ML20062E058
| ML20062E058 | |
| Person / Time | |
|---|---|
| Site: | Columbia  |
| Issue date: | 11/15/1978 |
| From: | Darby C HANFORD CONVERSION PROJECT |
| To: | |
| Shared Package | |
| ML20062E059 | List: |
| References | |
| NUDOCS 7812040072 | |
| Download: ML20062E058 (28) | |
Text
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
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/J BEFORE THE ATOMIC, SAFETY AND LICENSING BOARD $ h.,r[*-
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In the Matter of )
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WASHINGTON PUBLIC POWER ) Docket No. 5,0-397-0 ~
SUPPLY SYSTEM )
) AMENDED PET ' F0 '
(WPPSS Nuclear Project No. 2) ) LEAVE TO IN ."
// f f f WM Susan M. Garrett and Creg Darby, pursuant to the Commission's notice dated July 26, 1978 and the Order relative to petition for leave to intervene dated October 11, 1978, submit this Amended Petition to Intervene (11-on their own behalf, and (2 ) as authorized representatives of the Hanford Conversion Project. '
Petitioners allege: 7 I. NATURE OF PETITIONERS ' RIGHTS ',$
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F~. u '1 Petitioners request for leave to intervene constitutes j a de facto motion to rsopen issues. Regulations permit thisr,
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if there exists significant and important additional evidence >
which substantially affects conclusion (s ) reached at an earlier g
b stage, or if there is other good cause. 10 CFR 2 503. The Atomic Safety and Licensing Appeal Board had held that early findings are" subject to reconsideration should supervening develonments or newly available evidence so warrant."1 NRC at545 Further, the Appeal Board has held that the need for careful, thorough examination of critical safety and environmental issues outweighs the need to expedite the decision-making process. Cleveland Electric Illuminating Co. et al. (Perry Nuclear Power Plant, Units i and 2 ), ALAB-993, 2 NRC 730, 737 (1975). The bulk of the reconi of the WNP-2 project was 781204 0072 G
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developed prior to 1973; in the intervening five years a wealth of evidence has come to light which significantly ;
modifies material in the record. This new evidence is appropriate to raise at operating license s tage. Georgia Power Co. (Vogtle, Units 1 and 2 ) ALAB-291, 2 NRC 404, 469.
P Had this evidence been considered initially, different con-clusions would have been reached. Kansas Gas and Electric Co.. et. al. (Wolf Creek Generating Station, Unit No. 1),
ALAB-462, slip op. p.36, (3/9/78). Some of the evidence to be presented by petitioners is outlined and discussed under the Contentions section of this amended petition.
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II. PETITIONERS' INTERESTS A. Petitioner Susan M Garrett resides at 632 SE 18th St.
4 Portland, OR. She uses the Columbia River for recreational purposes, including swimming, fishing and boating; eats fish.
from.the Columbia Piver; consumes produce and meat grown with water from the Columbia River; consumes produce grown, live-stock raised and dairy oroducts from livestock raised within 50 miles of the nanford 5eservation; and consumes livestock and dairy products from livestock red with produce grown within 50 miles of the Hanford Reservation and watered with Columbia I
River water. She is of childbearing age and is a potential
! mother.
B. Petitioner Creg Darby resides at 2425 SE 24th, Portland, OR.
He consumes produce grown with water from the Columbia Piver; consumes produce grown and dairy products from livestock raised i l
within 50 miles of the Hanford Reservation; and consumes dairy products from livestock fed with produce grown within 50 miles
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of the Hanford Reservation and watered with Columbia River water. He eats mainly organic foods. He is of childbearing age and is a potential father.
D. Petitioner Hanford Conversion Project has a business address of 4312.S.E. Steele, Portland, OR. 97215. It is a coalition of reeresentatives from anti-militarist and anti-nuclear organizations from all parts of Washington and Oregon.
Represented organizations are the American Friends Sservice committee, Clergy and Laity Concerned, Yakima Nuclear Study t
Group, Trojan Decommissioning Alliance, New American Movement, Mobilization for Survival, Crabshell Alliance, Fellowship of
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neconciliation, Center for Energy Research, Live Without Trident, and Power Research droup. Individual members of the Hanford Conversion Project include the persons named in I
affidavit attach =d to original petition to intervene, in-corporated by reference herein, plus additional persons whose affidavits are attached hereto or will be mailed under sepa-rate cover as soon as available. Most of these members, along with their families, use the Columbia River for
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recreational purposes, including swimming, fishing and boating; eat fish from the Columbia River; consume produce and meat grown with water from the Columbia River; consume produce grown, livestock raised, and dairy products from livestock raised within 50 miles of the Hanford Reservation; and consume livestock and d_Ary products from livestock fed with produce grown within 50 miles of the n anford Reservation.
Some of these members eat only organic food. Some of them have children and some are of childbearing age. Certain of the members have additional particular interests , as follows:
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- 1. A.C. Rollo leopy of affidavit, lotter and tax assessments attached as petitioners' attachment D) is an attorney in Oceanside, Oregon. He owns land at at 3, Box 3570, Kennewick, Washington, about 10-15 miles west from the Hanford Reservation, near the Columbia River. On this land are two residences, which he rents out. Part of his land is used by the tenants for c6mmercial farming and raising of livestock. The residences are dependent on well water for human consumption and irrigation.
- 2. Ruth Long( copy of affidavit forthcoming) resides in Richland, Washington aporoximately 12 miles from the Ehnford Reservation. She lives with her family, including 2 minor children, and is suonorted by her husband who works in the Richland area.
Further affidavits of members of the Hanford Con-version Project will be provided under separate cover.
III.HOW PETITIONERS' INTERESTS MAY BE AFFECTED BY THE RESULTS OF THIS PROCZEDING O In the event apolicant is granted an operating license, petiteners would be affected in the follmiind ways.
