ML20211H340
| ML20211H340 | |
| Person / Time | |
|---|---|
| Site: | Humboldt Bay |
| Issue date: | 10/31/1986 |
| From: | PACIFIC GAS & ELECTRIC CO. |
| To: | |
| Shared Package | |
| ML20211H329 | List: |
| References | |
| 1568M, NUDOCS 8611050092 | |
| Download: ML20211H340 (96) | |
Text
-
Octsber 1986 PGandE Responses to Public Comments On The Draft Envirjnmental Statement for Decommissioning Humboldt Bay Unit 3 t
1 1568M 8611050092 8610 3 PDR ADOCK 0"000133 D
Index Comments and Responses Paae 1.
Commenting Parties................................................
2 2.
Environmental Considerations......................................
3 3.
Hydrology........................................................
14 4.
Chemical Agents..................................................
16 5.
Fuel Pool Cooling System.........................................
18 6.
Radwaste System..................................................
19 7.
Spent Fuel Fool Cover............................................
27 8.
Radwaste Enclosure Structure.....................................
28 9.
Ventilation Paths................................................
31
- 10. Seismicity.......................................................
33
- 11. Coastal Development Permit....................................... 43
- 12. Decommissioning Funds............................................ 46
- 13. Delayed DECON.................................................... 49 14.
Lo w-L e v e l Ha s t e..................................................
51 15.
Fuel Storages Alternatives.......................................
53
- 16. Fu e l Pool Le aka g e................................................
57
. 17.
Fuel Handling Accident...........................................
65 18.
Fuel Pool Rupture................................................
67
- 19. Bo ral De t e ri ora ti on.............................................. 73 20.
Inadvertent Cri ti cali ty..........................................
75
- 21. Occupational Radiation Exposure.................................. 79 22.
Evacuation Plans.................................................
84
- 23. Health Effects................................................... 87
- 24. General.......................................................... 89 1568M 1.
COMMENTING PARTIES Date of Letter A
California Coastal Commission June 11, 1986 B
U. S. Department of Health and Human Services June 16, 1986 C
Sierra Club August 4, 1986 D
Redwood Alliance August 12, 1986 E
Elton Adams / June Crym August 14, 1986 F
Nancy Hiefiker August 8, 1986 G
Thomas P. Infusion June 15, 1986 H
Ralph Kraus July 14, 1986 I
Larry Lancaster May 25, 1986 J
Michael J. Manetas May 13, 1986 K
Acorn Alliance August 6, 19'86 L
Edith Kraus Stein August 14, 1986 M
Pam Hellish August 7, 1986 N
Senator Barry Keene August 14, 1986 0
Susan Ames August 14, 1986 P
Daniel J. Taranto August 14, 1986 0
Sierra Club - Redwood Chapter August 10, 1986 1568M -
2.
ENVIRONMENTAL CONSIDERATIONS Comment A.
The DES is notable in that it provides virtually no description or analysis of environmental setting of the proposed activities.
D.
There is no discussion of the environmental characteristics of the site, nor of its relative importance.
L.
DES Paragraph 3.2 - This paragraph states that radiological impacts of SAFSTOR will consist primarily of (1) the environmental impacts of releases of liquid and gaseous effluents....
This DES is notable in that it_does not go on to describe anywhere what these impacts might be and even reaches an apparently foregone conclusion that there are no environmental irr. pacts based on a generic determination by the commission.
This paragraph also contradicts the conclusions reached in 3.1.4 and 3.1.5.
N.
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.
Q.
There is no discussion of the environmental characteristics of the site, nor of its importance relative to other such sites in the state or nation. There is no inventory of plant or animal species which would be
-affected by the proposed action at the site.
The complete lack of this information in and of itself serves to minimize the meaning of the document, which is, after all, an Environmental Impact Statement. The environmental significance to the state and nation of Humboldt Bay, on which the plant is located, is quite great.
Humboldt Bay according to the California Coastal Commission, is the largest wetland and estuarine habitat in the California Coastal Zone.
It contains approximately 23% of all coastal wetlands in California.
It's waters are home to 36 species of fish, including such aquatic fauna as anchovies, chinook, and coho salmon, steelhead, cutthroat trout, smelts, surfperch, rockfishes, sand dabs, soles and flounder. Approximately 750-acres of the bay's bottom and channels are used for commercial oyster production. Many of the birds using the bay are protected by international treaties which impose national responsibility for protection of their habitat. The Bay itself is considered a National Hildlife Sanctuary.
Peregrine Falcons, which hunt over the bay, are on the federal Endangered Species List.
The rivers and streams tributary to the bay provide spawning nurseries for juvenile salmon and trout.
Streamside riparian. habitats hold diverse wildlife populations. The DES fails to provide any description O dtsoever of the environment setting of the proposed activities.
The FES should provide detailed information on the environmental setting and potential impacts on marine and terrestrial fauna and flora of the proposed action and any accidents or incidents as " normal" or hypothetically projected as worst case.
1T68M - --
PGandE Resoonse Section 4.0 in the Environmental Report (ER) (Attachment 6 to the SAFSTOR Decommissioning License Amendment Application) describes in detail the environmental setting of the plant.
Section 6.0 in the ER sufficiently discusses the impact of. decommissioning activities on the local environment and biota. The following summarizes the discussion of the environmental impact of decommissioning.
No measurable offsite, public exposure is expected during SAFSTOR, nor are any detectable effects on environmental quality expected.
Releases to the environment via atmospheric emission through the stack, and aqueous discharges through the discharge canal, are expected to be equal to or less than measured values during shutdown, and remain within 10CFR20 MPC levels. Surveys of plant and animal material, milk, and air samples have shown that operation and.
shutdown have had no significant effects on the environment.
The probability of significant accidents occurring during SAFSTOR-is low..The consequences of the credible accidents affect occupational dose only. There are no significant public exposure or environmental quality consequences of credible accidents occurring during SAFSTOR.
Comment A.
It appears that the SAFSTOR alternative proposed by PGandE involves risks of serious biological consequences to the marine resources of Humboldt Bay.
H.
Under " Aquatic Resources" on Page 3-1 no mention is made of the fact that Humboldt Bay waters are extremely rich in planktonic life.
Radio isotopes, especially chromium, manganese, cobalt, zinc and iodine, are 1568H._
accumulated by various planktons and are then passed up the food chain, being concentrated a little more with each step up the chain. This bay supports intensive sport clamming. and a commercial oyster industry.
These bivalves are filter feeders ingesting, metabolizing and thus concentrating the phytoplankton and zooplankton mentioned above.
L.
DES Paragraph 3.1.7 - (Radwaste Discharges) - Hhat is their poter,tial 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 tha levels of these contaminates will be compounded, rather than diluted, as they move up the chain?
PGandE Response Releases to Humboldt Bay over the 30-year SAFSTOR period are insignificant with respect to environmental quality and public exposure.
Section 6.0 of the Environmental Report (ER) (Attachment 6 to the SAFSTOR Decommissioning License Amendment Application) sufficiently discusses the impact of decommissioning activities on the local environment and biota. Section 4.0 of the ER discusses in detail the aquatic resources in the area. Surveys of aquatic plant and animal materials have been performed during operation and after
~
shutdown. These surveys have shown that operation and shutdown of the plant have had no significant effects on the aquatic resources. Releases during SAFSTOR are expected to be equal to or less than those which occurred during shutdown and remain within 10 CFR 20 MPC levels. Section 4.2 of the ER discusses the effects of operation and shutdown on the environment. Sections 6.2 and 6.3 of the ER discuss the impacts of SAFSTOR on the environment.
Comment H.
Under " Terrestrial Resources" on page 3-2 the report ignores the fact that the South Bay directly to the south of the power plant is a migratory wildfowl refuge supporting a large migratory duck and goose population and also the site of the largest remaining eel grass beds on the Pacific Coast.
i 1568M l l
4 PGandE Response Section 4.0 in the Environmental Report (ER) (Attachment 6 to the SAFSTOR Decommissioning License Amendment Application) describes in detail the 4
environmental characteristics of the site and surrounding areas. Terrestrial ecosystems, including the eel grass beds, are discussed in this section of the ER. Wildlife in the area are studied in Section 4.0 of the ER, including migratory birds and those present throughout the year (Table 4.7 of the ER).
Endangered or rare species are not known to exist at the plant.
There is, therefore, no population of rare or endangered species at risk during SAFSTOR. Studies of milk, and air samples from the plant area show no measurable effects due to plant operation or shutdown. Soil samples indicate negligible radionuclides in surface soil due to reactor operations or shutdown.
Releases are negligible with respect to public exposure, directly or by food or water pathways, and to the environmental quality. Releases during SAFSTOR are expected to be equal to or less than measured values during shutdown, and remain within 10 CFR 20 MPC levels.
i Comment L.
' DES Paragraph 1.3.3.
Subparagraph 2 - The generic " Haste Confidence Decision" (49 FR 34658) does not take into consideration the unique geologic (seismic) and ecologic factors associated with the Humboldt Bay Power Site. These factors should be addressed in much greater detail in this document and generic statements not relied upon for convenience.
PGandE Resnonse The Environmental Report (ER) (Attachment 6 to the SAFSTOR Decommissioning l
License Amendment Application) comprehensively addresses all environmental impacts of 30-year SAFSTOR and the impacts of accidents during SAFSTOR.
1568M I
. - - - - -. - _ _ _ _ _. ~ _ - -.
The environmental concentrations of nuclides outside the Unit 3 restricted areas are..in the range of background. No elevated concentrations were detected in sediments of the intake and discharge canals, in soil or vegetation, or in Bay mollusks or algae.
Credible accident scenarios were postulated and analyzed. These accidents have a very low probability, but if they occurred as postulated, they would result in a slightly increased occupational dose. The consequences of credible accidents are estimated to be negligible with respect to public dose-or environmental quality.
Environmental impacts of SAFSTOR and accidents are discussed in Section 6 of the ER.
Comment D.
Even in its assumption that SAFSTOR is the only viable alternative for decommissioning the plant, the DES fails to address the effect of storage and eventual dismantlement on the human and natural settings of the plant.
Included in this should be a detailed analysis of the potential impacts should high level waste be released into the environment by catastrophic earthquake or otherwise.
PGandE Resoonse The Environmental Report (ER) (Attachment 6 to the SAFSTOR Decommissioning License Amendment Application) comprehensively addresses all environmental impacts of 30-year SAFSTOR, delayed dismantlement (delayed DECON), and the impacts of accidents.
Section 6.0 of the ER addresses the health and environmental implications of 30-year SAFSTOR, including worst-case 1568H. _ _.
consequences of credible accidents that could occur during SAFSTOR. Section 7.0 of the ER addresses the health and environmental implications of delayed DECON.
Accidents that could occur during DECON were found to have no consequences with respect to public dose or environmental quality. Transportation accidents that could occur in conjunction with the DECON process were discussed and found to result in negligible releases or public dose.
Comment K.
DES Subparagraph 3.1.5:
"No mechanism for impacting...is evident." This is unpardonably vague. A DES is properly supposed to evaluate impacts which may become evident during the length of the proposal. Any of the many accidents which could happen during SAFSTOR would provide ample
" mechanism for impacting..."
L.
DES Subparagraph 3.1.5 - 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 species in question been scientifically evaluated? This statement is contradicted by the first sentence of paragraph 3.2 which states that "The radiological impacts of 30 years of SAFSTOR 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.
PGandE Resoonse
~
The Environmental Report (ER) (Attachment 6 to the SAFSTOR Decommissioning License Amendment Application) has adequately assessed the impact of 30 years SAFSTOR, delayed DECON, and possible accidents associated with those decommissioning activities. The wildlife in a'quatic and terrestrial ecosystems near the plant are described in detail in Section 4.0 of the ER.
Section 6.0 of the ER describes the health and environmental implications of j
1568M j
~SAFSTOR. There are no detactable effects on environmental quality, including those upon the two endangered species noted, as a result of SAFSTOR.
Accidents during SAFSTOR have no significant consequences on environmental quality.
Comment H.
I find it incomprehensible that the list of contributors to the draft E.I.S., on page 7-1, does not contain a single biologist, marine biologist invertebrate zoologist or M.D. specializing in nuclear medicine. After all, we are concerned here primarily with an entire estuarine and marine ecosystem.
L.
DES Paragraph 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 its functioning. 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 fingerlings. 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?
PGandE Resoonse The authors of the Environmental Report (ER) (Attachment _6 to the SAFSTOR Decommissioning License Amendment Application) included a PhD of ecosystems analysis and microbiology and a chemist who is board certified in industrial hygene. The other authors include a chemical engineer, a nuclear engineer, and an electrical engineer. The authors have broad backgrounds in environmental quality monitoring, including radioactive waste management.
1568M The ER has adequately assessed the impact of 30 years SAFSTOR and possible accidents associated with those decommissioning activities.
The wildlife in aquatic and terrestrial ecosystems near the plant are described in detail in Section 4.0 of the ER. Section 6.0 of the ER describes the health and environmental implications of SAFSTOR.
There ere no significant effects on environmental quality, including those upon the two endangered species noted, as a result of SAFSTOR. Accidents during SAFSTOR have no significant consequences on environmental quality.
Comment N.
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 a.ny, 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.
PGandE Resoonse The Environmental Report (ER) (Attachment 6 to the SAFSTOR Decommissioning License Amendment Application) has adequately assessed the impact of 30 years SAFSTOR and possible accidents associated with those decommissioning activities.
The wildlife in aquatic and terrestrial ecosystems near the plant are described in detail in Section 4.0 of the ER.
Section 6.0 of the ER describ2s the health'and environmental implications of SAFSTOR. There are no significant effects on environmental quality, including upon the two endangered species noted, as a result of SAFSTOR. Accidents during SAFSTOR have no significant consequences on environmental quality.
Data taken during the baseline characterization, show that no significant contamination has resulted from the pool leakage.
1568M In addition, PGandE prepared a hydrological report dated June 1985 which was an assemblage of various hydrological data which described the probable maximum flood, the determination of flood levels, maximum wind and wave data, plant site drainage, and various tsunami levels at the bay near plant site.
Comment I.
No other agencies were actively involved in the preparation of this document, why is this? It seems that there are several jurisdictions that are to be affected. The Fish and Hildlife Service and California Coastal Commission are two agencies that would have to deal with impacts should an accident occur. Does NEPA provide exclusive jurisdiction in cases such as this? If so, please cite it specifically or justify your decision to prepare this document alone.
PGandE Resoonse The preparation of the DES for decommissioning a nuclear reactor'is within the charter of responsibility of the NRC.
In preparing this document, the NRC has complied with regulations cited in 10 CFR Part 51 and 40 CFR. Parts 1501 and 1503. The DES has 'been sent to various federal, state, and local agencies as referenced on page 8-1 for comment.
These comments along with the public comments will be considered in the Final Environmental Statement.
Comment A.
The FES should contain additional data, plans and mitigation measures sufficient to protect the environments around the plant from additional contamination.
(Repeat of A-7 and A-9)
PGandE Response Section 4.0 -in the Environmental Report (ER) (Attachment 6 to the SAFSTOR.
Decommissioning License Amendment Application) describes in detail the environmental setting of the plant. Section 6.0 in the ER sufficiently 1568M _
discusses the impact of decommissioning activities on the local environment and biota.
The following summarizes the discussion of the environmental impact of decommissioning.
No measurable offsite public exposure is expected during SAFSTOR, nor are any detcctable effects on environmental quality expected.
Releases to the environment via atmospheric emission through the stack, and aqueous discharges through the discharge canal, are expected to be equal to or less than measured values during shutdown, and remain within 10CFR20 MPC levels.
