ML20198F182
| ML20198F182 | |
| Person / Time | |
|---|---|
| Site: | Washington Public Power Supply System |
| Issue date: | 02/18/1975 |
| From: | Sant R FEDERAL ENERGY ADMINISTRATION |
| To: | Regan W NRC |
| References | |
| CON-WNP-1223 NUDOCS 8605280432 | |
| Download: ML20198F182 (7) | |
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FEDERAL ENERGY ADMINISTRATION
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WASHINGTON, D.C.
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%s Mr. William H. Regan,br.
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.r Environmental Projects Branch i
Directorate of Licensing k
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Washington, D.C.
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Dear Mr. Regan:
dju' This'isinresponsetoyourrequestforreviewandcommAt on the draft environmental statement Washington Public Power Supply System, Nuclear Projects 1 and 4, Benton County, Washington (AEC 50-460 and 513).
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Our comments are presented according to the format of the statement or according to subject.
GEOLOGY - 2.4 - This section of the statement indicates that no detailed geological discussion of the area is uvulained in the environmental impact statement.
- Instead, it indicates that a detailed discussion of the geology will be contained in the AEC Safety Evaluation Report.
Notwithstanding this report, some discussion of the local geology of the proposed site area as it relates to the safety of the proposed projects should be included in the environmental impact statement.
Since the potential for faulting may significantly affect the analysis of environmental impacts, the safety of the projects and a discussion of this issue is necessary.
The Safety Evalu-ation Report does not receive the circulation and review that an environmental impact statement receives and may be published at a much later date.
In particular, a discussion of the tectonic history of the region should be summari:ed in the statement.
While it is probably not necessary to include an exhaustive review of all geological literature regarding faulting in these particular basalt fields, the statement should explain the potential consequences of fault movement in the area and assess the probability of faulting in the region.
181"I B605280432 750218 PDR ADOCK 05000460 D
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. It is recognized that there is no conclusive evidence of any faulting in the area since the Miocene period, how-ever, there has been a study done by the United States Geological Survey which supports the contentions made in the " Jones Report"* that the area may be much more tec-tonically active than generally believed.
These and other geologic reports, published and unpublished, on both the sedimentary formations and the basalt flows of this region should be compiled and summarized and con-clusions drawn as to safety of placing the nuclear reactors in the area and disposing of nuclear waste (including fission) products in the area.
The discussion of local geology as it presently exists in Section 2.4 is much too generalized and provides no essential information upon which to judge the environ-mental impact of the proposed activity.
NOBLE GASES - 5 The statement estimates the probable gaseous and particu-late releases in Table 3.4 and uses those estimates to evaluate the p,otential radioactive dosages due to gaseous effluents upon man in Table 5.10.
However, when the environmental impact of gaseous effluents are analyzed -
in Section 5.4.2.3, a discussion of the environmental impact of direct releases of the noble gas Krypton-85 (which has a half-life of 10.7 years) is not included.
That.section asserts that the primary food pathway to man is through a process of digestion by dairy cows of r.adiciodine deposited into the grazing areas, the con-sumption of milk from these cows by man, and the resultant exposure of the human thyroid to radioactivity.
- Jones, F.O. and Deacon, R.J.,
Geological and Tectonic History of Hanford Area and its Relationshio to the Geological and Tectonic History of Washington State and Active Seismic Zones of Western Washington and Western Montana, D.U.N.
1410, June 1966.
This contro-versial report corroboraten earlier independent findings by Royce and Skeehan of relatively recent active fault zones, especially along the north slope of the Rattle-snake ridge line.
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. Table 5.7 presumably includes the deleterious effects of krypton-85 upon the skin and lungs of human beings located various distances from the site itself.
Section 5, however, does not consider the residual effect of krypton-85 or any other gaseous affluents upon biota directly exposed to gaseous effluents (other than for grazing which does not occur close to the site).
Other birds and animals may come close to the sites, and thereby become directly ex-posed to the gaseous affluents and take on a toxic dose in the process.
This toxic dose can be ' concentrated and move through the food chain to endanger both higher pre-dators and man.
It is unclear from the description of the gaseous waste management system (GWMS) in Section 3 that sufficient amounts of krypton-85 will be stripped from the gaseous waste and placed in controlled containers.
If not, the alternative of installing cryogenic noble gas strippers f
and facilities to compress and bottle krypton-85 should
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be discussed.
RADIOLOGICAL CONSEOUENCES OF POSTULATED ACCIDENTS - 7 Both Table 5.11, which summarized the anticipated annual total body dose of nearby populations and Table 7.2, which summarizes the radiological consequences of postu-lated accidents, are calculated for a population within 50 miles of the proposed site.
The dosage estimate in Table 7.2 was also based upon a projected population within 50 miles of the site.
In reality, Richland, Washington, is located only 10 miles south of the site, and two other population centers --
Kennewick, Washington, and Pasco, Washington -- are located within 15 miles of both sites.
Both Table 5.11 i
and 7.2 should be revised to reflect the proximity of these population centers to the proposed sites anc the potential damages should not be described in terms of a 50 mile radius.
Table 7.2 also reflects only those radioactive dosages transmitted aerially.
In reality, an accident may result in the contamination of the Columbia River and local aquifers and irrigation systems.
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Moreover, the accidents set cut in Table 7.2 reflect relatively insignificant sub-classes of accidents within each class described.
For example, in Class 7 (Spent Fuel Handling Accident), the sub-classes include only those accidents which occur in the fuel rack itself.
