ML20008G267

Comments on Des for Facilities.Solid Radwaste Treatment Sys Should Be Considered as Addition to Summary List of Outstanding Issues.Fes & Supporting Documents Should Be Strengthened in Noted Areas

ML20008G267
Person / Time
Site:	Comanche Peak
Issue date:	06/30/1981
From:	Phillips F ENVIRONMENTAL PROTECTION AGENCY
To:	Miraglia F Office of Nuclear Reactor Regulation
References
NUDOCS 8107070224
Download: ML20008G267 (6)

Text

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l jos I I UNITED STATES1201REGION ENVIRONMENTAL VI PROTECTION l AGEQ[ ]

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DALLAS, TEXAS 75270 , g,i June 30, 1981 / J 8 ; J u l L ) h\

Mr. Frank J. Miraglia 5L JUL 0 _._ 61981* 4 -

Acting Chief, Licensing Branch No. 3 U.S. Nuclear Regulatory Commission c3 u.s.Wp j /

Washington, D.C. 20555 A (*

Dear Mr. Miraglia:

We have completed our review of the Draft Environmental Impact Statement (EIS) related to the operation of the Comanche Peak Steam Electric Station, Units 1 and 2 (Docket Nos. 50-445 and 50-446), located on Squaw Creek Reservoir in Somervell County about 40 miles southwest of Fort Worth, Texas. The proposed action is to issue an operating license for the start up and operation of both units. These units are being built by the Texas Utilities Generating Company and are scheduled for commercial operation in 1982 and 1984.

The following comments are provided for your consideration when preparing the Final EIS:

RADI01OGICAL ASPECTS Generic Comments In our past reviews of Draft EIS's related to light-water nuclear power facilities, we have included generic comments which are applicable to all such facilities. As a result of the Three Mile Island accident and other recent activitias, we have decided that we must revise our generic comments to consider these events and activities. We will provide our revised generic comments to the Nuclear Regulatory Commission (NRC) as soon as they are completed.

Generic areas undergoing review are:

O Population dose commitments Reactor accidents Fuel cycle and long-term dose assessments High-level radioactive waste management Transportation impacts Decommissioning Radioactive Waste Treatment Systems The Draft EIS does not contain detailed descriptions of the radio-active waste treatment systems or the NRC staff's detailed evalua-tions. Such matters are referenced to the Safety Evaluation Report (SER), which has not yet been issued. On request, however, we were supplied an advance copy of draft sections ca the ventilation and radioactive waste treatmert systems. We appreciate being supplied this information.

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i The applicant has made extensive modifications to the liquid ,

gaseous , and solid radioactive waste treatment systems since we last reviewed them. It appears that these systems are capable of controlling emissions to levels such that, when direct radiation is also considered, operations will be within EPA's Environmental

- Radiation Standards, 40 CFR 190. However, the pre-draft parts of the SER which we were provided indicate that the NRC staff judges the solid radioactive waste system to be unacceptable, and also the high level noble gas effluent provisions and analysis of liquid storage w tank failure are still undergoing review.

I k- We believe the Final EIS should include an evaluation and full discussion of any ongoing review items which are not resolved by 1- the time it is issued. We also suggest the solid radwaste treat-6 ment system be considered as an addition to the Summary list of

% outstanding issues on page iv.

Reactor Accidents l

<- When discussing accident risk and impacts of d* sign basis accidents, the Draft EIS addresses probabilities of occurrence qualitatively.

j Yet, when discussing more severe core melt accidents, the probabili-Wg ties of occurrence are quantified (Table 5.19). For consistency in the presentation of all environmental risks, we believe the proba-l bilities of occurrence of infrequent accidents and limiting fault design basis accidents should also be provided.

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l Timing of Supporting Documentation for the EIS The practice of issuing the Draft EIS in advance of the SER has prevented our performing a complete review of the environmental impacts of the Comanche Peak station. As discussed in our comments on radioactive waste treatment systems, we were provided advance copies of draft SER sections on those systems, so the problem was alleviated, although we do not consider this pre-draft information to be formal documentation. Also, the Draft EIS refers to several other important areas which are still under NRC review. These include:

i- 1. Site features. The authority of the applicant to control all activities within the exclusion area is still under NRC staff review and will be addressed in the SER or in a supplement. Off-l g3 site hazards, including those from nearby industrial and military l

facilities, pipelines, air transportation, waterways, and rail-I ways are judged by the NRC staff to be acceptably low. A more l . detailed discussion of site features is referenced to the SER.

l 12. Facility safety features. Reference is made to the forthcoming p SER for the NRC staff evaluation of safety features and characteristics of the facilities and description of some of the accident mitigation features.

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3. Emergency preparedness. Factitty emergency plans and State l and local plans are reported to be in an advanced, but not yet fully completed stage. NRC staff findings of adequacy and h implementability, for both the on-site and off-site plans, have not yet been finalized. Also, the required upgrading of emergency planning has not been evaluated for its environ-

- mental impact, 7 4 Operational Radiological Monitoring. The applicant's proposed y *j program is still being evaluated and the details of the l required program will be incorporated in the license technical specifications.

