ML19254D033

Responds to NRC Request Seeking Specific Contentions.Alleges That Transportation of Radioactive Matls on Tx Highways Will Result in Accidents.Suggests Const of Coal Plant or Locating Proposed Plant at South Tx Site as Alternative

ML19254D033
Person / Time
Site:	Allens Creek File:Houston Lighting and Power Company icon.png
Issue date:	09/12/1979
From:	Conn C AFFILIATION NOT ASSIGNED
To:	NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD)
References
NUDOCS 7910220016
Download: ML19254D033 (2)

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Co to Staff Council US ruclear 9.egulatory Cocaission 03DVEq ilashington, D. C. 20555 ScP f a 79,,7 In the Mattar of )

Houston Lighting & Power Company ) Docket Zo. 50-4c5 (Allans Oreek suclear Jenerating )

5tation, Unit 1) )

Gentlemen:

In compliance with your requests for an additional letter explaining specific contentions--I do hereby present saae:

1) A coal plant would be a preferable choice of generating plants for the Allens Creeh Site. The impact on the area would be less in that the general risk to the local citizen and the outer area citizen is greatly altered and reduced. Iconomically a coal plant would very nearly compare in costs--in 1975 money l'Ilectrical '.iorld", Nove:bar 15, 1975 showed that electricity fro: nuclear plants t==S actually avaraged 13.2 2111s per kilowatt-hour whereas GEES electricity from coal plants cost only 13 5 nills per kilowatt-hour. In 1975, Investors' 2es E55? Research Center's " Hews for Investors"pointed ponsibility out the jf5' following liabilities of nuclear plants: increasins capital ypf y cost including hushe overruns, the increasing price of

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uranium, the disappointing operatin6 (capacity) experience of nuclear plants; uncertainties related to fuel enrich-vuJ cent, the lack of reprocessing plants, and the lack of a c,

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definita program for the disposal of high-level radio-active wastes. f.esearchers are beginning to co e up with CE S_ solutions to the environmental probleas of coal: Dr. .ialph

@zii 2. Peck and Dr. ~ add Pircon at the Illinois Institute of (5((

Technology have developed a " scrubbing" process that recoves sulfur dioxide fro: coal combustion effluent and coabines the residue with other chemicals to produce a high-grade fertill:er for agriculture. If the process proves effective in the field, experts say the outcome could be lower utility ratos for consumers, a scrubbing system that psys for itself and a steady source of domestic materials for fertilizer for fs.rmers. Another nice thing is this scrubber syste; costs about 33 :lllion compared with others up to 140 million. This process was tested . tith both high sulfur coal and low sulfur coal; therefore it should be possible to use Texas li3 nite. The a2 cunt of sulfur dioxide leaving the ano2estack was reduced by 95l?

with signifiaant reductions in the particulate :stter as well. (5 tory appeared in the Houston Post Septe2bar 1, 1979.)

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2) The Incation of the South Texas nuclear Plant in 3ay City is a more desira'ola choice of location than the .,llens Creek site near Wallis. The city of Houston is rapidly encroaching on the western suburbs. Eaty , 3ugarland, Richmond and Rosenberg all had small populations back in 1970 of 2,92?; 3,313; 3,777;12,093 respectively. In ,1ust ten years the area west of Houston has spread and spread to where its difficult to point to a rural boundry--perhaps Sealy. Its not hard to picture solid residential areas solid all the way out Interstate 10 to Iaty in just a few c__n years. By the time this nuclear plant will have worked c?t . 30 years about 2020 the area within 20 diles of the plant eis will be highly developed. It would seem extremely likely

[r that EL&P's estimates are badly off particularly lookins at Ft. Send County. (Texas Depart 2ent of 'clater Resources; gf cE- Population Projections, Plannin5 and Devlopment Division,

@? Secember 1973 and The Rossnberg Chamber of Oo :erce) gjy- EL&P's projections in the Final Environaantal State.nent appear to be off about 100,000 in the year 2000 and ouch ggpa sore so oy the termination of tha plant. This area is zuch more heavily populated than the Jay City area and

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<=E totally unsuitable for a nuclear plant. The Scy City 6Z28 plant has facilities for the addition of a 1200:s.I plant.

63L, The existin6 lake is adequate--this would create essentially a water savings by not having to maintain the Allens Creek Lake. The water supply in Houston is gettin.3 to be a coh-cern particulary with the su'osidence with wcter well usease.

Enviror.:entally the place =ent of the plant in 3ay City uses such Iess land, and the 1.: pact is greatly reducei

. oecause an entire section of the city reaains free of a nuclear plant and its accompanying possible " accidents".

3) The transportation of radioactive n;.terial on Texas diahways will surely result in several accidents. I contend that the present plan to use Interstate 10 is not acceptable because of the population density of the area. Harric(1. enter)

County estia2.tes ranfe fro 2 over 7 tillion people (Poju-lation Projections for Texas Countirs: 1930-2020, 'Jniversity of Texas nustin, Popul>. tion 7,esearch Janter, IJ73) to dLOP's 4,530,c00. Until such time as we have trucks th?.t don't collide, the persit for the Allens Creek plant should be denied lue to the possibility of accidents through Housten.

4)' Ihe present status of storage for radioactive :;teritis is in liabo because noone knows where to store something for several thousand years (550 for reprocessel). Until such a challenging problea is solved--all peraits for other nuclear plants should oe denied.

mzm-O ::~ Cordially yours, vo r. cw

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