ML20054L513

Exhorts NRC to Suppl 1977 Fes.Myriad Changes & New Data Compel Need for Suppl.If Fes Is Not Updated,Nrdc & Sierra Club Will Sue Nrc.Minor Delay Will Obviate time-consuming Litigation

ML20054L513
Person / Time
Site:	Clinch River
Issue date:	07/01/1982
From:	Cochran T, Finamore B, Weiss E HARMON & WEISS, National Resources Defense Council, Sierra Club
To:	Ahearne J, Asselstine J, Gilinsky V, Palladino N, Pallodino N, Roberts T NRC COMMISSION (OCM)
References
NUDOCS 8207080197
Download: ML20054L513 (67)

Text

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Natural Resources Defense Council,Inc.

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SUITE 600 WASIIINGTON, D.C. 2000 6 8 202 223-8210 l'ndd New York o@ce IVestern o$ce a t t E A S T .j t N D ST R E E T 25 KEARNY STREET N Ew voa x, N.Y.10168 S A N FR ANCISCO, C A E.I F. 0 4 8 08 )

at: 919-0049 July 1, 1982 45428-66: 5 The Honorable Nunzio Palladino U.S. Nuclear Regulatory Commission D00F2T !!UCZ2 Wasbington, DC 20555 P:;02.L UT!L Fl.0.hh .53.7...

Victor Gilinsky, Commissicner U.S. Nuclear Regulatory Commission Washington, DC 20555 Jonn F. Ahearne, Commissioner U.S. Nuclear Regulatory Commission Washington, DC 20555 Thomas M. Roberts, Commissioner U.S. Nuclear Regulatory Commission Washington, DC 20555 James K. Asselstine, Commissioner U.S. Nuclear Regula tory Commission Washington, DC 20555

Dear Commissioners:

We are writing on behalf of tne Natural Resources Defense Council, Inc. (NRDC) and the Sierra CluD to express our views regarding the NRC's legal and etnical responsiDility under the National Environmental Policy Act, 4 2 U.S .C. $43 21 et sea.

(1976) (NEPA' , to supplement the 1977 Clinch River Breeder Reactor Plant (CRBR) Final Environmental Statement (FES) to address significant new information, changes in circumstances, and changes in the pro]ect wnich have arisen since the CRBR was deferred in 1977. We also wish to remind you that this supplemental EIS must be circulated for comment by agencies and New England Office: 7 Eute oRive

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2 the interested public as required by NEPA, the Council on i Environmental Quality regulations, and the NRC's own requirements.

This letter is a f ollow-up to recent informal discussions with Dr. Harold Denton, members of the Office of Executive Leoal Director, and NRDC representatives. Our continued concern arises from the fact that some members of the NRC Staff apparently believe the Staff can exempt itself from Council on Environmental Quality (CEQ) regulations governing environmental impact statement preparation despite the existence ot i

substantial changes and new information bearing on the Clinch River project. As the attached memorandum of law snows, h o weve r , this interpreta' tion of the applicable la w is selt-serving and clearly incorrect. See Attacnment A.

NRDC is at a loss to understand why these members of your staff are showing an almost reflexive resistance to our request that the FES be supplemented before it is introduced as evidence in the upcoming LWA-I proceeding. Several tactors demonstrate way such resistance is not in the best interest of the public. First, the ager.cy owes it to tne public to evaluate the environmental, health.and safety risks posed by the CRBR using the most recent and reliable inf ormation. Its i

role is not to promote tne development of breeder reactors, but to regulate and license tnem to protect tne public from a headlong rush into an inadequately evaluated tecnnology.

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3 Second, more than five years have passed since President Carter, expressing concern over the proliferation risks or plutonium production and recycle technology, indefinitely deferred domestic programs, including the licensing ot the CRBR, which presented unacceptable dangers to public health and national security. Tne current administration has chosen to ignore these risks and has resumed CRBR licensing activities.

However, no reasonable argument can be made that the changed circumstances and new information gained during the five year hiatus, as well as substantial cnanges mace in the project since 1977, do not warrant careful reevaluation by both the NRC and the public before any decision to license the CRBR can responsibly be made.

The following sections discuss a few of the numerous changes and new information af fecting the environmental impact of the CRBR project. Tnis list is not all-inclusive, and NRDC does not expect the NRC to limit its evaluation to this list. It is the NRC's continuing responsibility to gather and evaluate information relevant to the environmental impact of proposed federal actions.d!

J/ Warm Springs Dam Task Force v. Gribble, (621 F. 2d 10 17, 1023 (9th Cir. 1980).

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, A. Substantial Changas in the CRBR Project

. Although licensing of the CRBR Project was deterred in 1977, design work has continued unabated during the last five years. As a result, the Department of Energy, TVA, and the l

Project Management Corporation (" Applicants") have made substantial changes in the Clinch River reactor design and other aspects of the project which are noscere reflected in the 1977 FES. These changes directly a f fect tne environmental .

impact of the proposed project, particularly the effects of CRBR accidents, and must therefore be analyzed in a j supplemental EIS.

In response to NRCs request, the Applicants have submitted a 30-page table listing all the changes to the project since 1977 that have potential environmental impacts.

i (See Appendix B.) Applicants have discussec each of these l changes in amendments to their 4-volume Environmental Report, which forms the basis for the NRC's environmental impact statement. In this 30-page table, even the Applicants, not tne most objective of participants, have been forced to admit that several of these project enanges would have aaverse environmental ef fects. And in reviewing this list of changes and impacts, independent NRC consultants at Los Alamos National

Laboratory have concluded:

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We believe the possible numoer of design

l. changes could be greater than given by the

DOE in Attachment 2. The list of design

5 changes given by the DOE should not be assumed to be complete and the DOE conclusion of " positive effect or no impact" of the design changes snould not be assumed correct.

Letter from E. W. Barts, Los Alamos National Laboratory, to Mr.

B. Morris, CRBR Project Office, NRC, dated December 18, 1981 (re: Engineering Analysis, WX-8-4544 (R644) (emphasis added) .

This list alone should compel the conclusion that the project as it is proposed today bears very little relationship to the one analyzed Dy the NRC in tne 1977 FES. One example should suf fice, however, to demonstrate the enormous potential environmental impact of these changes.

1. Change in the CRBR Core Design.

One substantial change which DOE and the other Applicants admit would have an adverse environmental impact is the change in the CRBR core design from a homogeneous to a heterogeneous core. The Applicants note that the new core design would necessitate a revised refueling schedule and an increase in shipments of spent fuel by 50%. (See Appendix B, p. 12.)

Similarly 50% more shipments of fresh CRBR fuel, which is directly nuclear weapons usable, will presumably be required.

Applicants admit that this increase would be environmentally adverse, and indeed, no reasonable argument can be made that the potential effect of transporting and handling such highly radioactive wastes would not be significantly adverse. Yet this is not the only potential environmental impact of the heterogeneous core design.

6 As the NRC staf f has recently explained to the Advicory Committee on Reactor Safety, CRBR Subcommittee, the probability and consequences of core disruptive accidents, or explosions, is one of the most hotly debated subjects in the reactor technical community, and the issue has not yet been resolved oy the NRC Staff. (See Transcript of ACRS CRBR Subcommittee Meeting, May 5, 1982.) A core disruptive accident ("CDA")

constitutes one of the most severe potential environmental impacts caused by the Clinch River breeder reactor, and as such must be discussed in the NBC impact statement. Yet, the potential for a core disruptive accident is directly dependent on the core design. (See Transcript, supra and attached vugraphs.) And, as shown below, Applicants' changes to that core design have severely af fected the NRC's analysis of core disruptive accidents, and significantly increases the uncertainty surrounding the environmental impacts associated with potential CRBR accidents.

For example, NRC consultants at Argonne National Laboratory performed a comparative analysis in May 1977 of the CRBR homogeneous core and the so-called "parf ait" or heterogeneous core. Henninger, et al. , An Analysis of Selected Transient Undercooling Accidents Without Scram For the Clincn River Breeder With a Parfait Core, Argonne National Laboratory, Reactor Analysis and Safety Division, May 1977 (ANL/ RAS 77-16). This report concluded that "several aspects of these design differences have the potential for causing the behavior

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I of the two cores to differ significantly under TUC [ transient undercooling} HCDA conditions." Id. p. 4. A Brookhaven National Laboratory report agreed that:

This change [in CRBR core design] causes substantial variation in key reactivity feedback parameters. Computations of these parameters are more complex and subject to larger variation / uncertainties than for their counterparts in homogenous core design.

Bari, et al. , Review of the Status of CRBR Licensing Technical Issues Related to Heat Removal System and Severe Accident Analysis, Brookhaven National Laboratory, Dept. of Nuclear Energy, November 19 81, Section 2. l( a) . See also Reactor and Structural Systems Analysis for CRBR Licensing,

[ Final Report for Task 1 and Task 2], Los Alamos National Laboratory, Jan. 1982.

According to these reports, three national laboratories agree that the change in CRBR core design is not only substantial but also introduces large uncertair ties into NRC's ability to predict the accident potential (i.e., environmental e f f ects) of the CRBR project. Furthermore, the NRC staf f has repeatedly stated that its own analysis of the CRBR design and its accident potential will not be completed until June 1983.

In a recent deposition taken by NRDC of the NRC Staf f, the Staff admitted tnat they have not even reached any preliminary i

or tentative conclusions in their CRBR accident analysis (Transcript of Deposition of NRC Staf f, May 6, 1982).

Because the Staf f has not concluded its safecy review, it cannot predict with confidence that the substantial changes in

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! CRBR's design will not have adverse environmental ef fects. It ,

must therefore supplement its impact statement to take these changes into account, and in particular, must discuss the uncertainties brought about by the new design. See Natural Resources Defense Council, Inc. v. NRC, F.2d , No l

74-1586 'O.C. Cir. Apr. 27, 1982).

i B. Significant New Information and Changes In Circumstances Bearing on tne CRBR Project In addition to the 30-page list of changes in the CRBR l project itseJf, a veritab1'. avalanche of significant new i

information and changes.in circumstances relevant to the Clincn I

River project or its environmental impact have arisen since the FES was published. Eaco new circumstance or piece of information alone is sufficient to warrant a FES supplement, but together they absolutely preclude any other course of 1

action.

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1. Environmental Impacts of CRBR Waste i

Disposal -- The Table S-3 Decision.

The most important change of circumstances- is the D.C.

! Circuit Court of Appeals' recent decision in NRDC v. NRC, I

F.2d , No. 74-1586 (D.C. Cir. Apr. 27, 1982). In that case the court invalidated NRC's so-called " Table S-3 rule," which, i inter alia, purported to list the environmental effects of t reprocessing and disposal of high level nuclear waste. NRC had l

9 developed the generic Table S-3 for inclusion in environmental impact statements on individual nuclear plants and for use by Licensing Boards in their NEPA cost / benefit analyses.

The D.C. Court of Appeals invalidated the Table S-3 rule as arbitrary and capricious, and "a blatant violation of NEPA" (slip op. at 46) . Tne court held that the rule must explicitly 1

deal with the uncertainties inherent in the assumption that no radiological ef fluents wi]1 be released into the environment once wastes are sealed in a permanent repository.

It is abundantly clear that the CRBR impact statement must be supplemented as a result of the decision in NRDC v. NRC.

The radioactive wastes produced by CRBR plutonium fuel would be at least as toxic, if no't more so, as those produced in l ligh t-water reactors, (see, e.g., slip op. at 3-46 ( Ed wards ,

J., concurring)). Realizing that waste disposal ef fects must

! be considered in the CRBR FES, NRC included Appenoix D, Tables 2 and 3, which are scaled-down versions of Table S-3. Tables 2 and 3 rely upon the same background documents as Taole S-3, (see FES Appendix D, Section 2.a) characterize the impacts of long-term waste disposal as " insignificant," and fail to discuss the uncertainties in the estimates of radiological j impacts. These tables therefore suf fer f rom tne same

infirmities as the Table S-3 rule, and must be revised in a supplemental statement.