'- In view of the above, the conclusion stated in Section 5.16.3 l regarding the station's acceptable environmental impact, would seem to be contingent on favorable results from some important ongoing staff reviews, and hence premature. The Final EIS should be

! withheld until the above-mentioned reviews are completed, or should

( p specifically evaluate any of the areas which are still undergoing review.

We urge the NRC to ensure that, in the future, the Safety Evaluation Report is available before issuing the Draft EIS. Material incor-gorated into an EIS by reference should be reasonably available for inspection within the time allowed for comment (40 CFR 1502.21).

We do not believe the citations of missing but forthcoming informa-tion in the SER constitutes a " reference" in the common meaning of

i. that word.

Decomi ssioning F The Draft EIS states that planning for decommissioning can affect health and safety as well as cost, and that financial assurance that funds will be available, when required, is a factor to be considered. We concur in this assessment, but were unable to find in the Draft EIS arrangements for financing decommissioning costs.

N Although decommissioning costs are noted to be less than 10 percent of present worth comissioning costs, this is still quite a large sum and will represent a large cost burden when needed, if not accumulated out of revenues during the plant's operating lifetime.

The Final EIS should explain what specific arrangements have been made, or are planned, to assure that funds will be available when required.

In this connection, it is not clear at wnat point the licensee's paI financial responsibility is to be terminated. Termination of the ,

nuclear license is required at the end of facility life, and this l

requires decontamination of the facility such that unrestricted use l can be allowed. Although the applicant's present plans call for

immediate dismantlement at the end of the station's economic l operating life, one option to achieve such decontamination is l SAFSTOR, which allows deferral of decontamination for up to 100 l

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years. It is not clear, in such a case, whether license termination would occur prior to or at the end of such an extended storage M period. If termination a curs at the beginning of the storage period, financial arrangements evidently will be necessary to pay for the deferred decontamination. The Final EIS should clarify this point.

Economic Risks 1

- As the Three Mile Island accident demonstrated, the cost of reactor building decontamination and replacement power following an accident can be sizable. This underscores the need to develop standard methodologies for estimating the contribution of these costs to economic risks. Economic risks are addressed in considerable detail (go in Section 5.8.2.4 of the Draft EIS under Station Accidents and, based on low probability of occurrence, annualized risk is shown to I be modest. Because of the potentially* severe economic costs.

I however, we believe these risks should be mentioned explicitly in l , the benefit-cost summary, Section 5.16.

Additional Radiological Comments l

,- 1. The statement on page 5-38 that a dose greater than about 25 l rems over a short period of time is necessary before any l physiological effects are clinically detectable, should be yll reviewed. Information contained in the World Health Organiza-l tion technical report No.123 would seem to indicate that l _

physiological changes can occur at exposures as icw as 10 rems.

~ 2. The calculated annual release of iodine-131 in gaseous effluents is given as 0.062 C1/ unit in Table 5.11. In Table 5.6, however, yN it is listed as 0.0076. This discrepancy should be corrected j ,

in the Final EIS, or explained.

I NON-RADIOLOGICAL ASPECTS Groundwater l r 1. As indicated in the Draft EIS, groundwater resources are being " mined" in the vicinity of the steam electric station.

Groundwater withdrawal to operate the facility would contribute l to lowering area groundwater levels. We therefore support the staff recommendation, on page 5-6, that a condition be YI3 included in the operating license to restrict groundwater use. Groundwater should be used to supplement surface water l

only for potable and sanitary purposes and only when produc-tion from the water treatment plant is insufficient to meet

. demand.

" 2. If hazardous wastes will be discharged to the evaporation pond, gg monitor wells should be drilled in agreement with Resource and Conservation and Recovery Act regulations to detect migration

[. of contaminants into groundwater.

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5 Water Intake Structure The makeup water intake structure in I.ake Grandbury has been approved by EPA under the provisions of Section 316(b) of the Clean

'g 15 Water Act. The EIS would be strengthened if the EPA approval was included in Section 5.5.2.4 where the water fatake is discussed.

NPDES Permit Requirements

- On page 5-9 it is stated that the maximum total residual chlorine concentration of 0.5 mg/l in the discharge circulating water will satisfy the NPDES permit. The Final EIS should state that the Federal effluent limitations of the NPDES permit for chlorine are gb 0.2 mg/l daily average and 0.5 mg/l daily maximum for free available chlorine.

In view of the information provided and our comments on the Draft EIS, we classify the proposed project action as ER-2 (Environmental Reserva-tions, Insufficient Information). We ask that the Final EIS and support-ing documents be strengthened in the areas our preceding detailed comments have identified.

Our rating is based on our evaluation of the EIS, advance copies of pre-draft SER sections and other important areas which are still under-going NRC review as discussed earlier. We reserve the right to change our rating if published information is substantially changed from what we have reviewed. Our classification will be published in the Federal 1

Register according to our responsibility to inform the public of our j views on proposed Federal actions, under Section 309 of the Clean Air Act.

