ML20147B972
| ML20147B972 | |
| Person / Time | |
|---|---|
| Site: | Allens Creek File:Houston Lighting and Power Company icon.png |
| Issue date: | 09/29/1978 |
| From: | Rentfro W, Sohinki S AFFILIATION NOT ASSIGNED, NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| To: | Atomic Safety and Licensing Board Panel |
| Shared Package | |
| ML20147B961 | List: |
| References | |
| NUDOCS 7810110238 | |
| Download: ML20147B972 (3) | |
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D N'UM DorTP,g q-g" 09/29/78 UNITED STATES OF AMERICA NUCLEAR REGULATORY C0K4ISSION BEFORE THE ATOMIC SAFETY AND LICEllSING BOARD
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1 A-In the Matter of
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HOULTON LIGHTIflG & POWER COMPANY Docket No. 50-466 p'O h
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m STIPULATION BETWEEN THE NRC. STAFF AND WAYNE E. RENTFR0 The Petitioner, Wayne E. Rentfro, and the Staff of the Nuclear Regulatory Commission (NRC Staff) have reached the following agreements with respect to the legal standing of the Petitioner to intervene in this proceeding and the contentions he has advanced.
I.
INTEREST (STANDING) l The Petitioner has alleged that the proposed transmission line corridor for the Allens Creek Nuclear Generating Station would come very near to his home and divide his property in half.
He further alleges that he is concerned with the health hazards of living beneath high voltage trans-mission lines, with possible injuries to his family and horses, should M
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noise and shock effects of the transmission lines scare the horses, and with the detrimental effect on the appearance of his neighborhood which the transmission lines would have.
The NRC Staff agrees that these allegations are sufficient to demonstrate that Mr. Rentfro has met the interest requirement of 10 CFR 92.714.
II.
CONTENTIONS The following contentions are now advanced by the Petitioner and all other contentions previously advanced by the Petitioner are withdrawn.
The NRC Staff agrees that these contentions should be admitted as issues in controversy in this proceeding.b 1.
Transmission Corridor 1A should be relocated because the population within a one (1) mile radius of my home has increased from ninety-six (96) people in 1974, to over two hundred eighteen (218) people at this time.
There are thirty-two (32) new homes and six (6) under construction.
Two of the homes under construction are in the proposed transmission corridor and directly under the line.
The area has grown rapidly and the trend appears to be accelerating.
U e agreement between the Petitioner and the NRC Staff goes only to the Th admissibility of the contentions under 10 CFR 52.714(a).
The NRC Staff reserves the right to oppose the contentions on the merits at the upcoming hearings.
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By relocating this section of the line.80 mile farther' South, this f
population concentration could be avoided.
The overall length of the line would be changed by less than two percent (2%) and no additional corner C
towers required.
This route would be through open farmland with relatively few scattered homes.
This alternative has not been adequately examined.
2.
The Applicant has not adequately analyzed the potential health hazards associated with living in proximity to high-voltage transmission lines.
Hearings on this subject are currently being conducted before ths Pennsylvania Public Utilities Commission in the case of Winfred Higgins who has experienced considerable discomfort and mild electric shocks
.while. living beneath a high-voltage line.
Respectfully submitted, d' '
rylJ Stephen M. Schinki Counsel for NRC Staff
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Wayne E. Rentfro Petitioner
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Dated at Bethesda, Maryland,
-this 29th day of September,1978.
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0 PUBLIC.DOCUMIN5'.PMi 4 N1:
UNITED STATES OF A!1'RICA,
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. NUCLEAR REGULATORY C0!ntISSION
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BEFORE' Tile ATOMIC SAFETY-AND LICENSING BOARD
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In the !!atter of
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0 110USTON LIGHTING & PO'n'ER Col!PANY
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Docket No.
50-466
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(Allens Creek Nucicar Generating
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-Station,' Unit 1)
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_ STIPULATION BETWEEN NRC STAFF AND TEXAS PIRG
'i The petitioner, Texas Public Interest Rc' search Group (Texas Pirg), and the rl I.!
