ML19209C329

Amend to 790718 Petition to Intervene.Contends That Applicant Calculated Normal Radiation Is Inaccurate & Misleading.Other Related Contentions,Re Economic Impacts & Appropriate Site Are Stated.W/Certificate of Svc

ML19209C329
Person / Time
Site:	Allens Creek File:Houston Lighting and Power Company icon.png
Issue date:	09/14/1979
From:	Pavlovic F AFFILIATION NOT ASSIGNED
To:
References
NUDOCS 7910150047
Download: ML19209C329 (10)

Text

'- '

-NRC PUBLIC DOCUMENT ROOM SEP 181979 9 WEE

~ .7. . s .........v' . ...... . ,;

Ndu. t IMLATORI w.. w. TON ,i SEP 18197.9 > j

'l BEFORE THE A"OMICI SAFETI AND LICE:. .G BOARD Dj. N N tat-In the Matter of I I

HOUSION LIGHTING CPO'#ER COI.' PANI J Docket No. 50-466 f

(Allens Creek Nuclear Generating I Station, Unit 1) 1 FRANCES PAVLOVIC'S AMENDED PETITION TO INTERVENE By letter of July 18, 1979, I interded to be considered as a full intervenor in the licenaing of construction of the above captioned facility by APPLICANT.

The following paragnphs represent ;y contentions regarding the hazards to health posed by locating the plant at the proposed sita.

1. CONfENTION REGARDING OVERLAPPING ZONES A. The fifty-mile zone of ACNGS would overlap that of South Texas Nuclear Project, exposing populations, lard and air in the overlap zone to double dcaages of radiation. Since this fact was not considered when calculati.g normal backgrourd radiation, I contend that the effects on the " maximum" individual ard his environment are inaccurate and misleading.

B. Although health effects are estimated for the entire country assuming a total nuclear ' economy, areas which are in nuclear plant overlap zones are not considered. For example, (S.D.15 FES August 1978) states, "It is believed that genetically related diseases....certain anemias, and congenital abnor.ulities... .and abnornalities in the desce rdents of workers and the general public from both normal operations and accidents would be perhaps twico the number of excess deaths due to cancer from total-body irrir.'.ation; . .."

l.146 001-

,~

7 010150 O V 7 G

Popalation of towns in tne overlup sora. (T.' m i' . mc 1978-1979' ,

San:.do 1,70 idfield 70 ar'ca:a 60'i 3ay City 13,54,7 sucony 3,025 En Vlock 1,051 Old Ocean 915

'! Colur.bia 3,330 ) ),

2. Colamoia 95 l lI h

.'agne t 42 Luca Cit:r 111 i'ierco 49 ,s

?.illjo 51 -

Louise 310 _ _. . _.

Lunovan; 61 .

hu u A =

%. .fada 20'2 Esynt 26 Glen /lora 210 Garwood 975 2ce,c !aland 160 07.2,Ji? 20&,

c'loccer 159 3o1;ng 720

".narton 7,7U.

.a ::o . do e,)-

..C K tis 1, Jo

• _.

Dar.on 375 .3Gy u *uj Louville 1,662 f.c r.dle to n 641 hrtiy ?oint 30 toscaron 435 Dowalt 40 lich .ord 8 452 .

lesenaerg 14,995 Sugar Lurd 7,306 lu13 hear 200 .

'allis 1,103 1clo ' ake 3,587 -

lisaie 70

2. 3errard 1,500 .

e < .,

- Idf. . . b' .g m; T

• 4* A

.c G.

s. c.

~

contoni that statictica cr.oulu ou :at:ared from audi.m or. m ac.D^ m of the abovo houlth off. ct., . . . . overlap zoraa in othor acetic.~ vJ ~':c country beforc u truo ec,ti; ato of the actria.ontal health offecta of <1.C '4-can be doter 0.iLOG.

