ML19277G451
| ML19277G451 | |
| Person / Time | |
|---|---|
| Site: | Satsop |
| Issue date: | 03/06/1984 |
| From: | Fitch W WASHINGTON, STATE OF |
| To: | Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 8403120174 | |
| Download: ML19277G451 (3) | |
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Subject:
D af t Environmental 5:a:emen - Tashinnen Nuclea.- ?rcect Nc. 3 Gent!emen: Thank you :or :ne opper unity :o commen on the Draf: Eh.ironmental 5:.:cment (DES) prepared by :he U. 5 Nuclear Regu'atory Commission (NRC) related to the opera:!cn of Washington Public Power Supply System Nuclear Project No. 3 (TNP-3) (NRC Docket No. 50-508). The DES presents NRC's assessment of the various environmenta!, economic and technical impacts, both beneficial and adverse, associated with the issuance of an operating liceniIe for WNP-3. Because of NRC's unique requirements for environmental statements at both the construction and operating stages, this DES examines any changes or new information that have occurred since the construction permit stage environmental s:stement was issued in 3une 1975. On October 27, 1976, the state of Washington issued a Site Certification Agreement to the Washington Public Power Supply System (Supply System) to construct and operate WN P-3. The Site Certification Agreement sets forth the license condi: ions under which WNP-3 is to be safely constructed and operated while minimizing adverse impacts to the greatest extent possible. The Energy Facility Site Evaluation Council (E.:5EC) admini-sters the certifica:icn agreement through a comprehensive moni:oring program that ensures compliance with the environmental regulations, public health and safety standards and the other terms of the license. In view of the shared federal-state licensing responsibilities for nuclear facilities, the Council is very much interested in NRC's updated assessment of the impacts associated with an operating project and their relationship :o our already existing license and permit conditions. The Council has reviewed the information presented in the DES and finds that the document accurately describes project conditions and impac:s as they existed in :he originallicensing considerations, as they have evolved over the initial construction period, and as they are forecast during operation of the facili y. The staternen provides a thorough explanation of the potential environmental, technical and social impacts of the project and we concur with the determination " hat TNP-3 can be opera:ed wi:n minimal. environmental impact." The following comments are provided on specific sec: ions of # DES. s 4, w-s
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Direc ct, Division of Licensing Page 2 Marcn 6,19S4 Section 2.1 Proiect Descriotion Resume - Te vould agree :ha: :he majcr chan:;e since f.e C? s: age is the cancella: ion of N N P-5. Thi!c :he requirements : r TNP-3 remain essentially ne same from the earlier review, mr.ny of the Ilcense conditions were basec N on the two units operating at :he site. Ti h only one uni: now planned for coeration, many of the projections for usage, design capacities, effluen: amounts, etc., have been reduced significan !y and have lessened the potential for impact. Section a. /a:er Use and Trea: ment - The s:a:emen: Occura:L/ :accr.bes the s:a:e's requirements f or wa er wt:hcrawal, ther nal discharges and desn;n cnanges made in :ne g g4 discnarge diffuser and cooling system since :he CP stage. Section 5.3.1 **/ater Ouality - Under the s:ste's National Po!!utan: Discharge Elimina !cn Sys:em I.NPDF.5) Permit, :ne Supply 5ys:em was .equired to c:ncac: si:e s ecific, f!cw-through bicassays on !ccal salmonids to assess the toxic levels of cop;;er and zinc, both g g h singly and in combination, during differen: times of the year and with different life stages. The results of the bioassay studies are now available and should be included in the final statement. Te appreciate the opportunity to comment on the DES and look forward to working with the NRC as you proceed with license proceedings for WNP-3. S. ,in _ rely,
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Y' ni sam L P~i / w[-rv c,.c - E .ecutive Secretary TLF:ke ' bec: Barbara Ritchie e
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' ;4cus Tsows arecor sTeE or u e NcTcN OFRCE OF ARCHAEOLOGY AND HISTORIC PRESERVATION m n est T.sentv-Firs: M enue. u- 11 . Oirm=a trasneg:on H5 a e ;. % .~53 2u11 Februarf 22, 1984
-2E' 2-11934 Ler c.i . -: OF ECOLOGY Ms. Barbara Ritchie h* EPA Coordinator Dept. of Ecology Mail Stop ?V-11 Oly= pia, k'A 95504 Eog
Reference:
!.49-7-NRC-01 Re: 47PSS No. 3 Draft EIS
Dear Ms. Ritchie:
A staff review has been completed of the above referenced draft envi-ronmental impact statement. The document adequately considers known p and anticipated cultural resources and the potential for impact to- - these. Thank you for this opportunity to comment. Sincerely, b'h Robert G. kiitlam, Ph.D. State Archaeologist dw e e e
Sebastian Degens 4515 SE Medision Portland, Gregeon 97215 Portland March 15, 1982 US Huelear Regulatory Commission Matomic 3uilding 1717 E Street HW Uashington, D.C. 20555
Dear Concission Members,
Enclosed is a lengthy con ent on EIS Ho. 840014, concerning the operating licence of WFPSS No. 5 in Grays Harbor County in Washington. I realize my co= cent 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 term at Fortland State University. The class was ' Environmental Impact Assessment' and in the enclossd critinue, I point to some of the strengths and weaknesses of this particular ZIS, based upon a reading of assessment itself, H3?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 co=es out on this project. Thank You, N / r
