ML20053B852
| ML20053B852 | |
| Person / Time | |
|---|---|
| Site: | Skagit |
| Issue date: | 05/24/1982 |
| From: | Bell N NORTHWEST ENVIRONMENTAL ADVOCATES (FORMERLY COALITION |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| NUDOCS 8206010286 | |
| Download: ML20053B852 (33) | |
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UNITED STATES OF #9ICA NUCLEAR REGULATORY C0!'MISSICI; BEFORE THE ATOMIC SAFEU AND LICENSING E0ARD In the Matter of PUGET SOUND POWER & LIGHT CO.
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Docket Nos. STN 50-522
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STF 50-523
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(Skagit/Hanford Nuclear Project,
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Units 1 and 2)
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REVISED CONTENTIONS OF COALITION FOR SAFE PO'a'ER - MAY 2h,1982 Intervenor Coalition for Safe Power hereby sub its its revised con-tentions pursuant to the Board's oral order made at the stecial prehearing conference held in Richland, Washington on May 5, 1982.
In so doing, Inter-venor does not in any way admit to the stated objections of the NRC Staff and the Applicant.
The revised contentions contained herein meet the re-quirenents of 10 CFR 2.71h(b) and the case lav vhich has evolved on this subject. The most important of these is the Appeals Board holding in Mis-sissippi Power & Light Co. (Grand Gulf Nuclear Station, Units 1 and 2),
ALAB-130, 6 AEC h23, h2h (1973) which states that a petitioner does not have
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-to~" establish that' its ~ assertion is well-founded in fact" and that 10 CFR 2.71h "does not require the petitioner to detail the evidence which vill be offered in supuort of each contention."
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NEED FOR TOWER Bevised:Contenti'on i (Feplaces CISD n mi 9I Petitioner contends that Applicant will not need the never generated by the Skagit/Hanford Nuclear Prpject, Units 1 and 2, to serve their own loads or the loads of the region as clained in the Application for Site Certification /Environmentel Report (ASC/ER).
Applicant has outlined in Section 1.1 of the ACS/ER forecasts for its member utilities and forecasts for the region.
As stated in Secticn 1.1.1.1, the data for these forecasts was prepared in late 1980.
Oh Since that tine, numerous events have occured which render Applicant's forecasts D f
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e outdated.
These events, which include the increased price ef. electricity due to the ternination and e scalating cests of the five Washin ten Public Power Supply Systen (WFPSS) nuclear plants, the Bonneville Power Ad dni I
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stration (BPA) development of conservation programs and a poor regional economy, have led to a decrease in the ferecasted need for additional thermal power plants.
Forecasts issued more recently show the need for the S/ENP to.be-non-existent.
These forecasts include the Washington State Forecast; Washington Energy Research Center, Washington State l'niversity/ University of Washington (March 1982). The Washington forecast states that "the most likely rate of load growth, as measured by tott'. regional electricity sales, over the period 1980 to 2000 is about 1.5 percent / year." (pg. b)
This projection corresponds closely to the recently released BPA draft forecast, Forecasts of Electricity Consumption in the Pacific Northwest,
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which shows regional loads growing at an average rate of 1.6 from 1980-1990, and 1.7 from 1990-2000.'(pg.'5)
Applicant has relied on the 1981 Pacific Northwest Utilities Confe-rence commit', tee (PNUCC) forecast __(See.ASC/ER 1.1-20.tc.1.1-2h)..However,r:;_
since that forecast has been released it has received much critisism for not being accurate.
Such was the critisism from the Northwest Power Planning, Council, the group responsible under Public Law 96-201 for energy planning in the Northwest.
According to staff member James Litchfield, "They vere not accurately reflecting the tremendous increases in the cost of the WFPSS plants." (Oregenlan, October 22, 1981, " Electric Needs Revised Downward")
Furthermore it has been stated by a member of the PNUCC and a Puget Pcrer official (David Hoff) that the computer system used for forecasting "is sort of a Model T that once was useful, but nov it is not useful for scr.e purposes." (Pacific Northwest Regional Power Planning Council November L, 1981 Neeting) At that same neetin Mr. Hoff presented a revised forecast
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o-figure of 2.5 down from the original projection of 2.8.
Such a decline vculd nean a reduction in any energy deficit clained by Applicant of 1,660 megawatts.
Revised Contention 2 (Berlaces CFSP h and 56)
Petitioner contends that any decision on the need for the S/HNP must avait the regional forecast to be issued by the Northwest Power Plan-ning Council in April 1983.
Under the Pacific Northwest Electric Power Planning and Conserva.
tion Act, PL 96-501, 9h Stat.2697, it is the responsibility of the North-west Power Planning Council (Power Council) and the Bonneville Power Ad-ministration of the Department of Energy (BPA) to plan and meet the elec-trical power needs of the Pacific Northwest. ' Applicant sunported the pas-sage of this bill in Congress. Applicant has stated in its ASC/ER, Sec-tion 1.1 and its PSAR, Section 1, that the S/ENP is to considered as a re-gional resource. Applicant has stated that it vill not construct the pro-ject unless it is "regionalized" (i.e. included in'the Power Council's plan and financed by the BPA) publically since August of 1981.
Furthmcre, Ap-plicant has stated that "the Pacific Northwest region is thus the appropriate area" to be' considered in evaluating the.need for the.. pro.iect.= (PSAR,.Sec _:_
tion 1.1) Given these statenents by Applicant it is only logical that this Board avait the outcome of the Power Coun-il's planning process. The Nu
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cicar Regulatory Commission has recognized the need to consider forecasts by_ state agencies.
See Rochester Gas and Electric Co., (Sterling Power Pr6jebii suc~1 car'Nnic 1) 8 NBC 383, 389 (1978) While the Power Council is not a state agency, it is a regional arency empowered by the Congress of the United States and must receive at least equal consideration with state l
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For the NRC to ignore the Power Council vould be to ignore the intentions of Congress.
Revised Contention 3 (Renlaces CFSP 5)
Petitioner contends that no weight'should be given to Apolicant's projected load forecast as outlined in ASC/ER Section 1.1 and Table 1.1.
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0 Applicant has the " burden of showing that (their) projections of demand are reasonable."
~ Duke Power Co. (Catawba Nuclear Station, Units
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1 and 2), h NRC 397, LO5 (1976).
Applicant has presented no basis fer such an affirmative decision by the Board in this case.
Section 1.1 cf the ASC/ER treats us to merely an outline of Applicant's forecast.
It is devoid of any data to aid in determining the reasonableness of Applicant's wojections._Fer_ exa=cle, Applicant states, without elaboratierr, that con-servation is figured into the projections..Voreover, each member utility uses a differ'.at method in determining what its load vill be and each states that its method is the best.
For example, Portland General Electric states that the residential end-use model is more suited than the econometric model.
Pacific Power and Light uses a combination of both. Washington Water Power uses tradi-tional and econometric.
Thus it is clear that even the me=ber utilities do not agree on which model is the most appr6priase.
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The Atomic Safety and Licensing Board must also base its decision on more than ' hope'.
Dusquene Light Co. (Beaver Valley Power Station,
_._..S"it2),ALAB-2h0, AEC,829d191hl _ Applicant's past_: record _in--this= pre
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ceeding and in the Portland General Electric Dockets50-51h & 515 (Pebble SprinEs Nuclear Plants, Units 1 and 2) is one that leaves nuch to be de sired. Applicant originally stated in its ER that Unit 1 of the Skagit project would need to come on line in 1982, assumming that Unit 1 of Peb-I ble Springs, WPPSS Units 1,2,3 and h were all on line by that year. None of these plants is presently operational and Unit 1 of the Skagit/Hanford i
Nuclear Project is projected for 1990 and the devastating consecuences l
portrayed by Apulicant in Section 1.3 of the Skagit ER, "Consecuences cf Delay" are not even remotely imminent.
Forecasting is, of course, an un-certain art.
