ML20041F493

Comments on Des.Questions Raised Re Radiological Consequences on Water Supply Cost of Operation & Emergency Preparedness

ML20041F493
Person / Time
Site:	Wolf Creek
Issue date:	03/10/1982
From:	Moore A AFFILIATION NOT ASSIGNED
To:	Office of Nuclear Reactor Regulation
References
NUDOCS 8203170009
Download: ML20041F493 (3)

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1007 Alabama Lawrence, KS 66044 March 10,1982 A

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4 Nj}q blS$ga,27 Director, Divicion of Licensing k Nuclear Regulatory Commission E Washington D.C. 20555

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Dear Director,

Division of Licensing, ,,

I am writing in response to the Nuclear Regulatory Commission's invitation to interested percons to comment on the Draft Environmental Statement related to the operation of Wolf Creek Generating Station, Unit No.l. After a very limited reading of the Statement I make. the following oboorvationa and questions:

1) In there any way to protect the water shed which cupplies the drinking water for the City of Lawrence, Kansan from the consequences of a radiological emergency? With winda coming our way 38% of the time, will emissions from normal operating of the plant reach the Wakaruna Valley which is 35 miles north of WCGS?

2) In order to keep the radioactivity at a minimum in the water leaving the plant, thru trying to prevent denting and corrosion in the oteam generating tubes by the quality of the water which enters them, 10 there provision for continious and frequent reporting on the purity of the water to the NRC?

3) on page 5-44 the safety evaluation of the site includes a review of potential external hazards. Have the activities at the Richards-Gebaur Air Base couth of Kansas City, Miscouri been included in this review?

4) Will not the costs per kilowatt hour be greater than forecast if the life of the plant is actually shorter than the predicted 30 years? Based on the experience of other nuclear generating stations it ocems imprudent to expect that any where near full capacity production will continue for 30 years. This would make the coct/ benefit ratio quite different than presented in the DES.

5) Are the Emergency Preparednens plans that are already written and the State one which is in process workable? Will there be opportunity for public hearings on theoc emergency preparedness plans before they are accepted by the NRC7 Will the plans be approved before the reactor is loaded?

In the case of the Coffey County plan, how can the sheriff's force of 7 officers and 6 reserves who are volunteera possibly make the initial warning.within 15 minutes while still maintaining their workload within the County? How can 14 volunteer viremen be adequately trained to do the necessary monitoring of radioactive substances with cafety 8203170009 820310 00 PDR ADOCK 05000482 I !

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d to themceiven and otill keep performing their necescary duties? It doca acom like the coats of these added functionu should at least be borne by the utility company, rather than by the County which had no choice in the matter. The equipment necennary to meet the NRC's ex-pectation of a prompt (45 minute) alert within the 10 mile EPZ scemn to be lacking when you know of the existing fixed cirono and the use of mobile cireno. This in an example of the gap between what is written in an emergency preparedneno plan and what the actualities arc. That gap will effect the environment.

6) In Appendix F, pg F-3 there is mention of evacuating people moving under the cloud and moving in the came direction ac the cloud in moving.

Would it not make more acnce to have the people move away from the path of the cloud in a perpendicular direction no as to escape fallout?

7) An for coctc, why are not the cocts incurred by rate payers included in the calculations of coct/ benefit in the production of electricity?

8) I do not agree that the chort-term destruction of"5) the atmocphere and rater bodice used for dispocal of heat and certain waste effluents to .no extent that other beneficial unes are curtailed, and 6) land areac rendered unfit for other unca" (FE3-CP pg 10-8) in going to necessarily create long-term productivity. If one-quarter of our population already la at one time in their livec coing to have cancer, incroacing that proportion is not going to enchance long-term productivity and well-being.

9) The production of 12,000 cu ft of low-level waste every year at WCCS creates a problem for un for which there is no solution currently.

This is a problem that people have been trying to solve for over 37 years.

Granted this in a now technology, it still is not right to continue making more low-level radioactive wastes that rapidly when there is no way to cafely contain it. The amount of low-level wasto created at WCC3 annually will be 30 times more than the whole rent of the State producca. Even low-level radiation is detrimental to peopic's health.

I think that Wolf Crook Generating Station chould not go on line before there in a way to cafely deal with the wanto problem. This means both the low-level radioactive wactec ad the fuel rodo after they have ficcioned.

For neither in there a good wa.y of managing the radioactivity over the many years that io necoscary. (People 240,000 yearn from now may not be abic to read the cigna that indicate the danger of radioactivity even if we could find containcra to hold it for a chorter period of time).

10) The cont of decommiccioning is given in Table 6.1 ac 363 million in 1984 dollars. I understand that there is no way to really estimate how much decommincioning will coct, and a rough figurc used might be 10% of conatruction conta. If that is the cace, then it would be enti-mated at closer to $200,000,000. Would the NRC ctaff acacco thic an a cmall cont? For only one paragraph to be written on decommiccioning ccems not to correnpond with the concept of the limited number of years that the generating station will be of use in cupplying an alternative cource of electricity.

11) " Radiation docon to the public as a result of decommincioning activitica should be very omall and would primarily come from the trancportation of decommissioning wanto to wanto-burial grounds."pg 5-68.

Eccidea that time of expocuro of the public thru transportation of radio-active want, there is alco that of the annual transport of low-level wantos and cpont fuel rods from the cite. Since the health effects of radioactivity are cumulativo, exposing the public thru the chipment and accidents while being chipped, is not to be taken lightly nince it in a real coat to the individualc affected, and therefore should be included in your cost / benefit cummary.

12) I'm glad that it 10 recogniced that concervation io making a difference in the rate of incroace in the uno of electricity. It raicos again whether there in a need for cuch a large nuclear plant.

13) The remaining 20% of construction costa does not seem to be included in the overall coat / benefit cummary and might influence the decision as to whether or not to consider operating the plant.

As stated in the beginning of thic letter, I havo not read the Dd3 completely, but I do raine many questions about the conclusion which the staff reachen in 6.4 3, page 6-4 Sincorolyfis

~ " pw _

Anne Mooro

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