ML20214K344

Comments on NUREG-1166 Re Des for Decommissioning Facility. Des Inadequate & Fails to Meet Min Requirements of Natl Environ Policy Act

ML20214K344
Person / Time
Site:	Humboldt Bay
Issue date:	08/10/1986
From:	Zichella C Sierra Club
To:	Office of Nuclear Reactor Regulation
References
RTR-NUREG-1166 NUDOCS 8608210045
Download: ML20214K344 (7)

Text

'

/ ' (0-155 SIERRA CLUB - REDWOOD CHAPTER

..... , m: p .m August 10,1986 Oficeof Nuclear ReactorRegulation U.S. Nuclear Comrnission Washington,D. 2055 Re: Comrneris of the Redwood Chapterof the Sierra Club on the Draft Environmerhi ct Statement for Decommissioning the Humboldt Bay Power Plant,

.Unt 3(NUREG-1 66)

Dear Sr-The Redwood Chapterof the Sierra Club submts the following commerds on the Craft Envronmerhl impact Statement for decomrnissioning the Hurrt>oldt Bay Power Plant, Unt 3 hereafterreferred to as W plant"(NUREG-1166).

The RedYeod Chapter is one of 13 Sierra Club Chapters operating in Calfornia, and the one in which the plant is'iocated.

The Redwood Chapter is appreciative of the oppcrtunty to commenton the xoposed decomrnissioning of the plant . This is an issue of great ' nce, notonly

'or northern Calfornia, where this partkular plant is located, but for nation as a who which will haYe to Contend WRh many SUCh decommissionings In the ahea . How this partmular decomrnissioning is handled will )erience provide the exl years from whkh futire decomrnissionings will beneft. t will also set the tone for We p@lk partKpation such proceedings must accommodate underthe law. Accordi , we urge you to include another pubik hearing from whkh to incorporate formal into the final EIS (FES). We commend you for extending the tirneframe for comme on this DES.

We haYe both General and specfic commeris on the Draft.

Comments

1. Comments and concerns o#ered by the publi: in the scoping session have not been considered. No compilation or analysis of them is included in the DES. Many comments were o#ered by members of the publk and elected c(Klats at the sco al session. The c sponse of the agency to these points of concern is no:ab absentfrom the DES. FES should cordin a listing of the comments and a general response to eachma area of concern, as reflected in an analysis of aternatives and information relative the'rconsideration.

2. The DES does notc wth the proYisions and intentions of the National EnvronmentalPolky Act (NEP because t fails to examine the drect, Indrect, and cumulattye efects ithe propos action, and falls to substantive examine and discuss the range of aternatives that are presently available. nerk determinations are inhere InYalid for the examination of the enYronmerDI ' ofa flC projectora n. AssumingthatSAFSTORisagenerical acce le forall nuclear power pla nts nores the Yery serious special lem o'the H idt Bay sRe-thattsiswthin 000feetof threecapableor ntially capable fauts. This is the main reason the tant was shut down in 1976, and the pnme reason is retoft is presently uneco 1. t is illogical and 'trational to dismiss this fact whon ,

8609210045 860010 0g PDR ADOCK 05000133

. . . To explore, enjoy a. D, PDR wlldllfe, and wilderness. .  : ,0

~

COWENTS ON THE DRAFT EIS FOR DECOttilSSIONING HLM90LDT BAY POWER PLANT, UNIT 3 (NUREG-1188)

REDWOOD CHAPTER SIERRA CLUB I

I considering the wisdom of storing highly dangerous nuclear materials at the plant for the next 30 years, or as is arguably the case, longer.

3. The DES, by stating that SAFSTOR is the "soie viable alernahve flor sport fuel  :

, storage," indkates that a decision has akady been arrived at by the NRC concerning the decommesioning policy- rendering the ES process a farce and reducing the document to an instrumert for ustfying the decision rather than a tool flor obtaining irformationandprovidm' g foradecisionasrequiredb i purpose as an EIS the DE mustconsiderall topads- direct,y NEpA.

indtect,andcumulative; To futill Rs  !

must be based on accurate, h h quait I scientfic information and analysis; and must .

tobe :roposedactionIAntav. Sierra Chb.422 discussaJ1 reasonablea U.S. 347i 1979Y FlintRdoe 2;;cisewCo.v. Scenic Iivers nas'n of Ok ahoma j 690 U.S 176 56rn a v. E hx:k. 610 F. 2nd 750 (9 . Is purpose under the islaw as a(II?6);

got-decisiona Ca document to provide the h Ct.1982)tering adminis a wth the infbrmation t needs to make an enytonmentally Informed decision r 7a$ncy than justfying decisions ateady made."[40 CFR $ 1502.2(g)].

i .

