ML20214A564

Final Environmental Statement for Decommissioning Humboldt Bay Power Plant,Unit 3.Docket No. 50-133.(Pacific Gas and Electric Company)

ML20214A564
Person / Time
Site:	Humboldt Bay
Issue date:	04/30/1987
From:	Office of Nuclear Reactor Regulation
To:
References
NUREG-1166, NUDOCS 8705190499
Download: ML20214A564 (164)

Text

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NUREG-1166 1

Final Environmental Statement for decommissioning

' Humboldt Bay Power Plant, Unit I\ o. 3 '

Docket No. 50-133 Pacific Gas and Electric Company 4

U.S. Nuclear Regulatory

, Commission Office of Nuclear Reactor Regulation j April 1987 q

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l NOTICE Availability of Reference Materials Cited in NRC Publications Most documents cited in NRC publications will be available from one of the following sources:

1 The NRC Public Document Room,1717 H Street, N.W.

Washington, DC 20555

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l NUREG-1166 Final Environmental Statement for decommissioning Humboldt Bay Power Plant, Unit No. 3 Docket No. 50-133 Pacific Gas and Electric Company U.S. Nuclear Regulatory Commission Office of Nuclear Reactor Regulation April 1987 I

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ABSTRACT This Final Environmental Statement (FES) contains the assessment of the envi- l ronmental impact associated with decommissioning the Humboldt Bay Power Plant, Unit No. 3 This California. located FES4ismiles southwest prepared pursuantof to the city the of Eureka, National in Humboldt Environmental County, l Policy Act of 1969 (NEPA) and Title 10 of the Code of Federal Regulations, Part 51, as amended, of the Nuclear Regulatory Commission regulations. The proposed decom-missioning would involve safe storage of the facility for about 30 years, after which the residual radioactivity would be removed so that the facility would be at levels of radioactivity acceptable for release of the facility to unre-stricted access.

This FES has been prepared by the NRC Office of Nuclear Reactor Regulation.

Section 9 provides the staff's responses to comments on the Draft Environmental Statement (DES) (published in April 1986) from Federal, State, and local agencies; from interested organizations; and from members of the public. Re-visions to the DES, where needed, are discussed in the staff's responses (Sec-tion 9). Also, subsequent to publication of the DES, the consequences of postulated accidents were re-evaluated and FES Sections 3.2.3.2 and 3.2.3.3 have been revised accordingly.

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SUMMARY

AND CONCLUSIONS This Final Environmental Statement (FES) was prepared by the U.S. Nuclear h l Regulatory Commission, Office of Nuclear Reactor Regulation (hereinafter referred to as the staff).

(1) This action is administrative.

(2) The proposed action is to approve plans by Pacific Gas and Electric Company j (the licensee) to decommission the Humboldt Bay Power Plant, Unit No. 3.

The proposed decommissioning would involve safe storage of tho facility for about 30 years, after which the residual radioactivity would be re-moved so that the facility would be at levels of radioactivity acceptable for its release to unrestricted access. The spent fuel would remain on i site in the spent fuel storage pool until a Federal repository is available to receive it.

i (3) Humboldt Bay Unit 3, a 65-MW electric boiling water reactor, operated commercially from August 1963 until July 1976, at which time it was shut

, down for seismic modifications. In 1983, the licensee concluded that the

! seismic requirements and the requirements imposed on reactor licensees as a result of the accident at Three Mile Island Unit 2 made continued opera-tion too costly to consider and, therefore, decided to decommission the plant.

(4) This FES assesses the various impacts associated with the SAFSTOR option l for decommissioning, as proposed by the licensee. It also assesses other decommissioning options as discussed in Section 1.3. The information in i this FES is an assessment of the environmental impact of decommissioning l

! Humboldt Bay Unit 3 pursuant to guidelines of the National Environmental

Policy Act of 1969 (NEPA) and 10 CFR Part 51 of the Commission's regulations.

! (5) The staff has reviewed the potential impacts, both beneficial and adverse, i of the proposed decommissioning plan. The staff's conclusions are summarized as follows:

(a) Storing the spent fuel assemblies at Humboldt Bay Unit 3 has mini-mal environmental impact. Other alternatives for spent fuel storage are not available at this time and have no significant environmental advantage. 10 CFR Part 51.23(a) states that the Commission has made a generic determination that for at least 30 years beyond the expira-tion of reactor operating licenses, no significant environmental impacts will result from the storage of spent fuel in reactor facility storage pools.

(b) The licensee has established a radiation protection program that will maintain radiation exposures within the applicable limits of 10 CFR l Part 20 and will maintain exposures ALARA (as low as reasonably l achievable) in accordance with NUREG-0800 and Regulatory Guide 8.8.

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(c) A fuel handling accident would result in atmospheric radionuclide releases that are well below EPA Protective Action Guide (PAG) levels.

(d) Damage to all the stored fuel assemblies resulting from a non-mechanistic heavy load drop would result in atmospheric radionuclide releases that also are well below the PAG levels.

(e) There is a negligibly small likelihood that seismic loads or other mechanical loads would generate criticality among the spent fuel l assemblies stored in the pool. i (f) The upper limits of potential lung, liver, and bone doses resulting from an instantaneous expulsion to the atmosphere of the entire water /radionuclide content of the spent fuel pool are very small fractions of the PAG 1evels.

(g) A rupture of the spent fuel pool or the liquid radwaste tanks would result in a total body dose to an average individual via the seafood chain that would be less than the dose from natural background levels.

Doses resulting from water recreational activities in Humboldt Bay would be negligible.

(h) As a result of its analysis and review of potential environmental, technical, and societal impacts, the staff has determined that Humboldt Bay Unit 3 can be placed in SAFSTOR for a 30 year period with minimal environmental impact.

(6) A DES was made available to the public, to the Environmental Protection Agency, and to other Federal, State and local agencies in April 1986 as specified in Section 8.

l (7) The personnel who participated in the preparation of this FES and their areas of responsibility are identified in Section 7.

l (8) On the basis of the analyses and evaluations set forth in this FES, it is concluded that the action called for under NEPA and 10 CFR Part 51 is the issuance of an amendment to authorize Humboldt Bay Unit 3 to be decom-missioned in the SAFSTOR mode as proposed by the licensee.

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l l TABLE OF CONTENTS Page ABSTRACT......................................................... iii

SUMMARY

AND CONCLUSIONS.......................................... v 1 INTRODUCTION ................................................. 1-1 1.1 Background .............................................. 1-1 1.2 Proposed Action ......................................... 1-2

1. 3 Decommissioning Alternatives ............................ 1-2 1.3.1 DECON ............................................ 1-2 1.3.2 ENT0MB ........................................... 1-2 1.3.3 SAFSTOR .......................................... 1-3 1.3.4 No Action......................................... 1-5 2 DESCRIPTION OF PLANT AND PROPOSED DECOMMISSIONING PLAN ....... 2-1 2.1 Itumboldt Bay Power Plant, Unit No. 3 .................... 2-1 2.2 Decommissioning Plan .................................... 2-5 3 ENVIRONMENTAL IMPACTS ........................................ 3-1 3.1 Assessment of Nonradiological Impacts of Decommissioning 3-1 3.1.1 Sociotconomic and Cultural Resources ............. 3-1 3.1.2 Hydrology ........................................ 3-1 3.1.3 Aquatic Resources ................................ 3-1 3.1.4 Terrestrial Resources ............................ 3-2 3.1.5 Endangered and Threatened Species ................ 3-2 3.1. 6 Land Use .......................... .............. 3-2 3.1.7 Water Use ........................................ 3-3 3.1.8 Unavoidable Environmental Impacts................. 3-3 3.1.9 Local Short-Term Uses versus Long-Term Productivity...................................... 3-3 3.1.10 Irreversible and Irretrievable Commitments of Resources......................................... 3-3 3.2 Assessment of Radiological Impacts of Decommissioning.... 3-3 3.2.1 Occupational Radiation Exposure . . . . . . . . . . . . . . . . . . 3-4 3.2.2 Radioactive Waste Management Systems ............. 3-6 3.2.3 Postulated Accidents ............................. 3-7 3.2.3.1 Evaluation .............................. 3-8 3.2.3.2 Fuel Handling Accident .................. 3-8 Humboldt Bay Unit 3 FES vii

TABLE OF CONTENTS (Continued)

P_ age 3.2.3.3 Fuel Assembly Damage Caused by Non-Mechanistic Heavy Load Drop or Site-Related Hazards .................... 3-10 3.2.3.4 Criticality Potential of Stored Spent 1 i

Fuel Rearranged as a Result of Seismic or Other Mechanical Loads . . . . . . . . . . . . . . . 3-10 3.2.3.5 Non-Mechanistic Expulsion of Pool Water 1 and Radionuclide Contaminants to the I Atmosphere .............................. 3-11 l 3.2.3.6 Spent Fuel Pool Rupture ................. 3-12 3.2.3,7 Uncontrolled Release of Radwaste Tank l Contents ................................ 3-13 4

SUMMARY

OF DECOMMISSIONING ALTERNATIVES....................... 4-1 5 CONCLUSIONS .................................................. 5-1 6 REFERENCES ................................................... 6-1 7 CONTRIBUTORS ................................................. 7-1 8 LIST OF AGENCIES AND ORGANIZATIONS TO WHOM COPIES OF THE DRAFT ENVIRONMENTAL STATEMENT WERE SENT................... 8-1 9 STAFF RESPONSES TO COMMENTS ON THE DRAFT ENVIRONMENTA STATEMENT............................................L ......... 9-1 APPENDICES APPENDIX A CULTURAL RESOURCES: LETTER FROM STATE HISTORIC PRESERVATION OFFICER APPENDIX B EXAMPLES OF SITE-SPECIFIC DOSE ASSESSMENT CALCULATIONS l APPENDIX C COMMENTS ON THE DRAFT ENVIRONMENTAL STATEMENT Humboldt Bay Unit 3 FES viii i

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1 INTRODUCTION 1.1 Background l Humboldt Bay Power Plant, Unit No. 3 (a nuclear power plant) received a con- l struction permit on October 17, 1960. Provisional Operating License DPR-7 was issued in August 1962 and commercial operation began in August 1963. On July 2, 1976, Unit 3 was shut down for refueling and seismic modifications. In 1983, the licensee (Pacific Gas and Electric Company) concluded that the seismic and TMI modifications

• required for restart were uneconomical and decided to decom-mission the plant.

By letter dated July 30, 1984 (Schuyler, 1984), the licensee proposed (1) to amend License DPR-7 to possess-but-not-operate status; (2) to delete certain license conditions related to seismic modifications required before the NRC would authorize a return to power operation; (3) to revise the Technical Specifications to reflect the possess-but-not-operate status; (4) to decommis-sion Humboldt Bay Unit 3 in accordance with the plan included with the submittal; and (5) to extend License DPR-7 for 15 additional years to November 9, 2015 to be consistent with the decommissioning plan.

In response, the staff issued License Amendment 19 on July 16, 1985 (NRC, 1985)

, revising License DPR-7 to possess-but-not-operate status (Item 1 above). Those items that are a necessary part of the decommissioning plan have been evaluated l in conjunction with the issuance of the Safety Evaluation Report and Final Environ-mental Statement (FES). All these actions will adhere with the prin- l ciple of keeping occupational radiation exposures as low as reasonably achiev-able (ALARA).

To support the license amendment request, the licensee submitted an Environmen-tal Report (Schuyler, 1984). In response, the staff prepared a Draft ** Environ- l mental Statement (DES) as required by Title 10 of the Code of Federal Regulations Part 51.20(b)(5) (10 CFR 51.20(b)(5)), " Criteria for and Identification of Li-censing and Regulatory Actions Requiring Environmental Impact Statements." Hav-ing received and considered comments on the DES, the staff is issuing this Final Environmental Statement (FES).

The Notice of Intent (NOI) for the DES was published in the Federal Register (Vol 49 No. 213, November 1, 1984). In accordance with 10 CFR 51.26, a public scoping meeting was held in Eureka, California, on December 4,1984 (Zwolinski, 1984). The DES considered the issues raised by comments on the DES scope re- l ceived in response to the NOI and the public scoping meeting.

• Modifications necessary to comply with requirements imposed after the accident at Three Mile Island (TMI) Unit 2.

• • A bar has been drawn in the outer margin to mark lines in this FES that differ from the DES. Minor editorial changes, such as punctuation and capitalization changes, that do not alter the substance of the text, have not been noted with a change bar.

Humboldt Bay Unit 3 FES 1-1

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This FES addresses the occupational, public health, and environmental impacts of the licensee's proposal to decommission the unit by the safe storage (SAFSTOR) mode for 30 years, followed by removal of residual radioactivity.

l The proposed 30 year SAFSTOR period would require a 15 year extension of the i

license to allow a full 30 years of storage because the present expiration date l of the license is November 9, 2000. This FES evaluates the-SAFSTOR option; there-fore, it also evaluates the proposed 15 year extension of the license.

1.2 Proposed Action The proposed action would permit safe storage (SAFSTOR) of Humboldt Bay Unit 3 and delayed dismantling of the unit after a 30 year safe storage period (DELAYED DECON). This action is needed to provide for safe control of the residual radio-activity to ensure the protection of the health and safety of the public and the environment until the radioactivity is removed from the site. The spent l fuel pool will store 390 used fuel assemblies and 54 in-core fission chambers until the Department of Energy (D0E) has a permanent Federal repository for spent fuel.

The licensee has provided a preliminary dismantling plan (Schuyler, 1984) that will be the basis for the final dismantling plan. The final plan, which will support the application for termination of the unit's license, will be provided near the end of the 30 year SAFSTOR period.

1. 3 Decommissioning Alternatives The purpose of decommissioning a nuclear facility is to take the facility safely from service and to remove the associated radioactivity effectively from the environment so that the facility can be released for unrestricted use. A licensee can propose to decommission a nuclear power plant using one of three methods: DECON, ENTOMB, or SAFSTOR.

Each of these is addressed below, as well as the no-action alternative.

1.3.1 DECON In the DECON method, equipment, structures, and those portions of the facility containing radioactive contaminants are removed or decontaminated to a level that permits the property to be released for unrestricted use shortly after operations stop. This alternative is not presently feasible for Humboldt Bay Unit 3 because spent fuel assemblies will be stored on the site until a perma-nent Federal repository is ready to receive them. A Federal repository is not likely to be ready to receive spent fuel before 2003 (U.S. Deaprtment of Energy, 1987). After a 30 year custodial safe storage period (SAFSTOR), Humboldt Bay Unit 3 will be dismantled and the site will be decontaminated and released for unrestricted use (delayed DECON).

1. 3. 2 ENTOMB

The ENT0MB alternative involves encasing radioactive contaminants in a struc-turally long-lived material, such as concrete. The entombed structure is appro-priately maintained, and there is continued surveillance until the radioactivity 1

is removed from the site or decays to a level that permits unrestricted use of Humboldt Bay Unit 3 FES 1-2

l the property. Long-lived radionuclides such as niobium-94 are likely to be present in the reactor vessel so that waiting for decay would be impractical.

For entombment in some cases, there may be no need for a full-time onsite security guard force and less radiation monitoring and environment surveillance would be required because all radioactive material is contained within the entombment barrier. However, in this case, because the spent fuel will remain on the site until a Federal repository is ready to accept the spent fuel, a full-time security force and adequate radiation monitoring and environmental surveillance would be required. Thus, the need for these spent fuel storage safety provisions and the presence of long-lived radionuclides makes it imprac-tical to entomb Humboldt Bay Unit 3. The entombment structure may also fail as a result of seismic events with a potential for a release of radioactivity.

Entombment is not, therefore, a reasonable decommissioning alternative.

1.3.3 SAFSTOR The SAFSTOR alternative involves placing a nuclear facility in a safe condition and maintaining it in that state until it is dismantled and all remaining radio-active materials that would restrict use are removed. The facility may be left intact except that all fuel assemblies should be removed from the reactor and radioactive fluids and wastes should be removed from the site.

The licensee selected the SAFSTOR alternative because:

(1) It is the most cost effective of alternatives available while there is no Federal repository for spent fuel.

(2) It allows radionuclide decay over t%, so that when final dismantling takes place, occupational radiation exposures are reduced.

Use of SAFSTOR would include the storage of the spent fuel assemblies at the Humboldt Bay Unit 3 spent fuel storage pool. 10 CFR 51.23(a) states: "The Commission has made a generic determination that for at least 30 years beyond the expiration of 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). Moreover, storing spent fuel assemblies at Humboldt Bay for the 30 year 3AFSTOR period is safer and more cost effective than other alternatives, when handling and transshipment operations are considered. Seismic considerations for this requested alternative are discussed in Sections 3.2.3.4 and 3.2.3.5.

Other alternatives for spent fuel that were evaluated but were found to be not effective are (1) Ship spent fuel to Diablo Canyon and dismantle (DECON) or SAFSTOR Humboldt Bay Unit 3.

(2) Ship spent fuel to a Federal interim storage facility and dismantle (DECON) or SAFSTOR Humboldt Bay Unit 3.

(3) Ship spent fuel to a reprocessing facility and dismantle (DECON) or SAFSTOR  !

Humboldt Bay Unit 3.

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(4) Construct an independent spent fuel storage installation (ISFSI) at a site away from Humboldt Br" 'Init 3 and dismantle (DECON) or SAFSTOR Humboldt Bay Unit 3.

The first alternative, to transship spent fuel to the Diablo Canyon spent fuel facility, would provide only short-term storage of Humboldt Bay Unit 3 fuel assemblies. Use of this alternative also adversely affects the availability of extended spent fuel storage to meet the needs of Diablo Canyon. This alter-native would require a separate licensing action, and there is some uncertainty about the availability and timely implementation of this alternative. In addi-tion, the-licensee made a commitment at an NRC Atomic Safety and Licensing; Board hearing that the Diablo Canyon spent fuel storage pool will only be used to store fuel assemblies from Diablo Canyon Units 1 and 2. Thus, this alternative is not available.

The second alternative is the shipment of the Humboldt Bay Unit 3 spent fuel ~to a Federal interim storage (FIS) facility. Under the Nuclear Waste Policy Act~

of 198? (NWPA), the Federal Government has the responsibility to provide not more than 1900 metric tons of capacity for the interim storage of spent fuel.

The impacts of storing spent fuel at an FIS facility fall within those already assessed by the NRC in NUREG-0575 (August 1979). In passing the NWPA, Congress determined that the owners and operators of nuclear power stations have the primary responsibility for providing interim storage of spent nuclear fuel.

i In accordance with the NWPA, shipping spent fuel to an FIS facility is a last-i resort alternative. Therefore, as long as the licensee can pursue licensable alternatives that can be reasonably available in a timely manner, this alterna-tive is not considered pertinent.

The third alternative is to ship the spent fuel to a reprocessing facility.

However, reprocessing the Humboldt Bay Unit 3 spent fuel is not a viable alter-native because there is no operating commercial reprocessing facility in the United States, nor is there the prospect for one in the foreseeable future.

The fourth alternative is to construct an independent spent fuel storage in-sta11ation (ISFSI) at a site away from Humboldt Bay Unit 3.

a dry type or a pool type. The only difference between this The ISFSI could be alternative and storage at Humboldt Bay would be that an ISFSI away from the reactor site would

' require offsite shipment of spent fuel and construction of a fuel handling facility. Thus, this alternative would be more costly than SAFSTOR, would have the additional environmental impacts associated with offsite transportation of spent fuel, and would require seismic considerations of the ISFSI. 10 CFR Part 51.52 establishes the conditions for offsite transportation of fuel and radioactive wastes. The staff has generically assessed the impacts for this alternative and found that storing light-water-reactor spent fuel in pools has an insignificant impact on the environment and that dry storage appears to be environmentally acceptable (NUREG-0575). However, there is some doubt about the availability of alternative sites and the time it would take to construct an ISFSI (about 5 years). Also, the alternative of constructing an offsite ISFSI would require handling and shipping the fuel twice with more exposure to i workers and an increased potential for accidental releases during the handling and shipment.

Humboldt Bay Unit 3 FES 1-4

1.3.4 No Action The licensee has determined that the facility will not be operated again because of the high cost of modifications nce.Jad to meet NRC safety rcquirements for operation.

With the facility permanently shut down, the alternative of not proceeding with a decommissioning plan could introduce uncertainty about the types of actions needed to ensure protection of the health and safety of the public and the envi-ronment. Although the licensee currently holds a possession-only license, the facility Technical Specifications have not been revised to reflect the SAFSTOR status. Thus, with no action, there could be a greater potential for release of radioactive material from systems and tanks containing contaminated water as a result of system deterioration or a seismic event. The decommissioning plan ensures that contaminated water is removed from these cystems and tanks, except for the spent fuel pool and the associated radwaste system. Eventually the resi-dual radioactivity would have to be removed and, if no advance plans or prepara-tions for this were made, the costs in dollars and the potential exposures to the workers and the public would likely be higher.

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l 2 DESCRIPTION OF PLANT AND PROPOSED DECOMMISSIONING PLAN 2.1 Humboldt Bay Power Plant, Unit No. 3 l Humboldt Bay Power Plant Unit 3 is a natural circulation 65-MWe boiling-water

reactor that was operated by Pacific Gas and Electric Company (PG&E, 1961). <

! The plant is located about 6.4 km (4 miles) southwest of the city of Eureka, ,

) in Humboldt County, California. The plant was operated commercially for the '

production of electrical energy from August 1963 to July 1976 under License DPR-7.

The site plan is shown in Figure 2.1. Humboldt Bay Unit 3 is located alongside i two fossil-fueled power plants (Humboldt Bay Units 1 and 2). Two gas turbine units are designated mobile emergency power plants. The plant structures and equipment are shown in Figures 2.2 and 2.3. The reactor primary containment,

, located below grade, consists of the drywell vessel, which contains the reactor, and the suppression chamber. The drywell and suppression chamber are located inside a concrete caisson. The refueling building encloses the space above the caisson. The refueling building contains the spent fuel storaga pool and the new fuel storage vault in addition to the reactor caisson. Next to the refuel-ing building are the power building and turbine pedestal. The power building contains the condenser, feedwater and condensate systems, steam cycle auxiliary

systems, and the control room. The turbine generator is located on the turbine l pedestal. Liquid and solid wastes are processed in the radwaste treatment j facilities.

' The fuel was removed from the reactor early in 1984. At the present time the spent fuel pool contains 390 spent fuel assemblies and 54 in-core fission cham- l l bers. These units will remain in storage until the U.S. Department of Energy I (00E) has a repository ready to receive them. The fuel fission product inven- '

1 tory is approximately 1.1 x 106 curies (as of July 1985). A cover (a contami-

! nation control barrier) will be installed over the spent fuel pool to mitigate

the spread of small amounts of contamination that may be released from the pool 1

and to provide protection against objects dropping into the pool. The pool contamination control barrier will be tied into a radiation-monitored ventila-tion system. i j The inventory of activation products in the plant is about 1.0 x 104 curies (as

! of July 1985). Approximately 67 curies (July 1985) on contaminated surfaces are also within the plant inventory. During initial operation of the plant i (March 1966), spent fuel pool leakage was detected. Although this leakage was i attenuated by the installation of a stainless steel liner, the leakage produced ,

j a small amount of soil contamination. A test in January 1985 measured the ,

l liner leak rate. Liquid samples were taken from the spent fuel pool and liner '

i gap to determine tritium activity. The spent fuel pool tritium activity was l 686 pCi/mL, while that of the gap was 30.5 pCi/ml. (Groundwater leakage

diluted the spent fuel pool leakage into the gap.) The gap tritium level

! indicates that the spent fuel pool leak rate into the liner gap is less than j 0.45 L (0.12 gallon) per day. Pumps keep water level in the liner gap lower 4

Humboldt Bay Unit 3 FES 2-1 4

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than the water level in the pool and the groundwater level. The water from the liner gap is pumped to the radwaste system.

2.2 Decommissioning Plan The Humboldt Bay Unit 3 decommissioning plan proposed by the licensee is SAFSTOR for a period of 30 years followed by DECON. SAFSTOR requires that a nuclear facility be placed and maintained in such a condition that the nuclear facility can be safely stored and subsequently decontaminated (deferred der.ontamination (DECON)). DECON requires that equipment, structures, and portions of a facility

, and site containing radioactive contaminants be removed or decontaminated to a level that permits the property to be released for unrestricted use.

In preparation for SAFSTOR, the licensee is completing several tasks that are permitted under the operating license (DPR-7) and the recently issued possess-but-not-operate amendment. These activities iaclude (1)* removing irradiated fuel assemblies and in-core fission chambers and trans-l ferring them tc the spent fuel storage pool where they will remain until 00E has a permanent Federal repository to receive them (2)* drainins, the reactor vessel and reactor cooling system l (3) processing, packaging, and shipping radioactive waste to a low level waste disposal facility (4) removing certain pipe sections and components that are significant contri-butors to dose rates in work areas (to implement the ALARA program)

(5) decontaminating components and the facility (6) modifications to the plant security system l Approval of the decommissioning plan and the extension of the possess-but-not-operate license will allow decommissioning Humboldt Bay Unit 3 in the 5AFSTOR mode for a period of 30 years.

When approval of SAFSTOR is obtained, the licensee will perform the following activities:

(1) complete the layup of systems not required during SAFSTOR (2) complete the modifications of the spent fuel storage pool facilities, (3) complete decontamination of systems and components (4) process, package, and ship the radioactive waste generated by SAFSTOR l activities (5) when the activities to place Unit 3 into SAFSTOR are complete, perform l baseline radiological surveys

• These activities are now complete.

Humboldt Bay Unit 3 FES 2-5

When the 30 year SAFSTOR phase is complete, the licensee plans to dismantle (DECON) Humboldt Bay Unit 3. Near the end of the SAFSTOR phase, the licensee will submit the DECON plan for staff review and approval. The objective of DECON is to dismantle the facility in a way that will ensure the health and safety of the public and maintain occupational exposure ALARA, so the site can be released for unrestricted use. The licensee has initiated action with the California Public Utilities Commission to set aside and accrue funds for DECON activities.

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Humboldt Bay Unit 3 FES 2-6

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3 ENVIRONMENTAL IMPACTS 3.1 Assessment of Nonradiological Impacts of Decommissioning 3.1.1 Socioeconomic and Cultural Resources The socioeconomic impacts of SAFSTOR maintenance of Unit 3 are expected to be minor (Schuyler, 1984). No impacts to cultural resources are anticipated.

The permanent plant staff required for SAFSTOR maintenance of Unit 3 and the '

operation and maintenance of._the fossil-fueled units and gas turbines is ex-pected to total 73 PG&E employees. The plant staff for the past 5 years has varied between 75 and 82 persons. 'The number of temporary additional employees (contractor and PG&E) needed for the'l- to 2 year period required to prepare

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Unit 3 for SAFSTOR-is expected to vary between 7 and 15 persons. Because of the small number of temporary workers involved, the impact on the communities ,

in which they reside and on tratfic is expected to be minimal.

The total annual labor costs for the Humboldt Bay plant are estimated to be

$2.77 million (1984 dollars), of which $0.22 million is allocated for Unit 3 during SAFSTOR. The average annual dollar amount of purchases of materials and supplies resulting from SAFSTOR activities.is expected to be $20,000 (1984 dollars). The purchases are expected to be made in Humboldt County.

No impacts to any properties in or eligible for the National Register of His-4 toric Places are expected (see letter of agreement from State Historic Preser-l vation Officer in Appendix A).

3.1.2 Hydrology l The licensee's Environmental Report (Schuyler,- 1984) was reviewed using the hydrology-related sections of the Environmental Standard Review Plan for Con-l struction Permit Review of Nuclear Power Plants (NUREG-0555).

On the basis of its review, the staff concludes that there will be no measur-able nonradiological hydrologic impacts, including water use impacts. The pri-

itary noncooling water supply for the Humboldt' Bay plants is obtained from two l fresh water wells, one on site and one just off the site. The use of this water by Humboldt Unit 3 during SAFSTOR will be a small fraction of the use by Units 1 and 2.

3.1.3 Aquatic Resources Humboldt Bay receives very little fresh water inflow. Salinity remains high year round, effectively limiting withdrawal uses. Although the tidal range is moderate, about 1.2 to 1.8 m (4 to 6 feet), flushing;of the bay is great with about 44% exchange of water on each tidal cycle. The bay is broad and shallow with deep channels. Diverse habitat types are found in the bay, although the cost predominant are extensive mud flats.

Humboldt Bay Unit 3 FES 3-1

Water for cooling the condensers for the three units at the site is transported from the bay by a common intake canal and is returned by a combined discharge canal. Potable water is obtained from wells. All discharges from the nuclear unit are directed to the discharge canal where they mix with cooling water dis-charges from the two fossil-fueled units.

During the SAFSTOR period, the only industrial water system to be used will be l the spent fuel pool cleanup system. Because of the long time (more than 10 years) that has elapsed since the reactor has operated, it is no longer necessary to operate the fuel pool cooling system. The spent fuel pool coolers will be flushed and drained when they are removed from service.

3.1.4 Terrestrial Resources The types of terrestrial ecosystems bordering the Humboldt Bay site are de-scribed in Section 4.1.5.2 of the Environmental Report. These ecosystem types are situated as follows: to the north and east, the plant tarders fresh water marsh and agricultural grazing lands; to the south are salt marsh and fresh water marsh areas; toward the bay are mud flats, sand flats, a few eelgrass beds, and numerous substrates created by humans; and within the bay shallows to the north are brackish marshes, mud flats, sand flats, beach sands, sand islands, and a woody riparian community on Indian Ishnd.

There will be no decommissioning activity in the area occupied by the natural ecosystem types, nor is there likely to be any change in their function that would be affected by the decommissioning process. Therefore, the staff con-cludes that there will be no impact on terrestrial resources.

3.1.5 Endangered and Threatened Species There are no resident terrestrial or aquatic species in the area of the site that are federally listed as endangered or threatened species (Environmental Report Section 4.1.5). However, the brown pelican (Pelecanus occidentalis) and the peregrine falcon (Falco peregrinus), which are on the Federal list of endan-gered species, occasionally visit the Humboldt Bay area. No mechanism for

impacting these two species is evident. Therefore, decommissioning is not l

likely to result in any detrimental impacts to these species.

3.1.6 Land Use The decommissioning of the Humboldt Bay Unit 3 by SAFSTOR will not affect land use on or in the vicinity of the plant site. The only related new construction on the site will be the installation of a building around the exposed parts of the radioactive waste processing system (Environmental Report Section 10.5.2.5).

The construction of this building will not require the disturbtf.ce of any pre-viously undisturbed land.

The decommissioning will not affect any offsite land uses. Environmental Report Section 4.1.5.2.4 states that the U.S. Army Corps of Engineers is mitigat-ing several marshes to enhance approximately 14.2 ha (35 acres). Mitigation involves breaking existing dikes, allowing tide currents to move into the area.

Mitigation will provide wildlife- primarily migratory birds--with refuge and feeding areas. These marshes are located at the northern ~end of Arcata Bay, and the licensee is not involved with this project.

Humboldt Bay Unit 3 FES 3-2

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3.1.7 Water Use During the SAFSTOR period, the only discharge from Humboldt Bay Unit 3 will be an occasional release from the liquid waste treatment system. This relatively clean water will be piped to the discharge canal where it will be further di-luted with the cooling water flow from the two fossil-fueled units. The tidal flushing action in the bay will further dilute and disperse these intermittent discharges. In addition, although some metallic corrosion. products may at l times be present in the discharge, they are not expected to occur at toxic levels. The State of California Regional Water Quality Control Board has deter-mined that discharge levels are within the limits of the National Pollution Discharge Elimination System (NPDES) discharge permit (Environmental Report Section 4.2.4.1.2), as revised.

3.1.8 Unavoidable Environmental Impacts-The Humboldt Bay Unit 3 facility will occupy the present site for approximately 30 years, thus making that property unavailable for other uses for that period of time. Restricted land use for 30 years is the only known unavoidable envi-ronmental effect of the planned decommissioning. The proposed decommissioning alternative, as well as others, is discussed in Section 1.3 of this FES. Re-gardless of the alternative adopted, the site would continue to be used for power generation. Therefore, the restriction is to the licensee rather than to the general public.

3.1.9 Local Short-Term Uses versus Long-Term Productivity The site is now being used for power production with the operation of the two adjacent fossil-fired electrical generators. The licensee has no plans for this site other than electrical power production for the 30 years involved in the storage (SAFSTOR) of Humboldt Bay Unit 3. Therefore, there is no conflict in short-term uses versus long-term productivity.

3.1.10 Irreversible and Irretrievable Commitments of Resources The proposed 30 years of SAFSTOR followed by dismantling would not involve the commitment of any significant amount of resources. In fact, there would likely be less volume of radioactive waste to dispose of at the end of the SAFSTOR period in contrast with the amount present with immediate OECON because of radioactive decay. With less volume of radioactive waste, the required burial area at a waste burial site would be reduced.

l 3.2 Assessment of Radiological Impacts of Decommissioning The radiological impacts of 30 years of SAFSTOR consist primarily of (1) the environmental impacts of releases of liquid and gaseous radioactive effluents, (2) the occupational radiation exposure of workers involved in decommissioning and SAFSTOR maintenance, and (3) radiation exposure resulting from the trans-portation of radioactive waste from the plant site for disposal. There is also a potential for additional impacts as a result of possible accidents at the plant site.

During normal SAFSTOR operations, small quantities of radioactivity (fission, corrosion, and activation products) will be released to the environment. As Humboldt Bay Unit 3 FES 3-3

required by the National Environmental Policy Act (NEPA), the staff has deter-mined the estimated dose to members of the public outside of the plant bounda-ries as a result of the radiation from these radioisotope releases and relative to natural background radiation dose levels. These estimated doses are detailed in Appendix 8.

Little transportation of radioactive waste from the site during SAFSTOR will be required. The staff considers the licensee's estimate of 0.02 person-rem of public exposure for the 30 year period to be reasonable.

To estimate the environmental radiological impacts from delayed DECON, the staff is using the estimates in NUREG/CR-0672: 0.0055 millirem to the total body and 0.04 millirem to the lung for the maximally exposed individual, and 0.003 person-rem total body and 0.05 organ-rem to the lung for the population within 80 km (50 miles) of the plant boundary.

3.2.1 Occupational Radiation Exposure During the 30 year SAFSTOR period, maintenance and waste management will be the principal contributors to occupational radiation exposure. The licensee has estimated that maintenance will account for about 47 person-rems and waste management for about 36 person-rems. The licensee estimated that monitoring and surveillance will add another 8 person-rems, for a total of 91 person-rems.

The licensee is committed to maintain occupational exposure ALARA during SAFSTOR.

Either during or at the end of the SAFSTOR period, the spent fuel will be shipped off the site. The licensee estimated that this activity will result in exposures of 4.6 person-rems to workers plus about 0.3 person-rem to the public.

During the decontamination and dismantling of the plant following SAFSTOR, there will be an occupational radiation exposure of about 86 person-rems, plus a public exposure of about 0.4 person-rem when materials are transported off the site. The licensee estimates that total occupational exposure for SAFSTOR with delayed DECON will be about 177 person-rems. The staff has reviewed the estimates and considers them reasonable.

In estimating the health effects resulting from both offsite and occupational radiation exposure as a result of decommissioning this facility, the staff used somatic (cancer) and genetic risk estimators that are based on widely accepted scientific information (National Academy of Sciences, 1972,1980). The esti-mates of the risks to workers and the general public are based on conservative assumptions (that is, the estimates are probably higher than the actual number).

The following risk estimators are used to estimate health effects: 135 poten-tial deaths from cancer per million person-rems and 220 potential cases of all forms of genetic disorders per million person-rems.

The cancer mortality risk estimates are based on the " absolute risk" model de-l scribed in BEIR I (National Academy of Sciences, 1972). Higher estimates can l

be developed by use of the " relative risk" model, along with the assumption I that risk prevails for the duration of life. Use of the relative risk model would produce risk values up to about four times greater than those used in this report. The staff regards the use of the relative risk model values as a l reasonable upper limit of the range of uncertainty. The lower limit of the range would be zero because there may be biological mechanisms that can repair Humboldt Bay Unit 3 FES 3-4

1 l

damage caused by radiation at low doses and/or dose rates. The number of poten-tial cancers would be approximately 1.5 to 2 tipes the number of potential fatal cancers, according to BEIR III (National Academy of Sciences, 1980). '

Values for genetic risk estimators range from 60 to 1100 potential cases of all forms of genetic disorders per million person-rems (BEIR III). The value of 220 potential cases of all forms of genetic disorders per million person-rems is equal to the sum of the gecmetric means of the risk of specific genetic defects and the risk of defects with complex etiology.

Tha preceding values for risk estimators are consistent with the racommenda-tions of a number of recognized radiation protection organizations, such as the International Commission on Radiological Protection (ICRP, 1977), the National Council on Radiation Protection and Measurements (1975), the National Academy of Sciences (BEIR III,1980), and the United Nations Scientific Commit-tee on the Effects of Atomic Radiation (1982).

The risk of potential fatal cancers in the exposed work forca population at the Humboldt Bay facility is estimated as follows: multiplying the plant-worker population dose (about 177 person-rems) by the somatic risk estimator, the staff estimates that about 0.02 cancer death may occur in the total exposed popula-tion. The value of 0.02 cancer death means that the probability of I cancer death over the lifetime of the entire work-force as a result of facility decom-missioning is about P. chances in 100. The risk of potential genetic disorders attributable to exposure of the work force is a risk borne by the progeny of the entire population and is thus properly considered as part of the risk to the general public.

Multiplying the dose to the general population from exposure to radioactive effluents and transportation of fuel and waste from the decommissioning of this facility (16 person-rems) by the preceding somatic risk estimator, the staff estimates that about 0.002 cancer death may occur in the exposed population.

