ML18017A251

Forwards Comments on Suppl 2 to Des.Analysis Makes Several Assumptions Which Overstate Impacts of Events Being Considered

ML18017A251
Person / Time
Site:	Susquehanna
Issue date:	05/26/1981
From:	Curtis N PENNSYLVANIA POWER & LIGHT CO.
To:	Youngblood B Office of Nuclear Reactor Regulation
References
RTR-NUREG-0564, RTR-NUREG-564 PLA-818, NUDOCS 8105280266
Download: ML18017A251 (184)

Text

TWO NORTH NINTH STREET, ALLENTOWN, PA. 18101 PHONE: (21$ ) 82 I.$ 151 NORMAN W. CURTIS Vice President Entpneereg 8 ConsrrUcten 821-SSSI May 26, 1981 r

Mr. B. J. Youngblood, Chief Licensing Branch No. 1 U.S. Nuclear Regulatory Commission Washington, D.C. 20555 SUSQUEf&NNA STEAM ELECTRIC STATION COMMENTS ON SUPPLEMENT 2 OF DRAFT ENVIRONMENTAL STATEMENT ER 100450 FILE 991-2 PLA-818

Dear Mr. Youngblood:

Attached are PP6Lts comments on Supplement 2 of the Draft Environmental Statement.

Very truly yours, g,vd N. W . Curt xs Vice President-Engineering 6 Construction-Nuclear DPM/mjm 6-81 8yosgsSgg44 Q PENNSYLVANIA POWER 4'IOHT COIAPANY

Applicants have reviewed Supplement No. 2 to the Draft Environmental Statement related to the operation of the Susquehanna Steam Electric Station Units 1 and 2 (NUREG-0564) and in general concur with the Staff's analyses, evaluations, and conclusions.

Applicants believe the Supplement meets the intent 'of the Commis-sion's statement of interim policy regarding accident considerations and agree with the Staff's conclusion that while the environmental impacts of the. accidents considered may be severe, the likelihood of their occurrence is remote. Therefore, the conclusions reached in the Draft Environmental Statement should remain unchanged.

Applicants -do have the following specific comments on Supplement No. 2.

A) The Staff's analysis makes several assumptions which tend to overstate the impacts of the events being considered.

l. 7-Day Ground Dose Assumption Page 6-12 of Supplement No. 2 contains the following statement:

The RSS consequence model also contains a provision for incorporating the consequence reduction benefits of evacuation and other protective actions. Except as otherwise indicated below, the results shown for Susquehanna do not include this provision.

With respect to this aspect of the calcula-tions, therefore, the results are "worst case" estimates. The model does, however, provide for relocation of persons to avoid prolonged exposure to ground contamination. Unless otherwise specified, the calculations for Susquehanna incorporate this provision fog re-location following seven days of exposure.

. This "seven days of exposure" refers to irradiation from fission products deposited on the ground following a pos-tulated core-melt accident. It is extremely conservative to assume the population would remain in place and be exposed to this radiation for as long as seven days. This over-conservatism is particularly great for early health effects, such as acute fatalities. The results of the Reactor Safety Study (RSS)~ ) show that in the highly unlikely event of accidental releases of large amounts of radioactivity, the incidence of acute.gatalities in,the population is dominated by the radiation dose from deposited gamma-emitters.~ ) It "

is therefore particularly important to try to make a more 6-82

realistic estimate of the magnitude of this dose, taking into account what can reasonably be expected by way of protective actions such as evacuation. The Staff recognizes this, since it refers to the results as being "worst case" and includes calculations which incorporate a model for early evacuation as indicated in Table 6.1.4-5. The use of the seven-day ground dose in Supplement No. 2 results in the prediction of unwarra'ntedly large consequences and conveys an incorrect impression of the risk of reactor accidents.

Realistic values should be presented as the main re-sults of the report. Table 6.1.4-5 shows that the use of realistic protective actions reduces the predicted. annual average values of.'public risk due to population exposure or to latent cancer fatalities by a factor of between five and twelve. The risk due to, early- fatalities is similarly reduced by,, a factor~ of about thirty. Figure 6.1.4-4 marked reduction in acute fatalities which realistic protective means are assumed. However,results shows'he when most of the data in Supplement No. 2 does not reflect realistic protective actions 'and is therefore overly conservative.

(See figures 6.1.4-2, 6.1.4-3, 6.1.4-5, 6.1.4-7, 6.1.4-8.)

The plot of isopleths in Fig. 6.1.4-7 and Fig. 6-1.4-8 by incorporating the 7-day ground dose assumption gives a misleading impression of how far downwind acute fatalities might be expected to occur following a reactor accident.*

2~ Comments on the Use of CRAC It is Applicants'nderstanding that the version of the CRAG (Calculation of Reactor Accident Consequences) computer code used in the preparation of Supplement No. 2 was essen-tially the same as that used for the preparation of the RSS.

A significant difference was the incorporation of an evacuation model, recently developed at Labora-tories(3). Although, this model representsSandia an improvement over that used in the RSS, there are other modifications which could be incorporated into CRAG. These have been in recent studies such as that of the Limerick BWR(4). Applicants believe the omission of these modifi-

~ Ag L'escribed cations is another significant source of conservatism-Examples of these conservative elements include:

Applicants al'so have reservations about the meaningfulness of isopleths of individual risk at the 10 10 or 10 1 per year level.

At this vanishingly small probability level (one in 10 billion or one in 100 billion per year), these values have little meaning.

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(a) Plume Width The width of the plume in the dispersion model used in the RSS and in Supplement No. 2 is hxsed upon releases of radioactive material for only three minutes duration; that is, the formulae used for calculating the plume width are phenomen-ological fits .to data taken in experiments in which the duration of release was about three minutes. In practice, the shortest release duration considered in the RSS and Supplement No.

2 was thirty minutes. It is a well-known characteristic of dispersing plumes that, roughly speaking, their average width is an increasing function of the duration of cloud passage.(l) If plume widths for a thirty-minute release are used, predicted plume center line concentrations are reduced by a factor of about two. Radiation doses are also reduced by the same factor.'he pre-dicted effect on the number of acute fatalities depends upon the population distribution around the reactor, but should be a reduction by at'least a factor of two.

(b) Shielding Factors The CRAG analysis incorporates shielding factors for people assumed to be sheltered from gamma-rays emitted by deposited fission products. In the RSS and presumably Supplement No. 2, a shielding factor of 0.3 was used. In the Limerick Study(

the shielding factor was estimated by considering the. shielding provided by typical houses found in Pennsylvania. Since brick houses with basements are common there, with excellent shielding charac-teristics, a more realistic shielding factor of 0.15 was deduced. Since the accumulated ground dose is the dominant contributor to the radiation dose that is used in calculations of early fatalities, this shielding factor can lead to a substantial reduction in that dose.'-84

Taken together with the factor of two due to the change from a 3-minute to a 30-minute plume width, a reduction by a factor of 3-4 in predicted doses is possible. The corresponding reduction in the predicted number of early deaths may be even greater because of the thresholds in the early fatality dose-risk relationships. These consid-erations would suggest that a considerable reduction of the acute fatality probability distdibutions shown on Figure 6.1.4-4 is possible with appropriate changes in CRAG. Consequently, the results as shown are conservative and over-state the risk.

B) Table 6.1.4-1 provides a list of some Design Basis Accidents. The indicated frequency categories for these accidents are not consistent with previous NRC documents. This table implies that these accidents were included in the design basis as Infrequent Accidents, when in fact they have been considered as Limiting Faults based on the acceptance criteria contained in the Standard Review Plan.

C) On pages 6-8 in Section 6.1.3.2, the fourth paragraph states that only one industrial plant, the Luzerne Outerwear Company, is located within the LPZ. Last summer, CAR-MAR moved into an industrial park which is also within the LPR. CAR-MAR employs Pg'L(~

approximately 70 people. This industrial park is located in Sector 10 approximately 1.7 miles from the site.

D) On page 6-16, the second paragraph in Section 6.1.4e5 states that there are no wells between the plant and the river via the northern bedrock valley pathway. While this statement is correct in terms of pathways for exposure to'he public, there are five wells P PAL) located on Applicants'roperty in the area in question. In the unlikely event of an accident involving releases to groundwater, these wells would not be used.

6-85

REFERENCES:

1. Reactor Safety Study, WASH-1400 (NUREG 75/014), 1975.

2. Wall, I.B. Yaniv, S'.S., Blond, R.M., et al, "Overview of the Reactor Safety Study." Paper presented at the International Conference of Nuclear Systems Reliability Engineering and Risk Assessment, Gatlinburg, Tennessee, June 19-25, (1977).

3. Aldrich, D.C., Blond, R.M. and Jones, R.B., "A Model of Public

'Evacuation for Atmospheric Radiological Releases", Sandia Laboratories Report SAND, 78-0092 (1978).

4. Probabilistic Risk Assessment,'imerick Generating Station, Philadelphia Electric Company, Docket Nos. 50-352 and 50-353, (March, 1981).

6-86

-PPKL(Al)

Analyses and text now presented in FES are different from those in the DES Supp. No. 2.

Regarding use of individual risk at 10 0 or 10-"1 levels per reactor-year in the isopleths, these levels are not meaningless when there would be distribution of several million per'sons in the regio'ns spanned by these isopleths. Societal risk from those regions would be in the range of 10-4

<<10 cases per reactor year - as directly derived by multiplying the individual risks and the number of persons in the regions.

-PPKL(A2)

The staff has not completed the review of the accident consequence calculati'ons in the Limerick Risk Analysis Study referenced in the comment.

However, the licensing staff is in the process of reviewing the recent changes made to the CRAC code used at the Sandia National Laboratories and the staff will incorporate any appropriate and qualified changes into the version of CRAG currently used in licensing actions.

-PPKL(B)

See minor text change in the se'cond paragraph of Section 6.1.4.1 Desicen Basis Accidents.

-PP&L(C )

The staff has recently learned of this industrial activity near the site. The staff is requesting additional information from the applicant regarding CAR-MAR activities, as well as anticipated plans for the industrial park, and will provide an evaluation in a forthcoming supplement to the Safety Evaluation Report.

-P P/LI D)

The staff has corrected the statment to indicate that there are no offsite wells that could be encountered via the northern bedrock valley pathway.

6-87

0

7. NEED FOR PLANT AND ALTERNATIVES TO THE PROPOSED ACTION 7.1 RfSUMP When the FES-CP was issued in June 1973, the applicant, Pennsylvania Power & Light Co., sched-uled operation of the Susquehanna Steam Electric Station, Units 1 and 2, to begin operation in 1981 and 1982, respectively. In 1973, need for the plant was projected to occur between 1978 and 1982 in order to meet the projected annual energy demand increase of 7.2X. Since 1973, the oil embargo and rising electricity costs have led to a decline in growth of electrical energy and peak demands in the nation and in the PP&L service area. The PP&L service area demand for power did not continue to grow at the historical rates occurring prior to the 1973 Arab oil embargo. PP&L had projected 'a 1980 winter peak demand of 4970 MW, without UGI (Luzerne Electric Division of UGI Corp.), a 255 reduction from the 1973 forecast of 6600 MW. Construction has proceeded approximately on schedule with operation of Susquehanna Units 1 and 2 now scheduled for the second quarter of 1982 and the second quarter of 1983, respectively. Since 1973, Pp&L has agreed to sell a 10K share of both units to the Allegheny Electric Cooperative.

During the construction-permit stage, the staff analyzed alternative sites, plant designs, and methods of power generation, including the alternative of not adding production capacity. The staff concluded, based on its analysis of these alternatives, as well plant as on a cost-benefit analysis, that additional capacity was needed, that a nuclear-fueled would be an environ-of providing the capacity, and that SSES, Units 1 and 2, at a specified mentally acceptable means perspectives.

site and of a s'pecified design, were acceptable from both economic and environmental Since that time, construction of SSES has been nearly completed; and many of the economic and environmental costs associated with the construction of the station have already been incurred and must be viewed as "sunk costs" in any prospective assessment.

7.2 APPLICANT'S SERVICE AREA AND REGIONAL RELATIONSHIPS The PP&L service region is shown in Figure 8.1 of the FES-CP. The applicant supplies electric

'power to about 26,000 kmz in east central Pennsylvania (225 of the area of the state}. In 1973, the population of the service area was about 2.3 million (20Ã of the state total}, Major cities served by PP&L include Allentown, Bethlehem, Harrisburg, Hazelton, Lancaster, Scranton, Wilkes-Barre, and Williamsport.

Along with the following utilities, PP&L is a signee to the Pennsylvania-New Jersey-Maryland (PJM) Interconnection Agreement: Public Service Electric and Gas Co. (PS); Philadelphia Elec-tric Company (PE); Baltimore Gas and Electric Company (BC); General Public Utility (GPU), which consists of Jersey Central Power & Light Co'mpany (JC), Metropolitan Edison Company (ME), and Pennsylvania Electric Company (PN); Potomac Electric Power Company (PEPCO); Atlantic City Electric Company (AE); Delmarva Power & Light Company (DPL); and Luzerne Electric Division of UGI Corporation (UGI). These eleven companies, operating their transmission and generation facilities as a single system with free-flowing power interchange between companies, account

'or energy flow between companies and use after-the-fact accounting procedures. The agreement with PJM requires that PP&L meet its generation capacity obligation as a part of the PJM

,interconnection.

7.3 BENEFITS OF OPERATING THE PLANT SSES-1 and -2 are b'eing constructed for the purpose of assuring an adequate low cost supply of electrical energy for the needs of the PP&L and PJM service area needs. At the operating license stage, consideration of alternatives involves only the decision as to whether the plant should operate or not. This decision is based on a weighing of the benefits of operation against environmental impacts (including production costs). Potential benefits of operating Susquehanna 1 and 2 include reliability, diversity, and economic advantage.

7.3.1 0 eration of the PJM Interchan e One of the most important concepts of the PJM interconnection is its economic operation as a single system with centralized dispatch of generation and free-flowing power exchanges between 7-1

7-2 member companies. Transmission lines connecting the various PJM companies provide for the transfer of energy from one company to another as required to meet the loads of each company.

This allows for the full utilization of the resources of all companies to meet the customer loads of all companies most economically. Coordination is not restricted to the generation phase; it is also implemented in capacity, maintenance, and transmission planning.

Central dispatch of all PJH generating units is accomplished by providing the Interconnection Office, located at Valley Forge, PA, with the necessary data, control equipment, and computers to economically load all PJH units at levels needed to meet the PJH load. The Interconnection Office, a central coordinating office, is connected to all company dispatch centers (i.e.,

applicant's Allentown Power Control Center) via voice, digital and analog computers, and tele-typewriter circuits.

In order to meet a specific PJM load the Interconnection Office transmits to all companies the incremental cost, taken from the combined loading schedule, needed to provide generation at the required level. As the PJM load increases, higher incremental cost values are transmitted to the various companies and the level of generation is increased. Each company will raise or lower generation on its units according to the PJH incremental cost signal regardless of its own load requirement.

Occasionally, due to unit operating constraints, transmission limitations, or reliability con-siderations, units are operated at above the incremental cost level at either the company's or PJH's request, depending upon the circumstances.

Since some companies have a larger amount of less expensive generation, such as nuclear coal-fired uni,ts, .these companies may be generating at levels above their own load and as suchormay be supplying energy to other companies over the interconnected transmission lines. To provide a means of compensating for this exchange of energy between member companies, an accounting pro-cedure, based on the split-savings principle, is used.

The interchange accounting procedure used on PJH provides both the supplying companies (sellers) and the receiving companies (buyers) with a savings as a result of the energy transactions between them. The billing for each transaction is halfway between the cost incurred by the suppl'ying companies and the cost that would have been incurred by the receiving companies had they used their own higher-cost generation to meet their loads (split-savings principle).

7.3.2 Minimization of Production Costs In order to determine the potential economic advantage of operating SSES, the staff studied the cost associated with operation of SSES Units 1 and 2 and the projected cost of replacement electricity. The unit costs for fuel, operation and maintenance, and the projected source and its share of supply of replacement electricity provided by the applicant are shown in Table 7.1.

It appears that 75% of the replacement electricity would come from other members of the PJH interchange. Compared to other sources, the cost projections provided by the applicant are reasonable (Table 7.2). Based on the applicant's 90% share of SSES-1 and the unit's projected operation at 70K, the savings (in fuel and operation and maintenance costs) for the initial year of operation are estimated to be $ 64.5 million ($ 1980). Kowever, the applicant's assump-tion as to the capacity factor of the Susquehanna units during their initial years of operation is probably high (based on the experience of nuclear units in general).> If a lower capacity factor'were assumed, e.g., 50K to 60K, the savings per unit per year would be about $ 46 million to $ 55 million. However, the cost savings would not be confined only to the initial year of operation; the applicant would continue to save as long as SSES Units 1 and 2 were capable of operating, a period of about 30 years.

In 1980, the fuel cost for generating electricity from an oil-fired unit was 43.1 mills/kWh, which is higher than the applicant's projection (made in 1978) of 25 mills/kWh.z This is due to the rapid rise in the price that electric utilities paid for oil from 1978 to 1980. Kence, the savings to the applicant, using current cost of oil-fired generated electricity, would be

$ 100 million and $ 118 million per unit per year, respectively (assuming the units were operating at 605 and 70K capacity factor). If it is assumed that the replacement cost of electricity to Allegheny Electric Cooperative, Inc., which owns 10K undivided interest in SSES Units 1 and 2, is the same, the total savings from the operation of SSES would be $ 112 million per unit per year (assuming the units were operating at 60% capacity). In calculating the savings, it assumed that the quantity of electricity demanded would remain the same regardless of whether or was not SSES were operated.

'I The staff views the applicant's assessment of potential savings as reasonable to conservative (ER-OL, p. 1.1-4). The results could not be significantly altered if the demand for electricity grew at a lower rate than assumed; this is because the applicant's marginal energy source would continue to be oil. Thus, the staff concludes that economic considerations justify adding the Susquehanna facility in the scheduled time period.

b Table 7.1. Projected Type/Cost of Replacement Energy Associated with Applicant's Share of Susquehanna Unit 1 A licant PJH less a licant Susquehanna Combustion Combustion Nuclear Coal Oil Turbinec Coal Oil Turbinec Percent or replacement energy generated 15 10 30 40 Fuel cost (mills/kWh) 14 25 50 14 27 45 OEM costs (mills/kWh) 4 2 1 10 2 1 10 Total operating cost (mills/kWh) 12 16 26 60 16 28 55 Partial costs (million dollars) 73 13.9 15.0 27.8 64.9 15.9 Total costs (million dollars) 73 137.5 1980 dollars.

With a 70% unit capacity factor, applicant's 90$ share (945 HW) of Susquehanna Unit 1 would provide approximatelv 5794 GWh.

Does not reflect price increases due to events in the Hideast during 1979.

Due to rounding errors, column does not add up.

7-4 Table 7.2. A Relative Comparison of Projected Cost by PP&L, Comnonwealth Edison, and NRC (mills/kWh)

Nuclear Coal Oil PP&L 13 16 ,26 (in projected $ 1980)

CE 17 27 (in $ 1977)

NRC 10 16 (in projected $ 1980)

From Table 7.1, in 1980 dollars.

b In 1977 dollars. See Reference 3.

c Low-sulfur coal without scrubbers.

d Based on 1980 as first year of operation. See Reference 4.

7.3.3 Diversit of Su 1 Source 0

Regardless public of the relative utility to have economic advantage of nuclear or coal, it is to the advantage of a diverse sources of power available. In the event of the unavailability of imported oil, major strikes, frozen coal piles, enrichment facility shortages, or regulatory uncertainties, a reliance upon one primary fuel, especially for baseload operation, could cause cutbacks in power to the grid. Currently, all of PP&L's baseload units utilize coal or oil. As noted in Table 7.1, no baseload nuclear is available to PP&L's replacement power. With the Susquehanna nuclear station in operation, PP&L will be better prepared to meet unexpected changes in the supply of coal and oil. The fact that operation of SSES Units 1 and 2 will improve the diversity of generation supply for the applicant is an important factor in support of issuing an operating license.

7.3.4 Reliabilit Anal sis 7.3.4.1 PP&L Projections Table 7.3 presents the applicant's historical winter peak load and energy between 1966 and 1977 and the projected winter peak load and energy sales between 1978 and '1990. The growth rates for winter peak and energy sales for the'period 1966 to 1977 were 7.1% and 6.8%, respectively. The rates of increase of peak load and energy sales through the projected period 1978 to 1990 are 2.7X and 3.1$ , respectively.

7.3.4.2 PP&L Reserve Margin The PP&L reserve margin, with and without the Susquehanna facility, is presented in Table 7.4 for the period 1978 through 1985. Adjusted peak is defined to be "peak load plus sales minus purchases." Reserve is defined as "capacity minus adjusted peak," and reserve margin as "reserve divided by adjusted peak."

The rate of growth of peak demand and energy has been much smaller than anticipated during the planning for construction of Susquehanna. Consequently, the, reserve margin for PP&L, even without the Susquehanna facility, is much larger than the 5% required by the interchange agree-ment or the 15 to 25K recommended by the Federal Economic, Regulatory Commission (formerly Federal Power Administration).* At the time construction was planned (early 1970s), the reserve requirement was 205 (not 5l as now). There is, however, the possibility that this reserve requirement could increase toward the current PJH reserve requirement of 205. If PJM summer-peaking companies tend toward winter peaking as more electric heating loads are sub-stituted for gas and oil, the applicant's credit for peak load diversity will be reduced and its capacity obligation could approach the 20K requirement of PJM. If the PJM reserve requirement increases as a result of such conditions, it is expected that an equivalent and direct change

• PP&L's 5X reserve margin is due to diversity on the PJM system; i.e., with the exception of PP&L, all utilities belonging to PJM are summer peaking. PP&L can rely upon the capacity of other PJM utilities to support its winter peak load.

7-5 Table 7.3. Applicant's Peak Load and Energy Sales:

Past and Projecteda Ener Sales Winter Peak Year kWh x 10 Increase MW 5 Increase Historical 1966 10,157 2,085 1967 10,967 8.0 2,326 13. 3 1968 '12,081 10. 1 2,514 8.1 1969 13,531 12.0 2,850 13.4

~ 1970 14,683 8.5 3,238 13. 6 1971 15,685 6.8 3,294 1.7 1972 17,013 8.5 3,598 9.2 1973 18,865 10.9 3,662 1.8 1974 18,963 0.5 3.772 3.0 1975 19,113 0.8 4,122 9.3.

1976 20,354 6.5 4,514 9.5 1977 20,926 0.3 4,431 -1.8

~Pro'ected 1978 21,650 3.5 4,650 4.9 1979 22,400 3.5 4,790 3.0 1980 23,400 4' 4,970 3.7 1981 24 350 4.0 5,140 3.4 1982 25,251 3.7 5,310 3.3 1983 26,110 3.4 '5,480 3.2 1984 26,919 3.1 5,630 2.7 1985 27,673 2.8 5,770 2.5 1986 28,379 2.6 5,910 2.4 1987 29,069 2.4 6,030 2.0 1988 29,754 2.4 6,160 2.1 1989 30,439 2.3 6,290 2.1 1990 31,124 2.2 6,420 2.1 Source: ER-OL, Table 1.1-9.

Table 7.4. 1977 Projection of Applicant's Loads, Capacity, and Reserves for the 1978-1985 Period (mid-range load projection)a 1978 1979 1 980 1981 1982 1983 1984 1995 Winter Peak (MWe) 4,650 4,790 4,970 55140 5,310 5,480 5,630 5,770 Total capacities (MWe)

Fossil (coal) 4,145 4,145 4,145 4,145 4,145 4,145 4,145 4,145 Fossil (oil) 1,640 1,640 1,640 1,640 1,640 ',640 1,640 1,640 CT 5 Diesel 539 539 539 539 539 539 539 539 Hydro 146 146 146 146 146 146 146 209 Nuclear 945 1,890 1,890 1,890 Firm purchase 76 76 76 76 76 76 76 76 Capacity Transactions ~41 ) ~50) ~110) ~65) ~31) ~62) ~93) ~125)

Total (MWe) 6,505 6,496 6,436" 6,481 7,460 8,374 8,343 8,374 Adjusted peak 4,650 4,790 4,970 5,140 5,310 5,480 5,630 5,770 With Susquehanna Reserve (MWe) 2,150 2,894 2,713 2,604 Reserve margin (N) 40 53 48 , 45 Without Susquehanna Reserve (MWe) 1,855 1,706 1,466 1,341 1,205 1,004 823 714 Reserve margin (X) 40 36 29 26 23 I8 15 12 Data from ER-OL, Answer to,Cost-Benefit questions January 1979, Table CAB-11.1; ER-OL, Table 1.1-4.

7-6 in the applicant's capacity obligation will occur. The staff also recognizes that additional reserve capacity above 20% may be desirable for a system with units that are large in relation to system size (as will be the case with the Susquehanna facility in service).

7.3.4.3 PJM Reserve Margin In Table 7.5, the staff presents the reserve and reserve-margin calculations for PJM with and without the Susquehanna facility through 1985. Since there are no firm purchases or sales outside PJH and since all PJM utilities except PP&L are sumer peaking, the reserve margin is defined as "capacity minus summer peak load, divided by sumer peak load." Without the Susque-hanna facility, the reserve margin of PJH could be as low as 23K in 1983 and 1984. In an interchange such as,PJM, with about 7000 MW or more than 20K nuclear baseload operation, a 23%

reserve margin might not be adequate to meet minimum reliability standards. With the Susquehanna facility, the reserve margin for PJH will be an acceptable 28K in 1983 and 1984.

Table 7,5. Projection of PJH Loads, Capacities, and Reserves 1978 1979 1980 1981 1982 1983 1984 1985 Summer peak (HWe) 31,686 33,670 34,870 36,200 37,630 39,000 .40,310 41,650 Total capacities (HWe)

Fossil (coal) 15,501 15,487 15,887 15,870 15,884 15,791 15,791 16,191 Fossil (oil ) 12,132 12,132 '2,132 12,132 13,164 13,383 13,993 13,525 Nuclear 6,197 8,192 83192 8,1 92 9,182 10,242 11,362 13,484

'CT and diesel 7,926 7,960 7,960 7,959 7,972 8,247 ',246 8,132 Hydro ~2236 ~2236 ~2236 ~2267 ~2267 ~2267 ~2267 ~2267 Total (HWe)b 43,992 46,007 46,407 46,420 48,469 49,930 51,659 53,599 Reserve over summer peak:

With Susquehanna Reserve (MWe) 10,839 10,930 11,349 11,949 Reserve margin (l) 29 28 28 29 Without Susquehanna Reserve (HWe) 12s306 12 '37 113537 103220 9s849 86960 96399 10s019 Reserve margin (5) 39 37 33 28 26 23 23 24 Actual 1978 summer peak; occurred on 16 August 1978.

-Capacity as shown in "Load and Capacity Forecast," PJM Interconnection, 1 June 1978.

7.4 ALTERNATIVES The staff believes that the only reasonable alternative to the proposed action of granting an operating license for SSES available for consideration at the operating license stage is denying the license for operation of the facility and ther eby not permitting the constructed nuclear facility to be added to the applicant's generating system. Alternatives such as construction at alternative sites, extensive station modification, or construction of facilities utilizing different energy sources would each require additional construction activity with its accompany-ing economic and environmental costs, whereas operation of the already constructed plant would not create these costs. Therefore, unless major safety or environmental concerns resulting from operating the plant that were not evident and considered during the construction-permit review are revealed, these alternatives are unreasonable as compared to operating the already constructed plant. No such concerns have been revealed with regard to operation of SSES.

With respect,to the proposed action of operating the facility, it was shown that the addition of SSES to the PJM system is expected to result in savings in system production costs of about

$ 112 million per year for each of the two units of SSES. Further, as stated, ope'ration of these

7-7 units will provide diversity of fuel sources, thereby decreasing dependence on fuel supplies of uncertain availability (gas, oil, and lignite) and will contribute to increased system reli-ability. The environmental impacts of operation are reassessed in Section 4 of this Statement.

As discussed in Section 4, as a result of this reassessment, the staff has been able to forecast more accurately the effects of operation of SSES and has determined that the station will operate with acceptable environmental impact.

The alternative of not operating the facility will require the utility to substitute approxi-mately 11 billion kWh per year of electrical energy that would have been provided by SSES with other sources of energy that have a greater economic cost and an equal or greater environmental cost. As indicated, the additional economic cost has been estimated at approximately $ 112 million per year for each of the two units.

After weighing the described options, the staff concludes that the preferable choice is opera-tion of SSES.

References

l. U.S. Nuclear Regulatory Commission, "Licensed Operating Reactor Status Report," Vol. 5, No. 2, NUREG-0020, February 1981.*

2. "Energy Review," Vol. 5, No. 2, Spring 'l981.

3. A. D. Rossin and T. A. Rieck, "Economics of Power," Science {201}582-589, 18 August 1978.

4. J. 0. Rober ts, S. M. Davis, and D. A. Nash, "Coal and Nuclear: A Comparison of the Cost of Generating Baseload Electricity by Region," NUREG-0480, December 1978.**

var a e or pure ase from the NRC/GPO Sales Program, U.S. Nuclear Regulatory Commission, Washington, DC 20555, and/or the National Technical Information Service, Springfie'id, VA 22161.

• "Available for purchase from the National Technical Information Service, Springfield, VA 22161.

8. EVALUATION OF THE PROPOSED ACTION 8.1 ADVERSE EFFECTS THAT CANNOT BE AVOIDED The staff has re-assessed the physical, social, biological, and economic impacts that can be attributed to the operation of SSES. Inasmuch as the units are currently under construction, many of the predicted and expected adverse impacts of the construction phase are evident. The staff has not identified any additional adverse effects from those presented in the FES-CP that will be caused by the operation of the units. The applicant is coranitted to a program of resto-ration and redress of the station site that will begin at the end of the construction period.

8.2 SHORT-TERM USES AND LONG-TERM PRODUCTIVITY (here have been no significant changes in the staff's evaluation of the use of land for the Susquehanna Steam Electric Station since the preconstruction environmental review. There have been major changes in the location of some of the transmission corridors since the FES-CP was issued; however, the staff's evaluation of the environmental impacts of the transmission lines remains essentially as before. The presence of the station in Luzerne County will continue to influence the future use of other land in its iamediate environs as well as the continued removal of county land from agricultural and timber use as the result of any increased industrialization.

8.3 IRREVERSIBLE AND IRRETRIEVABLE COMMITMENTS OF RESOURCES There has been no change in the staff's assessment of this impact since the earlier review except that the continuing escalation of costs has increased the dollar values of the materials used for construction and fueling of the plant, The staff has'xpanded and updated'the discussion of uranium fuel availability in Section 8.5.

8.4 COMPARISON OF NUCLEAR AND COAL-FIRED POWER PLANTS 8.4.1 Health Effects In addition to the environmental costs attributable to coal and nuclear fuels (Table 8.1), the differing health effects from using coal a'nd nuclear fuels have been considered in the environ-mental assessment o'f each alternative. In making these assessments, the entire fue'1 cycle rather than just the power-generation phase was considered to compare the total impacts of each cycle.

coal, the cycle consists of mining, processing, fuel transportation, power generation, and 'or waste disposal. The nuclear fuel cycle includes mining, milling, uranium. enrichment, fuel prep-aration, fuel transportation, power generation, irradiated fuel transportation and reprocessing, and waste disposal.

In preparing this assessment it was recognized that there are great uncertainties due to the lack of an adequate data base in certain areas of each fuel-cycle alternative. The overall uncer in the nuclear fuel cycle is probably about an order of magnitude (increased or decreased -'ainty by a factor of 10) over 100 years and about two or more orders of magnitude'over 1000 years. The uncertainty associated with the coal fuel cycle tends to be much larger because of the inability to estimate total health impacts from all the pollutants released to the environment from that cycle. However, if one assumes most of the public impact over a period of several decades is caused by inhalation of sulfur compounds and associated pollutants, there is as much as a two-order-of-magnitude uncertainty in the assessment of the coal fuel cycle. The much greater uncertainty associated with the coal fuel cycle results from the re'latively sparse and equivocal data'egarding cause-effect relationships for most of the princi'pal pollutants in the coal fuel cycle, the effect of federal laws on the future performance of coal-fired power plants, mine safety, and culm-bank stabilization, and the long-term impacts of coal ash and flue gas desulfur-ization sludges.

"Health effects," as the term is used here, is intended to mean excess mortality, morbidity (disease and illness), and injury among occupational workers and the general public ("excess" refers to mean effects occurring at a higher-than-normal rate; in the case of death, "excess" is 8-1

8-2 Table 8.1. Comparative Environmental Costs for an 1800-MWe Coal Plant and SSES at Full Output Impact Coal Nuclear Land use, ha Station proper and associated 470 ponds; fuel and waste storage areas Release to air Dust, kg/day 20,000 None Sulfur dioxide, kg/day 230,000 None Nitrogen oxides, kg/day 132,000 None Radioactivity, Ci/yr Small 21,000 Releases to surface water Chemicals dissolved in blowdown, gb kg/day Radioactivity, Ci/yr None 160 Water consumed, ms/min +55 106 Fuel Consumed, kg/day I*20,000,000 186 Ash, kg/day ~2,000,000 Social Moderate Moderate Esthetic Both require large industrial-type structures and cooling towers Coal yard, ash pit, tall stack required a

Coal-fired plant emissions estimated on the basis that the plant just meets applicable EPA standards.

Information not available.

Of UsOa.

used synonymously with "premature mortality" ). The most recent and detailed assessments of health effects of the coal fuel cycle have been prepared by the Brookhaven and Argonne national laboratories.~ The most complete and recent assessment of the radiological health effects of the uranium fuel cycle for normal operations was prepared for the "Final Generic Environmental Statement on the Use of Recycle Plutonium in Mixed Oxide Fuel in Light Water Cooled Reactors (GESMO I)" 7 However, in accordance with 10, CFR Part 51.20(e), the current impact of the uranium fuel cycle (excluding reactors and mines) is defined by the 14 Harch 1977 revision of Table S-3, 10 CFR

'lly Part 51. [Consistent with the Commission's announced intention to reexamine the rule periodic-to accormodate new information (39 FR 14188, 22 April 1974, and 42 FR 13803, 14 March 1977), staff studies, are under way to determine what areas, in addition to waste management and reprocessing, may require updating in Table S-3 (Notice of Proposed Rulemaking, Docket No.

RM 50-3, Environmental Effects of the Uranium Fuel Cycle, 41 FR 45849, 18 October 1976).] Using the Table S-3 effluents and the models developed for GESMO I, it was possible to estimate the impact of the uranium fuel cycle on the. general public for routine operations.

These values are shown in Tables 8.2-8.7 and some critical assumptions related to estimates are shown in Appendix H.

Because Table S-3 (Table 4.16) excludes radon releases from uranium mines, the health effects of such releases on the general public are not included in Tables 8.2-8.7. The effects of such releases would result in some small increases in the total risks of mortality and morbidity as discussed further under "Other Considerations." '1'

Table 8.2. Suranary of Current Energy Source Excess Mortality per Year per 0.8 GWy(e)

Occu ational General Public Fuel Cycle Accident Disease Accident Disease Total Nuclear (U.S. population)

All nuclear 0.22a 0.14b 05 '.18-1.3 b 0. 59-1 ~ 7 (1 ~ 0) d With 1005 of electricity used in the fuel cycle 0.24-0.25 '.14-0.46 0.10 0.77-6.3 1.2-6.8 (2 ')

produced by coal power Coal (regional population) 0.35-0.65 e 0-7 h 1.2 13-1109 15-120 (42)

Ratio of coal to 42 (all nuclear) nuclear (range): 14 (with coal power)

(geometric means)

Primarily fatal nonradiological accidents, such as falls or 'explosions.

b Primarily fatal radiogenic cancers and leukemias from normal operations at mines, mills, power plants, and reprocessing plants.

Primarily fatal transportation accidents (Table S-4, 10 CFR Part 51) and serious nuclear accidents.

Values in parentheses are the geometric means of the ranges (~a Primarily fatal mining accidents, such as cave-ins, fires, and explosions.

Primarily members of the general public killed at rail crossings by coal trains.

Primarily respiratory failure among the sick and elderly from combustion products from power plants, but includes deaths from waste-coal-bank fires.

Primarily coal workers pneumoconiosis (CWP) and related respiratory diseases leading to respiratory failure.

With 100K of all electricity consumed by the nuclear fuel cycle produced by coal power; amounts to 45 MWe per 0.8 GWy(e).

Although Table S-3 no longer includes release estimates for Rn-222 from uranium and milling operations,* the staff has reevaluated the question and prepared new estimates which were used in this assessment. These new estimates indicate that Rn-222 releases account for most of the potential premature mortality from the uranium fuel cycle.

In addition, Tab'le S-3 does not generically address releases for 'light-water-cooled power reactors.

The estimated total body population dose commitments for goth occupational workers and the general public were taken from GESMO I (uranium recycle only option). In addition, the occupa-tional dose corrmitments to workers in uranium mines, mills, uranium hexafluoride plants, uranium fuel plants, and uranium enrichment plants were taken from GESMO I, because they are not consid-ered in Table S-3. However, these dose coranitments are comparable to those that would the radiological releases described'n NUREG-0216, which provides background support for result'rom Table S-3.

The dose commitments to the public and occupational workers in the March 1977 Table S-3 were used for estimating health effects from the reprocessing and waste-management aspects of the uranium fuel cycle. The risk estimator s used to estimate health effects from radiation dose commitments were taken from GESMO I and WASH-1400.e

• Effective 14 April 1978 [Fed. Reg. 43(15613) (ll April 1978)j, NRC directed the staff to delete the 74.5-Ci Rn-222 source term from Table S-3 (10 CFR Part 51), and consider such health effects as might result from radon releases from mining and milling one RRY of uranium on a case-by-case basis.

8-4 Table 8.3. Excess Mortality per 0.8 GMy(e) -- Nuclear Occu ational General Public Fuel-cycle Component Accident Disease ' Accident 'iseaseg Total Resource recovery 0.2 0.038 sO 0.085 (mining, drilling,'tc.)

Processing 0. 005 0.042 j/ ~

0.026-1.18 Power generation 0. 01 0.061 0. 04 0.016-0.20 Fuel storage J/ sQ J/ aQ Transportation aO =0 0.01 eO Reprocessing j/ 0. 003 J/ 0.054-0.062 Waste management j/ ~0 3/ O.OQl Total 0. 22 0.14 0.05 0.18-1.3 0.59;1.7 Breakdown of Table 8.2.

L. D. Hamilton, ed., "The Health and Environmental Effects of Electricity Generation: A Pre-liminary Report," Brookhaven National Laboratory, July 1974..

U.S. Nuclear Regulatory Comnission, "Final Generic Environmental Statement on the Use of Recycle Plutonium in Nixed Oxide Fuel in Light Mater Cooled Reactors," NUREG-0002 (August 1976).

d 10 CFR Part 51. Table S-3.

10 CFR Part 51, Table S-4.

U.S. Nuclear Regulatory Commission, "Reactor Safety Study," MASH-1400 (NUREG-75-014), October 1975.

Long-tenn effects from Rn-222 releases from mills and tailings piles account for all but Q.001 health effects.

h Includes milling, uranium hexafluoride production, uranium enrichment, and fuel fabrication.

Corrected for factor of 10 error based on referenced value (report WASH-1250).

JThe effects associated with these activities are not known at this time. Although such effects are generally believed to be small, they would increase the total in the column.

Table 8.4. Excess Mortality per 0.8 GWy(e) -- Coal Occu ational General Public Fuel-cycle Component Accident Disease Accident Disease Total Resource recovery 0.3-0.6 0-7 b/ b/

(mining, drilling, etc.)

Processing 0. 04 b/ b/ 10 Power generation 0. 01 b/ b/ 3-100 Fuel storage b/ b/ b/ b/

Transportation b/ b/ 1.2 b/

Waste management b/ b/ b/ b/

Total 0.35-0.65 0-7 1.2 13-110 15-120 Breakdown of Table 8.2. See also L. D. Hamilton, ed., "The Health and Environmental Effects of Electricity Generation: A Preliminary Report," Brookhaven National Laboratory, July 1974.

b The effects associated with these activities are not known at this time. Although. such effects are generally believed to be small, they would increase the total in the column.

8-5 Table 8.5. Sumnary of Current Energy Source Excess Horbidity and Injury per 0.8 GWy(e) Power Plant Occu ational General Public Fuel Cycle Mor bidi ty Injury Horbidity Injury Total Nuclear (U.S. population)

Al 1 nuclear 0.84 12b 1.0-3.1 0 ld 14-16 (15)

With 1005 of electricity 1-.7-4.1 f 13-14 1,5-7.6g 0.55 17-24 (21) used by the fuel cycle produced by coal power Coal (regional population) 20-70 17-34 10-1009 10h 57-210 (109)

Ratio of coal to 7.3 (all nuclear) nuclear (range): 5.2 (with coal power)

(geometric means)

Primarily nonfatal cancers and thyroid nodules.

b Primarily nonfatal injuries associated with accidents in uranium mines, such as rock falls or explosions.

Primarily nonfatal cancers, thyroid nodules, genetically related diseases, and nonfatal (such as radiation thyroiditis, prodromal vomiting, and temporary sterility) following ill-'esses high radiation doses.

d Transportation-related injuries from Table S-4, 10 CFR Part 51.

Values in parentheses are the geometric means of the ranges (~a fPrimarily nonfatal diseases associated with coal mining such as CWP, bronchitis, and emphysema.

gPrimarily respiratory diseases among adults and children caused by sulfur emissions from coal-fired power plants and waste-coal bank fires, Primarily nonfatal injuries among members of the general public from collisions with coal trains at railroad crossings.

Coal effects are based on a regional population of 3.8 million people within 80 km of the coal plant.

3Primarily injuries to coal miners .from cave-ins, fires, and explosions.

With 100$ of all e'lectricity consumed by the nuclear fuel cycle produced by coal power; amounts to 45 HWe per 0.8 GWy(e).

The impact of accidents in fuel-cycle facilitiess and reactorsa generally does not markedly increase the impact of normal operations for the uranium fuel cycle, but has been included in this assessment for completeness. No comparab'Ie analysis of health effects resulting from accidents in coal-fired plants is available at this time.

Estimates of death, disease and injury from nonradiological causes for the uranium fuel cycle are from the Brookhaven evaluations,> s with the exception of transportation-accident-related deaths, which were taken from Table S-4, 10 CFR Part 51. The results of these assessments are shown .in Tables 8.2-8.7. It should be noted that there are two lines under the nuclear fuel cycle: the first assumes all of the electricity used within the uranium fuel cycle is generated by nuclear power (i.e., all-nuclear economy); the second line assumes, as shown in Table S-3 (10 CFR Part 51), that 100K of the electricity used within the nuclear fuel cycle comes from coal power. This is equivalent to a.45-HWe coal-fired, plant, or 4.5X of the power produced.

8.4.2 The Uranium Fuel C cle Currently the NRC estimates that the excess deaths per 0.8 gigawatt-year electric (.GWy(e)1 wil'1 be about 0.47 for an all-nuclear economy. This is probably somewhat high due to the conservatism required in evaluations of generic p'lants and sites ("Conservatism" is used to mean that assump-tions regarding atmospheric dispersion, deposition of particulates, bioaccumulation, etc., generally

8-6 Table 8.6. Morbidity and Injury per 0.8 GWy(e) -- Nuclear Occu ational General Public Fuel-cycle Component'orbidi ty Injury Morbidity Injury Total Resource recovery d/ 10 e/ ccp (mining and drilling)

Processing d/ 0.6 e/ ap

- Power generation'uel d/ 1.3 e/ ap storage d/ g/ e/

Transportation d/ <1 e/ 0.1 Reprocessing d/ (L/ e/ (L/

Waste management d/ g/ e/ ~0 Total 0.84 12 1. 0-3.1 0.1 14-16 Breakdown of Table 8.5..

L. 0. Hamilton, ed., "The Health and Environmental Effects of Electricity Generation: A Pre-liminary Report," Brookhaven National Laboratory, July 1974.

Table S-4, 10 CFR Part 51.

d Nonfatal cancers < fatal cancers (excluding thyroid) or 0.14. Nonfatal thyroid cancers and benign nodules ~3 x fatal cancers or 0.42. Genetic defects ~2 x fatal cancers or ~0.28.

Reactor accidents: 10 x fatalities or ~0.40 nonfatal cases.

Normal operations: Nonfatal cancers < fatal cancers or ~0.18-1.3.

Nonfatal thyroid cancers and nodules ~3 x fatal cancers (from total body doses) or ~0.26-0.84.

Genetic effects ~2 x fatal cancers (from total body doses) or 0.17-0.56.

f Includes milling, uranium hexafluoride production, uranium enrichment, and fuel fabrication.

The effects associated with these activities are not known at this time. Although such effects are generally believed to be small, they would increase the total in the column.

Table 8.7. Morbidity and Injury per 0.8 gWy(e) -- Coal Occu ational General Public Fuel-cycle Component Morbidi ty Injury Morbidi ty Injury Total Resource recovery 20-70 13-30 b/ b/

(mining and drilling) h Processing b/ 3 b/ b/

Power generation gb 1.2 10-100 b/

Fuel storage gb b/ Jb

'b Transportation b/ gb b/ 10 Waste management b/ b/ b/ b/

Total 20-70 17-34 '0-100 10 ~ 57-210 Breakdown of Table 8.5. See also L. 0. Hamilton, ed., "The Health and Environmental Effects of Electricity Generation: A Preliminary Report," Brookhaven National Laboratory, July 1974.

The effects associated with these activities are not known at this time. Although such effects are generally believed to be small, they would increase the total in the column.

8-7 result in estimates of impact that are typically upper bound estimates. In most cases, the estimates would be lower for real plants). However, it is not greatly different from estimates by others such as Comar and Sagan~o (0.11 to 1.0), Hamilton'0.7 to 1.6), and Rose et al.~~

(0.50). The uncertainty in the estimate is about an order of magnitude for periods up to about 100 years, and probably two or more orders of magnitude for estimates as far into the future as 1000 y'ears. If, as shown in Table S-3, 100K of the electrical power used by the uranium fuel cycle comes from coal-fired power plants, NRC estimates there would be about l,l to 5.4 excess deaths per 0.8 GWy(e). Of this total, about 0.62 to 4.9 excess deaths per 0.8 GWy(e) would be attributable to coal power (Table 8.6). The uncertainty in the estimate is about one order of magnitude.

The total number of injuries and diseases that might occur among workers and the entire U.S.

population as a result of normal operations and accidents in the uranium fuel cycle was estimated to be about 14 per 0.8 GWy(e) for an all-nuclear economy. Injuries among uranium miners from accidents account for .10 of the 14 cases (Table 8.5). If 100Ã of the electrical power used by the uranium fuel cycle comes from coal-fired power plants, NRC estimates there would be about 17 to 24 injuries and diseases per 0.8 GWy(e). Of this total, about 3 to 10 excess events per 0.8 GMy(e) would be attributable to coal power (Table 8.6). The uncertainty in the estimate is also about one order of magnitude.

Although anticipated somatic (nongenetic) effects associated with normal releases of radioactive effluents from the nuclear fuel cycle are limited to potential cancers and leukemias, for the higher doses associated with serious nuclear accidents there is some small risk of various non-fatal somatic effects (Table 8.5, Footnote c). At this time only light-water-cooled power reactors have been thoroughly evaluated.a However, it should be noted that power reactors probabl~

account for most of the potential health effects associated with nuclear accidents in the uranium fuel cycle.

This results from the fact that power reactors represent 80K of all fuel-cycle facilities expec-ted to be operating for the balance of this century~ and account for the majority of occupa-tionally exposed individuals. In addition, although the probability of serious accidents is extremely small, if one were to occur, the health effects would be larger than for any other type of fuel-cycle facility. Serious nuclear accidents in power reactors might also contribute about 0.04 excess deaths per 0.8 GWy(e), whereas transportation-related accidents are estimated to contribute about 0.01: excess deaths per 0.8 GMy(e) (Table 8.2, Footnote c).

Early and latent nonfatal somatic effects that might be expected after high radiation doses include a variety of effects (Table 8 ', Footnote c). It is possible that nonfatal somatic effects could be an order of magnitude greater than excess deaths resulting from accidents; thus, the total number per 0.8 GWy(e) would be about 0.4. This accounts for about one third of the morbidity shown for the general public and an all-nuclear economy in Table 8.5. The number of nonfatal thyroid cancers (5-10$ 'mortality rate) and benign thyroid nodules would be about 0.6 per 0.8 GWy(e) from routine releases to the public and occupationa'} exposures (primarily external irradiation), whereas. other nonfatal cancers would be less than or equal in number to fatal cancers [about 0.2 per 0.8 GWy(e)] (Table 8.5, Footnote c).

It is believed that genetically related diseases (e.g., cystic fibrosis, hemophilia, certain anemias, and congenital abnormalities such as mental retardation, short-limbed dwarfism, and extra digits), and abnormalities fn the descendants of workers and the general public from both normal operations and accidents would be perhaps twice the number of excess deaths 'due to cancer from total body irradiation; * 'this could add another 0.3 health effects per 0.8 GWy(e) among workers and 0.2 health effects per 0.8 GWy(e) among the general public (Tables 8.5 and 8.6, Footnote c).

In assessing the impact of coal power used in the uranium fuel cycle, Table S-3 (10 CFR Part Sl) was the basis for the assumption that 1005 of the electricity used in the uranium fuel cycle, primarily for uranium enrichment and reactor operation, came from coal-fired plants. Adding 4.55 of the health effects per 0.8 GWy(e) from the coal fuel cycle significantly increases the health effects power 0.8 GWy(e) from the uranium fuel cycle, as shown on the second lines of Tables 8.2 and 8.7.

8.4.3 The Coal Fuel C cle*

Current estimates of mortality and morbidity resulting from the coal fuel cycle are quite uncer-tain; this is the principal reason for the wide range of values reported in the literature.

These uncertainties result from the limited number of epidemiological studies and differences in

• See also "Activities, Effects, and Impacts of the Coal Fuel Cycle for a 1,000 NWe Electric Power Generating Plant," NUREG/CR-1060, U.S. Nuclear Regulatory Comnission, February 1980,

8-8 interpretation of the results of such studies. There is additional uncertainty regarding the effects of new federal laws on coal cycle facilities in the next decade. Current estimates of excess deaths for the entire coal cycle range from 15 to 120 per 0.8 GWy(e), whereas disease and.

injury estimates range from 57 to 210 per 0.8 GWy(e).

In the case of occupational effects, there is considerable uncertainty because of ant'icipated reductions in health effects resulting from the implementation of the Federal Coal Mine Health and Safety Act of 1969 (PL 91-173). The'provisions of this act should result in significant improvement of the'underground work environment, particularly regarding coal dust. Coal dust is both a cause of underground explosions and fires and a cause of coal workers pneumoconiosis (CWP), comenly called black lung disease, and subsequent progressive massive fibrosis (PMF).> s In addition, more coal in the years ahead is expected to be produced by strip mining, which results in lower mortality rates.> As a result, the frequencies of both types of events are anticipated to decline in the years ahead, on a per GWy(e) basis. On the other hand, statistics show new coal miners experience higher mortality and injury rates than egperienced miners.s As a result of expected increases in coal production, an influx of inexperienced miners will tend to increase the mortality, and injury rates for miners as a group.

For the general public,there is also considerable uncertainty in the estimation of health effects. ( In the case of coal-plant effluents, consideration of health effects,was limited to the population within 80 km of such plants.) For example, although there are estimates of health effects related to burning culm banks (waste banks from coal screening), recent efforts by mine operators have greatly reduced such fires, and future processing activities are expected to avoid fires as a result of new methods of stabilizing the banks to prevent slides.>~ Current estimates of excess deaths in the public from sulfates from such fires range from one to ten per 0.8 GWy(e)

(Table 8.2, Footnote f). Power generation is estimated to result in 3 to 100 excess deaths per 0.8 GWy(e) (Table 8.2, Footnote f), whereas excess morbidity ranges from about 10-100 per 0.8 GWy(e)

(Table 8.5, Footnote e).

t The uncertainties are even greater in the power-generation phase of the coal cycle, where esti-mates of health effects range over several orders of magnitude.~o 'This is largely due to the lack of a reliable data base for predicting health effects from the various pollutants emitted from coal plants, and the effect of the EPA New Source Performance Standards for coal plants regarding particulate and sulfur emissions in future years on a long-term 'basis. There is some uncertainty as to whether these standards can be met in large coal-fired power plants over the life of the plant. The major pollutants emitted include:

1. Particulates: Contain large amounts of toxic trace metals in respirable particle size~"

such as arsenic, antimony, cadmium, lead, selenium, manganese, and thallium;s significant quantities of beryllium, chromium, nickel, titanium, zinc, molybdenum, and cobalt; >> and traces of Ra-226 and -228 and Th-228 and -232>~

2. Hydrocarbons: Include very potent carcinogens (cancer-causing substances) such as benzo(a)pyrene

3. Sulfur oxi'des

4. Nitrogen oxides 4

5. Other gases: Include ozone, carbon monoxide, carbon dioxide, mercury vapor, and Rn-222 Regarding the preceding list* of pollutants, there are no well-established epidemiologic cause-effect relationships that can be used to estimate total health effects accurately, either from acute exposures during air-pollution episodes or from chronic long-term exposures.