4. Adiscussionof theseismicandgeologiccharacteristicsof the HumbodBay sie is not included, and the DES trealment of the hazards of the sie and the'r effects on the proposed action are far too cwsory. The Humbokt reactor, as mentioned above l (#2) , was not permited to restart by the NRC in 1976 because of serious concerns about the abilty of the facllty to wthstand the maxtnum possble earthquake expeded tom the t!1ree capable fauts located dkectly adjacent to the plant. In 1983 modficationstobri the plant into NRC comphance, in addtion to TMI backft i requirements,were tobe soex The existence of three very close llpenswe as to be uneconomical.auts is b fauts lace the on and offshore topography of Humbold Cou which also could I adversely effect the plant and the radioacuve materials stored . Wthina40 mile .

radius are: The Fakr-Korbel faut (active). This fauttraneocts northwoet Arcata and is t I capable of a 6.0 7.0 magntude quake (ENVI 1975); The CaDe Mendocino-False Cape ShearZone active isestimatedtobe le of a 7.3 earthe umke; andthe Mendocino Fn tctw(e Zone)(potentialf r active) In,orcomprses,one of the mostsommica ly active areas in Norts Amenca (The Mendocino tacture zone is partof the tectonically active triple plate junction, and is capable of a 7+ 'Rkhler scale magntude November 19801 and is possbie of a seemic event cPweatquake{

i

magntude '8.0 orgeater1 The November 1980 temblor toppled a keeway overpass lees than two miles from the plant, deepte the epicenter's location being nearly 40 l

l miles away.)her tisrat . hard to believe that the licensee could be informed that the pli unsutable for continued operation of the plant, while being permited to advocate that -

l high level nuclear waste be stored there for an addtional 30 years. More incredble sail, is that the NRC would conclude that two othermethods of storage and l

would be at least partly rejected as options because of seismic co[nsiderations The Entemlunant structure maysiso rel as aresd of seisnic events Wh a potentisifera release shadoecthay(DES p t-31.3.2Xemphasis added). I

! Thus,this acthty . wodd reeuke seismic considmahans of the lSFSl[ DES p. H l 1.3.3Xemphasis added).  !

2  !

i_____._ __ ___

~

COWENTS ON THE DRAFT EIS FOR DECOWISSIONING HtAdBOLDT BAY POWER PLANT, UNIT 3 (NUREG-11SS)  !

REDWOOD CHAPTER SIERRA CLUB The FES should provide a detailed trealmentof the sem' mology of the area and an examination of the risk of a 30 year or longer storage plan at the sle. The most hportaitseismic cons 6derations to be taken mio accourtare those at the plant. t the seemic considerations of other, hypothetkal aternatives are to be considered as well, j they should be considered from the sta int of comparison wth the risks associated i wtnthoseakoadyadcnowledgedatthe nt, which have prechtaled the need ibr the .

proposed actioninthethtplace. '

5. There is no discussion of the enykonmental characteristks of the ste, nor of is noe relative 10 other such sles in the stale or nation. There is no invenbry of rtor animal species which would be afeded by the proposed ad!on atthe ste.

cornplete lack of this irformation in and of Iser serves to minkrnN the meaning of thedocument,whichis,allerall,an Emnhamssmate/ hpa<tStatenwnt. The .

enytonmental is located is c ute signficance goat. Hunbokt10 the Bay, stale and accordirm nation io the of Humbokt Bay,Coastalonwhichthep Calfornia Commission, s the largest wetland and estuarineimblat in the Calfornia Coastal Zone. tcontains approxrnalmly 23% of allcoastalwetlands in Calfornia. Es waters are home 1036 species of fish, including such aquenc faura as anchovies, chinook i and coho salmon, steelhead, etAthroat trott , smets,s h, rockfishes, sand dabs, soles and flounder. Approxknalely 750 acres of the ba bolbomandchannels are usedIbrcommercialoyalerproduction. Manyof theb usingthebayareprotected

