ML20197C539

Petition by G Kainer to Intervene as Full Participant in Proc Re Subj Facil.Contends That Pub Is Not Adequately Protected from Dangers of Proposed Facil

ML20197C539
Person / Time
Site:	Allens Creek File:Houston Lighting and Power Company icon.png
Issue date:	11/07/1978
From:	Kainer G AFFILIATION NOT ASSIGNED
To:
References
NUDOCS 7811210123
Download: ML20197C539 (5)

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Nuclear Regulatorv Commission 8- P L2 i

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%n, %, fgE85' BEFORE THE ATOMIC SAFETY AND LICENSING ECARD g $h J In the matter of ) oi 7 1

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HOUSTCN LIGHTING & POWER COMPANY ) Docket No.# -

) 50 466

( Allens Creek Nuclear Generating Station, Unit 1) )

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I, Gregory J. Kainer recuest termission to intervene as a full particicant in the construction permit hearinzs concerning H L & P Allens Creek Nuclear Power Generating Station.

I feel unreasonably insecure about these hearings, not because of formalities of a public hearing, but of the inadequate length of time permitted to prepare formal and legal argument with reasonable speci.ficity. At this time,I wish to formally request termission to forward additional supplementary contentions,as these were arranged in creat haste. My additional contention will be well within the realm -

of these proceeding, as also enhance the intended public interest with relevant material matter. Please excuse the inadequacies and }

incompleteness of the contentions at hand, but time is an important element to assess one's resourses,as EL & P and the NRC staff already 781121o I'A3 4 Can the applicant EL & P prove with reasonable specificity that his exterince in the Dublic utilities sector and forehand develotment knowledge with nuclear power,cualifv him to eterate with anticitated imtrokement of annual ocerational time and safety,a nuclear pcwer ceneratinc station (Et.'iR). I trates he . -

can a.ot. In 1976 of the LO nuclear power stations,(not just Eiias), with a combined assumed operating capacity of 26 hours3.009259e-4 days <br />0.00722 hours <br />4.298942e-5 weeks <br />9.893e-6 months <br />

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daily X 365 days yearly, before subtracting the normal 42 day-to-- .

10 week fuel reloading period, a total of 314,760.00 operational hours. The common occurance then;- 113,782 hours0.00905 days <br />0.217 hours <br />0.00129 weeks <br />2.97551e-4 months <br /> (72% of total) of combined scheduled and forced outage.of commercial service. This is evidence of the undeveloped nuclear generating technology and error, ,

Equipment failure attributed to 40%(forced outage), maintence 22%

(scheduled outage and ocerator error-8%(89 out of 699 combined outages)

It is known that with a nuclear plant shut down(routinely or a scam) stored energy drops severely in seconds, from approx.210 MWe(7% original operational power-1500 MWe), to approx. 105 mie(3 5% original power) in 5 sec. ,then on to 1.0% original power af ter 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. I contend the limited exterince must be a burden of proof the applicant must satistv, as this is absolutely unjust to the already strained energy needs of Houston and the U. S. I request denial of the necessary permit.

I contend the statistical radiation exrosure risk factor for Allens Creek is misalizned and irrelivant to the matter at hand.

For statistical extrapolation,using regression methods one can draw interesting conclusions, providing the data base is of reasonable specificity. ligures supplied by The Nationa'. Safety Council-1976 indicate the electrical utilities (202 reporters) recorded 850 disabled weeks per 1 million working hours,(25,000 weeks), rankinz

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29 out of 41 different industrial categories. The total averare of all the industries-688 weeks disabled per 1 million workinz hours.