Definitions of the categories are provided on the enclosure. Our procedure is to categorize the EIS on both the environmental conse-quences of the proposed action and on the adequacy of the EIS at the draft stage, whenever possible.

We appreciated the opportunity to review the Draft EIS. Please send our office five (5) copies of the Final EIS at the same time it is sent to the Office of Federal Activities, U.S. Environmental Protection Agency, i

Washington, D.C.

i Sincerely, fLpd Frances E. Phillips Acting Regional Administrator Enclosure i

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'. ENV:RC 2 ENTAL IMPACT OF THE ACTION

- LO - Lack of Objections .

EPA h'as no objections to the proposed action as described in the draft impact statement; or suggests only minor changes in the proposed action.

ER - Environmental Reservations -

EPA has reservations concerning the environmental effects of certain aspects of the proposed action. EPA believes that further study of  ;

suggested alternatives or modifications is required and has asked the ,

originating Federal agency to re-assess these aspects. '

EU - Environmentally Unsatisfactory EPA believes that the proposed action is unsatisfactory because of its potentially harmful effect on the environment. Furthermore, the Agency believes that the potential safeguards which might x utilized may not ,

adequately protect the environ =ent from hazards arising from this action. '

The Agency recer:= ends that alternatives to the action be analyzed further (including the possibility of no action at all).

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ADEOUACY OF THE IMPACT STATEMENT Catecory 1 - Adecuate -

l Tne draft impact statement adequately sets forth the environmental impact of the proposed project or action as well as alternatives reasonably available to the project or action.

4 Catecorv 2 - Insufficient Infor :ation EPA believes the draft impact statement does not contain sufficient I information to assess fully the environmentti ivoact of the proposed project or action. However, from the infr - %:ics submitted, the Agency is able to make a preliminary d @ W.' rc:sn of the impact i on the environment. EPA has request x L: At le originator provide '

the information that was not includt; ;is N ft statement.

Cate2ory 3 - Inadecuate EPA believes that the draft impact statament does not adequately assess the environmental impact of the proposed project or action, or that the statement inadequately analyzes reasonably avai3jule ,

alternatives. Tne Agency has requested more information and ar. clysis concerning the potential environmental hazards and has asked that substantial revision be made to the i. pact statement. If a draft statement is assicned a Category 3, no r ating will be made of the project or action, since a basis does not generally exist on wnich to make a determination.

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Licensing Branch No.1 Division of Licensing o'/

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Washington, D.C. 20555 Re: DEIS - Comanche Peak Steam g Electric Station, Units 1 & 2

Dear Mr. Youngblood:

i We hava received and reviewed the document referenced above. Pursuant to Section 102(02)(c) of the National Environmental Policy Act of 1960 the above referenced document doee rot contain a sufficient level of information to allow review of tae cultural resources. Our office does not i have copies of the archeological investigations mentioned on 4/21/81.

We request copies of reports concerning the cultural resources of the project area so we can complete review.

Sincerely, Truett Latimer  :

State Historic Preservation Officer by tt &tu/ I i

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LaVerne Herrington, Ph.D. l Director i Resource Conservation i i

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Ir. Chase R. Stenhens Docketing & Gervice Branch U. 3. Nuclear Re-ulat: ry Coca.

.lashington D. C. 20:#5 RE: CCIEENT CU D.t.FT 2: VIRO:..:.2:C.'.~. I:..'A02 22ATEMI..T (OP.2ATILG LICE: 3E) CG'J:ANCHE PEAK GTE1.li ILIC2RIO .i2.^.Clc'i.3 1 & 2,

• NUREG-0775, Docket "o. 50 h45 and P.b456. 1 To whom it may concern:

Below, I offor my c.ost,ents on the 23:ve dor.:.":en:. I am an Interveninl: 7 arty in the 1._lton: Groek c e atr:: .; L : tir.cnne nroceedings and have cm' aonted on other .'20 ir. cued ';.;IS' ,

~2.ulena' tings , and other ~.!RC ,u -li.. inmut omoruu.:i cio .- I amr? cicte this o"pertunity as well.

Cor. ment Doherty 1

_ On ucce "-F:1 of the Draft, the discuscion of the i.nount l'

of crotection given :roundwater y_various 8.i'rientone fornations under the niants' paeninzula and Muaw Creek. deseM:ir does not indicate that a thor.urh exec.instian was dono f:r Old well holes for either wat.cr, naturcl gas or oil. i%i.c would also mean canned holes which may have been ahorted (in the case of water wells) before re ch8.n; the acuifer) but obviously '

would reduce the level of conCidence in the Staff's -inding on breach of containment by e. .*lten fuel scsr,.

Coccent Dohertv 2 .

In Sec. 5.S.2.2 (Pa;e 5 1.:0) the last sentance ,:akes a bald assertion with regard to safety. It is ispassible to be sure what " kind of ac :ident" the author (s) had in mind here. Do the author (s) assert fuel cannot overheat in the

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CPSES7 Com=ent Doherty 3 .

On page 7-1 you list, ' ' . . . l&:NCI53, CRGAnIZ:.TIGU3, AND .

