ML20204C920

Petitioners'Contentions Re Nuc Fuel Cycle,Site Storage of Radioactive Waste,Nuc Terrorism,Adverse Impact on Farmland, & BWR Pipe Cracks.Petitioners Also Raise Objections to Deterrents Places Upon Them During Special Prehearing

ML20204C920
Person / Time
Site:	Allens Creek File:Houston Lighting and Power Company icon.png
Issue date:	11/27/1978
From:	Framson M, Framson R AFFILIATION NOT ASSIGNED
To:
References
NUDOCS 7812050291
Download: ML20204C920 (3)

Text

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U. S. NTLEAR NJLATORi COMMIC3ICN B3FOR THE ATOMIC SMTY AND LICENSING BCARD i In<* "CUSTON LIGHTING AND POWER C0FfANY Docket No. 50- 4 6

} ( Crook k r Generating Stat 1NWP8]EM DOCUMENT ROOM

.nnr in he Applicant and NRC Staff grouped responses together of 11 petitionero'  :

en ds id e o of Appliennt's nnd NRC Stnff's unspecificity and vogueness. In many tancas $ t i ionn vero inappropriately grouped with a resumption of similarity, ti $ cry h t gister their vigorous objections to the unnecessary, arbitrary and unjust c .loadehd det nte deliborately burdened upon petitioners by the USNRC's capricious conduct i pr the i urchenring and during the special prehearing in countless ways - doreliction in p ,- r . orientation for petitioners to pr iont valid contentions, imposing unreasonabic and imposololo limitations of timo to present adequa,ely-proparedente ntions by correspondenco, further compounding this problem for petitioners by arbitrarily expecting petitioners' rebuttals immidiately following receipt of the NRC Staff's response to contentionc at the time of tho sp]cial preheering, iuposing on petitionero a location for preparation of rebuttals - a rostrict ed location without accoscibility to documents, data, referenco materials, without typewritors, p por, etc. , in an environmert absolutely not cc iducive to thought, research and concentration.

Pctitioners wish to object to the fact they have never received copios of the contentions of the e:rlier peti tioncre, such as TEXpirg and John Doherty. ObJoctions are hereby registered to Applicant's Motion for Ord9r of Schedule. This schedule in an acce/loration in a timo frame that vill negate intervenors' adequate time for proper preparation for prnoontation. It is hoped that tbs NRC will not follow ito previous pattern in enco more placing this arbitrary obatacle before intsrvonorn and will givo serious weight for a more reasonable time schedule.

P;titione maintain that all contentions are based on new information and should be part of the full hearing.

2. Some of the background material on this contention is based on " Growth Options", Rice Conter for Community Design, May,197C, under the aegic of Charles Sevino, " Population Land-Uco Draft for Greater Mcucton, 208 Area, Houston-Galveston Arca Council (HOAC), Dorio Ebner, April 1,1976, "Popula tion Laod-Ure for Greater Hounten, 205 Area", HGAC, Doris Ebner, April 1.1977 and Houston Chamber of Ccmmerco Houston Area Popalation Report, Tebruary, 1976,1977, anc 1978.

2.-3 These contentions regarding the nuciocr fuel cycle, transport of radioactivo materials to th? plant and nuclear wastes from the plant impose a scricus environmsntal impact on our family, our residence is located leso than 30 miles from the plant and Robert Framson's business requires his frequent travel in Harris, Fort Bond, Wharton, Austin, Brazoria, Colorado and Waller Countice.

and our residenco is located a close proximity to major thoroughfares, freeways, 610 Loop and less than i. t mile frcm a main railroad line. Many accidents have occurred in our country during th) traneport of radioactive materials - to cite just two - one on September 15, 1978 in Panney.1-vanin and another in early Septembor,1978 vi *h a truck destined for Barnwell, S. Carolina. Con-tnincra carrying radioactive me.torialo ruptured during the accidenta and it i s obvious radiation cmitted during accidents will exccod limits of r'gulations.

