ML20081D119

Comments on Facility Des.Info Should Be Segregated Into Generic site-specific Topics & Put Into Laymans Language If Essential Part of Format Required for Des

ML20081D119
Person / Time
Site:	Satsop
Issue date:	03/08/1984
From:	Lundblad D WASHINGTON, STATE OF
To:	Knighton G Office of Nuclear Reactor Regulation
References
NUDOCS 8403150151
Download: ML20081D119 (2)

Text

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! DONALD W. MOOS Governor , owettor STATE OF WASHINGTON DEPARTMENT OF ECOLOGY Ataul Stop PV-l1 e Olynyta, Washington 98504 e (36) 459BC0 March 8, 1984 Mr. George Knighton Chief, Licensing Branch No. 3 U.S. Nuclear Regulatory Commission Washington, D.C. 20555 i

Dear Mr. Knighton:

Thank you for the opportunity to comment on the draft environmental impact statement (DEIS) for the operation of WPPSS Nuclear Project No. 3 (Docket No. 50-508). The Department of Ecology has been designated as the state coordinator for review of NEPA documents. We have cocrdinated the review of this DEIS with other state' agencies and received comment letters from the Energy Facility Site Evaluation Council and the Office of Archaeology and Historic Preservr. tion. Their letters, along with comments from the Department of Ecology, are attached.

If you have any questions, please call Mr. Greg Sorlie at (206) 459-6237.

Sincerely, Dennis Lundblad trb v Acting Assistant Director Office of Operations.and Enforcement DL:CS:pk Attachments cci Greg Sorlie State Agencies 8403150151 040300 PDR ADOCK 05000500 PDR D _ .

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. o Comments on WPPSS #3 from the Department of Ecol;gy While this facility will produce 'large,' calculable quantities of spent fuel, by the earliest time it can be in operation some progress will have been made toward developing one or more national high-level nuclear waste (HLW) repositories. Because of currently enticipated delays and the inherently long development time associated with the first repository, it should be noted that HLW will need to be stored on-site for at least 10 years, barring some unusual change in operating procedures.

Figure 4.1 (page 4-2): The_ site layout' map indicates the Keyes Road exten-sion to the east of the plant and into the exclusion zone. A significant section of this road is not shown--the portion that extends from near the No. 3 cooling tower, past the turbine generator, and connecting with the main Keyes Road terminus at the top of Fuller Hill. It is significant as an alternative access to the site and/or evacuation corridor. There has been some discussion of eliminating use of this road in the future in favor of diverting any required cross traffic to the plant connecting road. Use of either or both could have impacts on plant security and emergency response plans, and should be discussed in the DEIS.

Sec. 5.4.2: The Energy Facility Site Evaluation Council recognized the necessity of maintaining and testing back-up diesel engines for emergency use. The certification agreement, as amended in March 1982, waived air-quality standards for these stationary sources with respect to NO , SO , and particulate, but called for the utility to use low sulfur fuel oil (0.Y%

sulfur). With this requirement, all practical means~of providing rapid start up and load acceptance without unnecessary adverse air quality _ impacts are accomplished. Given this understanding, the conclusion appears valid.

Footnote "***", end of Table 6.1 (page 6-3), does not appear applicable to -

the table.

Sections 5.9 through 5.14 contain some very useful information, particularly when taken in conjunction with Appendices D,-E, and F. There is, however, a large amount of academic verbage that tends to dilute the real conclusions or comparisons useful to public understanding of risks and consequences. The information should be segregated into generic / site specific topics and put into laymans language if it is an essential part of the format required' tor a DEIS. Otherwise, some of it probably should be dropped in favor of taking selected portions of Appendices D, E, and F, and inserting them where appro-priate.

