ILLINOIS POLLUTION CONTROL 

BOARD

November 15, 1971

in the matter of

JOINT APPLICATION OF       

)

PCB 71-20

COMNONWEALTH EDISON CO. AND

IOWA-ILLINOIS GAS & ELECTRIC CO.

(QUAD-CITIES PERMIT)

Dissenting opinion by Mr. Duinelle:

The Board, by a 3-1 vote on this date has granted the permit

for the Quad-Cities reactors to operate. I dissented for the following

reasons in this order of importance.

1.

The lack 

of

time 

which 

to adequately assess

the Emergency Core Cooling System (ECCS) testi-

mony received only eight working hours previous

to the decisi’on,

2.  The excessive and unnecessary radiation dosage

to the public 

in the vicinity of the Quad-Cities

nuclear plant under

the

permit.

The opinion that the jet diffuser 

will

serve as

a barrier to the passage of fish in the Mississippi

River.

I. The

Emergency Core Cooling System

On Thursday, Novereber 11, the Board heard Dr. 

Henry

Kendall,

Chairman

of

the Union of Concerned Scientists,

and a physicist 

the

Massachusetts institute of Technology, tell why 

his group

feels

that present Emergency Core 

Cooling

System design is not

adequate.

His testimony, which 

was

well researched and 

impressive,

detailed the 

consequences

of

ECCS failure.

If a Loss of Coolant Accident occurs, the uncovered

fuel rods

in the core

would 

heat

up,

distort, rupture

and

thus

block coolant

flow into the hot spots of the core.

Metal—water reactions will

add to

the

heat

present~ 

embrittlement ot the cladding

will 

occur

and eutectic alloys will form. All of this could lead to an

irreversible

reaction-—a molten core at 3,090F. to 5,000Ff which

would rupture both the inner and outer contaminant vessels and

release clouds cf radioactive

gases to the atmosphere.

Depending

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11~

upon the winds at the time, these lethal clouds could travel over

highly populated areas and cause lethal doses of radiation within

a 60-70 mile radius. Hundreds of thousands of people might be

killed if such a sequence occurred at either Quad—Cities or its

twin at Dresden (R. 2467—8, 2527—30).

Commonwealth Edison Company and Iowa-Illinois Gas & Electric

Company 

(the Utilities) and their vendor, General Electric Company,

point to the several core cooling or feedwater systems which would

energize and cool the core before the fatal 60 seconds of uncovered

core has passed. Accepting as true the uncontroverted testimony

that

after the initiation of an incident requiring Emergency Core

Cooling, 30 seconds elapse before the core sprays are activated,

leaving only another 30 seconds for the ECCS to do its job

(R,2475, 2491) 

must 

take

note 

the import of Dr. Kendall~s

testimony.

Dr. Kendall tells us that even if the ECCS system functions

it may not 

~

the excursion and ~     

disaster. The ECCS

system is like the emergency brake system on our cars. We may

put it on and the brakes may engage 

but

just as the mechanical

momentum impels the car forward so too may the reaction in the

core be unstoppable and proceed to total core meltdown. That is

the

meaning of 

all

the testimony by Dr. Kendall about test results

and computer codes and blithe assumptions that are not realistic.

The next logical question is “What are the chances of a

Loss-of-Coolant-Accident?” Dr. Kendall puts them at being very

high when he says “1 expect an incident (of core uncovering) in

the next few years” CR. 2532) 

If we take a “few years” as

being three years and compare the seven existing power reactors

in Illinois soon to be on line (Dresden 3, Quad—Cities 2, Zion 2)

with the 121 reactors listed by Dr. Kendall (Bd, Ex. ~2 Supp. 2 p.l)

the chances are simply 7 in 121 that this incident will occur

in Illinois or a 1:17 chance. These are very high odds. And if

the “brake” does not work then monumental tragedy may ensue.

The short time left after Dr. Kendall~s testimony was finished

was simply not enough to read the Final Safety Analysis Report or

the Edison report to the Atomic Energy Commission of the previously

not publicly known ECCS 

activiation

incident at Dresden 2 on

June 5, 1970. From these documents, at the very least, a fuller

picture would have emerged that might have resulted in some core

temperature restriction or, a speedup in the sensor testing program,

or both, I had asked to defer consideration of the permit application

until the next Board meeting a week hence and that motion, by a 

2-2

vote was lost. With so much at stake the Board should have granted

the additional study time.

II. Excessive Radiation Doses to the Public

The permit as passed by the Board will permit dosages to the

public living nearby of 80 millirems when full power on both reactors

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is achieved, supposedly after April 1, 1972, From this date, until

September 1973, the amended date at which the gas cleaning system

is to be operative, an approximate 120 millirems dose will be

delivered to the 

public

living nearby. In other words, these

people will receive an unnecessary dose of radiation equal to a

year’s normal background 

level. 

Put another way, in the year—

and

a half of full power, the 

nearby 

public will receive two and

one half years of radiation. Since most scientists hold that no

acceptable threshold values exist for unnecessary radiation

exposure, it follows that 

there 

is some unnecessary risk of induc-

tion of leukemia, other cancers and genetic defects.

