ML19224D095
| ML19224D095 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 07/03/1979 |
| From: | Falco P ENVIRONMENTAL PROTECTION AGENCY |
| To: | Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 7907100633 | |
| Download: ML19224D095 (10) | |
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j UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
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215 Fremont Street San Francisco, Ca. 94105 3 JUL 1E Project #IMiPC-K06003-AZ U.S. Nuclear Regulatory Ccrrission Washington, D.C.
20555 Attention: Director, Division of Site Safety arxi Environmental Analysis
Dear Sir:
The Envirormental Protection Agency (EPA) has receival aM reviewd the draft envirormental i:" pact state.ent (DEIS) cn THE PAID VERDE TCLEAR GDIEFATING STATION UNITS 4 and 5.
EPA's ccruents on the DEIS have been classified as Categcry ER-2.
Definitions of the categories are provided in the onclosure. The classifications aM the date of EPA's ccmaents wil be published in the Federal Register in acccrdance with our responsibility to inform the public of cur views en prcpcsed Fcderal actions under Section 309 of the Clean Air Act. Our procedure is to categorize our ccnrents on V
the environmental conseqt.ences of the proposed action and the adeqt..
the environmental statemcat.
The enclosed detailed canaents reflect sericus concerne in tFa area of energency response preparations, reactor operational experience, and availability of cooling water for five reactor units. Given these ccncerns en the need for systeatic procedures for cperational assessments and for acceptable energency response preparations we reccrmend that the Nuclear Regulatory Comission DIFC) sericusly consider withho] ding reactor licensing acticns until these cencerns are nddressed.
'"he EPA arpreciates the ccporturity to ccment en this draf t envircrmental irpact statcment and 2.equests (3) three cccies of t".e fi.al enviremenral irpact statsent when available.
If ycu have any questicns regarding cur ccrrents, please contact Betty Jankus, EIS Cccrdinatcr, at (415) 556-6695.
Sincerely yours,
. SsswL%
Paul De Falco, Jr.
Regional htniristratcr Enclosure h
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EIS CATEGORY CODES Environmental Impact of the Action LO--Lack of Objections EPA has no objection to the proposed action as described in the draft impact statement; or suggests only mit.or changes in the proposed action.
7 ER--Environmental Reserv3tions EPA has reservatior i concerning the envircnmental effects of certain aspects of the prog 1 sed action.
EPA believes that further study of suggested alternatfies or modifications is required and has asked the originating Federal agency to reassess these aspects.
EU--Environmental 1} Unsatisfactory EPA believes thr.t t he proposed action is unsatisfactory because of its potentially hcrmful effect on the environment.
Furthermore, the Agency believes thst the rotential safeguards which mi'ht be utili ed may not adequately protect the environment from hazards arising frou this action.
The Agency recommer ds that alternatives tc the action be analyzed further (including the pos:ibility of no action at all).
Adequacy of the leiact Statement Category 1--Adequate The draft impact st atement adequately sets fortn the environmental impact of the prop < sed project or action as well as alternatives rea-sonably available to the project or action.
Category 2--Inaufficient Information EPA believe= that ite draft impact statement does not contain suf fi-cient information to assess fully the environmental impact of the pro-posed project or action. However, frcm the information submitted, the Ageng is able to nake a preliminary determination of the impact on the environment SPA has requested that the originator provide the information H wis not included in the draft statement.
Category 3-nadeqtate EPA believes that the draft impact statement dces not adequately assess the environt ental ancact of the proposed project or action, or that the statement inadequr:ely analyzes reasonably available alternatives.
The Agency has request !d more information and analysis concerning the poten-tial environmental hazards and has asked that substantial revision be made to the impact statement.
If a draft impact statement is assigned a Category 3, no rating will be made of the project or action, since a basis does not generally exist on which to make such a determit.ation.
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GENE 9AL CCRE7fS 1.
The EPA believes major improvcments are needed in the review of reactor operating expericnce to assure that such experience is translated into improved safety designs and operating procedures. The reactor accident at the Three Mile Island 2 (IMI-2) reactor on March 28, 1979, has focused attention on tne great need for a thorough re-examination of reactor safeef.