The significance of this risk can be determined by comparing it to the total incidence of cancer death in the population of the United States. Multiplying the estimated population of the United States for the year 2000 (260 million persons) by the current incidence of actual cancer fatalities (18%), about 47 million cancer deaths from all causes are expected (American Cancer Society, 1985).

For purposes of evaluating the potential genetic risks, the progeny of workers are considered mernbers of tFe general public. However, according to para-graph 80 of ICRP Publication 26 (1977), it is assumed that only about one-third of the occupational radiation dose is received by workers who have offspring after the workers' radiation exposure. Multiplying the sum of the dose to the population from exposure to radioactivity attributable to the decommissioning of the plant (16 person-rems) and the estimated effective dose from occupational l exposure (one-third of 177 person-rems) by the preceding genetic risk estimators,

! the staff estimates that about 0.02 potential genetic disorder may occur in all

! future generations of the exposed population. BEIR III indicates that the mean l

parsistence of the two major types of genetic disorders is about 5 generations and 10 generations, respectively. Thus, in the following analysis, the risk of potential genetic disorders from the storage and decontamination of the plant i is conservatively compared with the risk of actual genetic ill health in the first 5 generations, rather than the first 10 generations. Multiplying the 1

Humboldt Bay Unit 3 FES 3-5

estimated population within 80 km (50 miles) of the plant ($130,000 persons in the year 2000) by the current incidence of actual genetic ill health in each l generation (*11%),about71,000geneticabnormalitiesfromallcausesare expected in the first five generations of the population within 80 km (50 miles) of the plant (National Academy of Sciences, 1980).

The risks to the general public from exposure to radioactive effluents and transportation of fuel and wastes from the facility are very small fractions of the estimated normal incidence of cancer fatalities and genetic abnormalities.

On the basis of the preceding comparison, the staff concludes that the risk to the public health and safety from exposure to radioactivity associated with the decommissioning of the facility will be very small.

3.2.2 Radioactive Waste Management Systems Radioactive liquid waste generated during the SAFSTOR period will be processed and disposed of. The expected sources of radioactive liquid wastes include spent fuel pool liner leakage, spent fuel pool recirculation pump packing leak-age, waste water from ongoing decontamination activities, hot lab waste, and rainwater runoff from contaminated areas.

! A building will be erected to enclose the exposed portions of the radioactive waste processing system. This building will prevent rainfall contamination and thus eliminate a need for processing contaminated rainfall. During the SAFSTOR period, the only significant activities involving radioactivity will be associ-ated with the decontamination of systems and components, the operation and main-tenance of the spent fuel storage pool, and the processing of wastes resulting from these operations. These activities will account for essentially all re-leases of radioactive materials.

The liquid radwastes from the spent fuel pool, decontamination activities, and the hot lab will be collected and sampled. If contamination is present or sus-pected in a batch, the batch will be processed more before it is discharged to the plant discharge canal. Prccessing consists of filtration and, if necessary, treatment by the radioactive waste evaporator or a demineralizer, depending on the chemical composition of the waste. After processing, the liquid effluent will be sampled and released to the plant discharge canal where it will be di-luted with circulating water from Unit 1 and/or Unit 2 before it is discharged to Humboldt Bay.

The liquid radioactive waste concentrated by the evaporator will be accumulated in the concentrate waste tanks until one tank is filled. A contractor will then analyze and solidify the concentrated liquid waste using portable equipment. ,

Spent cartridge-type filters and filter crud will be packaged in drums and stored in a shielded area. When a sufficient a contractor will analyze and solidifyencapsulate/ quantity ofit waste has been using portable accumulated, equipment.

Dry active waste and contaminated tools, equipment, lumber, and soil will be

! packaged for shipment and stored until they are shipped off site for disposal.

The handling of activated components will be similar to the handling of spent filter or dry active waste, as appropriate. After processing and handling as l above, all solid wastes will be stored on the site until they are shipped, in l appropriate containers, for disposal at a licensed disposal site. The solid waste vault, the low-level waste storage building, and the solid waste handling Humboldt Bay Unit 3 FES 3-6

building will be used to store solid wastes before they are chipped off the site for disposal.

The ventilation exhausts from the refueling building, hot lab, hot machine shop, and the radwaste treatment building operating area will be routed to the moni-tored plant ventilation system for release from the 250-foot-high plant stack.

No treatment is provided by this system for normal releases. A cover with a j controlled ventilation exhaust will be installed over the spent fuel pool. Con-trolled ventilation is not provided for the solid waste storage vault, the low-level waste storage building, or the solid waste handling building.

The operation and maintenance of the spent fuel storage pool and the processing of wastes resulting from the spent fuel pool have continued since the plant ceased commercial operation in July 1976. The calculated annual gaseous and liquid effluent releases over the 30 year SAFSTOR period were evaluated using values given in the Humboldt Bay Power Plant semiannual reports on radio-active effluent releases and waste disposal covering the post-shutdown years 1977 through 1983. On the average, actual releases are expected to be less than the calculated releases (listed in Tables 3.1 and 3.2) as a result of radioactive decay over the 30 year SAFSTOR period.

The staff's detailed evaluation of the radwaste system and its capability to accommodate the solid waste expected will be in the safety evaluation report (SER). The licensee has estimated that, on the average, approximately 1 ma (36 ft3) of resins containing 0.1 curie of radioactivity, 2 ma (75 f t3) of evap-orator bottoms containing 0.01 curie of radioactivity, and 4 m3 (150 ft3) of dry, active wastes containing 0.0015 curie of radioactivity (all mainly Cs-137 and Sr-90) will be generated annually to be processed, stored, and shipped to a licensed disposal site. The packaging and shipping of these wastes will be in conformance with the applicable requirements of 10 CFR 20, 61, and 71 and 49 CFR 170 to 178.

The licensee has proposed: (1) Technical Specifications limiting release rates for radioactive materials in liquid and gaseous 2f fluents and (2) routine monitoring and measurement of principal release points to ensure that release rates are in conformance with the regulations.

Releases of radioactive materials during final decontamination and dismantling at the end of the 30 year SAFSTOR period will result primarily from waste man-agement operations. Atmospheric releases will be insignificant. Releases in liquid effluents during the 4 year DECON period are estimated to be about 0.6 curie of gross beta gamma and gross alpha and 6 curies of tritium. Liquid radwastes will be treated, as necessary, before they are released, and the solid radwastes from this treatment will be processed before they are shipped off the site for disposal. Radicactive solid wastes will be analyzed, processed, and packaged to meet the requirements for transportation and final disposal.

3.2.3 Postulated Accidents In assessing the impacts of postulated accidents, the staff has reviewed the licensee's submittals (Schuyler,1984; Shiffer, February, April, and July,1985) related to decommissioning and to maintaining Humboldt Bay Unit 3 in SAFSTOR for a nominal 30 years before its ultimate dismantling. The review was con-ducted in accordance with Regulatory Guide 4.2, Revision 2 and NUREG-0612 and Humboldt Bay Unit 3 FES 3-7

NUREG-0554 with respect to accident assumptions, and in accordance with the

. Standard Review Plan for the Safety Review of Nuclear Power Plants (NUREG-0800)

Section 9.1.2 with respect to criticality.

The SAFSTOR mode does not allow power operation, criticality, or fuel loading.

Because the license restriction of " possession only" is in effect during SAFSTOR, i the staff assessed only non-reactor core accidents _ for low probability scenarios.

In the SAFSTOR' mode, all of the spent fuel (390 assemblies) is stored in the

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l spent fuel pool. Except for one assembly, Boral neutron-abrcrbing blankets sur-round each assembly to ensure subcriticality after any event that may result in i

a rearrangement of stored spent fuel assemblies. The one assembly is stored in i a stainless steel box.

3.2.3.1 Evaluation To evaluate offsite radiological consequences of potential accidents involving spent fuel stored in the spent fuel pool, the staff considered three types of

hypothetical accidents

a fuel handling accident, a non-mechanistic heavy load i

drop, and a seismically, or otherwise induced, rearrangement of stored spent

, fuel assemblies. Other hypothetical accident scenarios considered were: a non-

mechanistic expulsion of all pool water and radionuclide contaminants of the

, pool water to the atmosphere, a spent fuel pool rupture, and an uncontrolled ,

release of all contents of the liquid radwaste tanks to the discharge canal.

These are discussed below. No credit is given for seismic integrity of facility structures in the staff evaluation of postulated accidents (i.e., the staff assumed that the structures would fail in a seismic event).

3.2.3.2 Fuel Handling Accident The offsite radiological consequences of the drop of a spent fuel assembly con-sist almost entirely of the whole-body dose resulting from the release of one-sixth of the Kr-85 gap activity contents of two stored assemblies. This is 4

l because all stored assemblies have a decay time of at least 10 years. The prin-cipal thyroid dose contributor, I-131, witn an 8.05-day half-life, has decayed to negligible concentrations (as have other significant iodine radioisotopes).

Release of the long-lived isotope Kr-85, with a 10.8 year half-life, produces a l 0- to 2-hour offsite whole-body dose at the exclusion area boundary of 2.5 x 10 3 mrem. This estimate assumes there has been damage to one row of pins in each of two assemblies, a reasonably conservative assumption, taking into account fuel assembly geometry and type. It also assumes an exclusion area Lnundary 50th percentile atmospheric diffusion and transport relative concentration 3 (X/Q) of 7.7 x 10 4 sec/m3 The U.S. Environmental Protection Agency (EPA) has 1 proposed a range of doses above which protective actions would be warranted.

These projected dose levels, known as the Protective Action Guide (PAG) levels, i are 1 to 5 rems to the whole body or 5 to 25 rems to the thyroid (EPA, 1975).

l The projected dose from a fuel handling accident is well below the PAG levels.

1 I

Potential offsite dose at the exclusion area boundary has been recalculated using improved s3urce term and dosa conversion factor assumptions. The source term is now based on the actual Humboldt Bay Unit 3 spent fuel data rather than a generic assumption. Also, the dose conversion factor for a ground level release of krypton-85 is now obtained from Regulatory Guide 1.109, Revision 1, Table B-1, which better describes the potential dose caused by releases from Humboldt Bay Unit 1 FES 3-8 l

l l Table 3.1 Calculated releases of radioactive materials in liquid effluents from Humboldt Bay Unit 3 during the 30-year SAFSTOR period Nuclide mci /yr Nuclide mci /yr Corrosion and activation products Fission products, continued t

Cr-51 0.004 I-131 0.004

, Mn-54 0.4 Xe-133 0.004 Co-58 0.004 Xe-135 0.004 j Co-60 28 Cs-134 11 Zn-65 0.4 CS-137 110

Zr/Nb-95 0.004 Ba/La-140 0.004 Np-239 0.004 Ce-141 3.2 Ce-144 4

Fission products i Others Sr-89 0.004 1

Sr-90 - 0. 3 Tritium 83 Mo-99 0.004 Gross alpha 0.42 Tc-99m 0.004 i

Table 3.2 Calculated releases of radioactive materials in gaseous and particulate effluents from Humboldt Bay Unit 3 during the 30 year SAFSTOR period

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Nuclide mci /yr Nuclide mci /yr 1

i Kr-83m 0.004 I-133 0.004 I

Kr-85 0.920 I-135 0.004 Kr-85m 0.004 H-3 40 l Kr-87 0.004 Mn-54 0.019 Kr-88 0.004 Co-60 0.220

, Kr-89 0.004 Sr-89 0.004 i

Xe-133 0.004 Sr-90 0.0081 Xe-133m 0.004 Sb-125 0.0047 Xe-135 0.004 Cs-134 0.014 Xe-135m 0.004 Cs-137 0.061 Xe-137 0.004 Ba/La-140- 0.004 Xe-138 0.004 Ce-144 0.025 I-131 0.004 Gross alpha 0.004 i

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the spent fuel at Humboldt Bay Unit 3. These changes result in a reduction in predicted offsite exposures from those presented in the DES.

3.2.3.3 Fuel Assembly Damage Caused by Non-Mechanistic Heavy Load Drop or Site-Related Hazards The 0- to 2-hour offsite radiological consequences of a non-mechanistic heavy l load drop in the spent fuel pool are estimated to be 0.5 millirem te the whole body. This estimate assumes there has been damage to one row of pins in all 390 spent fuel assemblies and a minimum 8 year cooldown time although the active cooldown time is more than 10 years. This estimate uses the same atmospheric diffusion and transport relative concentration used in Section 3.2.3.2 above.

Again, the thyroid dose is estimated to be negligible. These consequences are also a very small fraction of the PAG dose levels.

On the basis of the non-mechanistic heavy load drop analysis, the staff has de-termined that site-related hazards that might produce heavy falling objects do not pose a significant environmental threat to the spent fuel pool or its con-tents. Fcr example, although the onsite storage of liquid propane may represent a fire or explosion hazard, ignition or detonation of liquid propane is not a significant threat to the integrity of the spent fuel pool. The damage potential would be primarily in terms of the impact of heavy objects (e.g., nearby equip-ment or structural debris) that might fall into the spent fuel pool. Because of the difficulty of postulating specific potential load drops over the 30 year SAFSTOR period, for this analysis the staff assumed that the offsite radiological consequences of a non-mechanistic heavy load drop described above bound the potential consequences of this type of hazard. Hence, the presence of combust-ible fuels on this site does not pose a significant environmental threat to the spent fuel pool.

The improved source term and dose conversion factor assumptions discussed in Section 3.2.3.2, above, result in a reduction in predicted offsitu exposures for the postulated nonmechanistic accident.

3.2.3.4 Criticality Potential of Stored Spent Fuel Rearranged as a Result of Seismic cr Other Mechanical Loads In a submittal of July 30, 1985 (Shiffer, July 1985), the licensee provided an analysis of the criticality features of the stored spent fuel configuration.

Both the CASM0-2E computer code, used by PG&E, and the MERIT computer code, used by the General Electric Company (GE), have been used extensively in pre-vious criticality analyses. PG&E has provided data to validate the use of the CASM0-2E code in the Humboldt Bay analyses, and GE has provided data to validate the use of the MERIT code.

To decrease the probability and mitigate the consequences of a criticality acci-dent that would result from a heavy load drop or a seismic event, the licensee has committed to make the following spent fuel rack modifications:

(1) Except for one assembly which is stored in a stainless steel box, each fuel bundle will be contained in a can fabricated from a neutron-absorbing ma-terial (poison) containing B-10. The B-10 density precludes achieving a K eff (the effective neutron multiplication factor) greater than 0.90 for any possible configuration. The neutron-absorbing material, Boral, has Humboldt Bay Unit 3 FES 3-10

i been previously accepted by the staff for controlling criticality in spent fuel pools.

(2) Mechanical means will be provided to prevent separation of the fuel bundle from the poisoned can.

(3) The poisoned can/ fuel bundle assembly will be stored in the existing fuel storage racks.

The licensee has analyzed the effect of varying the internal pitch of an assembly and the distance between stored spent fuel cans. The results are consistent with staff estimates.

The licensee's analysis of the most reactive combination of the spacing param-eters shows that the calculated values of K,ff meet the (maximum) limiting criterion (NUREG-0800) of 0.95 with a margin greater than 0.05.

These calculations make the tacit assumption that any distortions of the racks would leave t% basic geometry unaltered (i.e., the fuel rods would remain in a parallel arraj and be surrounded by the Boral plates). This assumption may not be valid under all credible array-altering physical mechanisms. However, the following statements can be made about the likely effects of calculational as-sumptions and possible distortion of a spent fuel assembly geometry:

(1) 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 somewhat.

(2) Assuming infinite length for the assemblies is conservative. Use of the correct length would reduce K by 0.01.

eff (3) It is very unlikely that any credible rearrangement of the stored spent i

fuel by crushing under seismic or other loads would increase the reactivity

! of the system enough to make it critical. The licensee's analysis (Shiffer, July 1985) assumed no radial er axial neutrcn leakage for example, and, therefore, it is unlikely that crushing the assemblies into a pancake geo-metric configuration (with rods still vertical) would increase the reactiv-ity.

Likewise, a local pile of fuel pellets (low enrichment) is very likely to be undermoderated and subcritical.

Therefore, the staff concludes that there is a negligibly small likelihood that there is any credible means of producing criticality in the stored spent fuel array.

1 3.2.3.5 Non-Mechanistic Expulsion of Pool Water and Radionuclide Contaminants to the Atmosphere In the event of a large seismic event near the site, it is conceivable that 1

falling debris could cause some of the spent fuel pool water containing radio-nuclide contaminants (chiefly cobalt, cesium, and strontium) to slosh or splash through newly created building fissures or openings. To bound the potential  ;

offsite doses resulting from such a hypothetical occurrence, the staff assumed

\

i Humboldt Bay Unit 3 FES 3-11 4

that all radionuclide contaminants in the pool water inventory are released instantaneousiv and directly to the atmosphere.

The integrated source term assumed for the dose assessment was 9.2 x 10 3 curie of Co-60, 1.7 curies of Cs-137, and 2 x 10 3 curie of Sr-90. Of these quantities, 1% was assumed to be inhalable. No credit was taken for washout. Using the same X/Q value used in Section 3.2.3.2 above and the methods given in Regulatory Guide 1.109, Revi:, ion 1, the staff calculated the following offsite 50 year inhalation-initiated dose commitments: 1.8 x 10 2 millirem to the lung, 0.35 millirem to the liver, and 6.4 x 10 2 millirem to the bone. (In this scenario, immersion doses are negligible.) These are all very small fractions of the PAG dose levels.

3.2.3.6 fpent Fuel Pool Rupture The conrequences of a rupture in the spent fuel pool were analyzed by the licensee and the staff. The analyses assumed the released effluent would enter the tidal-affected water table aquifer and flow down gradient toward Humboldt Bay.

The rainy season groundwater level at the spent fuel pool is 2.7 m (9 feet).

Mean lower low water (MLLW) and the mean tide level are 1 m (3.3 feet). From estimated values.of hydraulic conductivity of 3170 m/ year (10,400 feet / year) and effective porosity of 0.25, a groundwater velocity of 173 m/ year (564 feet / year) was determined. On the basis of this velocity and a distance to Humboldt Bay from the spent fuel pool of 128 m (420 feet), a travel time of about 9 months was estimated for the effluent to enter Humboldt Bay. The geochemical properties of the site would further retard the movements of radionuclides such as cesium, strontium, and cobalt. To determine the amount of retardation, the licensee estimated distribution coefficients of 1.5 mL/g for strontium and cobalt and 20 ml/g for cesium. The staff considers these estimates to be reasonable and conservative for the site.

For the release scenario, the licensee assumed that only that effluent in the pool between the top of the pool and the mean tide level of 1 m (3.3 feet) MLLW would flow out. Although the staff does not consider the licensee's assumption conservative for all conceivable release scenarios, the staff used the licensee's estimates of amounts released for calculating reasonable doses.

The staff used a simple analytical model of contaminant flux through a vertical plane to estimate the amounts of Cs-137, Cs-134, Sr-90, and Co-60 entering Humboldt Bay. From the flux calculation and the licensee's release estimates, the staff determined Cs-137 to be the primary contributor to dose with about 3.2 x 10 2 curie of Cs-137 entering Humboldt Bay. Sr-90 and Co-60 were lesser contributors, with 5.2 x 10 4 curie of Sr-90 and 8.7 x 10 4 curie of Co-60 entering Humboldt Bay. For dose calculations, the radionuclides were assumed to remain in Humboldt Bay for 1 year. Using estimates of the amount of human food consumed from the commercial fish catch data, the staff determined that a rupture of the spent fuel pool would result in a total population dose of 0.133 person-rem (Shiffer, July 1975, and RG 1.109), implying an average indi-vidual dose commitment less than that of background radiation. Doses to the population as a result of recreational activities in the water wnuld be negli-gible compared with those resulting from seafood consumption.

Humboldt Bay Unit 3 FES 3-12

If the entire inventory of radionuclides in the spent fuel pool were assumed to be released, the resulting population dose would still be less than 1 person-rem.

3.2.3.7 Uncontrolled Release of Radwaste Tank Contents The licensee presented an analysis of an uncontrolled release from the two con-centrated waste storage tanks as a worst-case scenario for radwaste tank acci-dents. The licensee assumed that the entire 37,850-L (10,000 gal) volume of the two tanks would flow directly into the discharge canal. The licensee then calculated the concentrations in the canal for Cs-137, Cs-134, Co-60, and Sr-90.

In all cases, the licensee determined that the concentrations in the discharge canal were more than an order of magnitude less than the limits given in 10 CFR 20, Appendix B, Table II. The staff agrees with the licensee's determination.

The staff also made an independent analysis of the tank spill to estimate popu-lation dose. The staff assumed that the entire contents of the tanks eatered Humboldt Bay and remained there for 1 year. This is a very conservative assump-tion because the tiaal exchange with the bay is about 44% per tidal cycle. The buildup of the various radionuclides in both 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 calcula-tions, using the methods in RG 1.109, the staff estimated that the annual popu-lation-integrated total body dose resulting from a tank spill into the discharge canal would be less than 0.1 person-rem (Schuyler, 1984, and RG 1.109). Thus an average individual consuming finfish and/or shellfish harvested from Humboldt Bay after an accident in which the contents of the two radwaste storage tanks were discharged into the bay would receive from this food source much less than the average annual background radiation dose received by individuals in the United States from all sources. Again, doses resulting from recreational activities in the water would be negligible compared with those resulting from seafood consumption.

I Humboldt Bay Unit 3 FES 3-13

l l

4

SUMMARY

OF DECOMMISSIONING ALTERNATIVES The proposed decomaissioning alternative, SAFSTOR, and other possible alterna-tives are discussed in Section 1.3. Table 4.1 provides summary compari-sons of the alternatives.

Facility restart is not a viable alternative because the licensee has concluded that the restart of Humboldt Bay Unit 3 is economically unattractive. The li-censee concluded this because the costs of meeting NRC seismic requirements and modifications imposed since the accident at Three Mile Island Unit 2 (TMI-2) would be high and the total scope of such modifications is uncertain.

The DECON decommissioning alternative is not feasible at this time because there is presently no available location for the spent fuel other than onsite storage in the spent fuel pool (see Section 1.3.3). In addition, DECON would result in greater occupational radiation exposures to workers and more radioactive waste than other alternatives.

Again, with spent fuel stored on the site, the ENTOMB alternative is not prac-tical. Continued surveillance and security would be needed for spent fuel storage under this alternative. There also would be the potential of the en-tombment structure failing as a result of seismic events. In addition, there would be greater difficulty in monitoring during the entombment period and in the future removal of residual radioactivity.

Although the SAFSTOR decommissioning alternative may have a higher dollar cost than other alternatives, the occupational radiation exposures would be the lowest. Also, the volume of solid radioactive waste for transport and disposal is likely to be lower because dismantling would take place after a 39 year radio-active decay period (since shutdown in July 1976).

SAFSTOR also is consistent with the need to maintain onsite storage of spent fuel l l

until a Federal repository is available. On August 31, 1984, the Commission issued the " Waste Confidence Decision" (49 FR 34658) and amended 10 CFR 51.23 and 51.30. In this rule, the Commission foiind that no significant environmental impacts will result from the storage of spent fuel in reactor facility storage pools for at least 30 years beyond the expiration of nuclear reactor operating licenses. This conclusion by the Commission supports the proposed SAFSTOR option at Humboldt Bay Unit 3.

The Nuclear Waste Policy Act of 1982 established a framework for the disposal of high level waste, including spent nuclear fuel. The Act stated that the primary responsibility for providing interim spent fuel storage rests with the licensee. Fuel storage must continue at a permanently shutdown reactor facility such as Humboldt Bay Unit 3 until a Federal repository is available, unless the licensee has another facility that is suitable. The SAFSTOR option is the only option that is compatible with long-term onsite storage of spent fuel at Humboldt Bay Unit 3.

1 l

Humboldt Bay Unit 3 FES 4-1

z Table 4.1 Comparison of Humboldt Bay Unit 3 decommissioning alternatives 5

k Potential release Other potential g Alternative Potential advantages Potential disadvantages of radioactivity effects E' DECON If fuel is shipped off- About twice the occupa-M Moderate release poten- Requires transfer of (immediate site, lowest cost of any tional dose of the other tial during dismantling; more curies and vol-E dismantle- alternative; fastest re- action alternatives; eliminates potential re- ume of radioactive

" ment) lease of land for unre- largest amount of radio- lease of radioactivity waste to disposal

" stricted use; immediate active waste to be trans- after dismantling is sites; and more land removal of radioactivity poited; not compatible complete. for burial of radio-A from the site. with Waste Policy Act of m

1982 with respect to on- active waste. Truck site fuel storage. traffic increase off the site.

ENTOMB Intermediate occupational Potential for failure of Low release potential radiation dose; reduced Site is not available entombment structure due during preparation for for other use for very amount of solid radio- to seismic events; not entombment, moderate long time (unless active waste to be trans- compatible with Waste potential for release ported. Policy Act of 1982 with structures are opened a

during entombment. and residual radio-respect to onsite fuel A storage.

activity removed).

No offsite non- .

radiological infacts.

SAFSTOR; Lowest occupational ra- Requires surveillance for Very low potential for deferred diation dose of any 30 more years. Potential release during safe Site is unavailable DECON action alternative; con- for failure of facility for other uses for (preferred storage and deferred 30 more years.

sistent with Waste Policy structures due to seismic dismantling because of alter- Act of 1982 with respect events. No offsite non-native) to onsite fuel storage; easy access for monitor- radiological impacts less commitment of land ing and maintenance dur- during SAFSTOR period, ing storage and reduced Reduced offsite truck area to radioactive waste radioactivity during disposal. traffic for waste dismantling. disposal during final DECON.

No action; Delays the need for de-continue commissioning plans and Uncertainty about protec- Moderate potential for Site is unavailable surveil- actions; initial costs tion of health and safety rebase of radioactive for other uses for and environment; contin- material from deterio-lance reduced. ued high security and an indefinite period.

rating equipment and No offsite non-surveillance costs; lack tanks that contain low radiological impacts.

of planning may result in level radioactive wastes.

higher final cost for re-moval of residual radio-activity.

5 CONCLUSIONS The staff issued a Draft Generic Environmental Impact Statement (GEIS) (NUREG-0586) in support of proposed rulemaking for the decommissioning of nuclear facilities.

The staff concluded in the GEIS that the technical basis exists for decommission-ing plants in a safe, efficient, and timely manner.

Stering the spent fuel assemblies at Humboldt Bay Unit 3 has minimal environ-mental impact. Other alternatives for spent fuel storage are not available at this time and, on balance, have no significant environmental advantage.

10 CFR Part 51.23(a) states that the Commission has made a generic determination that for at least 30 years beyond the expiration of reactor operating licenses, no significant environmental impacts will result from the storage of spent fuel in reactor facility storage pools.

On the basis of its review of the plant's health physics organization, equipment, and procedures, the staff concludes that the licensee has established a radiation protection program that will maintain radiation exposures within the applicable limits of 10 CFR 20 and will maintain exposures ALARA in accordance with NUREG-0800 and RG 8.8. The staff concludes that a fuel handling accident resulting in damage to two spent fuel assemblies will result in atmospheric radionuclide releases that are very small and well below the EPA PAG levels at which protective actions would be warranted.

The staff similarly concludes that damage to all the stored spent fuel assemblies resulting from a non-mechanistic heavy load drop would result in atmospheric radionuclide releases that also are well below the PAG levels.

The staff also concludes 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.

The staff has determined that the upper limits of potential lung, liver, and bone doses resulting from an instantaneous expulsion to the atmosphere of the entire water /radionuclide content of the spent fuel pool are very small fractions of the PAG levels.

The staff also has determined that a rupture of the spent fuel pool or the liquid radwaste tanks would result in a total body dose to an average individual via the seafood chain that would be less than the dose from natural background levels. Doses resulting from recreational activities in the water of Humboldt Bay would be negligible.

As a result of its analysis and review of potential environmental, technical, and societal impacts, the staff has determined that Humboldt Bay Unit 3 can be placed in SAFSTOR for a 30 year period with minimal environmental impact.

Humboldt Bay Unit 3 FES 5-1

6 REFERENCES j American Cancer Society, "1985 Cancer Facts and Figures," American Cancer Society, Inc., New York, 1985.

International Commission on Radiological Protection (ICRP), " Recommendations of the International Commission on Radiological Protection," ICRP Publication 26, January 1972.

National Academy of Sciences, Advisory Committee on the Biological Effects of Ionizing Radiation, "The Effects on Populations of Exposure to Low Levels of Ionizing Radiation" (BEIR I), 1972.

-- , "The Effects on Populations of Exposure to Low Levels of Ionizing Radiation" (BEIR III), 1980.

! National Council on Radiation Protection and Measurements (NCRP), " Review of the Current State of Radiation Protection Philosophy," NCRP Report No. 43, January 1975.

Nuclear Waste Policy Act of 1982 (Public Law 97-425, January 7, 1983).

Pacific Gas and Electric Company (PG&E), " Final Hazards Summary Report - Humboldt Bay Nuclear Power Plant Unit No. 3," September 1, 1961.

Schuyler, J. O., PG&E, letter to H. R. Denton, NRC, HBL-84-027, July 30, 1984.

Shiffer, J. D., PG&E, letter to J. A. Zwolinski, NRC, " Responses to NRC staff questions of January 23, 1985," February 28, 1985.

-- , letter to J. A. Zwolinski, NRC, " Responses to NRC staff questions of i January 23, 1985 and February 14, 1985," April 3, 1985.

-- , letter to J. A. Zwolinski, NRC, "Humboldt Bay Power Plant Unit 3 Critical-

! ity Analysis for SAFSTOR Decommissioning," July 30, 1985.

-- , letter to J. A. Zwolinski, NRC, "Humboldt SAFSTOR Decommissioning-Document Transmittal" October 7, 1935.

l -- , letter to H. N. Berkow, NRC, "PG&E Responses to Public Comments on DES,"

Octobor 20, 1986.

-- , letter to Document Control, NRC, " Spent Fuel Pool Liner Gap Level Exceeded i the Control Band, January 22, 1987.

United Nations Scientific Committee on the Effects of Atomic Radiation (UNSCEAR),

" Ionizing Radiation: Sources and Biological Effects," 1982.

j U.S. Department of Energy, " Draft Mission Plan Amendments," DOE /RW 0128, January 1987, i

Humboldt Bay Unit 3 FES 6-1

- - - .- - . - - - - - - - - . - - - - , - - - . - - - - - - - - - - - - - -- r--- - - - .- , --. .--- - . ,-, . - - .. . -

U.S. Environmental Protection Agency, " Manual of Protective Action Guides and Protective Actions for Nuclear Incidents," EPA-520/-75-001, September 1975.

U.S. Nuclear Regulatory Commission, " Amendment of License No. DPR-7 to Possess-But-Not 3perate Status," letter 6505-07-023, July 16, 1985.

-- , Regulatory Guide (RG) 1.109, " Calculation of Annual Doses to Man from Ruuc1ne Releases of Reactor Eff1 tents for the Purpose of Evaluating Compliance with 10 CFR Part 50, Appendix I," Revision 1, October 1977.

-- , RG 4.2, " Preparation of Environmental Reports for Nuclear Power Stations,"

Revision 2, July 1976.

-- , RG 8.8, "Information Relevant to Ensuring that Occupational Radiation Exposures at Nuclear Power Stations Will Be as Low as Is Reasonably Achievable,"

j Revision 3, June 1978.

-- , NUREG-0554, " Single Failure Proof Cranes for Nuclear Power Plants," May 1979. !

-- , NUREG-0555, " Environmental Standard Review Plans," May 1979.

-- , NUREG-0575, " Final Generic Environmental Impact Statement on Handling and Storege of Spent Light Water Power Reactor Fuel," August 1979.

-- , NUREG-0586, " Draft Generic Environmental Impact Statement on Decommissioning of Nuclear Facilities," January 1981.

-- , NUREG-0612, " Control of Heavy Loads at Nuclear Power Plants," July 1980.

-- , NUREG-0800, " Standard Review Plan for the Safety Review of Light-Water-Cooleci Reactors," July 1981.

-- , NUREG/CR-0130, " Technology, Safety, and Costs of Decommissioning a Refer-ence Pressurized Water Reactor," June 1978.

-- , NUREG/CR-0672, " Technology, Safety and Costs of Decommissioning a Reference 1 l Boiling Water Reactor Power Station," June 1980.

-- , NUREG/CR-0912, "Geoscience Data Base Handbook for Modeling a Nuclear Waste Repository," Isherwood, D., Lawrence Livermore Laboratory, January 1981.

-- , " Waste Confidence Decision," 49 FR 34658-34688, August 31, 1984.

Zwolinski, J. A., NRC, le';er to J. O. Shiffer, PG&E, December 18, 1984.

4 1

I l

Humboldt Bay Unit 3 FES 6-2

7 CONTRIBUTORS This Final Environmental Statement is a product of the NRC staff. The principal contributors to this report are Staff Title Organization Louis Bykoski Regional Environmental Economist Siting Analysis Branch Peter Erickson Project Manager Standardization & Special Projects Directorate Germain LaRoche Environmental Scientist Uranium Fuel Licensing Branch Charles Nichols Senior Nuclear Engineer Plant, Electrical, Instrumentation & Control Systems Branch Robert Screworth Senior Reactor Systems Engineer Facility Operations Branch Jerry Swift Reliability & Risk Analyst Reliability & Risk Assessment Branch Rex Wescott Hydraulic Engineer Engineering Branch Frank Witt Chemical Engineer Plant Systems Branch Millard Wohl Reactor Engineer Technical Specification Coordination Branch Walter Brooks Nuclear Engineer Reactor Systems Branch Humboldt Bay Unit 3 FES 7-1

8 LIST OF AGENCIES AND ORGANIZATIONS TO WHOM COPIES OF THE DRAFT ENVIRONMENTAL STATEMENT WERE SENT Advisory Council on Historic Preservation Attorney General, State of California California Department of Conservation California Energy Facilities Siting Commission California Energy Resources Conservation and Development Commission California Office of Intergovernmental Management California Public Utilities Commission California State Clearinghouse California State Department of Health Services Federal Emergency Management Administration Federal Energy Regulatory Commission Forest Service Field Office - California Region Humboldt County Board of Supervisors The Conservation Foundation U.S. Army Corps of Engineers, San Francisco District U.S. Department of Agriculture

a. Natural Resources and Economic Division

b. Rural Electrification Administration

c. Soil Conservation Service, State Office U.S. Department of Commerce U.S. Department of Health and Human Services U.S. Department of Housing and Urban Development, San Francisco Region U.S. Department of the Interior, Office of Environmental Project Review U.S. Department of Transportation, San Francisco Region U.S. Environmental Protection Agency, Office of Federal Activities Humboldt Bay Unit 3 FES 8-1

9 STAFF RESPONSES TO COMMENTS ON THE DRAFT ENVIRONMENTAL STATEMENT i Pursuant to 10 CFR Part 51, the " Draft Environmental Statement for Decommission-i ing of Humboldt Bay Power Plant, Unit No. 3" (DES) was transmitted, with a request for comments, to the agencies and organizations listed in Section 8.

1 In addition, the NRC requested comments on the draft environmental statement from interested persons by a Notice published in the Federal Register on April 28, 1986 (51 FR 15853). In response to requests from Miclael R. Sherwood of the Sierra Club and James S. Adams of the Redwood Alliance, on June 12, 1986, the NRC extended the initial 45-day comment period by an additional 60 days (51 FR 21427).

In response to the request for comments, comments were received from:*

A. California Coastal Commission, North Coast Area B. U.S. Department of Health and Human Services C. Sierra Club

0. Redwood Alliance E. Elton Adams / June Crym F. Nancy Hiefiker G. Thomas P. Infusino

H. Ralph Kraus I. Larry Lancaster J. Michael J. Manetas K. Acorn Alliance i L. Edith Kraus Stein M. Pam Wellish N. Senator Barry Keene, State of California Senate

0. Susan Ames P. Daniel J. Taranto

Q. Sierra Club, Redwood Chapter

R. Judith Field S. Bonnie Blackberry T. Pacific Gas and Electric Company U. U.S. Department of Agriculture V. U.S. Environmental Protection Agency The staff's consideration of comments is reflected in the following discussion.

In Appendix C (which reproduces all the letters received), each commenter is identified by a letter * (A through V), and each comment is numbered. Responses in this section refer to that identification.

i *The licensee, Pacific Gas and Electric Company, received copies of all public comments and voluntarily responded. (Shiffer, 1986). The NRC retained the same alphabetical designation assigned by PG&E to minimize confusion.

l Humboldt Bay Unit 3 FES 9-1 1

i . . - _ , - _ _-- . - - _ _ . - -

Responses to Comments of California Coastal Commission (A)

A-1 The scope of the descriptive material is tailored to that necessary to assess and evaluate impacts. Airborne and waterborne releases of any sub-stances to the offsite environment during the SAFSTOR stage of decommis-sioning will be small. In the absence of significant anticipated releases, and thus no anticipated mechanism for impact, detailed discussion of the environmental setting would serve no useful purpose. The licensee's Envi-ronmental Report (ER) Section 4 (Schuyler, 1984) does provide a more detailed discussion of the environmental setting of Humboldt Bay Unit 3.

Sixty species of fish, 38 species of plants, and 57 species of birds known to the area are listed in the ER. The climatology, topography, hydrology, ecology, and demography of the site are given.

With respect to requirements of the California Coastal Act, the licensee indicates (Shiffer, 1986) that it will continue to coordinate activities at Humboldt Bay Unit 3 with the California Coastal Commission. The licensee, however, does not anticipate that the activities conducted during the SAFSTOR period will require any Coastal Commission permits. Although the NRC does not evaluate State or local permits, the staff expects the licensee to comply with State and local government requirements.

