ML19260A669

Comments on Safety & Environ Factors Re Proposed Westinghouse Application.Opposes Loan to Filipino Govt to Finance Nuclear Plant.Nrc Obliged to Study Safety Health & Environ Impacts of Facility

ML19260A669
Person / Time
Site:	05000574
Issue date:	11/19/1979
From:	Brendan Collins, Cowap C, Jefferson K AFFILIATION NOT ASSIGNED
To:	NRC COMMISSION (OCM)
References
NUDOCS 7912030066
Download: ML19260A669 (6)

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1 INTERFAITH CENTER ON CORPORATE RESPONSIBILITY

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A Sponsored Related Movement of the National Council of Churches 475 Riverside Drive e Room 566 e New York NY 10027(212) 870 2293

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Written S tuement - I l3IE Submitted to .w.n Q

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The Nuclear Regulatory Cocsission ((. ., . . . . -

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Regarding Safety and Environmental Factors "h Related to Proposed Fxport License for the Westinghaus Reactor and luterials on November 19, 1979 by Barbara H. Collins Regina Murphy, SC

• World Division Sisters of Charity of New York Board cf Global Ministries United Methodis t Church Lin Neumann United Methodis t Church Of fice Chris Cowap for the United Nations Economic Jus tice-Division of Church & Society Rev. S. Garry Oniki National Council of Churches Office for Church in Soc'ety United Church of Chris t Rev. Kim Jefferson National Division Sr. Arlene Woelfel Board of Clobal Idnis tries Eighth Day Center for Justice United Methodist Church (A coalition of ten Roman Cattiolic religious orders located in Chicago)

Martha Lind.g Social & Ethical Rei.porsibility Sr. Patricia Wolf, RSM in Inves tment Program New York Coalition for Responsible American Baptis t Churches Inves tme lt W ry Ann McGivern, SL Richard E. Ullrich 1ddwes t Coalition for Responsibla Office of Jus tice and Peace Invest =ent The Marianis ts William Millerd, SJ Interfaith Coalition on Energy j f{ff contac t: Beth Lerch Energy Program Director i

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ICCR (212T 370-2936 7 912080 Continuing the work of the Coredrate fatormation Center and the Intertaith Comn'attee on SocialResponsibutsty in Investments

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As church organizations concerned with corpora te and governmental responsibility, we oppose the proposed export of Westinghouse reactor equipment and fuel to the Philippines. Many of our organizations have energy policies which raise serious questions about further growth in the commercial nucle. r energy indus try. The

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churches are guided in their energy policies by values based on concepts of creation, stewardship and hope. In our view, these values are useful guidelines in making policy decisions about how to meet the profound challenge of providing and sharing limited amounts of energy without poisoning the environment and ourselves. In building our energy systems, we should exercise dominion, not domination over people and the land.

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As stated in the National Council of Churches policy statement "The Ethical I=plications of Energy Production and Use," our criteria for mcking judgements on energy policy are the following: Sa fe : protective of the human and natural environment, and not threatening irreversible damage. Aporooriate: most nearly matched to the society and the purposes to be served. Aporooriate to Human Nature: not requiring infallible performance from humans or machines. Flexible, c..oable of adapting to unpredictable eveats such as an earthquake or volcanic eruption. Non-Violent: difficult to use indirectly as a weapon; for instance, not able to be made into a bomb.

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While we recognize that the task of the Nuclear Regulatory Commission differs in many respects from that of the church community, we suggest that the National Council of Churches' criteria for judging energy technologies could be used by the Nuclear Reta > tory Commission in its deliberations on whether to grant the license.

