ML20054G315

Comments on Des (NUREG-0894).DES Inadequate Re Effect of Plant Const on Buried Waste at Hanford,Use of March & Corral Codes,Releases of Radioactivity from 790328 TMI-2 Accident & Conclusions in Section 3.2.2.1

ML20054G315
Person / Time
Site:	Skagit
Issue date:	06/15/1982
From:	Doherty J AFFILIATION NOT ASSIGNED, DOHERTY, J.F.
To:	NRC
References
RTR-NUREG-0894, RTR-NUREG-894 NUDOCS 8206210420
Download: ML20054G315 (4)

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GCEDF , m, sw COMMEliTS ON THE DRAPI ENVIROIEIEUTAL STATEMENT (NUREG-0894)_ _

FOR THE SKAGIT/1IAUFOR NUCLSAR PROJECT, DOCKET N0. STN 50-522 & 523 The Gulf Coast Environmental Defense Foundation Inc.,

of ^327 Alconbury Lane, Houston, Texas 77021, incoroorated under the laws of the State of Texas, comment as follows on the DES:

GCEDF COMM6MT 1 Site suitability for the several candidate sites in' Ssction 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.considering sites where nast activitf have bad no influence and comparing them aith those that have been oreviously effected by such ash.

GCEDF COMiiEUT 2 The DEG 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-ert:7 to Furet Sound Power and Licht. There, it states,

" Based on ovaluations made for the WPPCG reactors, it is unlikely that olant construction or operation at the ref-erence site would affect buried radioactive wastes on the Hanford site." (Emohasis supplied) Section u.2.3.1 of the DES does not mention any effect on buried waste at Han-ford through h:/drology, but all the Annendix I DOE Report

ives for uidance is that it is "unlikely", which could mean a broad range of things in probability terms. The FES ggo C)$).

should discuss this DOE brought up possibility, and give mare nrecise probability terms or explain why it can be na more orecisc than the DOE report.

8206210420 820617 PDR ADOCK 05000522 n pna

w GCEDF Inc. Cram'nts 2. .

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

"To illustrate: A single model 1000-MWe LWR operating at:an 80% capacity factor for 30 years would be predicted to.

induce between 3.3 and 5 7 cancer fathlities in 100 years,'

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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 impact description, the following other impacts should be. determined ,

and added:

A) The range of number of fatal birth defects, induced by fuel cycle radon-222, f or-bach Skagit/Hanford unit at its projected capacity factor Landrfor:thetlicensingr periodaunder consideration when construction is' completed,(i.e. 40 years)

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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/Han'for4 unit at its projected capacity factor and for the licensing period under consideration when construction is completedf(i.e.,J40: years) for 100, 500 and 1,000 years.

C) The range of number of non-fatal cancers induced by fuel cycle radon-222, for each Skagit/Hanford unit at its pro-jected capacity 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 many of the dominant accident sequences. The DES is inadequate with regard to this use of MARCH because it does not say there are great reservations on the use of MARCH code. In the minutes of the ACRS Cla'ss 9 Accidents Subcommittee Meeting of May 21-22, 1981 (NRC Accession Number 8108280372) several members pointed out these deficiencies.

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

One member of the' subcommittee indicated MARCH misus,es classical heat transfer equations. A Brookhaven Scientist pointed 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 compiled by Sandia Laboratory.

GCEDF Comment 5 With regard to "the use of the CORRAL code mentioned on page E-1 of the DRAFT, the DRAFT needs to indicate which CORRAL code was used. According to Dr. Kerr of the Advisory Committee on Reactor Safeguards, this code had not been vali-dated one year ago, although it was published. (See: Minutes of the ACRS Class 9 Accidents Subcommittee Meeting of May 21-22, 1981, NRC Accession Number 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 measurmel ts 1 may also be more accurate because they used calculations based I on measurements made in the auxillary building and fuel handling buildings and used a proportion to determine the releases from the plant stack. Other determinations did not do this and had no measurements because stack monitors went off-scale.

Therefore, the discussion on previous accident releases should )

be modified to include the range of estimates of releases.

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GCEDP Inc. Comments 4.

GCEDF Comment 7 The Staff Conclusions in Sec. 3.2.2.1, " Adequacy of Reconaissance Level Information", are".inddequate 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 siting decision.,(Environmental Defense Fund, Inc. v. Corpos 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 requirements at this stage, to reach the conclusion no site 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, ha t oJohn F. Doherty (for GCEDF Inc.)

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