A. The operation of the plant would endanger the health and safety of all petitioners by its damaging effect on the water temperature and water quality of the Columbia River, resulting in the killing and polluting of the fish; the polluting of the river making it unsafe for swimning and boating; the polluting of the water making it unsafe for the irrigstion of crops consumed by petitioners and by livestock
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I consumed by petitioners; the polluting of the water making it unsafe for drinking by livestock consumed by petitioners.
B. The operation of the clan $ would endanger the health and safety of all petitioners by its possible con-tamination with radioactive materials of the atmosphere within at least 50 miles of the olant, making the air unsafe for l
petitioners to breathe and contaminating the livestock who
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i breathe it and are consumed or have their dairy products consumed by petitioners.
C. The coeration of. the plant would endanger the health ,
() and safety of all petitioners by its possible contanination with radioactive materials of the soil within at laast 50 ;
miles of the plant, makingthe soil unsafe to grow crops for consumption by petitioners and by animals who are consumed or have their dairy products consumed by petitioners.
D. Those petitioners with young children would be further damaged in their inability to provide a clean and safe living environment for their children.
() E. Those petitioners of childbearing age would be further damaged in their inability to protect their future children from possible genetic damage and to assure a clean l living environment for their future children.
l F. The pollution of food sources and the killing of the fish herein before mentioned would further damage petitioners i in that the sources for their food would be limited, causing increases in prices, particularly for those petitioners who eat only organic food.
G. Those petitioners who have jobs in the area of the
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I l plant would b3 further damagcd in that a major plant accident
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in the area would necessitate evacuation and the loss of their jobs; additionally, possibility of a major accident or lesser contanination by the plant might cause people to move from the area causing loss of businees and consequent loss of jobs.
H. Those petitioners who own property in the area of the plant would be further damaged in that the property value of their land might decrease. making it difficult to sell and to rent and causins decrease in rental or sales value.
I. Those petiti.ners who raise crous or livestock in the area of the nlant would be further danaged in that
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release of radioactive materials from the proposed reactor would occassion harm to the produce and livestock and make them unfit for sale and consumption.
J. Petitioners would be particularly injured because radioactive effects are additive and the Hanford site includes the N-reactor; Purx olant which may be reopened in the next yeart and extensive nuclear waste storage in addition to the pronosed WPPSS 2 reactor.
IV. SPECIALIZED EDUCATION & PERTINENT EXPERIENCE OF PETITIONERS A. Petitioner Susan Garrett received a law degree from Northeastern University School of Law, Boston, Mass., in 1975 She has worked since the fall of 1977 for the Center for Energy Research, Portland, Oregon, researching nuclear power safety and econonic issues. On March 16, 1978, she was ac=
cented as an intervenor in In the Matter of the Portland General Electric Co. et. al. , NRC docket No. 50-344(spent fuel storage). She participated in extended hearings in that 1
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case during Spring 1978, cross-examining witnesses and presenting experts on need for power issues involved in that proceeding and on other issues, including the safety hazards of the pronosed expansion. As plaintiff, researhcer and drafter, 1
l she brought lawsuit against Portland General Electric Co.
in the U.S. District Court for the District of Oregon in -
mid-1978, claiming that an Environmental Impact Statement (EIS) was needed to assess the effects of long term storage of scent fuel at the Trojan nlant and that modifications to allow on-site storage were impermissible without an EIS.
() Among other contentions, she raised need for power issues in that proceeding.
B. Petitioner Creg Darby has a B.A. degree from Reed College; he has taken courses in math and physics; he has studied safety and economic issues of nuclear power and of nuclear waste issues; he is an independent student of philo-sophy, with a special interest in the philosophy of science.
C. Pettioner Hanford Conversion Project through its member organizations and individual medbers has extensive
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information and access to information on safety and economic T
issues of nuclear uower in general and this croposed plant in particular. HCP has fund raising abilities and abilities to finance transportation and witness fees of expert witnesses.
V. WITNESSES AND OTE R ASSISTANCE A. Petitioners have the intention and ability to call expert witnesses to testify. Hanford Conversion Project has funds and fund-raising capacity as described in para 5rach IV C . herein. In particular, and in addition to other wit-L_
, ,o . .., . coer nossoa, petitionars will seek to call as witnesses the follow-ing persons:
- 1. Carl Friedman. Mr. Friedman has been studying the power situation in the Pacific Northwest for the past year.
He has conferred with experts at the Bonneville Power Admini-stration and the Oregon Department of Energy. He has assisted intervenors with their preparation of the Pebble Springs case. (In the Matter of Portland General Electric Co. , Pebble Springs Nuclear Plant, Units 1&2 ). He was certified to give expert testimony regarding need for power issue at the Trojan spent fuel case. (In the Matter of "
Portland General Electric Co. , Trojan Nuclear Plant, NRC docket No. 55-344 (1978) (spent fuel storage). He assisted Oregon Department of Energy director Lionel Topaz with research on need for power in the scent fuel case.
- 2. Robert Murray. Mr. Murray has been appointed to head Seattle City Light which serves the electricity nos ..
of the city of Seattle. He participated in the Skidmore, Owings, and Merrill study for the Bonneville Power Admini-
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(_)' stration which indicated that more efficient use of electri-city could save this region as much as one half'of the growth forecast by the region's utilities.
B. Petitioners have the volunteer assistance of several attorneys, including Constance Crooker, David Shapiro and Doreen Nepos, all of Portland.
VI. OTHER MEANS AVAILABLE TO PETITIONERS j Petitioners have no other means available to them at this time to protect their enumerated interests.
