ML20206A056
| ML20206A056 | |
| Person / Time | |
|---|---|
| Site: | Humboldt Bay |
| Issue date: | 06/11/1986 |
| From: | Snow G CALIFORNIA, STATE OF |
| To: | Erickson P Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML20206A049 | List: |
| References | |
| NUDOCS 8606180008 | |
| Download: ML20206A056 (12) | |
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Resources Cuiidng GEORGE DEUKMEJIAN Air R: sources Board 1416 Ninth Street GOVERNOR OF Catornia Coast;# Commission CALIFORN!A Cahfernia Tahoe Conservancy 95814 Cahfornia Waste Management (916) 445-5656 Board TOD (916) 324-0804 Colorado Rever Board Energy Resources Conservation Cahfornia Conservation Corps I m I And Development Commission San Francisco Bay Conservation Department of Boating and Waterways and Development Commission
= Department of Conservation State Coastal Conservancy Department of Fish and Game State Lands Division
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De rtm ni of : and Recreation State water Resources Control SACRAMENTO, CALIFORNIA Department of Water Resources Regional Water Quahty Control Boards Mr. Peter Erickson
. Nuclear Regulatory Commission Standardization & Special Pro,jects June 11, 1986 Washington, DC 20555
Dear Mr. Erickson:
The State has reviewed the Draft Environmental Statement for Decommissioning Humboldt Bay Power Plant, Unit 3, submitted through the Office of Planning and Research. -
Review of this document was coordinated with the Coastal, Energy, and Public Utilities Commissions, the Air Resources, Reclamation, and Regional Water Boards, and the Departments of Boating and Water-ways, Conservation, Fish and Game, Parks and Recreation, Water Re-sources, Health Services, and Transportation.
Attached for your consideration and use are comments received from the staff of the Coastal Commission.
The Department of Health Services comments that its Division of-Hazardous Waste Management will contact the applicant directly on this matter.
The North Coast Regional Water Board is already working directly with the applicant.
Thank you for providing an opportunity to review this document, S n. rel /
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t ordon F. Snow, Ph Assistant Secretary'for Resources Attachment (1) cc: Office of Planning and Research 1400 Tenth Street Sacramento, CA 95814 (SCH 84112723) 8606180008 860611 PDR ADOCK 05000133 D PDR ,
% a L STATE OF CACORNIA-THE RESOURCES AGENCY GEORGE DEUKMERAN, Govemor
- CALIFORNIA COASTAL COMMISSION ,--
NORTH COAsi AREA 7 -
y 431 HOWARD STRitT. 4fH FLOOR SAN FRAN?ISCO, CA 9410s (4 m s434sss June 9, 1986 Mr.? ken Fellows
-Resources Agency
.1416 Ninth Street, Room'131
.' Sacramento, CA 95814 g REi SCH:.#84112723--Decommissioning of Humboldt Bay Nuclear Power Plant #3, Eureka, California
Dear Mr. Fellows:
'Thank you for the opportunity to comment on the proposed decommissioning of the Humboldt Bay Nuclear Power Plant. The staff of the California Coastal Commission has reviewed the information in the Draft Environmental Statement (DES) prepared by the U.S. Nuclear Regulatory Commission (NRC). The remarks that follow are solely those of staff and-not the Commission itself. This letter is intended to provide early identification of the areas of concern to
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the Commission staff in order that these issues can be adequately addressed in the Final Environmental Statement (FES). We may modify these' comments in' response to any changes in information in any supplementary DES or the Final Environmental Statement (FES).
