Leave to Intervene Filed the Wvironmental Coalition on'Huclear

~Po-er dn Docket Nos.50-387 and 50-388~have been served on the fo33.owing, by deposit in the U S Hai1~first class~postage paid>this Q~day of January~1979.J MmcW~Judith H.Jahnsrud Co-Director and Representative, hCNP Secretary'f the Commission U.S Huclear Regulatory'ommission Washington~

D C, 20555 Charles Bechhoef er,'squire Chairman~ASLB Panel U.S, Nuclear Regulatory Commission Washington~

D.C.20555 Hr, Glenn 0.Bright ASLB Panel U.S.Nuclear Regulatory Commission Washington~

D,C.a0555 Dr.Oscar H.Paris ASLB Panel U,S, Nuclear Regulatory Commission Mashington, D, C.20555'tomic Safety and Licensing Board Panel U.S.Nuclear Regulatory Commission Washington~

D,C, 20555 Atomic Safety and Licensing Appeal Board Panel U.S.Nuclear Regulatory'ommissi,on Washington~

D, C 20555 James M.Cutchin, IV, Esquire Office of the Wecutive Legal Director U,S.Huclear Regulatory Commission Mashington~

D,C, 20555 Docketing and Service Section Office of the Secretary U S Nuclear Regulatory Commission Vashington~

D, C 20555 Jay Silberg, Esquire Shaw~Wttman, watts~and Trowbridge 1800 H Street NW Washington, D,C, 20036 Gerald Schultz, asquire Susquehanna Mvironmental Advocates 500 South River Street Milh:es-Barre~

Pa.18'(Oc>!rs.Irene Lemanowicz~

Chairpersan Citizens Against Nuclear Danger P.O, Box 377 R.De 1 Berw9.ck, Pa.18603 1<s.Colleen Marsh 558 A~ReD.g4 Hountain Top@Paean 18707 Hr Thomas H.Geruslqr, Director Bureau of Radiation Protection Department of Environmental Resources Commonwealth of Pennsylvania P 0 Box 2063 Harrisburg~

Pa, 17120 CQ/pgCKHEO USNgt>>~g JP,N(7@79>5 Q(f~~>~ice O~~an (5 Ol