PERSONS REQUFETED TO COMi4ENT ON TEE DRAFT. . .", but none of these are critics of nuclear cower ner se,. 'dhile I : resume Intervenors received copies, it makes ce wonder that URO is

• not comfortable under close scrutiny from gr:ups and indi-viduals who are concerned and are familiar ;ith aspects of the project, and are no re'spectors of beaureaucratic smooth-ness. The project recort chould have been sent to such groups as the Commanche . Peak Life Force.

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Comment Deh_erty 4 In Gee. '2 5 (Diversity or 1uel Gun ly (p. 2-s) 3:cfr zakes the unsupoorted statenant thet diversite cf fuel may be a need

-to justify the OFGSS. The need is unaqucatifinble, and certainly -

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. belongs in no cost benefit analysis. '!ould staff cung: t the i id'ea that a peat noss plant should te built, "rocar11ess of the econonics 3f (that) energy verrus ener y from other cources" if the peat cane f: m Ireland? It is a venh arsunent '

based on the coal miners strike of <977 as heavily prenagan-dized by those who profit from nuclent ontorprise. Here it is uncritically accepted. Sec. 2.3 should be eliminated.

Comment Loherty 5 Table 2.1 on page 2-3 chould be revised to chow ;as in

.cne colunn and oil in another in order to reflect the true

• consumption of these different fuels. This is also beccuse natural gas and oil are quite different in assessing 67tentisl,  !

because oil is the product on which our national trcns'ortation system is based. This fact, has male the ns. tion moro e neerned

.about oil consuction where the bo'ief con 9rall/ is t':ct there .

is a continual danger of sh:rtage, e locron of hist ry.T77ically -

utilities in Te::as are run ing peak londinr on cas niants and usin~g oil as little as oossible, which I ather is r2flected in foot note 2 to Table 2.1. In the F23 it would be desirable to see how much oil consumption (if any),can be reduced b.7 the oDeration of t'ne CPSS3.

Conment_ _Doherty 6 ~

On page iv, in part 5. a. o r the "su.2 mary and Co.:clusions" ,

(and evidently in the text as well), Gtaff has not at e-eted .

to qualify the fact that a base loaded nuclear plant cannot by itself replace power of peak loading plants , luo to the in-ability of li-ht water reactors to load follow. Again (Gee -

Concent Doherty 4, suora) Staff c.apears to be taking a rosy view of the CPSES instead of a critical one, which draws it to shallow conclusions. CFSES will replace licnite (and perhanc coal) units of TUGCO, but not peak loading plants. ..s sur:Cested in " Comment Doherty 5" improving -Table 2.1 may illuninete this -

, connon but unwisely held-belief that such replaconent is direct. .

. C_omment Doherty 7

.See. 4 3 6.2 " Recreational Uses" and Gua.ary item 5. b.,

cre too varue for inclusion here. E! hat possible meaninr$n canno  !

be construed from this except a " benefit"? However, wi -

I nore than this, Staff should have not included sention of any . I recreational benefits,as it is by no neans certain au crtificial imeoundment can provide a benefit since there is ther ct Icading '

fron the condensor. '

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CommentDohert[8 In attenpting to compare Gec. n.3.6.1, " Demo; ra7hy" of the Draf t to pace 5-M of the FES for the l'roposed plants, one is boggled tryIng to compare cercenta.gos and absolute numbers.

This Sec. of the Draft. should narenthetically croress all cor-centages in numbers. Percontages lose sir.2ificahce in small nagnitude countings such as for Soncrvell Count r.

Co= lent Doherte 9,,

Has Staff been pro.ne-ted with e".y en'l i.:ntion _'r : urve.7 as to how the staying on phe'io e .on was :icced in the original FES? , One is to-.stod to believe cone 'zcrkers b:pe to gain Occcisional work at the plant cs at refuelin.:. or refittinc-times, but did anyone attempt assessT.cnt? (The "ntevinte on phenomenon" is discussed in Soc. 4.3.1.1 af c':o Drnft, Comment Dohertv 10 Giving consumptive vet."- lons in n 3/secnnd an on pe.ge v, in Conclusion S. d., is abeurd . I got 2,555,00-) e. t :rs cube:1 ner year, which is.more meaningful. F.rhe's tTe. 1ne.1 5 Otctenont can use more meaningful u.iits t' san the are.it.

In cor.clusion, I . ould sa7 there ia ca.1rldera51e 1,oceness in the Draft. I hope I hsys e.,i.toi eut sone of the core is-portant inatcnces. I would hapa :.t:ff o' 1d locato o :3ers and make similar alteretions. .

Thank you for the opw rtunity to eco ent.

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$[fhjg. .y)'fY County Courthouse Post Office Box 851 Phone: 817-897-2322 N M) Glen Rose, Texas 76043 i-July 6, 1981 k h 'jh$[89 t -m

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8 Mr. Spottswood Burwell \ . tp 5' 5 *

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Office of Nuclear Reactor Regulation 'O(g U.S. Nuc1 car Regulatory Commission Washington, D.C. 20555 Q-

Dear Sir:

Re: Solid Waste, Radioactive (ll.5.8 Environmenta1 Statement June 1974)

With regard to the radioactive solid wastes materials ,

which will be generated at the Commanche Peak Steam Electric Station (CPSES), located in Somervell County, Texas, we wish to object to the statement as shown in the subject data. The statement will be found on page 0 C-155 of the Draft Envormomental Statement, May 1981 (NUREG-0775).

