ML20002E394

Comments on Des Suppl Re Facility Operation.Exposure Area of 500 Miles Is Not Required by NRC Policy Statement. Practically All health-related Exposures Would Occur within 50-mile Radius

ML20002E394
Person / Time
Site:	Summer
Issue date:	01/19/1981
From:	Bouchey G WASHINGTON PUBLIC POWER SUPPLY SYSTEM
To:	Office of Nuclear Reactor Regulation
References
RTR-NUREG-0534, RTR-NUREG-534 NUDOCS 8101270743
Download: ML20002E394 (1)

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Washington Public Power Supply System I A JOINT OPERATING AGENCY P.O. 80X v44 3000 GEO. WASHINGTON WAY filCHLANO. WASHINGTON 99352 PHONE (509) 372-5000 January 19, 1981 Docket No. 50-395 U.S. Nuclear Regulatory Comission 1717 H. Street N.W.

Washington, D.C. 20555 Attention: Director, Division of Licensing Gentlemen-

Subject:

Coments on Draft Environmental Statemeret Supplement

Reference:

Draft Environmental Statement Related to the Operation of Virgil C. Sumer Nuclear Station Unit No. 1, NUREG-0534 Supplement, November 1980 Based on our experience with previous NRC Environmental Statements, we suspect that the reference supplement may be prototypical of the environ-mental analysis the Comission Staff will prepare in other operating license cases. We, therefore, have reviewed the subject report and find that, while it generally complies with the NRC interim policy statement (45 FR 40101), it can be improved in a few areas.

Subsection 6.1.1.3 seems excessively brief, given the body of literature and public interest in radiation exposure health effects. This general discussion should relate pathways and individual organ doses to health effects. The susceptability of different age groups should also be dis-cussed.

The second sentence of the fourth paragraph of Subsection 6.1.4.1 should be deleted. The judgment that the health effects of design basis accidents are " exceedingly small" contributes nothing and invites debate.

In Subsection 6.1.4.2, we can find no explanation for considering environ-mental parameters out to 500 miles. Such a large exposure area is not required by the NRC policy statement. The projection of population and land use statistics for this area to year 2000 is not a useful exercise when the health-related expcsures would virtually all occur within a 50-mile radius (see Subsection 6.1.4.3). Such projections and the attendant assumptions only invite unproductive criticism.

Subsection 6.1.4.4 is weak in that the considerations employed to derive the economic costs in Ffgure 6.1.4.-6 are not explained. For instance, the reader doesn't know what uses of property or services are assumed to QC0b ho p 8101270 y

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U.S. Nuclear Regulatory Comisshn Page Two January 19, 1980 Coments on Draft Environmental Statement Supplement be foregone and for how long. (In this section, and in others, there is inadequate cross-referencing to other sections of the DES which provide thebasis.) Also not considered are the probable costs associated with forced outages of other units of similar design operated by SCE&G or other licensees (ala TMI-1).

Radiological impacts via the groundwater pathway, discussed in Subsection 6.1.4.5, are referenced to the " Liquid Pathway Generic Study" (LPGS) results. The reader doesn't really know what water sources are made unusable or whether the individual doses in Columbia and Charleston, South Carolina, and other comunities would exceed 40 CFR Part 141 standards. As presently written, the reader is told that the drinking water of upwards of 550,000 people "would be affected" without being given any basis for assessing the significance of the contamination. It is stated that the population doses for the liquid pathway from Sumer are the same order of magnitude as for the LPGS, but it would be more effective to provide the calculated doses.

Reference to the latest environmental crisis--acid rain--at the top of Page 6-20 seems patronizing. On the same page, the economic risks associated with cleanup and decontamination are inappropr'ately compared with individual plant insurance coverage.

In summary, the DES supplement appears to fulfill the intent of the Commission's policy statement and provides a generally good statement of environmental impacts due to accidents. The length and detail of the discussion in general seems appropriate for the uncertainties and assump-tions inherent in the subject matter.

Very truly yours,

^, fc c.. l~w G. D. Bouchey Nuclear Safety Dircrtcr shm cc: J. R. Lewis, BPA