ML20206L464
| ML20206L464 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 06/23/1986 |
| From: | Whittington D ENVIRONMENTAL PROTECTION AGENCY |
| To: | Noonan V Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 8606300279 | |
| Download: ML20206L464 (5) | |
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IO UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION Vi
%, g6 1201 ELM STREET DALLAS, TEXAS 75270 JUN 2 31986 i
Mr. Vincent S. Noonan i
Director Division of PWR Licensing-A U.S. Nuclear Regulatory Commission Washington, D.C.
20555
Dear Mr. Noonan:
We have completed our review of the Draft Environmental Impact Statement (EIS) related to the operation of the South Texas Nuclear Power Project, Units 1 and 2 (Docket Nos. 50-498 and 499), located about 12 miles south of Bay City in Matagorda County, Texas.
The proposed action is for the i
Nuclear Regulatory Commission (NRC) to issue an operating license to the Houston Lighting and Power Company for startup and operation of Units 1 i
and 2.
l The following comments are provided for your consideration:
RADIOLOGICAL IMPACTS i
j Timing of Supporting Documentation for the Draft EIS In the past, the practice of issuing the Draft EIS in advance of the Safety Evaluation Report (SER) has prevented us from performing a complete review of the environmental impacts of nuclear power plants.
In the present case, 4
the SER was received after our review of the Draft EIS for the South Texas Project was completed. The Draft EIS referenced the (unavailable) SER in numerous places as providing detailed support for NRC staff conclusions on environmentally important considerations. Consequently, we requested extra time to review this very relevant supporting documentation needed to adequately evaluate the environmental impacts.
Such materials incorporated by reference should be reasonably available for inspection within the time allowed for comment (40 CFR 1502.21). We do not recognize the citations, in the Draft EIS, of missing but forthcoming information as acceptably i
referenced material.
In the future, we ask that the SER be made available i
to the Environmental Protection Agency (EPA) prior to issuing the Draft l
EIS. This will provide this agency the necessary information to conduct a thorough evaluation in the time allotted for our 309 review.
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2-Radioactive Waste Management Sometime prior to May 1978, at a meeting between NRC and EPA staffs, EPA objected to the NRC's practice of omitting the detailed descriptions of the radioactive waste treatment systems from environmental statements for nuclear power plants.
EPA acquiesced after being assured by the NRC that such details would be included in the SER for each facility, and that the SER would be made available prior to issuing the Draft EIS.
Because the SER was issued after the Draft EIS, an extended review period as discussed 1
in the preceeding comment was obtained to accommodate our review.
l Some of the waste management system details that were once included in EISs and SERs have been omitted; in particular, there are no flow diagrams of
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the liquid and gaseous waste treatment systems, and purge and ventilation systems.
If these flow diagrams are not to appear in the SERs, then they should be placed back in the Draft EISs.
According to the SER, the main condenser vacuum pump discharge is unfiltered, and gases released from liquid radwaste system equipment vents are released without filtration. Since these ef fluents are treated prior to release at some nuclear power plants, the Final EIS should exolain the reason for not treating them at the South Texas Projects Because the projected nnual activity releases are not given for these sources, we could not judge whether the "as low as reasonably achievable" (ALARA) criterion has been met. We therefore ask that the Final EIS address radioactive effluents from these sources in the context of the ALARA concept.
Open and Confirmatory Items Although not reflected in the Draft EIS, the SER describes numerous open and confirmatory items that have not been resolved, or not resolved to the NRC staff's satisfaction, at the time that the EIS and SER were issued..
Many of these itens relate to systems, procedures, planning, analysis, documentation, and proposed operating practices,which directly affect safety and environmental impact considerations. Most of these items are to be discussed in future supplements to the SER, af ter they.are resolved.
Also, compliance by the Applicant with the applicable requirements of 10 CFR 20, 50, 51 and 100 has not yet been established (SER, page 1-3). The report explains that these concerns will also be addressed in. future SER sappiene nts.
In view of the above, the conclusion stated in Section'6.5 of the EIS, "that South Texas Project, Units 1 and 2, can be operated with minimum environmental impact", would seem to be contingent upon obtaining favorable results from important ongoing staff reviews, and hence premature.
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. The Final EIS should include an evaluation of the environmental impact of each of the open and confirmatory items which is still undergoing review.
Furthermore, we believe that the Final EIS should be withheld until the above mentioned reviews of the most significant open and confirmatory items have progressed to such an extent that their potential environmental impacts can be described meaningfully.
Plant Safety Appendix G of the SER notes that, as the NRC's criteria on postulation of arbitrary intermediate pipe breaks (AIBs) were implemented by the industry, the impact on plant reliability and costs as well as on plant safety became apparent. Recent interest expressed by the industry, along with submittals l
from the applicant, have convinced the NRC staff that their criteria can I
be overly restrictive and may result in an excessive number of pipe rupture protection devices that do not provide a compensating level of safety. The l
NRC staff thus conclude that the pipe rupture postulation and the associated effects are adequately censidered in the desiga of South Texas Project Units I and 2, and the deviation from the standard review plan is acceptable.
