ML20234B374

Marked-up Response to Re PG&E Application for CP for Const of Nuclear Power Plant at Bodega Head.Law Provides for Comprehensive Safety Review Before Decision Reached Re Issuance of CP

ML20234B374
Person / Time
Site:	05000000, Bodega Bay
Issue date:	08/01/1963
From:	Price E US ATOMIC ENERGY COMMISSION (AEC)
To:	Tatsapaugh M AFFILIATION NOT ASSIGNED
Shared Package
ML20234A767	List: IA-85-665, Discusses Seismic Design of Nuclear Power Plants,Including Const of Nuclear Plants in Seismically Active Zones ML20234A761 ML20234A769 ML20234A792 ML20234A798 ML20234A803 ML20234A812 ML20234A816 ML20234A827 ML20234A830 ML20234A838 ML20234A841 ML20234A844 ML20234A847 ML20234A851 ML20234A855 ML20234A858 ML20234A861 ML20234A864 ML20234A868 ML20234A871 ML20234A874 ML20234A893 ML20234A896 ML20234A900 ML20234A911 ML20234A922 ML20234A929 ML20234A932 ML20234A937 ML20234A944 ML20234A956 ML20234A965 ML20234A968 ML20234A976 ML20234A984 ML20234A993 ML20234A996 ML20234A999 ML20234B005 ML20234B008 ML20234B023 ML20234B032 ML20234B035 ML20234B040 ML20234B062 ML20234B066 ML20234B076 ML20234B084 ML20234B098 ... further results
References
FOIA-85-665 NUDOCS 8709180381
Download: ML20234B374 (4)

Text

_ _ _ _ - _ _. -

I

)

(

('

[" ' *e,,

UNITED STATES l

./

"t ATOMIC ENERGY COMM(SSION j

h 1

wassmovou n. o.c.

1 e

s,,,n,, l i

DLR CTE I

Docket No. 50-205 l

/"'

5963 1

1 Mr. Melville Tatsapaugh San Francisco, California Dear Mr. Tatsapaught j

This replies to your letter of May 31, 1963 addressed to President rennedy concerning the application by Pacific Gas & Electric l

Company for a construction pemit to construct a nuclear power j

reactor at Bodega Head. You expressed concern with respect to the procedures being followed in connection with c. consideration of the application by Pacific Gas & Electric Company for the necessary l

authority te permit construction and operation of a nuclear power plant at the proposed site.

In cases of this kind, the law provides for a comprehensive safety review by several technical groups who are expert in matters of

)

reactor safety. This safety review must be conducted under regu-latory procedures also prescribed by law, including a public hearing in which the rights of interested parties to participate I

j and voice their objections are fully protected. The various technical safety reviews have not yet been empleted in this case i

and the public hearing has, therefore, not yet been held. For these reasons, we are unable to state a position on the merits of this case at the present time. Ho.tever, a brief description of our procedures for reviewing applications of this type may be helpful to you.

Before the C mmission can reach a decision on the issum ee of a pemit authorizing construction of a power reactor like the one proposed by Pacific Gas & Electric Company, our technical staff must make a comprehensive safety review of the proposed design, construction and location of the plant. In addition, these J' matters must be reviewed by the Advisory Connittee on Reactor gg. Safeguards and the reports of the Committee must be made public.

N N- (The Advisory Cmmittee on Reactor Safeguards was established by jd Congress to advise, the Cocaission on matters of this kind. It

,3i-is made up of scientists and engineers who are eminently qualified in the scientific disciplines relating to reactor safety.

tv.?!qq'r -

I

' l 8709100301 851217 hES 665 PDR i1

_ _ _ _ _ _ - _ _ _ _ _. _ _.____L

• 4

~

Mr. Melville Tatsapaugh- /:

1953.

i After these reviews have been completed, a public hearing must be held before an Atomic Safety and Licensing Board. At such a hear-ing the company proposing the plant must present evidence justi-fying the proposal from the standpoint of public health and safety and ambers of the technical staff of the Commission present their evaluation of the safety aspects of the plant. In this hear-ing, nebers of the public who have an interest in the matter may participate in the hearing in accordance with the Commission's

" Rules of Practice",10 CFR Part 2, a copy of which is enclosed.

fYou will note that. Sections 2.714 and 2 715 describe the con-

,[;up,i ditions under which persona may participate in the hearing and do not necessarily preclude the receipt of testimony by individuals "not technically qualified".

s e s.t.

u At the conclusion of the public hearing, the Atomic Safety and Licensing Board renders an initial decision and this decision is then subject to review by the Commission at the request of a party or on its own motion.

