ML20024E470

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Comments on Des (NUREG-0974).Draft Does Not Contain Worst Case Analysis of Accident & Effect on Environ Per Requirements of NEPA of 1969
ML20024E470
Person / Time
Site: Limerick  Constellation icon.png
Issue date: 08/09/1983
From: Doherty J
AFFILIATION NOT ASSIGNED
To: Rajender A
Office of Nuclear Reactor Regulation
References
RTR-NUREG-0974, RTR-NUREG-974 NUDOCS 8308150093
Download: ML20024E470 (2)


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1 August 9 , 1983 318 Summit Ave. #3 Brighton, Mass. G2135 Dr. Rajender Auluck, P. E.

Project Manager Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory. Commission Washington D. C. 20555

SUBJECT:

COMMENT ON NUREG-0974, DRAFT ENVIRONMENTAL IMPACT STATEMENT, PHILADELPHIA ELECTRIC CO., LIMERICK GENERATING STATION, UNITS 1 & 2, Docket No. 50-352, 50-353

Dear Dr. Auluck,

John F. Doherty, of 318 Summit Ave., Brighton, Mass-achusotts, conments as below on the DEIS:

4 COMMENT 1 The DEIS is deficient because it does not contain a worst case analysis of an accident and its effect on the environment, and an estimate of its probability, ag required by the National Environmental Policy Act of 1969, 89 2, et son., 102. A " worst case" analysis is not beyond the Etatutory minima of NEPA. (See: Sierra Club v. Sieler, 695 F 2d 957, 5th Cir.: 1983)

COMMENT 2 The DEIS fails to mention other serious cancer'and infant mortality impacts on human beings from tailings piles which must be. created to provide the fuel for the two Limerick atomic plants. Thus, at page C-6 "A single model K00-MWe LWR' operating at an 80%, it states capacity I

factor-for 30 years would be predicted to induce between j 3.3 and 5.7' cancer fatalities in 100 years, 5 7'and 17 in 500 years, and 36 and 60 in 1,000 years as a result

, of releases of radon-222." (This-does NOT refer to operation of the plants, it refers to Table C-4; oneration-of the plant does not create Radon as can be seen from Table D-1) l- Thus, the FES should contain additional imoacts from the fuel. cycle to fuel'a 1000 MWe unit which befall humans.-

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These would be: betwoon 3.5 and 5.7 non-fatal cancers in 100 years, G.7 to 17 in "00 7 ears and 36 and 60 in 1000 years as a result of relence of radon-222, from " stabilized tailinrs niles."

Also, since the amount of fatal birth defects impact is ecual to the fatal cancer iunact, there would be between 3 5 and 9.7 fatal Sirth defects in '03 years, 5.7 to 17 in GOO years and % and 60 in '000 rears as a result for release of radon-P?2 from "staMlized talin ~s 7iles. " And, since bhe fatal birth defects from these niles are believed to be ecual to the number of non-fatal birth defects, there would be between 3.5 and

" . 7 non-rntal birth defects in 100 years, 5.7 to ^7 in 500 years, and 36 to 60 in 1,003 years as a result of release of radon-222, from " stabilized tailings piles." (See: Testimony of Annen1 Bon-d Member Gotchy in Allens Creek CP nroceedinrs, Dr. Gotchy was with IiRC Staff at that tima.)

Waile it is nrobably likely a decrease in fatal cancers con be ex7ected over the course of the next 1,000 years, which would decrease this fuel cycle impact, orobably this is not true for the fatal birth defects. -

The DEIS should be modified such thst the FEIS rives fatal and non-fatal total ranges. "on-fatal cantars, fatal birth defects and non-fatal birth defects are significant impacts.

COM:'ENT 3 The ofrect or the transmission lines on migratory birds has evidently not been expl6 red or considered.

C O I 'E!!T 4 Poco D ' of the DEIS states, "For roun-er norsons, changes in or-an noss and metabolic narameters with a~e after the initial untake of radioactivity are accounted for." This would seem to indicate there accountine for the sex of the individual. While there are certain11 chan~es with age in adolescense for both sexes, the DEIS should iniicate if its asressment of dose takes in contamination of woman at construation when breast tissue cells are in ranid multinlication.

Tv ak you for the o~nortunity to comment.

I would like to roccive a copy of the planned sunnlement to this DEIG on the nrobabilistic risk assessment analysis of severe accidents. This is relevant to Comment 1, above.

John F. Doherty

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