ML19254D525

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Comments That Fes Is Inadequate Re Economic & Radiobiological Effects of Class 9 Accident on Surrounding Area & Population.Requests Suppl to Fes or Justification for Denial of Request
ML19254D525
Person / Time
Site: Green County Power Authority of the State of New York icon.png
Issue date: 03/08/1979
From: Parnes M
FRIENDS OF THE EARTH
To: Hendrie J
NRC COMMISSION (OCM)
Shared Package
ML19254D524 List:
References
RTR-WASH-1400 NUDOCS 7910260239
Download: ML19254D525 (2)


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...a FRIENDS OF THE EARTH 124 SPEAR sax FRAscisco CattroRNIA 941o3 (415)495-4770 March 8, 1979 Mr. Joseph Hendrie Chairman Nuclear Regulatory Co= mission Washington, D.C.

20555 Dear Mr. Hendrie.

This letter is in response to the recent notice of availability of the Final Environmental Statement for the Greene County Nuclear Power Plant (United States Nuclear Regulatory Commission Dockett No. 50-549).

The recent Statement of Policy by the Nuclear Regulatory Commission on the Reactor Safety Study (January 19,1979) raises several questions about nuclear reactor safety. Friends of the Earth is concerned about the NRC's own findings on the possibility of a nuclear reactor accident. The Statement of Policy states:

The Commission accepts the Review Group Report's conclusion that absolute values of the risks presented by WASH-1400 should not be used uncritically either in the regulatory processIfor public policy purposes and has taken and will continue to take steps to assure that any such use in the past will be corrected as appropriate. In par-ticular, in 11 ht of the Review Group conclusions on accident prob-6 abilities, the Commission does not regar? as reliable the Reactor Safety Study's numerical estimate of the over all risk of reactor accident.

Friends of the Earth requests that the Commission's Office of Nuclear Reactor Reguition respond to the criticisms of the Review Group Report on WASH-1400 as they apply to the Greene County Nuclear Plant. In particular, what would be the economic and radiobiological effects of a Class 9 accident on the surrounding area and local population? An addendum to the EIS would be in ecmpliance> with Title 10, Chapter 1, Section 51.26 of the Code of Federal

-Regulations, which notes:

The final environmental impact statement will make a meaningful reference to the existence of any responsible opposing view not adequately dis-cussed in the dr.ft environmental statement indicating the respcase to the issues raised.

In addition the Couacil on Environmental a,uality final regulations for 1:he implementation of procedural provisions of the National Environmental Policy Act (Federal Register, Volume 43, No. 230, Section 1502 9 (c)) require agencies to:

prepare supplements to either draft or final environmental impact statements if... (ii) There are significant new circumstances, or information relevant to enviror. mental concerns and bearing on the proposed action or its impacts.

It appears, therefore, that under the National Environmental Policy Act, the Creene County FES is inadequate. The possible significant environmental impact of a Class 9 accident was not discussed based on the ' ASH-1400 findings of in-finitesimally small probability of occurence. Since the NRC now admits that the WASH-1400 probability estimates are unreliable, we must insist that under NEPA, which requires a thorough exa..tination of all possible environmen'C impacts, the Creene County FES must discuss in detail the effects of the occur..ce of a Class 9 accident. Failure to discuss these effects leaves the FES fatally deficient under the law.

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Friends of the Earth also requests that a supplement be prepared for the following nuclear plants, or that a justification be E ven in each EIS for not-

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l considering Class 9 accidents:

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1) Pilgris, Unit 2, Plyaouth County,:M 2,7*
2) ' Watts Barr, Units 1 and 2, Spring City, Tennessee

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3) Waoerford, Unit 3, St. Charles Parish IA

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4) Byron Station, Units 1 and 2 Rockvale, IL

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5) 3raidwood Station, Units 1 and 2, Reed, IL Z,.M
6) San onofre, Units 2 and 3, San Clemente, CA
7) Yellow Creek, Units 1 and 2, ':'ishosingo County, Mississippi
8) Ia Salle, Units 1 and 2, la Salle County, IL Sy delineating the effects of a Class 9 accident. the Office of Nuclear Regulation would follow the Commission's stated intention of correcting any erroneous reliance on the viASH-1400 study and would fulfill the candate of the National Environmental Policy Act.

Thank you very much for your consideration.

Sincerely, s' !:Likmth;G; Mark Parnes Legal Researcher

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.. H. Regan. Jr., Chief cc:

Environmental Projects Branch 2 Division of Site Safety and Environmental Analysis U.S. Nuclear Regulatory Consission

'lashington, D.C. 20555 fg.

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