ILLINOIS POLLUTION CONTROL BOARD
May
3,
1972
APPLICATION OF
COMMONWEALTH EDISON CO.
)
(Dresden, Quad—Cities,
Zion,
)
#70—21,
71—20,
71—328, 71—354
and LaSalle)
APPLICATION OF
)
GENERAL
ELECTRIC CO.
#71-238
(Midwest Fuel Recovery Plant
Supplemental Statement by Jacob D. Dumelle
By this unanimous
action
the Board has taken itself out of
the regulation of nuclear power plants and nuclear fuel reprocessing
plants and in effect declared Title
IV—A to be of no force and effect
because of Northern States v. Minnesota.
In Mr. Currie~sopinion the efforts of this Board to regulate
in radiation-related fields is termed an Hexperimentu,
I think it was
more than
that.
It was an exercise valid at the time
of
inherent State
powers to protect the health and safety of its citizens.
The Supreme Court
of the United States has now said that this area has been pre-exnpted
by the national government and we must accept this.
But it does
not mean that the problems this Board faced in regulating radiation
will go away with the stroke
of
the pre-emption pen.
What are these persistent problems?
They are:
1.
The well—founded fears
as to the safety of nuclear
plants.
2.
The poor record of nuclear plant operation and
design to date.
3.
The worry as to synergism of radiation with other
pollutants.
Let us briefly explore each of these categories and lay out the
spectrum of knowledge as it stands at this writing:
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451
1.
Nuclear Plant Safety
My dissenting opinion in the Quad-Cities thermal variance
(PCB
71-20, April
25,
1972)
details the consequences of a nuclear
plant core meltdown.
It is grim reading.
If a meltdown occurs,
it could dwarf in fatalities
the combined death toll of the
Johnstown Flood,
the sinking of
the Titanic, the Chicago Fire,
the capsizing
of the Eastland, the Iroquois Theater fire,
the
Texas City explosion,
the Coconut Grove fire and
the Queen of
Angels School fire.
The Union of Concerned Scientists,
an organization of
scientists and engineers in the Boston area,
sums up the conse-
quences
of a nuclear plant accident in their March
23,
1972 study
of 352 pages titled An Evaluation of Nuclear Reactor Safety as
follows:
Our analysis
of the scale of the disaster that can
occur should only
a fraction of the fission product
inventory of
a modern power reactor be loosed upon
an unsuspecting population shows that tens or
hundreds
of thousands of deaths
is not
a remote
possibility.
The scale is immeasurably greater
than
that for any other peace-time accident
(Chap.
9,
p.
1)
And if by some quirk of fate or
wind, no person were hurt or
killed by
a core meltdown the possibility
is great that Lake Michiga:
itself could he so polluted by strontium—90
(from
a lakeside plant)
that the radioactivity levels would be above acceptable standards.
The Businessmen For the Public Interest has recently issued
“A Preliminary Hazards Analysis Report on
Bailly Generating Station
Nuclear I.”
On p.
2 appears the following:
The strontium—90 alone released by
a major accident
would contaminante
the 1,170 cubic miles of Lake
Michigan water to levels far in excess
of U.S.
Public Health Service drinking standards, even if
no one died directly from the accident.
Strontium-90
has
a half-life of
28 years.
Lake Michigan has
a
mean flushing time of over
100
years.
All of the
cities using Lake Michigan as a source of drinking
water
(Milwaukee, Chicago,
etc.) would have to
fiiid
some other source of supply.
If either fatalities, injuries or water contamination occurred
or all three the next inevitable result would be
a national closing
of all nuclear plants until
the hazards were corrected.
Having established the consequences of
a nuclear plant meltdowr
we next turn to the question of safety systems.
The safety system
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452
to cool a core is the Emergency Core Cooling System (ECCS).
The
respected publication Science, in a four page article by Robert
Gillette titled “Nuclear Reactor Safety:
At the AEC the Way of Dissenter
is Hard”
(May
5,
1972) puts it this way;
The argument over ECCS
is neither academic nor
trivial.