The purpose of these ertensive technical safety reviews and pro-cedures is to assure thorough consideration of all aspects of the l

proposed plant bearing upon the question 'of whether it can be constructed and operated at the proposed site without undue. risk to the health and safety of the public. A more detailed descrip-tion of the regulatory review of reactor projects is provided in the enclosed pamphlet.

At the Ccannission's request, the U. S. Geological Survey has been conducting a thorough field study of the geology of Bodega Head since early May. In addition, expert consultants have been retained to assist the AEC Regulatory Staff in evaluating Pacific Gas & Electric Ccanpany's application with respect to the seismology of the area and structural design of the proposed plant. Final action on the Pacific Gas & Electric Company application will not be taken until the report by the U. S. Ge-ological Survey has been received and evaluated. Further, a h construction permit will not be issued unless the Commission, following a public hearing and a decision by the Atomic Safety and Licensing Board and consideration of all factors bearing l upon safety is convinced that the facility can be constructed i

and operated at the proposed location without undue risk to the

'h health and safety of the public, p.

.bfew j %dk. c c

l l

1 h

a

[

_ = = _ = _

_ _ _==- =_,_-=__

(

(

i

(

Mr, Melv111e Tatsapaugh /* C '

'?53 t}t

-..d

.... y u]l u KG:,cc I'

The application by Pacific Gas & Electric Company is before the ( \\

Countission as a regulatory matter. The reactor project covered '

by the application was conceived by the Company on its own

\\

initiative and is proposed to be entirely financed with private 4

capital. No financia._1_ or_nthet_ commitments by the Ccumnission 1

6.,,, c.. e.,

are involviid { ~ ~

' j. g,,.

ao -

- You indicated that the AEC has lowered distance limitations from active earthquake faults from i to of a mile.

,On_ February _ ll % 9

'^',l.

1961, the Ccamission published in the. Federal. Register.a pro-

)/' T, 4 4:

posed'"Reaeto'r 51Te' Criteria" 10 CFR Part 100 for public comment./

Section 100.10 (b).(1) thereof provided as follows:

"The design for the facility should conform to accepted building codes or standards for areas having equivalent i

earthquake histories. No facility should be located closer than } to i mile from the surface location of a l

known active earthquake fault."

In connection with finalization of Part 100 it was recognized that the statement "no facility should be located closer than t to 4 (underlined for emphasis) mile from the surface location of a i

i known active earthquake fault", constituted an ancxialy. Therefore,

\\ when Part 100 was made effective on May 13, 1962, the sentence was 1

). changed to read "No facility should be located closer than one-fourth]

_ mile from the_surfacTe~licationJCiTnownlitTvii'Eirthiuake fjult."._ )

~

l

I believe you will agree that, in fact, no change was made in Ee minimum permissible distance. Copies of Part 100 as orginally pro-( posed and in its presently effective form are enclosed.

You will note that the Statement of Considerations and Section 100.1 (a) of P=rt 100 make it A/.:. dant,1y clear that Part 100 is intended l

only as a guide for the evaluation of the suitability of proposed l

sites for stationary power and testing reactors, and that Section 100,10 (d) specifically provides that "where unfavorable physicalN n, 3, characteristics of the site exist, the proposed site may never-

'f

\\;

theless be found to be acceptable if the design of the facility l

includes appropriate and adequate compensating engineering safe-guards".

Concerning your reference to construction work at Bodega Head site, please refer to the enclosed copy of the Commission's regulation, 10 CFR Part 50, " Licensing of Production and Utilization Facilities".

Section 50.10 (b) provides that the construe.cn of a proposed l

l 1

l

.A y

-(,.

g O

M.r. F.elvil)' Tat:apauen 4-rea:1.or af not. by:ir, c:i ce 14, tJ.c i etsu an c..

of. a<.nturu-Licn perv.i.'

in the At % c Er>segy C n ea:Lun.

n v i ' n :*..,

.

• t,.hn:

" construct ot" w e O a t-i in l' e n ow: e t te':.;c s: C or., _

Ln abde sit.s excaveio,, es:mt ruc uon of ro.16;aya, ra'.'mer, r.c-run.3 apars, temporar, bul.1-lings for m.* in conrmet..:.o : with ilanr' re; tion at e.

. It is important to note in thu connectio. tnat suh cenetra:t.io:q as is cermissib1<4 prior to the obtainit:c cf a c'ensttaaetim per-c.it /

must be undertaker at the applicant's risk cir:':r. th<.ro ca:,...nc]

scourance that a f e.r.it wii3 be issucc tmiti the Car' applientiuc. and a faw.rati.- deeitier.jl ar: or. r,s..

coo;lete'd its review of the 10 P-) ached.