11 This contention rei-arding on site storage of radioactive wasten, the crite-ia for the interim stornge in nct adoquately covered in tw Final Supplement to the EIS. " Nuclear Wante", MacNeil/

LArst Report DOE Aost. Sec'y. Jchn O'Legen St. Erdph Lapp, Dr. Peter Montague, July 27, 1978, c'Jozments of the State of Texas On the Draft IIS Conecrning Manngement of Coc.morcial High Level and Trnneuraniu=-contaminated Radioactive Waste", Nove nber,1974, "Improvemento nooded in the land dioposal of radioactive wastes - a problem of centurics, GAO,1976. Not only are the en-vironmental, enfoty and health factors issues germano to the steady increment of on cito storage of r;dioactivo Gasten, but this has a serious economf.u 'mpact in that the plant could prematurely hav3 to curtail operation and shut down altogether i 2 u.'er to cease the generation of wastes.

781205029I 5.-7. Thege, contenti6ns regarding nuclear terrorism tith the resultant threat to civil liberties beenuce of stringent protectivo safeguards is based on many documents including NRC contracted

" Int:nsified Nuclear Safeguards and Civil Libertion", John H. Ihrton, late 1975, statement by Truca L. Welch. THD, before the Joint Committee on Atcmic Energy, U.S. Congress ,197h, " Nuclear Sierra C.

P;w:r Bu110 Flanto Vu]ncrab1c tin, Dec.1975, to takoover

" Nuclear by Armod Sabotage", Individuals Bull. Atomic Scientistc. CAO,197h, " Nuclear"Securit Oct.1976, Terror"'y at Nuc1cne power P1nnts: nt bnct, Inndequato", GAO,19 77

6. This. contention relates to the somatic and ,,onctic effects of low level radiation. As ths Ap'pli cante 's re sponce staten, " low lovel radiation have ~been subjects of continuing research and investigation over the past 25 years or moro" the hictory of government radiation standards, in spi te of the fact that scientists and medien1 physicists have taken icouo, have always been indicated by hindsight in cycr 25 years that the radiation expocure allowed vac always too high!

Countless times in tiiis timo frame, the government has had to revise itc safe radiation standards downward af ter obvious "bodycounts" - thus, tronting at.mic workers and the population-ot ':.arge as human guinea pigs, conoidering many segments of the population, dopending on their jobs, ages, somatic conditions, etc. oxpendablo! At the prosent time the Texao Dept. of Health, Division of Occupational Health and Radiation Control in in the proceso of revising its regulations with the

" Proposed Amendments to the Texas Rogulations for Control 7f Radiction, Parts 32 and 36", Draf t January , 19 78. Some references on this contentinn include " Health Physics", Dr. Thomas Mancuso, Oct.19 77, Dr. I rwi n Broes ' Study revievad in Journal of AMA , May, 1977, eseta-dose to Critical Human Tumor riten from Krypton E5", Henith Physics, Dec. 1977, "Panger: Radiation",MacUcil/Leh-ror Roport, with Dr. Irwin Brose and Dr. Karl Morgan, " Nuclear Cancer: It's Top Secret", Jack Anderson, Doc.1977, Good Morning America, with Dr. Thoma n Manruco, Enrch,1978. On November 10, 1976, Environmental Protection Agency Stephen J. Gage indicated that a study that began in 1975 by EPA and the Colorado Medien1 School showed that quantition of plutonium have been discovered in personn living near a nuc1 car facility.

8. This contention relates to the safety analysis failure to consider tho danger from insulator failures i n containment electrical penetrations. The failures that occurred in October and November 1977 nt the M111ctcne Plant wac with Unit 2. Similar to the M111stono Plant, Unit 2, ACNGS has wiring paccing through its containment and thic dqfective wiring can enure electrical failuro during the oper, tion of the plant.