A-2 Leakage from the spent fuel pool to the groundwater is prevented by peri-odic operation of the liner gap pump. The water from the liner gap is pumped to the radwaste system. The pump is operated about once per week for 10 to 15 minutes to maintain the liner gap level below both the pool water level and groundwater level (Shiffer, 1986). If the pump fails to operate, the change in liner gap water level is slow enough that the pump could be repaired or replaced before the water level in the gap exceeded Technical Specification (TS IV-A.2) limits. See also response to comment L-8.

There are no plans to increase the amount of radioactive contamination in the pool water. The amount of radioactive contamination in the pool water is controlled with an ion-exchange purification system.

DES /FES Appendix B estimates potential exposure to the public from liquid and gaseous effluents during SAFSTOR. The level of these exposures is a small percentage of natural background and does not indicate a need for mitigation.

A-3 The DES /FES (Section 3.2.3) evaluates postulated accidents that could be caused by seismic or other events. No credit is given for the seismic design or integrity of the facility structures or components in evaluating the consequences of a postulated accident. The structures are assumed to fail in the analysis. In each accident analysis, the potential exposure to the public has been shown to be well below EPA Protective Action Guide levels.

A-4 The independent spent fuel storage installation (ISFSI) is not rejected or accepted by the DES /FES. Seismic considerations of an ISFSI would be necessary for that fuel storage alternative if it were selected by the l Ifcensee. Section 3.2.3 of the DES /FES, "Postelated Accidents," considers seismic events in evaluating the SAFSTOR alternative.

I I Humboldt Bay Unit 3 FES 9-2

-.- - - _-___ - =- - . .- . - , -- , -_ . -

i

! Seismic requirements for an operating nuclear reactor are much more exten-sive than those for a plant that has been permanently shut down. During plant operation much safety-related equipment needed for safe reactor shut-

, down, such as the emergency core cooling system, must remain operational during and after a seismic event. There is no safety related safe shutdown equipment now required at Humboldt Bay Unit 3. The reactor has not operated for more than 10 years. The decay heat now generated in the spent fuel has decreased to a level that no longer needs cooling systems to prevent 1

fuel melting. The fuel can be adequately cooled without water by the natural convection of air (Shiffer, February 1985).

) The DES /FES considers the 30-year SAFSTOR period because that is the i period of time requested by the licensee. A Federal repository should be available for disposal of the spent fuel within 30 years.

l A-5 The high-level waste at the Humboldt site is the spent fuel. The spent fuel is in solid, zirconium-clad form in the fuel assemb'tes and will be stored in the spent fuel pool until a Federal repository is available.

All other radioactive waste at the site is considered low-level waste.

i The licensee is disposing of some of this low-level waste at the U.S.

j Ecology site, Richland, Washington, in preparation for SAFSTOR. When the l facility is dismantled after the fuel has been shipped off site, the i

remaining low-level waste will probably be disposed of at a State of California low-level waste burial site. Part of the reactor vessel and l some of the reactor internal components may exceed 10 CFR Part 61 Class C j low-level waste burial limits at the time the facility is dismantled (after the SAFSTOR period). The U.S. Department of Energy (DOE) is responsible

for storage and disposal of low-level waste that exceet Class C limits.

A-6 See response to comment L-15.

f ,

q i A-7 The licensee lists chemical agents in Table 10.5.9 in the Environmental Report (Schuyler,1984) that may be used during final DECON/ dismantling of the plant. These chemical agents are not stored on the site now nor will they be. If chemical decontamination is used as part of the DECON opera- ,

tions at the end of the safe storage period, they would be brought on site l l at that time. The licensee is required to submit a DECON/ dismantling plan i before dismantling the plant. A DECON/ dismantling plan must include an l

analyses of the safety and environmental impacts of any chemicals to be 4

used in decontamination.

l The licensee's Environmental Report (Schuyler,1984) and a letter to the California Regional Water Quality Control Board (Shiffer, October 1985) l lists and evaluates hazardous materials existing on site during the SAFSTOR l period as well as the intended disposal methods. With the exception of j small quantities of laboratory reagent chemicals, the licensee does not i plan to store or use any chemicals at Humboldt Bay Unit 3 during the SAFSTOR l period. Waste discharge requirements are stated in Order No.85-110 from l the California Regional Water Quality Control Board North Coast Region (Shiffer, October 1985).

A-8 There is no high-level waste disposal site anywhere in the United States

{ at this time. The Shippingport fuel is federally owned and, therefore, may be transferred to a Federal site for storage. The TMI-2 fuel, which was l

involved in a loss-of-coolant accident, is being sent to the DOE site in Humboldt Bay Unit 3 FES 9-3

Idaho for research and analysis. 00E does not now accept commercial power reactor fuel for reprocessing or disposal at any of its sites.

The staff has determined that the Humboldt Bay Unit 3 fuel can be stored, without a significant environmental impact in the spent fuel storage pool until a Federal repositc.y is available. Also, in 10 CFR 51.23a, the Commission has made a generic determination that for at least 30 years beyond the expiration of reaccor operating licer.ses, no significant environmental impacts will result from the storage of spent fuel in reactor facility storage pools.

A-9 The Carlsbad facility is not available nor is it under consideration by the Department of Energy for disposal of any commercial high-level waste. It is a deep geological facility that was tested for potential use for disposal of high-level waste.

A-10 The disposal of the reactor vessel and other major radioactive parts of Humboldt Bay Unit 3 must be analyzed in the licensee's DECON/ dismantling plan which must be submitted to the NRC and approved before dismantling operations commence. The NRC will evaluate the licensee's proposed method for disposal of the reactor vessel as part of its review of the DECON/

dismantling plan. Dismantling can not occur before the fuel is shipped because the fuel storage pool is an integral part of the reactor shield structure.

A-11 Costs and funding for the Humboldt Bay Unit 3 decommissioning have been proposed by the licensee before the State of California Public Utilities Commission (CPUC). On December 4, 1985, the CPUC authorized the licensee to collect, in an external or trust fund, the necessary decommissioning funds (estimated to be $58 million in 1986 dollars) over a 4 year period (Shiffer, 1986).

A-12 The licensee is subject to all local and State regulations in addition to NRC regulations. The licensee indicates (Shiffer, October 1986) that a permit from the California Coastal Commission may be required before start of DECON operations following the storage period.

A-13 The DES /FES (Section 3.2.3.7) assumes that there is an uncontrolled release from the radwaste tanks to ensure that the staff has considered the worst-case scenario in its accident analysis. The licensee indicates (Shiffer, October 1986) that there are mitigating systems which would reduce the consequences of this accident. The radwaste tankage system is prnvided with a radwaste sump and tankage area berms that vould reduce the impact of an accidental release from the radwaste tanks. Staff analysis demon-strates, however, that even without mediation the potential releases would not exceed the limits specified in 10 CFR Part 20 for unrestricted areas.

A-14 The impact of a rupture of the spent fuel pool is evaluated in Sec-tion 3.2.3.6. The evaluation indicate , potential exposure.s to the public to be a small fraction of background radiation if such an event were to cccur. See also response to comment C-24. The licensee does not antici-pate that a Coastal Development Permit will be required for SAFSTOR l

activities; but such may be required for DECON/ dismantling activities at the end of the storage period.

Humboldt Bay Unit 3 FES 9-4 l

A-15 The emergency plan is evaluated in the NRC's Safety Evaluation Report (SER)* related to the proposed decommissioning plan. The licensee's pro-posed emergency plan was submitted by letter dated April 4, 1985, as re-vised June 12, 1986 and January 20, 1987. The emergency plan is available in the Local Public Document Room at the Eureka-Humboldt County library.

Evacuation of offsite areas is not required for any accident at the Humboldt plant since postulated accidents would result in potential offsite exposures that are less than Environmental Protection Agency (EPA) protec-tive action guides (see Section 3.2.3 of the DES /FES).

A-16 The fuel will be shipped off site when a Federal repository is available.

There are no NRC or non-NRC spent fuel disposal sites in the United States at this time. Any extension of the possess-but-not-operate license beyond 30 years would require further NRC review and approval.

A-17 The staff agrees that the Humboldt facility is not a permanent waste re-pository. This FES and the staff's associated safety evaluation of the proposed SAFSTOR decommissioning do not support permanent storage of spent fuel at the site. The staff has evaluated the 30 years of SAFSTOR as proposed by the licensee. Also, see response to comment A-8.

Responses to Comments of U.S. Department of Health and Human Services (B)

B-1 No response is required.

B-2 The Technical Specifications (TS) that will be issued with an amendment approving SAFSTOR will require a stack gas monitoring system, a process water monitor, and monitoring of discharge canal water. The TS require J that the results of radiation monitoring be reported to the NRC on an annual basis. Copies of these reports are also sent to the California Department of Health Services and the Local Public Document Room at the Eureka-Humboldt County library.

B-3 No response is required.

B-4 No response is required.

B-5 See response to comment A-15.

Responses to Comments of the Sierra Club (C)

C-1 The DES /FES meets the standard referenced in Andrus v. Sierra Club. The and direct, indirect, and cumulative effects of the proposed action were found C-2 to be small. In this context, small means acceptable without the need to consider further mitigation. The 06S and FES are predecisional documents.

Findings are those of the staff. The decision on the proposed amendment is yet to be made. The staff is aware of no realistic environmental con-sequence other than those set forth in the DES /FES. The FES Summary and ,

Conclusions (page v) and Conclusions (Section 5) have been revised to re- I flect more clearly the staff's evaluation of spent fuel storage alternatives. l "The SER will be publicly available and provided to the Atomic Safety and Licensing Board (ASLBP No. 86-536-07 LA) that presides over the proceeding concerning the licensee's SAFSTOR application.

Humboldt Bay Unit 3 FES 9-5

C-3 See response to comment A-1.

C-4 Section 3.2.3 of the DES /FES addresses " Postulated Accidents" including and fuel pool rupture and other assumed accidents that may result from seismic C-5 events. Also see responses to comments A-3 and A-4 with respect to seismic analysis.

C-6 See responses to comments C-1 and Q-3. l C-7 DECON would probably be preferable for this single-unit nuclear plant if and spent fuel could be sent to a Federal repository. There is however, no l

C-8 repository, Federal or private, for the spent fuel. Entombment is un-acceptable because fuel is stored on site and because of long-lived radionuclides such as niobium-94 which has a 20,000 year half-life.

C-9 There is no Federal or private respository or reprocessing facility for licensed spent fuel at this time. Interim spent fuel storage at DOE facilities is not available for a licensed plant undergoing decommis-sioning. The Waste Policy Act of 1982 (HR 2809) specifies that 00E storage is available "only if the Commission determines that adequate storage capa-city to ensure the continued orderly operation of the civilian nuclear power reactor at which such spent nuclear fuel is generated cannot be rea-sonably provided by the person owning and operating such reactor at such site or at the site of any other civilian nuclear power reactor operated by such person" The Humboldt Unit 3 plant is permanently shut down. Furthermore, adequate storage space is available and being used on the Humboldt site; therefore, 00E interim storage would not be available for Humboldt Unit 3 fuel. The Shippingport reactor and fuel are owned by the Federal Government and Federal storage is, therefore, available for the fuel. The Three Mile Island fuel was sent to DOE for research purposes because the reactor had been involved in an accident.

C-10 See responses to comments A-3 and A-4.

C-11 The conclusion that the probability of criticality in the spent fuel stor-age area as a result of a seismic event is negligibly small is based on engineering judgment. Negligibly small means, in this context, that the probability of occurrences is so small that the consequences of such an event do not need to be evaluated.

The judgment that the probability of criticality is negligibly small is based on the following considerations:

The amount of boron poison to be included in the storage racks was chosen to ensure that the K eff values would be less than 0.95 when the parameters which govern criticality were all at their most conservative values simultaneously. The actual value obtained was 0.894 for these conditions.

The most conservative parameter for which the racks were evaluated include:

(1) the storage cans in contact with each other Humboldt Bay Unit 3 FES 9-6

(2) the racks filled with fresh fuel of 2.52 weight percent uranium-235, which is greater than the highest possible enrichment present among i

the fuel assemblies (3) the water at full density (4) the water-to-fuel ratio in the assemblies at the value which yields the highest reactivity 1

(5) the fuel pellets at maximum density (6) no credit taken for the burnup in the fuel or the presence of gadolinium (7) infinite size for the assembly i

Any departure from these assumed conditions will result in a reduction of the K eff values of the racks. For example the reduction in K,ff above due to the minimum burnup (1307 MWD /T) is estimated to be 0.013 to 0.018. The 4 distortion of the racks and/or fuel assemblies during a seismic event will lead to a reduction in Keff since the analyses have been performed for the most reactive configuration.

C-12 The term " spent" fuel is in common use throughout the nuclear industry and by Congress, as in the " Waste Policy Act of 1982." The staff agrees that " completely spent" fuel means fuel that is not suitable for further operation in a reactor, but that it is radioactive. The words " partially or completely" have been deleted from FES Section 2.1 as they are not l needed. The total fission product inventory of the spent fuel is specified in curies.

l The spent fuel pool cover is used to provide a contamination barrier between -

the water in the pool and the refueling building, to allow air above the pool to be exhausted through the ventilation system to the stack, and to prevent dust and foreign materials from entering the pool. The cover was designed in accordance with the uniform building code (Shiffer, 1986).

C-13 The proposed TS to be issued with the license amendment approving the

. SAFSTOR alternative require the liner gap pump to be operational and the level of water in the pool liner gap to be maintained below a specific limit. The limit has been established to ensure that water from any leaks flows into the liner gap from both pool water and ground water sources.

See also response to comment L-8.

C-14 See response to comment L-9 with respect to schedules. See response to comment C-13 with respect to maintaining water level in pool liner gap.

There is no indication that soil contamination is migrating; however,  !

sample wells in the vicinity as well as the cooling canal are monitored l l for radioactivity and would detect any migration of radionuclides. Any soil contamination above levels acceptable for release to unrestricted access must be removed at the end of the storage period when the facility is dismantled. The major activated and contaminated structures'of the l Humboldt Bay Unit 3 FES 9-7 l

facility, such as the reactor vessel, reactor shield, and reactor cooling system can not be removed at this time because the spent fuel pool is an integral part of the reactor shield structure. Minor decontamination has been done and will continue to be done as part of placing the facility into a SAFSTOR status.

C-15 TS requirements specify limits on the allowable radionuclide concentra-tions in any liquids released to the bay from Humboldt Bay Unit 3. These restrictions apply whether the two fossil units are operating or not. If the fossil units were not in operation, the licensee would have to estab-lish other methods for decreasing the radionuclide concentrations in liquids that are released.

C-16 NUREG/CR-0672 entitled " Technology Safety and Costs of Decommissioning a Reference Boiling Water Reactor Power Station" was prepared by Battelle Pacific Northwest Laboratories (PNL) for the NRC. The NRC staff consi-ders these estimates from pages 11-20 and 11-21 of NUREG/CR-0672 to be conservative for the Humboldt plant since these values were calculated by Battelle for an 1100-MWe plant as compared with the 65-MWe Humboldt plant.

C-17 The DES /FES evaluation is based to a large extent on information in the licensee's Environmental Report (Schuyler, 1984). The PG&E estimate for SAFSTOR with delayed DECON is 177 person rems occupational radiation expo-sure. PG&E estimates 685 person-rems occupational exposure for immediate DECON. Although occupational exposure for entombment (ENTOMB) is not

', calculated by the licensee, calculations by Battelle PNL in NUREG/CR-0672 indicate that ENTOMB would result in occupational exposure between that for SAFSTOR and that for immediate DECON.

C-18 The TS proposed by the licensee specify that the activity of any liquids discharged into Humboldt Bay shall not exceed the limits given in 10 CFR Part 20, Appendix 8, Table II on an instantaneous basis. These proposed TS limits are more restrictive than the requirements of the regulations

[10 CFR 20.106(a)]. The NRC staff has found these TS limits to be adequate.

C-19 See responses to comments C-12 and L-17.

C-20 The Boral is a composite of neutron-absorbing boron carbide dispersed in an aluminum alloy matrix that is clad in aluminum (Shiffer, 1986). It has been in use at Oak Ridge National Laboratory for more than 25 years and has been licensed for use in about 30 of the spent fuel pools at commer-cial reactor sites (Shiffer, 1986).

There have been two instances of fuel rack swelling when Boral was used but there was no detectable loss of neutron-absorbing effectiveness. In both instances, water-aluminum reactions in the Boral plates caused the swelling. Fabrication procedures for the Humboldt plants and at other facilities have been revised to correct this problem (Shiffer, 1986) by venting the Boral cavity to prevent gas accumulation and subsequent swelling. PG&E has also e:,tablished a surveillance program with 25 sample coupons which will be installed in the spent fuel pool adjacent to the spent fuel. Proposed TS require that representative samples be periodi-cally removed, inspected, and tested to ensure that neutron absorption of the Boral inserts remains effective.

Humboldt Bay Unit 3 FES 9-8

C-21 The NRC assumed that one row of pins in each of the two assemblies would be damaged (6 pins in each assembly), which is reasonably conservative.

If, however, all of the pins in both assemblies were damaged so that all of the krypton-85 gap activity was released, the calculated whole-body-dose at the exclusion area boundary would be increased by a factor of six.

The projected dose would still be well below Protective Action Guide levels of 1 to 5 rem.

C-22 See response to comment C-20.

C-23 See response to comment C-11 with respect to the comments on reactivity and criticality. The PAG dose levels are 1 to 5 rem. Therefore, in DES /FES Section 3.2.3.5, the calculated dose committments, which are all less than 1.0 millirem, are less than 1/1000 of 1 rem and less than 1/5000 of 5 rem.

Similar comparisons to PAG dose levels could be done for other postulated l accidents.

C-24 The groundwater transport parameters having a significant effect on net radionuclide transport into Humboldt Bay are as follows:

(1) permeability (2) groundwater gradient (3) retardation coefficients The permeability of the soil between the spent fuel pool and the bay was determined by the licensee from tests performed by Dames and Moore, and by Bechtel. The permeability measured ranged from 2000 ft/yr to 10,400 ft/yr.

Hence, the licensee's choice of 10,400 ft/yr represents the highest (most conservative) reasonable value for permeability.

The groundwater gradient used by the licensee was determined from the dif-ference between the rainy season groundwater level and mean tide level (5.7 ft) divided by the distance from the spent fuel pool to the bay (420 ft). This gradient resulted in a travel time of about 9 months for the effluent to reach Humboldt Bay. If the water level in dry season had been used to calculate the gradient, the effluent travel time would have increased to more than 1-1/2 years.

In regard to the distribution coefficients, the licensee chose a value of 20 ml/g for cesium-137, 15 ml/g for cobalt-60, and 1.5 ml/g for stron-tium-90. In the staff's analysis, a value of 1.5 ml/g was assumed for cobalt-60, and cesium and strontium were assumed to be the same as in the licensee's analysis. The coefficients for cesium and strontium are at the l low end of the range of values for distribution coefficients for soils as listed in NUREG/CR-0912 (Dana Isherwood, Geoscience Data Base Handbook for i Modeling a Nuclear Waste Repository, Lawrence Livermore Laboratory, 1981).

Cobalt was given an artificially low distribution coefficient because it was not a major contributor to dose and therefore could be treated conser-t vatively. In fact, if the cobalt is not held up at all in the soil, the l dose will increase less than 10%.

I As stated in Section 3.1.3 of the DES /FES, tidal flushing of Humboldt Bay is great, with about a 44% exchange of water on each tidal cycle. With this type of exchange, it may be assumed that any radionuclide in Humboldt Bay Unit 3 FES 9-9

solution entering the bay will be quickly mixed and dispersed throughout the bay. Arproximately one-half of any dissolved contaminant entering the bay is likely to be flushed out into the Pacific Ocean within every 24-hour period. Once it leaves the estuary it does not contribute significantly to the population dose. Instead of trying to estimate the time-varying concentration of radionuclides in the bay to compute dose rates, the staff conservatively assumed that all of the radionuclides which can enter the bay would reside there for one year. The staff is confident that this assumption is conservative in that it will result in an estimate of popula-tion dose (DES /FES Sections 3.2.3.6 and 3.2.3.7) many times larger than.the l actual dose. '

C-25 See responses to comments C-11 and C-23.

The review of the licensee's proposed TS is provided in the staff's SER (see footnote for response to comment A-15).

Bounding pathways for exposure from liquid and gaseous releases have been analyzed for normal and accident situations. See DES /FES Section 3.2.3 I

and Appendix B.

C-26 See response to comment C-17.

C-27 Occupational exposure comparisons are given in response to comment C-17.

The NEPA process does not require quantitative selection of the best alternative. A quantitative selection is neither necessary nor possible for all factors in each alternative.

Responses to Comments of Redwood Alliance (D)

D-1 See responses to comments A-1 and C-1.

D-2 The NRC staff organized the scoping meeting in accordance with 10 CFR 51.26, 51.27, and 51.28. The results of this meeting were used to help develop the scope and identify the issues to be presented in the DES. Although the DES

did address the significant issues, there is no regulatory requirement to identify each meeting comment and respond specifically to it in the DES.

Comments submitted on the DES are specifically responded to in this FES.

A transcript of the scoping meeting is available in the Local Public Docu-ment Room in the Eureka-Humboldt County Library, Eureka, California. Copies of letters received after the scoping meeting are also available in the Eureka-Humboldt County Library.

] D-3 See response to comment C-9.

D-4 See responses to comments A-4 and C-9. Criticality potential of stored fuel is evaluated in Section 3.2.3.4 of the DES /FES.

D-5 See response to comment A-1.

D-6 DES /FES Section 3.2.3, " Postulated Accidents," evaluates the licensee's analysis and provides an independent assessment of accidents caused by seismic or other events. Section 4.1.3 and Appendix 10.3 of the licensee's Environmental Report (Schuyler, 1984) discuss the seismology of the area.

l l Humboldt Bay Unit 3 FES 9-10

l l

l l

D-7 Section 3.2.3 of the DES /FES provides an evaluation of the licensee's en-vironmental analysis (Schuyler, 1984; Shiffer, February, April, and July '

1985) and of postulated accidents caused by catastrophic earthquakes or other events. The licensee must submit a detailed dismantlement plant for NRC review and approval before start of dismantlement.

0-8 See response to comment C-24. Postulated accidents involving spent fuel pool rupture and uncontrolled release of radwaste tank contents are evaluated in Sections 3.2.3.6 and 3.2.3.7 of the DES /FES.

D-9 See response to comment L-8.

D-10 The facility cannot be dismantled until the fuel is shipped off site as discussed in response to comment A-10. Fuel shipment cannot be done now as discussed in response to comment A-8. Even though seine shorter-lived isotopes may have decayed to very low levels, cobalt-60, with a 5.2 year half-life, is still present in the reactor vessel in an amount which is a significant exposure concern for any dismantling operations.

D-11 See response to comment L-15. The radwaste building is not intended for additional onsite storage of radioactive waste. It will reduce the possibility of environmental contamination by providing weather protection j for the existing radwaste facilities.

D-12 See response to comment A-7.

D-13 Radwaste is not directly discharged into Humboldt Bay. It is sent to the radwaste facility where it is processed through an ion-exchange system to remove radionuclides. Any water released to the discharge canal which flows into the bay must meet TS limits.

D-14 See response to comment C-12.

0-15 See response to comment C-20.

0-16 See response to comment L-9.

D-17 See responses to comments C-13 and L-8 with respect to pool leakage. See response to comment K-12 with respect to funding of decommissioning.

D-18 See response to comment C-11.

D-19 Trucking of low-level radioactive waste to a licensed waste burial facility in preparation for SAFSTOR and during SAFSTOR is minimal and has no sig-nificant environmental or public exposure impact (DES /FES, page 3-4, second paragraph).

Responses to Comments of Elton Adams / June Crym (E)

E-1 The DES /FES does not state that ENTOMB is impractical in an area where seismic occurrences could rupture the casings. The DES /FES states that the need for spent fuel storage safety provisions (full-time security force and adequate radiation monitoring and environmental surveillance) and the presence of long-lived radionuclides makes it impractical to en-tomb Humboldt Bay Unit 3 (DES /FES Section 1.3.2).

Humboldt Bay Unit 3 FES 9-11

See response to comment L-5 with respect to seismic occurrences and ENTOMB.

Spent fuel pool water is processed by circulation through an ion-exchange column in the proposed SAFSTOR option. The ENTOMB option does not permit a spent fuel pool purification system because it would be required to be located within the entombment structure and would not be accessible for maintenance, repair, and resin replacement.

i No liquid waste is stored on site. Any water that is contaminated with I radionuclides is sent to the radwaste system for processing by ion exchange systems or by evaporation.

E-2 See response to comment C-11.

Responses to Comments of Nancy Hiefiker (F).

F-1 A " Notice of Opportunity for Prior Hearing" on the Humboldt Bay Unit 3 decommissioning was published in the Federal Register on July 3, 1986 (51 FR 24458) Five individuals and one organization filed a request for hearTng and petition to intervene. A prehearing conference was held on October 21, 1986 in the Eureka Inn, Eureka, California. Further develop-ments with respect to the requested hearing will be available in the Local Public Document Room at the Eureka-Humboldt County Library in Eureka, l California.

F-2 Appendix B of the DES /FES evaluates potential public exposures to radio-activity from Humboldt Bay Unit 3 during the SAFSTOR period.

Responses to Comments of Thomas P. Infusino (G)

G-1 See responses to comments A-4, C-1, and C-9.

and G-2 G-3 See response to comment A-4. The FES Section 1.3.3 has been revised to and discuss the additional handling and shipment required by offsite storage.

G-4 Revision also recognizes that an ISFSI would result in increased worker exposure and an increased potential for shipping and handling accidents.

G-5 See responses to comments A-1 and G-8 for discussions of impact on flora and fauna.

G-6 See responses to comments A-2 and L-8.

G-7 See response to comment C-24. TS requirements for the spent fuel pool will be imposed as part of the issuance of the amendment approving the SAFSTOR Decommissioning Plan. The TS specify that pool liner gap water level shall be maintained at an elevation that is below the level of pool water and also below the groundwater level. Therefore any inleakage of water from pool or groundwater will be pumped to the radiation waste treat-ment system. The TS also require onsite monitoring of the water in the discharge canal and of groundwater for radionuclide contaminants.

Humboldt Bay Unit 3 FES 9-12

G-8 The radiation protection guides for humans are so stringent as to protect other life forms from lethal effects. Relatively little is known about sublethal effects on other species. However, it is reasonable to expect that the relative occurrence of sublethal effects will parallel occurrences in human populations. The expectation of minimal exposures of humans (DES /

FES Section 3.2.3 and Appendix B) would be paralleled in other species.

G-9 For a single-unit plant with fuel stored on site, the SAFSTOR alternative

, is estimated to cost somewhat more than DECON because of the added cost of continued security guards on site and the cost of maintaining the stor-age pool and associated monitoring equipment. Since immediate DECON is not a reasonable alternative for the Humboldt plant, the cost difference is not a part of the staff's decision process. The Battelle studies, NUREG/

CR-0672 and NUREG/CR-0130, also predict a higher cost for the SAFSTOR alternative. See response to comment A-11 with respect to the cost of the SAFSTOR alternative. See response to comment C-17 with respect to occupational radiation exposures for various alternatives.

G-10 The DES did in fact review (as does the FES) the environmental aspects of spent fuel storage at the Wmboldt Bay Unit 3 site even though 10 CFR 51.23b indicates that none is required for the 30 year storage period. The com-menter seems to misinterpret the rule. See also response to comment C-1.

G-11 With respect to fuel storage at the Humboldt Bay Unit 3 site, the licensee did in fact add the neutron-absorbing Boral cans around each fuel assembly to " decrease the probability and mitigate the consequences of any criti-cality accident" (DES /FES Section 3.2.3.4). This modification was done in response to the NRC review.

G-12 See responses to comments G-9, G-10, and K-12. Appendix B of the DES /FES evaluates the potential exposures to the public from liquid and gaseous discharges during the SAFSTOR period.

Responses to Comments of Ralph Kraus (H)

H-1 See response to comment A-1.

and H-2 H-3 See response to comment L-17.

H-4 See responses to comments A-1 and L-11.

Responses to Comments of Larry Lancaster (I).

1 I-1 The DES was sent to other Federal agencies as well as to State and local agencies (DES /FES, Section 8). Comments from these agencies and others are included in the FES as well as the staff's responses to these comments.

The DES was distributed to Federal, State and local agencies in accordance with 10 CFR 51.74. The Resources Agency of California, Sacramento, CA, coordinated the review of the DES with the California Coastal, Energy and l Humboldt Bay Unit 3 FES 9-13

Public Utilities Commissions; the Air Resources, Reclamation, and Regional Water Boards; and the Departments of Boating and Waterways, Conservation, Fish and Game, Parks and Recreation, Water Resources, Health Services, and Transportation. See Appendix C of FES (p. 2) for letter from Resources Agency of California which provided comments from California Coastal Commission.

I-2 The half-life of cobalt-60 is 5.2 years, not 10.6 years. Cesium-137 is the dominant gamma-emitting fission product in the spent fuel. Cesium-137 has a half-life of 30 years.

The mass of the spent fuel does not change. The residual radioactivity does decrease by about 50% in 30 years, however.

The component parts e the reactor structure may be activated and contam-inated with cobalt-60 and cesium-137. The cobalt-60 radiation levels will decrease by more than 98% in 30 years. The cesium-137 radiation levels will decrease by about 50% in 30 years.

I-3 See response to comment A-8.

I-4 The EPA Protective Action Guide (PAG) levels are public (community) expo-sure levels above which protective actions may be warranted.

1-5 Tables B.3 and B.4 of Appendix B in the DES /FES give the calculated annual dose commitments to an individual at 0.32 km (less than 1/5 mile) from Humboldt Bay Unit 3. This calculated dose commitment is for the age group and organ that results in the highest cumulative dose at that location.

The maximum annual exposure from the Humboldt Bay plant in the SAFSTOR mode is calculated to be less than 1% of natural background radiation.

Postulated accidents are evaluated in Section 3.2.3 of the DES /FES. Doses are evaluated at the site boundary assuming that this location is downwind.

The maximum resultant exposure is calculated to be less than PAG 1evels.

I-6 See response to comment A-3.

I-7 Diagrams and an analysis of the spent fuel racks are included with the licensee's submittal dated July 30, 1985 (Shiffer) and in the SER. The licensee's submittal and the SER are available in the local Public Docu-ment Room at the Eureka-Humboldt County Library.

Responses to Comments of Michael J. Manetas (J).

J-1 The DES /FES has evaluated the impact of loss of pool water caused by a seismic or other event (see DES /FES Section 3.2.3.6). No credit is given for the seismic integrity of plant structures. That is, it is assumed that all structures will fail.

J-2 If the leakage rate through the liner were to increase, the pumping fre-quency (now needed about once per week for about 10 to 15 minutes) could be increased (Shiffer, 1986). See response to comment L-8.

J-3 Postulated accidents are evaluated in Section 3.2.3 of the DES /FES.

Humboldt Bay Unit 3 FES 9-14

l J-4 The DES /FES analysis indicates that the population arc"nd Humboldt Bav wad not .. ave to me evacuated in L.e event of an acc.oent. Poten u o ,

exposures from accidents would be less than EPA Protective Action Guides.

l See DES /FES Section 3.2.3. The integrity of U.S. 101 is not a factor when no evacuation is required.

Responses to Comments of the Acorn Alliance (K).

l K-1 See responses to comments A-3 and A-4.

K-2 Other alternatives, their advantages, and their disadvantages are discussed in Section 1.3 of the DES /FES. See also response to comment C-9.

See response to comment C-11 with respect to " negligibly small likelihood" of criticality.

3 K-3 The magnitude of the earthquake would r.ot change the results of the 1 analysis. Polar cap melt is considered very remote and would not occur suddenly. Tsunamis are considered in the staff's safety evaluation of the amendment to the license, lhe licensee will be required to maintain i a security system that is reviewed from the safeguards perspective by the NRC. Hypothetical wartime events are beyond the scope of the DES /FES.

1 K-4 The Federal repository, although projected to be ready by 2003, may not be available for the Humboldt Bay fuel until a later time because of priority disposal of other fuel. Exposure levels for workers, although reduced in

! 26 years, will have further reduction in 12 additional years. Cobalt-60, 4

with a 5.2 year half-life, is the major contributor to exposure during dismantling of a reactor facility.

K-5 The Harris, Illinois spent fuel storage facility is not accepting any s additional spent fuel beyond that presently contracted for. See response to comment K-30. Section 1.3.3 of the DES /FES evaluated shipment of spent fuel to Diablo Canyon. The Nevada test site does not currently have

. facilities for accepting spent fuel. Also see respnnse to comment A-8.

! K-6 See responses to comments E-1 and L-5.

K-7 The DES sentence is misquoted in the comment. The DES /FES reads "all fuel 1 assemblies should be removed from the reactor and radioactive fluids and i

wastes should be removed from the site." The radioactive fluids are being concentrated and solidified and shipped with the solid wastes to low-level I waste burial grounds such as the licensed facilities in Nevada and the

, State of Washington. The spent fuel is classified as high-level waste and remains in the spent fuel pool. Seismic conditions at the Humboldt Bay site are considered in the DES /FES evaluation of " Postulated Accidents,"

Section 3.2.3. No credit is given for the seismic integrity of the facil-ity structures or components in the accident analysis.

l K-8 FES Section 1.3.3 has been revised to clarify the impact of constructing an independent fuel storage installation vs. the use of onsite fuel storage.

K-9 See response to comments A-2, C-12, and L-8.

! Humboldt Bay Unit 3 FES 9-15 1

j M

K-10 See responses to comments C-13 and L-8.

K-11 The 30 year time period proposed by the licensee provides a reasonable leeway for implementation of the Nuclear Waste Policy Act with respect to disposal of spent fuel at a Federal repository.

K-12 PG&E applied to the State of California Public Utilities Commission for a rate increase to fund the decommissioning of Humboldt Bay Unit 3. The California Public Utilities Commission approved the rate increase with funds to be held in an external reserve (Shlffer, 1986). Costs of decom-missioning are given in the PUC Ruling on Humboldt Bay Unit 3 (provided as Appendix A to the SER).

K-13 The rate of release of decay heat begins decreasing as soon as the reactor is shut down. Section 3.1.3 has been revised to read "because a long time (more than 10 years) has elapsed since the reactor has operated it is no longer necessary to operate the fuel pool cooling system."

K-14 See response to comment G-8.

K-15ion-exchange The quality /demineralizer i,ystem.of Also the water water frominanythefurther spentcleanup fuel poolof is m contaminated areas during SAFSTOR period would be sent to the Ifquid waste treatment system. All unneeded systems, such as the reactor cooling system and the suppression pool have been drained. If the fossil-fueled units are not in operation, that further dilution, by the cooling water flow for these units, would of course not occur.

10 CFR Part 20 and the Technical Specifications specify maximum concentra-tions allowed for each radionuclide in any water that is discharged from 1

the fr.cility.

The sentence in Section 3.1.7 about metallic products has been revised to say "In addition, although...."

K-16 DES /FES Appendix B quantifies the impact of potential releases of liquid and gaseous radioactive effluents during the SAFSTOR period.

Radiation inventory of the fission products in the fuel will be reduced by approximately 25% in 15 years. This is based on the 30 year half-lives for fission products cesium-137 and strontium-90. Radiation inventory of gamma-emitting radionuclides in the activated components of the reactor will be reduced by approximately 85% during that 15 year period since cobalt-60, with a 5.2 year half-life, is the dominant activation radionuclide.

K-17 Immediate dismantling would result in higher work-force exposures. Although the estimates for immediate dismantling of the Humboldt Day plant are not i given, studies by Battelle PNI (NUREG/CR-0672) indicate that dismantling

now would result in about four times as much exposure as dismantlement af ter 30 years of SAFSTOR.

i K-18 The floors and walls of the refueling building and external surfaces in other spaces ire decontaminated to make access to these areas easier for maintenance and inspection during the SAFSTOR period.

Humboldt Bay O.'t 3 FES 9-16 l

- - - _ - _ - - - - - - . - - - . - = - - - -

K-19 Each batch is tested before release. The TS specify limits for release.

l See resnonse to comment C-18.

K-20 Spent cartridge-type filters and filter crud will be packaged in drums and and stored in the 1200 cubic foot underground vault, a shielded shipping con-K-21 tainer, or another shielded area, until there is enough radioactive waste to justify shipment to a licensed burial ground. During the SAFSTOR period, the radiation levels and volumes of the waste will be considerably reduced from levels that were present during reactor operation. The only trans-l uranics present at the facility would be in the spent fuel which will be sent to a Federal repository when one is available.

K-22 The NRC license does not specify where the waste must go. The selection

of a site by PG&E will be affected by activities under the low-level Radioactive Waste Policy Act (PL 96-573).

I K-23 See responses to comments C-11 and C-20.

K-24 See Section 3.2.3.4 of the DES /FES and response to comment C-11.

K-25 See response to comment C-11.

l K-26 See response to comment C-24. Also see DES /FES Section 3.2.3.6 which

, analyzes " Spent Fuel Pool Rupture."

K-27 The worst-case release scenario as evaluated in DES /FES Section 3.2.3.3 is i

" Fuel Assembly Damage Caused by Non-Hechanistic Heavy Load Drop or Site-Related Hazards." These estimates were made by the staff.

l K-28 See response to comment C-24. '

K-29 See Appendix B of the DES /FES. Appendix B calculations for maximally ex-

, posed individuals assume individual consumption of well-above-average quantities of affected foods (DES /FES Appendix B, Section 2(a)).

K-30 DECON is not feasible for reasons discussed in Sections 1.3.1 and 1.3.3 of i the DES and response to comment A-10. The Morris. Illinois commercial fuel storage facility is not accepting any spent fuel for storage that is not currently under contract. Fuel from Elk River was transferred to a Federal reprocessing facility since the facility and its fuel were owned by the Federal Government (U.S. Atomic Energy Commission). Personnel ex-j posure would be greater if DECON were done now rather than later. Removal ,

of the reactor vessel and its external components involves the greatest  ;

potential for occupational radiation exposures because of the cobalt-60  !

that is produced in these components by neutron activation. Since cobalt-60 has a 5.2 year half-life, the 30 year SAFSTOR period is more than 5 half-lives of this radionuclide, in 30 years radiation exposure rate would '

bereducedtolessthan1/32oftheoriglnallevel.

