ML17275B251

Comments on Des Re Operation of Facility.Document Should Discuss Requirements for Operator Certification,Const Record,Reasons for NRC Work Stoppages & Evidence That Reasons for Const Halts Have Been Rectified

ML17275B251
Person / Time
Site:	Columbia
Issue date:	09/21/1981
From:	Corbyn E ENVIRONMENTAL PROTECTION AGENCY
To:	Office of Nuclear Reactor Regulation
References
MS-443, NUDOCS 8109240412
Download: ML17275B251 (4)

Text

REGUL > URY INFORMATION DISTRIBUT SYSTEM (RIDS)

ACCESSIONi N8R:8109240412'OC ~ DATEIi 81/09/2'J NOTARIZED: NO DOCKET FACIL~:50-397 HPPSS Nuclear Project~ Unit~ Washington Public Powe 05090397 AUTH~,NAME" AUTHOR AFFILIATION CORD YiVg Et. Environmental Protection Agency

'RECIP, VAMKI RECIPIENT AFFILIATION Division of Licensing SUBJECT;: Comments on DKS re ope'ration>> of facility Document should ~

discuss requirements. for operator certificationiconst" re'cordireasons for NRC work stoppages L evidencei thati reasons for const halts have~ been rectified.

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U.S. ENV NMENTAL PROTECTION ENCY

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ATIN OFs M/S 443 cygne a> sF.P 881 Director, Division of Licensing U.S. Nuclear Regul atory Commission Washington, D. C. 20555

Dear Sir/Madame:

The Environmental Protection Agency (EPA) has reviewed the NRC's Draft Environmental Statement Related to the Operation of WPPSS Nuclear Project No. 2. In accordance with our responsibilities under Section 309 of the Clean Air Act, as amended, we have rated this EIS LO-1 (LO - Lack of Objections, 1 - Adequate Information). The basis for this r ating is discussed below.

The environmental impacts of the proposed action, based on the informa-tion provided in the FEIS-construction phase and the DEIS operation phase, indicate that the project should be capable of operating well within EPA's Environmental Radiation Protection Standards for Nuclear Power Operations and should meet all applicable water quality standards.

We believe that the quality of the EIS could be improved, however, in two ways. First, the DEIS asserts that the delays in plant construction were in response to a slowdown in growth of electricity demand during the 1970's (page 2-1). This assertion overlooks the fact that the NRC put a halt to construction on the project for two years due to poor construc-tion practices and bad record keeping. From a NEPA "full disclosure" standpoint, it would benefit the reader to have a synopsis of WPPSS construction record, reasons for NRC's work stoppages and, as assurance that an operating license is warranted, evidence that the causes for NRC's construction halts have been rectified and evidence that these construction problems will not magnify the potential environmental consequences of reactor operation.

Second, the DEIS does not discuss requirements for operator certifi-cation. This would seem to be as critical to safe and proper operation as the soundness of the reactor itself, including its various safety backup systems.

Thank you for the opportunity to review the DEIS. If you have any questions pertaining to our comments please contact Bill Riley, of my staff, at (FTS) 399-1285.

Goo C

Sincerely yours,, S i(e Elizabeth Corbyn, Chief mental Evaluation Branch 81092404i2 8i092i PDR ADOCK 05000397',~

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