Humboldt Bay is the largest wetland and estuarine habitat in the California coastal zone, containing approximately 23 percent of the coastal wetlands in California. Its waters hold a diverse fish fauna,. including anchovies, chinook and cojo salmon, steelhead, cutthroat trout, smelts, surfperch, . .
rockfishes, sand dabs, soles and flounder. Thirty six species of fish utilize the bay as a nursery ground or spawning area. The invertebrate biota of the '
bay. include species.in sixteen major invertebrate groups. Approximately 750
- acres of the bay's bottom and channels are used for commercial oyster m l production. Many of the bird species using the. bay are prutected by
! international treatles which impose national responsibility'for protection of their habitats. Peregrine falcons, which are on the federal endangered -
species list, hunt over the bay's marshes and farmlands, and rare and L endangered plants grow on the dunes and in the brackish and' saltwater
, marshes. The rivers and streams tributary to'the bay provide spawning 4
habitats.for anadromous fish,.and the bay's estuarine areas provide important
- - nursery areas for juvenile salmon and trout. Streamside riparian habitats L hold diverse wildlife populations. The Coastal Commission has.a long history l
of concern for protection these and other resources of the Humboldt Bay area.
'-~ :The DES is notable in that it provides virtually no description or analysis of
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environmental setting of the proposed activities.
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Mr. Fellows June 9, 1986 Page 2 Should the-proposed decommissioning commence, the development activities associated with it will be subject to the provisions of the California Coastal '
Act (Cal. Public Resources Code, Division 20, Section 30000 et seq.). Section 30600 requires that any new development in the Coastal Zone be authorized by a coastal development permit. " Development" is defined (Section 30106), in part, as:
" Development" means, on land, in or under water, the placement or erection of any solid material or structure; g discharge or disposal of any dredged material or of any gaseous, liquid, solid, or thermal waste; grading, removing, dredging, mining, or extraction of any materials; change in the density or intensity of use of land, including.....
change in the intensity of use of water, or of access thereto; construction, reconstruction, demolition, or alteration of the size of any structure, including any facility of any private, public, or municipal utility;...
As used in this section, " structure" includes, but is not limited to, any building, road, pipe, flume, conduit, siphon, aqueduct, telephone line, and electrical power transmission and distribution line.
In connection with the coastal permit process, Commission staf.f is available to assist the applicant in answering any questions or. to serve in a consultative capacity.
According to the information provided by the NRC, Pacific Gas and Electric (PG&E) proposes to decommission the Humboldt Bay Nuclear Power Plant in a (1) safe storage (SAFS10R); and (2) delayed two-step process:
decommissioning (DECON). PG&E (the licensee) proposes to store the spent fuel assemblies at the Humboldt Bay site for at least 30 years to be followed by a dismantling of the entire nuclear facility, a process of indeterminate length and one for which no plan yet exists. As the following comments indicate, we -
do not believe that current plans or documentatlon have adequately addressed the potential significant environmental impacts of long term storage of nuclear materials at Humboldt Bay in the manner required by either the National Environmental Policy Act (NEPA) or the Coastal Act,
- 1. Soil and Water contamination The Humboldt Bay area includes about 12,000 acres of farmland, including about .
7,000 acres of diked lands. These farmlands, including portions of the bay's diked lands, hold a substantial area of prime agricultural soils. Eastern Humboldt Bay contaias approximately 4,000 of agricultural land of high value ,
to the local farm economy.
The DES identifies the problem of continuous leakage (since 1966) of radioactive liquid f rom the spent fuel pool which has resulted in soil contamination. The document further states that the installation of a stainless steel liner has attenuated the leak. We note, however, that the radioactive discharge has not been halted. In view of the licensee's proposal
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I Mr. Fellows June 9, 1986 Page 3 l to store the irradiated fuel assemblies and in-core fission chambers within the same pool, we believe that there is a greater risk for a higher level of soil contamination than has been indicated in the DES. Moreover, this leakage has the potential to contaminate the ground water basin beneath the plant facility. As noted in the Environmental Report (ER), there is exchange of water between the bay and wetlands and ground water in the vicinity of the plant. The DES states that, " Pumps keep water level in the liner gap lower than the water level in the pool and ground water level. The water from the liner gap is pumped to the radwaste system". (p. 2-1,5). Such mechanicals means of controlling the leak are subject to malfunction. The FES should fully disclose the potential cumulative effects of increasing the amount of long-term storage of radioactive liquid in a pool already plagued by leakage.