F VII. EXTENT TO WHICH PETITIONERS' l INTERESTS WILL BE REPRESENTED BY :
EXISTING PARTIES [
No other oarties will adequately represent petitioners' interests. l VIII. CONTENTIONS ;
PREFATORY COMMENTS Leeway is permitted to the Board in judging the suffi-ciency of petitions (and, by implication, contentions) where i lay persons with limited technical and legal expertise are O
t concerned. The Appeal Board stated the following On dicta from Kansas Gas and Electric CO. ,and Kansas City Power and Light Co.. (Wolf Creek Generating Station, Unit No.1. ,
(ALAB-279, 1 NRC 559 at 576-7 (6/30/75): ;
We can appreciate the difficulties a party may have where it must express in a petition to intervene tech-nical matters beyond the ordinary grist for the legal i mill. And we empathize with petitioners who must of f necessity proceed ero se, or with counsel new to the i field (if not also to the bar). In those circumstances ,
the Commission has for good and sufficient reason allowed
(~') us and the licensing boards leeway in judging the suffi-V' ciency of batervening petitions. / Citing Dignen, AEC t Rules of Practise ,16 Atomic Energy L.J.3, 9-24(1974)./ ,
That the merits of the contentions are not at issue has .
I been well established. Section 2.714 "does not require the ;
petition to detail the evidence" which will be offerred in ;
support of each contention. Mississioni Power and Light Co.
(Grand Gulf Nuclear Station, Units 1 and 2), ALAB-130, )
6 NRC 423 at 426 (6/19/73); Ducuesne Light Co. (Beaver Valley :
Power Station, Unit 1), ALAB-109, 6 AEC 243 at 244-5 (4/2/73):
" . . .in holding that. . contentions fulfill the requirements of Section 2.714(a), we do not pass upcn whether they are i
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maritorious..."; Duke Powar Co. (Catawba Nuclear Station, Units 1 and 2 ), ALAB-150, 6 AEC 811 at 812 (lo/2/73). A contention may be admissible " irrespective of whether resort to extrinsic evidence might establish the contention to be insubstantial." Alabama Power Co. (Joseph M. Farley Nuclear Plant, Units 1 and 2 ), ALAB-182, 7 AEC 210 at 217 (3/7/74).
Rather,".. the intervention board's task is to determine, I from a scrutiny of what appears within the four corners of the contention as stated, whether (1) the requisite specificity exists; (2) there has been an adequate delineation of the basis for the contention; and (3) the issue sought to be raised is cognizable in an individual licensing proceeding." l Alabana Power, suora, at 216-7. The requisite specificity is that which is " reasonable." Grand Gulf, suora, at 426.
Moreover, a contention may,not attack the rules and regula-tions of the Commission.10 CFR 2.758(a).
The Board must be " satisfied .'ith respect to each con-tention.., that a genuine issue in fact exists." Duke Power, suora, at 812 Clarity and precision should be adequate to O
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insure that the applicant does not have to " speculate about what a pleading is supposed to menn" such that it does not have a fair chance to defend itself. Wolf Creek, suura, at 576.
The ".. office of a cleadind is to give notice.. of the ultimate facts and matters of law asserted." Alabana Power Co. (Alan R. Barton Nuclear Plant, Units 1,2,3 and 4),
L3P-75-32,1 NaC 612 at 615 (6/13/75), emphasis added. We argue that the contentions noted above meet these cri-teria, as will be discussed in more detail infra.
,n .. . - 11 Moreover, even where a contention is not " as narrow l or specific as it should be before embarking on an evidentiary ;
hearing... where ab issue, clearly ocen to factual adjudi-i cation, can be discerned somewhere within the four corners '
of the submitted pleadings, the Board is not free to disregard it." Tennessee Valley Authority (Browns Ferry Nuclear Plant, i i
Units 1 and 2 ), LBP-76-10, 3 NRC 209 at 221 (3/11/76). [
CONTENTION 1: NEED FOR POWER f Neither the Applicant nor the NRC has prepared a rigorous j exploration and up-to-date, objec tive evaluation of the l l
() alleged need for power to be generated by WNP-2 This in-adequate and deficient analysis (1) violates the National ;
i Environmental Policy Act and the Commission's regulations, and (2 ) results in failure to demonstrate adequate financial
' qualification of the Applicant to engage in the activities to be authorized by the Operating License. These deficiencies result in noncompliance with criteria for issuance of an Operating License as outlines in 10 CFR 50 57.
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'3A5I3 The EMP-2 need-for-power analysis is based concletely ;
i on the West Group forecast of growth in energy demand. The r
West Group forecast is compiled, with the exception of inputs ,
from a very few utilities, of projections from member utilities !
which utilize a straight trend-extrapolation method of fore-casting. Since the trend of growth in electricity demand was fairly high in the 1950's and 1960's, this practise has resulted in serious and consistent overforecasting since the
i carly 1970's, when the need-for-power analyris for WNP-2 was first developed. The ER asserts at 1.1-10 that Wes t f
Group has a "long-term record of reliability in forecasting.' ,
The reality is that while forecasting by West Group may have been reliable in the decades prior to the 1970's, when growth rates were 7.7%(1950's) and 7 5%(1960's) (ER Q 8.1), reliability fell as sharply as did the growth rates beginning in the early 1970's. Betwen 1973 and 1976, actual load growth was only an .
average of about 4%(calculations from ER Q 1.1). Although the WNP-2 ER includes figures from which the following con-clusions may be drawn, the conclusions and their imp 1.ications 04 are nowhere discussed or factored into any need-for-power analysis.
(1) West Group overprojections in 1971 resulted in overforecasting equivalent to power produced by over two nuclear olants (1315 avg. MW; see ER Table 1.1-2(n). West l
Group's projections in 1972 were only very slightly more accu-i rate, resulting in an overforecast of "only" 1183 MW, slightly :
less than two nuclear plants. (See ER Table 1.1-2 (a). ) (WNP t is exnected to supoly about 600 av. MW per year when operational.