Prior to the issuance of the operating license for this plant, we feel that the question of " disposal" of nuclear waste must be finally and firmly settled. It is not in the best interest of the general population of the area or the plant employees to allow this part of our County to become a " Temporary Waste Disposal Site." Temporary some-times becomes permanent. The citizens of Somervell County object to even the possibility that the CPSES would be used as a burial site - permanent or te=porary.

The question of nuclear waste d'sposal must be firmly decided by Texas law before any fuel loading, operations of generating or licensing begin at the plant.

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w I request that this letter and the objection it conveys be placed in the record and be favorable considered during your upcoming hearings.

Sincerely,

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George R. Crump County Judge GRC:lw I

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CITIZENS FOR FAIR UTILITY REGULATION (CFUR) / ' ~- m%

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U.S. Nuclear Regulatory Comission p Washington, D. C. 20555 f,b, s Re: NUREG-0775 DEIS Comanche Peak Dear Sir CFUR would like to take this opportunity to cement on the two sections of the DEIS that it has examined in detail.

PURPOSE AND NEED FOR THIS ACTION 1-

1) Table 2.3 presents capacity Resources, Peak-Hour Denands, and Reserve Margins for TUCS. 'the last paragraph on page 2-6 indicates that differing

crojections of demand growth exist. Nevertheless, the NPu Staff has chosen to oresent outdated data in Table 2.3.

The foilMng figure presents a concilation of projected denands for TUCS obtained by adding together the seoerate denand orojections of each TUCS sister comoany from their nost recent rate increase requests to the Texas Publie Utility Comission. As can be noted, these conbined demand crojections are consistently lower than that oresented in the DEIS. By 4I sinoly adding the seperate projections, it is cresumed that the individual comoanies demand crojections are coincident - a situation not necessaril<

true and which tends to overstate the denand projections.

TUCS PEAK DEMAND PROJECTIONS (MW)

Year TESCO TFL DPL TC*AL 1981 4280 5620 2850 12,750 1982 hh95 5910 2950 13,355 1 - Docket 3250 June, 1980 1983 4715 6220 3050 13.c85 2 - Docket 3780 Mar. ,1981

! 198h 4945 6560 3150 14,655 3- n t 3460 Sect., 1980

1985 5185 6940 15,375 3250 1986 5435 7320 3350 16,105 Substitution of these demand crojections in Table 2.3 yields the following reserve nargins (%).

WITH CCMANCHE PEAK NITHCUT CCMANCHE PEAK 1981 40.8 40.8 i 1982 41.9 34.1 1983 35.3 27.9 C.CO3 i 198h 35.0 20.9 .f 1985 36.6 23.1 1986 33.3 20.5 f g 9107170259 810713 PDR ADOCK 05000 D =

2-C?UR rocceanends that the NRC Staff obtain projections for TUCS made in 1981 to include in the EIS published in 1981.

g 2) Table 2.2 presents the TUCS Projected Annual Fuel Costs through 1986.

6 The estimated increase in Fuel Price ($/10 BTU) from 1979 to 1986 is 178%

i for Lignite and 96% for nuclear fuel. No substantiation for this projection is sucolied. Lignite (and/or coal) is the more abundant fuel in the.U;S..

7 l There is a great deal of uncertainty about the supoly of U.S. uranium I (Lieberman, "U.S. Uranium Resources - An Analysis of Historical Data",

i Science, April 30, 1976 and Letters in Science, May 6, 1976). Some measure I of independent substantiatien would seem to be in order.

! On page 2-2, the following amoears: "The applicant states that by 1990 r

! it will have fully exoloited the lignite deoosits of central and eastern i k Texas.'"Turthur fossil-fuel exoansion beyond 1990 will have to be based

l on coal." Yet the amolicant has attemnted to sell a lignite facility to 1 Houston Lighting and Power and has just succeeded in selling water from Lake Fork in Zact Texas (imoonnded for the puroose of const meting a lignite facility) to the City of Dallas while retaining ^tture cotions on part of i the water rights.

The applicant has purchased a large quantity of coal deposits in New

Mexico and has announced prelininary plans for a large coal facility located in Texas near the New Mexico border. In addition, the applicant is engaged 4

in a vigorous development program in an attemot to utilize gas produced in 1

deeo-basin lignite deposits in central and eastern Texas.

For these reasons, it acpears unreasonable for the staff to conclude

that the replacenent of any energy not oroduced by CPSES Units 1 and 2 i through 1990 would have to come from lignite and gas in about a 50

50 crocortion, j If there is any basis for this conclusion, it has materialized through default

! of alternatives until such tine that a remedy is me practical - not because l of any overriding need to construct Cemanche Peak.

