ML20206L477

Comments on Des for Decommissioning of Facility. Recommendation That Plant & Spent Fuel Remain on Site for 30 More Yrs,Plus Decommissioning Time,Not in Best Interest of Public Health & Safety

ML20206L477
Person / Time
Site:	Humboldt Bay
Issue date:	08/14/1986
From:	Stein E AFFILIATION NOT ASSIGNED
To:	Erickson P Office of Nuclear Reactor Regulation
References
NUDOCS 8608200194
Download: ML20206L477 (6)

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50-195 EDITH KRAUS STEIN 3825 Erie Street Eureka, CA 95501 August 14 1986

. )Mr . Peter B. Erickson Project Manager Standardization and Special Projects Directorate U.S. Nuclear Regulatory Commission Washington. D.C. 20555

Dear Mr. Erickson:

I am writing to you with my comments for you and the NRC Staff on the DES for the Decommissioning of the Humboldt Bay Nuclear Power Plant. Unit 3 The comments are arranged by paragraph and subparagraph moving consecutively through the document.

1. Ps. V. (2) - Why is it necessary to wait for a Federal Repository? What about commercial repositories, or reprocessing at a DOE Reprocessing Plant? Have these and other options been throughly investigated by PG&E7

2. Pg. V. (3) - How is it possible for the Commission to support the action by PG&E to shut down the plant for seismic safety considerations and at the same time recommend the SAFESTOR option? These actions are contradictory in that the seismic capability of the three faults which lie within a couple of miles of the plant (one of which runs through the plant site) are in excess of magnitude 75 University of California Seismologists and U.S. Dept. of Geodetic Survey have concluded that heavy seismic activity is to be expected within the next 10 to 20 years all along the California Fault Systems. To recommend that the Plant and spent fuel remain on site for thirty more years, plus the time it takes for the actual decommissioning of the plant is not, in my opinion, in the best interest of the public health and safety nor is it an environmentally responsible action. Is it not better to dismantle the plant now under controlled conditions than to have Mother Nature do it for you under uncontrolled conditions with potentially catastrophic results?

3 Pg. vi. (5)(e) - "There is a negligibly small likelihood that..." This is a matter is subjective opinion without basis given in this document. Has the Staff determined the quantity of thie likelihood in terms of X probability or other equivalent units? In view of the seismic capability of the site, does this increase the probability for occurrance?

What is the likelihood?

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DE3 CcmmOnta - H%PP Unit 3 (Continusd)

4. Pg. ' v1. (5)(f) - Dose limits appear to make the assumption that the spent fuel pool water remains in the liquid state and that it does not turn to steam or a mixture of water and steam. Would the result of the dose calculations be different if this event resulted in the generation of steam from the spent. fuel pool water? What is the percentage of the PAG 1evel represented by these new figures?

5 1.3.2 Subparagraph 1 - If any probability for the entombment structure to fail as the result of seismic events exists, why not also the current reactor containment structures, waste storage buildings, solid waste vault and spent fuel pool containment? (See Item #2)

6. 1.3.3. Subparagraph 3 - The generic " Waste Confidence Decision" (49 FR 34658) does not take into consideration the unique geologic (seismic) and ecologic factors associated with'the Humboldt Bay Plant Site. These factors should be addressed in much greater detail in this document and generic statements not relied upon for convenience.

7 1 3 3. Subparagraph 7 - This poses the alternative of sending the spent fuel rods to a commercial reprocessing plant. Why is the possibility not addressed to ship the spent rods to a DOE facility for reprocessing?

8. 2.1. Subparagraph 4 - This states that spent fuel pool leakage was detected in 1966 and that a "small amount of soil contanimation was produced". Has this amount been quantified? If this leakage has been occurring since 1966 and the liner installed in the spent fuel pool has only attenuated, not stopped, the leak then the potential exists for more than just a "small amount" of contaminated soil.

Has the water in the aquarir under the site been tested for possible contamination? Have provisions been made for assessment and removal of the contaminated soil from the site? Will the pumping of the liner gap contaminant into the radwaste system be required to reduce the environmental impact of storing the spent fuel at Humboldt Bay? If so. it should be so stated in this document. What would be the result of a failure of the liner gap pumping system? Are seismic loads likely to increase the liner leak rate?