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The proposed action which renuired the Rr2'.t ES B'leted ;p th.e Cneretion of the WPPCS Nuclear Project No.5 (DES-OL) is the isauance of an operating license to the Uashington Public Power Sunply System (WPPUG) for start-up and opera tion of its nuclenr project no. 3 (WPN-3), located in Greys Harbor County, WA. The project consists of a two-loop pressurised water reactor (P'ciR) with a pro,iected electrien1 output of 1240MW. A conling tower and pumping station to draw water from an anuifer below the Che-halis River are included on the 2570 acre site. The U.G. Nuclear Regulatory Commission (URC), and its staff in the Of' ice of nuclear Reactor Regulation prepared j the docume. . in response to an application for nn operatine license for thin facility from the URC. The projected water withdrawals as well as the radioactive emissions by the facility clearly make this e Federal action significnntly affecting the nunlity of the hum"n environment (3 1502.3). The statutory renuirements for an EIG cre met. WPU-3 was 75.' connlete st t.he time of ap-lication for the operating license. Construction delays since thnt time have push'd the anticipated fuel-loading date into 1987-1089. The staff noted that this DES could therefore be issued up to six years prior to the fuel loading date. This constitutes an unusual'.v early issuance. It was the staff's judgement that -he facility's operational characteristics were sufficiently 1:nown to ,alla u . the present assessment. (WUP-3 DES, 1-2). ~ The LE3 is dated December 1983. The notice of Availability
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(CO/.) was pohli hed by the Invironmental Protecclon .gency in the ?ederal Recister on Fridny, Jnnuary 27,1984 ([R; Vol 49. :70 19). A 45 day content periou was scheduled endini on Earch 12. ?. copy of tiis critinue has been submitted.
"RC licensing procedures for nuclear power plants are sep-orated into distinct phases. 'Phe NRC hns tiered their environmental statements to correspond with the construction and operating strges. 7his enrtles "... focus on the netun1 isnues ripe for decision .e.t each level of environmental review." (!51502.20) 7he purpose of the DES-OL is to center on i~ sues specifically related to the operational system of the nuclear plant. An ad '
ditionc1 purnose emerges in the text. The DES-OL evaluates design chon es in the project which have occured since the time of the Final Environrental ;tatecent on the construction permit (FES-CP). The bulk of the desis7n end environnentnl imnnet information is contained in the FES-CP wri ten in 1975. This information is summarized in the DEC text,and encorpornted by reference. Tiering has o number of important implientions for the DES. First, it is physically shortened by the ability to reference the document in tko previous stnge in the process. More importnntly, the range of isnues covered is also reduced. The HRC has interpreted tiering to obviete evaluations of the need-for -power issues during the operntion-license phase. Discussion of the need-for-power issue has occured durinr the construction permit stege and is considered resolved.. . The :IRC has assuced that nuclear power plants cost lens to
cperste than fossil fueled plents. Uho :iRC cencludes that nucleer 7cwer would be n treferred energy cource, even were a reduction in dernnd to elininnte the need for nny ndditional genern. tion. C.I'II- 3 D E U , 2-1) !!eed for the proposed nction in eliminated oc or issue and barring special circunstances, the operating license is not cubject to a test of need. The logic of the environnantla review process, ns conducted by the EZC in tre licensing of nuclear power plants, t?us elininates a broad range of alternatives durinr the OL ctage. Both nlternative g]) energy sources es well as alternative sites ere no longer relevant. Conmitted resources end the advanced stnge in the process have left no feasible alternatives and none are presented in this DES. Alternative plans of operation were not connidered, thou~h I feel they would have been apnropriate for comparison. Examples could have been alternative monitorinr progrnes for the surrounding
;g enrth, water, nnd nir resources. Also, in n?dition to mitigative renponses to wnter renoval.at times of low strene flow, nn op-perational plen which synchroniced refueling with all or part of
{ [{{[h the seasonel dry periods could hnve been presented. The existinc envircnnent was described adenuately in the LSS. Unchanged portions of the project were sunrariced from previous documents and referenced. A compnretive evaluation of the impncts of alternatives could not be undertnken in the absence of alternet-ives. Iiowever, design changes since the FES-CP had altered many impacts. These new impacts were discussed in r comprrative nonrer - with the initially nnt'icipated ones. The =cjor chnnge was the enneellation of n second unit,
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'JTFdd :!o. 5, '^ich hr.d boon rinnred for "hnt site es well. In meny respects
- his c5 r.re e f f'crded the DIS ruite n bit of leeway in the discussicn cf innects. For ex2mnle, 'dPr c. , increased its es-tirate fer the sulfuric acin r?nnirement to control scale in the circu'0'inr water system. There will be an acknowledged effluent inpact of sulfates on thc Chehalis River. This increase in the concentr' tion of culfr.tes was swept owny in the text with the recclection that the ;1snned second unit had now been scrapned and the resulting nabient concentrations for one plant were lower than had previcusly been projected for two.