Surveys of
. plant and animal traterial, milk, and air samples have shown that operation and shutdown have had no significant effects on the environment.
The probability of significant accidents occurring during SAFSTOR is low. The consequences of the credible accidents affect occupational dose only. There are no significant public exposure or environmental quality consequences of credible accidents occurring during SAFSTOR.
In addition, SAFSTOR is a mitigative measure for immediate dismantlement of Unit 3.
Since releases (see Section 6.1 of the ER) are negligible with respect to public exposure (directly or by food / water pathways) and to environmental quality, no mitigative measures are expected to be needed during SAFSTOR normal operations.
1568M _
Comment A.
He do not believe that current plans or documentation 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.
PGandE Resoonse The potential environmental _ impacts of SAFSTOR have been adequately addressed in the Environmental Report (ER) (Attachment 6 to the SAFSTOR Decommissioning License Amendment Application). The ER is responsive to all aspects of 10.CFR 51.45, " Environmental Report." The process for preparing the ER and Draft Environmental Statement (DES) also comply with the EPA's regulations in 40 CFR Parts 1500 through 1503, which specify how~ federal agencies are to comply with NEPA.
For response to this comment on the Coastal Act, refer to the responses in Section 11. " Coastal Development Permit," (pp. 43-45).
Comment Q.
There 1: no inventory or surveys of evidence of cultural resources that may be located at or near the site which would be affected by the proposed action.
PGandE Resoonse No impacts to cultural resources have been identified that might occur as a result of SAFSTOR activities. PGandE's SAFSTOR Decommissioning License Amendment Request and Environmental Report were provided to the State Historical Preservation Office.
The State Historic Preservation Officer, upon review of PGandE's Submittal, has concurred that decommissioning will not involve any historic preservation properties or eligible properties.
1568M 3.
HYDROLOGY Comment D.
The Final Environmental Statement (FES) should include a full discussion of the site hydrology, and its relationship to future potential and past contamination of the groundwater around the plant, and the potential for migration into the adjacent bay.
L.
This section, 3.2.3, does not address the potential environmental impact of a tsunami. What precautions have been takenfto mitigate the effects of such an event to the-surrounding community and environment? The stretch of Highway 101 which runs adjacent to the plant boundary was closed to traffic just this past winter due to a tsunami watch posted.for the California coastline.
PGandE Resoonse The hydrology of the HBPP site is described in sections 4.1 and 10.3 of the Environmental Report (ER) submitted in support of the decommissioning of HBPP Unit 3.
The impacts of contamination due to plant operation (past, present, and potential) on site hydrology are discussed in sections 4.2, 6.2, and 6.3 of the ER, and in the response to NRC question number 72 on the ER.
The DES provides an assessment of the hydrological impacts of the Decommissioning License Amendment Application based on the hydrology-related sections of the Environmental Standard Review Plan for Construction Permit Review of Nuclear Power Plants (NUREG-0555). During its review, the NRC Staff generated numerous questions, one of which concerned the worst-case flooding effects on plant structures containing radioactive material.
PGandE's response included a detailed flood hydrology report (June 1985), which addressed the effects of a probable maximum flood resulting from storm rainfall, windstorms, and tsunami. Based on PGandE's response, the Staff concluded in the DES that there would be no measurable nonradiological hydrological impacts.
1568M - _ _ _
Comment L.
3.2.3.6 - What is the potentiality for contamination of the community wells located on the northeastern site boundary in the event of a spent fuel pool rupture?
PGandE Resoonse As noted in the response to NRC question number 72 on the Environmental Report submitted in~ support of the decommissioning of HBPP Unit 3. "there is no radienuclide transport landward because of the persistent gradient of the groundwater level toward Humboldt Bay."
However, concentrations of radionuclides were calculated for the nearest offsite wells (east of the site) even though this release path is not credible. The results of these calculations were presented as part of the response to the above NRC question. These results, which show release concentrations well below the 10 CFR 20 limits, may also be applied to the wells to the northeast of the site, since the analyses performed are for the most limiting cases (two nearest wells).
1568M.
4.
CHEMICAL AGENTS A.
Comment It is critical to know which of these materials ~(chemical agents) will remain onsite (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... important to know how hazardous materials presently used in plant maintenance and operation are transported and the location of the disposal site.
The FES 'should provide this information, including alternatives to offsite disposal and mitigation measures.
D.
The DES does not address the use and storage of chemical agents used for decontamination. What are the potential environmental impacts of these chemicals?
Q.
There is absolutely no discussion of the dangers and impacts of the use of chemical agents for decontaminating surfaces in the plant during the decommissioning process anywhere in.the DES.
The ER prepared by the licensee acknowledges that these chemicals possess hazardous properties.
Their misuse or spillage would have serious consequences. The FES should contain an inventory and analysis-of these chemicals, and provide information on the plans for storing, applying, rinsing, transporting, and disposing of them. There should also be a discussion of'the ramifications of accidents associated with their handling and storage, under " normal" circumstances and in the event an earthquake.
This is a major issue that is not even superficially addressed.in the DES. This oversight cannot be permitted to be repeated in the FES.
PGandE Resoonse The chemical agents referred to in these comments were listed in the Environmental Report as part of a general discussion of chemical decontamination in the event it might be used as part of the final DECON of the unit. These chemical agents are not now (nor currently planned to be) stored onsite.
If, as part of the final DECON 'of the unit, a chemical decontamination program is used, the processing and dispos &1 of wastes resulting from the process will be considered in light of regulations and 1568M..
disposal facilities existing at that time. PGandE's letter of October 2,1985, to Mr. John Hannum of the California Regional Hater Quality Control Board (copy provided to NRC staff on October 7, 1985) contains a discussion of hazardous materials existing onsite during the SAFSTOR period.
As part of the preparation for SAFSTOR, plant decontamination has been conducted primarily with mechanical techniques (high pressure wash, scrubbing, and wiping surfaces) using water and mild detergents. Chemical decontamination of the main condenser was conducted using a 5% solution of hydrochloric acid followed by a neutralizing solution of sodium carbonate and sodium sulfite. The waste generated by this process, (primarily sodium chloride solution) was collected in the radioactive waste treatment system, solidified using a cement process and shipped to the Richland, Hashington radioactive waste disposal facility. Hastes and. chemicals from that project are no longer onsite.
1568H..
5.
FUEL POOL COOLING SYSTEM Comment K.
Pg. 3-2, PP. 3:
"Because of the long time that has elapsed..." -- The fuel was removed from the reactor in 1984, not even two years ago!
(...it is no longer necessary to operate the fuel pool cooling system.)
PGandE Resoonse Humboldt Bay Unit 3 has been shut down since July 1976.
The 144 fuel assemblies which were in the reactor at that time remained there from July 1976 until 1984, when they were discharged to the spent fuel pool. At that time the spent fuel pool contained an additional 246 fuel assemblies which had been removed from the reactor during previous refuelings. During this time, the fission products in the fuel assemblies were decaying, and the residual decay heat of the fuel was also decreasing. Therefore, all of the spent fuel assemblies in the spent fuel pool have been cooling down for at
-least 10 years.
l l
1568M -.
6.
RADHASTE SYSTEM Commenj; C.
Section 3, Environmental Impacts.
Page 3-3, paragraph 3.1.7, water use.
This paragraph indicates that there will be occasional releases from the liquid waste treatment system which will be diluted with the cooling water flow from the two fossil fuel units. Has PGandE given any assurance that the two fossil fuel units will be in operation for the next.30 years?
K.
" diluted with cooling water. flow from two fossil-fueled units." -- What guarantee does PGandE make that t..ese two units will remain operational throughout the next 30 years? What will the diluting do if not?
L.
This paragraph also states that the releases from the liquid waste treatment system are "further-diluted with cooling water flow from the two fossil-fueled units." This gives the impression that the assumption is made that the 2 fossil-fueled units will continue to be operated throughout the 30 year SAFSTOR period and beyond through the decommissioning process.
PGandE Resoonse Although the remaining operational lifetime of the fossil-fueled units cannot.
be assured, the units are important for maintaining the electric system reliability in the Humboldt area.
It is likely that either these units or some'other facility will continue to be operated in the Humboldt area for this purpose.
Regardless of the operating status of the fossil-fueled units, PGandE will comply with the requirements of the Unit 3 NRC license regarding liquid waste discharges. The dilution of liquid radicactive waste discharges with cooling water flow from the fossil-fueled units is the current method of release. Changes from this method of release will require prior NRC review and approval of a license amendment.
J 1568M _.
Comment C.
Page 3-6, fifth paragraph.
This paragraph discusses the processing of liquid radwastes from the spent fuel pool. The statement that "the batch will be processed more before it is discharged" is quite nebulous. Some limits should be specified.
Limits are mentioned on the following page 3-7, fifth paragraph, where the draft EIS indicates that PGandE has proposed technical specifications. These specifications are not set out or discussed. Has the NRC reviewed these specifications and are they adequate?
K.
3.2:
" release of liquid and gaseous radioactive effluents." -- What releases? How much?
Pg. 3-4, pp 1:
"small quantities of radioactivity... will be released to the environment." -- Why will these releases happen? How much is small?
Pg. 3-6, pp 5:
"If contamination is... susoected in a batch" -- Does this reveal that not every batch will be tested?
"After processing" -- How clean is clean enough? Specify.
L.
3.1.7 - How occasional will be the releases from the liquid waste treatment system and in what quantities? What are the expected levels of radionuclide contaminants in this water?
3.2.2, Subparagraph 3 - The wording indicating the liquid radwastes from the 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?... Is any provision made for reprocessing of the effluent should the samples not be wi$;nin limits for contamination? These points should be stated more clearly.
PGandE Resoonse Section VI.B.1 of the proposed SAFSTOR Technical Specifications requires that each batch of wastes be sampled and analyzed before release to the discharge canal and that radioactive waste discharges to Humboldt Bay shall not exceed the limits given in 1C CFR 20, Appendix B, Table II, Column 2, on an instantaneous basis. This subject was also addressed in PGandE's response to NRC questions 8 and 9.
Review and approval of the proposed Technical Specifications is part of the review of the license amendment application.
1568M __
Estimates of. quantities to be discharged were contained in Section 6.2.1 of the Environmental Report and in response to NRC question 66. Calculated releases of radioactive materials in liquid, gaseous, and particulate effluents during the SAFSTOR period are contained in the DES Tables 3.1 and 3.2.
Comment K.
Pg. 3-3, 3.1.7:
" occasional release from the liquid waste treatment system." -- What 11guld will remain in the unit? Isn't the. plan to have it flushed at the onset?-
Page 3-6, pp 3:
" wastewater from ongoing decontamination activities..."
- - What activities are these? Be specific.
PGandE Resoonse 6
Some systems containing radioactive liquids that will remain in operation during SAFSTOR. These systems include the spent fuel storage pool, the spent fuel storage pool purification system, and the radioactive war,te collection and treatment systems. Operation and maintenance of these systems will result in liquid radioactive waste, which will be collected.in the radioactive waste treatment system. Once the wastes have been collected, they will be sampled, analyzed, and, if found to be within limits permitted by the license, released.
Decontamination work associated with.the operation and maintenance of systems in operation during SAFSTOR would involve activities such as collection of pump and valve leak-off, routine sample and analysis programs, and cleanup of contamination resulting from the disassembly and overhaul of pumps, valves, and other equipment.
1568H..
Comment K.
"Some metallic products...not expected to occur at toxic levels." There will obviously be lom.e radioactive effluent here; how much? and how hot?
This isn't data! And " expected" is very vague when we're dealing with toxicity to health.
PGandE Re3Donse The comment refers to a paragraph in the DES which states that the California Regional Water Quality Control Board has determined that the levels of metallic corrosion products in waste discharges are within limits of the National Pollution Discharge Elimination System (NPDES).
Limits for metallic corrosion products present in waste streams are specified in the HBPP NPDES Permit No. CA0005622. A revised permit was supplied to the NRC by PGandE letter dated October 7, 1985. The concentration of metallic corrosion products in the liquid radioactive waste effluent is discussed in Section 4.2.4.1.2 and Table 4.15 of th'e Environmental Report.
Comment B.
It is expected that small quantities of radioactivity will be released to the environment during normal SAFSTOR operations.
The source of such radioactivity will result from decontamination of systems and components, the operation and maintenance of the spent fuel storage pool, and the processing of waste management operations which have continued since the plant ceased operation in July 1976. Thus, the source term for estimating population dose over the 30-year SAFSTOR period is based on data gathered for the years 1977 through 1983. The calculated annual release rate of radioactive material in liquid effluents and in gaseous and particulate effluents are shown in Table 3.1 and 3.2 respectively.
Even though the releases are 'in the low nC1/yr range we believe that a measurement program should be conducted to verify that the releases are maintained as low as reasonably achieveble (ALARA). The results of such l
a program should be made available to state and local health officials l
responsible for evaluating potential population dose from the decommissioning operation.
l l
I l
l 1568M i l
-, - - -. -.. -,. - -.. - ~. _ _ _ _ -
PGandE Resoonse The proposed SAFSTOR Technical Specifications require monitoring of liquid, gaseous, and particulate effluents as well as the reporting of these effluents to the NRC in a semiannual effluent report. This report will become a public record and will be available for any officials needing the information.
Comment K.
PP 6:
" stored in a shielded area" -- With what degree of protection?
For how long?
PP 7:
" packaged for shipment and stored..." -- For how long?
Idefinitely? Specify.
"The handling of activated components will be similar... as appropriate." This is extremely vague; elaborate. Activated wasta is pretty nasty stuff. What plans are there for transuranics? Will anybody take them?
PGandE ResDonse As stated on page 3-7 of the DES,. solid radioactive wastes will be stored in the solid waste vault, the low-level waste storage building, and the solid waste handling building. Prior to storage, the wastes will be packaged in appropriate shipping containers. The storage location selected for a particular package will be determined by the radiation level * '
the package. The storage location selected will have sufficient shielding to prevent the radiation levels at the exterior.of.the storage location from exceeding as low as reasonably achievable (ALARA) levels and to prevent dose rates at controlled area boundaries from exceeding 10 CFR 20 limits.
The radiation hazard from activated components is similar to the hazard from other solid waste, thus, these components will be handled in a similar manner.
1568M -
When a sufficient quantity of radioactive wastes has been accumulated, it will be shipped to a licensed disposal facility.
Comment L.
2.2 Subparagraph 2, (2) - Into what will the reactor vessel and reactor cooling system be drained?
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?
N.
A statement is r>ade' on page 1-5 that the " plan" ensures that contaminated water is removed from certain systeins and tanks. How is this accomplished? Where does the contaminated water go?
PGandE Response The reactor vessel and reactor cooling system have been drained to the liquid radioactive waste collection and treatment system. The spent fuel pool coolers have been flushed with demineralized water and drained. Other plant systems have been flushed and drained. This water was also drained to the liquid radioactive waste collection and treatment system.
Treatment of liquid radioactive wastes is described in Section 3.2.2 of the DES.
Treatment consists of filtration, and if chemical composition of the waste requires or if the radioactivity levels exceed limits for release, the wastes will be treated through a radwaste evaporator.
The evaporator concentrates the waste into a slurry to reduce waste volume. The slurry is then retained onsite until it is solidified by a contractor and shipped to. a licensed disposal site.
1568M.-
' Comment
~
~
A.
The DES is deficient in that it does not propose an alternative to discharge into the bay or indicate that there~are backup systems available tx) handle the described emergency (radwaste-tank accident).
D.
The DES. fails to address alternatives to direct discharge of radwaste into the bay.
It also glosses over the use of backup systems in case of the need for emergency discharge.
Q.