Although definitive cause-effect relationships are lacking, tentative cause-effect relationships for sulfur emissions have been used by numerous groups to estimate health effects, from sulfur emissions from coal plants they are described by the National Academy of Sciences in a recent report to the U.S. Senate. 7 The most widely quoted studies are those by Lave and'Seskin,>a Winkelstein et al.,'s and an unpublished study by EPA that was used in the NAS/NRC study for the U.S. Senate.>>

In general, the effects range from excess deaths from cardiovascular failure and increases in asthma attacks during severe air pollution to excess respiratory disease from long-term chronic exposures, Most of the acute deaths are among the elderly and the severely ill, whereas mor-bidity from long-term exposure also includes children. Although widely accepted cause-effect relationships were not derived from studies of acute air-pollution episodes in London in 1952;zo Donora, Pennsylvania, 1948;z~ and New York, these studies definitely support the conclusions regarding excess death and disease associated with emissions from combustion of coal.

A There are no estimates of possible long-term carcinogenic effects by sulfur oxides or pssociated pollutants. In addition, the large-scale EPA Conmunity Health and Environmental Surveillance System (CHESS) study (completed in 1976) failed to provide any new or definitive cause-effect relationships for any of the pollutants from coal-fired plants that could be used to provide better

8-9 estimates of health effects than are currently available. s The $ 22 million CHESS study attempted to correlate air-pollution data collected fry six U,S. cities with a variety of health problems.

Assuming that new coal-fired plants in the 1980s can meet EPA New Source Performance Standards (which could require 905 sulfur removal for high-sulfur coal and about 99$ particulate removal) and other federal laws regarding mine safety and culm-bank stabilization, the number of deaths should be reduced. Thus, current estimates of 15 to 120 per 0.8 GWy(e), due largely to sulfates from combustion of coal, may be reduced by about half.

I Argonne National Laboratory recently developed a predictive model for deaths from emission of benzo(a)pyrene, which indicates about 1 to 4 deaths .per 0 ' GWy(e) depending on use of conven-tional combustion or fluidized-bed combustion.< Such effects, although greater than the expected deaths from the entire uranium fuel cycle (all-nuclear economy), do not significantly change the total impact of the coal fuel cycle and were not included in the effects listed in Table 8.2.

Probably the most reliable estimates of deaths associated with the coal fuel cycle are those associated with transportation accidents. Because a 1000-HWe coal-fired plant consumes about 2.7 million tonnes (three million tons) of coal per year, there are literally thousands of carloads of coal being transported by rail from mines to plants. It has been estimated that about one out of every ten trains in the U.S. is a coal train going to a coal-fired power plant.z4 These trains are estimated to travel an average distance of about 480 km from the mine to the plants.~s As a result, there are about 1.2 deaths per 0.8 GWy(e) among workers and the general public. Further, because most of these deaths occur at railroad, crossings, the numbers can rail- be expected to increase as more automobiles are operated and driven greater distances, and as transportation distances increase when hauling low-sulfur western coals to eastern markets.

Sickness among coal miners and the general public accounts for, most of the nonfatal occurrences in the coal fuel cycle, with most of the remainder due to injuries among coal miners. As a result of implementation of federal laws, it is probable that future rates among underground miners will be substantially reduced. It is not unreasonable to assume that current estimates of about 57 to 210 cases of sickness and injury among workers and the general public could be reduced in the years ahead, inasmuch as occupational sickness and injury currently account for about half of the total nonfatal health effects.

The overall uncertainty in the estimates of health effects for the coal fuel cycle in this assess-ment is probably about one to two orders of magnitude. Although the breakdown estimates generally fall within the range of estimates in the literature, such estimates represent only the impacts occurring over a period of a few decades (e.g., while a power plant is operating) and do not include potential long-tenn health effects rgsulting from Rn-222 and toxic heavy metals which may be released to the biosphere from coal ash and flue gas desulfurization sludge waste pits. Such releases, which may occur over centuries or millenia, could substantially increase the estimated health impacts presented in this assessment. Therefore, these potential long-term impacts substantially increase the uncertainty in the health impacts just discussed.

8.4.4 Other Considerations Although the Reactor Safety Studya has helped provide a perspective of the risk of mortality or morbidity from potential power-reactor accidents (the current experience for serious accidents is zero),* there is the additional problem associated with individual perception of risk. Thus,

• In July 1977, NRC organized the independent Risk Assessment Review Group to: 1) clarify the achievements and limitations of the Reactor Safety Study (RSS); 2) assess peer coranents thereon and responses to those coranents; 3) study the present state of such risk assessment methodology; and 4) recoranend how and whether such methodology can be used in the regulatory and licensing process. The results of this study were issued in September 1978 (NRC, "Risk Assessment Review Group Report," NUREG/CR-0400, September 1978).

While praising the RSS's general methodology and recbgnizing its contribution to assessing the risks of nuclear power, the Review Group found that it was unable to determine whether it the absolute probabilities of accident sequences in report WASH-1400 are high or low; did conclude that the error bounds on those. estimates are, in general, greatly understated.

On 19 January 1979, NRC issued a statement of policy concerning the RSS and Review Group Report. NRC accepted the findings of the Review Group and concluded that the RSS's numerical estimates of the overall risks of reactor accidents should not be regarded as reliable.

The importance of this uncertainty can be better perceived by considering the effects of an increase in the risks, of reactor accidents on the estimated overall mortality rate asso-ciated with the nuclear fuel cycle. Assuming the reactor accident risk to be 100 times that estimated in the RSS, the upper bound of the range of mortality per reference reactor year presented in this document from the nuclear fuel cycle could increase from 1.7 to 3.7.

If, however, the risk of such accidents were lower than estimated in the RSS, the lower bound of the range of mortality would not change appreciably.

8-10 although the study concluded that "All non-nuclear accidents examined in this study, including fires, explosions, toxic chemical releases, dam failures, airplane crashes, earthquakes, hurri-canes and tornadoes, are much more likely to occur and can have consequences comparable to or larger than, those of nuclear accidents," uncertainty will continue to be associated with such evaluations. Furthermore, there may be a problem of public acceptance of potential accidents, because the consequences can be severe. In fact, it appears that some peoplezs more readily accept, for example, having,55,000 people actually killed each year in violent highway acci-dents, one or two at a time, than they do the unlikely occurrence of perhaps several thousand possible deaths from a single catastrophic accident during their li'fetime.

/

As noted in Footnote 5 to the March 1977 revision of Table S-3 the GESMO I Rn-222 release increases from 74.5 Ci to about 4800 Ci when releases from mines are included. This would result in a small increase in the total number of excess deaths shown in Table 8.2, although the mortal-ity per 0.8 GWy(e) for the general public would increase by about 304.

With regard to the coal fuel cycle, numerous it is a well-established fact that the use of cdal resu'its in other costs to society that have not yet been adequately quantified. These include

1. The short- and long-term impacts of sulfur and nitrogen oxides on biota and materials.

Acid rain, for example, is known to be severely damaging to terrestrial and aquatic habitats. Argonne National Laboratory provides a detailed discussion of these and other effects of sulfur and nitrogen oxide emissions.s However, as more coal plants come on line, these effects can be expected to expand to surrounding areas.

2. Damage to materials, such as paints, building surfaces, statuary, and metals, caused by emissions of sulfur oxides, ozone, and nitrogen oxides. A 1976 review of such effects indicates that the costs could range into billions of dollars per year in the United States alone.zs

3. 'ontamination of soil and vegetation to toxic levels by such mechanisms as deposition and bioaccumulation of trace elements present in gaseous emissions.

4. Destruction of entire ecosystems in streams and rivers by acid-mine drainage, and the potential for public-health effects from downstream use of such water for domestic or agricultural purposes.

5. In addition to the occurrence of excess mortalities, injuries, and morbidities, the costs to society in terms of medical costs, lost productivity, and other social losses, represent a significant consideration that has not been completely evaluated at this time. Two recent studies, which dealt with these extremely complex issues,z~ >>a concluded that social costs from one coal-fired plant may currently be about $ 50 million per year, not considerin'g the rest of the costs for the coal fuel cycle.

6. The possibility of the so-called "greenhouse effect,"a phenomenon expected to occur sometime early in'h'e next century as-a result of the present and future anticipated production rates of carbon dioxide from the combustion of fossil fuels. s Because each 1000-MWe coal plant produces about 7.5 to 10.5 million tons of carbon dioxide per year,>

it is believed that these emissions from hundreds of fossil-fueled power plants may result in greater releases of carbon dioxide than the atmosphere and oceans can cycle. As a result, the carbon dioxide concentrations would be expected to increase in the atmosphere.

Because carbon dioxide strongly absorbs infrared, temperature will rise several degrees.

it is postulated that'the mean atmospheric This may cause all or part of the polar ice caps to melt, resulting in inundation of many inhabited areas of the world. 'At the same'ime, drought would be expected to prevail in many of the agricultural areas of the temperate zones, resulting in huge crop losses. It is possible that the particulates emitted fossil plants will counteract some of the greenhouse effect by reducing the amount ofby sunlight reaching the surface of the earth.

However, another effect from carbon dioxide released by coal combustion occu'rs because coal has essentially no carbon-14. In effect, the stable carbon dilutes the carbon-14 in the biosphere, resultin'g in a reduction in the radiological'mpact of both naturally occurring and manufactured carbon-14.

7. An additional consideration that has not been evaluated for the coal cycle is the radio-logical impact of mining and burning coal". Of interest is the release of radon-222 from the decay of radium-226 in coal: Not only is the radon released during mining and combustion, but it will continue to emanate from flyash for millioris of years after the coal has been burned. Although Pohl has shown that this is not a problem with most eastern coal (generally of high sulfur content but with 1-3 ppm uranium content), the average uranium and radium content of some reserves of low-sulfur western coal is as much as 50 times higher than that of most eastern coal.>~isz Combustion of the coal and disposal of the remaining ash leads to about the same health effects from radon-222 emissions as do uranium-mill-tailings piles. These releases would account for less than one excess death per 0.8 GWy(e) due to fuel-cycle activities during the rest of this century. As a result, such releases do not significantly affect the conclusions reached with regard =to a comparison of the two alternative fuel cycles. In addition, some t

8-11 believess that if the physical and biological properties of the radium released from

, conventional coal-powered plants (burning coal with 1-2 ppm U-238 and Th'-232) are con-sidered, such plants discharge relatively greater quantities of radioactive materials into the atmosphere than do nuclear plants of corn(arable size. The Environmental Protection Agency has estimated radiation doses from coal and nuclear plants of early designs and reached similar conclusions.>>

8.4.5 Sugar and Conclusions For the reasons discussed, it is extremely difficult to provide precise quantitative values for excess mortality and morbidity, particularly for the coal fuel cycle. Nevertheless, a number of estimates of mortality and morbidity have been prepared based on present-day knowledge of health effects, and present-day. plant design and anticipated emission rates, occupational experience and other data. These are sumarized in Tables 8.2 and 8.5 (see Footnote k, Table 8.5), with some important assumptions inherent in the calculations of health effects listed in Appendix H.

Although future technological improvements in both fuel cycles may result in significant reduc-tions in health effects, based on current estimates for present-day technology, it must be concluded that the nuclear fuel cycle is considerably less harmful to man than the coal fuel cycle.~-s.>o~>>~z>~ e ss ss As shown in Tables 8.2-8.7, the coal fuel-cycle alternative may be

~

more harmful to humans by factors of 7 to 42 depending on the effect being considered, 'for an all-nuclear economy, or factors of 6 to 14 with the assumption that all of the electricity used by the uranium fuel cycle comes from coal-powered plants.

Although there are large uncertainties in the estimates of most of the potential health effects of the coal cycle, it should be noted that the impact of transportation of coal is based on firm statistics; this impact alone is greater than the conservative estimates of health effects for the entire uranium fuel cycle (all-nuclear economy) and can reasonably be expected to worsen as more coal is shipped over greater distances. In the case where coal-generated electricity is used in the nuclear fuel cycle, primarily for uranium enrichment and auxiliary reactor systems; the impact of the coal power accounts for essentially all of the impact of the uranium fuel cycle.

However, lest the results of this be misun'derstood, it should be emphasized that the increased risk of health effects for either fuel cycle represents a very small incremental risk to the average public individual. For example, Comar and Sagan~o have shown that such increases in risk of health effects represent minute increases in the normal expectation of mortality from other causes.

A more comprehensive assessment of these two alternatives and others is anticipated in 1979 from the National Research Council Coranittee on Nuclear and Alternative Energy Systems. This study may assist substantially in reducing much of the uncertainty in the analysis presented.

8. 5 URANIUM RESOURCE AVAILABILITY Thfs section reviews information available from the Department of Energy (DOE) on the domestic uranium resource situation and the outlook for development of additional domestic supplies, availability of foreign uranium, and the relationship of uranium supply to planned nuclear generating capacity.

Analysis of uranium resources and their availability has been carried out by the government since the late 1940s. The work was carried out for many years by, the Atomic Energy Coranission (AEC). The activity was made part of the Energy Re'search and Development Administration (ERDA) when the agency was created in early 1975s~ and was subsequently transferred to DOE when the department was formed 1 October 1977.

8.5.1 U.S. Resource Position To establish some basic terminology, a review of resource concepts and nomenclature would be worthwhile. Figure 8.1 defines resource categories based on varying geologic knowledge.

Resources designated as ore reserves have the highest assurance regarding their magnitude and economic availability. Estimates of reserves are based on detailed sampling data, primarily from galena ray logs of drill holes. DOE obtains basic data from industry from its exploration effort and estimates the reserves in individual deposits. In estimating ore reserves, detailed studies of feasible mining, transportation, and milling techniques apd costs are made. Consis-tent engineering, geologic, and economic criteria are employed. The methods used are the result of more than thirty years of effort in uranium resource evaluation.

8-12 URANIUM RESERVES- Defined POTENTIAL RESOURCES-RESOURCES by direct sampling Incompletely de(ined or undiscovered Probable Possible Speculalive DECREASING KNOWLEDGE AND ASSURANCE Fig. 8.1. DOE Uranium Resource Categories.

Resources that do not meet the stringent requirements of reserves are classed as potential resources. For its study of resources, DOE subdivides potential resources into three cate-gories: probable, possible, and speculative.sII Probable potential resources are those con-tained within favorable trends, largely delineated by drilling, within productive uranium districts, i.e., those having more than 10 tons of UsOs production and reserves. guantitative estimates of potential resources are made by considering the extent of the identified favorable areas and by comparing certain geologic characteristics with those associated with known ore deposits.

Possible potential resources are outside of identified mineral trends but are in geologic provinces and formations that have been productive. Speculative resources are those estimated to occur in formations or geologic provinces that have not been productive but which, based on the evaluation of available geologic data, are considered to be favorable for the occurrence of uranium deposits.

8ecause any evaluation of resources is dependent upon the availability of information, the estimates themselves are, to a large degree, a scorecard on the state of development of infor-mation. Thus. appraisal of U.S. uranium resources is heavily dependent on the completeness of exploration efforts and on the availability of subsurface geologic data. Since the geology of the United States as it relates to mineral deposits can never be completely known in detail, it is not possible to produce a truly complete appraisal of domestic uranium resources. It is likely that the total resource picture will eventually prove larger than currently estimated, given the nature and status of estimation methodology. The key factor may be the timeliness with which resources are identified, developed, and produced.

Conceptually," a resource, whether uranium or other mineral commodity, would initially be in the potential category. Development of additional data and clarification of production techniques and economics would be required to delineate and understand specific ore deposits to a degree that they could be categorized as reserves.

We can expect a dynamic balance between anticipated markets and prices and the extent to which exploration and reserve delineation will be done. There is no economic incentive for industry

'o expand reserves if the additional uranium will not be needed for many years, and especially if the long-term market outlook is uncertain. This has been true for uranium. The mining companies are concentrating on markets for the next five to fifteen years. The utilities and government are concerned with the outlook for the next thirty to forty years.

Conversion of the currently estimated potential resources into ore reserves will take many years and will cost several billion dollars. It would be difficult to economically justify acceler-ating such an effort to delineate ore reserve levels equal to lifetime requirements of all planned reactors cover ing some thirty to-forty years in the future simply to satisfy planners.

Supply assurance through continued timely additions to reserves and maintenance of a resource base adequate to support production demands, coupled with carefully, developed information on potential resources, is considered to be adequate and a more realistic and economic approach.

8-13 e The conversion of potential resources to ore reserves and expansion of production be accomplished when needed as markets expand and production is needed.

facilities can All'ranium resource estimates made by DOE and its predecessor agencies before 1979 were single estimates of tons of ore and grade for various cost categories. The estimtes were made by experienced geologists and engineers according to standard procedures, and represented a reason-able measure of resources.'he current procedures for estimating uranium resources provide both mean values and distributions to characterize the reliability of the estimates at specific confidence levels. All available geologic information and the expertise of the estimators are fully utilized. These procedures are standardized and documented to minimize personal biases and to facilitate reviews and revisions as new information is acquired.

The estimates of resources in the United States are developed from a data base accumulated during the past three decades of government and industry activities and enhanced by National Uranium Resource Evaluation program investigations of the past five years. Data acquired to support resource assessment have been extensive and varied. The assessment includes the evalu-ation of several hundred thousand industry-drilled holes; aerial radiometric surveys; sampling and geochemical analyses of groundwater, stream water, and stream sediment; selective drilling to fill voids in subsurface information; and extensive geologic field examinations. These data have been evaluated to determine those areas favorable for uranium occurrences. Evaluation criteria have been developed from studies of uranium deposits throughout the world. In favor-able areas, the uranium endowment, material greater than 0.01 percent UsOa, is estimated, and subsequently economic factors are applied to assess the potential resources available at selected costs'.

The costs used to calculate uranium resources are forward costs .that consider both operating and capital costs (in current dollars) that would be incurred in producing the uranium. These costs include power, labor, materials, royalties, payroll, severance and ad valorem taxes, insurance, and applicable general and administrative costs. All previous expenditures (before the time of the estimate) for such. items as property acquisition, exploration, mine development, and mill construction are excluded. Also excluded are income taxes, profit, and the cost of money. The resources assigned to the various cost categories are independent of the market price at which the uranium might be sold.

There are two major methodologies in uranium assessment: one is used for the estimation of reserves based on sample results from drill holes on specific properties, the second involves the use of a variety of geologic information to subjectively estimate potential resources.

Reserves are calculated, individually for properties throughout the United States using data voluntarily provided by the uranium companies to DOE. The data consist primarily of radiometric drill hole logs and maps. Parameters evaluated include thickness and tenor of mineralized rock; depth and spatial relationships, mining methods, ore dilution, and recovery; and amenability of ores to processing. The amounts of uranium 'that* could, be exploited at the forward cost levels are calculated according to conventional engineering practices utilizing available engineering, geologic, and economic data.

A regional reserves distribution estimate is obtained by mathematically combining the estimates of individual distributions for each property. These regional distributions are then combined to provide a total for the United States. Estimates include all material over a selected mini-mum thickness with a uranium content above 0.01% UsOa. A recovery factor is applied, after rate procedures are used for properties on which solution mining is in progress or is planned.

Potential resource estimates are based on geologic analogy. Geologic characteristics related to uranium potential in the area being investigated are compared with those in an area with similar characteristics, that is, a control area that contains uranium deposits for which the frequency distribution of grades and tonnages in the deposits has been developed. The analogy-based methodology is made feasible by DOE's extensive data base from which detailed characterizations of the distribution of uranium have been developed. From systematic comparison with an appro-priate control area, an estimate is developed of the total amount of uranium, above 0.01% Us0a, that might be present in an area being evaluated. Uranium endowment factors, such as surface area, fraction underlain by endowment, grade, and tonnage are estimated at three confidence levels, i.e., a modal value that is considered as most likely, and a low and high estimate corresponding respectively to a 95 and 5% probability that the factor is at least that large.

The endowment estimate is analyzed to determine the portions that are producible at various cost categories within stated confidence levels.

Table 8.8 provides the mean reserve and potential resource estimates for each cost category, as well as estimates at the 95th'and 5th percentile. The 95th percentile value provides an esti-mate for which there is a 95% confidence that at least that amount exists. The 5th percentile provides an estimate for which there is a 5X probability that it will be exceeded. Due .to the correlation of the individual estimates that are aggregated to generate the regional and national totals, the estimates at the 95th and 5th percentile are not directly additive; however, the mean values are additive.

8-14 Table 8.8. Uranium Resources of the United States Forward-cost Category Mean 95th Percentile 5th Percentile At $ 15 per pound uf Us0a Reserves 225,000 190,000 260,000 Probable 295,000 185,000 448,000 Possible 87,000 42,000 156,000 Speculative 74,000 30,000 162,000 Totals 681,000 447',000 .

1,026,000 At $ 30 per pound of UsOa

'eserves 645,000 567,000 729,000 Probable 885,000 659,000 1,161,000 Possible 346,000 194,000 530,000 Speculative 311,000 155,000 600,000 Totals 2,187,000 1,731,000 2,748,000 At $ 50 per pound of UsOa

'eserves 936,000 821,000 1,060,000 Probable 1,426,000 1,102,000 1,802,000 Possible 641,000 346,000 973,000 Speculative 482,000 251,000 890,000 Totals 3,485,000 2,771,000 4,313,000 At $ 100 per pound of UsOa

'eserves 1,122,000 971,000 1,291,000 Probable 2,080,000 1,646,000 2,573,000 Possible 1,005,000 521,000 1,526,000 Speculative 696,000 '78,000.

1,225,000 Totals 4,903,000 3,875,000 6,056,000 Uranium resources are estimated quantities recoverable by mining. Reserves shown as of 1 January 1980; other resources as of 7 October 1980. Tons UsOa probability distribution values.

$ 6.80/kg.

Includes lower cost'esource categories.

$ 13.60/kg.

$ 22.65/kg.

$ 45.30/kg..-

Conversion Factors: to convert lb to kg, multiply by 0.454.

to convert tons to tonnes, multiply by 0.907..

Host of the uranium resources are located in a few areas in the Colorado Plateau of New Mexico, Arizona, Colorado, and Utah, in the Wyoming Basins, and in the Texas Gulf Coastal Plain (Figs. 8.2 and 8.3). It should be noted that the reserve estimates in Table 8.8 were as of 1 January 1980, and the lower cost reserves have undoubtedly decreased since that date because of continuing rising costs.

8-15 SOsSIll os O rn Colossi l 100rsl AOC CI II TII Ol CSSIOSAO Ssssllo 0

0 ~s IO 01 rR FACSFsc COIAT FIAIOS Colll l ass lo SMIOO A Clollll1001MIOS 0 Cool OC 0 OI VAOA 0

IC 0

ISS 40 ~s ss ss II FFF lllo IOSIILAOOS SOSO 0S aC 0 sssl 0 COI00000 107 IOS Plllllo So ll SI1 OS) 10 COllllLPLlso 111 01 1

AIA5SA 2

os TOTALS ITSSOUSANOS OP TONS USOSI PAOSAOL! lss?0

~ OSSIOLS Sl1 SPECVLATIVE SST Al ol I OI00 Fig. 8.2. Potential Uranium Resources by Region ($ 22.65/kg;

$ 50/lb of UBOG);

SPOKA Y/YOMING BASINS POIVOEA RIVE CROOKS GAPy + SSIIA LET BASIN P FRONT RANGE BIGINO. ~

I CAATT>>OOG" URAVAN MINERAL BELT SHA<<

GRANTS

'sL

~ MINERAL BELT COLORAOO P PLATEAO P TEXAS COASTAL PLAIN GEOLOGIC PAOVINCE KAANES~gg F LOB IO A

.C, 4>, QPIIOSPHATES LIVE OAK Q URANIUM AAEA Fig. 8.3. Uranium Areas of the United States.

8-16 8.5.2 Uranium Ex loration Activities Uranium exploration in the United States reached its all-time high in 1978 as measured by the principal exploration indicator, surface drilling. Data provided to DOE by the exploration companies indicated a total of 14.6 million meters of drilling in 1978. In 1979, however, drilling declined to 12.5 million meters and the downward trend steepened during 1980 with drilling estimated to be approximately 8.5 million meters for the year (Fig. 8.4).

~ t. R6 ACTUAL

~ ttt mm a PLANNED 1979

~ ~~ tt ~~ PLANNcO 1960 1960 ESTIMATE Etwnditt(n ~

200 3

160 cn Z

O Ttttl OUI'Q 720 >

IlQ OIYtlOphlttl (t t ~

tt gZ 80 OLRI t9 O

20 Eti&NlbnONVQ0 1966 1968 1970 1972 1976 1976 1976 1980 YEAR 0

Fig. 8.4. U.S. Exploration Activity and Plans. (To convert ft. to m, multiply by 0.3048.)

Annual gross additions to reserves, a measure of exploration success, have been at high levels for the higher cost, i.e., $ 13.60 to $ 22.65 per kilogram UsOa categories, but have been decreasing for lower cost levels. Costs have increased significantly in recent years raising the quality

~ of resources needed to produce at a given cost level and reducing the quantities available at that level. For example, in 1979 only 907 tonnes (1000 tons) were added to $ 6.80 ($ 15) cost revenues, but 47,164 tonnes (52,000 tons) were removed, largely because of inflation, and an additional 12,698 tonnes (14,000 tons) were depleted by production. Hence, in 1979, $ 6.80 ($ 15) reserves decreased from 263,030 to 204.075 tonnes (290,000 to 225,000 tons). This trend continued in 1980. On the other hand, in 1979 some 84,351 tonnes (93,000 tons) were added to $ 22.65 ($ 50) reserves and 69,839 tonnes (77,000 tons) removed for a net increase of 14,512 tonnes (16,000 tons)

U30a ~ Thus, while exploration has been successful, the costs of producing the resound'ces found are high in comparison with current prices and concurrently the cost of producing previously found resources has also increased.

The sharp rise in exploration resulted from the increase in prices in the 1974 to 1976 period, the active procurement activity of utilities, and the optimistic progections of future growth in uranium demand. Many new companies became acti.ve in exploration. More than 150 comp'anies were involved in exploration in 1979. ,Considering the drop in requirement projections, the level of activity reached probably was in excess of real needs. Therefore, some reduction of effort more in line with future needs is not detrimental.

8-17 Domestic uranium production in 1980 was 19,573 tonnes (21,850 tons) UsOa in concentrate. This represents a 15K increase over 1979 and is the highest U.S. production level for any single year. Production in recent months has been at record rates; the equivalent of more than 19,954 tonnes (22,000 tons) UsOa per year. This production comes from conventional mine-mill operations as well as from such nonconventional sources as solution mining and byproduct recovery from processing of other minerals. The high production levels are in response to prior sales contracts. Buyers are actually receiving uranium in excess of their currently scheduled needs.

Several new uranium processing facilities are under construction or planned, which could bring the total national, capacity'o around 27,000 tonnes (30,000 tons) per year by the mid-1980s.

Despite the increases in ore throughput and uranium production in 1980, a widespread curtailment of uranium mining and milling activities is underway. Production at some operating mines has been reduced and some planned mill expansions and construction are being postponed. The reduc-tion in mine output will not be reflected in decreased uranium production until mine and mill ore stockpiles are reduced.

Studies have been conducted on attainable uranium production levels from uranium reserves in the United States and related costs. The uranium production capability projections should not be construed as being estimates of actual future supply, but simply as potential production that may be available to meet whatever demand eventually exists.

Using the "production center" concept, U.S. uranium production capability has been projected from ore reserves estimated as of January 1980, to be available at forward costs of $ 13.60 to $ 22.65 per kilogram UsOa or less. The production centers consist of operating (Class 1),

committed (Class 2), planned (Class 3) uranium extraction and processing facilities, and pro-jected (Class 4) facilities based on probable potential resources. The study included conven-tional mills supplied by open-pit and/or underground mines; solution mining and heap-leach operations; and operations where uranium'is recovered as a byproduct of phosphate, copper, or beryllium mining and processing. activities.

Projections are based primarily on .operating conditions average ore grades, mill recoveries, and operating and capital costs--similar to those currently prevalent in the uranium mining and milling industry. Specific information on 'company plans, costs, 'and 'operating methods has been considered.,

Figure 8.5 shows the total projected'production capability for $ 13.60 ($ 30) resources by resource category. Figure 8.6 shows the capability for $ 22.65 ($ 50) resources. Projected uranium demand and current sales coneitments are also shown. Domestic demand is based on the DOE's Office of Uranium Resources and Enrichment (URE) 1980 nuclear-power growth projections, assuming no repro-cessing and a 0.20% U-235 enrichment tails assay.

8.5.4 Domestic Reactor Re uirements The outlook for uranium requirements is closely related to the growth of nuclear power. On 1 December 1980, 75 nuclear power reactors were licensed to operate in the United States, concentrated mostly in the East and Midwest. These plants have an electrical genera'ting capa-city of 55 GMe. In addition to operating plants, 86 plants are under construction with a total rated capacity of 95 GWe. Some of the plants are at such an early construction stage that they may be deferred or canceled completely. An additional 17 reactors with 20 GWe capacity are on order. Together the group aggregates 170 GWe of capacity. Mowever, the future for some of the ordered reactors is questionable.

Latest projections of nuclear-power growth by URE and the Energy Information Administration (EIA) (Table 8.9) show an increase in nuclear power licensed to operate from 55 GWe at the end of 1980 to 96 GWe in 1985, 129 GWe in 1990, 155 GWe in 1995, and 180 GWe in 2000. EIA also projected a low case of 160 GWe and a high case of 200 GWe for the year 2000.

There are alternative views on U.S. power growth. The DOE's Office of Planning and Analysis has projected nuclear growth to the year 1990 at 125 GMe and to the year 2000 at 150 GWe, based on historic delays to nuclear power growth. The DOE Office of the Assistant Secretary of Nuclear Energy has projected 400 GWe, based on energy demand, growth, nuclear competitiveness, and industry construction capability. All of these values are sharply reduced from the projected growth of the nuclear industry of just a few years ago. For example, in 1976 UPS. nuclear capacity in the year 2000 had been projected to be 500 GWe, and in 1978 it had been projected to be 320 GMe.

8-18 70 60

~!'"

Cias s 1-3, without expansions Class4 and Classes 1-3 expansions EG

/

otr n 50 X .c"~ o~'cP D"n 40 Z

0

+ 30 20 Probable'otential'eserves 10 80 82 84 86 88 90 92 94 96 98 00 02 04 06 08 09 YEAR Fig. 8,5. Estimated Annual Near-term Production Capability from Resources Available at $ 13.60/kg of.Us0a or Less with Class 1, 2, and 3 Expansions and Class 4.

120 Uranium requirements based on URE enrichment planning cases at 0.20% tails assay' 100 eo a 1

80 1 I- Fro rn pos sibl'e an Z spec ulativ e res ou O

Z 60 gj)6 ~ ntao~~;.:.

0 From V

Z probab potent le~ r 40 0

8 th Z 20 ,~A.

0 I

From reserves ~ 4r 1980 1990 2000 2010 2019 YEAR Fig. 8.6. Annual Production Capability from Resources Available at $ 22.65/kg of Us06 or Less Projected to Neet Nuclear-Power Growth Oemand.

8-19 Table 8.9. U.S. Nuclear-Power Growth Projections, June 1980 Power Ran e GWe End of Year Low Mid 'igh 1985 85 96 105 1990 125 129 140 1995 142 155 165 2000 160 180 200 Even at the more conservative estimates, nuclear capacity still is expected to expand substan-tially and to provide a significant portion of future domestic electric capacity. Current methods of proiecting nuclear growth and uranium requirements are based on estimates of reactor startup dates considering construction and licensing times, and systems power requirements.

Accurate forecasts have proven to be difficult.

The uranium needed to be delivered by uranium concentrate-producing plants as fuel for the nuclear plants will also increase over time; for the URE mid-case, from 12,063 tonnes (13,300 tons)

U30a in 1981 to 21,405 (23,600) in 1985, 26,212 (28,900) in 1990, 31,745 tonnes (35,000 tons) in 1995, and 36,280 tonnes (40,000 tons) in 2000, U-235 tails assay.

if the enrichment plants are operated at 0.20%

Cumulative uranium requirements through the year 2000 range from 462,570 to 562,340 tonnes (510,000 to 620,000 tons) UaOa with 516,990 tonnes (570,000 tons) UsOa for the mid-case.

Uranium requirements are based on normal lead times for fuel-cycle steps and current technology for enrichment and for reactor design and operation. There are possible improvements in enrich-ment that would allow use of lower tails assays, which, would reduce uranium requirements. 1'here are also possible improvements to reactor design and operation that could reduce uranium require-ments. These factors are not likely to have a significant impact on uranium demands until at least well into the 1990s.

8.5.5 Uranium Inventories Buyers'nventories of uranium have been increasing for several years as actual deliveries have been in excess of needs. Inventories at the beginning of 1980 totalled .32,742 tonnes (36,100 tons) of natural uranium (Table 8.10), with .25,033 tonnes (27,600 tons) held by utilities. In 1980, U.S. utilities sent an equivalent of 15,691 tonnes (17,300 tons) UsOa to the DOE gaseous dif-fusion plants for enrichment. Thus, the 25,033 tonnes (27,600 tons) inventory level amounted to 1.6 years of U.S. utilities'eeds. Of those UPS. utilities that responded to questions on inventory levels, most indicated that they desire a level amounting to about one year's needs, although some reported inventory levels as small as three month's needs, while others desire inventories as great as two year's needs. Producers also had inventories of about 2,177 tonnes (2,400 tons) UsOa at the beginning of 1980, which is about a normal working inventory. The outlook, is for a continuing buildup of buyers'nventories, as current contracted deliveries are in excess of actual needs.

Table 8.10. Buyers'nventories of Natural Uranium in Tons UsOa Beginning of Domestic Foreign Year Origin Origin Total 1976 22,600 1,100 23,700 1977 25,800 3,500 29,300 1978 25,100 3,600 28,700 1979 28,000 5,200 33,200 1980 30,800 5,300 36,100 Conversion Factor: to convert tons to tonnes, multiply by 0.907.

8-20 8.5.6 Anal sis of Production Ca abilit and Reactor Ca acit Study of attainable production capability from currently estimated $ 13.60 ($ 30) U.S. ore reserves and probable potential resource indicates that production levels of 40,815 tonnes (45,000 tons)

U30Q per year. can be achieved with aggressive resource development and exploitation, including both mining and milling. Although the level may be achieved by use of domestic $ 13.60 ($ 30) ore reserves and probable resources alone, development and utilization of $ 30 possible and specu-lative categories and use of $ 22.65 ($ 50) ore reserves and potential resources would provide added assurance that the levels could be attained and sustained. Considering the use of $ 22.65

($ 50) resource, a level of 54,240 tonnes (60,000-tons) per year supply is achievable from currently estimated resources. Such a level could be reached by the early 1990s. Imported uranium and inventories would add to the supply from these projections.

The level of nuclear generating capacity supportable with 54,240 tonnes (60,000 tons) per year of uranium, will vary with enrichment tails assay and recycle assumptions. Without recycle of uranium or plutonium and with a 0.30K U-235 enrichment tails assay, about 260,000 HWe could be supported. Without recycle and at 0.20$ tails assay, about 310,000 HWe could be supported.

With recycle of uranium and plutonium and a 0.20% tails assay, about 520,000 HWe could be supported.

All the levels of supportable capacity are above the 170,000 HWe of capacity in oper ation (55,000 HWe), under construction (95,000 MWe), and on order (20,000 HWe), as of late 1980.

Thus, currently estimated resources can provide'dequate uranium supplies for a sizable expan-sion to U.S. nuclear generating capacity.

The cumulative lifetime (30 years) uranium requirements for all of the above reactors (170,000 HWe) would be about 0.907 million tonnes (1.0 million tons) UsOa at 0.20% enrichment tails with no recycle, compared to the 1.45 million tonnes (1 6 million tons) mean value in $ 13.60 [($ 30) or

~

the 2.27 million tonnes at $ 22.65 (2.5 million tons at $ 50)] ore reserves, by-product, and probable potential resources. Evaluation of long-term fuel comnitments on the basis of ore reserves and probable potential resources is considered a prudent course for planning. The lifetime commitment would be less than one third of currently estimated $ 22.65 ($ 50) domestic resources, including the possible and speculative categories (see Table 8.8).

8 '.7 Uranium Resource Recover In regard to the availability of estimated uranium resources considering recoveries in mining and ore processing, estimates of U.S. uranium resources represent the quantity of uranium esti-mated to be minable expressed as tons of UsOa 'of ore in the ground, These estimates are a reflection of the information available to DOE at the time of the estimate; thus, they are dependent on the extent of exploration. In view of the considerations involved in preparing the resource estimates and the uranium resource outlook, no adjustment for losses is warranted.

U.S. mining practice results in recovery of high percentages of the uranium contained in a deposit. DOE resource estimation procedures consider the capabilities and requirements of mining systems currently in use so that the estimates are a realistic appraisal of what is minable. Because deposits frequently are not fully delineated before they are developed, not unusual for more uranium to be recovered from deposits than was included in ore reserves it is before such deposits were put into production. Mining company practice seeks to recover as much of the contained mineral content as possible before abandoning a mine. A strong incentive for such practice is 'the increase in financial returns. In the processing of uranium ores, recoveries generally are over 90%; in 1980, mill recovery averaged about 93K. Higher recoveries are usually possible if economically justified.

8.5.8 Hi h Cost Resources, An alternative 'to identification of additional low-cost resources is the utilization of higher cost resources. The highest cutoff cost category included in DOE resources in Table 8.8 is

$ 45.30/kg of UsOa. This level is an upper range of what might be of interest for utilization in light water reactors over the next few decades.

The increased price of oil and coal, in the last few years has been a contributing factor to the increased price of uranium economically acceptable in light water reactors. This impact results from the relative insensitivity of nuclear electric power costs to increases in uranium prices.

The cost of fuel is a very small fraction of the cost of power from a nuclear plant. In turn,

, the cost of natural uranium is only a small fraction of the fuel cost; enrichment,,fabrication, reprocessing, and carrying charges make up the balance. As a result, large increases in uranium prices result in comparatively small increases in power costs. As pointed out in Section 8.5.6, nuclear capacity currently in operation, under con'struction, and on order is expected to have adequate supplies of UsOa at prices much lower than $ 45.30/kg in 1980 dollars.

I Knowledge 8-21 of U.S. resources in the above $ 22.65 ($ 50) category is meager, largely because of the lack of past economic interest. There has been virtually no industry activity to search for or to develop such resources. Prospects for discovery of higher cost resources in the United States are considered promising at this stage of U.S. exploration. The principal large, very low-grade deposits that have been studied in some detail in the past are the shales and phos-phates ~ The Chattanooga shale in Tennessee is of particular interest because of its large size.

This deposit was extensively drilled, sampled, and studied in the 1950s. The higher grade part of the Chattanooga shale has an average uranium content of about 60 to 80 ppm compared to 1500 ppm in present-day ores. It contains in excess of 4 ' million tonnes (5 million tons) of UsOa that may be producible at a cost of $ 45.30 or more per kilogram of UsOa. Additional work to develop production technology will be needed.

If Chattanooga shale were mined to fuel an 1150-NWe reactor, assuming recycle of uranium (but not of plutonium) and a 0.3X enrichment tail, about 11,428 tonnes (12,600 tons) of shale would have to be processed. each day; with uranium and plutonium recycle (should that be practiced) and 0.20K enrichment tails, about 7,710 tonnes (8500,tons) per day would have to be processed. An average of about 10,250 tonnes (11,300 tons) of coal would have to be burned each day if 20 HJ/kg of coal were used to p'roduce power equivalent to that produced by a 1150-NWe reactor .

Utilization of the very low-grade resources such as Chattanooga shale would, of course, involve mining and processing very much larger quantities of ore than is currently mined to produce the same amount of uranium. From an environmental as well as from an economic point of view, identification and utilization of additional higher grade ores would be preferable. However, the shales are available if their use should become necessary.

8.5 ' Prices During the period 1973-1979, the average delivery price per kilogram of UsOa for sales from domestic producers to domestic buyers, in year-of-delivery dollars, increased from $ 3.22'o

$ 10.80, as shown in Table F 11.

I Table 8.11. Historical Trend of Average Uranium Prices Year Final Price 1973 3.22 1974 3.58 1975 4.76 1976 7.30 1977 8.95 1978 9.78 1979 10.80 In dollars/kg in year-of-delivery dollars.

Future prices for material under contract as of 1 July 1980, as reported to DOE, is shown in Table 8.12. Also shown are the percentages of material under contract price arrangements covering the price presented. The remainder is in market price contracts or in captive production.

8.5.10 Forei n Uranium Resource Position The most reliable source of information on world uranium resources is that compiled by the Working Party on Uranium Resources sponsored jointly by the Nuclear Energy Agency (NEA) and the International Atomic Energy Agency (IAEA). This group has'een gathering and publishing uranium resource estimates since 1965 and includes most of the significant uranium resource countries.

In compiling its estimates, this group classifies resources as "reasonably assured" resources

4 8-22 Table 8.12. Average Contract Prices and Settled Market Price Contracts for Uranium, 1 July 1980 Percentages of Procurement under Contract Price Year pricea Contracts 1980 11.78 66 1981 13.00 55 1982 15.76 47 1983 18.75 43 1984 19.68 35 1985 19.68 32 1986 21.22 16 1987 19 '3 18'2 1988 19.34 1989 '3.49 23 1990 24.12 16 In dollars/kg in year-of-delivery dollars.

These years include settled market price contracts. Market price contract prices are determined sometime before delivery, based on prevailing market prices.

(roughly comparable to ore reserves in the usual mining industry sense) and "estimated addi-tional" resources (roughly comparable to DOE's probable potential resources). Resources in the world outside'f the centrally planned economies area (WOCA) are tabulated by continents and major countries in Table 8.13.

Almost 80% of these resources are concentrated in three continents: North America, Africa, and Australia. Six countries, within those continents the United States, Canada, South Africa, Namibia, Niger, and Australia--have about three quarters of the reasonably assured resources.

This geographic concentration is a reflection of the geologic favorability of these areas as well as the extent of exploration and resource appraisal efforts to date.

8.5.11 Forei n Production Ca acit and Plans Studies by the NEA and the IAEA have also provided reliable information on world production capacity. The current production capacity of existing non-U.S. plants (Class 1) is about 34,466 tonnes (38,000 tons) UsOa annually, as shown in Table 8.14.. This production is primarily in Canada, France, Namibia, Niger, and South Africa.

Construction of new plants, (Class 2) with a capacity of about 7,256 additional tonnes (8,000 tons) is taking place, primarily in Australia and Canada. Plants that are planned (Class 3), could increase total annual production by another 32,652 tonnes (36,000 tons) UsOa for a total of 76,188 tonnes (84,000 tons) UsOa by 1990. Since needs for uranium are well below attainable production capacity levels, and prices would not justify all operations, it is likely that many of the projected plants will be built on a deferred schedule. It is also possible that some new plants will replace existing operations. Countries of particular significance in future pro-duction expansion are Australia and Canada, which have 82K of capacity under construction and 70K of the planned additional capacity.

8.5.12 Forei n Reactor Re uireme'nts The uranium requirements in non-Communist foreign countries have been projected by the Energy Information Administration based on the reactors planned and timing of construction. Table 8.15 shows three cases of power plant growth which, by the year 2000, range from 300 to 400 GWe of

8-23 Table 8.13. World Uranium Resources by Continent Reasonabl Assured Estimated Additional Continent $ 30/lb $ 50/lb $ 30/lb $ 50/lb North America United States 645 940 885 1,430 Canada 280 305 480 945 Other 9 44 44 65 Total 930 1 gg90 1,410 2,440 Africa South Africa 320 508 70 180 Niger 210 210 69 69 Namibia 152 173 39 69 Other 109 115 2 22 Total 790 1,000 180 340 Australia Total 380 390 165 180

~Euro e France 51 72 34 60 Spain 13 13 ll ll Sweden 1 390 0 4 Other 22 31 19- 53 Total 90 510 60 130 Asia India 39 39 1 31 Other 13 21 0 0 Total 50 60 0 30 South America Brazil 96 96 117 117 Argentina 30 36 5 12 Other 0 0 7 8 Total 130 130 130 140 Worldwide total (rounded) 2,400 3,400 1,900 3,300 Modified from "Uranium Resources, Production and Demand" OECD, Nuclear Energy Agency (NEA), and the International Atomic Energy Agency (IAEA), December 1979. "World" refers to world outside centrally. planned economic area. Resources given in 1000 tons UsOa.

b Includes resources at $ 30 per pound of UsOa.

Conversion Factors: to convert tons to tonnes, multiply by 0.907 to convert $ /lb to $ /kg, multiply by 0.453. a

Table 8;14. Foreign Uranium Production Capability Canada France NamiMa ~Ni er S. Africa 1 2 3 1 2 3 1 2 3 1 2 3 1 2 3 1 2 3 1 2 3 1980 '.3 0 0 9.8 0 0 45- 0 0 5.3 0 0 5.2 0 0 8.3 0 0 4.1 0 0 38.5 0 0 1981 18 11 0 9.8 1.4 0 4.5 0.2 0 5.3 0 0 5.2 0 0 8.3 0 1.2 4.1 0 0.8 = 39.0 2.7 2.0 1982 1.8 3.3 0 9.8 1.9 0 4.5 0.5 0 5.3 0 0 5.2 0 0 83 0 2.9 4.1 0 3.0 39.0 5.7 5.9 1983 1.8 3.3 0 10.5 1.9 2.0 4.5 0.7 =

0 5.3 0 1.2 5.2 0 0 8.3 0. 4.6 4.1 0 4.1 39.7 5.9 11.9 1984 1 8 3 3 0 11.0 2.9 4.0 4.5 0.7 0 5.3 0 1.2 5.2 0 0.7 8.3 0 5.2 4.1 .0 4.4 40.2 6.9 15.5 1985 1.8 3.3 6.5 12.0 2.9 5.0 4.5 0.7 0 5.3 0 1.2 5.2 0 2.5 8.3 0 5.5 4.1 0 5.1 41.2 6.9 25.8 1986 1.2 3.3 11.5 12.0 2.9 7.2 4.5 1.4 0 5.3 0 1.2 5.2 0 5.2 8.3 0 5.6 4.1 0 5.1 40.6 7.6 35.8 1987 1.2 3.3 11.5 12.0 2.9 7.2 4.5 1.4 0 5.3 0 1.2 5.2 0 5.2 8.3 0 5.6 4.1 0 5.2 40.6 7.6 35.9 1988 1.2 3.3 11.5 12.0 2.9 7.2 4.5 1.4 0 5.3 0 1.2 5.2 0 5.2 8 3 0 5.5 4.1 0 5.3 40.6 7.6 35.9 1989 1.2 3.3 11.5 12.0 2.9 7.2 4.5 1.4 0 5.3 0 .

1.2 5.2 0 5 2 8 3 0 5.5 4.1 0 5.4 40.6 7.6 36.0 1990 1.2 3.3 11.5 12.0 2.9 7.2 4.5 1.4 0 5.3 0 1.2 5.2 0 5.2 8.3 0 5.2 4.1 0 5.5 40.6 7.6 35.8 Total 84.0 In thousand tons UsOa per year.

Class: 1. Currently operating plants

2. Plants under construction

3. Planned plants Includes Argentina, Brazil, CAR, Gabon. India, Italy, Hexico, Portugal, Spain, Yugoslavia. Based on "Uranium Resources, Producti'on and Demand,"

December 1979.

Conversion Factor: to convert tons to tonnes, multiply by 0.907.

8-25 Table 8.15. Foreign Nuclear Capacity and Uranium Requirements Capacity Requirements tons U 0 Year Low Hid High 'ow Hid High 1980 66 68 77 17,300 18,400 19,800 1985 117 124 128 24;000 26,200 295200 1990 165 181 201 27,500 310600 32,700 1995 229 252 280 34,600 41,500 47,800 2000 300 350 400 42,700 54,100 64,300 0.20Ã U-235 tails assay.

Conversion Factor: to convert tons to tonnes, multiply by 0.907.

nuclear power in operation. The mid-case is taken as the most likely one. However, nuclear power growth projections have been subject to continual downward revision in the last several years.

In or'der to supply these nuclear plants, EIA has estimated the amount of uranium required assuming 0.205 U-235 enrichment plant tails and no recycle of uranium or plutonium. Table 8.15 gives the annual tons UsOa from 1980 to 2000 for high-, mid-, and low-cases.

For the mid-case foreign requirements increase from 16,689 tonnes (18,400 tons) UsOa in 1980 to 23,763 tonnes (26,200 tons) UsOa in 1985, and to 49,069 tonnes (54,100 tons) UsOa in the year 2000. Cumulative requirements through the year 2000 total 650,319 tonnes (717,000 tons) UsOa.

If all the planned foreign mine-mill production came on-stream as currently projected, there would be considerable excess capacity. If only operating mills or those under construction were available by the late 1980s, production capacity would cover annual demands through the late 1990s.

Additional projections of WOCA nuclear growth and uranium requirements were developed during the International Nuclear Fuel Cycle Evaluation (INFCE). While the projections are now considered as high by many, they do provide an additional, more optimistic, vfewpoint on future nuclear rowth. The INFCE low case modified to exclude the United States--indicated a growth in foreign WOCA) nuclear capacity, from 82 GWe at the end of 1980 to 217 GWe in 1990 and to 580 GWe in the year 2000, Corresponding foreign uranium requirements would be 19,047 tonnes (21,000 tons) in 1980, 45,350 tonnes (50,000 tons) in 1990, and 108,840 tonnes (120,000 tons) in 2000. Such projections indicate a much larger possible growth in future uranium demands.

8.5.13 Forei n Com etition and the Domestic Industr The concentration of world uranium resources and production has, in past periods of low prices and ore production, fostered attempts to form cartel-like organizations seeking to restrict the, free movement of uranium and influence pricing. The concentration of uranium production in a few countries will continue for, some time, though there is an increasing diversity of supply sources. The opportunity for future foreign cartel-like activities will continue, particularly if uranium producer country governments are involved, which has been the case in the past. How-ever, the severe criticism of such practice and the legal actions that have resulted in the United States might operate to discourage such activities in the future. Since the United States has the capability of producing a large portion, or all, of its uranium needs, and since United States uranium buyers historically have shown a strong preference for domestic uranium, the United States is not expected to develop a large dependence on foreign uranium. These fac-tors would tend to reduce the susceptibil.ity of the United States to direct impacts of any cartel-like activity.

8.5.14 Conclusions In conclusion, DOE assessment of uranium resources indicates'hat currently estimated ore reserves and probable potential resources at forward costs up to $ 13.60/kg UsOa total more than 1.36 mil-lion tonnes (1.5 million tons), and at forward costs up to $ 22.65/kg Us0a total almost 2.17 million

8-26 tonnes (2.4 million tons). The 2.17 million tonnes (2.4 million tons) U30a will support 390 GWe of nuclear power generating capacity, assuming a 30-year life for the reactors, no spent fuel reprocessing and an enrichment plant tails assay of 0:20% U-235. Under the latest DOE forecast for nuclear generating capacity in the post-2000 period, these resources should support U.S.

.nuclear power growth, including SSES 1 and 2, well into the next century. However, meeting the uranium requirements for an expanding U.S. nuclear power industry will require extensive indus-try efforts to sustain exploration, and success in discovering and developing the potential uranium resources.

Foreign uranium resources are substantial and have been growing. Some of the more recently discovered .deposits, especially in Canada and Australia, will have comparatively low-cost uranium production. The staff, therefore, concludes that there will be sufficient nuclear fuel available for SSES 1 and 2.

8.6 DECOMMISSIONING Termination of a nuclear license is required at the end of facility life. Such termination requires decontamination of the facility so that the level of any residual radioactivity remaining at the site is low enough to allow either unrestricted use of the site for nuclear or nonnuclear purposes. The objective of NRC regulatory policy in decoranissioning nuclear facilities is to ensure that proper and explicit procedures are followed to mitigate any poten-tial for adverse impact on public health and safety or on the environment.

