ML20215K196

Forwards Comments Re Des for Plant Decommissioning.Des Classified as Category EC-2 Due to Insufficient Info,As Discussed.Fes Should Describe Resolution of Remaining Generic Issues & Commitment to EIS

ML20215K196
Person / Time
Site:	Humboldt Bay
Issue date:	10/20/1986
From:	Charles Murray ENVIRONMENTAL PROTECTION AGENCY
To:	Berkow H Office of Nuclear Reactor Regulation
References
NUDOCS 8610280024
Download: ML20215K196 (3)

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.- . f afh g I UNITED STATES ENVIRONMENTALPROTECTION AGENCY b d REGION IX 215 Fremont Street San Francisco, Ca. 94105 2 0 0CT 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 repository 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

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appears to recognize this by noting that the proposed action 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 the NRC earlier. One of these was a comment letter (5/24/81) on the Draft Generic Environmental Impact Statement on gcM' Decommissioning of Nuclear Facilities--NUREG-0586. In that ,g hof0280024861020 D ADOCK 05000133 PD3

. r letter EPA agreed that "there would probably be very limited impact on the environment and public health from the proposed actions." Despite that, EPA also raised a number of detailed questions and concerns for NRC's consideration. It is our understanding that the NRC has neither completed nor issued  ;

a Final Environmental Impact Statement. This is a concern j 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-proposed Decommissioning Criteria for nuclear facilities (10 CFR 30, 40, 50, 51, 70 and 72). EPA commented on these to NRC on 5/13/85. Though EPA did not have major concerns with '

these, EPA raised a number of issues that could eventually be related to the Humboldt Unit. These included: the definition of l permanent cessation of operations and criteria for decommission-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 and when the NRC intends to resolve the remaining generic '

issues and comc.it 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 l send three copies of the Final Environmental Statement (FES) to this office at the same time it is officially filed with i 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.

incerely yours,f .

I' e >

g

. A y Charles W. Murray, Jr. .

Assistant Regional AdminiE rator I for Policy and Managemeng I l

Enclosure (1 page) l I

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• s SUPHARY OF RATING DEFINITIQ4S AND PONUP ACTIQi' Envirornental Impact of the Action ID--tack of Objections

'Ihe EPA review has not identified any potential environmental impacts requiring substantive changes to the proposal. 'Ihe review may have disclosed opportunities for. application of mitigation measures that could be accuplished with no more than I minor changes to the proposal.

EC-Envirornental Concerns

'Ihe EPA review has identified envirornental inpacts that should be avoided in . order

to fully protect the envirornent. Corrective measures may require changes to the preferred alternative or application of mitigation measures that can reduce the envirormental impact. EPA would like to work with the lead agency to reduce these l

impacts.

ED-Envirornental Objections j

'Ihe EPA review has identified significant envirornental impacts that must be avoided j in order to provide adequate protection for the envirornent. Corrective measures may ,

require substantial changes to the preferred alternative or consideration of s m e other project alternative (including the no action alternative or a new alternative).

EPA intends to work with the lead agency to reduce these impacts.

j EU-Envirornentally Unsatisfactory ,

' 'Ihe EPA review has identitied adverse envirornental inpacts that are of sufficient magnitude that they are unsatisfactory tre the standpoint of public health or welfare or enviremental quality. EPA intenas to work with the lead agency to redu these impacts. If the potential unsatisfactory inpacts are not corrected at the final i EIS stage, this proposal will be recomended for referral to the CEQ.

Adequacy of the Impact Statenent -

Category 1-Adequate EPA believes the craf t EIS adequately sets forth the envirornental impact (s) of l

the preterred alternative anc those of,the alternatives reasonably available to the project or action. No further analysis or data collection is necessary, but the reviewer may suggest the addition of clarifying language or information.

I Category 2-Insuf ficient Information

'Ihe craf t EIS does not contain sutticient information for EPA to fully assess l

environmental impacts that should be avoided in order to fully protect the environnent,

! or the EPA reviewer has identified new reasonably available alternatives that are within the spectrun of alternatives analyzed in the draf t EIS, which could reduce the envirornental impacts of the action. '1he identified additional information, data, analyses, or aiscussion should be included in the final EIS.

4 Category 3-Inadequate EPA does not De11 eve that the craft EIS adequately assesses potentially significant envirornental inpacts of the action, or the EPA reviewer has identified new, j reasonably available alternatives that are outside of the spectrun of alternatives analyzed in the draf t EIS, which should be analyzed in order to reduce the -

potentially significant envirornental inpacts. EPA believes that the identified additional information, data, analyses, or discussions are of such a magnitude that

they should have full public review at a draf t stage. EPA does not believe that the draft EIS is adequate for the purposes of the NEPA and/or Section 309 review, and thus should be formally revised and made available for public omnent in a supplemental or revised draft EIS. On the basis of the potential significant inpacts involved,

this proposal could be a candidate for referral to the CEQ.

l

• Fra EPA Manual 1640 Policy and Procedures for the Review of

' Fedeml C% ions Inpacting the Envirornent ]