ML20209C937

Forwards Responses to Comments Re Des.Comments Which Address Const/Benefit Issues Designated DEC-3,SD-1 & SD-13.No Comments Re DE-1,WND-3-27,WNP-3-28,SD-2,SD-11 & SD-14 Offered

ML20209C937
Person / Time
Site:	Satsop
Issue date:	05/09/1984
From:	Regan W Office of Nuclear Reactor Regulation
To:	Knighton G Office of Nuclear Reactor Regulation
References
CON-WNP-1453 NUDOCS 8405210396
Download: ML20209C937 (6)

Text

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DISTRIBUTION:

MAY s 1984 6 SAB Reading File SAB Plant -

NFields DCleary AToalston WRegan HDiORAtlDUM TO: George Knighton, Chief .

Licensing Branch No. 3, DL FPGt: kb. H. Regan, Jr., Chief Site Analysis Branch, DE

SUBJECT:

RESPONSES TO C0f-!MENTS ON THE WPPSS-3 DRAFT 3 ENVIROPf*EUTAL If1 PACT STATEMENT  ;

The captioned responses are attached. Some of the comments no longer fall under our purview. This is due to your decision to exclude, from the DEIS, the cost benefit analys.is I submitted to you on September 14,1983. The coments which address cost / benefit issues have been designated DEC-3, 50-1, and 50-13.

Other comments assigned to my iiranch and to which no responses have been prepared are, DE-1 WND-3-27 HNP-3-28 SD-2, 50-11 and SD-14. These coments are either misassigned, editorial in nature or require legal

. conclusions. A revised Section 5.7, Historical and Archeolocical Innacts g is also attached.

Any questions you may have regarding this nemorandum may be directed to Nick Field on X24722 or Don Cleary on X27680.

15. H. Regan, Chief Site Analysis Branch Division of Engineering

Enclosure:

l As stated

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DISTRIBUTION:

MAY' s 1984 Central File SAB Reading File SAB Plant NFields '

DCleary AToalston WRegan HEMCRANDUM TO: George Knighton, Chief Licensing Branch No. 3, DL FROM: W . H. Regan, Jr., Chief Site Analysis Branch, DE

SUBJECT:

, RESPONSES TO COMMENTS ON THE WPPSS-3 DRAFT ENVIRONMENTAL IMPACT STATEMENT The captioned responses are attached. Some of the comments no longer fall under our purview. This is due to your decision to exclude, from the DEIS, the cost benefit analysis I submitted to you on September 14, 1983. The comments which address cost / benefit issues have been designated DEC-3, 50-1, and 5D-13.

Other coments assigned to my branch and to which no responses have been prepared are. DE-1, WND-3-27. WNP-3-28, SD-2 SD-ll and SD-14 These carvaents are either misassigned, editorial in nature or require legal l-conclusions. A revised Section S.7, Historical and Archeolocical Innacts 2 is also attached. ~

Any questions you may have regarding this memorandum may be directed to Nick Field on X24722 or Don Cleary on X27680.

l Ha. H. Regan, Chief Site Analysis Branch Division of Engineering i

Enclosure:

As stated l

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Comment: 2. Section 2, Purpose of and Need for Action, page 2-1. The .

first sentence in the third paragraph stated that "... nuclear plants cost 1.ess to operate..." Although this is true, nuclear plants are much more expensive to construct than most fossil-fueled plants of which there are very few in this region'. You may wish to expand upon the infomation in this section in order to more fully support the conclusion.

Response: Issues related to the cost of construction were considered at the construction pemit stage of the licensing review. At the operating license stage, the substantial capital costs associated with the construction of the facility have already been incurred and will be borne whether or not the unit operates. The only economic factors which are relevant at this point are those related to the operation of the plant. Therefore, staff views it inappropriate to " expand...the infomation" in the DEIS to include a discussion of a subject which is no longer relevant to a decision as to whether the unit should be allowed to operate..