Three alternative methods can be and have been used to decomnission reactors.~s DECON means to remove inmediately all radioactive materials down to levels that would permit ttte property to be released for unrestricted use. SAFSTOR is defined as those activities required to place .

and maintain a radioactive facility in sucas condition that 1) the risk to safety is within accep-table bounds and 2) the facility can be safely stored for as long a time as desired and subse-quently decontaminated to levels that would permit release of the facility for unrestricted use. ENTOMB means to encase and maintain property in a strong and structurally long-lived materi~a to ensure retention until radioactivity decays to a level acceptable for releasing the facility for unrestricted use.

For a large BWR, DECON is estimated to cost $ 43.6 million (in 1978 dollars); SAFSTOR is estimated to cost $ 59.9 million with a 30-yr s'afe-storage period and $ 55.6 million with a 100-yr safe- .

storage period. ENTOMB is estimated to cost $ 35.0 million with the pressure vessel and its internals retained and $ 41.7 million with the pressure vessel and internals removed; a $ 40,000 annual maintenance and surveillance cost would be added in both cases. Either ENTOMB option requires indefinite dedication of the site as a radioactive waste burial ground. The security of the site could not be assured for thousands of 'years necessary for radioactive decay so this option will probably,not be. viable.

Although DECON is less costly, than SAFSTOR, it results in slightly higher radiation exposures to the decommissioning workers and to the public. The person-rem of occupational exposure is estimated at 1955 for DECON as compared to 442 for 30-year SAFSTOR and 1624 for ENTOMB (inter-nals retained). The person-rem exposure to the public is minimal for any of the alternatives:

10 for DECON, 2 for 30-year SAFSTOR, or 5 for ENTOMB.

Radiation doses to the public as a result of decomnissioning activities should be very small and would come primarily from the transportation of decorenissioning Haste to waste burial grounds.

Radiation doses to decoranissioning workers should be a small fraction of the exposure they experience over the operating lifetime of the facility; these doses will usually be well within the occupational exposure limits imposed by regulatory requirements.

Decoranissioning of nuclear facilities is not an inIIinent health'nd safety problem. However,-

planning for decoranissioning can have an impact on health and safety as well as cost. Essen-tial to such planning activity is the deconmissioning alternative to be used and the timing.

Also to be considered are 1) acceptable residual radioactivity levels for unrestricted use of the facility, 2) financial assurance that funds will be available for performing required deconmissioning activities at the end of the facility operation (including permature closure),

and 3) the facilitation of decoranissioning.

V Decoranissioning of a nuclear facility generally has a positive environmental'impact. Compared to operational requirements, the comnitment of resources for decoranissioning is generally small. The major environmental impa'ct of decoranissioning is the comnitment of small amounts of land for the burial of waste. This is in exchange for being able to reuse the facility and site for other nuclear or nonnuclear purposes. Because the land has valuable resource capability, in many instances (such as at a reactor facility) the return of this land to the coamercial or public sector is highly desirable.

8-27

~ 8.7 ENERGENCY PLANNING In connection with the promulgation of the Coamission's upgraded emergency planning require-ments, the staff (Office of Standards Development) issued NUREG-0685, "Environmental Assessment for Effective Changes to 10 CFR Part 50 and Appendix E to 10 CFR Part 50; Emergency Planning Requirements for Nuclear Power Plants," (August 1980). At this time, how'ever, the staff does not have sufficient information to determine whether any environmental impacts will result from implementation by the applicant of the upgraded emergency planning requirements in 10 CFR Part 50, Appendix E, such as construction of a near-site emergency operations facility and the conduct of emergency preparedness exercises. Upon receipt of all components of the applicant's emergency plan and implementing procedures, the staff will be in a position to determine whether or not such plan and implementing procedures will result in significant environmental impacts. The NRC staff will discuss emergency planning in a Supplement to the Safety Evaluation Report.

References

1. L.D. Hamilton, ed., "The Health and Environmental Effects of Electricity Generation: A Preliminary Report," Brookhaven National Laboratory, Upton, NY, July 1974.

2. L.D. Hamilton and S.C. Morris, "Health Effects of Fossil Fuel Power Plants," In Popula-tion Exposures: Proceedings of the Eighth Midyear Topical Symposium of the Health Physics Society," October 1974.

3. L.D. Hamilton, "Energy and Health," In Proceedings of the Connecticut Conference on Energy, December 1975.

4. S.C. Morris and K.M. Novak, "Handbook for the t)uantification of Health Effects from Coal Energy Systems'(Draft)," Brookhaven National Laboratory, Upton, NY, December 1976.

5. A.J. Dvorak et al., "Health and Ecological Effects of Coal Utilization (Draft)," Argonne National Laboratory, Argonne, IL, November 1976.

6. "An Assessment of the Health and Environmental Impacts of Fluidized-Bed Combustion Coal as Applied to Electrical Utility Systems (Draft)," Argonne National Laboratory, Argonne, IL, January 1977.

7. U.S . Nuclear Regulatory Comission, "Final Generic Environmental Statement on the Use of Recycle Plutonium in Mixed Oxide Fuel in Light Water Cooled Reactors," NUREG-0002, August 1976.*

8. U.S. Nuclear Regulatory Comnission, "Reactor Safety Study," WASH-1400 (NUREG-75/014),

October 1975.**

9. U.S. Atomic Energy Comnission, "The Safety of Nuclear Power Reactors (Light Hater-Cooled) and Related Facilities," WASH-1250, July 1973.

10. C.L. Comar and L.A. Sagan, "Health Effects of Energy Production and Conversion,"

pp. 581-600 In J. M. Hollander, ed., Annual Review of Energy, vol. 1, 1976.

ll. D.J. Rose, P.W. Walsh, and L.L. Leskovjan, "Nuclear Power--Compared to Whatf" Am. Sci.

64: 291-299, 1976.

12. D. Grahn, "Cost-Benefit as Weighed on Genetic Scales," In R.A. Karan .and K.Z. Morgan, eds., Energy and the Environment: Cost-Benefit Analysis, Pergamon: NY, pp. 371-386.

1976.

13. Council on Environmental guality, "Energy and the Environment," August 1973, p. 43.

14. D.F.S. Natusch, J.R. Wallace, and C.A. Evans, "Toxic Trace Elements: Preferential Concentration in Respirable Particles," Science 183: 202-204, 1974.

15. S.T. Cuffe and R.W. Gerstle, "Emissions from Coal-Fired Power Plants: A Comprehensive Suranary," U.S. Department of Health, Education, and Welfare, Public Health Service, PHS-999-AP-35, 1967.

8-28

16. J.E. Martin, E.D. Harward, and D.T. Oakley, "Radiation Doses from Fossil Fuel and Nuclear Power Plants," In D.A. Berkowits and A.M. Squires, eds., Power Generation and Environmen-tal Change, MIT Press: Cambridge, MA, 1971.

17. Comnittee on Natural Resources, National Academy of Sciences, National Research Council, "Air Quality and Stationary, Source Emission Control," prepared for the U.S. Senate Committee on Public Works, Serial No. 94.4, March 19?5, pp. 599-610.

18. L.B. Lave and E.P. Seskin, "An Analysis of the Association Between U.S. Mortality and Air Pollution," J. Am. Stat. Assoc. 68: 284-290, 1970.

19. W. Winkelstein, Jr., et al., "The Relationship of Air Pollution and Economic Status to Total Mortality and Selected Respiratory System Mortality," In Men: I. Suspended Parti-culates, Arch. Environ. Health 14: 162-171, 1967.

20. Ministry of Health, "Mortality and Morbidity during the London Fog of December 1952,"

Report No. 95; London, Her Majesty's Stationery Office, 1954.

21. H.HE Schrenk, et al., "Air Pollution in Donora: Epidemiology of the Unusual Smog Episode of October 1948," Preliminary Report, Public Health Bulletin No. 306, 1959.

22. H. Schimmel and L. Greensburg, "A Study of the Relation of Pollution to Mortality; New York City, 1963-1968," J. Am Polit. Contr. Assoc. 22(8): 607-616, 1972.

. 23. C. Normal, "Castles in the Air," Nature 264: 394, 1976.

24. L.A. Sagan, "Health Costs Associated with the Mining, Transport and Combustion of Coal in the Steam-Electric Industry," Nature 250: 107-111, 1974.

25. B. Coneoner, The Poverty of Power, Alfred A. Knopf: NY, May 1976.

26. J.E. Yocon and N. Grappone, "Effects of Power Plant Emission on Materials." Research Corporation of New England for the Electric Power Research Institute, July 1976.

27. S.M. Barrager, B.R. Jedd, and D.W. North, "The Economic and Social Costs of Coal and Nuclear Electric Generation," Stanford Research Institute, March 1976.,

28. D,W. North and M.W. Merkhofer, "A Methodology for Analyzing Emission Control Strategies,"

Comput. Oper. Res. 3: 187-207, 1976.

29. C.F. Baes, Jr., et al., "The Global Carbon Dioxide Problem," ORNL-5194, Oak Ridge National Laboratory, Oak Ridge, TN, August 1976.

30. R.O. Pohl, "Health Effects of Radon-222 from Uranium Mining," t Search 7(5):' 345-350 1976.

31. N.W. Denson, et al., "Uranium in Coal in the Western United States," U.S. Geological Survey Bulletin 1055, 1959.

32. R.F. Abernethy and F.H. Gibson, "Rare Elements in Coal," Information Circular 8163, U.S. Department of the Interior, Bureau of Mines, 1963.

33. M. Eisenbud and H.G. Petrow, "Radioactivity in the Atmospheric Effluents of Power Plants that Use Fossil Fuels," Science 148: 288-289, 1964.

34. L.B. Lave and L.C. Freeburg, "Health Effects of Electricity Generation from Coal, Oil and Nuclear Fuel," Nucl.. Saf. 14(5): 409-428, 1973.

35. U.S. Atomic Energy Comnission, "Comparative Risk-Cost Benefit Study of Alternative Sources of Electric Energy," HASH-1224, December 1974.

36. K.A. Hub and R.A. Schlenker, "Health Effects of Alternative Means of Electrical Generation,"

In Population Dose Evaluation and Standards for Man and His Environment, International Atomic Energy Agency, Vienna, 19?4.

37. U.S. Department of the Interior, Bureau of Mines, "Mineral Facts and Problems," 1970, p. 230.

38. U.S. Atomic Energy Coranission, "Uranium Industry Seminar," Grand Junction, CO, Office, GJ0-108(74), October 1974.

39. U.S. Nuclear Regulatory Commission, "Draft Generic Environmental Impact Statement on Decommissioning of Nuclear Facilities," NUREG-0586, January 1981 P*

• val a e or pure ase from the National Technical Information Service, Springfield, VA 22161.

• +Available free upon written request to the Division of Technical Information and Document Control, U.S. Nuclear Regulatory Comnission, Washington, DC 20555.

9. BENEFIT-COST ANALYSIS' 9.1 RESUME.

The following sections suranarize the economic; environmental, and social benefits and cost's associated with the operation of Susquehanna Units 1 and 2. Table 9.1 suamarizes all benefits and costs of plant operation. Reduced generating costs are presented for the expected energy demand situation. The environmental costs are calcu'lated for an assumed worst-case situation.

9.2 BENEFITS The direct benefits, of the plant to the PJH interchange include the approximately 11.0 to 12.9 billion kWh of electrical power the plant will be able to produce on an annual basis (assuming a plant capacity factor of between 60% and 705), the increase in system reliability brought about by the addition of 1890 HW of generating capacity to 'the PJM interchange and 210 HW to the Cooperative, and the saving of $ 112 million in production costs per unit per year ($ 1980).'f "river-following" were to be undertaken by the applicant (see Appendix A, Sec. A.5.1), the staff has determined that occasional low-flow conditions resulting in forced outages would

'ause less than a 2C decrease in the direct energy benefit.

9.3 SOCIETAL COSTS No significant socioeconomic costs are expected from either station o'peration or station personnel and their families 'living in the area.

9.4 ECONOMIC COSTS The capital cost for completion of Susquehanna Units 1 and 2 is presently estimated to be $ 1833 million. Fuel and operation and maintenance costs for the first ful'1 year of operation of Unit 1 are estimated to be $ 51 and $ 22 million dollars, respectively; Decomnissioning costs for the complete restoration of the site are estimated at $ 78.5 million ($ 1980).

9. 5 ENV IRONHENTAL COSTS The environmental costs of most land-use, water-use, and biological effects previously evaluated have not increased or otherwise adversely changed. The staff review of the water-intake struc-ture revealed that there may be an increase in fish kills due to impingement and entrainment.

Chemical usage will result in a maximum discharge of. 1.4 x 10s kg of chemicals per year into the Susquehanna River. This discharge should not result in any adverse effects to the environment.

The heat discharge system will result in an average water consumption of 1.4 ms/s from evapora-tion and other uses. A maximum of 3.4 x 10>> J/hr will be rejected from the reactors into the Susquehanna River as heat. No adverse impacts are expected as a result of this discharge.

The design of the radioactive waste systems has been finalized. Under normal operation, each reactor will be in conformance with Appendix I to '10 CFR 50 and discharge a total of 17 curies of tritium and 0.46 curies of all other radionuclides to the Susquehanna River annually. Each reactor will also discharge approximately 19,000 curies of noble gases, 0.52 curfes of radio-iodines, 0.004 curies of radioactive particulates, 9.5 curies of carbon-l4, and 69 curies of tritium into the atmosphere surrounding the Susquehanna Steam Electric Station facility annually.

These effluents will result in a total body dose comnitment of 40 person-rem per year to the general public of the U.S, population in the unrestricted area. This dose coneitment will have no discernible effect on the population.

The operation of the Susquehanna facility, even for a brief period of time, will produce a radioactive structure requiring decommissioning and long-term protective storage. However, the 9-1

9-2 Table 9.1. Benefit-Cost Summary Primary Impact and Population or Resource Affected Unit Heasure Hagnitude of Impact Direct Benefits Energy kWh/yr x 10s 11,000 Capacity kw x 10s 2,100 Reduced generating costs $ (1980)/yr About $ 224,000,000 Economic Costs Operating:

Fuel $ (1980)/yr per 5ls000s000 unit Operation & maintenance $ (1980)/yr per 22,000,000 unit Decommissioning $ (1980) 78,500,000 Environmental Costs

1. Impa ct on water 1.1 Consumption (average) m>/s 1.4 1.2 Heat discharge to natural water body 1.2.1 Cooling capacity of water body J/hr 3.4 ~ 10~~ (maximum) 1.2.2 Aquatic biota Hinor, acceptable 1.2.3 Higratory fish- Minor, acceptable 1.3 Chemical discharge to natural water body 1:3.1 People Not discernible 1.3'.2 Aquatic biota 0 1.3.3 Water quality 0 1.3.4 Chemical discharge kg/yr 1,400,000 1.4 Radionuclide contamination of natural surface water body 1.4.1 All except tritium Ci/yr per reactor 0.46 1.4 ' Tritium Ci/yr per reactor 17.0 1.5 Chemical contamination of groundwater 1.5.1 People Not discernible 1.5.2 Plants Not discernible 1.6 Radionuclide contamination of groundwater 1.6.1 People 1.6.2 Plants andanimals 1.7 Raising/lowering of groundwater levels 1.7.1 People Not discernible 1.7.2 Plants Not discernible 1.8 Effects on natural water body of intake structure and condenser cooling systems 1.8.1 Primary producers and consumers Chemical discharges discernible but most likely of acceptable concentration 1.8.2 Fisheries Hinimal unless in-creased productivity caused by intake 1.9 Natural water drainage 1.9.1 Flood control No damage 1.9.2 Erosion control Insignificant

9-3 Table 9.1. (Cont'd)

Primary Impact and Population or Resource Affected Unit Heasure Hagnitude of Impact Environmental Costs (cont'd)

2. Impact on air 2.1 Chemical Discharge to ambient air 2.1.1 Air quality, chemical 2.1.1.1, CO kg/yr 2,900 2.1.1.2 SOz kg/yr Negligible 2.1.1.3 NOx kg/yr 8,700 2.1.1.4 Par ticulates kg/yr Negligible 2.1.1.5 HC kg/yr 130 2.1.2 Air quality, odor Negligible 2.2 Radionuclides discharged to ambient air 2.2.1 Noble gases Ci/yr per reactor 19,000 2.2.2 Radioiodines Ci/yr per reactor 0.52 2.2.3 Par ticulates Ci/yr per reactor 0.004 2.2.4 Carbon-14 Ci/yr per reactor 9.5 2.2.5 Tritium Ci/yr per reactor 69.0 2.3 Fogging and icing 2.3.1 Ground transportation None 2.3.2 Air transportation Negligible 2.3.3 Water transportation None 2.3.4 Plants Negligib'le 2.3.4.1 Cooling tower emissions Not discernible 2.3.4.2 Spray pond emissions Potential local ice-loading offsite 2.4 Salt discharge from cooling system 2.4.1 People Negligible 2.4.2 Plants and soil kg/ha per yr 28.0 (maximum), staff estimate kg/ha per mo 0.88 (maximum), appli-cant's estimate 2.4.3 Property Not discernible

3. Impacts on terrestrial systems 3.1 Station area 3.1.1 Proposed post-construction recla- Acceptable mation of station area (e.g.,

landscaping, erosion control) 3.2 Bird impingements on station Individual Unknown (to be facilities (e.g., cooling towers) impingements monitored)

4. Transmission line corridors 4.1 Right-of-way maintenance and inspection Acceptable 4.2 Production of ozone, other gaseous Inconsequential

.pollutants 4.3 Audible noise Hinimal 4.4 Radio and TV ingerference Individual Reception problems complaints resolved by applicant as necessary 4.5 Electrical field effects Acceptable

5. Total body dose coomitments to U.S. popula- person-rem/yr 65 tion general public, .unrestricted area Societal Costs

l. Operational fuel disposition 1.1 Fuel transport (new) Trucks/yr 10 1,2 Fuel storage 1.3 Waste products (spent fuel) Rail shipments/yr

2. Plant labor force people 200

3. Historical and archeological sites Acceptable

4. Station operational noise Sound level, dBA Acceptable with proper mitigation; to be monitored.

5. Esthetics 5.1 Visual impacts to station structures, Acceptable 5.2 Visual impacts to cooling tower plumes Acceptable 5.3 Visual impacts of transmission corridors Acceptable

9-4 nuclear waste associated with decemnissioning of the Susquehanna facility will be a small quan- '

tity compared to that already generated by coamercial and military nuclear applications.

9.6 ENVIRONMENTAL COSTS OF THE URANIUM FUEL CYCLE The contribution of environmental effects associated with the uranium fuel cycle is indicated in Table 4.16 and described in Section 4.5.6. The staff has evaluated the environmental impacts of the fuel-cycle releases presented in Table 4.16 and has found these impacts to be sufficiently small so that, when they are superimposed upon the other environmental impacts assessed with respect to the construction and operation of the plant, they do not affect the -benefit-cost balance.

9.7 ENVIRONMENTAL COSTS OF URANIUM FUEL TRANSPORTATION The contr'ibution of environmental effects associated with the transportation of fuel and waste to and from the facility are summarized in Section 4.5.2 and Table 4.13. These effects are sufficiently small so as not to affect the benefit-cost balance.

9.8

SUMMARY

OF BENEFIT-COST As a result of the analysis and review of potential environmenta'i, technical, economic, and social impacts, the staff has been able to forecast more accurately the effects of the station's operation. No new information has been acquired that would alter the overall balancing of the benefits of this station versus the environmental costs.- Consequently, the staff has determined that it would be possible to operate the station with only minimal environmental impacts. The staff believes that the primary benefits'of providing 2100 MW of electrical energy, minimizing system production costs, and increasing system reliability through the addition of 2100 MW baseload capacity will greatly outweigh the environmental, social, technical, and economic costs. Benefit-costs are sunmarized in Table 9,1, which is explained in Appendix E.

Reference

1. "Technology, Safety, and Cost of Oecoranissioning a Reference Boiling Water Reactor Power Station," Vol. Ien prepared for the U.S. Nuclear Regulatory Coamission by Pacific North-west Laboratory, Richmond, WA, NUREG/CR-0672, June 1980. Available for purchase from the NRC/GPO Sales Program, U.S. Nuclear Regulatory Cornnission, Washington, OC 20555, and/or the National Technical Information Service, Springfield, VA 22161.

10. DISCUSSION OF CONMENTS RECEIVED ON THE DRAFT ENVIRONMENTAL STATEMENT 0

Pursuant to Paragraph A.6 of Appendix D to 10 CFR Part 50, the Draft Environmental Statement for the Susquehanna Steam Electric Station, Units 1 and 2, was transmitted, with'a request for com-ments, to Advisory Council on Historic Preservation Department of Agriculture Department of the Army, Corps of Engineers Department of Commerce Department of Health, Education, and Welfare Department of, Housing and Urban Development Department of the Interior I I Department of Transportation Department of Energy Environmental Protection Agency Federal Energy Regulatory Administt ation Pennsylvania State Clearinghouse Pennsylvania Department of Environmental Resources Luzerne County Planning Comnfssion Economic Development Council of Northeastern Pennsylvania Board of Supervisors, Berwick The Draft Supplement to the Draft Environmental'Statement Related to Operation of Susquehanna Steam E'lectric Station, Units 1 and 2, was transmitted, with a request for comnents, to the same federal, state, and local agencies. The Draft Supplement was also transmitted to:

Susquehanna River Basin Commission In addition, the NRC requested comments on the Draft Environmental Statement from interested persons by a notice published; in the Federal Re ister on 24 June 1979. In response to the requests refer red to above, comnents were rece ve rom of Agriculture, Forest Service (DA-FS) 'epartment Department of Agriculture, Soil Conservation Service (DA-SCS}

Department of Commerce (DOC)

Department of Health, Education, and Welfare (HEW)

Department of Housing and Urban Development {HUD)

Department of the Interior (DOI)

Department of Transportation (DOT)

T.R. Duck Economic Development Council (EDC)

Environmental Protection Agency (EPA)

Federal Energy Regulatory Comnission (FERC)

T.J. Halligan H.L. Hershey N.J. Huntington H.C. Jeppsen S. Laughland W.A. Lochstet Luzerne County Planning Comoission (LUZ)

M.H. Holesevich L. Hoses D. Oberst Pennsylvania Power & Light Company (PP&L)

Pennsylvania State Clearinghouse, Department of Environmental Resources (PDER)

W.L. Prelesnik

- Council, of Governments 4i SEDA (SEDA)

F.L. Shelly S. Shortz 10-1

10-2 Sierra Club, Pennsylvania Chapter (Sierra)

Susquehanna Alliance (SA)

Susquehanna River Basin Commission (SRBC)

F. Thompson L.E. Watson The comments are reproduced in this Statement as Appendix B. The staff's consideration of the coments received and its disposition of the issues involved are reflected in part by revised text in the pertinent sections of this Final Environmental Statement and in part by the following discussion. The comments are referenced by use of the abbreviations indicated above; also, the pages in Appendix B on which copies of the comments appear are indicated.

10.1

SUMMARY

AND CONCLUSIONS, FOREWORD, INTRODUCTION a

10.1.1 Sumnar and Conclusions (SRBC 8/30/79:8-68; HUD:B-6)

The staff agrees that the estimate of the 7-day, 10-year low flow based upon the longer record should be used. They concur in the value of 22.7 ms/s. However, the controlling discharge should be considered fixed at 22.7 m /s to preclude annual changes due to new data affecting the 7-day, 10-year flow.

'10.1.2 Foeewoed (SA 8/17/79:8-62; T.J. Balllgao:8-26)

The Atomic Safety and Licensing Board for Susquehanna has considered the question of "piece-mealing" the NEPA review and has found no merit to this argument. It is the staff's conclusion that the Final Environmental Statement represents a comprehensive environmental assessment.

The NRC has published draft proposed procedures for implementing NEPA regulations. Public and agency coranents have been received on the draft proposed procedures, and proposed final regu-lations are now before the Cotmoissioners for approval. The final regulations provide that actions undertaken prior to publication of the final rule will not require adherence to the new procedures.

10.1.3 Introduction (PP&L 9/4/79:B-42; PDER 8/20/79:B-50)

National Pollution Discharge Elimination System (NPDES) Permit No. PA-0047325, effective 31 July 1979, was issued to cover the blowdown and other lesser discharges. This permit prohibited the discharge of floating debris, visible foam, and polychlorinated biphenyl compounds (PCBs); it also set limits for the discharge of free available chlorine, total iron, total suspended solids, oil and grease, but did not specify limits for sulfate in the discharge. The staff notes that this permit expired on 30 September 1980 and was administratively extended by PDER, Upon receipt of a new permit application from PP&L under the EPA's Consolidated Permit Re9u-lation Program (45 FR 33425, 19 Hay 1980), the permit will be renewed. This is expected to occur by March 1982.

10.2 THE SITE 10.2.1 Resume No comments.

10.2.2 Sociocultural Profile (EDC 9/26/79:B-14) 10.2.2.1 Introduction No coraaents.

10.2.2.2 Demography No comments.

10.2.2,3 Settlement Pattern (H.H. Holesevich:B-39)

Figure 2.1 has been revised to reflect these coments.

10-3 t 10.2.2.4 Social Organization (M.M. Molesevich:8-39, ment Agency (FEMA) before th'e operating license can be issued.

EDC 8/27/79:8-13)

The state and local evacuation plans will be reviewed by NRC .and the 'Federal'Emergency Manage-FEHA requires that the plans include al'I hospitals and institutions within the Susquehanna plant plume exposure.

10.2.2'.5 Political Organization 1

No comments.

10.2.2.6 Land Use (M.H. Holesevich:8-39)

The text has been revised to reflect the corments on land-use categories.

1D.2.2.7 Changes in the Local Economy No conments.

10.2.3 Water Use (EPA 8/17/79:8-17; EDC 9/26/79:8-14)

The third paragraph of Comment 8-17 is not clear: if it is intended to indicate the possibi'Iity of interactive effects, any such effects should be reflected in appropriate standards. Regard-ing stoichiometry, it is pointed out in Section 10.3.2.4 that the "maximum" conditions assumed in estimating chemica'I discharges are inconsistent and could not occur in practice. This inconsistency is largely responsible for'he apparently high sulfate discharges estimated in the DES.

The applicant gave the following response to this cornnent (applicant's responses 13 November 1979):

The NPDES permit for the Susquehanna SES has specified no average limitation on iron but a daily maximum of 7 mg/L. The iron. content in the Susquehanna River normally does not meet Pennsylvania Department of Environmental Resources, Chapter 93, Water I)uality Criteria, On DES pages 4-4 through 4-7 and Table 4-3, the discussion of the discharge from the station does not indicate the settling rate of suspended solids in the cooling tower basins. The ratio of suspended solids of the water in the cooling tower basins to the water in the discharge is about 3 to 1 which approximately offsets the concentration factors listed in Table 4-3. If the concentration of iron in the river exceeds DER criteria, the station wil'I discharge approximately the same concentration. This is noted in the NPDES permit which states that the effluent quality need not exceed the quality of the raw water supply.

Since the DES was published, the applicant has indicated that the parking-lot pond has been deleted. Figure 2.3 has,been amended accordingly. The only water discharged to the river through the drainage ditch will be rainfall-genera'ted water and treated waste water from sumps and drains in non-radioactive plant areas (e'.g. condenser, pumphouse, diesel generator and electrical equipment areas), estimated as 9.1 L/s. Oil will be separated and recovered where necessary. The waste water from raw water treatment (essentially clarified water) will be recycled to the condenser cooling system together with neutralized and filtered demineralizer waste. The total water so recycled is estimated as 3.15 L/s. The average demineralizer waste flow was estimated in the ER-CP as 0.21 L/s.

The applicant has provided the following additional information on other internal station flow rates (applicant's responses dated November 13, 1979):

Flow Path guua~tt tr Raw Water Treatment Plant to Radioactive Area Waste Uses 0-12.6 I./s Raw Water Treatment Plant to Demineralizer 7.6 L/s (batch)

, Demineralizer to Radioactive Area Water Uses 1-'I2.6 L/s Demineralizer to General Plant Uses 0-F 1 L/s, Raw Water Treatment Plant to General Plant Uses 0-9. 1 L/s

10-4 Because these flow rates are variable or intermittent, a precise water balance is not possible, but the average. rates are so small that the effect on the overall plant water balance will be negligible. In estimating the chemical discharges, the staff did not find to establish a precise water balance for each of these unit it necessary processes'll water recycled to the condenser cooling system will be filtered. The solids from the water recovery filter will be trucked offsite and disposed of in a licensed landfill.

The staff has analyzed the construction and use of Pond Hill Reservoir in Appendix A.

Responsibility for regulating downstream uses and users of water is assigned to the U.S.

Environmental Protection Agency, the Susquehanna River Basin Coamission, and the Pennsylvania Department of Environmental Resources.

The location of the plant relative to the floodplain of the Susquehanna River is discussed in Section 4.3.2.2. The major plant structures are well above the floodplain; only the intake structure, its access road, and some recreational facilities are in the floodpl,ain.

The Tioga-Hamond Dam is primarily a flood control project. An analysis of the effects of.

its (hypothetical) sudden catastrophic failure showed that resulti,ng water levels on the Susquehanna River near the plant site would be lower than the level of the flood for which the plant is designed.

10.2.3.1 Regional Water Use No coments.

10.2.3.2 Hydrology No corments.

10.2.3.3 Mater Sources (PPEL 9/4/79:8-42)

Figure 2.3 has been modified as a result of the design change.

10.2 '.4 Mater Ouality (EPA 8/17/79:B-17; PPIIL 9/4/79:B-42)

Table 2.8 has been updated to, show the revised State Mater Criteria published in July 1979, and applicable to the North Branch Susquehanna River from the Lackawanna River to the West Branch confluence, including the waters in the vicinity of the site, which are'lassified WWF (protec-tion of warm water fishery). The criteria include the state-wide list plus dissolved oxygen, temperature, and manganese, but sulfate and chloride are not included. Although criteria for chloride do not currently apply to this stretch of the river, criteria for them do sulfate andcited exist in the state. These limitations could be applied in the future state.

if deemed necessary by the Section 2.3.4.1 has been revised to respond to the co+vents made.

10.2.4 ~Meteorolo (PPSL 9/4/79:6-42)

The recovery rate of approximately 70K for onsite meteorological data collected during calendar year 1973 "in the Susquehanna DES is for wind speed and wind direction measurements at the 9.6 m level and on temperature differential measured between 91.7 m and 9.6 m. The staff agrees that the data recoverability of joint wind speed, wind direction, and temperature differential may be enhanced by using temperature differences measured between 30.5 m and 9.6 m when the 91.7 m to 9.6 m are not available, However, because of the large difference in the deoths of the two layers over which the temperature differences were measured (62.1 m and 20.9 m) and particularly the shallow depth of the lower layer (20.9 m), the staff questions the result of direct substitution of the lower temperature differential measurement when the 91,7 m to 9,6 m data are missing.

The staff acknowledges that the unusually high occurrence of unstable atmospheric conditions recorded at the Susquehanna site may represent the meteorological conditions that occurred in 1974 and 1975. However, in the staff's opinion, this period does not adequately represent average conditions expected to occur during the lifetime of the plant. Since these data would represent a substantial part of the meteorological data base if they were used in the evalu-ation, they could deceptively weight the resultant dispersion estimates. Therefore, the staff did not include the meteorological data collected during the 1974 and 1975 calendar years in its atmospheric dispersion evaluation.

10-5 The staff agrees that the wind from the west-southwest and west directions as recorded at the 9,6-m level occurred with frequencies of 13.5% arid about 12.0%, respectively, during calendar year 1976. The recorded frequency of calm was 1.5%. These corrections have been made in the appropriate section of the text.

10.2.5 ~Stte Ecole 10.2.5.1 Terrestrial Ecology {PPSL 9/4/79:8-42)

Section 2.5.1.3 has been revised to reflect the cogent made.

10.2.5.2 Aquatic Ecology No contents.

10.2.6 Cultural Resources (Sierra:8-61; SA 8/17/79:8-62; PDER 8/20/79:B-50; DOI 9/10/79:

See Section 10.4.7.

10.3 THE PLANT 10.3.1 Resume No comments.

10.3.2 Desi n and Other Si nificant Chan es 10.3.2.1 Water Use (SRBC 8/30/79:8-68; EDC 8/27/79:8-13 and 9/26/79:B-14)

Section 3,2.1 has been revised to reflect the applicable comments. Table 3.1 has also been revised.

The applicant has calculated that, unde'r the worst meteorological condition, which runs 1% of the time (a dry bulb temperature of -29.4'G or 85'F and a wet bulb of 23.9'C or 75'F) and a maximum plant load, the maximum evaporation rate will be 1.81 ms/s.

Appendix A addresses the compensation reservoir proposed by the applicant to meet the Susquehanna River Basin Comnission's regulations with respect to consumptive water use during periods of low river flow.

The plant river intake structure is designed to be operational during the Standard Project Flood (SPF), which is the most severe flood reasonably characteristic of the region. The calculated river level of the SPF at the intake location is more than 2.4 m above the maximum recorded level, which resulted from Tropical Storm Agnes. In the SPF analysis, no credit was taken for any protection the proposed Tioga-Haneond Dam would provide. In addition, it must be emphasized that the plant can be safely shut down without using the Susquehanna River intake. For further discussion of the safety-related aspects of plant water supply, see the Safety Evaluation Report (SER).

The effects of floods on SSES are discussed in detail in the SER, Section 2.4. The plant is well above the level of any credib'le flood on the Susquehanna River. The ability of the plant to safely'hut down using the onsite spray pond in the event that the river intake structure is flooded is also addressed in 'the SER, Section 2.4.

10.3 ' ' Heat Dissipation System (EPA 8/17/79:8-17; SRBC 8/30/79:8-68)

The staff is familiar with EPA Document 660/2-73-016. Construction of the intake was 'essentially complete at the time of the site visit (September 1978). Determination of compliance with Section 316(b) of the Clean Water Act is the responsibility of EPA, not the NRC. Approval of the applicant's impingement/entrainment study, either under Sectibn 402 or 316(b) of the Clean Water Act, is interpreted by NRC to mean that the design of a given intake is EPA approved.

PDER (Pennsylvania being an agreement state) approved the applicant's impingement/entrainment study on 29 April 1980.~ Should the applicant's entrainment study indicate that mitigative measures are necessary, appropriate modifications will be made. Section 5.3.4 has also been updated to reflect this information.

Construction of the intake is essentially complete. Determination of compliance with Sec-tion 316{b) of the Clean Water Act is the responsibility of EPA. Pennsylvania is an EPA

10-6 agreement state with the Pennsylvania Department of Environmental Resources responsible for determining compliance with Section 316(b). PDER has accepted the applicant's proposed impingement/entrainment study.~~z A determination of the environmental acceptability of the intake will be made by PDER after the 316(b) study is complete. Section 5,3.4 has also been updated to reflect this information.

10.3.2.3 Radioactive Waste Systems No comments.

10.3.2.4 Chemical, Sanitary, and Other Waste Treatment (EPA 8/17/79:B-17; DOI 9/10/79:8-?)

Sulfate The NPDES permit does not limit the sulfate concentration in the discharge. The only currently applicable standards for river water quality are those shown in Table 2.8. The state criteria for protection of aquatic life in the stretch of the river adjacent to the plant site do not currently include a limit on sulfate concentration, although a limit of 250 mg/L for drinking water is included in the list of specific criteria, which could be applied if deemed desirable to any stream in the state. The recoat.'nded drinking water standard is based on taste percep-tion; adverse (laxative) effects ar'e not noticeable at sulfate concentrations below 400 mg/L, Under the most adverse conditions, the staff estimates that the sulfate concentration in the river will not exceed 250 mg/L (Table 4.3) after complete mixing of the blowdown with the minimum river flow. As stated in Section 4.3.3.2, impurities not added in the plant will be concentrated by-a factor of 1.06 to 1.08 by evaporation in the cooling towers. With a maximum observed sulfate concentration of 222.5 mg/L, the maximum final concentration would be about 241 mg/L if no sulfuric acid were added; thus, the maximum sulfate addition would produce an increase of only 6 mg/L under these unlikely conditions. As shown in Section 3.2.4.2, it be possible to reduce this small contribution even further by operating with a more positive may saturation index, which would also improve corrosion protection.

Other Sulfuric acid addition is the most effective and economical method of scale control; it is used in virtually all large generating stations, nuclear and fossil-fueled, where water quality demands scale control. Its action depends on well-known physicochemical principles and the dosage can be calculated quite accurately for given water quality and plant conditions. Sulfate ion is present in most natural waters; its environmental effects have been well studied, and are reflected in water quality criteria. The staff's evaluation shows that sulfuric acid can be used at SSES without violating these criteria, although careful analytical control will be necessary because of the high and variable ambient sulfate level. The Amertap system of mechan-ical cleaning may retard the buildup of calcium carbonate scale, should scaling conditions prevail for prolonged periods. Controlled sulfuric acid addition should avoid these conditions.

Theoretically, hydrochloric acid could be used to reduce alkalinity and control scale, but it is never used fot this purpose; corrosion is a major objection. EPA has already expressed concern regarding the chloride" concentration in the discharge (see EPA 8/17/79, p. 8-ll); this would be greatly increased by:the use of hydrochloric acid.

Organic scale control agents (tannins, lignins, polyacrylates, polyphosphonates) are known to be effective. They inhibit crystal growth rather than increase solubility. These agents are not in common use in large cooling systems, and their environmental effects are not well known. The phosphonates appear to be the most effective, but the release of phosphorus compounds on a large scale appears highly undesirable.

In any event, the purpose of the Environmental Impact Statement at the Operating License Stage is to assess the impacts of the station as designed; alternatives are not normally considered at this stage, unless the impact of the proposed system or procedure is assessed as being unaccept-able. That is not the situation in this circumstance. A more detailed analysis is therefore not warranted.

10.3.2.5 Transmission Systems (Sierra:8-61)

The staff interprets the cogent as being related to the Pennsylvania,.Scenic Rivers Act of 1972, which authorizes establishment of a scenic rivers system. Accordingly, the Pennsylvania Depart-ment of Environmental Resources conducts river studies and reports to the governor and general assembly regarding designation and management of candidate waterways.

The applicant indicates that the transmission line crossing at the Lehigh River Gorge was specif-ically selected to minimize the visibility of the line. The PDER. reviewed and concurred with plans for the crossing (ER-CP, Amendment 5). The staff also notes that the PDER granted the applicant a permit for crossing the gorge (ER-OL, Sec. 12.1.2).

10-7 The staff has also contacted the Department of the Interior Heritage Conservation and Recrea-tion Service (HCRS) concerning the status of the Lehigh River Gorge area for consideration in the National Wf'Id and Scenic Rivers System. A Nationwide River Inventory has recently been developed by HCRS and the Lehigh River Gorge area is listed as having potential for inclusion fn the Nationwide River System. However, it is the staff's understaridirig that, because the excavation, construction, and erection of the towers at the gorge crossing began in the fall of 1978, prior to publication of the Nationwide River Inventory list, the Susquehanna 500-kv line ,

would not impact the future status of this river segment for inclusion into the National Mild and Scenic River System.

10.4 ENVIRONMENTAL EFFECTS OF STATION OPERATION 10.4.1 Resume No comnents.

10.4.2 0

Im acts on Land Use (H.H. Holesevich:B-39)

The state ayd local evacuation plans will be reviewed by NRC and the Federal Emergency Manage-ment Agency (FEHA) before the operating license can be issued. FEHA requires that the plans include all hospitals and institutions within the Susquehanna plant plume exposure.

10.4.3 Im acts on Water Use (T.R. Duck:8-11)

The Pond Hill Reservoir is being planned to supplement river flow during periods of low river flow. The Susquehanna River Basin Commission has directed that the reservoir be constructed by 1 July 1984. The Pond Hill Reservoir fs not required for the safe operation of the nuclear plant. Therefore, the Environmental Statement review dealt only with the effect of the construc-tion and operation of the Pond Hill Reservoir on the environment.

10.4.3.1 Thermal Impacts in Water Use (PP&L 9/4/79:B-42; L.E. Matson:B-75)

Section 4.3.1 has been revised to reflect the conditions specified in the NPDES permit. Table 4.1 has also been revised.

The staff assumes that "additional destruction of habitat" refers to wildlife habitat. This was discussed in Section 4.3.1 of Appendix A.

10.4.3.2 Hydrological Alterations and Plant Mater Supply No comments.

10.4.3.3 Industrial Chemical Wastes (EPA 8/17/79:B-17; PP&L 9/4/79:B-42; PDER 8/20/79:B-50)

The increase in chloride ion is due primarily to evaporative concentration of the ambient chloride content, but the chlorine added as a biocide also contributes significantly. The applicant has demonstrated to the staff's satisfaction that the proposed chlorine usage does not exceed the quantity required to maintain an adequate biocidal concentration (Response to Staff guestfon CHE-1 in ER-OL, Rev. 'I, 1/79). Even so, the estimated chloride concentrations at the edge of the mixing zone (Table 4.3) do not exceed the proposed criteria.

The applicant states 'that inhibitors containing chromium will be used in closed cooling loops.

The text (Section 4.3.3.3) has been amended accordingly.

The frequency of discharge, if any, from these loops has not been s'pecified by'he applicant.

However, review of the applicant's NPDES permit application indicates that none of the waste streams from the plant will contain chromium. This is consistent with the recently proposed EPA Effluent Limitations Guidelines for the Steam Electric Power Generating Point Source Category, which would prohibit discharge of power p'lant waste streams containing chromium.

1'he cooeent on sulfate concentration was addressed in Section 10.3.2.4.

10.4.3.4 EPA Effluent Guidelines and Limitations (EPA 8/17/79:8-17; DOI 9/10/79:B-7, EDC 9/26/79:8-14)

Section 4.3.4 has been revised to reflect the comments made.

F An entrainment study will be conducted as part of the applicant's NPDES requirements.> The FES text has been modified to reflect this new information.

10-8 10.4.3 ' Effects on Water Users through Changes in Water I)uality No comments.

10.4.3.6 Sanitary Wastes (EPA 8/17/79:B-17)

The treated sanitary effluent is discharged to the river at a separate outfall (see FES Fig. 2.3).

The treatment plant uses the activated sludge, extended aereation process. 'There are three independent aereation tanks and clarifiers, each designed for 15,000 gal/day. During construc-tion, all three units were used, but the applicant expects to use only two units during oper-ation, with the third as a standby for peak employment periods such as maintenance or refueling.

The modular design should permit the effective handling of reduced loads without serious under-loading.

- 10.4.4 Environmental Im acts 10.4.4.1; Terrestrial Environment (DA-FS:B-4; DA-SCS:B-4; DOI 9/10/79:B-7; EOC 9/26/79:8-14; W.L. Prelesnik:B-55)

Coranitments by the applicant include a stipulation that "any chemicals used to control vegeta-tion will be approved by state and federal authorities and applied as directed by said author-ities" (ER-CP, Amendment 4, p. 5.5-4 and Amendment 5, p. 5.5-4). This coranitment was a con-sideration in the staff's assessment, as, indicated on page C-6, Appendix C of this Statement.

Recent information indicates the "applicants presently. anticipate using primarily Dicambra and Fosamine."> Ammonium sulfamate may also be used in watershed areas to a limited extent.

The staff differentiates between construction and operation impacts; the latter being the principal focus of this Statement. The staff does not foresee instances in which routine opera-tion of the station and transmission facilities will result in appreciable impacts on additional important farmlands.

The environmental impacts of construction and use of the Pond Hill Reservoir are discussed in .

Appendix A; impacts related to the operation of the cooling towers are addressed in Section 4.4.3.

Impacts on terrestrial wildlife habitat and aquatic organisms resulting from the proposed devel-opment and operation of the Pond Hill Reservoir are discussed-in Section A.4.3.1.

The staff is not aware of any instance in which the planned operation of SSES will result in a temporary loss of habitat that "would kill all fish and wildlife currently living near the site." The staff does not foresee how operational impacts on aquatic comaunities would result in killing all local wildlife. 0 The staff offers, the following observations. As indicated in Section 4.4.1.1, the anticipated operational noise levels referred to are estimates based on calculations and various assump-tions. Thus, the extent to which operational noise may warrant mitigation is not clear at this time. The staff also wishes to point out that the applicant will be required to monitor local noise levels following initial operation of the station (see Section 5.3.5). Comparisons between preconstruction surveys and operational monitoring data will enable the estimation of increased noise levels attributable to station operation. If need for mitigation is indicated, the operational monitoring data will provide a basis for selecting between alternative methods, structures, and/or equipment to be used in reducing noise emissions from the stati'on.

10.4.4.2 Aquatic Environment (EPA 8/17/79:B-17; PP&L 9/4/79:B-42; PDER 8/20/79:B-50; SRBC 8/30/79:B-68; EDC 9/26/79:B-14)

The staff agrees that the practicability of reintroducing shad to the Susquehanna River is questionable; however, the staff is also aware that various state and regional agencies are considering such a possibility. Therefore, )he discussion is warranted.

With respect to the 'adult shad, the adults generally remain in the main channel of the river during their upstream migration. Operation of the existing intake would have a potential impact on those adults using the intake pool for resting. The staff feels that the greatest impact to migrating shad would be during the fall when young-of-the-year are using the pools and shallower portions of the river during the downstream migration; The entrainment study to be conducted as part of the applicant's NPDES permit requirements will indicate what, future studies if if any, mitigative measures are necessary. The EPA has the authority to require conditions warrant them. Section 5.3.4 has also been updated to reflect this information.

The staff still believes that "the intake design at SSES as currently sited and designed will adversely affect the aquatic cormunity within the imaediate vicinity of the wing walls and

10-9 associated riprap" (DES p. 4-9). Also, the staff stands, by its statement relative to embayment-type intakes having a greater potential for "attracting" fish than other intakes. At the time the DES was written, the Pennsylvania Department of Environmental Resources had not'accepted or rejected the intake design at SSES. With the acceptance of the applicant's impingement/entrain-ment study,~ the PDER rules the intake design as environmentally acceptable. The entrainment study will indicate if mitigative measures are required to be in compliance with Section 316(b) of the Clean Water Act. The staff does not have the authority to require impingement/entrainment studies.

The staff agrees with the comment that the intake site does not necessarily occupy a particularly unique area of the river. The first paragraph of Section 4.4.2.1 of the FES has been modified to reflect this opinion. The staff feels the term "pool" is properly defined and used in the FES.

Page 4-10 has been modifie'd- to reflect new information on the impingement/entrainment study; however, the staff is still not convinced that impingement impacts can be accurately predicted based on results at another power plant.

The staff still does not believe that monitoring of the benthic coranunity in the vicinity of the discharge is necessary. As stated on page 4-10 of the DES, "the vicinity of the discharge is not particularly unique to the river and any loss of habitat should not have a significant impact on the various populations."

The applicant will be operating the Pond Hill Reservoir. to compensate for water consumed during periods of low flows; therefore, the staff concludes that impacts due to operation of SSES during low-flow periods will not be significant.

10.4.4.3 Atmospheric Effects of Cooling-Tower Operation (PDER 8/20/79:B-50; H.H. Holesevich:

B-39)

The use of SSES in its planned baseload mode will probably result in the conversion of one or more oil- or coal-fired power plants to load-following or'eaking duty., Since the operation of SSES will result in essentially zero emissions of particulates, SOz, NOx and other pollutants characteristic of fossil units, the staff expects an improvement in the region's air quality as a result of the use of SSES.

Test plants observed in the Chalk Point studies referenced in Section 4.4.1.1 include corn (Zea mays), soybeans (G7ycine max) tobacco (Nicotiana tobaccum), dogwood (Comus florida), black locust (Bobinia pseudo-acaciaI, Virginia pine (Pinus vizginiana), and sassafras (Sassafras aIbidum). Additional test species observed in other related studies include tulip poplar (Siriodenchon tulipifeva); privet (triquetrum spp.); Amur and red maples (Acer ginnaIa, A. rubicon);

and Scotch, white, and lobbolly pines (Pinus eySvestTia, P. etrobus, P. taeda).4 Distributions of these species are not limited to Haryland nor to coastal areas affected by salt depositions of oceanic origin. In view of the extensive occurrence of these species in Pennsylvania, the staff believes that the Chalk Point vegetation studies are relevant to the future operation of the Susquehanna station. Soil investigations are also considered pertinent; the staff is uncertain as to the intended meaning of statements implying that some soils are, tolerant of or "accustomed to" salt depositions.

As reported in 1978, investigations (1975-1977) of test plant species and local soils at Chalk Point failed to reveal effects that could be attributed to cooling-tower, operation. Conclusions presented by investigators included various caveats such as the need'for future studies to document long-term effects. However, simulated salt-drift studies are indicative of levels of salt depositions being investigated. For example, "applications of salt up to 3.6 kg/ha per week failed to induce statistically significant reductions in yields for corn and soybeans" (Section. 4, Reference 7). "Of the agricultural species investigated thus far," corn exhibits the highest sensitivity to salt drift. . In other simulated drift studies at Chalk Point invol-ving an estimated salt deposition rate of 7.46 kg/ha per month, the reporting investigators

. concluded that "some injury may occur to a sensitive species such as dogwood under certain cooling tower operating conditions."s The investigators also cautioned against assuming that the reported deposition rate was "a general indicator of any salt drift injury." However, the staff believes a general comparison is warranted since the reported deposition rate (7.4 kg/ha'er month) is almost nine times greater than the maximum deposition rate (880 g/ha per month) estimated to occur during SSES operation.

Postoperational surveys of vegetation in the vicinity of the Three Hile Island Nuclear Station are also of interest since the Susquehanna River is the source of that station's cooling water.

Reported results of 1975 plant pathology surveys and quantitative vegetation studies did not indicate any effects that could be attributed to salt drift from station cooling towers.7 Nor were any effects detected in 1974.

10-10 The staff expects no adverse effects from the mineral drift from the plant's cooling towers due to the low salt deposition rates, the nature of the material deposited (primarily calcium sul-fate vs sodium chloride typical of coastal areas), and the natural rainfall that is expected to dilute and wash away the salt deposits. This conclusion is supported by studies made at fresh-water cooling towers (Refs. 22-25 and 29 of Chapter 4; also a recent study for USEPA: G. A.

Englesson and M.C. Hu, Nonwater guality Impacts of Closed-Cycle Cooling Systems and the Inter-action of Stack Gas and Cooling Tower Plumes, EPA-600/7-79-090, Industrial Environmental Research Laboratory, Research Triangle Park, N.Cfh 1979, 214 pp.).

Observations of plume from natural-draft cooling towers, including several in Pennsylvania and Kentucky, show that the plumes do not reach to the ground and cause ground fog and icing because of their height and plume rise due to buoyancy and momentum. This is discussed in the DES and the references cited above.

10.4.5 Radiolo ical Im acts from Routine 0 eration (SA 8/17/79:B-62; W.A. Lochstet:8-32; atson: - ; . . re esne :B- ; 8/27/79:8-13; EPA 8/17/79:8-17; F.L. Shelly:

8-57)

Risks from Low-Level Radiation The NRC staff is not aware of any studies that have established that there is no safe level of radiation. However, as a conservative and prudent assumption, it has been assumed that no amount of radiation is safe. For more than four decades, the effect of a radiation on humans and animals has been thoroughly studied. Numerous major biological research programs have been well documented and may be found in the open literature. The United States has been the fore-runner in radiation research, but many other countries also have pursued similar programs and have contributed substantially to current knowledge. While the relationship between ionizing radiation dose and biological effects among humans is not Errecisel known for all levels of radiation, the principal uncertainty exists at very low dose levels where natural sources of radiation (cosmic and terrestrial) and the variations in these sources are comparable to the doses being evaluated. The most important biological effects from radiation are somatic diseases (principally cancer), hereditary diseases, abortions, and congenital anomalies. These effects are identical to those that occur normally among humans from other causes. It is this last point, in combination with other confounding factors, e.gf magnitude and variations 1) in h

normal incidence of diseases, 2) in doses from natural radiation sources, 3) in radiation doses from human-made sources other than the nuclear industry, and 4) in exposures to other (non-nuclear) carcinogens, that is responsible for much of the uncertainty in the dose-risk relation-ship at low dose levels.

