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{{#Wiki_filter:22. Brown and Caldwell, 1977. San Onofre Nuclear Generating 10, Lockheed Center for Marine Research (LCMR). 1978. San         Station Unit l, Environmental Technical Specifications, Onofre.Nuclear Generating Station Unit 1, Environmental       Annual Operating Report, Volume 1. Oceanography Data Technical Specifications, Annual Operating Report, Volume     Summary-1976.
{{#Wiki_filter::Do I
III -Biological Data Analysis - 1977. Prepared for         23. Brown and caldwell, 1978. San Onofre Nuclear Generating Southern California Edison Company, 125 p.                     Station Unit 1, Environmental Technical specifications,
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: 11. Marine Biological Consultants, Inc., 1978. Construction       Annual Operating Report, Volume 1. Oceanographic Data Monitoring Program, San Onofre Nuclear Generating Station,     Analysis-1977.
"-1 10, Lockheed Center for Marine Research (LCMR). 1978. San Onofre.Nuclear Generating Station Unit 1, Environmental Technical Specifications, Annual Operating Report, Volume III -Biological Data Analysis - 1977.
Units 2 and 3, December, 1976- December, 1977. Prepared   24. Brown and Caldwell, 1977. San Onofre Nuclear Generating for Southern California Edison Company, 78RD-21. n.p.         Station, Unit 1, Environmental Technical Specifications,
Prepared for Southern California Edison Company, 125 p.
: 12. North, W. J., 1960. The effects of waste discharges on         Annual Operating Report, Volume III. Oceanographic Data kelp. University of California Inst. Mar. Res., IMR Ref.      Analysis-1976.
: 11.
: 12.
: 13.
: 14.
: 15.
: 16.
: 17.
: 18.
: 19.
: 20.
: 21.
Marine Biological Consultants, Inc., 1978.
Construction Monitoring Program, San Onofre Nuclear Generating Station, Units 2 and 3, December, 1976-December, 1977.
Prepared for Southern California Edison Company, 78RD-21. n.p.
North, W. J., 1960.
The effects of waste discharges on kelp.
University of California Inst. Mar. Res., IMR Ref.
b0-4:1-44.
b0-4:1-44.
: 13. North, W. J., 1976. Introducing warm tolerant Macrocystis to the vicinity of a thermal discharge.
North, W. J., 1976.
Summary report of the 1975 activities. 64 p.
Introducing warm tolerant Macrocystis to the vicinity of a thermal discharge.
: 14. North, W. J. and C. L. Hubbs, 1968. Utilization of kelp-bed resources in Southern California. California Department of Fish and Game, Fish Bull. (139):1-264.
Summary report of the 1975 activities.
: 15. Phillips, R. C., 1974. Kelp beds in : Coastal ecological
64 p.
:Do systems of the United States. The Conservation I      Foundation, Was~!ngton, D.C., Volume II, pp. 442-487.
North, W. J. and C. L. Hubbs, 1968.
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Utilization of kelp-bed resources in Southern California.
"-1 16. Scripps Institute of Oceanography (SIC), 1978a. Surface water temperatures at shore stations - U.S. West Coast, 1977-1976. SIC Ref. 78-5. 77 p.
California Department of Fish and Game, Fish Bull.
: 17. Scripps Institute of Oceanography (SIC), 1978b. Surface water temperatures at shore stations - U.S. West Coast, 1977. SIO Ret. 78-16. 45 p.
(139):1-264.
: 18. North, W. J., 1958. The effects of waste discharge on kelp. University of California Inst. Mar. Res., IMR Ref.
Phillips, R. C., 1974.
Kelp beds in : Coastal ecological systems of the United States.
The Conservation Foundation, Was~!ngton, D.C., Volume II, pp. 442-487.
Scripps Institute of Oceanography (SIC), 1978a.
Surface water temperatures at shore stations - U.S. West Coast, 1977-1976.
SIC Ref. 78-5. 77 p.
Scripps Institute of Oceanography (SIC), 1978b.
Surface water temperatures at shore stations - U.S. West Coast, 1977.
SIO Ret. 78-16. 45 p.
North, W. J., 1958.
The effects of waste discharge on kelp.
University of California Inst. Mar. Res., IMR Ref.
59-1:1-27.
59-1:1-27.
: 19. Southern California Edison Company, "Biennial Forecast of Electric Loads and Resources Report," March 17, 197o.
Southern California Edison Company, "Biennial Forecast of Electric Loads and Resources Report," March 17, 197o.
: 20. Southern California Edison Company, "Revised Resource Plan submitted to Energy Commission," September 22, 1976.
Southern California Edison Company, "Revised Resource Plan submitted to Energy Commission," September 22, 1976.
: 21. North, w. J., January 25, 1979, letter to Mr. T. Sciarrotta, Southern California Edison Company.
North, w. J., {{letter dated|date=January 25, 1979|text=January 25, 1979, letter}} to Mr. T. Sciarrotta, Southern California Edison Company. 22.
      ,......~
Brown and Caldwell, 1977.
      ~               UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION IX 216 Fremont Street Water Quality Comments
San Onofre Nuclear Generating Station Unit l, Environmental Technical Specifications, Annual Operating Report, Volume 1. Oceanography Data Summary-1976.
: 1. In Section 5.3.1.1., some assessment is made of the San Francisco. Cs. 941 06                       effects of the discharge of heated cooling water on the receiving coastal waters with regards to the Project t D-NRC-K06002-CA                                                       California State thermal standards. When evaluating thermal discharge, all effects of Units 2 and 3 should William H. Regan, Jr., Chief                                                   be considered in conjunction with the effects of Environmental Projects, Branch 2                                               Unit 1. The natural background is a situation where Division of Site Safety & Environmental                                         none of the three units is operating. The natural Analysis                                                                     receiving water temperature as defined by California u.s. Nuclear Regulatory Commission                                             Thermal Plan (see next paragraph) is *the temperature washington, D.c. 20555                                                         of the receiving water at locations, depths, and times which represent conditions unaffected by any elevated
: 23.
Brown and caldwell, 1978.
San Onofre Nuclear Generating Station Unit 1, Environmental Technical specifications, Annual Operating Report, Volume 1. Oceanographic Data Analysis-1977.
: 24.
Brown and Caldwell, 1977.
San Onofre Nuclear Generating Station, Unit 1, Environmental Technical Specifications, Annual Operating Report, Volume III.
Oceanographic Data Analysis-1976.
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION IX 216 Fremont Street San Francisco. Cs. 941 06 Project t D-NRC-K06002-CA William H. Regan, Jr., Chief Environmental Projects, Branch 2 Division of Site Safety & Environmental Analysis u.s. Nuclear Regulatory Commission washington, D.c.
20555  


==Dear   Mr. Regan:==
==Dear Mr. Regan:==
FEB 131979             temperature waste discharge*. Unless Units 2 and 3 are not planned to operate concurrently with Unit l, their effects will occur in concert. All modeling, the SAN          graphs, and maps produced from models should include 3,  sotiTHERN    Unit l effects when evaluating SONGS' effects on the TRIC          receiving water temperature.
FEB 131979 the SAN 3, sotiTHERN TRIC EPA's comments on the draft environmental statement have been classified as Category ER-2.
Under Section 316(a) of the Federal water Pollution control Act of 1972 (FWPCA) and under the water
Definitions of the categories are provided on tne-inclosure.
=r    EPA's comments on the draft environmental statement have been classified as Category ER-2. Definitions of the                            Quality Control Plan for Control of Temperature in the coastal and Interstate Waters and Enclosed Bays and
The classification and the date of EPA's comments will be published in the Federal Register in accordance with our responsibility to Inform the public of our views on proposed Federal actions under Section 309 of the Clean Air Act.
~    categories are provided on tne-inclosure. The                                  Estuaries of California (1975 Thermal Plan} (EPA classification and the date of EPA's comments will be                          approved State water quality standards), there are published in the Federal Register in accordance with our                        several criteria which discharges to coastal waters responsibility to Inform the public of our views on                            must fulfill. These should be addressed in any EIS on proposed Federal actions under Section 309 of the Clean                        operating a new coastal.discharge of elevated Air Act. our procedure is to categorize our comments on                          temperature wastes. These are as follows:
our procedure is to categorize our comments on both the environmental consequence of the proposed action and the adequacy of the environmental statement.
both the environmental consequence of the proposed action and the adequacy of the environmental statement.                                a. In part 3.B.(3.) of the Thermal Plan, it is EPA appreciates the opportunity to comment on this draft                            stated that *the maximum temperature of thermal environmental statement and requests three copies of the                             waste discharges shall not exceed the natural final environmental statement when available.                                         temperature of receiving waters by more than 2o*r.* Part 3.2.2. of the DBIS states that the If you have any questions regarding our comments, please                            cooling water *experiences an ll.l°C (20°F) contact Betty Jankus, EIS Coordinator, at (415)556-6695.                            temperature rise across the condenser.* Since the waters in the vicinity of the intakes for Sincerely,                                                                          Units 2.and 3 are close to the discharge structures for these units, it is possible that these intake waters are already heated beyond
EPA appreciates the opportunity to comment on this draft environmental statement and requests three copies of the final environmental statement when available.
      <a..*:l.cd"f'( ~~                                                                    their natural temPerature. SOme evaluation of
If you have any questions regarding our comments, please contact Betty Jankus, EIS Coordinator, at (415)556-6695.
  ~Paul      De Falco, Jr.                                                                 this effect must be included in the FBIS. The ib Regional Administrator                                                                influence of the heated discharge from Unit 1 must also be described. In addition, the intake Enclosure
Sincerely,
                                                                *greater respiration rates", also, "significant and discharge facilities and their depths and bow        effects should be localized". For fish, the temperature stratification profiles relate to the         effects will be mainly "shifts in the types of 20&deg;F requirement should be discussed.                    species (and their numbers) which inhabit the area*. For benthic fauna, adverse effects may be
<a..* :l.cd"f'( ~~
: b. In Part 3.B.(4) of the Thermal Plan, it is stated        expected if *weekly mean temperatures of 22"C that "the discharge of elevated temperature              prevail for one month or more or where daily wastes shall not result in increases in the               temperatures reach or exceed 24&deg;C. It is not, natural water temperature exceeding 4&deg;P at (a)            however, anticipated that temperatures averaging the shoreline, (b) the surface of any ocean              22"C will occur for more than 2 to 3 weeks or substrate, or (c) the ocean surface beyond 1,000          that the area experiencing temperatures of 24&deg;C feet from the discharge system. The surface              or greater as a result of SONGS operation will be temperature limitation shall be maintained at            considerably larger than the area experiencing least 50 percent of the duration of any complete          these temperatures under natural conditions".
~Paul De Falco, Jr.
tidal cycle.* Figure 5.3 of the DEIS represents          For kelp, the information *suggests that tbe projected incremental increases above natural            thermal discharges from SONGS 1, 2 and 3 may surface temperatures for the study area. This            result in the destruction of at least a portion figure should be changed in the FEIS to include          of the San Onofre Kelp Bed during the summer the Unit 1 intake and discharge structures and           months~. All of these statements indicate that the increase of surface temperatures already             the indigenous populations will be altered, caused by Unit l discharges in conjunction with           giving no specific documentation that these those of Units 2 and 3 so as to compare the              effects will be minimal or acceptable. A increases with the true natural surface water             detailed evaluation of how the aquatic ecosystem temperature.                                             will be affected, over what area each species or
ib Regional Administrator Enclosure Water Quality Comments
=r w  c. In addition, the FEIS should document the type of fauna may be influenced, and what constitutes a significant adverse effect should u:.                                                              be made and presented clearly in the FEIS.
: 1.
estimate (Section 5.3.1.2) of the increase in temperatures at the surface of the ocean substrate around the discharges. This estimate   2. Section 5.4.2.1. Thermal Effects, mentions a final indicates that wvioiations of the state thermal     report due on December 29, 1978. This study, provided standards are unlikely.* Again, such estimates       for under the Thermal Plan and Section 316(a) of the should compare natural temperatures to the           FWPCA, is to be used in evaluating the heat-treatment combined effects of Units 1, 2, and 3. These         process which is used to clear the intake facilities temperatures are of special concern because of       of biological growth. EPA considers this study to be the importance of low basal temperatures to         an integral part of the assessment of the maintaining the nearby kelp bed.                     environmental effects of the thermal discharges from the Units. As such, it must be distributed, along
In Section 5.3.1.1., some assessment is made of the effects of the discharge of heated cooling water on the receiving coastal waters with regards to the California State thermal standards.
: d. Finally, lhe Thermal Plan and Section 316(a) of     with biological and water quality assessments and the FWPCA assert *the need to "assure the           conclusions (perhaps in the form of a supplement to protection and propagation of a balanced,           the DEIS) to all recipients of this OEIS, with the indigenous population of shellfish, fish, and       allowance of a comment period prior to incorporation wildlife in and on the body of water into which     in the Final EIS.
When evaluating thermal discharge, all effects of Units 2 and 3 should be considered in conjunction with the effects of Unit 1. The natural background is a situation where none of the three units is operating.
the discharge is to be made". In Section 5.4.2.1 of the DEIS, biological/ecological evaluations refer to the effects of the discharges on various types of organisms, indicating the effects to be minimal and acceptable. For plankton, the effects will be >>species composition changes" and
The natural receiving water temperature as defined by California Thermal Plan (see next paragraph) is *the temperature of the receiving water at locations, depths, and times which represent conditions unaffected by any elevated temperature waste discharge*.
: 3. Section 5.4.2,2 includes a discussion of the potential Radiological Comments effects of chlorine discharges. The discussion evaluated potential *significant impacts* of the      Beach Regulation periodic 15-minute chlorine dosing period. The FEIS should include a comparison of effluent concentrations This DEIS gives little information on the anticipated with the State Standards contained in the Water        beach population. The presence of thousands of daytime Quality Control Plan for the Ocean Waters of           beach users and hundreds of overnight campers within 1.5 California (1978 Ocean Plan), Table Band Footnote 11, miles from the reactors has significant security, should appear in the EIS. Should the comparison        emergency planning, and radiation dose implications.
Unless Units 2 and 3 are not planned to operate concurrently with Unit l, their effects will occur in concert. All modeling, graphs, and maps produced from models should include Unit l effects when evaluating SONGS' effects on the receiving water temperature.
predict that the discharges exceed the requirements,   Consequently, we believe this issue warrants a thorough the plans to lower the discharge concentration to      discussion in the Final EIS so that those reviewers who agree with the State Standards must be described in    will not read the Environmental Review and Emergency Plan the FEIS.                                              will be aware of this situation and have an opportunity to evaluate it.
Under Section 316(a) of the Federal water Pollution control Act of 1972 (FWPCA) and under the water Quality Control Plan for Control of Temperature in the coastal and Interstate Waters and Enclosed Bays and Estuaries of California (1975 Thermal Plan} (EPA approved State water quality standards), there are several criteria which discharges to coastal waters must fulfill. These should be addressed in any EIS on operating a new coastal.discharge of elevated temperature wastes.
: 4. No assessment appears in the DEIS of the potential seismic effects of nearby faults on the units,         We agree with the decision to restrict usage of the beach although there is a fault within a mile of the plant  in front of the reactors since it will simplify the (the Christianitos Fault and others in the vicinity). security and emergency planning problems and will reduce The FEIS should address the potential of seismic      the radiation doses to the population from routine events and the resultant damage from fault movement,  release. However, the practical effectiveness of this with particular emphasis on the water quality and      restriction should be addressed in the FEIS (e.g., is the off-site radiological contamination.                  prohibition against restricting the area seaward of mean high water, coupled with permitting viewing and pedestrian passage going to make enforcement difficult?).
These are as follows:
=r a                                                            It would be helpful to briefly mention the Emergency Response Plan that is in effect for the Nuclear Station and relate it to the transient population.
: a.
In part 3.B.(3.) of the Thermal Plan, it is stated that *the maximum temperature of thermal waste discharges shall not exceed the natural temperature of receiving waters by more than 2o*r.* Part 3.2.2. of the DBIS states that the cooling water *experiences an ll.l&deg;C (20&deg;F) temperature rise across the condenser.* Since the waters in the vicinity of the intakes for Units 2.and 3 are close to the discharge structures for these units, it is possible that these intake waters are already heated beyond their natural temPerature.
SOme evaluation of this effect must be included in the FBIS.
The influence of the heated discharge from Unit 1 must also be described.
In addition, the intake
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u:.
: b.
: c.
: d.
and discharge facilities and their depths and bow temperature stratification profiles relate to the 20&deg;F requirement should be discussed.
In Part 3.B.(4) of the Thermal Plan, it is stated that "the discharge of elevated temperature wastes shall not result in increases in the natural water temperature exceeding 4&deg;P at (a) the shoreline, (b) the surface of any ocean substrate, or (c) the ocean surface beyond 1,000 feet from the discharge system.
The surface temperature limitation shall be maintained at least 50 percent of the duration of any complete tidal cycle.* Figure 5.3 of the DEIS represents projected incremental increases above natural surface temperatures for the study area.
This figure should be changed in the FEIS to include the Unit 1 intake and discharge structures and the increase of surface temperatures already caused by Unit l discharges in conjunction with those of Units 2 and 3 so as to compare the increases with the true natural surface water temperature.
In addition, the FEIS should document the estimate (Section 5.3.1.2) of the increase in temperatures at the surface of the ocean substrate around the discharges.
This estimate indicates that wvioiations of the state thermal standards are unlikely.* Again, such estimates should compare natural temperatures to the combined effects of Units 1, 2, and 3.
These temperatures are of special concern because of the importance of low basal temperatures to maintaining the nearby kelp bed.
Finally, lhe Thermal Plan and Section 316(a) of the FWPCA assert *the need to "assure the protection and propagation of a balanced, indigenous population of shellfish, fish, and wildlife in and on the body of water into which the discharge is to be made".
In Section 5.4.2.1 of the DEIS, biological/ecological evaluations refer to the effects of the discharges on various types of organisms, indicating the effects to be minimal and acceptable.
For plankton, the effects will be >>species composition changes" and *greater respiration rates", also, "significant effects should be localized".
For fish, the effects will be mainly "shifts in the types of species (and their numbers) which inhabit the area*.
For benthic fauna, adverse effects may be expected if *weekly mean temperatures of 22"C prevail for one month or more or where daily temperatures reach or exceed 24&deg;C.
It is not, however, anticipated that temperatures averaging 22"C will occur for more than 2 to 3 weeks or that the area experiencing temperatures of 24&deg;C or greater as a result of SONGS operation will be considerably larger than the area experiencing these temperatures under natural conditions".
For kelp, the information *suggests that tbe thermal discharges from SONGS 1, 2 and 3 may result in the destruction of at least a portion of the San Onofre Kelp Bed during the summer months~. All of these statements indicate that the indigenous populations will be altered, giving no specific documentation that these effects will be minimal or acceptable.
A detailed evaluation of how the aquatic ecosystem will be affected, over what area each species or type of fauna may be influenced, and what constitutes a significant adverse effect should be made and presented clearly in the FEIS.
: 2.
Section 5.4.2.1. Thermal Effects, mentions a final report due on December 29, 1978.
This study, provided for under the Thermal Plan and Section 316(a) of the FWPCA, is to be used in evaluating the heat-treatment process which is used to clear the intake facilities of biological growth.
EPA considers this study to be an integral part of the assessment of the environmental effects of the thermal discharges from the Units.
As such, it must be distributed, along with biological and water quality assessments and conclusions (perhaps in the form of a supplement to the DEIS) to all recipients of this OEIS, with the allowance of a comment period prior to incorporation in the Final EIS.
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: 3.
Section 5.4.2,2 includes a discussion of the potential effects of chlorine discharges.
The discussion evaluated potential *significant impacts* of the periodic 15-minute chlorine dosing period.
The FEIS should include a comparison of effluent concentrations with the State Standards contained in the Water Quality Control Plan for the Ocean Waters of California (1978 Ocean Plan), Table Band Footnote 11, should appear in the EIS.
Should the comparison predict that the discharges exceed the requirements, the plans to lower the discharge concentration to agree with the State Standards must be described in the FEIS.
: 4.
No assessment appears in the DEIS of the potential seismic effects of nearby faults on the units, although there is a fault within a mile of the plant (the Christianitos Fault and others in the vicinity).
The FEIS should address the potential of seismic events and the resultant damage from fault movement, with particular emphasis on the water quality and off-site radiological contamination. Radiological Comments Beach Regulation This DEIS gives little information on the anticipated beach population.
The presence of thousands of daytime beach users and hundreds of overnight campers within 1.5 miles from the reactors has significant security, emergency planning, and radiation dose implications.
Consequently, we believe this issue warrants a thorough discussion in the Final EIS so that those reviewers who will not read the Environmental Review and Emergency Plan will be aware of this situation and have an opportunity to evaluate it.
We agree with the decision to restrict usage of the beach in front of the reactors since it will simplify the security and emergency planning problems and will reduce the radiation doses to the population from routine release.
However, the practical effectiveness of this restriction should be addressed in the FEIS (e.g., is the prohibition against restricting the area seaward of mean high water, coupled with permitting viewing and pedestrian passage going to make enforcement difficult?).
It would be helpful to briefly mention the Emergency Response Plan that is in effect for the Nuclear Station and relate it to the transient population.
As mentioned under the Dose Commitment section, it is not clear whether beach users and Visitor Center users are included in the individual and population dose calculations.
As mentioned under the Dose Commitment section, it is not clear whether beach users and Visitor Center users are included in the individual and population dose calculations.
Environmental Dose Commitments Page 5-31-34 of the DEIS:
Environmental Dose Commitments Page 5-31-34 of the DEIS:
The estimated maximum individual dose and the population dose were independently checked by EPA with results similar to those presented in the DEIS. However, we do have several questions about assumptions used in the DEIS calculations. The FEIS should clarify the following items:
The estimated maximum individual dose and the population dose were independently checked by EPA with results similar to those presented in the DEIS.
                                                                                      -s-
However, we do have several questions about assumptions used in the DEIS calculations.
: l. The manner in which the individual and population dose to users of the beach is calculated is unclear. Environmental Monitoring For example, what allowance is made for direct radiation doses, especially to those using the walkway The pre-operational and operational radiological between-the south and north beaches, and to those at   environmental monitoring program (as described in Section the Visitors Center? Do the individual and population 6.1.5 of the Environmental Report) appears adequate with doses include these users of the beach and the         the following exceptions which the FEIS should address:
The FEIS should clarify the following items:  
Visitors Center and, if so, what assumptions were made on. hours of exposure, shielding factors, etc.? Also, 1. A delay of 8 days before analyzing charcoal filter air it would be helpful if the habits of "a maximum           samples would permit over 99% of the Iodine-133 and individual" were described so it could be determined       50% of the Iodine-131 to decay before being counted.
-s-
to what extent these various pathway dosages are           The decay would be much greater for contamination additive.                                                 occurring at the beginning of the 7-day sampling period. The maximum time before analyzing filters
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: 2. The actual maximum individual dose from present           should be shortened significantly in order to detect operation of Unit 1 should be described. This dose         as many incidences of sporadic contami"nation as should be added to those being projected for Units 2       possible.
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and 3 (from all pathways). This, in turn, should be compared with the 25 millirem per year limit (75       2. It is not clear why a minimum of only ten 7-day air millirem per year to the thyroid) of the Uranium Fuel     particulate samples are required per quarter. The Cycle Standard (40 CFR 190).                              intent should be to monitor all 13 weeks in a
: l.
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The manner in which the individual and population dose to users of the beach is calculated is unclear.
I  EPA is encouraged that the NRC is now calculating annual population dose commitments to the u.s. population, which   3. No TLD stations are indicated for the walkway along
For example, what allowance is made for direct radiation doses, especially to those using the walkway between-the south and north beaches, and to those at the Visitors Center?
~    is a partial evaluation of the total potential                 the seawall or the mean high water exclusion area in environmental dose commitments (EDC) of H-3, Kr-85, C-141       front of the reactors. It would be desirable to iodines and "particulates.* This is a big step toward           include TLD's at these locations to monitor the direct evaluating the EDC which EPA has urged for several years.       radiation at a site boundary where the public has However, it should be recognized that several of these         access.
Do the individual and population doses include these users of the beach and the Visitors Center and, if so, what assumptions were made on. hours of exposure, shielding factors, etc.? Also, it would be helpful if the habits of "a maximum individual" were described so it could be determined to what extent these various pathway dosages are additive.
radionuclides (particularly C-14 and Kr-85) will contribute to long-term population dose impacts on a       Reactor Accidents world-wide basis, rather than just in the u.s. To the extent that the draft statement (1) has limited the EDC to The EPA has examined the NRC's analyses of accidents and the annual discharge of these radionuclides, (2) is based   their potential risks. The analyses were developed by NRC on the assumption of a population of constant size, and     in the course of its engineering evaluation of reactor (3) assesses the doses during SO years only following each safety in the design of nuclear plants. Since these release, it does not fully provide the total environmental issues are common to all nuclear plants of a given type, impact. Assessmenf of the total impact would (1)           EPA accepts NRC's generic approach to accident evaluation incorporate the projected releases over the lifetime ot     in the DEIS. However, the NRC is expected to continue to the facility (rather than just the annual release), (2)     ensure safety through plant design and accident analyses extend to several half-lives or 100 years beyond the       during the licensing process on a case-by-case basis.
: 2.
period of release, and (3) consider, at least qualitatively or generically, the world-wide influences on In 1972, the AEC initiated an effort to examine reactor the total environmental impact or specify the limitations   safety and the resultant environmental consequences and of the model used.                                         risks on a more quantitative basis. The final report of this effort was issued in October 1975 by the u.s. Nuclear Regulatory Commission as the Reactor Safety Study, WASH-1400 (NUREG-75/014). The EPA's review of this study Transportation included in-house and contractual efforts, and our          In its earlier reviews of the environmental impacts of comments were released in a report in June, 1976. In        transportation of radioactive material, EPA agreed with subsequent discussion with _NRC we determined that of the   AEC that many aspects of this program could best be concerns we expressed, those having the most significance  treated on a generic basis. The NRC has codified this with regard to the results of the study were on (1) the    generic approach (40 PR 1005) _by adding a table to its latent cancer health effects and (2) the probability of    regulations (10 CPR Part 51) which summarizes the BWR scram failure where we differed by factors of four and' environmental impacts resulting from the routine a maximum of ten, respectively. We believe that the        transportation of radioactive materials to and from methodology of the Reactor Safety Study should continue to light-water reactors. These regulations permit the use of be used as a tool in the evaluation of nuclear systems      the impact values listed in the table in lieu of assessing that vary from the models chosen for the study, and that a the transportation impact for individual reactor licensing generic analysis should be made of the acceptability of     actions if certain conditions are met. Since San Onofre the present risks and the necessity for increased levels    appears to meet these conditions and since EPA agrees that of safety.                                                  the routine transportation impact values in the table are reasonable, the generic approach appears adequate for this High-Level waste Management                                plant.
The actual maximum individual dose from present operation of Unit 1 should be described.
The techniques and procedures used to manage high-level    The impact value for routine transportation of radioactive radioactive wastes will have an impact on the              materials has been set at a level which covers 90*percent environment. To a certain extent, these impacts can be      of the reactors currently operating or under directly related to the individual projects because the     construction. However, the basis for the impact, or risk, spent fuel from each new facility will contribute to the    of transportation accidents is not as clearly defined. At r
This dose should be added to those being projected for Units 2 and 3 (from all pathways).
This, in turn, should be compared with the 25 millirem per year limit (75 millirem per year to the thyroid) of the Uranium Fuel Cycle Standard (40 CFR 190).
EPA is encouraged that the NRC is now calculating annual population dose commitments to the u.s. population, which is a partial evaluation of the total potential environmental dose commitments (EDC) of H-3, Kr-85, C-141 iodines and "particulates.* This is a big step toward evaluating the EDC which EPA has urged for several years.
However, it should be recognized that several of these radionuclides (particularly C-14 and Kr-85) will contribute to long-term population dose impacts on a world-wide basis, rather than just in the u.s.
To the extent that the draft statement (1) has limited the EDC to the annual discharge of these radionuclides, (2) is based on the assumption of a population of constant size, and (3) assesses the doses during SO years only following each release, it does not fully provide the total environmental impact.
Assessmenf of the total impact would (1) incorporate the projected releases over the lifetime ot the facility (rather than just the annual release), (2) extend to several half-lives or 100 years beyond the period of release, and (3) consider, at least qualitatively or generically, the world-wide influences on the total environmental impact or specify the limitations of the model used. Environmental Monitoring The pre-operational and operational radiological environmental monitoring program (as described in Section 6.1.5 of the Environmental Report) appears adequate with the following exceptions which the FEIS should address:
: 1.
A delay of 8 days before analyzing charcoal filter air samples would permit over 99% of the Iodine-133 and 50% of the Iodine-131 to decay before being counted.
The decay would be much greater for contamination occurring at the beginning of the 7-day sampling period.
The maximum time before analyzing filters should be shortened significantly in order to detect as many incidences of sporadic contami"nation as possible.
: 2.
It is not clear why a minimum of only ten 7-day air particulate samples are required per quarter.
The intent should be to monitor all 13 weeks in a quarter.
: 3.
No TLD stations are indicated for the walkway along the seawall or the mean high water exclusion area in front of the reactors.
It would be desirable to include TLD's at these locations to monitor the direct radiation at a site boundary where the public has access.
Reactor Accidents The EPA has examined the NRC's analyses of accidents and their potential risks.
The analyses were developed by NRC in the course of its engineering evaluation of reactor safety in the design of nuclear plants.
Since these issues are common to all nuclear plants of a given type, EPA accepts NRC's generic approach to accident evaluation in the DEIS.
However, the NRC is expected to continue to ensure safety through plant design and accident analyses during the licensing process on a case-by-case basis.
In 1972, the AEC initiated an effort to examine reactor safety and the resultant environmental consequences and risks on a more quantitative basis.
The final report of this effort was issued in October 1975 by the u.s. Nuclear Regulatory Commission as the Reactor Safety Study, WASH-1400 (NUREG-75/014).
The EPA's review of this study r
i!!;
i!!;
total waste. The AEC, on September 10, 1974, issued for comment a draft statement entitled "The Management of Commercial High-Level and Transuranium-Contaminated present, EPA, DOE, and NRC are each attempting to more fully assess the radiological impact of transportation risks. The EPA will make known its views on any Radioactive waste" (WASH-1539). In this regard, EPA        environmentally unacceptable conditions related to provided extensive comments on WASH-1539 on November 21,    transportation. On the basis of present information, EPA 1974. Our major criticism was that the draft statement      believes there are no unique characteristics of the San lacked a program for arriving at a satisfactory method of   Onofre site which would result in greater accident risks "ultimate* high-level waste disposal. At present, DOE is    than from the "typical" site being studied generically.
included in-house and contractual efforts, and our comments were released in a report in June, 1976.
preparing a new draft statment which will discuss waste management and emphasize ultimate disposal in a more        Fuel Cycle and Long-Term Dose Assessments comprehensive manner. EPA concurs with this decision and will review and comment on the new draft statement         EPA is responsible for establishing generally applicable replacing the September 10, 1974 version when it is         environmental radiation protection standards to limit available.                                                  unnecessary radiation exposures and radioactive materials in the general environment resulting from normal EPA is cooperating with both NRC and DOE to develop an      operations that are part of the total uranium fuel cycle environmentally acceptable program for radioactive waste   as well as those of the facilities. The EPA has concluded management. In this regard, on November 15, 1978, EPA       (in 40 CPR 90) that environmental radiation standards for issued proposed environmental radiation protection         nuclear power industry operations should take into account criteria (43 FR 53262) for the management of all           the total radiation dose to the population, the maximum radioactive waste and will propose environmental radiation individual dose, the risk of health effects attributable protection standards for high-level waste in 1979.         to these doses (including the future risks arising from the release of long-lived radionuclides to the environment), and the effectiveness and costs of effluent
In subsequent discussion with _NRC we determined that of the concerns we expressed, those having the most significance with regard to the results of the study were on (1) the latent cancer health effects and (2) the probability of BWR scram failure where we differed by factors of four and' a maximum of ten, respectively.
                                                                                                                                -s-
We believe that the methodology of the Reactor Safety Study should continue to be used as a tool in the evaluation of nuclear systems that vary from the models chosen for the study, and that a generic analysis should be made of the acceptability of the present risks and the necessity for increased levels of safety.
 
