ML19303A295

Submits Review of Des,Citing Environ Reservation Re Lack of Detailed Descriptions of Gaseous & Liquid Waste Treatment Sys.Radiological Aspects,Radwaste Treatment Sys,Reactor Accidents & EIS Supporting Documentation Timing Discussed

ML19303A295
Person / Time
Site:	Callaway
Issue date:	11/23/1981
From:	Hajinian C ENVIRONMENTAL PROTECTION AGENCY
To:	Youngblood B Office of Nuclear Reactor Regulation
References
NUDOCS 8112020481
Download: ML19303A295 (5)

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UNITED ST,ATES ENVIRONMENTAL PROTECTION ACiENCY

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, 324 EAST ELEVENTH STREET lg l

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November 23, 1981 D?.C

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' Mr. B. J. Youngblood .-  % 9/

Chief Licensing Brancti No. l 4 -

i U.S. Nuclear Regulatory' Comission

• Washington, D.C. 20555

; Callaway plant; Unit No.1 Callaway County, Missouri

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[' Dear Mr. Youngblood(

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. We have reviewed the Draft Environmental Statement for the proposed operation of tne planned nucle'ar prower plant identified abpve. The project and draft statement have been ratzd ER-2 (environmental reservations 'insufficien,t, information),respectively. Our primary environmental reservation with tne proposed operation is a lack of detailed descriptions of the gaseous th3-

-liquid waste treat'nent systems. The failure'to provide the ofter: referenced Safety Evaluation Report with the Draft Environmental Statement prevented 4 _

thorough evaluation of tti planned facility. -- --- -- --

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. . 5-The following~ comments are provided for your consideration when preparing the Final Envi,ronmental Statement:

Radiolocical Ascects -

, .' Generic Coments

. In cur past reviews of Draft Environmental Impact Statements (EIS) relating to light-water nuclear power facilities, we have included generic comments which are applicable to all such facilities. As a result af the Three i

Mile Island accident, we have decided that we must revise our generic comments to tensider these events and activities. We will provice.our.

revised generic coments to the Nuclear Regulatory Comission (NRC) as soon as they are completed. Generic issues undergoing review are:

~ . Popule. tion dose commitments .

. Reactor accidents .

. Fuel cycle and longaterm dose assessments 1

. High-level radioactive waste management

. Transportation impacts >

. Dccomissioning  ;

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_ g Radioactive Waste -Trettrient Systems The Draft EIS does. not'. contain detaileo descriptions of the- radioactive waste treatment system) or the NRO staff's detailed evaluations of'these systems. -Such matters are referenced to the Safety Evaluation Report

. ISER), which has not yft been received by our office for use in this l j ,_

revi eW.

Section 3.5 of the 4ppff cant's Environmental Report (ER) states that,

• ' ". . . there are no mafor changes to the (radwaste treatment) systems

, as described in the PSAR . . . ". Ou,r comments on the Drsft EIS-Con- ~

struction Permit (DEIS-CP) stated that, " Based on our evaluation of the draft statement, the pr' posed o gaseous and liquid waste management systems

~ ' are capable of limiting tte radioactive releases and the resulting doses '

to w.ithin the 'as Jdw as practicable' ' uidanceg of proposed Appendix I 4

to 10 CFR Part 50." . Frqm these. statements, we conclude that operations r ~

sill be *within EPA's..Env.ironmental Radiation 3tiTidards (40 CFR 190).

f.. .- However, an explanat4on ;is required for the lower gaseous effluents l

calculated by NRC for this Draft EIS versus those calculated for the

~ - Final EIS-Constructi'on Permit (FEIS-CP) and the calculated liquid efflisents of 0.17 cur;ie!f

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per year in the FEIS-CP.' per year in this document versus 0.29 curies 3..

Liquid radioactive effluents from the Callaway Plant will be discharged % 1

'to the Missouri River. Two other nuclea. power plants (Fort Calhoun - '

_ Nuclear Station and C.coppr. Nuclear Statien)' have been operating upstreah." -

l for severai. yea s. The comained environmental effects of effluents from r - -

MT' i all three plants should be calculated for drinking water systems downstrgkm from the plannec Caliaway Plant. These calculatiens should use actual

{ discharge cata. from tne operating plants. ,

We believe the Final EIS should include an ev'abat. ion and full discussion i

. of any confirmatory items not resolved by the time it is issued.  !

Reactor Accidents I i

When discussing accident risk and impacts.of design basis accidents, the Draft EIS addresses probabilities of occurrence cualitatively.

) Yet, when disrussing the more severe ccre melt accidents, the proba-bilities of occurrence are quantified (Table 5.7). For consistency in the presentation of all environmental risks, the probabilities -

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of occurrence of infrequent accidents and limiting fault design basis i accidents should also be provided.

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Timino of Supoortino Documentation for the EIS 4

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The practice of issuing the Draf t EIS in advance of the SER has prevented our performing a complete review of the environmental impacts of the Callaway Plant. As discussed in our comments on radioactive waste S

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treatment systems, this is felt to be detrimental to cur review of the' Draft EIS. Also, the* Draft EIS refers to the SER regarding several oth^r '

topics which are still under NRC review. These include:

- . 1. Fa,cility safety- features. Reference is made to the forthcoming SER

. for the NRC . staff ervaluation of safety features and characteristics of  !

the ' facility, and description of some 'of the accident mitigation features.

2., Site features. FReference is made to a review of potential external hazards that might. adversely affect operation of the plant. A more <

detailed discussion '0f site features is referenced to the SER.