Data from studies of animals and humans are reviewed continuously by teams of scientific experts who evaluate radiological information and provide recomendations. In the United States, the principal expertise in radiological matters lies with the National Council on Radiological Protection and Measurements and the National Academy of Science/National Research Council (NAS/

NRC). Federal agericies also retain expertise in the radiologic disciplines in order to fulfill their responsibilities; these agencies, however, rely heavily on recomnendations of the pre-viously mentioned advisory organizations. Other countries have national advisory organizations similar to those of the United States. There are also cooperative international organizations that evaluate data from all sources and present recormendations and conclusions; for example, the United Nations Scientific Committee on the Effects of Atomic Radiation (UNSCEAR) and the International Commission on Radiological Protection (ICRP). In summary, not only have the radiological data been ascertained by the world's outstanding biologists and epidemiologists, but the data have been evaluated independently by their peers' In lieu of precise knowledge of the relationship between low-level radiation and biological effects, a linear non-threshold extrapolation from high radiation levels to the lower levels is assumed for radiation protection purposes. This means that it is assumed that any dose of

~rad ation, no matter how low, may be hamnful. Several federal agencies, principally'SPA, the Occupational Safety and Health Administration (OSHA), and NRC have responsibilities for regula-ting exposures to radiation or radioactive material. In all cases, the staffs of these agencies are well aware of the potential health effects and have expertise in biology and the other disciplines needed either within the staff or available to them.

0 The basis for the risk estimators on p. 4-27 of NUREG-0564 is more fully described in Chapter 4, Section J, Appendix 8, "Health Risks from Irradiation," of the Final Environmental Statement on the Use of Recycle Plutonium in Mixed Oxide Fuel in Light Water Cooled Reactors (NUREG-0002).

As stated in NUREG-0002, "Though these risk estimates are the upper bound estimates given in the Rasmussen Report,> higher estimates can be developed by use of the 'relative risk',model along with the assumption that risk prevails for the duration of life. This would produce risk values up to sevenfold greater than those used in GESMO." Consequently, the risk estimators in NUREG-0511 are consistent with those used in NUREG-0002.

t 10-11 Several of the general statements in WE L. Prelesnik's comment reflect'some misunderstandings regardjng NRC policy and positions. Therefore, the staff has attempted to provide more detail on some of these concerns.

First, it is stated that "any low-level radiation releases are significant as has been admitted old AEC and the NRC's own studies. There is no safe level of radiation and proven, even by the level of radiation. However, as a conservative and prudent assumption, the staff assumes that no amount of radiation is safe (see Section 5.5.5 of the FES for additional inform~ation .

Secondly, it is Those stated that "The current standards, were initially set in order to justify atomic in order to justify nuclear power plants because the bomb testing. standards. were kept nuclear industry and our 'government recognizes that no plant operates without 'normal'eleases of radiation." General information about radiation standards is provided in the NRC's "Radia-tion Standards Fact Sheet" (a copy has been sent to W. L. Prelesnik in a letter dated 18 October 1979, however, it is too lengthy to repeat here). As, noted in this fact sheet and in Sec-tion 10.4.5, the radiation protection standards were based on the best scientific judgment available in the world.

In addition, see Section 4.5.5 of the FES and responses to comments in Section 10.6.2.

Im acts from the Fuel C cle i

Dr. Lochstet's basic contention is that "the health consequences of radon-222 emissions from the uranium fuel cycle are improperly evaluated" in the Susquehanna Draft Environmental State-ment (DES, NUREG-0564). The basis for Lochstet's contention is that the staff"has arbitrarily evaluated the health impacts of radon-222 releases from the wastes generated in the fuel cycle for 1000 years or less,'ather than for "the entire toxic life of the wastes." Lochstet then estimates that radon-222 emissions from the wastes from each annual reactor fuel re-quirement will cause about 600,000 to 12 million deaths over a period of more than 1 billion years' The major difference between the staff's estimated number of health effects from radon-222 emissions and Lochstet's estimated values is the issue of the time period over which dose com-mitments and health effects from long-lived radioactive effluents should be evaluated. Lochstet has integrated dose commitments and health effects over what amounts to an infinite time inverval, whereas the staff has integrated dose coomitments from radon-222 releases over a 100-year period, a 500-year period, and a 1000-year period.

The staff has not estimated health 'effects from radon-222 emissions beyond 1000 years for the following reasons. Predictions over time periods greater than 100 years are subject to gr'eat uncertainties. These uncertainties result from, but are not limited to, political and social considerations, population size, health characteristics, and, for time periods on the order of thousands of years, geologic and climatologic effects. In contrast to Lochstet's conclusion, some authorsa estimate that the long-term (thousands of years) impacts from the uranium used in reactors will be less than the long-term impacts from an equivalent amount of uranium left undisturbed in the ground. Consequently>> the staff has limited its period 'of consideration to 1,000 years or less for decision-mak'ing and impact-calculational purposes.

With regard to Dr. Kepford's testimony regarding use of $ 1,000 per person-rem for environmental health costs, the staff would like to make the following points.

The $ 1,000 per person-rem value was selected by the coranissioners as the upper bound of all the numerical estimates in the literature. The purpose was to estimate the potential monetary costs of health effects during the lifetimes of persons living within 80 km of a nuclear power plant (no other facilit ) so that those potential costs could be compared with the real costs of adding a tiona ra o ogical waste treatment systems to each proposed nuclear power plant to determine if the operation of the plant would result in meeting the 10 CFR Part 50, Appendix I "as low as reasonably achievable" rule. It was nev'er the intent of the comnissioners to use that monetary value for any other purpose, such as estimating the monetary costs'f future health effects from other sources on today's populations or future populations. The absurdity of future monetary.

costs can be demonstrated very simply, ~assumin human institutions and the human race persist into the future in the same manner as today. Ignoring the real possibility that radon health effects may not occur in the future due to technological advances, in the, cure and 'prevention of such effects, it is possible to calculate how much money would have to be'eposited in a savings account now to meet "future monetary costs" of $ 10 billion per reference reactor year.

As a conservative estimate, it was assumed that a 5 percent simple interest rate would demonstrate the meaninglessness of such calculations. Conservative staff estimates indicate that only a few health effects might occur within 1000 years. It is obvious that essentially all of Dr. Kepford's "health effects" would occur over periods of time that exceed the probable life expectancy of the human race and our solar system. Nevertheless, tongue-in-cheek, it can be shown that, if

10-12 the utility were to deposit one cent in a perpetual savings account to pay for any future health costs that might occur, that fund would contain nearly $ 16 million-trillion after only 1000 years.

Clearly, one cent would not significantly modify the future costs of electrical power generated today.

With regard to Dr. Kepford's estimates of millions of future deaths from radon-222 per reference reactor year, see also Section 10.4.5.3.

The contention that '-'the NRC itself has been unable to disagree with Dr. Kepford's findings that 1.2 million people per .year will die in the future from the effects of radon gas emitted from the tailings produced just to fuel THI," is incorrect. The staff has refuted such claims in several hearings as meaningless for many reasons. Some of the more important reasons were discussed earlier.

It is the responsibility of NRC to protect the health and safety of the public as they relate to nuclear plant operations. NRC requires that the design and operations of nuclear facilities consider and protect the health and safety of the public. NRC reviews each nuclear facility and determines if it will endanger the health and safety of the public. NRC will only permit opera-tion of a facility if it finds the facility can be safely operated.

Si nificance of Radiolo ical Im act W.L. Prelesnik's contents asked the following questions (responses follow each question};

I}uestion 1: What is your definition of significant, and how was it arrived at7 Response: NRC currently evaluates the radiological impact to three individuals:

1) a hypothetical maximally exposed individual, 2} an average individual within 80 km of the site, and 3) an average individual in the United States. The risk to the first two types of individuals from radio-active effluents from one year of reactor operations is quantified in Table 4.17 of the FES.

,For example, the risk of premature death to the hypothetical maximum exposed individual from gaseous effluents from one year of reactor operations is less than one chance in a million. (The risk from liquid and gaseous effluents has not been added because 'it is very unlikely that any real individual would be exposed at the maximum level from both sources.) This risk is much 'less than similarly calculated risks from many other types of radiation exposure (e.g.,

medical radiation exposure, natural background radiation, and air travel.) The risk to the maximum individual is within the range of many other common sources of radiation (e.g., airline travel, natural gas heating, and television viewing;} The risk to the average individual within 80 km of the site, and the risk to the average individual in the United States from one year of reactor operations is less than 1/100 of the risk to the maximum hypothetical individual. Since the risk from radioactive effluents from nuclear power plants is so low compared with many other types of risk (radiation related or otherwise} and since the radiation-related risks are based on conservative assumptions, the staff considers the risk to real individuals in the vicinity of nuclear power stations from normal operations to be insignificant. See Sec<<

tion 4.5.5 of the FES for additional infomation comparing the risk from annual operation of the reactor(s} with the risk from other sources of radiation, and the risk from the current incidence of cancer fatalities and genetic abnormalities.

I}uestion 2: On what basis do you calculate the "antici ated" occurrences'he Rasmussen Report has already been proven to e incorrect.

Response: The anticipated occurrences to which the'corments refer are based on operational occur rences and not on accident considerations. The Rasmussen Report is not used to calculate the impacts from opera-tional occurrences, Furthermore, the Rasmussen report has 'not been proven to be incorrect, but as a result of the Lewis Comnittee

10-13 report, it has been suggested that the numerical results may have a wider range of uncertainty than as suggested by the Rasmussen Report.

Question 3: How do you define "normal" ? Normal operation levels,-of radiation emission are quite different and separate from normal background levels of radiation already existing in the environment. Also, because of bomb testing and power plants, the "normal" levels of background radiation have increased over the past 30 years.

Response: NRC regulations (10 CFR Part 50) require the light-water-cooled nuclear power stations be designed and operated in a manner that will limit radiation exposures to any individual jn the general population to a small fraction of the general radiation standards during normal operation.

An extensive rule-making proceeding (Docket No. RH-2) was conducted over a several-year period (December 1970 to Hay 1975) to quantify the numerical guides for keeping levels of radioactive material in the effluents of light-water-cooled nuclear power reactors as low as is reasonably achievable during normal operating .conditions (Appendix I of 10 CFR Part 50). The normal operating conditions for these reactors were characterized by NRC during the course of the rule-making, based primarily upon data obtained during operations. Considerable more data have been obtained since 1975. The procedures used by the staff to characterize the radioactive material in the effluents are given in Regulatory Guide 1.112, "Calculation of Releases of Radio-active Haterial in Gaseous and Liquid Effluents from Light-Water-Cooled Power Reactors." This guide is used in conjunction with in-formation in NUREG-0016 and NUREG-0017 for boiling-Hater reactors and pressurized-water reactors, respectively (copies may be obtained from NRC). A narrative explanation of the population dose for the entire uranium fuel cycle for light water reactors was published on 4 Harch 1981

>>N.

The estimated U.S. population dose from radioactive effluents from one year's operation of Susquehanna, Units 1 and 2, is about 50 person-rem (Table 4.10). This estimate is based upon a 15-year buildup of activity in sediment and soil (i.e., the nomimal mid-point of the reactor's life). This dose is a very small fraction (less than 0.0002%) of the annual U.S. population dose from natural background radiation (i.e., 26,800,000 person-rem).

Question 4: What individuals, by name, set these "normal" levels?

Response: The "normal" levels of radiation from radioactive releases from nuclear reactors referred to are contained in Title 10 Code 'of Federal Regulations, .Part 50, Appendix I (10 CFR 50, App. I},

The annual dose design objectives set in 10 CFR 50, App. I, were set in a rule-making hearing by NRC, Although many people participated in the rule-making hearing, Comnissioners Anders, Rowden, Hason, Gilinsky, and Kennedy made the final decision to adopt the limits set in 10 CFR 50, App. I. A copy of the Coomission opinion in the matter of 10 CFR 50, App. I, has been sent to W. L. Prelesnik.

Question 5: How much "normal" radiation will be expected to be released in Berwick?

Response: The calculated releases of radioactive materials in liquid effluents are provided in Table 4.11 of the FES, and the calculated releases of radio-active materials in gaseous effluents are provided in Table 4.4. These two calculated source terms represent annual releases per reactor from normal operation, including anticipated operational occurrences, when averaged over the 30-year operating life of the plant. These source terms were used to calculate exposures due to releases (Table 4,8 of the FES). Dose estimates and lifetime risk estimates from these releases are given in Section 4.5 of the FES.

Question 6: What. are the NRC's recorded, documented levels of "normal" radiation releases from the operating plants'in the United States?

Response: The quantity of radioactive materials released from nuclear power plants in the year 1977 is contained in a document entitled, "Radioactive Haterials Released from Nuclear Power Plants - Annual Report 1977,"

(NUREG-0521). NUREG-0521 contains a nuclide-by-nuclide summary of'he radioactive effluents released from operating reactors in the year 1977, as well as a categorical suraaary (i.e., noble gases, I-131 and

10-14 particulates, tritium, mixed fission and activation products) for.

earlier years. Excerpts from NUREG-0521 are,too lengthy to repeat here, but have been sent to W. L. Prelesnik.

Population dose commitments for the year 1975 for about 50 reactors are given in a document entitled, "Population Dose Commitments Due to Radioactive Releases from Nuclear Power Plant Sites in 1975"; D. A. Baker, J. K. Soldat, and E. C. Watson; Battelle Pacific Northwest Laboratories; PNL-2439; pp. 3-4; October 1977. Population dose comnitments were calculated for the population. between 2 and 80 km of each reactor site. The average individual dose commitment to that population (about 0.02 mrem) represents about a 0.02K annual increase over background

,radiation. The dose to the hypothetical maximum individual would be higher.

10.4.5.1 Exposure Pathways No comnents.

10.4.5.2 Dose Commitments (PDER 8/20/79:B-50; EPA 8/17/79:8-17)

The Safety Evaluation Report was published in April 1981.

Modifications and design changes to the radwaste treatment systems since the FES/CP were consid-ered in calculating the source terms. The staff's detailed evaluation of these systems and the capability of these systems to meet the requirements of Appendix 'I will be presented in Chap-ter II of the Safety Evaluation Report. However, for the FES, the quantities of radioactive materials in effluents used to assess radiological impacts are given in Tables 4.4 and 4.11.

I The calculated value for the direct radiation dose (20 mrem/yr at a typical site boundary 0.6 km from the turbine building) given in the Braun Safety Analysis Report is for a standard BMR plant design. .The direct radiation dose of 2.7 mrad/yr in NUREG-0564 is an estimated dose for the specific design incorporated in the Susquehanna plant. Since the direct radiation dose is dependent on the shielding incorporated in the specific plant design, the above values are not directly comparable. Nonetheless", since the actual direct radiation dose could be higher (or lower) than 2.7 mrad/yr, a survey will be required at the time of plant operation. If the survey indicates that the limits of 40 CFR 190 could be exceeded, steps will be taken to reduce the dose.

Annual doses per site from liquid'ffluents were given in Table 4.9. The estimated dose to the total body or any organ of the hypothetical maximum individual from all pathways was about 1.0 mrem/yr for the site. This dose includes the dose from ingestion of fish as well as con-sumption of water. The dose to the average individual using the nearest coimunity water system would be less than 1.0 mrem/yr . The Environmental Protection Agency's "National Interim Primary Drinking Water Regulation" states that "the average annual concentration of beta particle and photon radioactivity from man-made radionuclides in drinking water shall not produce an annual dose equivalent to the total body or any internal organ greater than 4 millirem/year" (Sec. 141.16).

The annual doses from liquid effluents from Susquehanna, Units l,and 2, are below the above limits.

10.4.5.3 Radiological Impacts on Humans (H.L. Hershey:B-27; EPA 8/17/79:B-17; T,R, Duck:B-ll; PPSL 9/4/79:B-42' SA 6/10/80:B-64)

A formal program for the management of low-level radioactive wastes disposed of in,comaercial burial grounds is provided in "The NRC Low-Level Radioactive Waste Hanagement Progiam," NUREG-0240, September 1977, available at the Public Document Room, NRC, 1717 H Street NW, Washington, DC, 20555. The program recoranended new regulations and requirements for the Disposal of Low-Level Radioactive Waste and Low-Activity Bulk Solid Waste (Draft, Regulation 10 CFR Part 61);

these are presently being developed.

The staff does not believe that presently available worldwide dose models are capable of making, such projections with meaningful results. The staff has determined that present models for the United States sufficiently represent the population exposure due tooperation of this plant.

u Environmental impacts from uranium mining and milling are addressed in Section 4.5.6, "Uranium Fuel Cycle Impacts," of NUREG-0564.

The FES includes credit for the leakoff collection system for the turbine building releases.

The off-gas system releases were based on ambient operation conditions of 77'F (dew point 45'F) for the adsorption unit in reasonable agreement with the applicant's proposal of 60 to 65'F (dew point 40'F).

t , Table 4.12 provides estimates in this'table; it is assumed that 10-15 of transit time for effluents from various locations. As indicated sport fishermen may use the area near the plant discharge area. This is considered the "nearest sport fishing location" for purposes of an upper limit estimate.

Radiolo ical Models The staff has reviewed a report known formally as the "Radioecological Assessment of the Wyhl Nuclear Power Plant," and infor'mally as the "Heidelberg Report." The report was written by a private group of individuals at the University of Heidelberg, West Germany, concerned with energy and environmental issues. The authors of this report are affiliated with a group called Institute for Energy and Environmental Research (IFEU), and have not been authorized to use the name of the University of Heidelberg. Hence, their report is now referred to as the IFEU Report, although it has been referred to as the "Heidelberg Report" in the past.

of the environmental radiological impact of a proposed The IFEU Report pre-pressurized-water sents an assessment reactor to be built near Wyhl, West Germany.

H The assessment is based largely'on mathematical models used to calculate doses to humans in the area surrounding a reactor site and to"describe the movement of radioactive materials in the environment. These are the same mathematical models used by NRC to calculate doses to ensure that any radiation exposure resulting from reactor, operations is far below national and international recommended "safe" levels.

The staff reviewed the IFEU Report because the report implied that NRC may be substantially underestimating doses to individuals living neat nuclear power plants by using incorrect values for parameters in mathematical models. Although the IFEU Report assessment is based largely on environmental models described in four NRC Regulatory Guides, the staff's review of the report indicates that the IFEU authors-used values for some model, parameters that are too high.

As a result, the IFEU Report estimated doses to the public by some pathways that are up to 10,000 times higher than the doses calculated us.ing the NRC's values for those parameters.

The staff's review concluded that the IFEU Report does not provide any substantial evidence that NRC significantly underestimates doses. This conclusion is based on: 1) measured effluent releases at reactors operating in the United States, which are much less than those used in the IFEU Report; 2) measured environmental concentrations near reactors operating in the United States, which are much lower than those calcualted in the IFEU Report; and 3) a detailed review of the literature regarding critical parameters employed in the models in question, which does not support the values used in the IFEU Report.

The results of the staff review have been published in draft form for public coranent, both as a main report for the technical coranunity (NUREG-0668) and as a suranary report for general public information. The final report is expected in 1981.

In response to the contention that the "old AEC ... deliberately rigged the experiments," while NRC acknowledges that some of the AEC experiments done for some radionuclides in the 1950s'ould be done better today in light of advancements in technology, the staff has never characterized these studies as fraudulent and knows of no evidence to support such a claim.

The cogent also states that the "Heidelberg Report is the first time that independent scien-tists have examined the NRC's safety assurances about routine emissions from operating plants,"

thus implying that the validity of NRC radionuclide transport and dose models have not been reviewed and assessed by scientists outside NRC. This is absolutely incorrect. The Environ-mental Protection Agency, Argonne National Laboratory, Oak Ridge National Laboratory, Battelle Northwest Laboratory, privately owned technical consulting companies, and numerous national and international scientific organizations all have radionuclide transport and dose models based on field measurements that yield results consistent with the NRC calculations. InofSeptember 1977, Radionuclide a workshop of "The Evaluation of Models Used for the Environmental Assessment Releases" was held in Gatlinburg, TN, and the results were published as CONF-770901. Partici-pants in this workshop were selected to ensure an appropriate combination of individuals repre-senting a spectrum of scientific and administrative expertise, The working group on terrestrial food-chain transport at this meeting, whose members were predominantly from organizations other than NRC, concluded that transport models, as given in NRC Regulatory Guide 1.109, are very adequate for'emonstrating compliance with NRC's regulations (as given in Appendix I of 10 CFR Part 50).

10.4.5.4 Radiological Impacts on Biota Other Than Humans No coranents.

10-16 10.4.5.5 The Uranium Fuel Cycle (Sierra:8-61; EPA 8/17/79:8-17; SA 8/17/79:8-62; F. Thompson:

8-74; M.J ~ Huntington:8-27; S. Laughland:8-32; PDER 8/20/79:8-50)

Section 4.5.5,"The Uranium Fuel Cycle," (now Sec. 4.5.6) has been revised to reflect the Com-mission's final rule published to the Federal Re ister on 2 August 1979 (44 FR 45362). An explanatory narrative of the significance o re ease n Table 4-14 was also published in the Federal Register (46 FR 15154-15175, 4 March 1981).

Since there will be no radioactive waste disposal at the Susquehanna Steam Electric Station, waste disposal techniques are not part of the facility FES but will be considered in the formu-lation of regulations and the licensing of disposal facilities.

The models used in estimating doses in the environmental statement for the operating license are state-of-the-art models. The source-term, meteorological dosimetry models have been improved since the issuance of the construction permit. These models have been reviewed by EPA in regard to implementing the Uranium Fuel Cycle Standard (40 CFR 190). The doses calculated by using these models are thought to be conservative (i.e.; the models probably overestimate actual doses). In addition, new information since the publication of the DES concerning the location at 0.7 miles NW has resulted in a change in the maximum receptor location forreceptor iodines and particulates from 0.7 miles NW to 2.2 miles E.

S ent Fuel Stora e The storage of spent fuel is addressed in an NRC document entitled "Final Generic Environmental Impact Statement on Handling and Storage of Spent Light Wat'er Power Reactor Fuel" (NUREG-0575).

The storage of spent fuel addressed in NUREG-0575 is considered to be an interim action, not a final solution. The commission has clearly distinguished between permanent disposal and interim storage.a One of the findings of NUREG-0575 is that the storage of light water reactor (LWR) fuels in water pools has an insignificant impact on the environment, whether stored at a spent reactor or away from a reactor. Primarily this is because of the physical form of the material, sintered ceramic oxide fuel pellets hermetically sealed in Zircaloy cladding tubes. Zircaloy is a zirconium-tin alloy which was developed for nuclear power applications because of its high resistance to water corrosion in addition to its favorable nuclear properties. Even in cases where defective tubes expose the fuel material,to the water environment, there is little attack on the ceramic fuel.

/

The technology of water pool storage is well developed; radioactivity levels are routinely main-tained at about 5 x 10 " uCi/mL. Maintenance of this purity requires treatment (filtration and ion exchange) of the pool water. Radioactive waste that is generated is readily confined and represents little potential hazard to the health and safety of the public.

There may be small quantities of sKr released to the environment from defective fuel elements.

However, for the fuel involved (fuel at least one year after discharge}, experience has shown this to be not detectable beyond the iranediate environs of a storage pool.

There will be no significant discharge of radioactive liquid effluents from a spent fuel storage operation as wastes will be in solid form.

This statement supports the finding that the storage of spent fuel in away-from-reactor facilities is economically and environmentally acceptable.

j 10.4.6 Socioeconomic Im acts (EDC 9/26/79:8-14; S. Shortz:8-60)

The staff is unaware of any specific land use changes that have not been evaluated either in connection with the plant or reservoir. Unless the context of land use change is made more specific, monitoring effort would be an exercise without an objective.

10.4.6.1 Demography No coranents.

10.4.6.2 Settlement Pattern No comments.

10.4.6.3 Social Organization No comments.

10-17 10.4.6.4

~ ~ Social Services (DOT 8/9/79:8-10)

The transportation impacts have been adequately addressed to the satisfaction of DOT, with the exception of sufficient coordination. It is the staff's view that the applicant and DOT should work together to consider adequate design of the access road to the reservoir as we'll as atten-dant impacts. NRC will not preempt DOT expertise in matters of design and traffic coordination.

The comnent attributes many of the changes in the past years to construction of SSES. Many of these changes are due to other projects, including past highway construction, and to urban-ization trends independent of SSES. The record shows that the blasting during construction did adversely affect residents, but this should not be considered in a decision as to whether or not the plant should be operated. The comment correctly states that the land used by SSES is an irrevocable loss, but the opinion that its former use was the best use cannot be demon-strated on economic grounds. The EIS mentions the effect of hurricane Agnes as part of the recent history and is not meant to characterize the local area surrounding the plant, 10.4.6.5 Political Organization (EDC 9/26/79:8-14)

The distribution of taxes generated by SSES is primarily a state and local government responsi-bility. For a discussion of taxes, see Section 4.6.6.2.

10.4.6,6 Economic Impacts (EDC 9/26/79:B-14)

The comment on anticipated noise levels was addressed in Section 10.4.4.

PPSL has undertaken a program of hiring local workers as discussed in Section 4.6.6.1.

10.4.6.7 Seminary and Conclusions No comnents.

10.4.7 Im acts to Cultural Resources (DOI'/29/80:B-9; Sierra:B-61; EDC 9/26/79:8-14;

B- an :B-64 PDER 8/20/79:B-50)

In the June 1973 FES-CP, the staff reviewed the effects of construction and aspects of operation on the total plant site plus the transmission line corridors. In that document, the staff identified those sites listed in the National Register that were within 32 km of the facility.

The Advisory Council on Historic Preservation found the staff's statement procedurally adequate and suggested contact with the State Liaison Officer for Historic Preservation. The State Liaison Officer for Historic Preservation indicated that the project would not affect a known archeological or historical site or historical structure, and that it appeared to be con-sistent with the plans and objectives of the Pennsylvania Historical and Museum Comnlssion.

In 1975, in Appendix 8 to the DES-OL (June 1979), the staff reviewed the applicants'roposed alternate transmission line corridors and determined that neither of the lines under review crossed or passed in the vicinity of any registered historic site. In the DES-OL, the staff requested that a survey be done of the recreation area. The staff later requested a survey of the Pond Hill Reservoir. These surveys resulted in the identification of three significant sites and one potentially significant site in the recreation area, which the staff, after con-sultation with the Pennsylvania Historic Preservation Officer, will submit to the Keeper of the National Register for a determination of eligibility.

10.5 ENVIRONMENTAL MONITORING 10.5.1 Resume No corments.

10.5 ' Prep erational Monitorin Pro ram 10.5,2.1 Onsite Meteorological Program No comments.

10.5.2.2 Water Iluality Monitoring No coranents.

10-18 10.5.2.3 Groundwater Monitoring (DOI 9/10/79:B-7)

The applicant states that "In general, groundwater in the Paleozoic rock formations of the Appalachian Highlands flows from the topographically higher areas (recharge areas) to the valleys. This groundwater, it is believed, discharges to springs and to the streams and rivers of the region, except at flood stage" (ER-OL, p. 2.4-12). Consequently. the doses from inges-

, tion of groundwater should be no greater than the doses from ingestion of water from the river.

Any use of groundwater as a drinking water supply should be balanced by a decrease in river water as a drinking water supply.

10.5.2.4 Aquatic Biology No coranents.

10.5.2.5 Terrestrial Monitoring Program No corenents.

10.5.2.6 Radiological Monitoring (PPSL 9/4/79:B-42)

The revisions discussed in PP8L's cornnent will be used in establishing that the environmental radiation monitoring program meets the staff's" position on environmental monitoring. Lower limits of detection will be incorporated in the applicant's technical specifications.

10.5.3 0 erational Honitorin (SRBC 8/30/79:B-68; L.E. Watson:B-75; EDC 9/26/79:B-14)

As discussed in Section A.3.2.2, consumptive water use will be determined by measuring the difference in volume between the intake flows for SSES and blowdown to the river.

Results of radiological monitoring programs at nuclear power reactors are routinely made avail-able to the public. For an example of r'adiological effluent monitoring see an NRC document entitled "Radioactive Materials Released from Nuclear Power Plants, Annual Report 1977" (NUREG-0521). Individual licensee reports on radiological environmental monitoring are avail-able in the NRC Public Document Room, 1717 N Street NW, Washington, DC 20555, and in local document rooms located near each licensed facility.

NRC has factored the impact of the Three Mile Island accident, into the review of the Susquehanna application. Specifically, the Environmental Statement has been supplemented to evaluate the site;,specific environmental impacts attributable to plant-specific accident sequences that lead to releases of radiation and/or radioactive materials, including sequences that can result in

,inadequate cooling of reactor fuel and melting of the reactor core (see Sec. 6),

10.5.3.1 Onsite Meteorological Program No corments.

10.5.3.2 Water I}uality Monitoring No coranents.

10.5.3.3 Groundwater Monitoring No corments.

10.5.3.4 Aquatic Biological Monitoring No coranents.

10.5.3.5 Terrestrial Monitoring Program No comments.

10.5.3.6 Radiological Monitoring (H.H. Molesevich;B-39)

Radiological environmental monitoring is not the only type of radiological monitoring required at the Susquehanna Station. NRC requires two types of radiological monitoring at nuclear power reactors to ensure that radioactive effluents are within acceptable limits; 1) radiological effluent monitoring and 2) radiological environmental monitoring. Radiological effluent moni<<

tors are required to monitor and control, as applicable, the releases of radioactive'aterials in liquid and gaseous effluents during actual or potential releases. The radiological effluent monitors operate continuously. In addition, NRC requires that the licensee operator of a

10-19 nuclear power reactor conduct radiological environmental monitoring to confirm that measured releases of, radioactivity (i.e., radiological effluent monitoring) from the plant do not result in unanticipated buildups in the environment.

The requirements for an acceptable radiological environmental monitoring program for nuclear power reactors are contained in the NRC's "Branch Technical Position" (Revision 1, Nov. 1979; copies are available from NRC's Radiological Assessment Branch). The Branch Technical Position was developed by experts in the field of -radiological environmental monitoring. The staff does not require more frequent sample collections for several reasons. First, based upon the staffs estimate of doses to maximum individuals (e.g., see Table 4.8), the staff does not anticipate a significant buildup of radioactivity in the environment due to,normal operation of Susquehanna, Units 1 and 2. Second, hundreds of reactor-years of environmental monitoring experienced at nuclear power plants have shown that the concentrations of radioactive materials in environ-mental samples are at or very near background levels due to natural sources and previous atmos-pheric weapons tests. In addition, while it is true that the most frequent collection of environmental samples is on a weekly basis, this does not mean that environmental monitors are required to be in place continuously in order to obtain an integrated dose. The Susquehanna Station radiological monitoring program meets the basic requirements of the NRC's "Branch Technical Position" in regards to collection frequency.

The radiological environmental monitoring program is not described more fully in the final Environmental Impact Statement because the impacts of the monitoring program are negligible, However, individual licensee monitoring reports are available in the NRC Public Document Room, 1717 H Street NW, Washington, DC 20555 and in local document rooms. located near each licensed faci1 i ty.

10.6 ENVIRONMENTAL IMPACT OF POSTULATED ACCIDENTS 10.6.1 Resume No comnents.

10.6.2 Postulated Accidents Involvin Radioactive Materials (D. Oberst:8-41; H, C, Jeppsen; B-3 ; :8- 8; L. oses:B- ; S erra:8- ; /79:8-17; SA 8/17/79:8-62 and 6/10/80:8-64; F.L. Shelly:8-57; S. Shortz;8-60; H.J, Huntington:8-27; PPSL 9/4/79:B-42; PDER 8/20/79:8-50; T.R. Duck:B-ll; L.E. Watson:8-75; DOI 9/10/79:8 .7; EDC 9/26/79:8-14; SEDA:8-56; M.H. Molesevich:B-39)

NRC has factored the impact of the Three Mile Island accident into the review of the Susquehanna application. Specifically, the Environmental Statement has been supplemented to'valuate the site-specific environmental impacts attributable to plant-specific accident sequences that lead to releases of radiation and/or radioactive materials, including sequences that can result in inadequate cooling of reactor fuel and melting of the reactor core (see Sec, 6).

Emergency Response Plans are required'by the Atomic Energy Act. Under this act, the NRC and the Federal Emergency Management Agency (FEHA) are responsible for reviewing evacuation plans.

State and local evacuation plans will be generated and reviewed by the NRC and the Federal Emergency Management Agency (FEMA) before an operating license is issued.

The 28 Harch 1979 accident at TMI-2 resulted in greater amounts of radioactive water and waste than could be processed by the installed radwaste treatment systems in a short time. The solu-tion to the problem was to contain these wastes so as to permit time for radioactive decay and for installing additional treatment equipment. The new equipment has been installed and cleanup is underway as planned.

For a discussion of the responsibility of NRC to protect the health and safety of the public as they relate to nuclear plants, see Section 10.4.5.

NRC has included an evaluation of Class 9 accidents in the FES. The radiation monitors describ-ed in Table 5.1 are for preoperational purposes only. The Technical Specifications will require additional monitors for operation.

State and local evacuation plans will be reviewed by the Federal Emergency Management Agency before an operating license is issued.

Animal and food-crop samples were taken prior to the startup of the plant; the background activ-ity in these samples is determined by destructive means. Similar destructive testing of humans would not be possible. Although whole-body counting (a non-destructive test) could be done of humans near the site, this would not be effective because of the mobility of the human popula-tion and the cost of whole-body counting.

10-20 NRC has studied postulated accidents associated with the storage of spent fuel at the Susque-hanna site. The spent fuel storage area was evaluated by postulating the effects of floods, missiles, pipe breaks, and seismic'vents. The results of the NRC evaluation are documented in NUREG 0776, Section 9.1.2.

NRC has a full-time resident inspector at the Susquehanna site. As a result, the reporting of any accidents by PP&L will be supplemented with an independent NRC report and assessment.

10.6.3 Trans ortation Accidents No comments.

10.7 NEED FOR PLANT 10.7.1 Resume (LE Moses:8-41; PP&L 9/4/79:8-42)

Section 7.1 has been modified to incorporate the latest information on startup dates.

10.7.2 A licant's Service Area and Re ional Relationshi s No comments.

10.7.3 Benefits of 0 eratin the Plant (SA 8/17/79:8-62; F. Thompson:8-74; H.J. Huntington:

8-  ; . . Duck:B-ll; EDC 9/26/79:8-14; H.M. Holesevich:8-39)

The basis for operating SSES does not depend solely on reserve margin considerations. In the near-term, the economic basis is the lower cost of electricity production. In a few years, the staff expects that reserve margin requirements will no longer be adequate, and that SSES will be needed for peak-load as well as baseload energy. A further consideration is that the reserve margins were calculated as if both units of the Three Mile Island nuclear plant were in opera-tion; the EIS has therefore overstated the actual energy available in the region, at least until decisions on operation of the THI Units 1 and/or 2 are made and the unit(s) are back on line.

As discussed in the comparison of coal and nuclear fuel costs, the need for SSES in the irnne-diate future depends on lower production costs of SSES compared to other units in the system.

The coranent points out that SSES could help replace energy loss due to THI; this factor was not evaluated in the EIS. In the long run, reserve margins will not be adequate without SSES. SSES operation as scheduled and planned makes economic sense because of lower production costs and because of its contribution to meet peak energy needs.

The Price Anderson Act and government subsidies for research of waste disposal technology do represent cost advantages to nuclear energy that are available to the industry as a whole.

Removal of these advantages would not make the cost of power from SSES prohibitive as you state.

All insurance premiums are how paid by nuclear plant operators. Federally funded research in waste disposal quite likely will be a small part of the cost of waste disposal, which in turn is a small part of the cost of fuel. Waste disposal costs are already included in estimated fuel costs for SSES. Operation of SSES would prove economical even repealed and government-sponsored research stopped.

if the 'Price Anderson Act were Reasons for operating the plant were discussed and evaluated and do not consist solely of reserve margin considerations. See summary and conclusions (p. iv). Also note responses to similar questions in Coal vs. Nuclear and Benefit-Cost Analysis sections.

Although staff notes that EDC concurs that the plant is needed, reserve margin consideration is only one of several reasons for operating the plant as scheduled.

Anthracite is discussed in response to other comnents on the subject (see Sec. 10.8.4).

10.7.3.1 Operation of the PJH Interchange No comnents.

10.7.3.2 Minimization of Production Costs (PP&L 9/4/79:8-42)

The text has been revised to reflect these comnents.

10-21 10.7.3.3 Diversity of Supply Source No comments.

10.7.3.4 Reliability of Analysis (H.H. Holesevich:B-39)

As discussed in Section 7.3.4.2 of the FES, a reserve capacity larger than 20K may be desirable for a system with units that are large in relation to the size of the system (as will be the case with SSES in service).

Table 7.4 has been revised to reflect the comnents.

10.8 EVALUATION OF THE PROPOSED ACTION 10.8.1 Adverse Effects That Cannot Be Avoided No comments.

10.8.2 Short-Term Uses and Lon -Term Productivit No comments.

10.8.3 Irreversible and Irretrievable Commitments of Resources No comments.

10.8.4 Com arison of Nuclear and Coal-Fired Power Plants (H,C. Jeppsen:B-31; DOT 8/9/79; B- 0; D - S:8- ; Sierra:B-61; SA /1 79:B-62 and 6/10/80;8-64; S, Shortz:B-60; H.J. Huntington:B-27; EDC 9/26/79:B-14)

The benefits of revitalizing the anthracite-coal-producing areas is a separate issue and not related to the operation 'of,SSES. Very small amounts of anthracite are used for steam production by the utility industry primarily due to the high price of anthracite coal. The new source per-formance standards (NSPS) were rewritten to encourage the use of Eastern'oal. . These standards require removal of at least 70Ã of the SOz in the fluegas if an emission rate of 0.6 lb. of SOz per million Btus can be achieved. Ninety percent removal of SOz is required if,the limit cannot be met.

f Although these new rules do encourage the use of Eastern rather than low-sulfur. Western coal because some scrubbing is required, there is plenty of Eastern bituminous coal that can meet these requirements. Much of this coal can be obtained in Pennsylvania. It is not likely that anthracite coal can economically compete as steam-market coal. Anthracite coal revitalization depends more on the steel industry; increased demand is also more likely to come from exports rather than domestic uses.

The economic 'argument for operating SSES rather than a coal plant is based on the lower oper-ating cost of SSES compared to coal-fired plants. The cost of coal is two to three times the cost of comparable nuclear fuel. Nuclear fuel costs have ceased their rapid price escalation, while real coal prices are forecast to increase at 2.2X per year through 1990 and at 1.7% per 1980, Lexington, HA).

The long-run differepces between nuclear and coal prices are not expected to diminish. Currently negotiated uranium prices are at the level they were in late 1975; i.e..about $ 28/lb UsOa, Primarily because of the difference in fuel costs, delay of operation of SSES makes no economic sense,,even if more energy could be obtained from existing coal-fired plants. Construction of a new coal-fired plant to replace SSES would be economically unwise since SSES has already been constructed. ',

Comparison of coal vs. nuclear using anthracite coal as a reference case would not improve the economics of burning coal. Since SSES has already been constructed, the use of coal can only be evaluated for use in existing plants, Not only is anthracite more expensive than bituminous at the mine, but boilers and auxiliary equipment would have to be refurbished to use a different coal type. Derating may also be involved.

As stated in NUREG-0564, there is a considerable amount of uncertainty in estimating health effects over long periods of time (greater than 100 years). The overall uncertainty in the

10-22 nuclear fuel cycle is probably about an order of magnitude (increased or decreased by a factor of 10) over 100 years and about two or more orders of magnitude over 1000 years. The uncer-tainty associated with the coal fuel cycle tends to,be much larger because of the inability to estimate total health impacts from all the pollutants released to the environment from that cycle. However, if one assumes that most of the public impact over a period of several decades is caused by inhalation of, sulfur compounds and associated pollutants, there is as much as a two-order-of-magnitude uncertainty in the assessment of the coal fuel cycle. In view of the,.

large uncertainties in any comparison of the health effects of coal versus nuclear power plants, a site-specific comparison is not warranted.

Increased use of coal and solar power are expected, but these should not be considered as alter-natives to the operation of SSES. Nuclear power may be as safe or safer than coal with respect to release of harmful emissions (Sec. 8.4). Solar power for electrical generation has not been developed to the stage that baseload electrical generation needs can be satisfied even with increased conservation.

The staff does not consider solar energy, biomass, cogeneration, and conservation to be adequate substitutes for amounts of power that will be generated by SSES, nor would the cost of genera-tion from SSES be nearly as high as from building and operating these alternatives.

For a discussion of the transportation effects, see Section 10.4.6.

Impacts associated with both the coal and uranium fuel cycles have been addressed within a generic framework involving the development and use of various models (i.e. model mines and mining methods, model power plants, etc.). Discussion of the land requirements for supporting the uranium fuel cycle of a model 1000-mWe LWR is presented in Section 4.5.5. In contrast, Dvorak et. al. characterized the coal fuel cycle within selected source areas, thereby factoring in regional differences in coal quality, bed thickness, mining conditions, etc:s Accordingly, land disturbance resulting from surface mining to supply the annual fuel requirement of a model power plant (1000 HWe) from the various source areas was estimated as follows; Wyoming-12.1 ha, Arizona-40.5 ha, Pennsylvania 66.8 ha, Illinois 76.9 ha, and eastern Kentucky 78.9 ha, However, the listed areas (in hectares) pertain only to lands over lying the coal to be extracted. The total affected area would be dependent on the disposition of excavated overburden and, in some cases, may be twice or more times the areas listed.

The staff agrees that a general trend exists whereby continued extraction of a given unit of coal or uranium results in increasingly greater adverse impacts on the landscape, However, it should also be noted that contemporary requirements, standards, and reclamation programs im-plemented to limit such impacts are also becoming increasingly more stringent. The Surface Mining Control and Reclamation Act (SHCRA) of 1977 exemplifies the increasing public awareness of the need to prevent, control, and/or mitigate mining-related impacts. One provision of the act mandates the establishment of environmental and other criteria whereby'some coal resource areas are or will be designated as unsuitable for surface mining. Some of the reclamation requirements of the act include specifications relative to restoring natural land contours, topsoil management and replacement, restoring land-use potentials to levels comparable to or exceeding those existing prior to mining, and revegetation standards.

The indirect impacts of the coal and nuclear fuel cycles have been treated .in depth in other documents. Consideration of the coal fuel cycle is beyond the scope of this proposed action; however, nuclear power does compare favorably when "indirect effect of mining on the landscape" are examined. A comprehensive evaluation of uranium mining and milling is presented in the "Generic Environmental Impact Statement on Uranium Hilling," April 1979, NUREG-0511 (two volumes).

If utilities choose to build coal-fired plants rather than nuclear plants in the future, is it not necessarily true that the cheapest coal will come from the area near the plant. It is i unlikely that anthracite coal will be used because of the premium that that type of coal corn<<

mands on the market.

The staff does not see any relation between the issuing of a permit for the construction of Pond Hill Reservoir and the impact of' renewed anthracite industry on the region. At this point, the cost of building a new coal plant and the recovery cost of SSES would be very large as compared to the benefit derived from the renewed anthracite industry.r 10.8.4.1 Health Effects (PP&L 9/4/79:8-42)

Table 8.1 has been revised to reflect this comnent.

10.8.4.2 The Uranium Fuel Cycle No comoents ~

10-23 1 0.8.4.3 The Coal Fuel Cycle No comments.

10.8.4.4 Other Considerations (T.R. Duck:B-ll)

NRC has factored the impact of the Three Nile Island accident into the review of the Susquehanna application. Specifically, the Environmental Statement has been supplemented to evaluate the site-specific environmental impacts attributable to plant-specific accident sequences that lead to releases of radiation and/or radioactive materials, including sequences that can result in inadequate cooling of reactor fuel and melting of the reactor core.

10.8.4.5 Summary and Conclusions No co+vents.

10.8.5 Uranium-Resource Availabilit (T.R. Duck:B-11)

Section 8.5 has been revised to reflect recent changes in the outlook for future uranium-fuel supplies.

The discussion in Section 8.6 has been revised to reflect the current staff position relative to the decommissioning of nuclear facilities. These revisions sumnarize a more extensive treatment of this subject published in the "Draft Generic Environmental Input Statement on Decommissioning of Nuclear Facilities" (NUREG-0586, January 1981, U.S. Nuclear Regulatory Commission).

The decommissioning alternatives for a nuclear reactor are discussed in detail in NUREG-0586.

The dollar amount indicated in the benefit-cost section refers to one of several deconmissioning methods; no specific method of decommissioning for SSES has been selected at this time. All reasonable methods of decommissioning can be planned for with respect to engineering and finan-cial considerations. The comparison to Three Nile Island is not appropriate, because 'PII involves problems of criticality, the extent of the contamination at Unit two, and extraordinary precautions necessary to minimize occupational exposure.

10.9 BENEFIT-COST ANALYSIS 10.9.1 Resume (F.L. Shelly:B-57; F. Thompson:8-74; H.J. Huntington:B-27; S. Laughland:B-32}

The assertion that nuclear power is not competitive with other sources of electrical energy production is incorrect. SSES has already been constructed and, because this is at least half of the electricity production cost, there is no need to evaluate the coal vs. nuclear vs. alter-native sources issue. The overall energy source comparison is useful only at the construction stage, when all costs are variable and economic choices of interest are the widest possible. At the construction stage, SSES is a competitive option; at the operation stage, it is the only logical economic choice.

The use of 60 to 705 capacity factor is realistic for new nuclear plants; average capacity for nuclear units in 1979 was 65.2%. In 1979, with TMI included in the data for the first ten months, the average capacity factor was 58.95 (NUREG 0020. ~0 cretin Units Status Re ort, Vol. 4, No. 9, September 1980, p. 1-3).

The availability of electrical energy affects the demand for use through the price. With in-creasing electrical energy prices, the additional power provided by SSES is not going to en-courage increased usage.

The subsidies to nuclear power mentioned in the cormnent cannot be attributed to the construction and operation of SSES. No subsidies were provided for'this cormercial plant. Waste disposal costs have been included in studies of nuclear power economics. Plant capacity factors of 60 to 70% and no accidents that release significant levels of radioactivity to the atmosphere are the expected future of SSES; therefore, these assumptions are the proper basis for the benefit-cost assessment.

The stress to some residents near THI is real. The stress on those residents cannot be compared to that on people who live within a few miles of plants that have operated successfully without accident.

The comparative relative cost of nuclear power operation was used as the basis for assessing SSES; the absolute costs will change.

10-24 The capacity factors cited in M.J. Huntington's comnent do not reflect current data. It is true that, over the life of a 'nuclear plant, capacity factors rise and then fall in the latter years.

However, this is true of coal plants as well; this does not represent a disadvantage of nuclear plants.

The need for the plant in the proposed operating time frame is based primarily on the savings in fuel costs. SSES is also needed in the longer run to replace energy due to loss of 'generating capability, and to meet future demand for energy.

i0.9.2 Benefits No comments.

10.9.3 Societal Costs No comments.

10.9.4 Economic Costs (M.M. Molesevich:8-39)

Decoranissioning plans are prepared for plants that have completed their useful lives. In the case of TMI or any other accident, where decomoissioning is considered prior to completion of a useful operating life of from 30 to 40 years, a special investigation and study would be re-quired. Any attempt to speculate in advance on a decomoissioning plan under such extraordinary circumstances would be useful only in a generic assessment and could not be specifically applied to SSES. The decoranissioning cost is estimated in 1978 dollars and represents only one mode of decommissioning. No deconeissioning alternative based on reasonable cost ranges would affect the conclusion that the plant should operate.

10.9.5 Environmental Costs No comments.

10;9.6 Environmental Costs of the Uranium Fuel C cle No coranents.

10.9.7 Environmental Costs of Uranium Fuel Trans ortation No comnents.

10.9.8 Summar of Benefit-Cost (SA 8/17/79:8-62; PP&L 9/4/79:8-42; EDC 9/26/79:8-14; o esevic :8-The text has been revised to reflect applicable coranents.

The staff has found no evidence that employees in the area would quit their jobs if SSES .were allowed to operate.

The cost/benefit analysis for Pond Hill is given in Section A.5.3.

10.A APPENDIX A: FINAL SUPPLEMENT TO THE EIS FOR SSES 10.A.l Suranar and Conclusions Foreword Introduction 10.A.l.l Sunmary and Conclusions and Foreward (LUZ:8-38; PDER 5/20/80:8-54; HEW:8-6; DOI 5/29/80:8-9; PP&L 5/29/80:8-47) k The text of the Summary and Conclusion has been changed to reflect applicable comments.

The applicant has proposed the construction of a compensation reservoir at Pond Hill Creek in order to meet requirements of the Susquehanna River Basin Conmission during periods of low flow.

Discussion of the proposed Pond Hill Reservoir is contained in Appendix A.

10-25 I

Item 3.0 has been added to the Summary and Conclusions section of Appendix A. The operation of Pond Hill Reservoir for compensation releases will have a minimal impact on downstream portions of the Susquehanna River (Sec. 4).

The SRBC has established 1 July 1984 as the deadline for compliance with its consumptive water makeup requirements (SRBC Regulation 1, Section 803.61).

The Pennsylvania Fish Commission has been added to the distribution list for the Final Environ-mental Impact Statement.

10.A.1.2 Introduction (PP&L 5/29/80:B-47)

The text of the Introduction has been changed to reflect the applicable coranents.

10.A.2 The Site and Its Environs (DOC:B-5)

The applicant will be required to determine if any USGS markers are located in the proposed construction area. If any markers are in this area, the applicant will notify the National Ocean Survey of the National Oceanic and Atmospheric Administration (NOAA) and take appropriate steps to relocate the markers.

10.A.2.1 Plant Location (PP&L 5/29/80:B-47)

Figures A.2.2, A.2.3, and A.2.4 have been replaced with revised figures.

10.A.2.2 Land Use No coranents.

10.A.2.3 Heteorology and Hydrology (PP&L 5/29/80:B-47)

Section A.2.3.3 has been revised to include a discussion of the spring within the project boun-dary.

10.A.2.4 Geology and Seismology I

No co~ents.

10.A.2.5 Site Ecology (PP&L 5/29/80:8-47)

The references have been corrected.

10.A.2.6 Socioeconomic Profile of the Local Area No comnents.

10.A.2.7 Cultural Resources (SA 6/10/80:B-64)

For a discussion of cultural resources, see revised Section A.2.7.

10.A.3 Reservoir Descri tion The text. of Section A.3 has been changed to reflect applicable comments.

10.A.3.1 Introduction (PP&L 5/29/80:B-47; SRBC 4/30/80:8-69)

Figures A.3.1 and A.3.2 have been replaced with revised figures. Revised P'lates A-l, 2, 5, 6, 17, and 19, supplied by PP&L, were used to correct the figures.

10.A.3.2 Node of Operation (EPA 5/30/80:8-23; PP&L 5/29/80:B-47; SRBC 4/30/80:B-69}

The staff has estimated the probability, of occurrence of different periods (number of days) of low river flow that would interrupt the operation of the power station based on historical river-flow measurement. Replacement and starting energy costs associated with each shutdown have also been calculated (Table A.5.3). Because future occurrences of low river flow are impossible to forecast, the staff has,simply provided the cost associated with probab'le different low riverflow periods. The decision to accept or reject the riverflow alternative will depend upon one's confidence that future river flow wi'll follow the historic pattern. At present, the Susquehanna River has a greater degree of flow control than it had in the past. The analysis shows that, if there is an average of four days per year of low river flow over a period of 30 years, the cost of the Pond Hill project will be more than the replacement energy cost.

10-26 C

10.A.3.3 Recreation Area (EDC 9/26/79:B-'l4)

I PP8L has proposed a recreational program for the Pond Hill Reservoir. The details of this program are provided in the Environmental Statement in Section A.3.3.

10.A.3.4 Esthetics No comments.

10.A.4 Environmental Effects of Construction and 0 eration 10.A.4.1 Impacts on Land Use (DOT 4/28/80:B-ll)

The transportation impacts have been adequately addressed to the satisfaction of DOT, with the exception of sufficient coordination. It is the staff',s view that the applicant and DOT should work together to consider adequate design of the access road to the reservoir as well as atten-dant impacts. NRC will not preempt DOT expertise in matters of design and traffic coordination.

The comment attributes many of the changes in the past years to construction of SSES. Many of these changes are due to other projects, including past highway construction, and to urban-ization trends independent of, SSES. The record shows that the blasting during construction did adversely affect residents, but this should not be considered in a decision as to whether or not the plant should be operated. The cogent correctly states that the land used by SSES is an irrevocable loss, but the opinion that its former use was the best use cannot be demonstrated on economic grounds. The EIS mentions the effect of Hurricane Agnes as part of the recent history and is not meant to characterize the local area surrounding the plant.

