ML20116B322
| ML20116B322 | |
| Person / Time | |
|---|---|
| Site: | Beaver Valley |
| Issue date: | 03/11/1985 |
| From: | Pomponio J ENVIRONMENTAL PROTECTION AGENCY |
| To: | Knighton G Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML20116B310 | List: |
| References | |
| NUDOCS 8504250222 | |
| Download: ML20116B322 (2) | |
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
[ O,3 REGION ill 841 Chestnut Building Philadelphia, Pennsylvania 19107 Mr. George W. Knighton, Chief Licensing Branch No.3 Division of Licensing MAR 111985 Nuclear Regulatory Commission Washington, D.C. 20555
Dear Mr. Vnighton:
Region III of EPA has completed its review of the Draf t EIS related to the operation of the Beaver Valley Nuclear Power Station. Our comments presented below center around the issues of, water quality, air quality, radiation, and decommissioning. These* concerns have led us to the con-clusion that the Draft EIS deserves a rating of EC-2, meaning that we have environmental concerns relating to the issues above, and that the the document includes insuf ficient information for these areas of con-cern. Our technical conusents are presented here for your consideration in preparing the Final EIS.
Water Issues:
Although most of the information presented in the Draft EIS is adequate, we have reservations regarding the effluent water quality. The water quality description on pages 4-10 and following indicates that improvement in water quality has been made since _1974, appearing to indicate an upward trend. The text on pages 5-3 and 5-9, on the other hand, detail loadings of criteria pollutants that will add to the pollution load levels already existing in the receiving waters. Even though it is stated that these loadings and levels will "... not necessarily result in adverse effects...", we feel that using mortality and survival as the measures of water quality begs the issue of maintaining and improving water quality.
The operator should make an effort to lower or eliminate these pollutant levels through treatment so that water quality in the receiving waters may continue its current upward trend in quality.
g, It is EPA's policy to adhere to the antidegradation clause of the Clean EHEB Water Act. The practice of incremental addition of these and other pollu-tants at this plant appears to set an unwise precedent that may be repeated elsewhere. Such incremental additions can result in the long term cuculative effects throughout receiving streams that appears to be contrary to the principles of the Clean Water Act.
Air Issues:
The description of airborne releases on page 5-5 presumes that, since the total annual emission does not exceed 250 tons and no air pollution standard will be violated, no further analyses are needed. This presump -
tion is not necessarily correct. The 250 tons per year is a cutoff below EPA-2 which no PSD (prevention of significant deterioration) permit is required.
'Ihe fact that plant's emissions will be below the cutof f does not assure EHEB that the ambient standards will be met. The document is deficient in the area of air quality analyses since no calculation of the expected air quality is performed, nor are the emission estimates stated. This is a 8504250222 850411 PDR ADOCK 05000412 D
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serious deficiency and should be cleared up prior to publication of the Final EIS so that it is assured that air quality standards will not be exceeded.
Radiation Issues:
It is acknowledged that most of the airborne radiological releases are a result of normal operation and it is our opinion, that this issue is adequately treated in the document. It is also our opinion that acciden-tal releases are probably adequately. treated, we are concerned with the the continuum of NRC documention of small component failores. The likeli-EP A-3 hood of a major accident is probably not mLsrepresented, however.
RAB In another matter, EPA has set standards for radiation releases from the uranium fuel cycle. Page 5-21 states that Unit 2 will be in com-pliance with the standard, using the statement, "the NRC staff concludes that under normal operations the Beaver Valley facility is capable of EPA-4 operating within these EPA standards." The identical statement has RAB appeared in previous EIS's and leaves EPA and the public with inadequate assurances that the standards of 40 CFR 190 will be met. These standards apply to the entire uranium fuel cycle, not just operation of the power plant.
Furthermore, page 6 of Appendix C quotes a 1975 NCRP (National Council on Radiation Protection) report regarding impacts of radon 222 dose to bronchial epithelium. The national average yielding a dose of 450 milli-rems has been revised to 3000 by NCRP, representing a substantial increase.
Since mining and milling contribute substantially to the dose from the EPA-5 uranium cycle the use of obsolete information is improper in this document. RAB The Final EIS and other future NRC and applicant documents should reflect i
the revised limits.
l Deccamissioning:
l Page 5-53 and following presents too little information regarding dose estimates and reviewers had to look elsewhere in NRC documents. In addi-EPA-6 tion, one reviewer was informed that NRC is developing more explicit RAS information than is current,1y available on decommissioning. The Final EIS should include more detailed information than is detailed in this document.
==
Conclusion:==
Improved analytical work and updated information is important to your Final EIS. In addition, further work on the possibilities of treating the effluent f rom the various water-using operations should be carried out. If you have any questions on any of these issues please call Bob Davis on (215) 597-8327 (Comm. and FTS).
l Si cerely.
A j/
in R. Pom on L
y, iarch 4, 1 -MS
. - /
318 Sumnit Ave. #3 Bri.Thton, Nass. 02135 of fice - af :iu :Iear detictor nepulstio,
U. S. Huclear Rerulatory Commission Washinrton i). C. 20555 RE: CO..f1EHTS ON TH6 Du,sil' ci!Vih0N.ia!%L df,1f6MelPI RELAT6D TO fHE Of 6 RATION Ur' l' aid B!:./ Vod V!iL! cY PO.inR STATION,
UHlT 2 (NUREG-1094) (Docket 50-412)
John F. Doherty, aitress above, comments as below on the DEIS of the Commission with regard to the Beaver Valley plant.
Comment 1 Page D-1 of the DES states, "For younger persons, changes in organ mass and metabolic parameters with eBe after-the initial uotake of rsdioactivity are accounted for."
This would seem to indicate an accounting for the age, but not the sex of the individual.
While there are certainly changes with age in adolescense for both JFD-1 sexes, the_ DES should in dicate if its assessment RAB dose takes into account ekposure to radiation from the of plant for females at puberty and women in the early stages of pregnancy when there is rapid proliferation of breast tissue cells with increased risk of one of the forms of breast cancer.
Comment 2 The DES fails to mention other serious cancer and infant mortality impacts on human be:
s from tailines JFD-2 piles which must be crested the _ Beaver Vallev - 2 plant. to urovide the fuel for "
RAB T t.u s, at pures 4 and 5 of Aonendix C, in the section titled "Raion-222" the
- DSS should mention both non-fatal cancers and deaths to infants due to radiation induced birth defects.
Thank you for this coportuaity.
Respectfully, w
k l Jonn F. Doherty' c.c. Ms. Marilyn Ley, Pro j ec t. la na.y:e r s,s.n il -
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