Staff of the Nuclear Ecgulatory Commission,(NRC Staff) have reached the followins agreements with respect to the legal standing of the Tex.as Pirs,
j to intervene in this proceeding and the contentions it has advanced..
I.
INTEREST (STANDING)
- The Texas Pirg has alleged that several named members live in the vicinity of the proposed plant and that they would be adversely affected j
by radioactive emissions from the proposed plant. The NRC Staff agrees that these allegations are suf ficient to comply with the inter'st require-e ment set forth in the Cotnission's Rules of Practice; 10 CFR 82.714 78191 L pa y1 5
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CONTENTIONS The' following contentions are now advanced by the Texas Pirg and all other j
contentions previously advanced by the Texas Pirg tire withdrawn.
Unless.
otherwise noted, the NRC Staff does not. object to the admission of the content 1ons now advanced and believes that they-should be ' admitted by the :
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board as issues in controversy.
1.- The South-Texas site is an obviously superior alternative to the Allens r
Creek site because: '
a.
South Texas is already the location for two nucicar plantis which are currently under construction and disturbing an unspoiled site is not justified; b.
the cooling lake at South Texas is'large enough to accommodate-one more unit such as the proposed Allens Creek facility; c.
constructing.another nuclear facility at. South Texas would involve significantly less land use than constructing the. proposed facility at the Allens Creek site;
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l The ogreement between the Texas Pirg and the NRC Staff goes only to the admissibility of the contentions under 10 CFR fi2.714(a).
The NRC_ Staff reserves the right to oppose the contentions on.the merits at the. upcoming hearings.
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d.
construction of an additional facility at South' Texas will involve the use of significantly less water than will the proposed facility.
Consumptive water use is a critical issue in Texas; indeed, the Legislature has required that ground water users in the liouston area convert tossurface water to reduce subsidence, which is a major problem in this area; c.
construction of an additional facility at South Texas would require less use of additional land for transmission If nes than would the proposed f acility; and f.
the population density in the vicinity of the South Texas site is and will in the future be significantly less tbsp-that}q the vicinity of the proposed facility. The residual rf sh to thN$bublic from operation of an additional facility at South Texas would therefore be less than that associated with the operation of a facility at the proposed site.
2 The smaller cooling lake size and changed location of the lake vis a vis the original proposal will render the lake useless as a viable recreational fishery because:
a.
the changed location eliminates the Bluff area as a recreational and fish spawning area;
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b.: the amount 'of chlorine which will be. rcicased -to the lake has _
more than doubled, which will result in significant. fish kills; I
c.
sever discharges from Wallis, Scaly and the nucicar plant will cause an excessive algae growth in the lake; d.
the hecvy metal concentrations in the lake will result in heavy metals concentrating in. the fish and will. make them inedible; c.
thermal shock will kill large numbers of fish during the winter when plant shutdowns occur; i
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the anbient temperaturcs in the lake will be too high to support game fish in sufficient numbers to make the lake a viabic recreational fishery; and i
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the removal of fine screens and fish pass from the intake structures will increase fish kills.
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A. cooling tower is.a preferred alternative to the proposed lake becauses '
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b.
the use of a cooling tower would save significant amounts of fresh water over the proposed lake.
This consideration is ecpecially important in the 11ouston area in light of the subsidence problem detailed in a separate contention; and c.
the cooling tower option, in addition to being environnentally preferable, is less expensive than the proposed lake.
4 Even if a cooling lake is approved by the Board, the Eoard should require that it be redesigned to be nore of an environnental benefit and less of an environmental burden.
specifically, the dam (levee) should be extended northward to a point just cast of its present NE corner so that the runoff can go into the lake and so that the north bluff area can be a viable fish spawning area.
5.
Neither the Applicant nor the Staf f have given adequate consideration to the combustion of solid vaste as an citernative energy sodrce, because:
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The Staff concludes on s.9-9 of the DS-rES that "the lack of deton-strated technology on a commercial basis eliminates the potential future energy sources from consideration as alternatives for central station power by the late 1980's," apparently including refuse
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. conbustion among the " future alternatives;" However, the i
evidence will indicate that the Staff has been inaccurate with regard to solid waste conbustion. Twenty-one operational plants exist in the United States, with nore than onc dozen under con-struction, over forty in the advance planning stage, and over sixty in the feasibility study stage.
