ML20205P987
| ML20205P987 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 04/12/1999 |
| From: | Lochbaum D UNION OF CONCERNED SCIENTISTS |
| To: | NRC OFFICE OF ADMINISTRATION (ADM) |
| References | |
| FRN-64FR11071, RTR-NUREG-1447 64FR11071-00009, 64FR11071-9, NUDOCS 9904210053 | |
| Download: ML20205P987 (3) | |
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UNION OF PECEIVED p
- 7. b/00 CONCERNED sp a in g 9: 12 SCIENTISTS RULES & DR BPANCH US NRC April 12,1999 Chief-Rules Review and Directives Branch Division of Administrative Services Mailstop T-6D-59 United States Nuclear Regulatory Commission Washmgton, DC 20555 0001
SUBJECT:
COMMENTS ON DRAFT ENVIRON 31 ENTAL D1 PACT STATEAIENT FOR CALVERT CLIFFS LICENSE RENEWAL APPLICATION i
)
Good Day:
In accordance with the guidance contained in NRC Press Release No.1-99-22, dated March 30,1999, the Union of Concerned Scientists (UCS) respectfully submits written comments on the draft environmental i
impact statement (NUREG-1447 Supplement 1) for the Calvert Cliffs license renewal application. These written comments supplement the oral comments provided during the public meeting conducted by the 4
NRC staff on April 6,1999, m Solomons, Maryland.
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l 1.
The drall supplement environmental impact statement (SEIS) appears unfairly biased. For example, l
page 6-4 of the draft SEIS states,".in accordance with Commission's Waste Confidence Decision, j
10 CFR 51.23, a repository can and likely will be developed at some site..
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In section 8.2.4.7, the draft SEIS states,"None of these technologies [ biomass-derived fuels] have l
progressed to the point of being competitive on a large scale or of being reliable enough to replace a baseload plant such as CCNPP." Other renewable energy technologies are comparably dismissed in l
Section 8.2.4 of the draft SEIS.
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1 On one hand, the drafl SEIS gives full credit to one uncertain and unproven technology (i.e., disposal j
of high level nuclear waste). Nuclear utilities have filed suit against the Department of Energy for j
l breach of contract related to overdue acceptance of high level nuclear waste. That lawsuit clearly suggests some doubt regarding the reliability of a repository. On the other hand, the draft SEIS tosses O
aside renewable technologies because their development has not progressed enough to be reliable at this time, even though the Calvert Cliffs' licenses do not expire until July 31,2014, and August 13, 2016. The draft SEIS apparently presumes that the repository will someday become available but that renewable technologies will not. Thus, the draft SEIS appears to apply separate standards to favor nuclear power and penalize alternatives. Such inequitable treatment must be removed from the final report.
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9904210053 990412 l
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- Washington Omce: 1616 P Street NW Suite 310 Washington DC 20036-1495 202-332-0900. FAX: 202-332-0905 Cambudge Headquarws: Two Brattle Square. Cambridge MA 02238-9105 617-547-5552. FAX: 617-864-9405 Cahfomia Office: 2397 Shattuck Avenue Suite 203. Berkeley CA 94704-1567 510-843-1872. FAX: 510-843-3785 l
9, April 12,1999 Page 2 of 3
- 2. The draft SEIS fails to properly consider the potential impact on human health from radioactive releases during normal plant operation. Section 4.1.2 of the draft SEIS discusses the impacts of -
routine plant operating on fish and shellfish, reporting that "...approximately 1,600,000 finfish and blue crabs would be collected on the traveling screens,260,000 would die..".
Section 4.3 of the draft SEIS discusses the potential impact on human health from radioactive material released during normal plant operation. On page 4-16, the draft SEIS states, "No significant new information has been identified by the staffin the review process and in the staff's independent review."
During the public meeting on April 6*, I asked Mary Ann Parkhurst, Staff Scientist at the Pacific Northwest National Laboratory and the NRC representative presenting this portion of the SEIS, why impacts on fish and shellfish were discussed in detail while radiation impacts on human health were not detailed. She replied that such an evaluation was outside the scope of the environmental reviews.
In his book The Enemy Within (Four Walls Eight Windows, New York,1996), Jay M. Gould reported that the white female breast cancer mortality rates for Calvert and Prince Georges Counties are approximately 15% higher since the Calvert Cliffs Nuclear Power Plant began operating.
During the public meeting on April 6*, Dr. David Rogers, health official for Calvert County, reported that unpublished data from a cancer incidence registry maintained by the State of Maryland since 1992 shows no discernable increase in cancer rates for the three southernmost counties in Maryland compared to the state and national averages.
UCS does not have the expertise to independently determine whether radiological releases from the Calvert Cliffs plant have had adverse public health consequences. Gould's book suggests there may be a lin'k. The unpublished data cited by Dr. Rogers suggests otherwise, although the creation of the registry in 1992 prevents any before/after conclusions to be drawn from this data.
In any case, the draft SEIS fails to seriously address this matter. The drafl SEIS goes into considerable detail when evaluating the impact of plant operation on fish and shellfish populations.
The draft SEIS, at best. evaluates potential impacts of plant operation on human populations superficially.
When nuclear power plants were initially licensed, the NRC made an assumption that the various regulations goveming routine releases of radioactive materials provided adequate protection of public health. Since Calvert Cliffs is the first nuclear power plant to seek license renewal, it would seem responsible for the NRC to ensure that its original assumption is valid. An environmental impact statement with considerably less attention paid to potential human health consequences from routine radiation releases than from impingement of fish and shellfish is totally inconsistent with the NRC's federal mandate to protect public health and safety.
The final report must include a detailed assessment of potential health effects from routine radiation releases. This assessment should be a plant-specific evaluation and not a mere repackaging of past generic studies.
If detailed assessments ofpotential health effects from routine radiation releases from the Calvert Cliffs plant and from at least two (2) other sites seeking license renewal confirm the NRC's
n April 12,1999 Page 3 of 3 assumption, then it might be unnecessary to conduct this effort for subsequent license renewal applications. Until that time, it would be imprudent for the NRC to grant a 20-year extension to any nuclear power plant operating license.
Sincerely, 1)
Abauk0-David A. Lochbaum Nuclear Safety Enb neer i
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