Further, the FES should more fully identify measures for mitigating the potential impacts, including pump malfunction and leakage risk. This analysis should address effects on area farmlands, ground water, wetlands, and bay waters.
According to the ER, a 1981 evaluation of the nuclide distribution and inventory at Humboldt Bay Power Plant indicated elevated and trace levels of certain nuclides.
These samples indicate areas of the Unit No. 3 exclusion grounds which may require decontamination prior to dismantlement since concentrations in these surface soils are all in excess of the proposed acceptable limits for residual soil contamination. (p. 4-64 ER.)
A soil analysis of transuranics in the exclusion area conducted by Pacific Northwest Laboratory (PNL) in 1983 also indicated the presence of plutonium of reactor origin. The ER states that "...the TRU concentrations may not be
- significant from a waster management viewpoint and would not warrant . soil excavation for disposal as LLW." It appears that varying levels of soil .
contamination persist in spite of efforts to contain the radioactive nuclides. The proposal to enclose the radwaste building for storage of '
additional contaminants generated by the SAFSf0R process may increase soil contamination.
The DES does not provide adequate information to determine how the proposed construction will incorporate safeguards to prevent soil and, possibly, contamination. The FES should contain additional data, plans and mitigation measures suf ficient to ' protect the environment around the plant f rom additional nuclide contamination.
- 2. Seismic Safety The decision of PG&E to pursue decommissioning was based upon several
- considerations including economic factors
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'In 1983, the licensee (Pacific Gas and Electric Company) concluded that-the seismic and TMI modifications
- required for restart were uneconomical and decided to decommission the plant. - ( p. 1 -1, DES. ) ,
In light of this history, we believe that the DES' treatment of seismic hazards-of this site and their potential ef fect in connection with the proposed project is too cursory.
The Environmental Report For the Decommissioning of Humboldt Bay Power Plant
[HBPP] Unit No. 3 (July,- 1984) indicates that there are three capable or potentially capable geologic faults near the H8PP: (1) Little Salmon Fault; (2) Bay Entrance Fault; and (3) the Buhne Point Fault. The surface trace of each fault passes within 21/2 miles of the facility with the Buhne Point subsurface trace coming within 600 feet of the plant foundation. Furthermore, the ER states that:
The proximity of these capable or potentially capable faults to the plant site, along with the assumption (WCC 1980) that major earthquakes could occur (with magnitudes up to 7.5) suggests that severe ground shaking could result from seismic activity generated along these faults. ( p . 10. 3-14)
Other potentially active faults have been documented in " Identification of Seismic Related Hazards in the Coastal Zone" (1977) and include the following faults 'within approximately 40 miles radius:
, The Falor-Korbel fault (active) transects northwest Arcata and is capable of a 6.0 to 7.0 M earthquake (ENVICOM, 1975).
The Cape Mendocino-False Cape Shear Zone (active) is -
estimated to be capable of a 7.3 M earthquake. .
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The Mendocino Fracture Zone (potentially active) is located in (or comprises) one of the most seismically active areas in -
North America. (V-[7]) .
(The Mendocino fracture zone is part of the tectonically active triple plate junction and is capable of a 7+ [ Richter scale] magnitude [ November,1980] and is possibly capable of a seismic event of " great quake" magnitude [8.0 or greater]).
I The report continues by stating that "Within the boundaries of the coastal zone, the majority of land areas ranks as 'least suitable' for siting of
- Modifications necessary to comply with requirements imposed after the accident at Three Mile Island (TMI) Unit 2.
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Mr. Fellows June 9,1986 Page 5 critical facilities...The criterion establishes 'least suitable' areas as those falling within a five-mile radius of a capable fault." The study considers much of Humboldt Bay as falling within a least suitable area.
