ML19330B076
| ML19330B076 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 07/22/1980 |
| From: | Chandler L NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| To: | Snyder B NRC OFFICE OF POLICY EVALUATIONS (OPE) |
| References | |
| NUDOCS 8007300271 | |
| Download: ML19330B076 (3) | |
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JUL 2 21580 Chandier MEMORANDUM FOR: Bernard Snyder. Director, TMIPO FROM:
Lawrence J. Chandler, Attorney, OELD
SUBJECT:
COMMENTS ON DRAFT PEIS FOR TMI-2 CLEANUP We have reviewed the referenced document which was received on July 19, 1980, to assure its compliance with applicable NRC regulations, CEQ regu-lations and, most fundamentally, NEPA.
In our review, we have given due
' consideration to the facts that (a) this is a draft document, and (b) because of its unique subject matter, much is based on judgment rather than hard fact. We would note that, in large part, the broad comments provided below were previously given to you during our review of the PEIS at Argonne National Laboratory on June 24-26, 1980.
By way of general consent, the reference in every section addressing "Other Envirormntal Effects
- to Sections 3.1.6 and 3.1.7 should be deleted. These two sections do not discuss environmental effects of any action but rather describe the socioeconomic and psychological environment which currently exists; the reference to Section 10.6 is the proper citation to the dis-cussion of the impacts.
As you were previously informed, CEQ regulations require that a list of all preparers (not reviewers) and their qualifications be included. Such list is not included.
1 NRC regulations require a balancing.of costs and benefits; the disclaimer on page 12-2 is inadequate. The need to c.leanup the facility will suffice to present the benefits (see Section S.2 sad Section 2 generally). Cos ts should be presented in quantified terms to the extent possible, including j
economic costs (as required by MRC and CEQ regulations) but, as they are not now available, a qualitative description of costs (approximate dollars costs (see Section 1.3) and envirovmental costs - e.g., total health effects, land
)
use, commitment of other resources--see Section 10 perarally), should at a
-minimum be presented. Thus, in lieu of the negative statement cade on l
page 12-2, reference to Sections 2 and 10 should be made (as a distinct sec-tion in Section 12) together with a judgment as to the balance to be struck.
NEPA also requires consioerstion of irreversible and irretricta' ale comit-ments of resources. Such discussion cannot be discarned in this doctment.
It should include, to the extent possible, a cor 1deration of what material resources, including land, might be required and irrevocably committed or hoo7soo n/
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0,nCE n SURNAME DATEk.
NAC FORM 313 (9 76) NRCM O240 DU.S. GOVERNMENT PRINTING OFRCE: 1979 289-369 i
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Bernard Snyder consumed as e result of the cleanup operation (i.e., resin and filter mate-rials, land required for off-site waste storage which may have other poten-tial uses, such as faming. -(See Section 9.))
It should be emphasized, in the appropriate sections, that a given activity will not involve any offsite effluent or impact in terms of themal, chemical or radioactive gaseous of liquid discharges since the effluent, at least initially, will be contained on-site as part of the nonnal operating process.
Your treatment of this matter is uneven at best and should be expanded.
Specific comments:
Page Coweents xiv (last line)
I believe that the correct date is Jan-uary 29, 1980, not " January.14,1980."
1-1 The footnote (*) should be deleted; it is a repeat of the footnote at page 5-1, 1-3 (fifth para., line 3).
Check whether the word " pilot" is correct.
1-16 (Sec. 1.5.6, line 3)
'NRC" and "SC-1" should be *NRU" ind "SL-l' I believe.
1-19 (last para., line 3)
Insert " proposed" between "of" ar i "10 CFR..."
1-21 (Sec. 1.6.1.4, line 2)
I believe that only Appendix 8 was amended; this should be checked.
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1-26 (Sec. 1.6.3.2)
In this section (and by additional require-ments set out in the proposed technical specifications in Appendix R), the licensee ~
should be required to provide infomation concerning each activity proposed to enable preparation of a Staff safety evaluation and to permit an evaluation of
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non-radiological environmental it,. acts on
~ man and the environment, not only the dose infomation you propose to require.
s Ibelievethatthecorrectdatewas Z-3 (Sec. 2.1.2.1, second para., line 4)
' October 16, 1979, not " October 25, 1979.*
3-3 (fifth para.)
I believe that Peach Botton 1 is shutdown (pemanently) and possibly even decommis-stoned. This should be checked and changed if this is the case.
OFFICE h SURNAVE......
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DU.S. GOVERNMENT PRINTING OFFICE: 1979 289-369.
NQC FORM 318 (9 ~ 6) NRCM 0240
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Bernard Snyder 4-2 (Sec. 4.3.1, line 9)
Af ter " demonstrated," add: "and the use of the systcm approved."
5-7 (first line,'-
The basis for using the " administrative dose limit" should be explained at this point and.iot left for page 10-10 or Appendix L.
5-9 (Sec. 5.1.5.4)
The impact of the discharge of freon should include its local effects, if any, not only " global releases."
6-5 (Sec. 6.1.5)
If actual data are now available from the purging cperation, they should be included.
6-8 (next to last para.)
The " urgent" need for information is not supported sufficiently to justify the conclusion.
7-21 (Sec. 7.2.4.1, line 3)
Change " selected" to " approved"; only the latter is ;egally relevant.
9-6 (Sec. 9.1.2.1, second "99 CFR" s ould, I believe, be "49 CFR."
para., line 2) 9-12 (forth para., line 2)
The cite 1.2 "(45 CFR 7140)" should be checked.
(Sec. 9.4, second pers.)
The conclusion of no impact is at odds with Table S-4 to 10 CFR Part 51, WASH-1238 and the text of the PEIS itself, in Sec. 9.5.1.
10-22(Sec.10.6.1.6,last The meaning of the third effect, as sentence) stated, is not. clear.
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Other suggested corrections, of an editorial nature, are conta1ned c.) the marked up copy of the document, returned here ith.
Based on experience in connection with consents received regarding the venting environmental assessment, it may be desirable to state, in the Forward, that only comments of a non-proprietary nature which can be disclosed to the public should be submitted.-
Lawrence J. Chandler Attorney, OELD
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