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2. Three Mile Island Accident The second area of significant new information and changes in circumstances relevant to the environmental ef fects of the Clinch River Breeder Reactor is the implications of the 1979 accident at Three Mile Island Unit 2. Based on the lessons learned f rom that accident, the NRC has issued the NRC Action Plan Developed as a Result of the TMI-2 Accident (NUREG-0660)

(Aug. 1980); the Identification of New Unresolved Safety Issues Relating to Nuclear Power Plants (NUREG-07 05) (Ma rch 1981); and Licensing Requirements f or Pending Applicantions f or Construction Permits and Manuf acturing License (NUREG-0718, Rev. 1) (June 1981) . Several reports on tne TMI-2 accident have also been issued, most n'otably the Report of the President 's Commission on the Accident at Three Mile Island (Oct. 1979).

These analyses of new information gained from TMI-2 regarding the probability and causes of reactor accidents must be f actored into all future reactor licensing proceedings, including the Clinch River project. In particular, an analysis of the ways in which human error can initiate, exacerbate, or interfere with the mitigation of accidents is of crucial importance to any discussion of the environmental impacts of an accident at Clinch River.S! The NRC must use this information, not only to supplement its discussion of core disruptive accidents (CDAs) as Class 9 accidents, 2/ The Report of the Reactor Safety Research Review Group (Sept. 1981) states that most studies of the likely causes of serious accidents conclude through probabilistic risk analysis that over 50s of tne risk is associated with human f ailure to perform as indicated.

Il but also to reevaluate whether CDAs are suf ficiently probable as to be considered in the FES as Class 8 accidents. To ignore the substantial vedy of TMI-2 information or to argue that sucn informa-tion is not s ignifica n t would make a mockery of the NEPA process.

3. Critiques of the Reactor Safety Study Report (WASH-1400)

The CRBR FES safety analysis must also be reviewed and modified because of its reliance on the draf t of the Reactor Safety Study Report, commonly called WASH-1400. This study, published in draft in August 1974 and in final form in October 1975, has been harshly critiqued and portions of it have been discredited. A Risk Assessment Review Group Report pointed to numerous shortcomings in'the WASH-1400 report, in particular the Executive Summary, and found that the report "may have been used prematurely as an estimate of the absolute risk of reactor accidents without full realization of the wide band of uncertainties involved. Such use snould be discouraged." Risk Assessment Review Group Report to the U.S. Nuclear Regulatory Commission, NUREG/CR-0400, p. x.

As a result of this report the Commission expressly withdrew "any explicit or implicit past endorsement of the Executive Summary" and further concluded that "in light of tne Review Group conclusions on accident probabilities, the Commission does not regard as reliable the Reactor Safety Study's numerical estimate of the overall~ risk of reactor accident." NRC Statement of Risk Assessment and the Reactor Safety Study Report (WASH-1400) in Light of the Risk Assessment Review Group Report, January 18, 1979.

12 If the WASH-1400 study is now considered unreliable, even in part, then clearly an impact statement analysis which expressly relies upon it must itself be considered unreliable. Tne discussion in the CRBR FES of accidents beyond the design basis expressly relies upon WASH-1400 for its conclusions that most LWR core melt accidents do not lead to early containment failure (FES Section 7.13). Based on this conclusion, the Staff required that the CRBR containment system must maintain integrity for 24 nours following a CDA in order to ensure CRBR safety at a level comparable to LWRs. Id. This Staff requirement, and tne entire discussion of Class 9 accidents, must now be reevaluated in light of the defects in WASH-1400, since the probability of early

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containment f ailure may be much greater than previously estimated. Without such a reevaluation, there is no guarantee whatsoever that the CRBR will be made as safe as a light water reactor, or that the environmental impacts will be comparable.2!

4. Aternative Sites ,

It is well established that the discussion of alternatives to the proposed action is " absolutely essential" to toe NEPA 3/ The basis for many of the Staff's conclusions in the FES is the concept that CRBR risks are or can be made comparable to those associated with LWRs. NRDC is not prepared to encorse tnis concept, particularly since we do not believe that the Staff has any meaningful measure of either the overall risks of LWRs or of the CRBR, nor has the Staf f even attempted to document that

" comparability" has been achieved. Nonetheless, since

" comparability" is the touchstone of this portion of the FES, we accept the concept for purposes of this argument.

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13 process. Natural Resoures Defense Council, Inc. v. Calloway 524 F.2d 79 (2d. Cir. 1975). The Commission has held that a discussion of alternative sites both within and outside of the Tennessee Valley Authority service area is relevant to the CRBR proceeding and must be included in the CRBR FES. In the Matter of United States Energy Research and Development Administration, f'

Project Management Corporation, Tennessee Valley Authority (Clinch River Breeder Reactor Plant), CLI-76-13, 4 N RC 67 3

(1976). The 1977 FES analysis of alternative sites must be supplemented to take into account several potential sites that l have recently become available, such as TVA Hartsville, Yellow Creek, and WPPSS-4 in Hanford, Washington. NRC must also reanalyze the desirability of alternative sites in light of new NRC policy favoring remote reactor siting.

On July 29, 1980, NRC published an advance notice of rulemaxing on toe revision of reactor siting criteria. 45 Fed.

Reg. 50350. The notice pointed out (ibid,):

Events during the past year, including the events at the Three Mile Island Nuclear l Station, have made the NRC, the Congress,

and the public increasingly concerned that past siting practice may not af ford suf ficient protection to the public healta

and safety. Considering revision of NRC siting policy using the Task Force's recommendations is, therefore, particularly ,

relevant at this time.

The NRC recently articulated its intent "to re-emphasize the desirability of site isolation * * *," Id. at 50351.

Moreover, new emergency planning regulations have been promulgated. 45 Fed. Reg. 55402, Augus t 19, 1980. In l

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addition, the Office of Nuclear Reactor Regulation has

, issued ,A Report of the Siting Policy Tusk Force (NUREG-0625) i

which recommends numerous enanges to NRC policy on nuclear power reactor siting. See also NRC, A Comparison of Site Evaluation Methods, (NUREG/CR-1684) (July 19 8 3) ; and the proposed rule regarding the review of alternative sites under NEPA, 45 Fed. Reg. 24168, April 9, 1980.

1 The siting decisions for the Clinch River project will thus have to be reevaluated in light of new information including siting criteria which are in the process of being developed. This is particularly essential because it has been acknowledged that the Clinch River site is not the best alternative, f rom tne sfandpoint of public health and safety, even using the criteria applicable in 1977. In the CRBR FES , pp. 9-22 to 9-23, the NRC Staff admits that radiological exposure at alternative sites would be significantly lower--by as much as a f actor of 10--than a t Clinch River, and tnat alternative sites would offer a relative advantage with regard to accidental releases of radioactivity. Nonethelass, because of the 1986 decision date then thought to be controlling, the Clinch River site was approved. Clearly, now that this deadline does not exist, and the criteria for siting are being revised to provide greater protection to the public, the decision as to the site of the Clinch River plant must be totally reconsidered.

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5. New Information on Radiological Healtn ,

i Two significant pieces or new inf ormation bearing on the potential consequences of CRBR accidents and the environmental impacts on nearby residents are the 1 '

publication of the Recommendations of the International s

Commission on Radiological Protection (Jan. 17, 1977) (ICRP i

i Publication 26) (and related reports); and the Environmental.

l Protection Agency (EPA) " Proposed Guidance on Dose Limits for Persons Exposed to Transuranium Elements in the General Environment.A! The ICRP 26 Report recommends a new methodology for establishing dose equivalent limits for combined internal and external radiation exposures.

The NRC Staf f did not utilize this approach in its 1977s 4

CRBR Site Suitability Report. In updating tnis Site -

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3 Suitability Report in May 1982, (NUREG 0786), the Staff has endorsed the ICRP 26 methodology (p. III-9) but has failed  !

to apply it properly and f ailed to consider the alternative method of applica tion recommended by the EPA. The proper l application of the ICRP 26 (or EPA) approach, including the i recommended use of separate organ dose limits to prevent non-stochastic ef fects, .would have significant bearing on

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NRC's calculations of the potential radiological impacts of l

J CRBR accidents on those living near the CRBR site.

! t 4/ EPA 520/4-77-016, September 1977.

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Similarly,. EPA;has recently propoted guidelines for the 4 \5 reduction of potential nealth impacts fhom future unplanned releases of plutonium und transuranium elements as might occur, for example, in an accident at the CRBR plant. This proposed l

guidance is in the form of limits on long and bone dose s ,

> 's l associated with exposure to transuranium elements in the t 2

general environraent. ' These limits are considerably lower than

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those currently being' utilized to assess the potential j i radiological impacts of the CRBR. The NRC is obligated under <

NEPA to examine the implications of using the proposed EPA dose s ,,

limitsfortransuraniumelementexposureand/or(toexplaintne basis for the Staff's failure to consider separate. control -

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measures for limiting land contamination from transuranic k l

elements with long radiological half-lives.

s 6. Changes in Safeguards Regulations The 1977 FES contains a detailed discussion of the proposed 1

safeguards measures to be employed by Applicants to prevent the 4 )

thef t or diversion of special nuclear materials and the sabotage i

' of the CPBR or its fuel cycle f acilities. ThissFES section must f

be completely redone since the protective safeguards requirements

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applicable to 'the CRBR and ' fuel cycle f acil'ities in 1977 have been completely superseded by new NRC regulations. 10 CFR 3 7 3. 55, 4

" Requirements for Physical Protection of Licensed Activities in

. Nuclear Power Reactors Against Radiological Sabotage." Tne new I

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17 regulations will result in a complete overhaul of the licensing ,

inspection, and enforcement requirements imposed on the CRBR plant, as well as the measures employed by Applicants for personnel screening, physical security organization, physical barriers, access requirements, detection aids, response requirements, testing and maintenance. Id.

The Atomic Safety and Licensing Board has held thac "an evaluation of the potential cost of safeguarding the CRBR, fuel cycle f acilities and transportation. supports should be included in the NEPA cost-benefit analysis." In the Matter of Project Management Corporation, Tennessee Valley Authority (Clinch River Breeder Plant) , LBP-76-14, 3 NRC 430, 435 (1976). If the new safeguards regulations a're in f act more stringent than the previous requirements, then the cost of additional personnel, eq u ipment , etc. must be included in the FES and factored into the 1

cost-benefit analysis. If the regulations are less stringent in some respects, then the additional risks to the public of thef t or sabotage must also be evaluated. NRC may not avoid assessing the costs and impacts of CRBR's safeguards system and making the results of that analysis available f or public comment by blithely characterizing these changes as an " improvement" over the previous system.5/

5/ The NRC Staf f has admitted that the FES discussion of CRBR safeguards must be revised. See, e.g. NRC S taf f 's ans wer s to i Natural Resources De1%nse Council, Inc. and the Sierra Club Twenty-Fou rth Se t of Inter rogatories to S taf f , pp. 10-13.

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7. Endangered Species Since the 1977 FES was issued, the U.S. Fish and Wildlife Service has notified the NRC that eleven species of freshwater mussels f rom the f amily Unionidae and one species of fish from the family Cyprinidae, each federally listed as threatened or endangered, may be present in the Clinch River near the proposed CRBR site. And, in fact, the March 1982 Survey of the Clinch River by the Applicants discovered one mossel specimen of Lampsilis Orbiculata, an endangered species, a t Clinch River Mile 19.1. Clincn River Breeder Reactor Plant Site Preparation Activities Report, June 1982, Section 2.6.2.1. This species is hypersensitive to increased radioactive and other effluent levels, and would also be affected by increased thermal levels and sedimentation from dredging and barging.

The 1977 FES states only that "no species designated as rare or endangered by any governmental agency were collected or observed in the baseline ecological survey performed from March 1974 through January 1975." FES p. 2-17. This FES must be revised to discuss the implications of the proposed construction and operation of the CRBE on the endangered mussels, and any mitigating measures proposed by Applicants.

Such discussion is required by both NEPA and the Endangered Species Act of 1973, 16 U.S.C. 3 1531 et sea.