It is evident that the plant site is located in an area with a high degree of
' Seismic activity, either active or potential, and that large, active f aults within 20 or even 40 miles of the Coastal Zone may have a substantial impact on the plant facility with concomitant adverse effects on coastal zone resources. The Energy Dilenma (California Resources Agency,1973, p. 46)s points out the shortsightedness of assuming an area safe from seismic hazards due to the fact that existing maps and data do not indicate active faults:
Indeed, in the past decade evidence has been produced to show that faults not previously recognized as active are potentially active. Further, with few exceptions, every earthquake that caused fault rupture and every swarm of earthquake epicenters has occurred along faults not previously recognized as active. Certainly the 1971 San Fernando earthquake occurred along a fault not previously known to be active.
The DES on this proposal for long-term storage of ' radioactive materials in an area highly susceptible to seismic hazards contains virtually no analysis of relevant seismic factors and only cursory consideration of those hazards' interactions with hazardous materials stored on site. The utility's inability to carry out the seismic modifications necessary to continue operation of the nuclear plant were in a large part responsible for the economic decision to decommission the plant. It seems contradictory for plant operator's to conclude seismic hazards required closure of the plants, and to also conclude
- that radioactive materials can be safely stored at this same seismically ' '
hazardous site for a period of 30 years. For example, in the existing alternatives analysis, one off-site alternative, independent spent fuel storage installation (ISFSI) is rejected in part because of possible seismic cons idera tions. The DES states: "
Thus, this alternative would be more costly than SAFSTOR, would have the additional environmental impacts associated with of f-site transportation, and would require seismic
- considerations of the ISFSI. (p 1-4, emphasis added.)
The anomaly of this result is highlighted by the DES discussion of the ENTOMB alternative which says, "The entombment structure may also fall as a result of seismic events with a potential for a release of radioactivity." (p.1-3.)
Apparently, even when entombed in a concrete container, the radioactive liquid cannot be safekept against seismic events. It is unclear how SAFSTOR will provide the necessary seismic security.
In fact, it is quite likely that the 30 year SAFS10R period may extend beyond this timeframe. As indicated in the ER:
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7 Mr. Fellows
' June 9, 1986 Page 6 The duration of SAFSTOR at HBPP Unit No. 3 may be affected by several factors:
availability of DOE repository for receipt of spent fuel from Unit No. 3; dose rate reduction sufficient to reduce / eliminate the need for remote handling; and need for site occupied by Unit No. 3 to be used by PG&E '
for an alternate purpose. (p. 6-5, ER)
It is dif ficult to account for the contradictory decisions to store spent fuel in a seismically active area while rejecting a potentially safer site on the basis of " seismic considerations." Also, the proposed 30-year SAFS10R period may extend for an indefinite period, further increasing the possibility that the facility will be exposed to seismic events, an issue not fully explored in either the ER or DES. These gaps in the environmental information and analysis must be closed before an adequate consideration of impacts, mitigation, or alternatives can occur. Clearly, substantial supplementation d this DES is needed to adequately address the seismic safety issue.
- 4. SAFSTOR /
- a. Radioactive Waste Storage The DES describes the radioactive waste management systems proposed for implementation during SAFSTOR, indicating that " liquid waste generated during the SAFS10R period will be processed and disposed of." Elsewhere, the DES states that " dry active waste and contaminated tools, equipment, lumber, and soil will be packaged for shipment and stor'd until they are shipped of f s.ite -
for disposal." In both instances, it is vague as to which of the contaminated l materials can be considered " low level waste" and thus may be dis ~ posed of f-site, and which materials contains a higher degree of radioactivity necessitating on-site storage. The DES is vague regarding the amounts of each .
type of material which will be stored on-site until a permanent licensed j disposal site is established. Further, it is unclear as to the location of a l LLW site and if existing materials are already being transported there. If PG&E has such a site already' selected, then the FES should state the location and evaluate the associated impacts at that location.. If one-is not available, then information should be provided regarding long-term storage of i high and low level radioactive materials.