8. 2.2 Subparagraph 2 (2) - Into what will the reactor vessel and reactor cooling system be drained?

9 2.2 - Why is a time frame not specified for completion of the tasks indicated under this paragraph?

10. 3 1 3. Subparagraph 3 ".. spent fuel pool coolers will be flushed and drained". Into what will they be drained? If this water is to be discharged into Humboldt Bay, what type of treatment program has been established for this water prior to discharge?

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DE3 C;mmento - H2PP Unit 3 (Centinued)

11. 3.1.4 - It seems a rather inappropriate statement that "the function of an ecosystem type would not be changed".........

therefore. there will be no impact. It may be difficult to change the " function" of a mud flat, per say, but not the very delicately balanced quality of it's funcctioning. This is a very inadequate statement considering the fact that much of this bay area is protected land and also one of the largest (if not the largest) estuary / wetland habitats in the state of California. Many species of mollusks live in the mudflats of Humboldt Bay. Fish use the bay as a spawning ground and as a growth area for finger 11ngs. Many species of animal and plant life in the dunes and marshes around Humboldt Bay are on the endangered and protected lists, the eel grass being just one of them. This area of potential serious impact should be evaluated also by experts in the fields of marine biology. ornithology. botany. zoology, geology, marine ecology. oceanography. etc. Your list of CONTRIBUTORS pg 7-1 did not contain anyone with these credentials. Why is this so? Is this not the purpose of an environmental impact statement?

12. 315 - The statement is made that "No mechanism for impacting these 2 species is evident. Therefore...." Have the potential exposure pathways likely to affect the 2 spccles in question been scientifically evaluated? This statement is contradicted by the first sentence of paragraph 32 which states that "The radiological impacts of 30 years of SAFESTOR consist primarily of (1) the environmental impacts of releases of liquid and gaseous radioactive effluents..." This paragraph is also notable in that it does not address the issue of " Protected" species.

13. 3.1 7 - How occasional will be the releases from the liquid

waste treatment system and in what quantities? "Relatively I clean water" is a subjective opinion without basis in this document. As stated in Executive Officers Summary Report of of California Regional Water Quality Control Board of Sept.

11 1985: "the waste discharge requirements govern parametern other than radionuclides. State rivernment is preempted by federal law to regulate radionuclide discharges from power generating plants." What are the expected levels of radio-nuclide contaminants in this water? What is their potential impact on the marine food chain of the Humboldt Bay region, given that these wastes are concentrated by the filter feeders of the bay and the levels of these contaminates will be compounded, rather than diluted, as they move up the chain?

This paragraph also states that the releases from the liquid waste treatment system are "further diluted with the cooling water flow from the two fossil-fueled units." This gives the impression that the assumption is made that the 2 fosuil-fueled units will continue to be operated throughout the 30 year SAFESTOR period and beyond through the decommissioning process. Is this. in fact, the case?

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DES Ccmm2nto - HIiPP Unit 3 (Continu2d)

14. 3.2 - This paragraph states that ;?adiological impacts of SAFESTOR.will consist primarily of' (1) the environmental impacts of releases of liquid and zaseous effluents...

This DES is notable in that it doen not go on to describe anywhere what these impacts might be and even reaches an apparently foregone conclusion that there are no environmental impacts based on a generic determination by the commission. .This paragraph also contradicts the conclusions reached in 3 1.4 and 3.1 5 15 3.2.2 Subparagraph 2 - Will the building erected to enclose the rad waste processing system be.able to withstand seismic loads up to a magnitude of 7.5 from the ccapable and potentially capable faults in close proximity to the plant?

16. 3.2.2 Subparagraph 3 - The wording indicating that liquid rad wastes from spent fuel pool and decontamination activities will be " collected and sampled" gives the impression that intermittent representative batch samples will be taken, not that each batch will be analyzed. Is this the case? The use. in the following sentence, of "If contamination is present or suspected..." implies that guesswork is used rather than scientific methods for analysis. The end of the same paragraph goes on to state that after processing the effluent will be sampled and released. Is any provision made for reprocessing of the effluent should the samples not be within limits for contamination? These points should be stated more clearly.