! by internationallreatles which hpose national res :ensb lbrprotocoonoftheir i i

habtat. The Bay Roer is considered a Nabonal Wl dife Sa . Peregine Falcolns, which hunt over the bay, are on the flederal Enda Species List The

rivers and streams trbulary to the bay provide spawning nusenes for juvenile salmon L and trout Streamside r$arian hablats hold diverse wildife populations. The DES fails to provide any descr1 phon whatsoever or the environmortal setting of the preposed activtles. The FES should provbe detailed irformadon on the 4

environmental setting and potential hpacts on marine and terresinal fauna and flora of

, the geposed action and any accidents or incidents anticpated as 'normar or  ;

I hypothebcally projected as worst case.

• l 6.There is no inventory ors of evidence of cutural resources thatmay be l located at or near the sie which wou be alreded by the proposed action l

I 7. The conclusion stated in the licensee's ER (Section 6.3 2.2), that :

Ground Worcodd be contaminated bytheless of poolwateri aleek were to develop frem tho poci te tho suroundng sel, but cordemrutien vodd be verysight even f the leek were very rapid ...This estimete is consenettve shes the welervolume released from the pool wedd reach en equabmen wh the very hieh wer table h the se e see ,

strata. '

is at odds wth Section 10.3 2.2 of the ER, which concludes that gound water flows toward the E av from the sie, and the aquier is nushed each year by htidos and I spring runof '. This clearly indicales that an exchange of radioactive ma ~ isItomthe see s ble, and perhaps has alreadtoccurred. A sonous leak wouldclearly have g consequences, both fbr the contamination of fish and mollusk species i lbundinthe and economically on the financially trotbied fishing industry which is l

an hportant of Humbokt Count rs volatile economy. Innuendo related to j contamination of seafood products alone would be sulficient to devastate this fragile 3

'~

CnhMNTS ON THE DRAFT EIS FOR DECOhmlSSIONING

. HLMBOLDT BAY POWER PLANT, UNIT 3 (NUREG-11 SS)

REDWOOD CHAPTER SERRA CLUB Ind .The DES falls to adtess this issue, presumably because of the quotation clod . The FES should contain a full and coropletie discussion of the sto hyeology, niativeofthepolertialfor a contaminationof the and Bay waters via theaswellasadiscuss aqudTor,nd consequences of, ion of any p suc cortamination.

8. There is no discussion of how the proposed action will be in cornpliance wth Stale slahAss, lo.The Calforna Coastal Act, or how inter-agency coordination e# orts j will be conducted to ensure compliance.

9. There is no discussion of the rale or consequences of continued contamination of the soil at, and youndvalor beneath, the sto due to the continued j and potentially increased leakage of the spent fuel storage pool.

10. The FES should more fully disclose the potential cisnulative efects of increasing the amount of long term of radioactive liquid in a pool already plagued by leakage.  !

11. Failure of the mechanical pump system preventing escape of leaked malertals Itom the spent fuel storage pool s not addressed in the DES. This should be rectfled in the FES along wth a docussion of the hpacts associated wth the pump's

• failure, and any backup systems, planned or to be required, by the NRC.

12.The FES should more fully identfy measures for m - ~ngthepotential impacts, including those caused by pump marunction and ge,onareafarmlands, pound water, wetlands, and bay waters.

l

13. Deeple licensee e# orts to prevert soil contamination at the plant such contamination has persisted. The proposal to enclose the radwaste building for the storage of addhonal contaminants may actually increase soil contamination by Increasing the volume to be handled and stored. The DES does not provide adequale l itformation on how the poposed conalruchon will prevent soil and poesb water i contamination. The FES should contain addtional data, plans, and m n i

measures suficiert to protect the soil and water around and beneath the rtfrom addtlonalcontamination. Addtlonally,aternativestoconstructinganew clity shouldbe discussedinthe FES.

14. The existmg precedert of storing sport fuel at other federal, but non-NRC as i; the cases of Three Mlle islandand Sh$

stes Idaho ( Falls roepechvely is ignored sinapparertviolation in the DES. Thepinport-stored of NEPA, at Han I

which requies a discus)sion of reasonable aternatives "not wthin the jurisdic the lead agency,"40 C.F.R. $1502.14 (c). Such a discussion must be included in the FES.