High-Level waste Management The techniques and procedures used to manage high-level radioactive wastes will have an impact on the environment.
control technology. EPA's Uranium Fuel Cycle Standards    persistent radionuclides should be assessed, qualifying are expressed in terms of dose limits to individual        such estimates as appropriate to reflect the large members of the general public and limits on quantities of uncertainties. In this regard, we note that NEA is certain long-lived radioactive materials released to the   addressing this approach in making assessments and that general environment.                                      NRC is represented in this effort.
To a certain extent, these impacts can be directly related to the individual projects because the spent fuel from each new facility will contribute to the total waste.
A document entitled "Environmental Survey of the Uranium  Another major consideration in updating WASB-1248 is the Fuel Cycle" (WASH-1248) was issued by the AEC in          health impact from Radon-222 from the uranium mining and conjunction with a regulation (10 CFR 50, Appendix D) for  milling industry. Estimates made by EPA, among others, application in completing the cost-benefit analysis for    indicate that Radon-222 contributes the greatest fraction individual light-water reactor environmental reviews (39  of the total health impact from nuclear power generation.
The AEC, on September 10, 1974, issued for comment a draft statement entitled "The Management of Commercial High-Level and Transuranium-Contaminated Radioactive waste" (WASH-1539).
FR 14188). This document is used by NRC in draft          In preparing an updated WASH-1248, we believe NRC should:
In this regard, EPA provided extensive comments on WASH-1539 on November 21, 1974.
environmental statements to assess the incremental environmental impacts that can be attributed to fuel cycle 1. include the Radon-222 contribution from both the components which support nuclear power plants.                uranium mining and milling industries; Recently, the NRC decided to update the WASH-1248 survey. 2. determine the health impact to larger populations, not We believe this is a prudent step and commend the NRC on      only the local populations; initiating this update. In providing comments to the NRC on this subject, dated November 14, 1978, we encouraged    3. recognize the persistent nature of the Radon-222 NRC to express environmental impacts in terms of potential    precursors {Th-230 and Ra-226) by estimating the
Our major criticism was that the draft statement lacked a program for arriving at a satisfactory method of "ultimate* high-level waste disposal.
:Jio consequences to human health, since for radioactive            health impact for a period reflecting multi-generation I  materials and ionizing radiation the most important            times.
At present, DOE is preparing a new draft statment which will discuss waste management and emphasize ultimate disposal in a more comprehensive manner.
w    impacts are those ultimately affecting human health. We believe the presentation of environmental impact in terms  Decommissioning of human health impact fosters a better understanding of the radiation protection afforded the public.             The NRC has published a proposed rulemaking on Decommissioning Criteria for Nuclear Facilities in the A second major concern of EPA deals with the discharge and Federal Register on March 13., 1978. EPA comments were dispersal of long-lived radionuclides into the general    sent to NRC on July 5, 1978, dealing with the environment. In the areas addressed in WASB-1248, there    decommissioning issue.
EPA concurs with this decision and will review and comment on the new draft statement replacing the September 10, 1974 version when it is available.
are several cases in which radioactive materials of long persistence are released into the environment. The        In summary, we believe that one of the most important resulting consequences may extend over many generations    issues in the decommissioning of nuclear facilities is the and constitute irreversible public health commitments. development of standards for radiation exposure limits for This long-term potential impact should be considered in   materials, facilities, and sites to be released for any assessment on health impact. EPA has consistently      unrestricted use. We have included the development of found inadequate the NRC's estimates of population doses  such standards among our planned projects. The work will for these persistent radioactive materials. In            require a thorough study to provide necessary information, particular, the NRC has generally limited their analysis   including a cost-effectiveness analysis for various levels to the population within 50 miles of a facility or, in     of decontamination.
EPA is cooperating with both NRC and DOE to develop an environmentally acceptable program for radioactive waste management.
rare cases, to the u.s. population, and to doses committed for a 50-year period by an annual release. These           The development of standards for decommissioning must, of limitations produce incomplete estimates of environmental course, include consideration of the many concurrent impacts and underestimate the impact in some cases, such   activities in radioactive waste management and as from releases of tritium, Krypton-85, Carbon-14,       radiological protection. EPA has developed proposed Technetium-99, and Iodine-129. The total impact of these   Criteria for Radioactive Waste for management of all radioactive wastes which.will provide guidance for        EIS CATEGOR! CODES decommissioning standards. From the decommissioning view, probably the most important criterion is that limiting reliance on institutional controls (guards and fences) to  Environmental rmpact of the Action a finite period. EPA believes that the use of institutional control to protect the public from retired  to--Lack of Objections nuclear facilities until they can be decontaminated and
In this regard, on November 15, 1978, EPA issued proposed environmental radiation protection criteria (43 FR 53262) for the management of all radioactive waste and will propose environmental radiation protection standards for high-level waste in 1979.  
* decommissioned should be limited at the most to 100 years  EPA has no objection to the proposed action as described in the draft and preferably less than so years. This includes nuclear  impact atatement1 or suggests only mtnor changes in the proposed action.
-s-Transportation In its earlier reviews of the environmental impacts of transportation of radioactive material, EPA agreed with AEC that many aspects of this program could best be treated on a generic basis.
reactors shut down and mothballed or entombed for a period of time under protective storage. After the allowable      ER--Environmental Reservations institutional care period is over, the site will have to meet radioactive protection levels established for release EPA has reservations concerning the environmental effects of certain for unrestricted use. We believe EPA's proposed criteria  aspects of the proposed action. EPA believes that further study of would be directly applicable, as above, to decommissioning suggested alternatives or modifications is required and has asked the of nuclear facilities and should be given serious          originating Federal agency to reassess these aspects.
The NRC has codified this generic approach (40 PR 1005) _by adding a table to its regulations (10 CPR Part 51) which summarizes the environmental impacts resulting from the routine transportation of radioactive materials to and from light-water reactors.
consideration by the Nuclear Regulatory Commission (NRC).
These regulations permit the use of the impact values listed in the table in lieu of assessing the transportation impact for individual reactor licensing actions if certain conditions are met.
ZU.-Environmentally Unsatisfactory The availability of adequate funds when the time to
Since San Onofre appears to meet these conditions and since EPA agrees that the routine transportation impact values in the table are reasonable, the generic approach appears adequate for this plant.
!Ill decommission arrives is also most important; it should be  !PA believes that the proposed aCtion is unsatisfactory because of its I  the responsibility of the NRC to assure that such          potentially harmful effect on the environment. Furthermore, the Agency
The impact value for routine transportation of radioactive materials has been set at a level which covers 90*percent of the reactors currently operating or under construction.
:1:  provisions are made. We recognize the great complexity of providing funds at construction for decommission in 40 believes that the potential safeguards which might be utilized may not adequately protect the environment from hazards arising from this action.
However, the basis for the impact, or risk, of transportation accidents is not as clearly defined.
years. However, if it can be determined that the total    The Agency re~nds that alternatives to the action be analyzed further cost of decommissioning in current dollars is a very small  {including the possibility of no action at all).
At present, EPA, DOE, and NRC are each attempting to more fully assess the radiological impact of transportation risks.
fraction of initial capital costs, provision of escrow funding may not be necessary. Therefore, we urge the NRC  Adequacy of the Impact Statement to conduct the necessary studies and assessments to determine unequivocally costs of decommissioning and to    Category 1--Adequate compare such costs to initial capital costs. It is only through a definitive.analysis, and perhaps through          The draft impact statement adequately sets forth the environmental realistic demonstrations, that this issue can be            impact of the proposed project or action as well as alternatives rea-resolved.                                                  sonably available to the project or action.
The EPA will make known its views on any environmentally unacceptable conditions related to transportation.
category 2--Insufficient Information EPA believes that the draft impact statement does not contain suffi-cient information to assess fully the environmental impact of the pro-posed project or action. However, from the information submitted, the Agency is able to make a preliminary determination of the impact on the environment. EPA has requested that the originator provide the information that was not included in the draft statement.
On the basis of present information, EPA believes there are no unique characteristics of the San Onofre site which would result in greater accident risks than from the "typical" site being studied generically.
category 3--Inadequate EPA believes that the draft impact statement does not adequately assess the environmental impact of the proposed project or action, or that the statement inadequately analyzes reasonably available alternatives. The Agency has requested more information and analysis concerning the poten-tial environmental hazards and has asked that substantial revision be made to the impact statement.
Fuel Cycle and Long-Term Dose Assessments EPA is responsible for establishing generally applicable environmental radiation protection standards to limit unnecessary radiation exposures and radioactive materials in the general environment resulting from normal operations that are part of the total uranium fuel cycle as well as those of the facilities.
If a draft impact statement is assigned a Cate9ory 3, no rating will be made of the project or action, since a basis does not generally exist on which to make such a determination.
The EPA has concluded (in 40 CPR 90) that environmental radiation standards for nuclear power industry operations should take into account the total radiation dose to the population, the maximum individual dose, the risk of health effects attributable to these doses (including the future risks arising from the release of long-lived radionuclides to the environment), and the effectiveness and costs of effluent
:Jio I...
w control technology.
EPA's Uranium Fuel Cycle Standards are expressed in terms of dose limits to individual members of the general public and limits on quantities of certain long-lived radioactive materials released to the general environment.
A document entitled "Environmental Survey of the Uranium Fuel Cycle" (WASH-1248) was issued by the AEC in conjunction with a regulation (10 CFR 50, Appendix D) for application in completing the cost-benefit analysis for individual light-water reactor environmental reviews (39 FR 14188).
This document is used by NRC in draft environmental statements to assess the incremental environmental impacts that can be attributed to fuel cycle components which support nuclear power plants.
Recently, the NRC decided to update the WASH-1248 survey.
We believe this is a prudent step and commend the NRC on initiating this update.
In providing comments to the NRC on this subject, dated November 14, 1978, we encouraged NRC to express environmental impacts in terms of potential consequences to human health, since for radioactive materials and ionizing radiation the most important impacts are those ultimately affecting human health.
We believe the presentation of environmental impact in terms of human health impact fosters a better understanding of the radiation protection afforded the public.
A second major concern of EPA deals with the discharge and dispersal of long-lived radionuclides into the general environment.
In the areas addressed in WASB-1248, there are several cases in which radioactive materials of long persistence are released into the environment.
The resulting consequences may extend over many generations and constitute irreversible public health commitments.
This long-term potential impact should be considered in any assessment on health impact.
EPA has consistently found inadequate the NRC's estimates of population doses for these persistent radioactive materials.
In particular, the NRC has generally limited their analysis to the population within 50 miles of a facility or, in rare cases, to the u.s. population, and to doses committed for a 50-year period by an annual release.
These limitations produce incomplete estimates of environmental impacts and underestimate the impact in some cases, such as from releases of tritium, Krypton-85, Carbon-14, Technetium-99, and Iodine-129.
The total impact of these persistent radionuclides should be assessed, qualifying such estimates as appropriate to reflect the large uncertainties.
In this regard, we note that NEA is addressing this approach in making assessments and that NRC is represented in this effort.
Another major consideration in updating WASB-1248 is the health impact from Radon-222 from the uranium mining and milling industry.
Estimates made by EPA, among others, indicate that Radon-222 contributes the greatest fraction of the total health impact from nuclear power generation.
In preparing an updated WASH-1248, we believe NRC should:
: 1.
include the Radon-222 contribution from both the uranium mining and milling industries;
: 2.
determine the health impact to larger populations, not only the local populations;
: 3.
recognize the persistent nature of the Radon-222 precursors {Th-230 and Ra-226) by estimating the health impact for a period reflecting multi-generation times.
Decommissioning The NRC has published a proposed rulemaking on Decommissioning Criteria for Nuclear Facilities in the Federal Register on March 13., 1978.
EPA comments were sent to NRC on July 5, 1978, dealing with the decommissioning issue.
In summary, we believe that one of the most important issues in the decommissioning of nuclear facilities is the development of standards for radiation exposure limits for materials, facilities, and sites to be released for unrestricted use.
We have included the development of such standards among our planned projects.
The work will require a thorough study to provide necessary information, including a cost-effectiveness analysis for various levels of decontamination.
The development of standards for decommissioning must, of course, include consideration of the many concurrent activities in radioactive waste management and radiological protection.
EPA has developed proposed Criteria for Radioactive Waste for management of all
!Ill I
:1:
radioactive wastes which.will provide guidance for decommissioning standards.
From the decommissioning view, probably the most important criterion is that limiting reliance on institutional controls (guards and fences) to a finite period.
EPA believes that the use of institutional control to protect the public from retired nuclear facilities until they can be decontaminated and
* decommissioned should be limited at the most to 100 years and preferably less than so years.
This includes nuclear reactors shut down and mothballed or entombed for a period of time under protective storage. After the allowable institutional care period is over, the site will have to meet radioactive protection levels established for release for unrestricted use.
We believe EPA's proposed criteria would be directly applicable, as above, to decommissioning of nuclear facilities and should be given serious consideration by the Nuclear Regulatory Commission (NRC).
The availability of adequate funds when the time to decommission arrives is also most important; it should be the responsibility of the NRC to assure that such provisions are made.
We recognize the great complexity of providing funds at construction for decommission in 40 years.
However, if it can be determined that the total cost of decommissioning in current dollars is a very small fraction of initial capital costs, provision of escrow funding may not be necessary.
Therefore, we urge the NRC to conduct the necessary studies and assessments to determine unequivocally costs of decommissioning and to compare such costs to initial capital costs. It is only through a definitive.analysis, and perhaps through realistic demonstrations, that this issue can be resolved. EIS CATEGOR! CODES Environmental rmpact of the Action to--Lack of Objections EPA has no objection to the proposed action as described in the draft impact atatement1 or suggests only mtnor changes in the proposed action.
ER--Environmental Reservations EPA has reservations concerning the environmental effects of certain aspects of the proposed action.
EPA believes that further study of suggested alternatives or modifications is required and has asked the originating Federal agency to reassess these aspects.
ZU.-Environmentally Unsatisfactory
!PA believes that the proposed aCtion is unsatisfactory because of its potentially harmful effect on the environment.
Furthermore, the Agency believes that the potential safeguards which might be utilized may not adequately protect the environment from hazards arising from this action.
The Agency re~nds that alternatives to the action be analyzed further
{including the possibility of no action at all).
Adequacy of the Impact Statement Category 1--Adequate The draft impact statement adequately sets forth the environmental impact of the proposed project or action as well as alternatives rea-sonably available to the project or action.
category 2--Insufficient Information EPA believes that the draft impact statement does not contain suffi-cient information to assess fully the environmental impact of the pro-posed project or action. However, from the information submitted, the Agency is able to make a preliminary determination of the impact on the environment.
EPA has requested that the originator provide the information that was not included in the draft statement.
category 3--Inadequate EPA believes that the draft impact statement does not adequately assess the environmental impact of the proposed project or action, or that the statement inadequately analyzes reasonably available alternatives.
The Agency has requested more information and analysis concerning the poten-tial environmental hazards and has asked that substantial revision be made to the impact statement.
If a draft impact statement is assigned a Cate9ory 3, no rating will be made of the project or action, since a basis does not generally exist on which to make such a determination.  


Mard.ll I. Lewis 6504 Bradford Terrace Phila. PA 19H9
> I....
                                              ;-6-79.
U'l Mard.ll I. Lewis 6504 Bradford Terrace Phila. PA 19H9  
Director, Divieioa of Site Safety EATironmeatal Analysis Office of nuclear Reactor Rogdation USNRC Waskiagton. /d.C. 20555 Southern California Edison Company
;-6-79.
                                                                                                                      ""'o. aox eoo see U. .... WALNUT GA:OVE AVENUE Sir:
Director, Divieioa of Site Safety EATironmeatal Analysis Office of nuclear Reactor Rogdation USNRC Waskiagton. /d.C. 20555 Sir:
* BUREG 0490 does a lot of things , but it does not 1a aay way justify   .J. H. CRAt<E                AOSEM&#xa3;.A.D, CALIF'OI'tNIA G'f770 Tt:t..J:,.HON&#xa3; tho operation of the Saa onofre Nuclear Generating Station.                                                   April 6, 1979              Ati3*'S72*U06 Although the NUREG does proTide a lot of good in!ermatien, thia iatermation actually contradicts the usefulness of the SONGS, Sa n Onofre Nuclear Generating Statioa. For instance, the growth rate in Table 2.2 ,Pace 2-2, is ;.5 ~ or less fer the period 1976 to 1990. The ~owth rate in Table a.; and 8.4 on Pacea %t 8-4and 8-5 is dDse to 5~ for the same perioa. Inotherwords , the growth ratea           Director, Office of Nuclear Reactor Regulation in Tarious parts of tao report are *selected
BUREG 0490 does a lot of things, but it does not 1a aay way justify tho operation of the Saa onofre Nuclear Generating Station.
* to provide justi!icatio*       Attn: Wm. H, Regan, Jr., Chief for whatever the writer wishes to r.s~ify 1~ &~f Ji>>fiX     particular               Environmental Projects Branch 2 p~t of the report *. This technique is called '!icti~.                               Division of Site Safety and Environmental Analysis In Appendix D-2; Page 2.5 Seismology is dismissed in a few paragraphs.       U.S. Nuclear Regulatory Commission Considering the recent and continuing at. seismic discoveries at             Washington, DC 20555 tho Hosgri fault at Diablo Canyon (which is in a similar -in fact aame- gelological domain), passing ott seismology this cavtlierly             Gentlemen:
Although the NUREG does proTide a lot of good in!ermatien, thia iatermation actually contradicts the usefulness of the SONGS, Sa n Onofre Nuclear Generating Statioa. For instance, the growth rate in Table 2.2,Pace 2-2, is ;.5 ~ or less fer the period 1976 to 1990. The ~owth rate in Table a.; and 8.4 on Pacea %t 8-4and 8-5 is dDse to 5~ for the same perioa. Inotherwords, the growth ratea in Tarious parts of tao report are *selected
>    t. is indefensible.
* to provide justi!icatio*
....I U'l Page 5-37. First you state in a Table that the Commissioner has directed that Radon 222 will be reconsidered elsew8ere; then,
for whatever the writer wishes to r.s~ify 1~ &~f Ji>>fiX particular p~t of the report *. This technique is called '!icti~.
In Appendix D-2; Page 2.5 Seismology is dismissed in a few paragraphs.
Considering the recent and continuing at.
seismic discoveries at tho Hosgri fault at Diablo Canyon (which is in a similar -in fact aame-gelological domain),
passing ott seismology this cavtlierly
: t.
is indefensible.
Page 5-37. First you state in a Table that the Commissioner has directed that Radon 222 will be reconsidered elsew8ere; then, the Staff includes Radon 222 in this Nureg in a convoluted and artificial manner which does not in any way investigate or acknowledge Radon 222's full period o! toaicity as required by NEPA.
Page 5~)9 Tailings are not required to be stabilized forever, and even if-it~ were required, tereTer stabilization ie a God like requiremen>>f whick may be impossible to mortal men~.
Jhapter 7.
This is based entirely on the Rasmussen Wash 1400
* Commisssionor Kennedy has already stated on October lG, 1978, "It ( Rasmussen Report) found some deticiendieo which ouggeet that the absolute values of the riske presented in the Study should not be used uncritically either i~ the regulatory process or tor public policy purposes."
The DES !or operation of SONGS proves unequivooally ~hat thia nuclear power plant is unnecessary and dangerous.
~is is despite the Stall evaluation which ignores all important negative effects.
DO NOT LICENSE THIS NUCLEAR POWER PLANT TO OPERATE A' OF HUMAN LIVES.
Marvin I. Lowi8 ~'
.J. H. CRAt<E Southern California Edison Company
""'o. aox eoo U..... WALNUT GA:OVE AVENUE AOSEM&#xa3;.A.D, CALIF'OI'tNIA G'f770 see April 6, 1979 Tt:t..J:,.HON&#xa3; Ati3*'S72*U06 Director, Office of Nuclear Reactor Regulation Attn:
Wm. H, Regan, Jr., Chief Environmental Projects Branch 2 Division of Site Safety and Environmental Analysis U.S. Nuclear Regulatory Commission Washington, DC 20555 Gentlemen:


==Subject:==
==Subject:==
San Onofre Nuclear Generating Station Units 2 and 3 Docket Nos. 50-361 and 50-362 the Staff includes Radon 222 in this Nureg in a convoluted and artificial manner which does not in any way investigate or acknowledge      Mr. Oliver Lynch, Jr., of the NRC staff called on March 27, Radon 222's full period o! toaicity as required by NEPA.                      1979, to request clarification of Applicants' Comment 6-4 to the Draft Environmental Statement for S~n Onofre Nuclear Page 5~)9 Tailings are not required to be stabilized forever, and            Generating Station, Units 2 and 3. Applicants' Comment 6-4 even if-it~ were required , tereTer stabilization ie a God                  was submitted with other comments by letter to you dated like requiremen>>f whick may be impossible to mortal men~.                    February 2, 1979.
San Onofre Nuclear Generating Station Units 2 and 3 Docket Nos. 50-361 and 50-362 Mr. Oliver Lynch, Jr., of the NRC staff called on March 27, 1979, to request clarification of Applicants' Comment 6-4 to the Draft Environmental Statement for S~n Onofre Nuclear Generating Station, Units 2 and 3.
Jhapter 7. This is based entirely on the Rasmussen Wash 1400
Applicants' Comment 6-4 was submitted with other comments by letter to you dated February 2, 1979.
* In response to Mr. Lynch's request, a revised Comment o-4 is Commisssionor Kennedy has already stated on October lG, 1978,                enclosed for your information. If you have additional comments "It ( Rasmussen Report) found some deticiendieo which ouggeet that          regarding this comment, please contact me.
In response to Mr. Lynch's request, a revised Comment o-4 is enclosed for your information.
the absolute values of the riske presented in the Study should not be used uncritically either i~ the    regulatory process
If you have additional comments regarding this comment, please contact me.
                                                                                                        ,:f??.JJ; or tor public policy purposes."
Enclosure
The DES !or operation of SONGS proves unequivooally ~hat thia nuclear power plant is unnecessary and dangerous. ~is is despite the Stall evaluation which ignores all important negative effects.
,:f??.JJ; i/
Enclosure DO NOT LICENSE THIS NUCLEAR POWER PLANT TO OPERATE A' i/
790424 0 '3 '? q c_~\\1  
                                              ~'
OF HUMAN LIVES.
Marvin I. Lowi8 790424 0 '3 '? q c_~\1


6.3.1 Water Ouality Monitorinv Pro~ram                               1 RICHARD J. WHARTON Comm~nt 6-4 (Revised April 6, 1979)                             Attorney at Law
6.3.1  
{Page 6-6)                                                     2 4655 Cass St., Suite 304 San Diego, CA 92109 The first five para~raohs of this section of the DES describe 3 (714) 488-2828 a proposed operational monitoring program which was presented 411Attorney fo;: Intervenors in the ER-OLS (Section 6.2) and was based upon the proposed preoperational monitorin~ program also presented in the ER-OLS. The ER-OLS was developed in 197~ and su~mitted in     5 1977 to the NRC.
~
6 Since that time, the Preoperational ~onitoring Program has been revised to incorporate the latest site specific study     7 results and recent developments in marine ecological study techniques. The revised Preoperational ~onitoring Program     8                      UNITED STATES OF AMERICA was approved by the NRC and implemented in 1978. It is the Applicant's intention to develop an operational monitoring     9                    NUCLEAR REGULATORY    COl~USSION program which incorporates results of the Preoperational                   BEFORE THE ATOMIC SAFETY AND LICENSING      BOA~
Water Ouality Monitorinv Pro~ram Comm~nt 6-4 (Revised April 6, 1979)
Monitoring Program and submit it in the near future for       10 approval. It was the intention of Comment 6-Q to indicate that the specific details of the operational monitoring       11 In the Matter of                      )  Docket Nos. 50-361 OL program proposed in the ER-OLS in 1976 (and contained in the                                           )                50-362 OL DES) should not be considered to represent the program which 12      SOUTHERN CALIFORNIA            )
{Page 6-6)
will actually be implemented. While the program which will             EDISON COMPANY, ~ al.,         )   CO~!ENTS ON DRAFT ENVIRONMENT.
The first five para~raohs of this section of the DES describe a proposed operational monitoring program which was presented in the ER-OLS (Section 6.2) and was based upon the proposed preoperational monitorin~ program also presented in the ER-OLS.
ultimately be implemented will be similar to the one included 13                                      )   STA~!ENT - SAN ONOFRE NUCLEAR in the ER-OLS, it will not be identical, and the differences    (San Onofre Nuclear Generating       )   GENERATWG STATION, UNITS 2
The ER-OLS was developed in 197~ and su~mitted in 1977 to the NRC.
Since that time, the Preoperational ~onitoring Program has been revised to incorporate the latest site specific study results and recent developments in marine ecological study techniques.
The revised Preoperational ~onitoring Program was approved by the NRC and implemented in 1978. It is the Applicant's intention to develop an operational monitoring program which incorporates results of the Preoperational Monitoring Program and submit it in the near future for approval. It was the intention of Comment 6-Q to indicate that the specific details of the operational monitoring program proposed in the ER-OLS in 1976 (and contained in the DES) should not be considered to represent the program which will actually be implemented.
While the program which will ultimately be implemented will be similar to the one included in the ER-OLS, it will not be identical, and the differences between the two cannot be specified at this time because the development process is still underway.
1 RICHARD J. WHARTON Attorney at Law 2 4655 Cass St., Suite 304 San Diego, CA 92109 3 (714) 488-2828 411Attorney fo;: Intervenors 5
6 7
8 9
UNITED STATES OF AMERICA 10 11 12 13 14 15 NUCLEAR REGULATORY COl~USSION BEFORE THE ATOMIC SAFETY AND LICENSING BOA~
In the Matter of
)
Docket Nos. 50-361 OL
)
50-362 OL SOUTHERN CALIFORNIA
)
EDISON COMPANY, ~ al.,  
)
CO~!ENTS ON DRAFT ENVIRONMENT.  
)
STA~!ENT - SAN ONOFRE NUCLEAR (San Onofre Nuclear Generating  
)
GENERATWG STATION, UNITS 2 Station, Units 2.and 3)
)
AtiD 3
)
)
16 We have carefully reviewed the above draft environmental 17 statement in relation to the requirements imposed by Section 18 102(2)(c) of the National Environmental Policy Act (NEPA) and 19 10 CFR Part 51 of the NRC Regulations, and have set forth below 2011intervenors' comments on the proposed action and on this draft 21
~
~
between the two cannot be specified at this time because the  14 Station, Units 2 .and 3)              )  AtiD 3 development process is still underway.                                                                )
statement pursuant to 10 CFR Part 51.25.
15                                      )
Intervenors find this draft statement inadequate in a) the discussion and assessment of 23 environmental effects, both beneficial and adverse, associated 24 with the operation of the San Onofre Nuclear Generating Station, 25 Units 2 and 3, and b) the *discussion and consideration of avail-26 able alternatives to.. t;he-p1:'0posed action.* *<Intervenors specific-all 27 identify the following deficiencies:
16      We have carefully reviewed the above draft environmental 17 statement in relation to the requirements imposed by Section 18 102(2)(c) of the National Environmental Policy Act (NEPA) and 19 10 CFR Part 51 of the NRC Regulations, and have set forth below 2011intervenors' comments on the proposed action and on this draft 21 statement pursuant to 10 CFR Part 51.25.         Intervenors find this
28
                                                                      ~  draft statement inadequate in a)       the discussion and assessment of 23 environmental effects, both beneficial and adverse, associated 24 with the operation of the San Onofre Nuclear Generating Station, 25 Units 2 and 3, and b)     the *discussion and consideration of avail-26 able alternatives to ..t;he-p1:'0posed action.* *<Intervenors specific-all 27 identify the following deficiencies:
: 1. The evaluation of cooling water discharge impacts is  
28       1. The evaluation of cooling water discharge impacts is


inaccurate and misleading. The heated water will very likely           1 or "may" violate the temperature differential, there really is no esult in the destruction of at least a portion of the San Onofre         2 question that such violations will occur."    (pp. 4-5) elp bed during the summer months, the long-term thermal impacts           3      In a hearing for the purpose of interpreting the term "re-violations of the state standards         4 ceiving waters" held on December 21, 1978, the California State On page   5-7 of the DES it is stated:   "The staff         5 Water Quality Control Board held that " .*. the temperature at the there exists a remote possibility that         6 intake point does not represent conditions at the receiving thermal standards could be violated by the operation of             7  aters," (p. 3 of Opinion of Chairman Bryson and Board Member 2 and 3, violations would, at worst, be infrequent and for           8 Mitchell) contrary to applicants' requested interpretation. The periods. There is no evidence in available drift data to           9 net result of this ruling is that the state thermal discharge occurence would take place during the summer     10 limitation will be exceeded by operation of SONGS Units 2 and 3.
t e inaccurate and misleading.
hen thermal impacts would be most severe."     This conclusion was       11      The DES states at *P* 5-27 "The greatest threat of SONGS to 12 apparently based on applicants' "worst case" modeling theory;             12 the long-term survival of the San Onofre kelp bed is the 13 however, in light of recent findings as a result of studies pre-         13 possibility of injury to the basal tissues from which the canopy t 14 sently being performed by the Marine Review Committee (MRC) at the       14 is regenerated each year ... under extreme worst case conditions e 15 request of the California Coastal Commission, it has been determindd     15 (e.g., several days with high ambient temperatures and slack 16 that the state thermal standards will ~ be met.       The following     16 currents, and with all the plants operating continuously),
The heated water will very likely esult in the destruction of at least a portion of the San Onofre elp bed during the summer months, the long-term thermal impacts violations of the state standards On page 5-7 of the DES it is stated:  
17 excerpts from the "Supplemental Staff Report And Recommendations -       17 destruction of the basal regenerative tissues might result."    The 18 Review of Thermal Requirements For San Onofre Nuclear Generating         18 DES further states:  " ... the community (kelp bed), if destroyed 19 Station, Units 2 and 3" prepared by the California State Water           191\frequently, could never achieve a stable state characteristic of 20 Quality Control Board staff are appropriate:     "The Report of the     20 other kelp beds in the area. Furthermore, constant temperature 21 MRC confirms the previous prediction that, under normal operating         21 increases coupled with added turbidity would be inimical to 22 conditions, the proposed discharge will violate the 20 degree F           22 interim reestablishment ... The perennial occurrence of worst case 23 temperature differential in the "receiving waters" i.e., waters           23 conditions seems highly unlikely and the staff thus concludes that 24 at the location and depth of the diffusers of Units 2 and 3.       This   24 the long-term thermal impacts from normal station operation are 25 Report notes:   ' ... if the "receiving" waters are defined as in         25 not likely to be severe."    (p . 5-27)  It is clear that since the 26 this paragraph, the standards of the State Thermal Plan will             26 state thermal discharge limitation will be exceeded during normal 27 probably be exceeded by the operation of Units 2 and 3.'       Although   27 operation of SONGS 2 and 3, the staff's conclusion was based on 1
"The staff there exists a remote possibility that thermal standards could be violated by the operation of 2 and 3, violations would, at worst, be infrequent and for periods.
28 the  R~port indicates that the discharge will "likely" or "probably
There is no evidence in available drift data to occurence would take place during the summer hen thermal impacts would be most severe." This conclusion was 12 apparently based on applicants' "worst case" modeling theory; 13 however, in light of recent findings as a result of studies pre-14 sently being performed by the Marine Review Committee (MRC) at the 15 request of the California Coastal Commission, it has been determindd 16 that the state thermal standards will ~
* 28 a faulty premise. Dischargers' normal plant operation will result 1 in continuous high temperature discharge approximating the worst      1  and alternative construction and operation with environmental 2 case conditions and resulting in both short and long-term thermal    2 quality standards and requirements which have been imposed by 3 impacts on the San Onofre kelp beds. The DES states at *p. 5-27  3 Federal, State, regional, and local agencies having responsibility 4 "It has been rather well established that temperatures above          4  for environmental protection, including applicable zoning and 5 18-20 degrees C. (64-68 degrees F) cause deterioration of kelp,      5 landuse regulations and water pollution limitations or requirement 6 and the degree of degradation is directly related to the duration      6 promulgated or imposed pursuant to the Federal Water Pollution 7 of the exposure to these temperatures."                              *711 Control  Act."
be met.
8      2. The DES is inadequate in its discussion of the 316(a)        8        3. The DES is inadequate in its evaluation and analysis of 9 exception process as related to thermal pollution caused by the      9 the social and economic impact of operating SONGS 2 and 3.
The following 17 excerpts from the "Supplemental Staff Report And Recommendations -
10 proposed action. Section 6.4.1 of the.DES discusses the "thermal  10            A. With respect to the environmental impact of SONGS 11 exception studies" as related only to periodic "heat treatment" to  11 on recreational resources, the DES reco~nizes the failure of 12 control fouling organisms. The DES fails to consider the 316(a)  12 applicants to comply with the terms and conditions of the
18 Review of Thermal Requirements For San Onofre Nuclear Generating 19 Station, Units 2 and 3" prepared by the California State Water 20 Quality Control Board staff are appropriate:  
:Ia 13 exception required for continuous high ambient temperature           13 construction permit:      "The current plan to restrict the use of I
"The Report of the 21 MRC confirms the previous prediction that, under normal operating 22 conditions, the proposed discharge will violate the 20 degree F 23 temperature differential in the "receiving waters" i.e., waters 24 at the location and depth of the diffusers of Units 2 and 3.
c  14 discharges during the normal operations of Units 2 and 3. It is  14 approximately 25%.of the 3 1/2 mile San Onofre Beach for the 30-15 highly likely that a 316(a) exception request will be forthcoming    15 year operating life of the plant is a significant loss of valuable 16 from applicants in light of the recent denial by the California      16 recreational and scenic space and represents a substantial change 17 State Water Quality Control Board of applicants' requested          17 in action between issuance of the FES-CP and application for an 18 interpretation    of the term "r~ceiving  waters" as used in the    18 operating license."      (Section 5.6.5) Staff reiterates previous 19 State Thermal Plan. Had applicants' interpretation been approved, 19 statements made in the FES-CP that "the beach ... is considered to 20 it would have obviated applicants' need for a 316(a) exception to    20 be a unique and scarce recreational resource," (FES-CP,      p. 2-11) 21 the requirements of the FWPCA. Because a 316(a) exception is      21  and "that closure even for a brief period is objectionable" 22 necessary for the operation of Units 2 and 3 in their present        22  (FES-CP,  p. 8-11). Despite the re-affirmation of these 23 desiga mode, the DES is inadequate for failure to consider the       23 judgments, staff concludes that the social and economic impact of 24 implications, both short and long-term, on the aquatic environment   24 operating SONGS 2 and 3 - with the significant exception of 25 if such an exception is granted. With respect to the maximum     25 restricting public use of the beach- will be only "moderate".
This 25 Report notes:  
26 temperature of thermal waste discharges, and contrary to the        26 The overall impact will be more severe than "moderate" if the 27 requirements of 10 CFR Part 51.23(c), due consideration was not     27 beach access restriction is factored into the balancing process.
'... if the "receiving" waters are defined as in 26 this paragraph, the standards of the State Thermal Plan will 27 probably be exceeded by the operation of Units 2 and 3.' Although 28 the R~port indicates that the discharge will "likely" or "probably1* 1 or "may" violate the temperature differential, there really is no 2 question that such violations will occur."
28 given to " ... compliance of the facility construction or operation 28 Staff's treatment of this issue is misleading and inconsistent 1 with the purpose and intent of NEPA, section 102(2)(c), which        1 the 50-mile radius for a large-break loss of coolant accident 2 calls for preparation of a detailed statement on, among other        2 (Table 7.2, p. 7-3, Class 8.1) is substantial and inadequately 3 things, any irreversible and irretrievable commitments of            3 discussed, if at all, in the text.
(pp. 4-5) 3 In a hearing for the purpose of interpreting the term "re-4 ceiving waters" held on December 21, 1978, the California State 5 Water Quality Control Board held that ".*. the temperature at the 6 intake point does not represent conditions at the receiving 7 aters," (p. 3 of Opinion of Chairman Bryson and Board Member 8 Mitchell) contrary to applicants' requested interpretation.
4 resources which would be involved in the proposed action should      4      5. The DES is inadequate in that it fails to discuss the 5 it be implemented. Restriction of the public's use of this beach    5 environmental impacts to the region in the event of an accidental 6 is such an irreversible and irretrievable commitment of resources. 6 release of radiation requiring evacuation. No discussion is 7          B. With respect to the economic impact of SONGS 2 and 3,  7 contained in the DES as to the adaptability of the San Onofre site 8 the DES provides no analysis of the effects of the Jarvis-Gann        8 to adequate evacuation processes including evacuation of the 9 Amendment (Proposition 13). The DES states that "The applicant      9 nearby beach areas during times of peak use; no discussion is 10 should reassess the potential tax benefits accruing to these        10 contained in the DES as to the suitability of existing evacuation 11 jurisdictions and districts in light of Proposition 13."            11 plans; no discussion is contained in the DES as to the effects 12 (p . 5-44)   This is a wholly inadequate treatment of the economic   12 which adoption of the NRC/EPA Task Force Report on Emergency
The 9 net result of this ruling is that the state thermal discharge 10 limitation will be exceeded by operation of SONGS Units 2 and 3.
.,.=-1 13 impact of SONGS 2 and 3, inasmuch as the revenue from the plant    13 Planning (NUREG-0396) will have on evacuation within the new and 14 and its allocation within communities will be "significantly        14 expanded Emergency Planning Zone as distinct from the presently CD 15 different from what was assumed" - to use the staff's own words -  15 designated Low Population Zone (NRC Regulations 10 CFR Part 100).
11 The DES states at *P* 5-27 "The greatest threat of SONGS to 12 the long-term survival of the San Onofre kelp bed is the 13 possibility of injury to the basal tissues from which the canopy 14 is regenerated each year... under extreme worst case conditions 15 (e.g., several days with high ambient temperatures and slack 16 currents, and with all the plants operating continuously),
16llin this economic impact analysis. (p  5-44, section 5.6.4)      16      6. The DES is inadequate in that it fails to reassess the 17      4. The DES inadequately evaluates the environmental impact  17 seismic design basis for SONGS 2 and 3 in light of a)  the 18 of postulated accidents in that Class 9 occurrences were omitted    18 dewatering-well cavities and b)  the recent earthquakes and faults 19 from consideration.   (Section 7-1)  The DES states on p. 7-2 with  19 discovered since the current design basis was established.
17 destruction of the basal regenerative tissues might result." The 18 DES further states:
20IIrespect to Class 9 occurrences that "Their consequences could be  20      7. The DES is inadequate in that the cost/benefit analysis 2tllsevere."  The DES fails to discuss the probability of Class 9     21  fails to provide consideration for the greatest possible 22lloccurrences in a complete and comprehensive manner. In view of   22 escalation of uranium prices, based on recent occurrences, for 23 the recent earthquake fault discoveries near the San Onofre site    23 SONGS 2 and 3 over the operating life of the plant. The projected 24 and the existence of the dewatering-well cavities found beneath    24 fuel costs identified as $87,900,000/yr for 1981 (Table 10.1, 25 the site, a full discussion of failures more severe than those      25 p. 10-2), will possibly escalate to a prohibitively high level 26 required for consideration in the design bases of protective        26 since long-term uranium contracts are generally tied to market 27 systems and engineered safety features (Class 9) is warranted.     27 price at delivery or 7$ per year escalation, whichever<is greater 28 Further, the estimated dose of 1400.00 man-rems to population in    28 Staff admits (section 10.3) that since the issuance of the FES-CP 1 the fuel, operating, and maintenance costs of nuclear plant                discuss the temporary storage of nuclear waste materials, 2 operation have escalated more rapidly than anticipated. The DES      2llincluding the interim storage of spent fuel, on site.
"... the community (kelp bed), if destroyed 191\\frequently, could never achieve a stable state characteristic of 20 other kelp beds in the area.
3 does not discuss adequately the possibility of additional future        3      10. The DES is inadequate in that it fails to discuss the 4 escalation of costs with respect to the fuel requirements of San        4 issue of plant security and provide assurances that all nuclear 5 Onofre, and does not utilize a "worst possible case" approach to       5 materials will remain accounted for and protected from the risk 6 determine total fuel costs over the operating life of the plant.       6 of terrorist or criminal activity or sabotage.
Furthermore, constant temperature 21 increases coupled with added turbidity would be inimical to 22 interim reestablishment... The perennial occurrence of worst case 23 conditions seems highly unlikely and the staff thus concludes that 24 the long-term thermal impacts from normal station operation are 25 not likely to be severe."
7 .The cost/benefit analysis contained in the DES is therefore            7      Because due consideration was not given to compliance with 8 invalid.                                                                8 the requirements of 10 CFR Part 51.23(c), and because this DES 9      8. The DES is inadequate in that it fails to discuss the         9 fails to consider all environmental impacts of the proposed action 10 possibility that decommissioning costs may escalate to                10 and alternatives to the proposed action as required by Section 11 prohibitively high levels by the end of the operating life of the      11 102(2)(c) of NEPA, staff's conclusion that the action called for 12 plant, at which time the applicant is required to prepare a            12 is the issuance of operating licenses for Units 2 and 3 of SONGS 13 proposed decommissioning plan for review by the NRC.   (Section 9.4  13 is premature and founded on insufficient and inaccurate data.
(p. 5-27) It is clear that since the 26 state thermal discharge limitation will be exceeded during normal 27 operation of SONGS 2 and 3, the staff's conclusion was based on 28 a faulty premise.
r
Dischargers' normal plant operation will result
:Ia I c 1 in continuous high temperature discharge approximating the worst 2 case conditions and resulting in both short and long-term thermal 3 impacts on the San Onofre kelp beds.
The DES states at *p. 5-27 4 "It has been rather well established that temperatures above 5 18-20 degrees C. (64-68 degrees F) cause deterioration of kelp, 6 and the degree of degradation is directly related to the duration 7 of the exposure to these temperatures."
8
: 2.
The DES is inadequate in its discussion of the 316(a) 9 exception process as related to thermal pollution caused by the 10 proposed action.
Section 6.4.1 of the.DES discusses the "thermal 11 exception studies" as related only to periodic "heat treatment" to 12 control fouling organisms.
The DES fails to consider the 316(a) 13 exception required for continuous high ambient temperature 14 discharges during the normal operations of Units 2 and 3. It is 15 highly likely that a 316(a) exception request will be forthcoming 16 from applicants in light of the recent denial by the California 17 State Water Quality Control Board of applicants' requested 18 interpretation of the term "r~ceiving waters" as used in the 19 State Thermal Plan.
Had applicants' interpretation been approved, 20 it would have obviated applicants' need for a 316(a) exception to 21 the requirements of the FWPCA.
Because a 316(a) exception is 22 necessary for the operation of Units 2 and 3 in their present 23 desiga mode, the DES is inadequate for failure to consider the 24 implications, both short and long-term, on the aquatic environment 25 if such an exception is granted.
With respect to the maximum 26 temperature of thermal waste discharges, and contrary to the 27 requirements of 10 CFR Part 51.23(c), due consideration was not 28 given to "... compliance of the facility construction or operation 1 and alternative construction and operation with environmental 2 quality standards and requirements which have been imposed by 3 Federal, State, regional, and local agencies having responsibility 4 for environmental protection, including applicable zoning and 5 landuse regulations and water pollution limitations or requirement 6 promulgated or imposed pursuant to the Federal Water Pollution
*711 Control Act."
8 9
: 3.
The DES is inadequate in its evaluation and analysis of the social and economic impact of operating SONGS 2 and 3.
10 A.
With respect to the environmental impact of SONGS 11 on recreational resources, the DES reco~nizes the failure of 12 applicants to comply with the terms and conditions of the 13 construction permit:
"The current plan to restrict the use of 14 approximately 25%.of the 3 1/2 mile San Onofre Beach for the 30-15 year operating life of the plant is a significant loss of valuable 16 recreational and scenic space and represents a substantial change 17 in action between issuance of the FES-CP and application for an 18 operating license."
(Section 5.6.5) Staff reiterates previous 19 statements made in the FES-CP that "the beach... is considered to 20 be a unique and scarce recreational resource," (FES-CP,
: p. 2-11) 21 and "that closure even for a brief period is objectionable" 22 (FES-CP,
: p. 8-11).
Despite the re-affirmation of these 23 judgments, staff concludes that the social and economic impact of 24 operating SONGS 2 and 3 - with the significant exception of 25 restricting public use of the beach-will be only "moderate".
26 The overall impact will be more severe than "moderate" if the 27 beach access restriction is factored into the balancing process.
28 Staff's treatment of this issue is misleading and inconsistent
=-
1.,.
CD 1 with the purpose and intent of NEPA, section 102(2)(c), which 2 calls for preparation of a detailed statement on, among other 3 things, any irreversible and irretrievable commitments of 4 resources which would be involved in the proposed action should 5 it be implemented.
Restriction of the public's use of this beach 6 is such an irreversible and irretrievable commitment of resources.
7 B.
With respect to the economic impact of SONGS 2 and 3, 8 the DES provides no analysis of the effects of the Jarvis-Gann 9 Amendment (Proposition 13).
The DES states that "The applicant 10 should reassess the potential tax benefits accruing to these 11 jurisdictions and districts in light of Proposition 13."
12 (p. 5-44)
This is a wholly inadequate treatment of the economic 13 impact of SONGS 2 and 3, inasmuch as the revenue from the plant 14 and its allocation within communities will be "significantly 15 different from what was assumed" - to use the staff's own words -
16llin this economic impact analysis.
(p 5-44, section 5.6.4) 17
: 4.
The DES inadequately evaluates the environmental impact 18 of postulated accidents in that Class 9 occurrences were omitted 19 from consideration.
(Section 7-1)
The DES states on p. 7-2 with 20IIrespect to Class 9 occurrences that "Their consequences could be 2tllsevere." The DES fails to discuss the probability of Class 9 22lloccurrences in a complete and comprehensive manner.
In view of 23 the recent earthquake fault discoveries near the San Onofre site 24 and the existence of the dewatering-well cavities found beneath 25 the site, a full discussion of failures more severe than those 26 required for consideration in the design bases of protective 27 systems and engineered safety features (Class 9) is warranted.
28 Further, the estimated dose of 1400.00 man-rems to population in 1 the 50-mile radius for a large-break loss of coolant accident 2 (Table 7.2, p. 7-3, Class 8.1) is substantial and inadequately 3 discussed, if at all, in the text.
4
: 5.
The DES is inadequate in that it fails to discuss the 5 environmental impacts to the region in the event of an accidental 6 release of radiation requiring evacuation.
No discussion is 7 contained in the DES as to the adaptability of the San Onofre site 8 to adequate evacuation processes including evacuation of the 9 nearby beach areas during times of peak use; no discussion is 10 contained in the DES as to the suitability of existing evacuation 11 plans; no discussion is contained in the DES as to the effects 12 which adoption of the NRC/EPA Task Force Report on Emergency 13 Planning (NUREG-0396) will have on evacuation within the new and 14 expanded Emergency Planning Zone as distinct from the presently 15 designated Low Population Zone (NRC Regulations 10 CFR Part 100).
16
: 6.
The DES is inadequate in that it fails to reassess the 17 seismic design basis for SONGS 2 and 3 in light of a) the 18 dewatering-well cavities and b) the recent earthquakes and faults 19 discovered since the current design basis was established.
20
: 7.
The DES is inadequate in that the cost/benefit analysis 21 fails to provide consideration for the greatest possible 22 escalation of uranium prices, based on recent occurrences, for 23 SONGS 2 and 3 over the operating life of the plant.
The projected 24 fuel costs identified as $87,900,000/yr for 1981 (Table 10.1, 25 p. 10-2), will possibly escalate to a prohibitively high level 26 since long-term uranium contracts are generally tied to market 27 price at delivery or 7$ per year escalation, whichever<is greater 28 Staff admits (section 10.3) that since the issuance of the FES-CP r  
~
~
14 Although NRC regulations do not require the applicant to have 15 developed a decommissioning plan at the time an operating license 14      For the foregoing reasons, intervenors request that the NRC 15 either a)    adequately address the issues raised above in the final 16 is obtained, the discussion of alternative decommissioning methods     16 environmental statement for SONGS 2 and 3, or. b)  deny applicants' 17 and their associated costs found in the DES is misleading and does     l7llrequest for licenses to operate SONGS 2 and 3.
1 the fuel, operating, and maintenance costs of nuclear plant 2 operation have escalated more rapidly than anticipated.
18 not present an accurate projection of what the actual decommission 19 ing costs for SONGS will be. Staff calculations for determining 18 Dated:
The DES 3 does not discuss adequately the possibility of additional future 4 escalation of costs with respect to the fuel requirements of San 5 Onofre, and does not utilize a "worst possible case" approach to 6 determine total fuel costs over the operating life of the plant.
19 0b__....v -:)OJ I 12 7f    Respectfully submitted, 20 decommissioning costs per unit of electricity generated do not         20 21 utilize a start-up date of 1981 or an escalation rate based on the     21 22 current rate of inflation. Staff's projection that "For the         22 23 SONGS Units 2 and 3 the decommissioning costs would be. about         23 24 double that indicated for all of the decommissioning one-unit         24 25 alternatives'.' (p. 9-17) is wholly inadequate for purposes of         25 2611making an informed cost/benefit judgment. As a consequence, the   I 26 2711cost/benefit analysis for SONGS 2 and 3 is invalid.                   27 28       9. The DES is inadequate in that it fails to comprehensively     28 Table of Contents Federal Energy Regulatory Conmission, *.**...* ,, ................ , .* A-56 U.S. Department of Agriculture, Economics and Statistics Service .......................................... A-52 Mr. Frank H. Arundel. ............................................. A-53 U.S. Department of Agriculture, Soil Conservation Service ................. , ........ , ................. A-54 U.S. Department of the Interior ................................... A-55 COMMENTS ON Richard J. Wharton .****.*.*****.*****.*.*.*...*.....*..*......*... A-55 SUPPlEMENT TO Union of Concerned Scientists. . . * * * * * * * * * * * * * . * * * * * * * * * * * * * . * . . . . . A-63
7.The cost/benefit analysis contained in the DES is therefore 8 invalid.
9
: 8.
The DES is inadequate in that it fails to discuss the 10 possibility that decommissioning costs may escalate to 11 prohibitively high levels by the end of the operating life of the 12 plant, at which time the applicant is required to prepare a 13 proposed decommissioning plan for review by the NRC.
(Section 9.4 14 Although NRC regulations do not require the applicant to have 15 developed a decommissioning plan at the time an operating license 16 is obtained, the discussion of alternative decommissioning methods 17 and their associated costs found in the DES is misleading and does 18 not present an accurate projection of what the actual decommission 19 ing costs for SONGS will be. Staff calculations for determining 20 decommissioning costs per unit of electricity generated do not 21 utilize a start-up date of 1981 or an escalation rate based on the 22 current rate of inflation. Staff's projection that "For the 23 SONGS Units 2 and 3 the decommissioning costs would be. about 24 double that indicated for all of the decommissioning one-unit 25 alternatives'.' (p. 9-17) is wholly inadequate for purposes of discuss the temporary storage of nuclear waste materials, 2llincluding the interim storage of spent fuel, on site.
3
: 10.
The DES is inadequate in that it fails to discuss the 4 issue of plant security and provide assurances that all nuclear 5 materials will remain accounted for and protected from the risk 6 of terrorist or criminal activity or sabotage.
7 Because due consideration was not given to compliance with 8 the requirements of 10 CFR Part 51.23(c), and because this DES 9 fails to consider all environmental impacts of the proposed action 10 and alternatives to the proposed action as required by Section 11 102(2)(c) of NEPA, staff's conclusion that the action called for 12 is the issuance of operating licenses for Units 2 and 3 of SONGS 13 is premature and founded on insufficient and inaccurate data.
14 For the foregoing reasons, intervenors request that the NRC 15 either a) adequately address the issues raised above in the final 16 environmental statement for SONGS 2 and 3, or. b) deny applicants' l7llrequest for licenses to operate 18 Dated: b__....v -:)OJ 12 7f 0
I 19 20 21 22 23 24 25 SONGS 2 and 3.
Respectfully submitted, 2611making an informed cost/benefit judgment.
As a consequence, the I
26 2711cost/benefit analysis for SONGS 2 and 3 is invalid.
28
: 9.
The DES is inadequate in that it fails to comprehensively 27 28  
~
~
.... DRAFT ENVIRONMENTAL STATEMENT U.S. Environmental Protection Agency .............................. A-65 San Diego Association of Governments .............................. A-68 Southern California Edison Company ................................ A-71
COMMENTS ON SUPPlEMENT TO DRAFT ENVIRONMENTAL STATEMENT Table of Contents Federal Energy Regulatory Conmission, *.**...*,,................,.* A-56 U.S. Department of Agriculture, Economics and Statistics Service.......................................... A-52 Mr. Frank H. Arundel.............................................. A-53 U.S. Department of Agriculture, Soil Conservation Service.................,........,................. A-54 U.S. Department of the Interior................................... A-55 Richard J. Wharton.****.*.*****.*****.*.*.*...*.....*..*......*... A-55 Union of Concerned Scientists... * * * * * * * * * * * * *. * * * * * * * * * * * * *. *..... A-63 U.S. Environmental Protection Agency.............................. A-65 San Diego Association of Governments.............................. A-68 Southern California Edison Company................................ A-71  