K-31 See response to comment K-30.

I I Humboldt Bay Unit 3 FES 9-17

Responses to Comments of Edith Kraus Stein (L)

L-1 There is no commercial repository and none is, anticipated. Also, see response to comment C-9.

L-2 See responses to comments A-3 and A-4.

L-3 See response to comment C-11.

l L-4 The decay heat from the spent fuel will not heat the water enough to make steam because Humboldt Bay Unit 3 has been shut down since July 1976 (more than 10 years). Also, the dose calculation referred to does not make any assumption about the temperature or the state of the water. It is a hypo-thethical calculation and the state of the water is not relevant to the i

calculation.

i L-5 The staff considered a seismic event for the proposed SAFSTOR decommission-i ing option (see DES /FES Section 3.2.3). The staff has concluded that there is a negligibly small likelihood of a criticality due to fuel rear-rangement and that the release of the krypton-85 from the fuel, all of the spent fuel pool water, or the radwaste tank contents to the environment would result in very low dose levels (much less than PAG dose levels).

1 L-6 Seismic considerations for the Humboldt Bay" site are considered in the staff's evaluation of " postulated accidents in DES /FES Section 3.2.3. ,

L-7 See responses to comments L-1 and C-9.

L-8 The amount of contaminated soil around the spent fuel pool has not been j

quantified. Monitoring wells around the pool indicated some contamination i in 1966, but the monitoring data in 1966 and since 1966 have shown ground-l water concentrations to be less than 10 CFR Part 20 Aprendix B. Table II limits for unrestricted areas: Anycontaminatedsollwithlevelsofradio-I. activity above that which is acceptable for release to unrestricted access I must be removed from the site during dismantling.

i On December 23, 1986, the spent fuel pool gap water level monitoring system '

was found to be defective during the installation of a new redundant level i

l monitoring system (Shiffer, 1987). The gap water level was also found to be higher than the administrative limits. There was, however, no indication of radiation levels above background in any of the monitoring wells. Also, i the radioactivity in the water in the french drain below the pool indicated no significant change in concentration of radionuclides.

PGAE has now completed the installation of a redundant gap water level mon-itoring system which will eliminate the single-failure problem discussed above.

In addition, a new high-capacity ion-exchange system is now installed for the spent fuel pool. The proposed TS limits require that the pool water be main-tained at cesium-137 concentrations of no more than 1 x 10 4 pCi/ml. The cesium-137 concentration limit of 10 CFR Part 20 Appendix 8. Table !! for water released to unrestricted areas is 2 x 10.s,pC1/ml.

I i

j Humboldt Bay Unit 3 FES 9-10 i

f

.._.- - - - _ . - = - . - . _ . _ _ - - - - . -

I Proposed TS limits specify that liner gap water must be maintained at a level that is lower than both the pool water level and the groundwater level. The liner pump must be operated for 10 to 15 minutes about once

per week to maintain the gap level below that upper limit.

i The staff has determined that there will not likely be a significant amount

! of radioactivity transferred from the spent fuel pool to the groundwater >

! because: (1) the pool water radionuclide concentrations are maintained l at levels near those acceptable for release to unrestricted access; (2) the gap water will be maintained at a level that is less than pool level and r i

groundwater level; (3) if the liner gap pump failed, there would be suf-ficient time to repair or replace it before the gap water level increased  ;

above groundwater level since the gap water level increases only about s 3 inches per day (Shiffer, 1986); and (4) groundwater dilution of any l

] pool leakage would reduce concentrations of radionuclides to well below l those levels acceptable for release to unrestricted areas.

1 L-9 The time frame for completion of the tasks to place Humboldt Bay Unit 3 l into SAFSTOR status (OES/FES Section 2.2) was not specified as there is no (

identifiable environmental impact related to the schedule. Items 1 and 2 *

) under " preparation for SAFSTOR" are now complete and the FES has been  ;

j modified accordingly. Items 3, 4, and 5 are nearing completion, j t

j L-10 The reactor vessel reactor cooling system, and spent fuel cooling system  !

havebeendrainedIntotheradioactivewastetreatmentsystem. Sec- l

{ tion 3.2.2 of the DES /FES describes treatment of liquid radioactive wastes  !

i to remove radioactivity, r i

j L-11 The SAFSTOR decommissioning activity proposed by the licensee does not L affect the function or the quality of the function of the ecosystem because l no construction or demolition is to be done that would disturb the bay, i i the mudflats, or other The DES /FES is based on a review of the licensee' parts s Environmental of the ecosystem. Report which describes the environ-I mental setting at Humboldt Bay Unit 3 in detail (Section 4) and the decom-

) missioning tasks to be done. See also response to comment A-1. The quali-i fications of the staff reviewers are broader than indicated in their current l job titles. They were selected on the basis of their education and previous i experience in environmental evaluations.

l L-12 The potential exposures of the two endangered species, the brown pelican  !

and the peregrine falcon, have not been calculated. DES /FES Appendix B i however,calculatesthepotentialexposureofthemaximallyexposedindIvi- '

dual who consumes well above average quantities of fish from the bay. The  !

potential exposure has been calculated to be less than 0.1 mrem / year. The potential exposure of humans from fish consumption is a small fraction of  :

exposure from background radiation. The potential exposure of the two endangered species would Ilkely be an even smaller fraction of natural background because these species only occasionally visit the Humbolt Bay area. This exposure level would not have observable impact on the survival  :

of these species. l L-13 Calculated releases of liquid waste during the SAFSTOR period are given  !

, in the DES /FES in Table 3.1. The proposed SAFSTOR TS require that each batch of wastes be sampled and analyzed before being released to the dis-charge canal. The proposed TS require that the radioactive waste discharges Humboldt Bay Unit 3 FES 9 19 I

to the Humboldt Bay not exceed the concentration limits given in 10 CFR Part 20 for unrestricted areas on an instantaneous basis. DES /FES Appen-i dix B provides site-specific dose calculations for individuals who are

! assumed to consume above average quantities of potenticily affected foods i such as fish from the Humboldt Bay. The results of these calculations, given in Tables B.3 and B.4, show that the maximum potential exposures are a small fraction of background radiation. PG&E must comply with the 3

requirements of the TS with respect to concentrations of radionuclides i that are released into the Humboldt Bay, whether the two fossil-fueled j units are operational or not, i I L-14 The impacts of releases of liquid and gaseous radioactive effluents are j calculated in Appendix B of the DES /FES. These impacts are not signiff-

cant since the potential exposures are a small fraction of background I radiation (DES /FES A Tables B.3 and B.4). Appendix B is the i basis for the staff'ppendix BsconclusIonsinSection3.2.The staff, therefore j concludes that Section 3.2 does not contradict the conclusions of Sec-1 tions 3.1.4 and 3.1.5 which indicate no likely detrimental impacts on j terrestrial resources or endangered species. .

L-15 The radwaste enclosure building will protect the existing radwaste treatment facility from weather conditions. No significant environmental impact j would occur if an earthquake damaged this building. This building was not

constructed to provide additional waste storage capacity. Seismic damage t i to this building would not release a significant quantity of radioactivity

j because only low-level waste would be processed in the existing radwaste l 4

treatment facility and temporarily stored in sealed containers in the rad- 1

! waste building while awaiting shipment to a low-level waste burial ground.  !

I l j L-16 See response to comment L-13. [

and L-17Theeffluentfromtherefuelingbuilding,hotlab,hotmachineshoplease radwaste b911 ding are routed to the plant ventilation system for re i from the plant stack. This effluent is not treated because of the low

! level of radionuclides that are present. A stack monitoring system will i be in operation during the SAFSTOR period to monitor gaseous and particulate l 1 activity. In the event of an accident that causes a release of particu- '

late radioactivity, the refueling building ventilation system can be iso- ,

l lated and building air can be exhausted through the gas treatment system ,

j high efficiency particulate air (HEPA) filter. l l ControIIed ventilation is not required for the waste storage vaults, low- i i level-waste-storage building or low-level-waste-handling building because wastes in those areas are packaged and scaled before they are stored in  !

thoseareas(Shiffer,1986).

L-18 If dismantling or decommissioning operations insolve potential production i of radioactive particulates, the licensee will be required to control any l potential releases through the use of containment control envelopes such s as the existing containment building or a temporary structure. NUREG/CR-0672 estimates potential exposure to the public from DECON/dismantilng r operations to be 0.005 millirem or less. Gaseous effluent limits are specified in TS VI.8.3 as the limits of 10 CFR Part 20, Appendix B, l Table !!, Column 1. l Humboldt Bay Unit 3 FES 9 20 l

t L-19 The staff believes that the assumption of damage to one row of pins in each of two spent fuel assemblies is adequately conservative. The number of pins damaged would not depend on whether the fuel was old or new.

i L-20 Calculations were made that assumed the rods would remain in a parallel t array because the parallel array is a more conservative assumption than assuming the rods are not parallel. Likewise, assuming all of the fuel was

, fresh is more conservative, as any burnup (all rods in the pool have one or more cycles of burnup) would reduce the reactivity of the configuration.

l See response to comment C-11.

l L-21 The groundwater flows toward the Humboldt Bay because the groundwater ele-

, vation remains higher than the average tide level in the bay (Shiffer, j April 1985). Therefore, there will be no transport of groundwater to the

, northeastern site boundary in the event of a spent fuel pool rupture.

Also, see response to comment C-24, i

l L-22 The effects of a tsunami are discussed in the staff's SER (see footnote for

response to comment A-15). Postulated accidents produced by seismic or

! other events are evaluated in Section 3.2.3 of the DES /FES. The potential d

impact of a tsunami is bounded by these postulated accidents.

l " Postulated Accidents" (OES/FES Section 3.2.3) considers the impact of i seismic events with no credit given for the seismic integrity of structures l or equipment.

! L-23 See responses to comments A-1, A-3, A-4, and A-16.

l Responses to Comments of Pam Wollish (M) l M-1 See response to comment F-1.

< M-2 The DES /FES list of the licensee's reasons for choosing SAFSTOR is quoted

) from the licensee's Environmental Report (Shiffer, 1984).

l M-3 See responses to comments A-3, A 4, and E-1.

i ,

M4 The risk estimators are based on current information. '

M-5 As stated, the lower limit of the range of uncertainty is zero.  !

M6 Changes in technology for dismantling, reduction in residual radioactivity, and changes in waste disposal requirements in 30 years might require a detailed dismantling plan to be entirely revised.

)  !

M-7 The decision of the California Public Utilities Commission is given in Appendix A to the SER. Also see response to comment K-12.

Rosponses to Comments of Sonator Barry Keono (N)

! N1 The title of the DES /FES incorporates the licensee's name and the docket i name of the facility: Humboldt Day Power Plant Unit No. 3. Identification

of the Nuclear Regulatory Commission as the author should suffice to alert j the reader that this was a nuclear power plant. The staff has, however, Humboldt Day Unit 3 FES 9-21

i l

revised the first line of Section 1.1 to identify Humboldt Bay Unit 3 as a nuclear power plant. NEPA and Council on Environmental Quality (CEQ) requirements do not extend to the title. The title on the cover is be-lieved to be adequate and is consistent with past practice of the NRC for l other Environmental Statements.

l The scope of the descriptive material is tailored to that necessary to assess and evaluate impacts. Airborne and waterborne releases during the l SAFSTOR stage of decommissioning will be small. In the absence of signif-i icant anticipated releases and, therefore, of mechanisms for impacting the l offsite environment, detailed discussion of the environmental setting in I

the DES /FES is not believed to be necessary. The licensee does however describe the environmental setting in some detail in the Environmental l Report (Schuyler, 1984). See also response to comment A-1.

N-2 See response to comment C-24.

N-3 See responses to comments A-3 and A-4.

N-4 The licensee's radiation protection program is discussed in detail in Section 6 of the licensee's decommissioning plan (Schuyler, 1984). This ,

program describes personnel monitoring, access control and radiation areas, '

radiation surveys, and other procedures for minimizing exposures to per-sonnel at the Humboldt Bay facility. The licensee's emergency plan, which deals with both onsite and offsite emergencies, was submitted by letter ,

dated April 4, 1985, as revised June 12, 1986 and January 20, 1987. Staff  !

review of these documents is included in the SER related to the licensee's <

proposed decommissioning plan. The licensee's emergency plan, as well es the SER, will be available to the pubile in the Local public Document Room at the Eureka-Humboldt County Library in Eureka, California.  !

I N-5 The licensee's Decommissioning Plan (Schuyler, 1984) references other  !

nuclear facilities that have been decommissioned. NUREG/CR-0612 (refer-  !

enced on page 6 2 of the DES /FES) discusses in some detail decommissioning l actions at other nuclear facilities. The Vallecitos Dolling Water Reactor ,

(VBWR), for instance, was shut down in 1963 and placed in a mothballed / '

SAFSTOR status. The V0WR, a 50 MWt reactor, is located in Alameda County, California, and is presently licensed for possess-but-not-operate statue.

The fuel was removed from the site and shipped to an AEC facility for reprocessing.

N6 The Decommissioning Plan proposed by the licensee discusses design de- i tails, waste disposal facility maintenance, radiation safety procedures, ,

andadminIstrativecontrols. The Decommissioning Plan is  ;

monitoringlntheLocalPublicDocumentRoomattheEureka-HumboldtCounty available  :

Library.

The contaminated water has been processed to remove radionuclides and then released to the Humboldt Day. Radionuclidus then concontrJted in

, fon-exchange resins are shipped to Ilconsed low-level waste burial grounds.

1 N7 The NRC staff has also prepared an SER which evaluates the Decommissioning Plan. The DES /FES is concerned primarily with those issues addressed in i Humboldt Bay Unit 3 FES 9 22

i l I  !

1  :

i i i  ?

I

! the licensee's Environmental Report which was submitted with the Decommis-j sioning Plan on July 30, 1984 (Schyler). Also, see response to comments i j E-1 and L-5. i i i j Responses to Comments of Susan Ames (0) j 0-1 Appendix B discusses potential exposures to the public, both adults and l l children, during the SAFSTOR period. The exposures predicted are less  !

i than 1% of natural background radiation. The Humboldt Bay facility is  !

I monitored to detect and quantify any releases of radionuclides as required j by the Technical Specifications.  !.

0-2 See response to comment F-1.  !

! Rosponses to Comments of Daniel J. Taranto (P)

I P-1 The DES /FES is based on an analysis of information in the licensee's En- f vironmental Report (Schyler, 1984) to determine the environmental impacts  :

of the decommissioning of Humboldt Bay Unit 3.

P-2 See response to comment K-12. .

P-3 Page 1-4, Section 1.3.3 of the DES /FES discusses the alternative of shipment of fuel to Diablo Canyon. Section 1.3.3 has been revised with respect to .

the licensee's reasons for selecting SAFSTOR. [

j P-4 DECON cannot be accomplished untti after fuel has been shipped to a Federal i repository (response to comment A-10). Since a Federal repository is not ,

! likely to be ready until after 2003, DECON can not be accomplished now. [

The licensee is reqaired by the Technical Specifications (TS VII-!.2) to  ;

maintain records of the facility that are important to the DECON operation, i such as records, and prints of changes to the plant, and records of plant *

radiation and contamination surveys. The staff does not anticipate that

{ the removal of the residual activity in 30 years will be an insurmountable

problem, as records of the facility are maintained and radiation levels L j near the reactor vessel will be less than 1/32 of present levels as a  !

]

result of cobalt-60 decay. ,

P5 Accidents evaluated in Section 3.2.3 of the DES /FES cover seismic events. l Tsunamis (tidal waves) and other flooding events are evaluated in the '

I staff's safety evaluation. Airplane crashes are not covered in either document. The low probability of a direct airplane impact combined with the fact that the spent fuel is in a pool of water below ground level makes  ;

this so unlikely that this accident does not need to be specifically eval- '

. usted. Damage to the above ground structures at the facility should not result in a significant release of activity, since the spent fuel does not need any active cooling system.

j PG In addition to the DES and FES documents, the NRC has completed a safety [

l evaluation of licensee-proposed TS requirements as part of the SER. The  !

TS will specify requirements for maintenance of the spent fuel pool and I associated equipment for the control of access to radiation areas, for control of ratticactive waste, for radiation monitoring systems, and for administrative controls.

Lumboldt Bay Unit 3 FES 9 23

DECON can not be accomplished now because there is no repository for the spent fuel (CES/FES Sections 1.3.1 and 1.3.3).

P-7 See response to comment F-1.

Responses to Comments of Sierra Club. Redwood Chapter (Q)

Q-1 A transcript of the December 4,1984 scoping meeting is available in the Local Public Document Room at the Eureka-Humboldt County Library. The staff review addressed the significant concerns identified during the scoping process.

Q-2 Alternatives are discussed in DES /FES Section 1.3. The response to comment A-4 discusses the concerns of an operating reactor in contrast to concerns with fuel storage.

Q-3 The DES /FES presents the findings of the staff from the review. The NRC licensing decision is based on tne DES /FES, a safety evaluation, the hear-ing findings (if applicable), and other considerations set forth in Title 10 of the Code of Federal Regulations. The DES /FES is viewed as a predecisional document. Also, see response to comment C-1.

Q-4 See responses to comments A-3 and A-4.

Q5 See response to comment A-1.

Q-6 See Section 3.1.1 and Appendix A of the DES /FES for evaluation of cultural resources.

Q7 See response to comment C-24.

Q-8 Section 8 of the DES /FES lists the local, State, and Federal agencies to which the DES was sent. A number of these agencies have responded to the staff's invitation for comments. Those comments and staff responses are included in this FES.

Q-9 See responses to comments L-0 and C-24.

Q-10 The quantity of water in the spent fuel pool will remain unchanged during the SAFSTOR period. Although the pool water may be contaminated with radionuclides, there are no radioactive liquids in the pool. The level of contamination in the pool water must be maintained within TS Ilmits.

Q 11 See response to comment A-2.

Q 12 See responses to comments A 2, C 13, and L-8.

0-13 The radwaste building is simply a structure to protect the existing radwaste systems from the weather. This building will produce a minor benefit by reducing the potential for rainwater runoff and resulting redistribution of contamination.

Also see response to comment L 15.

Humboldt Day Unit 3 FES 9,24

_ _ _ _=- _ _ - _ _ _ _

Q-14 See response to coment C-9.

Q-15 See response to comment A-5.

~

Q-16 See response to comment L-15.

I Q-17 See response to comment L-15.

Q-18 See response to comment A-7.

Q-19 See response to comment K-12.

Q-20 See response to comment A-13.

Q-21SeeresponsetocommentC-11.

Q-22 The activation element /radionuclide of major significance with respect to worker exposure during dismantling of the Humboldt bay plant is cobalt-60, which has a 5.2 year half-life. Assuming a SAFST00 period to the year 2015, the Humboldt Bay plant would have been shut down 29 more years at the time of dismantling or more than 5 half-lives of cobalt-60. In the 29yearperiod}de,willhavedecreasedtolessthan1/32ofitsoriginalthe nant radionuc1 occupational e

exposure rate at time of shutdown.

l Q-23 See response to comment C-12.

Q-24 See response to comment L-9.

Q-25 Requirements for monitoring and processing of the spent fuel pool water are included in the Technical Specifications and will be evaluated in the staff's SER related to the proposed decommissioning plan.

! Q 26 See response to comment C-20.

Q-27 80th the DES and FES contain the bases for conclusions.

l Q-28 The discussion of the postulated fuel handling accident (DES /FES Sec-tion 3.2.3.2) assumes that only one assembly would be dropped because only l one assembly can be Iffted at a time. The staff assumes two assemblies '

would be involved: the one dropped and the one in the rack that is impacted.

Q 29 See responses to comments A 17, C-9, and Q-3.

! Response to Comment of Judith Field (R) l R-1 With respect to pool leakage, see responses to comments C 13 and L 8.

With respect to seismic effects, see response to comment A-3.

Response to comments _of Ronnte_ Blackberry ($)

l l S-1 See response to comment L 8 with respect to spent fuel pool leakage. The l DES /FES is a specific evaluation of decommissioning Humboldt Bay Unit 3.

l l Humboldt 8ay Unit 3 FES 9 25

See response to comment A-1 with respect to the scope of the DES /FES. See response to comment F-1 with respect to the hearing actions now in progress.

Response to Comments of Pacific Gas and Electric Company (T)

T-1 FES Section 1.2 has been revised to reflect this information.

T-2 FES Section 2.1 has been revised to reflect this information.

T-3 FES Section 2.2 has been revised to reflect this information.

T-4 The staff recognizes that the text may be interpreted to mean that only one contractor does both analysis and solidification of the waste. In fact, the analysis is now done by one contractor and the solidification by another. Since this revision would not have any impact on the staff's evaluation and in the future both jobs may be done by the same contractor, the staff has decided not to change the discussion in the FES.

T-5 FES Section 3.2.3 has been revised to reflect this information, and T-6 T-7 Although comment T-7 calculations support the staff's evaluation, it does not revise staff conclusions. Therefore, the staff will not change the FES. Also, see response to comment C-11.

Response to Comment of the U.S. Department of Aariculture (U)

U-1 The Director of the Natural Resource Economics Olvision of the U.S.

Department of Agriculture indicated that he had no comments with respect to the DES. Therefore, no response is required.

_ Response to Comments of the U.S. Environmental Protection Agency _ Region IX (V)

V-1 The licensee is required to submit a detailed dismantling plan for NRC approval before dismantlement of Humboldt Bay Unit 3. The licensee must submit environmental information as required by then-current regulations.

The NRC will review the environmental aspects of the dismantling and pre-pare a supplement to the FES or an environmental assessment as required by the regulations in effect at that time. The staff will not approve the dismantling plan at this time. The staff is taking action with respect to the proposed 30-year storage portod.

V-2 Although the Humboldt Bay Unit 3 DES /FES refers to the Draft Generic Envir-onmental Impact Statement (NUREG-0586) in support of the concept of de-ommissioning, the Humboldt Day Unit 3 DES /FES does review the specific environmental aspects of the proposed Humboldt Bay Unit 3 decommissioning.

V-3 The proposed duration of 30 years of SAFSTOR for Humboldt Bay Unit 3 falls within the time period discussed in the proposed decommissioning rule changes of February 11, 1985. The proposed rule changes do not waive requirements for termination surveys at reactor facilities undergoing decommissioning.

Humboldt Bay Unit 3 FES 9 26 l

l V-4 The final rule changes on decommissioning are expected to be published in October 1987. The Final Generic Environmental Impact Statement on Decom- l sissioning Nuclear Facilities (NUREG-0586) is expected to be issued by  !

December 1987. The staff is aware of no conflicts in the Humboldt Bay Unit 3 DES /FES with either of the above documents. The staff will com-plate an environmental review of the DECON/ dismantling plan for Humboldt Bay Unit 3 when that plan is submitted near the and of the SAFSTOR period.

4

)

l i

1 j

i i

l I

Humboldt Bay Unit 3 FES 9-27

APPENDIX A CULTURAL RESOURCES: LETTER FROM STATE HISTORIC PRESERVATION OFFICER Humboldt Bay Unit 3 FES Appendix A

st:Tt of CAutoeN4A-Det BeSOU8CES AotNCY GEORGE DEugMEJt AN c.,,,ns, OFFICE OF HISTORIC PRESERVATION MPARTMENT OP PARK 5 AND RECREATION post oveice aos asso am-swto, cautoeNIA 95411 C16) 44'l-8000 REPLY TO: NRC841127A April 17, 1985 Mr. Franklin J. Burney Pacific Gas and Electric Coepany 77 Beale Street San Francisco, CA 94106 L.

Dear Mr. Burney RE: Humboldt Bay Unit 3 Decor.missioning Thank you for requesting our comments on the above cited project. We con:ur in your determination that this undertaking does not involve National Register or eligible properties.

If my staff can be of any further assistance, please contact Dwight Dutschke at (916) 322-9624 Sincerely, if Kathryn Gua tieri State Historic Preservation Officer 1

1 Humboldt Day Unit 3 FES 1 Appendix A

APPENDIX B EXAMPLES OF SITE-SPECIFIC DOSE ASSESSMENT CALCULATIONS l

'i l

Humboldt Bay Unit 3 FES Appendix B

APPENDIX B EXAMPLES OF SITE-SPECIFIC DOSE ASSESSMENT CALCULATIONS

1. Calculational Approach As mentioned in the main body of this report, the quantities of radioactive material that may be released annually from the Humboldt Bay Power Plant are estimated on the basis of the description of the design and operation of the radwaste systems as contained in the licensee's Environmental Report and SAFSTOR Decommissioning Plan (Schuyler, 1984) and periodic reports on radioactive effluent releases and waste disposal covering the years 1977 through 1983 (when Humboldt Bay Unit 3 was shut down). On the average, actual releases are expected to be less than those given in these documents because of the radioactive decay that will take place over the 30 year SAFSTOR period. For calculational conser-vatism, a minimal amount of selected radionuclides (4 microcuries per year) was included in the annual releases, although in recent years they have not been reported and in most cases are not expected. During the 30 year SAFSTOR period, most of the released radionuclide quantities are expected to originate with spent fuel storage operations. However, lesser quantities of radionuclides that may be leached from contaminated soil on the site have been included in the calcula-tions. These estimated values of effluent releases during SAFSTOR, along with the licensee's site and environmental data in the ER and in subsequent answers to NRC staff questions, have been used in the staff's calculation of radiation doses and dose commitments.

RG 1.109, Revision 1 discusses in detail the models and considerations for environmental pathways that lead to estimates (a) of radiation doses and dose commitments to individual members of the public near the plant and (b) of cumu-lative doses and dose commitments to the entire population within an 80-km (50-mile) radius of the plant as a result of plant operations. The calculations performed by the staff for the releases to the atmosphere and hydrosphere provide total integrated dose commitments to the entire population within 80 km of this facility based on the projected population distribution in the year 2000. The dose commitments represent the total dose that would be received over a 50 year period, following the intake of radioactivity for 1 year under the conditions existing 30 years after the beginning of SAFSTOR operation (that is, the end-point of SAFSTOR operation). For younger persons, changes in organ mass and metabolic parameters with age after the initial intake of radioactivity are accounted for.

2. Dose Commitments from Radioactive Effluent Releases The NRC staff's estimates of the expected gaseous and particulate releases (listed in Table 3.2 of the main body of this report) and site meteorological considerations were used to estimate radiation doses and dose commitments for airborne effluents. Individual receptor location and pathway locations consid-ered for the maximally exposed individual in these calculations are given in l

Table B.1. ,

Humboldt Bay Unit 3 FES 1 Appendix 8

Two years of onsite meteorological data (January 1976 to December 1977) were used in the calculation of effluent concentrations given in Table B.1. The data were comprised of wind speed and wind direction measured at 76 meters, and vertical temperature difference between 7.6 and 76.2 meters. These data were combined in a joint frequency distribution, used in a straight line gaussian plume model corrected for terrain heights and effluent recirculation using standard correction factors (NUREG/CR-2919). All releases were assumed to be continuous and out of the 76 meter plant stack.

The NRC staff estimates of the expected liquid releases (listed in Table 3.1) and the site hydrological considerations (summarized in Table 8.2) were used to estimate radiation doses and dose commitments from liquid releases. Leaching of contaminated soil on site was included in the estimates.

(a) Radiation Dose Commitments to Individual Members of the Public Calculations are made for a hypothetical individual member of the public (the maximally exposed individual) who would be expected to receive the highest radiation dose from all pathways that contribute. This method tends to over-estimate the doses because assumptions are made that would be difficult for a real individual to fulfill.

The estimated dose commitments to the individual who is subject to maximum exposure at selected offsite locations from airborne releases of radiofodine and particulates, and waterborne releases are listed in Tables B.3 and B.4.

The maximum annual total body and skin dose to a hypothetical individual and the maximum beta and gamma air dose at the site boundary are in Tables B.3 and B.4.

The maximally exposed individual is assumed to consume well above average quantities of the potentially affected foods and to spend more time at poten-tially affected locations than the average person, as indicated in Tables E-4 and E-5 of Revision 1 of RG 1.109.

(b) Cumulative Dose Commitments to the General Population Annual radiation dose commitments from airborne and waterborne radioactive releases from the Humboldt Bay Power Plant Unit 3 are estimated in Table B.4 for all members of the general public within 80 km (50 miles) of the station in the year 2000.

For perspective, annual background radiation doses are given in the table.

3. References Schuyler, J. O. , PG&E, Letter to Harold R. Denton, NRC, HBL-84-027, July 30,1984.

U.S. Nuclear Regulatory Commission, RG 1.109, " Calculation of Annual Doses to Man from Routine Releases of Reactor Effluents for the Purpose of Evaluating Compliance with 10 CFR Part 50, Appendix I," Revision 1, October 1977.

-- , RG 1.111, " Methods for Estimating Atmospheric Transport and Dispersion of Gaseous Effluents in Routine Releases from Light-Water Reactors," Revision 1, 1977.

-- , NUREG/CR-2919, "X0QD0Q: Computer Program for Meteorological Evaluation of Routine Effluent Release at Nuclear Power Plants," May 1985.

Humboldt Bay Unit 3 FES 2 Appendix B

Table 8.1 Summary of atmospheric dispersion factors (X/Q) and relative deposition values for maximum site boundary and receptor i locations near Humboldt Bay Power Plant Unit 3*

i l

! Relative >

Lccation** Source *** X/Q (sec/m ) 3 deposition (m 2)

NIarest effluent- Unit 3 4.42x10 4 6.12x10 7 control boundary stack >

(0.32 km S)

• The values presented in this table are calculated in accordance with Regulatory Guide 1.111, Rev.1, " Methods fcr Estimating Atmospheric 1

' Transport and Dispersion of Gaseous Effluents in Routine Releases fron  ;

Light Water Reactors," July 1977.

t

• • " Nearest" refers to that type of location where tha highest radiation dose il is expected to occur from all appropriate pathways. Beta and gamma air doses, total body doses, and skin doses from noble gase" are determined at the effluent-control boundaries in the sector where the maximum potential l value is likely to occur. Dose pathways including inhalation of atmos-

. pheric radioactivity, exposure to deposited radionuclides, and submersion in gaseous radioactivity are evaluated at residences. In this instance, the doses were calculated as if the nearest residence, nearest vegetable i garden, nearest milk cow, nearest milk goat, and nearest meat animal were all situated at the site boundary 0.32 km south of the stack.

4

• • • Source: Unit 3 stack, continuous release. Dispersion conservatively

. calculated as if the releases were at ground level. '

l l Table B.2 Summary of hydrologic transport and dispersing for liquid releases from Humboldt Bay Power Plant Unit 3 f Transit time Dilution Location (hours) factor Nearest sport-fishing location 0 10 j (discharge area)** '

Nearest shoreline 0 10 (shoreline near discharge area) 1

• See Regulatory Guide 1.113, " Estimating Aquatic Dispersion of Effluents from Accidental and Routine Reactor Releases for the Purpose of Implementing Appendix I," April 1977.

• • Assumed for purposes of an upper limit estimate.

i i I l

I Humboldt Bay Unit 3 FES 3 Appendix 8

, - - - . - - - , ,4-. r,--,,..e  % s r-. ,,e - - , - - + . - - , - ec - -,,,e-,-,,,.g-,.. ,c, .-* ,, . m

l Table B.3 Annual dose commitments to a maximally exposed individual near Humboldt Bay Power Plant Unit 3 Location Pathway Doses (mrem /yr, except as noted)

Noble gases in gaseous effluents Total Gamma air dose Beta air dose body Skin (mrads/yr) (mrads/yr)

, Nearest

• site Direct radiation l

boundary from plume a a b b (0.32 km S)

Iodine, particulates in gaseous effluents **

Total body Organ Nearest *** site Ground deposition 0.1 0.1 boundary (0.32 km S) Inhalation a a Nearest residence Ground deposition 0.1 0.1 and garden, milk Inhalation a a cow, milk goat, Vegetable consumption 0.1 0.2(C)(bone) and meat animal Cow milk consumptiun a 0.1(I)(bone)

(0.32 km S) Goat milk consumption a 0.1(C)(bone)

Meat consumption 0.2(I)(liver) a a Liquid effluents **

Total body Organ Nearest drinking Water ingestion c c water Nearest fish at Fish consumption a a plant-discharge area Nearest shore Shoreline recreation a a access near plant-discharge area Legend: a = Less than 0.1 mrem / year; b = Less than 0.1 mrad / year; c = Releases into the salty water of Humboldt Bay, which is not used for drinking water supplies.

• Nearest = that site boundary location where the highest radiation doses asga result of gaseous effluents have been estimated to occur.

• • Doses = the age group and organ that results in the highest cumulative dose for the location: A= adult, T= teen, C= child, I= infant. Calculations were made for these age groups and for the following organs: gastrointestinal tract, bone, liver, kidney, thyroid, lung, and skin.

• • • Nearest = the location where the highest radiation dose to an individual from all applicable pathways has been estimated.

Humboldt Bay Unit 3 FES 4 Appendix B

Table B.4 Calculated annual dose commitments to a maximally exposed individual and to the population from SAFSTOR of Humboldt Bay Power Plant Unit 3*

Source Individual **

Liquid effluents Dose to total body from all pathways a Dose to any organ from all pathways a Noble gas effluents (at site boundary)

Gamma dose in air b Beta dose in air b 4

Dose to total body of any individual a Dose to skin of an individual a Radiciodines and particulates in gaseous effluents ***

Dose to any organ from all pathways 0.4 mrem Population dose within 80 km, person-rems Total body Liver Natural-background radiationt 13,000 -

Liquid effluents 0.4 0.6 Noble gas effluents c c Radioiodine and particulates 0.1 0.1

Legend: a = Less than 0.1 mrem / year; b = Less than 0.1 mrad / year; c = Less than t

0.1 person-rem / year.

l

• Although Appendix I to 10 CFR 50 does not apply because SAFSTOR conditions l are not part of normal reactor operation, the staff notes that the annual doses in this table are much less than the annual dose design objectives of Appendix I.

C* Numerical values for individual doses were obtained by summing appropriate values in Table 8.3. Locations resulting in maximum doses are represented here.

Q** Carbon-14 and tritium have been added to this category.

t Source: " Natural Radiation Exposure in the United States," U.S. Environmental 1 Protection Agency, ORP-SID-72-1, June 1972; using the average background dose for California of 100 mrem /yr and year 2000 projected poptiation of 130,000.

Humboldt Bay Unit 3 FES 5 Appendix B

APPENDIX C COMMENTS ON THE DRAFT ENVIRONMENTAL STATEMENT l Comment No. Commenter Pages A A-17 California Coastal Commission, North Coast Area............ 3-13 B B-5 U.S. Department of Health and Human Services, Public Health Service, Food and Drug Administration, Center for Devices and Radiological Health................................... 15-16 C C-27 Sierra Club, Legal Defense Fund, Inc...................... 17-27 D D-19 Redwood Alliance.......................................... 29-32 E-1 & E-2 Elton Adams and June Crym................................. 33 i F-1 & F-2 Na n cy H i e f i ke r. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3 5-36 G G-12 Thomas P. Infusino........................................ 37-48 H H-4 Ralph Kraus............................................... 49 I I-7 Larry Lancaster........................................... 51-53 J J-4 Michael J. Manetas........................................ 55 K K-31 Jared Rossman, Acorn Alliance for Safe Energy............. 57-62 L L-23 Edith Kraus Stein......................................... 65-70 M M-7 Pam Wel1ish............................................... 71-72 N N-7 Senator Barry Keene, State of California Senate, Joint Committee on Fisheries and Aquaculture.................... 74-75 0 0-2 Susan Ames................................................ 77-78 P P-7 Daniel J. Taranto......................................... 79-80 Q Q-29 Sierra Cl ub , Redwood Chapter. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 81-87

, R-1 J u d i th F i e l d . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 89 S-1 B o n n i e B l a c kb e r ry. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 91

~

T T-7 Pacific Gas and Electric Company.......................... 95 U-1 U.S. Department of Agriculture, Economic Research Service, Natural Resources Economics Division...................... 97 V V-4 U.S. Environmental Protection Agency, Region 9............99-100 Humboldt Bay Unit 3 FES Appendix C i

,.e, 1

5taic of Enlifornia A4.

d- k*. GOVERP40R S OFFICE A, -f

• OFFICE CF PLANN;NG AND RESEARCH he 14CO TENTH STREET SACRAMENTO 95014 GEORGE oEUKMEJtAN

. .. e. 916/323-7480 l

DAIE: June 11, 1986 10: Mr. Peter Erickson Nuclear Regulatory Commission Standardization & Special Projects Washington, DC 20555 FIOt Office of Planning and Research

, State Clearinghouse RE: SCH 84112723---Draf t Environmental Statement for Decommissioning Humboldt Bay Power Plant Number 3 As the designated Caliternia Single Point ct Contact, pursuant to Executive Or6er 12372, the Citice et Planning and Research transmits attached carrroents 4 as the State Process Recccznert.aticn.

This reconinenct.tien is a censensus; no cppsing cccrents Fave been received.

Initiation of the faccccrocate or explairi response by your agency is, therefore, in effect.

Sincerely, 9 l l

/

usten T. Carlyle Director, Office [p P .ning and Research Attacrzent cc: Applicant

)

i Humboldt Bay Unit 3 FES 1 Appendix C

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, g,cne we,et Owe,tv ceaeren ewoo Mr. Peter Erickson Nuclear Regulatory Coramission Standardization & Special Projects June 11, 1986 Washington, DC 20555

Dear Mr. Erickson:

The State has reviewed the Draft Environmental Statement for Decommissioning Humboldt Bay Power Plant, Unit 3, submitted through the Office of Planning and Research.