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PROCMALISTIC ASSISSME!"" O' SE75REACCIEENTS and CCSI AND L .TH 'yPACTS P 1) Table 5.20 oresents a Su==ary of Invironmental Incaets and Probabilities.

I Footncte (a) states that there is only a 30-year period over which latent Cancer

, Fatalities might occur. It is not clear from the text whether this 30-year 3 period is an age or disease related oeriod or whether it is the eroected i

period of operation of Comanche Peak (the license request is for 60 years).

Clarificati:n would be helpful.

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2) Table 5.20 indicates that 2,800/2,800 Latent Cancer fatalities occur

.* ' ,10-0 probability level. Footnote (b) states that this number (2,800) sh related to thyroid cancer fatalities only and that cancer fatalities of all other organs do not contribute. An examination of Figure 5.6 (upon which gg the table relies) indicates that the graph for Latent Caheer Fatalities excluding Thyroid has not been extended to intersect with the 10~0 probability coordinate. C NR is not aware of any physical phenomena which prohibits this from being done. It appears to CFUR that the conclusion that only latent Thyroid Cancer Fatalities exist at the 10~0 probability level is not correct

_ and should be corrected.

3) CNR has additional reservations concerning this section but will rely on the intervention process to resolve them. -

Sincerely, SL1d$L Richard L. Fouke 4

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TEXAS UTILITIES GENERATING COMPAM sooi .nrw 2cw a +um.rax= = ' # 363 F

fyk.;, July 13,1981 R N Mr. Darrell G. Eisenhut Director,. Division of Licensing h' S U.S. Nuc' lear Regulatory Commission Washington, D.C. 20555 a t  ?

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SUBJECT:

COMANCHE PEAK STEAM tELECTRIC STATION DOCKET NOS. 50-445 AND 50-446 bf'/agt ,

APPLICANTS COMMENTS ON DRAFT -

ENVIRONMENTAL STATEPINT

Dear Mr. Eisenhut:

We have reviewed the Draft Environmental Statement (DES) related to the operation of Comanche Peak Steam Electric Station (CPSES) dated May, 1981. Our opinion is that this statement is a reasonable evaluation of the environmental impact of the operation of CPSES. 'ie offer the comments below which we believe should be considered in the preparation of the Final Environmental Statement.

COMMENTS r 1. On page vi of the DES item 9.C. states "The applicant shall be required to restrict the use of ground water for CPSES operat: ion to that amount needed for potable and sanitary purposes and for supplementing the supply of treated surface rater during short periods of peak demand when the station reluirements exceed the capacity of the reverse-osmosis-surface-water-tru.tment plant."

We agree with this requirement but propose the changed wording 41 below to expressly address the situation of routine or unplanned outage of the reverse-osmosis-surface-water treatment plant. The new wording should be: "The applicant shall be required to restrict the use of groundwater for CPSES operation to that 1 amount needed for potable and sanitary purposes and for supplementing the supply of t nated surface water during short periods when the station requirements excet 2 the capacity of the reverse-osmosis-surface-water-treatment plant because of peak demand or treatment plant outage.

2. On page 4-9 of the DES it states that the disposal method for 4 *L potasstun chromate is offsite disposal. It should be noted that

{ the CPSES design also permits disposal to the evaporation ponds.

3. On page 4-18 of the DES it states that "The appliant will monitor g the aquatic biota and selected other resource of SCR once the s

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PDR ADOCK 05000445 D PDR

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n .tation is in operation (ER-OL, ,cendment 1, response to staff question 65)." The response t: question 65 says: "There are no plans on the part of the ap91' cant at this time to monitor and manage the aquatic resources of Squaw Creek Reservoir. The right and responsibility for this function is the sole jurisdiction of the State of Texas. In the event that the Texas Parks and

4) Wildlife Department elects to delegate the authority for reservoir management to the Applicant, a suitable program will be developed for review by the appropriate agencies." The applicant has not received any indication from the State of Texas that it

. intends to delegate this authority. We therefore have no plans

% to monitor aquatic biota in SCR.

i 3- 4. Section 5.8.1.2 projects occupational doses at CPSES as much as 1300 person-rem /yr per unit averaged over the life of the statfor. We question the appropriateness of such a large dose for the following reasons:

a. It is based on a unique circumstance, causing a three times O larger than average dose, (steam generator replacement) for h which CPSES is designed to avoid.

b. It assigns this type of event to both units 1 and 2. CPSES units 1 and 2 do not have identical steam generators.

c. The resultant health effects estimates are unrealisticly large because very cuaservative risk estimators (1972 BEIR report) are multip'f ed by an unrealistic dose.

Again, the above comments are offered for consideration in the preparation of the Final Environn. ental Statement. Overall we believe that the DES is a reasonable assessment of the environmental effects of the operation of CPSES.

