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Yf 1 Resources Building .                     GEORGE DEUKMEJIAN                     Air Resources Corre
Yf 1 Resources Building.
          ^
GEORGE DEUKMEJIAN Air Resources Corre 1 16 Ninth Street GOVERNOR OF C8'"o'aia Cmtti Commission
    *^        1 16 Ninth Street                         GOVERNOR OF                         C8'"o'aia Cmtti Commission California Conservation Corps 95814                                CALIFORNIA                         Coiarado River soard Energy Resources Conservation and oeveiopment Consniission (916)445-5656                                                               Regional Water Quality Control Boards Department of Conservation                             sh                               San Francisco say Conservation and Development Commission
*^
  , Department of Fish and Game .
^
Department of Forestry                                                                   $'d,,*','',*
California Conservation Corps CALIFORNIA Coiarado River soard 95814 Energy Resources Conservation and oeveiopment Consniission (916)445-5656 Regional Water Quality Control Boards Department of Conservation sh San Francisco say Conservation and Development Commission
                                                                                                    , ,      n r cy Department of Boating and Waterways                                                     state Lands Commission Department cf Parks and Recreation                                                      5'''' "*c'***'' n soaro THE RESOURCES AGENCY OF CALIFORNIA                                 "
, Department of Fish and Game.
Department of Water Resources SACRAMENTO, CALIFORNIA                   e'Nr                           ,
Department of Forestry
Mr. John H. Zwolinski                                           January 4, 1985
$'d *','',*
              -U. S. Nuclear Regulatory Commission Washington, D. C. 20555-
n r cy Department of Boating and Waterways state Lands Commission 5'''' "*c'***'' n soaro Department cf Parks and Recreation THE RESOURCES AGENCY OF CALIFORNIA SACRAMENTO, CALIFORNIA e'Nr Department of Water Resources Mr. John H. Zwolinski January 4, 1985
-U. S. Nuclear Regulatory Commission Washington, D. C. 20555-


==Dear Mr. Zwolinski:==
==Dear Mr. Zwolinski:==
The State previously commented on the environmental report "For the De-commissioning of Humboldt Bay Power Plant Unit No.
3", dated July 1984, which had been submitted to the Office of Planning and Research. The only commenting agency was the California Coastal Commission.
By letter of December 21, 1984, the North Coast Region of the California
~
Regional Water Quality Control Board submitted comments to the State Clearinghouse of the Office of Planning and Research. Inadvertently there was a delay in receipt of those comments. A copy is attached for your information and consideration. It is hoped that these additional comments will be useful in your evaluation of this proposal.
Sincerely, c'M ordon F. Snow, Ph.D Assistant Secretary for Resources Attachment cc: Office of Planning and Research (SCH.#84112723) 0 956 Agd#
e.o m oa.2 esoio.
,,g PDR ADOCK 05000133 p
PM j


The State previously commented on the environmental report "For the De-commissioning of Humboldt Bay Power Plant Unit No. 3", dated July 1984, which had been submitted to the Office of Planning and Research. The only commenting agency was the California Coastal Commission.
9f ATE OF CALIFORNI A GEORGE DEUKMEJtAN, Goremor CAL!FORNIA REGIONAL WATER QUALITY CONTROL BOARD-NORTH C0AST REGION 1000 CODDINGTOWN CENTER SANTA ROSA,CALIFORNI A 95401 Phone: 707-576-222o December 21, 1984 l
                                ~
';.01 W
By letter of December 21, 1984, the North Coast Region of the California Regional Water Quality Control Board submitted comments to the State Clearinghouse of the Office of Planning and Research. Inadvertently there was a delay in receipt of those comments. A copy is attached for your information and consideration. It is hoped that these additional comments will be useful in your evaluation of this proposal.
J t
Sincerely, c'M ordon F. Snow, Ph.D Assistant Secretary for Resources Attachment                                                                                    <
OEC 2 61984 '-
cc: Office of Planning and Research (SCH.#84112723) e.o m oa.2 esoio.
State Clearinghouse 1400 Tenth Street State C108FIDgh011st Sacramento, CA 95814 Attention Price Walker Gentlemen:
                                                              .-            0 ,,g956 Agd#
PDR ADOCK 05000133 p              PM j
 