(2 ) West Group forecasts automatically assume that e
" critical water" conditions exist every year; forecasts are based on this assumption. (ER 1.1-3) "
Critical water" assump-tions assume that for 42 ncnths, drought conditions as bad as j the worst recorded conditions in history occuf in the Northwest; the probabability of such conditions reoccurring for such a ,
period is in fact only about 14 (In the Matter of portland l
! i l General Electric Co. , et al. NRC docket no. 50-344 (svent )
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fuel storage), TR. 6045). For. the purposes of the West Group forecasts, therefore , West Group assumes that "no water is spilled past / hydro / generating facilities" except for the run-of-the-river dans. (ER 1.1-3) Loads above the critical period firm resource capability are relegated to a "nonfirm" or "interruptible" status, (ER1.1-4) and are not counted in forecasts. These amounts are massive; for example, during calendar year 1976, over 21,6 million kwh of nonfirm energy were available to the region's consumers from the Bonneville -
Power Authority (BPA Generation and Sales Statistics, 1976, p.10), which regulates most of the region's hydro. This O
amount was over 25% of all energy sold by BPA in 1976, but was automatically excluded from any West Group forecast for 1976.
BPA narkets over half of all energy sold in the entire region.
(U.S. General Accounting Office, "Rdgion at the Crossroads-the Pacific Northwest Searches for New Sources of Electrical Inergy," 8/10/78, EMJ-78-76 p1 p. 3.7; hereaf ter "GAO" ) This may help exclain why the West Group forecast consistently forecasts " deficits" despite the region's glut of power; C' in 1976, a total of over 16 million kwh was sent outside the region to California. (3PA Generation and Sales Statistics, 1976, p. 10)
The combination of West Group's tendency to overforecast clus the hyper-conservative use of a " critical water" assumption has resulted in the overbuilding of the equivalent of over two nuclear ulants in the region, while West Group continues to predict phantom " deficits." The effect of this masking of resources can be seen in the following example: The Director
of the Division of Economics at the Federal Energy Regulatory Commission recently told the NRC that ". ./f/ or 1986-87, !
the reduction in estimates of energy load contained in the i
1978 / West Group / Forecast represents a reduction of 1,393 MW l of energy compared to the 1976 Forecas t. . ." He alleges, i however, that such reduced load estimates are not significant :
since " energy deficiencies nevertheless are projected to j occur in every year through 1988-89." (Affidavit of Dr. Gorden i T.C. Taylor, dated 4/28/78, NRC Bocket No. 50-514) l Use of the " critical water" assumption in forecasting ,
and ulahning system resources is entirely discretionary ,uth ;
the West Group member utilities. (ER 1.1-3,4) According to l former Oregon Department of Energy Director L.V. Topaz, i
h "BPA's water management policies are extrenely con- !
servative, maintaining a multiplicity of safety margins to absolutely assure its firm power commitments. Al- i though secondary /nonfirm/ power generation had proven to be an extremely valuable resource, its provision is not a management priority. The 3PA system could increase its total net generation by giving a'ditional priority to secondary availability in situations where overpro-tecting its firm power commitments results in subsequent ,
spillage of water without secondary power generation !
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benefit. The system could, for example, wait until the second year of a ' critical water' situation before cur- l tailing its secondary generation... Responsible changes ;
in SPA water management policies could yield considerable !
benefits..."
(In the Matter of Portland General Electric Co. et al. , NRC '
Docket No. 50-344, Testimony of Lionel Topaz, April, 1978, Exhibit 8, pp. 12,13.)
l There is no analysis by the Applicant or the NRC of the im- !
plications-or even of the existence- of this extremo con- I servatism in the forecasting on which alleged need for WNP-2 power relies, in either the original ER or in the
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" updates" of !!ay, 1978 An examination of the ER's past clains of need and the f
present realities rev als a disparity which can be exclained ,
by the availability of hydro to the region in excess of West j Group projections. The ER at 2 5 1-3 claims that no other power from outside the reg 2on will be available in 1978- !
power available inside the region from BPA is never considered. l The realities are that WPPSS received the following amounts of hydro energy fron BPA from 1976-78: i 1976 24,482 nwh (Source: BFA Generation and Sales l 1977 (cY) 28,993 mwh Statistics, 1976, p.5; telephone 1977 (?Y) 26.592 mwh communication of 11/9/78 from 1978 44,139 mwh camilla Downing, BPA, Branch of i Customer Services) l (3) Since the early 1970's, when construction on WNP-2 !
first began, a number of responsible organizations have pro-duced more un-to-date forecasts which (1) reflect use' of econonetric techniques in forecasting and/or (2 ) incorporate l electricity which may be " generated" by increased use effi- !
i ciency. Although the ER " update" mentions these factors in i passing, there is absolutely no discussion of how they may L potentially affect evaluations of need for WNP-2 power. There i
is extensive discussion of the general goals of the Hydro-l Thermal Power Program and operation of the region's power ,
system, but no snecific quantitative evaluation of need for the specific need for WNP-2 power beyond conclusory assertions, and reliance on West Group's projections of phantom deficits. ;
West Group estimates a near tripling of electricity usage by the region by 1995. (ER Table Q 8.1-1) If West Group's pro-jections of 4.5% load growth are accurate, the load require-
, - -- -y- . -y -- y.- - - . - --
i ments they anticipate would require the equivalent of over l 35 new nuclear plants by the year 2000 (computations from i
figures in GAO study, p. 6.25). This projection is disputed by nunerous other responsible forecasters, some of which have l predicted in recent years that load growth can be halved or .
cut even more by appropriate and nonmandatory efficiency ;
measures which will occur because of rising electricity prices in the Northwest.
(a) The Northwest Energy Policy Project (1977-78) sponsored I
by the governors of the Pacific Northwest states, outlined
() circumstances under which growth rates as low as 1.43% could i be expected. Even NEPP's " moderate" growth scenario forecast a rate as low as 2.93%. ;
(b)'The Skidmore , owings and Merrill Study performed for BPA in 1976, " Choosing an Electrical Energy Future for the ;
Pacific Northwest," demonstrated that more efficient use of .
electricity alone could save the region as nuch as one-half of the growth forecast by West Group.
