ML20197C920
| ML20197C920 | |
| Person / Time | |
|---|---|
| Site: | Allens Creek File:Houston Lighting and Power Company icon.png |
| Issue date: | 11/02/1978 |
| From: | Framson M AFFILIATION NOT ASSIGNED |
| To: | |
| References | |
| NUDOCS 7811210245 | |
| Download: ML20197C920 (3) | |
Text
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United States Huclear Regulat y Commission p/g NRC PUBLIC DPCU"SNT ROOM Bj q
BEFORM THD ATOMIC SAFET'l AND
/ CENSING BOARD g
y In the Matter of Ecuston Lighting and Power Company
)
Docko b No. SC y
(Allens Crook, Unit 1)
)
Ncvember 2, 1978 c1 llhbEL/N'E EMS FQt@N'o Contentions 1.
The proposed Allenc Crcok Plant is planned to be located at a oito that will have an environmental impact on a prosently denco-polmlated area. This location in in an arca that is about the fastest growing area in the nation, both in numbers and in geographical dimenciens. Applicant should be donied permit for construction until demographic ctudios cro made for a time framo during the life of the plant to its demise in 30 years.
Since tha plant and its environs will still be radteactive aftor its dysfunction, etudios should ba = ado on its environmental impact into perpetuity, and demographic otudies should be mado for a timo framo af ter the initial 30 year period and thoreaf ter, ad infinitum, of this population that will be burdoned with this environmontal impact.
2.
Construction permit should be denlod until studies are endo for the routes to be used for radicactive materiale in the ecmplete nuclcar cycle from dolivery of fuel roda to the plant to the removal and transport of radioactive wastos from the plant.
Licence should be denied until the public in informed of thoco routes and is allowod adequate time to inter-vono at hearingo, as to the trancport of radioactive materials and wantes to and from the plant, on the total spectrum of itu envirotu: ental impact.
3 Environmental impact studios, includice planned radiation emiscieno and unplanned radia-tion omissieno in an accident, during tranopert of radicactivo materiale and wastes in the complete nuclear cycle relating to the Allens Creek Plant on these propoced routes chould be made. My family will bo subJcct to thic environmental icpact and radiation emisci ons since our residence is located a clooe proxietty to the 610 Loop and many other main froc-wayo and thoroughfarou.
Robart S. Framson's job, which requires 50% travci, includes travel in the eccplote radius of Ecusten and Harris County, and also into Fort Bend, Wharton, Auctir..
Brazoria, Colorado and Waller Counties.
4 An averego nuclear reactor can turn out as much as 32 tons of radioactivo spent fuel a year.
DOE Assistant Secretary Jcha O' Leary and Dr. Ralph Lapp, utilities consultant, i n-dicate that there will be at least ten year on cito storago of high lovel radicactive wastca which makes the A11cus Creek Nuclear Generating Station cosentially a Uuclear Waoto Reposi-tory for at leact ten yoars and parhape, in porpetuity, cinco the prob 1cco of radicactiva wastco are insoluble. Formit shod 1d be denied until studies aro made of the radioactivo omissions from the etcady incromonts of radicactive wantos stored on site.
Thic increacod storago time would necessarily increase hazards to the public's health and cafety. A sub-stantial increase 'n the amount of radioactive wasto at the plant sito could foreo the plant to curtail eporation or ohut down altogother in ordor to ccace the generation of wastes. The environmental, health and cafety issues are germane to the interim and ultimato atorage of radioactive wastos not only to this generation but to future goncretions.
5 This increment of radioactive vaston, which will includo voapons-grado plutonium for bombs, atored on plant sito creates a serious accurity risk and makes this area vulacrable to thef t, violcuco and nuclear terrorism. These acts of nuclear terrortec could triggor an cecident of catastrophic porportion: rolcaoing exconsive amounto of radiation, with recul-tant destructivo.offects to the public and the onvironment.
6.
Drs. John Gofman and Arthur Tamplin, world renown nuclear phycicist and medical physi-cicto, both formerly connected with the Atomic Enorgy Ccmmission, in their many yearn of rescarch of effects of low level radiation indicate that there is no known Hsafed 1cvol of radiation. Also confirming their rocearch are studios by distinguiched scientists in this I
country and abroad, recently rovcaled in spite of attempted supprescion by certain govern-l 7811210v/r ment agencies.
Thoss studios indicate that govgrnment ctandards for safe levels of radlSL 4 tion are flawed and erroneous.
Drs. Karl Z. Morgan, former director of health physics at tho Oak Ridge, Tenn. Nuclear Facility for 30 years, Irwin Bross, Director of Biostatistics.
Roswell Park Cancer Institute, Thomas F. Mancuso, University of Pittsburg, research scientist under ERDA grant, Alice Stewart, internationally regarded epidomiologist, Birmingham Univ.,
Inglandand her associato, George Ineale, biostatistician, are just some of the scientisto whose rocce.rch data reficoto that levele of radiation unposure that have been considered safo by the government are actually dangerous.
These so-called government ctandards have caused cancer and the implications are far reaching in effecting not only nuclear workers but the popula ti on-a t. largo.
Dr. Mancuoobas stated, "... the risk for the industrial population is u
10 times greater than was estimated beforo.