GEORGE DEUKMEJtAN, Goremor 9f ATE OF CALIFORNI A CAL!FORNIA REGIONAL WATER QUALITY CONTROL BOARD-                                                             .-. '
NORTH C0AST REGION 1000 CODDINGTOWN CENTER SANTA ROSA,CALIFORNI A 95401 Phone: 707-576-222o December 21, 1984                                                                   '
                                                                                            ';.01 l
t       W              J State Clearinghouse                                          ,'      OEC 2 61984 '-
1400 Tenth Street                                             State C108FIDgh011st Sacramento, CA 95814 Attention Price Walker Gentlemen:


==Subject:==
==Subject:==
Pacific Gas & Electric Company, Humboldt Bay Power Plant, SCH #EK112723 We reviewed the subject environmental report for water quality related impacts that may result from decommissioning of the Humboldt Bay Power Plant (HBPP) Unit #3 (nuclear unit). He proposed decommissioning involves placing Unit #3 in a condition of safe storage for 30 years followed by decontamination, dismantling, and removal. Before correnting on the proposed decommissioning project, we believe it important to describe the Regional Board's involvement to date with the HBPP.
Pacific Gas & Electric Company, Humboldt Bay Power Plant, SCH #EK112723 We reviewed the subject environmental report for water quality related impacts that may result from decommissioning of the Humboldt Bay Power Plant (HBPP) Unit #3 (nuclear unit).
BACKGROUND Re Regional Board, as well as other State and Federal agencies, has been concerned with water quality impacts from all of the units in the HBPP facility. Although Unit #3 has not been in operation since 1976, wastewater continues to be discharged as a result of chemicals and wastewaters associated with Unit #3. Rese wastewater discharges will continue through the safe storage period.           All existing discharges are regulated as follows:
He proposed decommissioning involves placing Unit #3 in a condition of safe storage for 30 years followed by decontamination, dismantling, and removal. Before correnting on the proposed decommissioning project, we believe it important to describe the Regional Board's involvement to date with the HBPP.
BACKGROUND Re Regional Board, as well as other State and Federal agencies, has been concerned with water quality impacts from all of the units in the HBPP facility. Although Unit #3 has not been in operation since 1976, wastewater continues to be discharged as a result of chemicals and wastewaters associated with Unit #3. Rese wastewater discharges will continue through the safe storage period.
All existing discharges are regulated as follows:
Surface Water (Point Source Discharges). The Regional Board adopted Waste Discharge Requirements Order No. 82-85 on July 22, 1982. H e Order also serves as a Federal NPDES Permit No. CA0005622 and is effective for a five year period. See Section 5.0 of the Environmental Impact Repcrt for a summary of discharge ilmits. The Order implements water quality objectives set forth in the State Water Quality Control Plan for the North Coastal Basin and EPA effluent limitation guidelines promulgated pursuant to the Federal Water Pollution Control Act of 1972.
Surface Water (Point Source Discharges). The Regional Board adopted Waste Discharge Requirements Order No. 82-85 on July 22, 1982. H e Order also serves as a Federal NPDES Permit No. CA0005622 and is effective for a five year period. See Section 5.0 of the Environmental Impact Repcrt for a summary of discharge ilmits. The Order implements water quality objectives set forth in the State Water Quality Control Plan for the North Coastal Basin and EPA effluent limitation guidelines promulgated pursuant to the Federal Water Pollution Control Act of 1972.
Permitted discharges primarily are non-contact cooling water and rainfall runoff.
Permitted discharges primarily are non-contact cooling water and rainfall runoff.
Line 51: Line 55:
Discharges from Unit #3 are laundry wastewater and liquid low level radioactive waste comprised of treated, filtered, and stored liquids from Unit #3 only.
Discharges from Unit #3 are laundry wastewater and liquid low level radioactive waste comprised of treated, filtered, and stored liquids from Unit #3 only.
Groundwater (Non-Point Source Discharges). These are discharges that would occur as a result of spills or leaks from drummed chemicals, sumps, tanks, plumbing, surface impoundments or other containers. Discharges of this nature are not permitted.
Groundwater (Non-Point Source Discharges). These are discharges that would occur as a result of spills or leaks from drummed chemicals, sumps, tanks, plumbing, surface impoundments or other containers. Discharges of this nature are not permitted.
  --s--i
--s--i


