NUREG-1033, Forwards Public Comments Re Facility Des.Reviewers Received Copies on 840326 & 28.Reviewers Should Have Sufficient Time to Review & Comment & Provide Fes Input by 840423

Forwards Public Comments Re Facility Des.Reviewers Received Copies on 840326 & 28.Reviewers Should Have Sufficient Time to Review & Comment & Provide Fes Input by 840423

ML20209C831
Person / Time
Site:	Satsop
Issue date:	03/29/1984
From:	Knighton G Office of Nuclear Reactor Regulation
To:	Ballard R Office of Nuclear Reactor Regulation
Shared Package
ML19277G459	List: NUREG-1033, Forwards Public Comments Re Facility Des.Reviewers Received Copies on 840326 & 28.Reviewers Should Have Sufficient Time to Review & Comment & Provide Fes Input by 840423
References
CON-WNP-1458, RTR-NUREG-1033 NUDOCS 8404130150
Download: ML20209C831 (1)

Text

____.

m p

)

Docket No.:

50-508 f, R 2 9 1% !

MEMORANDUM FOR:

R. Ballard, Chief, Environmental and Hydrologic Engineering Branch, DE W. Regan, Chief, Site Analysis Branch, DE W. Gamnill, Chief, Meteorology & Effluent Treatment Branch, DSI G. Hulman, Chief, Accident Evaluation Branch, DSI F. Congel, Chief, Radiological Assessment Branch, DSI FROM George W. Knighton, Chief, Licensing Branch No. 3, DL

SUBJECT:

WPPSS NUCLEAR PROJECT NO. 3 COMMENTS TO THE DRAFT ENVIRONMENTAL STATEMENT (DES)

Attached are copies of the public comments to the DES we have received. More than likely, your Branch has received copies through the distrubition systen.

However, to ensure the cognizant staff reviewers received their copies, V.

Nerses, Project Manager, hand carried them to the staff on March 26 and 28,1984 This should allow the staff sufficient time to review the comments and provide their FES input by April 23, 1984.

The responsible Branches are identified in the margins of the attached letters.

If you have any questions, please contact V. Nerses (x27238).

U.'e'l ;;! n;;;Kn!;hba red by:

C 2.g3 '.7.

George W. Knighton, Chief Licensing Branch No. 3 Division of Licensing

Attachment:

As stated Distribution cc:

R. Samworth Document Control (50-508)

D. Cleary PRC System R. Gonzoles LB#3 Reading P. Easley JLee E. Fields VNerses A. Brauner Attorney, OELD C. Hickey E. Branagan J. Levine M. Singh pt:

3#3 DL:t AVNe es/yt dWl ton 34 84 3g/84 m

8404130150 840329 g>9 '

g ADOCK OSOO g 8 1

r.

'3

}

i SERutATuPT ANF0HMATION DISTRI6UTION SYSTE9 (WIaS)

"DsA40319434a DuC.0 ATE: Aa/03/15 t!OTAFIZLC:

P. C LCCat T a Do-Sv5 <.PDSS Nucle.c Project, Unit 3, rasnincton Aunlic v5ce 50e v

aufwwa A F F IL l a T Iu'i u.

Interior, nect. or 3

• E C l r* I t'i f I. HILI TIOi, Civision of Licensinc mments on Ots.Lun;-ter* a:ecuacy of uncerorain sys storone socity shoulo ce ciscusseo.cvaluation of sys l en c-e t c.:

toeritysif used to retain conta.cinated sump seter, Coccory.

• n C00E: C00dB COPIES HECEIVED:LTR l. ENCL..

SIZE:

hic Conment un Environmental Statement Scra t zec Pl an t. FNL ley FSAR ANOTS & NON PacP -EFTS.

u500050A f-ECIPIENT COPIES AECIPIENT CCPILS C00E/Na*E LTTP ENCL 10 CODE /NA"E LTTn ENLL L83 nr ao

/

Nuo IHT La i

d ANL 1

([v l E i s A, -;p v1

^

/nOSI NRR NORn!s,J 1

/UE/AEA6 20 1

NWR/0L/EEn 16 1

/DE/EnEm 1

NRR/DE/SAs 18 1

i

/OSI/AE6 19 1

NRR/OSI/METo 15 1

/uSl/WAo 1/

1 GEG FILE On 1

3 1

3 o

i LPok 03 1

P0x 04 1

NSIC 05 3

g A;

., t 1

)

Crn,n.+

).:~

,j g(P O

n

~

)

v

.M. u.?

t %'Ml; United States Departrnent of the Interior OFFICE OF THE SECRETARY

~M WASHINGTON, D.C.

002M h

ER 84/95 MAR I ' ~ 59 I

Director, Division of Licensing l

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

Dear Sir:

/g The Department of the Interior has reviewed the draft environmental impact statement related to the operation of WPPSS Nuclear Project No. 3, Grays Harbor County, Washington and has the following comments.

8M6/3 As noted on page 5-51, the accident analysis shows that the plant's passive underdrainf' system could deliver radioactive sump water to Workman Creek in the event of a cere-I melt accident.

The effects on Workman Creek, Chehalis River, and Grays Harbor, only briefly suggested, could be severe.

The statement mentions a possible mitigation

(

measure-the sealing of the underdrain, apparently af ter an accident on page 5-52.

However, it is not clear that the sealing of the drain after the accident can be assured g

before a major radioactive release has occurred. The question arises why the underdrain i

system does not include provisions to shut cif or divert to safe storage any contaminated flow from the reactor. It would be simplar to provide for these measures before an tecident has occurred than af terward.

The proposed sealing of the underdrain outflow would retain the highly radioactive water. The statement should discuss the long-term adequacy of the storage capacity of the underdrain system and should evaluate the system's long-term integrity, if it is used t3 retain the contaminated sump water. This evaluation should consider the potential for ground-water impacts if a loss of the underdrain system's integrity should release the contaminated water to the ground-water environment. The statement should also explain how the passive underdrain system below and in the vicinity of the reactor would be protected against damage if the basemat failed.

The Reactor Safety Study (WASH-1400) includes an analysis of possible depth of p:netration of a core-soil mass; heat transfer calculations indicated that this mass would be about 50 feet high. Thus, the Class-9 accident analysis for WPPSS No. 3 should assess the integrity of the underdrain system if 50 feet of penetration should occur. A sketch cf the underdrain system should be provided in the final statement.

'Wo hope these comments will be helpful to you.

P Sincerely,

./

s'

/

a

~

/

,,g'jc. % f :

,;; ' Bruce Blanchard, Director Environmental Project Review i

10 8

L m

r

,-s

]

ih'094ATIOf. GISTHInUT!Uli 31 STEM (5:04) 4EG*L17 WRY v

r

,e

$CCESSION NcA: 8400E70362 00C.0 ATE: ?a/02/19

'Ju T A R 12:0 : r.0 v0CHET =

FACILISTa-50-593..PP35 touclewc Preaect, unit 3, v.asming*en Pu=lic 45004508 auT41.!.a..E AurHJR AFF ALIATICN

.0CnERTY,J.r.

Affiliation Unknown sECIP.SAttc r.ECIPIEh!

4.: FILIArict; i!ETTI,1 Civision of Licensing abs Jf.C T: Sucmits comments an OCS (NunEU-1933) ce acerst ion or facility. Fuel cycle incact not ccmoletely cescricec.

db ENCL ;()

SI'*Es.._. _____

UISTR!buTION CUOE: Cv049 GCPIES AECEIVEO:LTR TITLES Suolic Comment on Environmental Statement NOTES:Stancardigec Plant. PNL tcy FSAP A40TS 4 iluN 2:sCP HEPTS.

u5300508 3

RECIPIE^er COPIE3 PECIPIEa7 COPIES s

I u C 0 0 E / 3. A id E LTIA ENCL 10 C 0] E/.'. A N E LTTh dNCL GRH LS3 oC Oo 7

NRP Lc3 LA.

1 1

til: AtiL 1

VIETTI,A 01 1

iTERNAL: ELD /HOS1 1

NRW NGRRIS,J 1

1 t:28 /DE /

• E A" 1

NRR/0E/EEa

!=

t Crhek/0E/EnE52)20 i

NAP /0E/Ga6 18 1

4Rd/OSI/AEs 19 1

NR R / 03I/*4ET8 15 1

)

f4Rd/03I/ RAS 17 1

REG FILE 04 1

]

AGN5 1

,TERNAL: ACh5 o

LPOR 03 1

asC FOR 02 1

N5IC 05 1

e T ' 3 1

)

)TES:

1 I

l l

0

+

a. 'C, * *,

• f. c,

d. '. 3. la a...

~) et *t.:.l 4

.sa..

,.4..,.

.j

-*..J

. :4 2.

,a

,q.

.o.

a.

.s e.,.,e

~43.

4

- a, 481 a..

• d..:0 0 TT

• 7

.a....e.....,=.

J.. 4.s.4

.m

• 4.4.w. 3 n a 4 7,1 L.,..,,

-.m.,.,;.. 4.,., 4 o.

. aa

-....3..,

,w

....4.....,..

D.

.e. o.n c; = =,

a 3,.,.t,5=

_ r 4

,..t.

.n,,

1.1. s. 4 no

...,.7....4.,.

a

- o.

.n.,..s,

,......v.....

.u,,-,.,,.,,.,.

MID ;G-10~,5 m,, n 8..-.3,,,.

., '.1.,

...,.., +.

..,...,I.,

...v 6

s.

..a 3.= g.m.ng A. e

..g.

4. 1. 4.. 3..,.

.3

. r,

',. -.. g o....,..

k,..

2

.a r

.. e. 4 1. o. A.

.v..

.:. "E - T 7".4

.(-= 9 e.

• J i

?,,'.

f.a b...