If there is any further it. formation which we can prendc. pleasa let ua km.v..

Sincerely yo'.trc, l

/

i.

thr R. Price Assistant Director Dhision of I.,1censin; and Ee.94.ativ:.

Encicntros:

, 0 G,r...r< tart e.

2.

Pam:bl.'

3 10 CF.'i Part..00 ( propo:.ed) 4 1.0 CFR Par +: 206 5.

.10 CFH Pr.t 50 l

l l

.e l

l e

4 u

. l

..a u_

._t

4

.1

(

(

j n;

i 1

S'an Francisco il September 2, 1963 j

Eber R. Price

-Assistant Director j

Division of Licensing'& Regulation The United States Atomic Energy Commission Washington 25, D,C'.

s Sir:

i i

This is in reply to your' letter of August 1, 1963 with' regard to the proposed PG&E nuclear powered _ plant at' Bode-ga Bay.

In reference to my previous letter to President'.

Kennedy I snist stand corrected.on my statement that the~'

ABC lowered the distance limitation from 1/2 ' to 1/}4 mile.

However, I must take issue with tho' interpretation (and J

there is legal opinion on my side here*) that Part 100,10-(d) of the Reactor Site criteria can overrule Part I

LOO.10(c)(1) which specifically states: "No facility.

should be located closer than one-fourth mile from the surface location of a known earthquake fault."

This is one of the rare instances in which the authors or the latest -

Reactor Site Criteria (April 12, 1962) have' pinned some-thing _down and discussed explicitly the safety aspect-are to be'used only as a " guide"y the Reactor Site Criteria in lucid terms.

While admittedl

, still it.would'seem that some limitations must be pertinent.

If the 1/l4 mile J

limitation does not_ apply to the San Andreas fault, which is the most active on this continent, then seemingly none af the reactor site criteria need apply, and this Ta E publication was a waste of time, effort and money -

a sop to the unsuspecting.

As the criteria stand now, l

they are so loosely worded and ambivalent with regard to safety as to be practically meaningless.

On the subject of subsidy, your statement that "No financial or other commitments by'the Conunission are involved" in the Bodega plant is simply not true in the light of the federal publication entitled:

j Hearings before the Joint Committee-on Atomic Energy

,1301.. Table A-1}, page. 2I 1 states thE the " estimated 4

average annual assistance or annual difference lease as compared to private ownership" will be between L$376,100 i

and $6l4,000 On page 2140, section 7, second paragraph 1

1 we read, "Goverranent ownership: and leasing of special-j nuclear materials provides a form of financial assistance i

to private utilities to the extent the Government use j

i a

w v.-

.c

4 I.

(

4

(,

y charges are less than the inventory carrying charges that would be necessary if the utilities had;to finance the pur-chase of the materials."

Also, I would like to point out 3

that-the U.S. Government under the Price-Anderson'Act (sponsered by the AEC) - passed as Public Law 85-256 by Congress on September 2, 1957 assumes a liability of

$0.5 billion for each catastrophic nuclear accident.

The private insurance companies, after pooling their resources felt obliged to limit their coverage to a. mere j

$60 million.

Their report included the following state-ments:

"The hazard is new.

It differs from anything which.

j 1

our industry has previously been called upon to insure.

.... The catastrophe hazard is apparently many times as -

great as anything previously known in industry and there-fore poses a major challenge.....We have. heard estimates of catastrophe potential under the worst possible circum-stances running not merely into millions or 1

tens of millions but into hundreds of millions and billions of dollars.

It is a reasonable question of public policy as to whether a hazard of this magnitude should be permitted

.... 0bviously there is no principle of insurance that i

can be applied...nhere the potential loss approaches such I

astronomical proportions.

Even if insurance could be I

found, there is a serious question whether the amount of damage to persons and property would be worth the possible benefits accruing from atomic development."

If these nuclear plants are so safe, why do the private insurance companies so limit their coverage?- Also it should be made i

clear that here to'o is another form of subsidy paid by Americans.

• Possibly these subsidies to the private utilities are justified, but both the AEC and the PG&E are not justified in misleading the public'that this oper-ation is entirely privately financed.

A. M. Weinberg (Director of Research, Oak Ridge National Laboratory) i made a fitting conclusion to my point when he said:

I

"....the current prices represent a substantial governmental subsidy for the Bodega Bay plant."

As the third and most important point, I would like to bring to the attention of the AEC a matter which I did not I

discuss in my previous letter to President Kennedy..and which, I think, should be carefully scrutinized.