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    ,f' Stat'e Clearinghouse                                                             -
,f' Stat'e Clearinghouse Page 2 December 21, 1984 l
Page 2 December 21, 1984 l
Storage,-treatment, and handling of drumed hazardous wastes are regulated by Hazardous Waste Facility Permit No. CAT 080011562 issued by the State Department of Health Services in November, 1983. The permit will be considered for amendment in 1985 to include surface impoundments (currently regulated by Interim Status Document j
Storage,-treatment, and handling of drumed hazardous wastes are regulated by                 ,
No. CAT 080011562 dated April 6, 1981) and any other containerized wastes which are
Hazardous Waste Facility Permit No. CAT 080011562 issued by the State Department of l
' defined as hazardous. 'Ihis may include chromated waters and other chemicals that are used or -stored in Unit #3.
Health Services in November, 1983. The permit will be considered for amendment in 1985 to include surface impoundments (currently regulated by Interim Status Document         j No. CAT 080011562 dated April 6, 1981) and any other containerized wastes which are
When adopting or amending hazardous waste facility permits, the Department of Health Services consults the Regional Board and EPA to
                  ' defined as hazardous. 'Ihis may include chromated waters and other chemicals that are
{
  ,                used or -stored in Unit #3.           When adopting or amending hazardous waste facility   ,
permits, the Department of Health Services consults the Regional Board and EPA to           {
satisfy their concerns over potential groundwater contamination.
satisfy their concerns over potential groundwater contamination.
Radioactive Wastes.         Radioactive waste discharges are regulated by the Nuclear Regulatory Cmmission pursuant to provisions of the Atomic Energy Act.                   In California, the State Department of Health Services regulates radioactive waste discharges pursuant to California Administrative Code provisions. Waste Discharge Requirements Order No. 82-85, adopted by the Re81 onal Board, requires that all wastewater       discharges   be   in   conformance   with California Radiation Control Regulations.       Some of the wastes within Unit #3 contain both radioactive and chemical contaminants (such as the chromated pool water); therefore, they would be subject to       ,
Radioactive Wastes.
regulation by a Hazardous Waste Facility Permit and/or Waste Discharge Requirements.
Radioactive waste discharges are regulated by the Nuclear Regulatory Cmmission pursuant to provisions of the Atomic Energy Act.
In California, the State Department of Health Services regulates radioactive waste discharges pursuant to California Administrative Code provisions. Waste Discharge Re8 onal Board, requires that all Requirements Order No. 82-85, adopted by the 1
wastewater discharges be in conformance with California Radiation Control Regulations.
Some of the wastes within Unit #3 contain both radioactive and chemical contaminants (such as the chromated pool water); therefore, they would be subject to regulation by a Hazardous Waste Facility Permit and/or Waste Discharge Requirements.
In sumary, the Regional Board is concerned with potential water quality effects from wastewater discharges and from stored, containerized substances. The Regional Board does not regulate radioactive wastes directly; however, it may regulate radioactive waste streams which could affect water quality with contaminants other than radionuclides.
In sumary, the Regional Board is concerned with potential water quality effects from wastewater discharges and from stored, containerized substances. The Regional Board does not regulate radioactive wastes directly; however, it may regulate radioactive waste streams which could affect water quality with contaminants other than radionuclides.
EIR 00MMEXIS After reviewing ~ the environmental document, we find that it focuses only on the radiological effects of the decomissioning proposal.               Other than reciting Waste
EIR 00MMEXIS After reviewing ~ the environmental document, we find that it focuses only on the radiological effects of the decomissioning proposal.
            . Discharge Requirecents Order No. 82-85 and the results of one stormwater sampling for heavy metals, it does not provide any details relating to water quality effects from other pollutants.         Additional information which must be provided to allow adequate assessment of water quality impacts is:
Other than reciting Waste
: 1. Complete description of chemicals and wastes used and stored in Unit #3.
. Discharge Requirecents Order No. 82-85 and the results of one stormwater sampling for heavy metals, it does not provide any details relating to water quality effects from other pollutants.
: 2. Geotechnical data defining groundwater occurrence, quality, and gradient.
Additional information which must be provided to allow adequate assessment of water quality impacts is:
                  '3. Geotechnical data defining underlying soil types, thicknesses and planes.
1.
4     Types and locations of leak detectors and groundwater monitoring systems.
Complete description of chemicals and wastes used and stored in Unit #3.
i
2.
: 4. Extent of groundwater degradation from spills and leaks to date and potential for cleanup.
Geotechnical data defining groundwater occurrence, quality, and gradient.
'3.
Geotechnical data defining underlying soil types, thicknesses and planes.
4 Types and locations of leak detectors and groundwater monitoring systems.
i 4.
Extent of groundwater degradation from spills and leaks to date and potential for cleanup.
Specific portions of the environmental document that need further description or
Specific portions of the environmental document that need further description or
              'information are:
'information are:
L.   .-
L.