.#91 1.O *..'in -

~s v

,'.,7 a *.. "v

(' 7. '., - <, ' ' O. c"w. S

• 5 e

w w 1 1. t u e c *.. *o a -

.9. 4..te-'.e

..o d. a. ' *' 0 0 0 M..'.a e.J..'t.. n - s 2. d... -

n 2

at an 303 ca7acit r factor for 3

7 ears wou'.i be 9 e-dicted to induca *cetueen 3 3 and 5 7 c2ncar fatalities in 100 7 ears, 3.7 and 17 in 500 years, 2nd 36 sad 50 in 1000 7=."..s as a. a. s u l,

.S.'. e '. =..". a a. s ~.#

- a d. a n. c o _o.

a

t..,. c c c..,

4. 3 n o.

r...o 1.

,. s.

A.. s c. 4 -

vs.,.a w.

a c.e.a e

w bed the fuel cycle i act in A7pendi:c C, not the i.:7se of co=..a.4. n s.'

"a *i. ant

,c k a. a n a. o. '

-le DIS should contain a sca:3 ment of:..uk. ' d..c.

..a *.. c.d.' d. 1 ' '..

d\\

%g. gn..-.. g.r.

m u 5..

a..r p.g a.

.,.1 a,,.....

4... d o. *. 4. s.e.

4... A. u a.. d j

6

.. w

• y.,

f. u g 1

a..c a..i. g 5

• 4.. a..

J '.

r,. a.he y..:0. 3c

"..o.1.,.=.

O.. a,.4. a. c. +

.o.

v

.c 3 4.

.,, 0 3 3.. C /.

r,, e - a C4 4

.. c 3,, ( a.. >

a..

.a v.

,,,....,4...

1 4., A. s g 7.,,,s

.c e.. : t

y. ')

• i*e..e g yg.= p.

m..-w 2 3 3 *.*

a.p.# o. 3.

.4...*.

4. s. *. a. =,

J

! '.' e.,. J.

9 4

i 4.S r.,

..e.'..

.,..,.s.. 2 0. 0,,.

1. J f.'

- 3.eg,7 A. 4. e.

... g '. # ~.,. %...

- *: ~. '.:

4 J

.J..

e~

e

')' #.. T 4.s J 3 4, g A.

=. 3 m. q m. 4...p

. ' q g.= * -

• *.1 e.1. 's.,

4 3 p.

. m..

J r

....u

....4,.

,. 4. A.

,a*

-3,*e.t.

.a

i. a. '.,. ;

.g a

....a-..,.

_....'......n

• i

".: 'l a. " ]3 1 *=,.* *&.,,..a.t.*.=,,*

4.,

• .. *.5. S..e,

if ".9***,

..

• i 4,..

8 "') J..,.

• *. g s

• 4. *. '.

• 4 w 3

• 4. 4...g.

.b.

.q

... a. l.' '. 4

.g 9...**'.b

"....*1.'.*.*.4

• 1. ** 4

-9. a.. * * *.4 a

!. 4... J.,., C

t....

...,.,. t

• ..3.,

..,. 4

.A a

....../.

.s

.I 7

3. m.7. g 2".*.3.*.*.

- 9. *. M.. 'I

.4

'.'a =. 9 *..t

o..* =.*

4. at.

..*.a....*w*=.=,')A.

.....4

., 4.,.,.

a..

. 4..

e3,.

.t..........,.4..,

I

_. a=4/006 340 1o

'oN ADCCX CSCCO5CG

/ w^

m J

A

~,... ;.A.

-)

=

-~

- :.-. m*~

u a

e '., e. y., g,...,S*r -.J.1 3 1,.

..C....a e..

.4.e c 4. <. 4 s

...a.,,.

.o 2 s,.

..s

.... 9 7.~ 4

.%.4. **..ar i..a.9 1. e i

e.

.l....'

~

9 e

C,.,, ",: ;.,

., % g

.. m. =, 9 g.,.,

4.. a.,.,..

t.:

f.., : 4..

. 3 g,.

4.

..(.

3..,.*...,.4....

.,. g

..)

3.,, 4.

., (,. r 4.

u..

g,a

..e.

7 4

• • 4*.

"_.2.3..... 1 =,..

4.,.g 4

4 4... m...g /.

g %..,..q.-.o...

,.3.y. 4 4..

.,.g 3p =

4

,3

.3

.e4

. a e..

..w 4

f 4.

., S d '...,, 4.

,...g e.

4. S..,

J..g.3. i.,. J..g '.

3..

c.=

443.

S.,.

.g

.'.'*..%,K,.

s.

.4 9

rt.

'A.%,,..

.S

.,4.,4...

4..s

,., 3.g s

a. r.

4. 5 4...

• .7 g

w

L.

J

., 3,

.I.

..la.

4 1.

• 4..a S =,

• 3 *. e.

• . *:. 4 c..n.A =. =.= es.. '.. ".

. 1 *. *c* ?

a==,

e.t a.a. 3 *='.a.4.,

4 4.

. h*1.e.

,%. 3 m.

6.%.

3 p 1..s e.+

g %.. 3.m.. pe.n S U.*.*.*.

3..4 6

. 4

= %.. e. a.

4. =

....-,.,,..#"f".'7 e..

4

.w 1

4 e

• %. 9

. a'

.n. '.10,2*. A

e. 3.a.

1.,... m e.. 6 4 m p.

[

4,1 o r.

%. <..g

. e. A

. m 9,.3 4,

.K

a. 9 e, w

s 2

4, NoS

+=!1.'. m. "1

?

I' ' 4.,.'. 4. S.

c'4 C,. s t. g, y., 3

....,e...8. w -, t..,.,g

.S&Se,,

ua 9.

1'

'lp 4.,9

., & w., e.,3 e. a. % O. *.,.

%. 6, a,.. y 1. e.

1 v.

4

,a 6. w..

. oa.

W

.18 r f.. r U

.J.')

44.4.3 O M.J.,. * *= 4 h y wO.,. 0 3 9 v.. =.

4 i

6 v

...w..

V l f.?

.,5,

$w e

a J

6.,

.1=.

.m g., s..A.

J g *n.e..ev y e

e, i

af i

A 3

.w.-

DEPARTMENT OF THE ARMY SEATTLE olSTRICT. CORPS oF ENGINEERS i

P.o. box C 3755

~k

,l '

SEATTLE. WASHINGTON 98124

~p

~

Planning Branch MAR 9!984 George W. Knighton, Chief Licensing Branch No. 3 Division of Licensing U.S. Nuclear Regulatory Commission Washington, D.C.

20555

Dear Mr. Knighton:

We have reviewed the draf t environmental impact statement for Washington Nuclear Project No. 3 (WNP-3), Grays Harbor County, Washington, with respect to the U.S. Army Corps of Engineers' areas of responsibility for flood control, navigation, and regulatory functions.

Our comments are attached.

Thank you for the opportunity to review this statement.

If you have any questions, please contact Dr. Steven F. Dice, telephone (20 6)'

764-3624, of my staff.

Sincerely, l

Le. O n -

/

1 Enclosure

[

jeorgeW.;;uc,g23.

l nsststent Cntet. :,;;;cieerIn3 Divts.nn 1

t' c O '-

l th W Qgp*d gr.,h 404130166 840329

{

ADOCK 05000508 a nO,

g j) a L

A a

J DEPARTMENT OF THE ARMY

,,..v.

SEATTLE olSTRICT. CORPS oF ENGIN EERS

• • N i

P.o. box C 3755

(

/

SEATTLE, WASHINGTON 98124 J'

~

Planning Branch pAq g [ggf

~

George W. Knighton, Chief Licensing Estanch No. 3 Divisien of Licensing U.S. Muclear Requistory Commission Washington, D.C.

20555

Dear Mr. Knighton:

We have reviewed the draf t environmental impact statement for Washington Nuclear Project No. 3 (WNP-3), Grays Harbor County, Washington, with respect to the U.S. Army Corps of Engineers' areas of responsibility for flood control, navigation, and regulatory functions.

Our comments are attached.

Thank you for the opport1nity to review this statement.

If you have any questions, please cor act Dr. Steven F. Dice, telephone (206) 764-3624, of my staff.

Sincerely, s

Q*

/

Enclosure yearge W. Ajouc,4_ 2 3 mststant :ntet =ait.1eenng Divls:cn h *j f

y ihr

.t vv.-

l

< y.s I'

,h,21 p

l 404130166 840329 ADOCK 05000 8

n gy.

a 51

1

.J

.)

NPSEN-PL-ER 8 March 1984 J

COMMENTS:

Draf t Environmental I= pact Statement, Washington Nuclear Project No. 3 (WNP-3), Grays Harbor County,. Washington 1.

Section 1.3, Permits and License, page 1-2.

This section should state that a Department of the Army permit under Section 10 of the River and g{fy/gpQ}

Harbor Act of 1899 would be required for the performance of any work in navigable water of the United States, which includes the Chehalis River.

Also, a Department of the Army permit would be required under Section 404 of the Clean Water Act for the discharge of any dredged or fill material into any waters of the United States or on their adjacent wetlands.

2.

Section 2, Purpose of and Need for Action, page 2-1.

The first sentence.

in the third paragraph states that "... nuclear plants cost less to ope-rate

". Although this is true, nuclear plants are much more expensive

((jg.{2, to construct than most fossil-fueled plants of which there are very few in thic region.

You may wish to expand upon the information in this section in order to more fully support the conclusion.

3.

General comment.

Impacts of the chemical and radiological contaminants in the effluent discharge are not fully evaluated.

In addition to water g{jfgp((

quality, the statement should include an evaluation of impacts on river sediments in the area of the dis, charge, in Grays Harbor estuary, and of I

the effects of bioaccumulation.,

4.

