ML19289B997

Addl Contentions of Tx Pub Interest Res Grp,Filed in Support of Petition to Intervene in Proceedings Re Subj Facil. Asserts That Plant Would Be Open to Sabotage & Would Also Destroy Nearby Fisheries

ML19289B997
Person / Time
Site:	Allens Creek File:Houston Lighting and Power Company icon.png
Issue date:	11/01/1978
From:	Jeffrey Scott TEXAS PUBLIC INTEREST RESEARCH GROUP
To:
Shared Package
ML19289B999	List: ML19289B997 ML19289C000
References
NUDOCS 7811210038
Download: ML19289B997 (5)

Text

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NRC PUBLIC DOCUMENT E0034 [

ov. 1, 1978 Ci1TED STATES OF A:TRICA NUCLEAR REGULATORY CO:': ISSICM or TEE U.S.

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BEFORE TliE 'sTO:!IC SAFETY A'7D LICE';5I'!G mARD f m ecesm Sa U( U se*Ac 3

In the !!atter of ) p" NOV 7197.8 >

) ce w = -

EOUSTON LIGrTING AND POWER CO:!PANY ) Q **e n 2 *e f

) 00C. 50-466 %

(Allens Creek Nuclear Generating ) 4 Unit 1)

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ADDITIONAL CO:iTENTIO:!S OF TI:E TENAS PULLIC INTE"EST RESEARCli GROUP The Taxas Public Interest Research Group, an organization seeking leave to intervene in the above-styled natter, herein files additional contentions beyond those already en record.

Texas PIRG would point out that these contentions supplement earlier contentions or issues __ offered before this Board, p.s stated in the instrucent, entitled " Stipulation Ectween the :IRC Staff and Texas PIRG" dated Sept. 26, 197S.

Eowever, this docunent is obviously separate fron the atove=nentioned subnission and in no way inplies that a sicilar agreenent has Mec reached as to the issues stated below.

Texas PIRG urges the Ecard to adctit the following issues into controversy in thi proceeding:

1.) S.4.5(3) of the Final Environnental Staterent (FIS) does not adequately disclose and analy e the alternatives chosen for the transport of constructien-related creponents to the site. In particular, the applicant ha s no t clearly decernined whether watervay barge transit will be used for transportation of large reactor conpenents to the site.

Such a transportation schere would require dredgin; and charneliz.ing of ~

sections of the San Eernard River or Erazos itver. Such activity suuld disrutt V 811210 OM &

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=arine life in that river, create excessive turbidity and clouding of the water, destroy river bottom-life, require environmental destruction during spoil disposal, and baitiste secondary impacts in the form of increased industrial usage of the river (s) . Petitioner contends that Applicant's committ=ent to transportation of the reactor vessel should be expressed = ore specifically, and that the Board should either deny the _

license wholly, or require the alternative site action sought by Texas PIRG in contention one of the stipulation between Texas PIRG and the -

NRC Staff .if the dredging and channelizing is necessary.

[This contention should be censidered because (1) new evidence in the form of the U.S. Fish and Wildlif e Servtce 1978 Stream Evaluation Ibp now available show both the Brazos River and San Eernard River to be excellent fishery pro-duction sites, and (2) failure to adequately discuss the environcental inpacts of the dredging above would constitute a procedural violation of :iEPA and thus its consideration is within the public interest]

2.) The EPA reports at S.A-6 of its comment en the Final Supplenent to the FIS that direct radiation dosage at the site boundary, when added to doses from other sources, say violate 40 CFR 190. Petitioner contends that the construction license should be conditioned upon a reduction in gaseous radiation emissions to ensure compliance with 40 CFR 190,in that a f ailure to do so may result in substantial costs, delays and further danage to the public interest during the operation of the f acility. (Since 40 CFR 190 was prenulgated in 1977, it obviously represents a "new circun-stance."]

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3 3*) The N.R.C. has not satisfied the requirecents under the Atomic Energy Act of 1954 to protect the health and safety of the public by failing to adequately demonstrate that the public can be evacuated from the heavily-populated Houston-area in the event of a taximum credible accident at ACNGS.