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- b. Radwaste Building
- The DES indicates that "a building will be erected to enclose the exposed portions of the radioactive waste processing system." However details
( regarding the dimensions, site plans, or seismic standards to which it will be l built are not included in the DES. The FES should provide sufficient detail
! regarding the radwaste building in order that public safety is ensured and in order that the Coastal Commission may determine whether the structure's design l and location are most protective of coastal resources.
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4 Mr. Fellows June 9, 1986-Page 7 Additionally, we remain concerned about development of another facility to
' store radioactive wastes in a seismically hazardous area. Presumably, the ,
structural integrity-of.the radwaste building will not meet the standards required of the larger power facility. Thus, it may be more susceptible-to
. earthquake damage with the resulting radioactive contamination of:the soil, ground water,'and 'open waters of Humboldt Bay. The FES should contain a
. seismic analysis for the proposed structure as wellias- details regarding any backup systems available to prevent contamination of the area should the primary system fail or be disabled by structural or power failures resulting from seismic events.
- c. Chemical Decontamination The ES indicates that it will be necessary to use chemical agents to decontaminate the facility at various phases of the decommissioning process:
The chemicals employed can have hazardous properties and/or
, toxic properties. In addition, these chemicals have appilcations to routine radiological waste management, such as solidification inhibition or evaporation attenuation.
Pre-treatment of these waste prior to disposal...can have toxicology consequences. (p. 10.5-23, ES)
The ES further notes that "use of chemicals has implications to shallow-land burial". Although existing state and federal regulations address the environmental consequences of the disposal of these hazardous materials,.it is critical to know which of these materials will remain on-site (and for how long), as well as the intended disposal site of those chemicals which can be safely transported to a licensed disposal facility. It is also important to know how hazardous materials presently used in plant maintenance and opera' tion are transported and~the location of the disposal site. The FES should provide this information, including alternatives to off-site disposal and mitigation .
measures.
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- d. . Alternatives to SAFSTOR Throughout the DES, the argument supporting SAFSTOR is based largely upon the assumption that there is no disposal site available for the spent nuclear fuel assenblies and that any federal decision regarding a licensed disposal site will be forthcoming during the 30-year SAFS10R period. The DES refers only to NRC disposal sites and ignores any other alternative sites which may be available through the Department of Energy (DOE) or other agencies.
For example, nuclear waste from at least two other major nuclear plants is being taken to other federal disposal sitet run by DOE. Nuclear waste f rom ,
the Three Mile Island nuclear plant in Pennsylvania is being shipped to the Hanford Reservation in eastern Washington. This same site is also slated to receive the nuclear material from the Shippingport nuclear power plant, also located in Pennsylvania. It is our understanding that Hanford has also been receiving' nuclear material f rom the Hur.coldt Bay nuclear plant for many years, in that there was a significant hazard associated with THI, and that Shippingport is being dismantled, there appears to be an established precedent t
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., i Mr. Fellows June 9, 1986 Page 8 for utilizing Hanford as a disposal site in certain situations where public safety is an overriding issue. The FES should'give stronger consideration to this alterative and explore not only shipping of nuclear fuel assemblies, but dismantling the entire facility to be ultimately disposed at Hanford or elsewhere. ;
In addition, the ES assumes for the purposes of analyzing the potential
' radiation occupational external dose and public dose _for fuel handling and shipment that the DOE facility in Carlsbad, New Mexico will be the repository for spent fuel. It is unclear why this facility was used for analytical purposes but not seriously considered for immediate disposal of the spent, fuel. Moreover, if this site is not available for disposal of radioactive waste, then the information presented in Table 7-1 (p. 7-5, ER) is not relevant and the DES should be revised to reflect data for sites that are realistic alternatives (e.g., Hanford). However, if the Carlsbad f acility is a potential receiver site, then PG&E and the FES should thoroughly analyze the possibility of using it as a repository for the fuel and other contaminated material from Humboldt.