() (c) The Oregon Denartment of Energy in its 1978 Annual Report projected an average growth rate in Oregon of 2.8% ,
in 1977-97. The results of this study were based primarily f
on the econometric concept that as electricity prices rise, l new and better ways to conserve energy will be found and used.
Growth rates forecast for Oregon are relevant, since WPN-2 l
energy will go to BPA, which sells to all Oregon utilities. ld (d) The U.S. General Accounting Office issues in August, 1978 a study titled," Region at the Crossroads-the Pacific Northwest Searches for New Sources of Electric 2aergy."
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(EMD-78-96. 8/10/78) The GAO study found that assuning moderato economic growth, without power curtailments or rationing, conservation could result in surplus electricity (in mezawatt f years) equivalent to at least three nuclear olants by 1980 i
and through the year 2000 (GAo s tudy, Fig.6.4) ,
(e) Dr. Richard J. Timm, past supervisor of the Energy Planning Program of the Oregon Department of Energy, pre- :
pared testimony presented before the NRC in December,1977 l which asserted that the West Group area would enjoy a surplus [
of 6651 MW (peak) in 1979 without the input of an additional l
I nuclear plant equivalent to that of WNP-2(961MW); the surplus !
increases each year, to a high of 13,782 MW (peak) in 1986-7. l (In the Matter of Portland General Electric Co., et al., Docket No. 50-344, Testimony of Richard J. Timm, Dec. 23, 1977, Schedule 14.) [
(f) The Natural Resources Defense Council projected in 1977 possible growth rates in electricity usage for the l l
Northwest as low as 47% <
(g) M erg 1990, a study precared by Seattle City Light which resulted in the city's decision to bbandon plans for ;
participation in two nuclear plants, estinated a baseline growth forecast in electricity use of 3,7% from 1974 to 1990. ,
(Energy 1990, p. 3-8. ) i (h) Recognizing the downward trend in the growth of electricity use, the International Atomic Energy Agency has cut its forecasts of world demand for nuclear power in hn1r since D
1970. In 1970, the Agency forecast a world demand of 610,000 MW; in 1976, the forecast was only 350,000. (U.S.
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House of Representatives Report No. 95-1090, " Nuclear Power Costs," 23rd Report by the Committee on Government Operations, 4/26/78, p.34)
Most of the above information regarding impeaching earlier and present West Group assessments of need for power have been generated only recently, within the last several years, and af ter the proceedings in this matter which resulted in the construction permit for WNP-2 This information is ;
certainly significant and important additional evidence t which substantially affects conclusions reached at an earlier stat;e in the proceedings regarding alleged need for WNP-2
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power. Applicant's attempts to " update" this information are nonspecific, general discussions of West Group regional ,
forecasting policy and organizational structure. To the extent ,
that any quantitative information is presented, reliance upon ,
West Group's forecasting is comnlete; there is no attempt to relate general West' Group data to this specific project, except through conclusory and unsubstantiated allegations of need for ;
WNP-2 cower. The ER asserts: "... accodding to the latest
(} l West Group Foresast, the power output of the unit will be fully utilized when it connences oceration." (ER at 9 1-1)
But the Apolicant's own information impeaches this assertien: ,
While the average availability factor (the percentage of time the plant is available for use) is expected to be .67, the average capacity factor (the time the olant is actually used) is pro-jected as .59. (ER responses to NRc question 8.7 of 9/6/77)
The ER makes it clear that this discrepancy is due to probable availability of hydropower, during which periods the plant'will not run. (Resconse to Q. 8.7, suura) Moreover, both of these
l' factors can be expoeted, according to the ER, to " deviate
! substantially" from the quoted estimates by as much as 15 to i 20 coints. (ER response to Q. 8.7 at p. 84). This means that I actual nlant availability could theoretically be as high as j
l
.85, while actual plant use could be as low as .40. This is
! hardly assurance of " full utilization."
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CONTENTION H: ALTERNATIVES I Neither the Apolicant nor the NRC has prepared a rigorous j exploration and up-to-date, objective evaluation of altema-tives to the construction or operation-immediate or eventual-I -
t of WNP-2. This inadequate and deficient analysis (1) violates the National Environmental Policy Act and the Commission's i regulations , and (2) results in failure to demonstrate i adequate financial qualification of the Applicant to engage I in the activities to be authorized by the Ooerating License.
j These deficiencies result in nonconpliance with criteria for issuance of an Operating License as outlined in 10 CFR 50 57.
BASIS i
Electric power rate; nP Northwest are the lowest in the .
I entire U.S. (GAO study, flg.2 3) Residents of Seattle used over j twice as much electricity as Chicago residents in 1976, but paid only one-third of what Chicago residents paid, (GAO study, figs.
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2 3 and 2.4)
One of the reasons residential use of electricity is so high in the Northwest (one-third of all use; GAO study fig 2 5)
{ is that homebuilders in the region have installed much more electric scace heating than is common in the rest of the nation.
For examnle, in 1974, 45% of homes in central and weste/n
Washington used electric space heating, compared with only 8% nationwide. (GAO s tudy, p. 21 2.3) Hot water heating for residences also uses a large chunk of the region's electricity:
about 8%, mor'e than half of that used by the region's entire commercial sector. (GAO Pig. 2 5)
Over half of all electricity used in the region is used by indastry. Most importantly, one-quarter of all electricity used in the entire Northwest is used by the huge aluminum industry. The six aluninum companies in the region use as much electricity as all other industries in the region put together-- including lumber, agriculture and paper products.