DEC-1

. Comment: Figure 4.1 (page 4-2): The site layout map indicated the Keyes

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Road Extension on the east of the plant and into the exclusion zone. -

A significant section of this road is not shown--the portion that

• extends from near the No.3 cooling tower, past the turbine generator, and connecting with the main Keyes Road teminus at the top of Fuller '

Hill. It is significant as an alternative access to the site and/or evacuation corridor. There has been some discussion of eliminating use of this road in the future in favor of diverting any required cross traffic to the plant connecting road. Use of either or both could have impacts on plant security and emergency response plans, and should be discussed in the DEIS.

Response: WPPSS intends to abandon the segment of Keyes Road extension within the site and control access to the exclusion zone easement area via Keyes Road; therefore, omission of the on-site segment of Keyes Road from Figure 4.1 is appropriate. A full review of emergency response plans is provided for by 10 CFR 50.47 and 10 CFR 50, Appendix E, and the staff findings will be reported in the operating license SER. -

Action: None.

l SD-12 Comment: Socio-economic impacts of WNP-3 should have been expanded to include discussion of the regional waste management costs,

! decommissioning impacts.

l Response: NEPA effects of waste management which were treated in the Uranium Fuel Cycle Rule, as explained in Section 5.10, -

Impacts from the Uranium Fuel Cycle, are not treated in detail in

. SD-12 individual EIS's. Socioeconomic impacts of decontamination (cont'd) are treated g:nerically in NUREG-0586 " Draft Generic Enviremental Impact Statement on Decommissioning of Nuclear Facilities" referred to in Section 5.4, Decommissionino Enviromental and related socioeconomic effects of decontamination will be reviewed for specific facilities at the end of the operating life of each facility.

Action: None.

WNP-3-1 Comment: Figure 4.1 is taken from ER-OL Figure 2.1-1 which will be amended consistent with the response to Q290.14 and the acreages cited in DES-01 Section 4.2.2. FSAR Figure 2.1-1 has already been amended (December 1983).

Response: The comment is accepted and Figure 4.1 has been changed.

Action: Replace Figure 4.1 with revised ER-OL Figure 2.1-1 or FSAR 2.1-1.

WNP-3-2 .

Comment: Also noted in Section 4.2.1 that reduction of the base diameter of the cooling tower by 90 feet is not an exception to conclusions regarding the significance of changes in the arrangement of site structures.

Response: The Section 4.2.l has been revised accordingly.

Action: Change the second sentence of Section 4.2.1 to read:

"Although...has not changed." Change the third sentence to read:

"The base of diameter of the twin natural draft cooling towers has been reduced from 155.4M (510 feet) to 128M (420 fekt.)"

WNP-3-3 Comment: Construction laydown area should be added to the list at the bottom of p. 4-1.

Response: Section 4.2.2 has been revised accordingly.

Action: Change the last sentence on page 401 to read: "These areas... include the construction laydown area, the construction water wells...."

WNP-3-16 Comment: In response to Q311.05 we noted minor errors in the distribution of near-plant residents. ER-01 Table 2.1-2 and FSAR Table 2.1-3 will be amended to provided corrections. For instance the 1980 population within one mile of WNP-3 is now estimated to be 3 versus the 15 noted in DES Table 4.7.

Response: Anended ER-OL Table 2.1-2 is requir'ed before the staff can respond.

Action:' Await amended ER-OL Table 2.1-2.

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WN 3-29 Comment: Based on the inf'cmation given in Section 5.7 concerning the effects of plant operation on historic / archeological resources, "none" seems more appropriate than "small."

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Response: Table 6.1 has. been revised accordingly.

Action: In Table 6.1 " Effects on historic and archelogical resources" substitute "none" for "small ."

WSUD-1 Comment: Specifically, the abstr.act of the dEIS asserts without documentation tnat "the net socio-economic effects of the projects will be beneficial," and pages S-8, after a brief description of some economic considerations, notes that "the staff anticipates no other significant socio-economic impacts from station operation."

These statements (p3rticularly the latter one) demonstrate either an unacceptablely low level of relevant expertise among the study team or else a refusal to consider relerant research findings on the social impacts of WNP-3.

