ML18031A258
| ML18031A258 | |
| Person / Time | |
|---|---|
| Site: | Susquehanna  |
| Issue date: | 08/20/1979 |
| From: | Heiss R PENNSYLVANIA, COMMONWEALTH OF |
| To: | Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 7909110482 | |
| Download: ML18031A258 (7) | |
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V REl"ULATQRY INFORMATION DISTRIBUTION S TEM <RIDS)
CCESSION NBR: 7909110482 DOC. DATE: 79/08/20 NOTARIZED:
NO FACIL: 50-387 Susquehanna Steam Electric Stations Unit ii Pennsglva 50-388 Susquehanna Steam Electric Stationi Unit 2i Pennsglva AUTH. NAME AUTHOR AFFILIATION HEISSi R. A.
Penn sg lvani ai State of RECIP. NAME RECIPIENT AFFILIATION Division of Site Safety 8c Environmental Analysis
SUBJECT:
Forwards evaluation of draft EIS re nuclear accidenti spent fuel storagei water qualitgi radiation releases 5 fish population.
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Commonwealth of Pennsylvania CEeer~4~
P.O. BOX 1323 HARRISBURG, PA. 17120 (717) 7874046 783-3133 GOVERNOR'S OFFICE OFFICE OF THE BUDGET August 20, l979
- Director, Division of Site Safety and Environmental Analysis U.S. Nuclear Regulatory Commission Washington, D.C.
20555
Dear Sir:
Qlyy@
yp The Pennsylvania State Clearinghouse has receive'd from your,office copies of the Draft Environmental Impact Statement related to the operation of Susquehanna Electric Station Units l and 2.
These copies have been transmitted for various State agencies for their review and comment.
Attached please find the comments of our Department of Environmental Resources relative to the above EIS.
Please consider these comments the official response of the State Clearinghouse.
Additional comments received from State agencies will be transmitted to your office for response and inclusion in the Final EIS as appropriate.
Thank you for your cooperation.
Richard A. Heiss, Supervisor
( L Vggg 1>D +'g2.A
v'A 601 12-67 COMMONWEALTHOF PENNSYLVANIA August 20, 1979
SUBJECT:
5-79-07-003 Draft ES Susquehanna Steam Electric Station Units 1 6 2 Operating Licenses TO:
Richard Heiss, Supervisor Pennsylvania State Clearinghouse FROM:
CLIFFORD L. JONES Secretary Depart@ant of Enviro Resources The Department feels the Draft Environmental Statement (ES) for the Susquehanna Steam Electric Station should include a more detailed discussion of several important concerns, especially in light of the recent accident at Three Mile Island:
- 1) the environmental consequences of a Class 9 nuclear accident,
- 2) contingencies for long-term storage of spent fuel,
- 3) routine radiation releases,
- 4) certain water quality
- aspects, and 5) impacts on fish populations.
(1)
Nuclear Accident Section 6.2 Table 6.2 lists the radiological consequences of all postulated accidents.
Since the consequences of the Three Mile Island (TMI) accident were greater than those listed and since the sequence of failures were more severe than analyzed as a design basis accident, it. could be considered as a Class 9 accident.
Therefore, this type of senario deserves more attention than a footnote in Table 6.2.
A suIImary discussion of lessons learned frcm the 'lMI accident which are applicable to this plant, should be included in the Final Environmental Statement (Operating Permit),
with a more detailed discussion in the staff safety evaluation.
Table 5.1 Section 5.3.6 states that, the preoperational rmnitoring program delineated in Table 5.1 willbe continued during the operational period.
Based on expmience gained as a result, of the Three Mile Island accident, the number of direct radiation monitors (TLD's) would be totally inadequate for accident considera-tions.
The Draft. ES should also evaluate the role and capability of state and local emergency managEEIent agencies in limiting the environmental health impacts of accidental radiation releases.
(2) t Fuel'Stora e
Section 4.5.5 Radioactive Wastes This section should be expanded to include contingencies for the long-term storage of spent fuel on site.
This may be required if a decision has not been made on the final disposition of spent, fuel after the plant has been operating for a few years.
(3)
Radiation Releases Section 4.5.2 Direct Radiation The direct radiation dose of 2.7 mrad/yr calculated by the applicant could be lmr by about an order of magnitude based on a more sophisticated type of analysis.
If this is indeed the case, the site could exceed a liberal inter-pretation of 40 CFR 190. It would appeax'hat these various reels could be confixmed or refined by measurements taken near several of the operating boiling water reactors (BWR's).
Table 4.5 It appears fram this table of expected annual releases that about 18% of the Xe-133, 23% of the I-131 and about 5% of the Cs-137 is released thxough operation of the gland seal and mechanical vacuum pump.
Since this is an untreated and unfiltered pathway, the routing of this effluent thxough the off gas treataent
- system, a seemingly simple design change, would significantly reduce the yearly routine station effluent.
In addition, it has been the eqperience of other boiling water reactors in the Ccaaunwealth having similar system arrangements, that the instantaneous technical specification limits have been exceeded by operating the mechanical vacuum pump following cert~ types of plant shutdowns.
Section 3.1 and 3.2.3 Section 3.1 states that the applicant has modified the liquid, gaseous and solid radwaste treatment systems.
Since these systems were described in some detail in the Final Environ-rrental Statement (Construction Permit), the major design changes and their impacts should be described in more detail in this document.
This is especially true of the gaseous radwaste treatment system which has changed frcm a cryogenic distillation system to one utilizing charcoal delay beds.
N) ~a The Draft. ES is somewhat outdated with respect to the National Pollution Discharge Elimination System (NPDES) permit issued by P~lvania on July 31, 1979, the National Interim Drinking Water Standards for Specific Radionuclides and Recamtended Water Quality
'tandards (Chapter
- 93) of the Pennsylvania Department of Environnental Resources.
(Attached are the latest recmmended standards which are
~ted to be adopted by the Environmental Quality Board on August 21, 1979).
The NPDES Pexmit issued by Pennsylvania limited iron to a maximum of 7 mg/1 and an average of 4.6 ng/1.'he Draft ES on page 4-5 at table 4.2 is not consistent with this pexmit requirement regarding the discharge.
The calculated radionuclide releases in liquid effluents is discussed in texms of dose nmnitments (pages 4-14, 4-15).
The Department believes that the impact of radionuclide releases and resulting river quality concentrations should be caapared to the National Drinking Water Standards.
The sulfate concentration in the river would be increased by apprcocimately 10% to a value of 244 mg/1 as a maxim'hich approaches the water quality standard of 250 mg/1.
The Department would encourage that sulfuric acid be utilized such that the Saturation Index is a positive valueg insofar as possible, to minimize sulfates in the discharge.
The Department feels that additional studies are needed on entrainment and impingent relative to water intakes and that mitigative steps identified by the studies be followed.
The report indicates that turbulance caused by the jetted water fran the discharge will scour the riverbed inaediately downstream and that there may be sme loss of spawning habitat.
The Department believes that the effect of the discharge on macroinvertebrate should be evaluated.
Attachment
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