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?                              Page 3; .x                                                                           ,            ,
_?
s          - Devember 21,'1984:
Page 3;.x s
- Devember 21,'1984:
4
4
        + -
+ -
Page 1-1;       . Imakage- of the Spent Fuel Pool was detected and there is a small amount of soil._ contamination. Radioactive' isotopes outside the liner' suggest a very slow migration Jof ' radionuclides from the Pool.- See also Page 4-65. Groundwater and soil contamination
Page 1-1;
                            ~s hould be defined both in areal extent and amount of degradation for chemical and organic e
. Imakage-of the Spent Fuel Pool was detected and there is a small amount of soil._ contamination. Radioactive' isotopes outside the liner' suggest a very slow migration Jof ' radionuclides from the Pool.- See also Page 4-65. Groundwater and soil contamination
contaminants.         This infomation also should address the soil and sediment contamination
~ hould be defined both in areal extent and amount of degradation for chemical and organic s
_            mentioned on Page 1-3(8).
contaminants.
Dage 1-3(10).           A- monitoring system will be- provided on-site and off-site to detect
This infomation also should address the soil and sediment contamination e
                              . increased .nuclide levels _ during the _decomissioning : period.         Monitoring and leak detecticn' systems also should be. provided to detect leaks where chemical and organi::
mentioned on Page 1-3(8).
Dage 1-3(10).
A-monitoring system will be-provided on-site and off-site to detect
. increased.nuclide levels _ during the _decomissioning : period.
Monitoring and leak detecticn' systems also should be. provided to detect leaks where chemical and organi::
substances are stor d or used.
substances are stor d or used.
g Water is pumped from the Pool wall / liner gap and the " blotter" (a french
g LPage 4-54 Water is pumped from the Pool wall / liner gap and the " blotter" (a french
                                          ~
~
LPage 4-54 drain under the Pool). Samples are analyzed for radionuclide concentrations and found to t                            be'-in . compliance ,with respective release limits. No analysis is provided for chemical
drain under the Pool). Samples are analyzed for radionuclide concentrations and found to be'-in. compliance,with respective release limits. No analysis is provided for chemical t
                            - and-' organic substances. .. It also should be noted that no release of hazardous materials is permitted. Treatment and disposal of~the pumpage is not addressed.
- and-' organic substances... It also should be noted that no release of hazardous materials is permitted. Treatment and disposal of~the pumpage is not addressed.
Page   4-63.. SecEion.4.2.3.2.1L is entitled " Chemicals and Hazardous Materials" and
Page 4-63..
                              ' describes - only four materials 1.in this l category which are utilized at' HBPP. It further-states .that only residual chromates will remain in Unit'#3 in the Suppression Chamber and in the Closed . Cooling 1 Water System, inferring that no other-chemical contaminants will remain.-     This section overlooks additional potential heavy metal contaminants mentioned on1PageL5-6:and 4-69..and' chemical wastes' described in the Hazardous Waste Facility
SecEion.4.2.3.2.1L is entitled " Chemicals and Hazardous Materials" and
                        - Permit.           All~ chemicals 'and hazardous wastes should be described along with respective-
' describes - only four materials 1.in this l category which are utilized at' HBPP. It further-states.that only residual chromates will remain in Unit'#3 in the Suppression Chamber and in the Closed. Cooling 1 Water System, inferring that no other-chemical contaminants will remain.-
                                                          ~
This section overlooks additional potential heavy metal contaminants mentioned 1PageL5-6:and 4-69..and' chemical wastes' described in the Hazardous Waste Facility on
handling and storage procedures.-
- Permit.
                            .Page' 4-65 and' 4-69.:           Groundwater. contamination is measured'and evaluated in terms of--
All~ chemicals 'and hazardous wastes should be described along with respective-handling and storage procedures.-
radionuclides.-       Other chemical constituents 'should: be measured and evaluated. If chemical contamination is discovered, what cleanup activities would be approiote?
~
                                                                                            ~
.Page' 4-65 and' 4-69.:
                              ~ Section - 6.3._     -Implications of Accidents During SAES10R. l A11' implications are described in terms of radionuclides. ~ Consequences involving chemicale also should be considered.
Groundwater. contamination is measured'and evaluated in terms of--
radionuclides.-
