ML19256B012
| ML19256B012 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 12/25/1978 |
| From: | Ryan C Citizens Concerned About Nuclear Power, INC. |
| To: | |
| References | |
| NUDOCS 7901170392 | |
| Download: ML19256B012 (9) | |
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UNITED STATES CF AMERICA NUCLEAR REGULATCRY CCMMISSICN BEFCRE THE ATCHIC SAFETY AND LICENSING ECARD fp
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In the Matter of
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HCUSTCN LIGHTING AND PCWER CCMPANY Dccket Nos.
50-498 i
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50-499 G[-'
(South Texas Project, Units 1 and 2 6
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PETITION FOR LEAVE TO INTERVENE Citizens Concerned About Nuclear Pcwer (CCANP), Inc., a non-profit organization, on its own behalf and on behalf of its members hereby petitions the Nuclear Regulatory Commission (NRC) for leave to intervene in the above-captioned matter pursuant to 10 CFR Section 2.714 of the NRC's Rules of Practice.
IDENTIFICATICN CF PETITICNERS Citizens Concerned About Nuclear Pcwer This Petitioner is a non-profit corporaticn with members in Bexar and Matagorda Counties.
The members are primarily interested in providing education and influencing policy regarding issues surrounding the use of nuclear pcwer.
The group has been active in promoting public hearings and forums on the issues of nuclear power.
The Petitioner has invited expert witnesses to testify at public hearings and forums.
CCANP has approximately 120 members. At least four of these members reside within twenty-five miles of the South Texas Nuclear Project (STNP). An affida-vit with their names and addresses is attached to this petition. There is also an affidavit with the names of the initial board of directors of CCANP and other members who have expertise and potential to contribute toward developing a sound record.
INTERESTS TO BE AFFECTED CCANP is concerned that its members may be subject to unnecessary risk of life and/or property from accident or ordinary operation of the Scuth Texas aclear Project and that the danger of exposure to radiation will be greatly increased by the escape of radon gas from the reactor, leaks in the transport and/or storage of #uel and wastes, and human errors in the handling cf radio-active material. CCANP is alsc concerned that mistakes and delays in ecnstruc-tion which have occured will adversely affect the operating safety of STNP and increase the econcmic burden on its members.
790117osg
-2 The mistakes and delays in construction make the request for an operating i
license premature since adequate inspection can not be performed.
CCANP is willing to participate in the proceedings because it is aware of the importance of broad and meaningful public participaticn and does not think that it will unduly delay the preceedings. There were no citizens groups or individuals recognized at the hearings for the request of the construc-tion permit for the STNP. CCANP asks the Ccmmission to recognize the request of citizens participation in the proceedings dealing with the operating license application.
CCNTENTICNS 3
- 1. CCANP maintains that since the basis for granting an cperating license depends on the ability to assess the safety of the construction, the current hearing for the request should be delayed until construction is far enough advanced to ensure proper inspection.
l (a) Officials are currently predicting that Unit #1 of the STNP will be
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operating fully in March 1983.I This CJnstitutes an eighteen month delay in the construction time table.
2.
Applicants request for an operating license is premature due to mistakes in construction.2 The mistakes in construction en the part of the contractor are directly related to the ultimite safety of the STNF.
(a) The South Texas Nuclear Project has not been built in accordance with design specifications and precedures.
(b) An auxiliary structure has been built one foot from where it should be located.
(c) Voids have been found in a concrete wall of a building that will contain the nuclear reactor.
(d) A field sketch of the plant design has been lost.
(e) Language dificulties have existed between Mexican-American and Viet-namese workers and their foremen.
(f) Allegations have been made that some construction foremen are unable to read and write.
(g) Unit #1 of the STNP will have to have a wedge secticn of the reactor wall removed in order to slide some equipment sideways into the reactor buil-ding. This unusual construction technique could pcssibly weaken the reactor wall.
3.
The health and safety of the members of CCANP are in jeopardy due to f
possible design defects in the Westinghouse pressurized water reactors.
(a)
The NRC has published a report, NUREG-0138, which notes that the l
Westinghouse reactor design has a problem relating to overpressurization.
