ML18026A362

Forwards Comments on Suppl to Des Re Plant Operation.Second Draft Should Be Published to Incorporate All Previous Comments

ML18026A362
Person / Time
Site:	Susquehanna
Issue date:	05/23/1981
From:	Molesevich M SUSQUEHANNA ALLIANCE, LEWISBURG, PA
To:	Office of Nuclear Reactor Regulation
References
NUDOCS 8105290236
Download: ML18026A362 (9)

Text

Susauehanna Alliance P 0 3ox 249 Lewisburg, 9>> 176'37 day 2'5, 1981 0ffice of Nuclear reactor Regu2.ation U.S. Nuclear regulatory Com=- ission

'Fashion"ton, U.C. 20555 Director, Qivision of'icensing Sir/~=-dam:

Pe a e

~v~Z enclosing our comments

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ave~ation Doc Since so much time has e assed from the date of the original ~ra t

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et ':..ushers it would be in the highest public interest to issue a 2nd. full corporatizg all previous comments and hRC responses.

"'his 2nd full draft would provide the ~iommission with furthe inform-ation with which to oase its decision regardin'g the environmental impacts of operating the Susquehanna Steam iZectric Station.

Sincerely,

-'ichael ~. Mo3. sev ch for the Susauehanna Q.liance

COSTS etITS ON D.cQ'T SU?Pm';KiNT TO DH='i~T ZZS FOF. TFZ SUSQU"'H~s'PJ'Ti~t'4

"'LZCTRZC ST<TTOitT p HUNG-0564, SU?PL" L~iVT Ã0. 2

1) The purpose of'his supplement was to assess the additional envir-onmental risks due to class nire accid,ents. These acc'dents .reviously have been conside. ed. to have m'nimal environmental effects oecause their pro'oabilities have been thought to be low. However, sine the accid.ent. at Three i'ile Island, the conclusion of this supplement has not changed from the conclusion of the original'Draft, EIS, of June 1979. Supplement: >>These impacts could. be severe, bu. the likelihood of their occu ence is judged to 'oe small.>> Page 6-2 pf the original I)raft states: >>Their consequences could be severe. However, the probability of their occurrence is judged so small tha their e". viron-mertal risk is extremely low.>> Zt is obvious that this supplement d.oes not achieve its purpose. There ore, the Susquehanna Alliuxce requests that another su)plement be made available that ad,equately addresses the additional environmental risks due to class one acc'dents.

2) Tht s suppl ement d.oes not address the long-term, man-made, and. natural surface contamination ~rom radionucleides. Accoraing to one source he delagel cancers and genetic defects due to radiation .from < smd. - .

• and, buiZaz.ngs contamin ted with long-lived r."=dioactive ces um could.

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oe the most severe consequence from a major release. ( J. "-eyea, =~aae to the At-,.osohere from Three Bile Island, Pres-'nt's Wouncx on Env'rona....tal ~unlit,

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September, ~1979

3) To always will receive ssume that downwind recipients of rad'oactive less dosage .han those closer to the pl~~t (source of f llout radionucl ides) is false.(Section 6.1.1.2) The plume does not always disperse more radionucleides closer and less farther away due to cer .ain meteorlogical cond'ions, i.e. ground base inversion. Also, the dos"'-

zeter readi..gs 9 miles northeast of T.'H, near Harr'burg, w=-re higher than wer the read'gs closer to the plant.

4) The supplement elies too much on si eltering and ev cuation me su"es to help mitigate the effects on the local population. this igno es the potential for for the seouences of an accident which c n take in a very short time.(6.1.1.3) Por example, anticipa.ed. irans=entsplace without SCR.~~ which, according to Dr. d'hard 'webb c n breach the reactor vessel within 6 second,s.

5) On page 6<<5, section 6.1.2 the supplement s .a.es, >>This xperience base is not la"ge enough to p rmit a reliable quantitative statis

'fo large-scale-coo ercial reactor has yet gone t'".rough ica'nference.>>

a complete life cycle. Therefore, to state that, "...s"gnificant environmental impacts due to accidents are very u¹kely to occur over time periods of a few decades.", is an inaccurete conclusion.

6) To state that, "...a few million curies of xenon-133,...>> were released. at 'iZZ implies a lesser severi y when he 5;-;C has s. ted.

that at least ~ gj~~~to curies were eleased.

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SUP?Lc'~'.IT COlZiKa TS COliTI lULG

'I 7r The Unit 2 reactor at TLK was very young. The fuel was only in service (fissioning) f'r th ee months. Had an ccident of this severity occured. with an old,er fuel assembly, then the inventory of'ne fission products available for release to the environment would have oeen much greater.

8) There are many assumptions based on the ev nth, data, and esults on the accident at TMI. however, there are =.any uncertainties in the analysis of the accident itsel . Vihile the supplement recogniz s that the numbers used. for population exposures are estimates, not discuss the uncertainties within tnose estimates.(6.1.2) it "Itdoes has been estimated. th t..." Por example, the moni.ors located on the stack vents mere pegged of'f scale, nd. many of the off-site dosi eters were not o ought into se vice until 3 days after the accid,ent vrhen most of'he radionucle d.es had. already esc ped..