These figures may imply anythin they want them to imply, but not how they could discredit E L s ?'s performance beyond a reasonable l doubt. I crotest EL s ?'s lack of assessment with reasonable scecificity the social and environmental imract a nup. lear tower station at Allens Creek will trovide They made an attempt to fullfill the increasinely

- continued better so'cial and environmental requiramonts the public concensus now demand. The past regulations and social observations allowed the NRC a coct/ benefit analysis relating'to consideration of a nuclear power generating site. This is unjust 1n that now new parameters 3

must be considered due to the serious treat of dangerous radiation d

exposure to the air I breathe. As disclosed in conclusion 3 of the GAO Report to Congress, January 12, 1976, there is guidance needed for eyaluation of environmental impacts. Also stated was the need for an Interagency Comprehensive Study of Existing Waste Disposal Sites, and also no standards for nuclear waste management. The House Report no.# 94-1320, June 30, 1976 from The Committee on Govermental Operations sited. that the management & regulatory responsibility is with consistent direction. and. . . . preformance of existing waste disposal is not good. The radwaste storage building is included in the risk evaluation. I contend the liability of myself and the people of Houston and nearby vicinity is not adequately administered for protection of the health and safety as amended by the Price Anderson Act. The Mark 3 containment has not been used before. As ilalter C.

Patterson, a nuclear physics graduate and writer from the University of Manitoba states; The genetic vulnerability of organisms to radiation ,

isn't known yet, so we don't know ':ca to extrapolate them to many generations of human exposure. There is,..not beyond a reasonable doubt a ethical question, not just a technical one, since society's health and happiness are at stake as also that off their offspring. The final HL i ? Environmental Study s.3-8 states t' rat taking into account the state of technology and the economics of improvement in relation to benefits to the public health and safecy, but in the same report

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s.iv; chemical discharges should not significantly affect aqtatfc biota,

....provided that discharge of total residual chlorine to the eccling

continusd ' l lake is maintained. As a fisher:an of many years this is a double l

standard, since we all know we can't have human perfection and since I we can't we all know we c_a't have a serious effect to the waterlife in the Allens Creek area. At the enpense of the environment we are santicning a temporary energy solution as inadequately as it may be.

If the nuclear industry, particularly, EL ': P was sincere about energy savings in relation to the environment they would have refined the state of the art beyond a reasonable doubt, reprocess the spent fuel decreasing the radiation daughters as also decrease the size need for nuclear waste storage. I prudently contend the equiocal nuclear industry's foresight, particularily, EL & P for the better ent of my future,as also that of Houston's citizens, in that atomic energy is in my interest as well as the public at the Allens Creek nuclear power generation site. I request absolute denit.1 of the necessary constro ion permit. I refer to Wash-1400, The Beactor Safety Study; An Asse'sment of Accidential Risks in U.S. Commercial Nuclear Power Etants. Professor Norman C. Rasmussen under contract with MIT to studythe Wash-1400 report, states the prompt & delayed accidents are greater than the statistical average in the draf t, and applied only to current commercial reactor designs. He also assesses,the Wash-1400 Report doesn't include fuel shipments, waste dispcsal, sabotage and fuel reprocessing in it's statistical analysis. jL, contend the present site location at Allens Creek is a safety Hazard and menace to me and the Houston society, due to accidential radiatien extosure. You must consider the public interest in this matter as the Houston area SMSA is one of the fastest growinz in the

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nation by current projections by the U.S. Census Sureau and The $1:y of Ecuston's City Planning Department. I refer to MIT Snerzy lab 8 s

continued Sadio-active Waste Management and Regulation, September 1,1976, Mason W111 rich states; safe management of post fission radio-active is a present necessity and an irreversible long term commitment. The basic goals of radio-active waste -management are unclear, as existing radioactive waste regulation ineffective, if left unchanged. I site _

Allens Creek Nuclear Power Generating Plant,due to the present site location and nature of experimental trial and error of dangerous radia' tion containment a health and safety hazard with reasonable specificity. As there are other alternate energy means that are safer and prepetuating, such as active and passive solar energy and geothermal, I plea with the licensing board to reconize this construction permit request as that of similar motion of Baltimore Gas and Electric at Perryman Maryland in which tha termit was denied. Another distantly remote site should clearly be choosen in view of the population density and environmental assessments made.

Sine rely, ti -

Gregory J. Kainer

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