10.A.4.2 Impacts on Water Use (EPA 5/30/80:B-23; SRBC 4/30/80:B-69; SA 6/10/80:B-64) ll Evaporation from and precipitation into the reservoir were included in the simulation of the drought of record.

The text has been changed'o reflect these comments.

10.A.4.3 Environmental Impacts (PP&L 5/29/80:8-47; EPA 5/30/80:B-23; DOI 5/29/80:B-9; SRBC 4/30/80:B-69)

The text and Figure A.4.1 have been revised to reflect applicable comments.

The statemen'ts in the text do not support the comnent per taining to'significantly negative impact on water quality." With respect to phosphorous levels, the text states that ambient phosphorous level exceeds criteria.

The expression "approximate original contours" (Appendix A, Sec. A.4.3.1) is in general accord with the applicant's commitment: "The borrow areas will be restored as closely as possible to their original condition" (ER-OL, Appendix H, Sec. 4.2.2.4). The extent to which original contours can be restored will vary; however, the staff expects the applicant to reestablish original onsite drainage to the extent possible, thereby avoiding undue disruption of offsite drainage patterns.

PPSL's coranitment on drainage features is in general agreement with a staff recommendation presented in the Section A.4.3.1, paragraph 6.

The staff acknowledges EPA's corwent to the effect that "discussion on wildlife resources is acceptable." However, the rationale whereby the staff's statement concerning the relatively low density of eastern cottontail at the Pond Hill project site has been interpreted as asserting that the cottontail is of "minor importance" is not readily apparent, nor does the staff clearly understand the intended meaning of "minor importance." Given that populations of cottontail exhibit cyclic fluctuations in northern states (as do those of ruffed grouse and snowshoe hare},

the local densities of cottontails generally parallel the availability of proper food and cover habitat. The extensive second-growth forest vegetation of the project site is approaching maturity, and the increasing closure of the overhead canopy has inhibited, and continues to inhibit, the production of shrubby and herbaceous vegetation that serves as food and cover for the cottontails. This principal consideration under lying the staff's contention is in general agreement with a citation (page A.2-12) to the effect that the cottontail population at the pro-posed reservoir site "is much lower due in part to the relatively sparse open field and meadow acreage and to high predation by great horned owl, eastern red and eastern gray foxes, and wild dogs."

The implementation of the fish and wildlife management plan is a state responsibility and is not normally handled by the NRC. The Pennsylvania State Fish Coranission and the Pennsylvania Game

10-27 Commission, with the aid of the U.S. Fish and Wildlife Service, will design a state fish and wildlife management plan.

The text of Section A.4.3.2.3 ("Operational Impacts of Discharge System".) has been revised to reflect this new information as well as the change in the design of the inlet-outlet structure.

As a result of the design change, most compensation releases from the reservoir will be from the epilimnion layer, minimizing the potential for cold shock in the river.

Several points need to be considered. First, the staff agrees that nutrients may be resuspended during turnover. Water quality data presented in Table A.4.1 of the DES indicated .pH values for Pond Hill Creek and the Susquehanna River. The staff, feels the pH of the reservoir will be such that nutrients suspended during turnover will quickly precipitate and return to the bottom sediments. A second point is that high levels of phosphorous are already present in the river.,

It is therefore incorrect to imply that phosphorous levels associated with eutrophic conditions in the reservoir will adversely effect the Susquehanna at times of compensation.'he third point is that information presented in Table 1.3.2-1 of Volume IV of the ER-OL suggests that compensation releases will primarily occur in early fall and therefore precede fall turnover.

Table 1 3.2-1 has been added to Section 4.3.2.2 of the text.

~

I Iron levels are already high in the river and have been shown not to have reduced primary pro-ductivity.

10.A.4.4 Hydrologic Impacts (DOI 5/29/80:8-9; EPA 5/30/80:8-23; SRBC 4/30/80:8-69; SA 6/10/80:

8-64; PP8IL 5/20/80:8-47)

The applicant has revised the spillway design. See Section A.4.4.2.3.

As stated in Section A.2.3.3', there is no information on historic flood flows in Pond Hill Creek because there is no gaging station on the stream.

The figures showing the floodplains of the Susquehanna River and Pond Hi'll Creek have been revised. See Figures A.2.5 and A.2.6.

Changes in the floodplain due to the construction and operation of the project are discussed in Section AD 4 "Environmental Effects of Construction and Operation."

The difference between EPA's estimate. of 986 ran and NRC's estimate of 973 ran for the 6-hr PHF is insignificant and would not alter the conclusions reached in Section A.4.4.2.3. The design precipitation series is chosen to represent an upper bound. The reservoir is designed to be able to accomnodate this precipitation series without being overtopped. Less intense storms will result in lower maximum reservoir e'levations.

The saddle referred to has a minimum elevation of 302.1 m HSL, 0.3 m above the dam crest eleva-tion of 301.8 m HSL and 2.7 m above the emergency spillway weir elevation of 299.4 m HSL. The applicant is considering the construction of an impervious cutoff across this saddle, as shown in Figure A.3.2. The minimum elevation between Lily Lake and the reservoir is 311 m HSL, more than 9 m above the elevation of the dam crest. Therefore, the possibility of either of these locations becoming spillways during a flood is precluded.

The applicant calculated the discharge temperatures from the larger reservoir using the revised inlet-outlet structure (Section A.3.1.3 and Figure A.4.1), the larger reservoir area and volume, and both 1964 and 1975 temperature data (see PP&L 5/29/80, p. 8-47). The calculated tempera-tures for the effluent stream flow, based on releases of 2.89 m>/s are given in the cited comnent.

The staff's assessment of the thermal impact of releases from Pond Hill Reservoir has not changed as a result of this design change and the modeling studies are based on 1975 meteoro-logical data.

The reservoir is well above the level of any credible flood event on the Susquehanna River. The downstream toe of the dam is'more than 70 m above the normal river level and more than 65 m above the historical maximum Susquehanna River stage (Tropical Storm Agnes, 'l972). See Sec-tion A.4.4.2.3 for a discussion of the hydrologic design of the dam with the proposed revised spillway.

Table 1.3.2-1 of Volume IV of the ER-OL presents past history data on the Susquehanna River.

This table indicates that withdrawal from the reservoir can be expected to be infrequent. This table has been included in Section A.4.3.2.2 of the text and should aid in clarifying the discussion.

10-28 The responsibility for requiring monitoring is the function of the EPA (see EPA 5/30/80,

p. 8-23), not the NRC. NRC cannot require monitoring of water quality. EPA is responsible for water quality monitoring and water quality.

, ~

Section A.4.4.2.1 has been revised to reflect these conments. The larger reservoir has been planned to meet SRBC's requirements and not specifically for the purpose of supplying additional storage capacity for other users or uses, such as sales to other utilities or industries on. the Susquehanna River. Although these other uses are possible, the staff has not attempted to evaluate them.

10.A.4.5 Socioeconomic Impacts (EPA 5/30/80:B-23)

The section has been revised to reflect these coranents.

10.A.4.6 Impacts to Cultural Resources (DOI 5/29/80:B-9)

For a discussion of cultural resources, see revised Section A.2.7.

10.A.5 Alternatives, Need for Facilit and Benefit-Cost Anal sis Section A.5 has been revised to incorporate applicable coranents.

10.A.5.1 Alternatives to Constructing a Water Storage Reservoir (EPA 5/30/80:8-23; PP&L 5/29/80:8-47 SRBC 4/30/80:B-69; FERC:B-25; SA 6/10/80:B-64)

The Pond Hill Reservoir is being planned to supplement riverflow during periods of low river-flow. The Susquehanna River Basin Conmission has directed that the reservoir be constructed by 1 July 1984. The Pond Hill Reservoir is not required for the safe operation of the nuclear plant. Therefore, the Environmental Statement review dealt only with the effect of the con-struction and operation of the Pond Hill Reservoir on the environment.

The staff does not see any relation between the issuing of a permit for the construction of Pond Kill Reservoir and the impact of a renewed anthracite industry on the region. At this point, the cost of building a new coal plant, and the recovery cost of nuclear portions of SSES would be very large as compared to the benefit derived from the renewed anthracite industry.

SRBC has failed to indicate in its comments the effect it believed its recooeendation would have on the availability of a back-up water supply contemporaneous with construction and operation of SSES. The staff notes, however, that the conclusions reached in the FES do not rest on the availability of a back-up water supply. Instead, the staff assumed compliance with the SRBC rules without such a system.

The FES (see Sec. A.5.1.2) has been revised to reflect the SRBC's position on the Cowanesque Reservoir.

10.A.5.2 Alternative Sites (SRBC 4/30/80:B-69)

The text of Paragraph 1 of Section A.5.2 is correct. As stated in References 24 and 29 of Section 2 of this Appendix, the initial design criteria for the water storage reservoir were based on a I)7 10 river flow of 21.8 ms/s; the alternative site analyses were 'conducted on this basis, including the 96-day compensation flow requirement. Later, the g7 ~0 value was changed 'o 22.7 m>/s. The dam design given in the ER-OL,,Appendix H, and in this Environmental State-ment is based on the higher g7 10 value.

10.A.5.3 Benefit-Cost Analysis (FERC:B-25; PP&L 5/29/80:B-47; SRBC 4/30/80:B-69)

The staff disagrees with the change suggested by PP&L (5/29/80, p. B-47}. If PP&L meets PJH's reserve requirements, PJK could still buy the needed amount of electricity from PP&L and would not suffer the loss of sale. Kowever, the ability of PP&L to supply power to the rest of the network would be re'duced if the river-following mode of operation were utilized.

The probability of a shutdown of less than or equal to 14 days is 94.1X. Section A.5.3.1 has been revised to reflect this comment.

A mathematical average of four-day shutdown does not mean that the plant will be closed, every year for four days. Like any average, it simply means that the plant may be closed for more than four days in some years and for less than four days in others. Over the period of observa-tion, the sum of deviation from the mean is expected to be zero, The calculation of the present value of the replacement energy cost gives an estimate of the cost incurred by the applicant the future riverflow follows a similar historical pattern. Table 5.3 does present the cost if associated with different expected values of number of days of plant shutdown.

10-29 As per the applicant's response, the average annual energy requirement, including the purchase of replacement energy during the four-day shutdown and the energy needed to, start the plant are between 160,000 and 170,000 HWh, depending on the length of time associated with cold or hot reactor shutdown conditions. The staff assumed that the incremental amount of electricity required to start up the plant from cold vs. hot reaction shutdown condition to be 10,000 HWh.

As there is no definite knowledge at this point of the plant shutdown condition, the staff assumed a 50/50 chance of hot or cold shutdown over the life of the project. Under this assump-tion, the yearly average amount of electricity requirement comes to 165,000 HWh. The staff assumes that the energy requiremen't is 146,000 HWh (2100 HW x 4 days x 24 hr/day x 0.70 cap.

factor + 5000 HMh).

The staff agrees that there may not be a substantial savings in the operating variable cost during the shutdown period. The amount of savings realized (if any) would not alter the find-ings of the analysis.

The staff does not find any cost difference between the report based on the applicant's response and the one by the cogent. Please note that the present value of the cost reported here includes the cost of the project ($ 65 million) and the yearly operating cost of,$ 100,700 over 30 years.

The staff agrees that such a situation may arise (see PP&L 5/29/80, p. 8-47}, but it is highly unlikely that low river flow and fuel-oil curtailment would occur at the same time.

Table A.5.4 has been revised to reflect this cogent.

10.A.5.4 Evaluation of Unavoidable Adverse Environmental Impacts of the Proposed Action No corments.

10.8 COHHEATS ON DES No coraaents.

10.C ENVIRONHENTAL ASSESSMENT BY THE DIVISION OF SITE SAFETY AND ENVIRONHENTAL,ANALYSIS FOR PROPOSED HODIFICATIONS TO THE TRANSMISSION LINE SYSTEH (DA-SCS:8-4; DOI 9/10/79:8-7; H.H. Holesevich:8-39)

Information presented by the applicant indicates that they sought and received an "erosion control program and permit" from the PDER (ER-OL, Sec. 12.1.2). Similar information indicates that., the applicant periodically consulted with the Soil and Mater Conservation Districts re-garding methods to control soil erosion (ER-OL; Sec. 4.5). Furthermore, the staff evaluated the applicant's proposed plans for control1ing erosion during transmission-line construction; such plans were found acceptable (see Appendix C, p. C-6 and Sec. 5.3.5}.

The staff would also like to point out that land disturbance at the plant site and within transmission-line rights-of-way results primarily from construction activities; whereas the focus of this statement is on impacts associated with operation of the station and transmission facilities. The staff foresees no instances in which routine operation of the facilities will result in significant land disturbance.

The staff has elected to address the "possibility" refer red to in the comment as follows. The applicant states that easements are usually acquired for transmission-line rights-of-way (ROM}.

These easements allow the owners continued use of the ROW consistent with safe and efficient operation and maintenance of the transmission lines and structures (ER-CP, Section 3.2.6).

Thus, the future use of cleared ROM will be subject to individual agreements between the owners and the applicant, and may or may not involve plantings for wildlife food or cover.

As indicated in Appendix 8 (p. 8-6), woody vegetation will be removed from the ROW by "selec-tive" or "tailored" methods of clearing. Accordingly, complete remova'1 of trees and underbrush will occur only in limited areas, such as tower-construction sites and service roads. In general, only tall trees and those of growth habits. that could interfere with energy trans-mission will be removed from the ROM. Certain trees of limited-height growth potential, shrubs, herbs, and grasses will be preserved "to the greatest extent practical" (ER-CP, Amendment 5, Exhibit 8), thereby limiting the area of disturbance and erosion potential. In many instances, the residual vegetation is expected to be sufficiently beneficial for wildlife so that plantings for, food and cover will be 'unnecessary.

The staff encourages the establishment of wildlife habitat in areas where such management is compatible with other land-use priorities. However, "using plantings recoranended by the

10-30 Pennsylvania Game Conmission for all forested areas cleared during transmission line construc-Figures have been changed in response to the comment made.

References

1. Letter from H.R. Buring (PP&L) to J.T. Ulanowski (PDER), 9 April 1980.

2. Letter from J.T. Ulanowski (PDER) to H.R. Buring (PP8L), 29 April 1980.

3. Letter from N.M.. Cuntis (PPQ.) to O.E. Sells (NRC), 13 November 1979.

4. G.W. Patterson, C.R. Curtis, T.L. Lauves, and G. Hosokaiva, "Chalk Point Cooling Tower Project, Native Vegetation Study, Final Report, FY '78," Report No. PPSP-CPCTP-24, WRRC Special Report No. 10, Water. Resources Research Center, University of Haryland, College Park, HD, June 1978.

5. C.L. Hulchi, D.C. Wolfe, and J.A. Armbruster, "Cooling Tower Effects on Crops and Soils, Postoperational Report No. 3, Final Report, FY-78," PPSP-CPCTP-23, WRRC Special Report No. 11, Mater Resources Research Center, University of Haryland, College Park, HD, 1978.

6. C.RE Curtis, B.A. Francis, and T.L. Lauver, "Dogwood as a Bioindicator Species for Saline Drift," pp. I-65 through I-77, In Proceedings of a Symposium on Environmental Effects of Cooling Tower Emissions, Hay 2-W 1978, University of Maryland, College Park, HD, 1978.

7. "An Ecological Study of the Susquehanna River in the Vicinity of the Three Hile Island Nuclear Station, Annual Report for 1975," ~B M.A. Potter, Project Leader, and Associates, for Hetropolitan Edison Company, Ichthyological Associates, Inc., Ithaca, NY, February 1976.

8. BE L. Cohen, "Radon: Characteristics, Natural Occurrence, Technological Enhancement, and Health Effects." Vol. 4, Pro ress in Nuclear Ener , 1979.

9. A.J. Dvorak et al., "The Environmental Effects of Using Coal for Generating Electricity,"

NUREG-0252, prepared by Argonne National Laboratory for the U.S. Nuclear Regulatory Com-mission, 1977. *

10. Natural Resources Defense Council, "Denial of Petition for Rulemaking," 42 FR 34391, 5 July 1977, Available in the NRC Public Document Room.

11. U.S. Department of the Interior, Fish and Wildlife Service, "Hanagement of Transmission Line Rights-of-Way for Fish and Wildlife," Vol. I, Chapter 3; Section 14, FMS/OBS-79/22, 1979.

va a e or, pure ase from the Natiogal Technical Information Service, Springfield, VA 22161.

NUREG-1981 APPENDIX A FINAL SUPPLEMENT TO THE ENVIRONMENTAL STATEMENT BY THE U.S. NUCLEAR REGULATORY COMMISSION FOR SUSQUEHANNA STEAM ELECTRIC STATION, UNITS 1 AND 2 proposed by PENNSYLVANIA POWER AND LIGHT COMPANY ALLEGHENY ELECTRIC COOPERATIVE, INC.

Docket Nos. 50-387 50-388

SUMMARY

AND CONCLUSIONS

This Appendix to the Final Environmental Statement was prepared by the U.S. Nuclear Regulatory Comtssloo (NRC), Off(ca of Nuclear Reactor Regulatloo (the staff).

1. The action is administrative.

2. The proposed action is the issuance of construction permits by local, state, and federal agencies (including the Susquehanna River Basin Co()I)ission, SRBC) for the construction of a water storage reservoir in the Pond Hill Creek drainage basin. The proposed site is 'located on a small tributary of the Susquehanna River in Conyngham Township, Luzerne County, Pennsylvania. The site is approximately ll km northeast of the borough of Berwick, Penn-sylvania, and about 3.7 km northeast of the Susquehanna Steam Electric Station (SSES), now under construction. The purpose of the proposed reservoir is to supply water to the Susquehanna River during periods of low river flow to replace the water consumptively used by SSES.

Action by the NRC is not required for the issuance of construction permits for this reser-voirs This Environmental Statement has been prepared by the Nuclear Regulatory Co)naission to describe the environmental impacts of construction and operation of the Pond Hill Reser-voir since the facility is associated with the operation of the Susquehanna Steam Electric Station.

The facility will consist of an earth and rockfill dam constructed across the valley, about 1.3 km east of the Susquehanna River, a spillway, an inlet-outlet structure, a pipeline, and a pumping station. The dam would be about 730 m in length at crest level; the maximum height above the streambed will be about 67 m. Normal water storage capacity of the reservoir would be about 30 )c 106 ms (24,100 acre-feet), of which about 905 (5 x 106 m ),

will be available for compensation flow. The water area of the reservoir will be about 128 ha at the design normal water level of 299 m MSL.

3. The information in this statement represents an assessment of the environmental impacts associated with the construction of the Pond Hill Reservoir, pursuant to the guidelines of the National Environmental Policy Act of 1969 (NEPA) and 10 CFR Sl of the Co)mnission's regulations. The staff has reviewed the impacts that would occur due to the construction and operation of the reservoir. The staff's analysis is based on a review of material supplied by the applicant, Pennsylvania Power 8 Light Co. (PP8L); a review of other mate-rial secured independently; a visit to the proposed and four of the alternate sites; and discussions with various state, local, and federal officials. The potential impacts, both beneficial and adverse, are su)n))arized as fol'iows:

a. The valley and Pond Hill Creek will be permanently altered.

b. Approximately 525 ha of land will be dedicated to the reservoir for the life of the faci1 i ty.

c. About 2.3 km of Pond Hill Creek will be converted from a free-flowing stream to a reservoir; the 1.3-km section of the creek below the dam will be converted from a free-flowing, sometimes intermittent, stream to a partially regulated stream with a minimum flow maintained by releases from the reservoir.

d. As much as 195 ha of terrestrial environment may be directly affected and variously altered due to development of the Pond Hill Reservoir. About 128 ha of forested area will be inundated. Impoundment structures will occupy about 16 ha. Most of the remaining disturbed area will be reclaimed and landscaped following construction.

e. Vegetation in,. the areas covered by water and structures will be converted into habitat for aquatic biota.

f. Some wildlife mortality wil'1 occur as the result of construction activities and the initial filling of the reservoir; in addition, some animals will be displaced from affected areas. Adverse effects on terrestrial wildlife will be variously offset by reclamation of disturbed areas, creation of aquatic habitat, and the implementation of a wildlife habitat -improvement program.

A.i

go Land-clearing and construction activities will temporarily cause locally increased levels of noise as well as emissions of smoke and dust. Some soil erosion will occur despite the implementation of control measures. Also, topsoil materials used in reclamation will have undergone adverse physical and chemical changes that may be reflected by reduced future productivity of the affected areas.

h. Fluctuating water levels, to the extent the project is used for low-flow compensation, will result in exposed areas and will alter some of the aquatic habitat created by the dam for the period of drawdown and refill.

There will be a temporary increase in highway traffic due to workers comnuting to and from the area during construction and to trucks bringing in construction materials and supplies and removing refuse.

The water quality of Pond Hill Creek below the reservoir will generally be lower than that prior to reservoir establishment.

k. Based on the droughts of record, the, discharge and storage capacities of the reservoir are greater than those required to provide compensation water to the Susquehanna River as a result of SSES operation.

l. About 145 ha of land will be converted from their present use to certain recreational uses, such as hunting and hiking. The reservoir may be developed for certain water recreational activities, such as non-power boating and fishing.

m. As a result of reservoir development, an increase in waterfowl and aquatic and shore-line wildlife may occur.

n. Hino'r changes in local demography, settlement patterns, and sociocultural structures will result from the construction and operation of the reservoir.

E

o. The operation of Pond Hill Reservoir will have a minimal impact on water quality and aquatic ecology in the downstream portions of the Susquehanna River, On the basis of the analysis and evaluation set forth in this Statement, and after weighing the environmental, economic, technical, and other benefits against environmental costs and after considering available alternatives it is concluded that the construction of the Pond Hill Reservoir is an acceptable method for complying with the low-flow water use require-ments of the Susquehanna River Basin Comnission. The staff's assessment indicates that the environmental and other impacts of the reservoir will be minimal'

'i/I nl.

CONTENTS

~Pa e A. i ll SUNHARY AND CONCLUSIONS .

q

~ ~

LIST OF FIGURES . ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ A.v LIST OF TABLES ~ ~ A.vi FOREWORD A.vii A.l. INTRODUCTION A.l-l A.l.l History A.l-l A.l.2 Permits and Licenses . A.l-l A.2. THE A.2.1 A.2.2 Land Use .

. ~.....

SITE AND ITS ENVIRONS .

Plant Location

~ ~

A.2-1 A.2-1 A.2-1 A,2.3 Meteorology and Hydrology ~ ~ ~ ~ A.2-1

, A.2.3.1 Meteorology A.2-1 A.2.3.2 Hydrology A.2-5 A.2.3.3 Mater Sources ~ ~ ~ A.2-5 A,2.4 Geology and Seismology ~ . . ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ A.2-9 A.2.4.1 Geology A.2-9 A.2.4.2 Seismo'logy . A.2-9 A.2.5 Site Ecology . A.2-9 A.2.5.1 Terrestrial Ecology A.2-9 A.2.5.2 Aquatic Ecology ~ ~ ~ ~ ~ ~ 4 ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ A.2-14 A.2.6 Socioeconomic Profile of the Local Area A.2-20 A.2 '.1 Demography . . . . . . ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ A.2-20 A.2.6.2 Settlement Pattern . . ~

• I

~ ~ A.2-20 A.2.6.3 Social Organization A.2-20 A.2.6.4 Social Services A.2-20 A.2.6.5 Political Organization ~ ~ A.2-21 A.2.6.6 Economic Organization ~ ~ ~ A.2-21 A.2.6.7 Sociocultural Character istics A.2-21 A.2.7 Cultural Resources . . A.2-21 A.2.7.1 Region . ~ ~ ~ A.2-21 A.2.7.2 Pond Hill Site , . . . A.2-21 References A.2-22 "

A.3. RESERVOIR DESCRIPTION . A.3-1 A.3.1 Introduction . A.3-1 A.3.1.1 Embankment Dam . . . . . .'. . A.3-1 A.3.1.2 Spillway . . . . . . . . . . . . . A.3-1 A.3.1.3 Inlet-Outlet Structure . A.3-1 A.3.1.4 Water Conduit A.3-5 A.3.1.5 Pumping Plant and Intake Structure A.3-5 A.3,1.6 Access Road A.3-5 A,3.2 Node of Operation A.3-5 A.3..2.1 Initial Filling of Reservoir . A.3-5 A.3.2.2 Compensation Releases A.3-5 A.3.2.3 Conservation Releases A.3-7 A.3,2.4 Refilling the Reservoir A.3-7 A.3 ' Recreation Area A.3-7 A.3.4 Esthetics A.3-7 A.3.4.1 Construction . . . . . . . . . . , A.3-7 A.3.4.2 Operation A.3-7 Refer ence . A.3-7 A.4. ENVIRONNENTAL EFFECTS OF CONSTRUCTION AND OPERATION ~ ~ A.4-1 A.4.1 A.4.2 A.4 ~ 3 Impacts on Land Use Impacts on Mater Use.............

Environmental Impacts A.4-1 A.4-1 A.4-1

CONTENTS

~Pa e A.4.3.1 Terrestrial A.4-1 A.4.3.2 Aquatic A.4-4 A.4.3.3 Atmospheric A.4-10 A.4.4 Hydrologic Impacts . . . ~ ~ 0 ~ ~ A.4-10 A.4.4.1 Construction A.4-10 A.4.4.2 Operation A.4-11 A.4.5 Socioeconomic Impacts A.4-12 A.4.5.1 Demography . A.4-12 A.4.5.2 Settlement Pattern . A.4-13 A.4.5.3 Impacts to the Social System . . . . . . . . . . A.4-14 A.4.5 ' Social Services A.4-14 A.4.5.5 Impacts to the Political System A.4-14 A.4.5.6 Impacts to the Economic System . . . . . . '.4-14 A.4.6 Impacts to Cultural Resources A.4-14 References A.4-14 A.5. ALTERNATIVES, NEED FOR FACILITY, AND BENEFIT-COST ANALYSIS A.5-1 A.F 1 Alternatives to Constructing a Water Storage Reservoir . A.5-1 A.5.1.1 No Action Alternative -- "River Following" '. A.5-1 A.5.1.2 Use of Existing Reservoirs . . . .

A.5-1 A.5.1.3 Summary A.5-2 A.5.2 Alternative Sites A.5-2 A.5.3 Benefit-Cost Analysis A.5-2" A.5.3.1 No Action Alternative -,- "River Following" . . . A.5-2 A.5.3.2 Use of Existing Reservoirs A.5-4 A.5.3.3 Pond Hill Reservoir A.5-4 A.5.3.4 Discussion and Conclusions A.5-4 A.5.4 Evaluation of Unavoidable Adverse Environmental Impacts of the Proposed Action . . , , . . . . . . . , .

~ ~ ~ . AD 5-4 A .5.4 ' Land . . ~ . . . . . . . . . . . ~ . . . . . , , . A,5-4 A.5.4.2 Water A.5-5 A.5.4.3 Air A.5-5 A.5.4.4 Terrestrial Ecology ~ ~ \ ~ ~ ~ A.5-5 A.5.4.5 Aquatic Ecology ~ ~ ~ ~ ~ A.5-6 Reference . . . . . ~ ~ ~ ~ ~ ~ ~ A.5-6 APPENDIX 1. LETTER FROM U.S. FISH AND WILDLIFE SERVICE re federal ly proposed endangered and threatened species in Pennsylvania A.App.

1-1 APPENDIX 2. ARCHEOLOGICAL SURVEY PLAN FOR THE POND HILL RESERVOIR SITE PREPARED FOR PP&L BY CURTIS E. LARSEN, ARCHEOLOGIST, COMMONWEALTH ASSOCIATES, INC , JACKSON, MICHIGAN, 31 OCTOBER 1979 . A.App.

2-1

FIGURES

~Ft ule ~Pa e A.2.1 Pond Hill Reservoir Site Location . A.2-2 A.2.2 General Plan of the Pond Hill ReserVoir Project . . . . . A.2-3 A.2.3 Land Requirements for the Pond Hill Reservoir Project . A.2-4

'.2 ' Water equality and Aquatic Life Sampling Stations at Pond Hill Creek . . . A.2-6 A.2.5 of Pond Hill Creek . . . . . . .'loodplain A.2-7 A.2.6 Floodplain of the Susquehanna River in the Vicinity of tPe Pond Hill Site . A.2-8 A.3.1 Pond Hill Reservoir Construction Areas A.3-2 A.3.2 General Project Plan for Pond Hill Reservoir with Alignment of Alternatives A.3-3 A.3.3 Detailed Schematic of Spillway Structure for Pond Hill Reservoir A.3-4 A.3.4 Proposed Intake for Pond Hill Reservoir . A,3-6 A.4.1 Inlet-Outlet Structure A.4-9 A.v

TABLES Table ~Pa e A.2.1 Principal Plant Species of Terrestrial Vegetation Types Occurring at the Pond Hill Site . A.'2-11 A.2.2 Water Iluality Criteria for Pond Hill Creek . A.2-15 A.2.3 A.2.4 Water Water Iluality Data from the Upper Section of Pond Hill Creek........

Iiuality Data from the Lower Section of Pond Hill Creek .

A.2-'16 A.2-17 A.2.5 Water Iluality in'the Susquehanna River near the Proposed Intake Site.... A.2-18 A.4.1 Comparisons of Water guali ty of Susquehanna River and Pond Hill Creek A.4-5 A.4.2 Summary of Reservoir Operation Based on Historical Flow Records of the Susquehanna River at Wi lkes-Barre A.4-6 A.4.3 Anticipated Evaporation Rated on a Monthly Basis fo'r the Pond Hill Reservoir A-4-8 A.5.1 Thirty-year Present Worth of the Average Annual Replacement Energy Cost. . . A,5-3 A.5.2 Staff Estimates of Replacement Energy Cost at the Incremental Price A.5-3 A.5.3 Shutdown Probabilities . . . . ~ . . . . . . . A.5-3 A.5.4 Effect of Shutdown on Reserve Hargin . . . . . . . . . . . . . . . . . . , . A.5-5 A.vi

FOREWORD This Appendix to the Final Environmental Statement was prepared by the U.S. Nuclear Regulatory Coranission, Office of Nuclear Reactor Regulation (the staff), in accordance with the Comnission's regulation, 10 CFR 51, which implements the requirements of the'National Environmental Policy Act of 1969 (NEPA).

NEPA states, among other things, that it is the continuing responsibility of the federal govern-ment to use all practicable means, consistent with other essential considerations of national policy, to improve and coordinate federal plans, functions, programs, and resources to the end that the nation may:

Fulfill the responsibilities of each generation as trustee of the environment for succeeding generations.

Assure for all Americans safe, healthful, productive, and esthetically and culturally pleasing surroundings.

Attain the widest range of beneficial uses of the environment without degradation, risk to health or safety, or other undesirable and unintended consequences.

~ Preserve important historic, cultural, and natural aspects of the national heritage, and maintain, wherever possible, an environment that supports diversity and variety of individual choice.

~ Achieve a balance between population and resource use that will permit high standards of living and a wide sharing of life's amenities.

4

~ Enhance the quality of renewable resources and approach the maximum attainable recycling of depletable resources.

Further, with respect to major federal actions significantly affecting the quality of the human environment, Section 102{2){C) of NEPA calls for preparation of a detailed statement on:

(i) the environmental impact of the proposed action (ii) any adverse environmental effects that cannot be avoided should the proposal be implemented (iii) alternatives to the proposed action (iv) the relationship between local short-term uses of the human environment and the main-tenance and enhancement of long-term productivity (v) any it reversible and irretrievable commitments of resources that would be involved in the proposed action, should it be implemented An environmental repot t accompanies each application for a construction permit. A public an-nouncement of the avai'lability of the, report is made. Any coaeents on the report by interested persons are considered by the staff. In conducting the required NEPA review, the staff meets with the applicant to discuss items of information in the environmental report, to seek new information from the app'licant that might be needed for an adequate assessment; and generally to ensure that the staff has a thorough understanding of the proposed project. In addition, the staff seeks information from other sources that will assist in the evaluation and visits and inspects the project site and surrounding vicinity. Hembers of the staff may meet with state and local officials charged with protecting state and local interests. On the basis of all the foregoing and other such activities or inquiries as are deemed useful and appropriate, the staff makes an independent assessment of the considerations specified in Section 102(2){c) of NEPA and 10 CFR 51.

This evaluation leads to the publication of a draft environmental statement, prepared by the Office of Nuclear Reactor Regulation, which is then circulated to federal, state, and local governmental agencies fot comment. A summary notice of the avai'lability of the applicant's A,vii

environmental report and the draft environmental statement is published in the Federal Re ister .

Interested persons are also invited to-cogent on the proposed action and the dra t statement.

Comments should be addressed to the Director, Division of Licensing, at the address shown below.

A After receipt and consideration of contents on the draft statement, the staff prepares a final environmental statement,. which includes a discussion of questions and objections raised by the cornnents and the disposition thereof; a final benefit-cost analysis, which considers and balances the environmental effects of the facility and the alternatives available for reducing or avoid-ing adverse environmental effects with the environmental, economic, technical, and other bene-fits of the facility.

This environmental review deals with the impact'of construction and operation of the Pond Hill Reservoir on the environment. This evaluation is based on information supplied by the applicant, Pennsylvania Power 8 Light Company, in Appendix H to the Environmental Report for the Susquehanna Steam Electric Station (May 1979) and other documents, a visit to the site of the proposed reservoir (and four of the alternate sites), and meetings with state and local off5cials.

No NRC action is required prior to the start of construction or operation of this facility,

~

since the nuclear power plant can be granted an operating license without the reservoir. Prior to start of construction, the applicant will obtain the necessary permits from state, local and federal agencies, such as the Susquehanna River Basin Commission (SRBC), U.S. Corps of Engineers (COE), and the U.S. Environmental Protection Agency (EPA).

Copies of this statement are available for inspection at the Commission's Public Document Room, 1717 H Street NW, Washington, DC, and at the Ousterhout Free Library, Reference Department, 71 South Franklin Street, Wilkes Barre, PA. Single copies of this statement may be obtained by writing to:

Director, Division of Licensing Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Comnissioni Washington, DC 20555 Mr. Richard M. Stark is the NRC Project Manager for this project. Mr. Stark may be contacted at the above address or at 301/492-7238.

A.l. INTRODUCTION A:1 .1 HISTORY Makeup water for the two nuclear reactors of the Susquehanna Steam Electr'ic Station (SSES) will be withdrawn from the Susquehanna River. When construction permits CPPR-101 and CPPR-102 were issued on 2 November 1973, there >>ere no restrictions on the amount of water that could be consumptive1y used by SSES. Water uses and withdrawals in the Susquehanna River Basin are controlled by the Susquehanna River. Basin Comnission (SRBC). This commission, formed by a compact between the states of New York, Pennsylvania, and Maryland and th'e federal government, issued new rules in 1976 prohibiting large water users, such as the applicant, from withdrawing water from the river and using it consumptively during periods of low river flow without return-ing to the river, from offstream storage reservoirs, water at a rate equal to actual consumptive losses. The cutoff point for limiting withdrawals has been set by the SRBC as the consecutive seven-day low flow to 'be expected every ten years (called the I)7-10 flow rate). In February 1980, SRBC established 1 July 1984 as the deadline for compliance with its water make-up require-ments (SRBC Regulations, Sec. 803.61).

The SRBC has determined that, based on 80,years of riverflow data, the g7-10 value applicable to SSES is 22.7 m /s, as measured at the Wi lkes-Barre gauge (letter from R. J. Bielo, SRBC, to W. H. Regan, Jr., NRC, 30 August 1979).

The applicant has considered three alternatives for meeting the low-flow compensation require-ments of SRBC:

1. Not to operate the plant whenever river flow is at or below the I)7-10 value plus consump-tive use.

2. To purchase the required water from an existing reservoir.

3. To construct its own water storage reservoir.

Option 1, called "river following,'.-'ould require replacement electrical-generating capacity, either from other Pennsylvania Power & Light facilities or from the PJM* grid.

The applicant has examined the relative merits of these three alternatives and has concluded that the most economically desirable and most reliable means of meeting the low-flow compensa-tion requirement would be by the construction of a new reservoir owned and controlled by PPSL.

After examining thirteen sites along the Susquehanna River, the applicant selected a small unnamed valley on the east bank of the river about 3.7 km upstream of SSES as the site for the proposed reservoir. The valley contains a small creek that flows intermittently and is near the settlement of Pond Hill. The company has named the proposed facility "Pond Hill Reservoir."

A.1.2 PERMITS AND LICENSES The NRC has no legal authority for the issuance or denial of any permit to construct or operate a water storage reservoir, since SSES can be granted an operating license without such a facility.

The NRC has reviewed the applicant's request to bui ld an offstream water storage reservoir and has prepared this Appendix to the Final Environmental Statement to describe the environmental impacts of the proposed facility as well as alternatives to the proposed action.

In March 1979 the applicant submitted an application to the SRBC to build the Pond Hill Reservoir; to date the Coaeission has not completed its review of the application. The applicant will obtain the necessary permits from the Corps of Engineers, U.S. Department of Commerce National Ocean Survey, and other federal, state, and local officials. The proposed facility is in Conyngham Township, Luzerne County, Pennsylvania.

• Interconnection Group located in Pennsylvania, New Jersey, and Maryland.

2 A.2. THE SITE AND ITS ENVIRONS A.2.1 PLANT LOCATION The site of the proposed Pond Hill Reservoir is a small valley drained by a small tributary of the Susquehanna River, about 3.7 km upstream of SSES (Fig. A.2.1). The site is about 24 km southwest of the city of Wilkes-Barr e and ll km northeast of the Borough of Ber wick, PA. The site is about 32 river kilometers downstream of Wilkes-Bar re. The creek draining this valley is not named on detailed U.S . Geological Survey maps (Nanticoke 7.5 minute U.S.G.S. quadrangle),

but is known locally as Catfish Creek. Figure A.2.2 is a plan view of the proposed project; showing the location of various structur es as well as high and low water levels in the proposed reservoir.

The site of the proposed facility is in Conyngham Township of Luzer ne County. Since the creek and valley are located -just north of the settlement of Pond Hill, the applicant has used. the terms Pond Hill Reservoir for the water storage facility and Pond Hill Creek for the tributary.

The coordinates of the site are 40'8'N, 76'7'W. Present access to the site is over secondary roads through the settlement of Pond Hill.

The north slope of the valley is steep, with a ridge rising from about 215 to 245 m above the valley floor (see Figs. A.2.2 and A.2.3). The south slope of the Pond Hill Creek drainage area is flatter, with a ridge line about 60 to 90 m above streambed.

State Highway 239 parallels the Susquehanna River just to the west of the site and connects the villages of Wapwallopen and Hocanaqua. The Pennsylvania Department of Transportation estimated that the average daily traffic on this stretch of Route 239 was 1 550 cars/day in 1 978. Local Road 40120 is the primary access road from Route 239, the Pond Hill Reservoir site, the settle-ment of Pond Hill, and the Lily'ake co~unity bordering the lake; estimated usage in 1978 was 750 cars/day.

The Delaware and Hudson Railroad runs a single-track, north-south line parallel to the river just to the west of State Route 239. Naximum daily use of this line is four trains per day.

A.2.2 LAND USE Although the exact site boundaries (and, therefore, the site area) have not yet been established, the area of the site is expected to be about 525 ha. The tentative site boundaries are shown in Figure A.2.3; this figure also shows local roads, local topography, and the settlements of Pond Hill and Lily Lake.

One unoccupied structure lies within the proposed site area. There are no inhabited structures.

About of the site is presently covered with second-growth forests and about 7$ consists of 93%

old fields and croplands. Less than ll of the area is classified as wetlands.

Recreational use of the site includes walking, hiking, nature study, and hunting. Fishing is not now possible since the str eam does not support a viable gamefish population.

A.2 ' METEOROLOGY AND HYDROLOGY A.2.3.1 ~Neteorolo Since the site of the proposed reservoir ss less than 4 km northeast of the site of SSES, meteor-ological and climatological conditions of the site are the same as those given in Section 2.4 of this Environmental Statement.

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A.2-5 A.2.3.2 ~Hdrolo Pond Hf'll Creek is a small stream with headwaters approximately 1.3 km north of the town of Pond Hill. The stream flows westerly for 3.5 km to fts confluence with the Susquehanna River, 3.7 km upstream from the Susquehanna Steam Electric Station. There are no signfffcant tributaries to Pond Hill Creek. During dry periods, the streamflow decreases and some sections become essen-tially intermittent, with water remaining only in the streambed interstices. The proposed reservoir, will inundate a 2.3-km (64%) upstream section of the stream, leaving 1.3 km from the dam to the Susquehanna River . For purposes of this discussion, the flooded stream and lower, unflooded section are referred to as the "upper" and "lower" portions of Pond Hill Creek, respectively.

The upper section of Pond Hill Creek has an average ll m/km stream gradient. Throughout most of this section, the stream alternates between small-pool and riffle habftats, with a substrate of boulders, rubble, and some bedrock. This pattern is interrupted fn two areas, which wer e pre-viously inundated as a result of beaver dams. In these areas, the streambed is mostly silt, mud, and gravel. Thus, the resultant stream habitat becomes a long, continuous run. The upper stream has a 2.1-m average width, with measurements ranging from 0.8 to 3 ' m throughout the year. The average depth is approximately 0.1 m, with a total range of from 0.03 to 0.39 m.

Current velocities average 0.005 m/s, ranging from 0.003 to 0.02 m/s.

The lower section of Pond Hill Creek has a much steeper gradient; the average stream gradient in this section is about 70 m/km, The 2.6-m average stream width ranges from 0 ' to 4.2 m, and the average depth is approximately 0.1 m, with a minimum of 0.03 and a maxfmum of 0.39 m. Current velocities average roughly 0.007 m/s, ranging from 0.003 to 0.02 m/s." Characteristically, the stream substrate is bedrock and boulders along with some rubble and isolated patches of gravel.

Because of the sharp gradient, stream habitats are typical'ly shallow, fast-flowing rfffles interspersed with small pools. There are several small, and one relatively large, waterfalls in this part of the stream. In addition, at Route 239, the stream passes through a culvert and falls about 1.5 m from the elevated culvert back into the stream channel.

Since there are neither extensive nor accessib'le pub'fished data concerning the aquatic ecology of Pond Hill C~eek, information presented in the following sections was gathered from field surveys conducted by the applfcant from September 1977 to August 1978 (ER-OL, Section 3 '.3.1.1).

The locations of the water quality and biological sampling stations used at Pond Hill Creek are presented fn Figure A.2.4. Water quality samples were taken monthly at the site, and biological samples were co11ected quarterly. In addition, a fish sample was taken from three small farm ponds, which are located at the site and drain into Pond Hill Creek.

The drainage area of the stream*above the proposed site of the dam is 329 ha. Because there is no gauging station on the stream, no information on historic flows is available. The applicant did, however, estimate flood flows using standard hydrologic methods. The estimated 4X chance (25-year recurrence) flood flow is 39. 3 m>/s, the 1$ chance (100-year) flood flow is 49.7 ms/s, and the estimated probable maximum flood flow is 202 m /s. In addition, the methodology utilized by the Pennsylvania Department of Environmental Resources (DER) to estimate the seven-day, ten-year low flow results in a flow of 0.005 ma/s. It .is probable, however, that the stream does not flow at all during drought periods. The hydrology of the Susquehanna River was discussed earlier.

The floodplain of Pona Hill Creek below the proposed site of the dam is very narrow (Ffg. A.2.5).

The floodplain of the Susquehanna River fn the vicinity of the proposed location of the pumping station is shown in Figure A.2.6.

Data from borings and wells indicate that the groundwater contours fn the vicinity of the pro-posed reservoir generally follow the surface contours. On the ridges north and south of the stream channel, groundwater was usually encountered between 4 and 15 m below the surfa'ce. The stream valley contains several marshes, springs, and farm ponds.

A.2.3 ' Water Sources At present there are no users of Pond Hill Creek water. A spring within the proposed project boundary is used as a water supply during part of the year. Its use would have to be abandoned.

Most of the nearby residences obtain water from individual wells. There are no wells within the proposed project boundary.

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< The site is about 160 km from the nearest Zone 2 (moderate damage) boundary and 210 km from the nearest Zone 3 (major damage) boundary.

Records of earthquake h1story 1n the site region were examined together with an evaluation of regional and local geologic structures to estimate the seismic risk at the site. This analysis resulted in a recommended design basis seismic coefficient of 0.025.

Several Intensity VI (Mod1fied Mercalli Scale) earthquakes have been recorded within 160 km of the site. Many of these were not felt at the s1te; others were felt at the site with intensit1es equal to or less than IV.

No known faults have been 1dentified in the vicinity of the site. Although low angle thrust faults abound in this part of the Valley and Ridge Prov1nce, they ordinarily, cannot be identi-,

fied except through detailed mapping. Thrust faults, however, are not generally associated with recurring seismic activity.

Reservoir-induced earthquakes are not anticipated as the proposed reservoir is small and there are no known subsurface structural weaknesses.

On the basis of this assessment, the seismic coefficient of 0.05 that has been used in the design of project features is considered by the staff as conservative.

A.2.5 SITE ECOLOGY A;2.5.1 Terrestrial Ecolo The north and south boundaries of the Pond Hill site generally parallel the upper ridges of a small, steep-walled valley; thus the environmental conditions at given locations within the site strongly reflect the influence of the local topography (see Fig. A.2.3). The occurrence of aquatic environments is essentially limited to the narrow valley bottom traversed by Pond Hill Creek, a small drainageway that conver ges with the Susquehanna River near the west boundary of the site. In general, soil moisture levels in terrestrial environments decrease at increasing distances normal to Pond H111 Creek. However, the topographic influence on local soil moisture gradients is most pronoun'ced in the northern portion of the site, where the valley wall 1s higher, the slopes are uniformly steeper, and the predominately south-facing slopes are exposed

to greater insolation. Accordingly, plant communities occurr 1ng on the middle and upper valley slopes tend to be dominated by species tolerant of relatively low soil moisture levels, while lowland vegetation is typically dominated by species with relatively high moistur e requirements.

A.2.5.1.1 Vegetation The Pond Hill site is located in the extreme northern portion of the Ridge and Valley Section, a subdivision of the Oak-Chestnut Region delineated by Braun.z Although hardwood communities were consider ed characteristic vegetation for this part of the section, Braun also noted the presence of hemlock and hemlock-white pine communities, referred to as the "most mesic" communities of the higher valleys. The occurrence of hemlock and white pine was considered indicative of transition to the more northerly Hemlock-White Pine-Northern Hardwoods Region. The foregoing and other reported observations are generally consistent with the applicant's characterization of forest vegetation occurring at the, Pond Hill site.

The applicant differentiated vegetation of the site into two -forest types, two wetland communties, and undifferentiated old fields and cropland (ER-OL, Appendix H, Table 3-1). About 92Ã of the total site (525 ha) is classified as forest land, about 7X as old fields and cropland, and less than 1% as wetlands. Principal species of each vegetation type are indicated in Table A.2.1.

Essentially all forest vegetation is second growth having developed subsequent to logging believed to have occurred during the early 1900s (ER-OL, Appendix H, Section 3.2.2.2). Host of the forest stands have not been disturbed for the last 30 to 40 years. The Mixed Deciduous is the most extensive of the two forest types, occurring on about 74K of the site; the Mixed Coniferous-Deciduous type on about 19K. The latter type is present in relatively narrow, irregular belts paralleling all but the extreme lower portion of Pond Hill Creek'where the stream gradient is particularly steep. This type also occurs as scattered stands on the lower slopes adjacent to the Susquehanna River, and as relatively small outliers on upland portions of the south valley slope where the more favorable soil moisture conditions prevail. The Hixed Deciduous type generally occurs on the drier uplands, thus flanking distributions of the Hixed Coniferous-Deciduous type. Stands of the Mixed Deciduous type do, however, occur adjacent to Pond Hill Creek in limited areas. Wetlands, old fields and cropland occurs on the remaining 7X of the site.

Small wetlands are located in the valley bottom adjacent to Pond Hill Creek. The Type 3 wetland, an inland shallow fresh marsh,s'resulting from the union of several seeps and soils'are saturated throughout the year. The presence of at least five small areas of Type 2 wetlands, inland fresh meadows, is attributed to previous beaver activities; the beaver dams are presently in disrepair .

Old field and cropland vegetation occurs as variously scattered blocks adjacent to, or near, the south boundary of the Pond Hill site, The distribution of this vegetation type generally cor-responds with relatively level areas of upland terrain where farm machinery can be operated with relative ease. As observed by the staff during site inspection, most of these areas were being managed for hay production.

In addition to a general site survey, the applicant sampled systematically selected forest stands that would be inundated or otherwise disturbed during completion of the proposed project.

The applicant's analysis involved pooling data and calculating overall importance values for individual species (ER-OL, Appendix H, Table 3.2.2-3). Accordingly, the principal overstory species include the following, in decreasing order of importance: red maple, American elm, white oak, eastern white pine, eastern hemlock, and shagbark hickory. A similar listing of understory species includes: American elm, red maple, flowering dogwood, witch-hazel, hawthorn, and round-leaved dogwood.

A.2.5.1.2 Wildlife Resources A relatively broad al'ray of wildlife habitat types exists within the Pond Hill site. However, as 1ndicated in Section A.2.5.1.1, fopest habitats prevail throughout most of the site. The predominance and the distribut1on of forest vegetation occur ring onsite tends to limit the occurrence of less mobile animals that are at least partially dependent on resources of other hab1tat types. In general, transit1ons or ecotones between diverse, adjoining plant communities are utilized by animals common to both comnunities, as well as additional species variously dependent on habitat conditions existing only in the ecotone. The density of animals associated with the ecotone also frequently exceeds that for either of the adjoining communities.4 Thus the diyersity and density of wfldlife animals associated with extensive, uniform forest vegeta-tion tend to be lower than for populations frequenting an equal area in wh1ch forest apd other plant communities are variously interspersed. In view of the greater interspersion of habitats (forest types, old f1elds, cropland, and wetlands) in the southern uplands and valley floor of the Pond Hill site, the abundance and diversity of wildl1fe populations is expected to be rela-tively high compared to that for northern portions of the site, where the vegetation consists primarily of uniform deciduous forest.

'Table A.2.1. Principal Plant Species of Terrestrial Vegetation Types Occurring at the Pond Hill Site Vegetation Types Principal Species Hixed Coniferous-Deciduous Overstory:- American elm (Vlmus Americana), eastern hemlock (Tsuga canadensis}, red maple (Acer rubrum),

eastern white pine (Pinus strobus), white ash (Fmrinus americana)

Associate species: Black ash (Fr~nus nigra), white oak (quercus alba). round-leaved dogwood (Comus rugosa),

flowering dogwood (C. florida), hawthorn (Cretaegus sp.), shagbark hickory (Carya ovata)

Understory and ground flora: Chestnut oak (Quercus prinus), swamp white oak (q. bicolor), American beech (Pagus gzenChfoHa), witch-hazel (Pamamelis virginiana), hawthorn, Virginia creeper (Parthenocissus quinquefolia), lady fern (Athyrium fili'-femina), Christmas fern (Polystichum acrostichoides) poison ivy (thus zedicans)

Hixed Deciduous Overstory: American elm, red maple, white oak, shagbark hickory, sassafrass (Sassafras albidum)

- Associate species: Chestnut oak, flowering dogwood, eastern white pine, eastern hemlock, gray birch (Betula populi fo lia)

Understory and ground flora: Flowering and round-leaved dogwood, witch-hazel, American elm, red maple, white oak, gray birch, sassafrass, American chestnut (Castanea dentata), mountain laurel (Kalmia latifolia),

ground cedar (lycopodium tristachyum), tree clubmoss (Eycopodium obscurum)

Type 2 wetland:

Overstory: Dead trees Understory and ground flora: Had-dog skullcap (Scutellaria laterifolia), goldenrods (So'Lidago sp.), sphagnum (Sphagnum sp.),

skunk-cabbage (Symplocarpus foeHdus}

Type 3 wetland:

Over story: Eastern hemlock Understory and ground flora: Sphagnum, skunk-cabbage, cinnamon fern (Osmunda cinnamomea), common cattail (Typha latifoNa),

shining clubmoss (Eycopodium lucidulum), mayapple (Podophyllum peltatum)

Old-fields and cropland Ground flora: White and red clover (Trifolium repens, T. pratense), cowen sorrel (Burne~ acetosella),

ox eye daisy (Chrisanthemum leucanthemum), comoon and English plantains (Plarttago maJor, P. lanceolata), timothy (Phelum pratense), junegrass (Koelria ~stata), sweet vernal grass (Anthoxanthum ocbratum)

Source: ER-OL, Appendix H, Section 3.2.2.2.