This problem, which is especially critical during startup and shutdown, could cause a rupture of the reactor pressure vessel and thus lead to a large scale release of radioactive material into the surrounding area.
(b) A nuclear engineer, Dale Bridenbaugh, who has followed the over-pressurization problem, reports that since January 1972, there have been 1
j 29 overpressurization incidents which have. challenged the reactor vessel i
j integrity. He has concluded that because of overpressurizatien, the gross vessel failure probability is in reality at least 1,000 times more likely than assumed in the NRC's Reactor Safety Study (WASH-1400).
(c) CCANP requests that the applicant provide research and development of design modifications which would prevent overpressurization of the reactor.
CCANP also requests that the applicant describe the necessary design modifica-tions and present a schedule for the implementation of those changes.
4 CCANP contends that the NRC's previous estimates of casualties from a major accident releasing radioactive material are low because they are based on unrealistic evacuation plans.
(a) The WASH-1400 estimate of casualty figures assumes that 90% of the population in an area affected by a radioactive accident could be evacuated at least twenty miles from the plant within eight hours of the accident.
(b) Applicant is requested to present the evacuatien plan for the twenty mile radius of the STNP and indicate what steps it has taken to inform the public of this plan.
5.
CCANP centends that STNP will present an undue risk to the health of members in the area due to the uncertainty of the amounts and types of radio-active materials to be released into the environment.
(a) Applicant is requested to estimate the total amount and type of radioactive material which will escape into the environment once the plant is in operation. Applicant is also requested to give a scientific explanation or estimate of where this material will go and who will be expcsed to it.
6.
The STNP should not be licensed to cperate until the prcblems of final nuclear waste disposal is resolved.
(a) The plant will be prcducing nuclear wastes in amounts too great to be handled on site.
4 (b) According to the Interagency Review Grcup on Nuclear Waste Managment the earliest date for the first repository of high level nuclear wastes will be l
1992 (if all geologic formations are considered).
CCNCLUSICN for all these reasons, we urge that the Applicant's proposal not be j
approved or if approved that it be approved on the basis of the stated contentions.
j Respectfully, M
h Coral Rcse Ryan Citizens Concerned Abcut Nuclear Power 414 Kings Ct. #C.
San Antonio, Texas 78212 ENDNCTES 1
Karen Jumulty " flaws Reported At N. Plant",
San Antonio Licht, November 19,1978 pp. 1&20.
Ibid.
3 Dale Bridenbaugh "Overpressurizatien of Reactor Vessels" Memerandum MGB Technical Asscciates, March 15,1977, Appendix B pp. 1 6.
- Frank Cchs " Nuclear Meltdcwn...When?",
Guardian, December 13,1978.
AFFDAVIT STATE OF TEIAS COUNTY OF BEIAR I am Coral Ryan, a meuber of " Citizens Concerned About Nuclear-Power", a public interest group with members in-Eexar and Yatagorda Counties.
I have personal knowledge that we have members residi=g in Matagorda County.
The names and addresses of those members who reside withm 15-25 miles of the Soutir Texas Nuclear Profeet are:
Sophie D. Burkart 2917 Ave. K.
Bay City, Texas 77414 Mr. & Mrs. George J. Bunk P.O. Box 362
'Nadsworth, Texas 77483 Dorothy Peters Route 1, Box 40 Palacious, Texas 77465 Sworn ta and subscribed before me thisjd day of December, 7.978.
b Signature:
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GAJLd2Y&
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AFFIDAVIT STATE OF TEIAS COUNTY OF BEIAR I, Coral Rya 1.
a member of Citisens Concerned About Nuclear Power (CCARP), have personal knowledge that the following information about the membership of the group is valid and ute.
The initial board of directors for CCAN? at the time of incorpora-tion on April 13, 1978 were:
Sydney Janak, Lanny Sinkin and Coral Ryan.
The following members are identified to indicate their expertise and potential to contribute toward developing a sound reccrd:
Louis E.. Campos Student in Environmental Studies 219 Ira # 3 San Antonio, Texas 78209 Golfrey Connally Bachelor's and Master's degrees in 300 W. Courtland Economics from the University of Sarr Antonio, Tx.