Should a reactor’s searingly hot core
run dry, the ECCS is supposed,
to reflood it with
water within seconds after the leak occurs.
Should
the ECCS
fail
-
or even hesitate for long
-
the
core could melt and ensuing steam explosions could
scatter
its
radioactive contents
over
a wide area.
The indications are that existing designs of back-
up cooling systems might not adequately reflood a
reactor after a major leak.
If
one reads the highly technical critiques
of ECCS
in the AEC
testimony it is easy to get lOst in the details of computer codes
and heat transfer assumptions.
Those men who have spent large por-
tions of their professional lives in the nuclear
field
are worth
listening to.
The Science article quotes a February 9,
1972 letter
from Dr. Alvin N, ~
director of the Oak Ridge National Labora-
tory,
to
AEC Chairman Dr. James Schlesinger expressing
a “basic
distrust” of computer calculations for evaluating ECCS performance.
And one of Dr. Weinberg’s staff, Philip Rittenhouse on March
9,
1972
read into the record the name of
28 scientists and engineers
of
the national laboratories and
the AEC’s research arm,
the Aerojet
Nuclear Corporation,who share his doubts as to the reliability of
ECCS
as presently designed and installed.
One could go on and on.
Aerojet Nuclear’s own April
9,
1971
review of the status of ECCS
is laced with terms describing
the
“state—of—the—art” knowledge as being “Inaccurate” or “Unverified”
or “Uncertain” or “Imprecise” or “Inadequate” or “Incomplete.”
If
the AEC’s
own safety research group feels this way then should not
we too be concerned?
No ECCS research has been done on a real nuclear core.
The core
tests
to destruction are not scheduled until
1975 although
Dr. Weinberg
has asked that they be speeded up and be done in a year.
My own feeling, expressed in the Quad-Cities April 25, 1972
dissent, is that existing nuclear plants ought to be derated to 70
of full power and that the testing research be accelerated.
We have now ample warnings from competent qualified people.
Will we
(and the AEC acting for us)
heed the warnings or court
disaster?
4
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453
2.
Record of Nuclear Plant Operation
Illinois which currently has five nuclear power reactors in
operation may well have 15 reactors by the 1980’s.
The
operation and
design of existing Illinois nuclear plants has not been of a high
order.
On June
5,
1970 the Dresden
2 reactor malfunctioned resulting
in extensive signal cable damage.
At least eight errors were identi-
fied in design, procedures, operation or settings.
The Union of
Concerned Scientists in their report cited above stated:
No member of the general public was exposed to
radioactivity.
Although the existence of fuel
damage from the accident was denied by the reactor
owners, the
plant was refueled after the accident.
It had been refueled two months prior to the acci-
dent.
This accident displayed an incredible level
of
irresponsibility and incompetence.
One should
recognize that such an unexpected combination of
poor design,
inadequate maintenance, and defective
operating procedures
can, in unfortunate circum-
stances, inject rad,ioactivity into the atmosphere
in amounts that can be lethal at dozens,
if
not
close
to 100 miles.
Extraordinary efforts have to
be made to prevent such an event from occurring
and it is abundantly clear that they have not been
made
(p. A2l)
On December 8, 1971
a malfunction occurred in the Dresden
3
reactor and again signal cable damage occurred.
This same type of
damage showed that the cables which had proven defectic/e
in the
twin reactor
(Dresden
2)
incident 18 months earlier had not been
replaced with higher rated cables.
The Union of Concerned Scientists
comment was:
It had been recognized after Dresden
II that feedwater
control, especially for high water levels had previously
been inadequate.
It is apparent that the lesson was
not learned.
We wonder what is required in order for
these potentially hazardous reactor installations
to be
designed,
constructed, maintained, and operated in safe
and reassuring ways.
On May
4, 1972 the Dresden
3 reactor shut itself down for a
reason not yet known.
No damage is said to have occurred.
Per-
haps the expression “Plus 5a change, plus ~a m~me”will apply.
3.
