ML20214K145

Comments on Des (NUREG-1166) Re Facility Decommissioning. Assumption That Safstor Sole Viable Alternative & Failure to Fully Discuss Safstor Consequences Criticized.Des Does Not Satisfy NEPA

ML20214K145
Person / Time
Site:	Humboldt Bay
Issue date:	08/12/1986
From:	Welch M REDWOOD ALLIANCE
To:	Office of Nuclear Reactor Regulation
References
RTR-NUREG-1166 NUDOCS 8608180151
Download: ML20214K145 (4)

Text

o August 12, 1986 Director Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, D.C. 20555 RE: Comments on Oraft Environmental statement for Decommissioning Humboldt Bay Power Plant, Unit No. 3 (NUREG-IISS)

Dear Sir,

The Redwood Alliance submits the following comments on the Nuclear Regulatory Comr;ission's Draf t Environmental Statement (hereinaf ter known as " DES"), for Decc9missioning Humboldt Bay Power Plant , Unit No. 3 (hereinaf ter known as "the plant") ( NUREG-1166 ) .

The Redwood Alliance has represented the interests of a large segnent of Humb idt County's ocpulation several times in matters concerning the plant, including, but not limited to, support for previous intervention, intervention in Public Utility Commission rate hearings, and monitoring and pub 1:cizing safety and environmental issues at the plant. The Redwood Alliance now represents the viewpoints and concerns of those in the above mentioned sugment 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 en this important document.

COMMENTS

1. The DES does not comply with the provisions and intentions of the Naticnal Environmental Policy Act (NEPA) because it fails to examine the direct, indirect and cumulative effects of the proposed action. The DES should have provided 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 should provide the lic with l'nf ormation on the environmental impact of the proposed project , as I

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Redwood Alliance's DES Comments Page 2 well es encourage public participation in the development of that information.

2. The DES contains no discussion or analysis of the comments from members of the public and elected officials 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 alternatives for a plant that is sited near several potentially active earthquake faults. Unfortunately, the NRC took the position that a 30 year SAFSTDR 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 position.

4. Further consideration 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 Federal Interim Storage facility or an independent spent fuel storage installation (constructed away from the plant site and away from seismic and other hazards ) may well qualify as the only safe (last resort) alternatives under the Nuclear Waste Policy Act of 1992 (NWPA).

It is difficult to understand how the plant can be considered unsafe for continued operation 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 facilities are currently being used for disposal of high level waste from the decommissioning of Shippingport and Three Mile Island nuclear power plants.

S. There is no discussion of the environmental characteristics of the site, nor of its relative impcrtance.

S. The FES should contain a full discussion of the potential for a major earthquake and series of earthquakes in the vicinity of the plant. Included in that discussion should be a detailed assesment of the resulting potential damage to the plant and the environment.

7. Even in its assumption that SAFSTOR in the only viable alternative for decommission 1'ng the plant, the DES fails to address the effect of storage and eventual dismantlement on the human and natural settings of the plant.

Included in this should be a detailed analysis of the potential impacts should high level waste be released into the environment by catastrophic earthquake or otherwise.

8. The Final Environmental Statement (FES ) should include a full discussion of the site hydrology, and its relationship to future potential and past contamination of the groundwater around the plant, and the potential for migration into the adjacent bay.

9. The impacts of a failure in the spent fuel storage pool liner pump should be more adequately discussed.

10.Because the plant has been shut down for over 10 years, the FES should further consider immediate dismantlement. Danger from occupational exposure has been overstated in the DES because many of the shorter-lived isotopes have B

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Redwood Alliance's DES Comments Page 3 already decayed away. Additionally, dif ferences in the of f-site truck traf fic projections for SAFSTOR and DECON have similarly been overstated, ll. Specific requirements for the proposed radwaste building should be discussed in the FES. Will the increased capacity of the facility contribute to an increased posibility for environmental contamination?

12.The DES does not address the use and storage of chemical agents used for decontamination. What are the potential environmental impacts of these chemicals?

13.The DES fails to address alternatives to direct discharge of radwaste into the bay. It also glosses over the use of backup. systems in case of the need for emergency discharge.

14.There should be design specifications for and a technical analysis of the

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safety specifications involving the proposed spent fuel cover.

15.The FES should contain a complete discussion of past experiences with boral shielding for spent fuel assemblies including effects of the long-term use proposed in the DES.

16.The DES contains no schedule for completion of proposed actions.

17.The DES needs to address assurances that the spent fuel pool will be adequately monitored for leakage, and needs to discuss what would happen to the plant if the licensee someday goes out of business.

18.The FES should contain the basis for all conclusions reached in it and should avoid using expressions like " negligibly small", "very likely", and

" negligibly small likelihood" used to back up a position without quantifying the possibilities.

19.The FES should contain a discussion of siternatives to trucking waste from the plant, incuding the use of barges.

Conclusion The DES is remarkably inadequate in its discussions of the issues pertinent to the decommissioning of the plant. In addition it doesn't even come close to fulfilling the requirenents for an Environmental Impact Statement as stated in i NEPA.

The most fundamental flaw in the OES is the assuspiton that the agency's and the licensee's preferred alternative is the sole vanble one. To compound this farce, the document then sets out to justify this position with little regard to a discussion of alternatives. Secondly the OES fatis to adequately disclose the full range and magnitude of the consequences of the 30 year SAFSTOR alternative.

The Redwood Alliance and the concerned citi: ens of this community can only hope that the FES will resolve these problems. This FES and the final license for decommissioning the plant will set many precedents for treatment of other

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Redwood Alliance's DES Comments Page 4 plants soon to be decommissioned. It is of paramount importance thet this process be undertaken with extreme care and not the arrogance and indifference that has been shown to date.

Thank you for this opportunity to comment.

Sincerely [ [

{lg Michael.Wele ,

\ g Offi e Coordinator

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