,. 15. The DES is vague as to which contaminated malertals are considered lowor i high level waste, and how much of other classficabon will be stored on-ste until 4

ermanentrepostories are located. The associated hpacts atthe finaldestination l heilly are also notaddressed t

16. Details on th, technical spectications lbr the proposed radwaste building are  !

not included in the DeiS. Netherare plans orseismic slandards included. The FES should provide this and related data on the structure to ensure that ptblic safety is 4

COINENTS ON THE DRAFT EIS FOR DECOlmlSSIONING HLA4BOLDT BAY POWER PLANT, UNIT 3 (NUREG-1188)

REDWOOD CHAPTER SIERRA CLUB protected, and proper reYlew by the Coastal Commission is possble. Under Calfornia law, the Coastal Commission must determine whether the structure's location and design are most protectlYe of coastal resources. This information should be proYided to the Corrunission forreviewand inclusion in the FES.

17. The DES does not indicate that the structural integrty of the radwaste building.will be in conformance wth standards requted of ntIser.

Failure to do so will resut in the strong Ikelihood of addtional soil and contamination in the eYent of a signficant earthquake on or near fauts adjacent to the plant. The FES should include a seismic analyss of the structwo as well as any details on backup safety systems t may be proposed to contain intended to preYent soil, ground water, or open water contamination at the plant due to a signficant seismic eYen[.

18. There is absolutely no discussion of the dangers and impacts of the use of chemical agents for decontaminating surfaces in the plant during the decommissioning rocess anywhereinthe DES. The ER bythe licenseeacknowledgesthat hose chemicals possess hazardous tox ical properbes. The'rmisuse orspillage would haYe serious Consequences. The FE should contain an inYentory and ana is of these chemicals, and provide information on the plans for stonng, applying, rinsi Iransporting and disposing of them. There also should be a discussion of the ram ns of accidents associated wth the'r handling and storage, under" normal" ctcumstances and in the eYent of an earthquake. This is a majorissuethatis noteYen superficially ad&essed in the DES. This oversight that cannot be permRted to be repeated inthe FES.

19. As the discussion of aternatiYes to SAFSTOR are inadequately nted, so is any discussion of the relative costs of any aternatives to the action.

The absence of this Information hampers an effectlYe analysis of tle asbllly of all aternatives, relative to each other or alone.

20. The DES is deficient in failing to address aternatives to the direct discharge of radwaste into Humbokt Bay as the resut of Rs Worst Case Scenario. t s' rnilarly rails to indicate that there are any backup systems- ether in place or proposed- to handie the descrbedemergency.

21. Throughout the DES the NRC uses such expressions as "negligbly small,"

"very Ike ," "negligbly small Ikelihood," and "very small fractions (see especially p.

3-11 . " actionor to dis) count the possbilty of or ramrications to consequences the resuterms are used roposed action. These terms are judgementfactors which are uns ntiatedand

oo vague.

22. The DES contains no discussion of the activation elements presentatthe plant. Nether is there any discussion of the relatiYe exposure rates of decommissioning in the future as op x> sed to the present. While t is clear that occupational exposure would be rec uced to some degee as shorter-liYed isotopes decay, this advantage may be signficantly overstatedbecause of the presence of high energy emtting actiYation elements in the steel and concrete of the reactor and containment, which will last for many hundreds, and in some cases, many thousands of years, and because the plant has been closed for ten years ateady. Many shorter-lived isotopes have already decayed away, increasing the proporbon of 5

COhMENTS ON THE DRAFT EIS FOR DECOhMISSIONING HLNBOLDT BAY POWER PLANT, UNIT 3 (NUREG-11SS)

REDWOOD CHAPTER SIERRA CLUB occu >ational exposwe attrt>ulable to activation elements. Data and ana, lysis are nee < ed to estimate the exposures projeded for the hiwe, and a detemune the'r sowces, as opposed to the sources and exposwes which could be expeded kom immediate dismartlement. In this way,a more cortplete andexamination of the available aternatives can be conducted, as required NEPA.