4 Sincerely,

.l R J. Gary i RJG:grr l

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68 - 4 :5~M',',

1. DEPARTMENT OF HEALTH 86 HUMAN SERVICES Public H:dth Servica

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' Food and_ Drug Administration f Food and Drug AdministratMn - j Rockville MD 20857 L JUL 141981

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'Mr. B. J. Youngblod.. Chief f.S Licensing Branch No. 1 it

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Division of Licensing - NRR U.S. Nuclear Regulatory Commission M f fh

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Washirgton, D.C. 20555 ~1 /w //'

Dear Mr. Youngblood:

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Staff of the Bureau of Radiological Health of the Food and Drug Administration have reviewed the health aspects of the Draf t Environmental Statement (DES) for the Comanche Peak Steam Electric Station, Units 1 and 2, NUREG-0775, May 1981 In reviewing the DES related to the operation of the Comanche Peak facility, it is recognized that this is an administrative action for the issuance of an operating license. DHHS comments sure provided on the Draf t DES - Construction Phase, in April 1974, (Appendix D-4-5, pages C191-192), prior to issuance of the construction permit in December 1974. We note that as of December 30, 1980, the

. construction of Comanche Peak, Unit 1, was 87 percent complete, and Unit 2 was about 50 percent complete. Thus, Bureau of Radiological Health staff have re-evaluated the health aspects associated with proposed operation of the plant, and have the following comments to offer:

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1. It appears that the design objectives of 10 CFR 50, Appendix I, and the l

proposed operating plan of the Comanche Peak facility provide adequate assurance that the potential individual and population radiation doses meet current radia-tion protection st ndards.

11 pathways identified in Section 5.8.1 and discussed in

! 2. The environ._

l Appendix C of the F' - Construction Phase, pages C-101-105, give all possible *

! .enission pathways th t could impact on the population in the environs of the facility. The dose computational methodology and models used in the estimation of radiation doses to individuals near the plant and to populations within 80 km.

of the plant have provided the means to calculate a reasonable esti= ate of the doses resulting from nor=al operations and accident situations at the f acility.

Results of these calculations are shown in Tables 5.9, 5.10, 5.11, and 5.12 and confirm the above ass essment.

We note that the annual dose commitment to the thyroid of a child through milk ingestion from the nearest dairy herd is expected to be 0.21 mres per year per unit. This dose has been revised downward from the estimate of 4.4 mrem per year, as reflected in our c.om=ents on page C-191.

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- .. 1 Page 2 - Mr. B. J. Youngblood, NRC 1- 3. The discussion in Section 5.8.2 on the environmental impact of postulated radiological accidents is considered to be an adequate assessment of the radia-tion exposure pathways and the dose and health impacts of _ atmospheric releases.

I However, we believe the emergency preparedness section is not adequate. We will forego further comment on this aspect, realizing that the process of granting an Mk operating licen ,e to the facility will include an adequate review of emergency preparedness (/EfA-NRC Memorandum of Understanding, Regional RAC's, criteria in NUREG 0654). We have representation on the RAC's whose evaluation of the

, emergency planning relevant to Comanche Peak will speak %r this agency.

The lessons learned from the accident at Three Mile Island - Unit 2, on March 28, 1979, should receive more attention in this bG. It would be helpful if the accident section could be expanded to 1.iclude a brief presentation of the critical public health and safety actions that the bRC has taken or plans to take to improve reactor safety and to mitigate the consequences of potential gg accidents. Such a discussion would provide an important amplification of this

% section of the DES, and would significantly increase public confidence and under-standing of the implementation of the measures that the NRC has undertaken.

The discussion in the first paragraph, page 5-42, is a possible introduction to y the proposed section.

In view of the problems encountered in measuring the releases of radio-l active materials at the Three Mile Island-2 reactor site, we believe that the emergency preparedness plan should contain specific information on the adequacy j

of radiation measuring instruments to be installed to detect the specific radio-nuclides in the vide range of concentrations expected from potential accidents, 1.e. , stack and containment monitors , and of f-cite direct radiation measuring t 3 devices. We suggest that the plan might be modified to address in particular l the problem of monitoring radiohalogens (especially radioiodines) in the presence of radionoble gases. This could be accomplished by reference to FD!A-REP-2, a document on instrumentation systems prepared with considerable input l ,. frem NRC.

4. The operational monitoring program for each facility is planned to be a continuation of the preoperational program. It appears that the program will provide adequate sampling and analysis of environmental meais for specific radio-nuclides that will be required to measure the extent of emissions from the plant and to verify that such emissions meet applicable radiation protection standards.

l 5 Section 5.8.3 contains discussion of the uranium fuel cycle. The envi-ronme teal ef fects presented are a reasonable assessment of the population dose commi vant and the health effects associated with releases of Raden-222 from the UFC.

Thank : ou for the opportunity to review and comment on this draf t document.

Sincerely yours,

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x John C. 7111forth f Director 1 Bureau of ladiological Health 1

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l 104 Davey Laboratory The Penni State Univ.

Univetsit/ Park Pa., 16302 13 July 1981 # os Director, Division of Licensing 4 -

U.S. Nuclear Regulatory Commission '

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Washington, D.C. 3 k [

20555

Dear Director:

k'f,M N y Attached are my comments on the Draft Environmental Statement en the operation of the Comanche Feak Station, Units 1 and 2, NUREG-0775. Please note that the opinions and claculations are my own, and not necessarily those of the Pennsylvania State University, which affiliation is given for identification purposes only.

