ML19209B856

Supplemental & Amended Contentions to Petition to Intervene. Urges Denial of OL Due to Hazardous & Dangerous Condition Created by Transmission Lines & by Inadequate Emergency Plans.Certificate of Svc Encl

ML19209B856
Person / Time
Site:	Braidwood
Issue date:	08/07/1979
From:	Bock C, Gordon T AFFILIATION NOT ASSIGNED, NEINER, B. (BOB NEINER FARMS, INC.), WAALER, EVANS & GORDON
To:
References
NUDOCS 7910110056
Download: ML19209B856 (6)

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CGIMEAIR EDISON GEPANY ] Docket Nos: 50-456, 50-457

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(Braidwood Station, Units 1 and 2)]

PEIITION TO E7IERVENE - SUPPIRETIAL RID RSIDED C0hTENTIONS C. Allen Bock P. O. Box 342 Urbana, IL 61801 Thcmas J. Gordon B\ALER, EVANS & GORDON 2503 S. Neil Cha: paign, IL 61820 Attorneys for Petitioners 31 o \b6 7910110 056 4 G

UNITED STATES OF AMERICA NUCLEAR REGUIMDRY EtNISSION ,

IN THE MATTER OF ]

CO::nCEALTH EDISON OTPANY j Docket Nos. 50-456, 50-457 (Braidaoed Station, Units 1 and 2)]

PETITION TO INIERVENE - SUPPIEEEAL AND AMENDED CONIEEEIONS The petitioners , BOB IEINER FARMS, INC. , as authorized by its shareholders; and BOB E. NEINER, ELEANDR M. NEINER, PAT NEINER, IDRRAI1E CREEK, IIO WAISH and ALTA WAISH, individually, hereby amend their contentions stated in their Petition to Intervene in this proceeding pursuant to 10 C.F.R. 52.714(b) through their attorneys, C. Allen Bock and Thcmas J. Gordcn.

I AMENDED AND SUPPLEMENTAL (XXEE!EIONS Intervenors herein belcw list the contentions and the basis for the cententions which they seek to have litigated.

1. Intervenors contend that the 765 Kv transmission lines that will be used to transport the electrical output frcm the Braidaced Station create an unacceptable, hazardous and dangerous condition to persons living cr working en a daily basis within 600 feet fram the closest line, and that 765 Kv transmissien lines should not be placed closer than 600 feet fran any structure er area in which people can be expected to be present six or more hours per day. The hazard-aus and dangerous conditions include: audible noise impairing hearing, increasing tension, interfering with sleep, interfering with speech; interference with the operation cf cardiac pacmakers; biological effects on hur.ans because of exposure to electric fields excluding the use of nearby areas for workig, livirg or recrea-tien, and the danger of shock to persons and animals.

The basis for this ccntention is that Ccrocrraealth Edison testified before the Illinois Ccrmerce Ccmissicn that as of March 3,1978, anproximately 60", of all transmissicn right-cf-way acquisitions included right-cf-way for 345 Kv and 765 Kv trcnsmissicn liner. Opinion No. 78-13, involving Case No.

26529, issued by the Public Service Ccrmissicn of New York discusses the hazarcis associated with 765 Kv lines.

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2. Intervenors conte .d that there nust be an NRC approved plan for decarissioning the Brai6:ccd nuclear facility before it opens due to the econanic, environmental and safety effects that ' fill exist at the time decem-missioning is necessary, it is unacceptably hazardous n,ot to have a plan readf in case of an accident requiring quick and cmplete decam:issioning of the plant.

3. Intervenors contend there are inadequate erargency plans fcr the Braidwood Station in case of a radiological emergency and that such plans should include the follcwing:

a) a program for educating and infenning the public within 20 miles of the Station of the respcase they should take and also of the means far obtaining instructions for evacuation or other protective measures in the event of a radiological emergency originating at the Staticn.

b) a specific picn for notifying pecple residing within 20 miles or using recreational facilities within ten miles of the Station of the existence of a radiological emergency.

c) assurance that institutions within 20 riles of the Station, such as the federal r:rison in Joliet, hospitals and nursing har.es, can be evacuated or acequately protected in the event of a radiological ser-gency.

d) identificatica of the medical facilities and available transportation that may be needed to provide treatment to mebers of the general public who may be expcsed to radiation in the event of a radiological energency and assurance that these facilities are capab'c of handling the treatment of persons injured as a result of a nuclear accident.

e) a suitable plan fer providing medical treatment to operating perscnnel who might be expmed to radiation in the event of an accident, including transportaticn to n:edical facilities equipped to creat radiation casualties.

f) an identification of the public and private organizations which will have pnmary responsibility to organize and execute evacuation plans or other protective measures.

4 Intervenors contend that the oroximity cf the Illinois Central Rail-road to the plant site and the.use of the rail syst'en to transport explosive materials fran the Joliet, Illinois arsenal and other plants or depositories creates an unacceptably hazardcus condition not considered by the Atomic Safety and Licensing Board, which issued the partial initial decisicn on envircamental and site suitability matters for the Braidwood Station (LEP-75-1, 8 AEC 1197 (January, 1975)). At the construction permit stage the analysis of the proba-bility of an explosien was inadecuate in that:

a) the six-month pericd during 1974 for which the traffic fran the Joliet arsenal was analyzed is not representative of other tra#fic periods in the past and may not be representative of the traffic to be expected in the future.