However, ten years and five nuclear units amounts to more than mere uncertainty.
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ALTE? NATIVE ENERGY SOUP.CES
" Revised Contention L (Reclaces CFFP 6,7,3,9 and 101 Applicant has misapplied the National Envirennental Felicy Act (NEPA), h2 USC h321 by rejecting the followinc alternatives which are a availcble, environmentally preferable and nore eccnonical than the pre-posed Skagit/Hanford Lu: lear Froject: vind power, bionacs, solar, cunser vation, co-generation, low-head hydro, ccean tetuerature differences and al:ohol fuels. Further, Applicant has followed a very narrow view of this Act by considering each alternative seperately.
Applicant turt also be required to consider ec=binations of various appropriate technologies as citernatives to the propoced project.
In Sentenber 1980, the Creron Alternative Energy Development Cc=-.,
mission iscued its Final Recort, ' Future Penewabit.
The.EvC states o'n page three of that repcrt that "we believe that Dregon's long tern energy interescs will best be served by developing a diverse array of energy op-tions." The report states, "no single renewable resource option could be expected to contribute a substantial share of projected cenand.
Collective-ly, however, the contributicas from all these researces can meet a signi-ficaat portion of future energy demand." (pg. 25) The AEDC continues:
"Using the coal rolerence in Figure 2 and the-low-range of costs, the' tech-nical economic potential of conservation and renewable resources is large enough-to provide 100 percent of the decand grovth between 1980 and 2000.
Assuming the high range costs, these rescurces have tae potential to_provids T5 percent of energy demand growth in this period." The AEDC looked at.
the following resources:
alcohol, tio-mass, hydro, conservation, geothermal, solar and vind.
Bio-r. ass trovides 20 percent of Oregon's enorgy supply on a per BTU basim-(Futire~RGn~evailes, pg.13) Cordvoodshpl[esabout8to10 percent of the residential space heating needs. The AEDC estimated that cordvood would continue to grow as a ' cce heating source as efficiency of stoves a
and vcatherization lowered heating demands.
The AEDC founa that by 1900, the year the S/hNP is due to ecce on lir.e, that about LOC ate. 20,1 of genera-tion capacity through bio-cass-fired ectoneration eculd bc brcugh; on line.
The Rochet hetort, Jar.uary 19, 1979, done for the Sonneville Power Administra-
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tion estinated that cogeneration frec existing industries cculd trovide 55).2 MW.
(pg. h-25) In its Phase Peport issued en February 29, 1980 the economic feasibility of thin is stated as "ccrpatitiva vith the 'new source' costs to this region."
(pg. 9)
These reports are more representative of the regiun's 6bility to supply alternatives to the Stagit/Eanford project than those cited by
-Applicant which are cerely articles from national trade magazines. TEere-fore Applicant's presentation on biomass clearly does not meet the stan-dards of NEPA and the Consission in a reasonable way.
Cogeneration is not even mentioned in the ASC/ER, thus not meeting the " rule of reasou" cri-teria.
Applicant's treatment of geothermal energy shows a similarly mis-guided use of the " rule of reason". Applicant states "in the Pacific Noqthwest Region cerved by Applicants have not produced much hopeful data on the occurence of resources, with sufficiently high tecperature and flowrates, to produce electricity at a cost competitive with alterna-tives."
(ASO/ER Cection 9.31.2.2)
In the final paragrapn uf that see-
. _._ tion. it _statea_that '!thr.-amount ofrgeothermal= energy available'td Appli' "
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l cants is uncertain at this time."
It is clear from those statcments that Applicant misundcrstands the energy situation.
The Oregon AEDC report cited above states that
" Oregon has the potential to_gaothermally_ generate._600_Kr7 n# electricity _ - w
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by 2300." (pg. 18) Clearly if Applicants can move 200' miles out of their service territory to build a nuclear power plant, they could de the same to develop geothermal energy sources.
(Cc= mon Sense) The AEDO Peport goes en to say tnat 600 M'l vould be available at a cost of 36 f>5 mills / wh.
(pg. 29) This conpares favorably to that of the estinstec cost of teth coal and nuclocr.
(See Fever Flant Cost Escalation, Charles Ecmanoff, 1961, pg. 282 ) In sum, Applicant has provided t.o basis for their ctate-
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tent made in ASC;'ER Section 9.2.1.2.2.
Hydro is another a: ea ir. which Applicant's presentation is la:hing Applicant does not project the ancunt of energy to be in fectual basic.
f produced from small-scale hydre projects. Applicant also fails to stat'e ene range of costs cf such projectc but ccrely states thcir conclusion that
~here are resources tnat can be developed for a cost that, althcugh high',
i will-be-competative with alternatives." (ASC/E" Section 0.2.2.2.h) Appli-L_
cant tt_kes the same approach with large-scale hydro projects. The Oregon 3
AE, however, concludai in its report that bl0 cve. f 3.' was "realistical-j ly achievable..." for small-scale hydre in the state of Oregon. This esti-mate vag made after accounting for environmental and economic factors. (pg.
19)
Applicant's statement on passive solar systans is,Although pas-siv.e solar ener&r systens have yet to be proven cost effective in the vestern portions of Oregon and WhAhing-5n, it 5 possible that they vill become competatise for some applications during the forecast period."
This statament show that Applicant has no intention of investigating the solar. alternative. tc the 3/ENP-or of< developing-ity regardless=of-its:-
feasibility. Applicant proviics no basis for such an outrageous statement cs well as ignoring all the existing literature on 1.hi.! subject and appears blind to the realities of the Pacific Northwest.
In July of 1978, the State of Oregon and the U.S. DeAartment of 2:
Energt held the Solar '78 Northwest conference in Portir_nd, Oregen. At the conference it was reported "that scir_r retrofits could be econo =ically attractive corrj'ared with continued reliance en conventicnal fuels rcr re--
side.ntial needs".
In each esse, it <as assmed that a seldr installatien vculd be cecncticalb feasible "if the amount cf energy naved by re;trofit vould pay back the cost of the syster. in less tha. ".3 years."
(Solar North-vest: 7ne Econctics are Getting Better all the Time. Light Energy, A2 gust e
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1978, Supplement to Cascade, EuEene, Oregon) This statement when taken together with ff ndings fcuid in Solar Energy for Pacific Northwest Resi-
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lential Heatine, May 1978, an Interagoney Report by U.S. fepartment.C f
Energy and U.f:. Enviionmental Protection Agency) show that solar enerrt is economically feasible in the Northwest. (pg. 3-6, Executive Suma n)
This economic feasibility is being recognized by the people of the Ucrthwest_as-evidenced by the increasing numberoO solar projects being-in-~
stalled on new and existing buildings, for exa=ple the McCormack Pier Apartr_ ente in Portland and the 7ar. Wer.t Federal Sr.ving: and Loan Building in Tigard, Oregon.
In 1980, Portland Sun was installing solar hot water systems on residences for $1,300.00 and an estimated ps.y back period of ten years.
(Portland. Sun, an organization) Applicants should be retro-fitting customers houses instead of building the proposed project and would avoid nuclear v2ste, cancer and ceanomic instability. Unlike the propcsedproject,solarpowervouldhavegreai,'r~socio-economicbene[its
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e by atiliz3ng core-trades people per professionals, and for the same a.nount cf energy produce 2 more jobn.
fJobs & Ener q and " Working Jeopic" pre-pat ed by Environmentalists __fo-Pnq Enpinyment,; Washington-D.C. ) ---
Applicant's treatment of conservation is no different than the other alternatives. Applicant merely states that conservation is figured into.
their projections; no amount is quantified and the only discussion provided is a brief summary of Applicant's programs. Over the nast seyeral~yeam 3
numerous studies have examined the potential for energy conservation in the Northwest in residences, businesses and industry.
All have reached the conclusion that conservation could render 30 to 60 percent of our future electrical requirements unnecessary and would be cleaner and cheaper than the proposed S/HI!P.