17. 3.2.2 Subparagraph 6 - Why is the ventilation exhaust from the refueling building, hot lab. hot machine shop and rad waste treatment building not treated? This is a potential pathway for unnecessary environmental contamination. Stating that "No treatment is provided by this system for normal releases" implies that there will be expected " abnormal releases". What constitutes a normal release? What constitutes an abnormal release? What treatment plan has been developed for these occurrances and why is it not so stated here?

This paragraph goes on to state that " controlled ventilation is not provided for the solid waste storage vault, low level waste storage building and solid waste handling building."

This is of concern because this provides another source for environmental contamination and public exposure. There is an almost continuous onshore flow of air off of the ocean, prevailing from the northwest, year around which has the ability to pick-up and carry particulste waste inland and off-site from these buildings since the ventilation and thus air currents are not controlled. especially when the doors are open.

18. 3 2.2 Subparagraph 10 - " Atmospheric releases will be insignificant." Upon what is this statement based? What quantity does " insignificant" represent?

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a n-DE3 CcmmOnts - H2PP Unit 3 (Continued)

19. 3 2 3.2' - Inithis paragraph the whole body dose' - estimates given are~ based on the assumption.that there is damage to only one row of pins.in each of 2 spent fuel: assemblies.

This may'be a conservative assumption for the new' fuel rod assemblies. but is it a realistic assumption for spent ~ fuel assemblies? Would it not be more conservative, considering the age and time in service of the fuel rods. that all of the pins might be damaged? Why are calculations not made for.

this condition?

20. 3 2.3.4 Pg. 3-11. Subparagraph 2 - Why are calculations not made for the potentiallity of the rods not remaining in a parallel- array, considering the seismic potential of the capable faults on and near the plant- site? Why is the presence of fresh fuel assumed when this is not the case?

The many uses off"very likely", "unlikely" and " negligibly small likelihood" are vague subjective opinion without basis in this document. Why is weak language of this nature used in the discussion of a topic as important as the potential for producing criticality in the stored spent fuel array?

21. 3.2 3.6 - What is the potentiality for contamination of the community wells located on the north eastern site boundry in the event of a spent fuel pool rupture?

22. This section. 3 2 3. does not address the potential environmental impact of a tsunami. What precautions have been taken to mitigate the effects of such an event to the

. surrounding community and environment? The stretch of Highway 101 which- runs adjacent to the plant boundry was closed to traffic just this past winter due to a tsunami watch posted for the California coastline.

Given the potential for heavy seismic activity during the SAFESTOR period this issue should be addressed. This section.

in my opinion, also does not adequately address the potential destructive effects of a major earthquake to the plant facilities and the resulting impacts to public health and the environment of the Humboldt Bay Basin.

In conclusion. I feel that given the geology of the area in which the Humboldt Bay Nuclear Powerplant is located and the seismic potential of the capable faults in close proximity to the plant as well as it's location relative to the triple plate junction off of the Mendocino Coastline'and other capable faults. that the decision to use the SAFESTOR option should be reevaluated. In any event. the serious nature of this situation should tut given much more validity then it has been given in this document and addressed in much greater detail. Furthermore. I feel that this document is gravely inadequate in it's attempts to assess the potential environmental effects of the proposed decommissioning process which will extent far beyond the 30 Yr. SAFESTOR period.

When the Humboldt Bay Nuclear Power Plant was built it was not 5

DES C mm:nta - H2PP Unit 3 (Continusd) intended to be used as a long-term storage facility for nuclear waste. I believe that PG&E and the Commission have not adequately explored the options available for handling the spent fuel on a long-term basis at a less hazardous location.

This document is generic in nature and does not assess the unique location of the Humboldt Bay Nuclear Power Plant with regard to fisheries resources, protected species of animals, protected lands, and unusual and rare ecology. Also this document does not assess the structural limitations of the facility with regard to the seismic potential of the area.

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