FEDERAL ENERGY REGULATORY COMMISSION G        United Slates Department of Agriculture L.vnilmics and Statistics Service Washington. D.C.
~
20250
FEDERAL ENERGY REGULATORY COMMISSION WASHINGTON 20428 L'>
                      ,.,         WASHINGTON 20428 L'>
"*~*
r:                                     IN REPLY REP'Cft T01 L .:~:*                                                                                                                           January 26, 1981 January 23, 1981
~
              ;;*-*
,., r:
              "*~*
L.:~:*
              ~                                                                                Mr. Frank J. Miraglia Acting Chief, Licensing Branch No. 3 Division of Licensing U. s. Nuclear Regulatory. Commission Washington, D. C. 20555 Mr. Frank J. Miraglia Acting Chief, Licesning Branch                                                         
Mr. Frank J. Miraglia Acting Chief, Licesning Branch No. 3 Division of Licensing U.S. Nuclear Regulatory Commission Washington, D. c.
20555  


==Dear Mr. Miraglia:==
==Dear Mr. Miraglia:==
 
IN REPLY REP'Cft T01 January 23, 1981 I am replying to your request of January 16, 1981 to the Federal Energy Regulatory Commission for comments on the Supple-ment to the Draft Environmental Impact Statement related to the operation of the San Onofre Nuclear Generating Station, Units 2 and 3, This Draft EIS has been reviewed by approprlatu PERC staff components upon whose evaluation this r~sponse is based.
No. 3
This staff concentrates its review of. other agencies' en-vironmental impact statements basically on those areas of the electric power, natural gas, and oil pipeline industries for which the Commission has jurisdiction by law, or where staff has special expertise in evaluating environmental impacts in-voled with the proposed action. It does not appear that there would be any significant impacts in these areas of concern nor serious conflicts with this agency's responsibilities shoulc1 this action be undertaken.
* Division of Licensing                                                                    Thank you for forwarding the Supplement to the Draft Environmental U.S. Nuclear Regulatory Commission                                                        Statement for the San Onofre Nuclear Generating Station, Units 2 and 3.
Thank you for the op~rtunity to review this statement.
Washington, D. c. 20555 We have reviewed the materia~, Docket Numblrs 50-3&1 and   50-3~, and
Sincerely, Heinemann on Environmental Quality Sl o :; :*Q r 1D1' G
~
:..~*-
:..! ~: ~
r::. ~;
United Slates Department of Agriculture L.vnilmics and Statistics Service Mr. Frank J. Miraglia Acting Chief, Licensing Branch No. 3 Division of Licensing U. s. Nuclear Regulatory. Commission Washington, D. C.
20555


==Dear Mr. Miraglia:==
==Dear Mr. Miraglia:==
have no comments at this time.
Washington. D.C.
I am replying to your request of January 16, 1981 to the                          Sincerely, Federal Energy Regulatory Commission for comments on the Supple-
20250 January 26, 1981 Thank you for forwarding the Supplement to the Draft Environmental Statement for the San Onofre Nuclear Generating Station, Units 2 and 3.
~      ment to the Draft Environmental Impact Statement related to the operation of the San Onofre Nuclear Generating Station, Units 2 and 3, This Draft EIS has been reviewed by approprlatu PERC                              MLL~
We have reviewed the materia~, Docket Numblrs 50-3&1 and 50-3~, and have no comments at this time.
staff components upon whose evaluation this r~sponse is based.                            MELVIN L. COTNER Director, Natural Resource This staff concentrates its review of. other agencies' en-                              Economics Division vironmental impact statements basically on those areas of the electric power, natural gas, and oil pipeline industries for which the Commission has jurisdiction by law, or where staff has special expertise in evaluating environmental impacts in-voled with the proposed action. It does not appear that there would be any significant impacts in these areas of concern nor serious conflicts with this agency's responsibilities shoulc1 this action be undertaken.
Sincerely, MLL~
Thank you for the  op~rtunity  to review this statement.
MELVIN L. COTNER Director, Natural Resource Economics Division r*-
Sincerely, r*-
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Il?IF&sect;]IDtlfiw                                                                                                 TIMES-ADVOCATE
Il?IF&sect;]IDtlfiw l: ;c.4 TIMES-ADYOCATt, ESC;ONOIDO, cA., SUNDAY, JAH. :zs, 19111 Nuclear neighbor asks for discount 11J DICK PlllWPS
                                                                                                                        ~***~
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deoiCMd to pro-
                                                                                                                                                                  -     Unlhld Slata Depar1mont of Agtfculture Soli Conaervation servtce 2828 Chiles Road Davfs,*CA* 95616 (916) 758-2200 February 11, 1981 Mr. Frank J, Miraglia l: ;c.4      TIMES-ADYOCATt, ESC;ONOIDO, cA., SUNDAY, JAH. :zs, 19111                                                                                                  Acting Chief, Licensing Branch No. 3 Division of licensing U.S. Nuclear Regulatory Commission Nuclear neighbor                                                                                                                                                    1-/ashington, D.C. 20555
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Unlhld Slata Depar1mont of Agtfculture Soli Conaervation servtce Mr. Frank J, Miraglia Acting Chief, Licensing Branch No. 3 Division of licensing U.S. Nuclear Regulatory Commission 1-/ashington, D.C.
20555  


==Dear Mr. Miraglia:==
==Dear Mr. Miraglia:==
2828 Chiles Road Davfs,*CA* 95616 (916) 758-2200 February 11, 1981 The Soil Conservation Service has reviewed the Supplement to the Draft Environmental Statement for San Onofre Nuclear Generating Station, Units 2 and 3.
We find no controversial items within the realm of SCS responsi-bilities.
This Environmental Statement Supplement reveals no conflicts with any of the ongoing projects within our jurisdiction.
No prime land will be lost to the proposed project.
We appreciate the opportunity to review and comment on this report.
Sincerely,
~~* t:Ut/_./
FRANCIS C. H.
LU~I State Conservationist cc:
Norman A. Berg, Chief, SCS, Washington, D.C.
Jack Smith, Area Conservationist, Escondido, CA
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asks for discount                                                                                                                                                    The Soil Conservation Service has reviewed the Supplement to the Draft Environmental Statement for San Onofre Nuclear Generating Station, Units 11J DICK PlllWPS
1:
* BaaO=h. II.O.DIIItllofOceaii-                                                                                        2 and 3. We find no controversial items within the realm of SCS responsi-T-A lid Wrlllr      .        lldt, llu- apenUDc ft1ICiw piiDI,                                                                                      bilities.
United States Department of the Interior OFFICE OF THE SECRETARY WASHINGTON, D.C. 20240 ER 81/80 Mr. Frank J. Miraglia Acting Chief Licensing Branch No. 3 Division of Licensing Nuclear Regulatory Commission Washington, D.C.
QCEAHSII)B- .All Oceu&l4e- wlllcll ... -                        dnD fott npaln II wwtfnc to aclllne a COIIIIderalllt lllrovebiiiOitof 1.110. UIIIIIJIIIIIII&N                                                                                      This Environmental Statement Supplement reveals no conflicts with any of the l'lldllclloD Ia aU111J ratu for a-U.. MU1aJ complllloa. at a CCII& of 1U to 111c aur lilt SaiiOIIolnl a:eclw powo IS lllllloll. llol!l - deoiCMd to pro-                                                                                        ongoing projects within our jurisdiction. No prime land will be lost to the
20555  
* plaiiL                                    dllCo l,lllO ....- o f tlec:lridl7*                                                                                    proposed project.
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    ...,. - aur San Ollolnl. He lblaU            11u 20 pereeat. Tba SOOH aerY1eo                                                                                        Sincerely, lllrJIIlotdd cat a 10 pereeat dlJeoulll      a r a - abouU,))Omecawatta
                                                                                                                                                                    ~~*
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t:Ut/_./
LU~I nd11ll a 40 perea~t rate rtclvdlcll;          eoplu dl Anllldel'a pn>posal bevo JIOOPiellrinc lila 40- to JO.tda nd11ll      baeD llvtA lo lba .mnmte"""""' lor                                                                                    State Conservationist aboaldbe'NibalrraluCIItbtiOJ*'"              lltltdr* "llul, I dal't ..... til oat..,..
CilllL.                                      tioD plalllld. lba lllbjeel," Jlatlu                                                                                  cc: Norman A. Berg, Chief, SCS, Washington, D.C.
        ''l'laplt bent - bailie ..... 10          lllld..                                                                                                                      Jack Smith, Area Conservationist, Escondido, CA deatb bt uWty ntu," 1114 AniDdel. .            He uld lilt commlalloa reacbaa 116-
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                                                                                                                                                                '81102180            !>&'
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                                                                                                                                                                  \!JI ~7-rA::ufttK*                                                                  I Own
 
United States Department of the Interior OFFICE OF THE SECRETARY                                 RICHARD J. WHARTON WASHINGTON, D.C. 20240                                 Attorney at Law University of San Diego ER 81/80                                                                     Alcala Park, California 92110 MPR      2 1981 (714) 291-6480  Ext. 4376 Attorney for Intervenors Mr. Frank J. Miraglia UNITED STATES OF AMERICA Acting Chief Licensing Branch No. 3                                                                         NUCLEAR REGULATORY COMMISSION Division of Licensing Nuclear Regulatory Commission                                                       BEFORE THE ATOMIC SAFETY AND LICENSING BOARD Washington, D.C. 20555


==Dear Mr. Miraglia:==
==Dear Mr. Miraglia:==
 
MPR 2 1981 We have reviewed the supplement to the draft environmental statement for San Onofre Nuclear"Generating Station, Units 2 and 3, San Diego, California, and find we have no comments.
In the Matter of We have reviewed the supplement to the draft environmental                                                           DOCKET Nos. 50-361 OL SOUTHERN CALIFORNIA                            50-362 OL statement for San Onofre Nuclear"Generating Station, Units 2                     EDISON COMPANY, et al.
The opportunity to review this document is appreciated.  
JOINT INTERVENORS COMMENTS ON SUPPLEME~:
*cECf!.. S. He;  
and 3, San Diego, California, and find we have no comments.                                                       TO DRAFT ENVIRONMENTAL STATEMENT RELATE 1:
'-'-'*'-'"*"' s1RI'ii-&#xa5;1Rfssistant to RICHARD J. WHARTON Attorney at Law University of San Diego Alcala Park, California 92110 (714) 291-6480 Ext. 4376 Attorney for Intervenors UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of SOUTHERN CALIFORNIA EDISON COMPANY, et al.
(San Onofre Nuclear Generating Station, Units 2 and 3)            TO OPERATION OF SAN ONOFRE NUCLEAR The opportunity to review this document is appreciated.                                                           GENERATING STATIONS, UNITS 2 and 3 (NUREG-0490)
(San Onofre Nuclear Generating Station, Units 2 and 3)
                                            *cECf!.. S. He;                               The Supplement to Draft Environmental Statement (NUREG-
DOCKET Nos. 50-361 OL 50-362 OL JOINT INTERVENORS COMMENTS ON SUPPLEME~:
                                '-'-'*'-'"*"' s1RI'ii-&#xa5;1Rfssistant to 0490, December, l9BO), hereinafter referred to as NUREG-0490, pre-pared by the Office of Reactor Regulation (Staff) of the united states Nuclear Regulatory Commission (NRC) related to the opera-tion of San Onofre Nuclear Generating Station, Units 2 and 3 (SONGS 2 and 3) has been reviewed by Intervenors in relation to the requirements imposed by the National Environmental Policy Act (NEPA) (42 O.S.C. J 4321, et seq.), 10 C.P.R. Part 51, and 40 C.P.R. Part 1502. Intervenors comments on the proposed action and on NUREG-0490 are made pursuant to 10 C.F.R. Part 51.25 and 40 C.P.R. Part 1503.
TO DRAFT ENVIRONMENTAL STATEMENT RELATE TO OPERATION OF SAN ONOFRE NUCLEAR GENERATING STATIONS, UNITS 2 and 3 (NUREG-0490)
The Supplement to Draft Environmental Statement (NUREG-0490, December, l9BO), hereinafter referred to as NUREG-0490, pre-pared by the Office of Reactor Regulation (Staff) of the united states Nuclear Regulatory Commission (NRC) related to the opera-tion of San Onofre Nuclear Generating Station, Units 2 and 3 (SONGS 2 and 3) has been reviewed by Intervenors in relation to the requirements imposed by the National Environmental Policy Act (NEPA) (42 O.S.C. J 4321, et seq.), 10 C.P.R. Part 51, and 40 C.P.R. Part 1502.
Intervenors comments on the proposed action and on NUREG-0490 are made pursuant to 10 C.F.R. Part 51.25 and 40 C.P.R. Part 1503.
8108180S.:Z&
8108180S.:Z&
 
i:
The purpose of NU~EG-0490 was *to identify and evaluate Office of Emergency Services (OES) to prepare Emergency Response the site-specific environmental impacts attributable to accident Plans for potentially severe nuclear accidents involving the sequences that lead to releases of radiation and/or radioactive release of large  amounts of radiation. In order to plan for materials including sequences that can result in inadequate such accidents, the State required information.of the potential cooling of reactor fuel and to melting of the reactor core.*
The purpose of NU~EG-0490 was *to identify and evaluate the site-specific environmental impacts attributable to accident sequences that lead to releases of radiation and/or radioactive materials including sequences that can result in inadequate cooling of reactor fuel and to melting of the reactor core.*
sc~narios and consequences that could result from meltdowns in NUREG-0490, p. vi. These accident sequences are commonly referred California reactors. The State lead agency, OES, contracted to as meltdowns or Class 9 accidents.
NUREG-0490, p. vi.
with a conservative consulting group, Science Applications, Inc.
These accident sequences are commonly referred to as meltdowns or Class 9 accidents.
The NRC's historic first site-specific impact study of a (SAI), to study the consequences and potential scenarios of meltdown accident at a California nuclear reaction is inadequate, meltdowns at California reactors. SAI has conducted research incomplete and misleading. NUREG-0490 is misleading because it for the NRC, the Department of Energy, .nuclear military projects, does not provide decision-makers with sufficiently detailed nuclear utilities, and the nuclear industry. The SAI-OES study information regarding the potential environmental impacts of a was released to the public in Sacramento,   California on July 15, meltdown at SONGS 2 and 3 to aid them in a substantive decision 1980. The portion of the SAI-OES study which relates to SONGS whether or not to proceed with granting an operating license to 2 and 3 was based on extensive site-specific data whereas NUREG-i: this federal nuclear project in light of the economic and other consequences of an accident at SONGS 2 and 3. NUREG-0490 does 0490, while it purports to be based on site-specific data, considers mainly excerpted "data, methodology and assumptions" not encourage public participation because it does not make        from the WASH-1400 study. The inadequacies of this approach adequate information available to the public in non-technical are demonstrated by the following comparison petween the SAI-OES language about the potential economic and environmental impacts study and NUREG-0490 consequence analyses:
The NRC's historic first site-specific impact study of a meltdown accident at a California nuclear reaction is inadequate, incomplete and misleading.
that could affect the  li~es of twelve million people. NUREG-0490 The SAI-OES study indicates that the maximum consequences appears inadequate and incomplete when compared with other indepen~ for a nuclear meltdown at SONGS 2 and 3 would be $180 billion'in dent meltdown impact analyses.                                      economic cost consequences, NUREG-0490 estimates $35 billion, SAI-OES After the Three Mile Island accident, which resulted      estimates 16,000 square miles of land contaminated with radiation, in mass evacuations and temporary relocation of many people, the    NUREG-0490 estimates 3,000 square miles: SAI-OES estimates eight California state Legislature passed a law (Senate Bill 1183, now    to ten million Southern Californians would be required to relocate Section 8610.5 of the Government Code), which required the State    and leave their homes and property for up to ten years. Four to five million of them would have to be relocated lon~er than ten years, NUREG-0490 gives no estimates for the magnitude of the        evacuations would take place out to 30 miles downwind from the population affected by relocation.      SAI-OES estimates that in    reactor accident. NUREG-0490, estimates the maximum conseqnences 1975 there were 7.7 million people living within 60 miles of          of a San Onofre meltdown to be $35 billion in costs for mitigating the San Onofre site. Within 100 miles there are approximately    actions (evacuations, relocations, land interdiction, emergency 12 millton people. The SAI-OES study acknowledges that "Latent    response by local, county, state and federal teams), 1 million
NUREG-0490 is misleading because it does not provide decision-makers with sufficiently detailed information regarding the potential environmental impacts of a meltdown at SONGS 2 and 3 to aid them in a substantive decision whether or not to proceed with granting an operating license to this federal nuclear project in light of the economic and other consequences of an accident at SONGS 2 and 3.
  ~eaths  from San Onofre can occur within 100 miles, which includes    ~eople would receive more than 25 rems, there would be 130,000 half of the population of California.*      Another report done for  acute fatalities, and 300,000 latent cancers in the population the California  Stat~  Legislature, discussed below, warns that      within SO miles who would be exposed to 30 to 40 billion person children within 100 miles downwind from the reactor would receive    rems released during the accident.
NUREG-0490 does not encourage public participation because it does not make adequate information available to the public in non-technical language about the potential economic and environmental impacts that could affect the li~es of twelve million people.
damage to their thyroid glands and would require surgery due to                The consequences of nuclear power plant core melt exposure to radioactive iodine gases.      The SAl-OES study also    accidents have also been estimated at the request of the
NUREG-0490 appears inadequate and incomplete when compared with other indepen~
dent meltdown impact analyses.
After the Three Mile Island accident, which resulted in mass evacuations and temporary relocation of many people, the California state Legislature passed a law (Senate Bill 1183, now Section 8610.5 of the Government Code), which required the State Office of Emergency Services (OES) to prepare Emergency Response Plans for potentially severe nuclear accidents involving the release of large amounts of radiation.
In order to plan for such accidents, the State required information.of the potential sc~narios and consequences that could result from meltdowns in California reactors.
The State lead agency, OES, contracted with a conservative consulting group, Science Applications, Inc.
(SAI), to study the consequences and potential scenarios of meltdowns at California reactors.
SAI has conducted research for the NRC, the Department of Energy,.nuclear military projects, nuclear utilities, and the nuclear industry.
The SAI-OES study was released to the public in Sacramento, California on July 15, 1980.
The portion of the SAI-OES study which relates to SONGS 2 and 3 was based on extensive site-specific data whereas NUREG-0490, while it purports to be based on site-specific data, considers mainly excerpted "data, methodology and assumptions" from the WASH-1400 study.
The inadequacies of this approach are demonstrated by the following comparison petween the SAI-OES study and NUREG-0490 consequence analyses:
The SAI-OES study indicates that the maximum consequences for a nuclear meltdown at SONGS 2 and 3 would be $180 billion'in economic cost consequences, NUREG-0490 estimates $35 billion, SAI-OES estimates 16,000 square miles of land contaminated with radiation, NUREG-0490 estimates 3,000 square miles: SAI-OES estimates eight to ten million Southern Californians would be required to relocate and leave their homes and property for up to ten years.
Four to five million of them would have to be relocated lon~er than ten  
~
~
estimates that $6.6 billion in cost consequences could occur         California State Legislature and the President's Council on within 500 miles of San Onofre following a meltdown.       Reports   Environmental Quality by Dr. Jan Beyea and Dr. Frank von Rippel, to the President's council on Environmental Quality warn that         nuclear physicists with the Princeton University's Program on areas as far away as 1,000 miles or more could be affected, and       Nuclear Policy Alternatives of the Center for Energy and Envir-that up to 125,000 square miles of land could suffer some contam-     onmental Studies. or. Beyea noted in his analysis that a melt-ination or crop or milk interdiction.      The possibility exists that down with a release of radioactive gases from a large reactor could Southern California could be permanently contaminated after a          involve "health effects and possible land use restrictions have meltdown at SONGS 2 and 3.      This is not surprising when we look    been considered out to distances of 1,000 miles and for periods at other accident scenarios and compare their estimates.              of decades after the release.*   He estimates that up to 175,000 One NRC analysis of reactor accidents, WASH-740, esti-    square miles of land could be under some form of interdiction or mated that an area the size of Pennsylvania could be permanently      restricted use following the meltdown. He explains this by saying contaminated by a meltdown at a reactor significantly smaller          "The number of health effects and the . *
years, NUREG-0490 gives no estimates for the magnitude of the population affected by relocation.
* land contamination than either Unit 2 or 3 at San Onofre.      Another report, the      can range so high because a substantial fraction of the released Rasmussen report, WASH-1400, estimated that 3,000 square miles        radioactivity can be carried for hundreds of miles downwind of land would be contaminated, but assumed that effective before being removed from the atmosphere by deposition on the                 (l)  The three reactors at Sen Onofre are uniquely ground. Dr. Beyea told the President's council on Environmental located near the intersection of two major Fault zones, the Quality (CEQ) that *early fatalities could occur up to 30 miles   Cristianitos and the Newport-Inglewood. Prior to l980, the downwind" of a reactor meltdown. Or. Frank von Hippe! testified NRC believed there was no structural relationship between the before the California State Leqislature after Three Mile Island   two Fault Zones. However, in 1980, fede;al and state marine
SAI-OES estimates that in 1975 there were 7.7 million people living within 60 miles of the San Onofre site.
  ~hat "the thyroid could receive a radiation dose tens to hundreds geologists discovered a new zone of faults which they named of times higher than the rest of the body. Exposed children     *cristianitos Zone of Deformation" which project directly more than a hundred miles downwind would suffer thyroid damage    beneath the three reactors. Thus, the possibility of damage which would require surgery years later." (emphasis added)         to the reactors during earthquakes is higher now because of the NUREG-0490 did not reference the SAI-OES study, in spite of.*the   possibility of surface rupture directly under the reactors.
Within 100 miles there are approximately 12 millton people.
fact that the Atomic Safety and Licensing Board {ASLB) and the    This was not factored into the Rasmussen Report, WASH-1400, the NRC Staff were made aware of the report by Intervenors during     Lewis Report, SAI-OES or NUREG-0490. NUREG-0490 does not even
The SAI-OES study acknowledges that "Latent
; July and August of 1960, six months before NUREG-0490 was issued.
~eaths from San Onofre can occur within 100 miles, which includes half of the population of California.*
The SAI-OES study is a conservative report in that it mention geologic-seismic site-specific events as a significantly possible factor in the probabilistic risk assessment.
Another report done for the California Stat~ Legislature, discussed below, warns that children within 100 miles downwind from the reactor would receive damage to their thyroid glands and would require surgery due to exposure to radioactive iodine gases.
calculates its predictions and models  ba~ed on site-specific                (2)   The San Onofre site is uniquely located on the data. NUREG-0490 is not conservative and is inadequate because  Pacific plate, near the Plate Tectonic Boundary Fault, the it is not sufficiently based on site-specific data. The SAI-OES  San Andreas. San Onofre is moving north in relation to the report used extensive site-specific data regarding the nearby    North American Plate. These reactors are uniquely migrating population centers and the various weather conditions in Southern  north on a geologic time scnle. Plate Tectonics were not under-California. That report identified several site-specific unique  stood when the San Onofre site was originally chosen in 1962.
The SAl-OES study also estimates that $6.6 billion in cost consequences could occur within 500 miles of San Onofre following a meltdown.
features which should have warranted a different conclusion from  It was not until 1969 that the plate tectonics theories were the NRC Staff than "there are no special or unique features about  accepted; the Sen Onofre site and environe that would warrant special or                (3)   The San Onofre site has the unique feature of additional engineered safety features for the San Onofre plants.*  baing sited close to San Onofre Unit 1. If Unit l had a melt-Joint Intervenors conclude there are special and unique features  down, it would sevenly effect operations of Units 2 and 3, that exist at the San onofre site which are listed as follows:    resulting in various consequences, none of which were considered in NUREG-0490. The older reactor at the site, San Onofre Unit 1,
Reports to the President's council on Environmental Quality warn that areas as far away as 1,000 miles or more could be affected, and that up to 125,000 square miles of land could suffer some contam-ination or crop or milk interdiction.
                                  -~                                                                   -~
The possibility exists that Southern California could be permanently contaminated after a meltdown at SONGS 2 and 3.
This is not surprising when we look at other accident scenarios and compare their estimates.
One NRC analysis of reactor accidents, WASH-740, esti-mated that an area the size of Pennsylvania could be permanently contaminated by a meltdown at a reactor significantly smaller than either Unit 2 or 3 at San Onofre.
Another report, the Rasmussen report, WASH-1400, estimated that 3,000 square miles of land would be contaminated, but assumed that effective evacuations would take place out to 30 miles downwind from the reactor accident.
NUREG-0490, estimates the maximum conseqnences of a San Onofre meltdown to be $35 billion in costs for mitigating actions (evacuations, relocations, land interdiction, emergency response by local, county, state and federal teams), 1 million
~eople would receive more than 25 rems, there would be 130,000 acute fatalities, and 300,000 latent cancers in the population within SO miles who would be exposed to 30 to 40 billion person rems released during the accident.
The consequences of nuclear power plant core melt accidents have also been estimated at the request of the California State Legislature and the President's Council on Environmental Quality by Dr. Jan Beyea and Dr. Frank von Rippel, nuclear physicists with the Princeton University's Program on Nuclear Policy Alternatives of the Center for Energy and Envir-onmental Studies.
or. Beyea noted in his analysis that a melt-down with a release of radioactive gases from a large reactor could involve "health effects and possible land use restrictions have been considered out to distances of 1,000 miles and for periods of decades after the release.*
He estimates that up to 175,000 square miles of land could be under some form of interdiction or restricted use following the meltdown.
He explains this by saying "The number of health effects and the.** land contamination can range so high because a substantial fraction of the released radioactivity can be carried for hundreds of miles downwind before being removed from the atmosphere by deposition on the ground.
Dr. Beyea told the President's council on Environmental Quality (CEQ) that *early fatalities could occur up to 30 miles downwind" of a reactor meltdown.
Or. Frank von Hippe! testified before the California State Leqislature after Three Mile Island  
~hat "the thyroid could receive a radiation dose tens to hundreds of times higher than the rest of the body.
Exposed children more than a hundred miles downwind would suffer thyroid damage which would require surgery years later." (emphasis added)
NUREG-0490 did not reference the SAI-OES study, in spite of.*the fact that the Atomic Safety and Licensing Board {ASLB) and the NRC Staff were made aware of the report by Intervenors during July and August of 1960, six months before NUREG-0490 was issued.
The SAI-OES study is a conservative report in that it calculates its predictions and models ba~ed on site-specific data.
NUREG-0490 is not conservative and is inadequate because it is not sufficiently based on site-specific data.
The SAI-OES report used extensive site-specific data regarding the nearby population centers and the various weather conditions in Southern California.
That report identified several site-specific unique features which should have warranted a different conclusion from the NRC Staff than "there are no special or unique features about the Sen Onofre site and environe that would warrant special or additional engineered safety features for the San Onofre plants.*
Joint Intervenors conclude there are special and unique features that exist at the San onofre site which are listed as follows:
(l)
The three reactors at Sen Onofre are uniquely located near the intersection of two major Fault zones, the Cristianitos and the Newport-Inglewood.
Prior to l980, the NRC believed there was no structural relationship between the two Fault Zones.
However, in 1980, fede;al and state marine geologists discovered a new zone of faults which they named
*cristianitos Zone of Deformation" which project directly beneath the three reactors.
Thus, the possibility of damage to the reactors during earthquakes is higher now because of the possibility of surface rupture directly under the reactors.
This was not factored into the Rasmussen Report, WASH-1400, the Lewis Report, SAI-OES or NUREG-0490.
NUREG-0490 does not even mention geologic-seismic site-specific events as a significantly possible factor in the probabilistic risk assessment.
(2)
The San Onofre site is uniquely located on the Pacific plate, near the Plate Tectonic Boundary Fault, the San Andreas.
San Onofre is moving north in relation to the North American Plate.
These reactors are uniquely migrating north on a geologic time scnle.
Plate Tectonics were not under-stood when the San Onofre site was originally chosen in 1962.
It was not until 1969 that the plate tectonics theories were accepted; (3)
The San Onofre site has the unique feature of baing sited close to San Onofre Unit 1.
If Unit l had a melt-down, it would sevenly effect operations of Units 2 and 3, resulting in various consequences, none of which were considered in NUREG-0490.
The older reactor at the site, San Onofre Unit 1,  
-~  
-~  


tating total rewiring of the control room and other systems.
c.n u:l was identified by the SAI-OES analysis as having the highest probability of a meltdown of any reactor in California for two primary reasons.  
was identified by the SAI-OES analysis as having the highest (6)  The San Onofre site is unique also in that probability of a meltdown of any reactor in California for San Onofre Unit 2 was constructed above earthquake faults that two primary reasons.   "The first reason is that the Unit One were not discovered until 1974 during construction excavations.
"The first reason is that the Unit One auxiliary feedwater system depends on operators to align and  
auxiliary feedwater system depends on operators to align and (7)  SONGS 2 and 3 are underlain by dewatering cavities
~nitiate the system.
    ~nitiate  the system. Potential failures due to human factors
Potential failures due to human factors  
                                                                        'that developed during construction. Intervenors believe this also
~aka the system less reliable than automated systems.
    ~aka the system less reliable than automated systems. The second is a special of unique feature at SONGS 2 and 3 which must be reason relates the long term recirculation mode of emergency con:Sidered.
The second reason relates the long term recirculation mode of emergency core coolant, which.requires at least one of two pumps located in the containment.
core coolant, which.requires at least one of two pumps located (8)  The Southern California region, including San in the containment. In the event of a pump failure, repairs Onofre, frequently has weather inversions. During these  inver~
In the event of a pump failure, repairs cannot be made because the pump is inside the containment and would be isolated during an accident."
cannot be made because the pump is inside the containment and sians, air pollutants, including accidentally leaked radioactive would be isolated during an accident."     NUREG-0490 does not gases, can be trapped beneath the inversion layer, where they can consider the proximity of SONGS   ~ and 3 to Unit 1 to be a unique only mix and travel horizontally. Thus, a meltdown at SONGS 2
NUREG-0490 does not consider the proximity of SONGS  
:,. or special feature.
~ and 3 to Unit 1 to be a unique or special feature.
c.n                                                                      and 3 could affect the nine to ten million people who live in u:l            (4)  San Onofre Unit l has been shutdown for approxi-the air basins that share the same East ~acific high pressure mately one year due to leaky corroded steam generator tubes. The zane inversion layers. Although NUREG-0490 admits that "accident NRC issued a report in 1976 (NUREG-0900-5, Report to Congress an consequences are very much dependent on the weather conditions Abnormal Occurrences) which explained that "the failure of a number existing at the time * *
(4)
* they do not specifically consider the of steam generator tubes as a result of the pressure transients unique Southern California high pressure inversion layers which during a loss of coolant accident could render the emergency core are a predominant characteristic of the San Onofre site.
San Onofre Unit l has been shutdown for approxi-mately one year due to leaky corroded steam generator tubes.
cooling system ineffective."   The Unit 1 was not designed for the (9) The San Onofre reactors are uniquely located on magnitude of ground motions that Units 2 and 3 were. An earth-a southern California beach state park that stretches for many quake could conceivably only damage Unit 1, because of its struct-miles, but which is inaccessible and inescapable except by driving urally weak steam generator tubes, but that could result in a past the reactors on the old-highway, now running parallel LOCA (loss of coolant accident) and a meltdown, which would affect to Interstate-S. On a typical summer day, 25,000 persons the two other reactors and the environment.
The NRC issued a report in 1976 (NUREG-0900-5, Report to Congress an Abnormal Occurrences) which explained that "the failure of a number of steam generator tubes as a result of the pressure transients during a loss of coolant accident could render the emergency core cooling system ineffective."
drive close to the reactors an a narrow and curving road. These (5) The San Onofre reactors are special and unique in beach-goers could be trapped during a meltdown, especially if that the reactor core of Unit 2 was installed backwards, necessi-
The Unit 1 was not designed for the magnitude of ground motions that Units 2 and 3 were.
                                                                                                                                              -a-
An earth-quake could conceivably only damage Unit 1, because of its struct-urally weak steam generator tubes, but that could result in a LOCA (loss of coolant accident) and a meltdown, which would affect the two other reactors and the environment.
 
