ML20087J420

Comments on Des Re Operation of Facility.Cumulative Impacts on Regional Water Use Should Be More Explicitly Evaluated. Des Adequate,But Unnecessary as Decisionmaking Tool

ML20087J420
Person / Time
Site:	Satsop
Issue date:	03/13/1984
From:	Degens S AFFILIATION NOT ASSIGNED
To:	NRC
References
NUDOCS 8403220198
Download: ML20087J420 (9)

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Enclosed'issa lengthy comment on~EISfNo. 840014, J c o.ncerning ; ,

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d 'in Washingtoni.I realize my comment i's'a few' day's~over the j.' *

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E iatiPortlandfState University 7 Th,e'. c1*alis;sas lEnvironmental Impact 1 c . cm ~, a v c ... , .. .,

criti,que ,"rIfp,o 6' t'o .'some ' of. the:'  :-

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Ci?TPInUE OF Ati ":Ili PRH1 '.l? SD BY TilK Ul?C 18 DR A P P c;I!VIt?C Jif AL .;W't' 1i WT R::1,A Jc;h TO T:IM OPERATICII Ol' W 191;i 1:UCI, ,*.R "

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ebnstian Depenc l 4515 J : Madison i

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The proposed action which renuired the I.trpJ't LS Reinted t_o th.e Operation af t.h. e WPlfBS 11uclear Project 110 3 (DES-OL) is the issuance of nn operating license to the Unshington Public Power Gupply System (WPP33) for start-up and opern tion of its nuclonr project no. 3 (WPN- 3), located in Grays Harbor County, WA. The project consists of .a two-loop pressurised unter reactor (MIR) with n projacted electrien1 output of 1240MW A cooling tower and pumping station to draw wnter from nu nouifer below the Che-hnlis River.nre included on the 2570 nere site.

The U.G. Nuclear RePulatory Commission (URC), and its staff in the Office of nuclear Renctor Herulation jprepared the documer.t in response to an appliention for nn operatin;r license for this facility from the NRC. The projected water withdrawals as well as the radioactive emissions by the facility clently mnhe this n Pederal action significnntly n f recting the nunlity of the human environment (01502 3). The statutory requirements for an dId nre met.

WPU-3 was 79.1 comnlete.nt t.he time of appliention for *;he operating license. Construction delnya since thnt time have punhad the anticipated fuel-loading date into 1987-1989. TN storf noted that this DES could therefore be issued up to six years prior to the fuel londing date. This constituten rn unusually early incunnce. It was the staff's judgement that the facility's operationn1 charncteristics were sufficiently known to 01/o u the present assessment. (WUP-3 DEU, 1-2).

The DE3 is dated December 1983. The Motice of Avnilability

(NOA) was publi~hed by the Environmental Protection Agency in the Federal Reciater on Fridny, Jonunry 27,1984 (FR; Vol 49. Do 19).

A 45 day connent period was scheduled ending on March 12. A copy of tFio critique has been submitted.

NRC licensing procedures for nuclear power plants are sep-orated into distinct phases. The NRC hns tiered their environmental statements to correspond with the construction and operating stages. This ennbles "... focus on the nctu,1 innues ripe for decision nt each level of environmental review." (N1502.20)

The purpose of the DES-OL in to center on incues specifically related to the operntional system of the nuclear plant. An ad '

ditional purpose emerges in the text. The DE3-OL evaluates design chon es in the project which hnve occured since the time of the Final Environnental Utatement on the construction permit (FES-CP).

The bulk of the design vnd environmentnl impnct information is contained in the FES-CP wri ten in 1975. This infornation is summarized in the DES text nnd encorpornted by reference.

Tiering hns n number of importnnt inplicntions fot* the DhS.

First, it is physically shortened by the ability to reference the document in tbo previous stage in the process. More importantly, the range of isnues covered is also reduced. The URC has interpreted tiering to obviate evaluations of the need-for -power issues during the operation-license phase. Discussion or the need-for-power issue hns occured durinr the construction permit stage and is considered resolved.

The NRC hns nasuned that nuclear power plnnts cost less to

_3 operate than fonsil fueled pinnts. The ilIC concluden that nuclear power vould be n preferred energy nource, ev3n were 7 reduction in demand to ol'iminate the need for nny ndditionnl generation.

(UPH-3 DEu, 2-1) Need for the proposed nction in eliminn ted nr nn iccue and bnrring special circumstances, the operating license in not subject to n tent of need.

The logic of the environnantla review procenc, na conducted by the ERC in the licensing o f nuclear power plants, thun eliminates a broad range of nlternntives during the OL ntnge. Both alternative energy sources as well as alternative nites are no }onger relevant.

Committed resources nnd the advnneed stage in the process have left no fensible alternatives and none nre presented in this DES.

Alternative plnnn of operntion were not connidered, thourh I feel they would have been opnroprinto for compnrison. Examplen could hnve been alternative monitorine programs for the currounding earth, water, nnd nir resources. Alco, in nddition to mitigative renponses to wnter renovnl. nt timen of low strenn flow, nn op-perationnl plan which synchronized refueling with all or pnrt of the seasonal dry periods could have been presented.

The exintinc environment was described ndenuntely in tuo DC.

Unchanged portions of the project were numenrized from previous documenta nnd referenced. A compnrative evoluntion of the impncts of alternativec could not be undertnken in the nbnence of alternat-iven. Ilowever, design ch'ngen cince the FES-CP hnd altered anny impacts. These new impncts were diccunned in n compnrative annner with the initinlly nnt'icipated ones.