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8. Cost-Benefit Analysis Finally, the cost-benefit analysis presented in section 10.4 of the FES is hopelessly out of date, and could not by any stretch of the imagination serve as an adequate basis for decisionmaking by the Licensing Board or the public. The estimated project cost of $1.95 billion has increased over 80%

to a new of ficial estimate of at least $3.5 billion (Final Environmental Impact Statement (Supplement to ERDA-1535, Dec.

1975) on the Liquid Metal Fast Breeder Reactor Program, DOE /EIS-0085-FS (May 1982)). The estimated $1.5 million capital costs and $2 million annual operating costs for the safeguards system may also be greatly increased, as noted above. Furthermore, the' costs of various CRBR components sucn as the steam generator system must be revised to consider the extensive problems with such systems in both LWRs and otner breeder reactors since 1977, and the additional costs and delays that might be necessitated by redesigning, modifying, and testing. A recent GAO report on the Clinch River Breeder Reactor Steam Generator Testing Program indicated that, according to DOE officials, testing a f ull-scale CRBR-design steam generator could delay the project by as much as 45 months if f abrication of the CRBR steam generator is halted. See GAO/EMD-82-75, May 25, 1982. Such a testing program might be required in light of the steam generator leaks that occured less than three months ago in the French Phenix demonstration breeder reactor. NRC must consider these additional costs and

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20 reveal such costs to the public and the Licensing Board in order that both can judge whether the CRBR can meet the objectives of the LMFBR program.

CONCLUSION The above topics constitute only a few ot the myriad changes and new data compelling the need for a supplement to the five-year old CRBR impact statement. NRC must itself scrutinize each area of the FES to determine if supplementation is necessary. We wish to emphasize that this discussion deals only with the need for supplementation of the 1977 FES, and not with the adequacy of the information that was presented in that document, which we conti~nue to challenge.

NRDC fully intends to file suit against the NRC if it fails to supplement the CRBR FES. As a practical matter, such litigation could cause significant delays to the CRBR licensing schedule. Ho weve r , should the NRC supplement the FES, only a minor delay of several months would ensue. NRDC understands that the FES update is substantially completed, and need only be circulated to the public to meet the requirements of NEPA.

Instead of time consuming litigation, this minor delay would have a beneficial result: the production of a supplement to the FES with a more adequate evaluation of the total environmental impact of the CRBR. Allowing the public the opportunity to comment on the " revised" Clinch River Project

. . . . . . . .)

21 would increase public confidence in both the NRC and the projects it licenses. This project was shelved for five years because of unprecedented controversy over its safety, cost, need, and foremost, the threat which it may pose to national security by increasing the risk of nuclear proliferation. At the very least, the agency owes the public an opportunity to voice its views on this EIS before the project goes forward.

Sincerely, Ech" a Barbara A. Finamore, Esq3 Attorney, NRDC

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f VU 244In R. Weiss, Esq.

Harmon & Weiss

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Dr. Thomas B. Cochran Senior Staff Scientist, NRDC cc: William J. Dircks, Executive rector for Operations

ATTACHMENT A MEMORANDUM OF LAW The function of an environmental impact statement is to aid l

the decisionmaker/ agency and the public in making meaningful i decisions whether to pursue a project or program. Save Lake Washington v. Frank, 641 F.2d 1330, (9th Cir. 1981); Suffolk

)

County v. Secretary of Interior, 569 F.23 1368 (2d Cir. 1977),

cert, denied, 434 U.S. 1064 (1978). The EIS facilitates and provides a record of the agency decision making process. NRDC

v. NRC, F.2d , No. 74-1586 (D.C. Cir. , April 27, 1982) at 32.

The detail required in an EIS is that which is sufficient to enable those who did not have a part in its preparation, such as tne public, to understand and consider the factors which the agency took into account in reaching an informed decision. Suffolk County, 562 F.2d at 1375. See also Weinberger v. Catholic Action of Hawaii, U.S. , 50 U.S.

L.W. 4027, 4028 (Dec. 1, 1981) (dual aim of EIS is to inject environmental considerations into decision making process and to inform the public that the agency has addressed environmental concerns) .

If an EIS issued by an agency fails to conform to the mandates of the National Environmental Policy Act, 42 U.S.C. 3 4321 et s ea . (1976) (NEPA) , as implemented oy tne Council on

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Environmental Quality regulations, 40 C.F.R. s 1500 et sea.

(CEO regulations) ,d! the impact statement must be supplemented and circulated before it can be used by the agency in its decisionmaking process. NRDC v. Ca lla way, 524 F.2d 79, 91-92 (2d Cir. 1975) (use of supplemental EIS is permissible to bolster deficient EIS 'vhen supplement remecies the deficiency and is properly circulateo before a tinal decision is reachea by the agency); see NRDC v. Morton, 337 F. Supp. 170 (D.C.

1972); I-231 Why? Ass'n v. Burns, 372 F. Supp. 223, 253-260 (D.

Conn. 1974), aff'd 517 F.2d 1044 (2d Cir. 1975).

J/ "Th e CEQ regu la tions, applicable to all federal agencies, including the [ Nuclear Regulatory) Commission ... were expressly designed to estaolish uniform procedures for implementing NEPA and to eliminate inconsistent agency interpretations." People Against Nuclear Energy v. NRC, __

F.2d , No. 81-1131, slip op. at 19-20 (May 14, 1982)[ emphasis added]; see Andrus v. Sierra Club, 442 U.S.

347, 356-57 (1979) (interpretation of NEPA by CEQ under its mandatory regulations is entitled to substantial de f e rence) ; E.O. No. 119 91, 4 2 Fed . Reg. 26967 (1977) (adding sec. 2(g) to E.O. 11514: tederal agencies have the responsibility to comply with regulations issued by the CEQ unless inconsistent with statutory requirements). Cf. 40 CFR 1502.9 (c) (4) (agencies shall prepare, circula'te and tile an EIS supplement in same manner as a draf t and final EIS unless alternative procedures are approved by the CEQ). It is thus indisputable that the NRC is bound by the procedural requirements of the CEQ regulations. See generally Leibesman, NEPA's Substantive 'iandate, 10 E.L.R 50039, 5004*,-52 (1980) (the rationale f or making agency compliance uth CEQ regulations mandatory includes furthering NEPA's substantive goals) .

T 3

The CEQ regulations specifically call for preparation ot a supplemental EIS if "the agency makes substantial changes in the proposed action that are relevant to environmental concerns" or there are "significant new circumstances or information relevant to environmental concerns and bearing on the proposed action or its impacts." 40 CFR S 150 2. 9 (c) (1) (i) and (ii). CEQ has recently elaborated on these provisions, noting that Elas more than five years old should be carefully reexamined to determine if Section 1502.9 compels preparation of an EIS supplement. 46 Fed. Reg. 18036 (1981).

In the instant proceeding, the 197 7 CRBR FES is legally insufficient because it fails to address substantial changes in the proposed projected as well as significant new circumstances and information wnich have arisen since the FES was issued in 1977. See Letter of July 1, 1982 from Barbara A. Finamore, Ellyn R. Weiss, and Dr. Thomas B. Cochran, NR DC , to NRC Chairman Nunzio Palladino; 40 CFR 150 2.9 (c) ( 1) (i) and (ii).

Therefore, to comply with NEPA the FES must be supplemented and i the supplement circulated for comments.

In EDF v. Marsh, 651 F.2d 983, 991 (5th Cir. 1981) plaintif f s claimed tnat the Army Corps of Engineers violated l

NEPA by failing to supplement the FES for the Tennessee-Tombigbee Waterway following tne pro]ect changes which resulted in increased projected trattic use, increased flooded land and a design change for the wa ter way. The court i

t 4

indicated that NEPA should not be read so narrowly as to leave the decision to supplement an EIS solely to the discretion or the agency. An EIS should be supplemented when subsequent project changes can, in qualitative or quantitative terms, be classified as major federal actions significantly af fecting the environment. Id. Another court has noted tnat the legislative history of NEPA indicates that major federal actions include expansion or revision of ongoing projects. City and County of Denver v. Be rg land , 517 F. Supp. 155, 202 (D. Colo. 1981),

citing S. Fap. No.91-296, p. 20 (1969). Cf. EDF v. Andrus, 639 F.2d 1368, 1377 (10th Cir. 19 80 ) (supplemen t will be required to program EIS if significant change occurs) .

S imilar ly , the exist'ence of significant new information and circumstances such as those discussed in the letter referenced supra, p. 3 mandate that the NRC supplement and circulate the FES since it is well established that a supplement must be prepared when such new information becomes available af ter the preparation of the final statement.S/

-2/ See, e.g., Society for Animal Rights v. Schlesinger, 512 F.2d 915, 917-918 (D.C. Cir. 1975); Natural Resources Defense Council, Inc. v. Ca lla wa y , 524 F.2d 79, 91-92 (2nd Cir. 1975); Essex County Preservation Ass'n v. Campbell, 536 F.2d 956, 960 >61 (1st Ci r. 1976); Warm Springs Dam Task Force v. G r ibb le , 621 F.2d 10 17, 1023-1024 (9th Cir.

1980); Red Line Alert v. Adams, 10 ELR 20314, 20316, (D.

Mass. 1980); Monaren Chemical Works, Inc. v. Exon, 452 F.

gSupp. 493, 500 (D. Neb. 1978).

7 5

In Essex County Preservation Ass'n v. Campbell, 536 F.2d 956, 960-61 (1st Cir. 1976), tne court addressed the sufficiency of an EIS prepared for a highway expansion project. The court noted that the etfects of a subsequent state moratorium on highway construction, which had not been addressed in either the draft or final EIS, warranted ventilation in a supplemental EIS.

As stated recently by the D.C. Circuit, the purpose of NEPA is to assure that agencies such as the NRC take a hard look at the envircnmental consequences of major proposed actions. See People Against Nuclear Energy (PANE) v. NRC, F.2d , No.

81-1131, slip op. at 23 (D.C. Cir. May 14, 1982). In PANE, the court addressed whether psychological health ef fects of the Three Mile Island accident were cognizable under NEPA. The cou r t held tha t th e TMI restart proceeding EIS would have to be supplemented to address post-traumatic psychological health effects of the TMI accident unless the Commission could reasonably find that the psychological nealth information was not new or significant. Id. Reasonableness would be evaluated l by such criteria as the environmental significance of the new information, the probable accuracy of the new information and the degree of care used by the agency in its explanation not to supp lemen t the EIS. Id. at 26 accord, Warm Springs Dam Task Force v. Gribble, 621 F.2d 1017, 1025 (9th Cir. 1980). Cf.

Citizens Against 2,4-D v. Watt, 527 F. Supp. 465, 468 (W.D.

e 6

Okla. 1981) (an agency determination not to prepare an EIS is reasonable only if the agency can demonstrate a compelling case of nonsignificance of the proposed action; in this case, since the agency showed that applications of pesticide would not increase 2,4-D levels above EPA minimums, the court held tha t the action was not significant) .

Beyond merely supplementing the deficient CRBR EIS, h o weve r , the NRC must circulate the supplement in draft form for comments by agencies and the interested public before using it in the LWA-I proceedings. See n. 1, supra, p. 2.

Circulating a draf t EIS allows the agency to receive comments from individuals not involved in its preparation; this fundamental procedural r'equirement guards against objective error and excessive bias which might otherwise go undetected in the EIS. Essex County Preservation Committee, 536 F.2d at 961; I-291 Why? Ass'n 372 F. Supp. at 258. The EIS decisionmaking structure, which requires circulation of supplements for comments by the interested public, is not inherently flexiole nor subject to agency discretion. See, e.g., NRDC v. NRC, supra, at 32; 40 CFR IS02.9 (c) (4) . Therefore, it is irrelevant under NEPA whether the NRC believes ab initio that the comments which might be received on a supplemental EIS would not a tfect their ultimate decision to proceed with the CRBR project; they still must conform to NEPA procedural requirements. See I-291 Why? Ass'n, 372 F. Supp. at 260, citing NRDC v. Morton, 337 F.

Supp. 167, (D.D.C. 1971), aff'd, 458 F.2d 827.