Other chemical constituents 'should: be measured and evaluated. If chemical contamination is discovered, what cleanup activities would be approiote?
~
~ Section - 6.3._
-Implications of Accidents During SAES10R. l A11' implications are described in terms of radionuclides. ~ Consequences involving chemicale also should be considered.
Fection 10.1'. 2. 2. 2. RContains a description of waste collection, treatment, and disposal
Fection 10.1'. 2. 2. 2. RContains a description of waste collection, treatment, and disposal
                              ; systems.; It should describe types'of wastes including chemical compositions.
; systems.; It should describe types'of wastes including chemical compositions.
                                                                                      ~
-Section 10.3.. Contains geologic and hydrologic information but..is primarily an overview
                              -Section 10.3. . Contains geologic and hydrologic information but..is primarily an overview
~
                              .of _ the o Humboldt- Bay. vicinity and'needs to be more site specific. ; Groundwater quality .
.of _ the o Humboldt-Bay. vicinity and'needs to be more site specific. ; Groundwater quality.
should : be_ characterized with respect' to on-site substances .that.- may cause adverse
should : be_ characterized with respect' to on-site substances.that.- may cause adverse
                        ''-effect.           Potential' plume.of pollutants should.be predicted so that detection monitoring stations can be installed.
''-effect.
[Section '10. 5. _ Draining and flushing may be performed to remove residual chemicals for SARSTOR; :and various chemical decontamination agents will be utilizea during' delayed.
Potential' plume.of pollutants should.be predicted so that detection monitoring stations can be installed.
DE00N.-     Proposed treatment,',. handling, and disposal methods should be described for the wastewaters ~~that will . be ' generated. ' Table 7.2' states that 20 million gallons of DE00N
[Section
'10. 5. _
Draining and flushing may be performed to remove residual chemicals for SARSTOR; :and various chemical decontamination agents will be utilizea during' delayed.
DE00N.-
Proposed treatment,',. handling, and disposal methods should be described for the wastewaters ~~that will. be ' generated. ' Table 7.2' states that 20 million gallons of DE00N
: wastewater will be generated over a four year period. Be advised that the existing NPDES permit - does not. allow; discharge of such vastewaters. Furthernure, the State Bays and l Estuaries. Policy l prohibits such discharges into Humboldt Bay or its tributaries.
: wastewater will be generated over a four year period. Be advised that the existing NPDES permit - does not. allow; discharge of such vastewaters. Furthernure, the State Bays and l Estuaries. Policy l prohibits such discharges into Humboldt Bay or its tributaries.
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              .            State Clearinghouse M. _ l         -
State Clearinghouse M. _ l Page 4~ _
:- Page 4~ _                                                                          _
l December 21, 1984.
l December 21, 1984.
s d
s d
Delayed DB00N.-     'Ihe decontamination, dismantling and removal of Unit #3 is proposed to take place -after. 30 years -of safe storaga. - (x e _ of the reasons for delaying the
Delayed DB00N.-
                        -decontamination process is the lack of a repository for radioactive wastes. Since leaks and spills at Unit #3 probably will continue during the next 30 years as they have in the past J12 -years,.we recommend that DE00N be completed as soon as a radioactive waste
'Ihe decontamination, dismantling and removal of Unit #3 is proposed to take place -after. 30 years -of safe storaga.
                                                  ~
- (x e _ of the reasons for delaying the
repository. is availabic.-. 'Ihis timely action.would minimize unnecessary water quality degradation in the vicinity of.the HBPP.
-decontamination process is the lack of a repository for radioactive wastes. Since leaks and spills at Unit #3 probably will continue during the next 30 years as they have in the past J12 -years,.we recommend that DE00N be completed as soon as a radioactive waste
Sincerely, A     .
~
repository. is availabic.-.
'Ihis timely action.would minimize unnecessary water quality degradation in the vicinity of.the HBPP.
Sincerely, A
Jota R. Hannum Senior Water Resources Control Engineer TBD:jmg--
Jota R. Hannum Senior Water Resources Control Engineer TBD:jmg--
cc: State.Boara, Attn Walt Pettit
cc: State.Boara, Attn Walt Pettit
                                  -Gary Grimm
-Gary Grimm Department of Health Services, HWMB, Berkeley Department of Health Services, Radiological Health, Berkeley -
                      .            Department of Health Services, HWMB, Berkeley Department of Health Services, Radiological Health, Berkeley -
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Latest revision as of 16:40, 11 December 2024