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The Aluminum industry buys about 30% of BPA's entire hydro-power output, an amount equal to all the thermal power now gener-ated in the area. (GAO s tudy, uc. 1.2,3 1, Fig. 2 5, Fig. 3.1, Table 3.1) Yet the aluminum companies directly employ only about 2% of the Northwest's population. (Arthur D. Little, Inc.,
Summary Report to 'the Western Aluminum Producers,11/74, p.9)
In point of fact, according to the A.D. Little report, aluminum
/~T companies helped with WNP-2 financing (p.6)
D These electricity uses-- home space and ' hot water heating, industrial activity, aluminum production- are areas of use which are heavily influenced by energy-efficiency activites such as cogeneration and modest use of domestic, decentralized solar and insulation technology which is currently on-shelf. That Northwest electricity consumutton is concentrated in areas
~
subject to such measures accounts in large part for the enor-
~
mous savings projected from conservation by many of the load growth forecasts cited suurn. But despite this fact, the '.iNP-2 ER mentions conservation only generally and in passing, and
- M1 -
devotes only 9 lines to a discussion of solar potential, as alternatives to the construction and operation of WNP-2. This ;
is c. significant omission, as may be emphasized by these quotes from the SOM study done for 3PA in 1977:
" Conservation savings are significant. . ./A/n anount equal to the output of approximately 11 thermal plants can be saved..."
"Up to 33% of regional electrical energy $me projected for 1995 can be saved." ;
Moreover, the same study found that making electricity available by not wasting it is six times cheater than producing it in nuclear or coal plants, and can create "as many or more jobs."
(GAO study, no.5 5,5.6) The Natural Resources Defense Council cited suora, supported the BPA study, and even considered the conservation potential Lo be underestimated. The NEPP study, completed in 1978 for the governors of the Northwest states, estimated total savings of up to 40%, although 22% was considered a more likely realis tic figure. (GAO study, 56) ,
According to Energy 1990, cited supra at p.2-17, the aluminum industry has committed itself to a 10% cutback in total
_ energy usage by 1990. According to the OreSon Department of Energy Annual Recort for 1978, technologies presently exist <
that can improve the efficiency of the aluminum production crocess. During World War II, it took 12 kilowatt-hours to eroduce a pound of aluminum; at present, 8 are used (0D05 report p.32 ). The newest equipment uses only about 6 and a half.
( Arthur D. Little report, cited sunra, at p.5) Rising costs, I even with more energy efficient equipment, will discourage purchase of aluminum for frivolous and non-essential uses.
14% of all aluminum, for example, was used in 1974 for packaging.
.,- g 9 U --W-------------- .
l .
(Arthur D. Little report, suora at p.5) Rising costs may also st?.mulate increased recycling of aluninun. 96% of the energy required to produce new aluminun van be saved by recycling.
(Transition, prepared for the Office of the Governor, State of Oregon, January 1, 1975, p.80) It may be recalled that the alv11nu , industry uses 25% of all electricity generated in the Northwest (citations suora). -
A recent study by the U.S. House of Representatives Committee on Government Ooerations (" Nuclear Power Costs," cited suora at u. 64 nade the following statement concerning the potential of conservation:
"More than half the current energy produced in the United States is wasted. For the next 25 years the United states could meet all its new energy needs sinply by improving efficiency. The energy saved could relieve the inmediate pressure to commit enormous resources to energy sources such as nuclear power, before all alternatives have been fully explored. Reducing energy demand through conservation would be safer, more reliable, less colluting than cro-ducing energy from other sources. Most importantly, a strong energy conservation program would save consumers billiens of dollars a year." (Emphasis added )
The House C4mmittee found that Americans waste more fuel than is used by 2/3 of the worlde s population (at p. 64). It con-cluded that the U.S. could reduce its energy consupption by 40% or more, without adverse affects on industrial output or individual lifestyles. The report reminded read-rs that pro-scerous and highly industrialized countries such as dweden and West Germany consume 40 to 50% less energy per person than we do. (" Nucle : Power Costs, pc.64-5)
Most of the above information regarding the considerable potential of conservation as an alternative source of electri-cityhns been generated only recently, within the last several years, and af ter the proceedings in this matter which resulted
---.r--.,n------- ------------------------------m--- - - - - - - - -
in the construction permit for WNP-2. This information is certainly significant and important additional evidence which substantially affects conclusions reached at an earlier stage in the proceedings regarding the viability of alternatives to the construction and operation of WNP-2. Nevertheless, in an
" update" of the earlier ER, the present ER asserts as the sum total of its discussion that l "Several alternate energy sources were given consideration during the early elsnning stages of WNP-2. There have been no changes in the technology or econonics of any of these j alternatives that would indicate that the project should be abandoned in favor of an alternate generation method."
There is no substantiating discussion whatever. (ER at 9.2-1)
The " update"..does
.- . . . , , . .. ,n..
not mention the alternative of conservation,
-- ., s . , .
which was not even considered during these "early planning stages." (See original ER at 2 5 2-12 through 18. ) Solar alter-natives were disnissed in a nine-line " discussion" as enjoying "no feasible nethod" fcr installation within the next twenty years. Geothermal was dismissed as enjoying "no develonnents" as yet. Only large-scale tower uroduction oossibilities were
(} considered; there was no consideratima of decentralized alterna-tives. ( ER 2 5 2-18 ) The only other alternatives discussed were various high-technology and extensive ontions--truly " exotic" forns--such as the LMFSR, MHD, fusion, and coal gasification.
CONTENTION III: COST-3DIEFIT ANALYSIS Neither the Applicant nor the NRC has precared a rigorous, u c-t o -da t e , objective cost-benefit analysis of WNP-2. The inadequate and deficient analysis cresented (1) violates the ,
National Environnental policy Act and the Commission's regulations, I
r- .,____ ____ _ _ _ _ _ _ _ _ _ _ _ _ _ _
and (2 ) results in failuro to demonstrate adequate finanulal qualification of the Anolicant to eng9ge in the activities to be authorized by the Ocerating License. These deficiencies result in noncomaliance with criteria for issuance of an Ocerating License as outlined in 10 CFR 50 57. I BASIS ,
(The basis for this contention will be mailed under separate cover.)