(5)
an earthquake occurred at the same time or caused it.               should be substituted for "'boilerplate' assessment of accident (10)   Another unique or special feature of San Onofre     initiating events and potential impacts, and &#xa3;IS's should be is its proximity to roads used by thousands of uncontrolled          comprehensible to non-technical members of the public ***
The San Onofre reactors are special and unique in that the reactor core of Unit 2 was installed backwards, necessi-
* travelers per day which presents a unique-possibility for sabotaqe  Intervenors comment upon the fact that NOREG-0490 contains 29 accidents that could lead to releases of radioactivity.             pages of text with about 8 pages of site-specific information (11)  The San Onofre site is special and unique in        which is selective and slanted. NEPA requires detailed statements that one-half of the population of the State of California lives    of aspects of proposed action significantly affecting the quality within 100 miles of the site.                                       of the human environment and Intervenors feel NOREG-0490 is (12)  It is a unique feature of SONGS 2 and 3 to be      inadequate in that it is"largely perfunctory, remarkably stan-the larqest reactors ever considered for operating  licenses~
-a-tating total rewiring of the control room and other systems.
dardized and uninformative to the public.*
(6)
(13) The San Onofre site is unique in that it is                   NOREG-0490 is also inadequate in that it failed to sited within* contamination distance of a major portion of the consider earthquake induced core melt accidents. While the nation's fresh produce farms, especially in the winter months.       Reactor Safety Study(RSS), WASH-1400, concluded that the probab-(14)  The San Onofre site is also unique in that it      ility of core melt accidents in nuclear power plants from seismic could cause international economic and environmental impacts        events was insignificant compared to core melt probabilities from by contamination of a significant part of Baja California's          other accidents, recent assessment of the potential for earth-agricultural resources.                                             quake induced.core melt accidents suggests that the probability After the Kemeney Commission and the Rogovin Report        of such events may be significant when compared to core melt were issued on Three Mile Island, the council on Environmental      accidents from other causes considered by  ass. Intervenors Quality wrote a letter to the Nuclear Regulatory commissioners      contend that the seismic design basis for SONGS 2 and 3 is in-on March 20, 1980. The letter released the results of the CEQ      adequate and, therefore, consider it prudent to evaulate the review and critized the NRC's lack of compliance with NEPA laws      potential for seismic-induced core melt accidents at SONGS 2 in the ElS analyses of potential accidents at reactors. The       and 3 to establish if they may be significant factors. The CEQ stated that the NRC's EIS discussions of *potential accidents    purpose of NOREG-0490 wae to identify and evaluate site-specific and their environmental impacts was found to be largely perfunctory, environmental impacts. It does not evaulate the potential remarkably standardized, and uninformative to the public.*    The   for seismic-induced core melt accidents and, therefore its CBQ also advised the NRC that "site specific treatment of data      probabilistic assessment of risk at SONGS 2 and 3 is inadequate.
The San Onofre site is unique also in that San Onofre Unit 2 was constructed above earthquake faults that were not discovered until 1974 during construction excavations.
in ease a release occurred. On the other hand, if people were given potassium iodide NUREG-0490 is further inadequate and particularly                  to keep in their medicine cabinets along with asprin, it is likely that many would lose misleading in its assessment of health affects avoidance                      track of it pretty quickly. Perhaps it should be attached by the local utility to household (Section 7.1.1,4). NUREG-0490 did not mention thyroid blocking              electricity meters and its presence announced in case of need. The best strategy is obviously in its assessment of health affects avoidance, relying only on                a problem well worth a study. California could break some important ground here.**
(7)
restricti'on of contaminated property and foodstuffs. or. Frank
SONGS 2 and 3 are underlain by dewatering cavities
                                                                      ~eetion 7.1.1.4. is particularly misleading in its statement von Hipple in his testimony before the California State Legislature that "radiation hazards in the environment tend to disappear states:
'that developed during construction.
by the natural process of radioactive pecay (but) can continue The thyroid can be protected against absorbing radioiodine, however, if before the cloud arrives        for a relatively long period of time -- months, years or  ~
Intervenors believe this also is a special of unique feature at SONGS 2 and 3 which must be con:Sidered.
you take about one thousand times your ordinary daily iodine intake in the form of potassium            ~**        (emphasis added)  This misleading statement fails .. to iodide (the form of iodine present in iodized salt). This will saturate the thyroid with              note that some ratioactive wastes from nuclear accidents such ordinary iodide and reduce its ability to absord the radioactive iodide when it arrives.           as radioactive Strontium and Cesium can enter the food chain This strategy was recommended in the American Physical Society's reactor safety study four            and remain a hazard for 1,000 years or more. Other isotopes years ago. The Food and Drug Administration approved potassium iodide for emergency thyroid          remain a hazard for 1 million years or more.
(8)
            'blocking' * *
The Southern California region, including San Onofre, frequently has weather inversions.
* I would recommend that California do two things with regard to this thyroid protec-                  NUREG-0490, Section 7.1.3. entitled Mitigation of
During these inver~
~            tion strategy*
sians, air pollutants, including accidentally leaked radioactive gases, can be trapped beneath the inversion layer, where they can only mix and travel horizontally.
Accident Consequences is inadequate in that it fails to note
Thus, a meltdown at SONGS 2 and 3 could affect the nine to ten million people who live in the air basins that share the same East ~acific high pressure zane inversion layers.
: 1) Develop a stockpile of potassium iodide in the appropriate dosage in either sealed foil            that consequences could be reduced by retrofitting SONGS 2 and wrapped pills or liquid solution. This would not be costly. Based on a 1972 study for the            3 with filtered venting systems to prevent accidental releases Defense Civil Preparedness Study, it appears that enough pills for the entire nation could            of radioactive gases.
Although NUREG-0490 admits that "accident consequences are very much dependent on the weather conditions existing at the time * *
be produced for a few million dollars.
* they do not specifically consider the unique Southern California high pressure inversion layers which are a predominant characteristic of the San Onofre site.
NUREG-0490, Section 10 is misleading, inadequate
(9)
: 2) The more difficult part of the job would be to develop an effective distribution system. If         and incomplete. The Section contains three sentences with one waited until a cloud of radioiodine had been released before distributing the blocking chemical       regard to its conclusions and Re-Evaluated Benefit-Cost Balance.
The San Onofre reactors are uniquely located on a southern California beach state park that stretches for many miles, but which is inaccessible and inescapable except by driving past the reactors on the old-highway, now running parallel to Interstate-S.
and informing the public of its use, one might well be too late.   (A week after the beginning of       ~his section should be expanded because the environmental risks the crisis at Three Mile Island, the Pennsylvania state government refused to distribute the chemical     of a Class 9 accident involve the entire region of Southern to the population within 10 miles of the site -
On a typical summer day, 25,000 persons drive close to the reactors an a narrow and curving road.
despite the joint recommendation to do so from the       California, Norther Baja California, Mexico, and parts of Arizona, Surgeon General, the Food and Drug Commissioner, and the Director of the National Institutes of           These regions could be permanently contaminated with'radiation Health who thought that sufficient warning time might not be available to protect this population       following a coremelt ~t SONGS 2 and 3. The risks involve the CERTiriCATE OF SERVICE value of all real and personal property, both public and private in those regions. The risks involve fatalities, latent cancer I hereby certify that the JOINT INTERVENORS COMMENTS deaths and genetic damage. The risks involve compensation to ON SUPPLEMENT TO DRAFT ENVIRONMENTAL STATEMENT RELATED TO victims in the event of such accidents. Section 10 of NUREG-OPERATION OF SAN ONOFRE NUCLEAR GENERATING STATIONS, UNITS 2 AND 0490 concludes that the environmental risks of Class 9 - coremelt 3 (NUREG-0490) have been served on the following by deposit in
These beach-goers could be trapped during a meltdown, especially if an earthquake occurred at the same time or caused it.
  ~ccidents  - "does not change the results of the cost-benefit the United States mail, first class, postage prepaid, this balance contained in the Draft Environmental Statement (Section 9th day of March, 198lz 10)."
(10)
COHCLOSION                                                   Office of Nuclear Reactor Regulation u.s. Nuclear Regulatory Commission NOREG-0490 concludes rtthat there are no special or                         washington, D. c. 20555 unique features about the San Onofre site and environs that                             Attention*  Director, Division of Licensing
Another unique or special feature of San Onofre is its proximity to roads used by thousands of uncontrolled travelers per day which presents a unique-possibility for sabotaqe accidents that could lead to releases of radioactivity.
(11)
The San Onofre site is special and unique in that one-half of the population of the State of California lives within 100 miles of the site.
(12)
It is a unique feature of SONGS 2 and 3 to be the larqest reactors ever considered for operating licenses~
(13)
The San Onofre site is unique in that it is sited within* contamination distance of a major portion of the nation's fresh produce farms, especially in the winter months.
(14)
The San Onofre site is also unique in that it could cause international economic and environmental impacts by contamination of a significant part of Baja California's agricultural resources.
After the Kemeney Commission and the Rogovin Report were issued on Three Mile Island, the council on Environmental Quality wrote a letter to the Nuclear Regulatory commissioners on March 20, 1980.
The letter released the results of the CEQ review and critized the NRC's lack of compliance with NEPA laws in the ElS analyses of potential accidents at reactors.
The CEQ stated that the NRC's EIS discussions of *potential accidents and their environmental impacts was found to be largely perfunctory, remarkably standardized, and uninformative to the public.*
The CBQ also advised the NRC that "site specific treatment of data should be substituted for "'boilerplate' assessment of accident initiating events and potential impacts, and &#xa3;IS's should be comprehensible to non-technical members of the public ***
* Intervenors comment upon the fact that NOREG-0490 contains 29 pages of text with about 8 pages of site-specific information which is selective and slanted.
NEPA requires detailed statements of aspects of proposed action significantly affecting the quality of the human environment and Intervenors feel NOREG-0490 is inadequate in that it is"largely perfunctory, remarkably stan-dardized and uninformative to the public.*
NOREG-0490 is also inadequate in that it failed to consider earthquake induced core melt accidents.
While the Reactor Safety Study(RSS), WASH-1400, concluded that the probab-ility of core melt accidents in nuclear power plants from seismic events was insignificant compared to core melt probabilities from other accidents, recent assessment of the potential for earth-quake induced.core melt accidents suggests that the probability of such events may be significant when compared to core melt accidents from other causes considered by ass.
Intervenors contend that the seismic design basis for SONGS 2 and 3 is in-adequate and, therefore, consider it prudent to evaulate the potential for seismic-induced core melt accidents at SONGS 2 and 3 to establish if they may be significant factors.
The purpose of NOREG-0490 wae to identify and evaluate site-specific environmental impacts.
It does not evaulate the potential for seismic-induced core melt accidents and, therefore its probabilistic assessment of risk at SONGS 2 and 3 is inadequate.  
~ -
NUREG-0490 is further inadequate and particularly misleading in its assessment of health affects avoidance (Section 7.1.1,4).
NUREG-0490 did not mention thyroid blocking in its assessment of health affects avoidance, relying only on restricti'on of contaminated property and foodstuffs.
or. Frank von Hipple in his testimony before the California State Legislature states:
The thyroid can be protected against absorbing radioiodine, however, if before the cloud arrives you take about one thousand times your ordinary daily iodine intake in the form of potassium iodide (the form of iodine present in iodized salt).
This will saturate the thyroid with ordinary iodide and reduce its ability to absord the radioactive iodide when it arrives.
This strategy was recommended in the American Physical Society's reactor safety study four years ago.
The Food and Drug Administration approved potassium iodide for emergency thyroid
'blocking' *** I would recommend that California do two things with regard to this thyroid protec-tion strategy*
: 1)
Develop a stockpile of potassium iodide in the appropriate dosage in either sealed foil wrapped pills or liquid solution.
This would not be costly.
Based on a 1972 study for the Defense Civil Preparedness Study, it appears that enough pills for the entire nation could be produced for a few million dollars.
: 2)
The more difficult part of the job would be to develop an effective distribution system.
If one waited until a cloud of radioiodine had been released before distributing the blocking chemical and informing the public of its use, one might well be too late.
(A week after the beginning of the crisis at Three Mile Island, the Pennsylvania state government refused to distribute the chemical to the population within 10 miles of the site -
despite the joint recommendation to do so from the Surgeon General, the Food and Drug Commissioner, and the Director of the National Institutes of Health who thought that sufficient warning time might not be available to protect this population in ease a release occurred.
On the other hand, if people were given potassium iodide to keep in their medicine cabinets along with asprin, it is likely that many would lose track of it pretty quickly.
Perhaps it should be attached by the local utility to household electricity meters and its presence announced in case of need.
The best strategy is obviously a problem well worth a study.
California could break some important ground here.**
~eetion 7.1.1.4. is particularly misleading in its statement that "radiation hazards in the environment tend to disappear by the natural process of radioactive pecay (but) can continue for a relatively long period of time -- months, years or ~
~** (emphasis added)
This misleading statement fails.. to note that some ratioactive wastes from nuclear accidents such as radioactive Strontium and Cesium can enter the food chain and remain a hazard for 1,000 years or more.
Other isotopes remain a hazard for 1 million years or more.
NUREG-0490, Section 7.1.3. entitled Mitigation of Accident Consequences is inadequate in that it fails to note that consequences could be reduced by retrofitting SONGS 2 and 3 with filtered venting systems to prevent accidental releases of radioactive gases.
NUREG-0490, Section 10 is misleading, inadequate and incomplete.
The Section contains three sentences with regard to its conclusions and Re-Evaluated Benefit-Cost Balance.
~his section should be expanded because the environmental risks of a Class 9 accident involve the entire region of Southern California, Norther Baja California, Mexico, and parts of Arizona, These regions could be permanently contaminated with'radiation following a coremelt ~t SONGS 2 and 3.
The risks involve the value of all real and personal property, both public and private in those regions.
The risks involve fatalities, latent cancer deaths and genetic damage.
The risks involve compensation to victims in the event of such accidents.
Section 10 of NUREG-0490 concludes that the environmental risks of Class 9 -
coremelt
~ccidents -
"does not change the results of the cost-benefit balance contained in the Draft Environmental Statement (Section 10)."
COHCLOSION NOREG-0490 concludes rtthat there are no special or unique features about the San Onofre site and environs that  
~
~
would warrant special or additional engineered safety features for the San Onofre plants.* Intervenors conclude there are Executed on March 9, 1981 at San Diego, California.
would warrant special or additional engineered safety features for the San Onofre plants.*
unique characteristics at SONGS 2 and 3 that warrant additional engineered safety features especially in light of the unique earthquake hazard which could cause a coremelt accident and common-cause failure of essential safety systems at SONGS 2
Intervenors conclude there are unique characteristics at SONGS 2 and 3 that warrant additional engineered safety features especially in light of the unique earthquake hazard which could cause a coremelt accident and common-cause failure of essential safety systems at SONGS 2 and 3.
:::u: .s\. \w DARITY WESLE N)  Ld.
A future earthquake near the San Onofre site could be the common cause for failure of the coolinq systems "of all three reactors on the San Onofre site and all three of the spent fuel pools simultaneously.
                                                                                                                                  \
This would be the woret case accident.that should be analyzed by the NRC and this analysis should be a part of a reviaed NUREG-0490. CERTiriCATE OF SERVICE I hereby certify that the JOINT INTERVENORS COMMENTS ON SUPPLEMENT TO DRAFT ENVIRONMENTAL STATEMENT RELATED TO OPERATION OF SAN ONOFRE NUCLEAR GENERATING STATIONS, UNITS 2 AND 3 (NUREG-0490) have been served on the following by deposit in the United States mail, first class, postage prepaid, this 9th day of March, 198lz Office of Nuclear Reactor Regulation u.s. Nuclear Regulatory Commission washington, D. c. 20555 Attention*
and 3. A future earthquake near the San Onofre site could be the common cause for failure of the coolinq systems "of all three reactors on the San Onofre site and all three of the spent fuel pools simultaneously. This would be the woret case accident .that should be analyzed by the NRC and this analysis should be a part of a reviaed NUREG-0490.
Director, Division of Licensing Executed on March 9, 1981 at San Diego, California.
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l_;ntcl/,     c1 1                                                                                                        Office of Nuclear Reactor Regulation 9 March 1981 Coi.J c.e~N:eD                                                                                                       Page 2.
DARITY WESLE
SCJEJlJTlSTS                                                                                                         report was provided to the NRC with the CEQ Chairman's letter.
\\
9 March 1981 Part 5 of the ELI report recommends that the NRC should continue, with some substantial improvements, its previous practice of studying a selection of accident scenarios. The Office of Nuclear Reactor Regulation                                                                                     ELI report recommends that this selection should be expanded u.s. Nuclear Regulatory Commission                                                                                       to include "Class 9" accidents. Section 7 (Environmental Washington, D.C. 20555                                                                                                   Impact of Postulated Accidents} of the san Onofre Draft Environmental Statement (dated November 1978} exemplifies Attention:       Director, Division of Licensing                                                                         this previous practice; it estimates radiation doses for a number of selected accidents in Classes 1 through 8. This
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l_;ntcl/, c11 Coi.J c.e~N:eD SCJEJlJTlSTS 9 March 1981 Office of Nuclear Reactor Regulation u.s. Nuclear Regulatory Commission Washington, D.C.
20555 Attention:
Director, Division of Licensing  


==Dear People:==
==Dear People:==
Supplement, however, merges nine release categories, weighted by assumed probabilities. The results of this analysis are Re:     Supplement to the Draft Environmental Statement                                                                   confusing for the public; one might suspect that this is by (NUREG-049o) related to the operat~on of San Onofre                                                             intention.
Re:
Nuclear Generating Station, units 2 arid 3 Each accident scenario should be considered alone. For each Herewith are some brief comments on the above Supplement, in                                                             scenario, the NRC should provide a clear account of:
Supplement to the Draft Environmental Statement (NUREG-049o) related to the operat~on of San Onofre Nuclear Generating Station, units 2 arid 3 Herewith are some brief comments on the above Supplement, in response to your invitation.
response to your invitation.
We are pleased that the NRC has finally published a document providing a hint of the consequences of severe accidents at the San Onofre Station.
(i} the nature of the postulated accident We are pleased that the NRC has finally published a document providing a hint of the consequences of severe accidents at                                                                     (ii} the estimated nature of the radioactive release the San Onofre Station. We consider, however, that this Supplement does not satisfy the intent of the Commission's                                                                     (iii) the estimated nature of the environmental con-
We consider, however, that this Supplement does not satisfy the intent of the Commission's Statement of Interim Policy of 13 June 1980 (Federal Register, 45, 40101}.
!:    Statement of Interim Policy of 13 June 1980 (Federal Register, 45, 40101}. Nor does this Supplement provide the pUbl~c with Information sufficient to make a reasoned assessment of the sequences of that release.
Nor does this Supplement provide the pUbl~c with Information sufficient to make a reasoned assessment of the risks of severe accidents at this plant.
The Commission's Statement of Interim Policy directs:
You will recall that the Commission's Statement of Interim Policy followed a letter of 20 March 1980 from the Chairman of the Council on Environmental Quality (CEQ} to the Chairman of the NRC.
risks of severe accidents at this plant.
Included inthisletter was the statement:  
                                                                                                                                    " * *
"The results of our review of impact statements prepared by the NRC for nuclear power reactors are very disturbing.
* approximately equal attention shall be You will recall that the Commission's Statement of Interim                                                                     given to the probability of occurrence of releases Policy followed a letter of 20 March 1980 from the Chairman                                                                    and to the probability of occurrence of the environ-of the Council on Environmental Quality (CEQ} to the Chairman                                                                  mental consequences of those releases."
The discussion in these statements of potential accidents and their en-vironmental impacts was found to be largely perfunctory, remarkably standardized, and unin-formative to the public.*
of the NRC. Included inthisletter was the statement:
This supplement must be substantially revised and improved before it overcomes these CEQ criticisms.
For guidance during this process of revision and improvement, the NRC staff should consult the report "NRC's Environmental Analysis of Nuclear Accidents: Is It Adequate?", prepared for CEQ by the Environ-mental Law Institute (ELI} in February 1980.
A copy of this
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report was provided to the NRC with the CEQ Chairman's letter.
Part 5 of the ELI report recommends that the NRC should continue, with some substantial improvements, its previous practice of studying a selection of accident scenarios.
The ELI report recommends that this selection should be expanded to include "Class 9" accidents.
Section 7 (Environmental Impact of Postulated Accidents} of the san Onofre Draft Environmental Statement (dated November 1978} exemplifies this previous practice; it estimates radiation doses for a number of selected accidents in Classes 1 through 8.
This Supplement, however, merges nine release categories, weighted by assumed probabilities.
The results of this analysis are confusing for the public; one might suspect that this is by intention.
Each accident scenario should be considered alone.
For each scenario, the NRC should provide a clear account of:
(i} the nature of the postulated accident (ii} the estimated nature of the radioactive release (iii) the estimated nature of the environmental con-sequences of that release.
The Commission's Statement of Interim Policy directs:
" * *
* approximately equal attention shall be given to the probability of occurrence of releases and to the probability of occurrence of the environ-mental consequences of those releases."
This Supplement does not satisfy the intent of that directive.
This Supplement does not satisfy the intent of that directive.
              "The results of our review of impact statements                                                                  It merges these two probabilities although they are of quite prepared by the NRC for nuclear power reactors                                                                    different natures. One might suspect that this approach is are very disturbing. The discussion in these                                                                      selected in order to persuade the public that severe con-statements of potential accidents and their en-                                                                    sequences have extremely low probabilities. This form of vironmental impacts was found to be largely                                                                        analysis and presentation does not fulfill the NRC's obligation perfunctory, remarkably standardized, and unin-                                                                    to accurately inform the public.
It merges these two probabilities although they are of quite different natures.
formative to the public.*
One might suspect that this approach is selected in order to persuade the public that severe con-sequences have extremely low probabilities. This form of analysis and presentation does not fulfill the NRC's obligation to accurately inform the public.
As the NRC staff should well know, probabilities in nuclear This supplement must be substantially revised and improved                                                                accident analysis fall into two distinct categories:
As the NRC staff should well know, probabilities in nuclear accident analysis fall into two distinct categories:
before it overcomes these CEQ criticisms. For guidance during this process of revision and improvement, the NRC staff should                                                                    (i} probability of occurrence of release consult the report "NRC's Environmental Analysis of Nuclear                                                                                This category of probability concerns Accidents: Is It Adequate?", prepared for CEQ by the Environ-                                                                          engineering estimates. These are very difficult mental Law Institute (ELI} in February 1980. A copy of this                                                                            to make since there is a l~mited statistical base and much of the uncertainty relates to human behaviour.
(i} probability of occurrence of release This category of probability concerns engineering estimates.
                          !:;g.:1 :,t5!B:1C~us.a:~s A*.'!nul! " Camor~cge.  :.iassac~use::s ~2238
These are very difficult to make since there is a l~mited statistical base and much of the uncertainty relates to human behaviour.  
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Office of Nuclear Reactor Regulation                            Office of Nuclear Reactor Regulation 9 March 1981                                                    9 March 1981 Page 3.                                                        Page 4.
t Office of Nuclear Reactor Regulation 9 March 1981 Page 3.
(ii) probability of occurrence of environmental conse&#xa3;hences, g1ven a particular release           In the light of the grave hazard shown by these estimates, T is<ategory of probability concerns         the NRC has a clear duty to provide the public with more factors such as wind speed and direction. These     complete information than is contained in this Supplement.
(ii) probability of occurrence of environmental conse&#xa3;hences, g1ven a particular release T is<ategory of probability concerns factors such as wind speed and direction.
factors can be estimated from a good statistical base.                                              Thank you for your attention.
These factors can be estimated from a good statistical base.
The NRC staff should revise this Supplement so as to exhibit                                 Sincerely, their estimates of these probabilities separately, within each accident scenario studied, The Commission's Statement of Interim Policy also directs:                                     G.~~s;~
The NRC staff should revise this Supplement so as to exhibit their estimates of these probabilities separately, within each accident scenario studied, The Commission's Statement of Interim Policy also directs:  
      " .* *
".* *
* consequences shall be characterized in                                         Gordon Thompson, Ph.D.
* consequences shall be characterized in terms of potential radiological exposures to individuals, to* population groups, and, where applicable, to biota.*
terms of potential radiological exposures to                                             Staff Scientist individuals, to* population groups, and, where applicable, to biota.*
This Supplement does not fulfill the intent of that directive.
This Supplement does not fulfill the intent of that directive.
It provides very limited information on the geographical varia-t tion of potential exposure. More seriously, it provides essentially no information on the significance of exposure for different population groups. As the NRC staff should well know, certain population groups (especially children and GT:VN fetuses) are at greater risk for a given release.
It provides very limited information on the geographical varia-tion of potential exposure.
More seriously, it provides essentially no information on the significance of exposure for different population groups.
As the NRC staff should well know, certain population groups (especially children and fetuses) are at greater risk for a given release.
The importance of revising this Supplement, so as to accurately inform the public, can be illustrated by two estimates which can be gleaned from the supplement itself:
The importance of revising this Supplement, so as to accurately inform the public, can be illustrated by two estimates which can be gleaned from the supplement itself:
(i) probability of occurrence of the "PWR2" core melt accident       .
(i) probability of occurrence of the "PWR2" core melt accident Th1s release is one of the most severe accidents considered in the Reactor Safety Study (WASH-1400) and this Supplement.
Th1s release is one of the most severe accidents considered in the Reactor Safety Study (WASH-1400) and this Supplement. Table 7.1.4-2 of the Supplement estimates its probability as 7xlo-6 per reactor-year. Section 7.1.4.2 concedes that this estimate could be low by a factor of 100.
Table 7.1.4-2 of the Supplement estimates its probability as 7xlo-6 per reactor-year.
Section 7.1.4.2 concedes that this estimate could be low by a factor of 100.
One thus finds (assuming a reactor life of 30 years) that this Supplement admits that a "PWR2" accident could have a 4% probability of occurrence during 'the life of San Onofre Units 2 and 3.
One thus finds (assuming a reactor life of 30 years) that this Supplement admits that a "PWR2" accident could have a 4% probability of occurrence during 'the life of San Onofre Units 2 and 3.
(ii) potential for serious health effects Table 7.1.4-4 of this Supplement admits that a severe accident at San Onofre could lead to 130,000 acute fatalities, 300,000 subsequent fatal cancers, and 600,000 genetic effects.
(ii) potential for serious health effects Table 7.1.4-4 of this Supplement admits that a severe accident at San Onofre could lead to 130,000 acute fatalities, 300,000 subsequent fatal cancers, and 600,000 genetic effects.
Office of Nuclear Reactor Regulation 9 March 1981 Page 4.
In the light of the grave hazard shown by these estimates, the NRC has a clear duty to provide the public with more complete information than is contained in this Supplement.
Thank you for your attention.
GT:VN Sincerely, G.~~s;~
Gordon Thompson, Ph.D.
Staff Scientist


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Our specific comments on the San Onofre Supplemental DEIS and generic comments are attached. The EPA appreciates 2:5 Fre.":'!c.<,. Str~~t               the opportunity to comment on this Draft Supplement. Should
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                                                ;.;.-,~ Franclsc:.>. L'a :'14 ~ :J5           the NRC choose to revise other sections of the EIS, EPA would like to review these documents. If you have any Project # DS-NRC-K06002-CA                                                                questions regarding our comments, please contact Susan Sakaki, EIS Review Coordinator, at (415)556-7858.
2:5 Fre.":'!c.<,. Str~~t  
Frank J. Miraglia, Acting Chief Licensing Branch No. 3                                                                    Sincerely y~r~
;.;.-,~ Franclsc:.>. L'a :'14 ~ :J5 Project # DS-NRC-K06002-CA Frank J. Miraglia, Acting Chief Licensing Branch No. 3 Division of Licensing Nuclear Regulatory Commission Washington, D.C.
20555 Oear Mr. Miraglia:
The Environmental Protection Agency (EPA) has received and reviewed the Draft Supplement (DS) to the Draft Environ-mental Impact Statement (DEIS) for the project titled SAN ONOFRE NUCLEAR GENERATING STATION, UNITS 2 AND 3.
In our previous reviews of environmental documents dealing with Light water Reactors (LWR) EPA has consistently emphasized the need for a thorough evaluation of the environmental impacts from different LWR accident scenarios to include Class 9 accidents.
The discussion of the environmental and societal impacts of a core melt down accident included in the Supplement to the Draft Environ-mental Impact Statement for the San Onofre Nuclear Genera-ting Station, Units 2 and 3 is a step forward in this respect and, as a result, EPA applauds the Nuclear Regulatory Commission's (NRC) decision to prepare this Supplement.
The assessment of environmental impacts for severe acci-dents at the plant uses methodologies originally developed in the Reactor Safety Study (WASH-1460) and the Liquid Pathway Generic Study (NUREG-0440).
Because these two studies will be the cornerstones for similar assessments for other nuclear power plants environmental statements, we would refer NRC to EPA's original technical comments on these studies.
These comments can be found in "Reactor Safety Study (WASH-1400): A Review of the Final Report" and a letter from EPA's Office of Federal Activities to NRC dated February 8, 1977.
St03ZS0423 Our specific comments on the San Onofre Supplemental DEIS and generic comments are attached.
The EPA appreciates the opportunity to comment on this Draft Supplement.
Should the NRC choose to revise other sections of the EIS, EPA would like to review these documents.
If you have any questions regarding our comments, please contact Susan Sakaki, EIS Review Coordinator, at (415)556-7858.
Sincerely y~r~
J~~tr:~
J~~tr:~
Division of Licensing Nuclear Regulatory Commission Washington, D.C. 20555 Oear Mr. Miraglia:                                                                        Surveillance and Analy,.i.s Division The Environmental Protection Agency (EPA) has received and                                Attachment reviewed the Draft Supplement (DS) to the Draft Environ-mental Impact Statement (DEIS) for the project titled SAN ONOFRE NUCLEAR GENERATING STATION, UNITS 2 AND 3.                                      ---
Surveillance and Analy,.i.s Division Attachment  
In our previous reviews of environmental documents dealing with Light water Reactors (LWR) EPA has consistently emphasized the need for a thorough evaluation of the t  environmental impacts from different LWR accident scenarios to include Class 9 accidents. The discussion of the
""  environmental and societal impacts of a core melt down accident included in the Supplement to the Draft Environ-mental Impact Statement for the San Onofre Nuclear Genera-ting Station, Units 2 and 3 is a step forward in this respect and, as a result, EPA applauds the Nuclear Regulatory Commission's (NRC) decision to prepare this Supplement.
The assessment of environmental impacts for severe acci-dents at the plant uses methodologies originally developed in the Reactor Safety Study (WASH-1460) and the Liquid Pathway Generic Study (NUREG-0440). Because these two studies will be the cornerstones for similar assessments for other nuclear power plants environmental statements, we would refer NRC to EPA's original technical comments on these studies. These comments can be found in "Reactor Safety Study (WASH-1400): A Review of the Final Report" and a letter from EPA's Office of Federal Activities to NRC dated February 8, 1977.
St03ZS0423