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On the basis of the biblical imperative to count the cost of present decfsions in ter=s of their impact on future generations, we oppose increased reliance on coc=ercial nuclear energy. In particular, the political, geologic, seismologic, technical and demog; 3 hic situation regarding construction of the proposed Westinghouse reactor in the Philippines calls us to speak out against the granting of an export license. As churches, we are called to speak on behalf of voiceless neighbors who may be subject to the risks of an energy technology without being conculted. We recognize that since 1972 martial law in the Phiippines has effectively silenced public participation in for=u-

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lation of energy policies. The majority of Filipinos are indeed voiceless. We support U.S. policy which seeks to share energy technologies with the Philippines, but without promoting capital-intensive, potentially harmfal technologies sucn as commercial nuclear reactors. We support U.S. cooperation and aid in Filipino efforts to develop and use appropriate energy technologies based on renewable resources such as anthanel from sugar cane, geothermal, ocean, low-head hydroelectric,' solar and wind. We oppose the current use of tax dollars to fic nce the U.S. Export-Import bank loan of over $600 millicn to the Filipino government to finance a potentially des tructive nuclear power plant. 1464 336

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We inhabit one world and are all human beings with the same requirements for survival. Accordingly, we implore the Nuclear Regulatory Commission to accept the ethical imperative that in its . deliberation on licensing the Wes tinghouse export it has not only thf

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legal Congressionally-mandated authority (as given by the Nuclear Non-Proliferation Act of 1978), but also the obligation to examine the resulting health, safety and environmental impacts on the Philippines. We believe that consideration of health, safety and environmental issues ought to reflect the same concern for the Philippines and for the Filipino people as if the application were for a domestic reactor license. For example, it is unlikely that the NRC would license a domestic plant which would be sited near an active volcano! We believe that the Nuclear Regulatory Commission should hold open, oral hearings shortly following its receipt of written testimony, in order to encourage full participation of both proponents and opponents of the export license. The following factors argue undeniably against granting of the license: The Report of the President's Commission on Thrae Mile asserts that it is impossible to guarantee the safe operation of nuclear reactors. The Philippines reactor would be sited on the slope of Mount Natib, a Philippine volcano (only 6 miles from that active volcano) and within 90 miles of three othar active volcanos (Washington Pos t article, October 2, 1979). Tne site, Napot Point, is also likely to experience earthquakes more severe than the Westinghouse plant is designed to 1464 337

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e withstano, according to an International Atomic Energy Report. In the event of an earthquake, rupture of the pipes which connect elements of the plant could result in a meltdown of the reactor core, which would kill thousands of people. Given the s trong possibility of earthquakes and volcanic

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eruption which could damage the plant and cause loss of control over operation of the reactor, explosion, and/or releases of radiation, the Philippines reactor would be sited under some of the worst possible conditions. There would be an ever-present threat of such accidents for 8 million Filipinos living in Manila (only 45 miles west of the site) and for the 261,000 Filipinos living in the Bataan peninsula, and for the 27,000 American service personnel living on Subic Naval Base and Clark Air Force Base. Now that the President's Co= mission on Three Mile Island is telling us that no reactor can be guaranteed saie, we should take heed of the possible catastrophe which could result from approving the export of the Westinghouse nuclear reactor and materials to the Philippines. We should be moved by a sense of reverence for life to reject the application for an export license. Nuclear reactor technology is also inappropriate in light of the problem of nuclear was te s torage. Even assuming the eventual discovery of a means to dispose permanently of nuclear was te, spent reactor fuel rods still could not be permanently s tored in the Philippices since the country is located in an active volcano and earthquake belt. We see a number of questionable political practices that have led to the situation where serious consideration is being given to approval to export of a reactor to be built near several active

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volcanos. One is simply the opportunism of Westinghouse in proceeding with the project thanks to the fact that the Marcos government favors the project and since 1972 has withheld from Filipinos the freedom of speech, press, right of assembly and other democratic rights. Westinghouse has received only one order for a domes tic. reactor since

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1976, making the Filipino market crecf al. Such disregard for human life for the sake of making a profit in a country which has no public forum for opposition to nuclear energy is deplorable. , While the State Department approved the export on prolifer-ation grounds, it nonetheless outlined the serious safety and environ-mental dangers. The Nuclear Regulatory Commission is the appropriate agency to evaluate thoce health and safety risks. The MRC was created to exercise independent judgement. We urge you to consider those risks and reject the Westinghouse application for a nuclear reactor and materials export license, in the name of respect for the lives of millions of Filipinos . We look forward to presenting our views to the public in an open, oral hearing. 1464 339

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