The DES is deficient in failing to address alternatives ta the direct discharge of radwaste into Humboldt Bay as the result of its Horst Case
-Scenario.
It similarly fails to indicate that there are any backup systems - either in place or proposed - to handle the described emergency.
PGandE Response The uncontrolled release of radwaste tank contents was evaluated in the Decommissioning Plan, Environmental ~ Report, and DES as the worst case scenario. The results of this analysis were.that even assuming no mitigation of the event, discharge limits would not be exceeded. Systems present that could mitigate the consequences of this event include:
.Radwaste sump - The radwaste treatment system tankage area is provided with floor drains that drain to the radwaste sump and are automatically pumped to one of the receiver tanks.
Tankage area berms - The radwaste tanks are contained within concrete l
vaults or in concrete-lined areas that include concrete curbs to contain j
tank contents.
l Yard drain system - Should leakage occur, the waste will enter the. yard drain system, which directs water to the intake canal.
Before entering the canal, the water passes through a sump, which can be lined up to pump the water to the turbine building drain tank.
1568M - - -
The only alternative to the routine discharge of liquid wastes to the outfall canal would be to process all water through the radwaste evaporator. The resulting slurry would then be retained onsite for future solidification. The condensate from the evaporator would then be sampled to verify that it is below release limits and would be released to the outfall canal.
This method of operation would not be practical since the capacity of the evaporator is limited, and much of the liquid radioactive waste collected will be groundwater inleakage or rainwater inleakage with activity levels anticipated to be well below release limits.
1568H _- -.... _..
7.
SPENT FUEL POOL COVER Comment C.
The same paragraph also mentions that a cover is to be constructed and installed over the spent fuel pool to mitigate spread of contamination.
No information is given as to the design requirements for the cover This should be specified.
D.
There should be design specifications for and a technical analysis of the safety specifications involving the proposed spent fuel pool cover.
K.
Pg. 2-1, PP 3:
"A cover will be installed" -- When? What kind of cover?
Q.
There are no design specifications in the DES for the proposed spent fuel pool cover. What standards are considered safe? Are these standards premised on seismic safety? Will the cover be constructed of a material that could cause impact damage to the stored fuel in the event of an earthquake? These and other questions must be addressed.
The FES should contain a complete description of the cover's composition, proposed installation methods, technical specifications, safety value, ability to permit monitoring activities, and eventual safe removal.
PGandE Resoonse The cover over the spent fuel pool will be installed to prevent the spread of contamination from the spent fuel pool to the surrounding refueling building due to evaporation of the pool water. The cover will also aid in the maintenance of spent fuel pool water quality by preventing foreign materials (dust, dirt, etc.) from falling in the po'ol.
The spent fuel cover will be composed of panels of grating installed over the pool. The grating will be covered with a fabric cover, which will prevent contaminants from falling into the pool.
The cover was designed in accordance
. with the uniform building code. Safety analyses conducted for the Decommissioning Plan and the Environmental Report (and confirmed by the NRC analysis for the DES) ' concluded that seismic qualification of the spent fuel pool cover was not required.
1568M - - -
S.
RADNASTE ENCLOSURE STRUCTURE Cqm_m_fLil.t A.
The proposal to enclose ti.e radwaste building for storage of additional contaminants generated by the SAFSTOR 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 [ SIC], contamination.
The FES should contain a seismic analysis for the proposed structure as well as 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.
The FES should provide sufficient detail regarding the radwaste building (new) in order that public safety is ensured and in order that the Coastal Commission may determine whether the structure's design and location are most protective of coastal' resources.
D.
Specific requirements for the proposed radwaste building should be i
discussed in the FES. Hill the increased capacity of the facility contribute to an increased possibility for environmental contamination?
L.
3.2.2, Subparagraph 2 - Hill 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 capable and potentially capable faults in close proximity to the plant?
Q.
Despite licensee efforts to prevent soil contamination at the plant such contamination has persisted. The proposal to enclose the radwaste building for the storage of additional contaminants may actually increase soil contamination by increasing the volume to be handled and stored.
The DES does not provide adequate information on how the proposed construction will prevent soil and possibly water contamination. The FES should contain additional data, plans, and mitigation measures sufficient to protect the soil and water around and beneath the plant from i
additional contamination. Additionally, alternatives to constructing a new facility should be discussed in the FES.
Details on the technical specifications-for the proposed radwaste building are not included in the DES. Neither are plans or seismic standards included.~ The FES should provide this and related data on the structure to ensure that public safety is protected, and proper review by the Coastal Commission is possible. Under California law, the Coastal
-Commission must determine whether the structure's location and design are.
most protective of coastal resources. This information should be provided to the Commission for review and inclusion in the FES.
1568M ;
The DES does not indicate that the structural integrity of the proposed radwaste building will be in conformance with standards required of the plant itself. Failure to do so will result in the strong-likelihood of additional soil and water contamination in the event of a significant earthquake on or near faults adjacent to the plant. The FES should include a seismic analysis of the structure as well as any details on
)
backup safety systems it may be proposed to contain intended to prevent soil, groundwater, or open water contamination at the plant due to a significant seismic event.
PGandE Resoonse-The radwaste enclosure building was constructed to provide weather protection for the existing radwaste treatment facility, not to provide additional waste storage capacity.
It does not increase the volume of radwaste stored or handled in the radwaste building.
It is not a_new facility, but is an upgrade of an existing facility.
It was constructed in accordance with the Uniform Building Codes for this area.
The components in.this facility now hold and process radioactive, and potentially radioactive liquids and resin slurries from SAFSTOR activities.
The same tanks and piping associated with the system were originally installed in open-top concrete bunkers. Before the enclosure building was built, rainwater entering tne facility was collected and treated as radioactive waste.
The building precludes the need to process this rainwater.
The
~
building also rlovides weather-protected access for maintenance of the waste processing equipment.. The building will provide additional assurance against the potential spread of contamination from the liquid radioactive waste treatment facility to the surrounding Unit 3 yard. Ventilation from this area will be directed to the stack where it will be monitored by the stack monitoring. system. However, the additional assurance provided by this building against the possible spread of contamination exceeds NRC requirements and is incidental to its primary purpose of providing weather protection, 1568M 9.
VENTILATION PATHS Comment C.
Pages 3-6 and 3-7, Section 3.2.2, Radioactive Haste Management Systems.
There are numerou:: points in this section which talk about the control of emissions and releases but which give little information on the actual limits that will be imposed.
The second paragraph on page 3-7 indicates that no treatment is to be provided for the ventilation system release for " normal releases." What about abnormal releases? This paragraph also discusses the cover to be installed over the spent fuel pool but gives no performance requirements.
It also indicates that controlled ventilation will not be provided for the solid waste storage vault, the low-level waste storage building, or the solid waste handling building.
Why not? The third paragraph indicates that actual releases are expected to be less than the calculated releases but does not indicate how much less.
H.
Page 3-7: Ventilation exhausts from the refueling building, hot lab, hot l
machine shop and the radwaste treatment building operating area should be treated for they are a potential source of hot particulates.
L.
3.2.2, Subparagraph 6 - Why is the ventilation exhaust from the refueling building, hot lab, hot machine shop and radwaste treatment building not treated? This is a potential pathway for unnecessary environmental cont' amination.
Stating that "No treatment is provided by this system for i
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 occurrences 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 ab cy to pick up and carry particulate waste inland and offsite from these buildings since the ventilation and thus air currents are not controlled, especially when the doors are open.
PGandE Resoonse These comments were answered in responses to NRC questions 47 and 48 supplied in PGandE's letter of February 28, 1985.
1568M i
The ventilation exhaust from the' refueling building, hot lab, hot machine 4
shop, and radwaste treatment-building (operating area) will be routed to the plant ventilation system for release from the plant stack. This effluent will not receive routine treatment due to the low levels of activity that will be present. A stack monitoring system will be in operation to monitor gaseous activity (particularly Kr-85) and particulate activity of the stack ventilation exhaust.
t In the event df an accident that results in high airborne particulate radioactivity in the refueling building, the refueling building ventilation
~
system can be isolated and the refueling building air exhausted through the gas treatment system HEPA filter.
Controlled ventilation is not required for the waste storage vaults, low-level waste storage building, and low-level waste handling building since wastes-in these areas are packaged prior to storage to preclude the release of airborne radioactivity. Routine periodic surveys will be conducted in these arcas to
~ detect any releases of particulate radioactivity from the packages should it occur.
1568H.
- 10. SEISMICITY Comment l
A.
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 tha 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.
C.
Page v Summary and Conclusions, Paragraph 3.
This paragraph indicates that PGandE concluded in 1983 that the seismic requirements may continue
.to be too costly to consider and therefore decided to decommission the plant. Has the NRC clearly determined that the seismic design of the structure necessary for safe storage of the spent fuel is of adequate design for the'next 30-50 years?
4 K.
PP(3):
If seismic dangers were too great to operate the plant, they are too great to use the same facility for long-term storage of water, for which the site was not designed. Six active or potential earthquake faults are within reach of the site:
Little Salmon, Bay Entrance, Buhne l
Point, Falor-Korbel, Cape Mendocino-False Cape Shear Zone, and the Mendocino Fracture Zone. More may be revealed.
L.
Pg. V,-(3).- How is it possible for the Commission to support the action by PGandE to shut down the plant for seismic safety considerations and at' the same time recommend the SAFSTOR 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 i
which runs through the plant site) are in excess of magnitude 7.5.
University of California Seismologists and U.S. Department 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.
It is not better to dismantled the plant now under controlled conditions than to have Mother Nature do it for you under uncontrolled conditions with potentially catastrophic results?
M.
My second area of concern is how the NRC has determined that the seismic design of the plant is adequate and safe for "SAFSTOR" when it has been i
determined inadequate for operation (page v, [3]) and inadequate for entombment (page 1-3):
"The entombment structure may also fail as a l
result of seismic event with a potential for release of radioactivity."
1568M l
If seismic factors were used to evaluate entombment then why is the staff using the Commission's generic determinaticn that no significant i
environmental impacts will result from the storage of spent fuel in storage pools for at least 30 years to evaluate "SAFSTOR" rather than looking at this particular site and evaluating it on the basis of actual seismic factors?
Q.
The DES does not comply with the provisions and intentions of the National Environmental-Policy Act (NEPA) because it fails to examine the direct, indirect, and cumulative effects of the proposed action, and fails to substantively examine and discuss the range of alternatives that are presently available. Generic determinations are inherently invalid for the examination of the environmental impacts of a specific project or action. Assuming that SAFSTOR is a generically acceptable option for all nuclear power plants ignores the very serious special problem of the Humboldt Bay site - that is sits within 4000 feet of three capable or potentially capable faults. This is the main reason the plant was shut down in 1976, and the prime reason its retrofit is presently uneconomical.
It is illogical and irrational to dismiss this act when considering the wisdom of storing highly dangerous nuclear materials at the plant for the next 30 years, or as is arguably the case, longer.
A discussion of the seismic and geologic characteristics of the Humboldt Bay site is not included, and the DES treatment of the hazards of the site and their effects on the proposed action are far too cursury. The Humboldt reactor, as mentioned above (#2), was not permitted to restart by the NRC in 1976 because of serious concerns about the ability of the facility to withstand the maximum possible earthquake expected from the three capable faults located directly adjacent to the plant.
In 1983 modifications to bring the plant into NRC compliance, in addition to THI backfit requirements, were deemed to be so expensive as to be uneconomical.
The existence of three very close faults is bad enough, but other potentially active faults lace the on and offshore topography of Humboldt County which also could adversely effect the plant and the radioactive materials stored there. Within a 40 mile radius are: The Falor-Korbel fault (active).
This fault transects northwest Arcata and is capable of a 6.0-7.0 magnitude quake (ENVICOM, 1975); The CaDe Mendocino-False Caoe Shear Zone (active) is estimated to be capable of a 7.3 earthquake; and the Hendocino Fracture Zone (potentially active) is located in, or comprises, one of the most seismically active areas in North America (The Hendocino fracture zone is part of the tectonically active triple plate junction, and is capable of a 7+ [ Richter scale] magnitude [ November 1980] and is possible of a seismic event of " great quake" magnitude [8.0 or greatar].
The November 1980 temblor toppled a freeway overpass less than two miles from the plant, despite the epicenter's location being nearly 40 miles away.).
1568M.-_
It is rather hard to believe that the licensee could be informed that the plant site is unsuitable for continued operation of the plant,' while being permitted to advocate that.high level nuclear waste be stored there for an additional 30 years. More incredible still, is that the NRC would conclude that two other methods of storage and decommissioning (Independent Spent Fuel Storage Installation [ISFSI] and ENTOM) would be at least partly rejected as options because of seismic considerations.
The Entombment structure may also fail as a result of seismic events with a potential for a release of radioactivity (DES p 1-3 1.3.2)(emphasis added).
Thus, this activity...would reauire seismic considerations of the ISFSI 1(DES p. 1-4 1.3.3)(emphasis added).
The FES should provide a detailed treatment of the seismology.of the area and an examination of the risk of a 30 year or longer storage plan at the site.
The most important seismic considerations to be taken into account are those at the plant.
If the seismic considerations of other, hypothetical alternatives are to be considered as well, they should be considered from the standpoint of comparison with the risks associated with those already acknowledged at-the plant, which have precipitated the need for the proposed action in the first place.
PGandE Response While it is true that seismic considerations played a part in the decision to decommission the unit, other factors, such as potentially required modifications, staff increases, the remaining duration of the Unit 3 Operating License, and lower than originally projected replacement power costs, all contributed significantly to the decision.
(Refer to Environmental Report Section 10.7.2.)
Seismic-related design criteria for an operating nuclear power plant or for a shutdown facility with fuel stored onsite have the same basic objective, i.e.,
to protect the health and safety of the public. An operating nuclear plant has much equipment that is classified as safety-related. This equipment is required to operate or be available in order to prevent or mitigate the consequences of an accident,that might potentially result in a release of 1568H _-
radioactivity that could endanger the public health and safety.
Examples of this equipment include the safety systems that shut down a reactor in an emergency and the emergency cooling systems that prevent the reactor fuel from overheating, which could result in melting of the fuel and release of large amounts of radioactivity. These systems and many others, such as containment structures and monitoring systems, would be required to remain functional even following an earthquake, and thus are required to be designed to comply with certain seismic criteria. This requirement does not apply in the case of Humboldt Bay Unit 3 for the reasons as outline ~d in the following discussion.
Spent fuel storage fac'111 ties require similar systems, because even as long as a year after fuel assemblies are removed from a reactor, they still produce enough decay heat to require cooling systems to prevent fuel melting. Spent fuel recently' removed from a reactor also still contains a significant quantity of radioactive gases that could be released to the atmosphere in the event of damage to the fuel and the containment system.
In the case of Humboldt Bay Power Plant Unit 3, the reactor has not operated for over 10 years.
The decay heat still being generated in the spent fuel has
~
diminished to a level that no longer needs cooling systems to prevent fuel melting. The fuel can be adequately cooled by the natural convection of air.
(Refer to the response to the NRC's question No. 84 in PGandE's letter 3
HBL-85-005 dated February 28, 1985.)
l I
1568M - - - - _
. =
In addition, the gaseous activity in the spent fuel stored in Unit 3 has decayed to the point that the only significant remaining fission product gas is Kr-85 and sufficient quantities of that gas do not exist to result in a significant offsite exposure in the event of fuel damage.