Section 5.3.1., Water Quality, page 5-2.

a.

Using chlorine as a bifouling agent may result in the chlorination of hydrocarbons present in the water supply system.

The applicant should describe the provisions that would be made to avoid accumulation of po-tentially carcinogenic chlorinated hydrocarbons in the water and sediments of the Chehalis River.

i b.

Waterborne contaminants should be monitored in sediments as well as in the receiving water below the effluent.

l Baseline data on sediment chemistry should be included so that g/

c.

j monitoring and effluent limits can be established.

5.

Section 5.9.3.4, Radiological Monitoring, page 5-21.

The EIS should discuss the potential for accumulation of radioactive wastes in sediments

[b.

)

in the river and estuary.

l l

I I

l

q y

n,

[

7; j

Department of Energy e4g: !,

[

Bonneville Power Administracon

.9 P.O. Box 3621 Shr #

Portland. Oregon 97208

.' };s. :.,s ;

s-

- + ce w SJ March 16, 1984

/I

,),pn w ~-

y, n!.

'L Ms. Annette Vietti Division of Licensing Nuclear Regulatory Commission

!?ashington, DC 20555

Dear Ms. Vietti:

Sonnev111e Power Administration (BPA) staff have reviewed your Draft Environ-mental Impact Statement (NUREG-1033) on the operation of '4ashington Public Power Supply System Nuclear Project No. 3 Section 4.2.7 of the statement correctly states, "The (power transmission)

[h system beyond the WNP-3 substation was evaluated, designed, and built by EPA, the lead Federal agency for the transmission lines."

EPA dccumented this cvaluation in an environmental impact statement entitled "Satsop Integrating Transmission" (Department of the Interior, FES 76-31).

A copy of this EIS is cnclosed here; please cross-reference this EIS in your final statement.

Thank you for the opportunity to comment.

Sincere 4, 2 9-.

/

Anthonyf. Morrell Environmerital Manager Enclosure 8404130172 840329 CF ADOCK 05000 8

A) 9, REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIOS)

ACCESSION NoR:8403200d3e DuC.DATE: 84/03/12 NOTARIZED: NO 00CKET s

~

FACILsSTN-50-508 *PPSS Nuclear Project, Unit 3, Washington Public 05000508 AUTH.NAME AUTHOR AFFILIATION

, F R EUD Eh6 URG, W.

Washington state Univ., Pullman, WA RECIP.NAME RECIPIENT AFFILIATION VIETTI,A.

Division of Licensing SudJECT: Comments on Od5 (nUNEG-1033). Assertions ce socio-economic impacts from station operation comonstrate low level of expertise among stuoy team or refusal to consider relevant research findings on social impacts.

COPIES RECEIVED:LTR _I_ ENCL l_

SIZE:__V

, DISTRIBUTION CODE: C00dB TITLE Public Comment on Environmental Statement NOTES:Stancardizec Plant. PNL icy FSAR AMOTS & NON PROP REPTS.

05000508 l

dECIPIENT COPIES RECIPIENT COPIES 10 CODE /NAME LTlR Ef4CL 10 CODE /NAME LTTR ENCL I

NRH LB3 BC 06 7

7 NHR L83 LA i

1 l

NL: ANL 1

1 VIETTI,A 01 1

1 bTERNAL: ELD /h0S1 1

1 NRR NORRIS,J 1

1 NRH/DE/AEA6 29 1

1 NRR/DE/EE5 16 1

1 NRK/DE/EHEb 1

1 NRR/0E/ sad 18 1

1 NRR/0SI/AEe 19 1

1 NRR/OSI/ MET 6 15 1

1 NRd/DSI/ rad 1/

1 1-REG FILE 04 1

1 i

RGN5 1

1 l

hTERNAL: ACMS b

6 LPOR 03 1

1 NRC POR 02 1

1 NSIC 05

~1 1

)

6T13 1

1

{

l 3TES:

1 1

l i

l

)

.~

WASHINGTON STATE UNIVERSITY PULU!AN. WASHINGTON 99164 DEPARTMENT OF SOCOLOGY/ DEPARTMENT OF RUR.M. SOCOLOGY Room 23, Wilson Hall March 12, 1984 Ms. Annette Vietti Division of Licensing U.S. Nuclear Regulatory Ccmmission Washington, D.C.

20555

Subject:

Assessment of Social and Econcmic Impacts in Draft Environmental

[

h Statement Related to the Oceraticn of WPPSS Nuclear Project $3, Docket 50-508, Washington Public Pcwer Supply System.

Dear Ms. Vietti:

After several attempts, I have just received a copy of the Draft Environmental Statement (dEIS) noted above (NUREG-1033).

Partly because the document itself does not make it entirely clear what day would be the actual deadline for receiving comments on the Draft EIS, and partly because an cmissicn noted below is so serious that I am certain that your study team would want to consider it in the interest of producing an adequate impact statement (regardless of the actual date of the deadline), I am writing to call your attention to a serious problem / error in the draft statement.

Specifically, the abstract of the dEIS asserts without documentation that "the not socio-economic effects of the projects will be beneficial," and page 5-8, after a brief description of some econcmic considerations, notes that "the j

staff anticipates no other significant socio-econcmic i= pacts from station op-eration." These statements (particularly the latter one) demonstrate either an unacceptablely icw level of relevant expertise among the study team or else a refusal to consider relevant research findings on the social impacts of WNP-3.

The local social environment has changed greatly, and the sccial i= pacts of the licensing and operation of the plant are likely to be dramatically different frem those that were envisioned in the original EIS on the construction permit phase of plant. An analysis by Redney Baxter and myself has shown that attitudes toward local nuclear facilities have declined dra-matica11y in nuclear " host communities" ac css the entire nation (Freudenburg and Baxter,1983), for example, and even more pointedly, as ncted in a report prepared by Rchert L. Wisniewski and myself (copies of which were shared with

{

the Washington Public Pcwer Supply System), "there is greater local cpposition i

to the WPPSS nuclear plants than to the nuclear facilities of any of the other

" normal" host ecmmunity in the history of surveys in the U.S."

The level cf opposition near the Satsop facility, in fact, is matched only by a survey done pyg V

-~

J

'l)

?

I Ms. Annette Vietti March 12, 1984 Page 2 at Three Mile Island itself, only fcur months after the infamcus accident S4B (Wisniewski and Freudenburg, 1981:38).

These reports and others have noted

)

further that the social consequences of permitting cperatien of a facility f

over such intense objections could be grave indeed.

I further call to your attention to the fact that the Regulations for Implementing Precedural Provisions of the National Environmental Policy Act make it explicit that " worst-case" assumptions should be utilized in situations such as these where the absence of an adequate quantitative data base makes it difficult to predict with any precision just what specific impacts are likely to occur.

I also call to your attention the fact that, as noted in a forthecming article in The Harvard Environmental Law Review, the recent Supreme Court decision in the Nuclear Regulatory Cc=missicn vs. People Against Nuclear Energy (PANE) would not be relevant here, since that case had to do with PANE's contention that an environmental impact statement was required even though no (non-psychoicgical) physical environmental i= pacts were alleged.

In the current case the Nuclear Regulatory Commission has clearly decided that an EIS is required, and is merely failing (in clear violation of the Council on Environmental Quality guidelines for E!Ss) to make best or even " token" use of the available scientific expertise en the likely social impacts of issuing an operating license for WNP-3.

If I may provide you with any assistance in responding to the substance of these comments and/or in identifying scientists with the relevant expertise for responding to the comments, please do net hesitate to centact me at the address on the letterhead above.

Sincerely, 8?N Y

William R. Freudenburg Associate Professor

• 4RFigm l

i l

1

A

^

4EGULATJPy la r 04'4 T I Or C I3 7h Ie:s t !L.9 5 3TFN P ir.0 aCCESSIL.i flo R : SuG31o022e CLC.DaTE: 30/G3/to N T ' F i Zic :

..J voCnci :

FACIL: E0-377 >PDSS Nuclear Proj ec t, Unit 2, nasningten ruelic an.e siv6u3-7 auTH. 4 WE 4Ur9uR arf 1LI;TIuN 309 LIE,G.

':a sn i ng t on, State of t

dECIP.'1AAE

-ECIridhi aFFILIATI0n ANIGT04 MAC - No betailec affiliation Given SudJECT: Forwares 3 tate of i4 Deot of Fisheries.esocese to cId.

esconse received arter state resocnse rorwar Jeu to 'inc.Enci snoutc ce attacned to etner state agancy I r.- s.

m,/

CISTRIdOTION CODE: C00dS COPIES RECEI'v6D:LTR E CL._

JIZE:._,________

TITLE: Puolic Comment on Environmental Statement

.40TES:

RECIPIENT LOPIE3 RECIPIENT COPIES 10 CODE /NAMt LTTR ENCL 10 CODE /NAtiE LTTW dNCL NRW LB2 SC Oo 7

7 NRR L32 LA 1

1 NL: ANL i

1 AULUCX,R.

01 1

1 BTERNAL: ELO/hDS2 1

1 NRR NORd!3,J 1

1 NRh/0E/AEA6 au 1

i NR9/0E/EE5 16 1

1 NRH/0E/EnEc 1

1 NRR/DE/ sad la 1

1 NRH/OSI/AES 19 1

1 NMR/OSI/ MET 6 15 1

.1 f4RR/OSI/RAb 17 1

1 REG FILE 04 1

1 RGN5 1

1 XTERNAL: ACd3 o

6 LPOR 03 1

1 NRC POR 04 1

1 NSIC 05 1

1 DTIS 1

1 l

l l

~

s s

)

8 a

%M g

e 1

/'/ rlC s.

h &w j

~

f g

h N'

3- ~ *lr " fy o

t

/

Y

/by~

w

% M' W b"W

/

'ye' 3 es.