Review of this document was coordinated with the Coastal, Energy, and Public Utilities Commissions, the Air Resources, Reclamation, and Regional Water Boards, and the Departments of Boating and Water-ways, Conservation, Fish and Game, Parks and Recreation, Water Re-sources, Health Services, and Transportation.

Attached for your consideration and use are comments received from the staff of the Coastal Commission.

The Department of Health Services comments that its Division of Hazardous Waste Management will contact the applicant directly on this matter.

The North Coast Regional Water Board is already working directly with the applicant.

Thank you for providing an opportunity to review this document.

ginee/ rely,/ / ,. ,

ordon F. Snow, Ph.D<

/'Ic y Assistant Secretary for Resources Attachment (1) cc: Office of Planning and Research 1400 Tenth Street Sacramento, CA 95814 (SCH 84112723) l Humboldt Bay Unit 3 FES 2 Appendix C

$ rare ce catseem-rae sesoveces aoence osoece oeusmemaN. o.-

CALIFORNIA COASTAL COMMISSION .

NORTH COAsf AREA 431 peOwat0 Sffftr 4Ta 7 toot SAN fBaNCISCO. CA 94103 t'isi san asss I

June 9, 1986 l

l l Mr. Ken Fellows Resources Agency 1416 Ninth Street, Room 131 Sacramento, CA 95814 RE: SCH: #84112723--Decommissioning of Hamboldt Bay Nuclear Power Plant #3, Eur,eka, California

Dear Mr. Fellows:

Thank you for the opportunity to comment on the proposed decognissioning of the Humboldt Bay Nuclear Power Plant. The staff of the California Coastal Commission has reviewed the information in the Draf t Environmental Statement (DES) prepared by the U.S. Nuclear Regulatory Commission (NRC). The remarks that follow are solely those of staff and not the Commission itself. This letter is intended to provide early identification of the areas of concern to the Commission staf f in order that these issues can be adequately addressed in the Final Environmental statement (FES). We may modify these comments in response to any changes in information in any supplementary DES or the Final Environmental Statement (FES).

Humboldt Bay is the largest wetland and estuarine habitat in the California coastal zone, containing approximately 23 percent of the coastal vetlands in California. Its waters hold a diverse fish fauna, including anchovies, chinook and cojo salmon, steelhead, cutthroat trout, smelts, surfperch, rockfishes, sand dabs, soles and flounder. Thirty six species of fish utilize the bay as a nursery grcund or spawning area. The invertebrate biota of the bay include species in sixteen major invertebrate groups. Approximately 750 acres of the bay's bottom and channels sre used for commercial oyster j(,g production. Many of the bird species using the bay are protected by international treatles which impose national responsibility for protection of their habitats. Peregrine falcons, which are on the federal endangered species list, hunt over the bay's narshes and farmlands, and rare and endangered plants grow on the dunes and in the brackish and saltwater marshes. The rivers and streams tributary to the bay provide spawning habitats for anadromous fish, and the bay's estuarine areas provide important nursery areas for juvenile salmon and trout. Streamside riparian habitats hold diverse wildlife populations. The Coastal Commission has a long history of concern for protection these and other resources of the Humboldt Bay area.

The DES is notable in that it provides virtually no description or analysis of II environmental setting of the proposed activities.

4 i

i t

Humboldt Bay Unit 3 FES 3 Appendix C

Mr. Fellows June 9, 1986 Page 2 l J L Should the proposed decomissioning commence, the development activities associated with it will be subject to the provisions of the California Coastal l

Act (Cal. Public Resources Code, Division 20. Section 30000 et seq.). Section 30600 requires that any new development in the Coastal Zone be authorized by a coastal development permit. ' Development' is defined (Section 30106), in part, as:

' Development

• means, on land, in or under water, the placement or erection of any solid material or structure; discharge or disposal of any dredged material or of any gaseous, liquid, solid, or thermal waste; grading, removing, dredging, mining, or extraction of any materials; change in the density or intensity of use of land, including.....

change in the intensity of use of wate*, or of access thereto; construction, reconstruction, demolition, or alteration of the size of any structure, including any facility of any private, public, or municipal utility;...

A-1 As used in this section, ' structure" includes, but is not limited to, any building, road, pipe, fiume, conduit, siphon, aqueduct, tele; hone line, and electrical power transmission and distribution line.

In connect 1on with the coastal permit process, Commission staff is available to assist the applicant in answering any questions or to serve in a consultative capacity.

According to the information provided by the NRC, Pacific Gas and Electric (PG&E) proposes to decomission the Humboldt Bay Nuclear Power Plant in a two-step process: (1) safe storage (SAFS10R); and (2) delayed decommissioning (DEC01). PG&E (the licensee) proposes to store the spent fuel assemblies at the Hunoldt Bay site for at least 30 years to be followed by a dismantling of the entire r.uclear facility, a process of indeterminate length and one for which no plan yet exists. As the following comments indicate, we do not believe that current plans or documentation have adequately addressed the potential significart envirer.cental '.? pacts of long term storage of nuclear materials at Hurboldt Bay in the 'nanner required by either the National Environmental Policy Act (NEPA) or the Coastal Act.

1. Soil and k!ater Conteminatien The Humboldt Bay area includes about 12.010 acres of farmland, including about 7,000 acres of diked lands. These far.T. lands, including portions of the bay's diked lands, held a substantial a,ea o' trwe agricultural soils. Eastern Humboldt Bay contain approricately 4,C?J of agricultural land of high value to the local f arr, c:enomy.

The DES identifits the p.-oblem of continuous leakage (since 1966) of radioactive liqual irrn the spent fuel occi which has resulted in soll conta'nina t ion. :t e c..ceent f urther states that the installation of a stainless sttel liner has attenuated the leak. We note, however, that the radioactive discharp has not been halted. in view of the licensee's proposal I f Humboldt Bay Unit 3 FES 4 Appendix C

M . Fellows June 9, iia 6 Page 3 JL to store the irradiated fuel assemblies and in-core fission chambers within i the same pool, we believe that there is a greater risk for a higher level of i soll contamination than has been indicated in the DES. Moreover, this leakage j has the potential to contaminate the ground water basin beneath the plant j facility. As noted in the Environmental Report (ER), there is exchange of water between the bay and wetlands and ground water in the vicinity of the plant. The DES states that, " Pumps keep water. level in the liner gap lower j than the water level in the pool and ground water level. The water from the i liner gap is pumped to the radwaste system". (p. 2-1,5). Such nechanical means of controlling the leak are subject to malfunction. The IES should fully disclose the potential cumulative ef fects of increasing tre amount of long-term storage of radioactive liquid in a pool already plae,ued by leakage.

Further, the FES should more fully identify measures for mitigating the potential impacts, including pump malfunction and leakage risk. This analysis should address ef fects on area f armlands, ground water, wetlands, and bay waters.

.I According to the ER, a 1981 evaluation of the nuclide distribution and l; in.entory at Humboldt Bay Power Plant indicated elevated and trace levels of

A-2 certain r.uciides.

! 'These samples indicate areas of the Unit No. 3 exclusion j grounds which may require decontamination prior to

dismantlement $1nce concentrations in these surface soils are all in excess of the proposed acceptable limits for residual soil contamination. (p. 4-64. ER.)

,' A soll analysis of transuranics in the exclusion area conducted by Pacific Northwest Laboratory (PNL) in 1983 also indicated the presence of plutonium of reactor origin. The ER states that *...the TRU concentrations may not be significant from a waster management viewpoint and would not warrant soll excavation for disposal as LlW.* It appears that varying levels of soll contamination persist in spite of efforts to contain the radioacthe nuclides. The proposal to enclose the radwaste building for storage of additional contaminants generated by the SAFSTOR process may increase soll contamination.

a The DES does not provide adequate information to determine how the proposed j construction will incorporate safeguards to prevent soil and, possibly, contamination. The FES should contain additional data, plans ano mitigation (neasures suf ficient to protect the environment around the plant f rom

- additional nuclide contamination. 1 1

l 2. Seismic Safety I

i The decision of PC&E to pursue decomissioning was based upon several considerations including economic factors:

i

? l Humboldt Bay Unit 3 FES 5 Appendix C

E Mr. Fellows June 9. 1986 Page 4 In 1983, the licensee (Pacific Gas and Electric Company) concluded that the seismic and TM1 modifications

• required for restart were uneconomical and decided to decommission the plant. (p.1-1. DCS.)

In 11gh'. of this history, we believe that the DES' treatment of seismic hazards of this site and their potential ef fect in connection with the proposed project 15 too cursory.

The Environmental Report For the Decommisaloning of Humboldt Bay Power Ply t (HBPP) Unit No. 3 (July, 1984) indicates that there are three capable or potentially capable geologic faults near the HBPP: (1) Little Salmon Fault; (2) Bay Entrance Fault; and (3) the Buhne Point Fault. The surface trace of each fault passes within 2 1/2 miles of the facility with the Buhne Point subsurface trace coming within 600 feet of the plant foundation. Furthermore, the ER states that:

The proximity of these capable or potentially capable faults to the plant site, along with the assumption (WCC 1980) that major earthquakes could occur (with magnitudes up to 7.5) suggests that severe ground shaking could res J1t from seismic A-3 activity generated along these faults. ( p. 10. 3-14)

Other potentially active faults have been documented in *!dentification of Seismic Related Hazards in the Coastal Zone' (1977) and include the following faults within approximately 40 miles radius:

The Falor-Korbel fault (active) transects northwest Arcata and is capable of a 6.0 to 7.0 M earthquake (ENVICOM,1975).

The Capee _Nendocino-False Cape Shear Zone (active) is estimated to be capable of a 1.3 M earthquake.

The Mendocino Fracture Zone (potentially active) is located in (or comprises) one of the most seismically active areas in North America. (V-(7])

(The Mendocino fracture zone is part of the tectonically active triple plate junction and is capable of a 7+ (Richter scale) magnitude (November,1980) and is possibly capable of a seismic event of " great quake

• magnitude (8.0 or greater]).

The report continues by stating that *Within the boundaries of the coastal tone, the majority of land areas ranks as 'least suitable' for siting of

• Modifications necessary to comply with requirements imposed af ter the I I accident at Three Mlle Island (TMI) Unit 2.

I Humboldt Bay Unit 3 FES 6 Appendix C

Mr. fellows June 9, 1986

( Page 5 i

critical facilities...The criterion establishes 'least suitable' areas as those falling within a five-mile radius of a capable fault." The study considers much of Humboldt Bay as falling within a least suitable area.

It is evident that the plant site is located in an area with a high degree of seismic activity, either active or potential, and that large, active f aults within 20 or even 40 miles of the Coastal Zone may have a substantial impact on the plant facility with concomitant adverse ef fects on coastal zone 1

'4-3 res urces. The Enerov Oilerna (California Resources Agency,1973, p. 46) l points out the shortsightecness of assuming an area safe from seismic hazards due to the fact that existing maps and data do not indicate active faults:

1 Indeed, in the past decade evidence has been produced to show I that faults not previously recognized as active are potentially active. Further, with few exceptions, every earthquake that caused fault rupture and every Swann of earthquake epicenters has occurred along faults not previously recognized as active. Certainly the 1971 San Fernando earthquake occurred along a fault not previously

_ known to be active.

The DES on this proposal for long-term storage of radioactive materials in an area highly susceptible to seismic hazards contains virtually no analysis cf relevant seismic factors and only cursory consideration of those hazards' interactions with hazardous materials stored on site. The utility's inability to carry cut the seismic itsdifications necessary to continue operation of the nuclear plant were in a large part responsible for tte 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. For example, in the existing alternatives analysis, one off-site alternative, independent spent fuel storage installation (ISFSI) is rejected in part because of possible seismic p considerations. The OES states:

Thus, this alternative would be more costly than SAFSTOR, would have the additional environmental impacts associated with off-site transportation, and would require seismit considerations of the ISFSt. (p 1-4, emphasis added.)

The anomaly of this result is highlighted by the DES discussion of the ENTONS alternative which says, "lhe entombment structure may also fall as a result of seismic events with a potential for a release of radioactivity." (p.1-3.)

Apparently, even when ento . bed in a concrete container, the radioactive liquid cannot be safekept against seismic events. It is unclear how SAFSTOR will provide the necessary seismic security.

37 In f act, it is quite likely that the 30 year SAFSIOR period may estend beyond this timeframe. As indicated in the R:

l l

Humboldt Bay Unit 3 FES 7 Appendix C

Mr. Fellows June 9, 1986 Page 6 j( The duration of SAFSTOR at HEPP Unit No. 3 may be affected by several factors:

availability of DOE repository for receipt of spent fuel from Unit No. 3; dose rate reduction suf ficient to reduce / eliminate the i

need for remote handling; and need for site occupied by Unit No. 3 to be used by PG&E A-4 for an alternate purpose. (p 6-5. ER)

It is dif ficult 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.* Also, the proposed 30-year SAFS10R period may extend for an indefinite period, further increasing the possibility that the facility will be exposed to seismic events, an issue not fully explored 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. Clearly, substantial supplementation

_ of this DES is needed to adecuately address the seismic safety issue.

3. SAFSIOR

a. Radioactive Waste Storace The DES describes the radioactive waste management systems proposed for implementation during SAFSTOR. Indicating that " liquid waste generated during the SAFS10R period will be processed and disposed of." Lisewhere, the DES states that " dry active waste and contaminated ' tools, equipment. lumber, and soil will be packaged for shipment and stored until they are shipped of f site for disposal." In both instances, it is vague as to which of the contaminated materials can be considered " low level waste" and thus may be disposed A 5 of r-site, and whleh materiais contains a higher degree of radioactivity necessitating on-site storage. The DES is vague regarding the amounts of each type of material which will be stored on-site until a permanent licensed disposal site is established. Further it is unclear as to the location of a LLW site and if existing materials are already being transported there. If PG&E has such a site already selected, then the FES should state the location and evaluate the associated impacts at that location.. If one is not available, then information should be provided regarding long-term storage of high and low level radioactive materials.

b. Radwaste Building The DES indicates that "a building will be erected to enclose the exposed portions of the radloactive waste processing system.' However details regarding the dimensions, site plans, or selsmic standards to which it will be A-6 built are not included in the DES. The FES should provide suf ficient detail regarding the radwaste building in order that public safety is ensured and in order that the Coastal Commissit,n nay determine whether the structure's design and location are most protective of coastal resources.

Humboldt Bay Unit 3 FES 8 Appendix C

Mr. Fellows June 9, 1986 Page 7 Jk l

Additionally, we remain concerned about development of another f acility to store radioactive wastes in a seismically hazardous area. Presumably, the structural integrity of the radwaste building will not meet the standards required of the larger po er f acility. Thus, it may be more susceptible to l /\-0 earthquake damage with the resulting radioactive contamination of the soil, i

ground water, and cpen waters of Humboldt Bay. 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 f ail or be disabled by structural or power f ailures resulting i

from seismic events.

c. Chemical Cecontamination The ES indicates that it will be necessary to use chemical agents to decontaminate the f acility at various phases of the decommissioning process:

The chemicals employed can have hazardous properties Snd/or toxic properties. In addition, these chemicals have applications to reutine radiological waste management, such as solidification inhibition or evaporation attenuation.

Pre-treatment of these waste prior to disposal...can have toxicology consequences. (p. 10.5-23, ES)

A-7 The ES further notes that "use of chemicals has implications to shallow-land burial". Althvugh existing state and federal regulations address the environmental conscquences of the disposal of these hazardous materials, it is critical to know which of these raterials will remain on-site (and for hos long), as well as the intendtd disposal site of those chemicals which can be safely transported to a licensed disposal f acility. It is also important to know how bazardous raterials presently used in plant maintenance and operation are transported ard the location of the disposal site. The FES should provice this infortation, .r:luding alternatives to off-site disposal and mitigatica measures.

d. Alternatives,to StJST04 Throughout the DES, the argunent su: porting SAFSTOR is based largely upon the assumption that thece is r,o disposal sitt available for the spent nuclear fuel assemblics and t'ai an/ f ederal decisicn regarding a licensed disposal site will be f orthcenim s. ring the 30-year !?J S109 period. The DES refers only to NEC disposal sitts afd ignores cny other alternative sites which may be available through tre Department of Enert> (00E) or other agencies, gg,g For example, nuclear waste f ro9 at least tuo other major nuclear plants is being taken ta et

federal discesal sit:1 run by 00E; Nuclear waste f rom the Three Mile is c c r.uclear plant in Pennsylvania is being shipped to the Hanford reserv.1ti;' n eastern '.?ashingtg.. This same site is also slated to receive the racleir raterial f rc9 the Shicaingport nuclear power plant, also located in Fcnos se ta. It is car understanding that Hanford has also been receiving nacit.: nite-tal f rom the Hv.;;1Jt Bay nuclear plant for many years. In that thare w3s a significant larard associated with Tril, and that 3r Shippingport is te.r.; dismantled, there e0 pears to be an established precedent Humboldt Bay Unit 3 FES 9 Appendix C

Mr. Fellows June 9, 1986 i l Page 8 for utilizing Hanford as a disposal site in certain situations where pubile A-R safety is an overriding issue. The FE5 should give stronger consideration to this alterative and explore not only shipping of nuclear fuel assemblics, but dismantling the entire facility to be ultimately disposed at Hanford or

_ elsewhere.

In addition, the E5 assumes for the purposes of analyzing the potential radiation occupational external dose and public dose for fuel handling and shipment that the DOE facility in Carlsbad, New Mexico will be the repository for spent fuel. It is unclear why this f acility was used for analytical

~

purposes but not seriously considered for immediate disposal of the spent A-9 fuel. Moreover, if th15 Site is not available for disposal of radioactive waste, then 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). However, if the Carlsbad f acility is a potential receiver site, then PME and the FES should thoroughly analyre the possibility of using it as a repository for the fuel and other contaminated material from Humboldt.

Similarly, the ES indicates that 'the reactor vessel might by shipped by barge, as the Shippingport vessel is scheduled to be shipped, to a commercial site at Richland WA.' (p.10.6-7, ES). If this component of the Pennsylvania A-10 plant can be transported across tne country to Washington, why is it not feasible to transport the same elements of Humboldt to Richland? Answers to the above questions will be necessary in order that the Coastal Commission can determine whether the final proposal is most feasible, least environmentally damaging alternative,

e. Projected Costs for SAFSTOR/0 ECON i

It is difficult to clearly ascertain the total costs involved in implementing the SAf5 TOR /0 ECON alternative. Neither the Executive Summary in the ES nor the DES contain readily available information indicating the 30 year costs for A-11 SAF510R and DECON. As the information provided for DECON is largely' conccptual, we are most concerned about the projected costs for this phase of decommissioning. Without this inforir.ation, evaluation of the feasibility of

_ the various alternatives is not possible.

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4 California Coastal Act of 1976

As discussed earlier in this coment letter, if the proposed decorrilssioning 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. At the A-12 time a coastal development permit application is received, a staf f report will be prepared and a public hearing scheduled. The project will be reviewed and analyzed in terms of its conformity with the policies of the Coastal Act, principally, those of Chapter 3. At the present stage.in our review of the l project, three sections of Chapter 3 appear most applicable, although others j may be applicable as well

(1) Section 30230--Marine Resources; (2) Section 30240--Environmenta11y Sensitive Habitat; and (3) Section 30253(1]--New J l f Development.

J Humboldt Bay Unit 3 FES 10 Appendix C i

f I

i l ,-

l Mr. Fellows June 9. 1986 i Page 9 I

b I k Section 30230 of the Coastal Act requires the maintenance, enhancement, and l restoration of marine resources and states that: ,

Marine resources shall be maintained, enhanced, and where j feasible, restored. Special protection shall be given to e

areas and species of special biological or economic '

significance. Uses of the marine environment shall be  !

carried out in a manner that will sustain the biological productivity of coastal waters and that will maintain healthy populations of all species of marine organisms adequate for long-term commercial, recreational, scientific, and 1 educational purposes.  !

Section 30240(a)(b) states that:

(a) [nvironmentally sensitive habitat areas shall be

! protected against any significant disruption of habitat values, and only uses dependent on such resources shall be allowed within such areas.

I (b) Development in areas adjacent to environmentally sensitive habitat areas and parks and recreation areas shall I

be sited and designed to prevent impacts which would i significantly degrade such areas, and shall be compatible j A-12 with the continuance of such habitat areas, i

j Section 30253(1) states in part that:

New development shall:

1

) (1) Hinimize risks to life and property in areas of high

geologic, flood, and fire hazard.

The Comnission's review will focus on possible ef fects to nearby resources and i

upon possible economic consequences of damage or risk to those resources, i Humboldt Cay has a diverse fish comunity which includes transit coastal and

{

offshore species as well as year round residents. The Bay also supports both commercial and sports fishery activities. The Bay's ecosystem also includes significant communities of eelgrass, mud and sand flats, salt and brackish marshes as well as freshwater marshes and ponds. The diversity of the aquatic

communttles is crucial to maintaining healthy fish populations which in turn l provide significant economic benefits to the area.

l Based on our current Ilmited information, it appears that the SAFSTOR j

alternative proposed by PG&& involves risks of serious.blological consequences to the marine resources of Humboldt Bay. [arly comments in this letter

! expressed concern over the continuing leakage of radioactive liquid, the

! prospect of increased leakage, and the potential resource damage or loss

( which could occur in the event of major seismic activity. 7 l

l Humboldt Bay Unit 3 FES 11 Appendix C

Mr. Fellows June 9, 1986 Page 10 The DES presents an analysis of an uncontrolled release from the two concentrated waste storage tanks as a worst case scenario for a radwaste tank accident. It assumes that approximately 10,000 gallons of the two tanks would A-13 flow directly into the discharge canal, and thence to Humboldt Bay. The FES is deficient in that it does not propose alternatives to discharge into the Bay or indicate that there are backup systems available to handle the

_ described emergency.

~

In its discussion of the potential impacts associated with a rupture of tie t spent f uel pool, Section 6.3.1.2 of the ER states that severe seismic shaking exceeding the .5g plant safe shutdown earthquake level is possible. The result assumed by the ER in the occurrence of such an event is a potential ,

rupture of the spent fuel storage pool's integrity. According to the ER, if '

this were to occur, the storage fluid would be retained because the ground water elevation surrounding the storage pool and suppression chamber exceeds  ;

the pool water elevation. This is further discussed in Section 6.3.2.2 of the  !

ER which states that:

• Ground water could be contaminated by the loss of pool water is a leak were to develop from the pool to the surrounding soil, but contamination would te very slight even if the leak  !

were very rapid...This esticate is conservative since the water volume released from the pool would reach an ,

equilibrium with the very high water table in the site soil t A-14 strata, l

This conclusion is at odds with the information presented in Section 10.3.2.2 of the ER, which concludes that ground water flows towards the Bay f rom the ,

site and that the aquifer is flushed each fear by high tides during winter and spring runoff, 1his information leads us to conclude that there clearly could be an exchange of radioactive material which could runof f to the wetlands and  ;

Bay. Such an ever.t could adversely ef fect tf.c Bay, both from the radiation in the various fish an1 tr.o11us'r species, and f rom serious financial iepacts on California's coastal fisherles industry. These impacts may result, in part, from either actual or p.iblicly perceived radiatlan hazards or contamination to various marine researces. If the consur-?rs either knew pr suspected that fish and shellfish wre coming f ron Hu.iboldt IMy coastal waters where radioactive wastes had been detected, sales of Bay fishery products could drop,  !

economically devastating Hutboldt'$ fistcries industry, f Any or all of these issues, as well as others such as ef fect of grading and construction activities, nay be the sut,1cet of Commission review of a coastal f

_ development permit application for this project.

5. Evacuation,,,hn P

Neither the ER rtr tr,e DES describes amt tristing or proposed evacuation plans to be irnplementoj in it.e event any of it c worst case scenarios presented in ,

A-15 the analyses, t . ein say ici proviee5 ine principal access between the Californla neti :t nd the r.etropoliie areas of the central and southern 1 portions of the si n e, and is appromir.attly one-half mile from the boundary of ,

the facility. It( *L1 should include ir.f ormation regarding evacuation plans.  !

_ t I

i t

Humboldt Bay Unit 3 FES 12 Appendix C I

Mr. Fellows June 9, 1986 Page 11

6. Conclusion In general, we believe the DES has not adequately addressed the issues of long-term storage of radioactive e.aterials in a known seismically hazardous area, nor has it adequately evaluated the alternative of transporting the spent fuel afsemblies to non-NRC disposal sites. Additionally, the analysis provided has been generic in nature to nuclear facilities and failed to A-16 address the specific limitations or the f acility in terms of its location and potential impacts to coastal researces. The DES indicates the likelihood thatg SAr$ TOR will extend beyond the proposed 30 year timeframe, and that the dismantling of the facility will take considerable additional time. Yet the DES does not analyze the irpacts of the possible longer duration of the fuel's

_ on site-storage.

The decomissioning of the Humboldt Bay plant will, in all likelihood, set the precedent for the rest of the nation's commercial reactors. The SAFSTOR alternative is essentially a time marker, f or it assumes that certain steps will be taken by others to ensure that the plant is permanently safe.

A 17 However, there is no analysis about long-term ef fects in the event that these anticipated steps are not taken. The Humboldt facility was never intended as a de f acto permanent waste dcpository, and any af ter-the-f act ef fort to convert it into one must be subject to a high level of environmental scrutiny. This does not occur in the present DES. It 15, in our view, seriously inadequate and must be substantially supplemented if it is to satisfy the requirements imposed by NEPA to insure informed decision-making.

If you have any questions about our coments or we can be of further assistance, please contact Michael Buck of our staf f at yuur convenience.

N Sincerely, ,

hf' O <, _

/

'/ -------%

8. Noah Tilghman ,

Program Manager /

Humboldt Bay Unit 3 FES 13 Appendix C

. - . . . . . _ - _ ._ .- - . - - - - - - . _ _ _ _ - . - - . . _ _ . . - . , ~ - - - -

[ DEPARTMENT Of HE ALTH A Ht'M O. %[RVICE% Put*c Heaith serv <e

\

Food and Drug admastraison Rockvdle MO 20867 JUN 161986 Herbert N. Berkow Director Standardization and Special Projects Directorate Division of IWR Licensiry-B U.S. Nuclear Regulatory Ccr1 mission Washington, DC 20555 Dear Mr. Berkow 1

The Staff of the Center for Devices and Radiological Health have reviewed

the Draf t Enviromental Statenent (DES) for deccrvnissioning the Htaboldt Bay Powr Plant, Unit No. 3, NURfD-1166, dated April 1986. Primarily our effort t has been directed to an evahation of the public health and safety impacts associated with the decawnbsionirg altematives. We have the following cuments to offer

! 1. Se discussion of decanissioning altematives in Section 1.3 provides a reasonable justification for selecting the safe storage alternative

B-1 (SAFSTOR). Further, story of the spent fuel assablies of the Htaboldt Bay Unit 3 spent fuel storage pm1 is considered to be the most effective i

alternative and will provide Mequate measures to protect public health and safety.

~

2. It is expected that mall quantities of radioactivity will be released to the enviroment during normal SAFSIOR operations. The source of such radioactivity will result froi decontamination of systems aM cmponents, I

the operation and maintenance of the spent fuel storage pool, and the processirn of waste managenent operations which have mntinued since the plant ceased operation in July 1976. Bus, the source term for estimating population dose over the 30-year SAFSTOR period is based on data gathered B2 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 rarge we believe that a measurement program should be conducted to verify that the releases are maintained as icw as reasonably achievable (AIARA). Se results of such a program should be made available to state and local health officials responsble for evaluating po-tential population dose fran the decanissioning operation.

I 3. The discussion in Section 3.2 on the radiological impact covers the gossible sources of occupational ard gepulation exposure. The dose computa-tion methcdology and mMels (Appendix B) used in the estimation of the dose B3 omenitments to individual mmbers of the public and to the general population within 80 kilcuneters of the plant have provided reasonable estimates of the dmes resulting fran decanissionirg operations. Results of these calcula-tions are shown in Appondix B, Table B.3 and B.4, and confim that the calcu-lated doses are minimal and meet current radiation protection standards. '

l P

i

.; Humboldt Bay Unit 3 FES 15 Appendix C ,

l

- -= , _ . - ._.- . _ , _ - - - - _

Herbert N. Berkow - Page 2

4. Se potential accident scenarios aM offsite radiological consequences of B-4 such accidents is considored to be an adequate assessnent of the exposure pathways aal the dose and health impacts resultirn fran accident situations.

5. The DES does not contain any specific infor.mtion on emengency plannirn ani coordination with~ the state of California in the unlikely event of an accident.

In our juigment, a section should be ailed to Cupter 3 that briefly presents B5 the plans aal emedination that would be in place durtry the 30-year deemnis-sionity period. This action is particularly important at this time in view of the increasal concern of the public relatiry to energency response and pro-

_ tective actions.

Thank you for the opportunity to review and cmwnt on this Draf t Environruntal Statenent.

Sincerely ars, Nwh///M ~

John C. Villfo Director Center for Devices and i Radiological Health

\

s.

Humboldt Bay Unit 3 FES 16 Appendix C

1

.Q SIERRA CLUB l

A a, . ., -

LEGAL DEFENSE FUND,INC.

l s .., u,. m ..ity Anal Adams ao44 Fd!more Screr San Frannsco, cahfornia 94Ii1 (415) 1674 ioo sau raeasco craca August 4, 1986 Fr:Jrw P. kcher:and

! tanew o'" Director I w.u..m s. catas Office of Nuclear Reactor Regulation

{ $jf3D, U.S. Nuclear Regulatory Commission i

Lawrens H. Sihn Washington, D.C. 20555

! M.6 o shn.aoa 5"**a C V**' Re: Comments on Draft EIS For Decommissioning Humboldt Bay Power Plant, Unit No. 3 (NUREG-ll66) i N tn Puku I G be a 4"+ a

Earl M. 8;aunee

Dear Sir,

l

u. K ""

The Sierra Club submits the following comments on the I In "",,c o,;. Nuclear Regulatory Commission's draft Environmental Impact j 3,3 y g,,g Statement (" draft EIS") on the Decommissioning of Humboldt c ".a,, Bay Power Plant, Unit No. 3 ("the plant") (NUREG-ll66).

9,,,, c % ,,, Individual members of the Sierra Club may submit comments u...,,,,,. of their own as well.

1 Tom Turwr l suf n ,..,, The Sierra Club is gratified that the NRC has seen fit l l ochn os,, to prepare a draft EIS on this issue, which is of immense  ;

public importance, and we thank you for extending the time

~

exiv e '" '" i l within which comments could be made. We have both general '

! [" j*" 5' and specific comments. ,

l Deain, Co Soaoz I oor 6e as,s General Comments W45MINGTone, O c prpicg is 6 P Strue. N W. The draft EIS is seriously deficient in three general 4 L,re im areas and the final EIS will have to be substantially 1 W h+ coa. o c- aaos improved in order to comply with the provisions of Sec.

3' 5 ' '"

• = onic8 102 ( 2 ) (C) of the National Environmental Policy Act (NEPA),

42 U.S.C. 5 4332(2)(C).

419 6th Sa 5

3%',ja8g g,, Under NEPA, an EIS has two purposes:

e s s am one purpose of the EIS is to provide decisionmakers with an environmental disclosure sufficiently detailed to aid in the substantive decision whether to proceed with the project in light of its environmental consequences. . . . In addition, preparation provide (s) the public with information on the environmental impact of a proposed project, as well as encourage (s) public participation in the development of that information.

Adler v. Lewis, 675 F.2d 1085, 1095-96 (9th Cir. 1982).

Humboldt Bay Unit 3 FES 17 Appendix C 1 l

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i -

f Office of Nuclear Reactor Regulation

August 4, 1986 Page Two i

1 See also Baltimore cas & Electric Co. v. NRDC, 462 U.S.

87, 97 (1983); 40 C.F.R. i 1502.1. When an EIS fails to fulfill either of its dual purposes of informing both the immediate decisionmaker and also the public of the environmental consequences of, and all reasonable I

alternatives to, a proposed action, it will be ruled inadequate by the courts. Ibid.

In order to fulfill these purposes, an EIS must i examine the direct, indirect, and cumulative effects of l the proposed action; must be based on accurate, high g quality scientific information and analysis; and must i discuss all reasonable alternatives to the proposed

, action. Andrus v. Sierra Club, 442 U.S. 347 (1979); Flint 4 C:-1 Ridge Development Co. v. Scenic Rivers Ass'n of Oklahoma, 1 690 U.S. 776 (1976); California v. Block, 690 F.2d 753 (9th Cir. 1982). Further, an EIS is to be a Ere-

, decisional document, providing the agency with the i information it needs to make an environmentally informed

! decision, "rather than justifying decisions already

made." 40 C.F.R. $ 1502.2(g).

i -

I When the draft EIS is examined in the light of these basic principles, it quite obviously is inadequate. o Perhaps the most fundamental flaw with the draft EIS is that it assumes throughout that the agency's preferred 1 alternative (30 year SAFSTOR) is "the sole viable alternative for spent fuel storage" at this time. E.g.,

pp. v (Summary and conclusions); 5-1 (conclusions). This C2 statement indicates that the agency has already made its

. decision; the discussion of alternatives (itself inadequate - see below), and indeed the entire EIS i

procedure thus becomes a sham, an exercise in l justification of the decision the agency has already made, j contrary to the mandate of NEPA.

I l Secondly, the draft EIS fails adequately to disclose l the full range and magnitude of the possible environmental j

consequences of the 30 year SAFSTOR alternative.

! To begin with, the draft EIS provides virtually no  !

j description or analysis of the human and natural "

C3 environmental setting of the plant. one would not learn from reading the draft EIS, for example, that Humboldt Bay

is the largest wetland and estuarine habitat in the J' qp california coastal zone, containing approximately 23 percent of the coastal wetlands in California, and that it i

i i

Humboldt Bay Unit 3 FES 18 Appendix C

Office of Nuclear Reactor Regulation August 4, 1986 Page Three d I provides habitat to hundreds of species of fish, birds and

, other wildlife, including several endangered species. Nor C-3 does the draft EIS describe the human populations within the vicinity of the plant that could be affected by the proposed action.

~~

A fatal deficiency is the draft EIS's failure to discuss the environmental impacts of a rupture in the spent fuel pool and consequent uncontrolled release of I highly radioactive materials into the environment caused

! by a major earthquake or series of earthquakes in the vicinity of the plant. This is the Sierra Club's main i concern with the 30 year SAFSTOR alternative. The plant sits on or near three major fault lines, and has been shut down since 1976 for the very reason that it is not designed or constructed to withstand a major earthquake.

Cl-4 It is hard to understand why a plant which everyone concedes is not seismically safe for normal operatiors could, without major modifications, be a safe repository for high level radioactive waste for 30 or more years.

The draft EIS does not answer, or even address, this question. After the tragedy at Chernobyl, it is not j sufficient to assume that "it could not happen here"; nor can the agency legally avoid discussicn of the impacts of such an event. See, e.g., Save our Ecosystems v. Clark, 747 F.2d 1240, 1243-1245 (9th Cir. 1984); 40 C.F.R. $5

,,,1502.22.

The final EIS should contain a full analysis of the possibility of a major earthquake or series of earthquakes occurring in the immediate vicinity of the plant during C;-5 the noxt 30 years, as well as a candid disclosure of the impacts to the natural and human environment in Northern j California should the spent fuel be released into the e

,, nvironment because of such an earthquake or otherwise.

( Third, the discussion of altornatives in the draft EIS is inadequate. The Council on Environmental Quality's regulations for implementing NEPA (which are, of course, binding on all ftAsral agencies, see Andrus v. Sierra i Club, 442 U.S. 347, 357-58 (1975)) term the alternatives C-6 section of an E 3 "the heart of the environmental impact statement." 40 C.F.R. $ 1502.14. The discussion "should present the environmental impacts of the proposal and the alternatives in comparative form, thus sharply defining the issues and providing a clear basis for choice among options by the decisionmaker and the public." Ibid. The

) EIS must " Rigorously explore and objectively evaluate all 4 j f reasonable alternatives," and must " Devote substantial 1 Humboldt Bay Unit 3 FES 19 Appendix C l

Office of Nuclear Reactor Regulation August 4, 1986 Page Four JL treatment to each alternative considered in detail including the proposed action so that reviewers may evaluate their comparative merits." Section 1502.14(a) and (b). A presentation of alternatives that is skewed and biased in favor of the preferred alternative does not comply with NEPA. E.g., California v. Block, 690 F.2d 753, 766-769 (9th Cir. 1982).

C-6 The discussion of alternatives is fatally flawed from the start because, as mentioned above, it assumes that the agency's preferred alternative, 30 year SAFSTOR is "the sole viable alternative." This premise results in a discussion of alternatives that is half-hearted at best and disingenuous at worst, and that omits completely a

__ number of reasonable alternatives.

The most important alternative, and the one Sierra Club favors, is immediate dismantling of the plant and removal of the spent fuel from the site ("DECON"). This is also the decommissioning alternative favored by the NRC itself in its draft Generic EIS on Deconissioning of Nuclear Facilities. (NUREG-0586, January 1981). As the NRC stated in that document, " Decommissioning of a nuclear j facility should have as its primary objective thorcugh decontamination of radioactivity resulting in unrestricted use of the facility at the earliest practicable g,7 time....DECON would be considered the more preferable alternative in most instances since it would restore the facility and sit s for unrestricted use in a much shorter time period than SAFSTOR or ENTOMB." NUREG-0586, p. 0-39 (emphasis added) . See also pp. 0-16; 5-3; 5-10 to 5-12; 15-2 to 15-3. In light of this, one must question how the NRC can, only five years later, reject DECON as "not presently feasible". The agency's reason, again, is the premise that the spent fuel rods must be stored on site until a permanent NRC repository is ready to receive them. As is discussed below, this premise is erroneous because reasonable alternatives do exist to storing the spent fuel for 30 years or more at this admittedly leaking j ,_, and seismically unsafe facility,

~~

Sierra Club agrees that ENTOMB is an unacceptable alternative, but notes that the agency's reason, namely that "the entombment structure may also fail as a result C;-8 of seismic events with a potential for a release of radioactivity," draft EIS, pp. 1-3; 4-1, seems equally applicable to the 30 year SAFSTOR alternative preferred by the agency.