9 7

The unique NRC regulation which allows modification of the content of a final EIS during the LWA-I proceedings, 10 CFR 51.52(3), does not alter the need to supplement the FES and circulate the supplement in the instant proceeding to conform with the procedural requirements of NEPA. In Public Service Co. of Ok lahoma, (Black Fox Stations Units 1 and 2), ALAB-573, 10 NRC 775, 786 (1970) the appeal board, citing NRDC v. Morton and 1-291 Why? Ass'n, noted that recirculation of a FES, rather than the 51.52(3) procedure, may be required if the proposed project had been so changed as to not have been "f airly exposed to public comment" during the initial circulation of the FES.

l And in Florida Power & Light Co. (Turkey Point Plant Units 3 and 4), ALAB-660, 14 NRd 987, 10 14 (1981) the appeal board, citing B]ack Fox Station, supra, said that there may be instances where absence of discussion in an FES "is so fundamental an omission" as to call for recirculation of the FES. The Board determined that the failure to discuss the impact of severe storms on low level waste was not such a fundamental omission; however, if the FES had disregarded important alternatives or f ailed to apprise the public of the nature of the project or its expected consequences, then sucn omissions could not be cured by evidentiary submissions to the Licensing Board. Id. Both these decisions support the proposition that agency regulations do not override NEPA procedura l requirements.

8 The fundamental nature of the omissions in the instant proceedings is also distinguishable from those involved in New England Coalition v. NRC, 582 F.2d 87 (1st Cir. 1978). In New England Coalition, the court affirmed a decision by the l l

Commission, Puolic Service Co. of N.H. (SeabrooK Units 1 and 2)

CLI-78-1, 7 NRC 1 (1978) not to supplement and recirculate a FES. After the FES was prepared the EPA required that the applicant move an intake from 3,000 to 7,000 feet otfshore to minimize environmental impacts. Id. at 93. The Licensing Board evaluated the impact of the 7,000 foot location during the construction permit stage pursuant to 10 CFR 5 50.52(b) (3) . The Court held that this procedure satisfied NEPA

~

because the NRC was entitled to rely on the EPA conclusion that the 7,000 foct location would have less impact than the 3,000 foot location addressed in the FES. "The FES . . . consider [ed]

a stronger case against the plant." Id. at 94.3/ Such a minor modification of the FES at the hearing complied with the "r.pirit of NEPA," Id. See also Citizens for Safe Power v. NRC, 3/ This is distinguishable from a situation such as the instant case where new regulations create stricter Standards wh ich the NRC must utilize in making decisions regarding siting and other safety issues.

Environmental analysis in the prior EIS utilizing the less stringent regulations would not constitute a " stronger case against the plant." On the contrary, new regulations might increase expenses or render a previously-suitable site unusable. Therefore, the impact of the new regulations upon the CRBR must be f actored into an updated cost / benefit analysis of the environmental costs and benefits of the plant.

9 524 F.2d 1291, 1294 and N.5 (D.C. Cir. 1975) (radiologica l stipulation could be included in FES via 51.52 procedure) ;

Philadelphia Electric Co. (Limerick), ALAB-262, NRCI-75/3 163, 395-7 (1975) (appeal board stressed that single new factor--adoption of alternative method of providing supplemental cooling water--did not constitute a major alteration of the proposal) .

Ho weve r , in the instant proceeding, in light of the quantity of new information and changed circumstances which have arisen during the five year hiatus, the action of the board could not possibly constitute a " minor modification" of the FES. Therefore, to comply with the mandates of the National Environmental policy Act, the Council' on Environmental Quality Regulations, case law and prior decisions of the NRC, the NRC must supplement and circulate the CRBR FES before relying on it in the LWA-1 proceedings.

O 8 ATTACHMENT B ITEM 290.1R Provide a succinct summary and discussion in table form, by ER section, of differences between currently projected station design and environmental effects (including those that would degrade, and those that would enhance environ-mental conditions) and the effects discussed in the environ-mental reports submitted in 1975, Amendments 1 through 7.

Summary of Resconser The changes to CRBRP design which have Jccurred since 1977 and the expected environmental effects of these changes are summarized succinctly by ER section in the attached table. Most of the ER sections have already been modified to reflect the design changes and their environmental effects. The sections that are yet to be modified in future amendments to the ER are highlighted in boxes in.the table and for your convenience are listed below.,

l ER Summary of Change (s) to be Section Reflected in Future ER Amendments 1.0 Heterogeneous core replaces homogeneous core arrangement. This section will also address the supplement to the LMFBR Program Final Environmental Statement.

2.2 Inclusion of the most recent demographic data available.

3.5 Numerous refinements in the plant systems designs that result in changes to the effluent from the plant.

4.1.2.1 Construction water consumption estimates have been increased.

l

_ _ _ _ _ _Q2_90._1 R-_1

e ,,

5.2 Changes to radiological source term and

__ pathway analysis.

5.3 Changes to the radiological source term, pathway and population data.

5.4.3 Instead of being directly discharged to the Clinch River via catch basins, storm water collected by the roof and yard drains is sent via the storm drainage system to the impounding ponds for settlement and ultimate discharge to the river.

5.8.1 Increased total acreage commitment.

6.1.4.2 Inclusion of most recent demographic data available.

Chapter 7 X/Q's based on a complete on-site meteorology data base have been provided; changes to the plant design and analysis methods which result in modified source terms require updated dose calculations.

Chapter 8 Revised construction manpower requirements, 1980 census and other recent demographics data.

Chapter 9 A supplement to the LMFBR Program Final Environmental Statement will be issued; responses will be provided for recent NRC questions.

Q290.lR-2

i PAG 3 1 CRBRP ENVIRONMENTAL REPORT REVIEW ER ENVIRONMENTAL EFFECT REV ISED ITEM DESCRIPTION OP CHANGE SECTION

. - - - . - . = - - -

Heterogeneous core replaces homogeneous core 1.0 TO BE PROVIDP.D arr angement (See Section 3.8) . This Section will also address the supplement to the LMFBR Program Final Environmental Statement.

Construction site acreage increased. Plant See Section 4.0 2.1 2.1-1 thru 2.1-10 Plant arrangements updated. Five impounding pnds were identified and located on Figure _

2.1-3.

Evaluation of demographic changes in 2.2 TO BE PROVIDED process. Changes will be provided in a future amendment.

No change.

2.3 Environmentally inconsequential.

2.4-15 thru G eology Changed to provide data for 24 additional 2.4 boreholes, taken from September 1916 to 2.4.22 June 1977.

2.5 Environmentally inconsequential.

2.5.1 thru 2.5-10 River Updated river levels, flows, temperatures, 2.5.1 etc.

2.5.2 No change.

2.5.2.1 No change.

2.5.2.2 No change.

2.5.2.3 Established piezometric gradient. Environmentally inconsequential, 2.5.2.4 2.5-18 Ground-water No change.

2.5.2.5 No change.

2.5.2.6 No change.

2.5.2.7 Environmentally inconsequential.

2.6 2.6-1 thru Meteor- Updated to include data accumulated 2.6-99 ology using permanent meteorological tower.

l

CRBRP ENVIRONMENTAL hu.NTRT REVIEW PAGE 2 I

I ER i SECTION REVISED ITEM DESCRIPTION OF CHANGE ENVIRONMENTAL EFFECT i

l 2.7 2.7.1 j 2.7.1.1 2.7-la Forest Incorporates ORNL forest management No change in estimated environmental Manag e- activities from 1976 through 1980. effects for CRBRP. Mitigation measures i for Southern Pine Beetle and Pitch Canker i infestations.

I J

2.7.1.2 No change.

I 2.7.1.3 2.7-7 thru Flora Update vegetation inventory reporting. Environmentally inconsequential.

2.7-9

) 2.7-24, -37 Flora Correct pine designation. Environmentally inconsequential.

I 2.7-3 81, -3 8m Flora Revise category designation from Environmentally inconsequential.

I " threatened" to " rare" to reflect l

4 current terminology.

l 2.7.1.4 2.7-380 thru Fauna Update wildlife occurrence data. Environmentally inconsequential.

2.7-38t j 2.7-38ee Insects Update reporting concerning insect Environmentally-inconsequential, j pests, i 2.7-38ff Fauna Revised to include possibility of Occurrence on CRBRP site not confirmed.

eastern cougar occurrence ,on Oak Also, cougar home range is sufficiently j Ridge Reservation. extensive to absorb ef fect or CRBRP 4 installation. Environmentally j inconsequential.

1 I

2.7-3899 ' Avifauna Adds mention of osprey nest occurrence Osprey nesting at CRBRP site has not been at Watts Bar Lake, observed. Environmentally inconsequential.

I 2.7.1.5 No change.

l 2.7.1.5 2.7-38tt Avifauna Update classification of American Occurrence of nesting at site has not osprey. been observed.

2.7.1.7 2.7-3 8ww Surveys Report on 1980 reconnaissance Environmentally inconsequential, surveys.

2.7.2 2.7.2.1 No change.

No change.

• 2 .7,. 2 . 2 _

CRBRP ENVIRONMENTAL REPORT REVIEW PAGE 3 ER SECTION REVISED ITEM DESCRIPTION OF CHANGE ENVIRONMENTAL EFFECT i 2.7.2.3 No change.

2.7.2.4 2.7-879 Fish Report of occurrences of the blue Occurrence not reported near Site.

i sucker in Watts Bar Lake. Blue Environmentally inconsequential.

sucker is identified as a threatened species.

2.7.2.5 2.7-87h -

Aquatic Report on 1980 reconnaissance surveys. Stocking activities have resulted in

-871 Surveys reported increases in gamefish. No change in estimated environmental effects due to CRBRP.

2.8 2.8-1 thru Back- Complete update reflecting latest Data better characterizes the actual 2.8-109 ground ORNL, 'IVA and similar organization site and the surrounding areas.

Radia- studies and scientific papers. Environmentally inconsequential.

tion O

CRBRP ENVIRONMENTAL REPORT REVIEW PAGE 4 ER SECTION REVISED ITEM DESCRIPTION OF CHANGE ENVIRONMENTAL EFFECT t

3.0 3.1 3.1-1 External A five foot high animal fence was added Preclude small animals from plant site and l Appear- at a distance of 33 feet from the and restrict them to more natural ance security fence, environs. Environmentally inconsequential.

l 3.1.1 3.1-2 Plant Gatehouse, circulating water pump house Environmentally inconsequential.

Bldg. s and fire protection pump house were Facili- identified. The switch yard relay house ties was added.

' Tha configuration and location of the Environmentally inconsequential.

emergency cooling tower structure were

revised.

l 3.1.2 3.1.4 Plant Five foot high animal fence added. Environmentally inconsequential.

Site

! 3.1.3 3.1-4 Other The size of paved parking area was Environmentally inconsequential.

Facill- reduced for accommodation of 155 cars ties instead of 250 before.

3.2 3.2.1 'N No change.

3.2.2 3.2-3 l Core h Replaced homogeneous core with hetero- Net change judged to be insignificant.

I geneous arrangementresulting in eliminating

,' one fuel enrichment zone (was 2 now 1), reducing number of fuel assemblies from 198 to 156, reducing number of radial blanket assen-blies from 150 to 132, adding 82 inner

% tsassemblies, ard increasing Pu en-4 richmenh'1q fuel assemblies f rom 18.7-324 to32-334.}

3.2.3 No change < #

3.3 i

3.3.1 3.3-1 Overall Average annual consumptive water use Environmentally inconsequential.

Plant figures were revised to be consistent with those in Tables 3.3-1, 3.3-2 and 3.3-3.

3.3.2 3.3-2 Cooling Flowrate to cooling tower from condenser Slight increase in plume size will not

. Tower increased from 209,200 gpa to 212,200 gpm. Produce signficant environmental impact. .

3.3.3 3.3-2 Process Added makeup water treatment system Environmentally inconsequential.

Water , ,

Treatment System

CRBRP ENVIRONMENTAL REPORT REVIEW PAG E 5 l ER lSECTION REVISED ITEM DESCRIPTION OF CH ANGE ENVIRONMENTAL EFFECT l 3.3.4 3.3-3 Waste All process waste water including floor Results in higher quality of water ,

Water drains, go to Waste Water Disposal System discharged.