L a n+

W cm /44h [N/

Y sWW.

pg

@A A ~' ";

p,,. 4 su JA%

• p 7t'f J

J-d,

/Lfs.c,-

w. /er V

ff

\\__

T,:,385R%!c33A47 g,>

)

I 1

s

'A J

1

,v,..c.

i.

i T i'.l..' ~

Idarch 7, 1984 RECT _iV EC fts. Barbara Ritchie, uf.R 1 ?.1984

.1 EPA Coordinator Department of Ecology' 7,d21$iE1N$

St. Martin's Campus Olympia, Washington 98504

Dear Ms. Ritchie:

hWO WPPSS tumber 3 Craft Environmental Imcact Statement We have reviewed the referenced report and find it thorough and complete as far as the aquatic resources are concerned.

There are two additions that should be included in the final report, however.

They are described below.

Table 4.6, on page 4-24, should include the 1982 coho plants as follows:

Fuller Creek 7,700 Workman Creek 42,000 Elizabeth Creek 25,500 The Cepartment of Game should also be contacted to obtain any trout planting data also.

Under Section 5.3.1, the report ifealing with toxic material studies is now available.

It is entitled Toxicity of Coccer, Zinc and Their Chemical.orms to Coho Salmon and Steelhead Trout in ene Chenalis River, Wasnington.

Thank you for the opportunity to co=ent on the referenced docucent.

We ho;:e these coments will assist the Nuclear Regulatory Comission in completion of their report.

Sincerely, n$$od (.Ni h l' i

[/

William R.

kerson Director cc:

Fenton, WDG i

_m

b-I

})

Washington Public Power Supply System Box 1223 Elma. Washington 98541 (206)482-4428 i

Docket No. 50-508 March 5,1984 G03-84-131 Director of Nuclear Reactor Regulation Attention:

Mr. G.W. Knighton, Chief Licensing Branch No. 3 U.S. Nuclear Regulatory Commission Washington, D.C.

20535

Subject:

SUPPLY SYSTEM NUCLEAR PROJECT NO. 3 DRAFT ENVIRONMENTAL STATEMENT (tiUREG-1033)

Reference:

Letter, G.W. Knighton, NRC, to 0.W. Mazur, Supply System same subject, dated January 13, 1984.

Thank you for th'e opportunity to review the subject document.

We offer the attached comments which you may wish to consider in the preparation of a Final Environmental Statement.

Very truly yours,

//

(

en

ES 1 ov.w.

G.C. Sorensen, Manager

' P 6

Regulatory Programs e/ k..,

JPC/mam T

' N"

Attachment:

As stated

' ^ ~ " ' '

i It f.(; '!

• cc:

D. Smithpeter (BPA)

' #^w f EY1112,CUfRCP 0

J. Adams (NESCO)

F ^ M 0d. /

N.S. Reynolds (Bishop, Liberman, Cook, Purcell & Reynolds)

J. Parrovecchio (Ebasco - NYO)

WNP-3 Files F. Swearingen (BPA)

')

O.

) &

t (L

0

,M O'

3

. ' SUPPLY SYSTEM C0ilftENTS

/

OH WNP-3 DRAFT ENVIROHf1 ENTAL STATEf4ENT (HUREG-1033)

Facility Description (Sections 4.2.1 and 4.2.2)

Figure 4.1 is taken from ER-OL Figure 2.1-1 which will be amended consistent with the response to Q290.14 and the acreages cited in DES-OL Section 4.2.2.

FSAR Figure 2.1-1 has already been amended (December 1983).

Also note in Mh Section 4.2.1 that reduction of the base diameter of the cooling tower by 90 feet is not an exception to conclusions regarding the significance of changes in the arrangement of site structures.

Construction laydown area should be added to the list at the bottom of p. 4-1.

Honradioactive Wastes (Secion 4.2.6)

With reference to the second paragraph in Section 4.2.6.2, it is new planned that potassium chromate will be added to the closed component cooling water system for corrosion control.

As described in the DES, leakages will be processed in the SHP system with re'sidual chromate removal by ion exchange. U Water drained from the component cooling water system during maintenance operations will be captured and reused in the system.

In the fifth paragraph of Section 4.2.6.2 (bottem of p. 4-11) it should be noted that sodium hypochlorite will be the source of free chlorine residuals.

With reference to the last paragraph of Section 4.2.6.2 (p. 4-12) and tne second paragraph of Section 5.3.1 (p. 5-2), we note that although we expect the chlorine residual in the discharge to be at or below 0.02 mg/1, the NPOES permit considers 0.05 mg/1 to be the detectable limit (p. G-4).

Sanitary waste disposal is mentirned in Section 4.2.6.3.

It should be noted that WHP-3 will continue to dispse of treated wastes in the drain field which was sized for construction phase loading (see ER-OL Sections 3.7.1 and 5.4).

Hydrology (Section 4.3.1) 3 Historical flow data for the Chehalis River are sumarized in the fourth paragraph of Section 4.3.1.1.1.

The average Chehells River flow at the site is given (without reference) as 6824 ft3/sec while the ER-OL and FSAR suggest 3

about 6630 ft /sec.

The average monthly flows cited for August and January should be given as 806 and 14,668 ft /sec, respectively (see FSAR p. 2,4-2; 3

ER-OL p. 2.4-1 and T. 2.4-1 to be amended, accordingly).

The minimum historical flow is now estimated to be 454 ft /sec (FSAR p.2.4-51) rather than 3

397 ft3/sec as cited in the DES.

In the third sentence of Section 4.3.1.1.3 f t should be noted that the 550-ft 3 /sec river flow limitation could be waived by the State based on regional power needs.

Water Ouality (Sections 4.3.3 and 5.3.1)

The anbient Chehalis River copper concentrations given in the fourth'paragraoh

.2/03 of Section 5.3.1 are based on older data.

Reference should be made to Table 4.2.

,3 Supply System Comments - huREG 1033 4

P, age Two The Supply System bioassay studies are mentioned in the last paragraph of Section 5.3.1.

Contrary to as cited therein, the draft report summarizing the results of these studies was provided to the ilRC by letter dated October 21, 1983.

The results suggest a long-term, no-effect level of 18 ug/l for coho salmon versus the 7 ug/l cited on p. 5-3.

Meterology (Section 4.3.3)

It should be noted in the third paragraph of Section 4.3.3 that observations of " heavy fog" are from valley stations where fog and stagnant air collects. [6 Wl4P-3 is located on a ridge above the heavy fog.

Aquatic Resources (Sections 4.3.'4.2 and 5.5.2)

The last two sentences of the second paragraph of Section 4.3.4.2 seem gy/d somewhat confusing and unnecessary in view of discussion provided in Sections

4. 2. 4 and 5. 5. 2.

This latter section (p. 5-6) notes that the diffuser was relocated to minimize potential impact to migrating salmonids.

Angler survey data are provided on p. 4-22 and 4-25.

We have difficulty relating the numbers to the referenced sources.

Does the range 4 to 17 anglers per day refer to all anglers or only salmon fishermen?

Does the range 10 to 26 per day and maximum of 50 mean steelhead fishermen?

Our reading of the data suggests that the annual average ranged from 6 to 12 anglers per day for 1978 - 1981.

Monthly averages for the survey period ranged from 0.2 to 26.4 anglers per day.

Terrestrial Resources (Sections 5.2.1 and 5.5.1)

The DES notes that a wildlife management plan is to be submf tted to the Energy 6//[S Facility Site Certification Council (EFSEC).

The plan is not specifically required, but stems from conditions of the Site Certification Agreement between the Supply System and the State of Washingt.>n.,

It is subject to approval by EFSEC; a copy will be provided to the !!RC at the time of its submittal.

Comunity Characteristics (Section 4.3.6) in response to 0311.05 we noted minor errors in the distribution of near-plant residents.

ER-OL Table 2.1-2 and FSAR Table 2.1-3 will be amended to provide Ih corrections.

For instance the 1980 population within one mile of WilP-3 is now estimated to be 3 versus the 15 noted in DES Table 4.7.

Radiological Impacts. Routine Operation (Section 5.9.3)

The estimated doses from routine operation are provided in DES Appendix 0. We I M only note that the Staff's calculated dispersion factors and resultant doses are roughly twice the Supply System estimates in the ER-OL.

The fish consumption liquid pathway dose, although very small, seems to be based on an excessively conservative dilution factor for an anadromous fishery.

The " maximally exposed" individual is explained in Section 5.9.2 (botten of o.

5-10).

It would be useful to remind the reader in Section 5.9.3.1.2 (p. 5-20) that this individual is hypothetical and that the doses from various pathways are calculated and summed very conservatively.

3 i *Sup* ply System comments - )EG 1033 c

i P, age Three The peoperational monitoring program is discussed in Secticn 5.9.3.4.1.

The Supply System plans minor changes to the program described by Table 5.3 to assure consistency with Regulatory Guide 4.8 and its Branch Technical Position.

Table 6.1-7 of the ER-OL will be amended to reflect the changes and correct the typos.

Radiological Impacts, Accidents (Section 5.9.4)

The evacuation model is referenced on p. 5-41 and discussed in Appendix F.

The DES (p. F-3) " conservatively" estimates an effective evacuation speed of gh 2 mph.

Given all the conservatisms of the accident analysis, we find this estimate overly conservative by comparison with evacuation times estimated in Tabij 12-5 of the WHP-3 Emergency Preparedness Plan.

The DES finds that the WNP-3 liquid pathway (p. 5-50 to 5-53) yields doses substantially greater than the LPGS doses and still poses much less risk than the gaseous pathway.

We note that the DES estimates are also much grester than Supply System estimates (RQ240.14).