(Refer to Environmental Report Table 10.4.5, " Spent Fuel Inventory," and SAFSTOR accident analyses in Section 6.3 of the Environmental Report and Section 3.2.3 of the DES.)
i Since.the potential for release of significant quantities of radioactivity from the spent fuel at HBPP as the result of an earthquake no longer exists, the structures and systems that would prevent these releases if the plant were I
operating are no' longer required to meet seismic criteria.
l In order to take the most conservative approach, the accident analyses contained in the Decommissioning Plan, Environmental Report, and PGandE's responses to NRC questions 71, 72' 74, and 75 assumed that structures and systems did fail as a result of an earthquake or some other event and that fuel damage did occur. These analyses concluded that a release of radioactivity which might endanger the health and safety of the public would i
not occur. These conclusions were confirmed by the accident analyses performed by the NRC Staff, as described in the DES.
Comment A.
He believe that the DES'. (sic) treatment of seismic hazards of this site i
and their potential effect in connection with the proposed project is' too j
cursory.
Large active faults 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.
i 1568M i i
.--__.,._,_,_,-,,.m,.r..,,
,-.__m._-, _ _. _,..., _,,,..
-,.-___._._.,.,_m....._.___.m_.,,___,___
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 j
those hazards' interactions with hazardous materials stored on site.
The proposed 30-year SAFSTOR period may extend for an indefinite period, further increasing the possibility that the facility will be exposed to seismic events, an issue not fully exposed 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. Substantial supplementation of this DES is needed to
. adequately address the seismic safety issue.
i D.
The FES should contain a full discussion of the potential for a major earthquake and series of earthquakes in the vicinity of the plant.
i Included in that discussion should be a detailed assessment of the resulting damage to the plant and the environment.
I.
The federal repository might be required to accept the spent fuel if an accurate geologic profile were presented in this document.
The geologic instability of this area is a well known fact and due to this, the i
nuclear site has always been threatened with an accident.
In my opinion, we have been lucky that no spillage of contaminated water or disarrangement of spent fuel rods has occurred.
This unstable condition should merit a reevaluation of your. assumption that this is a safe. place l
to keep nuclear wastes.
There is a great need for more adequate information on the geology within this report. Nowwhere in the report is there an accurate profile of the geologic structures and faulting ~of the Humboldt Bay region.
In several instances (i.e., item 3.2.3.4.), you refer to the possibility of seismic activity. How will a reviewing agency be able to qualify (and quantify) i the potential magnitude of seismic activity, if no documentation is i
provided? The San Andreas Fault is only 30 miles away. The Salmon Fault lies 3-5 miles from Unit 3.
The Freshwater Fault lies within 10 miles of i
the site.
I counted over 20. faults within 50 miles of the plant, and these were only the bigger ones.
I lived here during an earthquake that l
registered 6.9 on the Richter scale. The result to my house was fractures in the walls, objects being dislodged and a violent thrashing.
[
Another one knocked down a highway overpass that lies within 3 miles of the reactor site.
In light of this, I officially request that the study L
of geologic impacts be reviewed and modified with more complete information presented in the final document.
K.
Also, the " generic determination" is worthless, because Humboldt Bay's seismic situation places it at the extreme danger end of the spectrum i
i assessed. Humboldt does not fit into'an average scenario, because of the grossly different site-specific problems.
(An example of the meaninglessness of applying generic studies to vastly varying conditions are the cost estimates for decommissioning:
these generic estimates were widely accepted, but have proven way off base for individual plants.)
l 1568M. ~.
L.
Given the potential for heavy seismic activity during SAFSTOR period this issue should be addressed. This Section, 3.2.3, 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.
N.
I believe the Draft Environmental Statement (DES) for the decommissioning of the Humboldt Bay Nuclear Power Plant is. woefully inadequate in addressing the issues of long-term storage of radioactive materials in a known seismically active area.
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.
PGandE Resoonse Commentors confuse the purposes of the environmental statement and the applicant's Environmental Report (ER), which forms the basis for the statement. The purpose of the environmental statement is to describe the "...
probable impact of the proposed action on the environment." This the Draft Environmental Statement (DES) clearly accomplishes.
Seismology of the area in near proximity to the plant site has been exhaustively studied, as reported in the ER (4.1.3 and Appendix 10.3). The literature is readily available to the public. To assess the maximum consequences that could potentially result from a seismic event, two accidental release events that envelop possible seismic effect at the site have been postulated (DES 3.2.3.6 and 3.2.3.7).
The.results of thes'e postulated events, using extremely conservati'.e assumptions, clearly show that the resultant radiological impacts are extremely small and of no consequence to public-health and safety.
t 1568H. --
Comment A.
One offsite alternative, independent spent fuel storage installation (ISFSI) is rejected in part because of possible seismic considerations.
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.
It is quite likely that the 30 year SAFSTOR period may extend beyond this timeframe.
It is difficult 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."
E.
He have read the Draft Environmental Statement suggesting that DECON is the only viable alternative in the decommissioning process of our power.
plant.
It states that ENTOMB is impractical in an area where seismic occurrences could rupture the casings. Humboldt County is an area of high seismic activity. How much more dangerous is it to store the liquid waste without entombment?
L.
1.3.2, Subparagraph 1 - If ar.y 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)
~
K.
Pg. 1-3,- PP 1 :
"The entombment structure may also fail as a result of seismic events with a potential for a release of radioactivity." This is the reason given for rejecting entombment; yet the nonentombed storage structure being proposed would be even s mt prone to earthquakes!
The i
DES is totally illogical here.
EGandE Response While we will not attempt to explain the NRC Staff's justification for these statements, there are certain factors the public comments appear to have overlooked.
(
Hith regard to the seismic failure of an entombment structure, a basis of the entombment concept that makes if different from SAFSTOR is that the entombed j
facility ieed not be manned, and the structure would be designed to shield the facility and to prevent unauthorized exposure throughout the entombment 1568H -.
J
~ period.
In the case of a SAFSTOR facility, the facility would be manne'd to
. monitor conditions and to prevent unauthorized exposure of a member of the public.
If a seismic event were to damage an entombment structure.. personnel and monitoring equipment might not be available to prevent unauthorized exposures or to monitor the facility, which would no longer be considered
" entombed." It is obvious that the seismic criteria for an entembment i
structure would be much more restrictive than for a SAFSTOR facility.
i Hith regard to an Independent Spent Fuel Storage Installation (ISFSI), such a i
facility would be constructed and licensed under 10 CFR 72.
This would permit spent fuel with as little as one year decay following removal. from a reactor to be stored at the ISFSI. Systems would be necessary to ensure sufficient cooling of the fuel following a seismic event.
Since it has been demonstrated i
that the spent fuel at Unit 3 no longer requires cooling systems, the seismic requirements are less restrictive.
Comment J.
The major concern not fully addressed in the Environmental Statement is l
earthquakes. The spent fuel and wastes will be stored in a leaking pool for thirty years. Has the secondary liner been fully designed to 4
withstand earth movement?
L.
Are seismic loads likely to increase the liner leak rate?
PGandE Response 4
Based on the assumption that credit is not taken for seismic design of HBPP Unit 3 systems and equipment, the potential exists for the spent fuel pool 3
leakage rate to be increased as a result of seismic activity. However, the consequences of increased leakage rates would be less than those of the
}
}
i 1568M !
~
accident evaluated in the Environmental Report, which assumed rupture of the spent fuel pool. This accident has been shown not to result in a release of significant levels of radioactivity to the environment.
If leakage rates were to increase to a point approaching or exceeding the capacity of the liner gap pumping system, investigations would be conducted and repairs made to lower the leakage rate within controllable 11' s.
In the case of increased groundwater leakage into the gap, pumping frequency or pumping capacity could be increased.
l e
1568M. - - _
- 11. C0ASTAL, DEVELOPMENT PERMIT Comment A.
Section 30600 requires that any new development in the Coastal Zone be authorized by a coastal development permit.
PGandE Resoonse PGandE will continue to coordinate activities at HBPP-with the California Coastal Commission as required by the California Coastal Act.
However, PGandE does not anticipato that a Coastal Development Permit will be. required for the SAFSTOR activities based on an exemption presented in Section II 2.a. of the l
Repair, Maintenance and Utility Hook-up Exclusions from Permit Requirements (Adopted by the California Coastal Commission on September 5, 1978). This section states the following:
)
"A coastal permit is not required for repairs, maintenance, and minor
{
alterations which do not increase the capacity of the facility or work required to supply increased demand of existing customer's facilities in order to maintain the existing standard of service. A coastal permit is not required for installation of any required new safety _ devices and pollution control facilities within existing structures or equipment or where land coverage, height or bulk of existing structures will not be increased."
The SAFSTOR activities consist of repairs, maintenance and minor alterations 4
^
that will not increase the capacity of the facility and will not increase land coverage, height or bulk of. existing structures. New alterations will consist of the installation of required new safety devices and pollutic,n control facilities totally within existing structures. Therefore, the SAFSTOR activities are exempt from Coastal Development Permit requirements.
i 1568M 1 i
A building has been constructed over the existing low-level storage treatment facility at HBPP. This building was exempted from Coastal Development Permit
. requirements by the North Coast District of the California Coastal Commission on July 18, 1985, based on the Section II 2.a. exemption.
A Coastal Development Permit may be required for the eventual DECON activities.
If this is the case, PGandE will submit a Coastal Development Permit Application to the California Coastal Commission prior to the commencement of DECON activities.
Comment A.
Any or all of these is:ues (39-42), [ sic] as well as others such as effect of grading and construction activities, may be the subject of Commission review of a coastal development permit application for this project.
PGandE Response PGandE does not anticipate that a Coastal Development Permit will be required for the SAFSTOR activities, as discussed in the response to comment A (p.42).
Therefore, it is not anticipated that the California Coastal Commission will review the SAFSTOR activities except for reviews associated with the DES.
A Coastal Development Permit may be required for the eventual DECON activities.
If this is the case, PGandE will submit a Coastal Development Permit Application to the California Coastal Commission prior to the commencement of DECON activities. The California Coastal Commission may review the issues raised in the comment at the time the Coastal Development Permit Applir.ation for DECON activities is submitted.
1568M Comment A.
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.
PGandE Resoonse PGandE do~es not anticipate that a Coastal Development Permit will be required for the SAFSTOR activities, as discussed in the response to comment A (p.42)
A Coastal Development Permit may be required for the eventual DECON activities.
If this is the case, PGandE will submit a Coastal Development Permit Application to the California Coastal Commission prior to the commencement of DECON activities.
Comment Q.
There is no discussion of how the proposed action will be in compliance with State statues, i.e., the California Coastal Act, or how inter-agency coordination efforts will be conducted to ensure compliance.
EGandE Resoonse PGandE will comply with applicable federal, state, and local statutes, ordinances, rules, and regulations during the SAFSTOR and eventual DECON activities.
PGandE will coordinate SAFSTOR and DECON activities with federal, state, and local regulatory agencies, as required to satisfy applicable statutes, ordinances, rules, and regulations and/or permit conditions.
1568H 44 -
,_._,.-,,___----___.y-
.._,-..,,,.------_-.m--,,,_,,,
- 12. DECOMMISSIONING FUNDS Comment K.
Pg. 2-6:
" set aside and accrue funds for DECON activities." -- Only 17.
of the current estimated cost ($600,000 out of $60 million) has been set aside to date. The actual cost will probably be much higher due to inflation and regulations which are becoming steadily stricter and more expensive each year. Where are the funds to be kept? Who controls them? What if the company fails during the 30 years? Will the money then exist to cover the real dismantlement? Is there any guarantee that the total necessary funding will~ be available even if the company is
" solvent" in 2015? What will be left on Humboldt Bay's shores if not?
P.
Nowhere could I find in the D.E.S. a mention of the fact that virtually no funds have been set aside for the decommissioning of this facility.
The nuclear industry, in general, appears to be avoiding the issue of establishing a realistic cost basis for full decon of a commercial reactor.
Humboldt Bay Unit No. 3 is clearly the best candidate currently available for establishing the "real" (not estimated) DECON cost basis for projecting a more accurate " set aside" funding formula for cther active reactors around the nation. Until such a formula is established they too are destined to come to the end of their " economic lives" with insufficient funds for DECON.
As you are certainly aware, over dependence on the Battelle studies of very small experimental reactors are not comparable to commercial units and therefore a potentially catastrophic basis for " generic estimates."
PGandE Resoonse On September 19, 1983, PGandE filed its application with the California Public Utilities Commission (CPUC) to recover its unrecovered capital investment in the Humboldt Nuclear Unit, and to collect the necessary decommissioning funds. After hearings that stretched over 2 years, on December 4, 1985, the CPUC authorized PGandE to collect in an external or trust fund the necessary decommissioning funds (estimated $58 million expressed in 1986 dollars) over a 4-year period. Growth of the trust fund is anticipated to account for the 1568H __ __
effects of inflation to ensur6 that sufficient funds are available when final DECON is performed. The actual collection has been delayed pending j
. regulations under the Tax Reform Act of 1984 that would set treatment of the funds.
Briefly summarized, under PGandE's proposed external fund or Trust Agreement, most supervisory and administrative control of the Trust is in the hands of a Committee. The Committee will have the power to select trustees and investment advisors and to establish investment trust policy, among other-matters. The Committee would be established and Committee members selected by the CPUC. The operating and administrative control of the trust would be retained by the CPUC through its control of the membership.
Current California law requires a review of the decommissioning cost estimate at each general rate case (currently every 3 years).
In addition, PGandE has committed to a review and update of the deco =issioning plan every G years.
These reviews will account for the effects of changing regulations and technology to ensure that sufficient funds are available when the final DECON takes place.
Comment H.
Also on page 2-6 is the statement that "the licensee has initiated action with the California Public Utilities Comission to set aside and accrue funds for DECON activities." I would like to know why people who receive no electricity from Unit 3 (anyone who began receiving power after 1976) must pay for its dismantling.
1568M PGandE Resoonse The cost of decommissioning or retiring a power plant is part of the cost of doing business, as is the cost of constructing the plant. As such, these costs are recoverable in rates.
It has been the longstanding policy of the CPUC for customers to receive the full benefit of plants that exceed their.
estimated useful lives, and to bear the costs in rates of plants that do not meet their estimated useful lives. PGandE presently has 36 plants that have exceeded their estimated useful lives and 14 plants that for a variety of reasons did not reach their estimated useful lives.
The CPUC in its decision of December 4, 1985, concluded that the cost of decommissioning Humboldt Bay Power Plant Unit 3 is recoverable in rates.
Comment K.
Pg. 3-1, PP. 3:
"of which 0.22 million dollars is allocated for Unit 3..."
Is this not an unrealistically low figure? Where is the supporting data?
PGandE Response This figure was supplied to the NRC in PGandE's letter of February 28, 1986, in response to question number 79 in the NRC letter of January 23, 1985. This.
figure represents the portion of the total plant labor costs that will be required for the surveillance and maintenance of Unit 3 during the SAFSTOR period. Updated estimates in 1986 dollars indicate that the total annual labor costs for Humboldt Bay Power Plant are $3.616, million of which $0.377 million will be allocated for Unit 3.
These figures are not unrealistically low considering the low level of surveillance and maintenance that will-be required during SAFSTOR.
1568M - _ _ _ _
- 13. DELAYED DECON Comment C.
Page 3-4, last paragraph of Section 3.2.
This paragraph indicates that the NR'; is using estimates from NUREG/CR-0672 for calculating the environ.ontal radiological impact from delayed DECON. Have the NUREG/CR-0672 estimates been given proper review and have they been accepted by the NRC and/or others for this purpose?
L.
3.2.2, Subparagraph 10
" Atmospheric releases will be insignificant."
Upon what is this statement based? What quantity does " insignificant" represent?
PGandE Resoonse As stated in the Environmental Report, Section 7.2.2, " Releases during final decontamination and dismantlement will primarily be due to waste management operations. Based on the plant inventory decayed to 2016, the atmospheric releases from all operations will be negligible."