A.2-12 Mammals Published distribut1on maps indicate that the Pond Hill site 1s within the ranges of about 55 mammals,s however, habitat r equirements for many of these species is lacking or poorly repre-sented at the site. The applicant has identified 15 species as being "field checked" during site surveys; an additional species, porcupine (Erethizon dorsatum), was subsequently observed at the site (ER-OL, Supp., Response to NRC g.l3, 28 September 1979).

The whitetail deer (Odocoileus virginianus) and black bear (Ursus americanus) are the largest of the game species occurring in the area. Eastern gray squirrels (Sciurus carolinensis) are abundant, but the density of eastern cottontail (Sylvilagus floridanus), a popular game species, is relatively low compared to that of other areas (ER-OL, Appendix H, Section 3.2.2.3). Other species that may be legally hunted with firearms and are known or likely to occur in the area include: eastern fox s'quirrel (Sciurus nigez ), red squirrel (Tamkrsciurus hudsonicus), raccoon (Procyon lotoz ), woodchuck (Marmota monaz:). and snowshoe hare (Lepus americanus). Locally trapped species of fur-bearing animals include: raccoon, striped skunk (Mephitis mephitis),

shorttail and longtail weasels (Mustela erminea, M. frenata), opossum (Ndelphis marsupial'is},

mink (Mustela vison), red fox (Vulpes fulva), gray fox (thocyon cinezeoargenteus), muskrat (Ondatra zibethica), and beaver (Castor canadensis).

The applicant conducted small-mammal trapp1ng studies at the site, resulting in the capture of shorttail shrew (Blarina brevicauda), boreal redback vole (OZethrionomys gapperi), and white-footed mouse (Peromyscus leucopus). The pine vole (Pitymys pinetorum), eastern chipmunk (Tamias striatus), and deer mouse (Peromyscus maniculatus) were also observed (ER-OL, Appendix H, Table 3.2.2.6).

None of the ten bat species reported to occur in the regionz were observed during site surveys; however, all are variously associated with fdr est or woodland habit'ats. Some spec1es probably frequent the site, at le'ast on occasion. Other likely inhabitants of the site are noted as follows. Meadow )umping mouse (Zapus hudsonius)Iand meadow vole (Microtus pennsylvanicus) are frequently occurring species of moist meadows, old fields, and cropland.6 Masked and smoky shrews (Sorer cinereus, S. fumeus) are also typical inhabitants; the former inhabits a wide range of hab1tats, the latter inhabits hemlock forest.

Birds Information presented by the appliant indicates that "the list of birds for the region" includes 135 species, and that recent seasonal surveys verified the occurrence of 75 resident and migra-tory species at the Pond Hill site. Also noted, "60 species not field checked may also be using the area" (ER-OL, Supp., Response to NRC g.ll, 28 September 1979). However, a total of 210 bird species were identified during surveys conducted in the vicinity of the Susquehanna Steam Elec-tric Station located about 4 km downstream from the Pond Hill site.7 All species identified at Pond Hill are included in the inventory compiled from surveys at the SSES site. The inventories for the two sites are also similar in that both are comprised of a high proportion of species representative of the famil1es Parulidae (wood warblers) and Fringillidae (grosbeaks, finches, sparrows). In combination, species of the named families comprise 35.8X (21.1 and 14.7%,

respectively) of the Pond Hill species inventory. As derived from 1978 surveys at the SSES site, comparable percentages for the two families were 15.1 and 13.5, respectively.

The ma)or difference between the SSES and Pond Hill inventories is apparent in that the latter does not include waterfowl and other species variously- associated with aquatic habitats. However, the 1978 SSES surveys entailed censusing the Susquehanna River, including that portion of the river ad)acent to the Pond Hill site. The species most frequently observed during the spring migration period included, in decreasing drder of occurrence: Canada goose (Branta canadeneis),

mallard (Anas platyrhynchos), woodduck (Aix sponsa), common merganser (Mergus merganser), ring-necked duck (Aythya coZZaris), and black duck (Anas rubripes). Some of these species, especially woodduck and mallard, probably inhabit the Pond Hill s1te at var1ous times. Other recorded species that variously use habitats similar to those onsite include: killdeer (Oharadrius vociferus), spotted sandpiper (Actitis macularia), greater and lesser yellowlegs (Tonga melanoleucus, T. flavipes). belted kingfisher (Megaceryle alcyon), and great blue heron (Ardea herodius).

Upland game birds ident1fied duri.ng surveys at the Pond Hill site include only ruffed grouse (Bonasa umbellus) and wild turkey (Meleagris gallopavo) (ER-OL, Appendix H, Table 3.2.2-6).

Eastern portions of the site 'are'eriodically stocked with turkey and r1ng-necked pheasants (Phasianus coZchicus); the latter species was not observed during surveys. Typical habitat of the American woodcock (PhiZohela minor) exists onsite, and, although not observed, the species is expected to be present (ER-OL, Appendix H, Section 3.2 '.3). The bobwhite (C'oZinus virginianus) is also known to occur in the Pond Hill area.z Ruffed grouse was the only commonly observed game bird species dur1ng site, survey.

A.2-13 Information concerning the relative abundance of nongame birds that frequent the Pond Hill site, is not available, but other studies serve to characterize local bird populations. ~s Accord-ingly, the characteristic species of forest habitats include: black-capped chickadee'(Parus atricapiZZub), slate-colored junco (Junco hyemalis), white-breasted nuthatch (Sitta carolinensis),

golden-crowned kinglet (Regulus satrapa), and downy woodpecker (Dendrocopus pubescens). Other species abundant during two or more seasons include: blue jay (Gyanositta cristata), ovenbird (Seirus aurocapiZlus), and wood thrush (Hylocichla mustelina).

Bird populations of open-field habitats,tend to be dominated by field sparrows (SpizeZla pueilla),

song sparrows (Melospiza meZodia), starling (Sturnus vulgaris), and Amer ican goldfinch (Spinis trietis). Other seasonally abundant species include: yellowthroat (Geothlypis trichas), slate-colored junco, and indigo bunting (Passerina cyanea).

Characteristic species of wetland habitats include: swamp sparrows (Helospiza georgiana), song sparrows, red-winged blackbird (Agelaius phoeniceus), cardinal (Richmondena cardinalis), and American goldfinch. Other species well represented dur1ng two or more seasoris include: robin (Turdus migratorius), yellow warbler (Dendroica petechia). gray catbird (Dumetella carolinensis),

yellowthroat, and starling.

Re tiles and Am hibians Inventories of reptiles and amphibians'reported occurring in Pennsylvania consist of 48 and 38 species and subspecies, respectively.9 Based on published species-distribution maps, only 20 amphibians and 19 reptiles are likely to inhabit the Pond H111 area. o Inventories compiled from surveys of the Pond Hill site consist of 5 reptiles and 17 amph1bians (ER-OL, Appendix H, Table 3.2.2-6).

Reptiles reported as occurring onsite include 3 snakes and 2 turtles. The venomous northern copperhead (Agkistrodon contort~ mokasen) is associated with forest habitat; the northern water snake'(Rat~ sipedon sipedon) with all aquatic habitats, and the eastern garter snake (Thamnophis sirtalis sirtaZis) with all terrestrial and aquatic habitats. Hidland painted turtles (Chrysemys picta marginata) were observed in the marshes; the eastern box turtle (Terrapene carolina cmelina) occurred in all terrestrial habitats (ER-OL, Appendix H, Table 3.2.2-6).

Anurans (frogs and toads) reported as occurring in forest habitats near water include:, Amer1can toad (Bufo americanus), spr1ng peeper (Hyla crucif'er), and gray treefrog (Hyla versicolor) ~

Wood frog (Rana sylvatica) were observed in moist woods, as well as streamside. Northern leopard frog (Rana pipiens) was observed to frequent meadow habitats, Other anurans (3 frogs) identified during surveys were associated with the limited stream and marsh habitats occurring onsite. Similarly, most salamanders, as well as the red-spotted newt (Hotopthalmus viridescens viridescens) were observed in streamside habitats. The exceptions, red-backed and slimy salamander s (Plethodon cinereus cinereus, Plethodon glutinosus glutinosus), were associated with forest and rocky woodland habitats. Mountain dusky salamanders (Desmognathus ochrophaeus) and northern spring salamanders (Gyrinophilus porphayriticus) were reported to frequent wet woods as well as streamside hab1tats.

A.2.5.1.3 Endangered and Threatened Species None of the current federally designated plant species (including varieties) of endangered or threatened status occur in Pennsylvania. ~'ive plants that were proposed for federal listing in 1976~z are reported to occur in the state; known distributions of these five species, however, do not include Luzerne County, within which the Pond Hill site Ns located (see Appendix A). A grass species (Poa paludigina) proposed for federal listing in 1975>> has been collected in Luzerne County; however, the species was not observed in 1979 site surveys (ER-OL, Supp., Response to NRC I).9, 28 September 1979).

The Pond Hill site is within the reported d1stributional range of two mamaals and three b1rds 1ncluded in the federal list of threatened and e'ndangered species; >> namely, the eastern .cougar (FeZis concolor cougar), Indiana bat (Hyotis sodalis), bald eagle (Haliaeetus leucocephalus),

and American and arctic peregr1ne falcons (Paleo peregrinus anatum, F. p, tundrius). None of these animals was observed during surveys, of the Pond Hill site (ER-OL, Appendix H, Section 3.2,2,3), although recent local sightings of bald eagle and American peregrine falcon have been reported.>~~ The nature of these sightings is consistent with information received by the staff that indicates federally listed or proposed endangered or threatened animals under the juris-diction of the U. S. Fish and Wildlife Service (including those mentioned) are not known to frequent the Pond Hill area other than as occasional transient 1ndividuals (see Appendix A).

None of the rept1les and amphibians designated as threatened or endangered species by the Pennsylvania Fish Comnissjon~4 were observed during surveys of the Pond Hill site (ER-OL, Appen-

A.2-14 d'ix H. Section 3.2.2.3).

birds have not been made Comparable at this time state designat'iona of endangered or threatened (ER-OL, Supp., Response to HRC O. TER- 6.1).

naossais and ~

A.2.5.1.4 Soils An estimated 84% of the Pond Hill site soils are of Capability Classes V through VIII as defined by the OeS. Soil Conservat1on Service (ER-OL, Appendix H, Table 3.2.6-4) and are unsu1ted for normal tillage of agricultural crops. These onsite soils are characterized by excessive stoni-ness, wetn'ess, shallowness, and/or erosion hazard. Capability Class II soils (including prime farmland) are present on about 9.6l of the site, and occur as scattered, irregular tracts near or adjacent to the south boundary of the site. The distribution of Class II soils is limited to the more rlevel areas of upland ter rain.

The remaining soils of the site are designated as Class III and IV soils (ER-OL, Appendix H, Fig. 3-13), thus indicating suitability for the production of cultivated crops. However, the respective severe and very sever e limitations of Class III and IV soils restrict cropland man-agement alter natives, such as choice of crop plants and/or soil management practices required to conserve the soil resource. Some scattered patches of Class III and IV soils occur in the valley bottom and adjacent to the Susquehanna River; most of these soils, however, are con-tiguous with Class II soils in uplands of the southern portion of the site.

The foregoing groupings of onsite soils are based on relative potentials for agricultural pro-ductivity. In view of the high proportion of forest vegetation occurring onsite, soil-woodland site index correlations are also indicative of onsite soil productivity. With one exception, woodland productivity ratings for the major grouping of onsite soils are high (ER-OL, Appendix H, 3.2.6-5). 'able i

A.2.5.2.1 Water guality A.2.5.2.1.1 POND HIII CREEK. The Pennsylvania Department of Environmental Resources has recently promulgated a revised set of water quality regulations for the state's surface waters.

The water quality criteria that apply to Pond Hill Creek under these regulations are presented in Table A.2.2. In this system, Pond Hill Creek is classified with the unnamed tributaries to the North Branch of the Susquehanna River, and has a designated protected water use for the maintenance and/or propagation of coldwater fishes, specifically the Salmonidae (trout); however, fish sampling failed to reveal the presence of trout in the stream (ER-OL, Section 3,2,3.1,2).

Honthly water samples were collected from both the upper and lower sections of Pond Hill Creek.

Results of the analyses of these samples are presented in Tables A.2 ' and A.2.4. In general, Pond Hill Creek 'is a clear, highly oxygenated, coldwater stream. It has soft water and is weakly buffered. The water quality of Pond Hill Creek meets both the criteria proposed by DER and those recommended for fish and other aquatic life by EPA. A few parameters, specifically fecal coliforms and ammonia, occasionally exceeded DER criteria, but the magnitude by which'the standards were surpassed was not excessive.

A.2.5.2.1,2 SUSQUEHANNA RIVER AT RESERVOIR PUMP STATION SITE. Water quality criteria and analyses for the Susquehanna River were discussed in the main body of this Statement.

Additional sam'ples were collected from the river at the proposed intake location; results of the analyses are tabulated in Table A.2.5. Sampling was conducted from Harch to August 1978. The dat'a indicate that all parameters except total iron and fecal coliform bacter1a comply with the DER recommended criteria for the river.

A.2.5.2.2 Aquatic Life A.2.5.2.2.1 POND HItI CREEK;'gualitative samples of plankton, periphyton, and macrophytes were collected in Pond Hill Creek. guantitative sampling was conducted for benthic macroinver tebrates (ER-OL, Section 3.2.3.1.3) and fishes.

r Very few organisms were found in any of the plankton samples taken at Pond Hill Creek. Vir-tually all of the plankton1c species collected were washed out or detached from the periphyton community. These included the d1atoms (Syne&a, Nitzeohuz, NavicuEa, and Stauroneie) along with fragments of the f1lamentous green algae (Spriogyra). Zooplankton samples revealed the pr esence of a few rotifers, ostracods, cladocerans, copepods, and some drifting insect larvae. In general, the plankton of Pond Hill Creek is typical of most small streams, where the constant turbulent

A.2-15 Table A.2.2. Water equality Criteria for Pond Hill Creeka Stream Zone Unnamed Tributaries of the Basins, Lackawanna River to West Branch Susquehanna River (North Branch) Susquehanna River Protected water uses Coldwater fishes; maintenance and/or propagation of fish species including the family Salmonidae and additional flora and fauna indigenous to a coldwater habitat.

Dissolved oxygen Minimum daily~average 6.0 mg/L; no value less than 5.0 mg/L.

For lakes and impoundments only, no value less than 5.0 mg/L at any point.

Not less than 6.0 and not more than 9.0.

I pH'Iron Hot to exceed 1.5 mg/L as total iron; not to exceed 0.3 mg/L as dissolved iron.

Temperature No measurable rise when ambient temperature is 14'r above; not more than a 2.84C rise above ambient temperature until stream temperature reaches 144C; not to be changed by more than 1.134C during any one-hour period.

Total filterable residue at 1054C Hot more than 500 mg/L as a monthly average value; not more

'than 750 mg/L at any time.

Bacteria (fecal col i fdrm) During the swimming season (May 1 - September 30), the fecal coliform level shall not exceed a geometric mean of 200 per 100 mL based on five consecutive samples collected on dif-ferent days; for the remainder of the year, the fecal coliform level shall not exceed a geometric mean of 2000 per 100 mL based on five consecutive samples collected on dif-ferent days.

Alkalinity Alkalinity shall be 20 mg/L or more as CaCOs fon freshwater aquatic life, except where natural conditions are less.

Total manganese Hot to exceed 1.0 mg/L.

Flouride Not to exceed 2. 0 mg/L.

Cyanide Not to exceed 0.005 mg/L as free cyanide.

Sulfate Not to exceed 250 mg/L.

Phenol Not to exc'eed 0.005 mg/L.

Copper Not to exceed 0.1 of the 96-hour LC 50 for representative important species.

Zinc Not to exceed 0.01 of the 96-hour LC 50 for representative important species.

Aluminum Hot to exceed O.l of the 96-hour LC 50 for representative important species.

Arsenic Hot to exceed 0.05 mg/L.

Chromium Hot to exceed 0.05 mg/L as hexavalent chromium.

Lead Not to exceed 0.05 mg/L.

Not to exceed 0.01 of the 96-hour LC 50 for representative important species.

Nitrite plus nitrate as nitrogen Not to exceed 10 mg/L as nitrate nitrogen.

Ammonia nitrogen Not more than 0.5 mg/L.

Source: ER-OL, Vol. IV, Appendix H, Table 3.2.3-1.

Table A.2.3 Water equality Data from the Upper Section of Pond Hill Creek 1977 1978 d

Paraneter Sept. Oct. Nov. Dec. Jan. Feb. Har. Apr. Hay tune duly Au9. N Hean S.D. Hax. Hin.

Teuperature, water (<C) 17.0 9.0 6.0 3.5 -0.5 0.0 5.0 B.D 10.0 12.0 14.0 17.5 12 8.5 2. 92 '17.5 -0. 5 Dissolved oxy9en (pp) 9.3 11.2 11.3 12.5 13.0 12.4 12.3 11.6 9.9 8.4 8.2 11 10.9 3.30 13.0 8.2 BOD 7.0 3.0 2.1 0.5 <0.5 <I <1 <I 2.0 <1.0 <1.0 1.0 12 1.8 1.33 7.0 <0.5 COD 10.1 8.0 3.6 4.0 <5 7.3 <<5 <5 <5 17.0 9.0 23.0 12 8.5 2.92 23.0 3.6 pH (s.u.) 7. 00 6.30 7.25 6.70 6.80 7.25 6.45 7.20 7.30 6.60 6.80 11 6.88 2.622 7.30 6.30 Alkalinity as CaCDs 5.5 2.8 2.3 6.4 17.5 3.7 1.8 8.3 4.0 14.0 17.0 17.0 12 8.4 2.89 17.5 1.8 Total hardness as CaCos . 24.0 17.0 20. 0 15.0 '15.0 16.0 17. 5 30.0 14. 0 18.0 82.0 20.0 12 24.0 4.90 82. 0 14.0 Total dissolved solids 89.4 44.8 8.4 <0.5 99.4 37.8 3.0 45.5 37.6 56.5 47.4 S0.4 12 43.4 6.59 99.4 <0.5 1'otal suspended solids 150.0 <0.5 516.0 3.4 11.3 13.1 6.1 6.3 2.5 9.6 6.3 40.7 12 63.8 7.99 516.0 0.5 Turbidity (JTU) 1.0 2.5 0.6 2.2 6.0 2.3 2.0 1.9 5.5 7.0 10.0 ll 3.7 1.93 10.0 0.6 Specific conductance (thos) 55 48 42 46 48 48 48 52 52 49 53 ll 49.2 7.'10 55 42 Color (CPU) 11 <I 3 4 5 6 <I 7 10 22 23 28 12 10.1 3.18 28 Sulphate as 5 13.7 -11.0 12. 0 11.0 16.0 10.5 If.3 12.0 1'1.0 6.0 1.0 <'I.o 12 9.7 3.12 16.0 1 Ortho phosphate as P 0.02 0.01 0. 01 0.02 0.01 0.04 0.01 <0.02 0. 03 0.02 0.05 <0.01 12 0.02 0.144 0.05 0. 01 Total phosphate as P 0. 01 0.02 0. 02 0.08 0.01 0.04 0.06 0.03 0.09 <0.02 0.05 1.11 12 0.13 0.358 .1.11 0. 01 Nitrate as N 0. 01 0. 05 0.10 r 0.03 0.27 0.20 0.24 0.20 0.43 0.13 0.12 0.16 12 0.16 0.402 0.43 0. 01 Chloride 1.6 3.4 2.3 4.3 5.5 . 3.1 <0.5 0.5 1.7 0.4 1.7 0.6 12 r 2.1 1.461 5.5 0.4 Total copper .O.O2 <0.02 <0.02 0.03 <0.02 0.05 0.02 0.02 <0.02 <0.02 <0.02 <0.02 12 0.02 0.153 0.05 <0. 02 Total iron 0.47 0. 49 0.21 0.26 ,0.29 0.39 0.40 0.35 0.80 0.87 1.40 1.64 12 0.63 0.794 1.64 0.21

'Total nan9anese 0.05 0.03 0.03 <0.02 0.02 0.02 0.04 <0.02 0.05 0.05 0.07 0.02 12 0.05 0.224 0.20 <0.02 Col iforn total HPN/100 nL 1100 1100 1100 210 43 240 240 >>2400 210 >2400 1100 2400 12 1045.3 32.33 >>2400 43 Coliform fecal HPN/100 uL 93 93 150 64+ <3 <<3 240 460 23 1100 23 1100 12 279.3 16.71 1100 <3 fecal streptococci HPN/100 ni. <1 <1 5 25 <1 <1 <1 <1 20 35 10 30 12 10.9 3.30 35 <1 Source: ER-OL ~ Vol. IV, Appendix H, Table 3.2.3-2.

Units u9/L unless stated otherutse.

N ~ nunber of sanples.

S.D. standard deviation.

Table A.2.4. Water guality Data from. the Lower Section of Pond Hill Creek 1977 1978 c

Paraneterb Sept. Oct. Nov. Dec. Jan. Feb. Her . Apr. Hay June July Aug. N Hean S.D. d Nax. Hin.

Teoperature, water (4C) 16.0 9.0 6.5 3.5 0.0 1.0 4.0 6.5 8.0 10.0 14.5 19.0 12 8.2 2.86 16. 0 0.0 Dissolved oxygen (ppu) 9.5 11.8 12.0 13. 0 13.9 13.1 13.3 13.2 12.4 8.9 8.0 11 11.7 3.43 13.9 8.0 BOD 8.0 4.0 1.2 0.5 <0.5 <1 3 <1 2.0 <1.0 <1 1.0 12 2.0 1.42 8.0 <0.5 COD 11.1 7.4 3.4 9.0 6.8 <5.0 <5.0 <5.0 <5.0 7.0 18.0 12.0 12 7.9 2.81 18.0 3.4 pH (s.u.) 7.10 6.65 7.60 7.10 7.00 7.30 7.30 7.55 7.10 6.70 6.80 11 7.11 2.666 7.60 6.65 A)ta)in)ty as CaCOs 7.4 11;0 2.3 1.8 23.0 1.8 <1.0 11.0 5.0 11.0 19.0 16.0 12 9.2 3.03 23.0 <1.0 Total hardness as CaCOs 24.0 23.0 19.0 15.0 16.0 17.0 15.5 21.0 22.0 14.0 20.0 21.0 12 19.0 4.35 24.0 14.0 Total dissolved solids 108.0 .49.6 15.4 <0. 5 102.0 56.0 14.2 133.0 43.3 52.3 44.4 56.2 12 56.2 7.50 133.0 <0.5 Total suspended solids 120.0 <0.5 1.4 3.1 8.9 6.1 5.2 4.9 8.3 8.2 22.4 8.0 12 16.4 4.05 ) 20.0 <0. 5 Turbidity (JIU) 0.7 3.0 0.8 1.6 5.5 0.6 1.3 2.5 3.6 5.2 3.8 11 2.6 1.61 5.5 0.7 Specific conductance (yahos) 59 45 48 48 46 45 68 49 50 50 55 1) 51 7.2 68 45

- Color (CPU) 10 <1 3 4 5 4 <1 3 15 12 10 22. 12 8 2.7 22 1 Sulphate as 5 13.2 '12.0 11.8 )2.5 )6.8 13.6 1\.9 11.0 9.0 12.0 6.0 7.0 12 1).4 3,38 16.8 6.0 Ortho phosphate as P 0.0< 0.01 0.02 <0,01 0.02 <<0.02 0.02 <0.02 0.04 0.06 0.02 <0.01 12 0.02 0.150 0.06 <0. 01 Total phosphate as P 0.0) <0.01 0.02 <0. 01 0.01 0.05 0.10 <0.02 0. 08 0.04 0.02 0.47 12 0.07 0.265 0.47 <0. 01 Nitrate as N <0.01 0.07 <<0.05 0. 03 0.33 0.21. 0.12 <0.10 0.08 0.27 0.24 0.21 12 0.14 0.379 0.33 0.01 Chloride 0.7 2.6 9.5 <0.5 2.9 11.1 <0.5 <0.5 2.1 0.4 1.08 11 12 2.7 1.66 11.1 0.4 Total copper. <<0.02 <0.02 <0.02 0.03 0.03 0.06 0.02 <<0.02 <0.02 0.02 <0.02 <0.02 12 0.03 0.158 0.06 <0.02 Total iron 0.60 0.46 0.22 0. 20 0.25 0.39 0.34 0.25 0.41 1.08 3.11 0.65 12 0.66 0.814 3.11 0.20 Total nanganese 0.03 0.04 0.02 0.04 0.02 0.02 <<0.02 <0.02 0.03 0.04 0.21 0.10 12 0.05 0.222 0.21 <0.02 Co))fern total HPN/100 nL 460 240 150 150 43 43 460 460 210 >2400 240 >2400 12 609 24.7 >2400 43 Co))fern fecal HPN/100 nL 240 9 23 23 4 <3 43 43 43 93 9 93 12 52 7.2 240 <3 Fecal streptococci HPN/100 nL 10 <1 <1 <1 <1 <1 <1 <1 10 20 <1 <1 12 4 2.0 20 <1 Source: SN-OL. Yo), IV, Appendix H, Table 3.2.3-3.

Units ng/L unless stated otherwise.

N ~ nuuber of sauples.

d S.O. ~ standard deviation.

Table A.2.5. Water guality in the Susquehanna River near the Proposed Intake Sitea 1978 c

Parameterb Har. Apr. Hay June July Aug. N Hean S D. Hax. Min.

water ('C) 3.0 7.0 13.5 16.0 22.0 25.0 6 14.4 3.80d'emperature, 25.0 3.0 Dissolved oxygen (ppm) 12.6 10.7 14 ' 8.9 5 11.2 3.35 14.9 3.35 9.0'.0 BOD 1.0 <1 3.0 <1 2.0 6 22 1.47 5.0 <1 COD 7.0 24. 0 5.0 7.0 10. 0 25.0 6 13.0 3.61 25.0 . 5.0 pH (s.u.) 7.25 7.60 8.60 7.20 7.20 5 7. 57 2.751 8.60 7.20 Alkalinity as CaC03 23.0 41.4 19.0 46. 0 66.0 60.0 6 42.6 6.52 66.0 19.0 Total hardness as CaCOa 66.1 84.0 73. 0 109. 0 167.0 136.0 6 105.9 10.29 167.0 66.1 Total dissolved solids 67.2 122.0 138.0 196.0 290.0 215.0 6 171.4 13.09 290.0 67.2 Total suspended solids 9.1 21.7

'.5

19. 9 9.5 36.5 6 17.4 4.17 '36.5 9.1 Turbidity (JTU) 16 7.5 5.1 9.8 11.0 '2.0 6, 10.2 3.20 16.0 5.1 Specific conductance (thos) 160 190 200 230 330 5 222 14.9 330 160 Color (CPU) 26 7 25 68 65 80 6 45 6.72 80 7 Sulphate as S 28.8 30. 0 46. 0 97. 0 180. 0 148.0 6 88.3 9.40 180.0 28.8 Ortho phosphate as P 0.06 0. 04 0. 06 0.02 <0.01 0.10 6 0.05 0.22 0.10 <0.01 Total phosphate as P 0.07 0.05 0.12 0.10 0.84 6 0.20 0.45 0.84 0.04 Nitrate as N 0.97 1.00 0.73 0.61 0.43 0.55 6 0.72 0.846 1.00 0.43 Chloride 12.8 11.0 6.2 11.5 18 ' 14.5 6 12.4 3.52 18.4 6.2 Total copper <0.02 <0.02 <0.02 <0.02 <0.02 <0.02 6 <0.02 '0.141 <0.02 <0.02 Total iron 2.11 1.96 1.63 2 '3 2.34 4.70 6 2.53 1.590 4.70 1.63 Total manganese 0.29 0.19 0. 32 0.49 0. 66 0.90 6 0.48 0.689 0.90 0.19 Coliform, total HPN/100 mL >2400 43 >2400 >2400 >2400 >2400 6 2007 44.8 >2400 43 Coliform, fecal HPN/100 mL 240 3 210 460 460 1100 6 412 20.3 1100 3 Fecal streptococci HPN/100 mL 10 <1 35 85 10 65 6 34 5.9 85 <1 Source: ER-OL, Vol. IV. Appendix H, Table 3.2.3-7.

Units mg/L unless stated otherwise.

N = number of samples.

S.D. = standard deviation.

t and fast-flowing water usually inhibits the development of a true self-reproducing Instead, a normally spar se make-'shift plankton coaraunfty is derived from organisms small ponds and quiet backwaters or dislodged from the streambed and periphyton.

drift community.

washed out of The perfphyton coaraunfty fn Pond H111 Creek fs dominated by filamentous algae and attached dfa-toms. The most abundant diatoms were those listed in the prevfous paragraph. Other relatively common diatoms included MeZcsirvr and OymbsZZa. The most commonly observed filamentous algae was the green algae Spizcgym. Collectively, filaments of Spricgyva often formed noticeable tufts upon rocks, sticks, and other debris in the stream. Other filamentous algae present in the periphyton included gr'een algae (Oedogcnium and Desmidium), red algae (Batrvrchcspsvmrrm), and blue-green algae (OsciZZatc&a). Nfcrofauna found in the, periphyton consisted primarily of protozoans, part1cularly the ciliate OoZpidium and rotffer s from the family Brachfonidae.

The most common floweving plants found fn the stream included cattails (Typha), pondweed (Pctcmcgeton), bush pondweed (NaJ'as)', waterweed (EZodsa), iris (Iris), and watercress (Nasturtium).

Cattails, pondweeds, and waterweeds were relatively abundant in the upper section of Pond Hill Creek in areas previously inundated by beaver dams. However, the most noticeable macrophytes fn the stream were water moss (PontirraZis) and leafy liverwort (OhiZcscyphus), both of which formed dense growths on most of the stones and boulders in the streambed. Water moss and liverwort are generally considered typical inhabitants of hard-bottomed, coldwater streams. >>

1 A tota'1 of 12,435 macrofnvertebrate specimens were collected from seasonal visits to each of three sampling stations at Pond Hill Creek. The average density of these macroinvertebrates was 3,844 organisms/m2, ranging from a low of 1,789 to a high of 10,411.

The dominant insects found in the macroinvertebrate coraaunity of Pond Hill Creek were fly larvae (Diptera) and mayfly nymph (Ephemeroptera). These two groups of insect larvae comprised 44.2 and 28.3X, respectively, of all organisms collected. The most abundant Dipteran larvae were midge larvae of the family Chironomidae. Ircrropsis and EphsmsreZZa were the most numerous mayflies observed. Other well-represented macroinvertebrates included stonefly larvae (10.3% of the total specimens), caddfsfly larvae (8.8X), beetles (2.3X), clams (2.1%), and worms (1.9Ã).

Collectively, these macrofnvertebrates are typical of stony-bottomed, small streams.

Diver sity indices calculated for all of the macroinvertebrate samples collected fn Pond Hill Creek ranged from 2.87 to 4 .18. Only two of the twelve 1ndfces weve below 3.0. The overall average index was 3 '6. These very high values indicate that Pond Hill Creek supports a well-balanced community of macroinvertebrates.

The stream supports a very limited fish cosrnunfty. Seasonal fish samples collected fn the upper and lower sections of the stream revealed only five species. The primary factor limiting the fish community fn Pond Hill Cr eek is apparently the intermittent nature of the stream. Also, since fish are prevented from moving up into the stream from the Susquehanna River by an elevated culvert near the stream's mouth', there are no migratory species 'present in the stream.

Fish sampling 1n Pond Hill Creek covered a distance of about 250 m of the lower sectfon and approximately 830 m of the upper section. Samples were collected with an electrical shocker and minnow seines.

Of the five species found, only the blacknose dace (Rhirrichthys atvatuZus), a common minnow specfes in Pennsylvania and other parts of the northeastern United States, was abundant. Other c 0 mmon mfnnow species found included: golden shiners (Notemigonus cvyscZsucas), fathead minnows (PimephaZes promeZas), and creek chub (SsmctiZus atrcmacuZatus). However, only 9, 10, and 1 specimens, respectively, of these three species were collected. The remafning ffsh species was represented by a single specimen of largemouth bass (Micvcptevus saZmcides) caught in the lower section of the stream in December 1977. Since only this one individual was found fn all the fish samples, ft fs clear that Pond Hill Creek does not support a large resident population of this species. Furthermore, it 1s probable that the single bass Juvenile orig1nated from one of the small farm ponds located near the stream. These ponds are connected to Pond Hill Creek near 1ts source by a small rivulet.

1 None of the species found in Pond Hil } Creek is included on either the U: S. Fish and Wildlife Service's list of Endangered and Threatened Wildlife and Plants or the Pennsylvania Fish Com-mission's list of Endangered, Threatened or Indeterminate Fishes, Amphibians or Reptiles of Pennsylvania. The stream has never been stocked by the Pennsylvania Fish Commission, and no fishermen were observed on the stream during the sampling program.

A.2.5.2.2.2 SUSQUEHANNA RIVER AT RESERVOIR PUMP STATION SITE. Biological data gathered near SSES provide the most adequate representation of the nature of the aquatic biota in the vicinity of the proposed reservoir intake site.

A.2-20 The reader is referred to the 'applicant's annual reports and to the main body of this Environmental Statement for additional information about the site.>e-zo A.2.6 SOCIOECONOMIC PROFILE OF THE LOCAL AREA The socioeconomic profile for the area surrounding the proposed Pond Hill reservoir will focus on Conyngham Township, Luzet ne County. This"area has been selected because the proposed reser-voir site is centrally located in this township, and the most direct impacts of construction and operation are expected to occur here.

A.2.6.1 ~Demo ra h In 1970, the total population of Luzerne County was 342,301, a 22.5% decrease from 1940 (ER-OL, Table 3.1-1). Between 1970 and 1977, population declined at a rate of 1% per year.z~ In com-parison, Conyngham Township's populations totaled 1,693 in 1970 and was pro)ected to have increased to 1,788 in 1976, an increase of 5.6l.z Compared to national trends, the age structure of the county and township can be characterized as an older population because of the proportion of people over 65 years of age.zz6zs In 1970, the proportion of people over 65 was 13.0X for the county and 13.1% for the township, as compared to 10.8X for the state.z4 A.2.6.2 Settlement Pattern Population concentrations are located in four areas of Conyngham Township: Mocanaqua, Wapwall-open, Pond Hill, and Lily Lake.z" Scattered houses and small farms were observed surrounding these small population centers and in the areas between them.

~Hooeeo In general, the township housing stock is characterized as old; about 83% of the current struc-tures were built before 1939.z4 However, the condition of the available 1976 housing was still rated as fair to good, and the demand for new houses is expected to increase by 1980,zs Repair and renovation of older homes and summer homes was observed by the staff, particularly in the Pond Hill and Lily Lake areas.

Recreation

(

A series of recreational facilities are located in Conyngham Township; these have been listed in a county recreational study and presented as Table 3.8.3 of Reference 24. In addition to these listed facilities, trout fishing isavailable in Little Wapwallopen Creek, fishing and boating opportunities at Lily Lake, and hunting and hiking in several of the state gamelands,z" information on current recreational. needs and plans for the township are not available.

'etailed However, a need for additional recreational facilities of different types has been identified for all of Luzerne County, which would include Conyngham Township (see Section 2.2.3.3).

A.2.6.3 Social Or anization An estimated 80Ã of the 1970 households in the township were composed of families. The socio-cultural characteristics of the township have been described as rural in terms of its population density, atmosphere, and available services. However, the population concentrated in the 'settle-ment of Mocanaqua, which has been historically associated with the coal-mining industry, is now distinctively agricultural and more diverse than that typically associated with rural areas.>" .

A.'2.6.4 Social Services Sewa e'and Water Public water services are currently available in Mocana~ua and Wapwallopen.z4 Mocanaqua has some public sewage, but needs renovation of its system. ~ Sewage treatment is planned for Wapwallopen and Lily Lake.><

Fire and Police Protection The township has a part-time police force made up of four persons and is also served by the state police.z4 Volunteer fire companies provide fire protection.z"

A.2-21 A.2.6.5 Political Or anization Conyngham is defined

'he as a second-class township because it has fewer than 300 residents per square mile.zz township is governed by a board of three supervisors e'iected at-"large for six-year terms.zz The board exercises general governmental functions, including maintenance of a police force, the road system, and the levy and collection of taxes.z" A.2.6.6 Economic Or anization By the 1920s, anthracite mining was the chief source of employment and the economic base of Luzerne County. As coal production began to decline in the 1930s, the economic base was diversified to counteract serious income and job losses.z~ Today the economy is broad-based and has a strong apparel-industry orientation.z?~ a In 1976, the Department of Commerce listed only four establishments for this townshi~ employing a total of 154 employees.,za One business is a sawmill, another a,footwear firm;z4~z two busi-nesses were undefined. Additional retail and service facilities are located within the town-ship, primarily in Hocanaqua, Mapwallopen, and Pond Hill.z" A.2.6.7 Sociocultural Characteristics The staff observed no resident population living on the proposed site. The applicant states that the property does not contain any facilities or structures used by the loca'1 communities nor does it support any coranercial'r industrial activities.z4 The applicant also reports that site.z" there is no residential activity below the dam Recreation The applicant stated that this site is used for walking, hiking, hunting, and nature study b~

the people living in the nearby vicinity.z4 Since this information has not been quantified, 4 neither the number of individuals using this site nor the person-days of usage can be determined.

The applicant identified and characterized esthetic qualities of the site.>" During the site visit, the staff observed that the site, area was esthetically pleasing because of the steep topography, rock outcrops. waterfalls, and dense, but variable, forest cover. Therefore, it is reasonable that people would be attracted to the site to, hike and enjoy the kind of, natural environment present on the property.

In addition to recreational.use of the natural area, the staff observed that a pond has been constructed on the site. The applicant stated that the pond was used for fishing and swimming by several local residents. The extent of the pond's usage cannot be quantified at this time.

A.2.7 CULTURAL RESOURCES A.2.7.1 ~Re ion A regional culture history for Luzerne and Columbia county areas is provided in Section 2.6.] of this Environmental Statement.

A.2.7.2 Pond Hill Site A prehistoric cultural survey has been made in two areas of the Pond Hill Site: 1) on the proper ty designated for the reservoir and within the high water mark and 2) on a section of the floodplain. Fifty-meter intervals and walkover was utilized for the uplands, while closer spaced transects and test trenching were used in the floodplain.z~

A.2-22 References

1. S. T. Algermissen, "Seismic Risk Studies in the United States," Presented at the Fourth Work Conference on Earthquake Engineering, Santiago, Chile, 14 January 1969.

2. E. L. Braun, Deciduous Forests of Eastern North America, New York: Hafner Publishing Company, 1972.

S. P." Shaw and C. G. Fredine, "Wetlands of the United States," Circular 39, U. S. Depart-ment of the Interior, Fish and Wildlife Service, Washington, DC, 1971, 67 pages.

R, L. Smith Ecolo and Field Biolo , New York: Harper & Row, 1966.

5. W. H. Burt and R. P. Grossenheider, A Field Guide to the Mammals, Boston: Houghton Mifflin Company, 1976.

6. J. K. Doutt, C. A. Heppenstall, and J. E. Guilday, "Mammals of Pennsylvania," Pennsylvania Game Comaission, Harrisburg, PA, 1973, 280 pages.

7. R. M. Ruhe and J. D. Montgomery, "Birds," pages 250-283 in "Ecological Studies of the Susquehanna River in the Vicinity of the Susquehanna Steam Electric Station," T.V. Jacobsen (ed.), Annual Report for 1978, Ichthyological Associates, Inc., Berwick, PA, 1978.

8. R. M. Rube, "Birds,", Pages 311-342, in "Ecological Studies of the Susquehanna River in the Vicinity of the Susquehanna Steam Electric Station," T.V. Jacobsen (ed.), Annual Report for 1977, Ichthyological Associates, Inc., Ithica, NY, 1978.

C. J. McCoy, "List of the Amphibians and Reptiles of Pennsylvania," Section of Amphibians and Reptiles, Carnegie Museum of Natural History, Pittsburgh, PA, 1974.

10. R. Conant, A Field Guide to Re tiles and Am hibians of Eastern and Central North America, Boston: Houg ton M ff n ompany,

11. "List of Endangered and Threatened Wildlife and Plants," Federal Re ister, Vol. 44, No. 117, Department of the Interior, Fish and Wildlife Service, Washington, DC, 17 January 1979, pp. 3636-3654.

12. "Endanger ed and Threatened Species," Federal Re ister, Vol. 41, No. 117, Department of the Interior, Fish and Wildlife Service, Washington, DC, 16 June 1976, pp. 24524-24572.

13. "Threatened or Endangered Fauna or Flora," Federal Re ister, Vol. 40, No. 127, Department of the Interior, Fish and Wildlife Service, Was ngton, DC, 1 July 1975, pp. 27825-27924.

14 "Pennsylvania's Endangered Species, Reptiles and Amphibians", Reference Information, Pennsylvania Fish Commission, Harrisburg, PA, revised April 1978.

15. H.B.N. Hynes, The Ecolo of Runnin Waters, Toronto: University of Toronto Press, 1972.

16. T.V. Jacobsen (ed.), "Ecological Studies of the North Branch Susquehanna River in the Vicinity of the Susquehanna Steam Electric Station," Annual Report for 1974, Pennsylvania Power & Light, Berwick, PA, May 1976.

17. , Annual Report for 1975, , August 1976.

18. , Annual Report for 1976, , October 1977.

19. , Annual Report for 1977, , April 1978.

20. , Annual Report for 1978, , July 1979.

21. Pennsylvania Projection Series, July 1977, "Estimates of County Population by Age, Sex and Race," Office of State Planning and Development, October 1978.

22. Population Estimates and Projections: Series P. 25, No. 777, U.S. Department of Commerce, Bureau of the Census, January 1979;

23. "Planning and Development Considerations, The Wyoming Valley, lvania," Wilbur Smith and Associates, 8 December 1973. Pennies

24. Tippetts-Abbett-McCar thy-Stratton/Engineers and Architects, "Environmental Report: Pond Hill Reservoir," prepared for Pennsylvania Power & Light Company, February 1979.

t 25.

26.

Hous)ng Section 1978.

Land Use Plan 1976.

of of the Luzerne Luzerne County for the A.2-23 County Comprehensive Plan; Luzerne County Planning Comnission, Year 2000, Luzerne County Planning Comnission', June

27. "This is Luzerne County," League of Voters of Wilkes-Barre Area, 1976.

28. "Pennsylvania County Industry Report," Department of Commerce, Bureau of Statistics, Research and Planning, 1976.

29. Cotggonyeal th Associates, "Archeological Investigations at the Susquehanna Steam Electric Station: the Pond Hill Reservoir Site," prepared for PP8L, 1981.

AD 3. RESERVOIR DESCRIPTION A.

3.1 INTRODUCTION

In order to provide the desired water storage, a dam will be constructed across Pond Hill Creek 1.3 km upstream from its confluence with the Susquehanna River. The reservoir will have all of the features typical of this type of project, including a spillway and an inlet-outlet structure.

Since the drainage area above the dam is too small to it fill and refill the reservoir and also full between uses, an intake structure and pumping plant near the bank of the Susquehanna keep River and a water conduit from the pumping station to the inlet-outlet structure on the north shore of the reservoir will be constructed. A permanent access road will be provided. During construction, a concrete batch plant and borrow pits will be used. The 'location of the batch plant and borrow pits are shown on Ffg. A.3.1.

The applicant has supplied detailed design fnformation for a dam with a normal water level of 287 m HSL and an active storage volume of 12.5 32 10s ms and a total water storage volume of 16.0 32 106 ms (ER-OL, Appendix H). In response to comments by PDER and SRBC regarding the desirability of optional development of the site to meet water supply needs in addition to those of SSES, the applicant submitted design information on a larger dam, one utilizing 85% of the valley's maximum capacity. The higher, larger dam (normal water level 299 m HSL'), will have a storage volume of about 27.1 3 106 m~ and a total volume of 29.7 x 106 ms (responses to NRC questions, letters from N.W. Curtis, PP&L, to D.E. Sells, NRC, 12 October, 13 November, and 17 December 1979). The minimum water leve'l for the larger reservoir fs 264.6 m HSL.

The following analyses are for the larger (299-m normal water level) dam and reservoir and the 0 10-7 riverflow value of 22.7 ms/s.

Figures A.2.2 and A.2.3 show local topography, the layout of the higher dam and the other structures, and the area to be covered by water at maximum and minimum water elevations.

Figure A.3.2 is a detailed plan view of the higher dam and related structures.

A.3.1.1 Embankment Dam The dam will be of earth and rockfill construction using materials obtained mostly from the area to be inundated. The crest of the dam will be about 730 m long at 302 m HSL. The maximum height of the crest of the dam above the existing creekbed will be about 67 m. The applicant's engineering studies have shown that sufficient core materials are available from onsite borrow areas.

Because of low topography along the southern edge of the reservoir, construction of two,addi-tional water retention barriers will be required (see fig. A.3.2). In the saddle area, itewdi-ately southeast of the main dam, a shallow dike (about 150 m long and 2.4 m high) will be constructed. About 800 m east of the dam an impervious subsurface cutoff (about 380 m long and 6 m deep) will be required to prevent seepage through the saddle.

A.3.1.2 ~Ail lwa An over flow-type of spillway located on the south abutment of the dam wf'll be provided to release floodwaters when water levels exceed the 299-m HSL crest of the spillway (see Fig. A.3.2).

Figure A.3.3 is a detailed schematic of this spillway. A 425-m concrete-lined chute will carry the overflow water from the spillway to the existing riverbed. A concrete structure will be used to dissipate most of the kinetic energy of the flow.

A.3.1.3. Inlet-Outlet Structure This structure will be used to both control releases from the reservoir for conservation and compensation purposes, and to discharge pumped inflows into the reservoir.

This structure has been redesigned since the DES was-issued in Harch 1980 (letter from H.N.W.

Curtis, PP&L to Hr . B.J. Youngblood, NRC, 29 Hay 1980: this letter is on page B-47 of Appen-dix 8). The new structure is shown schematically in Figure A.4.1; its location is given in Figure A.2.3). The new design calls for a vertical structure inside the reservoir, with exit ports 7.6, 17.0 and 39.9 m below the normal water surface.

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~ aa twkad\tatt aat aaa I ~ <<taa 'GENERAL PROJECT PLAN f ALIGNMENT OF ALTERNATIVES ttktt aMtA t TFetIT&Aaaa tt~aatddt+taattOa p majeare aa aaoadaata ww aaaa Nd T Fig. A.3.2. General Project Plan for Pond Hi'll Reservoir with Alignment of Alternatives. (Source: Reference 1)

South fd 6 Sp>//nCFy I' ~ySpi kll~y Spittrioy i5 b~ k 55'r I I I SECTION A-A I I I I I brOO 7iOO, G/OO SiOO WFOO OiOO 2iOO liOO 0 OO JA SPILLWAY PLAN 4

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~ llll 6 Mcocccccc ~ low ciccccicccccconccccnolccccoc Fig. A.3.3. Detailed Schematic of Spillway Structure for Pond Hill Reservoir.

A.3-5 The concrete structure will be connected to the pumping plant by an underground pipeline (Fig. A.3.2, Alternative B). Pumped inflow will enter the reservoir at the base of the structure.

Three outlet ports, each at a different level, will be used for compensation and conservation flows. The outlet port {or ports) used for a given release will be the one at which the tem-perature of the water in the reservoir most closely matches that of the Susquehanna River.

A.3.1.4 Water Conduit A steel pipeline will be used to transpor t water between the pumping plant and the inlet-outlet structure (see Fig. A.3.2, Alternative B). The pipe will be capable of carrying 3.8 ms/s of water from the pumps to the reservoir, and an average flow of 3.0 ms/s for compensation releases.

The maximum release flow will be 8.5 ms/s. The pipe from the inlet-outlet structure to the pumping plant will have a diameter of 1.22 m. The pipeline will be constructed in a cut-and-cover trench along the proposed access road (see Fig. A.3.2).

A 0.61-m pipe'line with a control valve wi'il branch from the pipe'line, near the downstream toe of the dam, to allow releases to Pond Hill Creek. The system will be able to release water at a rate of up to 0.57 ms/s, a flow approximately equal to the capacity of the creek channel to

,carry water without flooding.

A.3.1.5 Pum in Plant and Intake Structure The proposed pump station will be built adjacent to the railroad in an area outside the flood-plain (see Figs. A.3 ' and A.3.4). The proposed intake will consist of two parallel steel pipes extending about 30 m into the river (see Fig. A.3.4). Although the final design of the intake structure has not been selected, screens similar to those manufactured by Johnson Screen'Company or slotted steel pipes similar to those manufactured by Ranney Co., approximately 60 m of 0.6-m diameter screens, will be provided. The maximum approach velocity will be 'about 0.12 m/s. The pipe and screen low points will be about 0.6 m above river bottom; pipe tops will be about 1.2 m below water level at minimum pumping flows. Figure A.3.4 shows the contemplated configuration of the proposed pump station, intake structure, and the burled pipeline from the pumping plant to the intake screens. Compensation releases to the river would be through the screens. Three 1.25-ms/s electrical driven pumps will be used to pump water into the reservoir.

A.3.1.6 Access Road A new paved access road will be constructed from State Route 239 to the construction areas. The road will parallel the pipeline. The road will be approximately 1220 m long and 9 m wide; the area impacted by the construction of the road and pipeline will be about 2 ha. The use of this road will minimize construction traffic through the villages of Pond Hill and Lily Lake.

A.3.2 HOOE OF OPERATION A.3.2.1 Initial Fillin of Reservoir Host of the water required to fill the reservoir will come from the Susquehanna River, the remainder from drainage and precipitation. The applicant is coranitted to pumping only when river flow is greater than 85.4 m'/s. The three pumps in the pumping plant are capable of delivering up to 3.8 ms/s to the reservoir. Pumping at this rate, it wou'Id take 84 days to fil1 the reservoir.

A.3.2.2 Com ensation Releases During periods of low river flow, defined as the I)7-10 value of 22.7 ms/s plus the actual con-sumptive use by SSES and dedicated compensation flGCFR803.61(c')(7)(i)], the applicant will be required to discharge water from the reservoir at the actual consumptive use rate. Consumptive water use of SSES will be determined by measuring the difference between the volume of water withdrawn from the river (pr imari'ly to replace that evaporated in the plant's cooling towers) and blowdown to the river.

The average rate of discharge from the reservoir will be 3.0 m /s; the active storage capacity of the dam will be such that this flow could be maintained for 106 days. The applicant esti-mates peak water consumptive use at about 1.8 ms/s, and average use at 1.4 m /s.

Compensation water will be taken from one of, the three outlet ports in the inlet-outlet struc-ture, pass through the conduit, and be discharged into the Susquehanna River via the multi-slotted pipes. The outlet port selected would be the one at whjch.the temperature in the reservoir most closely matches that of the river.

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(Source: Reference 1.)

'A.3-7 A.3.2.3 Conservation Releases The Pennsylvania Department of Environmental Resources requires that all new reservoirs provide a minimum release to maintain downstream flows. On streams without water-flow data, 'a value of 1.64 L/s per square kilometer, of upstream drainage area is normally utilized by DER, Since the area upriver from the proposed dam is about 4.4 kmz, the applicant proposes a conservation release of at least 5.7 L/s. The release point for this discharge would be just west of the toe of the dam (see Fig. A.3.2).

Precipitation on the lake and drainage in excess of that required to keep the water level at 299 m would be discharged into Pond Hill Creek through the conservation-flow outlet (up to 0.57 ms/s), over the spillway, or directly into the Susquehanna River via the conduit and the pumping plant.

A.3.2.4 Refillin the Reservoir Additional water will be pumped into the reservoir whenever precipitation and drainage are insufficient to keep the pond full and replace losses due to seepage, evaporation, compensa-tion, and conservation flows. As stated earlier, pumping will be permitted only with river flows in excess of 85.4 ms/s.

A.3.3 ~ RECREATION AREA The applicant proposes to construct a recreation area so that the recreational potential of the reservoir may be utilized. The proposed facilities include a 30- to 50-car parking lot, a launching ramp for non-combustion-engine boats, and a system of trails for hiking and nature study {ER-OL, Appendix H, Section 4.2.8). Hunting will be permitted in season fn the buffer areas around the reservoir. The Pennsylvania Fish Commission will be asked to stock the reser-voir for sport fishing; the new aquatic habitat will be suitable for warmwater fishing.

A.3.4 ESTHETICS A.3.4.1 Construction The appearance of, approximately 146 ha of land will be altered by construction and operation of the Pond Hill Reservoir. One hundred twenty-eight hectare's of forested land will be inundated.