CONTENTION IV: SEISMIC New information has come to light as a result of activities t the WNP-2 site that indicate that the selected site is unsuitable for the oroject, contrary to assertions by the Applicant in ER 9.3-1 and PSAR 1.4-5-7. The present inadequate and deficient seismic inalysis violates the National Environmental Policy Act and the Commission's regulations, resulting in noncono11ance with criteria .
for issuance of an Ooerating License as outlined in 10 CFR 50 57.
9 ASIS Petitioners have received recorts to the effect that the 'JNP-2 Such a finding is on
~~ site lies directly over a geological fault.
its face evidence which would substantially alter conclusions already reached as to the safety and environmental effects of WNP-2 oceration.
Sources of this evidence have been reluctant to cone forward with their findings; cetitioners are continuing efforts to remedy this.
CONTENTION V,: QUALITY ASSURANCE Applicant has f ailed to meet quality Assurance criteria during the construction of WNP-2. Apolicant h9s failed to denonstr,te its future concetence in neeting said criteria.
BASIS A news recort by the Associated Dress (" Memo on unsafe
l girders at Hanford N-plant went unheeded", Eugene Rseister-Guard, Sunday, October 8,1978) indicates on its face that W:PSS has not been able to meet safety, construction, engineer- '
i ing, and quality-control criteria. A fonner -Wo?SS metallur81st, Don Hetzel, is quoted as saying "we had what amounts to a total ,
breakdown in quality control in this area." By its failure in this instance, Applicant has cast serious doubts as to whether it is technically qualified to operate the plant, and therefore the requirements of 10 CFR 50 57 have not been met.
CONTENTIONJV : LOV-LEVEL RADIATION Applicant has not adequately demonstrated:
) that the standards of 10 CFR 20.101 for exnosure of individ-uals to radiation in restricted areas will be met;
) that the standards of 10 C/R 20.103 for exnosure of individ-uals to concentrations of radioactivity in air in restricted areas will be met;
) that the standards of 10 CFR 20.105 for permissible levels of radiation in unrestricted areas will be met;
) ) that the standards of 10 CFR 20.106 for release of radioac-tivity in effluents to unrestricted areas will be met.
Aeolicant has thus failed to orovide adequa.te assurance that a'.1 rrovisions of NRC regulations have been met, and therafore 10 CFR 50.57(3)(b) requires that an ocerating license not be issued.
Aculicant has further not nrovided reasonable assurance tha t the I henith and safety of the rublic is not endangered by radioactivity to be released by WNP-2, and therefore has not met the requirement of 10 CPR 50.57(3)(a).
w
R
~
BASIS The history of commercial nuclear nower clants in the United States shows numerous instances of unclanned, accidental exeosures ta, and/or release of, radioactivity in excess of ter-missible levels. Applicant has not demonstr,ted that it will be able to orevent such occurrences. Applicant has also failed to consider the additive effec ts of emissions from WNP-2 along with those from other installations at the Hanford Reservation, including the N reactor, Purex nlant, other crocosed WPOSS nuclear orojects, and the large volumes of low , intermediate , and high-level radioactive wastes currently being stored. Such effects would
- endanger the lives, health, and safety of HCP members and the nublic at large, yet these effects have not even been considered by the Applicant. It is clear, then, that the requirement of 10 CFR 50 57 (3)(a) has not been met; accordingly, license to operate WNP-2 should be denied.
Petitioners will cresent evidence which demonstrates that ex-osure to so-called routine levels of radiation lead to increased
,_, incidence of cancer, birth defects, and other deleterious health
- effects, both to nuclear nower olant workers and to the general
-ublic. Studies include, but are not limited to, those of Drs.
Helen Caldicott, John Gofnan, Arthur Tanelin, Thomas Mancuso, Thomas N'.jarian, and Sr. Rosalie Berte11. This substantial body of evidence clearly indicates that oceration of WN?-2 will endanger the henith and safety of the general public.
There is currently underway by the Federal government a review of radiation exuosure standards; a likely outcome of this is a reduction of cermi sible radiation levels. Applicant has not shown that it anticioates such reductions , nor that it will be able to neet the new standards. When such standards go into
offcot, Applicant will ba unablo to maintain an adequato and competant work force at a reasonable cost. This consideration affects Aeolicant 's cost-benefit analysis as well.
'4HEREFOP.E, petitioners oray the Atomic Safety and Licensing Board for an order as follows:
- 1) Granting them status as intervenors as of right in opera ting license croceedings herein, with full onportunity to particioate in all issues in contention; or
- 2) In the alternative, granting them status as intervenors as of discretion, with full occortunity to present oroof and
()otherwisecarticipateinfullhearingonallcontentionsher' raised by them.
Resnectfully, submitted, n 7'
, , .u ',
- .L .,'1 Creg Darby, nro se, for Susan Garrett, and for Hanford Conversion Project l
... 4 q, g A ch,_sy
$l.$7 -
s 1 SF 3 OF OREGON -
)
2 County of Tillamook Ob
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f 7 3 I, A. C. Roll, b dul *
, on oath, depose and
% ' "y o 4 say:
5 I am a member of the Hanford Conversion Project. As 6 such, I authorize the Hanford Conversion Project, Susan M.
7 carrett, and Helen Vozenilek to represent me as intervenors in 8 the matter of Washington Public Power Supply System (WPPSS 9 Nuclear Project No. 2).
10 I own land near Kennewick, Nashington, approximately 10 11 to 15 miles down the Columbia River from the site of the 12 proposed WPPSS 2 reactor. I own two houses at that site, which 13 I rent. one is being commercially farmed. Livestock is also l
14 pastured on my land.
15 I feel that the new reactor would pose a threat to 16 health and safety and the condition of the environment. As such, 17 it would make my land harder to rent and might decrease its 18 rental value. I feel that an accidental release of radiation would
()19 damage my land, the people present on it, the crops grown there, l
20 and the livestock raised there.
