ML19209C328

Addl Contentions Filed as Amend to 790808 Petition to Intervene.Urges Consideration of Interconnection Alternative,Environmentally & Economically Preferable to Nuclear Plant.Other Alternate Energy Sources Are Suggested

ML19209C328
Person / Time
Site:	Allens Creek File:Houston Lighting and Power Company icon.png
Issue date:	09/12/1979
From:	Schuessler W AFFILIATION NOT ASSIGNED
To:
References
NUDOCS 7910150042
Download: ML19209C328 (4)

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. N' UNITED STATES OF AMERICA N1.CIEAR REGUIATORY CCMMISSICN BEFORE THE ATCMIC SAFETY AND NNSING BOARD t- 9

.9 on September 12, 1979 In the Matter of ),c Juma HOUSTON LIGHTING & POWER . 1 -

-- Docket No. 50-466 t SEP 2 01978 >

COMPANY (Allens Creek Nuclear Generating gjm 11 Station, Unit 1) g ) /p a

ADDITIONAL CONTENTIONS OF WILLIAM J. SCHUESSIER In adi'Lon to the nine contentions filed in my ammend=ent to petition for leave to intervene dated August 8,1979, I wish to submit the following:

10. Applicant is the largest power e-mny in the U.S. which does not inter-connect interstate with other power < mpnies. Such inter-connecting power grids provide a capability of diverting electric power from one generat-ing and distributing system to another to meet peak demands. ACNGS, operating at a projected 50% capacity factor would supply only 6% of HIAP's eh peak load in 1979. NEC's own data show that large EWRs average less than 50%

of there rated espacity due to down time. By inter-connecting with other utilities who have facilities outside Texas all of this power could be supplied without ACNGS being built. Gulf States Utilities, Arkansas Power & Light, El Paso Electric Co. and other utilities are nearby-eempanies that have power to sell to HI2P.

There are now hatrings before the Federal Energy Regulatory Commission that will very likely require this intr. connection, thus avoiding any need to build ACNGS.

This alternative has not been sufficiently considered by either the applicant or the NF:C Staff in their final Environmental Statements. I submit that inter-connection is environmentally preferable to building a large nuclear plant, and economically preferable for the customers.

11. Neither Applicant nor NRC Staff has given adecuate consideration to coa 1 or lignite as alternate energy sources. For exa=ple, Dr. Ralph E. Peck, Professor Emeritus of Chemical Engineering, Illinois Institute of Technology and Dr. Iadd Pircon, chemical engineer, have developed a practical scrubbing process that removes sulfur dioxide from coal combustion effluent and combines residue with other chemicals to produce high-grade fertilizer for agricultural use. In this process the sulfur dioxide is drawn through a newly invented "heterogenedous reactor" which ecmbines the gas with water and calcium phos-phate, releasing phosphorus, which combined with anhydrous am=onia and coal ash residue, forms fertilizer. The process has been tested for more than two years at Illinois Institute of Technology. During that test period amounts of sulfur dioxide leaving the stack were reduced by over 95%. Also, significant reductions in particulate matter leaving the stack were established. During 1145 155 *olso @

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the tests, both high and low sulfur coals were used.

The system uses only a fraction of the energy needed for current methods.

Cost of the system may run less than 30% of the cost of the best scrubber systems now used. Fertilizer produced in this process returns a profit resulting in lower rates for utility customers.

"tilities and major chemical cmmntes are already taking an active interest in this procese.

Another environmentally safe method of' using coal or lignite (which is very plentiful in Texas) is to burn the lignite underground, where it is found.

This eliminates strip mining and transportation problems, and greatly reduces emissions; ==Hng it environmentally preferable to nuclear power. Such under-ground burning is presently being done in Texas.

Recent revelations M regard to radiation hazards found in uranium mining, harmful effects of low level radiation generally, experience from TMI, all prove the obvious advantages of coal or lignite as an energy source, as opposed to nuclear energy.