9 This contention s e baced on NUREG/CR-0400, " Risk Assessment Review Grcup Report to USNRC" pre pared by Harold Lewis, et al, Sept.1978. The BWR control rod controverey concerns a " square root bounding model" adopted by NRC for the calculation of low and high common cause failure prob abilities. The model unco a number of compounded. cubjective judgments (log-normal distribution c failuren, nymmetry in the placement of upper and lower bounds, etc. ). 2 th an end-recult that is comehow conuidored firm. "The degree of arbitrariness in this procecure',' comments the risk group in hardly representative language, "begglen the mind." ( A normal distribution of failurco would increane rioka by n factor of 1,000. For BWR contrcl rod ftilure, thic factor is hardly insigni-ficant. It is at the basin of the long-running controversy about the probability of an accident where tho' scram or chutdown cyctum failo (anticipated transient without scram). )

10. This centention is baced on " Nuclear Fuel Cycle", Un. of Concerned Scientisto,1975 EEAP received only one-third of a requested rato increase from the PUC of Texas on Nov. 20, 1978. A Michigan Power comoany af ter costly invcotment into nuclear generation suffered serious fiscal inntatility idth locnes to the extent that the stockholders of this company for a prolonged perio roccived no dividende. The Euclent Fuel Service Co, West Va llCT, New York, is finannially unabb to abeorb decommissioning costa to the nuclcar fac ility. As a Recult, the Tarpayern of N.Y. will now have to carry the unjuct burden o f this exorbitant expence for deccmmi urioning. It is pro-curpt! un end highly npeculative that HL&P will maintain a financial etability to enduro the mon-umental costs of dectnmicciening. For this roanon appliennt should post bond held in eccrow to insure the money will be available for proper decommintiening. Another reference: "How A Nuclear Pownr Plant Dies", Natural Resources Defence Council,1978.

11. Thin contention concerno the adverco impact of ACNGS on rich food-producing farmland. The 31 million acree of U.S. Farmlands have disappeared in the Lost decade, resulting in the diminich ing supply of food for our nation with its rapid growing population hac cerious economic implica-tions, as well as a growing threat to our nntion's stabili ty nnd security. This i n cuch a seriou problem that EPA Adminintrator Douglao Cootle has recently formulated an "Acricultural Lands Pro-tection Policy", to limi t thic adverre impact. ACNGC will doctroy 5000 acres of rich food-produc ing farmlnnd.

12. This contention concerto the cencric problem of EWR pipe crackn. Some of the background documente nro CBE-7875 " General Electric Reactor Pipe Cracks" and NEC "Technten1 Report: Investi-gntion and Evaluation of Cracking in Auctenitic Stoel Piping of BWR Plants (NUREG-75/067) late 1975 On June 17, 1978, Dvne Arno1;i Pinnt nunorn "worct us Renctor neci aent yot" necording

to N .1 "- ' '

. C! ti :' 'm 'Sr r- P ' t ' a r '9v.1 rc r.rre :.t . A 1 irr" l'r i nch !! ste t ": rrl: Miry cooling r y t t ' - ' t i te il e t .ve " 'I ro cLc'l I'I') & green n'- ml 1** cire'.crcr r.c' nt th Duano Arre>1d BVR.

Th5c r' t; r: . tel e r. v r" 20 t"r ! "c t r. C; tobe r, '

' g; , t r' 3;>rm.nc" nt that time urging prorpt rein ir + r r"<Ircted. Tr i: :: n vricuc problem .!th 91: c i p l J n rl:, d ""t @"4 'WR' n. IG C i r.di en t e -

that a "ro pi r t e circ.,f o rar.t 'l br".tk of cne c f the r" circ.41ation Icap piim

• s'a tild result in th-vorst 2 0*r-cf..cocinr:t" nccidant pas.cibic at a bolling vnter reactor". " & ther euch cracking will be detectable prict to n 360 degree circumferential break of a reeltculation pipe at the i rnfennd in a tr.atter of concerr.", notes CEE. Conotruction permit thcu3d be d.'nied until the now3y l reforrod Tirr Crrck Study Greun ca rea out wi th itr. findingc, 1

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