He has presented papers on the economics of'the STHP to:
San Antonio City Council October, 1978 on:
"How Much Electric Power Generating Capacity Does San Antonio Reed" Public Forum on Energy at Trinity University, San Autorrio,Tx.
" Critique of the Task Force Report on the STUP" Novesher, ' 78.
Philip Haves Ph.D.
Solar Energy Researcher 1305 E. Mulberry #15 San Antonio, Tx 78209 Sydney M. Janak Master of Arts in History 307 Bretonwood West Texas Str.te University (1968)
Sarr Antonio Tx.
78218 r
Presented a paper on " Nuclear Waste ' at an Energy Conference in San Antonio,T2. November 11,19l6 Coral Ryan Master of Science in Nursing 414 Kings Ct. #C The Catholic University of America San Antonio, Tx.
78212 Washington, D.C.
1967
2 Membership of CCAUP Continued:
Lann7 A. Sinkin Past Executive Director of the 838 E. Magnolia Ave.
Urban Coalition of Metropolitan San Antonio, Tx.
782I2 San Antonio, Tx. (1971-1975)
Hous ton Wade M.D.,.. Ph. D.
A native citizen of San Antonio,TI.
202 N. Woodlawn A physician practicing medicine in San Antonio, Tx.
Eexar County, Tx.
A biochemical geneticist with three degrees in chemistry and biology including a Ph.D. degree from the University of Texas in Molecular Biology.
A Clinical Professor of Family Medicine at the University of Texas Health Science Center at San' Antonio.
A research scientist with seven years of' full time research experience using redionuelides (radioactive isotopes) in biological systems.
O UMm Coral Ryan f-Sworn ttr and subscribed before me this M day of December,1978.
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UNITED STATES OF AMERICA NUCLEAR REGULATORT COMMISSION BEFORE THE ATOMIC SAFE"Y AND LICENSING E0AR3 IN THE MATTER OF
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HOUSTOR LIGHTING & POWER COMPANT, DOCKET Fos.
50-498 l
50-499
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(SOUTH TEXAS PROJECT UNITS 1 & 2)
I CERTIFICATE OF SERVICE w
l I hereby certify that copies of " CITIZENS CONCERNED ABOUT NUCLEAR POWER'S AMENDED PETITION FOR LEAVE TO INTERVENE WITH ITS CONTENTIONS" in 1;he above captioned proceeding have been served on the following by deposit in the United States mail, first class this 26 day of December 1978:
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Charles Bechhoefer, Esq.
Atomie Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Dr. James C. Lamtr, III 313 Woodhaven Road Chapel Hill, North Carolina 27514 Dr. Emmeth A. Luebke Atomic Safety and Licensing Board IT.S. Nuclear Regulator 7 Commission Washington, D.C.
20555 4
Henry J McGurren, Esq.
Staff Counsel l
Office of the Executive Legal Director U.S. Nuclear Regulatory Comm+ nsion Washington,. D.C.
20555 l
Richari W. Lowerre, Esq.
Assistant Attorney General for the State of Texas P.O. Ecz 12548 Capitel Station Ana tin,. Texas 78711
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Honorable Burt O'Connell County Judge, Matagorda County Matagorda County Court Ecuse Bay City, Texas 77414 R. Gordon Gooch, Esq.
Baker & Botts 1701 Pennsylvania Avenue, N.W.
Washington, D.C.
20006 Melbert D. Schwarz, Esq.
Baker & Betts One Shell Plaza Hous ton, Texas 77002 Mr. D. Michael McCaughan 3131 fic=ons Lane, Apartment 254 Houston, Texas 77027 Mr. David Marke 3904 warehouse Row suite C Aus tin,. Texas 7E704 Atomic Safety And Licensing Appeal Board U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Atomic Safety and Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Mr. Chase R. Stephens Docketing ami Service Section Office of the Secretary U.S. Nuclear Regulatory Cc= mission Washington,. D.C.
20555
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Coral R7an t/
Citizens Concerned About Nuclear Power 414 n'gs Ct. #C.
San Antonio',. Texas 78212