Both the DES analysis and that of the Supply System begin with the very conservative assumption that 100 percent of the core inventory of cesium, the major contributor to dose, reaches the river immediately, whereas 10 percent would be more realistic.

Given the conservative source tem, the large population dose for WNP-3, relative to the LPGS, is derived from conservative assumptions regarding shoreline usage, fish catch / consumption, and river dilution.

The fish consumption pathway provides the most significant contribution for comparison with the LPGS.

Besides using an overly conservative catch of one million pounds (see DES Table 4.3 and R0240.14), the analysis must assume (as did the LPGS) that all fish caught are fully exposed and consumed.

If the containment were breached such that the Chehalis River was severly contaminated, as postulated in the DES, among the immediate impacts would be the loss of recreational opportunities and disruption of the fishery markets.

The NRC would be more realistic if it assessed the liquid pathway in terms of economics rather than fictitious health effects.

The DES analysis (p. 5-52) uses the harmonic mean flow which is about one-fourth of the annual mean flow of the Chehalis River.

We assume it conservatively neglects the contribution of tributaries downstream.

Because a large fraction of the one million pounds of fish are caught in Grays Harbor, with its associated flushing and dilution, yet another conservatism is inherent in the analysis.

The analysis also neglects any sediment partitioning which would reduce concentrations.

In the second and fourth paragraphs on p. 5-51 (the third seems out of place),

it should ue noted that the plant underdrains discharge to a Workman Creek Bributary which is referred to as Stein Creek (see Figure 5.11.

Workman Creek is not an sphemeral stream.

Also, we note that the third paragraph on p. 5-56 seems misplaced and perhaps belongs to the discussion of uncertainties on 5-63.

po In sumary of our comments on accidents, we suggest that neither the Staff nor the Supply System has "shown" WNP-3 to have " considerably worse" consequences than the LPGS.

Given the conservatisms of the analysis, a more qualified judgement seems appropriate for the last paragraph of Section 5.9.4.5(5).

3

.4

/

Supply System Comments - HUREG 1033 Page Four Benefit-Cost Suncar/ (Table 6.1)

In Table 6.1 groundwater consumption impact is listed as "none." Consistent gg with Sections 4.2.4 and 4.3.1.1.2 this should probably be "small."

Section 5.5.2, rather than 5.3.2, should be given as a reference for thermal effects.

" Cooling lake drawdown" is incorrectly listed as an impact in Table 6.1.

Based on the information given in Section 5.7 concerning the effect of plant operation on historic / archeological resources, "none" seems more appropriate than "small."

Minor Editorial Comments On p. 4-1 (Section 4.2.2) the question number is 290.14, not 29.14 On the h h

same page, the exclusion area boundarf is at 1310 meters, not 13,611 meters, f On p. 4-6 the correct reference for withdrawal limitations is Section

4. 3.1.1. 3, no t 4. 3. 2.

On p. 4-11 in the third paragraph of Section 4.2.6.2, th'e seccnd reference to ER-CP should be ER-OL Table 3.6.2.

The last three sentences of this paragraph seem excessively wordy.

On p. 4-13 units of flow are 'm3/sec, not m2 sec.

/

On p. 4-24 "... Emergency... " should be "... Energy... "

On p. 5-2 ".. 61. 3 ug/1... " i s repea ted.

In the same paragraph reference to Section 4.3.2 should be to 4.2.6.3.

On p. 5-3 units of flow are m3/sec, not ug/sec.

On p. 5-5 and 5-71, it seems the FES, rather than DES, should be referenced.

Also on p. 5-5 (Section 5.5.1) the correct ER-OL figure reference is 5.1-4 (not 5.1.4) and the DES section reference is 5.14.2 (not 5.11.2).

On p. 5-53, at the bottom, Figure 5.9 should be Figure 5.11.

On p. 5-43 incorrect figure references are given in Table 5.7.

In the second paragraph on this page the background radiation dose should be 82,000 person-rems consistent with p. 0-9.

Also, at the bottem of the page "28-m" should be "28-km."

On p. 5-61 and 5-70, the date given for the Nieves reference should he November 1983.

On p. 5-68 FSAR Section 10.3 should be WNP-3 Emergency Preparedness plan Section 10.3.

Cn p.<F-2, at the bottom, "0.89 km" should be "3.2 km."

3

.s a

4EGULATu3f l'SOHWATION OISTHIJUTICf4 SISTE* (4103)

ACCESSION Nck: 4433150151 Ouc.0 ATE: P4/03/0e flC T aF 1 Z cn: i,0 LI:CXET s F ACIL $ 7f. 50 5Q4,,FDS$ f4uc l eer PPoJ ec t, Vnit 3,..asnington Pualic v50005vP Aufn.t.At'E Aurwup acF1 LIAR!GN LUN0uLAO,C.

aashington, State of

• ECID.esaMt nECId!ENI AFFILIATION C11CHTuN,G.

Licensins erencn 3 3'JdJECT: Comments on Pacility CE3.Into snoula se secrejateo into

eneric site-soectfte toctes s '"J t 19to lovtans I d e 'i'J a a e, t '

essential cart or *ur,at r=qisireo for 063.

C I573 Iau f t v'.

C 00 6. : C 'J J S

'.nH !i3 ULCEI*,EU:L?R d E.CL S t i E :.,_

TITLE: auccic Comment on Environnental Statement NO TE S 13 t ancar,oi:en P l asit. d '. 6 Icy FSAN at 073 ( 'rC N F-09 AEPTS.

0 50 0 0 5 c.8 aiC'-!: T

. '< ! C 1

• tC I:

• i.~

':t IL C it u F. / o a,J d

.T 4 E..C L IS CoC,/*. A: F

'iTA r '4 C L

• L ',3

+2 C n a

/

7

'lH 4 ' 3 L.

t 1

.4

.L :

. t.

A 1

'/IEil'I,a

., 1 9

1

• TtWN1.L : it. / >d S t 1

1

• 4

'. 4:3!3,J 1

.E 5 /b E/Atau 29 i

1

.MO/"l;/tEJ 12 1

1

-4*dP/QE/ENED 1

1 NRC/DL/34c 18 t

i taWm/031/4Ea 11 1

1

'lkm/03I/ *Eth 15 t

1 i4Rn/031/ RAW 1/

1 1

REG FILE Gd i

1 AGAS 1

1 XTERNAL: ACN!

o 6

LPON 03 1

1 f.PL Pori 04 1

1

'43 I C 05 1

1

.TL' 1

1

'o'

])

1 " v-STEst 1

1

?-

j

, _, P 1 :,,

t i

,,o s j. b '

.. ()y '

,,,~

V

/

'($

t.I

.t e

r

..o.

O {'

t;,.'

Y.

e 0

6 V

3 f.

CHN 9 M MAN e-

/

CW.Q.V

• :CC) b e *Cf

..rer.::t 3 m er '.us-ocros CEPARTME.NT.CF ECCLCC/

ua sco it s t,

a.w:t '.sw: p>n.t.:::

. t.u c March 8, 1984 Mr. George highton Chiaf, Licensing 3 ranch 'o.

3 U.S. Nuclear Regulatory Commission Washington, D.C.

20535

Dear Mr. highten:

Thank you for the opportunity to comment en the draft environmental i= pact statement (DEIS) for the operation of WPPSS Nuclear Project No. 3 (Docket No. 50-508). The Department of Ecology has been designated as the state coordinator for review of NEPA documents. We have coordinated the review of this DEIS vich other state agencias and received comment letters from the Energy Facility Site Evaluation Council and the Office of Archaeology and Historic Preservation.

Their letters, along with comments from the Department of Ecology, are attached.

If you have any questions, please call Mr. Cres Sorlie at (206) 459-6237.

Sincerely,

' w $,.. 7~. J: LG.s

,.g-Dennis Lundblad Acting Assistant Director Office of Operations and Enforcement DL CS:pk Attachments cc: Greg Sorlie State Agencies meat 1mai

^10*00

1. DR ADec o3 coa g D

ph t

2

I e

Comments on WPPSS t/3 from the Department of Ecology Wile this facility will produce large, calculable quantities of spent fuel, by the earliest ciae it can be in operation some progress will have been made toward developing one or more national high-level nuclear waste (HLW) repositories.

Because of currently anticipated delays and the inherently long development time associated with the first repostcory, it should be noted that KLW will need to be scored on-site for at least 10 years,.barring some unusual change in operating procedures.

Figure 4.1 (page 4-2):

The site layout map indicacas the Keyes Road exten-sion to the east of the plant and into the exclusion zone. A sipificant fa section of this road is not shown-the portion (nat e:ctands from near the fD No. 3 cooling cover, past the turbine senerator, and connecting uith the main Keyes Road terminus at the top of Fuller Hill.

It is sipificant as an alternative access to the site and/or evacuation corridor.

There has been some discussion of eliminating use of this road in the future in favor of diverting any required cross traffic to the plant connecting road.

Use of either or both could have tapacts on plant security and emergency response plans, and should be discussed in the DEIS.

Sec. 5.4.2: The Energy Facility Site Evaluation Council recognized the necessity of maintaining and testing back-up diesel engines for emergsney use. The ' certification agreement, as amended in March 1982, waived air quality standards for these stationary sources with respect to NO, SO, and gg{

particulate, but called for the utility to use icw sulfur fuel oif (0.h sulfur). With this requirement, all practical means of providing rapid scare up and load acceptance without unnecessary adverse air quality impacts are accomplished.

Given this understanding, the conclusion appears valid.

Footnote "***", and of Table 6.1 (page 6-3), does not appear applicable to j[h the table.

Sections 5.9 through 5.14 contain some very useful information, particularly MS when taken in conjunction with Appendices D, E, and F.