Impoundment 'structures will convert about 16 ha from natural cover to built-up structures.

A.3.4.2 ~eerattee Since most of the buffer area surrounding the site will not be altered during construction, no appreciable changes in the esthetic quality of these areas will occur. The primary change fn esthetic values will be the conversion of forested lands to a lake. None of the facilities will be visible from the settlements of Lilly Lake and Pond Hill, or from the roads leading to these communities. ,Since topographic features will screen the dam from view, the pumphouse will be the only structure visible from State Route 239.

Reference

1. Tippetts-Abbett-HcCarthy-Stratton/Engineers and Architects, "Design Report: Pond Hill Reservoir," prepared for Pennsylvania Power 8 Light Company, February 1979.

I

A.4. ENVIRONMENTAL EFFECTS OF CONSTRUCTION AND OPERATION A.4.1 IMPACTS ON LAND USE Approximately 525 ha of land will be converted from present uses to land dedicated to a water storage project. Pond Hill Creek and most of the valley it drains'ill be permanently altered.

About 146 ha of the site will be permanently altered by construction and operation of the reser-voir; about 128 ha of presently wooded 'Iands will be inundated and another 16 ha covered by impoundment structures, such as the dam, spillway, and inlet-outlet structure. The access road-pipeline corridors will occupy an additional 2 ha. Most of the areas disturbed by construction activities (about Sl ha) will be reclaimed and landscaped following construction; there will be only minor changes in land use in the remaining undisturbed areas of the site.

Farming on a controlled basis will be permitted to continue within the buffer area of the, site.

The impacts of reservoir construction and operation on the terrestrial environment are discussed in Section A.4.F 1, those on the aquatic environment are discussed in Section A.4.3.2.

A.4.2 IMPACTS ON WATER USE Construction-All effluents generated during the concrete batch plant operation will be collected in a holding pond. After the solids have settled out, the supernatant will be either recycled or discharged via a pipeline to Pond Hill Creek. ,With this treatment, the staff believes that the waste effluent disposal will meet PDER requirements for disposal of such waste.

A.4.3 ENVIRONMENTAL IMPACTS A.4.3.1 Terrestrial Construction Im acts Construction plans for the proposed project have not yet been completely finalized. As currently reported by the applicant, the principal areas to be directly affected by construction activities are indicated in Figures A.2.2, A.2.3, A.3.1, and A.3.2; however, the use of some designated impact areas is qualified as follows. The location of the construction staging area, as well as facilities within the staging area, will be dependent"on needs and requirements of the appli-cant's construction contractor. Also, borrow areas 3 and 4, located within the proposed impound-ment area (see Fig. A.3.1), will be the principal sources of fill materials used in dam construc-tion (ER-OL, Supp. Response to NRC I). 17, 28 September 1979). To the extent that suitable core materials available at borrow area 3 are insufficient to complete the dam embankment, the required materials will be removed from either or both borrow areas 1 and 2. Although the need for additional materials, is "not anticipated," the applicant has also identified borrow area 5 as a possible offsite source of core materials (ER-OL, Supp., Response to NRC I). 17, 28 September 1979). Thus a total of about 45 ha of local land outside the impoundment area (borrow areas 1, 2, and 5) may be disturbed to acquire materials for dam construction (ER-OL, Supp. Response to NRC I), 5", 28 September 1979).

The most obvious and extensive of the adverse construction impacts, on the terrestrial environ-ment will result from the destruction or alteration of local vegetation. Most of the vegetation to be affected during construction consists of forest and woodland. Merchantable wood products will be salvaged to the extent practicable (ER-OL, Appendix H, Sec. 4.3.2.5); however, the growth and growth potential of trees that have not 'yet attained merchantable size represent a loss of forest resources. The most significant loss of forest vegetation will occur within the proposed impoundment area and within the dam embankment and spillway sites (see Figs. A.2.2 and A.3.2), about 144 ha of total land area (ER-OL, Supp. Response to NRC I). 1, 28 September 1979). Virtually all of this area will be cleared of woody vegetation prior to or during con-struction (ER-OL, Appendix H, Section 4.2.5,2); nearly 140 ha of mixed deciduous and coniferous-

A.4-2 deciduous forest will be destroyed. Several small tracts of forest vegetation inside the perim-eter of the impoundment area will be left intact to provide habitat for fish (ER-OL, Appendix H,-

Section 4.2.2.2).

The level of use and activity within the onsite construction staging area will be relatively

'intense,'everely affecting the local vegetation. As noted previously, the size and location of the staging area are not yet resolved. However, given the area as indicated in Figure A.3.1, about 8 ha of forest and 6 ha of hayland and old field vegetation will be destroyed or disturbed.

Also, the extent to which upland borrow areas (areas 1, 2, and 5; Fig. A.3.1) will be disturbed to acquire fill materials for dam construction has not been established (ER-OL, Supp., Response to NRC O. 17, 28 September 1979). Assuming total utilization of all designated borrow areas, about 22 ha of forest and woodland, and a similar area of herbaceous vegetation will be destroyed.

Some additional vegetation, primarily forest, will be disturbed in the vicinity of small con-struction sites, including those identified in Figure A.3.2; namely, the saddle dike and cutoff, structure adjacent to the proposed impoundment, the pumping-plant site, and the narrow corridor (18,m wide) cleared for construction of water pipelines and the primary access road (Alterna-tive 8). About 2 ha of vegetation will be cleared from the coranon right-of-way required for pipeline and access-road construction; lesser areas will be affected at the other small construc-t tion sites.

The intensity and pattern of soil disturbance resulting from construction will closely corres-pond to impacts on the local vegetation as discussed. Soils of the proposed impoundment and dam sites will be comnitted, either totally disrupted during construction or inundated following construction. Land within these areas is unsuitable for cultivation, with the exception of isolated small tracts of Capability Class IV soils (see Sec. A.2.5.1.4).

About 29 ha of Class II soils (including prime farmland) occur within the construction staging and upland borrow areas (see Fig. A.3.1); the remaining land includes small tracts of Class III and IV soils and more extensive so'ils unsuited for cultivation (ER-OL, Appendix H, Fig. 3-13).

These soils will be variously disturbed during construction; however, soil impacts will be mitigated as follows. The applicant will require that the construction contractor schedule project activities so as to minimize erosion potential. Further, work areas will be stripped of topsoil that, in turn, will be stockpiled and stabilized by establishing a temporary vegetative cover (ER-OL, Appendix H, Section 4.3.2.1). Reclamation of disturbed areas will entail estab-lishing the approximate original contours, replacing topsoil, and providing suitable landscaping.

The applicant will also require the contractor to develop and submit an erosion and sediment control plan for the project site; this plan will be subject to review by appropriate agencies, including the Pennsylvania Department of Environmental Resources (ER-OL, Appendix H, Sec-tion 4.3.2.1). The plan will include details concerning practices to be employed, design specifications of control structure(s), and maintenance schedules to ensure effective erosion control. Given that the relatively marginal soils within the impoundment and dam sites will be disrupted or otherwise committed, the staff considers the foregoing provisions and requirements to be adequate precautions for conserving soil resources, provided that such measures are properly implemented. In view of the generally steep gradient of the proposed access road (see Fig. A.3.2), the staff recoranends that culverts and water-spreader structures be installed at appropriate intervals to control the volume and .velocity of runoff from the paved access road as well as runoff intercepted by the roadbed.

The applicant's comnitment to landscaping certain disturbed areas will variously offset the adverse construction impacts on the local vegetation. Additionally, the established vegetation will partially offset losses of wildlife habitat incurred during land-clearing and construction activities. However, development of the dam and impoundment sites will preclude reclamation, thus more than two thirds (144 ha) of the total affected wildlife habitat will be severely altered during construction and will be unavailable for use by terrestrial wildlife during reservoir operations The extent and types of wildlife habitats affected during construction are implicit in the pre-ceding discussion of impacts on the vegetation. Accordingly, the principal types to be affected will be forest and woodland habitats. Wildlife species strongly dependent on resources of these habitats include locally important game species such as whitetail deer, black bear, eastern red and gray squirrels, wild turkey, ruffed grouse, and American woodcock. Host of the locally occurring maranals.utilize forest habitats to varying degrees. For example, the habitat prefer-ences of the eastern cottontail includes brushy areas typical of forest - old field ecotones.

However, representative areas of all major habitat types occurring onsite will be affected during construction; thus populations of all mammals identified in Section A.2.5.1.2 will prob-ably be deprived of habitat to some extent. Characteristic habitat types of nongame birds as well as reported habitats of locally observed reptiles and amphibians are also indicated in Section A.2.5.1.2.

A.4-3 The alteration of habitats will be accompanied by a general migration of anima'Is from the affected areas. The displaced animals-will cause increased competition for habitat resources and space in adjacent habitats; the effects of this increased competition will be local and generally of short duration since habitat types similar to those onsite occur extensively throughout the surrounding area. However, all animals will not escape the impacted areas. Some of the less mobile animals, as well as juveniles of other species, will be impinged, buried, or otherwise destroyed during land-clearing and earth-moving activities. ,Any remaining animals will be subject to increased predation due to the removal of vegetative cover and to destruction of underground refuges. Some additional mortality will occur as the result of collisions with project-related traffic.

Construction noise and activity will also affect animal populations in areas not affected by construction. The applicant will require that noise emissions from construction equipment be in compliance with federal guidelines (OSHA, EPA) (ER-OL, Appendix H, Section 4.3:2.4). The intensity of blasting vibrations will also be controlled to the extent that local structures will not be affected. However, some of the more wary species, such as the wild turkey, will probably vacate the site during the construction period.

As noted, disturbed construction areas (with the exception of the proposed impoundment and dam sites) will be reclaimed if feasible, thus mitigating project impacts on wildlife. The appli-cant has further comnitted to improving wildlife habitat of the project site (see Sec. A.4.4.'1).

Pending final establishment of site bbundaries, the applicant, in consultation with the Pennsyl-vania Fish and Game Commissions, will prepare a management plan for the site (ER-OL, Supp.,

Response to NRC O. 15, 28 September 1979). Given proper implementation of a sound habitat management program, the staff believes the adverse construction impacts on wildlife can be offset to a substantial extent. The proposed reservoir will provide management opportunities not currently available.

Other construction impacts on the terrestrial environment include dust emissions from work areas and disturbed surfaces; however, the applicant will require the contractor to implement suitable dust control measures (ER-OL, Appendix H, Section 4.3.2.4). Slash materials and other com-bustib'le construction wastes will be burned in accord with applicable federal, state, and local regulations (ER-OL, Appendix H, Section 4.3.2.5)'The disposition of waste effluents generated during batch plant operation will be in compliance with requirements of the Pennsylvania Oepar t-ment of Environmental Resources (ER-OL, Supp., Response to NRC O. 6, 28 September 1979)., The staff believes that adherence to the foregoing precautions will limit the anticipated impacts to acceptable levels.

0 erational Im acts The most significant operational impacts will occur with the initial filling of the reservoir, i.e., conversion, of terrestrial habitats to an aquatic environment. Any residual soils and vegetation within the impoundment area will be inundated. Resident animals will either perish or be forced to migrate as the water level within the reservoir rises. Ihrtality will occur as animals seek temporary refuge on isolated islands created during initial filling of the reser-voir, and as these islands are subsequently inundated. The number and kinds of animals that escape will be influenced by the swiaming ability of the various species. The number of affected individuals will be relatively low since most 'will have been destroyed or displaced during land-clealing and construction activities.

Terrestrial habitat adjacent to the perimeter of the filled reservoir will be subject to dis-turbance due to wave action. However, the applicant proposes that "suitable ground cover of the slopes in the vicinity of the water line will be provided at all areas where sloughing may be a problem" (ER-OL, Supp. Response to NRC l}. 14, 28 September 1979). Thus, the onsite terrestrial habitat available to wildlife will be decreased by about 127 ha due to filling and operation of the reservoir. This loss of terrestria1 habitat will to some extent be offset by the creation of a similar area of aquatic environment that will be used by both terrestrial and aquatic organisms. The future use of the reservoir by wild'life cannot be readily quantified. However, given the applicant's cornnitment to undertake a wildlife habitat improvement program, the staff does not believe that project related impacts will cause an unacceptable diminution in the overall wildlife productivity of the Pond Hill site.

Other impacts on the terrestrial environment directly attributable to reservoir operation will be of minor consequence. For example, vegetation within the utility right-of-way extending from the pumping-plant site to the reservoir (about 1.2 km) will be controlled. The applicant indicates that only chemicals approved by EPA will be used to control vegetation (ER-OL, Supp.

Response to NRC O. 15, 28 September 1979). Other human activities associated with routine operation and maintenance will generally result in negligible impacts on vegetation, soils, and terrestrial wildlife resources of the site. Operational noise levels will be relatively low; power units used for periodic refilling of the reservoir will consist of electric motors.

A.4-4 The applicant plans to allow public use of the site for specific 'recreational activities (ER-OL, Appendix H, Section 4.2.2.3). Such use will, however, be controlled to prevent degradation of the site resources,(ER-OL, Appendix H, Section 4.3.3).

A.4.3.2 ~Acetic A.4.3.2.1 Pump House and Intake Screens Construction As presently proposed, the construction of the pump house will have minimal, if any, impact'on either the water quality or the biota of the Susquehanna River. The applicant is committed to construction practices that minimize erosion and control sedimentation. The staff concludes that there will be no aquatic impacts to the two unnamed creeks bordering the proposed pump house on the north and south (see Fig. A.2.4).

Installation of the slotted-pipe or wedge-wire screen type of intake (see Sec. A.3.1.5) will result in loss of habitat, increased turbidity, and siltation. The staff concludes that the loss of habitat will be insignificant and that increases in turbidity and siltation will be temporary.

~0eration Operation of either a slotted-pipe or wedge-wire screen type of intake is expected to have mini-mal impact on the aquatic comunity of the Susquehanna River. The applicant did not indicate what the slot width would be; however, slot widths as small as 0.25 ran are suggested as a means of screening fine debris and preventing the entrainment of ichthyoplankton.'mpingement is purportedly minimized by the absence of a confining screenwell, which may entrap fish, and by the flushing action of ambient currents flowing around the cylindrical screen. To minimize impingement mortalities and to enhance the escape potential of organisms in the zone of influence of the intake flow, the entrance-slot velocity for cylindrical wedge-wire screen designs is generally taken as 12.2 cm/s or less. As the proposed maximum approach velocity for the Pond

.Hill intake is 11.6 cm/s, the staff concludes that approach velocities should pose no problems.

A.4.3.2.2 Inundation and Operational Impacts The rocky, shallow, fast-flowing stretch of Pond Hill Creek to be inundated will become a soft-bottomed, deep, slow-moving body of water. As a result, the aquatic biota will change from a lotic to a lentic comunity, The effects of the reservoir on the water quality of lower Pond Hill Creek can be, projected by comparing the water quality of the Susquehanna River with that of Pond Hill Creek. A comparison of the respective maximum, minimum, and average water-quality parameters is shown on Table A.4.1.

The comparison shows that although some amelioration will take place in the reservoir, the water quality of lower Pond Hill Creek will be substantially lowered by the reservoir discharge.

The algae coranunity in Pond Hill Creek consists of periphytic algae and diatoms that become free-floating only when detached during high flow. After inundation, conditions in the reser-voir will permit the establishment of phytoplankton and zooplankton populations that .will become the principal source of primary production., The reservoir will represent a significant ecosystem change from the present stream habitat, which relies upon the input of organic matter from the surrounding area as the chief source of primary production.,

Productivity levels in Pond Hill Reservoir will depend, to a large extent, on the amount of nutrients available for the growth of phytoplankton. The Susquehanna River, which will be the main source of inflowing water for the reservoir, contains high putrient concentrations year round (ER-OL, Section 4,2.3.2.2). To prevent the development of algal blooms and to control eutrophication, EPA has recomnended that total phosphates as phosphorous should not exceed 0.050 mg/L in any stream at the point where it enters any lake or reservoir, nor 0.025 mg/L within the lake or reservoir.s. Data gathered from 1972 to 1976 indicate that nearly all monthly and annual means of total phosphate levels in the river near SSES considerably exceeded these criteria (ER-OL,,Section 4.2.3.2.2). Consequently, based on the total phosphate levels that would be expected in the inflowing water, the potential that eutrophic conditions will occur in Pond Hill Reservoir is relatively high.

The potential for high productivity (i.e., eutrophic conditions) during the first few years of impoundment will be enhanced, since the recently inundated terrestrial vegetation and soils will provide an additional large source of nutrients (ER-OL, Section 4.2.3.2.2). A reservoir becomes less productive over a period of time due to a decline in the quantities of land-supplied

A.4-5 I

Table A.F 1. Comparisons of Water I)uality of Susquehanna River and Pond Hill Creek Pond Hill Creek Sus uehanna River parametera Hean Hax. Hin. Hean Hax. Hin.

Temperature ('C) 8.2 16.0 0.0 14.4 25.0 3.0 Dissolved oxygen 11,7 13.9 8.0 11.2 14 ' 3.35 BOD 2.0 8.0 <0.5 2.2 5.0 <0.1 COD 8.9 18.0 3.4 13.0 25.0 5.0 pH (units) 7,1 7.6 6.65 7.6 8.6 7.2 Alkalinity as CaCOa 9.2 23.0 <1.0 42.6 66.0 19.0 Total hardness as CaC03 19.0 24.0 14.0 105.9 167.0 66.1 Total dissolved solids 56.2 133.0 <0 ' 171.4 290.0 67.2 Total suspended solids 16.4 120.0 <0.5 17.4 36.6 9.1 Turbidity (dTU) 2.6 5.5 0.7 1.2 16.0 5.1 Specific conductance (umhos) 51.0 68.0 45 ' 222.0 .330.0 160.0 Color (CPU) 8.0 22.0 1.0 45.0 80.0 7.0 Sulphate as S 11.4 16.8 6.0 88.0 180.0 28.0 Ortho phosphate as P 0.02 0.06 <0.01 0 '5 0.10 <0.01 Total phosphate as P 0.07 0.47 <0.01 0.2 8.84 0.04 Nitrate as N 0.14 0.33 0.01 0.72 1.0 0.43 Chloride 2.7 11.1 0.4 12.4 18.4 6.2 Total copper 0.03 0.06 <0.02 <0.02 0.02 <0.02 Total iron 0.66 3.11 0.20 2.5 4.7 1.63 Total manganese 0.05 0.21 <0.02 0.48 0.9 0.19 Coliform total HPN/100 mL 609.0 >2400.0 43.0 2007.0 72400.0 43.0 Coliform fecal HPN/100 mL 52.0 240.0 <3 412.0 1100.0 3.0 Fecal streptococci HPN/100 mL 4.0 20.0 34.0 85.0 <1 Units mg/L unless stated other'wise.

nutrients and organic matter and the loss of nutrients to bottom sediments.>~4 s Reservoirs act

~

as traps for the nutrients, which adhere to clay particles and settle to the bottom. Once removed, nutrients are less likely to reach surface waters because thermal stratification and chemical conditions in the sediment hinder resuspension or dissolution. During spring and fall circulation of water in the reservoir, some of the nutrients are recycled to the surface for use by phytoplankton. However, once phosphorus reaches the bottom sediments, very little of it usually returns to the epilimnion (ER-OL, Section 4.2.3.2.2). With increasing age, productivity levels in the reservoir will, to a large extent, depend upon nutrients introduced by inflowing waters and brought to the surface during overturns.

P Whenever water must be pumped from the river to meet storage requirements, nutrients in high

'concentrations will enter Pond Hill Reservoir. Consequently. although nutrients may be somewhat depleted in the reservoir as time passes, an additional supply will be provided during refilling operations. Data on Table A.4.2 indicate that very little pumping will be required during most years.

In general, Pond Hill Reservoir appears to have a relatively high potential for initial eutro-phication, followed by a gradual decline in productivity levels as nutrients are lost to bottom sediments, -This cyclic pattern may be repeated following periods of pumping to

'h fill the reservoir.

Elevated concentrations of iron will enter the reservoir from the Susquehanna River (ER-OL, Section 3.2.3.2.2). Hean monthly levels of iron in the river ranged from 2.2 to 7.3 mg/L from 1972 to 1976. Host of the iron entering the proposed reservoir will be oxidized, forming precipitates that will subsequently settle to the bottom. Some of this iron will appear in the water column during spring and fall circulation, and in the hypolimnion if it becomes anaerobic;

A.4-6

'Table A..4.2. Summary of Reservoir Operation Based on Historical Flow Records of the Susquehanna River at Wilkes-Barrea Drawdown Minimum Refill Number Levelb Acres Number Year Period of days (ft.) Exposed Period of days 1905-1907 No Operation 1908 Sept. 17-28 12 935.0 12 Jan. 6-14 10 1909-1910 No Operation 1911 Aug. 17-19 939.0 3 Sept. 1-3 1912 No Operation 1913 Sept. 12 Sept. 16-17 Sept. 20 938.5 4 Oct. 21-23 1914-1938 No Operation 1939 Aug. 26-31 6 937.5 Sept. 1-7 7 Sept. 10-24 15 927.5 28 Oct. 29-Nov. 19 24 1940 No Operation 1941 Sept. 26-30 938.0 5 Nov. 9-13 Oct. 1-9 ,934.0 14 Dec. 24-29 12 1942-1952 No Operation 1953 Sept. 1 939.8 2 Oct. 3-5 938.5 4 Nov. 23-25 1954 No Operation 1955 July 31 939.8 Aug. 1 Aug. 3-10 936.0 9 Aug. 14-21 1956-1 958 No Operation 1959 Sept. 24-30 937.0 8 Oct. 9-14 1960-1961 No Operation 1962 Aug. 3-6 4 938.5 4 Aug. 25-27 3 937.0 8, Aug. 31 1 936.6 8 Sept. 1-15 15 930.0 23 Sept. 20-27 8 926.0 32 Oct. 1-24 26 1963 Oct. 12-18 7 937.0 8 Oct. 20-31 12 931.5 20 Nov. 1-6 6 928.5 26 Nov. 29-Dec. 17 21 1964 -Critical Drought-Aug. 8-11 4 937.5 5 Aug. 15-18 936.3 8 Aug. 20-21 2 935.3 ,11 Aug. 28-29 2 933.0 15 Sept. 3-30 28 91.9.0 45 Oct. 1-31 31 900.0 83 Dec. 28, 1964-Jan. 18, 1965 Nov. 1-25 25 878.0 127 Feb. 7-Apr. 12 86 1965 July 30-31'o 2 939 ' 2 Sept. 26-27 2 1966-1975 Operation a

Does not include operations for maintenance purposes. Source: ER-OL, Vol. IV.

b To convert feet to meters, multiply by 0,305.

A.4-7 but, with the exception of iron chelated with organic matter, most of it will be oxidized and returned to the sediments as insoluble compounds. Since the iron will probably remain oxidized in bottom sediments, the dissolved iron concentration in the water column will be less than the 1.0 and 1.5 mg/L recomnended for the protection of aquatic life.

Iron (by combination and precipitation) does not appear to have reduced phosphate levels nor severely limited phytoplankton productivity near SSES. Because iron concentrations in the Pond Hill Reservoir will decrease, and the levels recorded in the river at present do not appear to have seriously reduced primary production, the effects of iron on productivity in the Pond Hill Reservoir is not expected to be great.

Impacts on water quality from other substances entering the reservoir from the river should be insignificant, since the remaining parameters have been found to meet criteria recommended by DER and EPA. Fecal coliform levels in the river usually exceed standards acceptable for bathing waters. However, fecal pathogenic bacteria will survive for only a few days in the reservoir.4 Since the reservoir will be eutrophic, large growths or blooms of diatoms, green algae, and blue-green algae may seasonally occur in some years. However, extensive algal blooms would not be anticipated every year, since there will be a net loss of nutrient salts to the bottom sediments. Hacrophytes, such as cattails and pondweeds, should appear in the shallow, inshore waters, but the amount of growth of macrophytes and periphytic algae in Pond Hill Reservoir will be limited, since much of the shoreline will be steep-sided. Mosses and liverworts, which are abundant in Pond Hill Creek, will be eliminated following inundation, since they require hard, unsilted substrates and continuously flowing water for survival.s Other periphyton will gener-ally be confined to the littoral or inshore areas of the new reservoir, since growing conditions in the flooded stream channel will no longer be suitable. Iron deposits may also inhibit macrophyte development.

Following reservoir -pool formation, a thin layer of silt will accumulate on the bottom, and a fairly uniform benthic habitat will result throughout the new reservoir. Consequently, since quiet and riffle water habitats and a variety of substrates will be eliminated or covered over by silt, the diversity of benthic macroinvertebrates in the proposed reservoir should be less than that observed in Pond Hill Creek. Species composition will also change significantly.

The Pond Hill Creek macroinvertebrates, which require a running-water habitat (stoneflies, caddisflies, and most mayflies), will not survive in the impoundment; those capable of adjusting to quieter waters and/or preferring soft substrates (oligochaete worms, snails, dragonflies, and midge larvae) will become more abundant in the reservoir. However, benthic macroinver tebrates-may be further limited by iron deposits on the bottom and/or low dissolved oxygen levels in the hypolimnion. Thus, only the more tolerant macroinvertebrate forms would be expected to inhabit the bottom of the:lake. Midge larvae (Chironomidae) will probably dominate the reservoir benthos, since they survive at very low oxygen levels and were found to be abundant in sections of the Susquehanna River in which heavy iron deposits were observed.,

Pond Hill Creek is very small and presently supports a limited fish population comprised chiefly of minnows. Ho endangered or rare fish species inhabit the stream, nor are there any permanent game fish populations present.

A number of factors will affect the type of fish community that will develop in the reservoir.

The fish species presently found in Pond Hill Creek, which prefer and/or require running-water habitats, are not expected to occur in the proposed reservoir. These include blacknose dace and creek chubs. On the other hand, golden shiner and fathead minnows, along with bluegills, largemouth bass, and other species inhabiting the small ponds adjacent to the stream may become abundant in the new reservoir.

Low dissolved oxygen and chemically-reduced substances released from bottom sediments may create an unfavorable habitat in the hypolimnion during late suraner for many fish species.

However, oxygen levels in the epilimnion should remain sufficiently high to support warmwater fishes (ER-OL, Section 4.2.3,3.2).

Iron levels, near the intake site have .been consistently higher than the 1,0 and 1.5 mg/L crite-ria. However, a total of forty-two fish species have been found to inhabit this section of the river. Apparently the ambient iron concentrations in the river are not directly toxic to these species. Nor do growth or spawning success seem to have been adversely affected. Consequently, most of the fish species, including a number of game fish, inhabiting the Susquehanna River near the intake site would be relatively unaffected by the iron levels in the reservoir. Possible detrimental effects of iron on the fish in the reservoir should be further reduced by the fact that iron concentrations will be lower than those usually found in the river.

Periodic drawdowns should have no major detrimental effects on fish or other aquatic life in the reservoir. Orawdowns generally will be infrequent and will expose a relatively small amount of

A.4-8 the lake bottom; an extensive drawdown of the reservoir would be anticipated only once in about 71 years. All drawdowns would be expected to occur during the late suraner and fall months.

The staff also concludes that evaporation rates will have insignificant effects on spawning habitat. The applicant's anticipated evaporation rates are presented in Table A.4.3.

In general, the proposed reservoir would be a suitable habitat for many warmwater game fish; these could include pickerel, muskellunge, catfish, bluegill (and other sunfish), crappie, smallmouth bass, largemouth bass, yellow perch, and walleye, all of which presently occur in the Susquehanna River near the intake site. These fish will be introduced and maintained by a fishery management program (ER-OL, Section 4.2.3.3.2). A number of these species would probably establish permanent populations in the reservoir.

Table A.4 .3. Anticipated Evaporation, Rated on a Monthly Basis for the Pond Hill Reservoira Month Evaporation (cm) Month Evaporation (cm)

January 0.0 July 1.9 February 0.0 August 1.7 March 0.0 September 1.2 April 1.3 October 0.8 May 1.7 November 0.6 June 1.8 December 0' Source: Response to NRC I)uestion 23, 12 October 1979.

A.4.3.2.3 Dischaege System Construction Im acts Since the discharge system, as presently proposed, will be contained within the same structure as the intake (see Fig. A.3.3), impacts associated with construction. of the discharge will be the same as those discussed for the intake system (see Sec. A.4.4.2.1.1).

0 erational Im acts The applicant indicates that the quality and temperature of water discharged from the reservoir into the downstream section of Pond Hill Creek and the Susquehanna River will be controlled by the multilevel inlet-outlet structure (ER-OL, Sec. 4.3.1). The outlet ports for compensation releases in the revised inlet-outlet structure (Fig. A.4.1) will be at the 291.4, 282.0, and 259.1 m levels. The applicant has performed new thermal modeling analyses for the reservoir, using the schedule of compensation releases that would be required, for, 1964 drought conditions and the two sets of meteorological data, 1964 and 1975 (PP8L Conment letter, 29 May 1980; Letter 17 of Appendix B). The results of these calculations are given in the above comment letter.

The staff has not verified the applicant's calculations but does agree with their conclusion that, under most conditions, the compensation releases will be from the epilimnion layer, mini-mizing the potential for cold shock in the Susquehanna River. However, in the unusual event that the water level in the reservoir is below that of Outlet No. 2 (282.0 m} (the minimum pool level is 264.4 m), compensation water would be pumped through the outlet at 259.1 m and wou'ld be hypolimnetic water. Thus, a potential for cold shock remains. However, the staff believes that the multi-slotted discharge will enhance dilution and thus mitigate the effect to some degree.

In addition to extreme temperature changes, nutrient concentrations in the discharge may be higher than presently expected, depending on from what portion of the hypolimnion the water is withdrawn. The deeper the water, the higher the concentrations. An exception would be during turnover, when the concentrations would be more uniformly distributed.

Iron levels in the discharge water may be high, especially if release coincides with overturns.

In addition, since the reservoir may be eutrophic, large amounts of organic matter may appear in discharges. High iron and organic-matter concentr'ations in the discharges should have little impact on the Susquehanna River, since compensation releases will be infrequent and usually small in volume.

I / //'

I 5 CI rrr r l' 5

TO>>CD AND SNIDSC iJ CLCVATKW

>>NI 0 SSCA r //

SCCTION C O w/ a rr>>r 5CCTION C.C rr rrI I>>>>t ti '". N Nwrr>>W>>I WA I I

>> 'LT

+w/arirr SCOT@>>I D.D SCCTNNI A A rr'1>>

SCC SION ~ D ~ W>>N>> nr r>>11>>>>wwN WN Fig. A.4.1. Inlet-Outlet Structure;

A.4-10 Dissolved oxygen concentrations vary inversely with reservoir depth. Anoxic conditions may exist in the deeper parts of the hypolimnion. Obviously the discharge of anoxic water to either Pond Hill Creek or the Susquehanna River would be adverse, with the effects being localized.

A conservation release of 5.7 L/s will be maintained for the remaining sec'tion of Pond Hill Creek below the dam. Host of the time, however, the downstream releases will exceed this rate due to natural runoff in the watershed. Although there should be a sufficient quantity of water to support the existing aquatic life in the stream, the quality of the downstream release water may be detrimental to some of the stream organisms. But iron levels in the release water may exceed the recormended criteria, particularly during reservoir overturns. This could result in the deposition or iron precipitates on the stream substrate, which in turn, could limit peri-phyton and macroinvertebrate comaunities to iron-tolerant species.

The average release velocity through the screens will be about 0.4 ft. per second (0.9 cm/s)

(measured 1 foot from the screens) and the screens will be about 2 ft. (0.6 m) above the river-bed. Any scour that may result from compensation releases will be localized and temporary.

The staff concludes that monitoring benthos in the vicinity of the discharge is not necessary.

A.A.3.3 ~Atmos heric Converting 128 ha of mixed woodland/field vegetative cover to water will have minimal impact on the atmosphere. The thermal inertia of the stored water will moderate air temperatures slightly.

In fall and early winter, light steam fog will occasionally form over the water and'move a few tens of meters inland before evaporating. Since there is no heat load on the reservoir, the frequency and density of the steam fog will be similar to that of other small lakes in the area.

Equipment used in construction will comply with the criteria established by OSHA and EPA for noise and exhaust emissions. The applicant will require the contractor to employ dust control measures (ER-OL, Appendix H, pp. 4-87).

A.4.4 HYDROLOGIC IHPACTS A.4.4.1 Construction Stripping of vegetation from the area to be inundated and from other areas will increase the runoff coefficient, resulting in higher peak flows in Pond Hill Creek. However, since this effect will be temporary (the dam, when complete, will provide flood control for the remaining section of the stream) and since there are no residences that can be affected by the higher streamflows, the staff concludes that the impact will be minimal.

The major hydrologic impact of the construction of the dam will be to convert a natural stream, Pond Hill Creek, into a reservoir and a stream whose maximum and minimum flows will be con-trolled. The hydrologic aspects of the stream before construction are discussed'in Sec-tion A.2 '.2. The upper portion of that stream will be replaced by a reservoir with a normal, or full-pool, elevation of 299 m NSL. This reservoir would cover 128 ha and contain approxi-mately 30 ht 10 m of water. The maximum depth during normal pool operation would be about 67 m; the average depth would be 23.3 m.

The applicant used the Hydrologic Engineering Center (HEC) Mater guality Model to simulate the thermal behavior of the reservoir. The model results are sensitive to calibration constants that can only be determined by field measurements. for the Pond Hill thermal, simulation, the vertical eddy diffusion coefficients were estimated by comparison with similar lakes and reser-voirs. Although the analysis was performed for the smaller reservoir originally proposed by the applicant, the results are useful in that they provide a general description that should be representative of the proposed reservoir's thermal characteristics.

The HEC model predicted that the proposed reservoir would be thermally stratified during the sumner with turnovers and mixing in early spring and late fall-. A relatively stable thermocline was predicted to form in late April and remain throughout the rest of the spring, suraner, and early fall (through October). The model predicted an epilimnion (upper layer) approximately 4.6 5'o 20'nd in the hypolimnion to 6.1 m thick with surfer temperatures between 25'C. Temperatures (lower layer) were predicted to range from 10'C.

The proposed location of the pumping station is adjacent to the railroad in an area outside the 1Ã chance (100-year) floodplain as shown in Figure A.2,5. Pipelines connecting the pumping plant to the submerged intake and discharge will be buried in the floodplain. The applicant is com-mitted to restore the land surface in the floodplain after completion of construction. The staff concludes that there is no practicable alternative to the construction of this section of pipeline in the floodplain and that the hydrologic impacts would be minimal.

A.4.4.2 .~0 erat)on A.4.4.2.1 Water Supply The Pond Hill Reservoir was proposed to provide replacement for Susquehanna River water consumed by. the Susquehanna Steam Electric Station during periods of low flow as defined in 18 CFR 803 low-flow criterion is the seven-year, ten-day (g7-10) low flow of the Susquehanna River plus 'he the consumptive water use of the power plant. At Wilkes-Barre, the g7-10 is estimated to be 22.7 m3/s. Thus, the requirement for replacement of consumed water becomes effective whenever the river flow at Wi lkes-Barre is below,22.7 m~/s plus the plant's actual measured consumptive use. Average plant consumptive use is estimated to be 1.4 m3/s, with the maximum estimated to be 1.8 ms/s. Therefore, water replacement may be required when flow at Wilkes-Barre is, below 24.5 ms/s.

The reservoir was designed to be able to supply the required replacement water to the Susquehanna River during a recurrence of the drought of record, August to November 1964. The effects of precipitation onto and evaporation from the reservoir during the drought, although minor, were included. During this drought, flow at Wi lkes-Barre was below 24.1 m~/s on 106 days, including one period of 84 continuous days. There was only one additional day,when the flow was below 24.5 ms/s. If it were assumed that the maximum consumptive use occurred on that day, the conclu-sions would not change significantly. At normal full pool, the reservoir will contain apprbx-imately 29.7 24 106 ms of water with approximately 27.1 x 106 m> available for release. If released at an average rate of 1.4 ms/s, the estimated average plant consumptive use, there will be enough water for more than 220 days without refilling the reservoir. The applicant has assumed a higher release rate of about 2.9 ms/s. At this rate, the reservoir's available storage would, be used up in about 106 days, the number of days for which replacement water would, be required during a repeat of the drought of record.

At the assumed average release rate of 2.9 ms/s, an average of 1.4 m>/s would be needed for replacement of plant water consumption and 1.5 m>/s would be available for other uses such as sales to other water users to supply compensation releases. During times of greater plant water consumption, the water available for other purposes would be reduced. At the maximum estimated plant consumption rate of 1.8 ms/s, approximately 1.1 m>/s would be available for other uses as described above.

The design rate at which the reservoir could be refilled with water from the Susquehanna River is 3.7 ms/s. At this rate, it would take approximately 84 days to refill the reservoir.

However, the applicant has stated that refilling will not occur at times when the flow in the Susquehanna River is below 85.0 ms/s. Even with this restriction, it is almost certain that the reservoir would be refilled prior to the next low flow.

A.4.4.2.2 Pond Hill Creek The operation of the Pond Hi lie Reservoir will change the character of the remaining portion of Pond Hill Creek, primarily during periods of high and low flow. Host of the time, with the reservoir full, surface flow into, or rainfall onto, the reservoir will be released through the spillway. This flow will be directed to the remaining lower portion of Pond Hill Creek. The replacement of approximately 39K of the upper drainage area of the stream with a reservoir will increase the flow at the spillway during moderate storms. However, during severe storms, the discharge will be limited by the cross-sectional area of the spillway. The excess inflow to the reservoir will be accommodated by a rise in water level'.

The applicant analyzed the system response during a lX chance flood.'(100-year recurrence flood).

The analysis indicated that under natural conditions the peak stream discharge would be about 49.7 ms/s. The calculated peak inflow (overland flow into and rainfall onto) to the reservoir was estimated to be about 60.8 m3/s. However, the peak discharge through the spillway was cal-culated to be only 0.84 ms/s. The reservoir,~therefore, will serve to considerably attenuate the effects of the flood on the downstream portion of the stream.

Normally, with the reservoir at full-pool elevation of 299 m HSL, all inflow to the upper por-tion of the watershed will pass to the lower portion of the s'tream via the spillway. The appli-cant has stated, however, that a minimum flow of 5.7 L/s will be maintained. A section of

'pipeline, connected to the reservoir-to-pumping plant pipeline imediately downstream of the dam will be used for this purpose. The release point will be between the toe of the dam and the spillway discharge location. The choice of 5 L/s for the minimum flow is based upon the method-ology used by DER to estimate the seven-day, ten-year low flow on ungauged streams. Since the natural streamflow probably ceases during drought periods, the proposed conserva'tion release represents a change in the hydrology of the downstream portion of the stream.

A.4-12 A.4.4.2.3 Hydrologic Design of Dam Since failure of the dam would not result in radioactive releases nor effect the reactor site, the staff did not perform a detailed evaluation of the dam's hydrologic design. The staff did, however, review the hydrologic criteria used and compared these with criteria used for (rat)io-logically) safety-related dams.

The applicant's hydrologic design criteria is a flood series consisting of the 6-hr Probable Maximum Flood (PHF) followed, 48 hr later, by a lesser "Recurrent Flood." Staff's criteria require a PHF preceded by 40 percent of the PMF. In addition, the criteria result in a PMF more severe than that calculated by the applicant. However, the applicant's design flood series,

'hile not as severe as the staff's, is an extremely severe flood event.

4 The applicant originally proposed a 3-m wide spillway, with a crest elevation at 299 m HSL.

The maximum reservoir level resulting from this design flood was calculated by the applicant as 300.19 m HSL, 1.18 m above the spillway crest and 1.56 m below the crest of the dam. The staff concluded, however, that its more severe design flood would result in overtopping of the dam. This was due primarily to the fact that the relatively narrow spillway was incapable of passing more than a small fraction of the postulated inflow to the reservoir.

The applicant has recently revised the proposed design of the spillway. The new design calls for the spillway to be 25.91 m wide with a crest elevation at 299.31 m HSL. The 0.30-m difference between the crest elevation and the normal full-pool reservoir elevation will provide additional flood storage.

The applicant routed its design flood through the reservoir with the revised spillway, assuming the initial water level to. be at the spillway crest; i.e., no flood storage below the crest available. The maximum reservoir level calculated was 300.21 m HSL, 0.9 m above the spillway crest and 1.54 m below the dam crest.

The applicant also routed the staff's more severe design flood series through the reservoir.

The calculated maximum reservoir level was 300.42 m HSL, 1.11 m above the spillway crest and l.'33 m below the crest of the dam.

The applicant's calculations indicate, therefore, that the dam can meet the hydrologic design criteria staff requires for (radiologically) safety-related dams..

A.4.4 ' ' Groundwater Effects Filling of the1 reservoir will alter the groundwater conditions within the drainage area of the upper portion of Pond Hill Creek. The groundwater level should rise to at least the level of the reservoir at its peI lmeter. Since. groundwater levels in the ridge north of the reservoir are clearly well above the reservoir level, there should be no effect on the groundwater regime north of the Pond Hill Creek drainage area. The limited information available on the ground-water conditions on the ridge south of the reservoir indicate that groundwater levels are also above the proposed water level in the reservoir. In addition, the applicant has proposed a saddle dam and an impervious cutoff section along the two lowest sections of that ridge. The staff, therefore, concludes that groundwater levels south of the ridge should not be affected by the reservoir.

4 A.4. 5 SOCIOECONOHI C IMPACTS The following is an assessment of the potential socioeconomic impacts of the construction and operation of the Pond Hill Reservoir on local communities in Luzerne County. Direct and in-direct changes to the sociocultural systems of local comnunities are expected to be a result of the construction work force and related activities and of the presence of a lake in a previously wooded, rural area.

A.4.5.1 ~Demo ra a The peak construction work force will contain 125 individuals with 85% (106) of the workers expected to be conmuters and 15K (19) in-migra'ting workers (Response to NRC Ouestion 26). The applicant estimates .that fewer than five of the. expected in-migrants will bring their families; assuming two children per family, an additional ten school-aged children are expected as a result of this project (Response to NRC Q. 26).

Because of the short duration (two years) of construction and concurrent phasedown of construc-tion at the Susquehanna Plant, the staff believes that i'nduced service personnel will not result h

A.4-13 from the nineteen additional workers and'their families moving into the local area. If these in-migrants are dispersed throughout the impact area, their additional service demands should be met by current staff and facilities.

A.4.5.2 Settlement Pattern A.4.5.2.1 Housing Specific information on the housing type and location preferred by the in-migrants is not avail-able. The applicant states that workers at the Pond Hill site are expected to make arrangements for temporary housing motels, boarding houses and return home on weekends (Response to NRC Q. 26).

Available housing in comnunities close to the project area, such as Pond Hill, Hocanaqua, and Shickshinny, is virtually nonexistent. However, the applicant believes that some transient housing would be available in Wilkes-Barre, or Nanticoke and additional housing is expected to become available in the Berwick-Bloomsburg area as the SSES work force is reduced.

However, factors such as local scenic qualities, recreational opportunities, gasoline prices, cost of living, etc., may attract more than the projected number of in-migrants. They and their families might choose to seek housing in the imnediate area during some parts of the year rather than to comnute from larger service center s. In such an event, housing competition may occur.

Operation of this project may also produce a secondary effect on local housing patterns because of the land-use changes brought about by the reservoir. Some residential development may esti- take place in the areas surrounding the reservoir and buffer area. The applicant has provided mates of the maximum and minimum number of residential development units that may be constructed, 35 and 140 units, respectively.s However, future development will depend on a combination of sociocultural factors, including the perceived attractiveness of the area, goals and values of the individuals wanting to build, local planning goals, availability of private land, and attitudes of local landowners.

A.4.5.2.2 Transportation The construction and operation of the Pond Hill reservoir will impact local transportation systems. During construction, Route 239 and, to a lesser extent, LR 40120 will be affected increased use for transport of construction-related equipment and materials and corrmuting

'y workers.< In order to minimize, traffic impacts in Pond Hill, the applicant will build a new access road to the reservoir site (Response to NRC Q. 8, part b). In addition, Route 239 will be affected by the construction of the pump station, when traffic will temporarily be reduced to one lane. The applicant has studied the cumulative effect of the Pond Hill and SSES projects and concludes that an additional police officer will be needed to facilitate traffic flow so as to avoid major transportation impacts.

During operation, increased traffic volumes are anticipated on township roads because of the recreational facilities that will be available at the reservoir.e And, although the construc-tion of a new access road to the site will lessen some of the impacts, the specific magnitude of these increases and their specific locations are not known at this time.

The applicant is comnitted to cooperation with the local townships to repair roads damaged due to reservoir construction activities.

A.4.5.2.3 Recreation The applicant has sumnarized the outdoor recreational areas by owner and acreage for the general region and Conyngham Township (Reference 6, Tables 3.2.8-1 through 3.2.8-3). Forecasts of state recreational demands show a need for more facilities in almost all outdoor recreational activi-ties. The staff believes that some of the projected recreational needs will be met byFish the Pond Hill Reservoir and associated facilities described in Section 3.3. The Pennsylvania Com-mission will be asked to stock the lake for warmwater sport fishing. The recreational potential created by these facilities is estimated to be from 7,300 to 10,000 visitor-days per year, not including visitations related to hunting or winter sports.e The applicant has defined five recreational development objectives in order to maintain the ecological characteristics and remote setting of the site and to minimize impacts of operation on the local comnunities while providing facilities that meet their perceived needs. The staff notes that these objectives were considered in the designs for recreational use and project maintenance particularly to avoid greater use of the site than its intended design capacity.

A.4-14 A.4.5.3 Im acts to, the Social S stem The applicant states that short- and long-term impacts 'to the cohesion of local comnunities near the reservoir site are not expected (Reference 6, Sec. 4.2.4.7). The staff believes that direct impacts to social institutions or cohesion will not be severe because of the small work force and projected number of in-migrants and because the project area does not physically divide a comaunity or separate coomunities. Potential effects on lifestyle; values; beliefs; and solidar-ity of local groups, neighborhoods, and comnunities would be due to indirect operational impacts of induced development. Such impacts could begin during construction. The potential for developmental impacts.to the local settlement system were discussed in Section 4.6 '.1 of Reference 6 ~

A.4.5.4 Social Services Because of the small work force, short duration of the project, and expectation of few.in-migrants, impacts to most kinds of social services are not expected. However, impacts asso-ciated with increased traffic may require traffic-control personnel in some local areas.

A.4.5.5 Im acts to the Political S stem Direct impacts to the political organization of local cormunities are not expected. Should indirect impacts occur, such as induced development, planning decisions,:increased personnel, financing and zoning, consideration may be required.

A.4 '.6 Im acts to. the Economic S stem Although the economic impacts of the construction phase of the project will be small, they are expected to be beneficial to the region and to some local businesses. The applicant states that construction cost (50K in materials) will have a multiplier effect on'the regional economy.<

Moreover, many construction materials and equipment may be purchased within Luzerne County; additional spending may result as these industries increase their purchases from other industries and hire more labor.<

A.4.6 IMPACTS TO CULTURAL RESOURCES Archeological investigations at the Pond Hill Reservoir site, limited to the area within the high water mark of the reservoir and a nearby section of the Susquehanna floodplain, disclosed negligible archeological materials.z References

1. "Johnson Screens in Surface Water Intake Systems," Bulletin 1S577. Johnson Division of United Oil Products, Inc.'t. Paul, MN, 1977.

2. J. B. Canon et al., "Fish Protection at Steam-Electric Power Plants: Alternative Screening Devices," Prepared for USNRC, Division of Site Safety and Environmental Analysis, under Interagency Agreement DOE.40-544-75 and the USEPA, Region II, Water Facilities, Branch-Energy 8 Thermal Wastes Section, Water Division, July 1979.

3. "Quality Criteria for, Water," U.S. Environmental Protection Agency, Washington, D.C., 1976..

4. E. T. Chanlett, Environmental Protection, New York: McGraw-Hill, 1973.

5. H. B. N. Hynes, The Ecolo of Runnin Water, Toronto: University of Toronto Press, 1972.

6. Tippetts-Abbett-McCarthy-Stratten(Engin'eers and Architects, "Design Report: Pond Hill Reservoir," prepared for Pennsylvania Power 5 Light Company, 1979.

7. Commonwealth Associates, "Archeological Investigations at the Susquehanna Steam Electric Station: the Pond Hill Reservoir Site," prepared for PP&L, 1981.

A.5. ALTERNATIVES, NEED FOR FACILITY, AND BENEFIT-COST ANALYSIS A.5.1 ALTERNATIVES TO CONSTRUCTING A WATER STORAGE RESERVOIR The applicant has given consideration to two alternative procedures, that would not require the construction of an offstream water storage reservoir and would comply with the requirements of the Susquehanna River Basin Comnission:

1. Not operate the Susquehanna Steam Electric Station whenever flow in the Susquehanna River fell below the consecutive seven-day low flow expected to occur every ten years (the g7-10 value).

2. Purchase makeup water from existing reservoirs.

The applicant has submitted the following documents in support of analysis of alternatives:

l. Appendix H, Section 2 to the Environmental Report for SSES,

2. "Assessment of Sites for an Augmentation Reservoir for the Susquehanna Steam Electric Station," Tippetts-Abbett-HcCarthy-Stratton, August 1977.

3. Letters from N. W. Curtis, PP&L, to,D. E. Sells, NRC, 12 October and 13 November, 1979.

Item 3 contains the applicant's response to staff questions on alternatives.

A.5.1.1 No Action Alternative--"River Followin "

The applicant could meet SRBC requirements by choosing not to operate SSES during specific per-iods of low river flow. This mode of operation, called "river following," would require the generation of replacement electrical power from other units within the PP&L or PJH power system, or the purchase of power from other utilities.

Based on the critical flow value, 24,1 ms/s, the river-following mode of operation would have required the shutdown of SSES for 106 days in 1964, the year of record low flow in the river.

The use of the river-following option would, in some years, require several additional shutdowns and startups of the SSES reactors, and also of the generating units providing the replacement electrical power. This cycling of units would add to maintenance costs and efforts and would probably decrease plant and system reliability.

A.5.1.2 Use of Existin Reservoirs The applicant has examined the potential for purchasing the required volume of, replacement water from an existing (or under-construction) reservoir. including those owned by the Pennsylvania Gas and Water Company {PGW), the U.S. Army Corps of Engineers (COE), and the Soil Conservation Service. Expansion of PGW's Nesbitt, Reservoir to hold the required volume of water would entail the construction of a new 64-m high dam and a long refilling pipeline from either the Lackawanna or Susquehanna River. Estimated costs of expanding the Nesbitt Dam would be greater than that of constructing the Pond Hill Reservoir. The staff agrees with the applicant that, due to higher costs and potential for delays. the use of PGW's water storage facilities is not to be preferred over the Pond Hill Reservoir.

COE has twd dams under construction in Tioga County, Pennsylvania. The applicant has sent to COE a request to purchase compensation water flow from the Cowanesque Reservoir, scheduled for completion in 1982 (ER-OL, Appendix H). COE has also indicated that congressional action may be required to make water storage an authorized use of the water in Cowanesque Lake (PP&L response to NRC questions). No firm cost values can be assigned to the use of COE-stored water.

A.5-1

A.5-2 A.S!1.3 ~Suamar The staff agrees with the applicant that the river-following alternative, while a viable one, is less desirable than the construction of Pond Hill Reservoir. The staff also agrees with'the applicant that there is the potential for long delays in obtaining the required compensation releases from Cowanesque Lake, making the second option less desirable than the construction of Pond Hill Reservoir.

A.5.2 ALTERNATIVE SITES The applicant has identified twelve potential alternate locations for the Pond Hill Reservoir (ER-OL, Appendix H, Section 2.4). This analysis is based on a usable water storage requirement of 11.7 x 10s ms, the volume of water that would be required for a compensation flow of 1.42 m /s for 96 days.

I The thirteen sites (selected and 12 alternates) were selected in part from a 1.970 Susquehanna River Basin Study Coordinating Committee study. In 1977, an engineering consulting firm iden-tified and investigated the technical, economic, and environmental characteristics of each site (Reference 1 and ER-OL, Appendix H, Section 4.2). TANS's analysis of the 12 alternate sites was based primarily on reconnaissance-level information.,

The applicant subjectively rated each site on the basis of eleven environmental engineering factors: number of residential units within the site; number of residential units below the proposed dam site; amount and type of agricultural activity affected; agricultural capability classification of soils within site; length of stream inundated; quality of the affected stream's fishery; water quality of the reservoir's water source (this would directly affect the reser-voir's potential water quality); potential impact on pumping source (with particular emphasis on proportion of total flow to be pumped and on fishery quality); a qualitative judgment of the wildlife habitat within the site relative to the other sites studied; length and type of water conduit (i.e., pipeline or tunnel) and character of area that would be traversed by a pipeline; and area exposed by maximum drawdown (directly related to the size and shape of the reservoir ).

