ML20136H461
| ML20136H461 | |
| Person / Time | |
|---|---|
| Site: | Beaver Valley |
| Issue date: | 11/15/1985 |
| From: | Pepino R ENVIRONMENTAL PROTECTION AGENCY |
| To: | Knighton G Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 8511250116 | |
| Download: ML20136H461 (1) | |
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
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NOV 15 '85 Mr. George W. Knighton, Chief Licensing Branch No.3 Division of Licensing Nuclear Regulatory Commission Washington, D.C. 20555
Dear Mr. Knighton:
I Region III of EPA has reviewed the Final Environmental Impact Statement for the operation of the Beaver Valley Power Station.
The following comments are offered for your consideration.
The NRC staff response to EPA's previous comments (EPA-1, p 9-5, Final EIS) fails to adequately address the issue of water quality.
Our comment on the Draf t EIS dealt with the improvement in water quality, not the acquisition of waivers to the NPDES Effluent Guidelines.
The Clean Water Act states that it is "the objective... to restore and maintain the chemical, physical, and biological integrity of the Nation's waters" (Sec.101.(a) and amplified else-where). As stated in EPA's letter on the Draf t EIS, environmental quality should not be based upon survival and mortality statistics, but rather on treat-ment technology that would assure the current upward trend in water quality that has been taking place since 1974.
Regarding accident sequence probabilities (EPA-3, p 9-10, Final EIS), the statistical base would be more reassuring than it is if the analysis were based on long-term available data.
In this way the NRC staff could reliably predict accident probabilities rather than rely upon staff opinions.
While we do not want to denigrate the staff's professional assumptions, we believe that technical evaluations based upon statistics rather than intuition, would provide a more obj ective approach than that represented by the EIS.
With the exception of these comments, we find the Final EIS acceptable.
Sincerely, Richard V. Pepino, Chief NEPA Compliance 8511250116 851115 88 PDR ADOCK 05000412 D
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