ML20197C929

Contentions of Petitioner R Framson,Who Is Seeking to Intervene in Proc Re Subj Facil.Asserts That Proper Studies Have Not Yet Been Made.Also Protests Accelerated Prehearing Sched

ML20197C929
Person / Time
Site:	Allens Creek File:Houston Lighting and Power Company icon.png
Issue date:	11/02/1978
From:	Framson R AFFILIATION NOT ASSIGNED
To:
References
NUDOCS 7811210249
Download: ML20197C929 (3)

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United States Nuclear EcCulato Commincion Q 6 h BEFORS 'iHE ATOMIC SAETY AND L7 INSING@fd@UBLIC DOCUMENT R kg f

, 4b D. y In the Matter of Houston Lighting and Powor Company (A11cnc Croek, Unit 1)

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1. The proposed Allenn Crcok Plant is planned to be loca~ted~tt riststEdt**t11.1 have an environmental i= pact on a prosently denco-populated area. This locatlen is in an area that 1o about the fastest growing arca in the nation, toth in numbers and in geographical dimencions. Applicant should to donied permit for conotruction until demographic ctudios aro made for a time framo during the life of the plant to ite demise in 30 yearc. Since the plant and its environs will otill be radioactive after ite dysfunctice, ctudios should be made on its environmental . impact into porpetuity, and demographic studies should. be mado for a timo frame af ter the initial 30 year period and thereafter, ad infinitum, cf thi::

population that will be burdened with this environmental impact.

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2. Construction permit should be decled until studies are cado for the routes to be used for radicactive materials in the complete nuclear cycle from dolivery of fuel redo to the plant to the removal and trancport of radioactive wastos from the plant. Licence should be doniod until the public in informed of those routeo and is allowed adequate time to inter-vono at hearingo, as to the transport of radicactive materials and vactos to and from the plant, on the total spectrum of itc environmental impact.

3 Environmental impact studios, includir.g planned radiation emisciono and unple.nued radia-tion omiscions in an accident, during transport of radioactivo materials and wacten in the complete nuclear cycle relating to the Allens Croek Plant on these propoced routec chould be mado. My family will be subject to thin environmontal impact and radiation eminci onc since our residence is located a cloce proximity to tho 610 Loop and many other main froc-vaya and thoroughfarcu. Robert S. Frameen's job, which requiros 50% travel, includeu travel in the complete Brazoria, Colorado radiuc and of Heuston Waller and Harris County, and also into Fort Band, Wharton, Auctin, Ccuntics.

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An averago nuclear reactor can turn out as much as 32 tons of radioactivo spent fuel a DOE Aseistant Sacrotary John O'Loary and Dr. Ralph Lapp, utilitien consultant, in-dicato that there will bo at least too year on cito storago of hich levol radicactive vastes which =akos the Allens Crcek Nuclear Generating Station esecntially a Huclear Waoto Reposi-tory for at least ton years and porkaps, in porpotuity, sinco the problems of radioactivo vastos are insoluble. permit ehould bo denied until studios are endo of the radioactivo emissions from the otcady incremonts of radioactive wastos stored on citc. Thic itercaced s' storago time would necessar$ly increase hazards to the public's health and cafety. A sub-stantial increase in the amount of radioactivo vasto at the plant sito could force the plant to curtail.oporation.or chut .down altogether in ordor to ccaca the generation of wasten. Tho onvironmental, health and.cafety. issues are gormane to the interim and ultimato gorage of, radioactivo yantos not only to ithis genoration but to future gonorations. "+e o

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.o .,- e i .: , i 4'5.W This incremont of radicactive vaates, which will includo weapons-grado pluton 4 bombs, stored on plant sito createn a serious socurity risk and makos thic arca vulnerabl e to).thof t, violence and nuclear terrorism. These acts of nuclear terrorica could triggor an accident of catastrophic porportions roloasing oxcessivo amounto of radiation, with resul-tant dostructivoc, effects.to the public and'the onvironment.

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6 .i Dre. John Gofman and Arthur Tamplin, world renown nuclear phyciciat and medical physi-cisto, both formerly connected with. the Atomic Enorgy Commission, in their many years of

.research of effects.of low levol radiation.indicato that there is no known " cafe n level of radiation. Also confirming their rosearch aroratudios by distinguished scientistic in thiu ~

country.,and, abroad. .recently rovcaled in spite of. attempted supprascion by certain gevorn- '

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, ,~n mhn agencico. Thace studios indicate that g rorement otandards for cafe invcle of rad.1a-tion aro flawed and erronecue. Drs. Karl 2. .:;rgan, former director of health phycico at I tho Oak Ridge, Tenn. Nuclear Facility for 30 years, Irwin Broos, Director of Bloctatistics, Roswell Park Cancer Inutitute, Thomas F. Mancuso Unircrcity of Pittsburg, ronearch acientict under EFDA grant, Alice Stewart, internatlocal]y regarded epidemiologist, Birmingham Univ. ,

Englandand her acaeciato, George Kncale, bloctatistician, are just scmo of tho scientiste whoce research data reficct: that levele of radiation enposuro that have been c:n aldered safe by the government are actually dangercus. These so-called government standarda have caused cancer and the implications are far rnaching in effecting not only nuclear workers but the populu tl e n- a t-la rgo. Dr. Mancunoban stated. "...the risk fcr tbc industrial pcyalution is 10 times c cater than wao cotimated beforo. Therefore, the standarda chould bo roduced by 10 tirou, accome 10 timou morn striegent, and consequently, the general population which is expened to a fractien of what the industrial population is, will havo to be reduced accord-ingly." Conctruction permit should be denica until non-government, independent investicatore study and reviso radiation limits for atomic workers and tho general public.