There is, however, a large amount of academic verbage that tends to dilute the real conclusicas Nb or comparisons useful to public understanding of risks and consequences.

The information should be segregated into generic / site specific topics and put g

into laymans language if it is an essential part of the format required for a DEIS. Otherwise, some of it probably should be dropped in favor of taking selected portions of Appendices D, E, and F, and inserting them where appro-priate.

l J

...m%p

y.<

,3.. ww.s.

- o r.n

%~

i et

,4

.., m. : o.

ENERGY FACILITY SITE EVMUATION COR C"-

. w x, y, n.,,.

%,,, y u.n -.

.... n. - o..... m

.t......

March 6,19S'4

.:.CN D

- 5 G5.;

t u. wr,; p em..<;y Director, Division of Licensing w a.gvu6Tiu U. S. Nuclear Regulatory Commission Washingten, D.C. 20355

Subject:

Orsi: Environmental Sta:emen:- Washincon Nuclear Proec: Ne. 3 Centlemen:

Tha% ycu ter the oppor: unity to commen: en the Draf: Envircnmen:a. 5::.:2 men: (D ESI prepared by the U. S Nuclear Regu story Commissica (NRC) raiated to :he cpers:.:n of Washington Public Power Supply System Nuclear Project No. 3 (TNP-3)(NRC Decket No.

50-503).

The DES presents NRC's assessment of the varicus environmen:al, economic and :echnical impacts, both beneficial and adverse, associated with the issuance of an operating ficens~e for WNP-3. Because of NRC's unique requirements for environmental statements at both the construe:lon and operating stages, this DES examines any changes or new informa: ion that have occurred since the construction permit stage environmental s:stement was issued in June 1973.

On October 27, 1976, the state of Washington issued a Site Certifica:icn Agreement to the Washington Public Power Supply System (Supply System) to cons: rue and opera:e W N P -).

The Site Certification Agreement sets for:h the license condi: ions under which WNP-3 is to be safely constructed and operated while minimi:ing adverse impacts to the greatest extent possible. The Energy Facility Site Evalua:!cn Council (EFSEC) admini-sters the cer:lfication agreement through a comprehensive moni:cring program :nat ensures compliance with the environmental regulations, public health and safety standards and the other terms of :he license.

In view of the shared federal-sta:e licensing responsibilities for nuclear facilities, the Councl! is very much interes:ed in NRC's updated assessment of the Impacts associated with an operating project and their relationship to our already existing licensa and permit conditions.

The Council has reviewed the information presented in the DES and finds that the document accurately desc.-ibes project conditions and imoac:s as they exis:ed in the or!ginal licensing considerations, e they have evolved over the initia! construe:!cn period, and as they are forecast during operation of the facill:y.

The sta:ement provides a thorough explanation of the potential envircnmental, technical anc social imoacts of the project and we concur with the determinatten ":nat TNP-3 can be opera:ed witn minimal environments! Impact." The following comments are provided en specific sec:!ans af :ne DES.

So 1 1 7fn i j# -

4 r.

. +.

v~

r Lg <x eq

}'

\\

(

j.

c. t\\

_xd

O Director, Division of Licensing Page 2 Maren 6,1934 Section 4.t Proiect Descriotion Resume - We wou!d agree tha: the malcr change since :he CP stage is :ne cance!!a: ion of 7/N?.5 Thi!e the requiremen:s f r TNP-3 remain essentially the same from the earlier review, many of the IIcense condi: ions were basec a

/r on the two units operat!ng at the site. Ti:h only one unit now planned for cpers:lon, many of the projections for usage, design capacities, effluent amounts, etc., have been reduced significantly and have lessened the potential for impact.

Sect!c.n '4.0 7/ater Use and Treatmnt The s:a:emen: accura:siy :escrdes the s:a:e's requirements for wa:er withdrawat, thermal discharges and design cnanges made in the y

discnarge diffuser and cool!ng sys:sm since :he CP s: age.

Saction 5.3.17/ater Ouality - Under :he s:ste's Naticnal Pol utan: Disenar;c E!!mination System (N?DE5) Permit, :ne Supply Sys:em was required :o c:nccc: si:e spec!!ic, flow-

hrough bicassays on local salmonids to assess the toxic levels of copper and zinc, both g f singly and in combination, during different times of the year and with differen: life stages. The results of the bioassay studies are now available and should be included in the final statement.

We ahoreciate the opportunity to comment on the DES and look forward to workin the NRC as you proceed with license proceedings for WNP-3.

Sin' rely, t-L.,is:

E ecutive Secretary W1.F:ke bec:

Barbara Ricchie t

I k.__

-g

/

1 6',

.'t; en *

OHN SPQiM AN N'.. g /

Cavemor

~

ACC8 THOMAS cirecor 57 ATE CF W AiH.NCTCN i

OFFICE OF ARCHAEOLOGY AND HISTORIC PRESERVATION 111 West Twenty Fest 4eze..u 11 Chnca. wwrvon 98502 e

e c.'C6). 31 :oI1 February 22, 1984

'83 241934 Cer-m.ur.t *3 iCOLCGi Ms. Barbara Ritchie EWlH0.WENTAL MfiC#

NEPA Coordinator Dept. of Ecology Mail Stop ?V-11 Olympia,%'A 98504 Log

Reference:

449-7-NRC-01 Re: k'PPSS No. 3 Draf t EIS

Dear Ms. Ritchie:

t A staff review has been completed of the above referenced draft envi-consental impact statement.

The document adequately considers kncun and anticipated cultural resources and the potential for impact to -

these.

Thank you for this opportunity to coausent.

Sincerely, bh Robert G. Whitlam, Ph.D.

State Archaeologist dw b

't CEGULATURY o.ORMATION DISTRIBUT20N SYS 4 (RIOS)

ACCESSI'ON NoR 8u03220198 00C.DATE: 84/03/13 NOTARI7ED: H0 00CXET s F ACIL STN 50=-508 WPPSS Nucleer Proj ect, Unit 3, Washington Puelic 05000508 AUTH.NAME AUTHUR AFFILIATION DEGENS,S.

Affiliation Not Assionea RECIP.NAME RECIPIENT AFFILIATION NRC = No Detailed Affiliation Given SU8 JECT: Comments on nds ce operation of facility.Cummutative impacts on regional water use snould be more explicitly evaluatec.

OES acequate,out unnecessary as decisionmaking tool.

DISTRIBUTION CODE: C00dB COPIES RECEIVED:LTR ENCL _f_ SIZES.

TITLE: Public Comment on Environmental Statement NOTES Stancardized Plant. PNL icy PSAR APOTS & NON PROP REPTS.

05000508 HECIPIENT COPIES RECIPIENT COPIES 10 CODE /NAME LTTR ENCL 10 CODE /NAME LTTA ENCL NRP Le3 BC 06 7

7 NRR L63 LA 1

1 NL ANL 1

1 VIETTI,A 01 1

1 3NTERNAL: ELD /H001 1

1 NRR NORRIS,J 1

1 NRR/CE/AEAd 20 1

1 NHR/0E/EES 16 1

1 NRH/DE/EHEb 1

1 NRR/DE/SAB 18 1

1 NRR/OSI/AEd 19 1

1 NHR/OSI/ MET 8 15 1

1 NRR/OSI/MA6 17 1

1 REG FILE 04 1

1 AGN5 1

1 3XTERNAL: ACHS o

6 LPOR 03 1

1 NRC POR Od 1

1 NSIC 05 1

1 NTIS 1

1 DOTES:

1 1

TOTAL NUMBEH OF COPIES HEuu1RdD: LTTR 32 ENCL 32

Sebastian Degens 4515 SE Madision Portland, Gregeon 97215 Portland March 13, 1984 US Nuclear Regulatory Commission Matomic Building 1717 E Street NV Uashington, D.C. 20555

Dear Concission Members,

Inclosed is a lengthy cocrent on IIS No. 840014, concernin5 the operating licence of WPPSS No. 5 in Grays Earbor County in 'dashington. I realize my com=ent is a few days over the deadline, but I had difficulties finding out where to send it.

The paper was submitted for a class offered in the winter ters at Fortland State University. The class was 'Invironmental I pact Assessment' and in the encloadd criticue, I point to some of the strengths and weaknesses of'thid particular IIS, based upon a reading of assesscent itself, U3?A regulations, as well as class discussions.

~s Please send this on to the appropriate reviewer.

Also, I would like to be on a list of people to recieve the FEA when it coces out on this project.

Chank You, bt f

eme,=n:\\ mr

~

PDR ADOCK d5000500 70

,0 D

PDR Il L

c_

~

,' r 1

j

- o.:

CRITIntE C+F AN EIS PRJE.'.thCD BY THis NRC 89 DRAFT TCTVIPC :.i:h'AI, JST tr: tit ID:7,A.'l:D TO '0:IE OP;sRATICI: CP

• r PG3 !;UCI.~:^.R Pif0 JECT IIO.3 PR:C Ai? C1 TY "'IrM 11.3.1:UCLMA" lii?Gt').aTORY C0i#Id!',I0t!

.,ebestian Degens 4515 3: Hndison Portland, OR 97215 Geo6 523 Winter 1984 9

4 e

,e ~

Ohe proposed action which renuired the D.rai.t ES Related as ths Operation of the '/PPUS Nuclear Pro.iect No.3 (DES-OL). is the isauance of an operating license to the Washington Public Power Sunply System (WPPUG) for start-up and opera tion of its nuclear project no. 3 (WPN-3), located in Grays Harbor County, WA. The project consists of a two-loop prosnurised water reactor (PWR) with a pro,iected electrien1 output of 1240MW. A conling tower and pumping station to draw weter froa an acuifer below the Che-holis River are included en the 2570 acre site.