These include: Bonneville Power Adminstration Electric Conservation Study, Skidmore, Owings and Merrill, July 1976, pg. 8
- North-west Enerry Poliev Project,1978, pg.12 ; Energy Futures Northwest, North-
vest Energy Policy Project, Final Eepert, 1978, pg. 15 ; Fegien at the Crossroads, U.S. Govern =cnt Accounting Office, August,1978, eg. h.2 Natural Fesources Defense Council Forecast 'A Model Electric Power Conser-o vation Plan for the Pacific Northwest, Drafts, January and March,1932; and the Washington State Forecast, Independent Review of Washineten Public Power Supply System Nuclear Plants h and 5, Final Report to the State Legi-slature,. March.1982, pp. h-5.
kind energy potantial in the Northwest is greater than Applicant portra:. s.. The Oregon AEDC found that 365 W could be troduced from vind in 1990 and 1,396 in the year 2000.
This compares favorably with the a=ounts stated by the Bonneville Power Adminstration in " Answer to Questions Posed by Chairmen Dingell and Ottinger in their letter of October 13, 1981" at page 13, where they state that 700 ave. W can be obtained from large-scale vind. This could be done at a cost equal to or lover than that for the prcposed project.
In summary ve vould quote from the AEDC report: "The task forces' combined estimates for physical energy potential in 2000 is approximately 3,7_00 ave W of _elegtricity1(not_ including.884 ave W: potential =froEFphoto -
voltaics), the equivelect of 10 Boardman coal-fited plants operating ati 70 percent capacity factor; 203 trillion Btu per year of thermal energy from solar, biomass, conservation and geothermal direct heat.
This potential represents 100 percent of projected new electrical de=and and over 200 per __,
cent of new thermal demand, or 150 percent of total combined new dencnd pro-jected in 2000." (pg. 25) Thus it is clear that Applicant has misapplied the " rule of reason" and that alternatives to the proposed project exist that are available to the Applicant, environnentally preferable, and more economical.
A$TEP"ATIVE SITES Revised Contention 5 (Replaces CFSP 12) 3_.
Petitioner contends that Applicant conducted the alternative site analysis reouired by 10 CFR 51.20(a)(3) inproperly in ceneluding that Hanford was the best site.
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Bonneville Power Adminstration vitness Gens testified in support i
of the Applicant in the original Skagit proceeding (TR509 -5311) that a site L
West of the Cascades was preferable to the Eastern side because of the high toll in reserves and reliability created by placing the generating capacity-distant-from the load.
( All the major load centers of the region '
are along the West Coast.) Applicant nov vishes to nahe the case that this very, great cost is nitigated by other circumstances in its alterna-tive site analysis.
Petitioner
- believes that Applicant cannot negate the weight of this testimony and further that Applicant has chosen the Hanford site, not because of its site characteristics.but because it is the only area in the region where the local population vould accept i t,.
Petitioner realizes that such "socio-economic & cultural" considera-.
tions are allowed in the site analysis but contend that Applicant has placed too great a weight on them.
SABOTAGE AND THREATS TO NATIONAL SECURI"T
_,__ _,Re' vised Contention 6_(Replaces-CFSP-1TI)
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Petitioner contends that Applicant has failed to provide an assess-ment of the threat to national security posed by a major accident at the S/HNP which would decrease the governnent's ability to maintain adqquate security on the Hanford Reservation and to continue defense-related acti-vities.
10 CFR 2.10h(b)(1)(iv) and 10 CFR 50.h0(c) provide that a project must not be inimicable to the conmon defense and security.
_2 Defenseactivites at-Hanford--include-the operation of faciliffiis such'-~
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.ns the N-Reactor and the Purex facility which produce and refine plutonium for the nation's nuclear warheads.
In the event of an accident at the S/HNP a certain amount of chaos vould exist, as evidenced by the TMI-2 ae-cident.
Since, as yet, there exists no evacuation plan even in rudinen-tary form, there exists no evidence that such chaos vould not affect the operation and security of these defense-related activities. For example:
- vhat vould be done with the 'a'ye Burial Ground guard post, sone three miles away; what provisions exist for additional security for the !!-reactor, im-1
__ mediately fo11oving an accident and in the long-term; what would_the_radic _
biological impact be upon security guards and personnel at other facilities?
Revised Contention 7 (Reulaces CFSF 18)
Petitioner contends that Applicant has not considered the effect of rovernment actions on the Hanford Reservation in times of var on the S/ENP, as required by 10 CFR 100.10 and 100.10(~d).
While 10 CFR 50.13 states that protective measures against armed attacks need not be considered this is, we believe, a reference to the.
design of ' he plant which, if bombed, vould intensify the effects of either t
a conventional or nuclear explosion.
However, the issue ve atte=pt to raise here is one of site suitibility. The Hanford Reservation is, above all, a government installation.
It performs the very important task of producing and refining plutonium for nuclear varheads (eg. N-Reactor, 1
Pufex facility). The placing of the S/HNP, in_ Droximity to _these works _
could have two results: first, in the case of armed attack against the United States, Hanford would be one of the main target areas, thus ren-dering the project inoperable, and secondly, in the event of a war, the
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haFa'et'er 6'f' tlie~~s~iiie vo~uld change dramatically. For exa=ple, the level
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c of security clearances would change and thus affect S/HNP vorkers. The S/NNP site and environs itself may be needed for future government facili-ties required for national security which would be precluded if the pro-Ject _- verenbuilt astvell as'if it~suffsFEd a catastioihic accident'.'
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. TECHNICAL ABILITY OF APPLICAI!T AND ARCHITECT-ENGINEE" Revised Contention 8 (Fenlaces CFSP 13)
Applicant's architect / engineer, Bechtel Corporation is not techni-cally qualified to engage in the proposed activities and lacks the villing-ness and desire to carry out a quality assurance program as required by l
Commission regulations.
i Bechtel has been responsible for numerous safety violations includ-ing the failure to design and construct the Trojan Nuclear Power Plant
Control Building to NRC requirerents.
This failure on the Tart of Eech-tel caused the Trojan clant to remain shut down for a period of eight
. _. _ _ months while hearinFs were held. Portland General Electric (Trojan Nuclear. _ ______.
Power Plant) Docket 50-3hh (Control Building). Further, in repairing.
the control building, Bechtel failed to meet the requirements and commit-ments made to the Atomic Safety and Licensing Board.
See Letters dated February 6,-1981, February 9, 1981, February 25, 1981, April 6, 1981, j
from Portland General Electric to R.H. Engelken, U.S. NRC Region 5, Docket 50,3hh and Licensee Event Report 80-17, September 5, 1980, same docket.
Bechtel was also the architect / engineer on the Humboldt Nuclear Plant and the Dresden, Unit 1, both of which remain shut down to this day.
The Humboldt plant was shut down due to seismic problems.
The Board in this matter has the right to ensure that a quality 4
acsurance program is met.
It is not enough 't'o rely upon what has been
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submitted on paper.
See Carolina Power & Light.(Shearon.Parris Plant),
ALAB h90, 8 NBC 23h (1978) and Deshutes Light Co. (Beaver Valley, Unit
_. 2)t ALAB-210 (1973)._=It_vak al eo stated-by:the: Appeals-Board-dn Cone =m---
sumers Power Co. (Midland Plants, Units 1 and 2) ALAB-106, AEC 182,18h (1973) that "The inquiry which the board must make is not necessarily resolved by a determination of whether, in a broad sense, the applicant and its architect / engineer are ' technically quali_fied'...Unless ther_e is__ _
a villingness, -indeed, desire - on the part of the responsible officials to carry it out to the letter, ne program is likelye to be successful."
It is clear from the history of Bechtel that they lack a villingness and a desire to conform to current standards of public safety.
R,evised Contention 9 (Reclaces CFSP 19,end'211 Petitioner contends that Applicant does not possess the technical ability to construct the proposed project.