We are concerned about the effectiveness of the procedures by which reactor operating experience is translated into improved reactor designs or operational practices. We believe it mcumbent on the NPC to careful 2y review its current procedures for identifying, assessing, and actag en potential accident scenarios as actual operating experience with reactors increases.
2.
The EPA anderstands that the NRC is reviewmg the current status of emrwncy response planning ard that the U.S. Congress is now censidering legislation regardmg emergency response plarming. As the result of these actions are reported, the EPA will make the BBC aware of its concerns.
However, based on present conditions the EPA believes the FPC should seriously consider postponing arry reactor licensing actions in any state unless em rgency response plaraing prel 'itions have been initiated in a marner satisfactory to the NRC.
3.
The EPA recognizes that high-level waste management is currently under review with the issuance of a DEIS. The EPA assumes that the recent work of the Interagency EcView Grcup cn Nuclear Waste IIanageirtsat (IRG) will provide a strong and well-coordinated Federal program to solve the probicm.
- 4. The EPA has examined the NPC's assessment of accidents ard their potential risks. The assessments were developed Lf the NBC in the course of its engineering evaluation of reactor safety in the design of nuclear plants.
Since these issues are crrnon to all r.uclear plants of a given type, the EPA understands the NBC's use of a generic approach to accident risk evaluation. Moreoter, the NRC is expected to continue to ensure safety e t assessments in the licensing through siting, plant design and ac n
process on a case-by-case basis.
RADIGIDGICAL CMETS I - SITE CPEPATION
- 1. The petiod of time that the reactor could operate ard/cr be brcught to a cold shutdcun ard mintained in the event of a ccrplete loss of effluent supply frcm Phoenix is not rmaily apparent frcm the discussion in section 3.3 of the DEIS. We note that Unita 4 and 5 have a 20 hectare (50-acre) storage reservoir, but seepage loss is expe_c ed to be 300 acre-feet / year, evaporative less is 500 acre-feet / year, ard cordenser cooling tower less is 12,300 gallcns/ minute per unit (six cooling truers for units 4 ard 5). The FEIS should address itself to the time necessary to bring reactor units 1,2,3,4, ard 5 to a cold shutdcwn mode and the arcunt and source of water necessary to acccnplish and mainWn this acticn.
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- 2. Although the c'1 Mated exposures per unit (Table 5.8) indicate that five units could operate at the Palo Verde site and that the population exposures allowed by the Uranium Fuel Cycle Standard (UEC) would not be excwded, EPA reccrrends that the actual site data from the operation of units 1,2, ard 3 be used to deternure the total site impcct frcm five units. Analysis at that time should indicate any need for modifications to units 4 and 5 before operation. The data and information regaired frcm the applicant for this type of analysis should be addressed in the FEIS.
- 3. The mention of 10CFR20 in Section 5.4.3., paragraph one, is ir ppropriate and should be deleted. Section 5.4.3., paragraph two, states that UFC Standard (40CFR190), not 10CFR20 musc be used to determine measureable radiological impact on man frcm the routine operation of all the units at the Palo Verde site.
- 5. In view of Three Mile Island-2 ('IMI-2) and the addition of subscript "e" to Table 7.2 (page 7-3), EPA strongly urges that Table 7.2 be nodified in the FEIS.
II - ENVIFONCTIAL LEIOREE The pre-operational and opemtional radiological environmental mtnitoring program (as described in Sedons 6.1.5. and 6.2.2 of the DEIS and Section 6.2 of the PWCS-1,2, & 3 ER) appears to be, in general, satisfactory with the followmg exceptions that should be addressed in tFa FEIS:
- 1. The environmental monitoring prcws must be capable of providire data which can be used to calculate radiation e. p ures frcm all path. rays in order to evaluate ccrpliance with 40CFR190, not just ccrpliance with Append.tx I of 10CFR50.
- 2. The planned quarterly analysis of the Phcen.tx sewage treat:nent plant treated wastewater for tritium content is not adequate to determine possible additions to the tritium emissions frcm the plant. The treated wastewater supply at the site should be analyzed ncnthly for tritium in addition to the tritium analysis for Jocally-collected food samples.