Forwards State of CA Regional Water QC Board 841221 Comments on Environ Rept for Decommissioning of Humboldt Bay Power Plant Unit 3,for Use in Evaluating Proposal
ML20140E681
Person / Time
Site: Humboldt Bay
Issue date: 01/04/1985
From: Snow G
CALIFORNIA, STATE OF
To: Zwolinski J
NRC
References
NUDOCS 8501110352
Download: ML20140E681 (5)
v • d • e


Text

-

Yf 1 Resources Building.

GEORGE DEUKMEJIAN Air Resources Corre 1 16 Ninth Street GOVERNOR OF C8'"o'aia Cmtti Commission

  • ^

^

California Conservation Corps CALIFORNIA Coiarado River soard 95814 Energy Resources Conservation and oeveiopment Consniission (916)445-5656 Regional Water Quality Control Boards Department of Conservation sh San Francisco say Conservation and Development Commission

, Department of Fish and Game.

Department of Forestry

$'d *',,*

n r cy Department of Boating and Waterways state Lands Commission 5'' "*c'*** n soaro Department cf Parks and Recreation THE RESOURCES AGENCY OF CALIFORNIA SACRAMENTO, CALIFORNIA e'Nr Department of Water Resources Mr. John H. Zwolinski January 4, 1985

-U. S. Nuclear Regulatory Commission Washington, D. C. 20555-

Dear Mr. Zwolinski:

The State previously commented on the environmental report "For the De-commissioning of Humboldt Bay Power Plant Unit No.

3", dated July 1984, which had been submitted to the Office of Planning and Research. The only commenting agency was the California Coastal Commission.

By letter of December 21, 1984, the North Coast Region of the California

~

Regional Water Quality Control Board submitted comments to the State Clearinghouse of the Office of Planning and Research. Inadvertently there was a delay in receipt of those comments. A copy is attached for your information and consideration. It is hoped that these additional comments will be useful in your evaluation of this proposal.

Sincerely, c'M ordon F. Snow, Ph.D Assistant Secretary for Resources Attachment cc: Office of Planning and Research (SCH.#84112723) 0 956 Agd#

e.o m oa.2 esoio.

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9f ATE OF CALIFORNI A GEORGE DEUKMEJtAN, Goremor CAL!FORNIA REGIONAL WATER QUALITY CONTROL BOARD-NORTH C0AST REGION 1000 CODDINGTOWN CENTER SANTA ROSA,CALIFORNI A 95401 Phone: 707-576-222o December 21, 1984 l

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State Clearinghouse 1400 Tenth Street State C108FIDgh011st Sacramento, CA 95814 Attention Price Walker Gentlemen:

Subject:

Pacific Gas & Electric Company, Humboldt Bay Power Plant, SCH #EK112723 We reviewed the subject environmental report for water quality related impacts that may result from decommissioning of the Humboldt Bay Power Plant (HBPP) Unit #3 (nuclear unit).