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6. The po71bation-at-large should not be lumped into one stereotypical individual, with equal succeptibility to radiation. Badiation Las a cumulative facter. Particular health, disease, ago, pregnancies, genetica are just scmo of the factora effecting individualo' susceptibility to radiation. It is already medically known that the young, who make up the nijerity of the population, and pregnant wcmen are prodiapocod to radiation. Our family is alco one with high eusceptibility to radiation.

Madeline Ense Framoon hac pornicicus anemia, ccmpleto deficiency of hydrochloric acid and sericuo hypothyroidist. Ecr pbycicianc aro Chiefs of their Departmente, in recearch and tonehing, at the Baylor College of Medicino, Housto m Tczas. Thece physicians, ac well ao medical journals and textbccko indicate that these medical conditions make Mrs. Fra en one vf the highest cancer-prone riuka. Theco doctors havo advised Mrs. Framcon that if cancer occurred it would be "onvirocmontally triggered".

Robert S, Fra= son has cerious colon and prostrato conditionc and is also cencidered a high cancer-pronc patient. Both Mr. and Mrs. Framcon will havo to be examined periodically for the rest of their lives for cancer - several timeo a year.

My family's interest is not protected with the propoced Allena Crcok Plant and ito environ- l mental impact and I fool we roprosent the vast numborn in the general population wi th varicue medical problema, conditions and agon that aro highly susceptible to radiation. To licence this plant is to state that a largo segment cf the population is expendable. Conctruction po rmi t should be denied. /

7 The building of Allons Creek Muclear Plant will not only incrcace the danger to health and safety, bit will also cause decreased civil liberties. This is becauco of the extensive protective categuards required to protect againut sabotage and terrorism. Supposo sc=eone reported that a portable rocket capable of broaching the containment was in the area of the plant, do you suppoco that the police would wait to get a search warrant before conducting house to house scarchen at all homen closo enough to hit the containment with the reckot.

The Earten Report of Oct. 31. 1975 wao prepared under contract of the FRC, and it gives a ,

detailed discussion of the probicm. The EIS has not considered thio environmental impact '

and so is incomplote.

8 The safety analysis has fallad to concider the danger from inculator failurcs in con-tain=ent cloctrical ponctrationc. During October and November 1977, the Milletone plant had several failures due to the epoxy insulator intrucion into cabic aplices tha t led to ,

high recistance heating that caused shcrt circuits between conductors that wore to have -!

been isolated. At Allcas Creek, this can cause electrically operated valvos to be in the '

I incorrect position (an open when supposed to be clooed), and failure of alarma to operata ,

proporly which can endanger the public health and welfare.  ;

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.% , 3 9 The EIs and safety Evaluation of Allonc 01 ek is def ective becauco they uced tha 4 ASH 1k00 Roactor Safety Study reevlte ao the ba:i; of expoeted :afety as the plant. 'lo t .

several recent studtcu have all indicated that the report in wrong in its calculation of the probabilitics of variouu accidents at tha plant. It faliled to account for the intor-action of various failurs mechanismo that are not independent cvonta ao assumed. It failed to account for the mistakec and feara aC ordicary human beinga that oporato planta euch ac Allone Creek. The report did not considor that a worker might use a candle to cet thu Brownc Ferry fire that almoot cauced two core melts. It claimed that no spaceman x)uld burn up on the ground while sitting in the space ahip, yet 4 cen have aircady done 30.

Until the data is convincing to the incurance industry cuch that they will insure all Icesea then the Allona Crack plant should not bo built.

10. The procent plan for decommissioning A11cno Creek to inadoquate becaucn it does not incuro that tho applicant will be able to properly deconmission the plant or pay for it if some way was available to do it catoly. Beforo building the plant acd sponding ovnr one .

billion dollars in construction costs, the applicant should post bonds hold in eacrow to J incure that the mency will bn available to properly decommiacion the plant. 3ath the CAO and tho Congraca have recently icaued reports cn this problem.

11. About 31 million acros of U.G. farmlands have disappearod in the lact decado, accord-ing to EPA. That's an area half the cito of the S' tate cf Wyoming. The diminiching cupply of food for our nations with its rapid growing population has corious implications for its econcey, etability and coeurity. In a world-vide contort, it's a peaco/wur factor. The EPA intends to limit thic adveran impact. The Allens Crook Plant abould not be cocatructed as it is obricucly contributing an advorce impact in dcatroying over 5000 acree of rich food-producing farmland, a dimininhing natural resourco.

12. A Inrgo number of cuvironmental and aafoty probless are acuociated sith the 2WR, Mark III co ntainment, Emergency Coro Cooling System, automatic Protection systema, etc. to be used in the Allonc Crook Plant, but I cuct stop ccw to get thin photocopied and mailod beforn deadline, although I hava ctudied and prepared almost full timo for t.ho 5 days cinco being told that contentions would have to be submitted by Nov. 2nd. I again wi ch to regiator my objections to tho arbitrary unfair acccleration of schedule not giving petitionera adequato time for proper preparation of contentions. If I am given sufficient time an allowed by my conctLtutional right of "real" due procosa, I vill submit more contentions and elaborato more on the above.

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4822 Waynesboro Drivo Houston,1. cas 77035 8

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