If it were necessary that this radiation occur then the balance

might be somewhat easier. The Board could then balance the effects

from the smoke from the Moline power plant and the leukemia-cancer-

genetic defects against the necessity for power. But it is wholly

unnecessary. Edison’s own witness, Mr. Harold Williamson testified

that fuel rods 

did

not deteriorate in storage and could be used

again (Dresden Record, October 19, 1971 p. 75-79) 

All that

would be necessary for the Utilities to do would be to refuel

when emissions exceeded 25,000 pCi/sec. per reactor at full load,

retain the “dirty” fuel, load with new fuel, and use the “dirty”

fuel after September 1973 when the off-gas control system would

be operative. The only cost to the Utilities would be the interest

on the fuel rod investment plus the cost of the additional down

time required for refueling. Since we have been told by Edison

that it took the unusual step of completely refueling Dresden 2

after the June 5, 1970 incident,refueling as a precaution is cer-

tainly possible and indeed has been done in the past.

I would have retained the 25,000 pCi/sec. limit on the uncon-

trolled Quad—Cities reactors as a maximum, similar to the limit we

set on the Dresden 3 reactor in March 1971. I think the Board has

now set a precedent, in permitting 80,000 pCi/sec~ for a single

Quad—Cities reactor (more than a 200 increase) that will haunt

the Board. 

The Board next week may decide a further order on

Dresden 3 and the pressure will be on to relax the limit in that

permit and to go ~iith the looser (and “dirtier”) Quad-Cities level.

III. The Jet Diffuser as a Barrier to Fish

The Board has given its permission to the Utilities to use a

jet diffuser to dissipate the heat from their operation. The

effluent is permitted to be 23°F. above river temperature. It

has not been proven to me that fish will in fact go through the

diffuser’s considerable turbulence (which is the reason for its

effectiveness as a heat spreader) 

Just because there may be

interstices of cool water between the individual hot plumes does

not mean that a fish will seek them out any more than a horse may

willingly run between burning trees in a forest fire. Furthermore,

the jets will create some underwater noise and fish are notoriously

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113

sensitive to noise. What is called for and what is lacking, are

actual experiments with full-width diffusers to determine if

fish will

in fact willingly go through them. The Board should

not permit a barrier to be constructed and then be under 

the

considerable pressure of making worthless this 

substantial

invest-

ment if it is 

shown to greatly 

impair natural fish movement.

IV. Conclusion

Between the November 11 testimony of Dr. Kendall and the

Board action of Novembet 15 the Chicago Daily News (November 13)

ran a perceptive editorial as follows:

Nuclear power dilemma

From the testimony adduced so far there appears no

reason to deny the Comrnohwealth Edison Co. a permit

to build its projected new Quad Cities nuclear plant

at Cordova, Edison, speaking through Asst. to the

President Byron Lee, told the Illinois Pollution

Control Board that at

no

time during a pre—operational

accident at the Dresden plant in June, 1970, was there

any hazard to the public. At that time a safety valve

was accidentally opened by a “spurious” electronic

signal. The steam turbine and reactor were shut

down instantly. Had the 

water level receded enough

to expose the reactor fuel core, the core could have

overheated and sent radioactive gas clouds over the

adjacent countryside.

Members of the Union of Concerned Scientists have

testified that, while “fail—safe” mechanisms operated

in this case, the sum—total of existing precautions

are not sufficient to ensure such an accident will not

recur and “lead to complete core uncovery”.

questions the feasibility of proceeding with 

new

plants of the Dresden design until and unless greater

safety can be built into the designs.

Corn Ed says that this is the only 

time a safety valve

has failed to function properly, and there is no

reason to suppose that if it ever did fail again,

the built—in precautions wouldn’t operate as they

did in this case.

Wrapped up in this single example is the~whole dilemma

facing government, industry and the public: Granting

the deadly potentials of the fuels used in nuclear power

plants, how safe is “safe enough?”

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114

There can hardly be any turning back from the course

of development charted by the power companies. In-

creasingly, the public is bejng locked into absolute

dependency upon the power from the great nuclear

plants that 

are mushrooming adjacent to the principal

lakes and rivers. In Illinois the Pollution Control Board

and

nationally 

the Atomic Energy Commission have the

job of making as certain as possible that the risk

of contamination is kept

at the 

absolute minimum. In

a situation where disasters can result either from too

little or too much caution, the public can only hope

that their judgment is good.

The Board by its Dresden decision in March 1971 and under

Title VI-A of the Environmental Protection Act has responsibilities

in the area

of nuclear plant regulation. With these tesponsibilities

comes the ~job of making as certain 

as possible 

that the risk of

contamination is kept at the absolute minimum”. I feel that we

should 

have done more in this proceeding to be”certain”.

J~///~

22/~-

~~/Jacob D. Dumelle

I, Christan Moffett, Acting Clerk of the Illinois Pollution

Control Board, hereby certify that the above Dissenting 

Opinion

was submitted on the/9__day of November, 1971.

Christan Moffett, Aci~’ Clerk

Illinois Pollution Control Board

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