EPA Technical Comments on the Supplement to the Draft Environ-         with respect to potential reactor accidents of mental Statement Related to the Operation of the San Onofre             exceedingly low probability of occurrence, and low Generating Station Units 2 and 3 (NUREG-0490)                           risk of public exposure to radiation.
EPA Technical Comments on the Supplement to the Draft Environ-mental Statement Related to the Operation of the San Onofre Generating Station Units 2 and 3 (NUREG-0490)
General Comments                                                 Secondly, by the description of infrequent accidents in the supplement ("events that might occur once during the The Final E!S for San Onofre Units 2 and 3 is dated March 1973. lifetime of the plant"), these accidents have an annual This statement contains a Section 7, titled "Environmental       probability of occurrences on the order of lo-2, are Impact of Postulated Accidents.* It is not clear if the           considered credible, and are not of exceedingly low Supplement is to replace the original information or if the       probability of occurrence. Reference to 10 CFR 100 and Supplement is supplemental. If this information is supplemental   its implementation provide a misleading inference that, then we would suggest that the original Section 7 be revised to   since the results shown in Table 7.1.4-1 are within the agree with the supplemental statements and data.                 dose values of 10 CFR 100, the risk of those infrequent accidents is small and therefore acceptable. Also, the It would also be hopeo that any previous information and con-     radiation doses listed in Table 7.1.4-1 are calculated clusions would be revised if it is impacted by events occur-     using a conservative model approach which is relevant to ring since 1973 or by a change in COmmission consideration.       safety evaluations and not consistent with the realistic For instance the supplement refers to the original Section 5.~   approach to the assessment of environmental risks of and further mentions 10 CFR Part 20 and 10 CFR Part SO. However, normal operation and severe core melt accidents.
General Comments The Final E!S for San Onofre Units 2 and 3 is dated March 1973.
the supplement does not make any mention of the Commission's implementation of 40 CFR 190 for normal operation.               The discussion of impacts of infrequent accidents and limiting faults, in both the original DES and the
This statement contains a Section 7, titled "Environmental Impact of Postulated Accidents.* It is not clear if the Supplement is to replace the original information or if the Supplement is supplemental. If this information is supplemental then we would suggest that the original Section 7 be revised to agree with the supplemental statements and data.
* Specific comments Table 7.1.4-4 This table should correspond on a one-to-one basis with the release categories (PWR 1-9) in Table 7.1.4-2. It Supplement, addresses probabilities of occurrence qualitatively *. Yet, in the discussion of the more severe core melt accidents the probabilities of occurrence are quantified (Table 7.1.4-2). For consistency in the pre-sentation of all envi~onmental risks, the probabilities of occurrence of infrequent accidents and limiting faults is also not readily apparent how the PWR 1-9 compares        DBA's should also be provided.
It would also be hopeo that any previous information and con-clusions would be revised if it is impacted by events occur-ring since 1973 or by a change in COmmission consideration.
to the original Table 7.1.
For instance the supplement refers to the original Section 5.~
It is not clear wheth~r the risks listed in Table 7.1.4-5, Design Basis Accidents                                      Annual Average Values of Environmental Risks Due to Acc~dents, Include those from infrequent accidents and In the discussion of accident risk and impact assessment      l~m~tlng faults (Table 7.1.4-2), postulated accidents of Design Basis Accidents (OBAs), Section 7.1.4.1, we do      (Table 7.2 of the original DES), and accidents leading to not understand the intent of the comparison of the results  the PWR 1-9 release categories (Table 7.1.4-2). The risks in Table 7.1.4-1 to the Reactor Site Criteria of 10 CFR      should include all those from moderate frequency accidents, 100. First, the infrequent accidents listed in Table          infrequent accidents, limiting faults and severe core melt 7.1.4-1 do not meet the requirements of 10 CFR 100 for        accidents. Although the risk of the infrequent accidents purposes of site analysis. Footnotes to 10 CFR 100 state:    and limiting faults is "judged to be extremely small" and appear to be overshadowed by the risk from core melt (l} *** calculations should be based upon a major      accidents, they should be fully presented. The risks from accident, hypothesized for the purposes of site          the more probable yet lower consequence accidents may analysis *** that would result in potential hazards      indeed be significant to the individual risk and should be not exceeded by those from any accident considered      listed in the Supplement. It would also be beneficial to credible, and                                          extend Figures 7.1.4-3, 7.1.4-5, and 7.1.4-7 to include the higher probability accidents.
and further mentions 10 CFR Part 20 and 10 CFR Part SO.
(2) *** this 25 rem whole body value and the 300 rem thyroid value have been set forth as reference values,  It would be helpful to provide a summary table of the which can be used in the evaluation of reactor sites    annual average value of environmental risks from operation of all the reactors at the San Onofre site. The risks
: However, the supplement does not make any mention of the Commission's implementation of 40 CFR 190 for normal operation.
Specific comments Table 7.1.4-4 This table should correspond on a one-to-one basis with the release categories (PWR 1-9) in Table 7.1.4-2. It is also not readily apparent how the PWR 1-9 compares to the original Table 7.1.
Design Basis Accidents In the discussion of accident risk and impact assessment of Design Basis Accidents (OBAs), Section 7.1.4.1, we do not understand the intent of the comparison of the results in Table 7.1.4-1 to the Reactor Site Criteria of 10 CFR 100. First, the infrequent accidents listed in Table 7.1.4-1 do not meet the requirements of 10 CFR 100 for purposes of site analysis. Footnotes to 10 CFR 100 state:
(l} *** calculations should be based upon a major accident, hypothesized for the purposes of site analysis *** that would result in potential hazards not exceeded by those from any accident considered credible, and (2) *** this 25 rem whole body value and the 300 rem thyroid value have been set forth as reference values, which can be used in the evaluation of reactor sites with respect to potential reactor accidents of exceedingly low probability of occurrence, and low risk of public exposure to radiation.
Secondly, by the description of infrequent accidents in the supplement ("events that might occur once during the lifetime of the plant"), these accidents have an annual probability of occurrences on the order of lo-2, are considered credible, and are not of exceedingly low probability of occurrence.
Reference to 10 CFR 100 and its implementation provide a misleading inference that, since the results shown in Table 7.1.4-1 are within the dose values of 10 CFR 100, the risk of those infrequent accidents is small and therefore acceptable.
Also, the radiation doses listed in Table 7.1.4-1 are calculated using a conservative model approach which is relevant to safety evaluations and not consistent with the realistic approach to the assessment of environmental risks of normal operation and severe core melt accidents.
The discussion of impacts of infrequent accidents and limiting faults, in both the original DES and the Supplement, addresses probabilities of occurrence qualitatively *.
Yet, in the discussion of the more severe core melt accidents the probabilities of occurrence are quantified (Table 7.1.4-2).
For consistency in the pre-sentation of all envi~onmental risks, the probabilities of occurrence of infrequent accidents and limiting faults DBA's should also be provided.
It is not clear wheth~r the risks listed in Table 7.1.4-5, Annual Average Values of Environmental Risks Due to Acc~dents, Include those from infrequent accidents and l~m~tlng faults (Table 7.1.4-2), postulated accidents (Table 7.2 of the original DES), and accidents leading to the PWR 1-9 release categories (Table 7.1.4-2).
The risks should include all those from moderate frequency accidents, infrequent accidents, limiting faults and severe core melt accidents.
Although the risk of the infrequent accidents and limiting faults is "judged to be extremely small" and appear to be overshadowed by the risk from core melt accidents, they should be fully presented.
The risks from the more probable yet lower consequence accidents may indeed be significant to the individual risk and should be listed in the Supplement. It would also be beneficial to extend Figures 7.1.4-3, 7.1.4-5, and 7.1.4-7 to include the higher probability accidents.
It would be helpful to provide a summary table of the annual average value of environmental risks from operation of all the reactors at the San Onofre site. The risks  


should include all those from normal operations, moderate frequency accidents, infrequent accidents, limiting faults   accompanying table or coding explaining the significance and severe core melt accidents. Both societal and           of the numbers.
~
individual risks should be presented.
should include all those from normal operations, moderate frequency accidents, infrequent accidents, limiting faults and severe core melt accidents.
Decommissioning 7.1.1.3 Health Effects The cost of reactor decommissioning and replacement The statement that a dose greater than about 25 rem is       power costs are as large as the costs from the Three necessary before any physiological effects to an individual Mile Island accident. It would seem that these costs are clinically detectable should be reviewed. Information   could significantly change the cost-benefit information contained in a World Health Organization technical report   originally provided in Section 13. Future EIS's or No. 123 would seem to indicate that physiological changes   Supplements to EIS's should include an evaluation of can occur at exposures as low as 10 rem.                    these costs.
Both societal and individual risks should be presented.
7 .1. 3. 3 Emer9enc~v Preparedn~
7.1.1.3 Health Effects The statement that a dose greater than about 25 rem is necessary before any physiological effects to an individual are clinically detectable should be reviewed.
It is unclear what is the basis of the statement, "Emergency preparedness plans including protective action measures for the San Onofre facility and environs are in an advanced, but not yet fully completed stage." The plans (seven) are at this date undergoing informal review by the Region IX Regional Assistance Committee (RAC).
Information contained in a World Health Organization technical report No. 123 would seem to indicate that physiological changes can occur at exposures as low as 10 rem.
Thus, there has been no request for formal review, there has been no drill schedule established and there has been no full scale exercise. We do not concur in the Commission's
7.1. 3. 3 Emer9enc~v Preparedn~
~ statement that these plans are in an advanced stage.
It is unclear what is the basis of the statement, "Emergency preparedness plans including protective action measures for the San Onofre facility and environs are in an advanced, but not yet fully completed stage."
The plans (seven) are at this date undergoing informal review by the Region IX Regional Assistance Committee (RAC).
Thus, there has been no request for formal review, there has been no drill schedule established and there has been no full scale exercise.
We do not concur in the Commission's statement that these plans are in an advanced stage.
Table 7. L 4-5 It is not clear from the information presented regarding risk and protective action that protective actions can be taken to reduce exposures by 10-20 times or in fact to prevent exposures determined by the State of California to be unacceptable considering the following:
Table 7. L 4-5 It is not clear from the information presented regarding risk and protective action that protective actions can be taken to reduce exposures by 10-20 times or in fact to prevent exposures determined by the State of California to be unacceptable considering the following:
: 1. The emergency preparedness plans and protective action measures for the San Onofre facility are r.ot yet complete.
: 1. The emergency preparedness plans and protective action measures for the San Onofre facility are r.ot yet complete.
Line 386: Line 858:
In view of the above, we feel the statements made are premature.
In view of the above, we feel the statements made are premature.
Figure 7.1.4-8 This figure, "Relative Directional Risk to Individuals,"
Figure 7.1.4-8 This figure, "Relative Directional Risk to Individuals,"
might be a useful risk analysis. However, as presented, the figure is illegible and lacking in background infor-mation. It should be presented more clearly, with an
might be a useful risk analysis.
However, as presented, the figure is illegible and lacking in background infor-mation. It should be presented more clearly, with an accompanying table or coding explaining the significance of the numbers.
Decommissioning The cost of reactor decommissioning and replacement power costs are as large as the costs from the Three Mile Island accident. It would seem that these costs could significantly change the cost-benefit information originally provided in Section 13.
Future EIS's or Supplements to EIS's should include an evaluation of these costs.


                                                                                                  ~
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Swllllcjfn A.".*;o('J.\TI0:-1 01' (rtl\'F.RX~IE:-1'11' RESOLUTION                                                                No.              a1-as San Diego ASSOCIATION OF GOVERNMENTS Suite 524. Security Pacific Plata 1200 Third AWDUO San Diego. C.lifornia 92101 17141236-5300 Much 19, 1981 RESOWl'I(:N SUPFOR!'Dl> '!HE Ol'ERATICtl or SAN CNOf'RE NUCIE.AA FI:M:R I?IAilT UNITS 2 AND 3 SUBJECT ro rEDERAL Rml!ATIOOS Rroi\RDDX> 'niE SAfl:I'Y    or NUCu:AA Po:l\'ER PIAtlT OPEAATICtlS AND D1ERGElCY PIJ\N!l!tx:i roR NOCIE.AA l'W.'T ACCIDE!ll'S Mr. Dino c. Scaletti San Onofre Project Manager Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Ccmnission Washington, OC 20555
San Diego ASSOCIATION OF GOVERNMENTS Suite 524. Security Pacific Plata 1200 Third AWDUO San Diego. C.lifornia 92101 17141236-5300 Mr. Dino c. Scaletti San Onofre Project Manager Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Ccmnission Washington, OC 20555  


==Dear Mr. Scaletti:==
==Dear Mr. Scaletti:==
Wll!:RFAS, the Ene!:<JY 2()00 Task Force, aP!Xlinted b!' Mayor Wilson of the City of ~ Diego, presented the conclusions and J.ea:r.tnendations On March 16, 1981, the Board of Directors of the San !'lie .;o Association           of its ref(lrt to the S!;NIY;G Board 'of Directors on Februat y 23, *1981; and oi Governments (SANDAG) adopted a resolution supporting :he operation of San Onofre Nuclear Power Plant Units 2 and 3 and requested the Nuclear                         Wll!:RFAS, .one of the reo:rmendations of the Energ; 2000 Task force Regulatory C011111i:;sion to grant an operating license for :hese units sub-       is to SIJP!Xlrt the CO!q)letion and. q;eration of San Onof1*e Plants 2 and 3; ami
Much 19, 1981 On March 16, 1981, the Board of Directors of the San !'lie.;o Association oi Governments (SANDAG) adopted a resolution supporting :he operation of San Onofre Nuclear Power Plant Units 2 and 3 and requested the Nuclear Regulatory C011111i:;sion to grant an operating license for :hese units sub-ject to federal regulations regarding thti safety of nuclJar p<'wcr plant operations and emergency planning for nuclear power plant nccidcnts.
This resolution and the *supporting staff report are attached.
Please call me or have your staff call Steve Sachs of my staff if you have any questions_ about the Board of Directors action.
~
f> ru~ fl:!r--
Executive Director RJH/SS/sc Attachments cc:
Patricia Fleming, SDG&E Fred Massey, SCE t.1EMl~!*t- ***.a:r:''lt"!i.t.*l**.. *
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ject to federal regulations regarding thti safety of nuclJar p<'wcr plant operations and emergency planning for nuclear power plant nccidcnts.                             Wll!:RFAS, San Onofre Units 2 and 3, if o::rnplete<'l and operated on This resolution and the *supporting staff report are attached.                      schedule, will supply awroximately half of the addition< 1 electric:ty need&#xa3; forecast for the San Diego region between now and 1995; and Please call me or have your staff call Steve Sachs of my staff if you have any questions_ about the Board of Directors action.                                              WHERFAS, the Nuclear Regulatory Carmission will begin licensing hearings for San Onofre Units 2 and 3 in June 1981; and
Swllllcjfn A.".*;o('J.\\TI0:-1 01' (rtl\\'F.RX~IE:-1'11' RESOLUTION RESOWl'I(:N SUPFOR!'Dl> '!HE Ol'ERATICtl or SAN CNOf'RE NUCIE.AA FI:M:R I?IAilT UNITS 2 AND 3 SUBJECT ro rEDERAL Rml!ATIOOS Rroi\\RDDX> 'niE SAfl:I'Y or NUCu:AA Po:l\\'ER PIAtlT OPEAATICtlS AND D1ERGElCY PIJ\\N!l!tx:i roR NOCIE.AA l'W.'T ACCIDE!ll'S No.
                  ~
a1-as Wll!:RFAS, the Ene!:<JY 2()00 Task Force, aP!Xlinted b!' Mayor Wilson of the City of ~
ru~fl:!r--
Diego, presented the conclusions and J.ea:r.tnendations of its ref(lrt to the S!;NIY;G Board 'of Directors on Februat y 23, *1981; and Wll!:RFAS,.one of the reo:rmendations of the Energ; 2000 Task force is to SIJP!Xlrt the CO!q)letion and. q;eration of San Onof1*e Plants 2 and 3; ami Wll!:RFAS, San Onofre Units 2 and 3, if o::rnplete<'l and operated on schedule, will supply awroximately half of the addition< 1 electric:ty need&#xa3; forecast for the San Diego region between now and 1995; and WHERFAS, the Nuclear Regulatory Carmission will begin licensing hearings for San Onofre Units 2 and 3 in June 1981; and Wll!:RFAS, federal regulations ooncerning nuclear I :JWer plant safety and emergency reSf(lnse.planning will have to be Jret in 01 3e:r for a hcen:;,:,
Wll!:RFAS, federal regulations ooncerning nuclear I :JWer plant safety and emergency reSf(lnse .planning will have to be Jret in 01 3e:r for a hcen:;,:,
to be' granted; N:W 'lHEREroRE BE IT RESOLVED that the Board of Directors SIJP!Xltlts the q;eratioi1 of San Q-lofre Nuclear Power Plant Units 2 and 3 and rec)\\.*f;ts the Nuclear Regulatory Carmission to grant an q;erating license for tiler.e units subject to federal regulations regarding the safety of nuclear p::~r plant O!X'ra-*
to be' granted; N:W 'lHEREroRE f>                                                                                                          BE IT RESOLVED that the Board of Directors SIJP!Xltlts the q;eratioi1 Executive Director                                                                  of San Q-lofre Nuclear Power Plant Units 2 and 3 and rec)\.*f;ts the Nuclear Regulatory Carmission to grant an q;erating license for tiler.e units subject RJH/SS/sc                                                                            to federal regulations regarding the safety of nuclear p::~r plant O!X'ra-*
tions and emergency planning for nuclear plant accidents.
tions and emergency planning for nuclear plant accidents.
Attachments PASSED AND AllOPTfD this 16th                   day of March 1981.
PASSED AND AllOPTfD this 16th day of March 1981.  
cc:        Patricia Fleming, SDG&E Fred Massey, SCE
.r r
                                                                                                                                                                                                                            ~"'/,,
-~
ATIEST: .
ATIEST:.
                                                                                                                  .r        &    r SECRE
SECRE RY
                                                                                                                                      -~
~
RY
~"'/,,
                                                                                                                                                                                              ~                            *~--* --**
*~--*
AiflMI\N MEMBER AGENCIES: Cilift of Carlsbad. Chula Vista. Coron.acfn. 0..1 Mu. El Ctinn.lmf'll"ro11 ~.. ",.... t 11._.* * * ,.,.. ... ,.
AiflMI\\N MEMBER AGENCIES: Cilift of Carlsbad. Chula Vista. Coron.acfn. 0..1 Mu. El Ctinn.lmf'll"ro11 ~.. ",.... t 11._.* *  
t.1EMl~!*t-  ***.a:r:''lt"!i.t.*l** .. *                    :*'l.':*-:-.
            * .* ,11,**    *,,.,.


San Diego Association of Governments BOARD OF DIRECTORS SAN DIEGO ASSOClATJO::\ OF 00\'ER!\l\lE!\'TS DATE:
~
March 16, 1981                      AGENDA REPORT No.:
SAN DIEGO ASSOClATJO::\\ OF 00\\'ER!\\l\\lE!\\'TS RESOLtrriO:-\\ 110. _ __,::8:.;1_-3:..:6:._._ ___ _
R-95 RESOLtrriO:-\ 110. _ __,::8:.;1_-3:..:6:._.__ _ __  DATE CU~SIDERED:         3/16/81 CCl<SIDEMTION OF SUProRT FOR OP&#xa3;AATIOO OF
DATE CU~SIDERED:
                                                                        -                          SAN OOOFRE: NUCLPJ\R J:aoi&#xa3;R PLAN!' l.JNITS 2 AND 3 AGENCY                                      YES    NO          ABSEl\T          ABSTAI:\      I j  Intt"OOuction CARI.SBAD                                    X                                                  !  The Board requested this report as the basis for oonsidet*in<J a n;,,<>J.,ticn to support the operation of San Onofre Nuclear R:>wet Plant ll:1its ~ '"*,, 1 l.
3/16/81 AGENCY YES NO ABSEl\\T ABSTAI:\\
OllilA VlSTA OJROI\AOO X
I ' j CARI.SBAD X
J  Three iJnj:Xlrtant j:Xlints the Board should <.:onsitler before takinq a P'*"' it ** .,.
OllilA VlSTA X
J OJROI\\AOO X
I DEL MAR X
EL CAJON X
IMPERIAL BEAOl X
LA MESA X
IDOl': GROVE.
X NATIONAL CITY X
OCEANSIDE X
SAN DIEm X
SAN MARCOS X
SANTEE X
VISTA X
I TOTAlS 13 1
I J certify from personal observation and count that the above results ar~ an accurBt~
:record of the SANDAG Board of Directors vote and action.
San Diego Association of Governments BOARD OF DIRECTORS DATE:
March 16, 1981 AGENDA REPORT No.:
CCl<SIDEMTION OF SUProRT FOR OP&#xa3;AATIOO OF SAN OOOFRE: NUCLPJ\\R J:aoi&#xa3;R PLAN!' l.JNITS 2 AND 3 Intt"OOuction R-95 The Board requested this report as the basis for oonsidet*in<J a n;,,<>J.,ticn to support the operation of San Onofre Nuclear R:>wet Plant ll:1its ~ '"*,, 1 l.
Three iJnj:Xlrtant j:Xlints the Board should <.:onsitler before takinq a P'*"' it **.,.
are:
are:
X DEL MAR EL CAJON X                                            I          The risks to health and life of both pre&mt ancl future \JC'I.*~rat ;,,,,,
The risks to health and life of both pre&mt ancl future \\JC'I.*~rat ;,,,,,
and the costs of reducing these risks as~ociatcd with almo~t all aspects of the nuclear fuel cycle, ate extre*cly contrcJVersi.:ll.
and the costs of reducing these risks as~ociatcd with almo~t all aspects of the nuclear fuel cycle, ate extre*cly contrcJVersi.:ll.
X                                                              There is little scientific or technical consensu. on the severity of the risks and the effectiveness or col't of st: Ategies tn redw~**
There is little scientific or technical consensu. on the severity of the risks and the effectiveness or col't of st: Ategies tn redw~**
these risks.
these risks.
IMPERIAL BEAOl                              X                                                              San Onofre Units 2 and 3 would provide 440 M\'1 of e.\ect.ric [.Qo'el' to the San Diego region - almost one-half of lh** ,)(J;litionill pow*!!
San Onofre Units 2 and 3 would provide 440 M\\'1 of e.\\ect.ric [.Qo'el' to the San Diego region - almost one-half of lh**,)(J;litionill pow*!!
~
requirments forecast to be needed between now <~nd l!/95 foi: Lhe Srx;&E Service Area by Srx;&P. and the Calif<>rnia P.r'Cr<JY Cnrmi::sion.
LA MESA X                                                              requirments forecast to be needed between now <~nd l!/95 foi: Lhe IDOl': GROVE.                                                                                              Srx;&E Service Area by Srx;&P. and the Calif<>rnia P.r'Cr<JY Cnrmi::sion.
These forecasts include the effects of exi.~;tinq "'ns~rviltio11 and alternative energy source pcograms which will t:educe electricity demand.
X                                                              These forecasts include the effects of exi.~;tinq "'ns~rviltio11 and NATIONAL CITY                                                                                              alternative energy source pcograms which will t:educe electricity X                                                              demand. Potential additional electricity supplhs and <.'Ons"rvati(*n OCEANSIDE                                                                                                  and alternative energy sources which could result in a bala'1*~e be-X                                                              tween demand and supply over the next lD to 20 y<>~rs without San SAN DIEm                                                                                                    Onofre Units 2 and 3 have been identified (see at tachmcnt for a par-X                                                              tial list) but are not yet corrrnittcd. In sane c; """' tl:esr r<l<Jn'""
Potential additional electricity supplhs and <.'Ons"rvati(*n and alternative energy sources which could result in a bala'1*~e be-tween demand and supply over the next lD to 20 y<>~rs without San Onofre Units 2 and 3 have been identified (see at tachmcnt for a par-tial list) but are not yet corrrnittcd.
SAN MARCOS                                                                                                  may be infeasible or unavailable.
In sane c; """' tl:esr r<l<Jn'""
X                          '
may be infeasible or unavailable.
The construction of '>an Onofre Units 2 and 3 iG **:'ilrlnq romletion.
The construction of '>an Onofre Units 2 and 3 iG **:'ilrlnq romletion.
SANTEE                                      X                                                              About one-half of the total $3.4 billion project.*':] c:--,n,;trur~t ion cost has been expende<'l. The plant is cun:ently t;\1C:l<Yt:g<Jing t'.S *. Nucle.oc VISTA                                        X                                                  I          Regulatory O::mnission review in order to obtain ,,, O[le!ciltinq license.
About one-half of the total $3.4 billion project.*':] c:--,n,;trur~t ion cost has been expende<'l.
TOTAlS                                      13      1                                            It is my
The plant is cun:ently t;\\1C:l<Yt:g<Jing t'.S *. Nucle.oc Regulatory O::mnission review in order to obtain,,, O[le!ciltinq license.
                                                                            --                    I RECOMMENI:li\TION that the Board of Directors support tile operation of &-,n Jnofrr, Nuc:l ""'
It is my RECOMMENI:li\\TION that the Board of Directors support tile operation of &-,n Jnofrr, Nuc:l ""'
Power Plants 2 and 3 and request the Nuclear Requl'ltory c,mnission J certify from personal observation and count that the above results            ar~ an  accurBt~
Power Plants 2 and 3 and request the Nuclear Requl'ltory c,mnission to grant an operating lic'lnse tor these units suo)ect: t:o f<x1eral n*n!l ltions regarding the safety of nuc!eilr pa.*;er p!ant operatwns ""d one* *.Jen, y planning for nuclear plant accidents.  
to grant an operating lic'lnse tor these units suo)ect: t:o f<x1eral n*n!l ltions
:record of the SANDAG Board of Directors vote and action.                                        regarding the safety of nuc!eilr pa.*;er p!ant operatwns ""d one* *.Jen, y planning for nuclear plant accidents.                         *


                                                                                          ~
~
                                                                                                  ~"''"**!!<*
Discussion San 01ofre Units 2 and 3 are scheduled to have a total c..1pacity of 2, 200 megawatts (lfi) of electricity. SrG&E is a 20% partner in the pl<il.
                                                                                                  .\S.-;1 K"I.\HO\ (II'
is therefore entitled to 440 lfi of the electricity generated. '!he otl.<:c l, 760. l<ti is scheduled to be used by Southerri California Edison Ccr.*peny (76%) and Municipal utilities servi11.9 the Cities *of Anaheim and Riversicle (total of 4U *  
(;0\"EH:I:MEXTli RESOLUTION                                                No.        Bl-36 Discussion San 01ofre Units 2 and 3 are scheduled to have a total c..1pacity of 2, 200 megawatts (lfi) of electricity. SrG&E is a 20% partner in the pl<il.
'!he !bclear Regulatocy Camlission (NRC) is the federal agency responsible for issui11.9 nuclear*~ plant operati11.9 licenses. '!he Nf<C ~*ill hold hearings on the license applications for san 01ofre Units 2 and 3 st<Jrting in June 1981.  
is therefore entitled to 440 lfi of the electricity generated. '!he otl.<:c l, 760. l<ti is scheduled to be used by Southerri California Edison Ccr.*peny (76%) and Municipal utilities servi11.9 the Cities *of Anaheim and Riversicle (total of 4U
'!here are many environmental and econcmic issues relilttld tx> tJ e opcriltiun of san 01ofre Units 2 and 3 which include:
* RESOUJrlCN SUProR'l'lM:; WE OPERATIOO
Cost and reliability of nuclear pc::r.~er Risk of accidents fran. transport of uranilttl, <:oent nuclear fuel and operation of the plants.
  '!he !bclear Regulatocy Camlission (NRC) is the federal agency responsible                                               OF SAN CNOFnE NOCIZAR ECMER. l?U\m' for issui11.9 nuclear*~ plant operati11.9 licenses. '!he Nf<C ~*ill hold                                                                   UNITS* 2 AND 3 hearings on the license applications for san 01ofre Units 2 and 3 st<Jrting                                     SUBJECT TO FtttRAL REXm.I\TICNS ROOI\RDING THE in June 1981.                                                                                                 SAFETY OF NUCIZAR roiEil. PU\m' Ol?ERA'!'ICtlS AND
Cost of decommissioning the plants.
* et-IE:RGENCY*PU\NIII!l; ~"OR NOCLEAR PU\NT l\CCir:mTS
Ability of the plants to withstand earthquakes.
  '!here are many environmental and econcmic issues relilttld tx>     tJ e opcriltiun of san 01ofre Units 2 and 3 which include:
Hazards, cost and technical feasibility of long- :etm stora~c
Cost and reliability of nuclear pc::r.~er Risk of accidents fran. transport of uranilttl, <:oent nuclear fuel and operation of the plants.                                                             WllERE:AS, the Energy 2000 Task Force, appointed b:
* of radioactive wastes.
* Mayor Wil mn Cost of decommissioning the plants.                                            of the City of san Diego, presented the conclusions und lecmrncndati.ons Ability of the plants to withstand earthquakes.                                of its report to the SANI:\1\.G Board of Directors on Februa1 y 23, 1981; and Hazards, cost and technical feasibility of long- :etm stora~c
Scope and aiequacy of emergency plans to reduce i."adiatlon <'x-posure i~ the event of an accident.
* of radioactive wastes.                                                                        WllEilEAS, one of the t'eOO'I!lendations of the Enet"'Jy 2000 *Task l'or<:e Scope and aiequacy of emergency plans to reduce i."adiatlon <'x-                is to support ~ <nnpletion ancl operation of San Onofre Plant!* 2 a"l 3; ''""
At the licensing hearings iri June, it aPrkars that th&#xa3;' most controversial issues will be the ahility of the plants to withstand cm*thqun1:,.:; '""' tb*
posure i~ the event of an accident.
adequacy of emergency planning in case of an *accident that coulci imnecL surroundil1.9 areas. '!he Plant must meet federal standard.' in both of these areas before a license will be issued.
~ At the licensing hearings iri June, it aPrkars that th&#xa3;' most controversial WHE:RFJIS, San Onofre Units 2 ant'! :r, if canpl.:lte<i <*n*l opc*rat.<.'<l on schedule, will supply approximately half of the aclditional (*lcddcity ""L'I'l issues will be the ahility of the plants to withstand cm*thqun1:,.:; '""' tb*              forecast *tor. the San Diego region between ro.~ ancl 1995; and adequacy of emergency planning in case of an *accident that coulci imnecL surroundil1.9 areas. '!he Plant must meet federal standard.' in both of                                *WilEilEAS, the Nuclear Regulatory Catmission will begin licensing these areas before a license will be issued.                                              hearil1.9s &#xa3;or-San Onofre Units 2 and 3 in* June 1981; and WHE!lF.AS, federal regulations concerning nuclear po11er plant :;afety*
~
and emergency response planning will have to be met in ot :Jc*r for a licen:-..e to be granted; !Oi' 'lHEREFORE BE IT RESOLVED that the Board of Directo'!:s supper. ::s th<: nper-1tion of san Onofre Nuclear ~r Plant Units 2 and 3 ""d re<]\U:"<_ts the Nm:l*~r Regulatm:y Catmission to gr<mt an operating licc;lSe for ~~'""'' units ''uhj<.*ct to federal regulations regaming the safety of nltclear prii*m* plant n~r.;
~"''"**!!<*
.\\S.-;1 K"I.\\HO\\ (II' RESOLUTION
(;0\\"EH:I:MEXTli RESOUJrlCN SUProR'l'lM:; WE OPERATIOO OF SAN CNOFnE NOCIZAR ECMER. l?U\\m' UNITS* 2 AND 3 SUBJECT TO FtttRAL REXm.I\\TICNS ROOI\\RDING THE SAFETY OF NUCIZAR roiEil. PU\\m' Ol?ERA'!'ICtlS AND
* et-IE:RGENCY*PU\\NIII!l; ~"OR NOCLEAR PU\\NT l\\CCir:mTS No.
Bl-36 WllERE:AS, the Energy 2000 Task Force, appointed b:
* Mayor Wil mn of the City of san Diego, presented the conclusions und lecmrncndati.ons of its report to the SANI:\\1\\.G Board of Directors on Februa1 y 23, 1981; and WllEilEAS, one of the t'eOO'I!lendations of the Enet"'Jy 2000 *Task l'or<:e is to support ~  
<nnpletion ancl operation of San Onofre Plant!* 2 a"l 3; ''""
WHE:RFJIS, San Onofre Units 2 ant'! :r, if canpl.:lte<i <*n*l opc*rat.<.'<l on schedule, will supply approximately half of the aclditional (*lcddcity ""L'I'l forecast *tor. the San Diego region between ro.~ ancl 1995; and  
*WilEilEAS, the Nuclear Regulatory Catmission will begin licensing hearil1.9s &#xa3;or-San Onofre Units 2 and 3 in* June 1981; and WHE!lF.AS, federal regulations concerning nuclear po11er plant :;afety*
and emergency response planning will have to be met in ot :Jc*r for a licen:-..e to be granted; !Oi' 'lHEREFORE BE IT RESOLVED that the Board of Directo'!:s supper. ::s th<: nper-1tion of san Onofre Nuclear ~r Plant Units 2 and 3 ""d re<]\\U:"<_ts the Nm:l*~r Regulatm:y Catmission to gr<mt an operating licc;lSe for ~~'""'' units ''uhj<.*ct to federal regulations regaming the safety of nltclear prii*m* plant n~r.;
tions and emergency plannfn9 for nuclear plant accidents.
tions and emergency plannfn9 for nuclear plant accidents.
PASSED AND l!OOPl'ID this 16th day of M3rch 1981.
PASSED AND l!OOPl'ID this 16th day of M3rch 1981.
ATTEST;                         SECRETARY *--                                                            CIIAIRMIIN l!.Qt.llBAGENCIES..:....Ci.bt:S....o~~~~;-Dt~"EtCtjon,lffl(WttJI su,.h, La Ni~*~.~. (triuail"Gtn~X~,f'latlnnal CTtv. Ot1!<W'>ad~.
ATTEST; SECRETARY CIIAIRMIIN l!.Qt.llBAGENCIES..:....Ci.bt:S....o~~~~;-Dt~"EtCtjon,lffl(WttJI su,.h, La Ni~*~.~. (triuail"Gtn~X~,f'latlnnal CTtv. Ot1!<W'>ad~.  
                                        "'*"                                            -~ D$t00. San Marca,   SaPllt and \/tata/Cx-olltC"tO Mtmblt. Cllifnrnia ~rtmttll of frantf)(WQttntllt~u*.,. Mtmh" lll'*'l. 8. Cf !'I
-~ D$t00. San Marca, SaPllt and \\/tata/Cx-olltC"tO Mtmblt. Cllifnrnia ~rtmttll of frantf)(WQttntllt~u*.,. Mtmh" lll'*'l. 8. Cf !'I  


A'lTACDIErn' (Fran Energy 2000 Task Force 11eport)
A'lTACDIErn' (Fran Energy 2000 Task Force 11eport) 5a.JRCE; Potential Supply Alternatives For thf' SOO&E Service Area*
Southern California Edison Company
1980-2000 San <Xtofre 2 and 3 Arizona (renelled contract)
                                                                                                                                              ,. o aox eoo ZlAA WALNUT GPIOVt: AVtNUf "OSEMEAD   CALifl'OIIINlA. 117'10 K. P. lASKlN
New llexl co (renewed contract)
                                                                                    """"''"'att* 01" MUCt.l** C:NCliHIIC:IliHG,           March 24, 1981                            Tll.ll ...*O"'I lfiJIU:t*J~OI t**ITV, ANC L.ICCf<OSIWG Director, Office of Nuclear Reactor Regulation Potential Supply Alternatives                                    Attention: Darrel G. Eisenhut, Director For thf' SOO&E Service Area*                                                        Division of Licensing 1980-2000                                            u.s. Nuclear Regulatory Conrnission Washington, D.C. 20555 San <Xtofre 2 and 3                                                             
Washington (ren~0 contract)
Mexiro (purchase)
Geothenna.l Blythe site Hydroelectric O:lgenerat.ion lnnd 440 MW (nuclear) 400 M\\1' (imported) 150 Mil' (in{)Orted) 100 MW ( in!pOrt.ed:
300 Mil' (imported) 800 lfil' (geothenn< 1) 1, 000 l!W (coal gasi fi caUon) 34 Mil' (hytlroeleC"tric) 100 Mil' (cogeneration)
TOJ'AL 30 Mil' (wind)
:f,3541iW San Diego Gas and Electric Canpany, Septernbct* 1979
*Sane of these sources may be infeasible or unavailable.
l"or cxampJ.>,
Arizona Public Service Canpany would have to agree to a* reneo.-Je<l cn:l-tract for 400 1-&1 of importP.d power fran Arizona; tl1e fe.. sibility of lODO megawatts fran a coal gasitication plant at Blythe ha:; i;nL been pwv<.vl.
y Southern California Edison Company  
,. o aox eoo ZlAA WALNUT GPIOVt: AVtNUf "OSEMEAD CALifl'OIIINlA. 117'10 K. P. lASKlN March 24, 1981
""""''"'att* 01" MUCt.l** C:NCliHIIC:IliHG, t**ITV, ANC L.ICCf<OSIWG Director, Office of Nuclear Reactor Regulation Attention: Darrel G. Eisenhut, Director Division of Licensing u.s. Nuclear Regulatory Conrnission Washington, D.C.
20555  


==Dear Sir:==
==Dear Sir:==
440 MW (nuclear)
Arizona (renelled contract)          400 M\1' (imported)                       
==Subject:==
==Subject:==
Docket Nos. 50-361 and 50-362 New llexl co (renewed contract)      150 Mil' (in{)Orted)                                        San Onofre Nuclear Generating Station Washington  (ren~0  contract) 100 MW ( in!pOrt.ed:                                            Units 2 and 3 Mexiro (purchase)                    300 Mil' (imported)
Docket Nos. 50-361 and 50-362 San Onofre Nuclear Generating Station Units 2 and 3  
Geothenna.l                          800 lfil' (geothenn< 1)                   


==References:==
==References:==
Realistic Estimates of the Consequences of Nuclear Accidents, Blythe site                      1, 000 l!W (coal gasi fi caUon)                                        M. Levenson and F. Rahn, EPRI, November, 1980.
Realistic Estimates of the Consequences of Nuclear Accidents, M. Levenson and F. Rahn, EPRI, November, 1980.
Hydroelectric                        34 Mil' (hytlroeleC"tric)
This letter provides Southern California Edison Company's cor.ments to the Sup~lement to Draft Environmental Statement related to the operation of San Ono re Nuclear Generating Station Units 2 and 3 RUREG-0490.
O:lgenerat.ion                                                                  This letter provides Southern California Edison Company's cor.ments to the 100 Mil' (cogeneration)
In our review of this document we have found two points whicn we feel are in need of further clarification prior to the issuance of a Final Environmental Statement.
!:          lnnd TOJ'AL 30 Mil' (wind)
: 1.
:f,3541iW Sup~lement to Draft Environmental Statement related to the operation of San Ono re Nuclear Generating Station Units 2 and 3 RUREG-0490. In our review of this document we have found two points whicn we feel are in need of further clarification prior to the issuance of a Final Environmental Statement.
The following statement contained In Section 7.1.4.3, "The 200-rem whole-body dose figure corresponds approximately to a threshold value for which hospitalization would be indicated for the treatment of radiation injury. The 25-rem whole-body (which has been identified earlier as the lower lfm1t for a clinically observable phystolgical effect) and 300-rem thyroid figures correspond to the Conrnission's guideline values for reactor siting in 10 CFR Part 100."
: 1.       The following statement contained In Section 7.1.4.3, 5a.JRCE; "The 200-rem whole-body dose figure corresponds approximately to a San Diego Gas and Electric Canpany, Septernbct* 1979                                                  threshold value for which hospitalization would be indicated for the treatment of radiation injury. The 25-rem whole-body (which has been identified earlier as the lower lfm1t for a clinically
requires clarification, to prevent the statement from being misconstrued to state that San Onofre does not meet the Conrnission siting guide11_qes of 10 CFR 100.
  *Sane of these sources may be infeasible or unavailable. l"or cxampJ.>,                                    observable phystolgical effect) and 300-rem thyroid figures Arizona Public Service Canpany would have to agree to a* reneo.-Je<l cn:l-                                correspond to the Conrnission's guideline values for reactor siting tract for 400 1-&1 of importP.d power fran Arizona; tl1e fe..sibility of lODO                            in 10 CFR Part 100."
In order to clearly differentiate between the Class 9 accident and the design basis accidents used in the Conrnission siting criteria, specific clarification is needed.
megawatts fran a coal gasitication plant at Blythe ha:; i;nL been pwv<.vl.                        requires clarification, to prevent the statement from being misconstrued to state that San Onofre does not meet the Conrnission siting guide11_qes of 10 CFR 100.
The traditional Design Basis Accidents (DBA's) are hypothetical and conservative scenarios, evaluated in accordance with regulations and other regulatory guidance. which define the required assumptions and methodology.
In order to clearly differentiate between the Class 9 accident and the design basis accidents used in the Conrnission siting criteria, specific clarification is needed. The traditional Design Basis Accidents (DBA's) are hypothetical and conservative scenarios, evaluated in accordance with regulations and other regulatory guidance. which define the required assumptions and methodology. In contrast, the Class 9 accident scenario is defined with no consideration of mitigation by engineered safety features, assumes highly conservative and consequence maximizing behavior of natural mitigation processes. Since the Class 9 acctdent uses much more conservative, unrealistic, assumptions, it. is not considered in the evaluation of reactor siting.
In contrast, the Class 9 accident scenario is defined with no consideration of mitigation by engineered safety features, assumes highly conservative and consequence maximizing behavior of natural mitigation processes. Since the Class 9 acctdent uses much more conservative, unrealistic, assumptions, it. is not considered in the evaluation of reactor siting.
y          s1o:ssoos 32
s1o:ssoos 32 Tll.ll... *O"'I lfiJIU:t*J~OI
: 0. G. Eisenhut                              2. Although uncertainties in probability calculations are discussed in Sections 7.1.4.2 and 7,1.4.7 of the Supplement, the uncertainties in the source terms, and hence the consequences of the accident, are not discussed in either Section 7.1.4.3 or 7.1.4.7, These radiation source terms have been shown to be conservative by experiments performed at RocKwell, karlsruke, Oak Ridge National Laboratory, General Electric (Aircraft Nuclear Propulsion Department), Bettis National laboratory, Hanford National Laboratory, and tests performed in the Idaho Reactor Test Site. The results of these tests and experiments, sulllll8rized in a paper by M. Levenson and F. Rahn ot the Electric Power Research Institute, indicate that natural processes are operating which prevent the release of radioactive nuclides from molten nuclear reactor fuel (Reference 1). Dr. Chauncey Starr, former President of the Electric Power Research Institute advised the Commission, at the Co~m~issions November 18, 1980 meeting in Washington, D.C., that, "The important issue is that the initial review of this subject appears to indicate that under any conceivable realistic circumstance, the real source term is likely to result in risk to the public that is less by factors of 10 to 100 than that which was previously estimated."
 