The report " Technology, Safety, and Costs of Decommissioning a Reference Boiling Water Reactor Power Station," NUREG/CR-0672, was prepared by a contractor for the NRC.
Reports that are developed as NUREGs must be approved by NRC management before publication, since they will be used as bases for specific studies.
In this report, the atmospheric releases of radioactivity during immediate decommissioning are calculated to be approximately 0.005 millirem to the total body for the maximum exposed individual. These radiation doses are extremely small in comparison with the range of annual radiation doses to individuals from natural background in the U.S., which is from 80 to 170 millirem per year.
The calculated radiation doses are also smaller than the allowable radiation doses to the public from operating LHR facilities set forth in 10 CFR 50 Appendix I.
1568M - - - - -. -
During the proposed SAFSTOR period, radioactivity levels would be significantly reduced by a factor of 19 to 100 because of radioactivity decay. Therefore, since the calculated radiation doses for immediate dismantlement are already small, public radiation doses for deferred dismantlement would be that much sraller, or insignificant.
t 1568M !
14.
Low-Level Haste Comment A.
It is vague as to which of the contaminated materials can be considered
" low level waste" and thus may be disposed offsite, and which materials contain a higher degree of radioactivity necessitating onsite storage.
PGandE Resnonse High-level waste (HLH) is primarily spent nuclear fuel; virtually all other j
radioactive waste is low-level waste (LLH).
LLH can be disposed.of at the l
U.S. Ecology site near Richland, Washington, and will continue to be until a California site is opened. Disposal of high-level radioactive waste is the 3
responsibility of the U.S. Department of Energy. A contract has been signed by PGandE and the DOE for disposal'of the high-level waste when a facility becomes operational.
In addition to the spent fuel, some material containing radioactivity F
concentrations exceeding 10 CFR 61 Class C limits will continue to be stored i
onsite. This will permit further decay of the radioactivity. These materials will be disposed of following removal of spent fuel from the site.
i Comment A.
The DES is vague regarding the amounts of each type of material which will be stored onsite until a permanent licensed disposal site is established.
It is unclear as to the location of a LLH site and if existing materials are already being transported there.
I If PGandE has such a (LLH) site already selected, then the FES should state the location and evaluate the associated impacts at the location.
If one (LLH) is not available, then information should be provided regarding long-term storage of high and low level radioactive materials.
t i
1568M I
1 K.
1.3.3:
"all fuel assemolies... and radioactive fluids and wastes should be removed from the site.:
Is there a place to ship them?
Pg. 3-7, PP1: Hill Richland take all the solid waste, or do new quotas preclude that? Where else?
Q.
The DES is vague as to which contaminated materials are considered low or high level waste, and how much of either classification will be stored on-site until permanent repositories are located. The associated impacts at the final destination facility are also not addressed PGandE Resoonse Spent fuel (HLW) will be stored onsite until the DOE is prepared to receive it.
LLH will be generated, processed, and stored onsite until enough is available to make a cost-effective shipment to a licensed disposal site, which will probably be Richland, Washington, until a California site is available.
Disposal of LLH is an activity already authorized by the facility license.
This activity is ongoing and will be essentially complete before SAFSTOR is begun. Quantities of waste to be generated during SAFSTOR are well within approved quotas for the disposal sites.
Presently, the Richland site will accept LLH from Humboldt.
Impacts associated with permanent storage of LLH at that site have been addressed by U.S. Ecology.
1568M - - _..
F
- 15. FUEL STORAGE ALTERNATIVES Comment A.
The DES refers only to NRC (spent fuel) disposal sites and ignores any other alternative sites which may be available through the Department of l
Energy (DOE) or other agencies.
There appears to be an established precedent 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 (sic) and explore not only shipping of nuclear fuel assemblies, but dismantling the entire facility to be ultimately disposed at Hanford or i
j elsewhere.
It is unclear why (Carlsbad) was used.for analytical purposes but not seriously considered for immediate disposal of the spent fuel.
{
If (Carlsbad) is not available for disposal of radioactive waste, then i
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).
If the Carlsbad facility is a potential receiver site, then PGandE and the FES should thoroughly analyze the possibility of using it as a repository for the fuel and other. contaminated material.from Humboldt.
l Why is it not feasible to transport the same elements (reactor vessel) of Humboldt to Richland?
Answers to.the above questions (32-37) will be necessary in order that the Coastal Commission can determine whether the final proposal is most i
j feasible, least environmentally damaging alternative.
C.
Section 2, Description of Plant and Proposed Decommissioning (sic) Plan.
l Page 2-1.
Third paragraph of the page mentions 390 partially or
" completely spent" fuel assemblies. The term " completely spent" is a j
term that is not particularly meaningful in the discussion of high-level waste.
It certainly does not mean that the fuel is non-radioactive.
What it really means is that the fuel assembly has been judged to be not suitable for reinsertion and operation in the Humboldt Bay reactor. The
[
EIS should make this clear.
K.
PP (Sa): There is no evidence given that this is the " sole" viable alternative.*
Why were not the following possibilities for spent fuel storage l
assessed?:
Idaho Labs; HIPP in New Mexico; Hanford; Savannah River; or any other DOE experimental programs. The one-time high risk of j
transporting may be safer than the ongoing, 30-year risk of seismic j
or ocean-front disaster.
I 1568H,
i
' "not presently feasible" -- The DECON alternative is dismissed 1.3.1.:
out of hand, with no investigation of moving spent fuel assemblies to any of the above-named facilities; to Morris, Ill.; to Diablo Canyon; or to another new temporary site with fewer seismic, coastal, or population problems (for instance, the Nevada test-site, already strongly contaminated and policed.)
i Pg. 4-1, PP 3:
"Decon is not feasible..." -- This is weak analysis:
Morris, Ill. is not even given passing consideration. The example of Elk River is discounted.
Pg. v, PP (2):
Terming the proposed storage " safe" is vague and cynical. Also, in light of recent waste storage developments, "until a Federal repository is available' could be longer than the 30 years:
this possibility is not engaged in the DES.
2.2 (1):
"until DOE has a permanent Federal repository" -- This might be a very long time, what with recent lawsuits filed by all of the proposed siting states' governors.
The DES doesn't address the impacts of a longer-than-expected wait; why?
L.
Pg. V (2) - Why is it necessary to wait for a Federal Repository? What t
about commercial repositories, or reprocessing at a DOE Reprocessing Plant? Have these and other options been thoroughly investigated by i
PGandE7 ll 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?
M.
My first comment on the DES involves the use of the word " alternative."
43 Alternative is defined as "a choice between two or more than two possibilities." The discussion on pages 1-2 to 1-5 makes it clear that all the possible decommissioning methods, except "SAFSTOR," are actually not possibilities at all. The statement on page 1-3 that "the licensee selected the SAFSTOR alternative for three reasons" (and goes on to list the reasons) is misleading and sloppy; the licensee has no real choice i
because of the lack of a Federal repository and because entombment is no i'
longer thought to be a reasonable option. At this time, mothballing is the only way to decommission (or rather to begin the process of decommissioning) a nuclear power plant.
The statement on page v,
" Storing the spent fuel assemblies at Humboldt Bay is the sole viable i
alternative for spent fuel storage at this time," is also misleading and should be reworded in the FES; there is no such thing as a " sole l
alternative."
(See also page 5-1, second paragraph.)
And finally I want to know why the nuclear power industry, which is over 1
j thirty years old, has not developed, or made it a priority to develop, comprehensive, realistic and ecologically responsible plans for disposing j
of its highly destructive wastes. Peter Erickson's response to my I
i 156&M.u
question of why the DES took so much longer to complete than expected was that the NRC's priority is licensing new plants. Hell, I say to you, NRC, that it is time to change your priority.
It makes no logical sense at all to have spent thirty years developing a technology that creates a highly toxic waste without developing a way of safely dealing with that waste.
It is the responsibility of the NRC and the DOE to see that these plans be developed and implemented now. Please wake up and stop leaving for your children to do tomorrow what you should be doing today.
P.
The arguments presented for "SAFSTOR" are inadequate:
1e: Page 1-3 1.3.3 (1)"...there is no Federal repository for spent fuel."
This fuel can be transhipped to Diablo Canyon to clear the way for complete DECON now.
It is in the interest of serving the greater need to establish a valid "DECON" cost basis for commercial units so adequate
" set aside" funds can be established prior to closure (unlike Humboldt Bay Unit No. 3).
Further:
Page 1-33 1.3.3. (2) & (3) are redundant reasons, therefore there is actually only one viable reason presented supporting SAFSTOR in the D.E.S. rather than the 3 suggested.
Q.
The existing precedent of storing spent fuel at other federal, but non-NRC sites (as in the cases of Three Mile Island and Shippingport--stored at Hanford and Idaho Falls respectively) is ignored in the DES.
This is in apparent violation of NEPA, wnich requires a discussion of reasonable alternatives "not within the jurisdiction of the lead agency," 40 C.F.R. Part 1502.14 (c). Such a discussion must be included in the FES.
PGandE Response As indicated in the Summary and Conclusions of the DES (page v), " storing the spent fuel assemblies at Humboldt Bay is the sole viable alternative for spent fuel storage at this time."
There are currently no recipient facilities in the U.S. for spent fuel since f
there are no spent fuel reprocessing facilities, away-from-reactor storage facilities, or geologic repositories currently operating or accepting uncontracted spent fuel.
1568H.
Pacific Northwest Laboratories (PNL) performed an independent assessment of
" Alternatives and Issues for Extended Storage of Spent Nuclear Fuel from Humboldt Bay Power Plant Unit No. 3" in July 1985. The alternatives investigated included:
(1) storage onsite in the storage pool; (2) storage at a federal government site; (3) storage at a commercial away-from-reactor (AFR) or independent spent fuel storage installation (ISFSI); (4) dry storage onsite 1
or offsite; and (5) transshipment of the spent fuel to another reactor for interim storage in its storage pool.
It was concluded that " extended storage in the onsite storage pool would be the most attractive course of action."
1 1568H 16.
FUEL POOL LEAKAGE Comment A.
He note... that the radioactive discharge (spent fuel pool leakage) has not been halted.
'PGandE Response As discussed in the Environmental Report, leakage from the spent fuel pool is controlled and monitored as part of the low-level waste treatment system.
Discharges from the spent fuel pool leakage pump and subsystem are expected to continue during the SAFSTOR period, and the requisite portions of the low level waste treatment system will be maintained operable to support operation of the spent fuel pool. Discharges from this system will be monitored, and plant effluents will be maintained within the limits established by 10 CFR 20.
Comment A.
He believe that there is a greater risk for a higher level of soil contamination than has been indicated in the DES.
PGandE Resoonse Soil contamination during SAFSTOR operation due to leakage from the spent fuel pool is not expected to occur due to the operation of the spent fuel pool liner gap pumping system.
I The operation and function of this system are discussed in ER section 4.2.3.1.1 and DES section 2.1.
Release of radioactivity as a result of soil contamination and the release of radioactivity to groundwater, Humboldt Bay, and potable water supplies were extensively discussed in PGandE's letter of April 3, 1985, (HBL-85-014) which responded to NRC Staff questions.
1568M -
Comment A.
The FES should fully disclose the potenti6l cumulative effects of increasing the amount of long-term storage of radioactive liquid in a pool already plagued by leakage.
PGandE Response There are no plans to increase the amount of radioactive liquid in the spent fuel pool, since the amount of liquid is controlled by the water levels required to be maintained in the pool. The amount of radioactivity contained in the pool (a function of the concentrations of the various radionuclides) will actually be reduced due to the upgrading of the spent fuel pool water cleanup system.
Since the spent fuel pool leakage through the stainless steel liner and groundwater inleakage through the pool walls are collected by the Unit 3 liquid radioactive waste collection system, the effects of this leakage are included in estimates for releases over the SAFSTOR period.
Refer to the Environmental Report (Section 6.2.1) and the DES (Section 3.2.2 and Table 3.1) for estimated releases and an evaluation of their effects.
Comment K.
Pg. 2-5, PP 2:
"The water from the inner gap is pumped to the radwaste system." -- These pumps will have to operate flawlessly for 30 years to maintain the proposed level of leakage. What provisions have been made to insure this?
PGandE Response The liner gap pump is not operated continuously.
The pump is currently operated for 10-15 minutes on approximately a weekly cycle to maintain the liner gap in the specified control band.
In addition, the pump will be demonstrated operable at least every 31 days under the proposed SAFSTOR 1568M Technical Specifications.
If the pump should fail to operate properly, leak rates into the gap are low enough (approximately 3 inches level increase per day) to permit repair or replacement of the pump before level could increase above groundwater level.
Comment A.
The FES should more fully identify measures for mitigating the potential impacts, including pump malfunction and leakage risks.
This analysis should address effects on area farmlands, ground water, wetlands, and bay waters.
(See also A-10)
PGandE Response Horst case (no mitigation with maximum release) scenarios have been evaluated for potential impacts on plant surroundings. The results of these evaluations are contained in the ER and the DES, and the net results do not dictate use of additional means of mitigation.
Measures (in place or to be used in the event of an accident) for the mitigation of accidents are not the subject of the ER/ES and are beyond the scope of these documents.
Comment C.
Page 2-1, 4th paragraph, discusses fuel pool leakage that has occurred in the past and is still occurring.
It indicates that the liner gap leakage is processed to the radwaste system and that the water level in the gap between the fuel pool liner and the structure it maintained at a level lower than the ground water level.
The implication of this is that this
" pump-down" processing should assure that the leakage is from the ground water into the gap rather than from the gap into the ground water.
There is no indication given, however, that the SAFSTOR decommissioning plan will require continued operation of the liner gap pumping system and the radwaste system to assure that the leakage does not go the other way.
Such a requirement should be a condition of approval of the plan, 1568M PGandE Response The Facility Operating License and Technical Specifications submitted for the SAFSTOR decomoissioning plan include requirements that the water level in the gap between between the spent fuel pool liner and the wall be maintained.
In addition, sufficient portions of the low-level waste processing system will be maintained operable to support system operation. As such, these requirements are a condition for the approval of the decommissioning licensing amendment.
Coment C.
No comitment is made for monitoring and processing the fuel storage pool liner leakage or for stabilization of soil contamination.
PGandE Resoonse Commitments for monitoring and processing spent fuel pool leakage and for monitoring onsite and offsite environment and groundwater contamination are l
provided as part of the Technical Specifications submitted for the SAFSTOR decommissioning plan. Commitments of this nature (specifics of commitments required for an OL) are not within the purview of an ER/ES.
Comment D.
The impacts of a failure in the spent fuel storage pool liner pump should be more adequately discussed.
EGandE Responig Failure of the spent fuel pool liner pump would have little or no impact on the site or its local environs, and pump operability is required (by Technical Specifications) to be demonstrated at least once per 31 days.
i l
1568M '
l
The water level in the gap between the spent fuel pool liner plate and the concrete wall is required by plant Technical Specifications to be within a certain range. As long as the appropriate water levels are maintained in this gap, pump failure would have no impact on plant releases.
Temporary inoperability of this pump could result in extremely small releases, only if the water level in the gap exceeded the groundwater level.
The effects of these releases are enveloped (by a very large margin) by the results of the spent fuel pool rupture, which has been demonstrated to have a very small impact on plant surroundings.
Comment D.
The DES needs to address assurances that the spent fuel pool will be adequately monitored for leakage, and needs to discuss what would happen to the plant if the licensee someday goes out of business.
PGandE Resnons'e Spent fuel pool level and leakage will be monitored as part of the decommissioning process. The commitments and requirements regarding the monitoring to be performed are provided as part of the plant Technical Specifications and, as such, are not within the scope of the ER or the ES.