Disposal instead of being routed to either cooling System tower basin or neutralization and settling facilities.

l3.3.5 3.3-3 Radwaste Updated description. See Section 3.5.

Systems Potable water is supplied by DOE's Bear Environmentally inconsequential.

l3.3.6 3.3-4 Potable Water Creek Road Filtration Plant instead of sources the Make-up Water Treatment System.

Tcblo 3.3-5 Plant Increase in plant make-up flow rate Environmentally inconsequential.

3.3-1 Fl ow- from 5835 gpa to 6145 gpm.

rates During Increase in cooling tower evaporation Environmentally inconsequential.

Maximum rate from 3475 gpa to 3623 gpm. l Power o Increase in cooling tower drif t rate Environmentally inconsequential. l from 105 gpm to 106 gpm.

Increase in cooling tower blowdown rate Environmentally inconsequential. l from 2210 gpm to 2306 gpm. p Decrease in Process Waste Treatment Environmentally inconsequential.

flow rate from 125 gpm to 110 gpa.

Waste Water Disposal System Flowrate Environmentally inconsequential.

designed at 100 gps.

Increase in plant discharge rate from Environmentally inconsequential.

2,251 gpm to 2,411 gpm.

Increase in total consumptive use of Environsentally inconsequential.

river water from 3,584 gpm to 3,733 gps.

l i

=

e

CRBRP ENVIRONMENTAL REPORT REVIEW PAGE 6

, ER I SECTION REVIS ED ITEM DESCRIPTION OF CHANGE ENVIPONMENTAL EFFECT l'

i i Table 3.3-6 Plant Increase in Plant Make-up Flowrate Environmentally inconsequential. g 2 3.3-2 Flow- from 2,361 gpa to 2,527 gpa.

j rates During Increase in cooling tower evaporation Environmentally inconsequential.

Minimum rate f rom 1,390 gpm to 1,450 gpm.

Power j Increase in cooling tower blowdown rate Environmentally inconsequential.

from 884 gpm to 925 gpm.

Decrease in process water treatment flow- Environmentally inconsequential.

rate from 125 gpm to 110 gpe.

i Waste Water Disposal System flowrate Environmentally inconeequential.

. designed at 100 gpm.

I Increase in plant discharge rate from Environmentally inconsequential.

925 gpm to 1,030 gpe.

Increase in total consumption use of Environmentally inconsequential.

river water from 1,436 gpm to 1,496 gym.

T1ble 3.3-7 Plant Increase in plant makeup flowrate from Environmentally inconsequential.

3.3-3 Fl ow- 625 gpa to 715 gpm.

rates During Increase in cooling tower blowdown Environmentally inconsequential.

, Tem- flowrate from 221 gpa to 231 gps.

l porary

Shutdown Increase in cooling tower evaporation Environmentally inconsequential.

rate from 348 gpm to 363 gpm.

Decrease in process water treatment Environmentally inconsequential.

flowrate from 125 gpm to 110 gpm.

Waste Water Disposal System flowrate Environmentally inconsequential.

designed as 100 gpa.

Increase in plant discharge flowrate Environmentally inconsequential.

from 262 gym to 336 gpm.

Increase in total consumptive use Environmentally inconsequential.

of river water from 363 gpa to 378.

Table 3.3-8 Plant Seasonal Flowrates in Table have been Environmentally inconsequential. ,

3.3-4 Water adjusted to reflect present design.

Usage Seasonal .

Variation

_ _m__ - - _ _ _ _ _ _ _____

CRBRP ENVIRONMENTAL REPORT REVIEW PAGE 7 ER SECTION REVISED ITEM DESCRIPTION OF CHANGE ENVIRONMENTAL EFFECT 1 l-

, 3.4.1 3.4-1 Cooling Updated Nakeup water addition to 6035 gpm. Environmentally inconsequential.

! Tower a

3.4.2 3.4-3 River Design flowrate fot river water pumps Environmentally inconsequential.

Water decreased from 10,000 gpa each to 9,000 gpm Pumps each.

3.4.3 No change.

i Table 3.4-5 Heat Heat rejected from a cooling tower Environmentally inconsequential.

3.4-1 Dissipa- increased from 2.172 x 109 BTU /HR to tion 2.256 x 109 BTU /HR.

Design Parameters

& Conditions Tablo 3.4-6 Component Updated Design Parameters. Environmentally inconsequential.

3.4-2 Desc ri p-tions Tcble 3.4-8 Cooling Average monthly cooling tower blow- Environmentally inconsequential.

3.4-4 Tower down temperatures increased slightly.

Blowdown Temperature 3.5 ( ALL CHANGES TO SECTION 3.5 MAT ARE DESCRIBED BELOW WILL BE PROVIDED IN A FUERE AMENDMENT TO THE ER.)

3.5.l' No change.

3.5.1.1 No change.

3.5.1.2 3.5-3 Filter A filter deleted from the liquid Environmentally inconsequential.

radwaste system.

3.5.2 3.5.2.1 3.5-7 ' Noble The 39At and 41A r produced by direct The additional Argon from this source is G ies activation of 38Ar and 40Ar is now negligible and the environmental impact included in the radioactive source terms is considered insignificant, used for design work.

3.5.2.2 3.5-8 Treat 8 , Design has been changed so that 85K from he site boundary beta skin dose is ment ncreased by approximately a factot_Df_2 # ,

\ and }thru CAPS and released to R&V. RAPS is no longer bottled but is prbcessed but the potential-for acci5eKEal exposure Release /

N_ System due to K storage and shipping is

/ removed. fhe net change in environmental

. 's effects is judged to be insignificant. _

s m

@W - -

v

1 CRBRP ENVIRONMENTAL REPORT REVIEW PAGE 8 ER l

REVISED ITEM DESCRIPTION OF CHANGE ENVIRONMENTAL EFFECT )

I SECTION Previously all leakages of cover gas or The site boundary beta and geena doses are recycled cover gas were processed through increased a slightly adverse ef fect. The ,i CAPS. Now moet of the cella containing beta dose increased by approximately 1.5, I components which could leak cover gas vent gamma dose by approximately 3. I to H&V.

3.5-9, 10 Tritium The tritium removal unit has been Environmentally inconsequential.

3.5.2.3 Removal redesigned.

System nead The reactor cover gas leakage rate The site boundary beta and gamma doses 3.5.2.4 3.5-11 are decreaseds a slightly favorable Besis was reduced from 0.012 SCC per minute to 3.0044 SCC per minute. environments 1 effect.

The diffusion of Tritium through The additional radioactivity contributed piping walls into PHTS and auxiliary by the small amount of Tritium diffusing Na cells has been added to design through piping walls is insignificant assumptions. Any significant amount compared to the radioactivity contained of Tritium has been included in the in the cover gas which is aseused to leak current radiological source terms, into cells at the rate of I cc/ min. The impact is judged insignificant.

3.5.2.5 3.5-12 Release Ventilation exhaust rates at radiological Higher exhaust rates could potentially Points release points have been revised. Examples have more environmental impact due to are the release point in the SGB Inter- shorter hold-up of radionuclides.

' mediate Bay which increased from 50,000 However, the doses resulting from l

SCFM to 64,000 SCFM and the exhaust point plant releases remain well below I on top of the RCB which increased f rom guideline limits.

415,000 SCFM to 418,000 SCFM.

This change in temperature range will Ventilation exhaust temperature ranges have no impact. Density variations which at radiological release points have could release more or less radioactive increased. An example is a release material are accounted for in the pre-point in the RSB that did have a range ceding changes in exhaust rates, of 65or to 120oF and now ranges from 55oF to 140or.

The CAPS Reactor Service Building R&V No environmental impact for normal Exhaust has been deleted. CAPS now release. Improved protection against exhausts through the RSB exhaust with release of above normal radioactivity safety-related exhaust radiation monitors, from Uhe plant due to off-normal con-ditions - a slightly favorable ef fect.

RAFS process components have been moved No environmental impact for normal from the RSB to the RCB. operation. Improved protection against release of radioactivity from the plant following RAPS accidents - _

l a slightly favorable ef fect.

e

CRBRP ENVIRONMENTAL REPORT REVIEW PAG E 9 ER ,

SECTION REVIS ED ITEN DESCRIPTION OF CHANGE ENVIRONNENTAL EFFECT 3.5.2.6 3.5-13, -14 RAPS Revises gaseous release data based on No environmental impact f or normal relocated RAPS, updated burnup and release aperation. Improved protection point data, and most recent meterology. against release of radioactivity from the plant following RAPS accidents -

l a slightly favorable ef fect.

3.5.2.7 3.5-14, -15 Balance Turbine generator building ventilation Environmentally inconsequential.

of Plant exhaust location change from elevation 905'6" to 878'0", release rate decrease from 17,500 cfm to 8,000 cfs, exhaust flow velocity increase from 585 feet / min.

with a tamperature range of 85 to 120or to 900 feet / min, with a temperature range from 55oF to 1200P.

Plant Service Building ventilation ethaust location changed from elevation 830'0" to 831'2".

Number of release points decreased f rom 2 to 1.

3.5.3 3.5-15 Solid Solid radwaste M uipment is now Environmentally inconsequential.

(3.5.3.1 Radwaste is now identified as including 3.5.3.2) System a cement filling station, a decanting station, Bquip- a concentrated waste collection tank, a drumming ment station, a filter handling machine and a compa ctor. (see also Tables 3.5-10 and 3.5-11).

3.5.3.3 3.5-15 Noncom- There will be a total of 82 (instead Environmentally inconsequential.

patible of 202) 55 gallon drums per year used to store Solids the low activity, non-compactible solide of Rad- af ter treatment at the solid radwaste waste system.

System 3.5.3.4 3.5-16 Radio- There are now 2 drums of waste metallic Environmentally inconsequential.

active sodium per year with an activity level sodium of 20 C1/ drum instead of 6 drums / year with an activity level of 1.5 C1/ drum stored and/or processed on site.

3.5.3.5 3.5-17 Sodium The disposal of sodium bearing waste, Fnvironmentally inconsequential.

Bearing which was not previously identified, So1Jds has been selected. No currently licensed off-site disposal facility will accept sodium bearing wastes, therefore, for off-site disposal of these wastes, the sodium will be removed, hhere sodium removal is not practical, the waste will be stored on-site.

. Activ- Individual primary cold trap contained Environmentally inconsequential.

ity actlyity of Tritium increased from 8.7 x 103 Ci to 1.85 x 5 Ci and activity of fission and corrosion products increase from 1 x 103 Ci to 1.41 x 105 C1. The

CRBRP ENVIRONMENTAL REPORT REVIEW PAGE 10 ER SECTION REVISED ITEM DESCRIPTION OF CH ANGE ENVIRONRENTAL EFFECT ,

contained activity will not be removed or released from the cold traps. The g EVST cold trap contained activity increased from 6.7 x 10J C1. The Tritium activity increased from 150 Ci to 180 C1.

Tcble 3.5-18, IALL Some of the assumptions that Table 3.5-1 Environmentally inconsequential.

} 3.5-1 -19 System had been based upon have changed:

1) Intermediate activity concentration for the first rinse computed assuming 104 (instead of 40%) of plated out activity and 100% of sodium activity adhering to the process components is dissolved in 100,000 (instead fo 37,000)  ;

gallons of water per year.  ;.

I

2) Processed compenents involve an average annual volume of 3,200 (instead of 14,700) j gallons.

T:ble 3.5-20 IALL Some of the assumptions that Table 3.5-2 Environmentally inconsequential.

3.5-2 thru -22 Jystem had been baaed upon have changed:  !*

1) Iodine DF-104 included. Monitoring tank volume decreased from 2,500 gallons to 2,400 gallons.

2) Iodine DF=104 included. -

Table 3.5-23, IALL Some of the assumptions that Table 3.5-3 Environmentally inconsequential.

3.5-3 -24 System had been based upon have changed:

Lgy Activity Liquid Waste Amma=ntions:

1) Iodine DF=104 and Tritium DF=1 included.

Intermediata Activity Liquid Maste Aman =ntions:

1. Liquid waste discharged to the common plant discharger (instead of the coolant water blowdown stream) . Iodine DF-104 and Tritium DF=1 included.

