ML19338C386
| ML19338C386 | |
| Person / Time | |
|---|---|
| Site: | Allens Creek File:Houston Lighting and Power Company icon.png |
| Issue date: | 08/15/1980 |
| From: | Doggett S, Schuessler W, Jeffrey Scott AFFILIATION NOT ASSIGNED, DOGGETT, S.A., TEXAS PUBLIC INTEREST RESEARCH GROUP |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| ISSUANCES-CP, NUDOCS 8008150334 | |
| Download: ML19338C386 (2) | |
Text
7 jg/fa UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION EEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of HOUSTON LIGHTING & POWER COMPANY Docket No. 50-466 (Allens Creek Huclear Generating Station, Unit 1)
CONSOLIDATION OF TexPIRG, DOGGETT AND SCHUESSLER CONTENTIONS DEALING WITH ADEQUACY OF APPLICANT'S EMERGENCY EVACUATION PLANS On July 24, 1980 the Atomic Safety and Licensin Board ordered that TexPIRG Additional Contention 16(d), (e), (g) and f
(i) and Additional Contention 42; Doggett Contention 5; and Schuessler Contentions 6 and 14 be admitted for litigation in this matter, and further directed that they be consolidated.
Mr. Schuessler was admitted as an intervening party, also.
The Board is herewith advised that the involved parties have conferred, as directed, and' agree that Mr. Schuessler is designated to act as the lead party for purposes set forth in the order.
The involved parties have agreed on the following language for their consolidated contention:
Schuessler Contention 1 (TexPIRG 56 - Doccett 6)
Applicant's Environmental Report and PSAR, and NRC's FES and SER, in regard to emergency planning, fail to comply with provisions of 10 CFR Part 50, Annendix E, and 10 CFR Part 100 as (to oe) ammended.
Applicant fails to demonstrate any capability of safely evacuating the Houston area in the event of an ACHGS accident of any magnitude up to and including Class 9.
ACNGS fails to adequately meet requirements of 10 CFR Part 100, regarding siting, for reasons which include, but are not limited to, the following: (a) Applicant fails to adequately recognize that metropolitan Houston is the fastest-growing area in the U.S.,
steadily and rapidly expanding toward the site of ACHGS; (b) The proposed site of ACNGS is not presently sufficiently remote, and will become even less so during its oper-ating life; (c) Traffic congestion at present and for the foreseeable future prevents any effective, timely emergency evacuation of the greater Houston area, or 8008180 MI b
any substantial part thereof; (d) The State of Texas has no tested and approved evacuation plan for nuclear emergencies; (e) The distance from ACHGS to population center should-be much greater than 1 1/3 x LPZ because of special circumstances cited above.
The'PSAR fails to meet requirements of 10 CFR Part 50, Annendix E, II, in that it fails to assure the compat-ibility of emergency plans with site location, access routes, population distribution and land. use.
The PSAR and the selection of the proposed site do not properly consider population density, land use, physical characteristics (possible radioactive contamination of Brazos River water), thereby failing to adequately insure low risk of public exposure ac required by 10 CFR Part 100.10 The Board should deny Applicant a construction permit until these requirements are met, and Intervenors contend that these requirements cannot be met at this proposed site.
~
Respectfully submitted,
/
William 4 pdhu'essler 5810 Darn m Houston, Tex. 77074 Stephen A. Doggett, Bsq.
P'. O. Box 592 Rosenberg, Tex. 77471 James Scott, J r., Esq.
TexPIRG 13935 Ivymount Sugerland, Tex. 77478
.(2)
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