- 3. The planned stack arv'. liquid radiation ncnitoring equignent should be reassessed to all s detection of operaticnal emission concentrations of nucleides as well as detection of estimated accident concentrations.
The FEIS should include a description of the re-designed monitoring system.
- 4. No Thernoluminescent Dosimeter ("1D) stations are irdicated for the visitcrs' center. EPA ccnsiders it mcst desirable to include TID's at this location to monitor direct radiation where the public has access. In gene ~al, che numbers of present TID stations shculd be addressed in the FEIS a*4 additicnal staticns shculd be ccnsidered.
III TRANSPCR GTION In its earlier reviews of the envi m tal izpacts of transportation of radioactive material, the EPA agreed with the Atcmic Energy Ccnmission (AEC) that many aspects of this program could hest be treated en a generic basis.
The NBC has codified this generic approach (40 FR 1005) 'cy arding a table to its regulations (10 CFR Part 51). That table stmrarizes the environmental f9.v/
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inpacts resulting frm tra #rcutine" transportaticn of radicactive raterials to and facin light-water reactcrs. 2ese regulations pernit the use of the inact values listed in tie table in lieu of assessing the transpcrtation inpact for individual reacter licensing actions if cer+2in conditions are ret. Palo Verde appears to reet these coriitions, so the rcutine transport-ation inpact values in the table are reasonable, and the generic approach appears adequate for this plant.
h inpact values for routira transmrtation of radioactive materials mentioned above have been set at a level which oavers 90 percent of the re&ctors currently operati:p or under constructicn. F4 Wever, the basis for the ir: pact, cr risk, of transportation "accidmts ' (versus "rcutine" transportation) is not clearly defined. At presente the EoA, the DCE, and and the ::PC are each atterpting to more fully aseen the radiclogical irpact of transportation risks. h EPA will then rake kncm its views en any ervircnmentally-unacceptable conditicns related to transportaticn. On the basis of present inferration, it appears that tbare are no unique characteristics of the Palo Verde site which would precipitate greater accident risks than those of the " typical" site studicd gerarically.
IV - FUEL CYCLE A D IRC TEP24 DOSE ASSESS 4ENTS The EPA is restensible fcr establishing generally applicable environmental radiation protection starsiards to limit unncecessary radiation egesures and radioactive rcaterials in the general enviraanent resulting frcxn rcrmal cperations that are part of the total uranium fuel cycle as well as those of the facilities. Se EPA has concluded (in 40 CFR 190) that environmental rnaintion standards for nuclear pcwer industry operaticas should take into account the total radiation dose to the population, the maxinna individual dese, the risk of health effects attributable to these deses (including future risks arising fran the release of long-lived radrcnuculdet to the environment), and the effectiveness and asts of effluent centrol technology. The EPA's Uranium Fuel Cycle Standards are expressed in terms of dose limits to individual members of the geraral public cni limit.s on quantities of certain long-lived radioactive materials released to the general envirement.
A docununt entitled, "Enviremental Survey of the UraniGn M:el Cycle" (NASH-1248) was issued by the AEC in conjunction with a regulation (10 CFR 50, Appendix D) fcr applicaticn in ecnpleting the cest-berafit aralysis for iniividual light-water reacter envircrrental reviews (39 FR 14188). This dccrent is used by the ::PC in draft envircnmental statcrents to assess the incremental enviremental ir:cacts that can he attributed to fuel cycle w mnents which narrt nuclear pcwr plants.
Recently, the :TC distributed an update of the WASH-1248 survey. We believe this to be a prudent step. In w.nents provided to the 2;PC cn Ncventer 14, 1978 on this subject, we encouraged the NPC to e:c ress envircnmental irpacts in terrs of poten ini ccnsequences to huran health hecause radioactive e
materials and icnizing radiation are the mest important factcrs affecting hunan health. We helieve the presentation of environmental inpact in ter s of human health irpact festers a hetter understanding cf the rnabtion protection afforded the public. Furthermore, huran health inpacts shculd he expressed in terrs of bcth death and sickness.
