ML20148G683
| ML20148G683 | |
| Person / Time | |
|---|---|
| Site: | Allens Creek File:Houston Lighting and Power Company icon.png |
| Issue date: | 11/02/1978 |
| From: | Hinderstein C AFFILIATION NOT ASSIGNED |
| To: | |
| References | |
| NUDOCS 7811130136 | |
| Download: ML20148G683 (8) | |
Text
l UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION b
q;h BEFORE THE ATOMIC SAFETY AND LICENSING BOARD
/
In the Matter of 5
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Docket No. 50-466
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HOUSTON LIGHTING & POWER COMPANY 5
November 2, 1978 (Allens Creek, Unit 1) 5 SPECIFIC CONTENTIONS SUPPLEMENTING CARRO HINDERSTEIN'S i
ORIGINAL PETITION FOR LEAVE TO INTERVENE The following specific numbered contentions are raised to supplement the original petition for leave to intervene in the construction permit proceedings of the above heading and docket number. The numbered contentions herein add to the original petition, but are not to be construed as the final contentions of this petitioner.
Petitioner received notice by mail on October 27, 1978 that the original prehearing date of November 27, 1978 had been moved up to November 17, 1978, thereby giving petitioner only six days to prepare these contentions for the prehearing conference.
Petitioner protested the November 17, 1978 date in a ma11 gram to Sheldon J.
Wolfe on October 30, 1978.
In the event that the prehearing conference is rescheduled at a later date, petitioner may supplement the original petition with further specific contentions.
Petitioner is qualified to intervene in the above mentioned hearings on the basis of living and working approximately 35 miles from the proposed construction site and being within the zone of l
7811130/36 t
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interest construction permit hearings were designed to protect.
Petitioner has a M.A. and B.A. in Biology and a J.D.
Petitioner presents contentions dealing with newly discovered evidence and changes in the construction plans, but argues that alleged defects in the Supplement to the final Environmental Impact Statement (EIS) must be considered since; (1) the hearings on the single permit must be regarded as a de novo proceeding, and (2) the supplement was not in existance at the previous hearings.
I.
The Environmental Protection Agency (EPA) has given the final EIS for the above heading and docket number a rating of ER-2 which means there is insuf ficient information. S, A-5.
It is requested that all proceedings involving the proposed Allens Creek nuclear power plant be suspended until the EPA gives this project an ER-1 rating.
II.
The final EIS lacks discussion of the length and manner of interim high level radioactive waste disposal and the manner of ultimate disposal of high level wastes.
Until industry-wide guidelines are generated by the EPA for an environmentally acceptable program for disposal of high level waste, petitioner proposes that a case by case analysis of such disposal is proper procedure.
It is requested that the construction permit not be awarded l
until a validated high level waste disposal plan for the proposed plant is presented.
l III.
l The final EIS does not specify how the reactor vessel j
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will be transported to the construction site and what means have to i
be taken to effect this transportation.
The probability that this transportation will have an environmental impact necessitates its coverage in a final EIS for construction.
For example, dredging, widening or otherwise altering the Brazos River to bring the vessel to the site by barge would have an environmental effect.
It is requested that the construction permit not be issued until the reactor vessel transportation is sufficiently addressed.
IV.
The possibility of cold-shock to the plant and animal inhabitants of the proposed cooling lake is not adequately addressed in the supplement to the final EIS since only one unit is now being considered, not two. 5-24.
The cold-shock ef fect will be increased by the change of design from two units to one unit since the one unit will not be operating as much of the time as two.
Reports on the percentage of operating time for a single unit range from between 40% to 60% of the time.
It is requested that the final EIS be supplemented to include j
an in-depth study of the effects of cold-shock on warmth adapted aquatic life that is projected to be present in the cooling lake.
The study should include the experience of other single light water nuclear reactors with cooling lakes in the United States.
It is requested that the construction permit not be awarded until this supplemental. study is completed.
V.
The people of Texas have an increasing need of fresh water
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for drinking, transportation, recreation, irrigation, washing, etc.
The possibility of using sea water as the coolant has not been explored.
Sea water from the Gulf of Mexico is more in abundance and less in demand by the people of Texas than the water in Allens Creek.
It is requested that the possibility of a site on the Texas coast to utilize sea water be fully explored, and that the construction permit be denied until the sea water coolant possibility is addressed.
VI.
An alternative possibility to conserve the fresh water needed by Texas is the wet cooling tower as opposed to the cooling lake.
The proposed cooling lake will have the thermal load of 4 acres /MW.
S.5-7.
In Houston, the cooling pond would use more water than a wet cooling tower because of increased natural evaporation from the larger pond surface.
Water For Texas, Dec. 1974.
In addition, a cooling tower would use less ground surface area than a lake, leaving more land available for farming and natural habitat.