. 1146 002

?00R ORSINAL

2. CO:C2?CION R2GA:CING NEAREST C2NT2R OF 20PULATION Rosenborg, population 14,995 (Tenn Alcarcc 1973-1979) is considered the nearest centor of population by ::RC. It is 15 miles from the site.

However, on Interstate 10 approximatoly 10 railes from the site, the average daily vehicle count is 16,230. Since each vohiclo would average more than one passengor, the average daily ranber of persons an I-10 could be well over 20,000. Sooly's population could be added to this figaro to give a more accurate count of the nearest center of population, since Scaly is located on I-10 approximatoly 10 milos from the sito and has a population of 3,211 (Tenn AMnac 1973-1979). Other major roads within ten milos of the site have average counts as follows: US 90, 2,320; Farm to t.tarket Road 14581,M0; Stato Highway 60 1,570, ard State Hi:nra/

36 2,930. The area arourri Scaly and all along I-10 is quite populous ard the population of Houston is apreading out to that area. For this reason, I contend that the proposed site is too close to a populated area.

3. CONTZ'. TION BASZD ON !l0ST APPROPRIATE USE OF TE SIT 2 ,

Since the larli on which it is oroposed that ACNGS be built is

/

presently arable and since the growing population of the area noods produco ard other food iteps that could be grown on the site ard shipped at 1 w energy cost to distribution centors in the area, I conterd it would :o

- coro healthful for the population of the area if the site remained avail-able for agricultural uso.

4. CC:."E::TIO:53AT A32qUA~'3 CONSDZRATION HAS NOT 323N GIVIN TO CONSERVATION AS ALTZRNATIVZ A. Applicant's projections of futuro need are based on present peak leads 1146 003

~

P00R ORIBlHL .

wEica i.avu been encouraged oy A9plicanc,'s ecvortising acG rate struc hrc.

"lous ton. . . .uses moro onorgy por capita than any other ci;,;-

in the world, as the city's privuto utility, Housten Lir;hting

& Power, proudly announcos in its advertisements."

- "The future of an illusion" by Potor Guntor in 72XAS 03SCRV2R, April 13, 1979 I conto.{ that Applicant's projocted ostimatos of nood are inflated una should bo revised aftor it has mado a bona fido offort to reduco ,waks of consumption.

B. I contend that Applicant should not be liconsed to construct another nuclear plant until it has mado a bona fido effort to encouraco conservauva of electricity ovur a fivo-yoar period.

"If the L~nited States were to rako a serious commitront to conservation, it might well consumo 30 to 40 porcent loss energy than it now doos."

C. 2xamplos of Conacrvation coasures that should be sponsored by Applicant.

1. applicant's rate structure should be changed so that thoso vino uso more pay moro. Since 51'] of Applicant's sales are to inaustrial customers, they should pay 51% of the cost; residontial 237,; commercial 203.

2. Anplicant should occourage the use of " house doctors ' as advocated recontly by a. United States Senator. These " doctors" would visit houses, diagnoso their energy problocs, proscribe the roredios needed. Upon completio*n of the proscribed "courso of treatment" utility bills ~ would be compared'with thoso of the preceding year to dotormino how much energy had been saved. If consumption of energy was reduced significantly, the

" doctor" could koop his foe. If not, he would have to rofund it to tho homoOwner.

Residential customors could be urged to use wachers, dryers, dish-vashers, and disposals during off-peak hours. Applicant's monthly mail-out to customers could list the off-peak hours. 1146 004 Applicants advertising should urgo customors to follow recommerdations of the fe,doral government with regard to thermostat settings.

~f-Applicant could suggest the use of lid ht meters in offico buildings with glass walls. .

Applicant could entor into co-gor: orating agreements with additioral industrial customors.

Applicant could consult with commercial buildings owners to phaso out supor-cooling and roheaters which tend to mako Houston's business environment colder indoors than out even in the winter months.