In read-ing the AEC publication TID-lh8kh Calculation of Distance Pactors for Power and Test Reactor Sites - MarcE 23, 1962, I became curious as to what the actual exclusion area for the Bodega plant would be.with its first reactor, y4 s;

-,.m

. q

_w.-.

,,,_.m,~-.,~,.,,n..

y._.,.

.7,w,.

e,..

7

....4

1

(

(

and what it would be with its final total of four reactors on the site in the future, iSince the proposed Bodega i

plant is of an experimental nature (under earthqua%e conditions, at least) in which the containment dome is j

replaced by the untried pressure-suppression system, and l

since this system consists of piping underground which i

is certainly subject to earthquake action and since the breakage of piping could also cause a, loss of coolant

{

and hence a meltdown and rupture of the vessel, it seems very logical.that more than one and very possibly all-j of the reactor vessels could be ruptured in the event of an earthquake.

Therefore Part 110 ll(b)(2) of the Reactor Site Criteria (April 12, 1962) would apply, and the cal-j culations reflect this probability.

The disturbing thing l

about the conclusions here is that not only would the U.C. marine biology laboratory be in the exclusion area, but the town of Bodega Bay as well.

Has the PG&E notified the AEC of this eventuality, and if it has, what course

{

will the AEC takei Will this simply be a case in which the AEC again i p ores its own rulings (as in the 1/4 mile limitation) for the benefit of the PG&E and' to the -

i detriment of the safety of the citizens of the Bay Area 1

I and Sonoma County 7 Certainly according to the calculations which are reasonable and logical, if the AEC permits the PG&E plans to be realized it would seem that the town of Bodega Bay would have to be eventually abandoned since according to the Reactor ~ Site Criteria Part 100 3 (a):

" Residence within the exclusion area'shall normally be 1

prohibited."

Do the people in Bodega know that, "resi-dents shall be subject to ready removal in. case of necessity"?

i Indeed, this is a very tragic situation when the life (not to mention the livblihood) of a town like Bodega can be snuffed out by the whim executive in a city miles away.lof a power utility company Finally, I cannot rest assured that " construction as is permissable prior to the obtaining of a construction permit must be undertaken at the applicant's risk", since the AEC ruled favorably on the construction permit of the Enrico Fermi plant in Detroit which was opposed by local residents and was recommended against by the Advisory Committee 'o'n~henctor Safeguards.

The reasoning was that the sponser7 the Power Reactor Development Company, had

)

spent so much money on the installation.

Is the AEC aware that the PG&B has already spent close to two million dollars on Bodega, and is the public to see a repeat per-formance on the Enrico Fermi plant fiasco?

Is the'AEC we eewe r-M*h***

TFT"A*

a_____2________-_------Y

.)

s i

'I considering any changes in i panies. to. become so hasvily 'e,ts rules-that encourage com,

cemitted financially to~ pro-jocks that~1t is almost impossible to turn down the con-struction perstits even 'in the light of more important fac-tors?

I would maintain that-there is need for deep and extensive reform in the reactor. safeguard criteria I-hope the AEC will become alert to the necessity for this H

requirement'before the 'public in violent reaction rejects the shole atoms for peace program, which in spirit'is a sasunandable project.

The. atom can be a great aid to modern civilization, but current developmental policies of the ABC emnnot help but make it a curse to present and future-generations.

Yours t y y, f

( V & 6d k Mel Tatsapau 4

y i

eBobuttal of reply to petition to reopen for further hearing before the California Public Utilities Comunission --k; June 1963.

Application 43808. Interim decision 61537.

i 4

1 l

I i

l I

J

-l 1

e 3

I 4

,A.

..-,,7,,....-

,m 7 ywer"

%7"s~N

,,P-. -~~, ~:. -7 r

..,~,-e.

3

~ ~" Cl:ElEII~'ElCZNJ i

l 1

1 gitta' t9

[

f'

1. "q UNITED STATES ATOMIC ENERG COMMISSION p

WASHINGTON 25. D.C.

i 3

DLR:CTE Docket No. 50-205

\\

/. ' ' '

1963 l

1 Mr. Melville Tatsapaugh i

San Francisco, California

{

Dear Mr. Tatsapaught This replies to your letter of May 31, 1963 Kennedy concerning the application by Pacific Gas & Electricaddressed to Pre Cmpany for a construction permit to construct a nuclear power reactor at Bodega Head.

procedures being followed in connection with consideration o application by Pacific Gas & Electric Company for the necessary authority to permit construction and operation of a nuclear power plant at the proposed site.

review by several technical groups who are expe reactor safety.

latory procedures also prescribed 'by law, including a pub hearing in which the rights of interested parties to participate and voice their objections are fully protected.

and the public hearing has, therefore, not yet been h The various case this case at the present time.these reasons, we are unable to sta For s of helpful to you.our procedures for reviewing applications of this t Before the C m mission can reach a decision on the issua proposed by Pacific Gas & Electric Ocepany, our te a

t must make a comprehensive safety review of the proposed design construction and location of the plant.