Similarly, the ES indicates that "the reactor vessel might by shipped by barge, as the Shippingport vessel is scheduled to be shipped, to a commercial site at Richland, WA." (p. 10.6-7, ES). If this component of the Pennsylvania
. plant can be transported across the country to Washington, why is it not feasible to transport the same elements of Humboldt to Richland? Answers to the above questions will be necessary in order that the Coastal Commission can determine whether the final proposal is most feasible, least environmentally damaging alternative,
- e. Pro _iected Costs for SAFSTOR/DECON It is difficult to clearly ascertain the total costs involved in implementing
. the SAFSIOR/DECON alternative. Neither the Executive Summary in the ES nor the DES contain readily available information indicating the 30 year costs for SAFS10R and DECON. As the information provided for DECON is largely' conceptual, we are most concerned about the projected costs for this phase of decommissioning. Without this information, evaluation of the feasibility of ,
the various alternatives is not possible.
- 4. California Coastal Act of 1976 As discussed earlier in this comment letter, if the proposed decommissioning of Humboldt Bay Nuclear Plant proceeds as described in the DES, it will be subject to permit requirements of the California Coastal Act of 1976. At the time a coastal development permit application is received, a staff report will be prepared and a public hearing scheduled. The project will be reviewed and analyzed in terms of its conformity with the policies of the Coastal Act, principally, those of Chapter 3. At the present stage in our review of the project, three sections of Chapter 3 appear most applicable, although others may be applicable as well: (1) Section 30230--Marine Resources; (2) Section 30240--Environmentally Sensitive Habitat; and (3) Section 30253(1]--New Development.
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Mr. Fellows June 9, 1986> ,
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Section 30230lof'the Coastal Act requires the maintenance, enhancement, and restoration of marine. resources and states that:
- Marine resources ~ shall be maintained, enhanced, and where feasible, restored. Special protection shall be given to
, areas and species of special biological or economic r significance. Uses of the marine environment shall be l carried out in a manner that'will sustain the fA ological productivity of coastal waters and that will maintain healthy ,
populations of all species of marine organisms adequate for long-term comercial, recreational, scientific, and l , educational purposes.
Section 30240(a)(b) states that:
(a) Environmentally sensitive habitat areas shall be protected against any significant disruption of habitat values, and only uses dependent on such resources shall be allowed within such areas. ,
(b) Development in areas adjacent to environmentally sensitive habitat areas and parks and recreation areas shall be sited and designed to prevent impacts which would significantly degrade such areas, and shall be compatible with the continuance of such habitat areas.
Section3b253(1)statesinpartthat:
New development shall:
(1) Minimize risks to life and property in areas of high geologic, flood, and fire hazard.
! The Comission's review will focus on possib'le ef fects to nearby resources and' .
upon possible economic consequences of damage or risk to those resources. .
Humboldt Day has a diverse fish comunity which includes transit coastal and offshore species as well as year round residents. The Bay also supports both l comercial and sports fishery activities. The Bay's ecosystem also includes L significant communities of eelgrass, mud and sand flats, salt and brackish marshes as well as freshwater marshes and ponds. The diversity of the aquatic communities is crucial to maintaining healthy fish populations which in turn provide significant economic benefits to the area.
Based on our current limited information, it appears that the SAFSiOR s alternative proposed by PG&E involves risks of serious biological consequences to the marine resources of Humboldt Bay. Early comments in this letter expressed concern over the c'ontinuing leakage of radioactive liquid, the prospect of increased leakage, and the potential resource damage or loss which could occur in the event of major seismic activity.