~
: 0. 2.
Although uncertainties in probability calculations are discussed in Sections 7.1.4.2 and 7,1.4.7 of the Supplement, the uncertainties in the source terms, and hence the consequences of the accident, are not discussed in either Section 7.1.4.3 or 7.1.4.7, These radiation source terms have been shown to be conservative by experiments performed at RocKwell, karlsruke, Oak Ridge National Laboratory, General Electric (Aircraft Nuclear Propulsion Department), Bettis National laboratory, Hanford National Laboratory, and tests performed in the Idaho Reactor Test Site. The results of these tests and experiments, sulllll8rized in a paper by M. Levenson and F. Rahn ot the Electric Power Research Institute, indicate that natural processes are operating which prevent the release of radioactive nuclides from molten nuclear reactor fuel (Reference 1). Dr. Chauncey Starr, former President of the Electric Power Research Institute advised the Commission, at the Co~m~issions November 18, 1980 meeting in Washington, D.C., that, "The important issue is that the initial review of this subject appears to indicate that under any conceivable realistic circumstance, the real source term is likely to result in risk to the public that is less by factors of 10 to 100 than that which was previously estimated."
Using Dr. Starr's estimate of a realistic maximum release into the atmosphere would lower the consequences (acute fatalities and cancer deaths) from a Class 9 accident by 1 to 2 orders of magnitude.
Using Dr. Starr's estimate of a realistic maximum release into the atmosphere would lower the consequences (acute fatalities and cancer deaths) from a Class 9 accident by 1 to 2 orders of magnitude.
~  The Final Environmental Statement for San Onofre Units 2 and accurate, concise, and not leave room for misinterpretation.
The Final Environmental Statement for San Onofre Units 2 and 3 should be accurate, concise, and not leave room for misinterpretation. Where applicable, a11 sources of error, and the relative magnitude of error, should be indicated.
applicable, a11 sources of error, and the relative magnitude 3 should be Where of error, should be indicated. We hope that these cOIMients will help to make the FES for SONGS 2 and 3 such a document.
We hope that these cOIMients will help to make the FES for SONGS 2 and 3 such a document.
Very truly yours,
Very truly yours,  
                                              )I)? /1-L*
)I)? /1-L*  


APPENDIX B NEPA POPULATION DOSE ASSESSMENT
APPENDIX B NEPA POPULATION DOSE ASSESSMENT  


Appendix 8 NEPA POPULATION DOSE ASSESSMENT Population dose commitments are calculated for all individuals living within 80 km (50 miles) of the facility employing the same models used for individual doses (see Regulatory Guide 1.109, in preparation).
Appendix 8 NEPA POPULATION DOSE ASSESSMENT Population dose commitments are calculated for all individuals living within 80 km (50 miles) of the facility employing the same models used for individual doses (see Regulatory Guide 1.109, in preparation).
In addition, population doses associated with the export of food crops produced within the 80-km region and the atmospheric and hydrospheric transport of the more mobile effluent species such as noble gases, tritium, and carbon-14 have been considered.
In addition, population doses associated with the export of food crops produced within the 80-km region and the atmospheric and hydrospheric transport of the more mobile effluent species such as noble gases, tritium, and carbon-14 have been considered.
B.1 NOBLE GAS EFFLUENTS For locations within 80 km of the reactor facility, exposures to these effluents are calculated using the atmospheric dispersion models in Regulatory Guide 1.111 and the dose models described in Section 5.5 and Regulatory Guide 1.109. Beyond 80 km and until the effluent reaches the northeastern corner of the. United States, it is assumed that all of the noble gases are dispersed uniformly in the lowest 1000 m (3280 ft) of the atmosphere. Decay in transit was also considered. Beyond this point, noble gases having a half-life greater than one year (e.g., Kr-85) were assumed to mix completely in the troposphere of the world with no removal mechanisms operating.
B.1 NOBLE GAS EFFLUENTS For locations within 80 km of the reactor facility, exposures to these effluents are calculated using the atmospheric dispersion models in Regulatory Guide 1.111 and the dose models described in Section 5.5 and Regulatory Guide 1.109.
Transfer of tropospheric air between the northern and southern hemispheres, although inhibited by wind patterns in the equatorial region, is considered to yield a hemisphere average tropospheric residence time of about two years with respect to hemispheric mixing. Since this time constant is quite short with respect to the expected mid-point of plant life (15 years), mixing in both hemispheres can be assumed for evaluations over the life of the nuclear facility. This additional population dose commitment to the U.S.
Beyond 80 km and until the effluent reaches the northeastern corner of the. United States, it is assumed that all of the noble gases are dispersed uniformly in the lowest 1000 m (3280 ft) of the atmosphere.
Decay in transit was also considered.
Beyond this point, noble gases having a half-life greater than one year (e.g., Kr-85) were assumed to mix completely in the troposphere of the world with no removal mechanisms operating.
Transfer of tropospheric air between the northern and southern hemispheres, although inhibited by wind patterns in the equatorial region, is considered to yield a hemisphere average tropospheric residence time of about two years with respect to hemispheric mixing.
Since this time constant is quite short with respect to the expected mid-point of plant life (15 years), mixing in both hemispheres can be assumed for evaluations over the life of the nuclear facility.
This additional population dose commitment to the U.S.
population was also evaluated.
population was also evaluated.
8.2   IODINES AND PARTICULATES RELEASED TO THE ATMOSPHERE Effluent nuclides in this category deposit onto the ground as the effluent moves downwind, which con-tinuously reduces the concentration remaining in the plume. Within 80 km of the facility, the deposition model in Regulatory Guide 1.111 was used in conjunction with the dose models in Regulatory Guide 1.109.
8.2 IODINES AND PARTICULATES RELEASED TO THE ATMOSPHERE Effluent nuclides in this category deposit onto the ground as the effluent moves downwind, which con-tinuously reduces the concentration remaining in the plume.
Site-specific data concerning production, transport, and consumption of foods within 80 km of the reactor were used. Beyond 80 km, the deposition model was extended until no effluent remained in the plume.
Within 80 km of the facility, the deposition model in Regulatory Guide 1.111 was used in conjunction with the dose models in Regulatory Guide 1.109.
Excess food not consumed within the 80-km distance was accounted for, and additional food production and consumption representative of the eastern half of the country was assumed. Doses obtained in this manner were then assumed to be received by the number of individuals living within the direction sector and distance described above. The population density in this sector is taken to be representative of the eastern United States, which is about 410 persons per km 2 (160 persons per mi 2 ). (This approach is conservative for San Onofre because population densities in the western United States are considerably lower than those in the eastern portion.)
Site-specific data concerning production, transport, and consumption of foods within 80 km of the reactor were used.
B.3   CARBON-14 AND TRITIUM RELEASED TO THE ATMOSPHERE Carbon-14 and tritium were assumed to disperse without deposition in the same manner as krypton-85 over land. However, they do interact with an atmospheric residence time of 4 to 6 years with the oceans being the major sink. From this, the equilibrium ratio of the carbon-14 to natural carbon in the atmosphere was determined. This same ratio was then assumed to exist in man so that carbon-14 to natural carbon in the atmosphere was determined. This same ratio was then assumed to exist in man so that the dose received by the entire population of the United States could be estimated. Tritium was assumed to mix uniformly in the world's hydrosphere, which was assumed to include all the water in the atmosphere and in the upper 70 m (230ft) of the oceans. With the model, the equilibrium ratio of tritium to hydrogen in the environment can be calculated. The same ratio was assumed to exist in man, and was used to calculate the population dose, in the same manner as with carbon-14.
Beyond 80 km, the deposition model was extended until no effluent remained in the plume.
8.4   LIQUID EFFLUENTS Concentrations of effluents in the receiving water within 80 km of the facility were calculated in the same manner as described above for the Appendix I calculations. No depletion of the nuclides present in the receiving water by deposition on the bottom of the Pacific Ocean was assumed. It was also assumed that aquatic biota concentrate radioactivity in the same manner as was assumed for the Appendix I B-1
Excess food not consumed within the 80-km distance was accounted for, and additional food production and consumption representative of the eastern half of the country was assumed.
Doses obtained in this manner were then assumed to be received by the number of individuals living within the direction sector and distance described above.
The population density in this sector is taken to be representative of the eastern United States, which is about 410 persons per km2 (160 persons per mi 2).
(This approach is conservative for San Onofre because population densities in the western United States are considerably lower than those in the eastern portion.)
B.3 CARBON-14 AND TRITIUM RELEASED TO THE ATMOSPHERE Carbon-14 and tritium were assumed to disperse without deposition in the same manner as krypton-85 over land.
However, they do interact with an atmospheric residence time of 4 to 6 years with the oceans being the major sink.
From this, the equilibrium ratio of the carbon-14 to natural carbon in the atmosphere was determined.
This same ratio was then assumed to exist in man so that carbon-14 to natural carbon in the atmosphere was determined.
This same ratio was then assumed to exist in man so that the dose received by the entire population of the United States could be estimated.
Tritium was assumed to mix uniformly in the world's hydrosphere, which was assumed to include all the water in the atmosphere and in the upper 70 m (230ft) of the oceans.
With the model, the equilibrium ratio of tritium to hydrogen in the environment can be calculated.
The same ratio was assumed to exist in man, and was used to calculate the population dose, in the same manner as with carbon-14.
8.4 LIQUID EFFLUENTS Concentrations of effluents in the receiving water within 80 km of the facility were calculated in the same manner as described above for the Appendix I calculations.
No depletion of the nuclides present in the receiving water by deposition on the bottom of the Pacific Ocean was assumed.
It was also assumed that aquatic biota concentrate radioactivity in the same manner as was assumed for the Appendix I B-1  


B-2 evaluation. However, food consumption values appropriate for the average individual, rather than for the maximum, were used. It was assumed that all of the sport and commercial fish and shellfish caught within the 80-km area were eaten by the U.S. population.
B-2 evaluation.
Beyond 80 km, it was assumed that all of the liquid effluent nuclides except tritium have deposited on the sediments so they make no further contribution to population exposures. The tritium was assumed to mix uniformly in the world's hydrosphere and to result in an exposure to the U.S. population in the same manner as discussed for tritium in gaseous effluents.
However, food consumption values appropriate for the average individual, rather than for the maximum, were used.
It was assumed that all of the sport and commercial fish and shellfish caught within the 80-km area were eaten by the U.S. population.
Beyond 80 km, it was assumed that all of the liquid effluent nuclides except tritium have deposited on the sediments so they make no further contribution to population exposures.
The tritium was assumed to mix uniformly in the world's hydrosphere and to result in an exposure to the U.S. population in the same manner as discussed for tritium in gaseous effluents.  


APPENDIX C EXPLANATION AND REFERENCES FOR BENEFIT-COST  
APPENDIX C EXPLANATION AND REFERENCES FOR BENEFIT-COST  


==SUMMARY==
==SUMMARY==
Appendix C EXPLANATION AND REFERENCES FOR BENEFIT-COST  
Appendix C EXPLANATION AND REFERENCES FOR BENEFIT-COST  


==SUMMARY==
==SUMMARY==
 
C.l ECONOMIC IMPACT OF STATION OPERATION C.l. 1 Direct benefits C. 1. 1.1 Energy 2114 MWe x 1000 kW/MW x 365 days x 24 hr/day x capacity factor (0.5 or 0.7). This product ranges from 9.3 x 109 kWhr/year (0.5 capacity factor) to 13.0 x 109 kWhr/year (0.7 capacity factor).
C.l   ECONOMIC IMPACT OF STATION OPERATION C.l. 1 Direct benefits C. 1. 1.1 Energy 2114 MWe x 1000 kW/MW x 365 days x 24 hr/day x capacity factor (0.5 or 0.7). This product ranges from 9.3 x 109 kWhr/year (0.5 capacity factor) to 13.0 x 109 kWhr/year (0.7 capacity factor).
C.l. 1.2 Reduced regional oil consumption Section 8.3.1 shows that the applicants primarily have oil/gas fired units, which would have to be operated to a greater extent if SONGS 2 & 3 are not operated.
C.l. 1.2 Reduced regional oil consumption Section 8.3.1 shows that the applicants primarily have oil/gas fired units, which would have to be operated to a greater extent if SONGS 2 & 3 are not operated. The additional fuel oil consump-tion (assuming a 50% capacity factor for the nuclear units) is calculated as follows:
The additional fuel oil consump-tion (assuming a 50% capacity factor for the nuclear units) is calculated as follows:
9.3 x 109 kWhr
9.3 x 109 kWhr
* 9,000 Btu/kWhr
* 9,000 Btu/kWhr
* 1 bbl oil = 13 . 2 x 10 6 bbl oil.
* 1 bbl oil = 13.2 x 106 bbl oil.
6.29 X 106 Btu C.1.2 Economic costs C. 1.2.1   Fuel From Sect. 8.3.1, the staff's estimate of fuel cost is $10.8 per megawatt-hour in 1983.
6.29 X 106 Btu C.1.2 Economic costs C. 1.2.1 Fuel From Sect. 8.3.1, the staff's estimate of fuel cost is $10.8 per megawatt-hour in 1983.
Assuming a 60% capacity factor or 11.1 x 106 MWhr/yr gives the value in Table 10.1.
Assuming a 60% capacity factor or 11.1 x 106 MWhr/yr gives the value in Table 10.1.
C.l.2.2 Operating and maintenance Using the staff's OMCST computer code, operating and maintenance costs are estimated to be 4.05 mills/kWhr at 60% capacity, which multiplied by 11.1 x 109 kWhr/year gives the values in Table 10.1.
C.l.2.2 Operating and maintenance Using the staff's OMCST computer code, operating and maintenance costs are estimated to be 4.05 mills/kWhr at 60% capacity, which multiplied by 11.1 x 109 kWhr/year gives the values in Table 10.1.
Decommissioning: Based on estimates given in Sect. 9.4, the cost of decommissioning each unit will be $66.7 million in 1978 dollars or $85.4 million in 1980 dollars at the end of the useful life of the plant. If this value is discounted from 2013 to 1983, then annualized over a 30-year life assuming a real interest and discount rate of 4.76%, and then multiplied by 2 units, the value in Table 10.1 is obtained.
Decommissioning:
C-1
Based on estimates given in Sect. 9.4, the cost of decommissioning each unit will be $66.7 million in 1978 dollars or $85.4 million in 1980 dollars at the end of the useful life of the plant. If this value is discounted from 2013 to 1983, then annualized over a 30-year life assuming a real interest and discount rate of 4.76%, and then multiplied by 2 units, the value in Table 10.1 is obtained.
C-1  


APPENDIX D CULTURAL RESOURCES}}
APPENDIX D CULTURAL RESOURCES}}

Latest revision as of 01:45, 2 January 2025

Public Watchdogs - NRC 2.206 Petition Exhibits 1-38 - Part 21
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Text

Do I

w

"-1 10, Lockheed Center for Marine Research (LCMR). 1978. San Onofre.Nuclear Generating Station Unit 1, Environmental Technical Specifications, Annual Operating Report, Volume III -Biological Data Analysis - 1977.

Prepared for Southern California Edison Company, 125 p.

11.
12.
13.
14.
15.
16.
17.
18.
19.
20.
21.

Marine Biological Consultants, Inc., 1978.

Construction Monitoring Program, San Onofre Nuclear Generating Station, Units 2 and 3, December, 1976-December, 1977.

Prepared for Southern California Edison Company, 78RD-21. n.p.

North, W. J., 1960.

The effects of waste discharges on kelp.

University of California Inst. Mar. Res., IMR Ref.

b0-4:1-44.

North, W. J., 1976.

Introducing warm tolerant Macrocystis to the vicinity of a thermal discharge.

Summary report of the 1975 activities.

64 p.

North, W. J. and C. L. Hubbs, 1968.

Utilization of kelp-bed resources in Southern California.

California Department of Fish and Game, Fish Bull.

(139):1-264.

Phillips, R. C., 1974.

Kelp beds in : Coastal ecological systems of the United States.

The Conservation Foundation, Was~!ngton, D.C., Volume II, pp. 442-487.

Scripps Institute of Oceanography (SIC), 1978a.

Surface water temperatures at shore stations - U.S. West Coast, 1977-1976.

SIC Ref. 78-5. 77 p.

Scripps Institute of Oceanography (SIC), 1978b.

Surface water temperatures at shore stations - U.S. West Coast, 1977.

SIO Ret. 78-16. 45 p.

North, W. J., 1958.

The effects of waste discharge on kelp.

University of California Inst. Mar. Res., IMR Ref.

59-1:1-27.

Southern California Edison Company, "Biennial Forecast of Electric Loads and Resources Report," March 17, 197o.

Southern California Edison Company, "Revised Resource Plan submitted to Energy Commission," September 22, 1976.

North, w. J., January 25, 1979, letter to Mr. T. Sciarrotta, Southern California Edison Company. 22.

Brown and Caldwell, 1977.

San Onofre Nuclear Generating Station Unit l, Environmental Technical Specifications, Annual Operating Report, Volume 1. Oceanography Data Summary-1976.

23.

Brown and caldwell, 1978.

San Onofre Nuclear Generating Station Unit 1, Environmental Technical specifications, Annual Operating Report, Volume 1. Oceanographic Data Analysis-1977.

24.

Brown and Caldwell, 1977.

San Onofre Nuclear Generating Station, Unit 1, Environmental Technical Specifications, Annual Operating Report, Volume III.

Oceanographic Data Analysis-1976.

=r

~

,...... ~

~

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION IX 216 Fremont Street San Francisco. Cs. 941 06 Project t D-NRC-K06002-CA William H. Regan, Jr., Chief Environmental Projects, Branch 2 Division of Site Safety & Environmental Analysis u.s. Nuclear Regulatory Commission washington, D.c.

20555

Dear Mr. Regan:

FEB 131979 the SAN 3, sotiTHERN TRIC EPA's comments on the draft environmental statement have been classified as Category ER-2.

Definitions of the categories are provided on tne-inclosure.

The classification and the date of EPA's comments will be published in the Federal Register in accordance with our responsibility to Inform the public of our views on proposed Federal actions under Section 309 of the Clean Air Act.

our procedure is to categorize our comments on both the environmental consequence of the proposed action and the adequacy of the environmental statement.

EPA appreciates the opportunity to comment on this draft environmental statement and requests three copies of the final environmental statement when available.

If you have any questions regarding our comments, please contact Betty Jankus, EIS Coordinator, at (415)556-6695.

Sincerely,

<a..* :l.cd"f'( ~~

~Paul De Falco, Jr.

ib Regional Administrator Enclosure Water Quality Comments

1.

In Section 5.3.1.1., some assessment is made of the effects of the discharge of heated cooling water on the receiving coastal waters with regards to the California State thermal standards.

When evaluating thermal discharge, all effects of Units 2 and 3 should be considered in conjunction with the effects of Unit 1. The natural background is a situation where none of the three units is operating.

The natural receiving water temperature as defined by California Thermal Plan (see next paragraph) is *the temperature of the receiving water at locations, depths, and times which represent conditions unaffected by any elevated temperature waste discharge*.

Unless Units 2 and 3 are not planned to operate concurrently with Unit l, their effects will occur in concert. All modeling, graphs, and maps produced from models should include Unit l effects when evaluating SONGS' effects on the receiving water temperature.

Under Section 316(a) of the Federal water Pollution control Act of 1972 (FWPCA) and under the water Quality Control Plan for Control of Temperature in the coastal and Interstate Waters and Enclosed Bays and Estuaries of California (1975 Thermal Plan} (EPA approved State water quality standards), there are several criteria which discharges to coastal waters must fulfill. These should be addressed in any EIS on operating a new coastal.discharge of elevated temperature wastes.

These are as follows:

a.

In part 3.B.(3.) of the Thermal Plan, it is stated that *the maximum temperature of thermal waste discharges shall not exceed the natural temperature of receiving waters by more than 2o*r.* Part 3.2.2. of the DBIS states that the cooling water *experiences an ll.l°C (20°F) temperature rise across the condenser.* Since the waters in the vicinity of the intakes for Units 2.and 3 are close to the discharge structures for these units, it is possible that these intake waters are already heated beyond their natural temPerature.

SOme evaluation of this effect must be included in the FBIS.

The influence of the heated discharge from Unit 1 must also be described.

In addition, the intake

=r w

u:.

b.
c.
d.

and discharge facilities and their depths and bow temperature stratification profiles relate to the 20°F requirement should be discussed.

In Part 3.B.(4) of the Thermal Plan, it is stated that "the discharge of elevated temperature wastes shall not result in increases in the natural water temperature exceeding 4°P at (a) the shoreline, (b) the surface of any ocean substrate, or (c) the ocean surface beyond 1,000 feet from the discharge system.

The surface temperature limitation shall be maintained at least 50 percent of the duration of any complete tidal cycle.* Figure 5.3 of the DEIS represents projected incremental increases above natural surface temperatures for the study area.

This figure should be changed in the FEIS to include the Unit 1 intake and discharge structures and the increase of surface temperatures already caused by Unit l discharges in conjunction with those of Units 2 and 3 so as to compare the increases with the true natural surface water temperature.

In addition, the FEIS should document the estimate (Section 5.3.1.2) of the increase in temperatures at the surface of the ocean substrate around the discharges.

This estimate indicates that wvioiations of the state thermal standards are unlikely.* Again, such estimates should compare natural temperatures to the combined effects of Units 1, 2, and 3.

These temperatures are of special concern because of the importance of low basal temperatures to maintaining the nearby kelp bed.

Finally, lhe Thermal Plan and Section 316(a) of the FWPCA assert *the need to "assure the protection and propagation of a balanced, indigenous population of shellfish, fish, and wildlife in and on the body of water into which the discharge is to be made".

In Section 5.4.2.1 of the DEIS, biological/ecological evaluations refer to the effects of the discharges on various types of organisms, indicating the effects to be minimal and acceptable.

For plankton, the effects will be >>species composition changes" and *greater respiration rates", also, "significant effects should be localized".

For fish, the effects will be mainly "shifts in the types of species (and their numbers) which inhabit the area*.

For benthic fauna, adverse effects may be expected if *weekly mean temperatures of 22"C prevail for one month or more or where daily temperatures reach or exceed 24°C.

It is not, however, anticipated that temperatures averaging 22"C will occur for more than 2 to 3 weeks or that the area experiencing temperatures of 24°C or greater as a result of SONGS operation will be considerably larger than the area experiencing these temperatures under natural conditions".

For kelp, the information *suggests that tbe thermal discharges from SONGS 1, 2 and 3 may result in the destruction of at least a portion of the San Onofre Kelp Bed during the summer months~. All of these statements indicate that the indigenous populations will be altered, giving no specific documentation that these effects will be minimal or acceptable.

A detailed evaluation of how the aquatic ecosystem will be affected, over what area each species or type of fauna may be influenced, and what constitutes a significant adverse effect should be made and presented clearly in the FEIS.

2.

Section 5.4.2.1. Thermal Effects, mentions a final report due on December 29, 1978.

This study, provided for under the Thermal Plan and Section 316(a) of the FWPCA, is to be used in evaluating the heat-treatment process which is used to clear the intake facilities of biological growth.

EPA considers this study to be an integral part of the assessment of the environmental effects of the thermal discharges from the Units.

As such, it must be distributed, along with biological and water quality assessments and conclusions (perhaps in the form of a supplement to the DEIS) to all recipients of this OEIS, with the allowance of a comment period prior to incorporation in the Final EIS.

=r a

3.

Section 5.4.2,2 includes a discussion of the potential effects of chlorine discharges.

The discussion evaluated potential *significant impacts* of the periodic 15-minute chlorine dosing period.

The FEIS should include a comparison of effluent concentrations with the State Standards contained in the Water Quality Control Plan for the Ocean Waters of California (1978 Ocean Plan), Table Band Footnote 11, should appear in the EIS.

Should the comparison predict that the discharges exceed the requirements, the plans to lower the discharge concentration to agree with the State Standards must be described in the FEIS.

4.

No assessment appears in the DEIS of the potential seismic effects of nearby faults on the units, although there is a fault within a mile of the plant (the Christianitos Fault and others in the vicinity).

The FEIS should address the potential of seismic events and the resultant damage from fault movement, with particular emphasis on the water quality and off-site radiological contamination. Radiological Comments Beach Regulation This DEIS gives little information on the anticipated beach population.

The presence of thousands of daytime beach users and hundreds of overnight campers within 1.5 miles from the reactors has significant security, emergency planning, and radiation dose implications.

Consequently, we believe this issue warrants a thorough discussion in the Final EIS so that those reviewers who will not read the Environmental Review and Emergency Plan will be aware of this situation and have an opportunity to evaluate it.

We agree with the decision to restrict usage of the beach in front of the reactors since it will simplify the security and emergency planning problems and will reduce the radiation doses to the population from routine release.

However, the practical effectiveness of this restriction should be addressed in the FEIS (e.g., is the prohibition against restricting the area seaward of mean high water, coupled with permitting viewing and pedestrian passage going to make enforcement difficult?).

It would be helpful to briefly mention the Emergency Response Plan that is in effect for the Nuclear Station and relate it to the transient population.

As mentioned under the Dose Commitment section, it is not clear whether beach users and Visitor Center users are included in the individual and population dose calculations.

Environmental Dose Commitments Page 5-31-34 of the DEIS:

The estimated maximum individual dose and the population dose were independently checked by EPA with results similar to those presented in the DEIS.

However, we do have several questions about assumptions used in the DEIS calculations.

The FEIS should clarify the following items:

-s-

liP I

~

l.

The manner in which the individual and population dose to users of the beach is calculated is unclear.

For example, what allowance is made for direct radiation doses, especially to those using the walkway between-the south and north beaches, and to those at the Visitors Center?

Do the individual and population doses include these users of the beach and the Visitors Center and, if so, what assumptions were made on. hours of exposure, shielding factors, etc.? Also, it would be helpful if the habits of "a maximum individual" were described so it could be determined to what extent these various pathway dosages are additive.

2.

The actual maximum individual dose from present operation of Unit 1 should be described.

This dose should be added to those being projected for Units 2 and 3 (from all pathways).

This, in turn, should be compared with the 25 millirem per year limit (75 millirem per year to the thyroid) of the Uranium Fuel Cycle Standard (40 CFR 190).

EPA is encouraged that the NRC is now calculating annual population dose commitments to the u.s. population, which is a partial evaluation of the total potential environmental dose commitments (EDC) of H-3, Kr-85, C-141 iodines and "particulates.* This is a big step toward evaluating the EDC which EPA has urged for several years.

However, it should be recognized that several of these radionuclides (particularly C-14 and Kr-85) will contribute to long-term population dose impacts on a world-wide basis, rather than just in the u.s.

To the extent that the draft statement (1) has limited the EDC to the annual discharge of these radionuclides, (2) is based on the assumption of a population of constant size, and (3) assesses the doses during SO years only following each release, it does not fully provide the total environmental impact.

Assessmenf of the total impact would (1) incorporate the projected releases over the lifetime ot the facility (rather than just the annual release), (2) extend to several half-lives or 100 years beyond the period of release, and (3) consider, at least qualitatively or generically, the world-wide influences on the total environmental impact or specify the limitations of the model used. Environmental Monitoring The pre-operational and operational radiological environmental monitoring program (as described in Section 6.1.5 of the Environmental Report) appears adequate with the following exceptions which the FEIS should address:

1.

A delay of 8 days before analyzing charcoal filter air samples would permit over 99% of the Iodine-133 and 50% of the Iodine-131 to decay before being counted.

The decay would be much greater for contamination occurring at the beginning of the 7-day sampling period.

The maximum time before analyzing filters should be shortened significantly in order to detect as many incidences of sporadic contami"nation as possible.

2.

It is not clear why a minimum of only ten 7-day air particulate samples are required per quarter.

The intent should be to monitor all 13 weeks in a quarter.

3.

No TLD stations are indicated for the walkway along the seawall or the mean high water exclusion area in front of the reactors.

It would be desirable to include TLD's at these locations to monitor the direct radiation at a site boundary where the public has access.

Reactor Accidents The EPA has examined the NRC's analyses of accidents and their potential risks.

The analyses were developed by NRC in the course of its engineering evaluation of reactor safety in the design of nuclear plants.

Since these issues are common to all nuclear plants of a given type, EPA accepts NRC's generic approach to accident evaluation in the DEIS.

However, the NRC is expected to continue to ensure safety through plant design and accident analyses during the licensing process on a case-by-case basis.

In 1972, the AEC initiated an effort to examine reactor safety and the resultant environmental consequences and risks on a more quantitative basis.

The final report of this effort was issued in October 1975 by the u.s. Nuclear Regulatory Commission as the Reactor Safety Study, WASH-1400 (NUREG-75/014).

The EPA's review of this study r

i!!;

included in-house and contractual efforts, and our comments were released in a report in June, 1976.

In subsequent discussion with _NRC we determined that of the concerns we expressed, those having the most significance with regard to the results of the study were on (1) the latent cancer health effects and (2) the probability of BWR scram failure where we differed by factors of four and' a maximum of ten, respectively.

We believe that the methodology of the Reactor Safety Study should continue to be used as a tool in the evaluation of nuclear systems that vary from the models chosen for the study, and that a generic analysis should be made of the acceptability of the present risks and the necessity for increased levels of safety.

High-Level waste Management The techniques and procedures used to manage high-level radioactive wastes will have an impact on the environment.

To a certain extent, these impacts can be directly related to the individual projects because the spent fuel from each new facility will contribute to the total waste.

The AEC, on September 10, 1974, issued for comment a draft statement entitled "The Management of Commercial High-Level and Transuranium-Contaminated Radioactive waste" (WASH-1539).

In this regard, EPA provided extensive comments on WASH-1539 on November 21, 1974.

Our major criticism was that the draft statement lacked a program for arriving at a satisfactory method of "ultimate* high-level waste disposal.

At present, DOE is preparing a new draft statment which will discuss waste management and emphasize ultimate disposal in a more comprehensive manner.

EPA concurs with this decision and will review and comment on the new draft statement replacing the September 10, 1974 version when it is available.

EPA is cooperating with both NRC and DOE to develop an environmentally acceptable program for radioactive waste management.

In this regard, on November 15, 1978, EPA issued proposed environmental radiation protection criteria (43 FR 53262) for the management of all radioactive waste and will propose environmental radiation protection standards for high-level waste in 1979.

-s-Transportation In its earlier reviews of the environmental impacts of transportation of radioactive material, EPA agreed with AEC that many aspects of this program could best be treated on a generic basis.

The NRC has codified this generic approach (40 PR 1005) _by adding a table to its regulations (10 CPR Part 51) which summarizes the environmental impacts resulting from the routine transportation of radioactive materials to and from light-water reactors.

These regulations permit the use of the impact values listed in the table in lieu of assessing the transportation impact for individual reactor licensing actions if certain conditions are met.

Since San Onofre appears to meet these conditions and since EPA agrees that the routine transportation impact values in the table are reasonable, the generic approach appears adequate for this plant.

The impact value for routine transportation of radioactive materials has been set at a level which covers 90*percent of the reactors currently operating or under construction.

However, the basis for the impact, or risk, of transportation accidents is not as clearly defined.

At present, EPA, DOE, and NRC are each attempting to more fully assess the radiological impact of transportation risks.

The EPA will make known its views on any environmentally unacceptable conditions related to transportation.

On the basis of present information, EPA believes there are no unique characteristics of the San Onofre site which would result in greater accident risks than from the "typical" site being studied generically.

Fuel Cycle and Long-Term Dose Assessments EPA is responsible for establishing generally applicable environmental radiation protection standards to limit unnecessary radiation exposures and radioactive materials in the general environment resulting from normal operations that are part of the total uranium fuel cycle as well as those of the facilities.

The EPA has concluded (in 40 CPR 90) that environmental radiation standards for nuclear power industry operations should take into account the total radiation dose to the population, the maximum individual dose, the risk of health effects attributable to these doses (including the future risks arising from the release of long-lived radionuclides to the environment), and the effectiveness and costs of effluent

Jio I...

w control technology.

EPA's Uranium Fuel Cycle Standards are expressed in terms of dose limits to individual members of the general public and limits on quantities of certain long-lived radioactive materials released to the general environment.

A document entitled "Environmental Survey of the Uranium Fuel Cycle" (WASH-1248) was issued by the AEC in conjunction with a regulation (10 CFR 50, Appendix D) for application in completing the cost-benefit analysis for individual light-water reactor environmental reviews (39 FR 14188).

This document is used by NRC in draft environmental statements to assess the incremental environmental impacts that can be attributed to fuel cycle components which support nuclear power plants.

Recently, the NRC decided to update the WASH-1248 survey.

We believe this is a prudent step and commend the NRC on initiating this update.

In providing comments to the NRC on this subject, dated November 14, 1978, we encouraged NRC to express environmental impacts in terms of potential consequences to human health, since for radioactive materials and ionizing radiation the most important impacts are those ultimately affecting human health.

We believe the presentation of environmental impact in terms of human health impact fosters a better understanding of the radiation protection afforded the public.

A second major concern of EPA deals with the discharge and dispersal of long-lived radionuclides into the general environment.

In the areas addressed in WASB-1248, there are several cases in which radioactive materials of long persistence are released into the environment.

The resulting consequences may extend over many generations and constitute irreversible public health commitments.

This long-term potential impact should be considered in any assessment on health impact.

EPA has consistently found inadequate the NRC's estimates of population doses for these persistent radioactive materials.

In particular, the NRC has generally limited their analysis to the population within 50 miles of a facility or, in rare cases, to the u.s. population, and to doses committed for a 50-year period by an annual release.

These limitations produce incomplete estimates of environmental impacts and underestimate the impact in some cases, such as from releases of tritium, Krypton-85, Carbon-14, Technetium-99, and Iodine-129.

The total impact of these persistent radionuclides should be assessed, qualifying such estimates as appropriate to reflect the large uncertainties.

In this regard, we note that NEA is addressing this approach in making assessments and that NRC is represented in this effort.

Another major consideration in updating WASB-1248 is the health impact from Radon-222 from the uranium mining and milling industry.

Estimates made by EPA, among others, indicate that Radon-222 contributes the greatest fraction of the total health impact from nuclear power generation.

In preparing an updated WASH-1248, we believe NRC should:

1.

include the Radon-222 contribution from both the uranium mining and milling industries;

2.

determine the health impact to larger populations, not only the local populations;

3.

recognize the persistent nature of the Radon-222 precursors {Th-230 and Ra-226) by estimating the health impact for a period reflecting multi-generation times.

Decommissioning The NRC has published a proposed rulemaking on Decommissioning Criteria for Nuclear Facilities in the Federal Register on March 13., 1978.

EPA comments were sent to NRC on July 5, 1978, dealing with the decommissioning issue.

In summary, we believe that one of the most important issues in the decommissioning of nuclear facilities is the development of standards for radiation exposure limits for materials, facilities, and sites to be released for unrestricted use.

We have included the development of such standards among our planned projects.

The work will require a thorough study to provide necessary information, including a cost-effectiveness analysis for various levels of decontamination.

The development of standards for decommissioning must, of course, include consideration of the many concurrent activities in radioactive waste management and radiological protection.

EPA has developed proposed Criteria for Radioactive Waste for management of all

!Ill I

1:

radioactive wastes which.will provide guidance for decommissioning standards.

From the decommissioning view, probably the most important criterion is that limiting reliance on institutional controls (guards and fences) to a finite period.

EPA believes that the use of institutional control to protect the public from retired nuclear facilities until they can be decontaminated and

  • decommissioned should be limited at the most to 100 years and preferably less than so years.

This includes nuclear reactors shut down and mothballed or entombed for a period of time under protective storage. After the allowable institutional care period is over, the site will have to meet radioactive protection levels established for release for unrestricted use.

We believe EPA's proposed criteria would be directly applicable, as above, to decommissioning of nuclear facilities and should be given serious consideration by the Nuclear Regulatory Commission (NRC).

The availability of adequate funds when the time to decommission arrives is also most important; it should be the responsibility of the NRC to assure that such provisions are made.

We recognize the great complexity of providing funds at construction for decommission in 40 years.

However, if it can be determined that the total cost of decommissioning in current dollars is a very small fraction of initial capital costs, provision of escrow funding may not be necessary.

Therefore, we urge the NRC to conduct the necessary studies and assessments to determine unequivocally costs of decommissioning and to compare such costs to initial capital costs. It is only through a definitive.analysis, and perhaps through realistic demonstrations, that this issue can be resolved. EIS CATEGOR! CODES Environmental rmpact of the Action to--Lack of Objections EPA has no objection to the proposed action as described in the draft impact atatement1 or suggests only mtnor changes in the proposed action.

ER--Environmental Reservations EPA has reservations concerning the environmental effects of certain aspects of the proposed action.

EPA believes that further study of suggested alternatives or modifications is required and has asked the originating Federal agency to reassess these aspects.

ZU.-Environmentally Unsatisfactory

!PA believes that the proposed aCtion is unsatisfactory because of its potentially harmful effect on the environment.

Furthermore, the Agency believes that the potential safeguards which might be utilized may not adequately protect the environment from hazards arising from this action.

The Agency re~nds that alternatives to the action be analyzed further

{including the possibility of no action at all).

Adequacy of the Impact Statement Category 1--Adequate The draft impact statement adequately sets forth the environmental impact of the proposed project or action as well as alternatives rea-sonably available to the project or action.

category 2--Insufficient Information EPA believes that the draft impact statement does not contain suffi-cient information to assess fully the environmental impact of the pro-posed project or action. However, from the information submitted, the Agency is able to make a preliminary determination of the impact on the environment.

EPA has requested that the originator provide the information that was not included in the draft statement.

category 3--Inadequate EPA believes that the draft impact statement does not adequately assess the environmental impact of the proposed project or action, or that the statement inadequately analyzes reasonably available alternatives.

The Agency has requested more information and analysis concerning the poten-tial environmental hazards and has asked that substantial revision be made to the impact statement.

If a draft impact statement is assigned a Cate9ory 3, no rating will be made of the project or action, since a basis does not generally exist on which to make such a determination.

> I....