- 1 t

.l Humboldt Bay Unit 3 FES 20 Appendix C

i i

office of Nuclear Reactor Regulation August 4, 1986 Page Five Sierra Club also agrees that the no action alternative is not acceptable.

I Finally, Sierra Club agrees that SAFSTOR for a period of no more than 30 years may, in some cases, well be an acceptable, or even the preferred, decommissioning alterna-tive, as also determined by the NRC in its Generic EIS on Decommissioning. Each particular situation must be looked at individually, however, and therefore the NRC cannot rely on its so-called generic determination, contained in 10 C.F.R. $ 51.23(a), that in all instances, under all conditions, "no significant environmental impact will result frcm the storage of spent fuel in reactor facility storage pools... located at... reactor sites." Draft EIS,

p. 1-3; 4-1. Rather, for potential environmental con-sequences of the magnitude involved in decommissioning nuclear power plants, NEPA requires that site-specific determinations must be made. E.g., City of Tenakee

' Springs v. Block, 778 F.2d 1402, 1407 (9th Cir. 1985).

The Humboldt Bay plant is a classic example of the i need for site-specific review: while spent nuclear fuel I could perhaps safely be stored temporarily at some nuclear

! facility sites around the country, it is at least i C.g questionable whether it is safe to do so at Humboldt Bay because of the earthquake problem. At the very least, this problem must be candidly acknowledged and fully discussed in the final EIS.

The discussion of alternative dispositions of the spent fuel ought to be the heart of this EIS. In the draft EIS, unfortunately, the discussion is fatally skewed and biased, apparently so as to confirm the agency's premise that the fuel rods have to remain at the site.

I Two of the four alternatives discussed, for example, are simply not alternatives, and their inclusion can only be seen as an attempt to " pad" the alternatives discussion. Shipping the spent fuel to Diablo Canyon is not a realistic alternative because that facility also sits on highly earthquake-prone ground and is just as seismically suspect as is the Humboldt Bay plant.

2 Similarly, one wonders why the draft EIS bothers to

include as an alternative shipping the spent fuel to a i reprocessing facility for reprocessing while simultane-ously acknowledging that this is not in fact a viable

alternative "because there is no operating commercial reprocessing facility in the United States, nor is there y7 the prospect for one in the foreseeable future," p. 1-4.

l l

I 1

Humboldt Bay Unit 3 FES 21 Appendix C

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Office of Nuclear Reactor Regulation August 4, 1986 Page Six J k Two of the alternatives discussed, on the other hand, seem reasonable and may be appropriate under the circumstances of this case: shipment of the spent fuel to a Federal interim storage (FIS) facility, or constructing an independent spent fuel storage installation (ISFSI) at a site away from the plant. See p. 1-4. These should be given a much fuller and more objective treatment in the final EIS, with a quantified discussion of the costs and environmental consequences of each for comparison with the costs and possible consequences of storing the spent fuel Cl-9 at the plant for 30 years.

Finally, the draft EIS omits altogether any discussion of alternative disposal sites that may be available through the Department of Energ/ or Department of Defense. Such facilities are being utilized as the waste repositories for the decommissioning of the Shippingport and Three Mile Island nuclear power plants. NEPA requires that the NRC include a discussion of reasonable alternatives "not within the jurisdiction of the lead agency," 40 C.F.R. 5 1502.14(c). The final EIS must not confine itself only to a consideration of the availability of NRC operated disposal sites.

Specific Comments 4

For ease of presentation, the following specific comments are listed sequentially page by page starting from the front of the draft EIS:

1. Page v, Summary and Conclusions, Paragraph 3. This paragraph indicates that PG&E concluded in 1983 that the seismic requirements may continue to be too costly C:-10 t c nsider 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?

2. Page vi, paragraph 5(e) indicates that there is a

" negligibly small likelihood" that seismic loads or other mechanical loads would generate criticality C:-11 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."

l l

l Humboldt Bay Unit 3 FES 22 Appendix C

Office of Nuclear Reactor Regulation August 4, 1986 Page Seven

3. Section 2, Description of Plant and Proposed Decommissir.g Plan. Page 2-1. Third paragraph of the page mentions 390 partially or " completely spent" fuel assemblies. The term " completely spent" is a 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 C:-12 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. 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.

""" 4 . 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 is maintained at a level lower than the ground water level. The implication of this is that this C -13 " pump-down" process 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 require-ment should be a condition of approval of the plan.

5. General comments on Section 2:

- No schedule is stated for the proposed actions.

]

- No commitment is made for monitoring and processing

, C-14 the fuel storage pool liner leakage or for stabilization of soil contamination.

i -

No consideration is given to the possibility of l decontamination and removal (now) of those portions

, of the plant that are not necessary for'the continued safe storage of the spent fuel.

l Humboldt Bay Unit 3 FES 23 Appendix C

Office of Nuclear Reactor Regulation August 4, 1986 Page Eight

6. 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 C:-15 treatment system which will be diluted with the cooling water flow from the two fossil fuel units.

Has PG&E given any assurance that the two fossil fuel units will be in operation for the next 30 years?

7. Page 3-4, last paragraph of Section 3.2. This paragraph indicates that the NRC is using estimates C;-1S from NUREG/CR-0672 for calculating the environmental 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?

8. Page 3-4, Section 3.2.1., Occupational Radiation Exposure. This Section states that the total occupational exposure for SAFSTCR with delayed DECON will be about 177 personrems. These totals are based g,j7 on estimates produced by PG&E. Later in the draft EIS (Table 4.1) it is stated that the SAFSTOR with deferred DECON alternative has the lowest occupational radiation dose of all alternatives. However, the draft EIS nowhere quanitifies the doses for the other

,,, alternatives for purposes of comparison.

9. 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 C-18 limits should be specified. Limits are mentioned on the following page 3-7, fifth paragraph, where the draft EIS indicates that PG&E has proposed technical specifications. ,These specifications are not set out or discussed. Has the NRC reviewed these specifications and are they adequate?

10. Pages 3-6 and 3-7, Section 3.2.2, Radioactive Waste Hanagement Systems. There are numerous 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 C-19 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 qr performance requirements. It also indicates that i

i Humboldt Bay Unit 3 FES 24 Appendix C

Office of Nuclear Reactor Regulation August 4, 1986 Page Nine

/ l controlled ventilation will not be provided for the solid waste storage vault, the low-level waste storage C-19 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.

11. 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 C;-20 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 PG&E proposed any surveillance of the program to ensure this material is maintained in a functional condition?

12. 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 C-21 assemblie's , "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.

( 13. Page 3-10, Section 3.2.3.4, Critically Potential of Stored Fuel. Sub-paragraph 1 discusses the neutron C:-22 i absorbing material boral. See comment on this issue L on page 3-9.

14 . Page 3-11. This page has numerous statements that are vague and/or unsubstantiated. For example: sub-paragraph (1) states that "this is conservative as even a small amount of burn-up will reduce reactivity somewhat"; sub-paragraph (3) asserts that a local pile C;-23 of fuel pellets (low-enrichment) is "very likely to be undermoderated and sub-critical"; next paragraph, "the staff concludes that there is a negligibly small likelihood" of criticality; last paragraph, "these are all very small fractions of the PAG dose levels." The above statements are judgment factors that are unsupported by the draft EIS.

l Humboldt Bay Unit 3 FES 25 Appendix C

Office of Nuclear Reactor Regulation August 4, 1986 Page Ten

15. 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 PGGE C-24 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 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.

~~~

16. Summarizing some of the above comments on Section 3:

There is a frequent use of imprecise terms including: somewhat, very likely, small likelihood, very small fractions, etc.

C-25 There is a need to make sure that the PG&E proposed technical specification is adequately reviewed and implemented.

The NRC should perform bounding (maximum possible) calculations for the consequences of all pathways.

The final EIS should provide the basis for all of the conclusions reached in it.

17. Section 4, Summary of Decommissioning Alternatives.

f Page 4-1, third paragraph. This paragraph states that the DECON decommissioning alternative would result in greater occupational radiation exposure. This is not C~26 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.

E 18. Page 4-3, Table 4.1.

C-27 This table provides a comparison of the decommissioning alternatives. These factors

(,, should all be quantified.

m Humboldt Bay Unit 3 FES 26 '

Appendix C i -

l-

Office of Nuclear Reactor Regulation August 4, 1986 Page Eleven Thank you for this opportunity to cominent.

Very truly yours, A 00 hichael R. Sherwood MRS:lhi Humboldt Bay Unit 3 FES 27 Appendix C

August 12, 19CS Otrectcr Office of Nuclear Reactor Regulation U.S. Nuclear Re;ulatory Conmasston Washington. 0.C. 20555 RE: Comments on Oraft Environmental statement for Decommtssioning Humboldt Bay Power Plant, Unit No. 3 (NUREG-1166)

Dear Str.

I The Redwood Alliance submits the following comments on the Nuclear Regulatory l Commission's Draf t Environmental Statement (heretnaf ter known as *0ES*), for Decommissioning Humboldt Bay Power Plant, Unit No. 3 theretnafter known as 'the plant *) (NURE6-1166).

The Redwood Alliance has represented the interests of a large segment of Humcoldt County's population several times in matters concerning the plant, including, but not Itmited to, support for previous intervention, int erverti t on in Public Utility Commission rate hearings, and monitoring and pubiscizing safety and environmental issues at the plant. The Redwoo; Alliance now represents the viewpoints and concerns of those in the above menttoned segment who for whatever reason are' unable to submit their own written comments on the DES. The Redwood Alliance feels, however, that these persons' comments would be better made by each individual in a public hearing on the DES, and strongly urges the NRC to reconsider the decision to not hold a public hearing on this traortant document.

COMMENTS t, The CES does not comply with the provtsions and intentions of the National Environmental Policy Act (NEPA) because it fatts to examine the direct, D.j andtreet and cumulative effects of the proposed action. The DES should have provided dectstonmakers with an environmental disclosure sufficiently detatted to aid in the substantive decision whether to proceed with the project in Itcht of its environmental consequences. In addition, preparation should provide the I p' cite with information on the environmental impact of the proposed project, as 4 .

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Humboldt Bay Unit 3 FES 29 Appendix C

l Redwood Alliance's DES Comments Page 2 J L D-1 "*11 *$ encourao* ouet te participatton 2n the developaent of that $a'oraation-2 '"' UES * "'" "' " d***""' " "

D4 '"*!Y'** *' 'h' * ""*" '" " "*""*"* '

the public and elected offtetals obtained at the scoping session.

3. This community has long held the position that immediate spent fuel removal' and reactor dismantlement at the earliest possible date are the only safe alteanatives for a plant that is sited near several potentially active D-3 earthauave raults. unfortunately, the Nac took the position that a 30 year SAFSTOR of fuel and reactor is the only viable alternative for the the plant, and then proceeded to use the DES as an instrument to justify that posttion.

1

4. Further consideretton should be given to off-site storage of spent and partially spent fuel. Because of the potential for seismic activity and because little is known about the way the fuel could react in the case of a major seismic event, storage in a Federa! Interan Storage facility or an independent spent fuel storage installation (constructed away from the plant site and away from seismic and other hazards Leay well qualify as the only saf e D4 clast resort s alternatives under the Nuclear waste Pottey Act of iss2 (NWPA).

It is difficult to understand how the plant can be considered unsafe for continued operetton because of seismic instability yet can be considered safe for storage of nuclear waste which could reach critical mass under extreme conditions. Department of Energy or Department of Defense factittles are currently being used for disposal of high level waste from the decommissioning

_of Shsppingport and Three fille Island nuclear power plants.

D-5 5' '"*"' ** " d*""'" ' 'h' '"" ""*" *"*"'***"'" ' ' " ' * * * * * " "

of its relative importance.

. The FES should contaan a full discussion of the potential for a major urth uake and neto f earth uaku in tne victntty r the plant. Included in D-6 that discussion should be a detailed assesment of the resulting potential

.I jamagetotheplant and the environment.

7.Evenan its assumption that SAFSTOR is the only viable alternattve for decommissiontng the plant, the OES fails to address the effect of storage and DJ eventual dismantlement n the human and natural settings f the plant.

Included tn this should be a detailed analysts of the potential impacts shculd high level waste be released into the environment by catastrophic earthquake or

, otherwise.

3. The Final Environmental Statement (FES) should include a full discussion of the site hydrology, and its relationshto to future potenttal and past contamination of the groundwater around the plant, and the potential for migratton into the adjacent bay.

D-9

'"* '""**** *' * ''""' '" '"' ***"' '" " ""' **** l'"*" """" '" "'d **

_more adecuately discussed.

0.Because the plant has been shut cown for over le years. the FES should D-10 further consider immediate dismantlement. 0 anger from occupatienal e posure qr has been overstated an the DES because many of the shorter-lived isotopes have Humboldt Bay Unit 3 FES 30 Appendix C

- _ _ _ _ ._ _ _ . _ . _ _ _ ~ _ . _ __ , - _ _

Redwood Alliance's CES Comments Page 3 4L already decayed away. Adantronally, differences an the off-stte truck traffic D-10 projections for SAFSTOR and DECON have samtlarly been overstated.

II.Spectfac reautrements for the procosed radwaste building should be l)-11 discussed an the FES. W&ll the increased capacity of the factitty contribute to an increased postbataty for environmental contamination?

12.The DES does not address the use and storage of chemical agents used for I)-12 decontamination, what are the potential environmental impacts of these

,, chemicals?

13.The DES f atls to address alternat tves to d& rect discharge of radweste into I)-13 ine bay. It etso glasses over the use of backup. systems in case of sne need

,,for emergency discharge.

g),34 14.There should be design spectftcstions for and a technical snelysis of the

,, safety specifications involving the proposed spent fuel cover.

15.The FES should con'tain a complete discussion of past empertences with boral

().15i shielding for spent ruel assemblies including effects of the long-term use proposed in the OES.

D-16l 16.The OES.contains no schedule for completion of proposed actions.

17.The DES needs to address assurances that the spent fuel pool will be D-17 edecuately monitored for leanage, and needs to dtscuss what would happen to the plant if the incensee someday goes out of business.

18.The FES should contatn the bests for all conclustons reached in it and j g),gg should avoid using empressions Lake " negligibly small*, 'very likely*, and

• negingably small likelthood* used to back up a position without Quantifying

,,the possibilities.

()-19 19.The FES snould contain a discusston of alternattves to trucking waste from

,,the plant. incuding the use of barges.

Concluston The DES to remarkeoly snadequate in its discuestons of the issues pertinent to the decommissiontng of the plant. In addition it doesn't even come close to fulfilling the requirements for an Envtronmental Impact Statement as stated in NEPA.

The most fundamental flaw to the DES ts the assumption that the agency's and the licensee's preferred alternative 19 the sole viable one. To compound this farce. the document then sets out to justify thts pos&tton with little regard to a discusston of alternatives. Secondly the OES fasis to adeouately danciese the full range and magn &tude of the consequences of th's 30 year SAFSTOR alternative.

The Recwood Alliance and the concerned etti: ens of this community can only hope that the FES will resolve these problems. This FES and the final license for decommissiontng the plant will set many precedents for treatment of other i

Humboldt Bay Unit 3 FES 31 Appendix C

Redwocd Alliance's DES Comments Page 4 l

plants soon to be decommisstoned. It as of paramou.it importance that this process be undertaken with entreme care and not the errogance and indifference

, that has been shown to date.

I l Thank you for this opportunity to comment.

Sincerely, [ [ ]

l

} l

? /

Michael Welch, Offt e Coordinator 1

Humboldt Bay Unit 3 FES 32 Appendix C

August 14, 1986 Peter B. Erickson Project Manager l Standardization and Special Projects Directorate i U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Res Proposed Decommission of

. Humboldt Bay Nuclear Power Plant

Dear Mr. Erickson:

We 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 E-1 J seismic occurrences could rupture the casings. Humboldt County is,an s area of high seismic activity. How much more dangerous is it to store the liquid waste without

_ entombment?

Our concern is that the DES will be accepted without much debate or further consideration. The DES contains E-2 numerousinstancesofvaguelanguage(eg.,"Thereisa negligibly en11 likelihood that seismic loads would generate critically among fuel assemblies stored in the pool.")

We are hoping that more research will be done into the decommissioning process, and more specific data can be provided about " worst case" environmental impact situations.

Sincerely, Elton Adams Kl O ^__ -

June Crym 3458 c Street Eureka CA 95501 l

l l Humboldt Bay Unit 3 FES 33 Appendix C i

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00KIENTS ON Ti!M LRAFT ENVIRONitE! ITAL STA"'" E!!T P03 DECUIIMISlI0llING HUMBOLT BAY POWER PLANT U::IT NO. 3 (Docket No. 50-133) by Thomas P. Infusino 1512 Drake Ave.

Burlingame, C A. 94010 June 15, 1986 Humboldt Bay Unit 3 FES 37 Appendix C

I) Introduc tion Upon reading the Draf t Environmental Statement for ve- '

com.

issioning Humbolt Bay Power Plan t No. 3 (EIS) I was struck by the many inadequacios of the document. The in-adequacies of the report compelled me to submit this public t

com;nent. I structured the comment so that the criteria used in the analysis are uct out firs t. Then the cri teria l are applied to the statement. The final section lists the conclusions of the analysis.

i j II) Criteria of Analysis A) Al ternatives The alternatives sce tion of an EIS presents "the en-vironmental impacts of the proposal and the alternatives in j comparative form. " (10 CFH 51, Subpt. A App. A g5).) The l agency must study the alternatives, and the study must be 1

revealed in the statement. (Rankin v. Coleman, 1975, 394 G1 F. Supp. 647. )

The agency uust develop all the alternatives in de tail, so as to provide a basis for comparison. (Joseph [

l

v. Adams, 1970, 467 F.Supp.141.)

The treatment of alterna-

tives must be comple te, so that a person removea from the j declulunmaking process can, on his own, evaluate the alter- I natives. (Sierra ulub v. Morton, 1975, 510 F.2d 81). )

B) Detail When composing an EIS, the Nuclear Regulatory Commission

! (ifRC) must a to the fullect extent prac.ticable quantify the

G2 various fac tors con.11dered. " (10 CPR 51.71d,) If on-si te in-vestidatica appears reasonably neccarary for an agency to i

. 1 Husoldt Bay Unit 3 FES 39 Appendix C i

2 h exercice its expertise, then such an investigation must be done. (3ierra Club v. Prochlk e , 1973, 39 F.supp. 1289 ) A valid ecosystem analysis is done by an interdisciplinary team of scientists conducting a rigorous examination. (EDF

v. Corps of Digineers, 1972, 348 F.3upp. 916. ) Also, a projec ts mere compliance with environmen tal quality standards does no t remove the requirement from the imC of analyzing and weighing all the environmental ef fec to cf the proposed action. (10 CFR 51.71 fn. 3) In addi tion, an EIS should in-clude a de tailed cost benefit analysis. (Cape lienry Ilird Club v. Liard, 1973, 359 F.Supp. 404. )

C) Objec tivi ty The courts have i..terpre ted the flational Divironmental

}'olicy Ac t (t El A) as requiring that agenciec produce com-prehensive and objec tive environmen tal ittpac t s ta tenen t s .

(EDF v. Corpa M E_ny,ineers, 1972, 340 P.3upp. 916) This means that the, fac to should be clearly separated from the opinions in the statement. It means that the statement muot reveal the unpleasant aspects of the propo ted projec t. It neans that ascertions taunt be supported by facts, and that the report is not misleading.

D) liitigation Measuroa "Where important to the comparative evaluation of alter-natives, appropriate mitigating measuren of the alternativoc will be diacusaed. ( 10 C F.1 51 Subpt A,. App. A (5).)

E) Unefulness Ul timately , an EI3 :.ius t be a useful docun.ent fo: at;ency Humboldt Bay Unit 3 FES 40 Appendix C 1

3  :

i decisionmakers and the general public. (City g Davis v.

i Coleman, 1975, 521 F. Supp. 661. ) A good EIS should provide a

enou3h information to enable one to understand and consider j r

i the essential elements of the decision. (Sierra Club v. Mor-i

! ton, 1975, 510 F.2d 813)

III) Application of C'riteria J  !

! A) Alternatives '

! A .s. .)

1 In this EIS, the agency 4 the alternatives in a circular j fashion, and failed to discuss all the viable alternatives.

,l Also, the ptaff failed to discuss the environmental impacts i of all threo major decommissioning alternatives noted in j ,

sec tion 1. 3. This prevents thoughtful comparison of the j I al torna tives.

~

The discussion of the DEO!! and ENTOMB alternatives is somewhat circular. (EIS, 1.3.3, 1.3.2) The report first assumes that the spent fuel will be stored on-site for those ll l alternatives. T.e report then no tes that this is a major i

! negative aspec t of each alternative. The discussion com-j

G3 pletely 1 6nores the possibility that the opent fuel could be stored off-site. Off-site storage at a large facility spe-I cificly built, sited, and designed for such a purpose may bo able to handle opent fuel from other plants in the near future, and reap efficiency of scale gains. It is inappropriate to structure alternativos so as to ensu're their undesirability. 3 The EIS does acknosledge that independent sient fuel l

G4 storace ir a posolble alcornative in its own ri6 t, hhowver,  !

the i l y the staff rejects the alternative duo to uncertainty of l

Humboldt Bay Unit 3 FES 41 Appendix C

3 decisionmakers and the general public. (City of Divin v.

Coleman, 1975, 521 F. Supp. 661. ) A good EIS should provide enou3h inf ormation to enable one to understand and consider i

l the essential elements of the decision. (Sierra Club v. Mor-ton, 1975, 510 P.2d 813)

III) Application of Criteria A) Alternativec J:s.ss el In this EIS, the agencynt he alternatives in a circular fachion, and failed to dincuss all the viable alternatives.

Also, the ptaff failed to discuco the environmental impacto of all three major deccanicoloning alternatives noted in sec tion 1. 3. Thin prevents thou6htful comparison of the al terna tives.

~

The discussion of the DT0!! and E!;T0tG altornatives is so:aewhat circular. (EIS, 1.3.3, 1.3.2) The report first accumes that the spent fuel will be stored on-site for these al te rna tives . T.ie report then no tes that this is a major negative aspec t of each alternative. The discussion com-pla te ly 16 nores the ponsibility tha t the opent fuel could be utored off-cite. Off-site storage at a large facility spe-cificly built, oited, and designed for auch a purpose may be able to handle spent fuel from other planto in the near future, and reap efficiency of scale gains. It in inappropriate to otructure alternativen so ao to ensu're their undesirability.

The EIS doca acknosledge that independent a,ent fuel G4 ctorace ir a ponnible alcornative in its own right, howver, the y the ataff rejects the alternative due to uncertair.ty of Humboldt Bat Unit 3 FES 41 Appendix C

! 4 i

4 J i available sites and the construction lead time. (EIS,1-4,

{

! 1-5.) Again, the altvrnative is structured so as to appear i less desirable than SAFSTON. Tne alternative, as struetured, j G-4 ignores the possibility that off-site storage could be en-ployed after a short period of on-site storage or storage at

a facility other than Humbolt.

i -

~

In addition to improperly atrueturing alternatives, the i

i staff failed to develop the environmental impacts of any al-I ternative other than SAF3 TOR. (EIS, 3 3-13.) In addi-G 5 tion, it failed to note the radiological impacts of SAF3 TOR j on the flora and Fauna around the Humbolt plant. The alter-natives are not detailed enough to provide a basis for com-

) -

pariron.

l The agency does have some diricretion to cull out of l

the analysis those alternatives that are beyond the ruiu of reason, but it should not have th discretion to atrueture otherwise reasonable alternatives ao as to unnecessarily l

1 burden them with unpleasant properties that enable the staff I to excuse itself from fully analysing the alternatives.

3) Detail The taost striking inadequacy of this EIS is the lack i of detail in almost every area.  ;

The alternatives to SAFSTOR are described in short paragraphs. (EI3, 1-2, 1-3) These are complex techniques

)

! involving high technology decontamination and dismantling I

i equipraen t. Tney require hours of labor and millione of dollars. However, none of this is uontionod or quantified.

i k . l t

j Humboldt Bay Unit 3 FES 42 Appendix C l l

{

I

_ . _ . _ _ _ . ._ _ _.- --_.._ - _._.._ _.,_ _ _ _ _ _-._ _ _ _ ~

- - _ - - - . - . - ~ - . . . . - . . - ._ . - - . ..- -_- .-

l l 5 1

The report claims that 3AFSTOR is the most cos t-effective '

alternative, but no quantitative data is provided to sub-stantiate that claim. As a result, one can't adequately

. weigh environmental costs and benefits against monetary costo l t

and benefits. A detailed cost / benefit analysis would be a step in the right direction.

1 The " Description of Plant" section is equally skotchy.

\ \

j (EIS, 2-1.) The report notes that their was a leak in the spent fuel pool during its initial operation in 1966, and l that the leak resulted in some soil contamination. It notes that, although a liner was installed to stop the leak, the liner itself leaks at a rate of .45 liters / day. It also f notes that there is some intermingling of the leakage and ,

the grounduster.

= llowever, the report fails to tell one if any tests have

} ,

been done to determine the migration rate of soil contami-l of nants, or3 the spread of contamination to the groundwater, or of

] any effects that the contamination or the leakage might have  !

u i on the environuent. These are all enne ntial de tails. It i

j G7 would be preposterous to license the storage of 6 pent fuul l in a pool whose leakage could cauoc extensive contamination, i That may not be the ense at llumbolt, but one is not given -

! enough informacion to make a deter.atnation regardin6 the l soundness of the pool. When such containation exists, thu l 4

j agwncy should perform a rigorous on-site investigation. The l i i j 1:IS ohown no evidence of such an investigation.

l Section 3, the impac t analysin, is plagued with similar i

I j Humboldt Bay Unit 3 FES 43 Appendix C

. _ - . _ _ . _ _ _ _ _ _ ~ _ ._ _ -._ . _ ._ _ -_

m . . . - . _ . _ _ __- _ - _ - _ _ _ _ . . _ . . _ . _ __. ._ ... _ __

l 6

oins of omloolon.

l Some of the area around the plant is used fos grazin6, and other areas around the plant support - rich and diverse I

estuarine habitato. Yet the EIS doco not mention the radi-l l ological effects of decomminoloning on plant and animal '

I popula tions . The report notes that the effects on humano l G8 from radiation exposure through the food chain would be

minimal following a major opent fuel pool opill, but the re-i , i port docon t detail the potential effect on other consumera

high on the Iood chain, like ahore birds, that would con-1 oume large quantitico of contaminated food if auch an'ac-

{ l l _

cident occurred. This ominaion should be rec tified.

~

Table 4-1 in t he project summary ocction includen un-1 f

j oubstantiated material. The table mentions that DECON 10

4 j the lowest cost alternative, but nowhere in the report are j dollar figure estimates of any of the alternatives given.

{ It also notco that DDCON resulto in twice the occupational ,

I doce of radiation of other alternativeo. This estimate 10 G 9 not mentioned anywhere else in the report, and the health i l

effects of such a done are not described in the report.

3 Are health effecto increased proportionally with the done l increnoe? If thio 10 the case, such a dooo incrence seems t lean aignificant when one conoidero that the ricks differ by a factor of four depending on the model one chooooo to une to measure the riok. (EI3, 3-4) The increa.se in health

rick would be within the error mar 61n of the nces ptoo co- l

! U tir:ation models. However, we are not given the inforuation 1

l i

I

! Humboldt Bay Unit 3 FES 44 Appendix C  !

l

. , _ , . . - . _ . - _ --.-,----.--_-v,_.,__m-----_-

_ _ ,___.. ___._._-...- m . . , - . - . . . - _ - - .

7 G9 necessary to make auch a determination.

' r This lack of regard for cignificant de tail is evident throughout the report, and 10 not limited to the few exampleo mentioned above. One would hope that when an agency is con-  ;

1 sidering an action oo expensive, complex, and potentially 1

hazardous as the decommionioning of a nuclear power plant that it would nore thoroughly dioplay the rigor of 1ts j analysio in the envirotunental impact statement.

< 0) Objectivity The agency'o use of 10 0FR 51.23a in the m;I3 iu miulcad-  ;

ing. The staff presento 10 0FH 51.23a ar If it were come i

j oort of evidence of the soundnoon of the on-site storage i proposal. (EIS, 4-1) When put in its proper context, the l regulation moroly clarifice when envirorunental impac to of opent fuel stora6e are to be conuidered, l i 10 0FR 51.23b useo the nouuranece se t forth in 10 0FR [

51.23a to state that no discussion needs to be made of the

! O environmental impacto of opent fuel storage in the reactor facility storage pools or an indupendent spent fuel storage installati'on for a period after that for which the applica-i j tion is bein6 made. So, new planto seeking operating 11- l

[ cences, or existing planto oceking to extend an operating l license, don't need to review the impacto of opent fuel etorage af ter the termination of the li conse for which the application is being made. The Eenoric detcrainntion mere- ,

i ly exprec.?es the NRO's educated opinion that there are some t p safe ways to atore npent fuel before final delivery to a Humboldt Bay Unit 3 FES 45 Appendix C l l

8 u Sovernment depository. It doco not imply that all preposed G-10 means of storage of opent fuel in existirq; facility otorace pool; is without environmental impac t.

Careful review of the development of 10 CFa 51.23 pro-video further support for the above interpretation. The rule grew out of a legal deciolon in which the court remanded to the liRC for a detemination on the availability of per-manent off-site s torage by 2007-2009, and on whether there are reasonable assurances that opent fuel could be otored on-cite safely beyond those dates. (ftinnesota v. tino, 1979, 602 F.2d 412.) In response to the remand, the tic began the "Was te Confidence" rulemaking proceedinco. 10 c/a 51.2 i was one of the resulto of those proceedingn. The tiRC interpreted this rule in a report printed in the Federal Rc61 ster":

This rule han the effec t of con tinuing the Coiv11 >nion!c practice, employed in the proceedirmo reviewed in '; tate of Minnesota, or limiting considerationa of environ-miT5 tal impuc to of opent tuel u torage in licensing pro-ceedings to the period in question and not requiring the tinC staff or the applicant to addreco the impacto of extended t.torage past the expiration of the licence appliud for." (Federal Regio ter, vol. 49, flo. 171, August 31, 1984, p. 34699.)

including referencuo to 10 Cru 51.23 in the analyais and concluoion sections of thio EIG was very ruuicading.

The rule, read out of context, appears to be an endorsement of all opent fuel storage in extoting npent, funi poola, when the rules true purpose 10 to clarify the timing and acope of impac t analyoen. The rule does not expreoc a find-ing of the tic wl .. ros;>ec t to the llumbol t plant. The fit otattd tha t auch prern turo chu tdown wa,.id be haridled "on a Humboldt Day Unit 3 FES 46 Appendix C

9 1

case by case bacia." (Federal Register, vol. 99, No. 171, Augus t 31, 1984, p. 34689.)

The mioleading use of 100FR 51.23a, as well as tne lack of uetail and curoory review of alternativus noted above, discount the credibility and objectivity of this EI$.

D) Mitigation Menoures The report noted no committment ey the licenace to mitigate any of the effects of the proposal. This may partly be due to the fac t that the unde tailed impact anal-yois f ailed to clarify the impac ts. When the impacto are properly determined, the agency should exact mitigation measurco from the licensee.

t) Usefulneus The lack of de tail and the inridequate treatment of t he alternativeo made it impoccible for me to fully evaluate the merito of the alternatives from the EIG. If the EIS is a reflection of the depth of analyoto done by the agency, then the EIS failed to properly channel the decisionmaking proceso of the agency, for it failed to reoult in a compre-hensive analysis. Although the EIS providen a framework for a future analyois of the proposal at inoue, it is inadequate to serve as a basic for decinionmaking.

IV; Conclusiono the agency failed to treat seriously many alternatives, and gave an undetailed analy Ain of the alternative; treated.

All the r:aconnble alternative; should be ceriously c.nd cor.-

prehensively analy:.ed. Such an analysis chsuid inclulc 47 Appendix C Humboldt Bay Unit 3 FES

1.

ouch considerationa as the management record of the plant and the r.3diological effec ts on nearby flora and fauna.

The agency failed to precent an adequately de tailed do-cument. Mone tary coo t estima tes chould be provided far each alternative. Inta on contamination from the t arly pool leak chould be provided to verify modeled projections of potential future contamination evento. The report should G 12 estimate impacto. of dischargen and exposures that are within re6ulatory limi to. The specific attributeo (f al te rna tiven n

should be discussed more fully. Greater effor(must be made to quantity estimates and provide the background ma-terial oo that decisionmakers don't have to rely on unsub-s tantiated s tat f opinionc.

l The diccuoolon of 10 CFrt S1.23a probably abould De left out entirely. It curven no useful purpose .i n the analyola, and i t 10 very miuleading.

When the impacta are fully defined, the agency should exact mitigation moacurco from the utility.

When all of t he above are done, this r,IS will be a use-ful document for decisionmakerc and the public.

Humboldt Bay Unit 3 FES 48 Appendix C

l  !

24 79 h'riclev ". cad Eureka, CA 95501 l Julv 14, 1930 ,

Mr. Har'ert ". "ar':ov, Sirector S-ecial and Standardization Proiects Division U.S. Nuclear Regulator', co--ission rashington, D.C. 20555 ne: Draft Enviror.r.cntal Statement for Decommissionino

!!umboldt Bay Fower Plant (NUREG-16F) Unit No. 3,

Pocket l'o. 50-133 1

Dear Fir:

]

After revieving the Draft E.I.S. I find that several iters disturb me greatly. ,

l. Under " Aquatic P.escurces" on Page 3-1 no nention .n i nado of the fact that Humboldt Fay vaters are extrene!.y i rich in 91anhtonic life. Radio isotones, esnecially

! chrorium, manganese, colalt, zine and iodine, are accumulated j H 1 by various planktens and are then passed up the food chain,

being concentrated a little nere with each steo up the I chain. This hay sunoorts intensive sport clamnino and. a j co,r.treial oyster industry. These bivalves are filter feeders inaosting, notabolizing and. thus concentrating j; ,_,the phytoplankton and zooolankton mentioned above.

j 2. Under " Terrestrial Resources" on page 3-2 the report ianeres the fact that the South Bay directly to the south j H 2 of the power plant is a niaratory wildfowl refuae supoort-j ing a large migratory duck and goose population and also i

the site of t5e largest remaining eel crass beds on the

! Pacific Coast.

( 3. Page 3-7: Ventilation exhausts from the refueling H 3 building, hot lah, hot machine shon and the radwaste i '

i treatrent buildina coerating area should be treated for

,,,they are a potential source of hot particulates. {

~~~

4. I find it incomnrehensible that the list of contributors i j to the draft E.I.S., on nage 7-1, does not contain a single i' H 4 biologist, narine biolegist, invertebrate zooloaist or M.D. specializing in nuclear medicine. After all, we are concerned here prinarily with an entire estuarine and marino 2 ecosystem.

1 In summary then, I would suggest that the recort is grossly ,

j .nadequate in the above-nentioned areas and should be given tire j for additional public reviev and nublic hearinas in Eureka where we can call unon the execrtise of many well-informed citizens ,

! and uoon the scholars of Hunboldt State University's Marine Lab. j l Sincerely S d. y ,L Ralph Kraus t

i Humboldt Bay Unit 3 FES 49 Appendix C I___ _ _ _ , , _ _

Larry Lancaster 1433 School Rd.

McKinleyville, Col.

95521 (707) 839-2047 Nog 25,1986

Mr. Peter Ericson l Project Director, i IJnited States Nucleer Regulatory Commision 1717 H Street NW Washington, D.C. 20555 l

Deer Mr. Ericson, I have reviewed the document titled p_taf t Envlornmentel Stetement for decommistenino of Humboldt Bou Power Plant. Unit 3..This document seems to overlook some rather substantial considerations and impacts. I hope to indicate to you these shortcomings. NEPA requires that l'

you consider and address them in the final document.The following comments era submitted to you within the prescribed time frome for public comment. Please eddress these comments:

~

A. No other agencies were actively involved in the preparartion of this document, why is this? It seems that there era i several jurisdictions that are to be offected.The Fish and Wildlife Service

l1 end Collfornta Coastel Commision are two agencies that would hcVe to i deal with impacts should an accident occur. Does NEPA provide exclusive jurisdicton in cases such as this? If so, please cite it specifically or I justify your docision to prepere this document alone.

C B. I wish to cellinto question your assumptions that the spent fuel rods must remain on site. Since this particular assumtion hinges on interpretation of low and policy, I have 2 points to be made:

f) Radiation has decomposed to a smaller quantity and is almost as safe to handle and transport.The half life of I2 radioective lodine 131 is 8.05 dogs.There has been little or no activity in the reactor for 9 years, so the levels of this radioisotope should be l negligible at this time. As for the radioactive Cobolt,it's half life (10.8 years), has already been echieved once for the majority of spent fuel. Isn't this true? If so, then please state how much editional mass would actually be diminished over the thirty year period? What quantity of radiation would be decomposed et the site? It might be helpful if you indicated the I

octual mess of the spent fuel now end in 30 years.

Humboldt Bay (Jnit 3 FES 51 Appendix C

2)The federal repository might be required to accept the spent fuel if an occurate geologic profile were presented in this document. The geologic instability ai this crea is a well known (cct ue s, me nudex sh Ms always been Weakned wM on 1-3 eccident. In my opinion, we heve been lucky that no spillage of contaminated water or disarrangment of spent fuel rods has occured. This unstable condition should merit a re-evaluation of your assumption that this is a saf e place to keep nuclear westes.