21
- 7;
/s/ A. C. Roll 22 Subscribed and sworn to before me this 08 day of d eer, J cm ,
24
(</f0Au h hf m Noter F1gpublic for oregon My commission expires: O(o g 26 27 28 1 - affidavit of A. C. Roll mc4 onn - n: ,
. n sm w .x p j y -
B.C.kOLL UWW ER P.O.50X N O. I OCEANSIDE. OREGON 97134 AppolNTM ENT C NLY pq , . . MONE AC 503-84M888
\ st MaAmtst November 7, 1978 % v Y' '
i d>o# agh Doreen L. Nepom, Attorney
(}M h fs'(-
9 101 Kellogg Building if3[*$,f j
EE c/
1935 S.E. Washington Milwaukie, OR 97222
,p oz Re: Hanford Conversion Proj ect
Dear Ms. Nepom:
This is my a7 plication for proj ect membership per your letter, together with authorization to represent me in Washington Public Power Supply System, et al; WPPSS Nuclear Project No. 2
{C}-L before the Nuclear Regulatory Commission, Atomic Safety and Licensing Board.
My family and I have owned two farms about three miles southeast of Kennewick on the downside of the Columbia River about 10 or 15 miles from where I understand proposed No. 2 reactor ir to be operated since long before the original Hanford proj ect ws.s built.
One farm is 12 acres under cultivation; the second farm about 6 acres, consisting primarily of pasture land and a private garden. Both farms have. rental houses, are o.ccupied and are dependent upon well water for human consumption as well as irrigation. About 10 persons reside on the two places, as well as livestock on both.
Only recently the sewage treatment plant near Kennewick leaked,
(\ ">i and it was officially reported to me that the underground water supply had been contaminated for miles and was unfit for human consumption. This included the area surrounding my ,
farms, neither of which were then affecued. It is publicly l reported that nuclear waste has escaped in the Hanford area l over recent years. I believe that,1f this has occurred, and if it has not occurred, it will occur, the underground water table very near the surface in my area either is now or will become dangerously contaminated and render my land I worthless.
I ma now apprehensive about the health and safety conditions of my property due to the Hanford plant. I am in actual fear for my own well-being when visiting the farms for inspection. The new reactor and all subsequent additions and enlargements necessarily increase the hazard.
In my opinion, present property value, both sale and rental, is markedly increased in the short-term by virtue of the atomic project. The extraordinary influx of workers into
. i j
l A . C. R O L L L.AWYER Doreen L. Nepom, Attorney Page Two November 7, 1978 the area has driven land and housing prices out of sight.
My conviction is that these are false values and that both farms will become totally worthless because of the Hanford proj ect , including the new reactor.
I not only fear underground water and air atomic contamination of my property and the entire area which will ultimately destroy all life; I believe that an explosion is expectable which will blow the entire area into smithereens, including all of my property and everything on and near it.
You are free to use this letter as part of the proj ect O presentation if you wish.
Very truly yours, ROLL ANp ROLL' LAWYERS ha
. C. ROLL ACR/tah
Enclosures:
Affidavit Tax Statements f :.
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UNITED ST'.TES OF AMERICA NUCLE.?.R REGUl ATORY CTC'ISSICN i BEFORE THE ATCMIC S AFETY AND LICENSING BC.tRD In the matter of "iASHINGT:5 PUBLIC PCiER ) Docket No. 30-337-OL SUFPLY SYSTEM, et al. )
(':IPPSS Nuclear Project No. 2) )
AFFIDAVIT OF TERRY SoRELLO I, Terry SoRello, do affirm and stste the following:
- 1. That I am a chaireerson of the Hanford Conversion Pro-ject, which seeks leave to intervene in the aforementioned troceeding;
- 2. That I am authorized in my encacity as chairrereon to arroint renresentatives of the Project;
- 3. TPat Creg Darby, 2425 S.E. 24th, Portland, OR 97214, is a member of Hanford Conversion Project;
- 4. TPat Creg Darby is authorized to rerresent the Project
_T in the aforementioned nroceeding;
- 5. That Creg Darby is renlacing Helen Vozenilek as a representative of the Project in the aforementioned
-roceeding.
Dated November lo, 1978 i~~, .
< ^ , -u Terry SoRello Chairnerson Hanford Conversion Project SUBSCRIBED AND S*10RN TC before me this loth day of November, 1978
- __________________________________________________________a
UNITED STATES OF MMERILcR\ l f '* '
. NUCLEAR REGULATORY COMMISSION 1
BEFORE THE ATOMIC SAFETY AND LICEN3ING BOARD 1
In the Matter of 9
)
WASHINGTON PUBLIC PCWER )
SUPPLY SYSTEM ) Docket No. 50-397 OL
)
(WPPSS Nuclear Project No.2 ) )
AFFIDAVIT OF I, Terry Stratton , hereby certify the following:
- 1. I am a member of the Hanford Conversion Project.
..-. 2. I reside at 19n? "A" street. Ellensburg, WA 98926
- 3. My place of residence is located approximaMy an miles from the site of WPPSS Nuclear Project No. 2.
l+ . My interests in the above-captioned proceeding are as discussed in the accompanying Amended Petition to Intervene.
- 5. I have the following specific personal, financial and property interests in this proceeding:
- IkE MflLTH of Nf HeTHER , Fqr4ER , GRaup4oritto., ;ters ,vN RES,cousip s que FRit uDS .
- Tkf EccLcG1catInttr RRW of 4ks C.IvasinledN af f A 6, I authorize Susan M. Garrett, Helen Vozenilek, Terry SoRelle, or any other persen designated by the Hanfoni
.,_ Conversion Project Coordinating Committee to represent
- myself and my interests in the above-captiened procee
- iing.
R y ectfully , submitted, I
b iAA> i
% h l TERRYSyTTON Subscribed and sworn to before me this 3 day of Noy_,_,1978
- }j fQ .,
Notary P l' My Commission expires i/7/2 2 l
I l