ML19254B066

Revised Contentions of Intervenors Citizens Association for Sound Energy

ML19254B066
Person / Time
Site:	Comanche Peak
Issue date:	08/21/1979
From:	Citizens Association for Sound Energy
To:
Shared Package
ML19254B062	List: ML19254B063 ML19254B066 ML19254B068
References
NUDOCS 7909240026
Download: ML19254B066 (5)

Text

<

Cit Izens A' noc iat J on for Seued Enerny (CASE) Contention

• ContenLior 1 kpplicantsbr.ve failed to deinonstra te suf fic ient r.:anagerial and administ rat ive controls to assure safe operat ion as required by 10 Ch a Part 50, Appendix E.

Ponition*

TU (Applicants) S (Staff) I (1 n t e t .s nor)

A A A Cont ent ion 2 Withdrawn. j ip CcIntent ionn 3'A Applicants have failed to deconntrate a need for the po.-zer to be generated by CPSES because

a. The reserve targins presented in the Environ: ent al Report (Ett) reflect adequate reserve margins through 1985 wit hout CPSES.

b. The figures for the Applicants' c a pab i li t. i e : . , demands an' reserven, set forth in the Ell are inaccurate, incorplete and out of date.

Ponition TU S I A (U) A (W) A '

Con t e n t_ i o n _.5_

The ER failt to adequat ely disenon and connider new inforuation concerning al ternativen to the operation of CPSES available to Applicants (specifically, t n ( \: \ {_ ;

Key: -

. A = Agreenent au to voi d in;; and subst ance A(W) Agreenent an to wordfun only N = No agree:,ent a: to wordin"" or subst ance 7909240024

gar., coal, lignite and coal gasificatic.n).

l'Pl.] t_igl TU S 1 A (") A (W) A Cont Mtion 6 A cost-benefit balance invorable to operation of CPSES ccnnot be struck because of the following costs, thich have not been adequately considered:

a. Decommiraioning; ,

b. The costs to insure that the reactor vessel for Unit #2 will fit correctly;

~

c. Fuel over the life of the plant;

d. Long--tera vas t e storage and/or disporal.

Position TU S I A (U) A A Contention 7_

Neither the Applicants nor the Staff has adecuately considered the health or economic cost s of a possible accident involving spent fuel stored on-site, as discussed in Report No. 290 (MC Translat ion #161, " Studies Comparing the Greatest Posn J bl e l'a ilure Seq _ ances In a Proces sing Installat ion and In A Nucl ear Powe r Plant") , SAND--7 7--1371, " Spent Fuel IIcatup Fo] Ice:ing 1.oss of Wat er During Storage," the st udies and testimony of Richard E. Webb, and the ef fects of a reactor accident on that spent fuel.

Position TU S 1 A (W) A A

.3, pynty;ption 8_

The Applicantt. fail to analyze the probahi.T i ty of and healt h and econo:nic costs of a cla v 9 accident.

Position TU S' I

, A (U) A (U) A Contentions 9617 Neither the Applicant s nor the Staf f has adequately considered the heal th ef fects of low-level radintion on the population surrounding CPSES.

Position TV S I A (U) A A j

ContentJon 10 3 1

lg Neither the Applicant nor the Staff has edequa t ely consir!ered the pot ent ial econouic effects on operation of CPSES because of accidents which nay occur inreactorsofsidiardesibn to CP SI T, .

Position TU S 1 A (U) A (U) A Contention 11 The c ot '.-bene f i t analysis is inaccurate in that Applicants' projection of a 30 40 yr. useful life for CPSES is unrealistic because of:

a. ef f ect s of ctunulat ive rad i.ation on the plant, and

b. economic incentives to discontinue plant operation at solan shot t er t it!o.

Position TU S ( l. q -f. J 1

)-

A (t ) A (U) A.

- 4 ,

Contentipo 12 (incorporates contention < 12, 33, 14 and 15)

Applicants have failed to cc:. ply with 30 CPR Part 50, Appendix E, regarding cuergency planning. for the foll u.:ing renons :

a. The FSAR does not ident ify stmte or regicual authoritics responsible f or emergency planning or who have special

. qualifications for dealing with en.ergencies.

b. No agreements have been reached with local and state officials and agencies for the early warning and evacuation of the public, including the indentification of the principal officials by -

titles and agencies.

c. There is no description of the arrangerc.ents for services of

. physicians and other medical personnel qualified to handle radiation emergencies and arrangement s for the transportation of injured or contaminated individuals beyond the site boundary.

d. There are no adequate plans for testing by periodic dri))s of en.ergency plans and provisions for participation in thc drills by persons whose assistance r,ay be needed, other than c:cployees of the ispplicant. s f

e. There is no provision for redical facilitles in the i r :r.ed i a t e vicinity of the nite, which include <. Glen Rose.

f. There is no provision for energency planning for Glen Rose or the Dallas /Ft. Worth netroplex.

fP_S_i_t_i on TU S I A (U) A A Contention 16 The requ'ren. cuts of the Atomic Energy Act, as an, ended , have not been wet i r. that the Applicants are not financially qualified to operate the proposed facility.

Position

. TU S I A A o N c07c s1 /_ v

Contention 18 (incorporated into 6) 6 Contention 19 The Applicants' failure to adhere to the quality araurance/ quality control provisions required by the construction peraits for Co.,ance Peak, Units 162, and the requircraents of Appendix B of 10 CFR 50, and the const ruction practices enployed, specifically in regard to conertte work, welding, inspec-f tion, tr.aterials used and craf t labor qualifications, hr.ve raised substantial questions as to coupliance with 10 CFR 950. 57(a)(1).

Position TU S I A A A t

g I

\ (. I L ' (,