C. page 3-9, section 3.2.3.2. Listed in this section are EPA

" projected dose levels

• of radiation that are acceptable.Ng question is: Are these levels indicating acceptable working risk levels or l-4 community risk levels. There is a substantial distinction to be mode here, as the working risk levels con be os rnuch as 1000 times the acceptable community level of exposure.This needs to be clarified because those exposed in the cose of en occident may well be the high risk populations

( pregnent women, old and young as in item D).

D. The reality of the SAFSTOR clternative is that it leaves a commenity at a higher level of risk for a longer period of time, with none of the ossociate 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 cro the at highest risk. I subinit to you that these students are at the greatest risk in both routine and occidental exposure b scenerios.Their continued vulnerability to the occasional releseses of radiation into the atmosphere is a senaus concern. I wish to know what mitigations are offered to minimize the exposure to these childeren and adults of South Dog Elementary School. Thnestelserefgp wwgh la te hichiu n!!ner8?? te !M eff."!! tr? r~rfistion Were your figures on rediction releeses,in worst case scenario, taking into account age / sex /proxemity of the students, to the plent? How about in " routine releases' during the SAFSTOR end deleyed DECON phases? Plasse be

_ reminded that the school is due east (down wind) of the power plant.

r--

E. There is a great need for more adequate information on the geology within this report. Nowhere in the report is there on ocurate profile of the geologic structures and f aulting of the Humboldt 16 Dog region. In several instences (i.e. Item 3.2.3.4.), you refer to the possibility of seismic activity. How will a reviewing agency be able to quellfy (and quantify) the potential megnitude of selmic activity,if no U

documentation is provided? The Sc heressieu/tts only a 30 miles away.

MeSalmmflotfeult1ies 3-5 ml1es from unit 3. Tu?freshwaterfadt Humboldt Bay linit 3 FES 52 Appendix C

. .- _ _ _ _ . _ _ _ _ _ _ _ _ - ~

H lies within 10 miles of the site. I counted over 20 faults within 50 miles of the plent end these were only the bigger ones. I lived here during an I earth quake that registered 6.9. on the Reichter scale.The result to my house was fractures in the wails, objects being dislodged and a violent

,4 threshing. Another one knocked down a highway overpass that lies within 3 miles of the reactor site. In light of this, I of ficially request that the study of geologic impacts be reviewed and modified with more complete j inf ormation presented in the final document.

l l

Finally, o few points to help clarify the document:

F. Please be consistant in your method of describing figures.

l4 Use scientic notation or don't, but mixing the two throughout the I-7 statement makes it more dif ficult to assess relative values.

G. Please insert a diagram of the rocks used to hold the j

spent fuel rods.Those of us who don't have ready access to the design of the structure con better evoluote their ef fectiveness,in this way.

! 1 i As you meg have surmised,I em opposed to the ides of storing the spent fuel here in Humboldt County. I em concerned that the leed ogency and the utillig expect residents to remain sedate os occured in the l

i late 1950's when this project was initiated. It seems that we have been the Gineau Pigs for the nucleer industry and that we shall again be the

, stage to find out the peremeters of that some industries ability to j influence government policy. In light of the fact that the Nuclear Regulatory Commiston has never prepared an impact statement on this subject,it is very importent that your agency cover all espects of this issue.This document will set the precident for future decommisioning processes. If this statement is not completely thorough,

) it will have serious ramifications to ours and the generations to come. My  ;

4 comments are not meant to be personal jebs, but on indicator of the frustration felt by this life time resident of Hurnboldt County.Thank you 1

! for your time and attention to my comments on this most importent and personal issue. If you have ony questions or need some clarification, feel I free to contact me.

f 7 I

7 SJncerelg . f ~~ -

E h' / /,7 d ' 6 j

' t'arry Lancaster \

t

! Humboldt Bay Unit 3 FES 53 Appendix C

t May 13, 1986 U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Dear sirst i

I would like to comment on the Draft Environmental Statement for Decommissioning the Humboldt Bay Power Plant. I feel this statement is inadequate, and does not address several of the major concerns of health and safety for the people of Humboldt County.

I I am a businessman and educator, and have lived in Humboldt County for over twenty years. The future of our economy, and the '

prosperity of our children depends upon the continued development i of tourism, fisheries, and agriculture. The proposed i decommissioning of the nuclear plant threatens these industries.

The close proximity of the plant to Eureka and Highway 101, and  ;

to south Bay Elementary school, jeopardizes the health of residents, people driving by, and out children. That plant should i

l never have been built there in the first place, and it should not

remain in place for thirty or forty more years.

~

! The major concern not fully addressed in the Environmental statement is earthquakes. The spent fuel and wastes will be 4

J1 stored in a leaking pool for thirty years. Has the secondary i j liner been fully designed to withstand earth movement? What are

,the impacts and the backup systems associated with a loss of 1

34 , water from the spent fuel storage pool? Would an accident l threaten the fisheries of Humboldt Bay and the Pacific waters?

J3 would the agriculture land near the plant become contaminated?

] ,would the population of 50,000 around the bay have to be 34 , evacuated? Would U.s. 101, our major corridor be useable?  :

]

4 We have lived with this nuclear plant for some twenty years now, and we have been lied to, deceived, cheated, and misled by both the utility and the government. we criticize the soviets for their i handling of the Chernobyl accident, and yet our authorities have acted in an equally criminal fashion.

The Draf t Environmental statement is totally insuf ficient, and I

! urge the Commission to do some serious homework in revisions for l the Pinal Draft. ,

(

• j sin erely, /

j

& /a Michael J. Manetas  !

1094 Birch l McKinleyv111e, CA 95521 j (707) 839-3779 s

1 1 1 1

k i

j Humboldt Bay Unit 3 FES 55 Appendix C f

August 6, 1986 Director Office of Nuclear Reactor Regulation US NRC Washington, DC 20555 l

l Members of the NRC:

I have read the DES for decommissioning Humboldt Bey Power Plant Unit

1. 3 (Docket #$0-133) . I find the DES grossly inadequate to cover such a serious and far-reaching subject; vague in its analysis; and deficient in its appraisal of alternatives to the utility's proposed sction.

My comments will follow the order and page numbers of the DES.

Pg. v, PP (2): Terming the propsed storage ' safe' is vague and cynical.

Also, in light of recent waste storage developments, "until j

a Federal repository is available' could be longer than the i

30 years: this possibility is not engaged in the DES.

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 4

1 of vaste, for which the site was not designed. Six active or

! K-1 potential earthquake faults are within reach of the site: Little Salmon, Bay Entrance, Buhne Point, Falor-Kortel, Cape Mendo-cino-False Cape Shear Zone, and the Mendocino Fracture Zone. j More may be revealed.

f ===

l PP (5a) There is no evidence given that this is the ' sole' viable al.

ternative.

• Also, the 'generlo determination' is worthless, because Hum-boldt Bay's seismic situation places it at the extreme danger end of the spectraa assessed. Humboldt does not fit into an average scenario, because of the grossly different site-l specific problems. (An example of the meaninglessness of apply-ing generic studies to vastly varying conditions are the cost

) ,

estimates for decommissioningt these generic estimates were 4

l widely accepted, but have proven way off base for individual

! plants.)

J

• Why were not the following possibilities for spent fuel storace assessed?! Idaho Labs; WIPP in New Mexico; Hanford;

) Savannah River; or any other DOE experimental programs. The one-time high risk of transporting may be safer than the on.

1 going, 30-year risk of seismic or ocesh-front disaster.

f Pr. vi, PP (e): 'ne611gibly small likelihood' of criticality is excessively c

i y 1 1 i

j l

j

Humboldt Bay Unit 3 FES 57 Appendix C l

_ - . _ - _ . _ _ _ _ . _ _ _ - _ . _ . _ _ ~ . _ , - - _ _ _ _ , _ __ . _ - - . _ _ _ -. _ _

(2)

K-2 a

vague. Clear evidence must be presented.

Pg. vi, PF(f): "very small fractions of the PAG 1evels.' The upner limits of doses could well be much higher if the DES evaluated g the avenues of possible release adequately. Larger-than-i expected earthquakes (of which there have been several lately K-3 in California); massive flooding due to polar cap melt (pre.

dicted by some within the 30-year time-frame); tsunamis from far-away events; terrorist attack; wartime events -- cumula-tively, the risk of disastrous event happening is not minimal, but rather substantially probable. The DES neglects to assess these possibilities -- some at all, others inadequately.

Pg. 1-2, PP 1: " require a 15-year extension of the license' This is not true, since the the Federal Repository is suonosed to be operational K-4 by 1998, before the current license expires. Once the fuel is then removed, the plant should be dismantled. It will have al-ready sat idle for more than 20 years, long enough for most short-lived radioisotopes to have decayed. **

131.3 'not presently reasible' -- The DECON alternative is dismissed out of hand, with no investigation of moving spent fuel assem.

K5 blies t any r the above-naud facilities; to honis, Ill.;

to Diablo Canyon; er to another new temporary site with fewer seismic, coastal, er population problems (for instance, the Nevada test-site, already strongly contaminated and policed.)

Pr.1-3, PP 1: "The entombment structure may also fail as a result of seismic events with a potential for a release of redtoactivity." This K-6 is the reason given for rejecting entombment; yet the non-entombed storage structure being proposed would be even gorg prone to earthquakest The DES is totally illogical here.

1 3 3. "all fuel assemblies... and radioactive fluids and wastes should be removed from the site.' Is there a place to ship them?

K7 'the most cost-effective of alternatives' -- where is the data?

' generic detemination' -- strongly huspect; see above.

Pr.1-4, last PP "only difference" -- This totally ignores the extreme 1

differences the coastal seismic 26ne at Humboldt presents, in

' l

" Can PG&E show that another 15 years will result in additional stantricant  !

decay, or significant exposure reduction? If not, why the full 30 years? l i

Humboldt Bay Unit 3 FES 58 Appendix C l

l

(3) contrast to almost any site further inland! Then the ITS bas the K-7 audacity to worry about tne costs of ' seismic considerations of the ISFSI", were it to be sited elsewhere!

Pg.1-5, PPi: "it wound have greater environmental impact thanna onsite fuel storage.' -- Not if there's a release of radicactivity caused by seismic movement at the proposed site!

last PP: "not proceeding with a decommissioning plan could introduce K-8 uncertainty... eventually the residual radicactivity would have to be removed.." -- By the same logic, SAFESTOR provides more uncertainty than DECON, and leaves residual radioactivity for a longer time. This was not addressed in evaluating the earlier alternatives.

Pg. 2-1, PP 3: " A cover will be installed" -- When? What kind of cover?

PP 4: "This leakage was attenuated' -- but apparently will continue, K-9 at a reduced rate, for thirty years? The California Coastal Commission, in commenting on thisypragraph, said: 'There is a greater risk for a higher level of soil contamination than has been indicated in the DES."

Pg. 2-5, PP 2: 'The water from the liner gap is ptynped to the radwaste sys.

KM te a." -- These pumps will have to operate flawlessly for 30 years to maintain the proposed level of leakage. What provis-lons have been made to insure this?

2.2 (1): "until DOE has a permanent Federal repository' -- This might K-11 be a very long time, what with recent lawsuits filed by G

, of the proposed siting states' governors. The DES doesn' t address the impacts of a longer-than-expected wait; why?

Pg. 2-6: " set aside and accrue funds for DECON activities." -- Only 1% or 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 expansive each year. Where are the funds to be l kept? Who controls them? What if the company fails during the 30 K-12 years? Will the money then exist to cover the real dismantlement?

Is there any guarantee that the total necessary funding will be I available even if the company is ' solvent

• in 20157 What will be left on Humboldt Bay's shores if not?

Pr. 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 sup-porting data?

l Humboldt Bay Unit 3 FES 59 Appendix C

d (4)

Pg, 3-2, PP. 3: "Because of the long time that has elapsed. . ." -- The fuel K-13 was removed from the reactor in 1984, not even'two years k--. ago!

3 1 5: "No mechanism for impacting... is evident." This is unpardon-ably vague. A DES is properly supposed to evaluate impacts K-14 which may become evident during the length of the proposal.

Any of the many accidents which could hapoen during SAFESTOR would provide ample " mechanism for impacting" ...

Pg. 3-3, 3 1.7: " occasional relense from the liquid waste treatment system."

-- What liquids will remain in the Unit? Isn't the plan to have it flushed at the outset?

" diluted with the cooling water flow from the two fossil-K-15 fueled units." -- What guarantee does PG&E make that these two unite will remain operational throughout the 30 years?

What will do the diluting if not?

• some metallic products... not expected to occur at toxic levels." There will obviously be some 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.

3.2: : "r-leases 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 hapten? How much is "small"?

K-16 PP 2: "Little transportation of radioactive waste from the site.."

What will be transported? How will it travel? How much is "little"? These statements are too vague.

PP 3: What will the radiation inventory be in 2000 versus 20157 Versus now?

PP.6: What was the basis of these estimates?

PP 7: There is still much room for debate in the mediaal community about estimating health effects of radiation exposure. There is no generally accepted threshhold under which exposure is K-17 .sare".

Pg. 3-5, PP4: "2 chances in 100. .." -- When? How does the probability differ between now and 2015. If the dif ference is negligible, why wait the 30 years?

K-1l[fg. 3-6, PP3: " wastewater from ongoing decontamination activities.. ." --

Humboldt Bay Unit 3 FES 60 Appendix C

h (5)

K-18 g What activities are these? Be specific.

l Pg. 3-6, PP 5: 'If contamination is ... suspected in a batch" -- Does this K-19 reveal that not every tatch of waste will be tested?

'After processing' -- How clean is clean enough? Specify, PP 6: ' stored in a shielded area" -- With what degree of protection?

For how long?

PP 7:

• packared for shipment and stored. . ." -- Por how long? Indefi-nitely? Specify.

K-21 "The handlirg of activated components will be similar ... as appropriate." This is extremely vague; elaborate. Activated waste is pretty nasty stuff. What plans are there for trans-uranics? Will anybody take them?

I Pg. 3-7, PP1: Will Richland take all the solid waste, or do new quotas

~, preclude that? Where else?

Pg. 3-9, PP 2: There has been some evidence of deterioration over time of these neutron-absorbing blankets. What surveillance does the K-23 licensee propose to monitor this over 30 years?

'to insure sub-crit!cality after g event..." Is this 'insur-ance" realistic in the event of a truly major earthquake?

Pg. 3-10, 3.2. 3.4: " Crit 2cality potential of stored spent fuel.." Cynthia Pollack, author of Worldwatch Paper 69, 'Decommissionir4:

Nuclear Power's Missing Link', asserts this matter to be K-24 "the m st severe threat" of all of the dangers posed by SAFESTOR. All of the speculations in this sect &on 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.

Pg. 3-11, PPs 3-7: ' tacit assumption' , "very unlikely" , " negligibly small" --

These are too vague. The fact is that noone can guarantee the sub-criticality of the stored spent fuel array in the event of an earthquake registering over 8 on the Richter K-25 ,e,1., . Negligibly small likelihood' is an ominous-sounding reassurance in light of the " impossible'1 accidents that have been happening at nuclear plants world-wide. 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.

I Pg. 3-12, PP 1: In an earthquake rupture, new rock fractures may increase K-26 groundwater velocity, reduce the rate at which radionuclides t

Humboldt Bay Unit 3 FES 61 Appendix C

ji (6) pre ipitate ut, and cause greater and m re rapid flush into K-26 a the Bay. This must be analyzed in the DES.

Pg. 3-12, PP3: What is the starr's worst-case release scenario? Why did the K-27 staff use the licensee's estimates, instead of independent I sources?

l PP 4: "the radionuclides were assumed to remain in Humboldt Bay K-28 ror 1 year." Why this assumption? Where will they "go' af ter

(___ 1 year is up?

Pg. 3-13: "Thus an average individual conduming 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?

K-29 . 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 addres-sed in the DES.

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.

K-30 "DECON would result in greater occupational radiation expos-ures... and more radioactive waste than other alternatives."

-- There is no evidence presented in $he DEF to substantiate this conclusion.

I PP 5: "SAFESTCH ... occupational radiation exposures would be the K-31

lowest." -- Again, there is no evidence presented in support.

In Jacan, nuclear utilities are advised to wait no lon6er than 10 years af ter closure to dismantle their plants. Humboldt Bey Plant has been closed now for ten years. It was built in the wrong place, using technology from the 1950's, when little was known about the true nature of nuclear safety, or about seismic voL&tility. Unfortunately,, this DES has no chapter entitled

" Common Sense" .

Common sense dictates that it's foolish to leave highly radioactive materials sitting on three earthquake faults in leaky pools right next to the Pacific Ocean! The risk over thirty years is too great.

This DES aprears to have been written with a pre-conceived goal in mind:

to bail PG&E and the NRC out of the mistakes they have been compounding for years. It won' t wash. It is incomplete, vague, and in its generic evasive-ness of critical seismic issues ,a travesty. This is not an acceptable environmental statement. Its conclusions appear to be only its premises, l

l Humboldt Bay Unit 3 FES 62 Appendix C

(7) t and should be rejected or completely reassessed.

Obviously, there is no " safe" way out of the decommissioning dilemma. 7 At best, we have a choice of bad choices. But the choice propsed in this

' document is possibly the worst of all. Back to the drawing boards, and let's ,

be honest this time!

Sinc (rely, for e Acorn Alliance for Safe Energy,

&W J red Rossman Box 786 Redway, CA 95560 i

i i

1 i

r 1

i '

i I

Humboldt Bay Unit 3 FES 63 Appendix C J

EDITH KRAUS STEIH 3325 Erie street Eureka. CA 95501 August 14 1985 Mr. Peter B. Erickson Project Manager Standardization and Special Projects Directorate U.S. Nuclear Regulatory Commission Washington. D.C. 20555

Dear Mr. Erickson:

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

1. Pg. V. (2) - Why is it necessary to wait for a Federal

' Repository? What about commercial repositories, or reprocessing (4 at a DOE Reprocessing Plant? Have these and other options been L__

throughly investigated by PG&E?

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

,, conditions with potentially catastrophic results?

3. Ps. 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 L-3 quantity of this likelihood in terms ce x probability or other equivalent units? In view of the seismic capability of the site, does this increase the probability for occurrance?

What is the likelihood?

1 Humboldt Bay Unit 3 FES 65 Appendix C

DES Comments - HBPP Unit 3 (Continued)

4. Ps. 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 andbe b4 steam. Would the result of the dose calculations different if this event resulted in the seneration of steam from the spent fuel pool water? What is the percentage of the PAG 1evel represented by these new fisures?

~

5 132 Subparasraph 1- If any probability for the entombment structure to fail as the result of seismic events exists, why L-5 not also the current reactor containment structures, waste storage buildings. solid waste vault and spent fuel pool containment? (See Item #2)

6. 1.3 3. Subparasraph 3 - The seneric " Waste Confidence Decision" (49 FR 34658) does not take into consideration the

(.g unique geologic (seismic) and ecologic factors associated with the Humboldt Bay Plant site. These factors should be addressed in much areater detail in this document and generic statements not relied upon for convenience.

f 7. 1.3.3. Subparagraph 7 - This poses the alternative of sending the spent fuel rods to a commercial reprocessins plant. Why (4 is the possibility not addressed to ship the spent rods to a DOE facility for reprocessins?

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

Mas the water in the aquatir under the site been tested for

(.g possible contamination? Have provisions been made for assessment and removal of the contaminated soil from the site? Will the pumping of the liner sap 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 sap pumping system? Are seismic loads likely to increase the liner leak rate?

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

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

g_,

10. 3 1.3. Subparasraph 3 ".. spent fuel pool coolers will be flushed and drained". Into what will they be drained? If L-10 this water is to be discharsed into Numbolds Bay, what type of treatment proscam has been established for this water prior to discharse?

2 Humboldt Bay Unit 3 FES 66 Appendix C

DES Comments - HBPP Unit 3 (Continued)

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

therefore. there will be no impact. It may be difficult to chanse the " function" of a mud flat. per say, but not the very delicately balanced quality of it's funcetionins. This is a Nery inadequate statement considerins 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 L-11 sround and as a srowth area for finserlinss. Many species of animal and plant life in the dunes and marshes around Humboldt Bay are on the endansered and protected lists, the eel srass beins just one of them. This area of potential serious impact should be evaluated also by experts in the fields of marine biology, ornitholosy. botany. zoology. soology, marine ecology. oceanography. etc. Your list of CONTRIBUTORS pg 7-1 did not contain anyone with these credentials. Why is this so? Is this not the purpose of an environmental impact statement?

12. 3 1.5 - The statement is made that "N'o 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

L-12 statement is contradicted by the first sentence of parasraph i

32 which states that "The radiological impacts of 30 years of SAFESTOR consist primarily of (1) the environmental impacts of releases of liquid and saseous radioactive effluents..." This paragraph is also notable in that it does

,_, not address the issue of " Protected" species.

13. 3.1.7 - How occasional will be the releases from the liquid waste treatment system and in what quantities? "Relatively clean water" is a subjective opinion without basis in this document. As stated in Executive Officers Summary Report of of California Regional Water Quality Control Board of Sept.

11. 1985: "the waste discharse requirements govern parameters other than radionuclides. State givernment is preempted by federal law to regulate radionuclide discharges from power seneratins plants." What are the expected levels of radio-nuclide contaminants in this water? What is their potential 1"'*** " *h* **"i"* ' d *h**" ' *** """" ld' "*" "*** "'

3 siven that these wastes are concentrated by the filter feeders of the bay and the levels of these contaminates will be compounded. rather than diluted, as they move up the chain?

This paragraph also states that the releases from the liquid waste treatment system are "further diluted with the cooling water flow from.the two fossil-fueled units." This sives the i

impression that the assumption is made that the 2 fossil-fueled units will continue to be operated throughout the 30 year SAFESTOR period and beyond throush the decommission 1ns process. Is this. in fact, the case?

l 3

Humboldt Bay Unit 3 FES 67 Appendix C

DES Comments - HBPP Unit 3 (Continued)

14. 3.2 - This paragraph states that radiological impacts of SAFESTOR will consist primarily of (1) the environmental impacts of releases of liquid and gaseous effluents...

This DES is notable in that it doen not go on to describe L-14 anywhere what these impacts might be and even reaches an apparently foregone conclusion that there are no environmental impacts based on a generic determination by the commission. This paragraph also contradicts the conclusions reached in 3.1.4 and 3 1 5.

15 3 2.2 Subparagraph 2 - Will the building erected to enclose

• h* "** ***** "" *****"* """*** '* *D1* * ***""**"d ****"*

5 loads up to a magnitude of 75 from the ccapable and potentially capable faults in close proximity to the plant?

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

17. 3 2.2 Subparagraph 6 - Why is the ventilation exhaust from the refueling building, hot lab. hot machine shop and rad waste treatment building not treated? This is a potential pathway for unnecessary environmental contamination. Stating that "No treatment is provided by this system for normal releases" implies that there will be expected " abnormal releases". What constitutes a normal release? What constitutes an abnormal release? What treatment plan has been developed for these occurrances and why is it not so stated here?

L-17 This paragraph goes on to state that " controlled ventilation i is not provided for the solid waste storage vault. low level waste storage building and solid waste handling building."

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

l 18. 3 2.2 Subparagraph 10 - " Atmospheric releases will be L-18 insignificant." upon what is this statement based? what

{_ quantity does " insignificant" represent?

4 Humboldt Bay Unit 3 FES 68 Appendix C

DES Comments - HBPP Unit 3 (Continued)

19. 3.2 3 2 - I t. 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 L-19 assemblies, but is it a realistic assumption for spent fuel assemblies? Would it not be more conservative. considering the age and time in service of the fuel rods. that all of the pins might be damaged? Why are calculations not made for this condition?

20. 3.2 3.A. Pg. 3-11. Subparagraph 2 - Why are calculations not

, made for the potentiallity of the rods not remaining in a parallel array, considering the seismic potential of the capable faults on and near the plant site? Why is the presence of fresh fuel assumed when this is not the case?

The many uses 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?

l 21. 3.2.3.6 - What is the potentiality for contamination of the L-21 community wells located on the north eastern site boundry in

[__ the event of a spent fuel pool rupture?

22. This section. 3.2 3. does not address the potential environmental impact of a tsunami. What precautions have been takeh to mitigate the effects of such an event to the surrounding community and environment? The stretch of Highway 101 which runs adjacent to the plant boundry was closed to traffic just this past winter due to e tsunami

(,gg watch posted for the California coastline.

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

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

In conclusion. I feel that given the geology of the area in which the Humboldt Bay Nuclear Powerplant is located and the seismic potential of the capable faults in close proximity to the plant as well as it's location relative to the triple plate junction off of the Mendocino Coastline and other capable faults. that the decision to use the SAFESTOR option should be reevaluated. In L-23 any avant. the s.erious nature of this situation should be given much more validity then it has been given in this document and addressed in much greater detail. Furthermore. I feel that this document is gravely inadequate in it's attempts to assess the potential environmental effects of the proposed decommissioning process which will extent far beyond the 30 Yr. SAFESTOR period.

If When the Humboldt Bay Nuclear Power Plant was built it was not i

5 Humboldt Bay Unit 3 FES 69 Appendix C

JL DES Comments - HBPP Unit 3 (Continued) intended to be used as a long-term storage facility for nuclear waste. I believe that PG&E and the Commission have not adequately explored the options available for handling the spent fuel on a L-23 long-term basis at a less hazardous location.

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

R p. ctf ys

'MJ raus Ob te n 1

6 Humboldt Bay Unit 3 FES 70 Appendix C

U.S. Nuclear Re;ulatory Commission Aug. 7, 1986 wasnington. 0.C. 20555 Dire: tor. Office of Nuclear Reactor Regulation The following are cenments on the Draft Environmental Statement for the decommissiening of Humboldt Gay pcwer plant, Unit 3.

To begin. I would like to go on record as stating my firm opinion that by limiting public comment to written form only, the NRC has not cone its job of gg,g serving and pt:tecting the public, many of whcm are concerned about this decom-nissioning but are not able to express their concerns on paper. A public hearing should have been held, and the lack of one Clearly inJicates the NRC's regard for the :ablic.

My first ccmment en the DES involves the use of the word " alternative."

Alternative is cefined as "a choice between two or more than two possibilities."

The discussion :n pages 1-2 to 1-5 makes it clear that all the possible decom-missioning met":ds, except "SAFSTOR." are actually not possibilities at all.

The state *ent en page 1-3 that " the licensee selected the SAFSTOR alternative for three reascas" (and goes en to list the reascos) is misleading and sloppy; h4-2 the licensee has no real choice because f the lack f a Federal repositcry and because entomtment is no Ichger thought to be a reasenable option. At this time, mothballing is the enig way to deccmmission (or rather to begin the prccess of ce:cmmissioning) a nuclear power plant. The statement on page v, " Storing t*e scent fuel assemblies at Humboldt Bay is the sole viable alternative fcr spent fuel stcrage at this time," is also misleading and should be reworded in the FES: there is nc such thing as a " sole alternative." (See also page S-1,

___ se::nd paragra:n.)

Py secena area cf cc-cern is how the NRC has determined that the seismic cesi;n Of the plant is acequate and safe for "SAFSTOR" when it has been deter-einee inacecuate for operatien (page v, [3]) and inadequate for entombment (page 1-3): "The ent:-:ee-t structure may alse fail as a result of seismic events ha-3 "it" * " tti*1 f : l5' f r*dio*ctivitr " If 5'15"ic factor $ **r* '5'c to evaluate ent:ntment then why is the staff using the Ccmmission's generic deter,ination tmat no significant environmental impacts will result from the s:crage cf s:e-t fuel in storage pools for at least 30 years to evaluate "SAF-STCC" rather than looking at this particular site and evaluating it on the basis

___ cf act.al seis-i: fa: tors?

On pa;e 3-e it is stated that "the staff used somatic and genetic risx esti at:rs t"at are basec on widely accepte: scientific informatien." The h4-4 s:ur:es for tse inf rmeti:n are catec 1372, 1075, 1977 and 1380. I consider this fairly "ci:" infernation and cuestion whether there might be newer infer atien that is *:re accurate and sh:uld be used.

Dage 3-5 c:'tains t*e state-ent, "The lower limit of the range would be Zer: because t"ere may be bicl ;ical mechanisms that can repair da-age caused hq.5Y "i*ti " *t 1:* ::5'5 c/ r :: rat *5 " I nave never neare of any evi-cence tnat soggests this (in fact, the bulk of evidence suggests the occasite).

ine FES snoul: either incluce occumentation for this statenent or else omit it,

__ as it is entre-ely misleacing.

It is stated cm cage 2-5 that "near the end of the SAFSTOR chase, the licensee will s.:mit the CECON plan for staff review and approval." I feel strcngly that te tite to *ame a cistantling plan is neg. It shculd be made by t~e ;e:;1e * -

b ilt a-c a:erate the plant because they are the ones who ha-6 a re fa-iliar .it- .. T,irt, years fr:m new they wil all ee ceae, ane tne

e

:le wr: ;;aa t*e dis *antling wi;l

• ave to rely e9tirely on written re:cres

• • i:- can't ;;ssitly :enta!* the inf:rmati:n that these workers have. A pla, s cu.'0 te devel :ec art s_t-itter news it can always be a-eared later .e~

• __,i-f:r ati:n :a :w :: cis aatle aaselear react:r is ac; wally devel: ped.

Humboldt Bay Unit 3 FES 71 Appendix C

comments page 2 Also on page 2-6 is the statement that "the licensee has initiated action with the California public Utilities Commission to set aside and accrue funds h5 '7 f or DECON activities." I weuld like to know why people wna received no elec-tricity from Unit 3 (anyone who began receiving power from pG&E after 197C)

__,must pay for its dismantling.

And finally I want to know why the nuclear power industry, which is over thirty years old, has not developed, or made it a priority to develop, com-prehensive, realistic and ecologically responsible plans for disposing of its highly destructive wastes. Peter Erickson's response to my question or why the DES took so much longer to complete than expected was that the NRC's priority is licensing new plants. Well, 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 00E to see that these plans be developed and implemented now. Please wake up and stop leaving for your children to do tomarrow what you should be doing today.

AESPECT THE EARTH In Hope, Il4 @ 2b  %

pam Wellish Sox 914 Redway, Ca. 95560 Humboldt Bay Unit 3 FES 72 .

Appendix C l

=c~""

...... Galifornia IEcgislaturc =-

JOINT COMMITTEE ON FISHERIES AND AQUACULTURE SENATCR BARRY MEENE C)*A #

ASSEMBLYM AN DAN HAUSER v<E Cma.e August 14, 1986 Mr. Herbert N. Berkow Director, Standardization and Special Projects Mail Stop P-234 U.S. Nuclear Regulatory Coraission Washington, D.C. 20555

Subject:

Corments on Draft Environmental Statement -

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

Dear Mr. Berkow:

In general, I believe the Draft Environmental Statement (DES) for the decoraissioning 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. To begin with, the title of the draft document misleads the reader by failing to mention that Unit No. 3 is a nuclear reactor. The N-1 first mention that the document is dealing with a nuclear facility appears on page 1-2. Furthermore, the abbreviated title

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

The Nuclear Regulatory Cornission's (NRC) own regulations -10 CFR 7 51.20 (b) (5)- call for the preparation of an "-- environmental Humboldt Bay Unit 3 FES 73 Appendix C

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

One of the most serious oversights in the draft is the failure to provide a detailed description and analysis of the environmental setting f the proposed decommissioning activities. Humboldt Bay N*1 is the largest coastal wetland and estuarine area in California, serving as habitat and spawning grounds for numerous species of fish and shellfish, including anchovies, salmon, steelhead, rockfishes, flatfishes, market crab, and oysters. Some 750 acres of the bay's bottom are used for the commercial production of oysters. Additionally, the environs of the bay serve as habitat for numerous bird species and other wildlife. The DES is silent

__,on these important features of the area.

1 -

l Another glaring omission in the document is the lack of an i

adequate site characterization for the vicinity of Unit No. 3.

l There is little, if any, treatment of groundwater, local soil N-2 conditions, and the overall hydrogeologic nature of ~the area.

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

In light of the fact that the licensee (P.G.&E) decided in July, 1976 to shut down Unit No. 3 for seismic modifications, it is imperative that this document contain a thorough analysis of the N-3 relevant seismic factors and give serious consideration to the -

interaction of those factors with the hazardous materials stored on site. The cursory treatment of seismic factors provided in this draft avoids probably the most important environmental issue

__,in considering the deccmmissioning of Unit No. 3.

The DES presents technical information on the dose assessment and risks of human exposure to radionuclides (section 3.2 and Appendix B), yet the document fails to explain exactly what the N.4 licensee's " radiation protection program" entails. Description of this program and inclusion in the final EIS of evacuation plans to be implemented in the event of a worst case scenario would help allay many of the public's concerns regarding this proposal.

"""There is no mention in the DES if other nuclear facilities in the country have been decommissioned, and if so, what information N-5 exists that might bear on this proposal. If this, in fact, is the first such decommissioning in the United States, it then becomes all the more important for the NRC to prepare a If 2

l l

Humboldt Bay Unit 3 FES 74 Appendix C

comprehensive, in-depth Environmental Impact Statement before any N5 consideration of storing radioactive materials in " safe storage" L for 30 years.

While the DES includes a section entitled the " Decommissioning Plan" (section 2.2), the document fails to explain what the plan actually does. The section is extremely superficial in that it N-6 makes blanket statements without providing any details. For example, a statement is made on page 1-5 that the " plan" ensures that contaminated water is removed from certain systems and tanks. How is this accomplished? Where does the contaminated water go?

This cursory treatment of the Decommissioning Plan, which is an essential part of the proposal, leads one to believe that NRC staff is treating the P G & E license amendment as a mere formality. In fact, Unit 3 has been in "SAFSTOR" since July 2, 1976 without a license amendment or an Environmental Impact Statement. Thus, with the "no action" aharnative, how could there be, as stated on page 1-5, "a greatus potential for release N7 of radioactive material as a result of syncem deterioration or a seismic event?"

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

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

Sincerely,

/

atd

1. 1,RRY KEENE lR BKajrlb Humboldt Bay Unit 3 FES 75 Appendix C

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Humboldt Bay Unit 3 FES 78 Appendix C

Daniel J. Taranto 890 Cloudswood. Road Fieldbrook, C A. 95521 August 14. 1986 Di.ector Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission hashington, D.C . 20555

Dear Sir:

In regard to the Draf t Environmental Statement for decommissioning Humboldt Bay Power Plant, Unit No. 3 I respectfully submit the follow-ing comments:

1 The D.E.S. document itself is, in my view, poorly prepared with insufficient specific data basis for arrived at conclu-sions. There is too much reliance on unidentified " staff" P-1 " generic estimates" which are not based upon current site ]

specific study, testing or analysis.

I do not feel securo with the safety;of my community being assured on the basis of " generic r.isk estimates".

2. Nowhere could I find in the D.E.S. a mention of the' fact that virtually no funds have been set aside for the decom-missioning 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.

Humeeldt Bay Unit No. 3 is clearly the best candidate currently available for establishing the "real" (not estimated) DECON P-2 cost basis for projecting a more accurate " set aside" fund-ing formula for other active reactors around the nation.

Until such a formula is established they too are destined to come to the end of their Neonomic lives" with insufficient funds for DECON.

As you are certainly aware, over dependence on the Batelle studies of very small experimental reactors are not comperable to commercial units and therefor a potentially catastrophic basis for " generic estimates".

3. The arguements presented for "SAFSTOR" are inadequate:

1e r Page 1-3 1.3.3. (1)"...there is no Federal repository for opent fuel."

This fuel can be transhipped to Diablo Canyon to clear the way for complete DECON now. In the interest of serving the greater need P3 for establishing 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 1-3 1.3.3. (2) & (3) are redundant reasons therefor there is actually only one viable reason presented supporting SAFSTOR in the D.E.S. rather than the three suggested.