This relaxation of the plant design raquirements appears, to be significant, I
but is nowhere mentioned in the Draft EIS. We believe that the Final EIS l
should thoroughly describe the rationales and findings leading up to this decision.
Futhermore, if the NRC staff's conclusion on the need to postulate AIDS is, in its effect, a generic decision to deviate from the standard review l
plan, we suggest that an environmental assessment might be appropriate, l
to support that decision. Possibly, an EIS might be appropriate, under NEPA, to support that major Federal action.
This should be addressed in the Final EIS.
Decommissioning m
Decommissioning of the South Texas Project will be subject to currently ongoing rulemaking proceedings, and the Environmental Protection Agency has commented on the NRC's proposed criteria (10 CFR 30, 40, 50, 51, 70, l
l and 72; 50 F.R. 5600 et seq.).
In our comments, we did not object to the l
substance of the proposed technical and financial requirements.
- However, we did express our concerns that criteria were not specified which would t
l assure that decommissioning will take place in a timely manner, following the end of the plants' useful operating lifetimes.
Specifically, we are i
concerned about the possibility that a licensee can defer decommissioning I
by maintaining the facility in a potentially operable condition so that its operating license can be renewed indefinitely. The EPA will continue its ef forts to resolve this specific concern, along with a few others, in the NRC's rulemaking proceedings.
. Additional Comments 1.
On page 5 of Appendix F of the EIS, the statement that a whole body dose greater than about 25 rems over a short period of time is necessary before any physiological effects are clinically detectable, should be reviewed.
Information contained in the World Health Organization Technical Report No.123 would seem to indicate that physiological changes can result from whole body exposures as low as 10 rems. This should be clarified in the Final EIS.
2.
The Applicant proposes to use direct-reading pocket dosimeters te keep a running total of exposure to external radiation exposures of workers, except for neutron exposures. For personnel working in neutron exposure areas, exposures will be calculated based on measurements by portable instruments, and known occupancy times (SER, p.12-11). Since neutron exposure pocket dosimeters are available from commercial suppliers, the Final EIS should explain why direct-reading neutron dosimetry is not needed for personnel at the South Texas Project.
1 NON-RADIOLOGICAL IMPACTS I
I RCRA Information The Draft EIS did not address the management of solid waste according to the Resource Conservation and Recovery Act (RCRA) of 1976. We might expect that operations of this size would generate sufficient volumes of nonradio-active hazardous waste to require a RCRA permit.
The management of all J
solid wastes, both hazardous and non-hazardous, should be addressed in the Final EIS.
Applicable State as well as EPA regulations should be addressed i
i as Texas is authorized to operate the RCRA program in lieu of EPA. The type and quantity of both nonradioactive hazardous and solid wastes expected to be generated at this power plant should be identified and discussed in the Final EIS.
Spills 1
The Draft EIS did not address oil spills in the transformer yard. Operations of this size usually have a large transformer yard where spills or leaks of the dielectric fluid during the operation of the project may occur.
If any of these spills include PCDs or if there are any PCB transformers on the project site, then applicable EPA procedures should be followed.
j This concern should be discussed in the Final EIS.
Wastewater Treatment On page 4-4 the EIS states that the sanitary-waste system is adequate for 500 people but 1,334 people are projected to work at the plant.
It further i
1
O states that a larger system will be necessary to comply with their NPDES permit effluent limitations. The Applicant should therefore supply assur-ances in the Final EIS that sufficient capacity for wastewater treatment will be made available to insure that effluent permit limitations will not be exceeded.
We classify your Draf t EIS as EC-2 (Environmental Concerns-Insufficient Information).
Specifically, we are requesting additional information on radioactive waste and solid waste management, open and confirmatory items, plant safety, decommissioning, spills and wastewater treatment in order to more fully assess associated environmental impacts that should be avoided in order to protect the environment. We will express environmental concerns with the proposed action and ask that the additional information requested in the above comments be provided to fully assure that the environment and the public will be adequately protected.
Further 'assessnient of these concerns may require that corrective measures be included in the proposed action.
Our classification will be published in the Federal Register according to j
our responsibility to inform the public of our views on proposed Federal J
actions under Section 309 of the Clean Air Act.
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i We appreciated the opportunity to review the Draf t EIS. Please send our of fice five (5) copies of the Final EIS at the sar.;e time it is sent to the Of fice of Federal Activities, U.S. Environ.nental Protection Agency, Washington, D.C.
Sincerely yours,
'%Y Dick Whittington, P.E.
Regional Adminstrator cc: Houston Lighting and Power Co.
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