ML20206M469

Criticizes Des for Plant Decommissioning as Inadequate for long-term Radioactive Matls Storage in Seismically Active Area.Concerns Which Must Be Addressed in Fes Discussed. NEPA & Ceq Requirements Not Met

ML20206M469
Person / Time
Site:	Humboldt Bay
Issue date:	08/14/1986
From:	Keene B CALIFORNIA, STATE OF
To:	Berkow H Office of Nuclear Reactor Regulation
References
NUDOCS 8608210223
Download: ML20206M469 (3)

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SENATE MEMBERS: JOMES W. ROTE. E4 D.

ROBERY G. SEVERLY PRfNCIPA CONSCLTONT MILTON MARKS JOYCE ROSAS HENRY MELLO COMMITTEE SECRETARY

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SAM FAPR Ealifornia Eegislature . "=

SACRAMENTO. CA 95814 GECALD N FELANDO (9161324 2273 DAN HAUSER ATSS 8 454<2273 (916p 445 3375

. JOINT COMMITTEE ON FISHERIES AND AQUACULTURE SENATOR BARRY KEENE CHAIR ASSEMBLYMAN DAN HAUSER VICE CHAIR August 14, 1986 Mr. Herbert N. Berkow Director, Standardization and Special Projects Mail Stop P-234 U.S. Nuclear Regulatory Commission Washington, D.C. 20555

Subject:

Comments on Draft Environmental Statement -

Decommissioning of Humboldt Bay Power Plant, Unit No. 3.

Dear Mr. Berkow:

In general, I believe the Draft Environmental Statenent (DES) for the decommissioning of the Humboldt Bay Nuclear Power Plant is woefully ir. adequate in addressing the issues of long-term storage of radioactive materials in a known seismically active area. To begin with, the title of the draft document misleads the reader by failing to mention that Unit No. 3 is a nuclear reactor. The first mention that the document is dealing with a nuclear facility appears on page 1-2. Furthermore, the abbreviated title

" Draft Environmental Statement" does not comply with the National Environmental Policy Act (NEPA), and the Council on Environmental Onality (CEQ) regulations which require the preparation of an Environmental Impact Statement.

The Nuclear Regulatory Commission's (NRC) own regulations -10 CFR 51.20 (b) (5)- call for the preparation of an "-- environmental 8600210223 DR 860814 &

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o impact statement - ", in conjunction with " issuance of a license amendment authorizing the decommissioning of a nuclear power reactor - ." It appears that NRC staff, in preparing this document, have attempted to downplay the adverse impacts of the proposal.

One of_the most serious oversights in the draft is the failure to provide a detailed description and analysis of the. environmental setting of the proposed decommissioning activities. Humboldt Bay is the largest coastal wetland and estuarine area in California, serving as habitat and spawning grounds for numerous species of fish and shellfish, including anchovies, salmon, steelhead, rockfishes, flatfishes, market crab, and. oysters. Some 750 acres of the bay's bottom are used for the commercial production of oysters. Additionally, the environs of the bay serve as habitat for numerous bird species and other wildlife. The DES is silent on these important features of the area.

Another glaring omission in the document is the lack of an adequate site characterization for the vicinity of Unit No. 3.

There is little, if any, treatment of groundwater, local soil conditions, and the overall hydrogeologic nature of the area.

This assessment is critical in light of the identification in the DES of continuous leakage, since 1966, of radioactive liquid from the spent fuel pool which has resulted in soil contamination.

In light of the fact that the licensee (P.G.&E) decided in July, 1976 to shut down Unit No. 3 for seismic modifications, it is imperative that this document contain a thorough analysis of the relevant seismic factors and give serious consideration to the interaction of those factors with the hazardous materials stored on site. The cursory treatment of seismic factors provided in this draft avoids probably the most important environmental issue in considering the decommissioning of Unit No. 3.

The DES presents technical information on the dose assessment and risks of human exposure to radionuclides (section 3.2 and Appendix B), yet the document fails to explain exactly what the licensee's " radiation protection program" entails. Description of_this program and inclusion in the final EIS of evacuation plans to be implemented in the event of a worst case scenario would help allay many of the public's concerns regarding this proposal.

There is no mention in the DES if other nuclear facilities in the country have been decommissioned, and if so, what information exists that might bear on this proposal. If this, in fact, is the first such decommissioning in the United States, it then becomes all the more important for the NRC to prepare a 2

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comprehensive, in-depth Environmental Impact Statement before any consideration of storing radioactive materials in " safe. storage" for 30 years.

While the DES includes a section. entitled the " Decommissioning Plan" (section 2.2) , the document fails to explain what the plan actually does. The section is extremely superficial in that it makes blanket statements without providing any details. For example, a statement.is made on page 1-5 that the " plan" ensures that contaminated water is removed from,certain systems and tanks. How is this accomplished? Where does the contaminated water go? .

This cursory treatment of the Decommissioning Plan, which is an essential part of the proposal, leads one to believe that NRC staff is treating the P G & E license amendment as a mere formality. In fact, Unit 3 has been in'"SAFSTOR" since July 2, 1976 without a license amendment or an Environmental Impact Statement. Thus, with the "no action" alternative, how could there be, as stated on page 1-5, "a greater potential for release of radioactive material as a result of system deterioration or a seismic event?"

In conclusion, I feel that the draft DES is seriously flawed and that the final Environmental Impact Statement must be substantially revised to address the above. concerns. Without adequate treatment of the environmental setting, a detailed site characterization, a thorough analysis of seismic factors, and emergency response and evacuation plans,.this document does not meet the requirements of NEPA and CEO regulations.

Thank you for the opportunity'to comment on the DES and for your consideration of my concerns. Specific technical comments on the DES will follow under separate cover.

Sincerely, ay ,-

U U$h1RY KEEN 3 's BK:jrlb 3