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A secci.d rajcr concern of EPA deals with the discharge and dispersal of log-lived radionuclides into the general envircr:nent. The EPA is encouraged to find sme discussion of the long-term inpacts in the DEIS.
However, in the areas addressed in MSH-1248, there are several cases in which radioactive raterials of lem persistence are released into the envircerent. The resulting consequences may extend over many generaticns and constitute irreversible public health ccmitnents. The long-term potential impact should also be considercd in any assessnent cn health inpact.
"he EPA has consistently found the NPC's estimates of population deses for the persistent radioactive materials to be inadequate.
In particular, tM NPC has generally limited their analysis to the population within 50 miles of a facilit/, cr, in rare cases, to the U.S. population, and doses ccmitted for a 50-year period by an annual release. These limitations produce unemplete estimates of environmental impacts and underestimate the inpact in sme cases, such as frcm re'. eases of tritit:n, Krypton-85, Carbon -14, Technetita-99, and Iodine-129. The total impact of these persistent radionuclides should be assessed, qualifying such estimates as apprcpriate to reflect the large uncertainties.
In this regard, we note that the Nuclear Energy Agency (NEA) is addressing this apcroach in raking assessments and that NFC is represented in this effort.
Another major consideration in updating MSH-1248 is the health impact frcm Raden-222 frcm the uranium mining and milling industry. Estimates made by EPA, areng others, indicate that Paden-222 contributes the greatest fraction of the total health inpact frcm nuclear power geraration.
In precaring an cpdated MSH-1248, W believe the NPC should:
1.
include the Radon-222 contribution frcm both the uranium mining and milling industries; 2.
detenni.ne the health inpact to larger populations, not only the local populations; 3.
recognize the persistent nature of the Faden-222 precurscrs (Th-230 and Ra-226) by estimati:q the health irpact for a period reflecting multi-generational tines.
V - DECOMISSIONING The NPC has published a prcposed rulM7g cn Deccrr.u.ssioning Criteria fcr Nuclear Facilities in the Federal Recister of 3hrch 13,1978. The EPA cczments dealing with the dectruissioning issue wre sent to the NPC cn July 5, 1973.
In these ccments, we stated that ene of the most igrrtant issues in the deccmissicning cf nuclear facilities is the develcment of standards fcr rnaintien exposure limits fcr materials, facilities, and sites prior to release for unrestricted use. We have included the develcment cf such standards among cur planned projects. The work will require a thercugh study to provide nemssary infernaticn, includmg a ccst-effectiveress analysis fcr varicus levels of decontamination.
The develcment of standards fcr dectruissicning must, of course, include censideraticn of the rany ccncurrent activities in radicactive waste managenent and radiolcgical protection.
"he EPA has developed prepcsed Criteria for Radicactive Waste for management of all radioactive wastes 4
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which will prcvide guWnce fcr dectraissioning standards. Frtn the dectrnissioning view, probably the most important criterien is the cre that limits the reliance on instituticral controls (guards and fences) to a finite period af time. 'lhe EPA believes that the use of institutional controls to protect the public frcra retired nuclear facility sites until they can be decontaminated and dectruissioned shouM have a time limit of a maxu:un of 100 years; a time limit of less than 50 years muld be preferred. This also includes nuclear reactors shut down and mothballed cr entcrbed for a period of time under protective stcrage. After the allcwable institutional care period is over, the site will have to meet radioactive protection levels established for release for restricted use unless the site is still in use fcr active units. We believe the EPA's proposed criteria would be directly applicable to deccrmissioning of nuclear facilities and should be given serious consideration by the I K.
The availability of adequate funds when the time to deccrrission arrives is also most mportant. It shouM be the !!PC's responsibility to assure that such provisicns are made. We recognize the great ccrplexity of providing funds at the tine of construction for use at the time of deccr:nission 40 years later. However, if it can be determined for public utilities that the total cosu of decxnissioning in current dollars is a very small fraction of initial capital cost, a provision of escrow funding ray not be necessary. Therefore, we urge the ::PC to conduct the necessary studies and assessnents to detemine unequivocally the costs of deccanissioning and to cer: pare such costs to initial capital costs.