It is requested that the construction permit be denied until the choice of a cooling lake over a wet cooling tower is environmentally and economically justified.
VII.
Economic aspects of the proposed plant have been overlooked in the final.EIS.
Areas that need to be realistically addressed include the cost of retiring the proposed plant after it is worn out,
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the cost of management of nuclear wastes generated in its operational lifetime, the cost and availability of uranium fuel, and estimated construction cost overrun.
The trend over the United States is to look at the costs to the public of nuclear power.
For example, the Wisconsin Public Service Commission recently declared a moratorium on future nuclear power plant construction in Wisconsin because of solely economic factors.
This fact is new evidence of the increasing economic burden of nuclear power plants.
It is requested that a realistic report be made of the economic factors mentioned above in the final EIS. The rising cost and decreased availability of uranium can be projected for the estimated life of the proposed plant.
The fact that the cost of uranium is going up at a rate higher than the average inflation rate should be included.
The cost of decommissioning the proposed plant must be considered as well as the cost of interim and ultimate unclear waste management. Another factor which must be considered is that the average operation of nuclear plants in the United States is at 56% of its designed potential capacity.
It is requested that the construction permit be denied until a realistic financial projection be made that includes the aforementioned factors. The cost of the proposed plant will be largely shouldered by the customers of Houston Lighting & Power.
VIII.
Although the final EIS recognizes that Attwater's prairie chicken nesting grounds are in the inmediate vicinity of the proposed high voltage transmission wores, petitioner alleges greater safeguards for the continued well-being of this scarce bird are needed.
These
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birds are found only in several areas in Texas. Additional proposed safeguards include no construction of transmission lines until after a nesting season is over and the prairie chickens are gone from the vicinity.
Construction of the proposed transmission line in this vicinity should not occur during the several months before the nesting season, so as'not to disrupt the habitat before the birds come to nest. Another safeguard would be a complete ban on pesticleds and herbicides in right of way maintenance in the vicinity of the nesting grounds.
If cor.struction delays would be costly in avoidance of habitat disruption, then Houston Lighting & Power should be required to purchase for the State of Texas mitigating lands which are close to and similar to the nesting ground habitat, or where habitat could be developed for the Attwater's prairie chicken.
It is requested that greater safeguards be utilized to protect these rare Texas birds. The construction permit should be denied until the aforementioned safeguards are made part of the construction permit.
IX.
Monitoring stations to measure chemical air pollution and afr radioactivity levels should be planned at the perimeter of the
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plant site and about 5 miles away to ensure the safe operation of l
the proposed plant. The locations of these stations should be in the following directions from the plant, as per the usual wind patterns; N,S, SSE, SE, and NNE.
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7, It is requested that the construction permit for the proposed plant be denied until an air contamination monitory system is developed.
X.
The final EIS lacks a soil survey and adequate information of the aquifer and water table.
Information on the porosity of the soil, the composition and extent of the aquifer beneath the proposed site, and the uses of the underground water is necessary in order to evaluate the possibility of radioactive contamination of the cooling lake water and ground water.
It is requested that the final EIS include the data discussed above so the paths of dispersal, including the water ingestion pathway for humans, be known in the event of radioactive or other waste contamination of the coolant.
It is requested that the construction permit be denied until the above data is included in the final EIS.
XI.
Newly discovered evidence that no dose of radiation is low enough to reduce the risk of cancer malignancy to zero. The Bulletin of United States Atomic Scientists, Sept. 1978. The risk of inducing cancer at low doses of radiation is greater than previously known.
The low levels of radiation associated with a working nuclear plant pose hazards to radiation workers, especially where they are assigned to areas that exceed the legal limit of 5 rem /yr/ total body and safety checks are falsified, as occurred recently at the Kerr-McGee Nuclear Corporation near Oklahoma City.
Depositions and interrogatories in the suit filed by the Estate of Karen Silkwood.
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It is requested that the maximum permissible radiation-exposure for radiation workers be decreast to correspond with this 4
newly discovered evidence.
The radiation risk has to be intelligently weighed against the benefits of haveng a nuclear power plant close to Houston.
The gist of th!S new evidence is that any more radiation above the natural background radiation and necessary medical radiation should be carefully scrutinized as any extra radiation increases the risk of cancer for both radiation workers and people living close the the proposed plant.
Petitioner requests that the coastruction permit be denied uniti the maximum permissible radiation exposure for radiation workers is decreased in line with the aforementioned recent evidence, and adequate safeguards for radiation workers and the people living close to the plant be made part of the final EIS so that a Kerr-McGee situation where a private company disregarded government safety regulations will not occur at the proposed plant.
Wherefore, contentions considred, petitioner requests leave to intervene in the construction permit proceedings of the proposed Allens Creek plant.
Respectfully submitted, N
Carro Hinderstein 8739 Link Terrace Houston, TX 77025
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