The local Soci.al enviroment has changed greatly, ano the social '

impacts of the licensing and operation of .the plant are likely to be dramatically different from those that vers envisioned in the

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original EIS on the ccnstruction permit phase of plant. A, analysis by Rodney Baxter and myself has shown that attitudes

' toward local reaclear facilities have declined dramatically in nuclear " host cormunities" across the entire nation (Freudenburg and Baxter,1983), for example, and even more poir,tedly, as noted in a report prepared by Roger i., Kisniewski and myself (copies of which were shared .with the Wshington Public Fower Supply System)

"there is greater local oppcsition to the WPPSS nuclear plants than to the r.uclear facilities of any of the other "nomal" host conmunity in the history of surveys in the U.S.' The level of opposition near the Sitsop facility, in fact, is matched only by a survey done at the 'bree Mile Island Plant itself, only four months after the infamous accident (Wisniew. ski ar,d Freudenburg, 1981:38.)

These reports and others have notsd ferther that the social consequences of pemitting operation of a facility over such intense objections could be a grave indeed.

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t Response: The coment would extend the scope of socioecononic analysis within the EIS beyond the intent of NEPA and CEO procedoral provisions in 40 CFR Parts 1500-1508. To be treated in an EIS socice:ononic phenomenon should be cautelly linked to effects of the project on the natural and physical environment. Peb11c opposition to or support of a project per se and resultin; political phenomena j

are not withic the appropriate scope of un EIS.

Action: Nene.

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-~m WSUDS-2 Comment: I further call to ycur attention to the fact that the Regulations for Implementing Procedural Provisions of the National Environmental Policy Act make it explicit that " worst-case" assumptions should W utilized in situations such as as these where

' the absence of an adequate quantitative data base makes it difficult to predict with any precision just what specific impacts are likely to occur. I also call to your attention the fact that, as noted in a forthcoming article in The Harvard Environmental 1aw Review, the recent Supreme Court decision in the Nuclear Regut! tory Commission vs. People Against Nuclear Energy (PANE) would not be relevant here, since that case had to do with PANE's contention that 30 environmental impact statement was required even though no (non-psychological) physical environmental impacts were alleged. In the current case the Nuclear Regulatory Commissinn has cleary decided that an EIS is required, and is merely failing (fr. clear violation of the Council on Environmental Quality guidelines for EIS's) to make best or even

" token" use of available scientific expertise on the likely social impacts cf issuing an operating license for WNP-3, Response: The issue is outside of the scope of the EIS as explained in WSUSD-1.

Action: None.

(Revised)5.7 Historical and Archeological Impacts As stated in Section 4.3.7, there are no properties listed or eligible to be listed in the National Register of Historic Places in the vjcinity of WNP-3.

The staff, therefore, concludes that no known or anticipated historic or archeological resources will be adversely affected by operation and maintenance of the station.

The conclusion is consistent with the cpinion of the State of Washirgton, Office of Archaeology and Historic Preservation (lettar from R.G. Whitlam to G.W. Knighton, dated 09-29-83, see Appendix ).

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JOHN 92d!'W4 $' \ ) MCC4 THOMAS Govemor . ,

\b/ orecor STATE OF WASHINGTON OFFICE OF ARCHAEOLOGY AND HISTORIC PRESERVATION 111 West Twenty-Fnt Avenue, h1-11 e Olympia. Washrston 96504 e (206) 753-4011  ;

September 29, 1983 306 ,

Mr. George W. Knighton, Chief Licensing Branch #3 .

Division of Licensing Office of Nur. lear Reactor Regulation Nuclear Regulatory Coannission Washington, D.C. 20555 Log

Reference:

449-F-h1C-01 Re: Washington Public Power Supply System Nuclear Project 3 (WNP-3)

Dear Mr. Knighton:

We have reviewed the materials forwarded to us for the above refer-

" enced project. Based en the information provided for our review, in our opinion the proposed project will have no effect on known cultural ,

• resources included in or eligible for inclusion in the National Regis-ter of Historic Places. .

Please feel free to contact us if we can be of any further assistance.

Sincerely, WQ-CvA h - -

Robert G. Whitlam, Ph.D.

Archaeologist dj -

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