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b) the analysis of the traffic was based cn peacetime traffic only.

c) only the probability of accidental or inadvertent explosions were assessed and the probability of sabotage or purposefully caused explcsions were not explcred.

Intervenors believe that adequate protection to the facility requires relocation of the railroad line, a redesign of the features of the Braidmod Staticn to mitigate the consequences of an explosien of a magnitude that could develop if greater traffic loads of exolosive materials were considered or the development of procedures by the railroad to reduce the probability of explosion.

5. Intervenors contend that in order to detect unacceptable contam-ination to groundaater supplies resulting frcm seepage frca the cooling lake, Applicant must establish a acnitoring program which specifies the nur.ber and location of offsite monitoring points and the frequency of sampling at each point.

6. Intervenors contend that since the Illinois River will be cunu-latively affected by chenical and radiological discharges frce the Braidwocd, Collins and Dresden power stations, that the existing envircumental irract studies are inadequate to show that an unacceptable impact on aquatic biota and fishing will not be created.

7. Within ten miles of Braidwood Station there are public and private recreaticnal facilities with a total annual attendance of 1,053,873 persons (Table 2.2-7 ER-DLS)~

Intervencrs ccntend that the potential that these facilities wculd have to be closed, either temporarily or permanently, ciue to the release of substantial quantities of radioactive materials during an accident creates an unacceptable environmental impact.

8. Intervenors contend that for purposes of determining ccxmliance with 10 C.F.R. Part 100.11(a)(3), Applicant and the NRC Staff should have used the populaticn expected to be at the nearby (within eight miles) recreational facilities in aggregate as a population center. (Table 2.2-7 ER-OLS)

9. Intervenors contend that the listed sources in Tables 2.1-17 throuzh 2.1-21 of the Braidwood ER-10S does not include data from the Farm Census - wttich data would be more accurate than that provided. The inaccurate estimate of the agricultural product from the area results in an underestimation of the total radiological dose to the population within 50 miles af the Statien.

10. Intervenors contend that prior to the operation of the Braidwood Station, Applicant should present data shcraing the exoected radiaticn exposure to individuals and livestock frca radioactive releases frcm the laSalle and Dresden Stations, as well as the Braidwood Station, in order that the curulative total dose to individuals and livestock can be assessed.

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11. Intervenors ccntend that the dike surrounding the Braidwood Station cooling lake is subject to failure due to rain licuification of the calcareous material frca dich the dike is constructed. In the event of a failure of the dike, the water reaining in the ultfrate heat sink basin might not be adequate to cool the reactor from full power cobration or to allow safe shutdom in the event of an accident.

II CC"CLUSIO:! AND PRAYER FOR RELIEF Based upon the foregoing, petitioners respectfully request that the Contentions as presented herein be litigated and that Ccmenwealth Edison's application for an operating pemit be denied.

Dated: August 7, 1979 C

C. Allen Bocn Attorney at Lra D Y Bf Thc6:as J. Gord Attorney at '

Attorneys for Petitioners:

Bob Neiner Fams, Inc.

Bob E. Neiner, President and individually Eleanor M. Neiner Pat Neiner Irrraine Creek Leo Walsh Alta Walsh C. Allen Bock Attorney at Ira P.O. Box 342 Urbana, IL 61801 217/897-6208 Thm.as J. Gordon Waaler, Evan:, & Gordon 2503 S. Neil lg 0 160 Champaign, IL 61820 217/352-7887

C!ITED STATES C'? A" ERICA

- NUCLEAR REGULATORY CCMISSION BEFT)RE THE AimIC SAFEIT E'D LICF231"G BOARD I'i TFE MATIER OF ]

] Docket Nos.* 50-456, 50-457 CQENWEALTH EDISON CCEPNW ]

(Brai& cod Station. Units 1 and 2) )

Lt. tun 1CATE OF SERVICE We hereby certify that copies of Petition to Intervene - Supplemental and Amended Cententions in the above-capitoned proceeding have been served en the following by deposit in the United States mail, first class, this 7th day of August, 1979.

Marshall E. Miller, Esq., Chairman Atcmic Safety and Licensing Atcric Safety and Licensing Appeal Board Panel Board Panel U.S. Nuclear Regulatory Cocrissica U.S. Nuclear Regulatory Ccruission Washington, D.C. 20555 Washington, D.C. 20555 Docketing and Service Section Dr. A. Dixcn Callihan Office of the Secretary of the Unicn Carbide Corporation Ccumission P.O. Box Y U.S. Nuclear Regulatory Ccrrissica Oak Ridge, TN 37830 Washington, D.C. 20555 Dr. Richard F. Cole Ms. Bridget Little Rorem U.S. Nuclear Regulatory Ccxmission Braidwood Area Coordinator Washington, D.C. 20555 Bailly Alliance-Illinois Braidwood, IL 60408 Paul M. Murphy, Esq.

Isham, Lincoln & Beale One First National Plaza Chicago, IL 60603 Mr. Myrcn Karman ,

Mr. Richard J. Goddard U. S. Nuclear Regulatory Ccrmission Washington, D.C. 20555 Atcaic Safety and Licensing Board Panel U.S. Nuclear Regulatory Cccrissicn '

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Washington, D.C. 20555 .

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Attorneys for Petitioners ,

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