No discussion er consideration is made of an accident in which containers of very dangerous spent fuels such as spent fission materials are released to the environment as a result of a railroad derailment or a sLnilar serious accident.
The probability of such an accident is of course smaller than some of the sub-classes discussed, however, the consequences of such an accident are much greater and it is those consequences which would have a significant effect upon the surrounding environment.
To pick rela-tively inconsequential accidents within each class is to make a self-serving analysis.
The stated intent of Section 7 is to discuss the environmental impact of postulated accidents.
Further, the statement in Section 7.1 which reads, "To 7
rigorously establish a realistic annual risk, the cal-f' culated dose in Table 7.2 would have to be multiplied by esrimared probacilities" really serves as a limiting factor on the discussion of Section 7 (Environmental Impact of Postulated Accidents).
For example, Section 7
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goes on to say that the probability of a " Class 9" acci-dent occurring is so low that the consequences will not be discussed in an environmental impact statement.
While the "Rasmusson Report" discussed in Section 7.2 does indicate that the probability of a Type 9 accident is extremely low, the consequences of,such an accident are extremely severe.,
Section 7 purports to present the environmental impact of postulated accidents but then goes on to say that some of these accidents are so un-likely that consideration of their environmental impact will not be made.
One of the primary purposes of an environmental impact statement is to assess the danger to that environment of a proposed action.
The proba-bility of such an accident is important and was reiter-ated several times in Section 7.1, nevertheless, the consequences of such an accident are also important and should be stated as well.
The statistical probabilities
.. of a " Type 9" disaster are based upon accidental occurrence and not upon a conscious sabatoge effort or as a result of warfare.
To not discuss the consequences of " Class 9" accidents is to circumvent the issue which causes the most concern to the public at large and which carries with it the greatest potential environmental impact.
NEED FOR POWER GENERATING CAPACITY - 8 One of the primary concerns of the Federal Energy Adminis-tration with the proposed action and its discussion in the environmental impact statement is whether the forecasts of power needed in the region are as accurate as possible.
The power requirements discussed in Section 8.2 are based upon the regional energy consumption specified in Section 8.2.1.
A graphic depiction of this consumption rise is made by means of a linear regression curve on Table 8.2.
These forecasts are termed " reasonable" by the AEC staff but no substantive date is provided except for reference to the Pacific Northwest Utilities Conference Committee's West Group Forecast (WGF) and a Bonneville Power Administration publication.
We have reviewed these documents and nowhere in the textual materials of the forecasts did we find a discussion of the forecasting methodology employed.
Absent 7
such a discussion, we can find no evidence upon which the
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AEC ct:ff cculd hav: ::::pted er rejected a single value forecast depicted in Table 8.2 on the basis of " reasonableness."
We have been unable to ascertain if, and to what extent, the forecast is based upon an extrapolation of historical trends, or upon other information unavailable to the public and utilities.
We could not find a quantitative analysis of l
the potential effects on future electric energy consumption l
of such other factors as (1) changing building insulation l.
requirements; (2) a concerted education effort to gain popu-lar support for energy conservation programs (discussed briefly in Section 8.2.3.2) ; (3) or changes in electric rate structures and the consequent effects of price elastic-ity; or (4) the effect of substitution of alternative energy sources such as liquid and gaseous hydrocarbons upon demand.
In short, it is not apparent how the Atomic Energy Commis-sion staff came to decide that the single value estimates as forecasted were reasonable or unreasonable.
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This comment should not be taken to imply that demand, as dampened by conservation efforts and energy efficiency, should be allowed to outstrip the available supply of electrical energy, but is an expression of concern that the unnecessary expansion of energy supply will act as a disincentive to conservation while raising the cost of energy.
Consumer Costs The statement does not include a discussion of how these increased rates will be imposed upon the public.
Section 8.1.5 states that in the late 1960's the Bonneville Power Administration had a " net billing" agreement with utilities in the region which had the effect of spreading increased cost among all member utilities.
It is also indicated that the " net billing" arrangement was effectively discontinued in 1973.
However, the state-ment does not explain what the present and future plans of the BPA or the Washington Public Power Supply System has for implementing the increased incremental cost of energy production.
Without such information, it is diffi-cult to assess the environmental impact of the increased energy costs attendant to the project.
Section 8.2.3.4 speaks in general terms about alternative rate structures such as inverted rate structures and peak period differential pricing.
It is also indicated that the demand elasticity of such pricing structures is un-certain.
However, the statement does not indicate whether ~
the members of the Washington Public Power Supply System will attempt to effectuate such a pricing structure.
If an alternative rate structure is not established, how will the increased incremental cost be passed on to consumers?
ALTERNATIVES - 9 Section 9 does not discuss in adequate detail the alternative of diminishing demand for electrical energy as a result of conservation measures undertaken by the consumer.
Section 8.2.3 discusses the need to conserve in general terms and alludes to the " Report to the President on the Nation's Energy Future."
However, this alternative is not discussed further as an alternative to generating electricity by nuclear means.
Alternatives could include, in addition to inverted rate or peak period differential price structuring,
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offering a discount or other incentive for installing insulation, conversion from resistive electrical heating mechanisms to more efficient heat pumps, or other rate incentives based upon a reduction of consumption over that used in a " base period."
If such conservation alter-natives are effective, it may defer the need for at least one of these projected power plants and thus substantially reduce the environmental impact on the area.
We hope that our. comments will be helpful to you in the preparation of the final impact statement and in your further consideration of the proposal.
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Y ger W. Sant Assistant Administrator Energy Conservation and Environment 9
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