Neither does the Applicant have the villingness and the desire to adhere to NRC regulations.
Thus, the
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Board has no basis to conclude that the Applicant r.eets the previsiens of 10 CFR 2.10h(b)(1)(ii) and that the project vill be constructed in a safe manner.
Apolicant has not participated, either in whole or in part, in 9
a project of this size, nuclear or othervise. The 18C Staff has recong-nized that such inexperience leads to many problems which affect the public health and sfaety. Working Paper, SALP Str.ff S-'q-VLY-2, Fe-bruary_1981,_pph-5. State:nents made @f Puget Pover's management fi$rther--
indicate that there is not much enthusiasm for NRd regulations.
Puget s
Power president John Ellis has stated publically since~ August, 1981
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that the NRC vould have to relax its regalations if the utility intended to pursue the construction of the S/UHP.
,A mbre recent state =ent ap-peared in the Seattle Post-Inteligencer on May 12,1932: snless "...we get federal assurances that its construction can be co=plet,ed.in six or seven years" the utility would not build the plant.'
Again, the'3oard is left with little more than hope.
See Consumers Power Co., sutra.
Revised Contention 10 (Replaces CFSP lh and 15,)
Petitioner contends that the work force and contractors relied ~
upon by the Applicant for the construction of'the project (ASC/ER Sec '
tion 8.3.7) are not capable _of,.and,do not desire to,, constructing-the=
project's units in confor=an' ce with NBC regulaiions.
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There exists no reason to believe, or even hope, that the work- _
force and the contractors, inclu8ing supervisors.and quality assurance inspectors, will perform to necessary standards based 'on' th,e nu=erous safetymviolations,at-WPPSS-Nuclear ~ProfchtT1~2 aiid h for which 'they
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have been responsible.
These contra 6tdrs include: J.A. Construction Co.,
H.P. Foley/Wis=er and Becker, United Engineers and Constructors, Eechtel Power Corporation and WBG. Failures;by this work force include:
- SALP, v'
supra, pp3-5; U.S.NRC Office of I & E, Region V, Report Nos. 50 h60/80-08 (pp. 2-5). 50 h60/8021h (pp.9, 15),'50 h60/81-01 (pg. 2).50 h66/81-ch U
(pp. 3,h), 50-397/80-08 andNoticeofviolatibn, June 17, 1980, Locket t
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6 Wo.60-397 Reviced Contention 11 (Reclaces CFSP 22 and 23)
Petitioner contends that Oregon state lav prohibits co-applfcanti! ~ ~~ -~
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Portland General Electric and Pacific Power and Light from participating in this project and thus any facts pertaining to these two utilities should be disnissed.
In November 1980, Oregon voters passed into lav Ballot Measure
- 7. This measure prohibits Oregon-based utilities from participating
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in niicliaFprojects outside the state of Oregon.
Neither utility has atte=pted to contest this law.
SOCIO-ECONOMIC EFFECTS OF THE PROJECT _
Revised Contention 12 (Replaces'CFSP 2h and'25)
Petitioner contends that Applicant has not correctly weighed the socio-economic and other benefits required by 10 CFR 51.20(b) and thus has overstated the benefits of the proposed project.
In the first instance Applicant-Puget's survey on the Socio-Economic Cost of Electrical Energy Shortages (ASC/ER Section 9.1) is entirely outdated and cannot be relied upon in any decision-making pro-Events have occured in the Northwest regarding nuclear power, in cess.
particular the five WPPSS projects, t_.o have changed the attitudes of
---a-cajority of the region's' residents ?. -. - -This~is to say 'that if the popula-
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tion were offered a choice between possible electrical shortages and the costs of yet another nuclear facility the results vould be different to
- day than a year ago.
In that time, the region's residents have realized that theygere_ paying for-cost-overruns'of--6005--for the VPPSS prolects -
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and in the case of at least two (WFPSS h and 5) for plants that would not operate.
In the face of escalating electric bills organizations called
" Irate Ratepayers" have formed all across the state of Washington and many are calling for default on their Public Utility District debts to WPPSS.
Furthermore Applicant has not included a discussion of surveys done by member utilities (eg. Pacific Power & Light) that have sought to deter-mine ratepayers' prefered energy sources.
Such surveys should be consi-n
w dered under the "other benefit" provision of 10 CFR 51.20(t<). For exa=ple, a more recent surtey done by Applicant-Puget shows its custo-mers prefer conservation to nuclear power.
NRCSTAFFABILITYTOADECUATELYEVALUATETHkPROJECT Revised C,ontention 13 (Re;olaces 28, 29. 30_,.31,,_32, 33. 3L and 35)
Petitioner contends that NRC Staff has not completed its review of the proposed project and that the curreid Safety Evaluation Report is inadequate and thus there exists r.o basis for the Board to nahe a determination on the avolication.
I y
At present, the FER has nothing in it co reflect the site change from Skagit to Hanford. This affects, for exa=ple, all issues related to the seismic capability of the project. The Board in Commonwealth Edison (Byron Plant) 12 FC 683 (1980) held that it "is normal to plead the inadequacies of documents as yet unavailable".
ENVIRONMENTAL EFFECTS OF CONSTRUCTION AND OPERATION OF THE PROJECT Refised Contention lb (Reulaces CFSP 36), _
i
)
Petitioner contends that the Applicant has underestimatsitthe environmental cost of the S/ENP in such a wayLas to. change the cost-benefit balance required by NEPA and 10 CFR 71.20 in favor 6f the pro-ject.
- H
,1 This has been.done _bnunderestimating the eristing_radiologi ---
g cal burden on the Hanford area environment and the Colur.bia River and their respective terrestrial and aquatic biota; undere'stimating the cu,
mulative effect of the S/HEand WPPSS plants 1,2 snd h; and failing entirely to consider the ef feet of a major accident on the terrestrial
__.=..:-.- -
and aquatic biota of the area and the Colunbia River and especially upon rare, threatened and endangered species.
The 'aplicant is required by 10 CFR 51,20(b) to quantify, to the fullest extent practicible, the factors considered in calculating the environmental effects of the project.
It is well known that the effect of low-level radiation on living crganisms is cumulative.
Radiation &
Human Health, Jbhn.W. Gorman, M.D., San Francisco: Sierra Club Books, 1981, y
~..
pg. L'f.
Therefore the Arplicant should be required to provide a ec plete and accurate analysis of the existing radiological burden.
Section 2.8 of the ASC/ER does not. This section fails to discuss the results of- ~~ ~
- - ~ ~
innumerable studies done since the 1950's on aquatic life of the ColumJ; bia River and Pacific Ocan, a partial listing of which is available from the Department of Eners;y - Richland Office. These studies show that radiation from artificial sources, ie. Hanford, exists in fish and. cy _..
sters (eg. Federal Water and Pollution Control Agency, May, 196h), birds (eg. C00-151h-3, " Distribution of Mallards from the Columbia Basin Region as Indicated by the Presence of 65Zn in Birds Shot By Hunters in the
'acific and Central Flyvays", June 1967, Fred A. Glover, g a_l. Colorado l
State University) anC river sediment (eg. TID-25895 "Radionucleides in Transport in the Columbia River from Pasco to Vancouver, Washigton, W.6 Hauschild, Battelle-Northwest, 1971). Additionally news articles (eg.
" Rolling Across the Desertf... Radioactive Tu=bleveed", Seattle P-I, ~May 3, 1979) refer to numerous occurance reports made to the DOE regarding radioactive nice, tumblevced, snakes, vasp nests, coyote and rabbit feces and migratory birds.
Appli' cant'sSection2.8ofASC/ERdoesnc(discuss,.
.-=
==:
for exa=ple, the artificial radiation in the Columiba River sediment I
downstream of the plant. Thus, there is reason to conclude that Applicant has underestimated the effect of past and present Hanford operations on the environment and underestimates, additionally, the effect of the oro-i
_.__ _. _ = _..