' matters must be reviewed by the Advisory Ccanittee oIn addition, these

• q g, Safeguards and the reports of the Ccemittee must be made public.

n Reactor L The Advisory Committee on Reactor Safeguards was established N

g9 Congress to advise the Cocaission on matters of this kind g gi-in the scientific disciplines relating to reactor safet It e

.mmanc.

l

^ ~

L L'~T i

,o, y,u j R o ? 3 L-q) w

O I

(

j

> Mr. Melville Tatsapaugh /.U 6 '

1963 After these reviews have been comp 15ted, a public hearing must be held before un Atomic Safety and Licensing Board. At such a hear.

1 ing the campany proposing the plant must present evidence justi-fying the proposal from the standpoint of public health and safety and members of the technical staff of the Commission present J

their evaluation of the safety aspe. cts of the plant. In this hear-f ing, maabers of the public who have an interest in the matter may 1

participate in the hearing in accordance with the Commission's

]

" Rules of Practice",10 CFR Part 2, a copy of which is enclosed.

j Qou will note that. Sections 2.714 and 2 715 describe the con-J pMgqh(

ditions under which persons may participate in the hearing and do

{

y not necessarily preclude the receipt of testimony by individuals j

"not technically qualified".

I K N!ru. q.

n w

At the conclusion of the public hearing, the Atomic Safety and Licensing Board renders an initial decision and this decision is then subject to review by the Commission at the request of a party or on its own motion.

The purpose of these extensive technical safety reviews and pro-cedures is to assure thorough consideration of all aspects of the j

proposed plant bearing upon the question of whether it can be j

constructed and operated at the proposed site without undue risk to the health and safety of the public. A more detailed descrip tion of the regulatory review of reactor projects is provided in the enclosed pamphlet.

At the Camaission's request, the U. S. Geological Survey has been conducting a thorough field study of the geology of Bodega Head since early May. In addition, expert consultants have been retained to assist the AEC Regulatory Staff in evaluating Pacific Gas & Electric Capany's application with respect to the s6ismology of the area and structural design of the proposed

- plant. Final action. on the Pacific Gas & Electric Company application will not be taken until the report by the U. S. Go-ological Survey has been received and evaluated. Further, a h construction pemit will not be issued unless the Camission, j

f following a public hearing and a decision by the Atomic Safety and Licensing Board and consideration of all factors bear h upon safety is convinced that the facility can be constmed and operated at the proposed location without undus risk to the health and safety of the public.

9%

.p)g t+0dlC. ch{ "

.J 9

I

(

i E :

'M3

,gg Mr'. Melville Tatsapaugh.

g

., h,,,

d j

> :*p :~t gap The application by Pacific Oas & Elec' ric Company is before the fry ^ #

t Commission as a regulatory matter. The reactor project covered " '

by the application was conceived by the Company on its own initiative and is proposed to be entirely financed with private 4

capital.

No, financial or_other commitments by the Commission _ - l.. s.,,,,n are involv'ed.

j.

3,,,

y

+y

.~

You indicated that the AEC has. lowered' distance limitations from

]

active earthquake faults from i to of a mile. On February 11 4

• i p'oseb"he Ccamission published in the Federal Re dsler i.'p~r

'f'^',.

ljl961 t i

R4a~cto~r'51ts criteria" 10 CFR Part 100 for public comment. '

Section 100.10 (b) (1) thereof provided as follows:

3 l

1 "The design for the facility should confom to accepted building codes or standards for areas having equivalent earthquake histories.- No facility should be located l

1,

{

closer than to } mile from the surface location of a 4

l known active earthquake fault."

f In connection with finalization of Part 100 it was recognized that the statement "no facility should be located closer than t to 4 (underlined for emphasis) nile from the surface location of a i known active earthquake fault", constituted an ancmaly. Therefore, I

when Part 100 was made effective on May 13, 1962, the sentence was

} mile from theJur ace 16 cation JCi~linown a.pt_ive'eirthquak_e. fault."

changed to read "No facility should be located closer than one-fourtli 7 g,

~I believe you will agree that, in fact, no change was made in the

, minimum pemissible distance. Copies of Part 100.as orginally pro-( posed and in its presently effective form are enclosed.