Therefore, the standards should be reduced by 4
10 timon, become 10 times more stringent, and consequently, the general po:mlation which is expocod to a fractica of what the inductrial population is, will have to bo reduced accord-ingly.d Construction pormit should be denied until non-government, independent investigators study and reviso radiation limits for atomic workers and the general public.
6.
The population-at-1 ergo chould not be lumped into one stereotypical ihdividual, with equal ausceptibility to radiation. Radiation has a cumulative factor. Particular health, diccase, age, pregnancien, genetics are just some of the factors offecting individuals' susceptibility to radiation.
It is already medically knownf that the young, who make up
'ths enjority of the population, and prognant women are predisposed to radiation.
Our family is also one with high succeptibility to radiation.
j Madeline Baoa Framaan hac pernicious anomia, c"oplcto deficiency of hydrochloric acid and j
seriouc hypothyroidism. Her physiciano are Chiefs of their Dopartments, ia research and j
teerhing, at the Baylor College of Medicino, Houstog Texas.
Those physicians, as well as me' dical journals and textbcoks indicate that these medical conditions cako Mrs. Framson one of the hichoot cancer-prone risks.
Thene doctors have advised Mrs. Framson that if cancor occurred it would bn " environmentally triggered".
Robert G. Framson has cerious colon and prostrato conditions and is also considered a high cancer-prone Imtient.
Both Mr. and Mrs. Framson will have to be examinod periodically for the rest of their lives for cancer ~ several timos a year.
My family' u interest is not protected with the propcocd A11cus Creek Plant and its env i ron-mental impact and I fool we represent the vast numbers in the general population with varicuo medical problems, conditions and ages that are highly susceptible to radiation.
To license this plant ic to stato that a large segment of the population,is expendable.
Conctruction pa rmit chould be denied.
7 The building of Allens Creek Nuclear Plant will not only increase the danger to health and safoty, but will also cauoe decreased civil liberties.
This ic becauce c ' the extensive pro tec tive safeguarda required to protect againut nabotage and terrorism.
Su pose someonc reported that a portabic rocket capablo of breaching the containment was in tl 9 arca of the plant, do you suppooc that the police would wait to Get a search warrant befor a conducting house to house searchee at all homes close enough to hit the containment with be rocket.
The Barton Report of Oct. 31, 1975 was prepared under contract of the NEC, and it gives a detailed discussica of the problom.
The EIS han not conaidered thio environmental impact and so l a incomple te.
S.
The safety analysin hac failed to consider the danger frcs insulator failures in con-tainment c1cetrical penetrations.
During October and Novembe-1977, the Millstonc plant had coveral failurea due to the epoxy insulator intrucion into cable splices that led to hich reslutance heating that caused short circuits be tween conductors that were to havn been icolated. At Al en Crook, this can cauce electrically operated valvos to-be in the
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incorrect position (as, pen wbon supposed to be closed), and failure of alarma to a ma te properly which can endanger the public health '.nd welfare.
J,
e
,6 9
The IIS and Safety Evaluation of Allons Creek is defective because they used the WASH i
1400 Reactor Eafety. Study results au the basis of expoeted safoty as the plant.
- Tot, several recent studies have'all indicated that the report is wrong in its calculation of the probabilition of various accidents at the plant.
It.faliled to account for tho intor-i action-of various failure mechanisms that are not indopondent events ao assumed.
It failed to account for the mistakes and fears of ordinary human beings that operate plants ruch as l
Allons Creek.
The report did not considor that a worker might use a candle to set the i
Browns Ferry firo that almont caused two core molts.
It claimed that no spacomon w)uld burn up on the ground while sitting in tho space ship, yet 4 men have already dono so.
Until the data ia convincing to tho insurance industry ouch that they will insure all locees
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then the A11ona Creek plant should not bo built.
1 1
10.
The procent plan for decommissioning Allens Creek is inadoquate becauco it does not i
incure that the applicant will be ablo to properly decommicsion the plant or pay for it if soms way,was available to do it safoly.
Before building the plant and opending over ons l
billion dollars in construction costs, the applicant should post bonds held in escrow to insure that the money will be available to properly decomminulon the plant.
Both the CAO and the Concross have reccably issued reports on this problem.
- 11. About 31 million acres of U.S. farmlands have ddsappearod in the last decado, accord-ing to EPA.
That's an area half the alto of the State of /Vyoming.
The diminishing supply of food for our nations with its rapid growing popuLition has serious implications for its economy, utability and securf ty.
In a world-wide context, it's a peaco/ war factor.
The EPA intends to limit this adveras impact.
The Allena Creek Plant abould not be constructed
]
as it in obviously contributing an adverse impact in destroying over 5000 acres of rich food-producing farmland, a dimininhing natural resource.
12.
A large number of environmental and nafety probless arc associated with the BWR, Mark III co ntainment, Emergency Coro Cooling System, automatic Protection systemn, etc. to be used in the Allenc' Crook Plant, but I must stop now to got this photocopied and mailed before deadline, although I have studied and prepared almost full time for thu 5 days since being told that contenticas wauld have to be submitted by Nov. 2nd.
I again wi sh to register my objectionc to the arbitrary unfair accoleration of schedule not giving petiticcers adequate timo for proper preparation of contentions.
If I am given cufficient timo as allowed by my conctitutional right of Wreald due process, I will submit more contentions and elaborato more on the above.
44t4E+L h822 Wayneuboro Drive 3
Houston, Texas 77035 6
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