Further, such facilitics have operated successfully in Europe for over 40 years.
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b.
The Staf f states on 59-6 of DS-FES that solid waste generation plants should be used to " regain lost energy," but expresses doubt that such plants will be contributing cicctricity in the near future.
The heat content of solid mixed municipal waste is approximately o
5,000 ETU/lb. or 40 percent the value of coal.
In waste pro-cessing systens, the renoval of light combustibics and separation of non-combustibics like glass and netals yield a paper-rich fraction in excess of 10,000 UTU/lb. or 90 percent the heat value of coal. Anong the 80 pperating " waste-to-c3 cetricity" plants in Europe are plants in Amsterdan and Frankfurt which supply six and seven percent of their city's electricity needs, respectively. The assumptions of the,Staf f regarding the use of this option are theref ore incorrect.
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i The six-thousand tens per day of solid vaste in Ecuston are c.
rore than adequate to suppcrt a three-thousard ton ;er day cenversion plant that muld obviate the need for the pre;csed AC:!CS; and this alternative is techtole;ically, environnentally, and cconenically desirable relative to nuclear generatics stations.
(Tids option should te an issue at this hearing.
Tetitioner telieves the solid vaste of 1:custon can sustain 600-1,000 }Fe of production; th009,h this icvel of supply could not have substituted for the tw-unit AC::GS proposal in 1975, it does beccee viable in cc parison ta enly one v.it.
In addition, since July,1975, 2S cerunities have, tegun feasibility studies for solid vaste rowr generation,14 ncv plants wnt into the planning stage, and tw core plants tweane operational-thus sussesting an incretsed viability cf this ^
option during that tine.)
6 Petitioner contends that the taxies:n credible accident has not been considered because the present saf ety and enviren-ents1 enalysis do not ccasider the ef fects of a large airplane crashin; into the centainrent vessel. :;ew infortation fron TAA indicates that large plane traf fic has increased at least 30 percent in the last three years, and vill te.
several hundred percent higher tefore the plant is closed in about 40
'o 8-o years. Also, new airports have been proposed to be buil in the Fort Bend County area nuch closer than present airports. This in conjunction s.
uith the heavy population density planned for the area cast of the plant nake it essential that the plant be noved much further away fron population centers or, as a less inviting option, require that the plant containment be strengthened to withstand the crash of the largest plane that is allowed to fly in the Ifouston area. This can be donc by roughly doubling
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s the thickness of the containment vessel or still nore cheaply by burying the plant for about a 5 percent increase in cost.
[The NRC Staff opposes the admission of this contention to the extent it deals with intentional aircraf t crashes and vill discuss the basis for its opposition in a separate response.]
7.
Energy conservation has not been adequately considered as an alternative to the proposed facility because:
a.
direct capital investacnt by the Applicant for conservation retrofitting in the service area has not been considered.
Examples of reasonabic retrofits are more effective insulation, scaling, more efficient lighting units, inproved air conditioning main tenance, use of nore efficient glass, ands use of nore efficient d
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Expenditur e of funds by the Applicant in the range of 50 percent that proposed for ACI4GS would mean that the rcraining demand for electrical power could be met with solid vaste cotbustion as detailed in a separate contention; b.
inadequate attention has been given to the likelihood that major industrial users in the liouston area vill be producing their own energy in the near future.
Texas City industrial compicx, Dou Chemical compicx and Bayport complex are presently considering such an option; c.
the rate structure of the Applicant does not provide an incentive for energy conservation. Recent testimony before the Texas Public Utility Commission by Dr. Frederich Wells demonstrates the viability of altering the rate structure to significantly reduce power usage; and d.
neither the Applicant nor the Staff has considered the increased
'une of " passive solar" techniques, such as architectural modificatfons and landscaping techniques that optimize the use
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of solar energy for residential and commercial structures.