You will note that the Statement of Considerations and Section 100.1 (a) of Part 100 make it abundantly clear that Part 100 is intended i

only as a gu_i_d_e for the evaluation of the suitability of proposed i

sites for stationary power and testing reactors, and that Section 100.10 (d) specifically provides that "where unfavorable physica1N <, c characteristics of the site exist, the proposed site may never-

}.'

\\

theless be found to be acceptable if the design of the facility includes appropriate and adequate compensating engineering safe I

guards".

Concerning your reference to construction work at Bodega Head site, l

please refer to the enclosed copy of the Commission's regulation, i

10 CFR Part 50. " Licensing of Production and Utilization Facilities".

Section 50.10 (b) protides that the constr"

. n of a proposed i

l o

3 l-l'

a J

(

f j

a q

i

..Mr.. b1ville Tatsapaugh '

k-

/

'l reactor may not begin prior to the issuance of 's con;truction. pew.it by the Atomic Energy CcarcJ.ssion.

You vill n 7te, however, tn.;c -

" construction" as defined 'in the above cited ecction, doet, no; include site excavation, construction of roadways, r:.12 road spurs, -

temporary buildings for. use in connection with ' construction etc.

- It is important to note in this connection that such ecnstruction9' as is penni.ssible prior. to the obtaining of a constructicm permit [

mrast.be undertaken at the' applicant's risk since there. can to no"

. assurance that a penni.t will be issued until the Cav:ission' has '

completed :its review of.the application 'and. favorable decision

$ s res:hed.

If there is any further infonaation which we can provide, please let us know.

l J

Sincerely yours, hl

/

~

Eber R. Price Assistant Director' Division of Licensing

'i and Regulation Enclosuress 1.

10 CFR Part 2 2

Pamphlet 3

10 CFR Part 100 (proposed) 4 10 CFR Part 100 5.

10 CFR Part 50 t

.l I

o 9

I f

4

-l

hgZileCopydv//

x. = G..f '

c' San Francisco

,;i'

.ff'.y i

September 2,1963

/

y C.-

Eber R. Price

' O. DJ,

,.\\

Assistant Director C

-[O 7

- ~ ' '

Division o.f Licensing & Regulation

%'?-

kfj

/ ;

j The United States Atomic Energy Commission

\\q %,% '? gjl

~

Washington 25, D'.C'. '

%(h 'y Sir:

1 This is in reply to your letter of August 1, 1963 with regard to the proposed PG&E nuclear powered plant at Bode-ga Bay.

In reference to my previous letter to President Kennedy I must. stand corrected on my statement that the AEC lowered the distance limitation from'l/2 to 1/4 mile.

However, I must take issue with the interpretation (and there is legal opinion on my side heroc) that Part 100,10 (d)'of the Reactor Site Criteria can overrule Part 100'10(c)(1) which specifically states: "No facility should be located closer than one-fourth mile from the surface location of a known earthquake fault."

This is one i

of the rare instances in which the authors of the latest Reactor Site Criteria (April 12, 1962) have pinned some-thing down and discussed explicitly the safety aspect in lucid terms.

While admittedl are to be used only as a " guide"y the Reactor Site Criteria

, still it would seem that some limitations must be pertinent.

If the 1/4 mile limitation does not apply to the San Andreas fault, which is the most active on this continent, then seemingly l

none of the reactor site criteria need apply, and this last publication was a waste of time, effort and money,

_LQ, j.s a sop to the unsuspecting.

As the criteria stand now,4

- ed

,<p [ g Q theyaresolooselywordedandambivalentwithregardj to safety as to be practically meaningless.

f 1

' On the subject of subsidy, your statement that "No 5

financial or other commitments by the Commission are )

/

involved" in the Bodega plant is simply not true

./

in the light of the federal publication entitled-Hearings before the Joint Committee on Atomic Energy lf.p),.

Table A-1}. 3 age 241 statea tha't the " estimated

-w average annual aspistance or annual difference lease as compared to private ownership" will.be between $376,100 and $641,000 On page 240, section 7, second paragraph we read, " Government ownership and leasing of special nuclear materials provides a form of financial assistance to private utilities to the extent the Government use

& f.'

a d,..

(

(

~

charges are less than the inventory carrying charges that i

would be necessary if the utilities had to finance the pur ~

chase of the materials that the U.S. Governmen."Also, I would like to point out t under the Price-Anderson Act (sponsered by the AEC) - passed as Public Law 85-256 by' Congress on September 2, 1957 assumes a liability of

$0,5 billion for each catastrophic nuclear accident.

The private insurance companies, after pooling their

• resources felt obliged to limit their coverage to a more

$60 million.

i Their report included the following state-ments:

"The hazard is new.