Humboldt Bay Unit 3 FES 79 Aopendix C

Director Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission August 14, 1986 Page 2

~~~

4 In 30 years it is unlikely that anyone will be alive that had worked at the Humboldt Bay Plant when it was in operation.

The D.E.S. does not discuss the fact that there will be no P-4 one familiar with those idiosyncratic elements inherent in all systems. The time to DDCON is now while there are trained personnel on hand that are intimately familiar with

___ the facility and its weak and strong aspects.

5. Currently there is no community contingency plan to 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. 'ahat would happen if an airplane crashed into Unit No.3 exploded and started,an uncontrolable fire?

c. What about this lack of a contingency plan?

6. 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 DECCN. There is no time ceiling set for SAFSTCR, hence it is conceivable that the utility will simply extend for another 30 years, etc.

P-6 Further, in 30 years;there will be cany more reactors shut down most of which will be much larger than Humboldt Bay and hence proportionately 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 SAFSTCR unit in order to channel funds and personnel to cope with larger problems.elsewhere.

__, DECON now is clearly in the Humboldt cor.munity's best interest.

I ~7. It is imperative that a local public hearing be held on P7 this matter prior to is dispensation. If for no other reason, a local public hearing is critically important to maintain the appearance of objectivity in decision caking.

He rectful'y su .itt 01 Da n'ie l J . ranto Humboldt unty Resident l Humboldt Bay Unit 3 FES 80 i;ppendix C 1

+~

/ q.jbn SIERRA CLUB - REDWOOD CHAPTER

..... .. o , .

August 10,1986 D~ector r

C1Tice cf Nuc' ear Reactor Regulation U.S. Nuckar A+gulatory Comrnssion Washington, D C. 20555 Pe: Ccmrrerts of the Redwod Chapterclthe Sierra Ckb on tN CraR Envronmenbl'rtpact Sbternert fcr Decorrmissioning the HtJrbod Bay Poww Pbrt, Unt 3(NUREG1166)

Dear S'r' The Redymd Chapterof the Slefra Ckb stimb the followirg corrrneris on tne Draft Envrorrrertal trpact Sbtemert fcr decc(nmissioning the Hurrboldt Bay Power Pbnt, Unt 3 hereafter referred to as "the p' arf (NUREG1166).

The Redmod Chapter is one el 13 Sietra Club Chapters cperating in Calfornia, and the one in which the plart ts located.

The Re<had Chapter is ap5(eciatWe of the cppc<tunty to comroert on the prcposed decorrmssioning of the plant . This is an ssue of great rrp-(tance, nctonly ror nc<thwn Ca!(ctnia, where ths particubr plart is located, but fcf the nabon as a whole, which will have to contend Wth many such decorrynssionirg in the years ahead. Howths partnulardecorrrnssioning is handkd will provka the e V4nce frcm which fitJe decc<rrnissionirgs will benefR. t will also sc4 tre tone fcr e ptilK partKpabon str.h proceedings must accc<rrnodate undw the law. Accc(dirg% we tige you to inc!ude a ncther pt.tlic hearing from which to incc(porate (cfmal irput irlo the nnal EIS (FES). We ccer< rand you fcr extending the trnv(rame fer corrrne rt on this DES.

We have bcth General and spec (K ccmmerts on the Dral Comrnents

1. Ccmrne rtr and concerr:s ol'ered by the psR in tha scopirg session have nct b+en cons 4&ed. No compitabon or analyss of tMm is included in the DES. Many corrrr:erts were crered by rrerrbers of the pttlic and eMcted c(ficials at the sccoina 0-1 s+ccion. TN cust- resoorse et the agency to tro poirts of concern is nobbfy absert. tom the DES. . F'ES should contun a isting d the cc(rrnerfs and a general response to each rnape area of concern, as refacted in an ana >fss ct a ternatnes and

_ tric(mabo n re btNe to the r co rsiderabon.

2. The DES does nct c wth the govisiors and irterbons of the National Eny'ronmertal Pork because R fads to examine the drect, ind rect, and ctrnulatNe e#ectsthe (y popos Act (Naction,and faib to stistartheP dscuss the rarge of atornatnes that are gesert2/ availabk. Ge/ examine and nene deterrninathns are inherert!y invalid fct the examinabon et the enYrorrnertal ' FrpaCis of a sp+C(K Q-2 project or act.on. Asstining that SAFSTOR is'a generical>f acceptabte opt > n for all nuclear power pbnts igncres the very serious specialprobic<n c(the Hurrbod Bay ste- that t sts wthin 4000 feet of trree capabk cc potertally capable faub. Ths s the main reason the plart was shut dovm in 1976, and the prrre reason ts retrc(t is presert?y uneconcmeal. t s ilbgical and 'trationalto esmss this factwhon U

i Humboldt Bay Unit 3 FES 81 Appendix C

COMMENTS OH THE DRAFT EIS FOR DECOMMISSIONING HUMBOLDT BAY POWER PLANT, UNIT 3 (NUREG-1166)

REDYr00D CHAPTER SIERRA CLUB A

Q-2 considering the Ynsdom of stonng highly dangerous nuclear materials at the plant for 1 the next 30 years, or as is arguably tne case, longer.

3. The DES, by stating that S AFSTOR is tne " cole viable aternative for sport fuel storage,* Indicates that a decision has aready been arrtved at by the NRC concerning the decomrnissioning policy- rendenng the ES process a farce and reducing the documert to an instrumert for just:fying the decision rather than a tool for obtaining infc<mation and providinq eptions for a decisbn as requr' ed by NEPA. To fulfill ts Q-3 purpose as an EIS the DES mustconsiderallimpacts-drect,indrect,and ctmulattve-must be based on accurate, high qually sciertlic information and analysis; and mir I discuss all reasonable atemaDYes to tne proposed action [Andrus Y. Sierra Ch* ,22 ,

Flint Aidos Deveboment Co v. Scenic Awers Ass'n of Okv' ,rn.

U.S.

690 U.S347 776(1(1970)9T6); Ca16ma Y. block. 690 F. . .F2nd 753 Jpose (9tn Cr 1982) underthe law is as a g_e-decsionaldoctmert to provide the adminv 4 agency wth the inforrnadon t needs to make an envrormerfalPf intctmed dewon "ramer than just fying decisions aready made.*[40 CFR $ 1502.2(g)].

4. A discussion d the seismic and geologic charactenstics d the Htmboldt Bay ste is not included, and the DES treatmert of the hazards d the sto and the~r effects on the proposed acDon are far too ct sory. The Htmboldt reactor las menboned aboYe

(*2), was not permRed to restart by the NRC in 1976 because of senous concoms about the abilty of the facllty to Yntnstand the rnaxmum possble earthquake expected from the trree capabk fauts located drectly adjacert to the plant. In 1983 modfrations to bnnq the pla nt into NRC cornplia nce, in addtion to TMI backft requrements, were deemed to be so expensive as to tra uneconomical.

The existence of three Yefy close faUts is bad enough, but other potentially aCliYe fauts lace the on ard o# shore topography of Humbokt County wttich also could adversely efectthe p*lart and the radioacuYa matertals stored there. Wthin a 40 mile radius are: The Fabr cetwl faut (activel This faut transects northwestkcata and is capable of a 6D7.0 magnrude quake (ENYlCCM,1975); The Caoe Mendocino-False O Cape Shear Zone (actrye is estmated to be capable d a 7.3 earthquake; and the Mendocmo Fracture Zone)(potent; ally acDYe) is located in, or Compnses, one of the ~

most seismically acuve areas in Nortn Amenca (The Mendocino fracttre zone s partof the tedonically active tnple late juncdon, and is capable of a 7+ [ Richter scale {

magnRude 'NoYorrber 198 and is possble of a seismM Overt cCgeat quake maantude '8.0 or greatef}. November 1980 terrblor tcppled a freeway oYerpass less than two miles from the plant, despte the epicenter's location being nearly 40 miles away.).

t is rather hard to believe that the licensee could be iricfmed that the plart sto is unsutable for condnued operation of the ptant, while being permRed to adYocate that high leYel nuclear Waste l'e stored there for a n addtenal 30 years. More incredble sull, is that the NRC would conclude that two other methods of storage and doccarnissioning ( Independert Spent Fuel Storage Installaton [ISFSl] and ENTOM )

would be at least partly rejected as opdons beca use d seismic considerations.

The Ertorntrnent dructure rneyalso f2 as a resis N s tpnr ever%4h a pat ertd f ora roletse of rsdonctr4(DES p1-31.3.21ernphess added).

Thus,tNs adMy...wtidteatsre s esrme cmsidWims of theISFSI[ DES p.1-4 1.3.3Xernphasis added).

7 2

Humboldt Bay Unit 3 FES 82 Appendix C

COMMENTS OH THE DiMFT EIS FOR DECOMMISSIONING HUMBOLDT BAY POWER PLANT, UNIT 3 (NUDEG-1166)

RED %OOD CHAPTER SIERRA Cl.UB N The FES should provide a detailed treatmentof the seismology of the area and an examination of the nsk of a 30 year or longer storage plan at the ste. The most nportantseismic considerations to be taken into account are those atthe plant. r the Q-4 seismic consideratbns of other, hypothedcal atemattyes are to be considered as well, they should be considered from the standpoint of companson with the nsks associated win those ateady acknowiedged at the pl&nt, which have precptated the need for the proposed action in the frstplace.

5. There is no discussion of the eny ronmental charactensbcs of the ste, nor of ts trportance relat!Ye to other such stes in the state or nation. There is no InYentory of plant or anrnal species which would be a#ected by the proposed action at the ste.

The complete lack of this Irtormadon in and of tser serYes to minrntZe the meaning of the doctanent,which is,after all,an Eartomwdr/ hpact Statement. The enYronmental signficance to the state and nadon of Htrnbokt Bay,Coastalon which the pbnt is located, is qute great. Htmboki Bay, acording to the Cattomia Commission, is the largest weCand and estuarine naDiat in the Calfomia Coastal Zone. tcontains approxmately 23% of allcoastalwetlands in Calfornia. L's waters are home to 30 species of fish, including such aquatic fauna as' anchovies, chinook and coho saknon, steelhead, cutthroat trout , sme ts,surfperch, rockfishes, sand dabs, Q-5 soles and flounder. Approxmately 750 acres of the bay s bottom and channels are used for commercial oyster production. Many d the brds using the bay are protected by intemational treaties whKh mpose national responsbil protec6on of the~r habtat The Bay tser is considered a NationalWildtte Sa . Peregnne Falcolns, which hunt oyer the bay, are on the federal Endanger Spec es List. The nyers and streams trbutary to the bay provide spawning ntrsenes for jwenile sarnon and trout. Streamside rparon habtats hold dryerse wifd!fe pcpulations. The DES fails to provde any desmobon whatsoever of the e nyrormental setting of the proposed actNtles. The FES should proylde detailed Irtormadon on tne envrormental setting and potential rrpacts on marine and terrestnal fauna and fkra of the poposed action and any accidents or inckfents anticpated as "normar or hypothebcally projected as worst case.

6.There is no inventory cc strveys of evidence of cutural resotrees that may be g{y located at or near the ste which would be afected by the prcposed action.

7.The conclusion stated in the licensee's ER (Secbc n 6.3 2.2), that :

Grotrid W ercod d b e contarmai e d bythe less d p ool W eri aleak vere t o d evelop from the pool to the strro triding soi, but conterrmation vedd b e veryM ght even i the leatvere very rapid. This estrnete is conservative trice the vetervohrne relessed frem tho poei vodd reech en eqdbman yt hthe very high W ortable ntho d e sol strsa.

Q-7 is at odds wth Secdon 10.3 2.2 of the ER, which concludes that sound water flows toward the Bay from the ste, and the aqu(er is flushed each year by high tides and spong runoff. This clearly indicates that an exchange of radioactive matenals from the sto is ble, a nd perhaps has a ready occtrred. A serious leak would clearly fnye ging consequences, both for the contaminatbn cf fish and mollusk species and economically on the financially troubled fishing ind which is found in the Bay,t of Htrrboki County's Yolatile economy. Innuendo related o an rrportantpar cortamination of seafood products abne would be stfrmient to devastate tnis fragile V

3 Humboldt Bay Unit 3 FES 83 Appendix C b - - -

COMMENTS ON THE DRAFT EIS FOR DECOMMISSIONING HUMBOLDT BAY POWER PLANT, UNIT 3 (NUREG-11SC)

REDWOO CHAPTER SIERRA CLUD A Ind .The DES falls to address this issue, presumably because of the qucation cted ve. The FES should contain a fulland complete discussion of the r.to Q-7 hydrology, representatIYe of the potentialfor,, and Consequences of, Cortamination of Lsuchcontamination.the youndwater and Bay waters via the aquter, as well as a dscus I 8. There is no discussion of how the proposed action will be in compliance with Q-8 State statutes,1e. The Callornia Coastal Act, or how inter-agency coordination Morts L will be conducted to ensure complia nce.

9. There is no discussion c(the rate or consequences of continued Q-9 contamination of the soil at, and groundwater beneath, the ste due to the continued

{and potental?y increased leakage of the spent fuel storage pool.

f""' 10. The FES should more fully disclose the potenbal cumulatfYe effects of Q-10 increasing the amount of long-term of radioactive liquid in a pool a teady plagued by Lleakage

~

11. Failure of the mechanicalpump system preYenting escape of leaked matenals from the sport fuel storage pool s not addressed in the DES. This should be 0-11 rectfied in the FES along wth a dscussion of the mpacts associated with the pump's

[failwo, and any backtp systems, planned or to be requred, by the NAC.

I 12. The FES should more fully idently rneaswet for mb' gating the potential Q-12 upacts,includi those caused by purrp rrarunction and leakage, on area farmlands,

{7ound water, nds, and bay waters.

~

13. Despte licensee e# orts to prevent soil cortamination at the plant such contamination has persisted. The proposal to enclose the rachvaste building for the storage of addtiorni contaminants may actually increase soil contamination by increasing the Yoltrne to be handled and stored. The DES does not proYlde adequate Q-13 information on how the proposed corstrueben will prevent soil and possbly water contamination. The FES should contain a<Mtional data, plans, and mtigation measwes s@cie r .to protect the soil and water around a nd be neath the pla rt from addtjonal contamhnbon. Addtiona!?y, aternatives to corttructing a new facllty

_ shoukt be dscusselin the FES.

14. The exiding precedert of storing spent fuel at other federal,but non-NRC, stes ( as in the cases of Three Mlle Islanda nd S hppIngport-stored at Harford and Q-14 Idaho Falls respectively) is ignored in the DES. Ths s in ap-parert violabon of NEPA, wtilch requres a dscussion of reasonable aternat!Yes *nC( Wthin the junsdktlon of the lead agency," 40 C.FA $1502.14 (c). Such a dscussion mustbe irv.luded in the

_ FES.

15. The DES is Yague as to wtiich contaminated materials are considered low or Q-15 high level waste, and b w much of e ther class (k:ation will be stored on-sto until L permanertrepostories facilty are also notaddressed. are located. The associated rrpacts at the final desbnation I 16. Details on the technical specfications for the propsed rachYaste buiMinq are Q-16 notincluded in the DES. Netherare phns orse' mic s slandards included. The FE5 should provide this and related data on the structwo to ensure that pelic safety is 4

Humboldt Bay Unit 3 FES 84 Appendix C

COh0AENTS ON THE DRAFT EIS FOR DECOMMISSIONING HUMBOLDT BAY POWER PLANT, UNIT 3 (NUREG-1166)

REDWOOD CHAPTER SIERRA CLUB h

protected, and properreview by the Coastal Commission is possble. Under Caitornia law, the Coastal Corrrnission must determine whether the structure's location and 0 ,16 design are most protective of coastal resources. This irformation should be provided to the Commsson for reyiew ard inclusion in the FES.

. ' The DES does not indicate thatthe structtralintegity of the proposed radwaste Ong willbe in cortormance wth standards requred of the plant tser.

Failure to do so .. %sut in the strong Ikelihood of addtional soil and water

• of a sign (icant earthquake on or near fauts adjacent to the Q-17 contaminaton In the s.

plant. The FES should irx.m a seismic analyss of the s!ructtre as well as any details on backtp safety systenv 'may be proposed to contain intended to preYent ,

soil,gound water,oropen water com mnabon at the plant due to a signficant sesme eYent.

18. There is absolutely no discussion of the u wrs and knpacts of the use of chemical agents for decontaminating strfaces in the pu. Muring the decorrmbsioning process anywhere in the DES. The ER pr by the lice.. % acknowledges that these chemicals possess hazardous toxic icalpropertes. h msuse orspillage would haYe serious consequerKes. The FE should corfain an inye. "v and Q-18 analysis of these chemicals, and provide irfctmation on the plans for stoi.. appying, rinsi.ng, transporting and dsposing of them. There also should be a discussL. 't me ramficationsof accidentsassociatedwithther handling andstorage,under"nori. "

ctcumstances and in the eYert of an earthquake. This s a major bsue that is not eYeo superficially addressed in the DES. This oversight that cannot be permtted to be repeatedin the FES.

19. As the discussion of aternatlyes to S AFSTOR are inadequately gesented, l

Q-19 so is any discussion of the routive costs of any aternatives to the proposed action.

The absence of this Irtormation harrpers an effect!ye analysts of the feasblity cf all I atomatNes, relatNo lo each other or alo ne.

20. The DES is d+ficient in failing to address a ternatives to the d' rect discharoe l

Q-20 otradwaste irto Humboldt Bay as the resutof ts Worst Case Scenarlo. t smitarty fails to indicate that there are a ny backtp systems- e ther in place or proposed- to handle the descrbed emergency.

21. Throughout the DES the NRC uses such expressions as *negligbly small,"

'very).Ike 3-11 * ,*terms

'negligbly are used to smallIkelihood," and "very desregard other aternatnes to the small ed fractions action or (see especially p.

Q-21 to discount the possbilty of or ramticabons to consequences resub the proposed acDon. These tems are judgemertfactors wtich are uns nt!ated and _

too vague.

22. The DES cordains no discussion of the activabon elemerts presert atthe plant. Ne ther is there any dscussbn of the rehtive expostre rates of decorrmissioning in the ftttre as cpposed to the presort. %Ie t is clear that Q.22 occtpabonal expostre would be reduced to some de<ree as shorter-lived isotopes decay,ths adrantage may be signficartly overstatedbecau's of the presence of high energy emiting actrYabon elements in the steel and concrete of the reactor and co ntairme rt, which will last for many hundc4s, and in some cases, many thousands of years; and because the plant has been closed for ten years aready. Many y shorter-lived isotopes have aready decayed away, increasing the proportion of 5

Humboldt Bay Unit 3 FES 85 Appendix C

CoheAENTS ON THE DRAFT EIS FOR DECOMMISSIONING HUMBOLDT BAY POWER PLANT, UNIT 3 (NUREG-1166)

REDWOOD CHAPTER SIERRA CLUB d

occ tional expostre at:rt>utable to act!Yation elements. Data and anaksis are Q-22 to estrnate the exposures projected for the tuttre, and a determine the r sotrees, as opposed to the sotrces and expostres wtiich could be expected from rrrnediate dErnartkment. In ths way, a more corrplete comparson and examination

_ of the aYallable aternat!Yes can bo conducted, as requred by NEPA.

~

23. There are no design specrkations in the DES for the proposed spent fuel pool cover. What standards are considered safe? #e these standards premised on seismic safety? Will the coyer be constructed of a material that could cause knpact Q-23 damage to the stored fuel in the eYertof an earthquake. These and other questions mustbe addressed. the FES should contain a complete descrpbon of the cover's cornpostion, proposed installation methods, technical specfications, safety Yalue, abilty to permt montoring actiYties, and eYentual safe removal.

Q- 24. The DES contains no schedule for the proposed actions.

I 25. There is no apparert commtment in the document for montoring or Q-25 processing the spent fuel storage pool, nor is there a ny for preventing or scacitizing L soil contaminabon existing or wilich may be the resut of liner leakage.

26. There is no discussion of the past experience wth boral plate shielding blarkets proposed for use in storing the fuel assemblies in Section 3.2.3, Postulated Q-26 Accidents, PP. 3-7 and 3-9. These may be subject to wear, deterioration and failtre. A discussion of the presort exponence wth these plates should be included in the FES, alona wth a descrpbon of the montonng and inspecbon program necessary to enstre

_ that they remain in a functional state.

Q-[ 27. The FES should contain the basis for all the conclusions reached in t gh 29. The discussion of the Fuel Handling Accidert(p 3-9) asstrnes that there u wouM be lhited damage to fuel asserrt) lies dopped. This is not stt>startiated in conclusion, the des fus failed to adequately adtess the issues and hpads of longterm storage of nuclear waste materials in an area of high seistlicly. Hether has t adequately eYaluated the fullrange of a ternaljYes, including those Wthin the junsdiction of otheragencies, as requred by NEPA. A fulldiscusson of the aYailable a ternat!Yes was dismissed in faYor of a oeneric determination that is wthott Yalidty given the ursutabilty of the plart's loca6on and physical condtion. The sad trtth s that, should the plart be considered for licensing as a repostory for spert fuel and other high level nuclear waste, t would not qual (y under the NHC's own licensing Q.29 requremerts. The ste is unsutable for nuclear Generic determinabons not based on fact or rea wergenerationandwastestorage.

There exids, then, a serious potential to damage failto"wsh'the stuation away.

marineandothercoastal resotrees existing in Callomia's largest wetland and estuarine habtat, as well as to the economy, heath, and safety of the ctizens of the Northcoast. This DES treats the veryrealand cosby rrpacts of the acbon in a cavalierfashion.

AstheDES notes,theSAFS D rnaywellextendbe No frame used ttroughott the documert as a benchmark. yond the projected 30 year The rrpacts of a longer' to. frame are not ad&essed, parbcularly not from the standpoirt of increased risk of seisn,. evert.

Hta. *>ld Bay Unt 3 was neYer irtended to be a de facto nuclear Waste storage y facilty. t is ..

• designed to be one, and nothing in the DES indicates that the structtre 6

i Humboldt Bay Unit 3 FES 86 Appendix C

COMMENTS ON THE DRAFT EIS FOR DECOMMISSIONING HUMDOLDT DAY POWER PLANT, UNIT 3 (HUREG-1166)

REDWOOD CHAPTER SIERRA CLUB A

would be fcatied to serve this ptspose. In addbon,the doctrnert asstmes that all steps in a decades-long process will be scrupulously observed, desp te the fad that there is no econornic incentive for the licensee to do so. Atruism on the part of a proftmaki concern should rot be assurned. Given the liconsee's recccd for safety cortpliance ich has been InYestigated by the NRC's predecessor agency already, and cted by tleastone state agert as well), what asstrances ca n be o#ered that thesestepswillbetaken? Whatare potertialin O-29 they be mtmted (indeed they are mUgable These are at all? pacts disturbing f they questions for are not? Howwill wtch the DES proYides no answefS The decomrnissioning of this facilty will set many precedents and proYide much of the pertinert experience upon wtich futtre such decomrnissionings will rely. t is extremeP/ rnportart that this process be undertaken wth the greatest etcumspedlon and care, and nottreated wth the same arrocance and indiference that has charadertzed and still charaderizes the corstruction and licensing of nuclear power piants today.

This doctrnert is wholly inadequate as a DES and fails to meeteven the minintrn requrements of the National EnY'ronrnental Policy Act Substartial stpplementation and rewrting is necessary before t will.

Thark you for the opportunty to comme rt.

/

Carl A.Zichella Charman Nuclearissues Task Force f S. Wbug 2 W aal uww my Le ,8r .-me. aJ- :

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AstarA, t,it . Scgzi 8A E Humboldt Bay Unit 3 FES 87 Appendix C

2345 Larkin Street San Francisco, CA 94109 June 23,1986 Director of Nuclear Regulation U.S. Nuclear Regulatory Cor:nission Vashington, D.C. 20555

Dear Sir:

I am strongly opposed to P.G. & E.'s proposal to allow the Humbolt Bay Nuclear Power Plant to lie fallow until 2015.

The plant's fuel stora6e pool leaks and there is considerable R-1 danger in storing radioactive materials in a plant the experts agree could not withstand a major quake, even though it rests on an earthquake fault.

Chernobyl should have tau 6ht us that accidents are an ever present reality at nuclear power plants, and devastatingly threatening to life.

Please act to dis =antal the Humbolt Plant. I believe it would insure greater safety for those of us on the Northern California Coast.

Thank you very much for considering the opinions expressed in this letter.

Respectfully,

} t J.CCla

' -7 o_y' 7 WLA'/w Judith Field San Francisco Resident Humboldt Bay Unit 3 FES 89 Appendix C

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0 ,t 2fM TO: U.S. Nuclear Regulatory Commission Subject : Response to the Draf t Environmental Impact Statement for Decommissioning The Humboldt Bay Nuclear Reactor.

I have attended the Scoping Hearing over a year and half ago. I have read the proposed Draft Environmental Impact Statement. I have called the NRC and talked to Peter Erickson regardinr; a ;,public hearing abr>ut the Draft end decow.issioninc ;rocess.

How can the NRC represent and protect ablic health and safety if the NRC is closed to public hearings and input? Why is the NRC and PG&E opposed to

, public input?

l Such a skimpy, vague attempt to satisfy the laws and rules requiring an Environ-mental Ispact Statement for the decoatissioning of a Nuclear Reactory -Setting the mode for future decommissioning.with such an inadequate draft is shocking!

DiMIAL OF PUBLIC INPUT SNAZY SAFSTOR CLOSED DOORS:&i SECRECT BUILDING FAST WITH GENERIC SLIDING IN TO SMOOTH THE WAT F0$t NO ACTION DRESSED UP AS SAFE The fact that this draft is an examp1,e of what the NRC and Nuclear Industry's plan for the "DECOMiISSIONING PROCESS" is appauling and frightening.

1 THE NUKE IS HOT, UE DCN'T WANT TO EE RADI ATED . TCU ARE RESPONSIBLE FOR CONTAINING THIS POISEN IN A SAFE, EFFIUlr.HT AI.D TIMELY MANNER.

STOP MAKING WE " WASTE " IF YOU DON'T HAVE A PLAN THAT IS HEAiISTIC A!!D LOhKAELE TC F30TECT TIE TUBLIC ) ROM IT'S PCISEN.

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Speci f$ colly, the crack and leak in the holding pond dcas t.ot assure that P.G.&E. has the ability to safely contain and store the radioactive fuel rods and waste. Proposino that the Environmental Impact Statement be Generic is absurd. And to propose that the SAFSTOR be generic is unbelievable. Specific site and environmental condition and asseonant are absolut3y necessary.

I expect a public hearinC to happen.

wVd tg

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+~ got. r% (OA*yM 95560 Humboldt Bay Unit 3 FES 91-Appendix C

PACIFIC GAS AND E LE C T RIC C O M PANY 3 ~cVO T 77 sEALE STREET

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Au, gust 14, 1986 PGandE Letter No.: HBL-86-026 Mr. John D. Philips, Chief Rules and Procedures Branch Division of Rules and Records Office of Administration, MNBB U. S. Nuclear Regulatory Commission Mashington, D.C. 20555 Re: Docket No. 50-133, OL-DPR-7 Humboldt Bay Power Plant, Unit 3 Comments on Draft Environmental Statement for Decommissioning

Dear Mr. Philips:

PGandE has reviewed the Draft Environmental Statement (DES) for Decommissioning of Humboldt Bay Power Plant. Unit No. 3. The Enclosure to this letter contains our comments on the DES.

Kindly acknowledge receipt of this material on the enclosed copy of this letter and return it in the enclosed addressed envelope.

Sincerely, J. ' . Shiffer Enclosure cc:

J. B. Martin Humboldt Distribution Service List (Decommissioning) 0996S/0047K/GHM/1739 l

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'l Humboldt Bay Unit 3 FES 93 Appendix C

PGandE Letter No.: HBL-86-026 ENCLOSURE

l. Page 1-2, Section 1.2 - In the last sentence of the M rst paragraph, the "18 in-core fission chambers" should be "54 in-core fission chambers."

T4 The fission chambers were initially contained in 18 fission chamber strings containing 3 chambers each. The strings have since been cut up to separate the chambers and minimize stored waste volume.

Reference:

Environmental Report, page 4-51.

T. 2. Page 2-1. Section 2.1 - third paragraph - Same comment as above (item 1).

3. Page 2-5, Section 2.2 - This section states that when approval of SAFSTOR is obtained, the licensee will complete modification of the plant security system. In LAR 86-01 (HBL-86-16), dated May 14, 1986, a T-3 proposed security plan was submitted based on the Possession-Only License amendment approved in July 1985. Following NRC approval of this LAR, the modification to the security system will be completed. Approval of SAFSTOR will not be required to complete these modifications.

4. Page 3-6, Section 3.2.2 - fourth paragraph - This paragraph, both in the first sentence and the last sentence, can be read tc imply that waste analysis and solidification will be completed by the same contractor.

This is not presently how this is done, and it is not likely to be the T-4 way it will be done in the future. These two sentences should be replaced with the following:

"A sample will then be taken by the plant staff and sent to an off-site contractor for analysis. Upon receipt of sample analysis results, a contractor will solidify the waste using portable equipment."

5. Page 3-9. Section 3.2.3 - In the second paragraph, it is stated that Boral neutron absorbing blankets surround each assembly to ensure subtriticality. One fuel assembly will not be surrounded by the Boral T-5 material. This fuel assembly was damaged in 1975 (PGandE letter to Region V dated June 11, 1975) and is stored in a stainless steel box constructed for this purpose. The box is stored in the spent fuel

_ storage racks.

T- 6. Page 3-10, Section 3.2.3.4, Item (1) - Same comment as above (item 5).

7. Page 3-11, Section 3.2.3.4 - PGandE believes the following discussion will better reflect the conservatism of the criticality analysis:

TJ These calculations make the assumption that since the Boral plates were designed as an integral part of the fuel assemblies, any distortions of the racks would still leave each fuel assembly surrounded by Boral plates. While this assumption cannot be proved to be valid under all array-altering physical mechanisms, the following statements show the y calculations are conservative:

0996S/0047K Humboldt Bay Unit 3 FES 94 Appendix C l

Ik

• The licensee assumed the presence of fresh fuel at the highest enrichment with no credit for the presence of gadolinium, a burnable poison. This is conservative as even a small amount of burnup will reduce reactivity, and none of the fuel in the pool is fresh.

• No credit was taken for neutron absorption in the materials of the

fuel storage racks, the fuel channel, or the aluminum outside of the i B4 C containing core of the Boral.

• The 2-D neutron transport calculation assumed an infinite array of infinitely tall fuel assemblies, thus no credit was taken for radial or axial leakage.

• Optimal moderation was imposed by varying the gap between assemblies, T-7 the inner dimension of the poison can, and the fuel rod pitch within

the poison can. This is considered to be a very conservative assumption, since it is extremely unlikely that a distortion of the fuel racks would lead to optimal moderation.

• Since no radial or axial leakage was assumed and optimal moderation was imposed, it is very unlikely that any credible rearrangement of the stored spent fuel by crushing under seismic or other loads would increase reactivity enough to make the system critical. Even if a local pile of fuel pellets from the assemblies were formed, it would

, very likely be undermoderated and, therefore, subcritical.

B_ased on the above, there is a negligibly small likelihood that there is any credible means of achieving criticality in the stored spent fuel l

array. PGandE believes that the DES should be revised accordingly to reflect these considerations.

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f Humboldt Bay Unit 3 FES 95 Appendix C

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United States Economic Washington, D.C.

Department of S Agriculture Research Service 20005-4788 May 1, 1986 i

Herbert N. Berkov Director Standardization and Special Projects Directorate Division of PWR Licensing-B U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Dear Mr. Berkove We appreciate receiving a copy of the Issuance of Draf t Environment State -

Decoussissioning of Humboldt Bay Power Plant Unit No. 3. I have reviewed the draf t and have no cosaments.

_ Sincerely, i

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,y \ L=z _ub ' Ag [-

RN A. MIRANOWSKI Director Natural Resource Economics Division i

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Humboldt Bay Unit 3 FES 97 Appendix C

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' dMb $ f I UNITED STATES ENVIRONMENTAL PROTECTION AGENCY  !

( REGION IX 215 Fremont Street San Francisco, Ca. 94105 1

2 0 OCT E86 Herbert N. Berkow Director Standardization and Special Projects Directorate U.S. Nuclear Regulatory Commission Office of Nuclear Reactor Regulation Washington, D.C. 20555

Dear Mr. Berkow:

The Environmental Protection Agency (EPA) has reviewed the Draft environmental Statement (DES) for decommissioning Humboldt Bay Power Plant No. 3; Humboldt County; California.

We have the enclosed comments regarding this DES.

We have classified this DES as Category EC-2, Environmental Concerns - Insufficient Information (see attached " Summary of Rating Definitions and Follow-Up Action"). This DES is rated EC-2 because of the comments noted below. A summary of EPA's comments will be published in the Federal Register in accordance with our public disclosure responsibilities under Section 309 of the Clean Air Act.

After reviewing the DES and the proposed action, EPA agrees that the proposed action to store the spent fuel on-site (the "SAFESTOR" alternative) appears to be a reasonable alternative. This conclusion recognizes the fact that there is currently no commercial federal recository for spent fuel and no readily-available, alternate storage sites., We also agree that the proposed action would help reduce subsequent occupational radiation exposures by allowing radionuclide decay during the proposed 30 year interim storage.

~~

We would like to emphasize, however, that EPA views discussion in the Environmental Statement as an interim analysis only, not a final evaluation of the environmental impacts associated with complete decommissioning. The DES appears to recognize this by noting that the proposed action V-1 is both safe storage and delayed dismantling (DELAYED DECON) of the unit. Because numerous technical and environmental concerns are unresolved at this time, EPA believes it is essential that a supplemental Environmental Impact Statement be prepared as plans for final decommissioning are being

,_ developed and approved.

EPA's general questions and concerns relating to the

" generic" issue of decommissioning have been provided to V-2 the NRC earlier. One of these was a comment letter (5/24/81) on the Draft Generic Environmental Impact Statement on p Decommissioning of Nuclear Facilities--NUREG-0586. In that Humboldt Bay Unit 3 FES 99 Appendix C

o j J L letter EPA agreed that "there would probably be very limited l impact on the environment and public health from the proposed

actions." Despite that, EPA also raised a number of detailed.

1 questions and concerns for NRC's consideration. It is our

! y.2 understanding that the NRC has neither completed nor issued i a Final Environmental Impact Statement. This is a concern because the generic assessment that SAFESTOR is safe derives

. in large part from the conclusions in the generic EIS (page 5-1, paragraph 1).

Another related aspect that EPA has reviewed is the I proposed Decommissioning Criteria for nuclear facilities (10 CFR 30, 40, 50, 51, 7 0 a nd 7 2 ) .- EPA commented on these to NRC on 5/13/85. Though EPA did not have major concerns with j

these, EPA raised a number of issues that could eventually be V-3 related to the Humboldt Unit. These included: the definition of i permanent cessation of operations and criteria for decommission-J ing duration; level of detail in licensee termination survey requirements; waiver of requirement for license termination survey; and preparation of environmental documents. It is our understanding that these criteria also have not yet been completed.

~~

Because of these unresolved " generic" issues and future uncertainties regarding the site-specific. decommissioning at the Humboldt Unit, EPA believes that it is essential for the Final Environmental Statement (FES) to describe how V4 and when the NRC intends to resolve the remaining generic issues and commit to the preparation of a supplemental environ-mental impact statement for the Humboldt Unit. Without subsequent environmental documentation, EPA would view this document as

,, inadequate for completely assessing the effects of decommissioning.

We appreciate the opportunity to review this DES. Please send three copies of the Final Environmental Statement (FES) to this office at the same time it is officially filed with our Washington, D.C. office. If you have any questions, please contact Mr. Rick Hoffmann, Federal Activities Branch, at (415) 974-8191 or FTS 454-8191.

ncerelyyours,f I fl /.1

[] Q h.s kw Charles W. Murray, Jr.

Assistant Regional Adminin krator

for Policy and Managemedg Enclosure (1 page)

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Humboldt Bay Unit 3 FES 100 Appendix C

WMMARY OF RATItG DEFINITItm MD FD! LIM-UP ACTICN" Divirornental Iapact of the Action ID-Lack of Ctyections ne DA review has not identified any potential environmental inpacts requirirg sutstantive changes to the prtposal. De review may have disclosed opportunities

! for application of mitigation measures that could be acooiplished with no more than minor changes to the proposal.

l l EC-Envirernental Cbncerns De DA review has identified enviternental inpacts that should be avoided in order to fully protect the envircreent. Corrective measures may require changes to the preferred alternative or application of mitigation measures that can reduce the environmental impact. EPA would like to work with the lead agency to reduce these l inpacts.

ID--Envirornental Ctyections De DA review has identitied significant envirornental impacts that must be avoided in order to provide adequate protection for the envirornent. Corrective measures may require substantial changes to the preferred alternative or consideration of sane other pro;ect alternative (including the no action alternative or a new alternative).

DA intends to work with the lead agency to reduce these impacts.

$lU--Envirunentally Unsatisf actory De EPA review has ident1 tied adverse envirornental impacts that are of suf ficient magnitude that they are unsatisfactory trtn the standpoint ot public health or welfare or envirtroental quality. DA interns to work with the lead agency to reduce these impacts. If the potential unsatisfactory impacts are rot corrected at the f'inal EIS stage, this prcpcsal will be reccanended for referral to the CEQ.

Adequacy of the Impact Statenent category 1-Mequate DA believes the cratt EIS adequately sets forth the envircrrental inpact(s) of the preferred alternative ano those of.the alternatives reascrubly available to the project or action. to further analysis or data collection is necessary, but the reviewr may stggest the addition of clarifyirg language or inforuution.

Category 2-Insuf ficient Information ne oratt EIS oaes not aantain sutticient intormation for EPA to fully assess envirornental impacts that should be avoided in order to fully protect the envirornent, or the DA reviewer has identified new reascnably available altermtives that are within the spectrun of alternatives analyzed in the draf t EIS, which could reduce the envirornental impacts of the action. De identified additional information, cata, analyses, or ciscussion should be included in the final LIS.

Categot*/ 3--Inadequate DA cces not celleve that the craf t EIS adequately assesses potentially significant J

envirorrental inpacts of the action, or the DA reviewr has identified new, reasonably available alternatives that are outside of the spectrun of alternatives analyzed in the draf t EIS, which should be analyzed in crder to reduce the potentially significant envirarental inpacts. DA believes that the loentified additional information, data, analyses, or discussions are of such a magnituae that they should have full public review at a draf t stJge. DA ooes not believe that the draf t EIS is adequate for the purposes of the NDA and/or Sectico 309 review, and thus shoJ1d be fonnally revised and trade available for public coment in a supplemental j

or revised draft EIS. On the basis of the potential significant tapacts involved, this prcposal could be a candidate for referral to the CEg.

• Fran DA Manual 1640 Policy and Procedures for the Review of Federal Acttens inpactity the Envirurent Humboldt Bay Unit 3 FES 101 Appendix C I

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The Final Environmental Statement conta gs t e assessment of the environmental impact associated with decommissioning tH9 umboldt Bay Power Plant Unit 3 pursuant to the National Environmental Pol cy Act of 1969 (NEPA) and Title 10 of the Code of Federal Regulations, Part lg as amended, of the Nuclear Regulatory Commission regulations. The proposed de omaissioning would involve safe storage of the facility for about 30 years, aft which the residual radioactivity would be removed so that the facility would b at Ih release of the facility to unrestricte access \vels of radioactivity acceptable for l

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