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Mr. Fellows June 9, 1986 Page 10 The DES presents an analysis of an uncontrolled release from the two concentrated waste storage tanks as a worst case scenario for a radwaste tank '
accident. It a'ssumes that approximately 10,000 gallons of the two tanks would flow directly into the discharge canal, and thence to Humboldt Bay. The FES is deficient in that-it does not propose alternatives to discharge into the Bay or indicate that there are backup systems available to handle the
, described emergency.
In its discussion of the potential impacts associated with a rupture of the spent fuel pool, Section 6.3.1.2 of the ER states that severe seismic shaking exceeding the .5g plant sa'e :,hutdown earthquake level is possible. The result assumed by the ER in the occurrence of such an event is a potential rupture of the spent fuel storage pool's integrity. According to the ER, if this were to occur, the storage fluid would be retained because the ground water elevation surrounding the storage pool and suppression chamber exceeds the pool water elevation. This is further discussed in Section 6.3.2.2 of the ER which states that:
Ground water could be contaminated by the loss of pool water is a leak were to develop from the pool to the surrounding soil, but contamination would be very slight even if the leak were very rapid...This estimate is (.onservative since the water volume released from the pool would reach an equilibrium with the very high water table in the site s01.1 strata.
This c.onclusion is.at odds with the information presented in Section 10.3.2.2 of the ER, which concludes that ground water flows towards the Bay from the site and that the aquifer is flushed each year by high tides during winter and spring runoff. This information leads us to conclude that there clearly could be an exchange of radioactive material which could runof f to the wetlands and Bay. Such an event could adversely effect the Bay, both from the radiation in the various fish and mollusk species, and from serious financial impacts on California's coastal fisheries industry. These impacts may result, in part, m from either actual or publicly perceived radiation hazards or contamination to various marine resources. If the consumers either knew or suspected that fish and shellfish were coming from ilumboldt Bety coastal waters where radioactive wastes had been detected, sales of Bay fishery products could drop, economically devastating Humboldt's fisheries industry.
Any or all of these issues, as well as others such as ef fcct of grading and construction activities, may be the subject of Cormnission review of a coastal development permit application for this project.
- 5. Evacuation Plan ,
Neither the ER nor the DES describes any existing or proposed evacuation plans to be. implemented in the event any of tbc worst case scenarios presented in the analyses. U.'i Highway 101 provides the principal access between the Calif ornia northwst and the metropolitan areas of the central and southern portions of the state, and is approxir.:ately one-half mile f rom the boundary of the facility. The Ff.S should include information regarding ev'acuation plans.
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Mr. Fellows June 9, 1986-Page 11
- 6. Conclusion In general, we believe the DES'has not adequately addressed the issues of long-term storage of radioactive materials in a known seismically hazardous area, nor has it adequately evaluated the alternative of transporting the spent fuel assemblies to non-NRC disposal sites. Additionally, the analysis provided has been generic in nature to nuclear facilities and failed to address the specific limitations of the facility in terms of its location and potential impacts to coastal resources. The DES indicates the likelihood gthat SAFSTOR will extend beyond the proposed 30 year timeframe, and that the
.' dismantling of tho' facility will take considerable additional time. Yet the DES does not analyze the impacts of the possible longer duration of the fuel's on site-storage.
The decommissioning of the Humboldt Bay plant will, in all likelihood, set the precedent for the rest of the nation's commercial reactors. The SAFSTOR alternative is essentially a time marker, for it assumes that certain steps will be taken by others to ensure that the plant is permanently safe.
However, there is no analysis about long-term effects in the event that these anticipated steps are not taken. The Humboldt facility was never intended as a de facto permanent waste depository, and any after-the-fact effort to convert it into one must be subject to a high level of environmental scrutiny. This does not occur in the present DES. It is, in our view, seriously inadequate and must be substantially supplemented if it is to satisfy the requirements imposed by NEPA to insure informed decision-making.
If you have any questions about our comments or we can be of further assistance, please contact Michael Buck of our staf f at your convenience.
Sincerely,
{} .g ;
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- 8. Noah Tilghman -
Program Manager [ -
e
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