12. HIAP has contracted to buy Austin's excess electricity in the amount of 500 W per year. Also, HI&P has announced that it plans to build a 1500 W capacity lignite plant north of Houston which will be in operation by 1986. Also, due to recently announced $400 million overruns at the South Texas Plant, the cities of Austin and San Antonio have begun consideration of selling their project shares to HIaP.

The sale of Austin's 16% share and San Antonio's 28% share of power would make available almost 1200 W to HIAP.

Also, the city of Houston is considering the burning of its municipal waste to generata steam in co-generation facilities that could generate 500 W.

These alternate, already planned sources of power total 3700 W, which would exceed by almost 300% the full rated capacity of 1200 W of ACES.

This much power available to HIAF clearly eld =4 ates any need for ACNGS.

13. Because of:

a) Recently announced cost overruns totalling over 31.4 billion (140% overrun) on the South Texas Plant; b) Shilar cost overruns may be reasonably expected at ACNGS; c)The expected financial losses related to pullout of STP by cities of Austin and San Antonio because of cost overruns; d) Expected increased costs of new safety reouirements resulting from TMI disaster; e) Ever increasing et at of borrowirug money (prime rate now 13%)

along with the reduction of the bond rating of HIAP; f) Reasonable expectation that the Texas Public Utilities Com-mission will not allow HI4P's total 1979 rate increase request;

,, I contend that HI&P is, and will be unable to give reasonable assurance that 1145 iS6

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these conditions will not compromise the applicant's clear self-interest in safety, and meet the requirements of the construction permit.

14. Applicant has not adequetly met requirements of 10 CFR 50, Appendix E, which reads in part; The Preliminary Safety Analysis Report shall contain sufficient information to assure the compatibility of proposed emergency plans with . . . such considerations as access routes, surrounding population distributions, and land use.

I contend that any such information presently appearing in the PSAR must be regarded as false and misleading, rather than assuring. The State of Texas has legal responsibility for evacuation and other protective measuree in event of an accident at AClGS. If the State of Texas does in fact have such plans, they are totally unknown to the general public. The same is true of county and city governments, including those which would be affected by possible AClGS accidents. Absent such plans, PSAR cannot contain information which would satisfy minima required in paragraphs A through G of cited regulation.' If such plans exist, it is extremely doubtful that they come close to incorporating all of the essential elements included in the " Guide and Checklist published by NRC.

In the event of a serious accident at ACICS it would be most likely that immediate evacuation of densely populated Houston and Harris County would be necessary. Effective and timely removal of 2 to 3 :aillion people to safety is simply not possible. To' quote Civil Defense officials on the subject; We try to evacuate this city each morning and evening. We call it rush hour. You know how effective that is.

Six days might provide enough time to evacuate the area, but not 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> deemed sufficient by federal planners.

HoustonAlarris County being the fastest-growing metropolitan area in the country clearly indicates that building ACICS will al=cet certainly place it in the very midst of the population which will have grown around it.

I-contend the recently announced plans to require that low population zone will be extended to 10 miles, ccmbined with the expected announcement of stronger requirements for evacuation planning in the wake of TMI investigations, will assure that it will be impossible for the Applicant to comply with 10 CFR 50, Appendix E.

15. Neither applicant nor NRC Staff has sufficiently cons;'.dered the aesthetic impact of the huge, bloated energy station rising almost two hundred feet above the sightly, unspoiled grass-covered plains of southern Austin County. This massive unnatural, forbidding hulk will surely be an offensive intruder to the eyes of those many Texans who have enjoyed this scer:.c area for decades. This abominable structure will be visible for perhaps twenty miles, and will stand as a lamentable symool of man's folly, totally out of place in this unicue grassland area. Therefore, I contend

- that ACIGS should be built at a less aesthetically critical site, or be

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constructed in a manner which will permit the area to remain unblemished by the plant. This could well be possible if a substantial part of the facility were to be built below ground level.

Respectfully submitted, o  : -

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