ML17297B117

Comments on NUREG-0841,DES for Facilities.Wet Wastes Should Be Defined.Rise in Regional Aquifer Should Be Specified as Harmful or Beneficial

ML17297B117
Person / Time
Site:	Palo Verde
Issue date:	12/16/1981
From:	Jeffrey Mitchell AFFILIATION NOT ASSIGNED
To:	Office of Nuclear Reactor Regulation
References
RTR-NUREG-0841, RTR-NUREG-841 NUDOCS 8112230129
Download: ML17297B117 (6)

Text

ee REGULATORY INFORMATION DISTRIBUTION SY

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AGCESSION NBR:8112230129 DOC ~ DATE: 81/12/16 NOTARI'ZED: NO DOCKET FACIL:STN-50-528 (Palo Verde Nuclear Station< UniIt 1E Arizona Publ i 05000528 STN;50-529 'Palo Ver de Nuclear Station< Unit 2r Ar izona Publ i BYNAME 05000529 "STN 50-530 'Palo Verde Nuclear Station< Unitt 3E Arizona Publi 05000530 AUTH AUTHOR AFF'IL I ATION MITCHELL J. D.

P A f f i i a t i on 'Unknown 1

'RE'C IP ~ NAME RECIPIENT AFF ILIA'TION Di,vision of Licensing

SUBJECT:

Comments on NUREG"0841EDES for facility 'Net wastes should defined, Rise in regional aquifer should be specified as harmful or benefical.

DISTRIBUTION CODE: C002B COPIES ~RECEIVED:LTR ENCL, 4l SIZE:

TITLE: Environ, Comments.

NOTES:Standardi'zed )Plant ~ 1 cy'.C Grimes 05000528 Standardi'zed 'Plant, 1 cy:C Grimes 05000529 Standardized IPlant F 1 cy.C Grimes 05000530 RECIP I ENT ICOP IES RECIPIENT COPIES ID CODE/NAYE LTTR ENCL ID CODE/NAME LTTR ENCL ACTIOY: LIC BR 43 BC 06 ANL KERRIGANP J>> 01 INTERNAL: ELD 1 IE 13 2 NRR/DE/AEAB 20 1 NRR/DE/EEB 16 1 NRR/DE/HGEB 21 1 NRR/DE/SAB 18 1 NRR/DSI/AEB 19 1 TSB 15 1 NRR/DS I/RAB 17 1 REG FI E 04 1 EXTERYAL: ACRS 1 LPDR 03 NATL LAB 21 NRC PDR 02 NSIC 05 1 NTIS a( a lTOTAL NUMBER OF 'COPIES REQUIRED: L>TTR ~ ENCL

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yO ~y P.O. Box 654 811223012 9 P 811216%

~ppp528 Citrus Heights, CA 95610 CO PDR ADOCK PDP December 16, 1981 Q

Director, Division of Licensing gECQPJE9 Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission DEC 82~981~

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Dear Sir:

'a I wish to enter the following comments concerning the D (T~>3 Environmental Statement related to the operation of Palo Ver e Nuclear Generating Station, Units 1,2, and 3, Docket Nos. STN 50-528, STN 50-529, and STN 50-530 (NUREG 0841) for consider-ation in the final environmental statement:

SUMMARY

AND CONCLUSIONS Item 4.k (p iv) Add "Any increase in risk to the population near the site is more than offset by the reduction in risk to the population near the 91st Avenue sewage treatment facility or the Salt.-Gila River system as the on-site water treatment plant will reduce pathogens by chlorination and other treatment processes and the use of sewage effluent will decrease radia-tion exposures due to decay prior to ultimate release to the environment."

i CHAPTER 2 Paragraph 2.1 (p 2-1) Average annual rate of growth of 3.5%

seems low when compared to the population growth of 53.1%

between 1970 and 1980 (4.35% per,year) as noted in paragraph 4.3.7.3. As population is expected to gr'ow, why isn' electrical demand growth consistent, with population? Hasn' growth in electrical demand exceeded 3.5% per year during the last decade? I would think year.

it has been well above 4% per CHAPTER 4 Paragraph 4.2.5 (p 4-4) What are "wet" wastes? Specify that wastes are solidified. (See FES-CP paragraph 3.5.3.)

Paragraph 4.3.1.2 (p 4-.11) Is the rise in the regional aquifer harmful or beneficial? ~ Please clarify.

radioactivity levels of 4

Paragraph 4.3.2.2 (p 4-12) What are 91st Avenue sewage treatment facility effluent? Wouldn' PVNGS use of effluent result in decreased population doses since hospital and industrial radwaste will decay prior to re-. release at PVNGS? Where is this included in 10 CFR 50 Appendix I evaluation? Can this offset operational transient or steady state 'releases from the plant? As the effluent is being used for crop irrigation by other users, I would think that a reduction in the ingestion pathway could be quite COO4 significant. Does PVNGS operation also lead to reduced contamination of groundwater?

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~y Director, Division of Licensing December 16, 1981 page 2 CHAPTER 5 Paragraph 5.9.1.1.1 (p 5-21) How can occupational doses average as much as value is only 1300?

3 to 4 times 440 person-rems if Isn't 1300 representative of antheoldHinson plant, not a new one designed to tougher standards?

CHAPTER 6 Paragraph 6.1, Item (2) (p 6-1) Modify to require that the NRC conduct cost benefit analyses of monitoring programs and determine conclusively that the benefit to be gained from monitoring exceeds the cost to the owners or their ratepayers.

Paragraph 6.1, Item (3) (p 6-1) Modify to provide a threshold of damage up to which no applicant action is required. Such threshold should be based upon a statistically defensible in-crement above the nominal, or average, impacts upon the regional ecology described in the FES-CP or the FES-OL, whichever may be greater. Prior to NRC or applicant action to restrict operation or increase applicant's obligations, a cost benefit analysis must be conducted to assure that the potential benefit in mitigating damage does not exceed the withdrawal of benefits normally bestowed by the operation of the plant.

Table 6.1 (p 6-2) Why aren't taxes, employment, and payroll benefits of fuel cycle operations included in this table in the same manner in which fuel cycle impacts are included in section 5.10? The DES unfairly attributes a cost without consideration of the benefit.

APPENDIX C Table C-6 (p C-ll) Population doses appear to have been calculated by use of non correlated data. An average annual dispersion factor is multiplied by the gaseous releases, converted to dose, and then multiplied by the total population within 80 kilometers. Doesn't population distribution relative to the predominant wind enter into the equation? The Phoenix wind blows east to west. The population lives to the east.

Out west is barren desert. There should be a correlation of wind frequency to the population sectors.

Please provide me with a copy of the FES so that I may review the manner in which these comments have been addressed.

Sincerely'ours, Janet D. Mitchell

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