ML19350E890

Comments on Facility Des,In Response to NRC 810508 Ltr. Proposed Preoperational & Operational Aquatic Environ Monitoring Should Be Adequate to Determine If Further Mitigation Will Be Required

ML19350E890
Person / Time
Site:	Fermi
Issue date:	06/18/1981
From:	Hoffman C INTERIOR, DEPT. OF
To:	Youngblood B Office of Nuclear Reactor Regulation
References
ER-81-965, NUDOCS 8106230623
Download: ML19350E890 (3)

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United States Department of the Interior 9'30' OFFICE OF THE SECRETARY

, WASHINGTON, D.C., 20240 ..

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Mr. B. J. Youngblood, Chief J.,,, .t es ,.'gl g sa _,2,,.ea Licensing Branch No. 1 Division of Licensing u.M f

cu ,7; Nuclear Regulatory Commission s . \($,/

Washington, D.C. 20555 f3

Dear Mr. Youngblood:

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Thank you for your letter of May 8, 1981, transmi.tting copies of the draft environmental impact statement, . operating license stage, for the Enrico Fermi Atomic Power Plant, Unit 2, Monroe County, Michigan.

Our comments are presunted according to the format of the state-ment or by subject.

Ecology Concerns regarding impacts to fish and wildlife resources resulting from plan,t operation have been expressed previously in our comments on the, fin,a1 environmental statement for the coastruction permit and subsequent environment report supplements during the Operating Lic,ense ' Stage.

Our stated concerns over impacts of transmission line right-of-ways and u;ntrol of chlorine residuals have been addressed. The proposed preoperational and operational aquatic environmental monitoring should be adequate to determine if further mitigation will be required, especially in regard to intake impingement and entrainment af fish.

Releases to Groundwater An assessment of the consequences of seven hypothetical accidents on Lake Erie and Lake Ontario is only found under the section "Reluases to Ground Water" on page 6-25. Apparently the atmoart ric deposition of radionuclides in the lakes was not included in the assessment of atmospheric releases on pages 6-13 to 6-25. Since some of the accident sequences involve the release of substantial quantities of long-14ved radionuclides, the importance of assessing not only the health effects but also the environmental, social, and economic consequences of the entry of radionuclides fato the lakes should be ob'rious. The atmospheric deposition of radionuclides I

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p HMr. B. J. Youngblood- 2 should receive further' study at. Great Lake sites where a substantial fraction of radionuclides released

could be deposited in the 1skes.

The effects on-the lakes due to releases to ground water are primarily determined by.both the estimate of the rate of movement of the released radionuclides through the 460-foot distsace between the reactor and Lake Erie, and by the siza.of1the source terms for the.long-lived radionuclides.- The rate of movenant is dependent on estimates of

. ground water velocity and so-called ratardation. facto.rs. Although' numerical values for these are given on pages 6-27 and 6-28, the

, parameters used and assumptions made to arrive at these estimates are not ~ described. Therefore, it is notipossible to' evaluate whether the estimaces are adequately conservative.

The' source' term for the radionuc1' ides in the ground is apparently that.used in the Liquid Pathway Generic Study (NUREG-0440). There

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it.was limited to the prompt release of 15 percent of the-sump water; it did not. include. leaching from the core debris. The uncertainties concerning leaching rates were raised in the generic study, but there is;no indication in the present environmental statement that lasching of the core debris was assessed at this site. It is also not clear whether the asrumed prompt release of 15 percent of the sump water is an adequete represents;/on of the total release from this source that could occur in the aftermath of an accident.

It is indicated that the consequences in Lake Erie and Lake Ontario due to the. releases.co ground water would be largely sconomic or social. It is not clear that these effects have been evaluated and,'ifsso, whether they-are included in the estimates of costs shown in tablea 6.4 and 6.5 and'in-figure 6.6.

One of the findings of NRC's Independent Risk Assessment Review 4

. Group was that it is very difficult to follow detailed calculations through NRC's Reactor Safety Study. The assessment of severe accident consequences relating to Lakes Erie and Ontario is based in part.on that Reactor Safety Study, in part on the Liquid Pathway Generic Study, and in part on subsequent reports. We believe i- difficulties have been compounded. We recommend that calculations, ,

i estimates, and assumptions used to determine the entry into the l lakes be made available for review.

. Monitoring.of ground water during operstion should be specifically addressed. Water quality monitoring during oper4 tion is discussed L_ or page 5-7 br* it is not clear whether this will include monitoring '

j both quality ot ground water and water. levels. The hydraulic j gradients of the principal aquifer are fairly low; thus the gradients could" easily become changed and redirected by area development during the life of the plant. We suggest that oeriodic monitoring of ground wate r levels and radioactivity should be continued at appropriate l-intervals in wells properly located to detect any major change in gradients. -

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Mr.xB.-J... Youngblood.

3 Wo. hope'thesel. comments will be helpful to you.in the preparation

.: o f a . final -~: s tatement.' .

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- 'dN j , as s _ n CECIL S. HOFIMANN Speelal Assistant to assistants ECRETARY

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