The major chnnge was the enncellation of n necond unit,

4-WPPSS No. 5, which hnd been pinnted for ' hat site an well. In many respects this chnnge nfforded the DSU nuite n bit of Iceway in the dicauncion of imuncts. For examnle, WPFSU increased its es-tiente for the nulfuric acid reouirement to control scale in the circulating water system. There will be an acknowledged effluent inpact of sulfates on the Chehalis River. This increase in the concentrntion of sulfates was swept nway in the text with the recolection that the pinnned second unit had now been scrapned and the resulting ambient concentrations for one plant were lower than had previcusly been projected for two.

I feel this type of analysis in more round-about than direct.

Uhile it is important to knou that the sum of the impacts in lean thnn those previously p1nnned, if the denign changes represent significant alterations, they should be described nbsolutely (ie.

How much effluent renulta from one unit with nu increased reouire-ment of aulfuric ncid?).

r troublenome feature in the DEU was a multiple reference :;o n Gnfety Evnluntion Report (S',R) which is scheduled for release six months nfter the clonure dn'te for co"nents on the DES. In appendix form, the wnter and air effluents were summarized in an-ticipation of this report. The capability of the proposed radwaste system to accomodate the solid wasten expected during normal operations was not evnlunted nor sunnorized. This coems to me a significant omission..

The DSS covered nn extensive not of impnets both analytically and in concise and understandable language. The methodologies I

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1 were explained clearly and included in the text and apnendix.

I did not feel the impact discussions were each of the same cuality.

Direct impnets were evaluated in each of the environmental areas.

Indirect impacts were addrenned in certain of these. Cummulative inpacts were not evaluated by each of the DEG contributors. It was not clear whether those writers entertained such impacts and excluded them, or whether thov had boon irnored.

Cummulative impncts on regional water use should be more explicitly evalunted, for one. In the area of endangered specics, the theorization that beenuse of an engle's keen eyesight, collision with a cooling tower scened unlikely,seemed less important than some field datn on the effects of construction noises on the habitat ns a proxy for the anticipated noise from the pumping station.

Radiological impacts were described ver:7 well. The conclusions seemed reasonable, and arens of uncertainty and issues of public dehnte.were outlined. Tables of radintion emissions were confusing upon occaision when the Units of measurement did not cumpare (curies /rens) or when the base levels of bnckground radiation were presented for comparison in some tables and not in others.

.in evaluation of the cu: muln tive impact of the regional nuclear proeram was not included.

Hitigation mensures were developed for a range of expected environmental inpacts. The nn;iority of these were renuired in the desirn of the facility itself nnd opernted through avoidance and minimization of environmental impacts. Future mitigative mensures W

willvdevelopd h" sed on nonitoring pror rnas to detect unanticipated

m impacts. The prepnrers did n very thorough job in mntching mitign-tion measures to potential inpnets.

Two potential environnental inpnet arens which devinted from this genernlly fnetual, annlytical discussion of impacts, were those of the urnnium fuel cycle no well as the deconnissioning of the plant once its operating life is over.

Discussion of the impncts of the fuel cycle centered around theoretical design criterin incorporated by reference to optomistic A ,wahm e PRC rules and research documents.' factual experience in storage ,

reproceaning, nnd weste manngement would hnve been very useful.

Socio-economic impacts of hMP-3 should have been expnnded to include discussion of the region 91 raste management costs, decom-missioning impacts.

Finally, scenarios of three types of accidents (frequent and infrecuent events, and a nuch less prohnble limiting fault} wer very interestin nnd well exp1nined. The methodology for conduct-ing the 'clorst Unse analys.is seemed very occurnte and scientifically reliable. Mitigation meocures were proposed- to rectify and com-pensate the impncts of even the low probability / hirh risk events.

In conclusion, I would 'like to nrrue thnt the SWP-3 DN3 is adequate but not really necennary as n decision-mnking tool. An alternative to going ahead with the operntion of the facitlity was never presented. It does not provide the type of comparative evaluation INPA encourages. Also, the licensing procedures re-cuire more stringent evnluations than were contained in the DEG, (ex. Gnfty Evalua tion' Report). The document does not seem relevant to the agency decision. In many resnects, the Environmental Stntement

comes to late in the game to m9tter and simply becomes a procedural hoop.

There is a procedural contradiction with the HRC in'their implementhtion of HEPA which limits the usefulness of this doc-ument. Tbis stems from the duni role p1nyed by the DE1. Firstly, it reviews the operntional stage of project development. But at the time of the review, the plnnt was not complete, the radunste system was not fully evalunted, the finnncial state and ownership of the plant were even in quection, and there is no nn tional con-census on the manngement of high-level rndioactive wastes. This leads me to fool the operationnl review is premature.

The second purnose of thin DEM is to identify and evalunte chances in the project since the construction stage of review in 1975. It acts as n supplemental EIs, but unlike a supplemental c:IU , the URC procedures hnvqeliminated the re-ev,1untion of fundamental circumstnnces, ns -in this case, a determination of the need for a project.

If the DZG is to ant as 9 sunplement, then all altered environnental circunstanc,es should be open for review. If it is specifically concerned with the operating license stage of the progrna, environmental review should be conducted at a time when basic conditions nre known 40 CFR Parts 1500-1508 UEFA Regulations Draft Environmental Statement Related to the Operation of W1'P3S i;uclear Project Ho.3, IIUREG-1033, U.S.HRC: December,1983 Vederal Heciater, Vol 49. No 19: Janu'ry 27, 1984

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