ML19326D806

Comments on Proposed Rules 10CFR50 & 51:requirement That Class 9 Accidents Be Considered in EIS Should Be Applied Retroactively to Plant Since Site Has Not Been Fully Determined

ML19326D806
Person / Time
Site:	Allens Creek File:Houston Lighting and Power Company icon.png
Issue date:	05/04/1980
From:	Doherty J DOHERTY, J.F.
To:	Aherne J, Bradford P, Hendrie J NRC COMMISSION (OCM)
References
FRN-45FR40101, RULE-PR-50, RULE-PR-51 NUDOCS 8007030339
Download: ML19326D806 (1)

Text

- - - - - - - - - _ - - - - - - --

T Hay a, +-G &

- =a*S 3 + 5 PWSO RULE l

~~

b  % 9 a327 Alconbury

('15 Fkl40101)

Chairman John Aherne

$ = $$% A 1,' ~3 3 """ "' '"'"

ctfice d M Mr. Peter Bradford DMdigsch Mr. Joseph Mendrie Erci nr. Victor Gilensky ,N,O , ' kg/ #

IIr. Richard Kennedy ' c) l 43 RE: CCH::ISUICli ACTICli Cli SSCY S0-131, "AC"IDE:!T CCI!3IDER-ATIO1! UIiDER I!ATIO1125 EITVIRO12'ElTAL PCLICY ACT" Gentlemen:

As a pro-se Intervenor in the 111 ens Creek Uuclear Generati - Stntion croceedings, Docket 50-465, I am deeply ,

disturbed at recoc2endations that the illens Craak be '

excluded from Consideration of the environmental effects of Class 9 accidents as recommended by the Commission Staff.

I an disturbed because this reccommendation ignores us. This plant is in no less need of these considerations than a plant for which an environmental statement has not been published. The Allens Creek plant has had a statement and sunplement published (following a two year delay due to Anglicant financial inadequacy). Yet, the Staff for tne 111 ens Creak licensing has stated it , intends to pub-lish another supplement. 'ihen this supplement is published, it fill, unless the Staff position to omit consideration of Class 9 for this licensing is changed, contain no such studies.

As a result of these facts, I am urging that the Staff has been toereticent in applying the recuirement to consider Class 9 accidents retroactively. That the Allens Creek site has not been fully determined is but another reason the Allens Creek proceeding does not belon5 among the six licensings chosen by staff to not be subject to Class 9 accident considerations. ~

Myself, and Texas ?ublic Interest.Research. Groups have had several contentions denied admission-because they are buced on Class 9 accidents also. If the Staff's recommen-

! dation is acceoted, the Commission will have produced an anomaly for the six reactors involved. In'the case of Allens Creek, I helieve the anomaly will be greater, be cause the suitability and selection of site ~are not fully determined for it.

Respectfully submitted ohn 2. Ddherty R0070so p