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March 6,1984 RECEIVED MAR o 1984 l'

D.irector, Division o'f Licensmg Dee4:stNT t ECOLOGY ENYlRONMENTAL f:EVIEW r

'U. S. Nuclear Regulatory Commission Washington, D.C. 20555

Subject:

Draft Environmental Statement - Washington Nuclear Project No. 3

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Gentlemen:

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j. Thank you for the opportunity to comment on the Draft Erivironmental-Statement (DES) prepared by the U. S Nuclear Regulatory Commission (NRC) related to the operation of Washington Public Power Supply System Nuclear Project No. 3 (WNP-3)(NRC Docket No.

j $0-508).

-The DES presents NRC's assessment of the various environmental, economic and technical-impacts, both beneficial and adverse, associated with the issuance of an operating ficense j for WNP-3. Because of NRC's unique requirements for environmental statements at both i

- the construction and operating stages, this DES examines any changes or new information that have occurred since the' construction permit stage environmental statement was issued in June'1975.

l On October 27, 1976, the state of Washington issued a Site Certification Agreement to the Washington Public" Power Supply System (SuppJy System) .to construct and;. operate WNP'-3. The Site Certification Agreement sets forth the license conditions under which -

WNP-3 is to be safely constructed and operated while minimizing adverse impacts to. the greatest exte at possible. The Energy Facility Site Evaluation Council-(EFSEC) admini-

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sters - the . certification agreement through a cocnprehensive ' monitoring - program that -

ensures compliance.with the environmental regulations, public health and safety standards:

and the other terms of the- license. In view of the - shared federal-state licensing responsibilities for nuclear _ facilities, the Council is '.very. much! interested in 'NRC's-

. updated assessment ;of the_ impacts. associated 'with an operating. project' and their relationship to our already existing licens6 and permit conditions.

The Council has reviewed the information presented in the DES and finds' that . the

' document - accurately describes project conditions and -impacts 'as ' they -' existed . in . the -

original licensing considerations, as they have evolved over. the initial construction period, iand as they 'are forecast; during; operation of the facility . ,The 'statenient pro'vides a thorough explanation of the potential environmental, technical and sociallimpacts of the project and we concur with .the determination "that WNP-3 can be operated with' minimal'

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' environmental impact." LThe following corhments'are provided on specific sections of.the -

- DES. - -

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r Director, Division of Licensing Page 2 March e,1934 i

Section 4.1 Project Descript on Resume - We would agree that the majcr change since the CP stage is the cancellation of WNP-5. While the requirements for WNP-3 remain essentially the same from the career review, many of the license conditions were based on the two units operating at the site. With only one unit now planned for operation, many of the projections for usage, design capacities, effluent amounts, etc., have been reduced significantly and have lessened the potential for impact.

Section 4.2 Water Use and Treatment - The statement accurately describes the state's requirements for water _ withdrawal, thermal discharges and design changes made in the discharge diffuser and cooling system since the CP stage.

Section 5.3.1 Water Quality - Under the state's National Pollutanc Discharge Elimination System (NPDES) Permit, the Supply System was required to conduct site specific, flow-through bioassays on local salmonids to assess the toxic levels of copper and zinc, both singly and in combination, during different times of the year and with different life stages. The results of the bioassay studies are now available and should be included in the final statement.

We appreciate the opportunity to comment on the DES and look forward to working with the NRC as you proceed with license proceedings for WNP-3. .

Sin rely, L

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"d i L- a E ecutive Secretary WLF:kc bec: Barbara Ritchie I

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February 22, 1984 FEB 2 41984 OtraniMENT OF ECOLOGY Ms. Barbara Ritchie NEPA Coordinator Dept. of Ecology Mail Stop PV-11 Olympia, WA 98504 Log

Reference:

449-F-NRC-01 Re: WPPSS No. 3 Draft EIS

Dear Ms. Ritchie:

A staf f review has .been completed of the cbove ' referenced ' draft envi-ronmental impact statement. The document adequately considers known and anticipated cultural resources and the potential for impact to- -

these.

Thank you for this opportunity to comment.

Sincerely, b

Robert G. Whitlam, .Ph.D.

State Archaeologist dw N'h)

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