Table 3.5-31 Expected Values in table have been changed to Environmentally inconsequential.

3.5-10 Weight, reflect current design.

Volume .

and Total estimated volume of solid radwaste Activity generated decreased f rom 3,094 f t3 /yr to of Solid 2,865 ft3/yr. .

Radwaste

~

l

i CRBRP ENVIRONMENTAL REPORT REVIEW PAGE 11 i

ER j 3ECTION REVISED ITEM DESCRIPTION OF CHANGE ENVIRONMENTAL BFFECT 1

i Total estimated welsht of solid radweste generated decreased from 2.6 x 105 lbs/yr.

, to 1.9 x 105 lbe/yr.

Total estimated activity of solid radwaste i

generated decreased from 6.6 x 104 C1/yr. to 3.2 x 103 C1/yr.

1 l T:ble 3.5-32 Empccted Espected containers per year of solidified Environmentally inconsequential.

i 3.5-11 Solid liquid radwaste decreased from 170 to 135.

1 Radwante

) Ship- Espected containers per year of filters and

! ments resins decreased from 120 to 30.

! per year t

Figure 3.5-33 Basic Inlets of collecting tanks now include Environmentally inconsequential.

3.5-1 Flow filters.

Design Figure 3.5-37 Basic Completely revised to reflect vendor Environmentally inconsequential.

3.5-5 Fl ow design.

1 Design I'

3.6 No change.

) 3.6.1 No change.

l 3.6.2 3.6-3 Sodium capability of injecting sodium hypo- Environmentally inconsequential.

Hypo- chlorite into cooling tower basin, chlorite on a continuous or intermittent basis.

j Inj ection 3.6.3 3.6-4 penin- Delete limits on demineralizer chemicals. Environmentally inconsequential.

eraliser 3.6.4 3.6-5 Sewage Chlorine limits set to meet NPDES permit Environmentally inconsequential.

l Disposal limits.

1 j rigure 3.5-7 Incorporate changes as described in text. Environmentally inconsequential.

! 3.6-1 i

i 3 .7 No change.

4 3.7.1 3.7-1 Sanitary Addition of pretreatment and extended Environmentally inconsequential.

Sewage aeration of activated sludge. Compares System ef fluent concentrations to NPDES permit limits (Table 3.7-1) .

3.7.2 No change.

1 i

CRBRP ENVIRONNENTAL REPORT REVIEW pagg 13 l

j ER

, SECTION REVIS ED ITEN DESCRIPTION OF CHANGE ENVIROWfENTAL EFFECT 3.8 N l

3.8.1.1 3.8-1, -2 3 Core Replaced homogeneous core arrangement with Decreases the heavy metal commitment l Design heterogeneous core arrangement resulting (U or U + Pu) in the axial blankets

in reducing the number of fuel assemblies and core from 5.4 MT to 4.2 MT and i from 198 to 156, increasing the Pu enrich- from 6.5 NT to 5.2 NT, respectiv ely.

I ment f rom 18.7 to 324 fissile to 33.2% Environmentally inconsequential.

I total.

l Deleted option to use natural uranium Environmentally inconsequential.

as alternate material to depleted uranium i as feed material for fuel pellets.

1 i

Revised refueling scheme from replacing Average yearly shipmente of fresh

! approximately one-third annually to fuel would therefore increase from

$ batch replacement of all the fuel and about 33 to 42. Environmentally l Anner blanket assemblies at two year inconsequential.

j intervals with mid-interval replacement 4

of 6 inner blankets with fresh fuel assemblies.

I l 3.8.1.2 3.8-2 Core Replaced homogeneous core arrangement Increases the have metal (U) commitment j Design with heterogeneous core arrangement from 16.4 MT to 21.6 MT. Environmentally

] resulting in increasing the total number inconsequential.

of blanket assemblies from 150 (radial) l to 214 (82 inner and 132 radial) .

, Revised dimensional parameters of blanket Environmentally inconsequential.

rods (outside diameter decreased from 0.520 j in. to 0.506 in.) and assembly weight j increased (from 525 lbs. to 536 lbs.).

1

! Revised refueling scheme from annual Average yearly shipments fresh blanket j refueling to batch refueling at two- assemblies will therefore increase from

year intervals. 13 to 35. Environmentr '. ly inconsequential.

l Figure 3.8.1 3.8-10 Reactor Revised to show heterogeneous core layout. Environmentally inconsequential.

i _

) Figure Fuel 3.8.2 3.8-11 Dimensions removed. Environmentally incensequential.

~ 'Ng 3.8.2.1 3.8-3, -4 Core Replaced homogeneous core arrangement  !, Shipping schedule for spent fuel increases Designj with heterogeneous core arrangement , from 8 to 12 shipments per year to one and revised refueling scheme from annual. shipment per week. ' Change judged to j refueling to batch refueling at two year ( to be slightly adverseA intervals resulting in increasing the average )

number of fuel assemblies discharged yearly from 66 to 81, j -

decreasing the fuel assembly burnup from s.. .

i

CRBRP ENVIRONMENTAL REPORT REVIEW PAGE 13

{

ER SECTION REVISED ITEM DESCRIPTION OF THANGE ENVIRONMENTAL EFFECT l i

j 200,000 MWD / Ton average tc 80,000 MWD / Ton i average, and the peak burnup to 110,000 l MWD / Ton, decreasing the average burnup in the axial blankets f rom 4,000 MND/ Ton to 2,200 MWD / Ton, and reducing the amount of bred fissile Pu f rom 1 kg/apey, to 0.3 to 0.4 kg/assy.

J Revised weight and dimensions of spent fuel Environmentally inconsequential.

shipping cask.

3.8.2.2 3.8-4, -5 Core Replaced homogeneous core arrangement with Increases the number of spent blanket Design heterogeneous core arrangement and revised assembly shipments from 3 to 6-7 per year.

refueling scheme from annual to batch Change judged to be slightly adverse, resulting in increasing the number of blanket assemblies discharged f rom the plant per year from 25 to 70, increasing i

the burnup per assembly from 5,700 MWD / Ton to 8,000 MWD / Ton, increasing the average and peak heat generation from I kw average (radial) to 2.6 kw (inner) and 1.6 kw (radial) and f rom 7 kw peak (radial) to 19.7 kw (inner) and 12 kw (radial).

3.8.3 3.8.3.1 3.8-5 thru Core Replacement of homogeneous core arrangement Change judged to be slightly favorable.

3.8-7 Design with heterogeneous core arrangement results in reducing the number of primary control assesElles_ff5m~11-toJ_ and in' increasing the number of secondary control assemblies from 4 to 6.

If lifetime considerations permit, control Change judged to be slightly favorable.

I rods could remain in the reactor for two cycles, also the driveline lifetime has been increased from 10 to 15 years.

Revised configuration of radial shield Environmentally inconsequential.

assembly from stacked hexagonal plates to closely packed rods in a her duct and .

decreased assembly weight from 750 to 360 lbs.

I Because of the change to the heterogeneous This greatly reduces the number of ship-core arrangement the lifetime of the first ments of irradiated shield assemblies.

row of shield assemblies has increased Change judged to be favorable. _

from 3 to 10-to-15 years, part of the second row lifetime has increased from 6-to-12 to 10-to-25 years, and the third . .

CRIRP ENVIRONMENTAL REPORT REVIEW PAGE 14 ER SECTION REVISED ITEM DESCRIPTION OF CHANGE ENVIRONMENTAL RFFBCT ,

and fourth rows are not expected to require

~ - ~ ~

replacement during plant lifetime. The ,

number of first row assemblies has been

[ reduced from 72 to 54.

3.8.3.2 3.8-8 RAPS Design has been changed so that 85K r is no The site boundary beta skin dose is longer bottled but is processed through increased by approximately a factor of 2,

/ CAPS and released to H&V. but the p tential for accidental esposure due to 83Rr storage and shipping is removed the net change in environmental effects is judged to be irsignificant.

3.8-8, -9 Primary The tritium levels were updated f rom 1.8 Naterial will not be released so tha l Cold x 104 Ci to 1.85 x 105 Ci and the fission changes are judges to be environ-Trap products and corrosion products increased mentally inconsequential.

from 1 x 103 C1 to 1.41 x 105 C1.

i Cold traps are to be stored on site since ,

no currently licensed disposal site will j accept sodium-bearing wastes. .

I 3.9 i t

3.9-1 No change. ,

3.9-2 No change.

3.9-3 No change.

3.9-4 3.9-4 Flora Update to account for ORNL forest No change in environmental effects due management activities since 1976. to CRBRP.

(Table 3.9-1) 3.9-5 No change.

3.9-6 No change.

3.9-7 No change.

3.9-8 No change.

3.9-9 No change.

w e O w

CRBRP ENVIRONMENTAL REPORT REVIEW PAGE 15 ER SECTION REVISED ITEM DESCRIPTION OF CHANGE ENVIRONMENTAL EFFECT i

j 4.1 4.1-1, -2 Site Deletion of borrow area,'Incr' ease 'of Environmentally inconsequential.

Prep. site temporary acreage 'to 260 acres '

and f rom 195 acres required for plant '

l Plant construction, 37 acres inside security Cons- quarr increase from 25 acres to truc- (barrier,iprovdecrusherfacilityat 45 acres, tion quarry jyable 4.1-1, Figure 4.1-1) .

4.1.1 4.1.1.1 4.1-2 Clearing Choice to use open burning during site Change judged to have a slight negative clearing. environmental effect.

4.1-3, -4 Quarry Excavation depths increased. Change judged to be slightly favorable as Eliminate consideration of borrow pit. quarry location will be preferable to borrow pit's. Onsite availability of material will reduce offsite hauling r equir ements.

4.1.1.2 No change.

4.1.1.3 4.1-5 Access Modify Barge Unloading Facility. Change judged to be slightly favorable.

Facility Redesign minimizes dredging.

4.1.1.4 No change.

4.1.1.5 No change.

4.1.1.6 4.1-7 thru site Update terrestrial ecological effects Change judged to have slightly negative 4.1-8b Extent of site clearing and construction. environmental effect due to increased (Table 4.2-1 and Table 4.1-3) areas.

Include ORNL forest management plan. No change to estimated environmental effects due to CRBRP.

Updates impacts on wildlife. No change to estimated environmental effects due to CRBRP.

4.1.1.7 4.1-11 Human Eliminates borrow area. Reduces construc- Change judged to be slightly favorables Activ- tion activ.ities near cemetery. borrow area was in vicinity of Hensley family cemetery.

4.1.1.8 4.1-12 Miti- Updates redressability Environmentally inconsequential, gation in light of design changes (i.e, choice of quarry rather than borrow pit, addition of demolition fill

. area, etc.)

CRBRP ENVIRONMENTAL REPORT REVIEW PAGE 16 ER SECTION REVISED ITEM DESCRIPTION OF CHANGE ENVIRONMENTAL EFFECT 4.1.2 4.1.2.1 4.1-13 Nater Construction water consumption estimates Environmentally inconsequential.

Use have been increased and will be provided Additional water consumption still is only by ER amendment in the near futut e. a very small fraction of the available Clinch River flow.

4.1.2.2 No change.

4.1.2.3 4.1-15 Barge Relocation and redesign will reduce Change judged to be slightly favorable.

Unload- dredging.

ing Facility 4.2 No change.

Table 4.2-9 Trans- Transmission corridor acreages updated. Environmentally inconsequential.

4.2-1 mission Corridor 4.3 4.3-1 thru R e- Updated to account for revised affected Net effect of all changes is judged to be 4.3-3 sources areas, and addition of quarry. environmentally inconsequential.

e 8

--- ~ -=a ,- _ m CRBRP ENVIRONMENTAL REPORT REVIEW PAGE 17 ER SECTION REVISED ITEN DESCRIPTION OF CHANGE ENVIRONMENTAL EFFECT 5.1 No change.

5.1.1 No change.

5.1.1.1 5.1-3, -4 Cooling Updated to reflect effects of cooling Change demonstrates that latest design System system redesign, produces ef fects that are enveloped by previous (approved) designs.