Expended conservation measures as set forth above vould taitigate the need for a large central pover station such as 'AC:'GS.
This is especially true because:
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Applicant's projections of power demand fiave decreased 22 percent in the period in which the proposed facility was deferred, and 2.
reduced power production of a one-unit ACNGS vis a vis that of the original two-unit proposal can more readily be obviated by the ncasures outlined above.
8.
Applicant has not demonstrated a design that will provide an adequate margin of saf ety, in the event of Anticipated Transients L'ithout Scram.
In that Applicant has no nucicar reactors operating at the present time, and therefore will not be drawing upon a pool of operators experienced in responding to transients, and since transients occur most fre tuently in the early stages of power plant life, ACNGS in the fit at few years of operation in particular vill threaten release of radioactivity in excess of 10 CFR Part 100 guidelines. Therefore, Petitioner asserts that the license should be conditioned upon the incorporation of an automatic redundant scrae in the ACNGS design. New evidence, in' the form of an Elcetric Power Research Institute study and NUREC-0460, indicates that new reactor designs,of tenn have higher frequency of transients than older designs.
ACNGS vill be such a neu design, Ek'R/6/., (Additional notet studies by Peter Ecurne and others confirn that experience nitigates adverse responses to st' ess conditions.)
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Petitioner contends that the Staff has inaccurately concluded in its NEPA evaluations that a nuclear power alternative is 1 css costly, both economically and environnentally, than coal-fired generation.
This contention is based upon the following factors:
a.
The operating experience for nuclear plants of this size indicates they will produce caly half the power of their planned capacity, while coal-fired plants will produce at a 70 percent capacity.
Furthermore, a comparison of two 375 !!We coal-fired units should be analyzed relative to the ACI:CS, because smaller-sized units will be more reliabic and thus require smaller. reserve targins.
This alternative would thus utilize less resources and be less costly.
Studies by Kahn (1977) and Konanoff (Nuclear Power Performance and Update, 1976, 1977) provide evidence for this factor.
b.
Capital costs associated with coal-fired plants planned by other Texas Utilities are 40 percent icss than those projected by the Applicant and Staff, and the prospects of utilizing Texas-mined lignite would substantially reduce the operating costs of the coal fire alternative.
Both of these aspects would substantially i
1 alter the weighing process in Appendix S.D of the DS-FES.
c.
Research by Kahn (1977) indicates that peak-load central power units, such as small coal-fired units, vill be rere likely to encourage the use o'f supplemental solar heating and cooling units in the power grid.
Since such solar units would result in environcental benefits and long-tern econonic benefits in the Applicant's service area, the base-load nuclear generating station represents an environnental liability relative to peak-load station alternatives.
Petitioner, therefore, asks the Board to find that coal-fired generation of power would be a preferable alternative to ACNCS.
[The NRC Staff opposes the admission of this contention and will discuss the bases for its objection in a separate response.)
10.
Applicant has not adequately denonstrated coup 11ance with 10 CFR
" art 50, App. A, criterion 31,.vith regard to intergranular stress, cor--
rosion and cracking. Excessive oxyaen icvels, superposed loads, and residual stresses nay result in ultir. ate failure of piping, despite altered netal content for the ACNCS design. Tlyc NRC investigation of strces, corrosion, and cracking problens at sinilar BWR units was released in Decenber 1975.
[The NRC Staff opposes the adnission of this contention and vill discuss the bases for its objection in a separate response.]
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. 11.
Applicant has not adequately assessed the effects of flow-induced vibration on jet pumps, opargers, fuel pins, core instrumentation, and fuel rod s.
Feedvater sparger failures occurred at five IMt units from 1975 to 1976, all duc apparently to flow-induced vibration.
Petitioner asks that a license be denied until an adequate assessnent is presented by the Applicant.
[The IRC Staff opposes the adnission of this contention and will discuss the bases for its objection in a separate response.]
Respectfully subnitted, (Y
Stephen M. Schinki Counsel for IEC Staf f ates Scott, Jr.
Counsel for Texas Pirg l
September 26, 1978 4
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