It differs from anything which our industry has previously been called upon to insure.

j

.... The catastrophe hazard is apparently many times as 1

great as anything previously known in industry and there-fore poses a major challenge.....We have heard estimates,..

s j

of catastrophe potential under the worst possible circum-stances running not merely into millions or

{ tens of millions but into hundreds of millions and billionso got dollars.

It is a reasonable question of public policy las to whether a hazard of this magnitude should be permitted

.... 0bviously there is'no principle of insurance that can be applied...where the potential loss approaches such astronomical proportions.

Even if insurance could be found, there is a serious question whether the amount of damage to persons and property would be worth the possible benefits accruing from atomic development."

.If these nuclear plants are so safe, why do the private insurance companies no limit their coverage?

Also it should be made clear that here too is another form of subsidy paid by Americans.

Possibly these subsidies to the private utilities are justified, but both the AEC and the PG&E are not justified in misleading the public that this oper-ation is entirely privately financed.

(Director of Research, Oak Ridge National Laboratory)A. M. Weinberg made a fitting conclusion to my point when he said:

"....the current prices represent a substantial governmental subsidy for the Bodega Bay plant."

As the third and most important point, I would like to bring to the attention of the AEC a matter which I did not discuss in my previous letter to President Kenned which, I think, should be carefully scrutinized. y, and ing the AEC publication TID-1141;1. Calculation of Distance In read-8 4 Factors for Power and Test Reactor Sites - March 23, 1902, I became curious as ~to what the actual exclusion area for the Bode,ga plant would be with its first reactor, e

b i

4

_2.__~_.~.P_

• ~ ~ " "

• a

i

(

l

(

on the site in the future'.-and what it wo

. plant is of an experimental nature (under earthS

^

a replaced byconditions, at least) in which the c quake since this s the untried pressure-suppression systemont!

certainly subject to= earthquake actioystem ' con is

, and i

the breakage of piping could als which' very logical that more than one and vand he n

and since of the reactor vessels could be ruptu e vessel, it seems ery possibly all,.

earthquake.

Site Criteria (AprilTherefore Part 110.11(b)(2) of thred in the even culations reflect this probability 12,1962) wo ld e Reactor u

apply, and the cal-about the conclusions here is that notThe disturbing dain U.C. marine biology laboratory b but the town of Bodega Bay as w lle in the exclusion area only would the the AEC of this e

Has'the will th ye eventuality, and if it has, w. PG&E notified i

• yta the AEC'againJ @koi ores its own rulings (as in the 1/4W hat course mile li'mitat' ion) for the benefit of th detriment of the safety of the c

and Sonoma County?

e PG&E and to the Certainly according to thedcalcul tcitize which are reasonable and logical PG&E plans to be realized it would 1

of Bodega Bay would have to be event, if the AEC permit a ions seem that the town according to the Reactor Site Crite i

" Residence *within the exclusi ually abandoned si Do the people in Bodega know th ton ar r a Part 100 prohibited."

dents shall be subject to're d lly be Indeed, this is a very tragic sit a

"resi-a y removal in case,of necessity"?

(not to mention the liveliho d) uation when the life can be snuffed out by the whim i

o executive in a city miles away,'of a power utilityof a town lik Finally company permissa,ble pric: to the obtainiI cannot rest assured th must be undertaken at the applicant'ng of a construction ruction as is-AEC ruled favora'bly on the Enrico Fenmi plant in Detroitconstruction perm,it of the s risk" since the residents an Committee n~d was recommended against by the Ad i the sponsor Mid~ctor Safeguards.which was opposed by o

~

spent so muc,h money on the inst llthe P3ifer Reactorlevelo v sory s

aware'that the PG&

a ation.

Company, had dollars on Bodega,.E has already spent close to tis the AEC

'and is the public to see a formance on the Enrico Fermi wo millio plant fiasco?

repeat per n Is the AEC i

I

3 1

?

4

}

'[

o considering'any changes in its rules that' encourage com panies to become so heavilyicommitted financially to pro-jects that it is almost impossible to turn down the con-14

-structica permits even in~the light of more important fac :

tors?.

extensive reform in the reactor safeguard criteria.I would I

hope the AEC will become alert to the. necessity for this I

requirement.before the 'ublic in v p

the whole atoms for, peace program,iolent reaction rejeets '

which in spirit is'a commendable. project.

The atom can be. a great aid to modern civilization, but' current developmental policies of the AEC cannot help but make.it a curse to present and: future generations".

Yours t y y, f-(hl/ % dd w Mel Tatsapau D

i hearing before the California Public Utilities < Rebuttal Commission - k. June 1963.

Application h.3808. Interim deciaion $537.

I 1

4 9

I

+

+

a e

I e

.1 i

.l

P[E.(lh (

Ms.