5.1.1.2 5.1-5 "No Updated plume configurations to reflect Change falls within effects that are Fl ow" effects described in 5.1.1.1. enveloped by previous approvals.

Plumes 5.1.2 5.1-6, -7 Thermal Revised to include reference to NPDES NPDES requirements exert positive controls Dis- Permit requirements on ef fluent quality. a Charge S tandards 5.1.3 No change.

5.1.3.1 5.1-12 thru Fish Discusses recent studies of fish Environmentally inconsequential.

Habitat (strited bass and sauger) behavior in the Clinch River. Includes habitats, migration and spawning.

5.1.3.2 No change.

5.1.3.3 No change.

5.1.3.4 No change.

5.1.3.5 No change.

j 5.1.4 No change, t

5.1.5 5.1-22 Con- Update condenser water design flow rato. Environmentally inconsequential.

denser Also updates Clinch River flow data.

Entrainment 5.1.6 No change.

5.1.7 No change.

5.1.8 No change.

5.2 Radio- This section is being reviewed to determine logical the signficance of changes to radiological source Biota term and pathway to warrant re-analysis.

5.3 Radio- This section is being reviewed to determine the

. logical significance of changes to the readiologeal source -

Impact term, pathway and population data to warrant r e-analysis.

, ~_

i CRBRP ENVIRONMENTAL REPORT REVIEW PAGE IS l

! ER

SECTION REVISED ITEM DESCRIPTION OF CHANGE y!NVIRONIENTAL BFFBCT .l l

l 5.4 5.4-1 Effects Editorial change to clarify and explain Environmentally inconsequential.

! of Chem- that an acid feed system is provided. g i ical & Its use would adjust pH for control of Biocide corrosion and scaling, and to assure that i Dis- the blowdown is in compliance with the charges the Draf t NPDES permit limits.

Defined the limits of chlorine Environmentally inconsequential.

concentration.

5.4.1 5.4-2 Waste Adde discussion of changes to waste Environmentally inconsequential.

Water water disposal system that have been Disposal previously described.

5.4.1.1 5.4-4a Coolant Total volume discharged increased slightly Environmentally inconsequential.

System with no changes in chemical concentrations.

, Discharge 5.4.1.2 5.4-5 thru Discharge Changed per cent differential between Environmentally inconsequential.

5.4-8 Plume ambient and blowdown concentrations.

l Striped Described bass response to chemical Envircnmentally inconsequential.

l Bass plume.

I Water Identifies elements not meeting drinking Environmentally. inconsequential.

Quality water standards at 64 isopleth during periods of extended no flow.

Included consideration of the more Environmentally inconsequential.

stringent of state or federal requirements.

(Tables 5.4-1, 5.4-2 and 5.4-5).

! 5.4.2 5.4-12 . Effects Includes discussion of trihalomethanes Environmentally inconsequential.

I of Bio- (THM's) (Table 5.4-1) cide Dis-charges ,.

5.4.3 5.4-12a Storm Instead of bein directly dischar ed The incor ration of Ohls system Water to the Clinch R ver via catch bas no, provides urther assurance that. the l

storm water collected by the roof and yard final ef fluent discharged to the drains is sent via the storm drainage river via the impounding pound is system to the impounding pounds for within applicable ef fluent standards, j settlement and ultimate discharge to the The effect is judged to be environ-river. Change will be provided in a mentally favorable. _

future amendment.

5.4.f No change. .

5.4.5 No change.

5.5 No change.

CRBRP ENVIRONMENTAL REPORT REVIEW PAGE 19 ER SECTION REVISED ITEM DESCRIPTION OF CHANGE ENVIRONMENTAL BFFECT 5.5.1 5.5-1, -2 Effects Editorial change to clarify that a package Environmentally inconsequential.

from Ban- treatment plant will be used during the itary construction period. A slow sand filter Wastes unit will be installed following the CRBRP construction period to form a part of the permanent plant for the normal operation of the plant.

Third paragraph deleted since the des- Environmentally inconsequential.

cription of the treatment plant is given in Section 3.7.

Treated effluent discharges will be Environmentally inconsequential.

processed to meet the Draf t NPDES permit limits instead of "all State and' Federal discharge regulations".

Discharges from cooling tower blowdown were Environmentally inconsequential.

revised to be consistent with Table 3.3-4.

5.5.2 No change.

5.6 No change.

5.7 No change.

5.8 No change.

1 5.8.1 5.8-1 Plant Total acreage committed updated. Environmentally inconsequential.

Site Changes will be provided in a future amendment.

5.8.2 5.8-2 Water Water consumption updated to reflect Environmentally inconsequential.

l Resources latest estimates.

-i

CR3RP ENVIRONMENTAL REPORT REVIEW PAGE 20 ER SECTION REVISED ITEM DESCRIPTION OF CHANGE ENVIROMMENTAL EFFECT 5.8.3 5.8-2 thru

\

Core Replaced homogeneous core arrangement Change decreases the heavy metal 5.8-4 Design with heterogeneous core arrangement commitments in the f uel (U + Pu) resulting in reducing the number of from 6.5 MT to 5.2 MT, reduces the m.

fuel enrichment zones from 2 to 1, stainless steel commitments in the

, increasing the Pu enrichment in the fuel from 26.3 MT to 20.7 MT. The I

f uel f rom 18.7-to-27.1 to 33.2% , reducing heavy metal commitment in the blanket the number of fuel assemblies from 198 to went from 21.7 MT (radial & axial) to 156. This change also increases the 25.8 MT (inner, radial 5 axial), and number of blanket atsemblies from 150 increasen the stainless steel commitment (radial) to 214 (inner and radial). In the blankets from 17.3 MT to 27.6 MT.

Change judged to be environmentally inconsequential.

Revised Pu luotopic composition to be Environmentally inconsequential.

similar to FFTP grade instead of char-acteristic of LWR discharge.

Revised refueling scheme from annual to batch which results in increasing the This results in increasing ths'toEar eavy-me ents baseA on a once ] _-_

l

• total number of fuel assemblies, required through fuel cyc1 rom 20 MT'Pd'Co 27 MT duri ((er from 2,300 to 2,427 , from 410 MT U~ 336 MT U and increasing the total number of blanket from 410 MT stainless assemblies from 850 to 2,142. steel to 600 MT. If reprocessing is assumed, then the tTEiil 7n t-hean6

% tment of uranium decreases from 17.7 MT to 14.3 MT and the net of bred,

• MT .3 MT.

plutonium decreases Change judged to be slifr__ M.y adverse.

5.8.4 No changes.

5.9 5.9-1 Plant Permanent plant acreage is increased. Environmentally inconsequential.

Site i

I .

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CRBRP ENVIRONMENTAL REPORT REVIEW PAGE 21 ER i

SECTION REVISED ITEM DESCRIPTION OF CHANGE ENVIRONRENTAL EFFECT 6.0 No change.

6.1 6.1-1 Pre-con- Changed to indicate Ubat program was Environmentally inconsequential.

struc- conducted, tion .

Monitoring Program 6.1.1 6.1.1.1 6.1-1 thru Base- Completion of baseline aquatic monitoring Environmentally inconsequential.

6.1-24 line program description (results of baseline Monitor- program reported in Section 2.7, (Amendment ing VIII).

Program 6.1.1.2 6.1-25 Ohru Pre-con- Provides a summary description and con- Environmentally inconsequential.

6.1-28e struc- clusions of the pre-construction aquatic Change provides data base for deter-tion environmental monitoring, mination of environmental ef fects due Aquatic to construction as monitored by the construction environmental monitor 1~ng program.

6.1.2 6.1-29 Ground- Upated to incorporate reference to Environmentally inconsequential.

water me pre-construction monitoring program (1976-1977).

6.1.2.1 6.1-29, -29a Pre-con- Provides summary conclusions of Uhe Environmentally inconsequential.

struc- pre-construction groundwater quality Changes provides data base for the tion monitoring program. construction monitoring program.

Ground-water

,Ca611ty 6.1.3 6.1-30 thru Meteor- Updates meteorological description to Environmentally inconseauential.

6.1-33 ology incor porate description, instrumentation Permanent metebrological and data acquisition system for Ohe on- facilities will be used during plant site permanent meteorological monitoring construction and operation for on-site stations, meteorological analyses.

Environmentally inconsequential.

Deletes description of on-site temporary meteorological monitoring station.

6.1.4 6.1.4.1

~

6.1-35 thru Geology Provides update of site geology invest- Environmentally inconsequential.

6.1-37 igation (results provided in Section 2.4).

6.1.4.2 6.1-38, -39 Land Use. Evaluation of demographic changes in Environmentally inconsequential.

& Demo- process.

graphic Surveys

CRORP ENVIRONMENTAL REPORT REVIEW PAGE 22 1

ER SECTION REVIS ED ITEM DESCRIPTION OF CHANGE ENVIRONMENTAL RFFECT 6.1.4.3 6.1-39 thru Terres- Provides update discussion of baseline Environmentally inconsequential.

6.1-41 trial terrestrial monitoring program. (Con-4 Ecology clusions provided in Section 2.7).

l l

6.1-42 Construc- Provides reference to on-site construction Environmentally inconsequential, tion environmental monitoring program.

Monitoring 6.1.5 No change.

6.1.5.1 6.1-42a thru Precon- Provides complete description and results Change is judged to be slightly favorable.

6.1-43 struc- of pre-construction radiological (river Provides basis for improved determination tion water, groundwater, sediment) monitoring of radiological disturbance as monitored Radio- program, during the construction radiological logical monitoring program.

Monitorins 6.2 No change.

6.2.1 6.2.1.1 6.2-1 thru Gaseous Updates plant gaseous effluent monitoring Change is judged to be slightly favorable.

6.2-2b Efflu- locations (32 locations f rom 13 locations. System will provide ents 1 - steam generator building - continuous monitors at those locations 9 - reactor containment buildings which could conceivably undergo 3 - reactor service building significant increase in detectable 1 - radwaste area levels i 1 - plant service building - periodic sampling for areas as

14 - turbine generator buildinga necessary.

! 3 - steam generator buildings PSB Liquid effluents go to liquid radwaste Environmentally inconsequential.

i Liquid system for reprocessing.

Effluents i

6.2.1.2 6.2-3 thru Pre-or Provides current (atmospheric, terrestrial, Environmentally inconsequential.

6.2-10 peration- aquatic groundwater) radiological monitoring

. al Rad- programs for the pre-operational and

iologi- operational phases.

cal Monitoring 6.2.2 No change.

6.2.3 No change.

6.2.4 No change.

6.2.5 No change. .

6.3 6.3-1 Other Deletes monitoring stations at TVA's Environmentally inconsequential.

, Monitor- Kingston steam plant and Bull Run 1

ing , steam @lanto

CRBRP ENVIRONMENTAL REPORT REVIEW PAGE 23 I

, ER f SECTION REVISED ITEM DESCRIPTION OF CHANGE EWWIRONRENTAL EFFECT 7.1 ( ALL CHANGES 10 SECTION 7.1 T11AT ARE DESCRIBED BELOW WILL BE PROVIDED IN A FU1VRE AMENDMENT TO 11IE ER) 7.1.1 i

i 7.1.1.1 7.1-1 Meteor- Meterology contained in Section 2.6 as ology provided by Amendment IX will be used in the computa tions.

7.1.1.2 7.1-2 thru Method- Methodology changes, as appropriate, will be

, 7.1-6 ology provided.

7.1.1.3 No change.

7.1.2

, 7.1.2.1 No change.

I 7.1.2.2 7.1-8, -9 Steam The amount of tritiated water released The combined ef fect of these changes is to

] Drum to the environment is 353,000 lbs. instead increase the site boundary whole body dose Valve of 450,000 lbs. from 1.77 meen to 5.50 areer both are (2.1)* envronmentally inconsequential.

The tritium concentration has increased from .25 x 10-6 C1/g to .62 x 10-6 C1/g.

Conden- The tritium concentration in the Condensate The short-term downstream tritium concen-sete Storage Tank increased to .62 x 10-6 C1/g tration in the Clinch River increased from Storage from .25 x 10-6 C1/g. C1/g to 2.89 x 10-12 C1

j. Tank al er de postulated leaks both are /g 1k8x10-12 Leak environmentally inconsequential.

i (2.2) 7.1.2.3 7.1-10 thru RAPS RAPS components moved to RCB. The environmental effects are judged to be 7.1-15 favorable. RAPS leakage is processed i through the RCB BVAC.