Radiation Synergism
In the General Electric permit proceeding on its nuclear
fuel reprocessing plant, the United Auto Workers Community Action
Program asked to intervene to present testimony from Dr. Edward
Radford of Johns Hopkins University.
In an affadavit Dr. Radford
4
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454
spoke of the “combined effects of ionizing and u1travio1~etradiation.”
He was never heard and we do not know now how serious
these effects
are that he wished to discuss.
And now because of Northern States v.
Minnesota we must leave the exploration of this voiced hazard to the
Atomic Energy Commission.
The April 1972 issue of Environment
(p.
53) contains a letter
by Dr.
Clark Most, Jr. titled “Radiation Plus.”
He states~
It is not particularly surprising that the cancer—
inducing capabilities of radiation and chemicals
should act in an additive manner,
and indeed such
capabilities have been amply demonstrated, parti-
cularly in the field of radiology.
.
.What
is perhaps
more interesting
is that certain carcinogens have
been found to interact with radiation in a more than
additive, fashion, and that even some noncarcinogens
have been shown to be radiation sensitizers and to
augment radioactive effects
The possibilities
inherent in a synergism between chemicals and radiation
cry out for creating a more adequate level of research
and suggest a potential hazard in siting nuclear
facilities near urban areas, where a more carcinogenic
environment may already exist.
SUMMARY
Three persistent problems dealing with radiation have been
outlined above.
The first, nuclear plant safety,
is the subject
of ongoing AEC hearings already quoted.
These hearings may run
until December 1972.
In addition, on January 22,
1972 the Illinois
Society of Professional Engineers adopted a resolution setting up
an interdisciplinary committee to study ECCS adequacy.
A report is
expected in July 1972.
The second problem, that of nuclear plant design and operation
has been recognized at the highest level of State government.
In
February 1972 Governor Richard
B.
Ogilvie asked the Illinois Commerce
Commission to investigate the first two Dresden reactor malfunctions
cited.
The Commission has engaged two
noted nuclear consultants,
Dr. Ralph
E. Lapp, and Dr. Ernest Tsivoglou.
Their report is expected
late this summer.
The third problem,
that of possible synergism of radiation
with other pollutants, must depend solely upon individual researchers
such as Dr. Radford and Dr. Most to quantify unless the
ABC
can
step up
its research effort.
Dr. Arthur R.
Tamplin has testified before this Board in the
Dresden
3 permit proceeding.
He and his associate,
Dr. John W.
Gofman,
in
their book “Poisoned Power” have a chapter titled “Is
Any Radiation
Safe?’~ The
two scientists
(Dr. Gofman
is
also a
4
—
45&
physician)
state:
All the evidence, both from experimental animals and
from humans,
leads us
to expect that even the smallest
quantities of ionizing radiation produce harm, both
to this generation of humans and future generations.
Furthermore,
it appears that progressively greater
harm accrues in direct proportion to the amount of
radiation received by the various body tissues and
organs.
(pp.
92—93)
Since ionizing radiation is thus a “no-threshold” pollutant
should we not make absolutely certain that ECCS systems really will
work,
that nuclear plants are being well operated and designed, and
that we know the full extent of ‘synergistic effects?
Gofman and
Tainplin, in discussing radiation standards, give us a relevant public
health principle
Where unknowns exist, always
err on the side of protecting the
public health.
(p.
257)
Unknowns do exist as detailed before in this statement.
And
because we have not “erred on the side of protecting the public
health” we are now all exposed to nuclear power hazards.
The Atomic
Energy Commission and the United States Government have now sole
jurisdiction in these matters.
We pray that they discharge their
responsibilities to a greater degree in the future than they have
done in the past.
D. Dumelle
LI
I,
Christan
L. Moffett, Clerk of the IllinoIs Pollution Control
Board, here3y certify the above Supplemental Statement. was submitted
on the
/J’
~bfMay,
1972.
Ii
~,
.“.
/
,
‘V
~.
Christan L. Moffett, Clerk
Illinois Pollution Cbñtrol Board
4
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