ML20054G191

Forwards Comments on DES,NUREG-0894

ML20054G191
Person / Time
Site:	Skagit
Issue date:	06/12/1982
From:	Doherty J GULF COAST ENVIRONMENTAL DEFENSE FOUNDATION, INC.
To:	NRC
References
RTR-NUREG-0894, RTR-NUREG-894 NUDOCS 8206210235
Download: ML20054G191 (5)

Text

,

Director 6-12-82 Div.

USNRCof Site Safety * & Environmental Analysis Washington D.'C. 20555

Dear Sir:

Attached are 7 comments on NUREG-0894, Skagit/Hanford DES.

John F. Doherty gol GCEDF Inc.

8206210235 820612 PDR D ADOCK 05000522 PDR e -

1 0 5 GCEDF COMIIEliTS ON THE DRAPI EINIRONMENTAL STATEMENT (NUREG-0890 FOR THE SKAGIT/HANFOR NUCLEAR PROJECT, DOCKET UO. STN 50-522 & 523 ,

The Gulf Coast Environmental Defense Foundation Inc.,

of 4327 Alconbury Lane, Houston, Texas 77021, incoroorated under the laws of the State of Texas, comment as follows on the DES:

GC@F COMMF,NT 1 Site suitability for the several candidate' sites 7 1n Gection 3.2 of the DRAFT may be influenced by further ac-tivity of Mt. St. Helans volcano through ash deposition on cooling water sources and cooling towers. The DES should consider this factor by.consid9 ring sites where past activity have had no influence and comparing them with those that have been oreviously effected by such ash.

GCEDF COMF1EHT 2 The DES is inadequate because it does not deal with an item on P. I-20 of the subject document, which is part of a DOE document on the Land Sale of Hanford Reservation prop-erty to Puget Sound Power and Licht. There, it states,

" Based on evaluations made for the WPPSG reactors, it is unlikely that olant construction or operation at the ref-orence site would affect buried radioactive wastes on the Hanford site." (Emohasis supplied) Section 4.2.3.1 of the DES does not mention any effect on buried waste at Han-1 ford throur,h hydrology, but all the Anaendix I DOE Report

-ives for :uidance is that it is "unlikely", which could nean a broad range of things in probability terms. The FES shauld discuss this DOE brought up possibility, and give more nrocise probability terms or explain why it can be no more orecisc than the DOE report.

j' R [l 2.

GOEDF I'nc. Comments -

t GCEDF Comment 3 / ,s In Appendix C, the following statement (p. C-6) occurs:  ;

"To illustrate: A' single madel 1000-MWe LWR operatin6 at an l

' 80% capacity factor for_30 ' years would be predicted to in' duce ,between 3.3 a.id 5 7 cancer fatalitics in 100 years, 5.7 and 17 in 500 years, and 36 and 60 in 1000 years as a result of releases of radon-222., To this fuel cycle imoact description, the following other impacts should be determined i

and added:

A) The rance of number of fatal birth defects induced by fuel cycle radon-222, f or 6ach Skagit/Hanford unit at its projected capacity factor andefor :the . licensing 0 period.;under consideration when construction is completed (i.e. 40 years) for 100, 500, and 1,000 years.

B) The range of number of non-fatal birth defects induced by fuel cycle radon-222, for each Skagit/Hanford unit at its orajected canacity factor and for the licensing period under consideration when construction is completed'(i.e.,L40: years) for 100, 500 and 1,000 years.

C) The range of number of non-fatal cancers induced by fuel cycle radon-E22, for each Skagit/Hanford' unit at its pro-jected canacity factor and for the licensing period under considerstion when construction is completed (i.e., 40 years) for 100, 500 and 1,000 years.

GCEDF COMMENT 4 IN Anpendix E of the DRAFT, the Staff points out (p. E-1) that the use of of the MARCH and CORRAL code produced lower estimates of predicted iodine for nany of the dominant accident senuences. The DES is inadequate with regard to this use of MARCH because it does not say there are Freat reservations on the use of MARCH code. In the minutes of the ACRS Class 9 Accidents Subcommittee Meeting of May 21-22, 1981 (NRC Accession Humber 8108280372) several members pointed out these deficiencies.

GCEDF Inc., Comments 3 GCEDF Comment 4 (Contin.)

One member of the subcommittee indicated MARCH misuses classical heat transfer ecuations. A Brookhaven Scientist nointed out the code does not have predictive capability for core melt behavior,,another pointed out 100 limitations of MARCH have been identified in a code evaluation program to be comoiled by Gandia Laboratory.

GCEDF Comment 5 With regard to the use of the CORRAL code mentioned on page E-1 of the DRAFT, the DRAIT needs to indicate which CORiML code wan used. According to Dr. Kerr of the Advisory Committee on Reactor Safeguards, this code had not been vali-dated one year ago, althourS it was published. (See: Minutes of the ACRS Class 9 Accidents Subcommittee Meeting of May 21-22, 1981, URC Accession Humber 8108280372 where this is stated.)

GCEDF Comment 6 The DES has (on p. 4-199) not given a complete picture of the releases of radioactivity from the March 28, 1979 accident at Three Mile Island. The environmental consultants for Metropolitan Edison Company, Pickard, Lowe, and Garrick estimated 10 million curies of noble gases were released in the first three days of the TMI accident, in a study titled:

" Assessment of0ffsite Radiation Doses from the Three Mile Island Unit 2 Accident, TDR-TMI-116", and dated July 31, 1979, ,

This is considerably more than "a few million" as in NUREG/

CR-1250, Vol. 1. The Pickard, Lowe and Garrick measurmalts may also be more accurate because they used calculations based on measurements made in the auxillary building and fuel bandling buildings and uced a cronortion to determine the releases from the plant stack. Other determinations did not do this and hnd no measurements because stack monitors went off-scale.

Therefore, the discussion on previous accident releases should be modified to include the ran6e of estimates of releases.

s

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CCEDF Inc. Comments 4 GCEDF Comment 7 The Staff Conclusions in Sec. 3.2.2,1, "Adcouncy of Reconaissance Level Information", are' inadequate because they are based on its" general knowledge of the Region of Interest."The NRC is required to make a full, good faith consideration and balancing of environmental fac-

. tors in reaching a citing decision. (Environmental Defense Fund, Inc. v. Corp'.s of Engineers,470 F.2d 1029,1042, 8th Cir. 1972) Here it appears the staff's knowledge is set down too little, (even for the shallow, reconnaisance level requiremonta at this stage) to reach the conclusion o cite is environmentally preferable to the proposed (Hanford) site. Thus, the deficiencies in information noted should be remedied before a conclusion by Staff.

Thank you for the opportunity to comment.

Sincerely, uJohn;,$F. hy!tk,T O'

Doherty (for GCEDF Inc.)

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