Ifeelthistypeofanalysisismoreround-aboutthandirect.g{ghggy
'Jh'le it'is inrort t t,o knou that the sum of the impacts is lean th'n these creviously plenned, if the design changes represent cignificant elterations, ther should be described absolutely (ie.
?os cuch effirent renuits from one unit witti en increased renuire-ment of sulft ric neid?) . .
troublennte feature in the E:, w.rss a multiple referenceG tg., M e Safety Evr.lvreior Report (dTR) which is scheduled for release six months after the closure ddte for co ments on the DES. In /! appendix form, the water and air effluents were suncarized in an-ticipation of this report. The capnSility of the proposed radwaste system to acconodate the' solid wastes expected during normal opercticns was not evnlue.*;rd nor_ sunnnrized. This sects to me e significant omisaien. . , The 'n3 covered er. ; tensive set of'irnocts' both aF.alyticall r [ and in ceneise and.understnndeble innruere. The methodolo.-ies e i.4
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impncts. Zhe prernrers did n very thorouch , job in mntchinc citign-tion mensures :n noten7iel inprets. Two potentini cavircnnental innnet erens which deviated from this genernllv fretual, annlyticnl discussion of inpacts, were I'Jhb 25 those of the uraniun fuel cycle as well as the deconrissioning of the plant once its operatinr life is over. Discussion of the impnets of the fuel cycle contered around theoretical design criteria incorporated by reference to optomistic 6 FN'6"' " NRC rules end research documents./Actun1 experience in storage, reprocesninr, nnd weste canngement would have been very useful. Socio-economic impncts of ':.HP-3 should have been expnnded to include -discussion of the regicnnl vaste nnnagement costs, decom-SA b T.issicninc inumets. Finally, scenarios of thiee types of accidents (frecuent and infrequent events, end a nuch less Trobable limitinP fault) were very interes tin- 'nd well erninined. Ohe methodolory for conduct-ing the 'lorst Case analysis seeced very cenurate and scientifically reliable. Hitigation meecures were proposed- to rectify and com-pensate the irprets of even the low probability / hirh risk events. In conclusion, I would like to argue that the 'iUP-3 dig is adecuate but not really necesnnry es n decision-mckinn tool. I.n alternative to going ahead with the operation of the facitlity was never presented. It does not provide the type of comparative evnluetien EET!- encourages. Alno, the licensing procedures re-cuire more stringent ev,luations than were containeb in the DES, . (ex. Safty Evnlu-tion ~ Report). The document does not seem relevant to the ocency decision. In many rennects, the Environmental 3tetement
coces to late in the esce to metter and simply becomes a procedural hoop. 2here is a procedural contradiction with the liRC in'their i=plementation of liEP!. which limits the ucefulnenc of thic doc-utent. OPis stems from the dual role played by the JE:.s. Firstly, it reviews the oper7tional stage of project development. But at [2 A8 the time of the review, the plant was not complete, the radwaste 7 system was not fully evalunted, the financial ctate and ownership of the plant were ev n in question, and there is no national con-cer. sus on the management of high-level rtdioactive wastes. This leads me to feel tra operational review is premature. The second pur"ose of this D23 is to identify and evaluate ebences in the project since the construction stage of review in 1975. It acts es a supplemental EIS, but unlike a supplemental 31.:, the !!RC procedures hevqeliminated the re-ev,1uation of fundamental circumstances, es in thic cece, a determination of
- Pe need for a project.
If the E2.3 is to act as a sunplement, then all altered environnental 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 ere known a0 CF3 Parts 1500-1508 li2?A Regulations - - ; Drnft 2nvironmental Statement 0.elat2d to the Operation of t.CPSS i:ucleer Project !io.3, IIUREG-1055, U.S.HRC: Decenter,1983 lederal Pecister, Vol a9. No 19: Janunry 27, 1983
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