It is only through a definitive analysis, and perhaps realistic denonstrations, t.mt this issue can be successfully resolved.
HAZARDOUS WPSTE CCFM27FS 1.
The DEIS indicates (Section 3.3) that 99 percent of the effluent frcrn the Phoenix 91st Avenue Municipa' Sewage TreatInent Plant @STP) will be treated at the on-site PV!US reclamation plant. The applicant should have a knowledge of events at the !!STP prior to on-site treatment of the effluent since accidental cr unauthcrized disposal of ha::ardous waste into the Phoenix sewage mllecticn system could affect the operaticn of the "STP.
The responsibility for notification ani the can:nications plan to be used shculd be detailed ani docununted in the FEIS.
2.
"Other than radicactive" waste dispcsal is discussed in Secticn 3.7.3.
Ecwever, there is no mentien made regarding the irpact cf the Rescurce Ccnservation and Pecovery Act (RCPA) on the 160-acre, en-site dispcsal site. These factors should be discussed in the FEIS.
SITE CESCRIPTICN CCMC??S 1.
Although the site is 1ccated in the vicinity of a large metrcoolitan area, t"ere is no discussion in the CEIS regarding the surrounding air fields, whether private, ccrmercial, cr military. Khtle there was inferaticn included in the ER, the FEIS should include a current evaluation of the present and future air corriders, including the pcssibility of a determination of an "exclusien area" to pr hibit cver-flights of the area.
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ETER CCMETTS The DEIS fails to fully explain many of the i::racts on water rescurces, should provide more mitigation measures, ard seems to have uscd questionable assurptions in deterning the availabili'u of effluent for ecolirg. EPA requests that the FEIS naaress tra following cmtrnts:
- 1. Deoletion: A major problem identified in the Areawide 208 Plan is the depletion of grcu & ater. Also of concern is the increasing use of energy required to pump the water, the attendant costs, and the detericration of grounisater qmlity attibutable to over-p:= ping.
Though the DEIS notes the problen of depletion (Section 2.2.4, Paragraph 2; aM Section 2.5.3, Paragraph 1), it fails to address the i:" pacts of this prcposal en the prcbiss (e.g., Section 4.2.2, Para. 2; ard Section 5.2.2, Para.1). The FE.23 should discuss the igact of using effluent which otherwise muld be available for other uses, including the effects on depletien regionally and en grcund-water qmlity. A discussion of mitigation shcuid te added. This could include the requirennt for the applicant to conwrve water as fully as possible and to restrict diversion to the absolute minimum necessary to operate the power plant.
- 2. Effluent L~nacts: Two issues need further analysis. One, hcw the NPC intends to assure that the large salt load accur:ulated at the power plant site will be prevented frcm pollutirg water supplies. The ancunt of salt shculd be described. The seccnd issue has to do with discharges to the enviroment. Although the NIS indicates that wastewaters will not be dischargcd to any existing na ural waters (Sec. 5.2.2, Para. 4), the FEIS shculd include cont;unnent cr other mitigation measures to be iglemented in the event of a pipeline accident.
3.
Effimnt Available for Ccoling: NIC has assured that the 91st Avenue Sewage Treatment Plant will provide all the cooling water needed for five reacters, a dmand estirated at 115,000 acre-feet per year in 1995 (Section 5.1.2., Para.1, Para. 3). This assurptien appears to be inaccurate and/or outdated for the follcwing reascns:
a) EPA believes that the projected ficw at the 91st Avenue Plant described in the 208 Plan developed by the Miriccta Association of Governments (WC, June 1979) is well substantia *wd.
That projecticn is 138,700 acre-feet per year in 1995. The 208 Plan estirates prior ccrmitrents in 1995 at 38,500 acre feet per year. On the basis of the 208 Plan, it appears t"at Se actual flcus available to PTUS will be less t'ra (i.e., 138,700 less 38,500 acre feet per year) the NIC's estimated total denand cf 115,000 acre feet per year. Therefore, a pctentially rajcr prcblen exists within cooling reacters 4 and 5 (and perhaps 43) since the 115,000 acre-feet / year deand for the entire plant raises total ornittrents on an a:mual basis to 153,000 acre-feet /
year in 1995 (pp. 5-13). In additicn, the expected succccc cf E 's ficw reduction program may further reduce the expected flcw.