In particular, the Applicant has not adequately cocplied with 10 CFR 50, App. E, in that the evacuation description fails to assure the " compatibility of proposed e=ergency plans with... site locatien with respect to... access routes, surrounding population distributions, and land use." Petitioner further notes that land areas in the immediate eastern vicinity of the proposed site are projected to greatly increase in population density in the later years of the proposed facility's life, and that presently stated evacuation problems will be exacerbated in the future. Because of the heavy traffic congestion on all major escape routes within the area between downtown. city of Houston and the site, adequate evacuation response cannot be achieved presently and will be even less likely in the future. Fur thermo re ,

Applicant contends that heavy recreational usage will occur in the park associ-ated with the proposed plants, and in light of this, Petitioner forsees severe evacuation proble=s in re=oving large numbers of state park users, likely to be unfamiliar with the i= mediate environs; and particularly those who may be boating on the lake.will be dif ficult to evacuate.

As the 7th Cire. Court said in the case of a proposed plant also near a recreational park: "What would occur if a lar;e but unknown number o f carpers and visitors unfamiliar with the area and with no nearby hoecs in which to take shelter, heard a public address anncuncerent to evacuate the ares due ~

to nuclear accident. . .It strains credulity to expect tha t this problen will verk itself out..." Isaak b* alton tr. o f arerie , ,. 'c.

4 As further basis of the necessity of evacuation capability for the city of Houston, WASH-740 show.. up to 760 square miles (ten miles by 76 miles) would require evacuation in the event of a Loss-of Coolant accident with fission release, for a reactor of much s= aller (one-sixth the size) size.

For the foregoing reasons, Petitioner ur:,es that the license as presently described be denied. ..

(New evidence can be shown in the worsened traffic proble=s of the city of Houston over the past three years, the recent reports of state planning agencies showing cany of Houston's freeways have now. begun to' exceed their planned capacity, and the vastly increased populations of Katy and other nearby areas since 1975]

4.) Applicant has not provided a site configuration which adequately protects ACNGS from sabotage and potential subsequent releases of radioactivity in excess of 10 CFR 100 guidelines.

The Applicant predicts high population transient use of a state park and adjoining cooling lake, and this routine occurrence will greatly a;gravate the protection against sabotage.

A unit of scuba-equipped saboteurs, launched from the lake, and crossing under the lake boundary =arker, for example, could utilize tools and naterials described in 10 CFR 73.55a (1) (iv) in entering the _ site premises or through the water intake point to danage the reactor building internals. The configu-ration of the plant site facing an open lake with thousands of routine, unrestricted users per day results in many hypothetical sabotage scenarios described in Part 73.55a(1) being within the realm of possibility.

Furthermore, neither municipal er county law enforcenant of ficers can be considered accustomed . to encountering urban enforcerent problems, such ~

as those required in security for this proposed facility.

5 Petitioner contends, therefore, that Applicant has provided the necessary assurances required under 10 CFR 73.55. (rule promulgated in 1977]

5.) 7.1 of the Environ = ental Impact Statecent states that the environnental and/

risks of accidents are exceeding small "need not be considered further." However, the basic assu=ptions behind the calculations related thereto are grounded upon

ASH-1400 (such as the classification of certain Class 9 accidents).

However, the !!RC's Risk Assessment Review Group, chaired by Dr. Harold Lewis, found that WASH-1400 " suffers from a spectrum of problems ranging from a lack of data on which to base input distributions to the invention. and use of wrong statistical methods."

Petitioner contends that the license should be deferred, pending re-assessment of values in the environmental risk analysis, with particular emphasis upon the problems outlined by the Review Group, especially those probabilities. relating to

" Accident Initiation Events."

(The 'isk Assessment Review Group's report was issued in Sept. 1978]

6,) Petitioner contends that the drywell planned for Allens' Creek Unit 1 will not withstand the pressure generated in a LOCA. The water within the weir wall will not clear the first row of vents before the dif ferential pressure exceeds 23 p.s.i. This is due to failure to properly account fcr the :'annings roughness factor within the wair wall and the vent pipe. By delaying the time to clear the first row of vents by only 0.5 secend the drywell will be damaged allowin; the escape of high pressure stes= into the containment without being condensed.

This will lead to the containment vessel pressure e::ceedin; 15 psi; so that it vill crack allowing the escape of radicactive 3ases above the licits allowed by 10 CFR 100.

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