ML20214H990

Comments on Des for Plant Decommissioning.Failure to Hold Public Hearing Criticized.Urges Immediate Development of Plant Dismantling Plan Rather than Wait Until Near End of 30-yr Safstor Period

ML20214H990
Person / Time
Site:	Humboldt Bay
Issue date:	08/07/1986
From:	Wellish P AFFILIATION NOT ASSIGNED
To:	Office of Nuclear Reactor Regulation
References
NUDOCS 8608140472
Download: ML20214H990 (3)

Text

n U.S. Nuclear Regulatory Commission Aug. 7, 1986 Washington, D.C. 20SSS Director, Office of Nuclear Reactor Regulation The following are comments on the Draft Environmental Statement for the decommissioning of Humboldt Bay power 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 done its job of serving and protecting the public, many of whcm are concerned about this decom-missioning but are not able to express their concerns on paper. A public hearing should have been held, and the lack of one clearly indicates the NRC's regard for the public.

My first comment on the DES involves the use of the word " alternative."

Alternative is defined as "a choice between two or more than two possibilities."

The discussion on pages 1-2 to 1-S makes it clear that all the possible decom-missioning methods, except "SAFSTOR," are actually not possibilities at all.

The statement on page 1-3 that " the licensee selected the SAFSTOR alternative for three reasons" (and goes on to list the reasons) is misleading and sloppy 3 the licensee has no real choice because of the lack of a Federal repository and because entombment is no longer thought to be a reasonable option. At this time, mothballing is the only way to decommission (or rather to begin the process of decommissioning) a nuclear power plant. The statement on page v, " Storing the spent fuel assemblies at Humboldt Bay is the sole viable alternative for spent fuel storage at this time," is also misleading and should ue reworded in the FES there is no such thing as a " sole alternative." (See also page S-1, second paragraph.)

My second area of concern is how the NRC has determined that the seismic design of the plant is adequate and safe for "SAFSTOR" when it has been deter-mined inadequate for operation (page v, (3]) and inadequate for entombment (page 1-3): "The entombment structure may also fail as a result of seismic events with a potential for release of radioactivity." If seismic factors were used

• to evaluate entombment then why is the staff using the Commissicn's generic I determination that no significant environmental impacts will result from the i storage of spent fuel in storage pools for at least 30 years to evaluate "SAF-l STOR" rather than looking at this particular site and evaluating it on the basis

} of actual seismic factors 7 i On page 3-4 it is stated that "the staff used somatic and genetic risk estimators that are based on widely accepted scientific information." The j sources for the information are dated 1972, 1975, 1977 and 1980. I considor this fairly "old" information and question whether there might be newer information that is more accurate and should be used.

I page 3-S contains the statement, "The lower limit of the range would be

{ rero because there may be biological mechanisms that can repair damage caused by radiation at low doses and/or dose rates." I have never heard of any evi-

! dance that suggests this (in fact, the bulk of evidence suggests the opposite).

The FES should either include documentation for this statement or else omit it, as it is extremely misleading.

It is stated on page 2-6 that "near the end of the SAFSTOR phase, the licensee will submit the DECON plan for staff review and approval." I feel strongly that the time to make a dismantling plan is now. It should be made by the people who built and operated the plant because they are the ones who are familiar with it. Thirty years from now they will all be dead, and the q people who plan the dismantling will have to rely entirely on written records 0, which can't possibly contain the information that these workers have. A plan (,

should be developed and submitted news it can always be amended later when' O information on how to dismantle a nuclear reactor is actually developed. 1 8608140472 860907  ; -

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' comments paga 2 j Also on page 2-6 is the statement that "the licensee has initiated action with the Califnrnia Public Utilities Commission to set aside and accrue funds for DECON activities." I would like to know why people who received no elec-tricity from Unit 3 (anyone who began receiving power from PG&E after 1976) 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-p r e h e n t,1 v e , realistic and ecologically responsible plans for disposing of its highly destructive wastes. Peter Erickson's response to my question of 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 DOE 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.

RESPECT THE EARTH In Hope, W 2 Pam Wellish Box 914 Redway, Ca. 95560

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