Similarly, the financial health and well-being of the licensee is not within the scope of the ER/ES.
Comment K.
PP4:
"This leakage was attenuated" -- but apparently will continue, at a reduced rate, for thirty years? The California Coastal Commission, in commenting on this paragraph, said:
"There is a greater risk for a higher level of soil contamination than has been indicated in the DES."
1568M PGandE Resnonse Leakage from the spent fuel pool is expected to continue for the duration of SAFSTOR and until the spent fuel pool is finally drained. This leakage does not result in direct contamination of the soil during normal operations, since leakage from the spent fuel pool is collected and processed by the low-level waste processing system.
The potential for. soil contamination is discussed in the response to the second comment in this section.
Comment L.
2.1, Subparagraph 4 - This states that spent fuel pool leakage was detected in 1966 and that a "small amount of soil contamination 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 aquafir under the site been tested for possible contanination? 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 pump system?
PGandE Resnonse The spent fuel storage pool was originally constructed without a liner. The stainless steel liner was installed in 1963, and the pool operated from 1963 to 1966 with no indication of leakage.
In 1966, when a leak developed in the pool, it was determined that the source was both groundwater inleakage and leakage from the spent fuel pool. At that time, monitoring wells were drilled around the pool and determined that some contamination existed but that the levels were well below levels permitted for release by 10 CFR 20 Appendix B.
1568M Following discovery of the leak in 1966, operating procedures were developed to maintain the liner gap water level below pool level and below groundwater level so leakage would be collected in the radwaste treatment system.
The extent of soil contamination has not been specifically quantified due to the inability to sample under and around the pool while it is in operation. A series of 11 groundwater monitoring wells were drilled surrounding the spent fuel pool area and samples of soil and groundwater analyzed. These wells did not detect increased levels or radioactivity in either the soil or the groundwater that would have resulted from leakage of the spent fuel pool or any other subsurface structure.
It can be concluded that any soll contamination that may exist is most likely within the confines of the monitoring wells and thus is contained onsite.
The wells will continue to be used to monitor the groundwater during SAFSTOR to detect any movement of radioactivity.
Comment J.
What are the impacts and the backup systems associated with a loss of water from the spent fuel storage pool.
Q.
There is no discussion of the rate or consequences of continued contamination of the soil at, and groundwater beneath, the site due to the continued and potentially increased leakage of the spent fuel storage pool.
The FES should more fully disclose the potential cumulative effects of increasing the amount of long-term of radioactive liquid in a pool already plagued by leakage.
Failure of the mechanical pump system preventing escape of leaked materials from the spent fuel storage pool is not addressed in the DES.
This should be rectified in the FES along with a discussion of the impact associated with the pump's failure, and any backup systems, planned or to be required, by the NRC.
1568H )
The FES should more fully identify measures for mitigating the potential impacts, including those caused by pump malfunction and leakage, on area farmlands, groundwater, wetlands, and bay waters.
There is no apparent commitment in th( document for monitoring or processing the spent fuel storage pool, nor is there any for preventing stabilizing soil contamination existing or which may be the result of liner leakage.
PGandE Resoonse In March 1966, an apparent leak developed in the spent fuel storage pool stainless steel liner. The leak was reported to the NRC and investigations conducted to determine the extent of the leak.
In addition, interim measures were implemented to minimize the leak rate.
Although such a leak has the potential to release radioactivity to the ground around the pool and to the groundwater, concentrations of such radioactivity are well below federal limits for release to unrestricted areas.
Procedures were developed to direct any such leakage to the plant radioactive waste treatment system. These procedures have been in effect since 1967.
In 1984, in preparation for the SAFSTOR decommissioning of Unit 3, 11 groundwater monitoring wells were drilled encircling the spent fuel storage pool.
The wells verified that the ground between the pool and the site boundary has not become contaminated due to any leakage from the pool.
In addition, the wells will provide a groundwater monitoring system to detect any such leakage should it develop during the SAFSTOR period.
1568H l
17.
FUEL HANDLING ACCIDENT Comment C.
Page 3-9, Section 3.2.3.2, Fuel Handling Accident. This section discusses the offsite radiological consequences of the drop of a spent fuel assembly.
It calculates the offsite dose assuming that there has been damage to one of the pins in each of two assemblies, "a reasonably conservative assumption." What is the basis for the assertion that this is a reasonably conservative assumption? Given the age of this fuel it would certainly be more conservative to assume that damage would be sustained by all of the pins in the affected fuel assemblies. This should be considered.
L.
3.2.3.2 - In this 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?
Q.
The discussion of the Fuel Handling Accident (p 3-9) assumes that there would be limited damage to fuel assemblies dropped. This not substantiated.
PGandE Resoonse PGandE has performed an analysis to determine the impact of damaging all the fuel pins in all 390 assemblies which results in a release of the entire'Kr-85 inventory to the environment. The guidance of NRC Regulatory Guides 1.145, 1.109, and Safety Guide 1.25 were used in these calculations, along with the worst case meteorology.
The results of these calculations show that the dose to the whole body will be less than or equal to 5 mrem (0.005 rem). This is a sma11 fraction of the Environmental Protections Agency's Protective Action Guides of 1-5 rem whole body.
1568M
- 18. FUEL POOL RUPTURE Comment A.
This conclusion (spent fuel pool fluid, post structural rupture, would be retained because the ground water elevation surrounding the storage pool and suppression chamber exceeds the pool water elevation) is at odds with the information presented in Section 10.3.2.2 of the ER, which concludes 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 runoff to the wetlands and Bay, both from the radiation in the various fish and mollusk species, and from serious financial impacts on California's coastal fisheries industry.
J.
Would an accid.ent threaten the fisheries of Humboldt Bay and the Pacific waters?
Q.
The conclusion stated in the licensee's ER (Section 6.3.2.2), that:
Groundwater could be contaminated by the loss of pool water if 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 conservative since the water volume released from the pool would reach an equilibrium with the very high water table in the site soil strata.
is at odds with Section 10.3.2.2 of the ER, which concludes that groundwater flows toward the Bay from the site, and the aquifer is flushed each year by high tides and spring runoff.
This clearly indicates that an exchange of radioactive materials from the site is possible, and perhaps has already occurred. A serious leak would clearly have damaging consequences, both for the contamination of fish and mollusk species found in the Bay, and economically on the financially troubled fishing industry which is an important part of Humboldt County's volatile economy.
Innuendo related to contamination of seafood produces alone would be sufficient to devastate this fragile industry. The DES fails to address this issue, presumably because of the quotation cited above. The FES should contain a full and complete discussion of the site hydrology, representative of the potential for, and consequences of, contamination of the groundwater and Bay waters via the aquifer, as well as a discussion of any past such contamination.
1568H PGandE Resnonse The conclusions drawn in ER section 6.3.2.2 regarding a spent. fuel pool rupture are not at odds with information contained in ER section 10.3.2.2.
Loss of water into the suppression chamber will lower the water level of the pool to below the groundwater level. Water flow at this point would be into the pool rather than out of the pool.
ER section 10.3.2.2 concluded that the aquifer was flushed each year by high flows during winter and spring runoffs reaardless of the effects of tides.
This leads to the conclusion that in spite of the tides, net water flow is into the bay, and the effect of tidal action is, in fact, negligible.
In response to NRC question 72, PGandE provided in our letter of April 3, 1985, (HBL-85-014) a description of the consequences of a rupture of the spent fuel pool on the onsite groundwater, Humboldt Bay, and the nearest offsite potable water supply. This letter indicated that the radionuclides would be well below the 10 CFR 20 limits before they reached the site boundary.
Comment J.
Hould the agriculture land near the plant become contaminated?
EGandE Respanig In the event of a spent fuel pool rupture, contamination of the soil by groundwater transport is toward the ocean / bay. Concentrations of radionuclides in groundwater upon discharge to the bay have been shown to be less than the allowable limits for normal discharges, as specified in 10 CFR 20.
1568M Transport of radionuclides to areas east of the site is not considered credible due to the flow direction of the groundwater. An analysis performed (NRC question #72 response) shows that even if flow were to progress eastward, offsite concentrations of radlonuclides would be within 10 CFR 20 limits.
Thus, it is concluded that agricultural land in the vicinity of the site would not become contaminated due to a spent fuel pool rupture.
Comment K.
Pg. 3-12, PP 3: What is the staff's worst-case release scenario? Why did the staff use the licensee's estimates, instead of independent sources?
PGandE Resoonse The worst case scenario is that discussed in the last paragraph of section 3.2.3.6 of the DES, a release of the entire inventory of the radionuclides in the spent fuel pool water. The results for this scenario show a total population dose below I rem.
The Staff's basis for accepting licensee estimates / data should be justified by the NRC Staff.
Comment K.
PP 4:
"the radionuclides were assumed to remain in Humboldt Bay for 1 year." Why this assumption? Where will they "go" after 1 year is up?
EGandE RespDDIA This assumption is made to ensure conservatism of the analyses performed.
This assumption is conservative because the tidal exchange with the bay is about 44% per tidal cycle.
The buildup of the various radionuclides in both 1568H finfish and shellfish was estimated, and the commercial fish catch data for Humboldt Bay and Northern California were used to estimate the amount of fish consumed. On the basis of these calculatio'., using the methods in RG 1.109, the staff estimated that the population-integrated total body dose resulting from this event would be less than i rem for all cases.
Comment K.
Pg. 3-13:
"Thus an average individual consuming finfish and/or shellfish..." What about the risk to a family which relies mostly on this seafood for its sustenance, as do many fisherfolk in the Bay region?
" Average consumption" is based on general population -- but consumption in a fishing economy, such as Humboldt Bay, would be obviously many degrees higher.
This impact is not adequately addressed in the DES.
PGandE Response The total population-integrated dose for the rupture of the two radwaste tanks was calculated to be less than 0.1 rem. This total dose, if incurred by one person (i.e., the entire annual catch was consumed by one person), would be of the same magnitude as the total background radiation dosa over that sama period. Thus, the conclusions drawn for the average individual consuming i
fish / seafood from Humboldt Bay would also be applicable to members of the region who consume larger portions of the Humboldt Bay annual catch.
Comment C.
Page 3-12, Section 3.2.3.6, spent fuel pool Rupture. This section discusses the consequences of a rupture in the spent fuel pool.
The second paragraph (last sentence) states that the staff considers the PGandE estimates "to be reasonable and conservative for the site." What is the basis for this judgment? The fourth paragraph of this section indicates that for purposes of calculating doses, the radio nuclides were i
assumed to remain in Humboldt Bay for one year.
It is not clear where the staff expected the radionuclides to go after one year.
This should be clarified.
1568H -
PGandE Resoonse The basis for the Staff's judgment that the PGandE analysis is reasonable and conservative for the site must be provided by the Staff.
The basis and conservatisms behind the assumed one year residence time for nuclides in Humboldt Bay are discussed in the response to comment K-42.
As a result of tidal action, radionuclide concentrations will be diluted as contaminated water flows from the bay into the Pacific Ocean.
Comment L.
Pg. vi, (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?
PGandE Response The spent fuel pool water is expected to remain in the liquid state since there is no heat source in the building to cause heatup of the water, nor is there sufficient decay heat from the fuel to cause the same.
Comeat K.
Pg. vi, PP(f):
"very small fractions of the PAG levels." The upper limits of doses could well be much higher if the DES evaluated all the avenues of possible release adequately. Larger-than-expected earthquakes (of which there have been several lately in California); massive flooding due to polar cap melt (predicted by some within the 30-year time frame);
tsunamis from far-away events; terrorist attack; wartime events --
i cumulatively, the risk of disastrous event happening is not minimal, but rather substantially probable. The DES neglects to assess these possibilities -- some at all, other inadequately.
Pg. 3-12, PP 1:
In an earthquake rupture, new rock fractures may increase groundwater velocity, reduce the rate at which radionuclides precipitate out, and cause greater and more rapid flush into the Bay.
This must be analyzed in the DES.
1568H. _. _.. _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _
i PGandE Response The purpose of an ER/ES is to' determine the worst-case effects for reasonable scenarios. Postulation of accidents that are beyond the limits of the design basis accident (e.g., dispersion of the entire inventory of the. spent fuel l
l over the surrounding areas) are not considered credible and have not been addressed.
,i i
j t
i i
e j
1568M 70 -
O
,-mw w.y- - -wv---.--,,
-=-.-r--*w-w--ww-w--r----r-'-wv---
- ,+e++
+ - - - + - - - -
=--w--+---
---~~---v-mm--=r=wm-r e--yw-w'--
---e-
- 19. BORAL DETERIORATION Comment
)
C.
Section 3.2.3, Postulated Accidents, pages 3-7 and 3-9.
The last paragraph of this section indicates that boral neutron absorbing blankets surround each fuel assembly to~ insure subcriticality. Sierra Club understands that there has in the past been some problem with deterioration of the boral plates in high density spent fuel storage racks.
The EIS should discuss this. Has PGandE proposed any surveillance of the program to ensure this material is maintained in a functional condition?
Page 3-10, Section 3.2.3.4, Critically Potential of Stored Fuel.
Sub-paragraph I discusses the neutron absorbing material boral. See comment on this issue on page 3-9.
D.
The FES should contain a complete discussion of past experiences with boral shielding for spent fuel assemblies including effects of the long-term use proposed in the DES.
K.
Pg. 3-9, PP 2: There has been some evidence of deterioration over time of these neutron-absorbing blankets. What surveillance does the licensee propose to monitor this over 30 years?
Q.
There is no discussion of the past experience with boral plate shielding blankets proposed for use in storing the fuel assemblies in Section 3.2.3, Postulated Accidents, PP.3-7 and 3-9.
These may be subject to wear, deterioration and failure. A discussion of the present experience with these plates should be included in the FES, along with a description of the monitoring and inspection program necessary to ensure that they remain in a functional state.
l PGandE Resoonse Boral is a composite of neutron-absorbing boron carbide dispersed in an aluminum alloy matrix which is clad in aluminum alloy.
Its service life is expected to exceed 40 years from a corrosion-resistance viewpoint. This material has the longest continuous, in-pool service of any thermal neutron shielding material.
Boral has been exposed in the Brookhaven Medical Research Reactor coolant for over 19 years, has been in use at Oak Ridge National Laboratory for over 25 years, and is now in use at about 30 BHR and PHR spent fuel pools.
No detectable loss of neutron-absorbing effectiveness has ever been observed.
1568H
There have been two isolated instances of spent fuel rack swelling where Boral was used, i.e., at Monticello and Maine Yankee. At Monticello, Boral was sealed in square stainless steel tubes.
Bulging of some of these tubes was observed prior to shipment of any spent fuel storage modules to the plant and was attributed to an accumulation of hydrogen as a result of residual water on the surface of the Boral reacting with the aluminum cladding. Water-aluminum reactions are self-limiting, because a protective hydrated oxide layer forms on the surface of the aluminum. Therefore, the integrity of the Boral itself was unaffected; only the outer stainless steel tubes deformed. Today, similar racks are vented to avoid any gas buildup. At Maine Yankee, the aluminum cladding of the Boral itself bulged near welded joints due to hydrogen gas buildup from a water-aluminum reaction. Apparently, either some moisture was sealed in during the welding of sheared Boral panels, or pool water possibly entered through pin holes (which subsequently plugged when aluminum oxide formed) in the welds. However, the neutron-absorbing effectiveness of the Boral was not degraded at Maine Yanke's. Also, the fabrication of the HBPP inserts did not involve welding Boral panels together as was done at Maine Yankee.
Although no problems are anticipated with the HBPP Boral inserts, PGandE has, on its own initiative, developed a detailed surveillance program using 25 sample coupons, which will be installed in the spent fuel pool adjacent to spent fuel.