The U.S. Nuclear Regulatory Commission (URC), and its staff in the Of' ice of Nuclear Reactor Regulation prepared the docume..

j in response to en application for nn operatinF license for thin fa'cility from the URC. The projected water withdrawals as well as the radioactive emissions by the facility clenrly mal:e this e Federal action signifienntly affecting the nunlity or the hum"n environment (3 1502 3). The statutory requirements for an EIG nre met.

WPU-3 was 759 comnlete. at t.he time of apalication for the operating license. Construction dela.7s since that time have punh'd the anticipated fuel-loading date into 1987-1989. 0he staff noted that this DES could therefore be isnued up to six years prior to the fuel loading date. This constitutes an unusually early issuance. It was the staff's judgement that -he facility's operational characteristics were suf ficiently 1:nown fo.4/ law the present assessment. (WUP-3 DES, 1'-2 ).

?he LE3 is dated December 1983. The Motice of Availability u_

1 i

.e i

i (I!Oa) was publi-hed by the Environmental Proteccion Agency in the ?ederal Recister on Fridny, January 27,1984 (FR; Vol 49. Uc 19).

A 45 day comr.ent period was scheduled ending on March 12. A copy of t!.is critinue has been submitted.

URC licensing procedures for nuclear power plants are sep-orated into distinct phases. The NRC hns tiered their environmentd statements to corraspond with tile construction and operating stnges. This enables "... focus on the actun1 isnues ripe for decision at each level of environnontal review." (N1502.20)

The purpose of the DES-OL is to center on inaues specifically related to the operational system of the nuclear plant. An ad ~

ditional purpose emerges in the text. The DES-OL evaluates design chon es in the project which have occured since the time of the Final Environmental Utatement on the construction permit (FIS-CP).

The bulk of the desicn end environnental impnet information is contained in the FE3-CP wri ten in 1975. This information is summarized in the DES text, and encorpornted by reference.

Tiering has a number of important implientions for the D31 First, it is physically shortened by the ability to reference the document in the previous stnge in the process. More importnntly, the range of isnues covered is also reduced. The ITRC has interpreted tiering to obviate evaluations of the need-for -power issues during the operation-license phase. Discussion of the need-for-power issue has occured durinc the construction permit stage and is considered resolved.

The 3RC has assumed that nuclear power plants cost less to e

operate than fossil fueled plants. '.'ho ;iRC concludes that nuclear tower would be n croferred energy source, even were a reduction in denand to elininite the ne9d for any ndditional generation.

(*.iPU-3 DEU, 2-1) Need for the proposed nction is eliminated no an issue and barring special circumstances, the operating license is not subject to a test of noed.

l The logic of the environnentla review process, es conducted by the 1:2C in t'.-e licensing of nuclear power pian;s, thus eliminates gg) a broad range of alternatives during the OL ctn6e. Both alternative energy sources es well es alternative sites are no longer relevant.

Conmitted resources and the advanced stage in the process have left no feasible alternotives and none are presented in this DES.

Alternativo plans of operation were not connidered, thourh I feel they would have been apnropriate for comparison. Examples g g3 could have been alternative monitorinr programs for the surrounding enrth, water, and air resources. Also, in nedition to mitigative renponses to wnter renovnL nt times of low stream flow, an op-g//ff6) perational plan which synchronized refueling with all or part of theseason21dryperiods.coulf.havebeenprecented.

The existinq environment was described adonuately in the.:SU.

"nchanged portions of the project were sunrarized from previous documents and referoncod. A compnretive evaluntion of the inpnets of alternatives could not be undertnken in the absence of alternat-ives. !!owever, design chan6es since the FEG-CP had altered many impacts. These new impnets were discuaned in v conpc.rntive nnnrer with the initially nnt'icipated ones.

The nojor chnnge was the enneellation of a second unit,

u-

-4 UTFS3 No. 5, which hnd been pinnned for that site as well. In many respects this ch nge nfforded the DIS euite a bit of leeway in the discuscion of imoncts. For examnie, WPFSU increased its es-timate for the sulfuric acid renuirement 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 concentration of sulfates was swept owny in the text with the recolection that the planned second unit had now been scrapned and the resulting ambient concentrations for one pinnt were lower

,than had previcusly been projected for two.

Ifeelthistypeofanalysisismoreround-aboutthandirect.g{gMgg[

Uhil'e it is imnortant to knou that the sum of the impnets is less thnn these previously plenned, if the design changes represent significant elterations, they should be described absolutely (ie.

Mow much effluent renults from one unit with en increased renuire-ment of sulfuric acid?).

t.

troublenome fenture in the Dim was a multiple reference t M e Safety Evnluation Report (d R) which is scheduled for release six months after the closure da'te for corments on the DES. In appendix form, the water'and air effluents were summarized in an-t ticipation of this report. The capability of the proposed radwaste i

system to accomodate the solid wastes expected during normal operations was not evnluated nor sumnnrized. This seems to me a significant omission..

The D23 covered an extensive set of imnncts~both analytical 1~

and-in concise and understandable innpuere. The methodologies h

........ s. m.......L,. $. M, a :v, 4..g pa.>WYi W

~.

?

n,..

m.;.p,4yg,s gyv m

[: U,;'

k hf;,h4

,b gj. 3 y c: m K :u n Wg yM:%.,,

e% g g~

v.

e%en9:,. Y..~.a6 n%

.:.: ~

9>g.m...,w L F p -f p y 3 h $. Q v ?:p: R,Q

.p :

syp$

, "a

' ' : ' %. %dJ&

'rn

.,.S;,.4;...M/dtp/v=yd$p@Qf

~

$Mr dp s

~

..??' >;~., 3 %

were explained clearly end included in the'textMand.'appendiff.!/d[;-5,$-

I did not feel the inpact discussions were e%:.M:.Q.' Eun::.265%3#

@W ach offthe same.Tualit f-c..;= as.w:gy:.-i m -p W G 4 Direct iconcts were evalu' ted 'in each; of ~g.ww,.nm'menta-smm;:

Q q.

~ ~ t, a

vir

.a ogc W.&

IA0fhhhhhy

.h

h p bb indirectimpactsWere3ddreG3e@ddin?C,ertal@M@Wff 5

w

~

f %!$@ysT inpacts were not evaluated.by eachJ 'f".%tisi

.2 o.

ors

' ' ~

o 1

was not clear whether thes % @56 %"d M @A%E 51 i

~'

-:%F b

enwritersient.ertaIn

~

s

.3 N:# M d. M 12M M

[L d [

excluded them, or whether.'the r had-bend J.rmorg;dLag.d. k' %3

.>%s 4

c.

-?:. ;,--: a. a. w ; u..m.:, n e.m.

.~~.:: s me:cWsa.W.qc.sQ? q p;m ipy;Jfjf.svg ; t;

' 7.%

<w s

Cummulative impacts on regional. water pse :,sC;t1#v%bMdi.

should.: be more r explicitly evalunted,@, for 'one. %..n&. h, uY.JMmm,f;

.. 2 u. 3. n...

m erInJthe area;,o, %, w. m

.sw e

... w.

c dar e

o-the theorization that: bec$M$MM/S$? S%I '

26 @

1 towerseemed'unlikelygsee[me' M M dN M h.E:

ausec.of NEMN t

ess M'

with a coolinr':

N.l $ ! & % $ W M f}kf r

^

a w

g some field date on the. effects of;constructionco ses*;oe 1

as a proxy for the antic & MN % W ][fromat k:

M' :B

&W ipat'dunoise7 2adiologica1 impaetss.were ($N.$r1.be$n%,x=h.

5[

L

' @MMf$,

-j f

desc

a see=ed reasonable, and's$$$ M % f.hl@ h h. a&, ' e.

j 3

9' i

areas?of.uncertal s

~

N^ % C M ffi@.G @

pg"^

W s

deba te were ou t: lined. - Tables ;ofa radia tioqM$gi,o$,,A.,W.r Agi g y erni

.' :%.-4f2W.Mi&WG edtW l

upon ocnaision when the'CtiiiifsMS.Eddd65fENT

1. ~

MCh[ ~

(curies / recs) or when the $9Qi j$ $

7 seple rels.

r=,

4

..M d* 3t&#@

[e(a E

4 were presented.,oracomp?5W'$nsb... :p -

Q$ W-l arisonni

?'

lsu evaluation of the $

cur;mulQI an'iQ % d ' yegi,mpac jf.@

n g-At a

~

"1@N!

.7. NM prortram was not includ'idQM Hitication mcasures'w.?M M N M

"[.

~

El@f I

ere-developed onvironmentn1 inpncts.'Thenmaj % Yk Q.oritCbfG:y$

W %&$T.Wj 1

3 e.se we

.;-l g g K.:n. A. n y wy ; A. sm,..

.4

,.. s 7

design of the facility itself. and' ope.ratek.,;,t.h,rR95

... - ~.. -

n.,.:s%m.; %@<w;t.Mw

+ ~ ~ '

f minimization of environmethiaf.i.'m6acis7'$UMi'adm L.

5

-Q n..n s wr. -

.. g ys'pf,af,*pi Q. g* QAL,As,,.

n developed he sed on monitoring:.w@ rot rsms,to)

~~

6 willl.

p e

,y-MR..:..s.:Q;,"R:' ;- 5 i

i.

~

n s

.'Qw.k$l1&:l5

?

A

, n.,r w..w,5 p c p

.g,

ns,

wam y.$

i u...

-6,

impa' cts. The prenarers did n very thorouch iob in matchinr mitign-tien measures Oc noten7iel inprets.

Two potential environnental impnet areas which deviated from this genernllir fcetual, analytien1 discussion of impacts, were jI/b25 those'of the uranium fuel cycle as well as the deconmissioning of the plant once its operating life is over.