U'l Mard.ll I. Lewis 6504 Bradford Terrace Phila. PA 19H9

-6-79.

Director, Divieioa of Site Safety EATironmeatal Analysis Office of nuclear Reactor Rogdation USNRC Waskiagton. /d.C. 20555 Sir:

BUREG 0490 does a lot of things, but it does not 1a aay way justify tho operation of the Saa onofre Nuclear Generating Station.

Although the NUREG does proTide a lot of good in!ermatien, thia iatermation actually contradicts the usefulness of the SONGS, Sa n Onofre Nuclear Generating Statioa. For instance, the growth rate in Table 2.2,Pace 2-2, is ;.5 ~ or less fer the period 1976 to 1990. The ~owth rate in Table a.; and 8.4 on Pacea %t 8-4and 8-5 is dDse to 5~ for the same perioa. Inotherwords, the growth ratea in Tarious parts of tao report are *selected

  • to provide justi!icatio*

for whatever the writer wishes to r.s~ify 1~ &~f Ji>>fiX particular p~t of the report *. This technique is called '!icti~.

In Appendix D-2; Page 2.5 Seismology is dismissed in a few paragraphs.

Considering the recent and continuing at.

seismic discoveries at tho Hosgri fault at Diablo Canyon (which is in a similar -in fact aame-gelological domain),

passing ott seismology this cavtlierly

t.

is indefensible.

Page 5-37. First you state in a Table that the Commissioner has directed that Radon 222 will be reconsidered elsew8ere; then, the Staff includes Radon 222 in this Nureg in a convoluted and artificial manner which does not in any way investigate or acknowledge Radon 222's full period o! toaicity as required by NEPA.

Page 5~)9 Tailings are not required to be stabilized forever, and even if-it~ were required, tereTer stabilization ie a God like requiremen>>f whick may be impossible to mortal men~.

Jhapter 7.

This is based entirely on the Rasmussen Wash 1400

  • Commisssionor Kennedy has already stated on October lG, 1978, "It ( Rasmussen Report) found some deticiendieo which ouggeet that the absolute values of the riske presented in the Study should not be used uncritically either i~ the regulatory process or tor public policy purposes."

The DES !or operation of SONGS proves unequivooally ~hat thia nuclear power plant is unnecessary and dangerous.

~is is despite the Stall evaluation which ignores all important negative effects.

DO NOT LICENSE THIS NUCLEAR POWER PLANT TO OPERATE A' OF HUMAN LIVES.

Marvin I. Lowi8 ~'

.J. H. CRAt<E Southern California Edison Company

""'o. aox eoo U..... WALNUT GA:OVE AVENUE AOSEM£.A.D, CALIF'OI'tNIA G'f770 see April 6, 1979 Tt:t..J:,.HON£ Ati3*'S72*U06 Director, Office of Nuclear Reactor Regulation Attn:

Wm. H, Regan, Jr., Chief Environmental Projects Branch 2 Division of Site Safety and Environmental Analysis U.S. Nuclear Regulatory Commission Washington, DC 20555 Gentlemen:

Subject:

San Onofre Nuclear Generating Station Units 2 and 3 Docket Nos. 50-361 and 50-362 Mr. Oliver Lynch, Jr., of the NRC staff called on March 27, 1979, to request clarification of Applicants' Comment 6-4 to the Draft Environmental Statement for S~n Onofre Nuclear Generating Station, Units 2 and 3.

Applicants' Comment 6-4 was submitted with other comments by letter to you dated February 2, 1979.

In response to Mr. Lynch's request, a revised Comment o-4 is enclosed for your information.

If you have additional comments regarding this comment, please contact me.

Enclosure

,:f??.JJ; i/

790424 0 '3 '? q c_~\\1

6.3.1

~

Water Ouality Monitorinv Pro~ram Comm~nt 6-4 (Revised April 6, 1979)

{Page 6-6)

The first five para~raohs of this section of the DES describe a proposed operational monitoring program which was presented in the ER-OLS (Section 6.2) and was based upon the proposed preoperational monitorin~ program also presented in the ER-OLS.

The ER-OLS was developed in 197~ and su~mitted in 1977 to the NRC.

Since that time, the Preoperational ~onitoring Program has been revised to incorporate the latest site specific study results and recent developments in marine ecological study techniques.

The revised Preoperational ~onitoring Program was approved by the NRC and implemented in 1978. It is the Applicant's intention to develop an operational monitoring program which incorporates results of the Preoperational Monitoring Program and submit it in the near future for approval. It was the intention of Comment 6-Q to indicate that the specific details of the operational monitoring program proposed in the ER-OLS in 1976 (and contained in the DES) should not be considered to represent the program which will actually be implemented.

While the program which will ultimately be implemented will be similar to the one included in the ER-OLS, it will not be identical, and the differences between the two cannot be specified at this time because the development process is still underway.

1 RICHARD J. WHARTON Attorney at Law 2 4655 Cass St., Suite 304 San Diego, CA 92109 3 (714) 488-2828 411Attorney fo;: Intervenors 5

6 7

8 9

UNITED STATES OF AMERICA 10 11 12 13 14 15 NUCLEAR REGULATORY COl~USSION BEFORE THE ATOMIC SAFETY AND LICENSING BOA~

In the Matter of

)

Docket Nos. 50-361 OL

)

50-362 OL SOUTHERN CALIFORNIA

)

EDISON COMPANY, ~ al.,

)

CO~!ENTS ON DRAFT ENVIRONMENT.

)

STA~!ENT - SAN ONOFRE NUCLEAR (San Onofre Nuclear Generating

)

GENERATWG STATION, UNITS 2 Station, Units 2.and 3)

)

AtiD 3

)

)

16 We have carefully reviewed the above draft environmental 17 statement in relation to the requirements imposed by Section 18 102(2)(c) of the National Environmental Policy Act (NEPA) and 19 10 CFR Part 51 of the NRC Regulations, and have set forth below 2011intervenors' comments on the proposed action and on this draft 21

~

statement pursuant to 10 CFR Part 51.25.

Intervenors find this draft statement inadequate in a) the discussion and assessment of 23 environmental effects, both beneficial and adverse, associated 24 with the operation of the San Onofre Nuclear Generating Station, 25 Units 2 and 3, and b) the *discussion and consideration of avail-26 able alternatives to.. t;he-p1:'0posed action.* *<Intervenors specific-all 27 identify the following deficiencies:

28

1. The evaluation of cooling water discharge impacts is

t e inaccurate and misleading.

The heated water will very likely esult in the destruction of at least a portion of the San Onofre elp bed during the summer months, the long-term thermal impacts violations of the state standards On page 5-7 of the DES it is stated:

"The staff there exists a remote possibility that thermal standards could be violated by the operation of 2 and 3, violations would, at worst, be infrequent and for periods.

There is no evidence in available drift data to occurence would take place during the summer hen thermal impacts would be most severe." This conclusion was 12 apparently based on applicants' "worst case" modeling theory; 13 however, in light of recent findings as a result of studies pre-14 sently being performed by the Marine Review Committee (MRC) at the 15 request of the California Coastal Commission, it has been determindd 16 that the state thermal standards will ~

be met.

The following 17 excerpts from the "Supplemental Staff Report And Recommendations -

18 Review of Thermal Requirements For San Onofre Nuclear Generating 19 Station, Units 2 and 3" prepared by the California State Water 20 Quality Control Board staff are appropriate:

"The Report of the 21 MRC confirms the previous prediction that, under normal operating 22 conditions, the proposed discharge will violate the 20 degree F 23 temperature differential in the "receiving waters" i.e., waters 24 at the location and depth of the diffusers of Units 2 and 3.

This 25 Report notes:

'... if the "receiving" waters are defined as in 26 this paragraph, the standards of the State Thermal Plan will 27 probably be exceeded by the operation of Units 2 and 3.' Although 28 the R~port indicates that the discharge will "likely" or "probably1* 1 or "may" violate the temperature differential, there really is no 2 question that such violations will occur."

(pp. 4-5) 3 In a hearing for the purpose of interpreting the term "re-4 ceiving waters" held on December 21, 1978, the California State 5 Water Quality Control Board held that ".*. the temperature at the 6 intake point does not represent conditions at the receiving 7 aters," (p. 3 of Opinion of Chairman Bryson and Board Member 8 Mitchell) contrary to applicants' requested interpretation.

The 9 net result of this ruling is that the state thermal discharge 10 limitation will be exceeded by operation of SONGS Units 2 and 3.

11 The DES states at *P* 5-27 "The greatest threat of SONGS to 12 the long-term survival of the San Onofre kelp bed is the 13 possibility of injury to the basal tissues from which the canopy 14 is regenerated each year... under extreme worst case conditions 15 (e.g., several days with high ambient temperatures and slack 16 currents, and with all the plants operating continuously),

17 destruction of the basal regenerative tissues might result." The 18 DES further states:

"... the community (kelp bed), if destroyed 191\\frequently, could never achieve a stable state characteristic of 20 other kelp beds in the area.

Furthermore, constant temperature 21 increases coupled with added turbidity would be inimical to 22 interim reestablishment... The perennial occurrence of worst case 23 conditions seems highly unlikely and the staff thus concludes that 24 the long-term thermal impacts from normal station operation are 25 not likely to be severe."

(p. 5-27) It is clear that since the 26 state thermal discharge limitation will be exceeded during normal 27 operation of SONGS 2 and 3, the staff's conclusion was based on 28 a faulty premise.

Dischargers' normal plant operation will result

Ia I c 1 in continuous high temperature discharge approximating the worst 2 case conditions and resulting in both short and long-term thermal 3 impacts on the San Onofre kelp beds.

The DES states at *p. 5-27 4 "It has been rather well established that temperatures above 5 18-20 degrees C. (64-68 degrees F) cause deterioration of kelp, 6 and the degree of degradation is directly related to the duration 7 of the exposure to these temperatures."

8

2.

The DES is inadequate in its discussion of the 316(a) 9 exception process as related to thermal pollution caused by the 10 proposed action.

Section 6.4.1 of the.DES discusses the "thermal 11 exception studies" as related only to periodic "heat treatment" to 12 control fouling organisms.

The DES fails to consider the 316(a) 13 exception required for continuous high ambient temperature 14 discharges during the normal operations of Units 2 and 3. It is 15 highly likely that a 316(a) exception request will be forthcoming 16 from applicants in light of the recent denial by the California 17 State Water Quality Control Board of applicants' requested 18 interpretation of the term "r~ceiving waters" as used in the 19 State Thermal Plan.

Had applicants' interpretation been approved, 20 it would have obviated applicants' need for a 316(a) exception to 21 the requirements of the FWPCA.

Because a 316(a) exception is 22 necessary for the operation of Units 2 and 3 in their present 23 desiga mode, the DES is inadequate for failure to consider the 24 implications, both short and long-term, on the aquatic environment 25 if such an exception is granted.

With respect to the maximum 26 temperature of thermal waste discharges, and contrary to the 27 requirements of 10 CFR Part 51.23(c), due consideration was not 28 given to "... compliance of the facility construction or operation 1 and alternative construction and operation with environmental 2 quality standards and requirements which have been imposed by 3 Federal, State, regional, and local agencies having responsibility 4 for environmental protection, including applicable zoning and 5 landuse regulations and water pollution limitations or requirement 6 promulgated or imposed pursuant to the Federal Water Pollution

  • 711 Control Act."

8 9

3.

The DES is inadequate in its evaluation and analysis of the social and economic impact of operating SONGS 2 and 3.

10 A.

With respect to the environmental impact of SONGS 11 on recreational resources, the DES reco~nizes the failure of 12 applicants to comply with the terms and conditions of the 13 construction permit:

"The current plan to restrict the use of 14 approximately 25%.of the 3 1/2 mile San Onofre Beach for the 30-15 year operating life of the plant is a significant loss of valuable 16 recreational and scenic space and represents a substantial change 17 in action between issuance of the FES-CP and application for an 18 operating license."

(Section 5.6.5) Staff reiterates previous 19 statements made in the FES-CP that "the beach... is considered to 20 be a unique and scarce recreational resource," (FES-CP,

p. 2-11) 21 and "that closure even for a brief period is objectionable" 22 (FES-CP,
p. 8-11).

Despite the re-affirmation of these 23 judgments, staff concludes that the social and economic impact of 24 operating SONGS 2 and 3 - with the significant exception of 25 restricting public use of the beach-will be only "moderate".

26 The overall impact will be more severe than "moderate" if the 27 beach access restriction is factored into the balancing process.

28 Staff's treatment of this issue is misleading and inconsistent

=-

1.,.

CD 1 with the purpose and intent of NEPA, section 102(2)(c), which 2 calls for preparation of a detailed statement on, among other 3 things, any irreversible and irretrievable commitments of 4 resources which would be involved in the proposed action should 5 it be implemented.

Restriction of the public's use of this beach 6 is such an irreversible and irretrievable commitment of resources.

7 B.

With respect to the economic impact of SONGS 2 and 3, 8 the DES provides no analysis of the effects of the Jarvis-Gann 9 Amendment (Proposition 13).

The DES states that "The applicant 10 should reassess the potential tax benefits accruing to these 11 jurisdictions and districts in light of Proposition 13."

12 (p. 5-44)

This is a wholly inadequate treatment of the economic 13 impact of SONGS 2 and 3, inasmuch as the revenue from the plant 14 and its allocation within communities will be "significantly 15 different from what was assumed" - to use the staff's own words -

16llin this economic impact analysis.

(p 5-44, section 5.6.4) 17

4.

The DES inadequately evaluates the environmental impact 18 of postulated accidents in that Class 9 occurrences were omitted 19 from consideration.

(Section 7-1)

The DES states on p. 7-2 with 20IIrespect to Class 9 occurrences that "Their consequences could be 2tllsevere." The DES fails to discuss the probability of Class 9 22lloccurrences in a complete and comprehensive manner.

In view of 23 the recent earthquake fault discoveries near the San Onofre site 24 and the existence of the dewatering-well cavities found beneath 25 the site, a full discussion of failures more severe than those 26 required for consideration in the design bases of protective 27 systems and engineered safety features (Class 9) is warranted.

28 Further, the estimated dose of 1400.00 man-rems to population in 1 the 50-mile radius for a large-break loss of coolant accident 2 (Table 7.2, p. 7-3, Class 8.1) is substantial and inadequately 3 discussed, if at all, in the text.

4

5.

The DES is inadequate in that it fails to discuss the 5 environmental impacts to the region in the event of an accidental 6 release of radiation requiring evacuation.

No discussion is 7 contained in the DES as to the adaptability of the San Onofre site 8 to adequate evacuation processes including evacuation of the 9 nearby beach areas during times of peak use; no discussion is 10 contained in the DES as to the suitability of existing evacuation 11 plans; no discussion is contained in the DES as to the effects 12 which adoption of the NRC/EPA Task Force Report on Emergency 13 Planning (NUREG-0396) will have on evacuation within the new and 14 expanded Emergency Planning Zone as distinct from the presently 15 designated Low Population Zone (NRC Regulations 10 CFR Part 100).

16

6.

The DES is inadequate in that it fails to reassess the 17 seismic design basis for SONGS 2 and 3 in light of a) the 18 dewatering-well cavities and b) the recent earthquakes and faults 19 discovered since the current design basis was established.

20

7.

The DES is inadequate in that the cost/benefit analysis 21 fails to provide consideration for the greatest possible 22 escalation of uranium prices, based on recent occurrences, for 23 SONGS 2 and 3 over the operating life of the plant.

The projected 24 fuel costs identified as $87,900,000/yr for 1981 (Table 10.1, 25 p. 10-2), will possibly escalate to a prohibitively high level 26 since long-term uranium contracts are generally tied to market 27 price at delivery or 7$ per year escalation, whichever<is greater 28 Staff admits (section 10.3) that since the issuance of the FES-CP r

~

1 the fuel, operating, and maintenance costs of nuclear plant 2 operation have escalated more rapidly than anticipated.

The DES 3 does not discuss adequately the possibility of additional future 4 escalation of costs with respect to the fuel requirements of San 5 Onofre, and does not utilize a "worst possible case" approach to 6 determine total fuel costs over the operating life of the plant.

7.The cost/benefit analysis contained in the DES is therefore 8 invalid.

9

8.

The DES is inadequate in that it fails to discuss the 10 possibility that decommissioning costs may escalate to 11 prohibitively high levels by the end of the operating life of the 12 plant, at which time the applicant is required to prepare a 13 proposed decommissioning plan for review by the NRC.

(Section 9.4 14 Although NRC regulations do not require the applicant to have 15 developed a decommissioning plan at the time an operating license 16 is obtained, the discussion of alternative decommissioning methods 17 and their associated costs found in the DES is misleading and does 18 not present an accurate projection of what the actual decommission 19 ing costs for SONGS will be. Staff calculations for determining 20 decommissioning costs per unit of electricity generated do not 21 utilize a start-up date of 1981 or an escalation rate based on the 22 current rate of inflation. Staff's projection that "For the 23 SONGS Units 2 and 3 the decommissioning costs would be. about 24 double that indicated for all of the decommissioning one-unit 25 alternatives'.' (p. 9-17) is wholly inadequate for purposes of discuss the temporary storage of nuclear waste materials, 2llincluding the interim storage of spent fuel, on site.

3

10.

The DES is inadequate in that it fails to discuss the 4 issue of plant security and provide assurances that all nuclear 5 materials will remain accounted for and protected from the risk 6 of terrorist or criminal activity or sabotage.

7 Because due consideration was not given to compliance with 8 the requirements of 10 CFR Part 51.23(c), and because this DES 9 fails to consider all environmental impacts of the proposed action 10 and alternatives to the proposed action as required by Section 11 102(2)(c) of NEPA, staff's conclusion that the action called for 12 is the issuance of operating licenses for Units 2 and 3 of SONGS 13 is premature and founded on insufficient and inaccurate data.

14 For the foregoing reasons, intervenors request that the NRC 15 either a) adequately address the issues raised above in the final 16 environmental statement for SONGS 2 and 3, or. b) deny applicants' l7llrequest for licenses to operate 18 Dated: b__....v -:)OJ 12 7f 0

I 19 20 21 22 23 24 25 SONGS 2 and 3.

Respectfully submitted, 2611making an informed cost/benefit judgment.

As a consequence, the I

26 2711cost/benefit analysis for SONGS 2 and 3 is invalid.

28

9.

The DES is inadequate in that it fails to comprehensively 27 28

~

COMMENTS ON SUPPlEMENT TO DRAFT ENVIRONMENTAL STATEMENT Table of Contents Federal Energy Regulatory Conmission, *.**...*,,................,.* A-56 U.S. Department of Agriculture, Economics and Statistics Service.......................................... A-52 Mr. Frank H. Arundel.............................................. A-53 U.S. Department of Agriculture, Soil Conservation Service.................,........,................. A-54 U.S. Department of the Interior................................... A-55 Richard J. Wharton.****.*.*****.*****.*.*.*...*.....*..*......*... A-55 Union of Concerned Scientists... * * * * * * * * * * * * *. * * * * * * * * * * * * *. *..... A-63 U.S. Environmental Protection Agency.............................. A-65 San Diego Association of Governments.............................. A-68 Southern California Edison Company................................ A-71

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FEDERAL ENERGY REGULATORY COMMISSION WASHINGTON 20428 L'>

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Mr. Frank J. Miraglia Acting Chief, Licesning Branch No. 3 Division of Licensing U.S. Nuclear Regulatory Commission Washington, D. c.

20555

Dear Mr. Miraglia:

IN REPLY REP'Cft T01 January 23, 1981 I am replying to your request of January 16, 1981 to the Federal Energy Regulatory Commission for comments on the Supple-ment to the Draft Environmental Impact Statement related to the operation of the San Onofre Nuclear Generating Station, Units 2 and 3, This Draft EIS has been reviewed by approprlatu PERC staff components upon whose evaluation this r~sponse is based.

This staff concentrates its review of. other agencies' en-vironmental impact statements basically on those areas of the electric power, natural gas, and oil pipeline industries for which the Commission has jurisdiction by law, or where staff has special expertise in evaluating environmental impacts in-voled with the proposed action. It does not appear that there would be any significant impacts in these areas of concern nor serious conflicts with this agency's responsibilities shoulc1 this action be undertaken.

Thank you for the op~rtunity to review this statement.

Sincerely, Heinemann on Environmental Quality Sl o :; :*Q r 1D1' G

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United Slates Department of Agriculture L.vnilmics and Statistics Service Mr. Frank J. Miraglia Acting Chief, Licensing Branch No. 3 Division of Licensing U. s. Nuclear Regulatory. Commission Washington, D. C.

20555

Dear Mr. Miraglia:

Washington. D.C.

20250 January 26, 1981 Thank you for forwarding the Supplement to the Draft Environmental Statement for the San Onofre Nuclear Generating Station, Units 2 and 3.

We have reviewed the materia~, Docket Numblrs 50-3&1 and 50-3~, and have no comments at this time.

Sincerely, MLL~

MELVIN L. COTNER Director, Natural Resource Economics Division r*-

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Unlhld Slata Depar1mont of Agtfculture Soli Conaervation servtce Mr. Frank J, Miraglia Acting Chief, Licensing Branch No. 3 Division of licensing U.S. Nuclear Regulatory Commission 1-/ashington, D.C.

20555

Dear Mr. Miraglia:

2828 Chiles Road Davfs,*CA* 95616 (916) 758-2200 February 11, 1981 The Soil Conservation Service has reviewed the Supplement to the Draft Environmental Statement for San Onofre Nuclear Generating Station, Units 2 and 3.

We find no controversial items within the realm of SCS responsi-bilities.

This Environmental Statement Supplement reveals no conflicts with any of the ongoing projects within our jurisdiction.

No prime land will be lost to the proposed project.

We appreciate the opportunity to review and comment on this report.

Sincerely,

~~* t:Ut/_./

FRANCIS C. H.

LU~I State Conservationist cc:

Norman A. Berg, Chief, SCS, Washington, D.C.

Jack Smith, Area Conservationist, Escondido, CA

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United States Department of the Interior OFFICE OF THE SECRETARY WASHINGTON, D.C. 20240 ER 81/80 Mr. Frank J. Miraglia Acting Chief Licensing Branch No. 3 Division of Licensing Nuclear Regulatory Commission Washington, D.C.

20555

Dear Mr. Miraglia:

MPR 2 1981 We have reviewed the supplement to the draft environmental statement for San Onofre Nuclear"Generating Station, Units 2 and 3, San Diego, California, and find we have no comments.

The opportunity to review this document is appreciated.

  • cECf!.. S. He;

'-'-'*'-'"*"' s1RI'ii-¥1Rfssistant to RICHARD J. WHARTON Attorney at Law University of San Diego Alcala Park, California 92110 (714) 291-6480 Ext. 4376 Attorney for Intervenors UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of SOUTHERN CALIFORNIA EDISON COMPANY, et al.

(San Onofre Nuclear Generating Station, Units 2 and 3)

DOCKET Nos. 50-361 OL 50-362 OL JOINT INTERVENORS COMMENTS ON SUPPLEME~:

TO DRAFT ENVIRONMENTAL STATEMENT RELATE TO OPERATION OF SAN ONOFRE NUCLEAR GENERATING STATIONS, UNITS 2 and 3 (NUREG-0490)

The Supplement to Draft Environmental Statement (NUREG-0490, December, l9BO), hereinafter referred to as NUREG-0490, pre-pared by the Office of Reactor Regulation (Staff) of the united states Nuclear Regulatory Commission (NRC) related to the opera-tion of San Onofre Nuclear Generating Station, Units 2 and 3 (SONGS 2 and 3) has been reviewed by Intervenors in relation to the requirements imposed by the National Environmental Policy Act (NEPA) (42 O.S.C. J 4321, et seq.), 10 C.P.R. Part 51, and 40 C.P.R. Part 1502.

Intervenors comments on the proposed action and on NUREG-0490 are made pursuant to 10 C.F.R. Part 51.25 and 40 C.P.R. Part 1503.

8108180S.:Z&

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The purpose of NU~EG-0490 was *to identify and evaluate the site-specific environmental impacts attributable to accident sequences that lead to releases of radiation and/or radioactive materials including sequences that can result in inadequate cooling of reactor fuel and to melting of the reactor core.*

NUREG-0490, p. vi.

These accident sequences are commonly referred to as meltdowns or Class 9 accidents.

The NRC's historic first site-specific impact study of a meltdown accident at a California nuclear reaction is inadequate, incomplete and misleading.

NUREG-0490 is misleading because it does not provide decision-makers with sufficiently detailed information regarding the potential environmental impacts of a meltdown at SONGS 2 and 3 to aid them in a substantive decision whether or not to proceed with granting an operating license to this federal nuclear project in light of the economic and other consequences of an accident at SONGS 2 and 3.

NUREG-0490 does not encourage public participation because it does not make adequate information available to the public in non-technical language about the potential economic and environmental impacts that could affect the li~es of twelve million people.

NUREG-0490 appears inadequate and incomplete when compared with other indepen~

dent meltdown impact analyses.

After the Three Mile Island accident, which resulted in mass evacuations and temporary relocation of many people, the California state Legislature passed a law (Senate Bill 1183, now Section 8610.5 of the Government Code), which required the State Office of Emergency Services (OES) to prepare Emergency Response Plans for potentially severe nuclear accidents involving the release of large amounts of radiation.

In order to plan for such accidents, the State required information.of the potential sc~narios and consequences that could result from meltdowns in California reactors.

The State lead agency, OES, contracted with a conservative consulting group, Science Applications, Inc.

(SAI), to study the consequences and potential scenarios of meltdowns at California reactors.

SAI has conducted research for the NRC, the Department of Energy,.nuclear military projects, nuclear utilities, and the nuclear industry.

The SAI-OES study was released to the public in Sacramento, California on July 15, 1980.

The portion of the SAI-OES study which relates to SONGS 2 and 3 was based on extensive site-specific data whereas NUREG-0490, while it purports to be based on site-specific data, considers mainly excerpted "data, methodology and assumptions" from the WASH-1400 study.

The inadequacies of this approach are demonstrated by the following comparison petween the SAI-OES study and NUREG-0490 consequence analyses:

The SAI-OES study indicates that the maximum consequences for a nuclear meltdown at SONGS 2 and 3 would be $180 billion'in economic cost consequences, NUREG-0490 estimates $35 billion, SAI-OES estimates 16,000 square miles of land contaminated with radiation, NUREG-0490 estimates 3,000 square miles: SAI-OES estimates eight to ten million Southern Californians would be required to relocate and leave their homes and property for up to ten years.

Four to five million of them would have to be relocated lon~er than ten

~

years, NUREG-0490 gives no estimates for the magnitude of the population affected by relocation.

SAI-OES estimates that in 1975 there were 7.7 million people living within 60 miles of the San Onofre site.

Within 100 miles there are approximately 12 millton people.

The SAI-OES study acknowledges that "Latent

~eaths from San Onofre can occur within 100 miles, which includes half of the population of California.*

Another report done for the California Stat~ Legislature, discussed below, warns that children within 100 miles downwind from the reactor would receive damage to their thyroid glands and would require surgery due to exposure to radioactive iodine gases.

The SAl-OES study also estimates that $6.6 billion in cost consequences could occur within 500 miles of San Onofre following a meltdown.

Reports to the President's council on Environmental Quality warn that areas as far away as 1,000 miles or more could be affected, and that up to 125,000 square miles of land could suffer some contam-ination or crop or milk interdiction.

The possibility exists that Southern California could be permanently contaminated after a meltdown at SONGS 2 and 3.

This is not surprising when we look at other accident scenarios and compare their estimates.

One NRC analysis of reactor accidents, WASH-740, esti-mated that an area the size of Pennsylvania could be permanently contaminated by a meltdown at a reactor significantly smaller than either Unit 2 or 3 at San Onofre.

Another report, the Rasmussen report, WASH-1400, estimated that 3,000 square miles of land would be contaminated, but assumed that effective evacuations would take place out to 30 miles downwind from the reactor accident.

NUREG-0490, estimates the maximum conseqnences of a San Onofre meltdown to be $35 billion in costs for mitigating actions (evacuations, relocations, land interdiction, emergency response by local, county, state and federal teams), 1 million

~eople would receive more than 25 rems, there would be 130,000 acute fatalities, and 300,000 latent cancers in the population within SO miles who would be exposed to 30 to 40 billion person rems released during the accident.

The consequences of nuclear power plant core melt accidents have also been estimated at the request of the California State Legislature and the President's Council on Environmental Quality by Dr. Jan Beyea and Dr. Frank von Rippel, nuclear physicists with the Princeton University's Program on Nuclear Policy Alternatives of the Center for Energy and Envir-onmental Studies.

or. Beyea noted in his analysis that a melt-down with a release of radioactive gases from a large reactor could involve "health effects and possible land use restrictions have been considered out to distances of 1,000 miles and for periods of decades after the release.*

He estimates that up to 175,000 square miles of land could be under some form of interdiction or restricted use following the meltdown.

He explains this by saying "The number of health effects and the.** land contamination can range so high because a substantial fraction of the released radioactivity can be carried for hundreds of miles downwind before being removed from the atmosphere by deposition on the ground.

Dr. Beyea told the President's council on Environmental Quality (CEQ) that *early fatalities could occur up to 30 miles downwind" of a reactor meltdown.

Or. Frank von Hippe! testified before the California State Leqislature after Three Mile Island

~hat "the thyroid could receive a radiation dose tens to hundreds of times higher than the rest of the body.

Exposed children more than a hundred miles downwind would suffer thyroid damage which would require surgery years later." (emphasis added)

NUREG-0490 did not reference the SAI-OES study, in spite of.*the fact that the Atomic Safety and Licensing Board {ASLB) and the NRC Staff were made aware of the report by Intervenors during July and August of 1960, six months before NUREG-0490 was issued.

The SAI-OES study is a conservative report in that it calculates its predictions and models ba~ed on site-specific data.

NUREG-0490 is not conservative and is inadequate because it is not sufficiently based on site-specific data.

The SAI-OES report used extensive site-specific data regarding the nearby population centers and the various weather conditions in Southern California.

That report identified several site-specific unique features which should have warranted a different conclusion from the NRC Staff than "there are no special or unique features about the Sen Onofre site and environe that would warrant special or additional engineered safety features for the San Onofre plants.*

Joint Intervenors conclude there are special and unique features that exist at the San onofre site which are listed as follows:

(l)

The three reactors at Sen Onofre are uniquely located near the intersection of two major Fault zones, the Cristianitos and the Newport-Inglewood.

Prior to l980, the NRC believed there was no structural relationship between the two Fault Zones.

However, in 1980, fede;al and state marine geologists discovered a new zone of faults which they named

  • cristianitos Zone of Deformation" which project directly beneath the three reactors.

Thus, the possibility of damage to the reactors during earthquakes is higher now because of the possibility of surface rupture directly under the reactors.

This was not factored into the Rasmussen Report, WASH-1400, the Lewis Report, SAI-OES or NUREG-0490.

NUREG-0490 does not even mention geologic-seismic site-specific events as a significantly possible factor in the probabilistic risk assessment.

(2)

The San Onofre site is uniquely located on the Pacific plate, near the Plate Tectonic Boundary Fault, the San Andreas.

San Onofre is moving north in relation to the North American Plate.

These reactors are uniquely migrating north on a geologic time scnle.

Plate Tectonics were not under-stood when the San Onofre site was originally chosen in 1962.

It was not until 1969 that the plate tectonics theories were accepted; (3)

The San Onofre site has the unique feature of baing sited close to San Onofre Unit 1.

If Unit l had a melt-down, it would sevenly effect operations of Units 2 and 3, resulting in various consequences, none of which were considered in NUREG-0490.

The older reactor at the site, San Onofre Unit 1,

-~

-~

c.n u:l was identified by the SAI-OES analysis as having the highest probability of a meltdown of any reactor in California for two primary reasons.

"The first reason is that the Unit One auxiliary feedwater system depends on operators to align and

~nitiate the system.

Potential failures due to human factors

~aka the system less reliable than automated systems.

The second reason relates the long term recirculation mode of emergency core coolant, which.requires at least one of two pumps located in the containment.

In the event of a pump failure, repairs cannot be made because the pump is inside the containment and would be isolated during an accident."

NUREG-0490 does not consider the proximity of SONGS

~ and 3 to Unit 1 to be a unique or special feature.

(4)

San Onofre Unit l has been shutdown for approxi-mately one year due to leaky corroded steam generator tubes.

The NRC issued a report in 1976 (NUREG-0900-5, Report to Congress an Abnormal Occurrences) which explained that "the failure of a number of steam generator tubes as a result of the pressure transients during a loss of coolant accident could render the emergency core cooling system ineffective."

The Unit 1 was not designed for the magnitude of ground motions that Units 2 and 3 were.

An earth-quake could conceivably only damage Unit 1, because of its struct-urally weak steam generator tubes, but that could result in a LOCA (loss of coolant accident) and a meltdown, which would affect the two other reactors and the environment.

(5)

The San Onofre reactors are special and unique in that the reactor core of Unit 2 was installed backwards, necessi-

-a-tating total rewiring of the control room and other systems.

(6)

The San Onofre site is unique also in that San Onofre Unit 2 was constructed above earthquake faults that were not discovered until 1974 during construction excavations.

(7)

SONGS 2 and 3 are underlain by dewatering cavities

'that developed during construction.

Intervenors believe this also is a special of unique feature at SONGS 2 and 3 which must be con:Sidered.

(8)

The Southern California region, including San Onofre, frequently has weather inversions.

During these inver~

sians, air pollutants, including accidentally leaked radioactive gases, can be trapped beneath the inversion layer, where they can only mix and travel horizontally.

Thus, a meltdown at SONGS 2 and 3 could affect the nine to ten million people who live in the air basins that share the same East ~acific high pressure zane inversion layers.

Although NUREG-0490 admits that "accident consequences are very much dependent on the weather conditions existing at the time * *

  • they do not specifically consider the unique Southern California high pressure inversion layers which are a predominant characteristic of the San Onofre site.

(9)

The San Onofre reactors are uniquely located on a southern California beach state park that stretches for many miles, but which is inaccessible and inescapable except by driving past the reactors on the old-highway, now running parallel to Interstate-S.

On a typical summer day, 25,000 persons drive close to the reactors an a narrow and curving road.

These beach-goers could be trapped during a meltdown, especially if an earthquake occurred at the same time or caused it.

(10)

Another unique or special feature of San Onofre is its proximity to roads used by thousands of uncontrolled travelers per day which presents a unique-possibility for sabotaqe accidents that could lead to releases of radioactivity.

(11)

The San Onofre site is special and unique in that one-half of the population of the State of California lives within 100 miles of the site.

(12)

It is a unique feature of SONGS 2 and 3 to be the larqest reactors ever considered for operating licenses~

(13)

The San Onofre site is unique in that it is sited within* contamination distance of a major portion of the nation's fresh produce farms, especially in the winter months.

(14)

The San Onofre site is also unique in that it could cause international economic and environmental impacts by contamination of a significant part of Baja California's agricultural resources.

After the Kemeney Commission and the Rogovin Report were issued on Three Mile Island, the council on Environmental Quality wrote a letter to the Nuclear Regulatory commissioners on March 20, 1980.

The letter released the results of the CEQ review and critized the NRC's lack of compliance with NEPA laws in the ElS analyses of potential accidents at reactors.

The CEQ stated that the NRC's EIS discussions of *potential accidents and their environmental impacts was found to be largely perfunctory, remarkably standardized, and uninformative to the public.*

The CBQ also advised the NRC that "site specific treatment of data should be substituted for "'boilerplate' assessment of accident initiating events and potential impacts, and £IS's should be comprehensible to non-technical members of the public ***

  • Intervenors comment upon the fact that NOREG-0490 contains 29 pages of text with about 8 pages of site-specific information which is selective and slanted.

NEPA requires detailed statements of aspects of proposed action significantly affecting the quality of the human environment and Intervenors feel NOREG-0490 is inadequate in that it is"largely perfunctory, remarkably stan-dardized and uninformative to the public.*

NOREG-0490 is also inadequate in that it failed to consider earthquake induced core melt accidents.

While the Reactor Safety Study(RSS), WASH-1400, concluded that the probab-ility of core melt accidents in nuclear power plants from seismic events was insignificant compared to core melt probabilities from other accidents, recent assessment of the potential for earth-quake induced.core melt accidents suggests that the probability of such events may be significant when compared to core melt accidents from other causes considered by ass.

Intervenors contend that the seismic design basis for SONGS 2 and 3 is in-adequate and, therefore, consider it prudent to evaulate the potential for seismic-induced core melt accidents at SONGS 2 and 3 to establish if they may be significant factors.

The purpose of NOREG-0490 wae to identify and evaluate site-specific environmental impacts.

It does not evaulate the potential for seismic-induced core melt accidents and, therefore its probabilistic assessment of risk at SONGS 2 and 3 is inadequate.

~ -

NUREG-0490 is further inadequate and particularly misleading in its assessment of health affects avoidance (Section 7.1.1,4).

NUREG-0490 did not mention thyroid blocking in its assessment of health affects avoidance, relying only on restricti'on of contaminated property and foodstuffs.

or. Frank von Hipple in his testimony before the California State Legislature states:

The thyroid can be protected against absorbing radioiodine, however, if before the cloud arrives you take about one thousand times your ordinary daily iodine intake in the form of potassium iodide (the form of iodine present in iodized salt).

This will saturate the thyroid with ordinary iodide and reduce its ability to absord the radioactive iodide when it arrives.

This strategy was recommended in the American Physical Society's reactor safety study four years ago.

The Food and Drug Administration approved potassium iodide for emergency thyroid

'blocking' *** I would recommend that California do two things with regard to this thyroid protec-tion strategy*

1)

Develop a stockpile of potassium iodide in the appropriate dosage in either sealed foil wrapped pills or liquid solution.

This would not be costly.

Based on a 1972 study for the Defense Civil Preparedness Study, it appears that enough pills for the entire nation could be produced for a few million dollars.

2)

The more difficult part of the job would be to develop an effective distribution system.

If one waited until a cloud of radioiodine had been released before distributing the blocking chemical and informing the public of its use, one might well be too late.

(A week after the beginning of the crisis at Three Mile Island, the Pennsylvania state government refused to distribute the chemical to the population within 10 miles of the site -

despite the joint recommendation to do so from the Surgeon General, the Food and Drug Commissioner, and the Director of the National Institutes of Health who thought that sufficient warning time might not be available to protect this population in ease a release occurred.

