ML19209D239

Forwards Requested Contentions.Alleges That Growth of Population,Possible Pipeline Rupture from Moving Natural Gas Pipeline to Proposed New Route & Other Related Matters Have Been Underestimated by Applicant

ML19209D239
Person / Time
Site:	Allens Creek File:Houston Lighting and Power Company icon.png
Issue date:	09/13/1979
From:	Bishop J, Bishop M AFFILIATION NOT ASSIGNED
To:	NRC OFFICE OF THE SECRETARY (SECY)
References
NUDOCS 7910220152
Download: ML19209D239 (23)

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r1418 oalc Spring DR SEP M ;pg Houston, Texas 77o43 September 13, 1979 Secretary of the Commission U. 5. Nuclear Regulato T Consission

'fashington, D. C. 20555 Attention Docketing and Services 3 ranch 750-466 Gentlemen:

The contentions requested are hereby submitted on the following pages.

These contentions were mailed in order to comply with the Septeaber 14 deadline requirements.

However, Section2.714 of the Rules of Practice for Domestic !icensing Proceedings states:

(3) Any person who has filed a petition for leave to intervene or who has been admitted as a party pursuant to this section may amend his petition for leave to intervane.

A petition may be amended without prior approval of the presiding officer at any time up to fifteen (15.V ds.7s prior to the holding of the special prehearing conference pursuant to #2.751 or where no special prehearing is held, fifteen (15) days prior to the holding of the first prehearing conference.

Please be aware of this opportunity that shall no doubt be used.

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Demo 6raphic--Population inaand around a nuclear power plant is a vital consideration to the NRC when siting the plant.

HL&P has clearly understimated.the rate at which the population of Houston will grow and spread toward the plant.

Houston's suburbs are already as close to the plant as the applicant assumed they would be in 2020 AD.

I contend that this plant should not be sited so close to Houston which is the major population center in the south USA and the nation's fastest growing city.

At the rate the city of Houston la growins the plant will soon be in the city linits, possibly before it could be

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constructed.

It is absolutely unconscionable to endanger the lives of approxinately 5 million persons which HLP assures will be living witcln 50 miles of the plant at sone time durins.the plant's life.

I contend that El&P has underestinated the growth of the area and that the population within 50 niles of the plant may exceed to million persons during the plant's life.

Further: ore, to risk, in the case of a major accident, the forced abandonnent of the nation's major concen-tration of the petrochemical industry is folly.

To risk losing a major part of this nation's conventional energy processing sites to gain a =ere 1200 XW of electrical energy is foolishness of the worst sort.

2.

I contend that the apalicant has grossly underestimated the growth of population in the area of the plant and that a construction per it should be denied.

.{ultifasily dwellings, cluster homes and other high density developments are already underway within 2-3 miles of the plant boundary.

This trend can be expected to grow and accelerate.

Plans for a potential major recreational area lihe Disneyworld or 51c Flags Over Texas are being studied for a. site within about 10 211es 1173 137

of the plant.

If this should develop, a major influx of per=anent residents into the 1:sediate area of the plant would ensue.

Further, thousands ;f transient population would be in the area; =any of whom would be children.

I contend that this area is being developed too rapidly to risk siting ACN? in the area.

I contend this plant should be sited in an area : ore remote fron the city of Houston.

3 Demographic--3ased on the information supplied in the IIS, the proposed ACNP will have = ore people within 50 =iles of the plant durtns. the plant's life than did other plants to which Hi&? compared; i.e., N. Anna, Calvert Cliffs, Susquihanna, Peach 3ottos and 07 ster Creek.

Rather than sitin.3 ACN? in an area of greater population density than cocparative plants it should be sited in an area remote fron any major population centers and hence in an area with less popu-lation than other plants.

I contend that the construction permit should be denied on the basis of population exposure and that the site should be soved"elsewhere.

Demographic References 1.

Houston Chasber of Commerce; 2esearch Division 3.es-240307 2/73 2.

Teras Department of Water Resources; Fopule. tion Projections Planning and Development Division, Dece.:ber 1973.

3 Population F4 cjections for Texas Counties: 1930-2020,

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Texas-Austin, Population Research Center, 1973.

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" Growth Options 5tudy, Phase 1 of Economic Sase Analysis" for

. Houston and C-ibraltar Region--Rice Center, April 1979.

5.

United states Department of Conserce News, Jashington, D.

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C373-230, November 19,1978.

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4.

I contend that novig the Texas Utilities conpan7 24 inch natural Gas pipeline to the proposed route will incre.ise 'he danger, in the case of a pipeline rupture, to the people in the city of Sinonton and particularly to those people who live in the Valley Lodge su'o-division.

The proposed new route will put the pipeline between one-half and one nile closer to Valley Lodge and Sinonton.

In the case of a pipeline rupture natural gas in large volunes could escape and either axphiziate people in the area or nore likely, create fires or explosions.

I contend that the applicant has not adequately assessed the danger inposed on the area population.

I contend that the Applicant should re-route the pipeline elsewhere so that fewer people are endangered.

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5.