Scrne interest has also teen expressed in reducing the ultimate capacity of de 91st Avenue Plant by shifting up to 20,000 acre-feet / year to the plant at 23rd Avenue.
"hus, it appears that the effluent available to the pcwer plant ray be substantially shcrt of dmand on an annual basis and even more sen en a peak seascnal basis.
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Sm.e loss of water between the treatment plant ard the reactors and som loss due to poor quality precluding effluent usage will have to be deducted frcm the total amount available.
c) The DEIS projects Biochanical Cbefgen Dawd (BCD) in the effluent at 20 to 25 :ng/l (Sec. 2.5.2, Para. 2). There is a substanHal doubt that the expectation will be met. The plant is only intended to produce an effluent with a BJD cf 30 cn a monthly average, which will soon be accmplished. However, the plant is only required to meet Class III re]iability, the lowest class. hhile the EPA does not e.W rajcr prcblems it is likely that the power plant will receive som effluent of an unusable q m H ty.
d)
In the arrents to the EPA on the DEIS issued on a pcrtion of the MAG 208 Plan, the Arincna Public Service Canpany (APSC) projected a peak monthly demand for Units 1-3 at 6,550 acre-feet.
When extrapolated to five units, this estirate would be about 10,900 acm-feet / month. This greatly ex M the projected 1990 flcus (when Feactor #5 will go en the line) fran the 91st Avenue Plant of 7,400 acre-feetAcnth average (projections which, as noted above, may be high). Based en the 208 Plan, even Reacter #4's peak ficw demaM could not be bandled until circa 1997.
e) Another facter which has not been addressed is that of agricultural denand which will peak in the st:rnr - just when tha PWGS peak needs arc also likely to occur. Since the Btacye Irrigation District has a prior right to effluent, there ray be less than the average amount of effluent available to PVNGS during the strrer mcnths.
Exanuung "a" thrcugh "e" indicates clearly that the 91st Ave. Treatment Plant will not be able to previde sufficient effluent to cac1 five reacters. The carbined 23rd ani 91st Ave. plants might provide sufficient annual flow to support five reacters, but even this would depend cn the extent of sewage ficw reductions in the Phoenix area and the anount of effluent arriving at PVNGS which is unusable. Miitionally, it appears that peak darands could not be met if Buckeye Irrigation District elects to take nere than average amcunts of effluent during the pericd of peak PVNGS need. There is also the pcssibility that MacDcnald fanns Iray be entitled to much of the 23rd Avenue flow, a facter which NPC Fas not considered. The EPA strcngly urges further cocrdinaticn with MAG ard a re-emination cf supply /derand of effluent. The FEIS shculd be revised to reflect the increased ircacts if the STC prcposes to license five reacters ard require the use of effluent frcm 23rd Ave.
It sPculd also include a full a fsis of cooling water demand and effluent availability.
The aralysis shetud take into acccunt peak derand fran all users, including PVNGS., expectal losses of usable effluent ard the possibility of further reducticns in projected flcus to the 91st and 23rd Ave.
Treatm W Pla.s.
If, as appears to be the case, derard will exceed supp]y, tie FM shculd indicate alternative scurces of coolant ard their related irpacts.
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FSFILTTP DIVEPSION CCtTAIN1'S The DEIS notes tM t diversion of effluent will lead to " degradation" of riparian habitat (page 1). There appear to be many craissions in describing the impacts. Additionally, no mitigation is discussed. The DEIS indicates a maximtn 37 percent reduction in flow in " Segment B" and 9 pcreent in "Segnent D." of the Salt and Gila Rivers (Sec. 5.5.1.2, Para. 6 & 9). These figures shculd be reanalysed, in light of the questions concern.ing the arount of available effluent, and the fact that almost all the flou span in Table 2.13 would be eliminated. In addition to the above, tM FEIS should address seasonal variations in ficw and their inpacts as well as the impact on wildlife and on other beneficial uses such as fishing and recreation. The impact of decreased availability should be assessed.
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