ML20205Q081

Comments on Des for Decommissioning of Humboldt Bay Power Plant,Unit 3.NEPA Requires Consideration of Listed Comments in Final Document

ML20205Q081
Person / Time
Site:	Humboldt Bay
Issue date:	05/25/1986
From:	Lancaster L AFFILIATION NOT ASSIGNED
To:	Erickson P NRC
References
FRN-51FR15853 NUDOCS 8605280154
Download: ML20205Q081 (4)

Text

Jo cwe7 AIO SD - /33 Larry Lancaster 1433 School Rd.

NcKinleyville, Col.

95521 (707) 839-2047 Nog 25,1986 Mr. Peter Ericson Project Director, United States Nuclear Regulatory Commision 1717 H Street NW Washington, D.C. 20555 Deer Mr. Ericson, i i have reviewed the document titled Draf t Enviornmental

) Statement for decommisionino of Humboldt Bou Power Plant. Unit 3..This document seems to overlook some rather substantial considerations and impacts. I hope to indicate to you these shortcomings. NEPA requires that you consider and address them in the final document.The following

comments are submitted to you within the prescribed time frame for public comment. Please oddress these comments

(

I I A. No other agencies were actively involved in the f preparartion of this document, why is this? It seems that there are several jurisdictions that are to be of fected.The Fish and Wildlife Service and California Coastal Commision are two agencies that would have to deel with impacts should en occident occur. Does NEPA provide exclusive jurisdicton in cases such as this? If so, please cite it specifically or justify your decision to prepare this document alone.

D. I wish to cc11 into question your assumptions that the spent fuel rods must remain on site.Since this porticular assumtion hinges on interpretation of low and policy, I have 2 points to be made:  !

g, 1) Radiation has decomposed to a smaller quantity and ggg is almost as safe to handle and transport.The half life of '

88 radioactive lodine 131 is 8.05 dogs. There has been little or no activity in

$8 the reactor for 9 years, so the levels of this radioisotope should be u negligible at this time. As for the radioactive Cobolt,it's half life (10.8 h

g<

years), hos already been achieved once for the majority of spent fuel. Isn't this true? If so, then please state how much editional mass would actually 8e be diminished over the thirty year period? What quantity of radiation 4

$2a would be decomposed at the site? It might be helpful if you indicated the octual mass of the spent fuel now and in 30 years. [D

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2)The federal repository might be required to accept the spent fuel if an accurate geologic profile were presented in this document. The geologic instability of this crea is a well known fact and due to this, the nuclear site hos etways been threatened with on

' occident. In my opinion, we have been lucky that no spillage of contaminated water or disarrangment of spent fuel rods has occured.This unstable condition should merit a re-evoluotion of your assumption that this is a safe place to keep nuclear westes.

C. page 3-9, section 3.2.3.2. Listed in this section are EPA projected dose levels" of radiation that are acceptable.Mg question is: Are these levels indicating accepteble working risk levels or community risk levels.There is a substantial distinction to be made here, os the working risk levels can be as much as 1000 times the acceptable community level of exposure.This needs to be clarified because those -

exposed in the cose of on occident may well be the high risk populations

( pregnant women, old and goung as in item D).

D. The reality of the SAFSTOR alternative is that it leaves y

a community at a higher level of risk for a longer period of time, with none of the associate benefits. My specific concern here is for the public elementary school located 1/4 mile from unit 3. Nowhere is this school mentioned. In your document you have neglected to identify what members of the populus are the at highest risk. I submit to you that these students are at the greatest risk in both routine and accidental exposure scenarios.Their continued vulnerability to the occasional relesoses of radiation into the atmosphere is a serious concern. I wish to know what mitigations are of fered to minimize the exposure to these childeren and adults of South Bay Elementary School. Thesestudentsare uctmp enormh ta be hipjt! u swinereble to the effects of rndictiott Were gour figures on radiation releases,in worst case scenario, taking into account age / sex /proxemity of the students, to the plent? How about in " routine releases" during the SAFSTOR and deleged DECON phases? Please be reminded that the school is due east (down wind) of the power plent.

E. There is a great need for more adequate information on the geology within this report. Nowhere in the report is there en ocurate profile of the geologic structures and f aulting of the Humboldt Bog region. In several instances (i.e. item 3.2.3.4.), you refer to the possibility of seismic activity. How will a reviewing agency be able to qualify (and quantify) the potential magnitude of seimic activity,if no '

documentation is provided? The Sen Ae/Tasfeuitis only a 30 miles away.

The SalmonFlat Fault 1ies 3-5 mi1es from unit 3. TheFreshwelerFeult . .. ..

i lies within 10 miles of the site. I counted over 20 faults within 50 miles l' of the plant, and these were only the bigger ones. I lived here during on earth quake that registered 6.9. on the Reichter scale.The result to my house was fractures in the walls, objects being dislodged and a violent thrashing. Another one knocked down a highweg overpass that lies within 3 miles of the reactor site. In light of this, I of ficially request that the study of geologic impacts be reviewed and modified with more complete f information presented in the final document.

Finally, a few points to help clarify the document:

F. Please be consistant in your method of describing figures.

Use scientic notation or don't, but mixing the two throughout the statement makes it more difficult to ossess relative values.

G. Please insert a diagram of the racks used to hold the spent fuel rods.Those of us who don't have ready access to the design of the structure con better evoluote their ef fectiveness,in this way.

As you may have surmised, I am opposed to the idea of storing the spent fuel here in Humboldt County. I am concerned that the lead agency and the utility expect residents to remain sedate os occured in the late 1950's when this project was initiated. It seems that we have been the Gineau Pigs for the nuclear industry and that we shall again be the stage to find out the perameters of that some industries ability to influence government policy. In light of the fact that the Nuclear Regulatory Commision has never prepared an impact statement on this subject,it is very important that your egency cover all aspects of this issue.This document will set the precident for future decommisioning processes. If this statement is not completely thorough, it will have serious ramifications to ours and the generations to come. My comments are not meant to be personal jobs, but on indicator of the frustrollon felt by this life time resident of Humboldt County.Thank you for your time and ottention to my comments on this most important and personal issue. If you have ong questions or need some clarification, feel free to contact me.

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