ML20150E078

Affidavit Submitted by Petitioner K Hooker to Intervene as Attachment to Her Request for Waiver of NRC Standards for Low Gaseous Radioactive Emissions from Nuc Pwr Plants;Waiver Request Made Per 10CFR2.758.Cert of Svc Encl

ML20150E078
Person / Time
Site:	Allens Creek File:Houston Lighting and Power Company icon.png
Issue date:	11/22/1978
From:	Hooker K AFFILIATION NOT ASSIGNED
To:
References
NUDOCS 7812110103
Download: ML20150E078 (3)

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.- NRC PUBLIC DOCUMENT ROOM UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION j BEFORE THE ATOMIC SAFE.TY AND LICENSING BOARD 4

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a In the Matter of HOUSTON LIGHTING & POWER COMPANY Docket No. 50-466 i

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(Allens Creek Nuclear Generating ) # -

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AFFIDAVIT 'ATTACIDGr FOR PRO?OSED 'RUIES 1rRIVER by Kathryn Hooker This Affidavit is submitted as an attachment to my recy est for vaiver of Comdssion standsnis for so-called nncrrala or low gaseous radioactive emissiens from nuclear power plants, as set forth in 10 C.F.R. Sec. 50 and Sec. 20. The request was made on ::y cubmitsion, " Supplement to Oral Defense of Contentions," sent under separate cover Novenber pl,1976 (see p. 3).

The waiver request is filed pursuant to 10 C.F.R.2 758, which per: tits /.

a showing of aspecial circtutstances with respect to the subject r. attar of the particular ,areceeding. . . auch that application of the rule er regu]s tion would not erve the purposes for which the rule was adopted.*

Althou{;h I do not know with certsinty what the edssions rales 8 original purposes were, I aseame they related to attenpts to regulate radioa::tive adssions standards se as to ensure public safety. Indded, sny other purpose at odds with pubMc safety would, on its face, be contrary to the Camdssior.te legal nandate to pretect the public health and safety.

Therefore, ny request for waiver of the standard emissions criteria of 10 C.F.R. ie based on the special circumstances carrounding this partic-ular proposed site- circunstances that would make the application of the criteria a public health hacard, thereby nullifying the original purpose of the criteria (pubHe health and cafety). The special circum-stances I cite are the noncer:plianca of Houston-- the :rj or netropolitan 7812110103 ff

i area within the donnission's zone of concern *-- with Federal air pollution criteria, coupled with consideration of new infor::ation en the synard.stic effects on humans of air pollutants and gaseous radioactive emissions. I beg the Board to consider these special l J

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umstances as fellows: 1. As meriting, by themselves, waiver of H

aseous radioactive emissiens staMarde; and 2., as aeriting )

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,Jaiver of the standaMs when weighed in conjunction with new evidence I that low-In vel radiation does nore damage to humans than was previously supposed.

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Petitiorer verified Hounton's current non-co:upliance with Federal pollution standads in general by phene call to en officisi er the Houston Air Pollu-tien Board, and will supply written documentation of this fact if requested.

Time prohibits a more detailed discussion of actual data, but I would like to at least cite certain evidence in an attempt to meet the Beard's criterion of

• reasonable specificity." On synergistic effects of radiation and pollution, I would cite the following articles, among others:

nTae Study and Control of Environmental Radioactivity and its Relevance to the Control of Other Environmental Contaminants,a Presten, A. A tomic Enri cy Rariew, 15(3):371-hos, cept. '77.

"'Ihe Need for Radiation Controls in the Fhosphate and Related Industries,n Beethe, G.F., Health Phys. 32 (h): 285-90, Apr. '77.

If the cecond stipulation of the viaver request is grant ~i, I would cits the fellowing articles, among others:

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• Cancer Cases Spark Concern fleiit Radiation; Scientists -Debate 8 Safe' Limit for U.S. Werkers," Us11 Street Journal, July 11, 1978.

ndancer and Low Level IonizinC Radiation,s by Karl Z. Morgan, The ik1116 tin (medical publication) Septenbar 1978. _,

November 22, 1978 Respectfully, f +

/Kathryn Hooker 1 NGL CERTIFICATE OF SERVICE I hereby certify that copies of this Affidairit Attachment for Proposed Ruh a Waiver (Decket $C-h66) have been served on the fellowing persons through deposit in the United States inail, first class, this 21st day of November 1978: -

Shelden J. Wolfe, Chairman Richard Le warre Atomic Safety and licensing Board Fanel Asst. Atiorney General U.S. Nucissr' Esgulatory Commissien P.O. Box 125h8 Weskington, D.C. 20555 Capitel station Austin, Texas 78111 Robert Lon nstein Lowenstein, Reis, Neuman & Axelrad J. Gregory Copeland 1025 Cennecticut Ave. Baker & Botts-Waskington, D.C. 20555 1 shell Flsza Housten, Texas 770G Decketing 6. Services Branch U.S, Nuclear Regulatory Coredesion Washing +a n, D.C. 20555 Resp trully e 22/f wp ,f' %

SUBZRIBED AND SWORN to before me this 22nd day of November, 1978

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~ . Notam puync YICKIE NAnut,s m V My commiss,on [,]lll gy, n, ,,

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