On the other hand, if people were given potassium iodide to keep in their medicine cabinets along with asprin, it is likely that many would lose track of it pretty quickly.

Perhaps it should be attached by the local utility to household electricity meters and its presence announced in case of need.

The best strategy is obviously a problem well worth a study.

California could break some important ground here.**

~eetion 7.1.1.4. is particularly misleading in its statement that "radiation hazards in the environment tend to disappear by the natural process of radioactive pecay (but) can continue for a relatively long period of time -- months, years or ~

~** (emphasis added)

This misleading statement fails.. to note that some ratioactive wastes from nuclear accidents such as radioactive Strontium and Cesium can enter the food chain and remain a hazard for 1,000 years or more.

Other isotopes remain a hazard for 1 million years or more.

NUREG-0490, Section 7.1.3. entitled Mitigation of Accident Consequences is inadequate in that it fails to note that consequences could be reduced by retrofitting SONGS 2 and 3 with filtered venting systems to prevent accidental releases of radioactive gases.

NUREG-0490, Section 10 is misleading, inadequate and incomplete.

The Section contains three sentences with regard to its conclusions and Re-Evaluated Benefit-Cost Balance.

~his section should be expanded because the environmental risks of a Class 9 accident involve the entire region of Southern California, Norther Baja California, Mexico, and parts of Arizona, These regions could be permanently contaminated with'radiation following a coremelt ~t SONGS 2 and 3.

The risks involve the value of all real and personal property, both public and private in those regions.

The risks involve fatalities, latent cancer deaths and genetic damage.

The risks involve compensation to victims in the event of such accidents.

Section 10 of NUREG-0490 concludes that the environmental risks of Class 9 -

coremelt

~ccidents -

"does not change the results of the cost-benefit balance contained in the Draft Environmental Statement (Section 10)."

COHCLOSION NOREG-0490 concludes rtthat there are no special or unique features about the San Onofre site and environs that

~

would warrant special or additional engineered safety features for the San Onofre plants.*

Intervenors conclude there are unique characteristics at SONGS 2 and 3 that warrant additional engineered safety features especially in light of the unique earthquake hazard which could cause a coremelt accident and common-cause failure of essential safety systems at SONGS 2 and 3.

A future earthquake near the San Onofre site could be the common cause for failure of the coolinq systems "of all three reactors on the San Onofre site and all three of the spent fuel pools simultaneously.

This would be the woret case accident.that should be analyzed by the NRC and this analysis should be a part of a reviaed NUREG-0490. CERTiriCATE OF SERVICE I hereby certify that the JOINT INTERVENORS COMMENTS ON SUPPLEMENT TO DRAFT ENVIRONMENTAL STATEMENT RELATED TO OPERATION OF SAN ONOFRE NUCLEAR GENERATING STATIONS, UNITS 2 AND 3 (NUREG-0490) have been served on the following by deposit in the United States mail, first class, postage prepaid, this 9th day of March, 198lz Office of Nuclear Reactor Regulation u.s. Nuclear Regulatory Commission washington, D. c. 20555 Attention*

Director, Division of Licensing Executed on March 9, 1981 at San Diego, California.

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DARITY WESLE

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l_;ntcl/, c11 Coi.J c.e~N:eD SCJEJlJTlSTS 9 March 1981 Office of Nuclear Reactor Regulation u.s. Nuclear Regulatory Commission Washington, D.C.

20555 Attention:

Director, Division of Licensing

Dear People:

Re:

Supplement to the Draft Environmental Statement (NUREG-049o) related to the operat~on of San Onofre Nuclear Generating Station, units 2 arid 3 Herewith are some brief comments on the above Supplement, in response to your invitation.

We are pleased that the NRC has finally published a document providing a hint of the consequences of severe accidents at the San Onofre Station.

We consider, however, that this Supplement does not satisfy the intent of the Commission's Statement of Interim Policy of 13 June 1980 (Federal Register, 45, 40101}.

Nor does this Supplement provide the pUbl~c with Information sufficient to make a reasoned assessment of the risks of severe accidents at this plant.

You will recall that the Commission's Statement of Interim Policy followed a letter of 20 March 1980 from the Chairman of the Council on Environmental Quality (CEQ} to the Chairman of the NRC.

Included inthisletter was the statement:

"The results of our review of impact statements prepared by the NRC for nuclear power reactors are very disturbing.

The discussion in these statements of potential accidents and their en-vironmental impacts was found to be largely perfunctory, remarkably standardized, and unin-formative to the public.*

This supplement must be substantially revised and improved before it overcomes these CEQ criticisms.

For guidance during this process of revision and improvement, the NRC staff should consult the report "NRC's Environmental Analysis of Nuclear Accidents: Is It Adequate?", prepared for CEQ by the Environ-mental Law Institute (ELI} in February 1980.

A copy of this

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report was provided to the NRC with the CEQ Chairman's letter.

Part 5 of the ELI report recommends that the NRC should continue, with some substantial improvements, its previous practice of studying a selection of accident scenarios.

The ELI report recommends that this selection should be expanded to include "Class 9" accidents.

Section 7 (Environmental Impact of Postulated Accidents} of the san Onofre Draft Environmental Statement (dated November 1978} exemplifies this previous practice; it estimates radiation doses for a number of selected accidents in Classes 1 through 8.

This Supplement, however, merges nine release categories, weighted by assumed probabilities.

The results of this analysis are confusing for the public; one might suspect that this is by intention.

Each accident scenario should be considered alone.

For each scenario, the NRC should provide a clear account of:

(i} the nature of the postulated accident (ii} the estimated nature of the radioactive release (iii) the estimated nature of the environmental con-sequences of that release.

The Commission's Statement of Interim Policy directs:

" * *

  • approximately equal attention shall be given to the probability of occurrence of releases and to the probability of occurrence of the environ-mental consequences of those releases."

This Supplement does not satisfy the intent of that directive.

It merges these two probabilities although they are of quite different natures.

One might suspect that this approach is selected in order to persuade the public that severe con-sequences have extremely low probabilities. This form of analysis and presentation does not fulfill the NRC's obligation to accurately inform the public.

As the NRC staff should well know, probabilities in nuclear accident analysis fall into two distinct categories:

(i} probability of occurrence of release This category of probability concerns engineering estimates.

These are very difficult to make since there is a l~mited statistical base and much of the uncertainty relates to human behaviour.

t Office of Nuclear Reactor Regulation 9 March 1981 Page 3.

(ii) probability of occurrence of environmental conse£hences, g1ven a particular release T is<ategory of probability concerns factors such as wind speed and direction.

These factors can be estimated from a good statistical base.

The NRC staff should revise this Supplement so as to exhibit their estimates of these probabilities separately, within each accident scenario studied, The Commission's Statement of Interim Policy also directs:

".* *

  • consequences shall be characterized in terms of potential radiological exposures to individuals, to* population groups, and, where applicable, to biota.*

This Supplement does not fulfill the intent of that directive.

It provides very limited information on the geographical varia-tion of potential exposure.

More seriously, it provides essentially no information on the significance of exposure for different population groups.

As the NRC staff should well know, certain population groups (especially children and fetuses) are at greater risk for a given release.

The importance of revising this Supplement, so as to accurately inform the public, can be illustrated by two estimates which can be gleaned from the supplement itself:

(i) probability of occurrence of the "PWR2" core melt accident Th1s release is one of the most severe accidents considered in the Reactor Safety Study (WASH-1400) and this Supplement.

Table 7.1.4-2 of the Supplement estimates its probability as 7xlo-6 per reactor-year.

Section 7.1.4.2 concedes that this estimate could be low by a factor of 100.

One thus finds (assuming a reactor life of 30 years) that this Supplement admits that a "PWR2" accident could have a 4% probability of occurrence during 'the life of San Onofre Units 2 and 3.

(ii) potential for serious health effects Table 7.1.4-4 of this Supplement admits that a severe accident at San Onofre could lead to 130,000 acute fatalities, 300,000 subsequent fatal cancers, and 600,000 genetic effects.

Office of Nuclear Reactor Regulation 9 March 1981 Page 4.

In the light of the grave hazard shown by these estimates, the NRC has a clear duty to provide the public with more complete information than is contained in this Supplement.

Thank you for your attention.

GT:VN Sincerely, G.~~s;~

Gordon Thompson, Ph.D.

Staff Scientist

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.>. L'a :'14 ~ :J5 Project # DS-NRC-K06002-CA Frank J. Miraglia, Acting Chief Licensing Branch No. 3 Division of Licensing Nuclear Regulatory Commission Washington, D.C.

20555 Oear Mr. Miraglia:

The Environmental Protection Agency (EPA) has received and reviewed the Draft Supplement (DS) to the Draft Environ-mental Impact Statement (DEIS) for the project titled SAN ONOFRE NUCLEAR GENERATING STATION, UNITS 2 AND 3.

In our previous reviews of environmental documents dealing with Light water Reactors (LWR) EPA has consistently emphasized the need for a thorough evaluation of the environmental impacts from different LWR accident scenarios to include Class 9 accidents.

The discussion of the environmental and societal impacts of a core melt down accident included in the Supplement to the Draft Environ-mental Impact Statement for the San Onofre Nuclear Genera-ting Station, Units 2 and 3 is a step forward in this respect and, as a result, EPA applauds the Nuclear Regulatory Commission's (NRC) decision to prepare this Supplement.

The assessment of environmental impacts for severe acci-dents at the plant uses methodologies originally developed in the Reactor Safety Study (WASH-1460) and the Liquid Pathway Generic Study (NUREG-0440).

Because these two studies will be the cornerstones for similar assessments for other nuclear power plants environmental statements, we would refer NRC to EPA's original technical comments on these studies.

These comments can be found in "Reactor Safety Study (WASH-1400): A Review of the Final Report" and a letter from EPA's Office of Federal Activities to NRC dated February 8, 1977.

St03ZS0423 Our specific comments on the San Onofre Supplemental DEIS and generic comments are attached.

The EPA appreciates the opportunity to comment on this Draft Supplement.

Should the NRC choose to revise other sections of the EIS, EPA would like to review these documents.

If you have any questions regarding our comments, please contact Susan Sakaki, EIS Review Coordinator, at (415)556-7858.

Sincerely y~r~

J~~tr:~

Surveillance and Analy,.i.s Division Attachment

EPA Technical Comments on the Supplement to the Draft Environ-mental Statement Related to the Operation of the San Onofre Generating Station Units 2 and 3 (NUREG-0490)

General Comments The Final E!S for San Onofre Units 2 and 3 is dated March 1973.

This statement contains a Section 7, titled "Environmental Impact of Postulated Accidents.* It is not clear if the Supplement is to replace the original information or if the Supplement is supplemental. If this information is supplemental then we would suggest that the original Section 7 be revised to agree with the supplemental statements and data.

It would also be hopeo that any previous information and con-clusions would be revised if it is impacted by events occur-ring since 1973 or by a change in COmmission consideration.

For instance the supplement refers to the original Section 5.~

and further mentions 10 CFR Part 20 and 10 CFR Part SO.

However, the supplement does not make any mention of the Commission's implementation of 40 CFR 190 for normal operation.

Specific comments Table 7.1.4-4 This table should correspond on a one-to-one basis with the release categories (PWR 1-9) in Table 7.1.4-2. It is also not readily apparent how the PWR 1-9 compares to the original Table 7.1.

Design Basis Accidents In the discussion of accident risk and impact assessment of Design Basis Accidents (OBAs), Section 7.1.4.1, we do not understand the intent of the comparison of the results in Table 7.1.4-1 to the Reactor Site Criteria of 10 CFR 100. First, the infrequent accidents listed in Table 7.1.4-1 do not meet the requirements of 10 CFR 100 for purposes of site analysis. Footnotes to 10 CFR 100 state:

(l} *** calculations should be based upon a major accident, hypothesized for the purposes of site analysis *** that would result in potential hazards not exceeded by those from any accident considered credible, and (2) *** this 25 rem whole body value and the 300 rem thyroid value have been set forth as reference values, which can be used in the evaluation of reactor sites with respect to potential reactor accidents of exceedingly low probability of occurrence, and low risk of public exposure to radiation.

Secondly, by the description of infrequent accidents in the supplement ("events that might occur once during the lifetime of the plant"), these accidents have an annual probability of occurrences on the order of lo-2, are considered credible, and are not of exceedingly low probability of occurrence.

Reference to 10 CFR 100 and its implementation provide a misleading inference that, since the results shown in Table 7.1.4-1 are within the dose values of 10 CFR 100, the risk of those infrequent accidents is small and therefore acceptable.

Also, the radiation doses listed in Table 7.1.4-1 are calculated using a conservative model approach which is relevant to safety evaluations and not consistent with the realistic approach to the assessment of environmental risks of normal operation and severe core melt accidents.

The discussion of impacts of infrequent accidents and limiting faults, in both the original DES and the Supplement, addresses probabilities of occurrence qualitatively *.

Yet, in the discussion of the more severe core melt accidents the probabilities of occurrence are quantified (Table 7.1.4-2).

For consistency in the pre-sentation of all envi~onmental risks, the probabilities of occurrence of infrequent accidents and limiting faults DBA's should also be provided.

It is not clear wheth~r the risks listed in Table 7.1.4-5, Annual Average Values of Environmental Risks Due to Acc~dents, Include those from infrequent accidents and l~m~tlng faults (Table 7.1.4-2), postulated accidents (Table 7.2 of the original DES), and accidents leading to the PWR 1-9 release categories (Table 7.1.4-2).

The risks should include all those from moderate frequency accidents, infrequent accidents, limiting faults and severe core melt accidents.

Although the risk of the infrequent accidents and limiting faults is "judged to be extremely small" and appear to be overshadowed by the risk from core melt accidents, they should be fully presented.

The risks from the more probable yet lower consequence accidents may indeed be significant to the individual risk and should be listed in the Supplement. It would also be beneficial to extend Figures 7.1.4-3, 7.1.4-5, and 7.1.4-7 to include the higher probability accidents.

It would be helpful to provide a summary table of the annual average value of environmental risks from operation of all the reactors at the San Onofre site. The risks

~

should include all those from normal operations, moderate frequency accidents, infrequent accidents, limiting faults and severe core melt accidents.

Both societal and individual risks should be presented.

7.1.1.3 Health Effects The statement that a dose greater than about 25 rem is necessary before any physiological effects to an individual are clinically detectable should be reviewed.

Information contained in a World Health Organization technical report No. 123 would seem to indicate that physiological changes can occur at exposures as low as 10 rem.

7.1. 3. 3 Emer9enc~v Preparedn~

It is unclear what is the basis of the statement, "Emergency preparedness plans including protective action measures for the San Onofre facility and environs are in an advanced, but not yet fully completed stage."

The plans (seven) are at this date undergoing informal review by the Region IX Regional Assistance Committee (RAC).

Thus, there has been no request for formal review, there has been no drill schedule established and there has been no full scale exercise.

We do not concur in the Commission's statement that these plans are in an advanced stage.

Table 7. L 4-5 It is not clear from the information presented regarding risk and protective action that protective actions can be taken to reduce exposures by 10-20 times or in fact to prevent exposures determined by the State of California to be unacceptable considering the following:

1. The emergency preparedness plans and protective action measures for the San Onofre facility are r.ot yet complete.
2. The State of california does not use the EPA's Protective Action Guides (PAG's).

In view of the above, we feel the statements made are premature.

Figure 7.1.4-8 This figure, "Relative Directional Risk to Individuals,"

might be a useful risk analysis.

However, as presented, the figure is illegible and lacking in background infor-mation. It should be presented more clearly, with an accompanying table or coding explaining the significance of the numbers.

Decommissioning The cost of reactor decommissioning and replacement power costs are as large as the costs from the Three Mile Island accident. It would seem that these costs could significantly change the cost-benefit information originally provided in Section 13.

Future EIS's or Supplements to EIS's should include an evaluation of these costs.

~

San Diego ASSOCIATION OF GOVERNMENTS Suite 524. Security Pacific Plata 1200 Third AWDUO San Diego. C.lifornia 92101 17141236-5300 Mr. Dino c. Scaletti San Onofre Project Manager Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Ccmnission Washington, OC 20555

Dear Mr. Scaletti:

Much 19, 1981 On March 16, 1981, the Board of Directors of the San !'lie.;o Association oi Governments (SANDAG) adopted a resolution supporting :he operation of San Onofre Nuclear Power Plant Units 2 and 3 and requested the Nuclear Regulatory C011111i:;sion to grant an operating license for :hese units sub-ject to federal regulations regarding thti safety of nuclJar p<'wcr plant operations and emergency planning for nuclear power plant nccidcnts.

This resolution and the *supporting staff report are attached.

Please call me or have your staff call Steve Sachs of my staff if you have any questions_ about the Board of Directors action.

~

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Executive Director RJH/SS/sc Attachments cc:

Patricia Fleming, SDG&E Fred Massey, SCE t.1EMl~!*t- ***.a:r:lt"!i.t.*l**.. *

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Swllllcjfn A.".*;o('J.\\TI0:-1 01' (rtl\\'F.RX~IE:-1'11' RESOLUTION RESOWl'I(:N SUPFOR!'Dl> '!HE Ol'ERATICtl or SAN CNOf'RE NUCIE.AA FI:M:R I?IAilT UNITS 2 AND 3 SUBJECT ro rEDERAL Rml!ATIOOS Rroi\\RDDX> 'niE SAfl:I'Y or NUCu:AA Po:l\\'ER PIAtlT OPEAATICtlS AND D1ERGElCY PIJ\\N!l!tx:i roR NOCIE.AA l'W.'T ACCIDE!ll'S No.

a1-as Wll!:RFAS, the Ene!:<JY 2()00 Task Force, aP!Xlinted b!' Mayor Wilson of the City of ~

Diego, presented the conclusions and J.ea:r.tnendations of its ref(lrt to the S!;NIY;G Board 'of Directors on Februat y 23, *1981; and Wll!:RFAS,.one of the reo:rmendations of the Energ; 2000 Task force is to SIJP!Xlrt the CO!q)letion and. q;eration of San Onof1*e Plants 2 and 3; ami Wll!:RFAS, San Onofre Units 2 and 3, if o::rnplete<'l and operated on schedule, will supply awroximately half of the addition< 1 electric:ty need£ forecast for the San Diego region between now and 1995; and WHERFAS, the Nuclear Regulatory Carmission will begin licensing hearings for San Onofre Units 2 and 3 in June 1981; and Wll!:RFAS, federal regulations ooncerning nuclear I :JWer plant safety and emergency reSf(lnse.planning will have to be Jret in 01 3e:r for a hcen:;,:,

to be' granted; N:W 'lHEREroRE BE IT RESOLVED that the Board of Directors SIJP!Xltlts the q;eratioi1 of San Q-lofre Nuclear Power Plant Units 2 and 3 and rec)\\.*f;ts the Nuclear Regulatory Carmission to grant an q;erating license for tiler.e units subject to federal regulations regarding the safety of nuclear p::~r plant O!X'ra-*

tions and emergency planning for nuclear plant accidents.

PASSED AND AllOPTfD this 16th day of March 1981.

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ATIEST:.

SECRE RY

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AiflMI\\N MEMBER AGENCIES: Cilift of Carlsbad. Chula Vista. Coron.acfn. 0..1 Mu. El Ctinn.lmf'll"ro11 ~.. ",.... t 11._.* *

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SAN DIEGO ASSOClATJO::\\ OF 00\\'ER!\\l\\lE!\\'TS RESOLtrriO:-\\ 110. _ __,::8:.;1_-3:..:6:._._ ___ _

DATE CU~SIDERED:

3/16/81 AGENCY YES NO ABSEl\\T ABSTAI:\\

I ' j CARI.SBAD X

OllilA VlSTA X

J OJROI\\AOO X

I DEL MAR X

EL CAJON X

IMPERIAL BEAOl X

LA MESA X

IDOl': GROVE.

X NATIONAL CITY X

OCEANSIDE X

SAN DIEm X

SAN MARCOS X

SANTEE X

VISTA X

I TOTAlS 13 1

I J certify from personal observation and count that the above results ar~ an accurBt~

record of the SANDAG Board of Directors vote and action.

San Diego Association of Governments BOARD OF DIRECTORS DATE:

March 16, 1981 AGENDA REPORT No.:

CCl<SIDEMTION OF SUProRT FOR OP£AATIOO OF SAN OOOFRE: NUCLPJ\\R J:aoi£R PLAN!' l.JNITS 2 AND 3 Intt"OOuction R-95 The Board requested this report as the basis for oonsidet*in<J a n;,,<>J.,ticn to support the operation of San Onofre Nuclear R:>wet Plant ll:1its ~ '"*,, 1 l.

Three iJnj:Xlrtant j:Xlints the Board should <.:onsitler before takinq a P'*"' it **.,.

are:

The risks to health and life of both pre&mt ancl future \\JC'I.*~rat ;,,,,,

and the costs of reducing these risks as~ociatcd with almo~t all aspects of the nuclear fuel cycle, ate extre*cly contrcJVersi.:ll.

There is little scientific or technical consensu. on the severity of the risks and the effectiveness or col't of st: Ategies tn redw~**

these risks.

San Onofre Units 2 and 3 would provide 440 M\\'1 of e.\\ect.ric [.Qo'el' to the San Diego region - almost one-half of lh**,)(J;litionill pow*!!

requirments forecast to be needed between now <~nd l!/95 foi: Lhe Srx;&E Service Area by Srx;&P. and the Calif<>rnia P.r'Cr<JY Cnrmi::sion.

These forecasts include the effects of exi.~;tinq "'ns~rviltio11 and alternative energy source pcograms which will t:educe electricity demand.

Potential additional electricity supplhs and <.'Ons"rvati(*n and alternative energy sources which could result in a bala'1*~e be-tween demand and supply over the next lD to 20 y<>~rs without San Onofre Units 2 and 3 have been identified (see at tachmcnt for a par-tial list) but are not yet corrrnittcd.

In sane c; """' tl:esr r<l<Jn'""

may be infeasible or unavailable.

The construction of '>an Onofre Units 2 and 3 iG **:'ilrlnq romletion.

About one-half of the total $3.4 billion project.*':] c:--,n,;trur~t ion cost has been expende<'l.

The plant is cun:ently t;\\1C:l<Yt:g<Jing t'.S *. Nucle.oc Regulatory O::mnission review in order to obtain,,, O[le!ciltinq license.

It is my RECOMMENI:li\\TION that the Board of Directors support tile operation of &-,n Jnofrr, Nuc:l ""'

Power Plants 2 and 3 and request the Nuclear Requl'ltory c,mnission to grant an operating lic'lnse tor these units suo)ect: t:o f<x1eral n*n!l ltions regarding the safety of nuc!eilr pa.*;er p!ant operatwns ""d one* *.Jen, y planning for nuclear plant accidents.

~

Discussion San 01ofre Units 2 and 3 are scheduled to have a total c..1pacity of 2, 200 megawatts (lfi) of electricity. SrG&E is a 20% partner in the pl<il.

is therefore entitled to 440 lfi of the electricity generated. '!he otl.<:c l, 760. l<ti is scheduled to be used by Southerri California Edison Ccr.*peny (76%) and Municipal utilities servi11.9 the Cities *of Anaheim and Riversicle (total of 4U *

'!he !bclear Regulatocy Camlission (NRC) is the federal agency responsible for issui11.9 nuclear*~ plant operati11.9 licenses. '!he Nf<C ~*ill hold hearings on the license applications for san 01ofre Units 2 and 3 st<Jrting in June 1981.

'!here are many environmental and econcmic issues relilttld tx> tJ e opcriltiun of san 01ofre Units 2 and 3 which include:

Cost and reliability of nuclear pc::r.~er Risk of accidents fran. transport of uranilttl, <:oent nuclear fuel and operation of the plants.

Cost of decommissioning the plants.

Ability of the plants to withstand earthquakes.

Hazards, cost and technical feasibility of long- :etm stora~c

  • of radioactive wastes.

Scope and aiequacy of emergency plans to reduce i."adiatlon <'x-posure i~ the event of an accident.

At the licensing hearings iri June, it aPrkars that th£' most controversial issues will be the ahility of the plants to withstand cm*thqun1:,.:; '""' tb*

adequacy of emergency planning in case of an *accident that coulci imnecL surroundil1.9 areas. '!he Plant must meet federal standard.' in both of these areas before a license will be issued.

~

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.\\S.-;1 K"I.\\HO\\ (II' RESOLUTION

(;0\\"EH:I:MEXTli RESOUJrlCN SUProR'l'lM:; WE OPERATIOO OF SAN CNOFnE NOCIZAR ECMER. l?U\\m' UNITS* 2 AND 3 SUBJECT TO FtttRAL REXm.I\\TICNS ROOI\\RDING THE SAFETY OF NUCIZAR roiEil. PU\\m' Ol?ERA'!'ICtlS AND

  • et-IE:RGENCY*PU\\NIII!l; ~"OR NOCLEAR PU\\NT l\\CCir:mTS No.

Bl-36 WllERE:AS, the Energy 2000 Task Force, appointed b:

  • Mayor Wil mn of the City of san Diego, presented the conclusions und lecmrncndati.ons of its report to the SANI:\\1\\.G Board of Directors on Februa1 y 23, 1981; and WllEilEAS, one of the t'eOO'I!lendations of the Enet"'Jy 2000 *Task l'or<:e is to support ~

<nnpletion ancl operation of San Onofre Plant!* 2 a"l 3; ""

WHE:RFJIS, San Onofre Units 2 ant'! :r, if canpl.:lte<i <*n*l opc*rat.<.'<l on schedule, will supply approximately half of the aclditional (*lcddcity ""L'I'l forecast *tor. the San Diego region between ro.~ ancl 1995; and

  • WilEilEAS, the Nuclear Regulatory Catmission will begin licensing hearil1.9s £or-San Onofre Units 2 and 3 in* June 1981; and WHE!lF.AS, federal regulations concerning nuclear po11er plant :;afety*

and emergency response planning will have to be met in ot :Jc*r for a licen:-..e to be granted; !Oi' 'lHEREFORE BE IT RESOLVED that the Board of Directo'!:s supper. ::s th<: nper-1tion of san Onofre Nuclear ~r Plant Units 2 and 3 ""d re<]\\U:"<_ts the Nm:l*~r Regulatm:y Catmission to gr<mt an operating licc;lSe for ~~'"" units uhj<.*ct to federal regulations regaming the safety of nltclear prii*m* plant n~r.;

tions and emergency plannfn9 for nuclear plant accidents.

PASSED AND l!OOPl'ID this 16th day of M3rch 1981.

ATTEST; SECRETARY CIIAIRMIIN l!.Qt.llBAGENCIES..:....Ci.bt:S....o~~~~;-Dt~"EtCtjon,lffl(WttJI su,.h, La Ni~*~.~. (triuail"Gtn~X~,f'latlnnal CTtv. Ot1!<W'>ad~.

-~ D$t00. San Marca, SaPllt and \\/tata/Cx-olltC"tO Mtmblt. Cllifnrnia ~rtmttll of frantf)(WQttntllt~u*.,. Mtmh" lll'*'l. 8. Cf !'I

A'lTACDIErn' (Fran Energy 2000 Task Force 11eport) 5a.JRCE; Potential Supply Alternatives For thf' SOO&E Service Area*

1980-2000 San <Xtofre 2 and 3 Arizona (renelled contract)

New llexl co (renewed contract)

Washington (ren~0 contract)

Mexiro (purchase)

Geothenna.l Blythe site Hydroelectric O:lgenerat.ion lnnd 440 MW (nuclear) 400 M\\1' (imported) 150 Mil' (in{)Orted) 100 MW ( in!pOrt.ed:

300 Mil' (imported) 800 lfil' (geothenn< 1) 1, 000 l!W (coal gasi fi caUon) 34 Mil' (hytlroeleC"tric) 100 Mil' (cogeneration)

TOJ'AL 30 Mil' (wind)

f,3541iW San Diego Gas and Electric Canpany, Septernbct* 1979
  • Sane of these sources may be infeasible or unavailable.

l"or cxampJ.>,

Arizona Public Service Canpany would have to agree to a* reneo.-Je<l cn:l-tract for 400 1-&1 of importP.d power fran Arizona; tl1e fe.. sibility of lODO megawatts fran a coal gasitication plant at Blythe ha:; i;nL been pwv<.vl.

y Southern California Edison Company

,. o aox eoo ZlAA WALNUT GPIOVt: AVtNUf "OSEMEAD CALifl'OIIINlA. 117'10 K. P. lASKlN March 24, 1981

"""""'att* 01" MUCt.l** C:NCliHIIC:IliHG, t**ITV, ANC L.ICCf<OSIWG Director, Office of Nuclear Reactor Regulation Attention: Darrel G. Eisenhut, Director Division of Licensing u.s. Nuclear Regulatory Conrnission Washington, D.C.

20555

Dear Sir:

Subject:

Docket Nos. 50-361 and 50-362 San Onofre Nuclear Generating Station Units 2 and 3

References:

Realistic Estimates of the Consequences of Nuclear Accidents, M. Levenson and F. Rahn, EPRI, November, 1980.

This letter provides Southern California Edison Company's cor.ments to the Sup~lement to Draft Environmental Statement related to the operation of San Ono re Nuclear Generating Station Units 2 and 3 RUREG-0490.

In our review of this document we have found two points whicn we feel are in need of further clarification prior to the issuance of a Final Environmental Statement.

1.

The following statement contained In Section 7.1.4.3, "The 200-rem whole-body dose figure corresponds approximately to a threshold value for which hospitalization would be indicated for the treatment of radiation injury. The 25-rem whole-body (which has been identified earlier as the lower lfm1t for a clinically observable phystolgical effect) and 300-rem thyroid figures correspond to the Conrnission's guideline values for reactor siting in 10 CFR Part 100."

requires clarification, to prevent the statement from being misconstrued to state that San Onofre does not meet the Conrnission siting guide11_qes of 10 CFR 100.

In order to clearly differentiate between the Class 9 accident and the design basis accidents used in the Conrnission siting criteria, specific clarification is needed.

The traditional Design Basis Accidents (DBA's) are hypothetical and conservative scenarios, evaluated in accordance with regulations and other regulatory guidance. which define the required assumptions and methodology.

In contrast, the Class 9 accident scenario is defined with no consideration of mitigation by engineered safety features, assumes highly conservative and consequence maximizing behavior of natural mitigation processes. Since the Class 9 acctdent uses much more conservative, unrealistic, assumptions, it. is not considered in the evaluation of reactor siting.

s1o:ssoos 32 Tll.ll... *O"'I lfiJIU:t*J~OI

~

0. 2.

Although uncertainties in probability calculations are discussed in Sections 7.1.4.2 and 7,1.4.7 of the Supplement, the uncertainties in the source terms, and hence the consequences of the accident, are not discussed in either Section 7.1.4.3 or 7.1.4.7, These radiation source terms have been shown to be conservative by experiments performed at RocKwell, karlsruke, Oak Ridge National Laboratory, General Electric (Aircraft Nuclear Propulsion Department), Bettis National laboratory, Hanford National Laboratory, and tests performed in the Idaho Reactor Test Site. The results of these tests and experiments, sulllll8rized in a paper by M. Levenson and F. Rahn ot the Electric Power Research Institute, indicate that natural processes are operating which prevent the release of radioactive nuclides from molten nuclear reactor fuel (Reference 1). Dr. Chauncey Starr, former President of the Electric Power Research Institute advised the Commission, at the Co~m~issions November 18, 1980 meeting in Washington, D.C., that, "The important issue is that the initial review of this subject appears to indicate that under any conceivable realistic circumstance, the real source term is likely to result in risk to the public that is less by factors of 10 to 100 than that which was previously estimated."

Using Dr. Starr's estimate of a realistic maximum release into the atmosphere would lower the consequences (acute fatalities and cancer deaths) from a Class 9 accident by 1 to 2 orders of magnitude.

The Final Environmental Statement for San Onofre Units 2 and 3 should be accurate, concise, and not leave room for misinterpretation. Where applicable, a11 sources of error, and the relative magnitude of error, should be indicated.

We hope that these cOIMients will help to make the FES for SONGS 2 and 3 such a document.

Very truly yours,

)I)? /1-L*

APPENDIX B NEPA POPULATION DOSE ASSESSMENT

Appendix 8 NEPA POPULATION DOSE ASSESSMENT Population dose commitments are calculated for all individuals living within 80 km (50 miles) of the facility employing the same models used for individual doses (see Regulatory Guide 1.109, in preparation).

In addition, population doses associated with the export of food crops produced within the 80-km region and the atmospheric and hydrospheric transport of the more mobile effluent species such as noble gases, tritium, and carbon-14 have been considered.

B.1 NOBLE GAS EFFLUENTS For locations within 80 km of the reactor facility, exposures to these effluents are calculated using the atmospheric dispersion models in Regulatory Guide 1.111 and the dose models described in Section 5.5 and Regulatory Guide 1.109.

Beyond 80 km and until the effluent reaches the northeastern corner of the. United States, it is assumed that all of the noble gases are dispersed uniformly in the lowest 1000 m (3280 ft) of the atmosphere.

Decay in transit was also considered.

Beyond this point, noble gases having a half-life greater than one year (e.g., Kr-85) were assumed to mix completely in the troposphere of the world with no removal mechanisms operating.

Transfer of tropospheric air between the northern and southern hemispheres, although inhibited by wind patterns in the equatorial region, is considered to yield a hemisphere average tropospheric residence time of about two years with respect to hemispheric mixing.

Since this time constant is quite short with respect to the expected mid-point of plant life (15 years), mixing in both hemispheres can be assumed for evaluations over the life of the nuclear facility.

This additional population dose commitment to the U.S.

population was also evaluated.

8.2 IODINES AND PARTICULATES RELEASED TO THE ATMOSPHERE Effluent nuclides in this category deposit onto the ground as the effluent moves downwind, which con-tinuously reduces the concentration remaining in the plume.

Within 80 km of the facility, the deposition model in Regulatory Guide 1.111 was used in conjunction with the dose models in Regulatory Guide 1.109.

Site-specific data concerning production, transport, and consumption of foods within 80 km of the reactor were used.

Beyond 80 km, the deposition model was extended until no effluent remained in the plume.

Excess food not consumed within the 80-km distance was accounted for, and additional food production and consumption representative of the eastern half of the country was assumed.

Doses obtained in this manner were then assumed to be received by the number of individuals living within the direction sector and distance described above.

The population density in this sector is taken to be representative of the eastern United States, which is about 410 persons per km2 (160 persons per mi 2).

(This approach is conservative for San Onofre because population densities in the western United States are considerably lower than those in the eastern portion.)

B.3 CARBON-14 AND TRITIUM RELEASED TO THE ATMOSPHERE Carbon-14 and tritium were assumed to disperse without deposition in the same manner as krypton-85 over land.

However, they do interact with an atmospheric residence time of 4 to 6 years with the oceans being the major sink.

From this, the equilibrium ratio of the carbon-14 to natural carbon in the atmosphere was determined.

This same ratio was then assumed to exist in man so that carbon-14 to natural carbon in the atmosphere was determined.

This same ratio was then assumed to exist in man so that the dose received by the entire population of the United States could be estimated.

Tritium was assumed to mix uniformly in the world's hydrosphere, which was assumed to include all the water in the atmosphere and in the upper 70 m (230ft) of the oceans.

With the model, the equilibrium ratio of tritium to hydrogen in the environment can be calculated.

The same ratio was assumed to exist in man, and was used to calculate the population dose, in the same manner as with carbon-14.

8.4 LIQUID EFFLUENTS Concentrations of effluents in the receiving water within 80 km of the facility were calculated in the same manner as described above for the Appendix I calculations.

No depletion of the nuclides present in the receiving water by deposition on the bottom of the Pacific Ocean was assumed.

It was also assumed that aquatic biota concentrate radioactivity in the same manner as was assumed for the Appendix I B-1

B-2 evaluation.

However, food consumption values appropriate for the average individual, rather than for the maximum, were used.

It was assumed that all of the sport and commercial fish and shellfish caught within the 80-km area were eaten by the U.S. population.

Beyond 80 km, it was assumed that all of the liquid effluent nuclides except tritium have deposited on the sediments so they make no further contribution to population exposures.

The tritium was assumed to mix uniformly in the world's hydrosphere and to result in an exposure to the U.S. population in the same manner as discussed for tritium in gaseous effluents.

APPENDIX C EXPLANATION AND REFERENCES FOR BENEFIT-COST

SUMMARY

Appendix C EXPLANATION AND REFERENCES FOR BENEFIT-COST

SUMMARY

C.l ECONOMIC IMPACT OF STATION OPERATION C.l. 1 Direct benefits C. 1. 1.1 Energy 2114 MWe x 1000 kW/MW x 365 days x 24 hr/day x capacity factor (0.5 or 0.7). This product ranges from 9.3 x 109 kWhr/year (0.5 capacity factor) to 13.0 x 109 kWhr/year (0.7 capacity factor).

C.l. 1.2 Reduced regional oil consumption Section 8.3.1 shows that the applicants primarily have oil/gas fired units, which would have to be operated to a greater extent if SONGS 2 & 3 are not operated.

The additional fuel oil consump-tion (assuming a 50% capacity factor for the nuclear units) is calculated as follows:

9.3 x 109 kWhr

  • 9,000 Btu/kWhr
  • 1 bbl oil = 13.2 x 106 bbl oil.

6.29 X 106 Btu C.1.2 Economic costs C. 1.2.1 Fuel From Sect. 8.3.1, the staff's estimate of fuel cost is $10.8 per megawatt-hour in 1983.

Assuming a 60% capacity factor or 11.1 x 106 MWhr/yr gives the value in Table 10.1.

C.l.2.2 Operating and maintenance Using the staff's OMCST computer code, operating and maintenance costs are estimated to be 4.05 mills/kWhr at 60% capacity, which multiplied by 11.1 x 109 kWhr/year gives the values in Table 10.1.

Decommissioning:

Based on estimates given in Sect. 9.4, the cost of decommissioning each unit will be $66.7 million in 1978 dollars or $85.4 million in 1980 dollars at the end of the useful life of the plant. If this value is discounted from 2013 to 1983, then annualized over a 30-year life assuming a real interest and discount rate of 4.76%, and then multiplied by 2 units, the value in Table 10.1 is obtained.

C-1

APPENDIX D CULTURAL RESOURCES

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