ML18030A295

Provides Comments on Suppl to Des Re Operation of Facilities.Fes Should Include All Risks from Moderate Frequency Accidents,Infrequent Accidents,Limiting Faults & Severe Core Melt Accidents

ML18030A295
Person / Time
Site:	Susquehanna
Issue date:	05/28/1981
From:	Pomponio J ENVIRONMENTAL PROTECTION AGENCY
To:	Youngblood B Office of Nuclear Reactor Regulation
References
NUDOCS 8106020488
Download: ML18030A295 (3)

Text

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REGiON III 6TH AND WALNUT STRS=TS PHlLADELPHIA. PENNSYLVANlA 19306 MAY 28 l981 Zr. B. J. Youngblood, Chief Licensing Branch No. 1 Division of Licensing Mgh &au a ueruran 2 3 U. S. Nuclear Regulatory Commission fOA(2425$ goN Vashington, D. C. 20555

Dear Mr. Youngblood:

We have completed our review of the Supplement to the Draft Environmental Impact Statement related to the operation of the Susquehanna Steam Electric Station Units 1 and 2; We of'fer the following comments for your consideration.

The Co~s~son is to "be commended for'its decision to prepare this Suppleme'nt discussing the environmental and societal impacts of a core melt down accident.

EPA has emphasized the need to review an evaluation of the environmental impacts resulting from different LWR accident scenarios including Class 9 accidents.

The assessment of environmental impacts relating to severe accidents at the plant employs methods originally developed in the Reactor Safety Study (WASE-

)400). These two studies will be the basis for similar environmental assess" ments of other nuclear power plants so that we recommend that NRC refer to EPA's original technical comments on these studies. The comments are included in the publication "Reactor Safety Study (VASE-1400): A Review of the Final Reportig and a letter from EPA's Office of Federal Activities to NRC dated February 8p 1977.

The Table 6.1.4-4 (p. 6-26) should correspond on a one-to-one basis with the accident sequence or sequence groups of Table 6.1.4-2 (p. 6-23). The notations relating to this Table (6.1.4-2) and described in Appendix 8 needs clarification.

PN( )

The uninitiated reading this, we believe would be very confused.

The discussion of impacts of infrequent accidents and limiting faults, in both the original DES and the Supplement, addresses probabilities of occurrence qualitatively. Zn the discussion, however, of the more severe core melt acci-dents, the probabilities of occurrence are quantified (Table 6.1.4-2). For 6Plt uniformity in the presentation of all environmental risks, the probabilities of occurrence of infrequent accidents and limiting faults Design Basis Accidents should be provided.

Zt is not clear whether the risks listed in Table 6.1.4-3, Annual ~Ayers e Values of Environmental Risks Due to Accidents, include those from infrequent accidents gy 060-O

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s and limiting faults (Table 6.1.4-1), postulated accidents (Table 6.2 of the original Draft Environmental Impact Statement), and accidents leading to the sequence groups listed in Table 6.1.4-2. The Final Environmental Impact State-ment should include all risks from moderate frequency accidents, infrequent accidents, igniting faults aad seoere core melt accidents. The risk od the infrequent accidents, and limiting faults is "fudged to be extremely small" ~pp (~)

but should be fully presented and not overshadowed by the risks from 'core melt accidents. The risks from the more probable yet lower consequence accidents may indeed be significant to the individual risk and should be listed. It would also be informative to extend Figures 6.1.4-3 and 6.1.4-5 to include higher probability accidents.

It would also be helpful to develop a summary table of the annual average value of the environmental risks from operation of all the reactors at the Susque-hanna sit a Th.e risks should include those from normal operations, moderate PPP frequency accidents, infrequent accidents, limiting faults and severe core (Q) melt accidents; societal and individual risks should also be addressed.

The Three ?file. Islan&2 accilent demonstrated 'a factor that sho'uld be addressed.

The cost of reactor building decontamination and the replacement power economics have proved to be very sizeable items. 'hese factors aie significant and important to the benefit-cast analysis. These faces underscore the need to SPA C~+

develop standard methods for estimating the contribution of these costs to economic risks. Impact Statements or Supplements should include these economics in their benefit-cost balance.

We would classify this document in EPA's Reporting Category ER-2. This means we have re'servations concerning the manner in which the accidents are treated and we also believe additional clarification is required.

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We'hank you Eor the opportunity to review the document and await the issuance of the final.

Sincerely yours, eP ohn R. Pomponio Chief

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EIS & Wetlands Review Section