5. 00 iTE CION R2GARDI:!C OF7-SIT 2 f.:0!!ITORING R2QUIRZ'ENT

_I contend that Applicant chould be required to install an off-site radiation monitoring systom t'.at would also take into account weather conditions, with continuous computer processing. Such a system would erable a reliable esticate to be made of tho accumulated radiological dosage to the off-site population in the event of an abnormal release of radioactivity ard for long-term health projections.

Referenees: "!.*.onitor"--:iUCL2AR 2::GII.IRI: G, August,1979 ard "The 7tay to Save I;uclear Powor" by R. A. 3rightsen in FORTU:3, Sept.10, 1979.

The above references contain many valuabio suggestions regarding operation, communications, and public relat!.ons, ard I hope they will be adopted before the plant is licensod te operato. I mention them at this time because I understand that oporations licenses are often pro forra after a plant has boon built.

6. CONTE:iTIO:!5 REGARDING RAIL TRANSPORT OF I.~JCL2AR ?!ASTS I contend that railroads to be used for transport of nuclear waste be thorougN17 evaluated ard physically improved beforehard. Since sv 1146 005

.l}yo w o

& }-(e

. 7 to 10 rail shipments of spent fuel consisting of 42 tons of spent fua gid 20 tons of cladding will be traveling from ACNGS over Texas railroads, they will be subject to railroad crosairc accidents, derailments, and other problems common to Texas railroads. According to ER 5.3.4.2., and 7Jt 5.3.4.2.2, modo ard r'outo of transport of other solid wasto will be similar to that of the s; 7t fuel; the location of the reprocessing plant ard the route traversed by the spent fuel to the roprocessing plant has no' yot' boon choson.

7. CONTE!; TION REGARDING CU:JULATIVE EFFECTS OF ADDITIONAL 'JASTE FRO:.I OTHER NUCLEAR PLAI;TS ALONG THE RAILROU"!: ROUTES 'Al STORAGE OR REPROCESSING In addition to the proposed shipments of nuclear wasto from ACNCS that might concoivably pass throu;;h populated areas, I contend that I;RC requirements regarding radiolo'gical exposuro lovols could bo excoodod if the same rail linos aro usod to ship wasto from other nuclear planta.

_IJerefore contord that licensing should be delayod until rail routos are determined ard the cumulativo radiological effects calculated.

8.

00tiTENTION RECARDING PROTECTION OF PUBLIC AT RAILRCAD CROSSINGS Persons in Texas have boon killod by trains at railroad crossings throughout the stato, and the crossings are often lef t in disrepair after an accid,ent. Texg Chsorver article, " Crossing Over" by Jeanetto Carrett, 1976 April 27, 1979, quotes a/ Department of Transportation survey which" points out +,ha',

only 3,424 of the crossings have any sort of 'activo ' warning system in place--either flashing lights, bella, or gatos that block crossings whon a train is approaching. !Jost of them are marked only by

, the familiar black ard whito crossbuck sign to notify motorists that there's a crossing ahead. DOT found that 1,113 Texas crossings have no markings of a ry kird. " ~

D{~

"D g(f N fD [ F B 0

?

~

. 1146 006

-/

I conterd that all crossings used by trains hauling nuclear waste should be inspected prior to each shipment and adequate protection be provided to the motoring public.

9. CONTENTIONS REGARDING USE OF ALTERNATIVE SOURCES'0F ENERG'l Although various forms of alternative erorgy sources were described and abandoned in the staff reports, J conterd they were considering each individual alternative source independently and not as part of a multi-source system.

I_ further contend that a decentralized system utdizing alternati<e sources in conjunction with the existing system would be less wasteful of energy, especially electricity; use less non-rerawable resources; be more economical to build, maintain and operate; and be safer to workers and populations now without posing any health threats to future generations .

Since Applicant serves 70 or more municipalities, it has ample t

opportunities to supplement its present system with one or more alternative sources ia each locality.