,.;r-- -

\\

\\

ha-f I; '

..~;-b:y %..\\,;;..yN.,.

';)gy.'G

~

I

,,7 D., ( j Os n'

y

\\ [KJ j('\\

-.c= w I

(

i 3,

3 w

i

\\ \\ >.

i f ;,

E'h q

r

..e ",39 / h

\\

3mUrb iiQ y;. \\QrS W J. m\\.. d (, t o,),

p)L'

?*

P

'k:?'j.'Mg' s

t

~

4 eet T

Qk.?)f$

q pj' & C.?\\ Q ~~!l~j. 9 Ql,n,? %

m U}l

.hL D

g

' Au i

hMo jh oQ:$$g, g'*.

u n, l l.)c.]a{j.(.3

g.. *t x

b..f.

\\ '~+' % '

y 4 l,[p";;, WVMi 13

\\

N',1,$2

\\

p g.

. gA yh*

u9%

w\\.j.M e..'[' 3}'. DJ

. pg 3,h. y D

D Mh.

'4-Om s'

S sg e

.?..,..,..,w'&>??jjh.i;

.$,1.ki o

,m g p ' M, s

n....

v 4,1

~

v o-

.'*su n.:

M

Q f .,

o,,Ooran Beac. ' * ". N'

,e.. K i,-

.s g

O

. 98%

h

+.

E 9-

.y'.i.\\'m.,<.

~

y o

D E

e a

y

' - tjv.

Os

.}

'g; EXPL N A TION w

gr I#:j/ ;' g,f **

j-D#

\\

QUA,TER 4ARY SAND 0 JNES g

T I

1 AND BE ACH DEPOSIT ;

l N

C *I b ""*, "'~

QUATERf ARY MARINE AND I

c,

. g;sycr k " 7 $ f,,

lQ*

" ^ "'" E """'C' E' oS'78 I

i (t,w /

N,,., t fKJf gt FRANCI CAN FORMA ION.

r OS f'

or QUAR DIORITE 1

I/2 i MILE ocg N"N CO ACT, DASHE WHERE g

1 l

9 Bode IN EFINITE CONTOUR IN RVAL 25 FlET Gr

.DASM MR f.

BASE MAP F M U.S G.S.

AP PROXIM AT, DOTTED N[*WHERECON CEOLOGY A TER JOHNSON, 6 3 AND KOENIC, l965

ALED,

\\

/

[

/'I

/

/

\\ Coologic map of 8 GDTMamGs s

.,on Andreas Foule sone.

. _. EACW R.EACTOR. 3 1,008. MWq LAMES E>A s G D O N lioo c. M W g _...._.

(t) thermal os oprosed to @) /Zf4CidC

-. I o o 8 ( a - S '2 5 a 7

_____.___.___._________._____fA

't

~

" f4%W - ' T'q:M ' S{ '

it?iX % ' **^a.,.dil*

$fTT

'EL',$?]-Q*&.T f

'fC. g g g 77< =*(3

' ' CWA p -qM.

se<

• 3pmo d

P' ROM, DATE OF DOCUMEPfTs

• /

%M DATE WECEtVED NO,8

• .-?

}

g 9/

27 anana riaas I

LT R.

MEMO:

REPORTS OTHER:

Qar. Tr:t::cIcc:, CalifcrLia x

' U' M fylg ORIGJ CC:

C THER:

x 6 zerozed ACT40N NECESSARY Q

CONCURRENCE O

part ^"8*E"50' NO ACTION NECESSARY O

COMMENT O

' v' CLA86er.:

POST OFFICE FILE CODE:

EtG. NOs I

DESCRIPTION: (Must Se Unclassified)

REFERRED TO DATE RECElvtD Sy DATE Lt.r. furr:1.shirg a recly to mar t'-1-63 ltr wita e to the propcyd Mrcr Edwardos 9-11 plant st Lodega 3;y; swung tnat t&s; is refed : Tor de< p arrd extenrive refcain

'f/eupal file ey - r1 ACT. uff ENCLOSukES:

Lv. tne rractor w ecuard eitarte.

L $' # '

W

-f m u, sur umw Lanewatat n e

% 11

~

w/sztre, for irto

).. Pr1ce:

9 11 w/ extra, for info i

RE M AR KS:M E nirtritmtion: 1 - ferir.a1 fi]s l

1

.W File 1 - AEC mR l

. & su W u.

vsaa. m eni ma. oenes.

u.s. noxic ruznar comussrow MAIL CONTROL FORM roan Aze-ases na-mie.o (840) u.- - >w.

1 l

a E

L__________:_____._

. T: - -

~ :-

~~~

a