~^^ ~ =
jcet.
Applicant's analysis that the effects of low-level radiation from S/miP will be nonexiste it is inconsistent with cur own reading of the literature.
See Revised Contention 30_).
There is no reason to believe that Applicant would have applied more stringent standards to calculating the doses and effects of radiation from WPPSS 1,2 and h, currently under o
construction. Thus we conclude that Applicant has underestimated the cu-mulative effects of S/ETF and WPPSS 1,2 and h.,_
(
Petitioner believes that there is no reason to conclude under NEPA or Section 51 of 10 CFR that the effects of a major accident on the terrestrial and aquatic biota of the area is a " secondary impact", as stated by the Applicant. The Applicant should be required to assess the impact of an accident on rare, threatened and endangered species which depend on the area, for example, the Chinook salmon and the bald eagle.
Since Detitioner believes that Applicant's analysis that the primary in.
pact of an accidhet is small is entirely wrong (Revised Contention 32 ),
it is not inconsistent to conclude that the Applicaht has vastly under-estimated, in this case by o= mission, the so-called " secondary impacts" which Petitioner believes to be significant.
Revised Contention 15 (Reulaces 37, 38, 39 and LO)
Petitioner contends that Applicant incorrectly concludes that "none of the areas to be disturbed by the proposed project have sigai-ficant ' alue" thus understating the environmental cost in the analysis v
required by 10 CFR 51.20(b).
This statement made in Section h.l.3 of Auplicant's ASC/ER is contradicted by Applicant's own admission that the riparian area and the Old Hanford Townsite ar,e important to many species (e6 u..~ angered
^
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laptors[ Oregon Svdllovtail butterfly). Applicant has stated thaf,~on ~~
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c struction of the proposed intake / discharge system in the riparian area vill remain within one acre, (ASC/ER h.1) but has not shown that either:
- 1) containing the construction to one acre vill not have a significant
- -- --negative impact upon the area 'or 2)-that-the means-presently' exist tc - --
~~~
enss-e that construction vill indeed affect only one acre. Moreover, Petitioners believe that the proposed construction vill do irreversible harm to the biota of the riparian com= unity through direct destruction and loss of habitat.
Revised Contention 16 (Reclaces 38 and 39)
Petitioner centends that Applicant has failed to show that there are adequate ceasures to ensure that damage to the environnent and living i,.
orcanisms is minimized during construction, a position Applicant uses to meet the requirements of IEPA and 10 CFR 51.20(a).
Applicant relies on assertions such as " construction of thc2/EUP_ _-.
vill have no significant effect on vildlife" (ASC/ER L.3) and that cerg tractors and subcontractors vill take every effort to minimize damage of habitat and biota. (ASC/ER h.5) There is no reason to believe that such efforts vill occur or be satisfactory without evidence of a
.L C"*
concrete plan. The sensitivity of certain species can be very great with regard to changes in their environment and Applicant has not drawn on similar experiences nor projected with any specificity (as rerequired by 10 CFR 51.20(b)) what the effects wil1 be.
A plan needs
~
to exist to analyze the real effects before $rreversible harm is done.
Revised Contention 17 (Penlaces 37, L1, h3, and kh)
Petitioner contends that Applicant has failed to provide evidence that construction and oneration of the Skagit/Hanford Project vill not ir*rencrably harm rare, threatend and endangered. species of vegetation nacely Rorippa calycina var. columbine, Astragalus sclerocarnus and Crvotantha leuconhae as required for a finding of the environmental cost under NEPA and 10 CFR 51.20 (b).
Applicant does not, in the first instance, adequately quantify the location _ o_f.these in_ASch.-section h.1.---Neitheredoes-it provide = evidence l See CFSP Revised Contention 16, to substantiate its claim that Rorinpa "should not be threatened." (ASC/ER section h.l.1) Without stating where this vegetation is found and how contractors and subcontractors vill avoiddestroyingthemthereisreasontobelievethat_5his_vegetatim.
vill not be protected.
Additionally the Oregen Swallowtail butterfly, a " species of interest?"
depends on tarragon in the Old Hanford Townsite for which no detailed dC.a has been provided. Applicant has also failed to provide any indica-tion of its ability to detect if irrenerable harm is being done a. to act accordingly.
,w.
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Revised Contention 18 (Reclaces bl,h3 and hk)
Petitioner contends that Applicant has not nrovided evidence to shov that the construction and opertien of the Skagit/Hanford Project vill r.ct-'
cause irreperable harn to avifauna of the area directly and by the destruc-tion of habitat as required by 10 CFR 50.20(b).
Section 2.2 of the ASC/ER does not identify with any specificity where all species of raptors and other birds are located.
Heither does Anplicant provide substantiation for statements made in the ASC/ER that the effect on raptors is "exDected to i= prove" (section h.1.1) and on curlevs vill "probably be not lasting".(section h.2.h) The destruction of habitat and the operation of transmission systems is know to cause harm to species nov threatened and endangered such as the bald eagle and peregrine falcon (although the pri=ary reason for their dimintive numbers is the use of DDT).
Applicant has not provided a plan, including schedul-ing, refered to in ASC/ER section h.1.1,that vill ninimize negative effectc on the avifataa or detect them if they occur.
Absent these' shovings Petitioner has reason to conclude that construction activities which Applicant admits vill depress certain species,and transmission lines vill harm the avifauna of the area, including rare, threatened._and..
.. _ -.. _.. - -. -...:-- =.: =-
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endangered species.
Revised Contention 19 (Renlaces 37, 38, bl, h3, and hh) l Petitioner contends that Applicant has not provided evidence to show that the construction and operation of the Skagit/Hanford Project i
vill not irreperably harn theQquatic life of the Colu=bia River, most
. notably the_anadromous_sah-nn,_and..thus-have-underestimated-the environ-menthl cost of the plants as required by NEPA and 10 CFR 50.21(b).
~~~
The Applicant haa not provided adequate quantitative data on the location of allaquatic species in the area affected in ASC/ER section 2.2.
l Furthermore their desc2intion of the swimming and migratory habits of i
salmon along the Hanford Reach in the same section only refers to the I
" preference" of the fish without providing even a percentage. Without adequate c.uantitative data as reouired by 10 CFR 51.20(b), the effect of l
l
\\
the plant is difficult to gauge.
The Applicant states that scheduling vill be used to minimize damage to aquatic life. This plan is not provided in any detail nor is there a showing of the extent of their ability to minimize the harmful effects that are nrojected. For example, if the population is destroyed 255 instead of 35%, the damage has been minimized yet the information itself, rather than the conclusion, is necessary to determine the cost -
henefit ratio of the action. Applicant is similarly vague on the issue of impingement of the Chinook Salmon fry by the intake structure.
In sum Applicant does not provide any basis for the condlusion stated in ASC/ER section b.1 that the effects of river construction on salmon "is not expected" or that the harm to aquatic life caused by the oueration of the Skagit/Hanford vill out weigh the benefits of the project.
Revised Contention 20 (Replaces CFSP-37,'38, kl.and hh)
Petitioner contends that Applicant has failed to show that con-struction and operation of the proposed project vill not do irreperable harm to the giant Columbia River limpet and the great Columbia River spire snail pursuant to the recuirements of 10 CFR 51.20(b).
Se'etion 2.2.2.9 of the ASC/ER _st.ates..that_these_speciesg. usedm m _
~
to inhabit the entire Columbia River and at present are found solely, and thus depend on, the Hanford Reach.
Since the construction and opera-tion of the intake / discharge structure is in this area it stands to reason that Applicant would have examined the potential effects upon
= = =.
~~
these diminished nopulations. However, the ASC/ER contains nothing to show that this is true, thus Pctitioners have reason to conclude that the thernal, chemical and radioactive dischstges may negatively impact en the great Columbia River spire snail and the giant Columbia River limpet thus affecting the cost-benefit ratio in favor of the project.