Discussion of the impnets of the fuel cycle contored around theoretical design criteria incorporated by reference to optomistic 4 e.la6,.c NRC rules and research documents.g/ Actual experience in storage, reproces.sinr, and weste manngement would heve boon very useful.

Socio-economic impncts of 't.NP-3 should have been expnnded toMb include. discussion of the regionel 'enste menagement costs, decem-missioning impacts.

Finally, scenarios of three types of accidents (frecuent and infrecuent events, and a nuch less probable limitinP fault) were very interestin;" nnd well exnlaihed. The methodology for conduct-ing the 'lorst Case analysis seemed very occurote and scientifically reliable. Mitigation measures were propoced-to rectify and com-pensate the impacts of even the low probability / high risk events.

In conclusion, I would like to argue that the 'dHP-3 DMS is adequate but not really necesnary as n decision-making tool. An alternative to. going ahead with the operation o f the facitlity was never presented. It does not provide the type of comparative evnluation EEP!. encourages. Also, the licensing procedures re-cuire more stringent evnluations than were contained in the DES, (ex. Safty Evalu-tion' Report). The document does not seem relevant to the egency decision. In many resnects, the Environmental 3tatement I-

e o

c, g

m

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

2here is a procedural contradiction with the HRC ih'their implementation of NEPA which limits the usefulnens of this doc-ument. This stems from the duai role played by the DE3. Firstly, itreviewstheoperntionalstageof'projectdevelopment.3utat[7M the time of the review, the plant was not complete, ~the redwaste 7M system was not fully evalunted, the financial state and-ownership of the plant were even in question, and there is no national con-census on the management of high-level rcdioactive wastes. This leads me to feel the operational. review is premature.-

The second pur,ose of'this DEU is to identify and evaluate chances in the project since the construction stage of review in 1975. It acts as a supplemental EIs, but unlike a supplemental lI.3, the NRC procedures hevqeliminated-the re-evnluation of fundamental circumstances, es in this case, a determination of

~

tho need for a project.

If the n23 is to act as a sunplement, then all altered environmental circunstanc,es should be open for review. If it is specifically concerned with the operating license stage of the program, environmental review should be conducted at a time when basic conditions are known to CF3 Parts 1500-1508 N2?A Regulations Draft 2nvironmental Statement p. elated to the Operation of W7PSS I:uclear Project No.3, NUREG-1033, U.S.URC: December,1983 Federal Re#ister, Vol 49. No 10: January 27, 1984

n 1

(,_ ?

{:;

Dobastian Degens g4

\\',

4515 sis Madison Portland, OR 97215 liuclear Regulatory Commission

-jj J

i, 11 atomic Building i

/~.

tV 1717 II Street 11W I

g

(,}/ tvfth Washington, D.C. 20555

/

v s

L li,1,Ill n l l. I,l.,1,l...It,I

,s t

.c e

r 4

Docket No.: S0-508 m 13 W APPLICANT: Washington Public Power Supply System (WPPSS)

FACILITY:

Washington Nuclear Project. Unit 3 (WNP-3)

^ Q:"

e

SUBJECT:

Sutt1ARY OF MEETING s

On September 26-30, 1983 staff and applicant representatives met at Ebasco Services Incorporated in New York for the WNP-3 structural design audit. A copy of the meeting notice and a list of attendees are enclosed (Enclosure 1 and 2. respectively).

The applicant presented a brief description of general structures at WNP-3 (Enclosure 3). The audit was conducted in accordanca to NUREG-0800, Standard Review Plan, Appendix ~ B to Section 3/8/4 as outlined in the meeting agenda.

WNP-3 structural design audit report of findings was transmitted to the applicant by letter, dated November 2, 1983 Ori Ann.Cinal silned by-ette Vetu l

Annette Vietti, Project Manager Licensing., Branch No. 3 i

Division of Licensing

Enclosures:

As stated cc: See next page e6, o

se' m

wuE'230398 840213 PDR ADOCK 05000508 A

PDR o 1 8,3......

- ~ +.' N..l.f.......j....i...e.n...

g/84 2

= ^ " >2/.f84

,p WNP 3 s

Mr. D. W. Mazur Managing Director Washington Public Power Supply System P. O. Box 968 3000 George Washington Way Richland, Washinoton 99352 o

Nicholas S. Reynolds, Eso.

DeBevoise & Liberman 1200 Seventeenth Street Washington, DC 20036 G. E. Doupe, Esq.

Washington Public Power Supply System 3000 George Washington Way

~

Richland, Washington 99352 Mr. Nicholas D. Lewis, Chairman Energy Facility Site Evaluation Council Mail Stop PY-11 Olympia, Washington 98505 Mr. Douglas Coleman Washington Public Power Supply System P. O. Box 1223 Elma, Washington 98541 Resident Inspector /WPPSS 3/5 c/o U.S. Nuclear Reagulatory Comission P. O. Box 545 Elma, Washington 98541 Regional Administrator - Region V U.S. Nuclear Regulatory Commission 1450 Maria Lane Suite 210 Walnut Creek, California 94596 Mr. Eugene Rosolie, Director Coalition for Safe Power 410 Governor Building 408 Southwest Second Avenue Portland, Oregon 97204 Nina Bell Nuclear Information & Resource Services i

1346 Connecticut Avenue, N. W.

Washington, D. C.

20036

STRUCTURAL AUDIT SEPTEMBER 26, 1983 NAME AFFILIATION Annette Vietti NRR/DL/PM George Lear NRR/DE/SGEB Dinesh Gupta NRR/DE/SGEB Owen Rothberg NRR/DE/SGEB Robin H. Wang EBASC0/ Civil Engineering Michael Yates EBASC0/ Project Manager Jack Werle Supply System / Project Engr. Manager SangBo Kim NRR/DE/SGEB Rene Alexandru EBASC0/ Civil Engineering Sufian Khondker EBASC0/ Civil Engineering.

M. H. Ismail EBASC0/ Project Engineering E. S. Kowalski EBASC0/ Civil Engineering Art Moore Supply System / Licensing K. P. Chang EBASC0/ Civil Structural Design D. Simpadian EBASC0/ Civil Engineering M. Hsieh EBASC0/ Civil Engineering i.

g G. Han (sit in for K. T. Wu)

EBASC0/ Civil Design Engineering H. Worchel EBASC0/ Project Engineer T. Cheung EBASC0/ Applied Mechanics Lon Resnansky EBASC0/ Applied Mechanics I Dennis J. Chin EBASCO/ Project Licensing Engineer Char 1Ibs Leute EBASC0/ Civil Engineering Howar6 Lewis EBASC0/ Quality Assurance (Project)

Robert C. Iotti EBASC0/ Applied Physics Don Lagrou Supply System / Chief Mech / Civil Engr l

Paul Christofakis EBASC0/ Nuclear Licensing Engineer 1

Joseph Porroueccho EBASC0/NL

m+o+m e

4 T

.~

FEB 131984 Docket No.: 50-508 APPLICANT: Washington Public Power Supply System (WPPSS)

FACILITY:

Washington Nuclear Project, Unit 3 (WNP-3)

SUMMARY

OF MEETING On August 19, 1983, staff and applicant representatives met to discuss the physical security plan and to tour the WNP-3 plant site. A copy of the meeting notice and a list of attendees are enclosed (Enclosure 1 and

2. respectively). The entire information exchange was completed on August 19, 1983.

The purpose of this initial site visit was to fulfill the requinaments of 10 CFR 73.55. This site visit was held in accordance with NUREG-0800, Standard Review Plan, Section 13.6.

The meeting and site tour were closed to the public.

Topics discussed included the impact of the Safety / Safeguards recommendations, NRC guidance concerning " pass back systems", other elements of the physical security plan and the subsequent SER statement.

During the site tour, the impact of the cancellation of Unit 5 was reviewed in detail.

There were no major safeguards issued identified as a result of this meeting.

(The applicant has subsequently submitted revisions to the safeguards security plans).

^!ginal signed by:

Annette Vietu Annette Vietti, Project Manager Licensing Branch No. 3 Division of Licensing

Enclosures:

l As stated cc: See next page 0" :::938B"BVd'201 PDR ADOCK 05000508 F

PDR g

omc'h#3,:0,L,,,,[. Lh ( DL,,,,....

""*> h.'.^

.. 9.h.t.o n,,,

one) a/io/84

./. 84 ite r i Me a i

1 i

% *aa

• - a O FP OI f I NPOO D

OONS#

9 ' '

e

.s

%e WNP 3 Mr. D. W. Mazur Managing Director Washington Public Power Supply System P. O. Box 968 3000 George Washington Way Richland, Washington 99352 Nicholas S. Reynolds, Esq.

DeBevoise & Liberman 1200 Seventeenth Street Washington, DC 20036 G. E. Doupe, Esq.

Washington Public Power Supply System 3000 George Washington Way Richland, Washington 99352 Mr. Nicholas D. Lewis, Chairman Energy Facility Site Evaluation Council Mail Stop PY-11 Olympia, Washington 98505 Mr. Douglas Coleman Washington Public Power Supply System P. O. Box 1223 Elma, Washington 98541 Resident Inspector /WPPSS 3/5 c/o U.S. Nuclear Reagulatory Commission P. O. Box 545 Elma, Washi?, vion 9G541 Regional Administrator - Region V U.S. Nuclear Regulatory Commission 1450 Maria Lane Suite 210 l

Walnut Creek, California 94596 Mr. Eugene Rosolie, Director l

Coalition for Safe Power 410 Governor Building 408 Southwest Second Avenue l

Portland, Orecon 97204 l

Nina Bell

(

Nuclear Information & Resource Services l

1346 Connecticut Avenue, N. W.

Washington, D. C.

20036 I

l

-