ML19303A292
| ML19303A292 | |
| Person / Time | |
|---|---|
| Site: | Callaway  |
| Issue date: | 11/03/1981 |
| From: | Jeffrey Reed AFFILIATION NOT ASSIGNED |
| To: | Office of Nuclear Reactor Regulation |
| References | |
| RTR-NUREG-0813, RTR-NUREG-813 NUDOCS 8111170305 | |
| Download: ML19303A292 (3) | |
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03 November 1981
, Stbject:.Cc=ments.on N' UREG 0813; Draft Environmental Statement related to the operation of Callaway Plant, Unit No. 1 (50-423)_%:;t 'el a v-t !.q,r To:
' Director [f Licensing f
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Nuclear R,egulatory Ccemission 3[ a,,,0'D' O IS87d j
Jashingtcy, D.C. 20555
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Sir:
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gg The document identi.$ed above has been reviewed by the undersigned and several conclusions reached by the staff Appear to be centradictcry or are based dpon,. infor!r.ation which should le,ad_a reasoning person to make a decision centrary to that made by staff.
i e-In Chapter 3, Section 3.2, paragraph 3, the staff concluded that in the absence of an.y signi the plant ~ cperation;ficant environmental or safety objection relating to
.a decision to permit er teny the issuance of an.
j operating license is tased purely on ecenemics. The only entiety tF-- '-
benefit econo =ically frem such operations.is Union Electric Companyc,,Ihe financial i= pact upon the four :nal coun~ ties and several country towrne which must support the plants operstien through radiological emergenef,
response planning; try.ining, exercises and tests for 'the 40 year lieeging----
period of CE-1 is overlooked.
E-g In Charter 5, Section 5.B.1, the staff anticipates indirect a d induc}ed
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local jcbs.will be created by the cperation of CR-1 (see para.2) and that a secondary e=ployment level of 117 s'lppert, service jobs ceuld be achieved as estimated by U.E.
The retail' purchases of U.E. are esti=ated at $2.7 =L21icn in 1982 and indirect benefits to the local ecenc=y will eise therefr== (see paras. 4 & 5); however local benefit would be srW p)'
-and not necessarily cause an increase in local empleyment or egansion of local bus $ ness (para. 5) and the staff anticipates local purchases will have a minor i=nact on the re51cnal (locci) ecenocy.
Statements such as these in the above paragraph are c=ntradictory and appear to be used to provide a canability to justify a decision using specific sentances in the rencrt rather than existing facts. Se =0st "
probable overall conclusien that can be drawn from the economic data provided is that there will be no visible econo =ic benefit er in=act on the local econery be. sed upon the operatiens of the plant. Such 'a state-
, gent should be clearly stated in the final document.
' In Section 5 8.2 Tax Senefits: hax revenues of $3.25 r4.111:n in -198p and estimates of $4.4, S5.1, and $6.1 =illien were made for 1981, '52, and '83 respectively for Callaway County. Over two-thirds of all local tax revenue from CAL-1 goes through the County Collector's-Office directly to the South g3 Callaway R-2 School District (.wquired by Missouri statutes). S e remainder is divided among the existing county service orgar.izations. Secause cf the increased tax base ersated by Union Electric, Callaway County went f em a third. class county to a second class county which required =eny additional ki 170I305 811103 U[4, fg
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Subj: Co=ments on NUREG_O813 - (coht.)
I services. 11tch of the increased revenues went toward these added requirements. The study did not include the fact that no tax benefit was derived by,the*.three other counties impacted by the operation of CAL-1. Kentgomery ' County, Gasconade County and Osap County are all
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within.the 10 mile EPZ and have not received one red cent revenue from the construction of' CAL-1. Additionally, there are four ambulance
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i ig districts and four (possibly six soon) incorporated municipalities that I
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U are i=pacted by the 10 c.ls IPZ and no data hu been included which shows j
f hoy they benefit er are effected by the operation of CAL-1. Section 5 8.2 shows one favorsble " aspect of a tax benefit as it relates to one school
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district in Callaway, Couhty. A fair anc complete descriptien of all of the,
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facts should be given and evaluated before a cenclusion is drawn by staff.
l Planning, training and enual exercises, as cited in NL".EG 065L FIM-EEP-1
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adversly effect all 6f these cited local govemments.
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No study infomation:was pMsented on the, impact that'will be made af,ter
.- g g censiruction ilis ec==lete and the tax base is modified so that ' local assessment is removed on the poder generation portien of the plant. Local governments 7 e looked upon as " partners" with the State and utility in providing for public health and. safjty, yet for the LO year licensing period of the plant
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they do not receive any financial assistance frem the utility (unless it is grudgingly deled out);. A partnership should be beneficial to all parties; yet assu=ing additional responsibilities to meet NRC standards and acetpting financial liability fer actions inherent with the assumed responsibilitdes hardly qualifies as beneficial to local gove=ments nor appears econe_:Ceally profitable to such, "pprtner".