23. There are no design spectications in the DES forthe spentfuel poolcover. Whatstandards are considered safe? Are these sta promisedon seismic sakty? Will the cover be construded of a material that could cause knpact damage to the stored fuel in the event of an earthquake. These and other questions t

must tie ad@essed. the FES should contain a complete description of the cover's cornpostion, proposed installation methods, techmcal specticabons, safety value, abilsy to permt montoring activties, and eventual safe removal.

24. The DES contains no schedule forthe proposed actions.

25. There is no apparent commtment in the document for montoring or  !

prccessing the spent fuel storage pool, nor is there any for preventing or stabilizing soil contamination existing or which may be the resut of liner leakage.

26. There is no discussion of the past expenence wth boral plate shielding blankets proposed for use in storing the fuel assemblies in Section 3.2.3, Postulated .

Accidents, PP. 3-7 and 3-9. These may be s@)ectto viear, deterioration and failure. A discussion of the presort exponence wth these plales should be included in the FES, alo wth a GHu pion of the montoring and inspechon program necessary to ensure that remainin a functionalstate.

27. The FES should contain the basis for all the conclusions reached in t.

28. The discussion of the Fuel Handii /aidert(p 3-9)asstanosthatthere muld be Irnted damage to fuel assernbhes . Thisis nots @stantialed.  :

i in conclusion, the des has failed to adequately adeess the issues and irrpacts oflo storage of nuclearweste malenals in an area of seismicty. Nether j hast ly evaluabed the full range of aternathes, Inc thosewthinthe Jirisdiction otheragencies, as reqdred by NEPA. A full discussion of the available aternahves us dismissed in favor of a oeneric determmabon that is wthoutvalidty n the unsutabilty of the plart's loca6on and physical condtion. The sad truth is should the plart be considered for licensing as a repostory forspert fuel and other high level nuclear mste, t would not qually under the NRC's own licensing requtements. The sie is unsutable for nuclear generationandwastestora Generic determinations not based on Pact or real failto"wish"the stuation away.ge.

There exists, then, a serious potential to damage marineandothercoastal resources existing in Calfornia's largest wetland and estuarine habtat, as well as to 4

the economy, heath, and safety of trie etizens of the Northcoast. This DES treats the very realandcostly 'rnpactsof the actionina cavalierfashion.

AstheDES notes,theSAFS O maywellextendbe time frame used throughout the document as a benchmark. '

yond The rnpacis of the projected 30 year a longer timetame are not addressed, parbcularly not from the stan$oirt of increased risk of seismic event.

Hirnbokt Bay Unt 3 was never irtended to be a de facto nuclear waste storage

facilty. R is not designed to be one, and nothing in the DES irdicates that the structure 8

COhMENTS ON THE DRAFT EIS FOR DEcond1SS10HING HIMar4.DT BAY POWER PLANT, UNIT 3 (NUREG-1185)

REDWOOD CHAPTER SIERRA CLUB would be Ibitfled to serve this ptspose. In addtion, the documert assumes that all  !

steps in a decades-long process will be scrupulously observed, despRe the fact that there is no economic incentive forthe licensee to do so. Atruism on the partof a proft-mak' concern should not be asstaned. Given the licensee's record for compliance which has been investigated by the NRC's predecessor agency area ,

and cRed least one state agency as well , what assurances can be olpered these steps will be taken? Whatare the poten)tial knpads f they are not? Howwill they be mbgated i indeed they are mbgable at all? These are disturbing queshons for whichthe DESprovides noanswers.

Thedecommissioningofthisfacil will set many precedents and provide much oftheportinerte nee uponwhich such decommissionings will rely. t is extremely thatthis :rocess be undertaken wth the geatest cretsnspection andcare,a nottreatedwt1the same nce andindWorencethathas characterized and still characterizes the co nandlicensingof nuclearpower plants today.

This doctsnett is wholly inadequate as a DES and falls to meeteven the mintnum requtements of the National Enyr' onmental Policy Act. Substantial sipplementation and revating is necessary before t will.

Thark you for the opportunty to comment.

incerely, .

Carl A.Zichella

~

Chairman Nuclearissues Task Force f S. d& etmsueX1 a"A m ma.y Le. f<uG2 2r e aA- :

0 0- & 6,:?/

AsaATA, dA . 465.2t dA 2-7

_ _ _ _ _ . _ _ . _ _ . . . _ . . _ . _ _ . . _ _ _ _ _ . . _