.) The psychological impacts of, the population surrounding .h plant for at least a 75-mile rad,ius must also be considered. I is obv'ous that the psychological ef ects of the people sur ound'ng T."m and of central Pennsylvania were profound'and continue today .

10> ihe supplement assumes that the owners of the Susquehanna ?lant wi'1 have cont ol of the water from the river oy restricting its use du ng and a te an accident. (6.1.4.5) .hereby claiming that the consequences would be more economic and. social, and not adiological.

The supplement does not address the use of water from tne river by:

.i e oo ough o oanv lie, the city of Sunbury and. otner downstream communities who withd aw their drinking wa er from ti e river farmers that use water from 'the river for irrigation and. other ag"icultural lated activities (and especia'ly Amish farmers who might not oe awar of an accid.ent miles downstream), industries that are located

.and un 'r on the river that also use its water i.e. Herc'=- Co. 'n Danville, ed, people who may be fishing the river at the time of the accident. xhe supplement should also address the uptak of rad=:onucleides into the aquatic f'ood chain.

ll) The statement hat arrangements have already been made to c"ntrol highway tra fic (6.1.3.2) seem premature since the .emergency Prepared-ness Plans for Susquehanna are in an advanced but not fully co'pleted s.age.

12) The supplem nt recognizes he substant al unce ta-'ntie c lcu"=ted oy the Reactor Safety Study. Eovrever, these uncertainties are not re lected in the tables where firm numbe s a e used,. '~'hese .aoles should use an-es of numbers to reflect .hese uncertainties. Qso the range of accidents do not appear to have been adjusted to reflect the accident at TtG .(6.1.4.7) 13j The calculated, estimated, economic risk per year (p.6-19) reflects an inconsistency in the use of the Reactor Safety Study. In taking the example of an average aecontamination cost of one billion dollars, the supplement assumes We probability of chances of'his occuring in 100,000 reactor years. "'hue yielding an2.4estimated economic cost of

~age

'SU?PL:-"~Sic CQiiG~LHTS COHT1.HJED 24,000 doll s per year. Eowever, on page 6-20, section 6.1.4.7, it is implied that the reactor safety'.udy pr dieted the arobability of a TUI-type accident as greater than on chance in 400 reactor

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le'st Si." e one this accident has an estimated clean-up cost of at bill.ion dollars, then the econcmic risk could. be calculated

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that this f-gure is somewhat la ger than 24,000 dollars.

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14) An obvious shortcomi g of .he accident at TM was that there was no plan of recovery-either with the facility itself or the off-site consequences. .<<t present they a e developing the strategy and p ans for t~e recovery of that accident along with its environmental <<mpact.

iiith the safety of ihe puo'ic in mind, this should have been prepared before the accident had. occurred. Ther fore, a elan of recovery and.

its environmental impact should be included in the analysis of an accident ~

15) The econom' risk associated with protective action and decontam-ination =~a~o- be <cmpart;d ~th the pr".perte damage costs assoc'ated with altern=-iive energy technologies espec ally anth~acite coal.

Anthraai ~ioes not have .the same amount o sulfur compounds th"-t .pQst o.her coals have -"nd would no+ lead to a 'subs art='al amcunt of'cid rain as mould ihe use of bituminaus. Also, the increased use o anthracite ca.. only lead to improved envirorw ntal conditions in thet a a. Since much of the area is lready impacted .hen more mining would alleviate such problems found in that a ea such as:

acid mine drainage, abandoned. mines. and spoils, a distressed, economy, and .he em'nation of under~~ound mine f'es, ope: sha-'xs and pits, and o .her dan"erous conditions. This would be possible because all ne recent min ng w"uld mee. st ingent environmental laws and. guide 'nes hat wer not in ef ect years ago when most af the damag .was done.

~a~e 6-18,(sect. 6.1.4,6) 16> 'i~ay "-re t'. ere no thyroid doses included on table 6.1.4-1?

17) .~ccident seouence or sequence <groups si ould be expressed in terms rather than symbols or " etters. (table 6.1.4-2)

19) ?robability should be expressed as a range in tao' 6.1.4-2.

19) Other tail s-- should include sum totals of'.and/surface accumula-tions o adionucleides based on probability and, economics of decon-ination. ( tabl = 6.1. 4-4)

20) Evacuation item can also be conside ed probabi" istica" ly and the health effects should be more'properly treated using site spec'fic data. Considering the range of'usceptibili.y to the health ef ecis of radiation and other factors would be helpful io place on the figures the background radiat. on and other data from TM. ( figures 6.1.4-1 -2, -5, 5)

21) The conseauences of the accident at HK should. a'o oe included in fi<~~e 6.1.4-6.

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SUPP'.~i ZT COIri"i~~'AS CQiiTXHUE3

22) The maps are of'he poo est auali .y and should be improved. so that they could. 'oe read more clearly. (figures 6.1.4-7 and, 6.~.4-8) 2'5) .~dd a map or maps that would, show the isopleths of costs of mitigation.

24) The speed, of groundwater movement seems to be highly under stim ted,,

especially in the local glacial material, and. epspecially und.er saturated ground, conditions. (6.1.4.5)

25) There should, oe ref'erences sit d of past wor'z or studies that snow effective isolation of radioactive cont min nts i"" g oundwater.

(6.1.4.5) 26> This supplement should. address site-specific conditions and not generic conditions as it seems to have done.

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