Pipeline--I contend that novins the Texas Utilities congsny 24 inch natural gas pipeline to the proposed route creates a hazard of pipe-line rupture that did not previously exist.

Specifically the new route runs the pipeline very near the bank of the 3razos.

Sedinents near river banks are often unstable; furthernore durin6 floods the river could enlarge its channel and undercut the line.

In any event, due to unstable soil or being exposed by the river the probability of a pipeline rupture has been increased by Applicant's proposed rerouting.

A pipeline rupture and the attendant escape of highly flannable and explosive gas endanSers the lives of citizens and property in the area.

I contend that Applicant should be required to find a route for the pipeline that is less hasardous than the one proposed.

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6.

I contend that the Applicant has under-esti sted the effects of detonation of gas from a ruptured I2G line on the plant.

The Applicant's assu=ptions on yield, Point of ignition and volume of escaped gas are all conjectural.

I contend that an analysis usin5 different assumptions would show that the plant could be seriously damaged by detonation of a sas cloud.

The Applicant should reevaluate the assumptions used in his analysis and prove that the plant is designed to withstand the detonation forces that could e= anate from various combinations of cloud size, yield, etc.

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7.

pipeline--I contend that the proposed re-rout 128 9$eTexasUtilitles Co. 24 inch gas line so that it goes parallel to and very close to the cooling lake dan created a safety hazard.

The line could burst and through explosion or erosion breach the cooling lake dan and release the lake water.

At least two serious consequences could re sult; (1 )

people could be killed and property' destroyed in the area due to floodin6 (2) the plant could be le.ft without adequate cooling water.

The Applicant should be required to reroute the line or redesign the dan to withstand the forces associated with a gas explosion and erosion.

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8.

I contend that the Applicant has underestinated the effects of detonation of gas from a ruptured natural gas line on the plant.

The Applicant's assunptions on yield, point of ignition and volune of escaped gas are all conjectural.

I contend that different assunptions would lead to the conclusion that a gas cloud detonation could seriously damage the plant.

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9.

Pipeline--I contend that the Applicant has under-estimated the effects of detonation of gas ^; rom a.~.iptured natural 5as line on the plant.

The Applicant's assumptions on yield, point of ignition and volume of escaped gas are all conjectural.

I contend that an analysis usins different assunptions would show that the plant could be seriously dama5ed by detonation of a gas cloud.

The Applicant should re-evaluate the assumptions used in his analysis and prove that the plant is des 1 ned to withstand the detonation forces /that could 6

emanate fron various conbinations of cloud size, yield, etc.

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10.

Pipeline--

Applicant otates that there are no sources of corrosive 11 quid or oil upstrean of the plant on the Brazos river.

This, statenent is incorrect.

Nunerous pipelines carrying a variety of potentially dancerous substances cross the 3razos upstrean of the plant.

If such a pipeline broke, the kiver could carry lar5e amounts of flannable and/or corrosive naterials downstrea=. to the plant via the cooline lake' intake.

The materials could enter the 0011; ; lake and create a hazard to the plant.

I contend that the Applicant should redesign the plant or nove the pipelines to eleninate this hazard-to the public health and safety.

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11.

Plant coolant--The applicant has assumed that water would be available fron the Brazos river for plant coolant.

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has not considered the fact that the Brazos river has changed courses many times in the past and will do so many times in the future.

The Brazos floods periodically and the Applicant has calculated the magnitude of possible floods based on various rainfall and run-off sodels.

These modelled floods show that the Srazos will exceed its banks in many areas and may cut new channels.

I contend that the Applicant has not considered the,i.npact on the plant of the 3razos river :oving to a new location in its floodplain.

I further contend that the likelihood of the River changing channels is very high.

If the Brazos changed channels and the water from the river was no longer available to the plant, the plant would have to be shutdown.

I contend that due to the foregoing the Brazos is a poor place to put a nuclear reactor and that the plant should be moved to a river less likely to change course or to the Gulf of :!exico.

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12.

Lake Seepage--A signifi ant anount of water will seep out of the cooling lake.

Sone of this water and the radioactive natorials that it carries will eventually get into the Ivangeline Acquifer which supplies drinking water to the area residents.

I contend that the Applicant has not adequately estinated the ancunt of contaninated water and radioactive naterial that could be ingested by area res.tients over the indefinite future fron the contaninated acquifer.

I contend that the Applicant should not be allowed at construct the AONP until and unless he can prove that no radioactive naterial will ever reach an7 area resident.

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13.

Contention will be submitted later.

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14 Coal plant--Tlie applicant has decided to increas's its capacity to generate electricity by constructing a nuclear generating plant at Allen's Creek.

The Applicant conpared the cost and environnental inpact of' a nuclear plant with that of a coal plant and decided that the nuclear plant was preferable fron both standpoints.

I contend that the Appites:nt based his reccanendation as to type plant on inaccurate data, and that had proper data 'ceen used a coal plant would have energed as the preferable choice.

I contend that the applicant nust reassess its analyses pertaining to the choice of plant type and substantiate the validity and accuracy of the data used in those analyses.