Radwaste The tritium concentration in the The combined ef fect of these changes is to System storage tank water has increased to reduce the postulated spill cleanup time Failures .62 x 10-6 C1/g from .25 x 10-6 C1/g. and increase the whole body dose at the (3.1) site boundary to 1.01 x 10-5 stem from Storage tank cell parameters have 9.4 x 10-6 mres, but both are changed such as the floor area increase environmentally inconsequential.

to 1,000 ft2 from 800 ft 2.

I j Sump pump flow capacity increased to 50 gpa from 10 gpe.

• Refer to accident number in Environmental Report.

CRBRP ENVIRONMENTAL REPORT REVIEW PAGE 24 ER SECTION R EVIS ED ITEM DESCRIPTION OF CH ANGE ENVIRONMENTAL EFFECT l Liquid Tritium concentration in storage tank water The combined ef fect of these changes is Radwaste has increased due to change in interface to increase the site boundary whole body i System diffusion coe Concentration is dose f rom ghis postulated gccident to Tank now.62x10gficients.

C1/g in SGS. 2.13 x 10- from 5.0 x 10-J mren; both are (3.2) environmentally inconsequential.

Spill cleanup time is reduced to 6.7 hours8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br /> by using higher capacity sump pumps.

7.1.2.3.3 RAPS Accident redefined due to relocation of The environmental effects are judged to be Noble RAPS components, favorable.

Gas Stor-age Vessel Rupture (3.3) 7.1.2.3.4 Deleted due to deletion of equalization line.

Rupture of cover gas Equalization Line (3.4) 7.1.2.4 7.1-16a thru Sodium Analyses revised to update computations. Environmentally inconsequential. I 7.1-21 Fire -

Accidents (4.1)

(4.2) 7.1.2.5 7.1-22 thru Fuel The current plant design has a higher purge The net ef fect of the changes is to 7.1-24 Failures rate of the cover gas which has reduced the reduce the site bgundary whole body (5.1) available Xenon and Krypton activity to dose to 8.4 x 10-3 area from 3.4 x 56,588 Ci from 65,816 C1. 10-4 mress both are environmentally inconsequential.

I O

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CRBRP ENVIRONMENTAL REPORT REVIEW PAGE 25 ER SECTION REVISED ITEM DESCRIPTION OF CHANGE ENVIRONRENTAL EFFBCT l 7.11-24 thru Steam A revised DBL for the steam generator The net ef fect of the changes is to 7.1-27 Generator results in 465 lbs. of sod um mixing with do Tube with water instead of 337 bs. of sodium, increase the site b undaby .1 to8.3x10-2arenIrom whol8-godafen:se x 1 a

Rupture The tritium concentration in SGS is now both are insignificant.

(5.2) .62 x 10-6 C1/g and in the IHTS is

.13 x 10-6 C1/g. This change is judged to be adverse, since this could potentially Deleted the centrifugal separator from result in the release of more sodium-the Sodium-Water Reaction Pressure Relief water reaction particulates into the Subsystem (SWRPRS). atmosphere. ,,,/

The duration of the SWRPR venting to the atmosphere was increased from 15 to 28 seconds as a result of an updated TRANSWRAP No change to estimated environmental code analysis of this event. This more effects. ,

detailed analysis tracks the primary sodium l which might leak into the intermediate sodium.

It considers the length of piping between the IHX and the superheater inlet, and the reduced sodium flow during blowdown and predicts that no  !

primary sodium will reach the superheater during l this event for subsequent release to the atmosphere.

I i

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CRBRP ENVIRONMENTAL REPORT REVIEW PAGE 26 ER I SECTION R EVISED ITEM DESCRIPTION OF CH ANGE ENVIRONMENTAL EFFBCT l

I 7.1.2.6 7.1-28 thru Spent Earliest scheduled time for fuel assembly The combined effect of Uhe changes is to 7.1-32 Fuel handling is increased to 8 days from 87 increase the s Cladding hours. frw 1.5 x 10 gte boundary whole aren to 2.13 bgdynres; x 10- dose I Failure both are environmentally inconsequential.

In the Revised ORIGEN isotope library was used EVTM to generate fission product inventories.

(6.1)

Spent The same changes that applied to Accident The net result of the changes is to Fuel 6.1 apply here. increase the site boundary whole body 1

Cladding dose f or this postulated accident f rom Failure 1.5 aren to 2.1 area, bcth are environ-in the EVTM mentally inconsequential.

(6.2)

Accident- Revised ORIGEN isotope library was used The combined ef fect of the changes to ally to generator fission product inventories increase the site boundary whole body Opening Revisions were based on newer calculational dose to 1.08 mrem from .07 mrens both a Floor schemes. are environmentally inconsequential.

valve (6.3) 7.1.2.7 7.1-33 Spent Isotope inventories were revised using The combined effect of Uhe changes is to Fuel updated ORIGEN libraries. The ORIGEN decrease the site boundary whole body dose Cask changes were due to revisions in the to 2.8 x 10-4 mrem from 9.3 x 10-3 mrens Drop library calculational schemes. both are environmentally inconsequential.

(7.1)

The fuel has undergone an 80 day cooling period instead of 100 days.

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CRBRP ENVIRONMENTAL REPORT REVIEW PAGE 27 ER i

SECTION R EVIS ED ITEN DESCRIPTION OF CHANGE ENVIRONMENTAL EFFECT 7.1.2.8 7.1-34 thru Primary Primary sodium isotope inventory has The combined ef fect of the changes is to 7.1-43 Sodium changed due to revisions in the ORIGEN reduce the site boundary whole bgdy dose Drain library calculational schemes, from 9.7 x 10-4 rem to 8.4 x 10-3 rem;

, Tank both are environmentally inconsequential.

Failure Cell 102A dimensions have changed. For 1

(8.1) ex ample, the cell volume a 45,000 f t.3 j and was 68,000 f t.3 The potential sodium-spill volume has increased to 35,000 gallons from 32,000 gallons.

Primary The postulated sodium spill has been The combined ef fect of the changes is to i

Coolant reduced to 135,000 lbs. from 193,000. increase the site boundary whole body dose Sodium from 8.3 x 10-4 res. to 1.25 x 10-2 rem; both Spill It was conservatively assumed that the are environmentally inconsequential.

1 (8.2) aerosol leaked to the RCB was vented

! directly to the environmental. Previously 4

a leak rate of .1 volt / day at 10 psig. was

) assumed as the leak rate.

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Ex-Con- The postulated spill has been reduced The net effect of the changes is to reduce tainment from 90,000 gal, to 45,000 gal. of sodium. the site boundary whole bod dose from Primary This is the result of a failure of one of 7.9 x 10-3 ren to 4.2 x 10 y> rems both are

. Coolant two storage vessels in the cell rather environmentally inconsequential.

I Sodium two.

I spill (8.3) The leak rate of aerosol was based on the cell j design leak rate of .6 volt / day at 3.9 psig.

rather than 100 voll/ day at 10 psig which was previously used.

Ex-Ves- Aerosol leakage to the RSB f rom the cell The net ef fect is to reduce the site sel Stor- was calculated based on a cell design boundary whole body dose from 2.1 x 10-4 age Tank leak rate of .36 volt / day at 12 poig. mrem to 4.3 x 10-4 aren; both are j Coolant rather than 100 voll/ day at 10 psig, environmentally inconsequential.

Rupture This approach will release less aerosol

! (8.4) into the environment.

I l Large The SGS tritium concentration has in- The combined effect is to increase the i

Steam creased to .62 x 10-6 C1/g from .25 alte boundary whole body dose to 4.7 mren Line x 10-6 C1/g. This is the result of from 1.9 areas both are environmentally

Break changes in diffusion coefficients across inconsequential.

(8.5) syster interface boundaries.

The newer design basis results in 312,000 lbs.

of water being released frca the PRV instead

. of 479,000 lbs. The power relief vent period =

l has been increased from 1.5 to 5.7 hours8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br />.

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CRBRP ENVIRONMENTAL REPORT REVIEW PAGE 28 ER SECTION REVISED ITEM DESCRIPTION OF CHANGE ENVIRONMENTAL EFFECT i

7.1.3 No change.

7.2.1 7.2-1 Hydrogen The total amount of Eydrogen gas stored has Environmentally inconsequential.

Cas not changed however, the volume has been Storage restated in terms of standard volume (28,000 SCF) rather Uhan bottled storage capacity. This change will be provided in a future amendment to the ER.

7.2.2 New Oil and Systems / Buildings involved with the Incorporation of these features in station Hazard- storage, transfer, or loading / unloading design provides further protection against ous of any oil or hazardous material are spill of oil and hazardous material i Material provided with secondary containment reaching the local environment.

Spills systems capable of containing the Environmentally inconsequential.

largest source of an oil or hazardous material spill without any adverse environmental impact. This change will be provided in a f uture amendment to the ER.

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CRORP ENVIRONNENTAL REPORT REVIEW PAGE 31 >

ER SECTION REVISED ITEN DESCRIPTION OF CHANGE ENVIROIIIEIITAL EFFECT 10 No change has taken place. Refer to No change.

response to Question 320.9R.

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CRIRP ENVIROllNENTAL REPORT REyIEN PME 32 ER BECTION Rgygsgo . ITEN og8CRIPTION OF CRANGE MIRGINENTAL NrraCT 11 No change. No change.

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CRBRP ENVIRONMENTAL REPORT RE7IEW PAGE 34 ER SECTION REVISED ITEM DESCRIPTION OF CHANGE ENVIRONIENTAL BFFECT 13 13.0-3 thru Refer- Update to include Amendement IX references. No environmental effects.

13.0-38 ences l

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CRBRP ENVIRONMENTAL REPORT REVIEW PAGE 35 ER REVIS ED ITEM DESCRIPTION OF CHANGE ENVIRONRENTAL BFFECT SECTION 14 14.1-2 thru Clean Incorporates 1977 amendment to the State The change is judged to be slightly (Appen- 14.1-81 Water of Tennessee Water Quality Criteria favorable. It provides criteria for Act of incorporates the 1977 clean water act CRBRP design for reduction of impact on dix to Szction 1977 amendments to the Federal Water Pollution the environment.

2.5) Control Act.

14 14.3-3 Sauger Provides update information on spawning No environmental effects.

( Appen- of sauger.

dix to S;ction 2.7)

Updates cooling tower blowdown rate The increase in cooling tower blowdown 14 14.6-3 Cooling is judged to be insignificant compared (Appen- Tower provides current design blowdown dix to temperature values. to the Clinch River flow rate.

S ction 10.3) l 9

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CRBRP ENVIRONMENTAL REPORT REVIEW PAGE 29 ER SECTION REVISED ITEM DESCRIPTION OF CHANGE ENVIRONMENTAL EFFECT 8.0 8.1 (All Future) Socio- Complete assessment of socio-economic This change is judged to be slightly 8.2 economic parameters of CRBRP plant construction favorable. It provides current data 8.3 and operation is being provided in a future base for evaluation of socio-economic amendment. Assessment is based on assessment.

current construction manpower requirements 1980 census and 1981 community service and infra-structure data.

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CRBRP ENVIRONMENTAL REPORT REVIEW PAGE 30 ER AECTION REVISED ITEM DESCRIPTION OF CHANGE ENVIRONMENTAL BFFECT 9.1 To Be Provided Altern- This section will be addressed in tne Environmentally inconsequential.

ative supplement to the LMFBR Program Final Ap- Environmental Statement (PPES) . This pr oaches rection of the ER will be revised accordingly.

9.2 To Be Provided Altern- a) Same as Section 9.1 above. Environmentally inconsequential.

ative b) For discussion of Hook-on arrangements Sites & refer to response to Question 320.lR Plant and 320.2R.

Arrange- c) Further discussion of candidate sites will ments be provided in the near future.

d) Section 9.2.5.3.4 will be updated to reflect response to Question 230.5R.

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