He proposed decommissioning involves placing Unit #3 in a condition of safe storage for 30 years followed by decontamination, dismantling, and removal. Before correnting on the proposed decommissioning project, we believe it important to describe the Regional Board's involvement to date with the HBPP.

BACKGROUND Re Regional Board, as well as other State and Federal agencies, has been concerned with water quality impacts from all of the units in the HBPP facility. Although Unit #3 has not been in operation since 1976, wastewater continues to be discharged as a result of chemicals and wastewaters associated with Unit #3. Rese wastewater discharges will continue through the safe storage period.

All existing discharges are regulated as follows:

Surface Water (Point Source Discharges). The Regional Board adopted Waste Discharge Requirements Order No. 82-85 on July 22, 1982. H e Order also serves as a Federal NPDES Permit No. CA0005622 and is effective for a five year period. See Section 5.0 of the Environmental Impact Repcrt for a summary of discharge ilmits. The Order implements water quality objectives set forth in the State Water Quality Control Plan for the North Coastal Basin and EPA effluent limitation guidelines promulgated pursuant to the Federal Water Pollution Control Act of 1972.

Permitted discharges primarily are non-contact cooling water and rainfall runoff.

Discharges from Units #1 and #2 that contain pollutants are boiler blowdown, evaporator blowdown, boiler cleaning water, and miscellaneous low volume wastes.

Discharges from Unit #3 are laundry wastewater and liquid low level radioactive waste comprised of treated, filtered, and stored liquids from Unit #3 only.

Groundwater (Non-Point Source Discharges). These are discharges that would occur as a result of spills or leaks from drummed chemicals, sumps, tanks, plumbing, surface impoundments or other containers. Discharges of this nature are not permitted.

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,f' Stat'e Clearinghouse Page 2 December 21, 1984 l

Storage,-treatment, and handling of drumed hazardous wastes are regulated by Hazardous Waste Facility Permit No. CAT 080011562 issued by the State Department of Health Services in November, 1983. The permit will be considered for amendment in 1985 to include surface impoundments (currently regulated by Interim Status Document j

No. CAT 080011562 dated April 6, 1981) and any other containerized wastes which are

' defined as hazardous. 'Ihis may include chromated waters and other chemicals that are used or -stored in Unit #3.

When adopting or amending hazardous waste facility permits, the Department of Health Services consults the Regional Board and EPA to

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satisfy their concerns over potential groundwater contamination.

Radioactive Wastes.

Radioactive waste discharges are regulated by the Nuclear Regulatory Cmmission pursuant to provisions of the Atomic Energy Act.

In California, the State Department of Health Services regulates radioactive waste discharges pursuant to California Administrative Code provisions. Waste Discharge Re8 onal Board, requires that all Requirements Order No. 82-85, adopted by the 1

wastewater discharges be in conformance with California Radiation Control Regulations.

Some of the wastes within Unit #3 contain both radioactive and chemical contaminants (such as the chromated pool water); therefore, they would be subject to regulation by a Hazardous Waste Facility Permit and/or Waste Discharge Requirements.

In sumary, the Regional Board is concerned with potential water quality effects from wastewater discharges and from stored, containerized substances. The Regional Board does not regulate radioactive wastes directly; however, it may regulate radioactive waste streams which could affect water quality with contaminants other than radionuclides.

EIR 00MMEXIS After reviewing ~ the environmental document, we find that it focuses only on the radiological effects of the decomissioning proposal.

Other than reciting Waste

. Discharge Requirecents Order No. 82-85 and the results of one stormwater sampling for heavy metals, it does not provide any details relating to water quality effects from other pollutants.

Additional information which must be provided to allow adequate assessment of water quality impacts is:

1.

Complete description of chemicals and wastes used and stored in Unit #3.

2.

Geotechnical data defining groundwater occurrence, quality, and gradient.

'3.

Geotechnical data defining underlying soil types, thicknesses and planes.

4 Types and locations of leak detectors and groundwater monitoring systems.

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Extent of groundwater degradation from spills and leaks to date and potential for cleanup.

