ML19259B500

Comments on Fes Part 3.Agrees W/Close Scrutiny of Sites in Estuaries,Rivers or Near Barrier Islands.Believes Accident Consequences Are Much Greater than for land-based Plants.Notes Use of WASH-1400 in Preparation of Fes

ML19259B500
Person / Time
Site:	Atlantic Nuclear Power Plant
Issue date:	02/26/1979
From:	Hedeman W ENVIRONMENTAL PROTECTION AGENCY
To:	Deyoung R Office of Nuclear Reactor Regulation
References
NUDOCS 7903010207
Download: ML19259B500 (3)

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E UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

%,we WASHINGTON, D.C. 204G0 2 6 FEB 1979 OFFICE OF THE ADMINISTRATOR Mr. Robert C. DeYoung Director ~

Division of Site Safety & Environmental )>

Analysis Office of Nuclear Reactor Regulations U.S. Nuclear Regulatory Commission Washington, D.C. 20555

Dear Mr. DeYoung:

The Environmental Protection Agency has reviewed the fi.nal environmental impact statement (EIS) related to the manufacture of Floating Nuclear Power Plants -- Part III.

Throughout this 1.011ti-EIS process there has been a continuing dialogue between EPA and NRC concerning siting of FNP's in estuarine and barrier island areas. Our major concern has been that prospective applicants for licenses to construct FNP's in these sensitive areas be made aware of the difficulties involved. By emphasizing these concerns at this stage in the FNP licensing process, we hope to avoid future time consuming and non-productive debate on inappropriate site proposals.

To this end we are pleased that the NRC staff has concluded that "... finding acceptable FNP sites in estuaries, rivers or near barrier islands will most likely be extremely difficult..." and has specified a series of requirements that must be met before a site specific application will be processed beyond the Environmental Report stage. We believe that rigorous and complete fulfillment of these requirements is essential for the protection of these areas.

EPA intends to work closely with NRC in the detailed review [

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To insure the complete success of this process, however, we believe that prospective purchasers of FNP's should be advised to work with EPA and NRC to determine site suitability before final commitment to purchase.

With respect to the radioactive release potential from FNP's, the FEIS compares the risks and consequences of accidents involving FNP's versus land based plants (LBP).

We agree that the risks for FNP and LBP are similar, but maintain that the consequences of accidents beyond the design basis (core melt-through of containment) are significantly greater for an FNP, at least through the liquid pathway.

Much of the discussion in the FEIS reflects conclusions of the Reactor Safety Study (WASH 1400), commonly known as the Rasmussen Report. In view of the recent NRC agreement with long-standing criticisms of the Rasmussen Report, the accuracy of the final EIS is questioned.

Particularly noteworthy, the executive summary of the Rasmussen Report did not reflect the adverse consequences described in the body of the report. Similarly, the Summary and Conclusions in this FEIS does not, in our or_aion, give the clearest picture of the consequences of a core meltdown. For example, on page xii it is stated that "The monetized risk of radioactive release to the liquid pathway from core-melt accidents at an FNP for the most likely case is low and over the lifetime of the plant represents...about $3 to 65 million ...for the estuarine sita." The reader is not cautioned that

" monetized risk" refers to the cost of the event adjusted to its probability. As stated in the text (page 3-43 and 3-53) the unadjusted cost of a core-melt in an estuary might run into the tens of billions of dollars, and might require restrictions on fishir.3 w.J other water uses for up to one hundred years. hc Delieve that such unadjusted costs should be highlighted during final deliberations by the Commission on this license application.

e We look forward to a continued close working relationship with you in the implementation of your recommendation. ..

f Singre,1y you s, .

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William N. Hec'eman , Jr.

Director  ;

Office of Federal Activities (A-104i .

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.. . M MEETING NOTICE [

J. Knight Docket File S. llanauer NRC PDR R. Tedesco Local PDR S. Pawlicki TIC F. Schauer LWR #4 File K. Kniel NRR Reading T. Novak 11 . Denton Z. Rosztoczy E. Case R. Bosnak D. Crutchfield R. Satterfield D. Bunch W. Betler R. Boyd F. Rosa R. Mattson V. Moore R. DeYoung M. Ernst D. Muller R. Denise D. Ross R. Ballard D. Vassallo B. Youngblood D. Skovholt W. Regan W. Gammill G. Chipman F. Williams R. Ilouston J. Stolz J. Collins R. Baer W. Kreger

'O. Parr G. Lear S. Varga M. Spangler P. Collins V. Benaroya T. Speis L. Hulman W. Ilaass H. Ornstein C. IIeltemes J. Ledoux, IE ACRS (16)

Participants:

S. Kari L. Crocker

• B. Lovelace

11. Berkow E. Schweibinz Project Manager: J. Wilson Attorney, ELD IE (3)

SD (7)

M. Service Reccptionist L. Rubenstein L. So f fer

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