I should note that I recuested a copy of the Draft from .

Document Control on 23 June, but did not receive it until 10 July.

It is inconsistant to see the discussion of accidents in section 5.8.2 without the kind of peer review that the NRC admitted was necessary as related to WASH-14CO in its January 18, 1979 statement: "NRC Statement on the Risk Assessment and the Reactor Safety Study Report in light of the Risk Assessment Review Rrouc Report" ( Page 3).

I hope these comments are useful in developing the Final EIS rec,uired by lEPA.

Sincerely, h'Y& $E '

W.A. Loch:.tet, Ph.D.

C.OO 3

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The Leat Term Health Chnsequences of Cedanche Peak, Units 1 and 2 by William A. Lechstet The Pennsylvania State University

• July 1981 The Nuclear Regulatory Commission ( NRC) has attempted to evaluate the health consequences of the operation of the Comanche Peak Steam Electric Station, Units 1 and '., in its Draft EIS, NUREG-0775. The health consequences of the raden-222 released from the mill tailings and the open pit mines are evaluated for the first 1000 years from the present in section 5.8.3.

This evaluation suggests that the raden releases will increase with time, and gives ne suggestien that they will decrease or step after 1000 years. There is no reason to stop at 1000 years.

In fact, these raden releases are governed by the 80,000 year half life of thorium-230 and the 4.5 billion year half life of uranium-238. The therian situation has been discussed by Pohl (Search, 7(5), 345-350, August 1976). The impact of radon from the uranium-238 was recognized in GESMO (NUREG-0CO2), (1976) and is discussed in the Final Environmental Statement for the Split Rock Mill ( NUREG-G639, at pages A-57 to A-50) . The result is that the activity necessary to supply one 1000 MWe plant at 80%

capacity factor with fuel for one year, leaves behind uranium mill tailings that are estimated to cause 200,0C0 deaths due to re 2a-222 e=issions. This is much more thanz the consequences listed in the Draft, NUREG-0775.

• The opinions and calculations presented here are my wwn and l not necessarily hhese of the Pennsylvania State University, i My affiliation is given here for identification purposes only. ,

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ENCLOSURE 2 Comanche Feak DES Coment Response Assignments Commenter Comment No. Branch Assignment for Response Jon R. Davis 6/14 Davis 1 RAB(Pasciak)

Davis 2 ETSB(Boegli)

Joshua Hirsch 6/17 Hirsch 1 RAB (Pasciak)

Hirsch 2 RAB/AEC (Pasciak/Thadani)

George Crump 6/24 ANL (Denise; SAB-Kaltman)

USEPA Region VI 6/30 EPA 1 ETSB (Boegli)

EPA 2 AEB(Thadani)

EPA 3 SAB (Sinisgalli)

EPA 4 LPM EPA 5 EPLB(Kantor) -

FPA 6 RAB (Pasciak)

EPA 7 LPM EPA 8 ANL (Bush; UFB Feld)

EPA 9 ANL (Bush; UFB Feld) l-EPA 10 ANL(Bush;UFBFeld) l EPA 11 AEB (Thadani)

! EPA 12 AEB (Thadani)

L EPA 13 HGEB (Gonzales)

EPA 14 ANL (Harris; EEB Lehr) l EPA 15 ANL (Stearner: EEB Hickey) ,

EPA 16 ANL (Harris; EEB Lehr)

Texas Historical Com.

7/3 SAB (Bykoski)

John F. Doherty 7/4 Doherty 1 SAS/HGEB (Sinisgalli/Gonzales)

Doherty 2 AEB (Thadani)

Doherty 3 LPM l Doherty 4 ANL (Eush; UFB Feld) l Doherty 5 ANL (Bush; UFB Feld)

Doherty 6 ANL (Bush; UFB Feld)

Doherty 7 ANL (Stearner/Ocnise; IAB Kaltman)

Doherty 8 ANL (Denise; SAB Kaltman)

Doherty 9 ANL (Denise; SAB Kaltman)

Doherty 10 LPM George Crump 7/6 ETSB(Boegli)

Citizens for Fair CFUR 1 ANL (Bush: UFB Feld)

Utility Regulation CFUR 2 ANL(Bush;UFBFeld)

(CFUR) 7/13 CFUR 3 AEB(Thadani)

CFUR 4 AEB(Thadani)

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Enclosura 2- -

2-l Connenter Comment No. Branch Assignment'for Response Texas Utilities Generating Company 7/13

. TUGC0 1 HGEB (Gonzales) ,

i TUGC0 2 ANL (Harris; EEB Lehr) l i TUGC0 3 ANL.(Stearner;EEBHickey) l TUGC0 4 RAB(Pasciak)

U. S. Department of Health and Human Services Food and Drug Administration 7/14 FDA 1 EPLB (Kantor)

FDA 2 AEB(Thadani) l FDA 3' RAB (Pasciak) >

l W. A. Lochstet 7/13 , RAB(Pasciak)

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