Specific portions of the environmental document that need further description or

'information are:

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Page 3;.x s

- Devember 21,'1984:

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Page 1-1;

. Imakage-of the Spent Fuel Pool was detected and there is a small amount of soil._ contamination. Radioactive' isotopes outside the liner' suggest a very slow migration Jof ' radionuclides from the Pool.- See also Page 4-65. Groundwater and soil contamination

~ hould be defined both in areal extent and amount of degradation for chemical and organic s

contaminants.

This infomation also should address the soil and sediment contamination e

mentioned on Page 1-3(8).

Dage 1-3(10).

A-monitoring system will be-provided on-site and off-site to detect

. increased.nuclide levels _ during the _decomissioning : period.

Monitoring and leak detecticn' systems also should be. provided to detect leaks where chemical and organi::

substances are stor d or used.

g LPage 4-54 Water is pumped from the Pool wall / liner gap and the " blotter" (a french

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drain under the Pool). Samples are analyzed for radionuclide concentrations and found to be'-in. compliance,with respective release limits. No analysis is provided for chemical t

- and-' organic substances... It also should be noted that no release of hazardous materials is permitted. Treatment and disposal of~the pumpage is not addressed.

Page 4-63..

SecEion.4.2.3.2.1L is entitled " Chemicals and Hazardous Materials" and

' describes - only four materials 1.in this l category which are utilized at' HBPP. It further-states.that only residual chromates will remain in Unit'#3 in the Suppression Chamber and in the Closed. Cooling 1 Water System, inferring that no other-chemical contaminants will remain.-

This section overlooks additional potential heavy metal contaminants mentioned 1PageL5-6:and 4-69..and' chemical wastes' described in the Hazardous Waste Facility on

- Permit.

All~ chemicals 'and hazardous wastes should be described along with respective-handling and storage procedures.-

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.Page' 4-65 and' 4-69.:

Groundwater. contamination is measured'and evaluated in terms of--

radionuclides.-

Other chemical constituents 'should: be measured and evaluated. If chemical contamination is discovered, what cleanup activities would be approiote?

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~ Section - 6.3._

-Implications of Accidents During SAES10R. l A11' implications are described in terms of radionuclides. ~ Consequences involving chemicale also should be considered.

Fection 10.1'. 2. 2. 2. RContains a description of waste collection, treatment, and disposal

systems.; It should describe types'of wastes including chemical compositions.

-Section 10.3.. Contains geologic and hydrologic information but..is primarily an overview

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.of _ the o Humboldt-Bay. vicinity and'needs to be more site specific. ; Groundwater quality.

should : be_ characterized with respect' to on-site substances.that.- may cause adverse

-effect.

Potential' plume.of pollutants should.be predicted so that detection monitoring stations can be installed.

[Section

'10. 5. _

Draining and flushing may be performed to remove residual chemicals for SARSTOR; :and various chemical decontamination agents will be utilizea during' delayed.

DE00N.-

Proposed treatment,',. handling, and disposal methods should be described for the wastewaters ~~that will. be ' generated. ' Table 7.2' states that 20 million gallons of DE00N

wastewater will be generated over a four year period. Be advised that the existing NPDES permit - does not. allow; discharge of such vastewaters. Furthernure, the State Bays and l Estuaries. Policy l prohibits such discharges into Humboldt Bay or its tributaries.

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State Clearinghouse M. _ l Page 4~ _

l December 21, 1984.

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Delayed DB00N.-

'Ihe decontamination, dismantling and removal of Unit #3 is proposed to take place -after. 30 years -of safe storaga.

- (x e _ of the reasons for delaying the

-decontamination process is the lack of a repository for radioactive wastes. Since leaks and spills at Unit #3 probably will continue during the next 30 years as they have in the past J12 -years,.we recommend that DE00N be completed as soon as a radioactive waste

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repository. is availabic.-.

'Ihis timely action.would minimize unnecessary water quality degradation in the vicinity of.the HBPP.

Sincerely, A

Jota R. Hannum Senior Water Resources Control Engineer TBD:jmg--

cc: State.Boara, Attn Walt Pettit

-Gary Grimm Department of Health Services, HWMB, Berkeley Department of Health Services, Radiological Health, Berkeley -

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