Baseline measurements are being conducted to determine the initial physical properties and boron loading of the samples.
Selected samples will then be periodically removed, inspected, and tested to ensure the continued presence of a strong neutron absorber in the Boral inserts.
1568H 20.
INADVERTENT CRITICALITY Comments C.
Page vi, paragraph 5(e) indicates that there.is a " negligibly small likelihood" that seismic loads or other mechanical loads would generate criticality among the spent fuel assemblies stored in the pool.
This likelihood is not properly quantified and the draft EIS does not say how the NRC is assured that it is " negligibly small."
Page 3-11.
This page has numerous statements that are vague and/or unsubstantiated. For example:
subparagraph (1) states that "this is conservative as even a small amount of burnup will reduce reactivity somewhat"; subparagraph (3) asserts that a local pile of fuel pellets (Iow-enrichment) is "very likely to be undermoderated and subcritical";
next paragraph, "the staff concludes that there is a neolicibly small likelihood" of criticality; last paragraph, "these are all very small fractions of the PAG doses levels." The above statements are judgment factors that are unsupported by the draft EIS.
K.
Pg. vi, PP (e): " negligibly small likelihood" of criticality is excessively vague. Clear evidence must be presented.
Pg. 3-9. PP 2 "to. insure subcriticality after any event...". Is this
" insurance" realistic in the event of a truly major earthquake?
Pg. 3-10, 3.2.3.4:
" Criticality potential of stored spent fuel.."
Cynthia Pollack, author of Worldwatch Paper 69, " Decommissioning:
Nuclear Power's Missing Link," asserts this matter to be "the most severe threat" of all of the dangers posed by SAFSTOR. All of the speculations in this section of the DES are moot in the event of an unusually large earthquake near Humboldt Bay. Most experts are predicting such a quake somewhere in California within the next 20 years.
l Pg. 3-11, PPs 3-7:
" tacit assumption," "very unlikely," " negligibly 1
small" -- These are too vague. The fact is that none can guarantee the i
subcriticality of the stored spent fuel array in the event of an earthquake registering over 8 on the Richter scale.
" Negligibly small likelihood" accidents that have been happening at nuclear plants worldwide. There is too great a seismic risk present at Humboldt Bay to warrant 30 years of high-level waste so close to so many faults.
L.
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 this likelihood in terms of 7.
probability or other equivalent units? In view of the seismic capability t
of the site, does this increase the probability for occurrence? What is
(
the likelihood?
l 1568M. - -
3.2.3.4, Pg. 3-11, Subparagraph 2 - Why are calculations not made for the potentiality 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 of "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?
PGandE Resoonse "The licensee assumed the presence of fresh fuel with no' credit for the presence of gadolinium, a burnable poison. This_is conservative as even a small amount of burnup will reduce reactivity IQn).ewha.t."
Fresh fuel was assumed in the criticality analysis of the stored spent fuel configuration.
Fresh fuel has the highest weight percent of U-235, and reactivity is nearly proportional to U-235 weight percent.
Thus, the consideration of fresh fuel is a conservatism. Also, no credit is taken for fission products and burnable poisons, including gadolinium, all of which reduce reactivity. To rephrase the quoted sentence, as burnup increases, reactivity will always decrease.
i The fuel in the spent fuel racks is currently maintained in a subtritical condition by separation. The geometry of the fuel assemblies results in overmoderation.
In the event of an unspecified seismic event or a heavy load drop into the pool, the bundles might be moved into'a more reactive configuration.
Rather than attempting the impossible task of analyzing every conceivable earthquake scenario and resulting disturbance of the racks, the accident analysis philosophy is to assume the most reactive configuration 1568H -
4 of fuel, moderator, and poison physically possible.
If the most reactive case is subtritical, then, by definition, all others will also be subcritical.
This worst-case analysis is achieved by modeling the bounding optimal moderation case.
Several conservative assumptions were made in the criticality analysis to account for variations and uncertainties in the material properties of the fuel.
The pool contains several different fuel assembly designs containing varying masses and enrichments of uranium. A specific bundle design was chosen that maximizes the uranium loading and enrichment. The manufacturing tolerance on fuel density was added to the nominal density to represent the highest as-built density possible. These assumptions are conservative because reactivity is proportional to both uranium mass and U-235 enrichment in an optimally moderated geometry for low enriched thermal systems.
It is assumed that at beginning of life (cold conditions), all bundles are free of fission products, and burnable poisons (gadol'inium). At beginning of life the U-235 enrichment is maximal. Any exposure reduces the U-235 content, thus reducing reactivity.
Exposure also introduces fission products which increase parasitic capture in the system and activation products such as plutonium. The overall effect of exposure is always to decrease reactivity.
Gadolinium is a burnable poison which is contained in some fuel.
It serves to reduce the fuel assembly reactivity at low exposures. This effect is not considered in the model, so any gadolinium contained in the fuel would result in a lower reactivity than in the case analyzed.
1568M..
No credit is taken for any materials in the rack, fuel channels, or the aluminum in the Boral poison. These materials do not contribute to the fission process, only to increased parasitic capture.
The calculation bounds all geometries by assuming a 2-dimensional infinite array of assemblies which are infinite in the third dimension. This is 1
conservative and bounding because it neglects any loss of ' neutrons due to leakage. Any system that can be accurately modeled in 2 dimensions will have a reactivity greater than or equal to an equivalent 3-dimensional analysis.
The calculation assumes a square pin lattice geometry (parallel rows of fuel pins). Under optimally moderated conditions, this geometry will have a reactivity greater than or equal to any other geometry.
Optimal moderation is obtained by varying the following gaps to maximize K-infinity:
1) the water gap separating fuel assemblies i
2) the inner dimension or distance between poison walls of the box, and 3) the rod pitch, which is allowed to vary within the poisoned area.
Calculations were not made for the potentiality of the rods not remaining in a parallel array because the parallel array at the optimal moderation condition is the most limiting case and has reactivity greater than or equal to any other geometry.
1568M - - - -.
- 21. OCCUPATIONAL RADIATION EXPOSURE Comment C.
Page 3-4 Section 3.2.1, Occupational Radiation Exposure. This Section states that the total occupational exposure for SAFSTOR with delayed DECON will be about 177 person-rems. These totals are based on estimates produced by PGandE. Later in the draft EIS (Table 4.1) it is stated that the SAFSTOR with deferred DECON alternative has the lowest occupational radiation exposure of all alternatives. However, the draft EIS nowhere quantifies the doses for the other alternatives for purposes of comparison.
Section 4, Summary of Decommissioning Alternatives..Page 4-1, third paragraph.
This paragraph states that the DECON decommissioning alternative would result in greater occupational radiation exposure.
This is not quantified at any place in the draft EIS. Similarly, the fifth paragraph states that the occupational radiation exposure would be the lowest for the SAFSTOR alternative and that the volume of radioactive waste is likely to be lower. These two claims are not quantified at any place in the draft EIS.
Page 4-3, Table 4.1 This table provides a comparison of the decommissioning alternatives. These factors should all be quantified.
K.
Page 3-4, PP. 6: What was the basis of. these estimates?
"DECON would result in greater occupational radiation exposures... and more radioactive waste than other alternatives." -- There is no evidence presented in the DES to substantiate this conclusion.
PP 5:
"SAFSTOR... occupational radiation exposures would be the lowest." -- Again, there is no evidence presented in support.
PGandE ResDonse The Draft Environmental Statement's comparison of the radiation exposures resulting from the decommissioning alternatives is a summary and conclusion based on the information contained in the Environmental Report (ER)
(Attachment 6 to the Decommissioning License Amendment Application).
Section 10.7.4, Assessment of Decommissioning Alternatives, contains a comparison of the three decommissioning methods:.DECON, ENTOMB, and SAFSTOR.
A more detailed analysis of the SAFSTOR with delayed DECON option is contained in Section 6.0 of the ER, and an analysis of the immediate DECON option is 1568M - _
contained in ER Section 7.0.
A comparison of these two options is contained in Section 8.0.
Table 8.2 compares the radiation exposures from SAFSTOR (with delayed DECON) and from immediate DECON. As indicated by this table, the radiation exposures associated with the SAFSTOR option are approximately 267.
of the exposures for immediate DECON.
Comment D.
Because the plant has been shut down for over 10 years, the FES should further consider immediate dismantlement. Danger from occupational exposure has been overstated in the DES because many of the shorter-lived isotopes have already decayed away. Additionally, differences in the offsite truck traffic projections for SAFSTOR and DECON have similarly been overstated.
I.
I will call into question your assumptions that the spent fuel rods must remain on site. Since this particular assumption hinges on interpretation of law and policy, I have 2 points to be made:
- 1) Radiation has decomposed to a smaller quantity and is almost as safe to handle and transport. The half life of radioactive iodine 131 is 8.05 days. There has been little-or no activity in the reactor for 9 years, so the levels of this radioisotope should be negligible at this time. As for the radioactive Cobalt, it's half-life (10.6 years), has already been achieved once for the majority of spent fuel.
Isn't this true? If so, then please state how much additional mass would actually be diminished over the thirty year period? What quantity of radiation would be decomposed at this site? It might be helpful if you indicated the actual mass of the spent fuel now and in 30 years.
K.
Page 3-4, PP 3: What will the radiation inventory be in 2000 versus 2015? Versus now?
Q.
The DES contains no discussion of the activation elements present at the plant. Neither is there any discussion of the relative exposure rates of decommissioning in the future as opposed to the present.
While it is clear that occupational exposure would be reduced to some degree as short-lived isotopes decay, this advantage may be significantly overstated because of the presence of high energy emitting activation elements in the steel and concrete of the reactor and containmant, which will last for many hundreds, and in some cases, many thousands of years; and because the plant has been closed for ten years already. Many shorter-lived isotopes have already decayed away, increasing the 1568H __.
proportion of occupational exposure attributable to activation elements.
Data and analysis are needed to estimate the exposures projected for the future, and determine their sources,.as opposed to the sources and exposures which could be expected from immediate dismantlement.
In this way, a more complete comparision and examination of the available alternatives can be conducted, as required by NEPA.
PGandE Resconse The radiation exposure estimates contained in the Environmental Report (ER) were based on actual levels measured in 1984 when the report was prepared.
Host short-lived radionuclides had decayed by that time. ER Tables 10.4.9 and 10.4.10 identify the radionuclides contained in plant areas, and ER Table 4.10 provides a listing of the radionuclide inventory of the spent fuel as of July 1984. As can be seen from Table 4.10, the principal radionuclide in the spent fuel is Cs-137, which has a half life of 30 years.
Figure 10.6.1 from the ER describes how the radionuclide inventory (excluding spent fuel assemblies) will decay with time.
Comment N.
The document fails to explain exactly what the licensee's " radiation protection program" entails.
PGandE Resoonse s
Section 6 of the SAFSTOR Decommissioning License Amendment Application describes in detail the radiation protection program. The information
(;ontained in this section has been supplemented by PGandE's responses to NRC questions 26, 27, 31, 32, 33, 34, 41, and 46, as provided in our letter dated February 28, 1985.
1568M. _ - _ -
Comment-K.
Pg. 1-2, PP 1:
" require a 15-year extension of the license." This is not.true since the Federal Repository is suonosed to be operatonal by 1998, before the current-license expires. Once the. fuel is then removed, the plant should be dismantled.
It will have already sat idle for more than 20 years, long enough for most short-lived radioisotopes to have decayed.**
Can PGandE show that another 15 years will result in additional significant decay, or significant exposure reduction? If not, why the full 30 years?
PGandE Resoonse The 30 year SAFSTOR period was selected to allow for the startup of the federal spent fuel respository and to allow several years for the shipment of the fuel to the repository. In addition, the SAF TOR period will permit decay of the radioactivity at the plant to reduce radiation exposures during the event'ual DECON. Once the fuel is removed from.the site, the facility will continue to be in a stable condition to permit continued decay of radioactivity.
If, following removal of the spent fuel from the. site, PGandE determines it would be prudent to proceed with DECON of the unit, such action can be taken at that time.
Comment K.
Page 3-4 PP 7: There is still much room for debate in the medical community about estimating health effects of radiation exposure. There is no generally accepted threshold under which exposure is " safe."
1 Pg 3-5, PP 4:
"2 chances in 100..." -- When? How does the probability differ between now and 2015.
If the difference is negligible, why wait 30 years?
M.
On page 3-4 it is stated that "the staff used somatic and genetic risk estimators that are based on widely accepted scientific information."
The sources of information are dated 1972, 1975, 1977, and 1980.
I 3
consider this fairly "old" information and question whether there might be newer information that is more accurate and should be used.
j 1568M.,. - _ _
l Page 3-5 contains the statement, "The lower limit of the range would be zero because there may be biological mechanisms that can repair damage caused by radiation at low doses and/or dose rates." I have never heard l
of any evidence that suggests this (in fact, the bulk of evidence suggests the opposite). The FES should either include documentation for this statement or else omit it, as it is extremely misleading.
PGandE Resconse These comments concern the NRC's evaluation of the consequences of the radiation exposures projected for SAFSTOR and as such do not request any additional information that can be suppliled by PGandE.
4 15f8H
1
}
22.
EVACUATION PLANS j
Comment A.
Neither the ER nor the DES describes any existing or proposed evacuation plans to be implemented in the event any of the worst case scenarios presented in the analyses.
The FES should include information regarding evacuation plans.
N.
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.
P.
Currently there is no community contingency plan t'o deal with potential accidents which could leak radiation to the surrounding countryside putting human safety at risk. The D.E.S. lacks the worst case scenarios necessary to establish comprehensive preparedness.
For example:
a.
What would happen if there was an 8.0+ earthquake at high tide followed by a tidal wave?
b.
What would happen if an airplane crashed into Unit No. 3, exploded, and started an uncontrollable fire?
c.
What about this lack of a contingency plan?
PGandE Resoonse Section 3.1 of the Humboldt Bay Power Plant Unit 3 Emergency Plan for SAFSTOR (Revision 0), submitted to the Nuclear Regulatory Commission on April 4,1985, notes that accident classifications of the Alert, Site Area, or General Emergency levels cannot be reached durina any of the accidents costulated for HBPP durina SAFSTOR.
The highest emergency classification capable of being reached at HBPP is Unusual Event. This classification includes events that indicate a potential degradation in the level of safety of the plant. No releases of radioactive materials reauf rina offsite resoonse are exoected.
1568H - -
Under this classification, evacuation would not be considered necessary or prudent. There are no postulated accidents for Humboldt Bay Power Plant that could result in the release of radioactive material to the environment in quantities that would require protective actions for the public.
Comment B.
The DES does not contain any specific information on emergency planning and coordination with the State of California in the unlikely event of an accident.
In our judgment, a section should be.added to Chapter 3 that briefly presents the plans and coordination that would be in place during the 30-year decommissioning period. This action is particularly important at this time in view of the increased concern of the public relating to emergency response and protective actions.
PGandE Resoonse In any emergency action level for Humboldt Bay Power Plant Unit 3, notification of Humboldt County officials is made as soon as practical or within one hour of an Unusual Event declaration, measured from the time at which the Shift Foreman recognizes that events have occurred which make the declaration of an Unusual Event appropriate. Should the County of Humboldt require assistance from the State of California, notification would be made by the County.
The highest emergency classification capable of being reached at HBPP is Unusual event. This classification includes events that indicate a potential degradation in the level of safety of the plant.
No releases of radioactive materials recuirina offsite resoonse are exoected.
Comment J.
Hould the population of 50,000 around the bay have to be evacuated?
