ML19270F605

Motion for Admission of Two Contentions Previously Withdrawn Due to Rasmussen Rept Re Reactor Bursting Accidents & Meltdown.Submits Class 9 Accidents to Be Considered.Mailing List Encl

ML19270F605
Person / Time
Site:	Allens Creek File:Houston Lighting and Power Company icon.png
Issue date:	02/02/1979
From:	Jeffrey Scott TEXAS PUBLIC INTEREST RESEARCH GROUP
To:
References
NUDOCS 7902220198
Download: ML19270F605 (4)

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NRC PUELA MINT ROOM U.S NUCLEAR REGULATORY COMMISSION m (Before the Atomic Safety & Licensing Board g In the matter of:

HOUSTON LIGHTING & POWER

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g[c7 p h COMPANY (Allens Creek Nuclear ) DOCKET No. 50-46'd @ p"F, #

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Generating Station, Unit 1)

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TEXPIRG motion for admission of two contentions previously abandoned due to Class 9 Accident Prohibition based on Ras-mussen Report (RSS).

TEXPIRC, petitioners in the above captioned proceedings moves that the contentions listed below, formerly filed and removed as

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a re'sult of discussion with Staff in September 1978, be consid-ered by the board because the information supplied by the Staff has lost approval from the Nuclear Regulatory Commission. The motions are:

1. A breach of the pressure vessal could endarger a substantial portion of the Houston area population by producing a catastrophic accident. A nozzle break between the reactor vesscl wall and bio-logical shield could cause an instantaneous pressure wave and severe damage to the plant. Breach of the pressure vessal re-sulting in a class 9 accident should be considered at the con-struction license hearing because the recent withdrawal of approval of Wash-1400,means there is no current basis to de-scribe such accidents as too remote.

M 2. Electrical wiring for Allens Creek Nuclear Generating Sta-CD C tion (ACNGS) is susceptible to fast flaming, and resulting common mode failures in the event of an internal flash fire. Such a N circumstance is within the range of reasonably anticipated indus-h trial accidents, and would risk the possibility of catastrophic

'" O Class 9 accidents, such as breach of the reactor vessal due to c4 either meltdown of the fuel or overpressurization of the reactor vessal. Such accidents caused by destruction of wiring to relief valves, in-reactor pressure sensors, in-reactor temperature sensors, emergency core cooling system activation systems, control rod acti-Q uneinn sv s tcra= (insertion control systems) and other safety systems >

should be considered in the construction license hearing to assure maximum safety for the citizens of Texas. In addition, a recent report of Sandia Laboratories sent by the NRC to petitioners in, fall of 1978, indicates these flasa fires are still possible' inspite of intense effort in the wake of the frightening Browns Ferry fire of 1975, to find a way to pre-vent such accidents in the future by making cables and cable trays fire proof. The withdrawal o f approval of Wash-1400 has shaken confidence in the belief that the consideration of Class 9 accidents is unneessary because they are too reone.

So, petitioners urge that consideration of Class 9 accidents initiated by flash fires in cables which de-activate safety systems be included in the construction license hearing.

Petitioners further urge th;t as many of the systems listed as possible be activated through spatially independant cable systems so that the reactor can be safely halted with the risky situation which was heroically salvaged at the Browns Ferry fire of 1975.

TEXPIRG offers its reasons for believing it is in the public interest that these contentions be considered, below:

At the end of September, 1978, staff journeyed to Houston t discuss with petitioners contentions raised for construction license hearings on ACNGS. There were no transcriptions of the conversations. At that time, staff counsel Schinki informed petitioners Class 9 accidents did not have to be considered by ASLAB because they were "too remote". Staff stated that the Rasmussen Report (WASH-1400, " Reactor Safety Study")

had indicated there was so little liklihood of reactor bursting accidents or meltdown resulting in catastrophic in]ury to health-and property that they did not have to be considered. Petitioners deferred to the Staff and withdrew the two contentions (they were

1. 31 and #29 in ." Contentions Supplen.enting a Petitioner for Leave to Intervene Filed by Texas Pirg, Inc.," 6/29/78) largely on the Rasmussen Report evidence presented by Staff. Although the present contention #2 on this petition is greatly reworded from #29, it is reworded, to reflect the progress the Staf f-Petitioner conference had: Petitioners sought to contend a Class #9 accident in the orig-inal contention.

r-The Wash-1400 had its approval withdrawn by the NRC in Jan-uary 1979. Petitioner contends they have filed this motion in a timely manner, as there was no indication available to them that approval would be withdrawn by the Commission. Withdrawal

' was largely stimulated by release of NUkEG/CR-0400 (the " Lewis Report") which was published in September and kindly mailed by Staff to Petitioners in December.

WASH-1400 could hardly have been more completely criticized by the " Lewis Report" without charges of slander. But, specifically to the two contention Petitioners have listed, we urge the board's attention to one finding, (Pg. viii of the NUREG/CR-0400) rele-vant to the admission for consideration of the two contentions involving Class 9 accidents stated above:

We are unable to determine whether the absolute prob-abilities of accident sequences in WASH-1400 are high or low, but we believe that the error bounds on those estimates are, in general greatly understated. This is true in part becaus ~,h::: is in many cases an in-adequate data base, in part because of an inability to quantify common cause failures and in part because of some questionable methodological and statistical procedures.

In addition, we point out that the withdrawal of the WASH-1400 is new information on the accident possiblities listed here and this qualifys the two contentions past the "new evidence" rule and makes them clizible for consideration in the constguction license hearings.

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James Scott y'

. A' tty for TEXPIRG re .em,e

EE g (713) 749 3130 Texas Public Interest Research Group Box 237 U.C. University of Houston H ouston, Tx. 77004 TEXPIRG has mailed copies of this motion to the persons listed below at the address stated. _

Sheldon J. Wolfe, Esq., Chairman Chase R. Stephens Atomic Safety and Licensing Docketing and Service Section f Board Panel U.S. Nuclea.- Regulatory U. S. Nuclear Regulatory Commission Commission \

Washington, D. C. 20555 Washington, D.C. 20555 Dr. E. Leonard Cheatum Richard Lowerre, Esq.

Route 3, Box 350A Assistant Attorney General Watkinsville, Georgia 30677 for the State of Texas P. O. Box 12548 Mr. Glenn O. Bright Capitol Station Atomic Safe'" and Licensing Austin, Texas 78711 Board Pan;l U. S. Nuclear Regulatory Commission Washington, D. C. 20555 R. Gordon Gooch, Esq.

Baker & Botts 1701 Pennsylvania Avenue, N. W.

Washington, D. C. 20006 Mr. Steve Schinki Staff Counsel i U. S. Nuclear' Regulatory Commission Washington, D. C. '""-~

This motion was mailed from Houston, Texas, February 2,1979.

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