. _dsed Contention 21 (Renlaces CFSP h2)
Petitioner contends that Applicant has failed to. consider the b-
cumulative effect o# additional intake and discharge structures or the cumulative thermal and radiological effects of other facilities, presently non-Sterational, on the Columbia River and its bieta.
These facilities include WPPSS 1,2 and h and Pebble Springs, Units 1 and 2.
The Staff has expressed in the Pebble SFrings docket-that there is a limited number of intake structures that the Coludbia River can supnort with no negative effect.
The Applicant has not pro-vided any discussion of this issue in its ASC/ER.
' ~ ~ " "
Revised Contention 22 (Replaces CFSP h5)
Petitioner contends that Applicant has underestimated the en-vironnental effects of decommissioning such that the cost-benefit ba-lance required by 10 CFR 51.20(b) is improperly weighed.
Applicant fails to support its allegation that deco =missioning "does not usually invoke environmental impacts which are unique to a snecific project." ASC/ER 5.8 As with the construction of the plant, the environmental costs of decoccissioning, whether by dismantling, en-toudbmentormothballinF,shouldbeweighedwit5thesite-specific characteristics in mind.
As decommissioning represents an equal or grea-ter undertaking and is an act that cannot be avoided once the plant is
.._. _ _ _ constructed, its it: pact on-the environment =and: biota ~ must=belddressed'."
For example. if a particular species runs the riek of a setback during construction it runs the risk of significant har= during the process of.
decommissioning as well. Applicant has stated that there are species in the vicinity vhich depend on_the..ar.ea for_suryival.
INTERACTIVITY BETWEEN THE PROJECT AITD INDUSTRIAL FACILITIES Revised Contention 23 (Renlaces CFSP h6 and h8)
Petitioner contends that the Applicant has failed to conduct an assessment of the notential inoact of surrounding nuclear and chemical facilities on th'e S/ENP and its ability to continue operation in the case of an event at these facilities and the consequences of loss of operability as required by 10 CFR 100.10.
Section 100.10 of 10CFR is a discussion of factors to be consi-dered when evaluating sites and states that these include "those rela-
tinhbothtothenroposedreactordesignandthecharacteristicsrecu-liar to the site."
For exannle, the Applicant would not vant to site
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the reactor near a liquid natural gas facility. The industrial facili-
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ties near the proposed site include the Fast Flux Test Facility (FFTF),
four miles from the site, which, according to Richard Webb (The Accident Hazards of Nuclear Power Plants, Amherst: The University of Massachusetts Presa 1976, chapter 10) has the potential for a 1,160 SiEC explosive-r nuclear accident Dr. Webb states further that its containment is only capable of withstanding up to 150-300 lbs. TNT. Applicant has not ana-lyzed the project's ability to withstand this event, nor demonstrated that the project conforms -tolo CFR 100.10(d) with "apuropriate and ade-quate compensating engineering safeguards."
Applicant has not conservatively analyzed the other chemical and nuclear facilities within fifty miles which include the development
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of a hazardous vaste dumn (3 miles away) and'the"N-reactor which has no c.ontainment building.
Revised Contention 2h (Reclaces CFSP'h7)
Petitioner contenh tht the_ Applicant-haszfailed-to conduct =anr-
~~
~~ assessment of the potential impact of the S/ENP on nuclear facilities and activities located on the Hanford Reservation and the ability of these operations to continue in the event of a major accident at the S/HNP as required by 10 CFR 51.20 and 10 CFR 100.10.
These facilities include the Wye Burial Ground (th5ee miles a-vay), the FFTF (four miles away) and WPPSS plants 1, 2' and h.
A cata-strophic accident and steam explosion would, according to WASH-Th0, affcet the operation of these facitities and would cause significant expense.
GEOLOGY OF PROPOSED SITE Revised Contention 25 (Rerlaces h9, 50 and 51)
Petitioner contends that the present geology and seismic studies presented by Annlicant in Section 2 of the PSAR are inadequate and do not meet the requirenents of 10 CFR 100 Appendix A.
Applicant has not
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changed the sefsmic design of the project to reflect the local roology and seismology and thus the S/ENP is not properly designed to withstand the potential seismic events of the site.
Applicant has not considered the safety significance of all line-ments within a five-mile radius of the site.
See NRC Staff Question 231.1 Aunlicant has not adequately assessed the Cold Creek syncline. See NRC Staff Question 231.2.
A recent report by the Departrent of Energy (Rockwell-Hanford Operations,1981, Subsurface geology of the Cold Creek Syneline, RHO-BWI-ST-lk, Myers, C.W. and Price) suggests that se-veral structures and geophysical anonalies within the Pasco Basin may be faults. Aeplicant has made no determination if these are indeed faults.
_S,e_e, NRC Staf f Question 231.3.
Lacking such a determination e
and review of Applicant's findings, one must conclude that faults do exist which would have a significant impact on the proposed project.'
The design has not been changed to feflect the change in site.
InaMemorandumtoElinorAdensam,Chie'f[LicensingBranchNo.kfrom
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George Lear, Chief, Hydrologic and Gee',echnical Engineering Branch, Divi-sion of Engineering, dated March 10, 1982, Mr. Lear states that "The Skagit/Hanford NuclearA rchectr Units-1-and_2 =has-been moved-from=aT - -
4 area having hard rock essentially at ground surface to an area having sand to a depth of 200 ft.
The plant foundation design details, however ha'e_ngt been changed." (emunasis added) Further evidence of, this matter v
can be found in the answer to NRC Staff _ Question 220.10.-.
Revised Contention 26 (Reulaces h, 50 and 51) 9 Petitioner contends that electrical equipment, other than that supplied by General Electric, vill not be qualified to IEEE 3hh-1975 and Regulatory Guide 1.100, and thus the plant vill not conform to current standards of safety and regulctions.
Revisions 1 and 2 to the NRC Standard Review Plan Section 3.10 state that qualffication of electrical equipment should be in accord with IEEE 3kh-1975 and Regulatory Guide 1.100.
However, Applicant states
._ e -, - -
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in Section 3.10 of the PSAR that the seismic oualification of clectri-cal equipment other than that provided by Genersl Electric vill te in accord with IEEE 341-1971.
4.
WASHINGTON DUBT.IC POWER SUPPLY SYSTEM PLANTS h AND 5 Revised Contention 27 (Renlaces 52) l Petitioner contends that Anblicant has not considered the take-over and completion of the terminated nuclear projects h and 5 of the Washington -Pubite'-Power Supply System as an ehvironmental]y,' econorical-ly preferable alternative to the preposed project as rea.uired under NEPA and 10 CFR 51.20(a).
l These plants are under NRC jurisdiction and thus easily consider.ed as a viable alternative to the proposed project. Apnlicant's restonse to NRC Staff Question 230.01 in the ASC/ER is wholly inadequate because it fails, for examole, to discuss Auplicant-Pacific Power & Light's op-portunity to purchase WPPSS 5 in February, 1982. Most importantly, the di,scussion provided in response to this question makes it very clear that Applicant has not investigated this alternative. _
EMERGENCY PLANNING Revised Contention 28'(Reclaces CFSP SL)
Petiticner contends--that: Applicant: has.-failed to meet the -reF "-
quirements of 10 CFR 50 Appendix E (II) in not supplying the necessary information.
Atplicant har not provided the information required by Paragraph B: Appendix A which Applicant claims fulfills this turpose, states "To be provided subsequently."- - - - Aeplicant has not Drovi.ded the 4 n enr=ation--
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required by Paragraph C as it fails to describe the proceedures on how an evacuation vill be carried out. Applicant states in Section 7.h.2.1 of the PSAR that "if evacuation is deened necessary, it vil3 be carried out in accordance with detailed evacuation plans which vill be contained in Benton and Franklin Counties Emergency Response Plan."