Hould U.S.101, our major corridor be usable? -
1568M _
PGandE Response The highest emergency classification capable of being reached at HBPP is Unusual Event.. This classification includes events that indicate a potential l
degradation in the level of safety of the plant. No releases of radioactive materials reauirina offsite resoonse are exoected.
Under this classification, evacuation would not be considered necessary or prudent. There are no postulated accidents for Humboldt Bay Power Plant which could result in the release of radioactive material to-the environment in quantities that would require protective actions for the public. Therefore, there is no necessity for evaluating the surrounding population for potential evacuation.
Likewise, there is no concern that U.S. highway 101, which is outside the plant boundary, would be affected.
1568M._
- 23. HEALTH EFFECTS Comment I.
Page 3-9, Section 3.2.3.2.
Listed in this section are EPA " projected dose levels" of radiation that are acceptable. My question is: Are these levels indicating acceptable working risk levels of community risk levels? There is a substantial distinction to be made here, as the working risk levels can be as much as 1000 times the acceptable community level of exposure. This needs to be clarified because those exposed in the case of an accident may well be the high risk populations (pregnant women, old and young as in item D).
PGandE ResDonse This comment deals with the EPA Protective Action Guide (PAG) levels referred to by the Staff in the DES. The Staff should refer to the definition of the PAG in their response to this question.
In the case of the accident analyses used in the Decommissioning Plan and the Environmental Report, the estimated exposures were for the maximum offsite (i.e. community) exposure.
Comment-I.
The reality of the SAFSTOR alternative is that it leaves the community at a higher risk for a longer period of time, with none of the associated benefits. My specific concern here is for the public elementary school.
located 1/4 mile from Unit 3.
Nowhere is this school mentioned.
In your document you have neglected to identify what members of the populus are at the highest risk.
I submit to you that these students are at the greatest risk in both routine and accidential exposure scenarios.
Their continued vulnerability to the occasional releases of radiation into the atmosphere is a serious concern.
I wish to know what mitigations are offered to minimize the exposure to these children and adults of South Bay Elementary School.
These students are youna enouah to be hiahly vulnerable to the effects of radiation. Here your figures on radiation releases in the worst case scenario, taking into account age / sex / proximity of the students, to the plant? How about in " routine releases" during the SAFSTOR and delayed DECON phases? Please be reminded that the school is due east (down wind) of the power plant.
i 1568M !
I
PGandE Reesconse The radiation releases that may occur during SAFSTOR are insignificant in relation to natural background-radiation levels and, as such, pose no health hazard to the children and adults at the South Bay Elementary School. Maximum offsite radiation levels that could result following an accident are well below the EPA Protective Action Guide levels, which apply to all members of the general public.
Comment 0.
He are already concerned about the children, now adults, exposed to radiation at the Elementary School across from Humboldt Nuke; at they being monitored? If not how many other potential injuries are being ignored and therefore, allowed in the future?
PGandE Response This comment is outside the scope of the DES, which is intended to discuss the potential environmental impacts of the projected action, not to discuss prior operation of the unit. A program to monitor releases of radioactivity during SAFSTOR and an environmental monitoring program are described in the Decommissioning Plan and the Environmental Report.
1568M i
- 24. GENERAL Comment P.
It is imperative that a local public hearing be held on this matter prior to its dispensation.
If for no other reason, a local public hearing is critically important to maintain.the appearance of objectivity in decision making.
PGandE Resoonse At the request of the intervenors, a prehearing conference will be held before the designated Atomic Safety and Licensing Board, who will determine if any of their contentions on the decommissioning of HBPP are valid.
If any contentions are approved, then a public hearing will be scheduled.
Comment K.
Pg. 1-4, last PP:
"only difference" -- This totally ignores the extreme differences the coastal seismic zone at Humboldt presents, in contrast to almost any site further inland!
Then the DES has the audacity to worry about the costs of " seismic considerations of the ISFSI," were it to be sited elsewhere!
PGandE Response The discussion of the various alternatives is intended to describe the differences in activities among them. The costs associated with the ISFSI alternative are not only financial but also radiological.
Comment K.
Pg. 1-5, PP 1:
"it would have greater environmental impact than onsite fuel storage." -- Not if there's a release of radioactivity caused by seismic movement at the proposed site!
Last PP:
"not proceeding with a decommissioning plan could introduce uncertainty... eventually the residual radioactivity would have to be removed.." -- By the same logic, SAFSTOR provides more uncertainty than DECON, and leaves residual radioactivity for a longer time. This was not addressed in evaluating the earlier alternatives.
1568H -__
N.
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."
PGandE Response Analyses of postulated radiological releases, including those from seismic events, have shown that dose levels would be less than those proposed by the EPA to warrant protective actiors. However, using an independent spent fuel storage installation would create additional environmental impacts resulting from transportation of the fuel to that facility. Also, additional environmental impacts could be introduced by a no-action plan since the precautions outlined in the SAFSTOR plan to minimize and mitigate radiological releases would not be performed. The DECON alternative can be performed only after the spent fuel is removed from the site. This activity is not feasible until a federal repository is made available.
Comment C.
No consideration is given to the possibility of decontamination and removal (now) of those portions of the plant that are not necessary for the continued safe storage of the spent fuel.
H.
It is stated on page 2-6 that "near the end of the SAFSTOR phase, the licensee will submit the DECON plan for staff review and approval." I feel strongly that the time to make a dismantling plan is ns.
It should be made by the people who built and operated the plant because they are the ones who are familiar with it. Thirty years from now they will all be dead, and the people who plan the dismantling will have to rely entirely on written records which can't possibly contain the information that these workers have. A plan should be developed and submitted now; it can always be amended later when information on how to dismantle a nuclear reactor is actually developed.
P.
There is no guarantee in the D.E.S. that SAFSTOR is " safe" nor that the utility will actually be any better prepared in 30 years than it is now to DECON.
There is no time ceiling set for SAFSTOR, hence it is conceivable that the utility will simply extend for another 30 years, etc.
1568M -
Further, in 30 years there will be many more reactors shut down most of which will be much larger than Humboldt Bay and hence proportionately i
greater potential problems'that will dwarf Humboldt Bay Unit No. 3 in relative significance.
I can see this circumstance as creating a rationale to lower the priority to DECON our SAFSTOR unit in order to channel funds and personnel to cope with larger problems elsewhere.
i DECON now is clearly in the Humboldt community's best interest.
In 30 years it is unlikely that anyone will be alive that had worked at i
the Humboldt Bay Plant when it was in operation.
The D.E.S. does not i
discuss the fact that there will be no one familiar with those t
idiosyncratic elements inherent in all systems.
The time to DECON is now-while there are trained personnel on hand that are intimately familiar with the facility and its weak and strong aspects.
PGandE Resoonse The Decommissioning License Amendment Application details the activities that
~
I will be performed as preparation for SAFSTOR (Attachment 4) as well as the disposition of.the various plant systems and components during SAFSTOR (Attachment 6. Section 10.1).
The Decommissioning License Amendment Application also contains a discussion 4
of the preliminary Dismantlement Plan (DECON), which will form the basis for 4
further activities in preparation for and accomplishment of the final decommissioning. The commitment to have all historical documentation and data j
available to develop a detailed. site characterization (both physical and radiological) for preparation of DECON decommissioning is found in Section 2 of Attachment 5 of the Decommissioning License Amendment Application. A detailed scope of work for DECON will provide guidance regarding the technical i
approach to major evolutions. Currently, determination of technical approaches is inappropriate, since technology will change over the next 30 1
years. The final conditions, except for removal of radioactive materials above releasable levels, cannot be established at this time. Use of the site 4
4 1568M.
_J.---__-.
,._,__,--..,,m,_.-_.,--,,,m., _ _ _ _ _ _ _ _
_...,.._-__--___._.,.--4,m
,_..~..,___._,y.
after the 30-year SAFSTOR period will depend on many factors undetermined.
Therefore, preparation of the detailed scope of work will be deferred and become an initial effort during the DECON decommissioning planning and preparation program established prior to dismantling.
Comment I.
Please insert a diagram of the racks used to hold the spent fuel rods.
Those of us who don't have ready access to the design of the structure can better evaluate their effectiveness, in this way.
PGandE Response Diagrams of the spent fuel pool storage area and other major areas are shown in Section 10.1 of the Environmental Report to the Decommissioning License Amendment Application. Also, a diagram of the spent fuel racks is shown in Appendix B to the PGandE answer to NRC question 84 in the document entitled "SAFSTOR Decommissioning Responses to NRC Questions." The License Amendment Application, along with other docketed' material, is available in the Public Document Room.
Comment N.
The title of the draft document misleads the reader by failing to mention that Unit No. 3 is a nuclear reactor.
PGandE Response The fact that Humboldt Bay Unit 3 is a nuclear reactor is inherent on the title page since the Nuclear Regulatory Commission is listed as the preparer of the draft document.
It could be considered by the NRC to identify Humboldt Bay Unit 3 as a nuclear power plant on the title page of the FES.
l 1568H ____
Comment C.
No schedule is stated for the proposed actions (listed in DES Section 2.2).
D.
The DES contains no schedule for completion of proposed actions.
L.
2.2 - Why is a time frame not specified for completion of the tasks indicated under this paragraph?
Q.
The DES contains no schedule for the proposed actions.
PGandE Response The purpose of the DES is to review and evaluate, pursuant to federal regulations, the environmental impacts of the licensee's plan to decommission its nuclear facility.
Schedular information is contained in the Decommissioning Plan.
The proposed schedule is contingent upon when the license amendment for decommissioning is approved.
Comment
- Q.
As the discussion of alternatives to SAFSTOR are inadequately presented, so is any discussion of the relative costs of any alternatives to the proposed action. The absence of this information hampers an effective analysis of the feasibility of all alternatives, relative to each other or alone.
K.
Par. 1.3.3 "The licensee selected the SAFSTOR alternative for three reasons:
(1)
It is the most cost-effective of alternatives available while there is no Federal repository for spent fuel."
"the most cost-effective of alternatives" -- where is the data?
PGandE Resoonse Section 4.3.2, " Cost Estimates and Financing," in the Decommissioning License Amendment Application discusses the costs as well as the financial plan for the decommissioning activities. SAFSTOR cost estimates were based on experience in performing 1568M -
similar activities at Humboldt Bay Unit 3; DECON costs were based on a decommissioning and decontamination study performed for Unit 3 in 1981 by Gibbs and Hill, Inc. and Nuclear Energy Services, Inc.
Comment N.
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.
PGandE Response The purpose of the DES is to review and evaluate the licensee's proposal to decommission its nuclear facility.
In evaluating this proposal, the staff has used NRC-approved guidelines on decommissioning, as shown in Section 6
" References," as well as other appropriate guidelines.
These decommissioning guidelines are used along with other appropriate guidelines to form the basis for evaluation of decommissioning plans generically. The licensee's Decommissioning License Amendment Application references other nuclear facilities that have been decommissioned in a similar manner (esp. Attachment 6, Section 10.5).
Comment N.
The " Decommissioning Plan" (Section 2.2), the document fails to explain what the plan actually does.
PGandE Resoonse The Decommissioning Plan, as outlined in Section 2.2, describes the types of activities that will take place in order to eventually dismantle the Humboldt Bay nuclear power plant.
1568H._
1 Comment N.
The abbreviated title " Draft Environmental Statement" does not comply with the National Environmental Policy Act (NEPA), and the Council on Environmental Quality (CEQ) regulations which require the preparation of an Environmental Impact Statement.
Q.
Comments and concerns offered by the public in the scoping session have not been considered.
No compilation or analysis of them is included in the DES. Many comments were offered by members of the public and elected officials at the scoping session. The customary response of the agency to these points of concern is notably absent from the DES.
The FES should contain a listing of the comments and a general response to each major area of concern, as reflected in an analysis of alternatives and information relative to their consideration.
The DES, by stating that SAFSTOR is the " sole viable alternative for spent fu91 storage," indicates that a decision has alread" been arrived at by the NRC concerning the decommissioning policy--renuering the ES process a farce and reducing the document to an instrument for justifying the decision rather than a tool for obtaining information and providing options for a decision as required by NEF.i.
To fulfill its purpose as an EIS the DES must consider all impacts--direct, indirect, and cumulative; must be based on accurate, high quality scientific information and analysis; and must discuss all reasonable alternatives to the proposed action.(Andrus v. Sierra Club, 422 U.S. 347 (1979); Flint Ridae Develooment Co. v. Scenic Rivers Association of Oklahoma, 690 U.S. 776 (1976); California v. Block, 690 F. 2nd 753 (9th Cir.1982).
Its purpose under the law is as a nrg-decisional document to provide the administering agency with the information it needs to make an environmentally informed decision "rather than justifying decisions already made." [40 CFR Part 1502.2(g)].
PGandE Resoonse The Staff prepares its environmental impact statements in accordance with the requirements of Title 10 of the Code of Federal Regulations Part 51, which implements the direction of the National Environmental Policy Act (NEPA) and regulations of the Council on Environmental Quality. The process of preparing the environmental impact statement is twofold: a Draft Environmental Statement (DES) is first prepared, stating the Commission's position, and then a Final Environmental Statement (FES) is prepared with the Commission's final findings and conclusions.
1568M. -
The purpose of the DES is to review and evaluate the licensee's plan for decommissioning its nuclear facility. The bases used for these evaluations are shown in the References section of the DES.
The DES assesses the various impacts associated with the SAFSTOR option for decommissioning as well as other decommissioning options (pp. 1-2 ff.)
In accordance with federal regulations, impacts are discussed in proportion to their significance. After completing its review, the Staff normally develops conclusions in accordance with NRC guidelines on preparing environmental statements.
In this instance, one of the conclusions rendered was, " Storing the spent fuel assemblies at Humboldt Bay is the sole viable alternative for spent fuel storage at this j;1mg." These findings and conclusions cited in the Final Environment Statement, which takes into account public and other government agency comments on the DES, will be used as the basis, along with the Staff's Safety Evaluation Report, for the NRC to issue an amendment for decommissioning.
Comme 0.t D.
The FES should contain the basis for all conclusions reached in it and should avoid using expressions like " negligibly small," "very likely,"
and " negligibly small likelihood" used to back up a position without quantifying the possibilities.
K.
Para.1.3.3 "The Commission has made a generic determination that for at least 30 years beyond the expiration or reactor' operating licenses no significant environmental impacts will result from the storage of spent fuel in reactor facility storage pools or independent spent fuel storage installations located at reactor or away-from-reactor sites" (49 FR 34658).
" generic determination" -- strongly suspect; see above.
P.
The D.E.S. document itself is, in my view, poorly prepared with insufficient specific data basis for arrived at conclusions.
There is too much reliance on unidentified " staff" " generic estimates" which are not based upon current site specific study, testing or analysis.
1568H _. - - _ - _ - _
I do not feel secure with the safety of my community being assured on the basis of " generic risk estimates."
Q.
Throughout the DES the NRC uses such expressions as " negligibly small,"
"very likely,"" negligibly small likelihood," and "very small fractions (see especially p. 3-11)."
These terms are used to disregard other alternatives to the proposed action or to discount the possibility of or ramifications to consequences resulting from the proposed action.
These terms are judgement factors which are unsubstantiated and too vague.
The FES should contain the basis for all conclusions reached in it.
PGandE Resoonse The Staff prepared the DES in accordance with its guidelines, listed in Section 6, " References," which entail providing the bases upon which conclusions have been determined. Generic bases that have been approved by the NRC and have been included in the federal regulations were used to form conclusions for the appropriate issues. The qualifiers " negligibly small,"
"very likely," etc. were used in staff evaluations when it was difficult to develop a quantifiable answer.
The qualifiers will be described more specifically in the FES.
l l
I l
1568H,