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' San Francisco September 2, 1963 Eber R. Price Assistant Director Division of Licensing & Regulation The United States. Atomic Energy Commission Washington 25, D.C.
Sir:'
This is in reply to your letter of August 1, 1963 with regard to the proposed PG&E nuolear powered plant at Bode-ga Bay.
In reference to my previous letter to President Kennedy I must stand corrected on my statement that the AEC lowered the distance limitation from 1/2 to 1/h mile.
However, I must take issue with the interpretation (and there is legal opinion on my side here*) that Part 100.10 (d) of the Reactor Site Criteria can overrule Part 100,10(c)(1) which specifically states: "No facility should be located closer than one-fourth mile from the surface location of a known earthquake fault."
This is one of the rare instances in which the authors of the latest Reactor Site Criteria (April 12, 1962) have pinned some-thing down and discussed explicitly the safety aspect in lucid terms.
While admittedl are to be used only as a " guide"y the Reactor Site Criteria still it would seem that some limitations must be pertinent.
If the 1/h mile limitation does not apply to the San Andre s fault, which a
is the most active on this continent, then seemingly none of the reactor site criteria need apply, and this TasE publication was a waste of time, effort and money -
a sop to the unsuspecting.
As the criteria stand now, they are so loosely worded and ambivalent with regard to safety as to be practically meaningless.
On the subject of subsidy, your statement that "No financial or other commitments by the Commission are involved" in the Bodega plant is simply not true in the light of the federal publication entitled:
,, _ C' Hearings before the Joint Committee on Atomic Energy a.a W, e.
l 116,],.
TabTe~I 4-page 2Ii1: states thaT the " estimated
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average annual assistance or annual difference lease as compared to private ownership" will be between $376,100 and $641,000 On page 240, section 7, second paragraph we read, " Government ownership and leasing of special nuclear materials prcvides a form of financial assistance to private utilities to dhe extent the Government use 8709180334 e51217 '
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charges are less than the inv,entory carrying charges that would be necessary if the. utilities had to finance the pu) -
chase of the materials."
Aleo, I would like to point out that the U.S. Government under the Prico-Anderson Act (sponsered by the AEC) - passed as Public Law 85-256 by Congress on September 2, 1957 assumes a liability of
$0.5 billion for each catastrophic nuclear accident.
The private insurance companies, after pooling their resources felt ebliged to limit their coverage to a mere
$60 million.
Their report included the following state-ments:
"The hazard is new.
It differs from anything which our industry has previously been called upon to insure.
.... The catastrophe hazard is apparently many times as great as anything previously known in industry and there-fore poses a major challenge.....We have heard estimates
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1 of catastrophe potential under the worst possible circum-stances running not merely into millions or I
tens of millions but into hundreds of millions and billions of dollars.
It is n' reasonable question of public policy as to whether a hazard of this magnitude should be permitted
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.... 0bviously there is no principle of insurance that can Le applied...where the potential loss approaches such
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astronomical proportions.
Even if insurance could be r
found, there is a serious question whether the amount of damage to persons and property would be worth the possible benefits accruing from atomic development."
If these nuclear plants are so safe, why do the private insurance companies so limit their coverage?
Also it should be made clear that here too is another form of subsidy paid by Americans.
Possibly these subsidies to the private utilities are justifi3d, but both the AEC and the PG&E e'
i are not justified in misleading the public that this oper-ation is entirely privately financed.
A. M. Weinber6 (Director of Research, Oak Ridge National Laboratory) made a fitting conclusion to my point when he said:
"....the current prices represent a substantial governmental i
subsidy for the Bodega Bay plant."
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As the third and most important point, I would like to bring to the attention of thV AEC a matter which I did not discuss in my previous letter to President Kennedy, and I
which, I think, abould be carefully scrutinized.
ing the ABC publication TID lh6hh Calculation of Distance l
In read-L l
Factors for Power and Test Reactor Sites - MarcE 23, f
1962, I became curlbus as to what the actual exclusion l
area for the Bodegt plant would be with its first reactor,
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4 and what it would be with-its final total of four reactors-on the site in the future.
Since the proposed Bodega plant is of an experimental nature (under earthquake.
conditions, at least)'in which'the containment dome is replaced by the untried pressure-suppression system, and since this system consists of piping underground which is certainly subject to earthquake action, and since the breakage of piping could also cause a loss of coolant-and hence a meltdown and rupture of the. vessel, ~it;seems very logical that more than one.and very possibly all of the reactor vessels could be ruptured in the-event of an earthquake.
Therefore Part 110.11(b)(2) of the Reactor Site Criteria (April 12, 1962) would apply, and the cal-culations reflect this probability.
The. disturbing thing about the conclusions here is that not only would the U.C. marine biology' laboratory be in the exclusion area, but the town of Bodega Bay as well.
Has the PG&E notified the AEC of this eventuality, and if it has, what course 1
will the AEC takef Will this simply be a case in which the AEC again ignores its own' rulings (as -in the 1/}4 mile limitation) for the benefit of the PG&E and to the detriment of the safety of the citizens of the Bay Area
. and Sonoma Countyt Certainly according to the calculations which are reasonable and logical, if the. AEC permits the L
PG&E plans to be realized it would.seem that the town of Bodega Bay would have to be eventually abandoned since according to the Reactor Site Criteria Part 100.3 (a):
" Residence within the exclusion area shall normally be prohibited."
Do the people in Bodqga know that, "resi-dents shall be subject to ready removal in case of necessity"?
Indeed, this is a very tragic situation when the life (not to mention the livelihood) of a town like Bodega can be snuffed out by the whim'of a power utility company executive in a city miles away.
Finally, I cannot rest assured that " construction as is permissable prior to the obtaining of a construction permit
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must be undertaken at the applicant's risk", since the i
AEC ruled favorably on the construction permit of the Enrico Fermi plant in Detroit which was opposed by local residents and was recommended against by the Advisory Committee on heactor Safeguards.
The reasoning was that
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the sponser7 the Power Reactor Development Company, had spent so much money on the installation.
Is the AEC j
aware that the PG&E has already* spent close to two million dollars on Bodega, and is the public to see a repeat per-formance on the Enrico Permi plant fiascot Is the AEC i
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i considering any changes in'its rules that encourage com-panies to become so heavily committed financially to pro-
<jects that 'it is almost impossible to turn down the con-struction permite even in the. light of more important fac-tors?
I would maintain that there is need for deep and extensive reform in-the reactor safeguard criteria.
I hope the AEC will become alert to the necessity for this j
requirement before the 'public in violent reaction rejects l
the whole atoms for peace program, which in spirit is a commendable project.
The atom can be a great aid to modern civilization, but current developmental policies of the.
AEC cannot help but make it a curse to present and future generations.
Yours tr)u y, f
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/m Mel Tatsapau V-e
- Rebuttal of reply to petition to reopen for further hearing before the California Public Utilities Commission - k June 1963.
Application h3808. Interim 4
decision 64537.
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