This'is inade-Applicant has failed to provide features of the facility to be cuate.
7 provided for onsite energency firstaid ac required by paragraph D.
m..
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s Applicant merely states in ASC/EP section 7.5.1 of the PE AR that "further description of the facility will te provided in the FSAE."
Applicant continued by failing to discu'ss 'the major.intedinents to the evacuation or the taking of protective actions.
Applicant does not consider the pro-nuclear attitudes of local residents and their dis-regard for exposure to radiation. Thus Applicant has not meet the
~
requirements of paragraph G.
Applicant has not done a preliminary anal-ysis reflecting the need to include facilities, systems and methods for identifying the degree of seriousness and potential scope of radio-logical conseo.uences of emergency situations with in and outside the site boundary.
Applicant in this instance has failed to meet varagraph H.
Revised Contention 29 (Fenlaces 57)
Petitioner contends that the cost-benefit analysis performed by the Applicant is wholly falsified.
This cost-benefit analysis does not represent an analysis " conducted fu13y and in good faith" (See Calvert Cliff Coordinating Con =ittee v. U.S. A.E.C.,D.C'." Cir.,1971 at p 11).
In doing so Applicant has vrongfully concluded that the proposed project benefits outweigh the cost, and that the proposed uroject is cheaper then other alternatives such as coal.
Applicant has failed to account for the cont of design changes
--due-to-the U!r r~equirements and other reqUirsd safety changes. Kenonoff surpa at Chapter 6.
Applicant overestimates the reliability of the proposed project.
One way Applicant has done this overestimation is bi a'ssigning a capacity factor of 70 percent to the project when it should have a capacity _ factor _of-no-more-then-60-percent.- Komonoff sup~r'a p 2W-77
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Further Applicant has failed to account for the unreliability, due to its location.
Applicant vill be required to ao.uire more reserve capacity to make up the deficiet thus increasing the cost of the project.
Applicant underestinates the effects of low-level radiation em-missions on the health of the popluation near the project and facilities related to the fuel cycle.
(See Revised Contention 30) Applicant fails to include the chemical and radiation hazards of the zirconium ng L
oroduction in Albany, Zirconiun Pasards & Nuclear Pro"its (A Ecport en Teledyne Vah Chane; Albany, Pacific Northwest Pesearch Center,1979) de-tails the chenical discharges (eg. 6,000 lbs. ac=onia, 1-2 tons sulfer-t dxide and 1 ton MIBK, each da;r) and nuclear vastes (eg. 2,000lbs/ day Radium-226.).
Applicant has underestimated devatering, erosion control and soil stablisation techniques and the cost of tae methods thereof due to underestinaton of the anticipated excavation level.
(Egg NFC Staff Question 2hl.1) Applicant also has grossly underesticated the cost of nuclear vaste dispocal and storage.
Effective 1/15/82 the cost of lov-level vaste burial at the U.S. Ecology du=p went up 625 percent partial-ly to cover the expenses for increased surveillance and a site closure fund.
This example vill not only affect the projections of Applicant's cost for low-level vaste disposal but also illustrates how unpredictahlb and expensive the costs can be.
Applicants projections do not taEe these into account.
Komonoff supra e 26h-5 Applicant misrepresents reprocessing as current and viable technology and therdfore cannot adequately assess the cost of using the technology.
_ _ _ - - -.. -- =
Applicant fails to adequately assess the cost of decommissioning a reactor as large as the S/HNP units.
Applicant fails to consider the potential cost of deconnissioning the project in the case of an accident.
Applicant provides no basis for the assumption in ASC/ER,section 5.8 that
_ "at _the. present time deco==ission' can be perforced sifelyaniilt reason- ~
able cost."
Kononoff supra p 272-3 Applicant, in stating that seven years vill be sufficient to construct each unit (ASC/ER
), ignores present construction times for nuclear pcuer blants.
Applicant should use a time frame of 8.9 years.
(This is an average based en NUREG 0030 vol. 5 nos 1,2,3, pp 1-008 to 1 1-015.
See Komonoff n. 2L6-7.)
O l
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Auplicant has also misstated the fixed charge rate for nuclear to be 137885 tuul coal lb.58%. Komanoff shovs theseto be higher for nu-clear. (pp170-2) Applicant has also failed to consider higher interest a
rates that it would have to pay for building a nuclear power plant.
See Komanoff pg. 271.
And lastly, Applicant has underestimated the capital cost escalation for the project compared to a coal project.
See Komanoff,-Section 10.2.
SOMATIC AND GENETIC EFFECTS OF RADIATION RELEASES Bevised Contention 30 (Reclaces CFSP 58, 59 and 62)
Petitioner contends that Applicant underestimates the somatic and genetic effects of radiation released from the proposed project during normal and abnormal operating conditions thus entirbly underestimating the cost of the plant in the cost-benefit analysis required by 10 CFR 50.21(b).
Applicant fails to accurately portray: 1) the radiation dose to nuclear workers at the project, whether permanent or tectorary (" sponges")
including from the deccenissioning urocess and t'he'effect such vorkers
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vill have on the overall human genetic pool; 2) the effect of routine and accidental releases of radiation of children in utero; 3) the exist-
_. _.ing radiological and.othed health burdens of people-residing inrand a round the Hanford area and Columbia River without which it is impossible to accurately assess the radiobiological impact of the proposed project.;
- 4) the complete history of artificial radiation in the land, water, and biota of the Hanford area and the Columbia River without which it_i_sA _._
possible to accurately assess the radiation ~ doses caused by the proposed project; And 5) the conplete meterological and other characteristics of the site necessary to determine the radiation exposure pathways.
The health effects of ionizing radiation, whether somatic or ge-netic, are cumulative, thus existing radiological burdens must be con-sidered. (Gofhan',-sunrd,fpg. h7) 'Purthermore, the age of irradiation is all-inportant (ibid. pg. h6) with in, utero doses the most notent (ibid
4 pp.'126,729). Auplicar.t does not provide projections of. children in utero in its population projections in the ASC/ER.
Dr. Rosalie Bertell states that radiation has an enhancing effect on existing-health burdens and that such information is necessary to correctly determine the impact of a proposed project. See X-Rav Exuosure and Premature Aging, Journal of Surgical Oncology, 1977, pg. 379. and Radioactive Effluents: Pebble Surines Nuclear Plants, testimony be-fore the Oregon Energy Facility Siting Council, Auril 3, 1978. Gof-man discusses the implications of occupational exposures to the hu-man genetic pool (ibid. pg 58h) and calculates the the radiation ex-posure and effects to temporary workers (ibid.pg.586)
Applicant relies on models which underestimate both the dose and the effect of radiation that would be released from-the project by failing to incorporate the findings of "The Heidelberg Skudier" (Radioecological Assessment of the-Whyl Nuclear Power Plant) 1978, Department of Environmental Protection of the University of Heidelberg, University of Heidelberg, NRC Translation 520, U.S. NRC.
_ Revised Contention 31 (Reulaces_CFSP 60)
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Petitioner contends that the radiation monitoring system is inadequate and thus vill understate the dose to the public received from routine and abnormal releases of low-level radiation from the proposed' project. Auplicant should be required to use the " Spider-wort Strategy" which would provide significantly improved information. '
Appliant relies on models that are outdated and obsolete and i
therefore vill render their milk-monitoring system inadeo.uate.- - - - ~ - - - - - * - ~ ~
See^
"The Heidelberg Studies" supra. Moreover, Steve Given of the Spider-vort Committee, Portland, Oregon has stated that the Spiderwort Stra-tegy would be a significant improvement over current monitoring methods troposed by Applicant because, "it is the most readily quantifiable means of estimating all biologically significant forms or radiation r:3 eased from a nuclear power plcat".
Spiderwort, Tradescantia, is
a highly sencitive indicator of sc=atic mutations which yeilds re-sults within 8 to 12 days from exrosure.
