Dear Mayor Castro and San Antonio City Council Members,
I thought the following information regarding the status of interventions in the South Texas Project licensing process might be helpful to you as you make decisions regarding the future energy path for San Antonio.
Our legal case is strong. We already have five accepted contentions, and may have more coming. We don’t know of any other proposed reactor in the country that has more than two accepted contentions. The many serious health and safety issues must be resolved before an NRC construction and operating license (COL) can be issued.
The five contentions were accepted by the Atomic Safety and Licensing Board Panel, through the NRC. Hearings will be held after the NRC finalizes the Environmental Impact Statement, and are expected in 2011. The accepted contentions are listed below. They include the co-location impacts, such as how an accident at one unit would impact the others. The other four contentions are water related, involving radionuclides in the Main Cooling Reservoir, increasing groundwater tritium concentrations, seepage of the Main Cooling Reservoir and excess withdrawal of groundwater.
Additional contentions could still be accepted from among the 7 Fires and Explosions/ Aircraft impact contentions that were discussed on Nov. 13th in Rockville, Maryland.
If you would like to read the full original contentions they are posted at http://www.nukefreetexas.org/downloads/petition_to_intervene_STP.pdf
Also attached are our original fires and explosions contention and the NEI guidance on aircraft impact. These are materials available to the public, and we hope that much of the information that was part of this hearing will also be made public, as whole documents have been classified as sensitive based on a single word or sentence. Small portions could be redacted, and this important safety information could be made publicly available. We have submitted a filing to address this already, and will continue to push for public disclosure of any non-sensitive information. We believe the public has a right to know.
Thank you for your attention to this important energy decision.
Karen Hadden, SEED Coalition
If you have questions, please feel free to contact our attorney, Robert V. Eye, at 757-234-4040.
Summary of Texas’ Nuclear Interventions
Texas is Ground Zero in the fight against a new generation of nuclear reactors. We’ve gained Intervenor status in the cases against Comanche Peak and South Texas Project reactors and all of the contentions we have been granted will set national precedent.
Oral arguments were held on Nov. 12-13 for Comanche Peak and South Texas Project on the admissibility of new contentions regarding new NRC fires and explosions rules.
South Texas Project Intervention
5 Admitted Contentions (Hearing to be held after NRC issues final EIS, expected in Spring 2011)
1. Impacts from severe radiological accident scenarios on the operation of other units at the STP site have not been considered in the Environmental Report.
2.The Environmental Report fails to analyze the environmental impacts associated with the increase in radionuclide concentration in the MCR due to operation of STP 3 & 4.
3.The Environmental Report fails to predict or evaluate the effects of increasing groundwater tritium concentrations.
4.The Environmental Report fails to analyze the environmental impacts of unregulated seepage from the MCR into the adjacent shallow groundwater.
5.The Environmental Report fails to consider adequately the environmental impact of the possible withdrawal of additional groundwater in excess of that authorized by the current permits.
7 New Fires and Explosions Contentions Pending – Admissibility argued in Rockville, MD on Nov. 13
NRC recognizes in its new rules that nuclear plants are vulnerable to air attacks. On August 14th the Intervenors filed seven contentions regarding STP's failure to comply with the new NRC fire safety rule which says each licensee must “develop and implement guidance and strategies intended to maintain or restore core cooling, containment, and spent fuel pool cooling capabilities under the circumstances associated with loss of large areas of the plant due to explosions or fire,” including those that would occur from the impact of a large commercial airliner. However, the Intervenors’ contentions that STP has failed to meet the fire and explosion regulatory requirements, STP’s submittal, and related documents are considered “sensitive” by the NRC and are not available to the public.