3. Emergency Preparedness. Emergency preparedness plcns including pro-tective-action. measures for the Callaway Plant and environs are reported to @ in, an advNced) but not yet fully, esmpleted, stage. We are unable to comment on this topic since a draft of the local emergency prepared-  !

ness plans has-not bfen submitted to the Fedetal Emergency Management

'"_ Agency for review. The last draft of the State plan was found to.have numerous deficienties. NRC staff findings of adequacy and implementa-bility .for both the on-site and off-site plans have not yet been finali:ed. - -

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Operational Radiological Monitoring. The applicant's proposedcmenitor-ing program will be reviewed in detail by;the NRC staff and incorporafad '

- into the radiological technical specifications for the operating license.

The proposed program (DEIS, Table 5.4; ER Section 6.1.5 and 6.1-5) hths -

sufficient detail *for evaluation by EPA. 9,1 _

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g4 The information presented only states whet was done in 1973-74 anddMs n ct incluce, imorovements in monitoring technology or philosopny. The need

' for additional dosimetry for adequate accidhnt respon'se should be addressed.

Sampling at the nearest downstream drinking. water intake should include consideration of requirements under the Safe Dr. inking Water Act. We believe

ne operational radiological monitoring program should be well defined,

._since operation should begin during 1982. .

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In view of the above, any conclusion such as that in Section 5.9.4.5 regarding the plant's environmental impact would see'm to be contingent on favorable results from important ongoing staff reviews.; and hence premature. The Final EIS should be withheld until the above-mentioned reviews' are c.arpleted, or should specifically discuss any of the areas which are still undergoing review.

We urge the NRC to ensure that, in the future, the Safety Evaluation Report is avatlable before issuing the Draft EIS unless the Draft EIS is' a complete document net requiring references to the SER. Mater-ial incorporated into an EIS by referen 4 should-be reasonably availabig ' '

for inspection within the time allowed for comment (40 CFR 1502.21).

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We do not believe the citations of missing but forthcoming information in the SER constitutes a " reference" in the common meaning of the word.

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Denenissioninc ^

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l The Draft EIS states that planning for decommissior.ing can affect health .

-and safety as welf as kost. We concur in this assessment but were unable I

~ , to find a,ny arrangemerits for fdinancing decommissioning costs in the Draft  !

' EIS. Decommissioning costs are noted to be irt the range of $59 million to 573 million in 1983 dollars (Section 2.2). This is a large sum and will 4 ~ represent a large cost. burden when needed if not accumulated out of revenues i

durino the plant's operating lifetime. The Final EIS should explain what p*

specific arrangemerits have been made, or are planned, to assure that funds will be available for decommissioning when required. -

. . t Mt is not clear at what point the licensee's finaccial responsibility is to be terminated. Te Aination of the nuclear license is required at the . 1 f end of facility l'ifb, ar d this requires decontaminatien of the facility '

such' t!iat unrestricted Dse can be allowed. Although the applicant's ER  !

( (Section 5.8) does riot s'pecify a decommission 1m3. alternative; one option to achieve such. deco,nta91 nation is SAFSTOR, which allows deferral of decon-tamination for up to 100 years. It is not clear, in such case, whether license tennination -would occur prior to, or at the ' nd

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e of, such an extended storage per.iod. -If ' termination occurs at the becinning of the storage  ;

period, financial arrangen,ents etidently will be necessary to pay for.,_. ,,  :

security and the deferral decontamination. The Final EIS should clarifv . l this point. . q e . _

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Economic Risks S r'

._h[ 5 As the Three Mile Island eu ' cent demonstrated, the cost of reactor -T building decontamination ana replacement power following an accicent can be considerabTe. This underscores the need toi develop standard athodologies I for estimating the contribution of these cost; te economic risks.  !

Economic risks are addressed in some detail in Se6 tion 5.9.4.'of the 1 Draft EIS and, based on the low probability of occurrence, annualized risk l is calculated to be modest. However, because of the potentially severe  !

, economic costs, we cannot agree with the NRC staff's assessment that these l w

ccsts are "small" (lable 6.1). -

Non-Radiolooical Ascects e

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1. The Draft EIS indicates 7230 acres have been purchased instead of the f3 6600 acres identified in the FEIS-CP. The reason (s) for purchasing approximately one additional section of lartd should be explained.

l C. The applicant has cancelled pla'ns to construct a s2cond nuclea'r

! plant adjacent to Callaway Unit No. 1. The effect of the cancellation on p the operation of Unit No. I and use of the plant site should be. discussed

,in the Final EIS. ,

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, 3. Items Se and Sh in the Summa y and Conclusions section need to be -

M/O rewritten to agree' witt conclusions presented in Chapters 4 and 5. Itera 3e should read: There will be negligibic effect on the upstream 100-year glood level due to* int'ake and discharge structures. Item Sh should read:

ihe need for further mitigation of discharge relited impacts will depend

% ll ~ j on monitoring studies required by the NPDES permit and a section 316 determination by the State of Missouri.

Thank you for-the oppontunity to review and comment on the Draft Environmental Statement. If you havecquestiens regarding the concerns we expressed in this letter, please contact-our office. The staff members most familiar . -

with this project are Messrs. William Brinck and Robert Fenemore. They ~

can be reached at FTS 758-3307 and 758-2921, respectively.

• Sincerely yours, * . -

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. Charles H. Haj ien . Branch Chief  ;

" E.wironmental ' view' Branch- '

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