.y ectien 5.9.L Pestulated Accidents: Gasecus =aterials (Krypte'n and.Xen M
are indicated as having the highest potential fer release in an accident.
~"nese inert. ncble gases decay rather rapidly and the :?aughter products are net considered (specifically 3rc=ine, Rubidium, Iodine, and Cosiu=). All
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' accidents (CRA and Class 9) are generally discussed, but are dis =issed as "very low frecuency but credible" or are reduced in pctential by the inclusion of design base safety features. In Health Effects (pase 5-37, line B) an 7 extremely Icw prebability" is used to =ittgate the severe end of the accident j
spectrum. Expesure to certain radiation magnitudes are " theoretically g(
possible" (page 5-37, lines 9 & 10). Qualifying te=s such as these when
,pD speaking of possible accidents will deter positive atte= pts at e=ergency l
respense planning and is counter productive to providing for public health and safet This same conclusion was drawn in Union Calendar No. 23L, 96th Dengress,y.1st Session - House Repert No.96-413, 8 Aug. '79, Emergency Plan-ning Around U.S. Nuclear Powerplants: Nuclear Replatcry Cc::=issica Cversight
- Lth Report, VII Co==ittee Recc=nendations,1(a):
"1.
With regard to its responsib'ilit-/ of leadership in the field of e.Dergency plan.ing,J the NRC should:
(a) =ake clear in its rules, policy statements, regulatorg guides and other official docilments, that it considers severe nuclear accidents
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possible, not hypothetical, occurences for which emergency planning is appropriate;"
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,.,W Subj Coc:ments on' NURES 0813 - (cont.)
Probabilistic issessment of Severe Accidents (page 3-44) states that-
"The conseqcences gf's'uch accidents could be severe."
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This statetent is in' regard to Class 9 accidents and is supported by other documents (not included in the above study) prepared for the NRC by Sandia Labs.
Threughout the asse;ss=ent of severe accidents, there is a tendency for staff to' reduce,the i= pact of possible accidents and their severity by i
verbal t:itigation. The Reactor Safety Study (RSS) of 1975 (ret 40) was l'
g used for this purpoke even though substantial uncertainties in the, 4
probabilit'ies used i;1 the study were found and accepted by the Commission on 19 January 1979. : It yas concluded by the Comnission that error bounds were understated.
If such is the. case, comen sense dictates that public health and safety is, best served by use of the highest probability ec=put-Q tiens.
On page 5-47, para 3, staff states that "There are also uncertain-71es in the estimateb of the consequences, and the error bounds may be as 2.arge as they are for the probabilitiesf' - - yet, the staff blithly makes pg an unfounded judgemer.t that the calculated rpsults are everestimates ;ather than* underestimates.. Prudence and concem,fer public hezith and safety
, requires a decision t'o the contrary.
To decide in faver of protecting the public frem possible dangers does net
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have to jeprodice'iss,uance of an operating license for CAL-1; acknowledge p}
the possible danger and take steps to increase actual e=ergency res;2Ms4 -
capability at the local levels of severnment. Failure to make such (Mings places staff in a position wherein it cat'.be accused of selectively ustg
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study data to reach a pre-femed conclusion and when such data does AcI,,
support their ai=,,it,is summarily disa:issed as inconsequential.
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' Justification fer the operatien of CAL-1 is critical at this stage "n.31 ant eenstructien, but unless clearly valid and reasenable cenclusiens can be drawn frem concise, factual infer:Etien; public resistance to atc=ic pcwer plants will centinue to increase.
Use of hl.lf-truth prepaganda or white-wash techniques are self-defeating in the long run and violate the charter under which the AEC and NEC were founded.
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-Thc Ce::m:issien beca=e woefully aware of hcw tenuous was their e.redibility g
upcn the occurar.ce of the TE accident.
The staterents en pages 5-38 and 5-39 as concern the Enrico Fer=1 Power Plant bord 9r en the incredulous. To d--Ty that Unit 1 reached full power and cperated at th t level until 1973 a
when it was shut down because it had completed its =ission - - - unbelievable.
It is respectfully reco= ended that this entire report be Mtt,en and put is a fem which is clear, concise, factual and moderately brief.
Conclusions I
which oppose data presented or other Cpmmission reperts, statements, or studies published must be fully and com=letely explained.
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Jonn o. 3,ed Kingdern City,
.T. 65262 tel: (314) 642-2769 G
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