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15 Faulting--The health and safety of the public in the area of the proposed ACNSS will be endan6ered due to the Applicant's failure to (1) adequately deternine if surface faulting is present at the site (2) adequately deternine what forces are present in the subsurface that night activate or initiate faults at the plant site and (3) adequately design the plant to withstand the forces that could be placed on it due to earth sove=ent along fault planes at the site.

I contend that the Applicant must prove that faults do not and will not exist at the site during the. operating life of the plant and that until the Applicant does so a construction permit cust be denied.

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Flooding--The Applicant, in its flooding studies has not estinated the inpact at the plant of an upper bound flood event or a probable naminun flood event coapled with a probe.' ole nax12un hurricane.

I contend that these events are not mutually exclusive but would in fact be expected to occur sinultaneously with a reasonable degree of probability.

It would appear that if such events occurred sinultaneously the plant could be flooded with an attendant increase in the probabilit7 of harn conins to the public.

I also contend that the Applicant has nade no attengt to assess the inpact of erosion during a fload even though it is obvious that erosion during a flood will occur.

I contend that these oversights in plant design could negatively inpact the public safety and health.

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17.

Railroad accident--The Applicant has esti=sted the effect on the plant of Eipture and/or detonation to train car loads of chloring and TNT.

I contend that these esti.:ates are underestimated.

I, also, contend that these estimates are not. accurate for all cases and that the applicant should provide more design protection.

I further contend that the Applicant has

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not fully considered the effects on the plant of other hazardous materials that could be carried by rail car.

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13.

Aircraft accident--The plant is not designed for aircraf t 1.:: pact due to the Applicant's assunption the the nearest connercial airport is nore than 10 miles away fron the site.

I contend that there is a high 11hely hood of a connercial airport being ouilt in the near future in close proxinity to the plant and that the Applicant should either move the plant to a safer location or redesign the plant to withstand an airplane crash.

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19.

Lahe fog--The applicant has noted that foggins in the area of the

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site will increase d':e to the inpact of the cooling lake on atnospheric conditions.

The Applicant also notes that the resulting fogs will inpact visibility on highways and railroads in the area.

I contend that use of a cooling lake at this site creates vist'o111ty hazards for people travelins on the highways and railroads in the area and that the Applicant should rede51 n the cooling facilities for the 3

plant to elisinate this unnecessary ispact on the area residents and transients.

I further contend that the Applicant's calculations of goggins conditions are not correct for all possible cases and that foggi 5 in the area could be significantly greater than indicated by the Applicant.

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20.

Lightning a.ccident--The area of the plant is susceptible to generation of at ospheric condition's which create spontaneous discharges of massive amounts of electricil energy,/ through lightnin6 bolta.

I contend that a direct hit by a large lightning bolt could seriously inpair the ability of the plant to operate safely.and that the Applicant has net adequataly protected the plant from such an occurence.

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' 21.

Lake for recreation--I contend that the Applicant is constructing d

and attractive hazard" by building the cooling lake.

The lake will contain radioactive caterial and this caterial will increase over time.

Radioactive caterial is known to be hazardous to humans, particularly children and expectant nothers.

I contend that by buildin6 a recreational lake the Applicant is knowingly providing i facility that is hazardous to people's health and for which the Applicant will be liable.

I contend that the Applicant should either not build the lake or should eliminate all public access to it.

Children and Expectant nothers should be banned from the environs of the lake for their health's sake.

I contend that a cooling tower would be a preferable solution to the probles.

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22.

Coolins lake aise--Ihe Applicant has designed a cool'ns lake that is larger than necessary for one nuclear plant.

I contend that the lahe should ce redesigned to be as small as possible so that the =inisun land is withdnamn froc use and, consequently having the sinimum impact of the enviornment.

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23. Alternative Sites--I contend that if HLLP nust build another nuclear reactor, it would ce :uch preferable to build it at the South Texas site.

This would save the greater Houston population which is 3 rowing in a westerly direction along Interstate Highway 10 from the hazard of living near a nuclear reactor.

This would also spare an unspoiled site in 5reater Houston that is being rapidly developed for residential purposes.

The South Texas Site has an adequate cooling lake for one more reactor; consequently ~this would use less wate' which is at a premiun in Houston since water wells are no longer allowed where surface water exists because of the subsidence problen facing the city. The 3outh Texas site would also use less land than the Allen's Creek 51:e.

The South Texas site is the best choice for additional nuclear generating stations for Houston; there are however several other sites still such better th5n Allen's Creek.

It is absurd to begin building a nuclear complex 20 miles fro: the Ecuston suburbs.

One alternative ~. site to Allen's Creek would be offshore.

The location would be ideal fron a water supply standpoint and also

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Another alternative would be a plant located near the 0-ulf of Mexico south or southwest of Houston snd near the 3razos or Colorado Rivers.

The plant could use either sea water or fresh wcter as coolant and could be positioned so as to inpact' very few people either now or in the future.

I contend that the Applicant should search out such an alternative rr.ther than Allen's Creek.

Another alternative is the Lower Hill Creel Site which is further froa Houston and would affect less people, and is located on less 7:luable land, and is further upstrean of the 3ra:os and is less subject to flooding.

Ihis site is preferable x a the Allen's Creeh site.

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