Doctor Wayne Willey's financial analysis of Pacific Gas & Electric Co., (cited by the Envirormental Defense Fund in its August 1979 furd

, drive brochure) found thut the company "could cut 90", of its planned new nuclear and coal plants by shifting investments to presently available alternative energy sources--and meet all of the projected energy meds M h ,qo,aji to the company and the public. '

li46 007 e

0

10. CONTENTION REGARDING DELAY OF LICENSING TI , AFTER ntI COMMISSION FINAL REFORT I contend that kCNGS construction should not be ticensed until af ter the tree Mib Island Commission has made its final report ard recommenda-tions. Meanwhile, Applicant may gain valuable experience in operating the TSNP now under construction at a sito less populous than the proposed ACNGS since much of its 50-mile zono ir cludes coastal wators.

I listened to the 31I Commission hearings and was i prossed by the following facts: The control room's displayed inforration went around a corner so that it was impossible for the operator to get all portinont 1

, information from one viewooint. The computer was outdated. The oporators were overconfide..t and incapable of making split-second decisions based on an education in nuclear engineering at the level required by the situation.

CONTENTION REGARDING I."JCLEAR 'JASTE STORAGE

11. The disposal of radioactive wasto continue to be a problem tb,oughout the country. I conte _nd that until adoquate provisions can be made for the long-term safe contairnent or noutralization of such waste, both of' fuel and of cladding or liquid nuclear waste, licensing m zr of ACNGS at the proposed sito4be postponod.

INSEn 1146 008 S 5.44 Radiolonical imnact on man Page 5.5-31 "....the actual radiological impact of plant operation ray result in dosos close to the dose design objectivos. Evon if this 'tuation exists the individual dosos will still be very small whc. - . narod to ratural backgror.nd dosos (~92 milirom/ year) or of the doso lic.its specified in 10 CFR 20 As a reault, tho staff concluded that thoro will be no mot.aurable radiological impact on ran from routino operation of the ACNGS."

t I conterd this statement is misleading since it does not consider the amount of additioral radiological impact to which those in the overlapping zonas will be subjected. 2 m ca # --<- /9 2Cr bd AJG'M% : .C ,

_ -Lefe46 Era. o ; c C N1 vlo vic.

~

~

t' N. . _ _ . . ,

UNI"ED STATES OF A!/. ERICA NUCLEAR REGULATJRY C0:2.IISSION BEFORE TFE AM. TIC SAFETY A?O LICENSING BOARD In the Matter of I I

HOUS"0N LIGHTING & POWER C0?.tPANY I Docket No. 50-466 -

1 (Allen * " reek Nuclear Generating i Sta tio. Jnit1) 1 CERTIFICATE OF SERVICE I hereby certify that copies of the forogoing Amendment to Frances Pavlovie's Petition to Intervono in the above-captioned proceeding were served on the fo11owing by deposit in the United States mail, postage prepaid, this 14th day of September,1979.

Sheldon J. Wolfe, Esq., Chairman Atomic Safety ard Licensing Board Parol

, U.S. Nuclear Regulatory Commission Washington, D. C. 20555 '

Secretary of the Commission (20 copies)'

Attention Docketing a Service Se<ation Nuclear Regulatory Commission Washington, D.C. 20555 Richard Lowerce, Esq.

Assistant Attorney General for the State of Texas '

P.O. Box 12548 Capitol Station Austin, Texas 78711 Steve Schinki, Esq.

Staff Counsel U. S. Nuclear Regulatory Cox. mission Washington, D. C. 20555

• John F. Doherty 4438t Leelani '

Houston, TX 77023

• -e

a Carro Hirderstein 8737 Link Terrace Houston, TX 77025 7layne E. Rentfro P. O. Box 1335 Rosenb' g, TX 77471 James M. Scott, Jr.

8302 Albacore Houston, TX 77074 Brerda McCorkle

, 6140 Darnell Houston, TX 77074 WW France 2 Pavlovio 111 Datonia Bellaire, Texas 77401 i

e 6

.i

,