It has been used extensively
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in Japan. See "The Spiderwort Strategy", Sadoa Ichikawa, PhD, Laboratoht ~
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of Genetics, Saitama University, Jaoan. K0GAI Newsletter, Vol. 6 No. 3,1978.
PP03 ABILITY AND m ECT OF AN ACCTDENT 4
Fevised Contention 32 (Perlaces CFSP 63 and 6h)
"etitioner contends that Applicant underestimates the doses and effects caused by the release of radiation in the event of an accident at the S/HNP and thus wrongly concludes the benefits of the facility outweigh the ecste 'inder 10 CFR 51.20(b).
Applicant fails to include an assessment of early illnes: es and' attendant early morbidity which would be significant contributors to the human tel] in the event of an accident at the project. These in-clude: respiratory innairment, hypotbyroidis=, temperary sterility in males, permanent sterility in females, in utero effets, genetic effects, did the synergistic effects of one or more of the above illnesses and existinet, chronic diseases. Petitioner challenges the f3ndings of Ap-plicant's ASC/ER Section 7.h which find the so-called primary effects of an accident would be negligible.
See Risk Assessment: Pebble Snrings
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Huclear Plant, testimony fiefore 05egon Energy Facility Siting Council,
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March 31, 1978, by Richard B. Hubbard.
l Furthermore, Applicant underestimates the doses and effects by*
using as a receptor the standard man, the least succeptible form of
_..___ __h-n li'fe;; as-stated-in Revised-Contention ~ 30.-
Applicant also tsils
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to consider the radiological effcets of accidental releases of lio.uid effluent on the surface and groundwater supply of the downstream popu-lation in ASC/ER Section 7.h.8. which assu es such releases vill not occur.
Revised Contention 33 (Renlaces 65_1 Petitioner contends that Applicant has not met the'reauirements a
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of 10 CFR 5'O.3h(f)(1)(1), NUREG 0718 Fev. 1 Action Item II.3.8(1) requirements.and has no intention of meeting these requiremente.
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Action Item II.B.8(1) states. " demonstrate how the, risk
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assessment program vill be scheduled so as to influence system designs '
as they are being developed." Applicant's resnonse to this requirement merely states that 70 percent of the nuclear supply system components hav_e_already_been fabr3 cated and delivered into storage and that two -
thirds of engineering design has been ecmpleted.
Applicant goes on to state that any desing changes vill be made on a judgenental basis and not be license requirements.
Clearly this Board has no basis, and not even the hoce, to believe the plant vill be constructed d a a manner to adequately protect the public health and safety. Beaver Valler, supra.
Revised Contention 3h (Replaces CFSP 16, 67 and 68)
Petitioner contends that Applicant underestimates the probabi-lity and effects of an accident at the S/ENP thus falsly concluding that the benfits outweigh the costs in the analysis required by NEPA and 10 CFR 51.20(b).
Applicant underestimates the probability of an accident by re-
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lying upon the' Reactor Safety Study (RSS).which, according to the testi-__
mony of Richard Hubbard, suura, incorrectly assess: 1) the contribu-tien of BWP. accident secuences to the probability of a major radiation ~
release, 2) the ability of the E=ergency Core Cooling,8ystem to perform
__lts _ intended -functionst 3)- the effect of aging on reactor safety;4)~the -
effects of sabotage; 5) the impact of unresolved safety issues on overa all risk; and 6) relies exc'essively on " single failure" events when it is know that multinle failures exist. Applicant underestimates the ef-fccts of an accident further by overemphasizing the effectiveness of eva-teation, using outdated bio-offect models and understating the effect of common-cause failures such as sabotage, fire, earthouake etc. which
-according to th_e_ Lewis Report, NUREG/CR Oh00 are important inadequacies --
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of the RSS. Until the Applicant demonstrates that these inadequacies have been resolved in their "rebaselining" of the ESS these is reason to conclude that the risks of an ace,ident are significantly underesti-mated by the Applicant.
Revised Contention 35_jReplaces CFSP TO)
Petitioner contends tt4at Applicant underestimates the poten-tie.1 and significant costs of an accident in section 7.h of the ASC/ER as required ~by 10 CFR 71.20.
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The costs Applicant does not assess include: 1) the effects upon co=rercial river traffic on the Columbia River, 2) the temporary or rernanent closure of adjacent nuclear and industrial facilities; 3) the cost of clean-un and decommissioning; b) the long-term contamination of water supnlies within id without the fifty-mile radius decendent on the Columbia River erd
-) the cost of preventing the lionid pathways 4f radioisotopes to the Columbia River as discussed in ASC/ER Section 7.h.8.
Petitioner, alleges these costs would be significant.
The Colun-bia River is a major waterway, supulying an avenue of river traffic,
--hydroelectrieprprecreattons vater and fishFAn ' accident at3he=
S/HNP would seriously contaminate the water, silt and fish of the ri-ver, neFatively impacting upon the health of those using the river for recreation, drinking and food for many years to come.
The impact of this.vould far. exceed. the 50-mile _ radius.of._ the. plaat ase is_ evidenced--
by studies refered to in Revised Contention 1h which show that Hanford is the source of artificial radionucleides to the Pacific Ocean.
The cost of clean-up and decommicsioning for even a non-catostro-phic accident vould be enormous, as shown by the TMI-2 experience where, three years later, it is still too early to assess the total cost.
The cost of replacement power is also significant as evidenced by the Trojan Control Building proceeding where every hour of the shutdown cost PGE
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$h0,000.00.
Sinilarly, other significant investments such as the FFTF, four miles away, would be jeopardized in case of an accident g
CONCLUSION CFSP Contentions 3, 20, 26, 27, 53 and 55 have been dropped.
CFSP Contentions 11, 28, 29, 30, 31, 32, 33, 3h, 35, 61, 66 and 69 have.been. withdrawn pending the issuance of the NRC Staff's Safety Evaluation Report.
Int'ervenor, Coalition for Safe Power, hereby sub-r mits the remaining thirty-five revised contentions to the Board to accept under 10 CFR 2.71h.
4 Respectfully submitted, MM Dated this day, the 2hth Mina Bell, Staff Intervenor
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of May, 1982.
Coalition for Safe Power 4
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NUCLEAR REGULATORY COMMISSION
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,BEFORE THE ATOMIC SAFETY AND LICENSING DOARD In the Matter of
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PUGET SOUND POWER & LIGHT COMPANY,
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DOCKET NOS.
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STN 50-522 (Skagit/Banf ord Nuclear Project,
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STN 50-523 Units 1 and 2)
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CERTIFICATE OF SERVICE I hereby certify that Coalition For Safe Power's REVISED CONTENTIONS, dated May 24, 1982, has been served by placing true copies of said document, in the U.S. Mail, first class, postage prepaid, on May 25, 1982, in Portland, Oregon on the following:
(*) Denotes serve by Express Mail Richard Black, Esq.
- John Volf, Chairman Council for NRC Staff Atomic Safety and Licensing U.S. NRC
(
9 Sh'epherd St.
Director Chevy Chase, MD 20015 Washington D.C.
20555 Dr. Frank Hooper F. Theodore Thonisen University of Michigan Perkins et al School of Natural Resources 1900 Washington Building Ann Arbor, MI.
48109 Seattle, WA 98101 Gustave Linenberger Washington EFSEC Atom 2c Safety and Licensing Nicholas Lewis, Chairman Board g,gy gt, py_33 Olympia, WA 98504 ha.1$i g on D.C.
20555 Ralph Cavangh Atomic Safety and Licensing Appeal Board
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.. 25 Kearny_St. _... _ _ _ _.
San Francisco, CA 941,08 Washington D.C.
20555 Terence Thacher Secretary of the Commission f}01 Docketing and Service Branch 1 ncaid U.S. NRC ugene, Or, 97403 Washington D.C.
20555 Mtj
'Nina Bell Coalition For Safe Power Dated this 25th day of May
!082. Portland, i
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