Factors such as topography, hydrology, geology, and estimated cost of construction were also evolved. Construction impacts, except for the water condui t pipe and route, were considered to be similar for all sites. This analysis showed that the Pond Hill site would be the preferred site.

The staff has reviewed the applicant's site selection procedures and concludes that the method-ology used by the applicant is satisfactory and that none of the alternate sites is environ-mentally obviously superior to Pond Hill Creek. The staff's judgment is based in part on visits to the Pond Hill area and to four alternate sites.

A.5.3 BENEFIT-COST ANALYSIS A.5.3.1 No Action Alternative--"River Followin "

Based on historical river flow, the river flow will be lower than the critical level on an average of 3.3 days per year (ER-OL, Appendix H, Section 1). Under the river-following alternative, the applicant would have to buy replacement energy to make up for the loss of generation due to the shutdown of SSES. The applicant estimated the average annual energy requirement for four days of shutdown (including that for start-up time) to be between 160,000 MWh and 170,000 HWh (response to NRC I). 33, 12 October 1979). The energy range is due to the difference in length of start-up time associated with cold or hot reactor shutdown conditions. If an equal probability of hot or cold shutdown condition is assumed, the average annual energy requirement, as per the applicant's

.estimate, would be 165,000 HWh. Staff's estimate of energy loss during the four-day period, assuming 70K capacity factor, is 146,000 HWh. The applicant's and the staff's thirty-year present worth of the average annual replacement energy cost are 117.8 and 104.2 million dollars, respectively (Table A.5.1). In order to make a fairer comparison for benefit-cost Purposes, is important to subtract the cost of operating SSES from the replacement energy cost. It should it be noted, however, that there are .some advantages (such as improv'ed systems reliability) of operating SSES over and above the difference between replacement energy costs and SSES operating cost.

The applicant's and staff's thirty-year estimate of present worth of the average annual replace-ment energy cost at the incremental price are 64.3 and 56.9 million dollars, respectively (Tables A.5.1 and A.5.2). The staff's estimate of present value of average annual replacement energy cost falls between $ 41 million for the best-case (average annual shutdown of three days)

- and $ 192 million for the worst-case (average annual shutdown of fourteen days). The probability of shutdown of less than or equal to 3 days and 14 days are 86.1 and 99.1$ , respectively (Table A.5.3).

A'.5-3 Table A.5.1. Thirty-year Present Worth of the Average Annual Replacement Energy Cost Pond Hill Reservoir Cost Applicant Staff "

w/o tax w/tax Annual 4-day energy

'oss (MWh) 165,000 146,000 30-year present wor th at incremental price (M$ ) 64. 3 56.9 48.7 62.3 30-yean present 'worth at replacement price (MS) 117.8 104.2 49.5 63.1 Response to NRC I)uestion 33, 12 October 1979.

b Letter from L.E. Schroder, PP8L, to R. Prasad, ANL, 19 November 1979.

Table A.5.2. ,Staff Estimates of Replacement Energy Cost at the Incremental Price Replacement Nuclear Price Incremental Price Gen. Price Growth Price Year (mills/kWh) (mills/kWh) (X) (mil 1 s/kWh)

} 978 25 1980 35 13 0

~

1983 35 15.90 6.96 19.1 1985 40 18.20 6,9 21.8 1990 65 29. 5 10.19 35. 5 1995 100 45. 5 8. 99 54. 6 1995-over 5.0 Table A.5.3. Shutdown Probabilities Present Worth $ million Probability of Annual Average At Replacement At Incremental Oays Generation Loss Oay Loss Pr fce Price 83.00

<3 86.00 3 75. 6 41.2

<4 89.00 4 100.7 55,0

<7 90,00 7 176. 3 96.2

<14 94.00 14 352. 6 192.4

<31 99.0 31 780.8 426.1 96 1.0 96 2418.1 1319.8 Source: ER-OL, Vol. 4, pp. 1-4, Table 1.3.2-1,

A.5-4 A.5.3.2 Use of Existin Reservoirs The applicant has explored the potential for using water supply storage. in an existing storage facility to augment the river flow during the low riverflow period to keep SSES operating., Among the projects considered, the applicant, in consultation with COE, found the Cowanesque project to be the most suitable from the point of view of timeliness and availability of water supply storage. But in their'recent response they have pointed out many uncertainties regarding the availability of water storage due to congressional approval requirements and the Susquehanna River Basin Commission's coranent that: Cowanesque Lake cannot presently be considered as a timely .

alternative for supplying makeup water for SSES (applicant's response to NRC I). 39, 12 October 1979). The applicant estimates the approximate cost of this alternative to be $ 12 million over a 30-year period. The staff does not have sufficient information to substantiate the cost.

A.5.3.3 Pond Hill Reservoir The third alternative considered was the building of a reservoir; this would assure a source of low-flow compensation., The applicant has proposed to build Pond Hill Reservoir for water supply storage. The overall cost of the project is estimated by the applicant as $ 47 million 1983 dollars). The applicant has assumed that the only cost associated with the Pond Hill 'in Reservoir will be the electricity cost of pumping water into the reservoir. They estimate a yearly capacity cost of $ 40,300 and 2417 MWh (3357 kWh x 30 days x 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of electricity)

(personal communication, L. E. Schroder, PAL, to R. Prasad, ANL, 19 November 1979). The present values of this alternative, over 30 years, are $ 48.7 and $ 49.5 million, including incre-mental and replacement price of electricity. On a purely economic benefit-cost analysis,.which treats the tax cost as the transfer payment, these would be the costs of the project. If the property tax (in Pennsylvania the public utility realty tax is 3Ã of value) were treated as an added project cost, the staff's estimate of $ 63 million present value of the project would be very close to the replacement energy cost under the river -following alternative. One can also look at the property tax of $ 1.41 million as a compensation (benefit} for the environmental cost (undetermined) to the conmunity.

A.5.3.4 Discussion and Conclusions The cost of the river-following alternative is very dependent upon the probability of the occur-rence of period length (number of days) of low river flow. From the analysis, if it appears that, low river flow were to occur at an annual average of four days, the cost of the Pond Hill Reservoir alternative would be very close to the replacement cost of electricity under the

'river-following alternative. But, if the annual average period of low river flow were 25 days (4X probability), the energy replacement cost could be as high as $ 344 million.

The best economic alternative would appear to be the use-an-existing-reservoir alternative.

Based on the information available, Cowanesque appears to be the most economic among all alterna-tive reservoirs, given that concerned authorities grant the use of water for flow compensation.

The river-following alternative took into account only the cost of replacement energy; not consider the effect of SSES shutdown on system reliability. The effect of shutdown on it did reserve margin is shown in Table A.5.4. PP&L's projected reserve margin without Susquehanna after year 1985 is significantly lower than its historical margin since 1973'. PJM's reserve margin without SSES is projected to be approximately 25%, which is acceptable for the reliable opera-tion of the interchange. PPSL, being a winter-peaking system, is able to operate with a reserve margin of 5%. PPSL could provide reliable service to its customers even during a short interval of shutdown of SSES.

A.5.4 EVALUATION OF UNAVOIDABLE ADVERSE ENVIRONMENTAL IMPACTS OF THE PROPOSED ACTION A.5 '.1 Land The 525-ha site will be removed from current uses and dedicated to reservoir uses for the life of the project.

The development of the Pond Hill dam and impoundment sites will result in a long-term commitment of about 146 ha of land area. About 16 ha of this area will be altered during construction of the dam embankment, the spillway, and the overflow channel; 128 ha will be inundated following construction. About 2 ha will be used for the development of ancillary impoundment structures, water pipelines, pumping plant, service facilities, and highway access. Virtually all of the areas to be comnitted are presently forested land:

A.5-5 Table A.5.4. Effect of Shutdown on Reserve Margin PJM PPSL Reserve Mar in Projected 1980 1981 1982 1983 1984 1985 1986 1987 1988 1989 With Sus uehanna PJM 34 33 34 30 30 31 30 31 29 27 PP&L 29 44 58 53 48 46 42 35 33 30 Without Sus uehanna PJM 37 30 29 25 25 27 26 27 25 23 PPSL 29 26 23 18 15 13 10 4 2 , 1 Historical 1970 1971 1972 1973 1974 1975 1976 1977 1978 1979 PJM 13 21 22 16 ., 28 39 42 38 40 35 PPSL 1 6 14 34 30 39 27 48 39 35 Response to NRC guestion 35, 12 October 1979.

t Other principal land areas that will be disrupted or otherwise adversely affected during project construction include a construction staging site and upland tracts excavated to acquire core material for dam construction. An estimated 14 ha of land will be used for construction staging.

The areas, affected by borrowing activities will be dependent on the amount of core materials available at the various sites; a total of about 45 ha of upland terrain has been designated as primary and reserve source areas for borrow materials. There will be, less land available for hunting and hiking.

A.5.4.2 Water A 128-ha lake will be created in an area now forested. About 2.3 km of Pond Hill Creek will be destroyed and inundated. The lower 1.3-km stretch of Pond Hill Creek will be converted from a quality in the free-flowing stream to a regulated one with a minimum flow of 5.7 L/s. Water lower reaches will be degraded during construction (erosion) and operation of the reservoir.

A.5.4.3 Air Once the reservoir has been completed, there will be a very minor increase in the frequency of Air quality in the construction areas will be decreased during the steam fog in the area.

construction period due to fugitive dust and emissions from construction equipment.

A.5.4.4 Terrestrial Ecolo Construction total utilization of all designated borrow areas, about 195 ha of vegetation and, Assuming therefore, wildlife habitat will be destroyed or disturbed during land-clearing and construction activities. More than 805 of the vegetation to 25K be affected consists of forest comounities.

Site reclamation will entail landscaping about of the denuded area, partially mitigating losses of vegetation and wildlife habitat. Some individuals of the less mobile wildlife species construction; other species will vacate the disturbed areas. The will be destroyed during c'ompetition for habitat resources in adjacent areas; displaced animals will cause increased and of short duration since habitat however, the consequences will probably be minor in nature area.

conditions similar to those onsite occur extensively in the surrounding

A.5-6

~0eratteaal The principal impacts resulting from project operation will occur with the initial filling of the reservoir. Residual vegetation will be inundated. Some additional wildlife will perish by drowning or be displaced from the impoundment site. The end effect of reservoir filling will be the conversion of about 128 ha of terrestrial habitat into an aquatic environment.

About 2.3 km of aquatic habitat along Pond Hill Creek, a healthy, will be converted from that of a free-flowing small stream to that unpolluted, natural stream, of a stagnant reservoir. The reservoir will support a much larger fish population than the area presently will be some loss of fish and other aquatic life in the Susquehanna River due supports. There to impingement and entrainment during periods when water is pumped into the reservoir; these losses are expected to be minimal.

Reference

1. Tippetts-Abbett-HcCarthy-Stratton/Engineers and Architests, "Design Report: Pond Hill Reservoir," prepared for Pennsylvania Power 8 Light Company, February 1979.

APPENDIX 1 Letter from U.S. Fish and Wildlife Service re federally proposed endangered and threatened species fn Pennsylvania A,App. 1-1

A.App.l-2 UNITED STATES h I DEPARTMENT OF THE INTERIOR FISH AND WILDLIFESERYIGE

~ tt Nile tsltti TO:

One Ge:may ~+i. Stt te T00 NEWTON COANFA, MASSACHUSETTS lQ$ 5S Qilliaa E. Eagan, Jr, Chief ll.S. Nuclear Regulatory Commission Environmental Projects Branch 2 Division of Sita Safety and Environmental Analysis Washington, D.C 20555 Dear Mr. Regan'.

This responds to your May 23, 1979, request for information on the presence of Federally listed. or proposed endangered or threatened species vfthin the impact area of the proposed 230 acr~ reservoir to be operated in conjunction with the Susquehanna Stean Electric Station near Bervick, Pennsylvania.

Except for occasional transient individuals, no Federally listed or proposed species under our jurisdiction are known to exist in the project impact area. Therefore, no Biological hssessment or further Section 7 consultation is required Mith tbe Fish and Wildlife Service (FWS) ~ Should project plans change, or if additional information on listed or proposed species becomes avaQable, this determination may be reconsidered.

Thw response relates only to endangered species under our jurisdiction.

It does not address any other 85 concern or concerns of the National ttaraa itshartes harriet Ohtrt). is tha shorteose storieoo ~tet asser brevirostrum) is under NMFS jurisdiction and may inhabit the project impact area, contact should be made with Mr. Robert Lippson, National Marina Fisheries Service, Oxford Laboratory, Railroad hvenue, Oxford, Maryland 21654~ Telephone No. (301) 226-5771.

Lists of Federally listed and proposed endangered and threatened species in Pennsylvania are enclosed for your information. Thank you for your interest in endangered species. Please contact us if ve can be of further assistance.

R~

Sincerely yours, Reiiooal Director Enclosure

A.App. 1-3

. ALLY PROFOSiXI BCANCEPD)

LoQ ~MTBfED SPECIES Zt PKÃNSZLVAHIA Proposed Co. son htame Scientitic liame Status Distribution Pishese llone Beet'es.:

lions Bfrdse hone Y~cnals:

llone l.e--catt'l llano ol- a~s sea cz 4ccd) Zlodcs schvcinitzii N orth ampton Schl)cknei = 's (Bethlehem Area)

County "ullrvsh ~3ci us ancfstrochcctv! E Lscksl)sm~) Jehigh)

(B'nnamed) Cliaton, Blair Counties Pv.vnfa) small lsotrf a mcdcoloidcs Creen) Cent) c)

Maori& Moaroe, MootScsse?y)

Philadelphia) Berts Chester Cou!Sties

"~: sc-ear SeeatttIs- esveeee ess. B Chester, lancaster

-"h:-hB CW, (".nnsced) 51115515 ~ Islet Couaties

~::'se Darer)

.:".<ding rollius nexus Centre, ~e) Bucks Imvrenc e ) Mon?Oc )

lforthamptoa) Xeh5gh Counties Pe@ion 5 T/li/79

A.App.1-4 EtVDANGERED AND THREATENED SPEClES IN PE:PISZLYAVIA CJcsson Nese Scientific Nane Status Distribution FISHES:

Cisco ion+au ~C ~L Lake Erie - probably extincc Pike, blue Sticostedion vitreun Deep uqter of Lake Erie

$1 t probably extinct SturgconF sbortoosee ~dt Lt 1 t HH Delauare River and other Atlantic cbascal river HH. T L"H:

iionv

~tt~tt giRDS Eagle, bald Hll t 1 Ent ire state Falcon, Anerican F 1

• t Entire state-re-establishncnt co

~tt peregrine lerner breeding range in progress Falcon, Arctic F 1 dl Entire state nigracory-peregr'ne no nesting t'A.du~tdLLS t gac, Indiana Yvotis sodalis E Entire state Cougari eastern Falls concolor ~cou ar E Enrire scace - probably excinct HOLI.VHTH:

Ho t PLANTS:

None

• Principal responsibility for this species is vested vich che Nacienal Narine Fisheries Service.

APPENDIX 2 ARCHEOLOGICAL SURVEY PLAN FOR THE POND MILL RESERVOIR SITE Prepared for PENNSYLVANIA POMER 5 LIGHT by Curtis E. Lar sen, Archeolog)st, Commonwealth Associates, Inc.

Jackson, Hlchhgan 31 October 1979 A.App.2-1

A.App.2-2 INTRODUCTION The Pond Hill Reservoir Site is a project allied to the construction of the Susquehanna Steam Electric Station near Berwick, Pennsylvania. The purpose reservoir is to compensate for wa"er which will beofwith-the drawn from the Susquehanna for the power'lant'. BecauseRiver by the cooling process of differential cooling rates, approximately two-thirds of the vater will lost by evap-oration. PP&L is required to aug ent water belost by the Susquehanna River, especially during low flow periods.

The proposed reservoir will meet these requirements by storing river water i'n the reservoir which can be released to the river during periods of low flow.

The reservoir will be located on a small tribu-tary stream on the east bank of the Susquehanna, This stream is locally referred to as Catfish Creek, but is unnamed on the Nanticoke 7.5 minute USGS quadrangle. The site is approximately seven miles'northeast of the Borough of Berwick and one mile south of the village of Mocanaqua. The valley of Catfish Creek is oriented east-west. The reservoir will be created by constructing a dam across the mouth of the valley about one mile 'upstream from the confluence of Catfish Creek with the Susquehanna. The valley is undeveloped and in places is heavily wooded. The entire area to be included within, the reservoir.is approxi-mately 150 acres, however the ent re area to be affected by the PP&L project is 1300 acres. nis total includes both of the valley sides and the uplan" surfaces of the adjacent ridges. In addition to the reservoir, some of these. ad-jacent areas will provide borrow =aterial for various con-struction activities others will be used as staging areas for heavy equipment. Because much of the entire 1300 acres will be disturbed in some way, it will be necessary to take an inventory o'f any historic or archeological resources which may be impacted by the proposed construction. Such assessments are to be made pursuant to 36CFR800, Section 106 of the National HiStoric'Preservation Act of 1966 as amended (16USC470), hy Executive. Order 11>93, May 13, 1971 "Protec-tion and Enhancement of the Cultural Environment," and by the President's Memorandum on Environmental Quality and hater Resources Management, July 12,'978. This legisla-tion outlines Federal Agency responsibilities with regard to"National Register elibible properties and"provides for the protection and enhancement of such properties.

A.App.2-3 To meet these. directives, it is necessary to inventory the cultural resources of the project area prior to construction'. activities'. This will require an adequate literature search to determine, past historic uses of the area as well as to ascertain the presence of .previously recorded archeological sites within the project boundaries.

In addition, an on ground survey must be conducted to insure that archeological resources are not endangered by the proposed project. To satisfy these requirements, a.plan for survey'nd literature search must be devised which satisfies the licensing requirements of the Nuclear Regulatory Commission with the participation of the State Historic Preservation Officer acting through the Pennsylvania Archeological Commission. The following plan is submitted to assist PP&L with these requirements.

Cultural Resource Inventor Plan The cultural resource inventory of the Pond Hill Reservoir Site will consist of two concurrent investigations.

The first of these will involve a literatuxe and archival search to determine whether previous historic or pxehi:storic have been recorded for the project area. This will in- 'ites volve a canvass of the records of the State Historic Preser-vation Officer as well as a visit to the Luzerne County Courthouse in Wilkes-Barre. Should this research identify any previously recorded sites, each of these will be re-located in the field for future testing, if necessary.

addition to records'earches or published references, our In staff will investigate the oral nistories of the project area through interviews in the communities of Pond Hill, Mocanaqua, and Mapwallopen.

On the ground archeological survey will consist of a thorough canvass of the project area. At the present time, at least seventy-five percent of the valley of Catfish Creek i.s wooded. Areas of exposed soils are only present along cleared roads installed during test boring operations.

Only a fe~~ cultivated fields exist within the axea. These are located on upland surfaces near the village of Pond Hill.

These too are overgrown. Because of di.fficulties in suxface it visibility, will be necessary absence area to verify the presence or to 'shovel test the entire of archeological evidence. Our survey program will combine the necessary shovel testing with surface examination where, possible, along a series of walked transects across the project area.

The site will be canvassed by walking compass-oriented transects at 30 m intervals across the site. At 30 m intervals, along the transect,* a shovel test pit will

A.App.2-4 II be excavated to examine the soil beneath the surface debris or vegetation. Each pit will be no larger than 25 cm x 25 cm nor deeper than 25 cm. The soils removed from each pit will be carefully disaggregated and examined for artifacts.

Should any indication of an archeological site be encountered, the area will be flagged with survey tape and labeled in a system which will allow a site to be identified only 'oding by persons with direct responsibilities for archeological resources. This will prevent unauthorized persors from damaging sites. Any sites discovered will'hen be located on existing base maps. These will supply the client with the necessary site information to plan for the protection or mitigation of cultural resources that may be threatened by the project construction.

The potential incidence of rock-shelters is a major concern for archeological investigation along the Susquehanna River. More specifically, these are overhanging rock ledges which may have offered shelter to past human groups. At the Pond Hill Site, the northern valley slopes display the bedrock configuration for rock-shelter formation. Because of this potential for rock-shelters, the northern valley slopes must be given special attention. The best method for approaching this problem is to locate the outcrop patterns of the pertinent resistant sandstone beds along the valley sides. Then, linear traverses will be made along the base of any such outcrops. Should characteristic over-hanging ledges be found, shovel test pits will be excavated below them to check for archeological evidence. Once again, if evidence on base maps.

is found, each site wi'.1 be flagged and located Anal sis and Re ort h

Following field survey and literature search, any archeological collections will be analyzed and described.

The results of our survey will then be presented in a written report setting forth our research strategy, metho-dology and the'esults of our fieldwork. Should archeological sites be encountered during this survey, recommendations will be made regarding the testing of these s'ites to ascertain their eligibility for inclusion on the National Register of Historic Places. These recommendations will consist of a Phase II testing program with man-hour estimates for investigating the pertinent sites by hand excavation.

A draft report for the on-ground survey work presented here, will be submitted to PP&L in the spring of 1980. Following client comments, if any,, Commonwealth will prepare a final report in the required number of copies for agency review and PP&L record purposes.

APPENDIX B. COMMENTS ON THE DRAFT ENVRIONMENTAL STATEMENTS (June 1979 and March 1980)*

5>> ~:

• Comments on Supplement No. 2 to the Draft Environmental Statement published in March 1981 are contained in Section 6.1.6 of this Final Environmental Statement.

8-2 COMHENTS ON THE DRAFT ENVIRONHENTAL STATEHENT

~Pa e Department of Agriculture, Forest Service; August 14, 1979 . . B-4 Department of Agriculture, Soil Conservation Service; August 20, 1979 B-4 Department of Comerce; Hay 13, 1980 . . . . . . . . . . . . . B-5 Department of Mealth, Education, and Welfare; Hay 20, 1980 . . . . . . ~ . . . . . . . . B-6 Department of Mousing and Urban Development; July 31, 1979 . . . . . . . ~ . . . . . . . . B-6 Department of the Interior, received September 10, 1979 . . . ~ . . . . . . . . B-7 Department of the Interior; received Hay 29, 1980 . . . . . . . . . . . ~ . . . . . . . . B-9 Department of Transportation; August 9, 1979 B-10 Department of Transportation; April 28, 1980 . . . . . B-11 T. R. Duck; August 29, 1979 . B-11 Economic Development Council of Northeastern Pennsylvania; August 27, 1979 . . ~ . . . . . B-13 Economic Development Council of Northeastern Pennsylvania; September 26, 1979 8-14 Environmental Protection Agency; received August 17, 1979 . . . , . . . . . . . , , . . . B-17 Environmental Protection Agency; received Hay 30, 1980 B-23 Federal Energy Regulatory Comission; received June 10, 1980 8-25 T.J. Malligan; August 18, 1979 . . . . . . . . . . B-26 H.L. Mershey; August ll, 1979 B-27 H.J ~ Muntington; August 19, 1979 B-27 M.C. Jeppsen; August 8, 1979 . . . . . . . . . . . B-31 S. Laughland B-32 W.A. Lochstet; August 19, 1979 . B-32 Luzerne County Planning Coneission; August 10, 1979 8-38 H.H. Holesevich; October 25, 1979 B-39 L. Hoses; August 14, 1979 ~ ~ ~ ~ e ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ 41 D. Ober st; July 28, 1979 . . . . . . . . . . . . . . . ~ ~ ~ ~ ~ ~ 0 ~ ~ ~

j B-41 Pennsylvania Power 8 Light Company; September 4, 1979 ,

2-42 4

Pennsylvania Power 8 Light Company; September 10, 1979 , . IB-46

8-3 Pacae Pennsylvania Power 8 Light Company; Hay 29, 1980 . . . . . . . . . . . . . . .,. . . . . . 8-47 Pennsylvania Power & Light Company; January 7, 1980 . . . . , . . . , . . . . , , . . . . 8-50 Pennsylvania State Clearinghouse, Department of Environmental Resources:

August 20 '979 ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ 8-50 Pennsylvania State Clearinghouse, Department of Environmental Resources; Hay 20, 1980...... 8-54 M.L. Prelesnik; August 30, 1979 8-55 SEDA-Council of Governments; September 26, 1979 8-56 F.L. Shelly; August 18, 1979 8-57

,S. Shortz; August 20, 1979 . . . . . . . . . . . . . . , . . . . . . . . . . . . . , . . . 8-60 Sierra Club, Pennsylvania Chapter; August 15, 1979......... 8-61 Susquehanna Alliance; August 17, 1979 8-62 Susquehanna Alliance; June 10, 1980 ~ ~ 8-64 Susquehanna River Basin Coomission; August 30, 1979 ~ ~ ~ ~ ~ ~ ~ ~ ~ 8 68 Susquehanna River Basin Commission; April 30, 1980 . ~ ~ ~ ~ ~ ~ 8 69 F. Thompson; August 20, 1979 . ~ ~ ~ ~ 0 0 ~ ~ 8-74 L.E. Matson ~ s ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ B 75

Lbllvsn SvATss OsrAnv%lsnv or A<<uoa.vues UNITED STATES DEPARTMENT OF AGRICULTURE vonasv sanvla SO(L CONSERVA77CN SERVICE (21) 598 1872 Box 985 Pedezal Square Ststfon, Esrrmburg, Pounsylv~ 17108 Aufust 20, 1979 1950 Will(ns August 14, 1979 0 8 Suoleap Wsstnttoni D. C.

Sul tory 20555

~stoa r Hr. Attenttoiv Director

}I Regan; Envlronoental Pro)acts Smnch 2 Olvlslon of Situ Safety and Jr I Q Division of Site Safety snd Dlvtroaontsl Analys fs Elivlronsental Analysis U.S. Huc lear Regulatoly OrnaIas ton L Washington, 0 C 20555 Refer tol Docket Ho..50-587, 50-588 Draft Envlrctu>>ntsl Statenent Operation of Suslplehsnna Stean Electric Stat(on, PA This is to consent on the Draft EZS for the Sustuehsona Stean Electric Station, Cnits 1 snd 2, Peoasylvsats. The docuoont has been revteved Oeor Hr. Reganl

~

Our Hl lvaukee Office has forverded this Stateaent to us rav lee and The proposed use of 2,4,5-T as National Forest lands ara not Involvedi as a aced of-vay ls Illegal fol loving the <<osrgency order for ccntrol agent ln rlghts-by SPA suspen4-for fteas vithtu the erpertfse of the Soil Conservation Service ~ We feel that tvo tress should be added co the ststonent.

l. Sedtuont sud erosioa control for the lsn4 disturbed at rhe plane site end trsnsatsston ltna location should be discussed tn retsr4 to the rerulscious tuplaentfns Section 102 of the Peonsytv<<L'A Clean Strauss Act sn4 the Pennsylvsata Deparaont of Enviroaentsl Ing use of 2,4,5-T on forests rlghtsmf-vay) and pastures Resources r<<(ofroaents.

(Federal Register Vol 44, page 15874, Hatch 15v 19791 ~ We belleve a 4tscusslon of alternative seed-control aethods should 2. The pro)ect's tnpscts on prise agricultural lauds end fsrnlsods of be Included In the Final Stets>>eat Fotutllatlons of <<wonlu>> sratevtde tnporraute should be 4tspleye4 su! fnsata, dlcnnba or brcnac(l coul4 be considered.

111 other its=a of concern to the Soil Conservsttou Servtce have been Discuss(on at the coal and aran(lss fuel cycles should Include ade(uataly adds essed.

the Indirect effect of alnlng on the landscape This etfect 71>>nk you Statenent and ~

ls beccwlng nore severe as the nore productive alter are ac hausted slv( acre dlgglng ls needed for every tcn of fuel.

for the opportunity to ravlev on this

?.

Cr shat T. Hndotttriok State Cocsamsttontst co' N~

H DO&M Adsttnis trsto r SCS Wsshtutton DC Cletus J. Cttfssn, Director, ÃTSC, SCS, Brooasll, PA Director Office of Podersl Acttv ties 0 S ~ EPJ Boon 537 West Tover, Qatarsfde 1&1, 401 W Street Sg, Vsshtuttou, DC 20480 (5 copies)

Staff Olrechor Env l rota>>nta I Cue I 1ty Evs lust Ion QiPq)

IO 7 9082 l Chq(hq 79082T0gIO v~

~l ONO

8oo5 "0 0 l/p ee 7

UNiTED STATES DEPARTQEVT OF COMMERCE kP The Assistsnt Secretsrv ler Prodvctivitv, Techneloey, end Innovation wernnpot O C aotSO UnilTED STATES DEPARTMENT OF COIVIMEACE tuetionel Ocesnic end Atmospheric Administretion

~srr+vllt e335 4

ns c'e4. cash s'nrsr nota~ee. Yc, a Nay 13 ~ f900 ARR a;-3 OR/C52x6l JLR

~r/PP/~C a 0 APR IBBO TOl PP/EC - Joyce N. Mood Hr. Donald E. Sells Actfng Branch Chf e f, FRONl OA/C5 - Robert B. Roll ins Envfronnental Piojects Branch 2 Q.S. Nuclear Regulatory Connfssfon

SUBJECT:

OEIS 98004.01 - Susquehanna Stean Electr1c Stat1on Washington, D C 20555 Units I and 2 (Supplenent)

Dear Hr. Sells The subject statenent has been rev1ewed with1n the areas of the This fs ln reference to your draft envfro~ntal fnpact National Ocean Survey's (NOS) responsibility and expertise. and in statenent entitled, Susquehanna Stean Electric Station, telos of the inpact of the proposed action on NOS activ1t1es and Units 1 and 2, Pennsylvania Power and Lfght Conpany, projects; Allegheny Electrfc Cooperative, Inc.'he enclosed connent fron the Natfonal Oceanic and Atnospherfc Adnfnfstratfon Geodetic control survey nonirents nay be located in the proposed fs forwarded for your consfderatfon. project area. If there is any planned act1vity which will distu* or destroy these romtntnts, NOS requires not less than 90 days'otifica-Thank you for giving us an opportunity to provide thfs tion in advance of such act1vity 1n order to plan. for their relocation.

connent, which we hope will be of'ssfstance to you. tie NOS recocnends that funding for this project includes the cost of any would apprecfate receiving ten copies of the final statenent. relocation required for NOS noixnents.

Sincerely, Q~R.@~@

Bruce R. Barrett Acting Director, Office of Environmental Affairs Enclosure Nano front Robert B. Rollfns National Ocean Survey NCAA

i'iygORAib DPI ~gq CCFAISTSSK'I CF IICVSING AIIQ LlnSAN CCVSLCFLICRT

~ IeLAosmA AeeeertIcs czletls eu LsIee. M SALeut ste set

~

tcatsc IIEALTss sthLzct tOOD MD DECO ADSSDI(SZSLATSO.'C ANLAetLfWA,IS Ieov LV JAIL I SISS W,

e~

eSCION Ceno M etiam Ih fsNII chly 31. Lstg To I Oirector DATE: iiay 20, 1980 talos~ I ~ ISS w aseLV eetta teI Oivis1on of Site Safety and Envirolvsental Analysis U.S. Huclear Regulatory Cosnission Hashington, O.C. 20555 rhoss I Consultant (NFL)

Sureau of Radiological Health graft Supplenent to Oraft Enviroleental Statenent, NVREG-0564, Harch 1980 SSz. Peal Leech The Oraft Supplcsent to the Draft Envirolvsental Statenent, Eavtzcszsenchl pzo]ecc Heheeez Harch 1980 has been revtesed by the Bureau of Radiological HUREG-0564, Ehtizonoenchl pzoject Szanch. 3 and Orug Adsinistration. 'Ne prev1ously clznsented Health, Food Division of 51.ze Safety end

~ ttached) on the radiolog1cal health and on Harch 9, 1973 (copy Envizoonenzal anal~

safety aspects of the Oraft C.S..SSucleez Seuolaenzy Cosssission Envirolvsental lnpact statenent (ofls) related to the operations-Susquehaew Stean Electric Stat1on, Units l and 2. This draft uhs~r D.C 3OSSS

~

to the OEIS is lin1ted to a description of the envirorv-ental supplenent construct1on and operat1on of ~ water storage reservoir ln theispacts of Deer Hz. Leechs Creek drainage basin. Xe have no appl1cable cocssents. Pond H1ll -~

Svst)aces Dzsfc Ehvizonsenzal Especc szatAsenc Thank you for the opportunity of rev~iing this draft statenent. shsguehasha 5zecs station ~ chits 1 and 3 M have cseyleted ooz evaluation cd! the sohiecc Drest Envizosssencal I-II +LL-X ~ lhpecc staceoent, dated Jose lstg, and have no substantive coessencs tS3 I

CSI Charles L. Heaver to offez zelecive to mL suhlecc pzoposeL.

Enclosure CC:

Or. K. Taylor (HFY-2) ef eco eny psoseca rpohsssod by this y

~c hast of cuz hooiedeo, the pzopoeed pzoiece does not. dizeccly Jsees E. TzeedvelL Cf~

-2 United States Department of'the Interior HC ~ torte Preservation Officer (SHPO) fos Pannsylvanta, Edvard OFFICE OP THE SECRETARY Wefatraub, Executive Director, Historical Nuseua Couatsston, WASHL>GTON> D.O. 20240 P.O. Rox 1026, Nasrisburg, PA 17120> Result of the survey should ba facluded Ca che final docuaent. Also in coasultacion vich the SHPO the NRC should dctexaiae if any of those properties identified Ca tha survey axc eligible fos ltstiag Ca sha National RegCscer.

79/632 Spp L 0 STS If 36theyCFRaxe600>4 of deteraiaed to bc and 5 ause

~ ICgCble, the procedures followed to coapletfon.

and proces ~

be

~ 3~- >

Nr. Mtllfaa H. Regan, Jr.

Chief, EavCxoaaeatal Projects Sulfuric acLd vill be used to conerol seal ~ fosastioa. As noted Sraach 2 Ca thc stataaenc the systea vCII be operate4 at a posi.tive satura-DivCsion of SCta Safety and tioa Cadex to ainiaCsc ths addCeion of acid. Without this contxol Eaviroaaeatal Analysis on acid usage, ehe dLscharge. could carry over four tines che Nuclear Regul ~ cory Conafsston sulfate concentration of the xaceCviag vacers. This could NashCagton, D.C. 20555 aggravate .an already stresse4 ~ Ctuatioa since thc Susquehanna

~ xhibtts high aad variable sulfate conceatratioas Dear Nr..Regaal Ia tha sane aana<<r that altarnacLve levels of acid additioa have The draft cnvironaeatal ~ tateaent for Susquchaaaa Stean Electric bcsa 4iscussed, ve suggest that alternate aecbo4 ~ of scale and Station (SEES) Suits I aad 2 has been ravtcved by this Departaaae ead we hare ehc folloviag coaaeats corrosion coatrol should ba looked at. The fiaal ~ cateaaat should preseae an envCroaaental evaluatioa of such aethods as Thc coaaeats ase orgaaixed by page ndaber fn tha docuaene. organte or hydrochloric acids or aacbanical aeans Pa ~ 2 28 and Ps e 4 33 ~ ~>->

CXI s

Ve ara concerned that the draft stateaent does not adequately h Since the intake scruceurcs for this pleat have baca constructed, address archeological and historic coacerns There appease to be the final scateaeat should discuss vhat saaplCag yrograa Cs a need for further Cavescigatioa of ~ igaCffcaaC properties Ca chc proposed ead vhea Ct vou14 bs Laplsaentsd co deteraiae levels of area aa4 i4entC{icatioa of their relationship to the yroject. ~ acrainaent aad Capfngeaeat, during all expecta4 flov condCtCons, This applies co propcrcCcs already on the NaCLoaal Register aad of Susquehaaoa RCver fish and aquacic invertebrates. Further, the any potentCal yroperties in the area but not yat evaluated final stateaeat should include a discussion of the possible actions the ltcen ~ ees vCII cake to aodCfy tha project to procccc such Oa page 4-33, tha drafc states thee "given th>> present inadequacies aquattc resources in cha eveac sCgaificaat adrersc iapacts occur regardtag cultural resource Cavcntory and date> che staff csnnoC froa eneraiaaenc, iapingeaeae, or strcaaflov diversioa for asks ~ detaraiaacion to the effect thee tha plant' operation coosuaptire use (50 cfs avercga) wCII have no adrersa effects oa cultural resources that aay ba

~ ICgCble for Caclusion in the NacLonal Register. Hovevcx, Ct is >-> 2~

ualikely that tha plant's operatioa vill effete resources chat

~ ra correctly listed Ca the Nstioaal Rcgi ~ ter (located Ln excess The staff coaoludes that ao advexse envCroaacatal iapacts> other of 16 ka froa the plant property) . . " Thc draft is unclear thea ataosyherfc planes aa4 snovfall, vCII occur as a result of regardfng thc Capact tha plant aad traasai ~ ~ ion corridors vCII the operatCon of the <<ooliag towers at the SEES The Ifcensaasp have oa yroperties close to the project site Of partCcular concern propose to construct a resesvoCr (Poad Rill) Co provfde aalcup asa McClintock Hell, thc Deaison House, and Caclfn Hall> water during lov flov conditions Ca tbe Susquehanaa River The final ~ tsCeaent should be rcrised eo indicsC ~ soae adverse eavfron Ve urge tha NRC to undertake a coapletc archeological aad historic survey of the eras La accordcacc vftb cbe requLrcaeats of aeatal Cayact vill occur vit'h the operation of the cooling covers 36 CFR 600 and Executive Order 11593. Nenes of persons qualified to undertake this survey aay be obtained by contacting the State

-3 villrelated raservoCr, Construction of the dan and reservoir and d<<scroy terrestrial vkldlkfe habitat and reservoir filling activated dose to population kn ~ 50mfle radius iron any ac<<ident shovn in the table is 37 nan-r<<n. UntLI such tine as the table opera<<fons vill Cnpact Su<<bin<<hanna River aquatCc invert<<brac<< can bs revised, it nkghc be helpful to nota thee the <<<<tins<<ed dose and fish populations through inpingcnent, entraknnsntb'treanflow regulation, to the population vithkn a 50-nile radius of tha Three Mile Island and <<onsunptkve use of su<<h flovs sit>> vas calculated to be 3,300 nan-ren (NVREC-05SS) ~ p 2 ~ par. 2).

The populations vkthkn that radius are not greatly differ<<nt for

~bb-6 ths tvo sites, being 2,164 F 000 people kn tha case of the Three We 'agree vith the staff that the applicant should nonitor groundvatsr MLI<< Island <<Cte a<<4 projected to be I F 51'23 people vithkn 50 both upgradienc and dovngradkent on a nonthly basks. We note nCles of Su<<6Cuehanna Stean ElecCric Station kn th<< year 1980 thdc ths potencfal-Cor radL<<nuclide contaninatLon of groundvater (ER, table 2 I b)e is knplied on page D-I of Appendfz D (iten 1.6); hovever, fLgure

~

~h ~ 6 6 4 I (p 4 13) does not indicate groun4vater as an sup<<sure pathvay to hunans. Table g ~ 2 (page R-4) shove chat 1,236 acres of forest and farnland

~ 6-4 vill be regukred as rights-of~ay for construction of a nsv

~b tran<<uk<<sion line cyst<<a. The forest<<d area could be nanag<<4 Th>> <<onclui ion chat "the environnental risks 4<<e to radiological ~ ffectivsly for vkldlkfs if preferred vsgetatfon and <<over for gracing vC141CC ~ species vere planced Their feeding activities accidents arc ezceedkngly <<nell and need not be considered further" vou14 help control revegetation of nuisance voody vegetation and ignores the probabClity and tha consebluen<<es of <<<<remelt accidents reduce the need for clearing and herbicide applications, We (p. 6-4, par. I). As vas-szplafned kn tha environs<<ntal ~ tac<<n<<nt re<<ounsnd that Appsndiz R dfscuss the possibility of using for che Palo Verd ~ Nuclear Scatfon (NUREC-0522, 1979) ~ this plantings reconnended by tha Pennsylvania Cius ConnLs ~ Con for all "realistic<<analysis" is based on procedures Cn ths Proposed-Annez forested areas clear<<4 during cransnksskon line construction.

to Appendkz D, 10 CPR Part 50, vhich specifically <<zcludc the

<<valuation of core~alt accidents. Environnsntal dan<<gas We hope these connects vill assist ths preparation of ths final resulting fron a <<ore~alt accident can bs devastatCngly severe and <<onclu<<Cons concerning envkronnental risks that ignore these a<<<<ident<< aust be 6Cuestfon<<4. Wa beliav<< that site-specific neer ~

evaluations of the full range of potential ac<<ident<< should be a 6 part of the site selection process for nuclear pover stations ~ E~ Mcicrotto Ths section on Postulated Accfd<<nts Involving Radioactive Materials As<<I<<cunt SECRETART

~ nunerates ger<<tel of tha no'ra significs'nt fkn4kngs of the I<<vis Report (p. 6-3). The three fkndCngs sunnariscd szclude the final fin4kng of that report:

There have been instances Ln which WASH-IAOO has bess uk<<used as a vehicle to judge the acceptability of rea<<tor risks. In other eases it nay have been used prenaturaly as an estknace of ths absolute risk of r<<actor accidents vkthout full reali-sation of the vide ban4 of uncertainties involved. Such usa should be discouraged. (NDREC/CR 0400, p z)

A footnote to table 6 2 states that "These cal<<<<la<<fons do not tahe into <<on<<L4<<ratfon chc szperkcnce gainid fron the accident ac the Three Mile Island <<Ctc on March 28, 1979" (p. 6-3, fobtnote A) Row<<ver, this provides no guLdance on the possible nagnCtude or even the direction of che errors that nay eris<< in the ra4kologkcal cons<<6luances that ere shovn in the table. The largest

United States Department of the Interior I

g+'~ OFFICE OF THE SECRETARY to ba stored a>> Lndicaced, as vali as che daa's height are sigaificant and, failure could lead to loss of life {p. 4-11, WASHLWGTON~ D.C. 20240 yar. 8) ~ The spillvay desiga flood should be reevaluated ER 80/ 284 gAY 2 8 1%0 Itea 3(1) seates on page fi of the Suaaary and Conclusions seccion thee cares!a leads vill be converted co recreational uses. No dfscussfoa Ls givea, hovever, to thc possfble Nr. Donald ED Sells ~ avirooaeatal effects of chic proposed actLon. Also, there Acciag granch Chief Ls ao aeatfon of a need to survey this land to i)entify and Environocacal Pro3aets Stanch 2 evaluate culcural resources thee aay be fapaccad. At ehe Divfsion of Site Safecy aad request of the NRC, the Znceragcney Archcologieal Service EavLroaaeatal Analysis Atlanta OC(iec prepared a sarvey plan aad cost ostinato for a UPS. Nuclear Regulatoty Coaaission proposed r<<creacioaal arcs along the Susquehanna River. This Washington, D ~ C ~ 205SS vas provided to NRC on Deceuber 19, 1929. Th>> NRC should reference che requfrcoeac to survey the proyosed recreational

Dear Nr ~ Sells:

areas as vali as the proposed Pon4 Hill Reservoir Site.

The Departacnt of the Zatcrior has revicvad che draft The discus ~ Loa of Zayaccs to Culcural Resources (p. 4-14),

~ upplea<<nc co the envitonacntal Lapaet stateacnt related should tecooacad an appropriate aanageaeat prograa to be co the operation of che Susquahaoaa Steaa EleccrLe Scacion, developed only for chose sites that acct National Register Uaits I aad 2 ~ Luterae Couary, Pcansylvaaia. We have the of HL ~ corfc Places criteria. ZdeutiEfcation and evaluacioo follovfag coaaents. studies aad aanageacat yrograas ause ba developed Ln accordance vfth 36 CFR 800, Lacluding consultatioa vith tha State Historic Wa find chat cha supplcaeat adequately describes existing Presarvacioa Officer (SHPO). For pcansylvania, the SHPO fs fish and vildlffa resources an4 Lapaets on those resources Edvard Weiatraub, Exeeucive Director, Hiscorical Nuseua Coa-

.!toe construction of the proposed iapoundacnc ~ Provided aission, F.O. Sox 1026, Harrisburg, peaasylvania 12120 thee the Penasylvanfa Povar aad Light Coapany Lapleaents thc aanagcacat pleas to ba subaittcd by the applicant La Archeological Survey Plan for the Pond Hill Reservoir

'he eonsultatfoa vLth thc Peansylvaaia Ffsh and Canc Coaaissions SLte (Appendix 8) does aot clearly fadicate vhechcr thc (page 4 3 o! the draft suppleoent) ~ ve have ao objection acreage to be surveyed under the Coaaoavealth Assocfate, to eoastruetioa of the proIeet as proposed. Zne. proposal Ls che approxiaacely 150 acres vfchia che reservoir, or vould cover the apptoxiaately 1300 acres of We rccoaacad chat the Collovfag be stipulaccd La aay operacing ehe entire pro3ecc area. All areas to ba affected, Laelu4ing I!cease issued by the Nuclear Regulatory Coaaissfon for this traasafssioa liae corridors, borrov areas, aod rccreacfoa pro)cot. facilities, should be surveyed to insure that all cultural resources thee aay be affceeed by cha undertaking are "That cha Licensee iapleaeats thc fish aad vfldlffc LdentLCLed aaaageaeat plan co be developed ia eoasultation vith the Pennsylvania Pish Coaafssfon> che Pennsylvania Coaaoavealth Associates proposes that ttansects space4 ar.

Caae Coaafssion) and the U.S. FLsh and Wildlife Service." 30 aeter intervals vill ba valked, but does not Iuscify vhy ~ 30 aeter fotarval vas chosen. This osy bc sufffeieac The proposed spillvay capacity vas fouad by the NRC staff for uplands and slopes but not sufficicnr. Ln other areas co ba Insufficient to yass a probable aaxiaua floods The such as terraces. There is ao iadication of vhac tha daa vould be overtopyed Ln such a flood and aighc fail iaterval for shovel casting vill be along the traaseets.

(p. 4-11 'ten 4 4.2 3) ~ The applicant's syillvay flood, based on the 6 hour6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> probabla aaxiaua praeiyitatfon, design Also, resting co a 4epth of 25 cant!actors aay be Inadequate

~ ppareacly vas ealculaced vithout coasideratfoa of tha

~ ffeecs of potcorial antecedent scorn runoff. Alchough the drainage area above the daa Ls soall, tha aoount of voter

depeudiug oa the depth of the plow Roue or fili'e That shovel tests be tateu to a depth approxiaately 20 suggest l uS. OCIARTMCNT Os TRANCRORTAUON RMCNAL RCPRCCCNTATIYI OS TWI oa rwert wuo CCCCITARV eeutiaeters below the plow Roue or fill, aud to search below e IINAOllMA,P$ 04tLYAMA August 9 ~ 1929 HANOI cultural deposits. ~ <$ 4~

will be Qe hope these connects of assistance Sincerely, ~

to you.

CTEHURAWDUX TUC U.S. Nuclear Regulatory Connission Washington, D.C. 20555 Attnl Direcror, Division'of Site Safety and Environnental Analysis

SUBJECT:

Draft Environnentai lnpact Statenent-Susguehanna Stean Electric Station, Units. 1 0 2 We have reviewed the sub)ect draft. Elg and offer the following comments.

pron a transportation point of view, the statenent dtd not discuss the inpacts to existing highways in the area by Traffic traveling to and fron the plant. The transporta-tion of nuclear fuels and the. crossing of highways with power transnission lines has been nentioned. While there should be no signlficanr. lnpscts, the statenent could answer the following questionsl

l. Eave the access points been designated and coordinated with the pennsylvania Departnent of Transportation2

2. Would the travel trips by the 400 enployees affect the level of traffic service on the existing highways2 We appreciate the opportunity to connent on this docunent.

Sally H. Cooper Regional Representative of the Secretary

R.O. i1, Box 4 8005 07 (7><> Xinfie1d. Pa. 17889 August 29 1979 DEPARTMENT OF TRANSPORTATION b REGIONAI. REFRESENTATIVE OF THE SECRETARY Hr. Daniel Huller. Director A%4 WAIIIUTSTIICCT Division of Site Saftcy and FHILAMPHIA,TCHHSYI,YAHIA IIIIS Envirormental Analysis April 28, 1980 Nuclear Regulatory CceEIIssion Mashington, D.C. 20555

Dear Hr. Huller:

Donald E. Sells Thank you for the opportunity to corIsent on the 'Draft Environmental Statement Acting Branch Chief related to Operation of Susquehanna Steam Electric Station, Units and 2 Perm-1 Environmental Pro)ects Branch 2 sylvania Poser and Light Company. Allegheny Electric Cooperative. Inc.'ockets Divison of Site Safety 8 Environmental Analysis Nos, 50-387. and 50-388, June 1979. Since no svspense date was mentioned in the

.U.S. Nuclear Regulatory Commission Nashington, D.C. 20555 document, it can bc assumed that cccmcnts are still being accepted.

Draft Supplement to thc related to the operation Hy cxmmcnts will be very brief dve to thc limited amount of time available to REI DEIS review the document. 'cspitc being published in June, Tmt all of the PIfslic in of the Susquehanna Steam Electric Station, Units 1 8 2 the area affected by the plant were made aware of thc docuucnt. Efforts by local Docket Nos.I 50-387- and 50-388 envirormcntal groups to alert the public, such as myself, were successful. but The draft supplement to the DEIS covering the proposed con- that did not occvr NItil mid Augvst. The apparent efforts of the NRC were the minIImss that is required to do in order to seek Input.! This symbolizes NRC's struction of the Pond Hill Creek storage reservoir for the Sus- attitude in the entire 'public input'rocess- do the minisxsa required 3ust to quehanna Steam Electric Station has adequately addressed the probable impacts to highway facilities. However, the supplement satisfy a section of the Iaw. The public bc damned for the convenience of the still lacks evidence of coordination with the Pennsylvania NRC and utilitics. Hopefully this attitude will not carry over into the operation Department of Transportation. Since the pump station construction and regulation of a nuclear power plant.

will affect Route 239 (pg. 4-12) and an access road will be added Reguarding thc document it itself, is unconscionable that an environmental inpact for the reservoir construction, we repeat our comment of August 9, statement on a nuclear power plant published afteI April 1979, does not include 1979, recommending coordination with PA DOT.

specific analysis of the potential similar problems as occured at the Three Hile Island nuclear facility. Plant design differencps aside, there are smny generic issues such as cmergencySprcpardness that should be factored into the impact of Sally H. Cooper SESS. Emcrgcn<<y prepardness for an 80 km radius area costs a lot of money and Regional Representative time. and such costs should be factored into any cost/bcnifit discussion of SESS.

of the Secretary Thc Impact on the residents of thc TNI area(16km.not Just the Bkm under study) of radiation exposure. stress and its related effects, and other health conse-qucnccs should be carefully evaluated before SESS is permitted to continue in the licensing procedure.

general cosucnts on specific sections of thc docImcnt are as follows. On page 4-2, the possible effects of low river floI and excess river floI (floods) make one concerned about the assIEOtions used to draw the conclusion that the plang

~ovid need to be shut dam only four days per year. An adequate water supply is crucial to reactor saftey, therefore the assumptions should be more fully ex-plained.

SPIIS La%I

~55'S

~ HNS WO

~ SA SO WA.

Hull er, 8/29/79 Hul I er, 8(29/79 Page 2 Page 3 Table 4.12 on page 4-21 indicates that thc nearest sport fishing location ts Section 8.6 'Occaatsstontng's treated lightly consfderlng the tree>>ndous 24 hr. transit ttc>> away. Fishers>>n can be found aC nost points along the river tnpact a non functioning radioactive plant can have on the environs>>nt. Storage fros O.l hr. away on to Che Chesepeak. Perhaps the probfes ls deftnltlonal. for thousands of years wfth unproven technologies deserves a>>re consMcration in an cnvtronncncal tnpact statcncnt. Along with dcconfssfontng, waste storage The stateoents ln Section 4 which state Chat radfoactlve releases, both oc<<vpat- and disposal deserve core detailed analysis as the have a direct tcpach to the tonally and envtronc>>ntally, will have no significant envtronnental tcpact are health of the people tn the area.

- ntsleadtng when one considers: that the effects of low level radtation are unknown. 6roups such as the Nattonal Acadeny of Sciences hesitate to place accept- In conclusion, the need for the plant versus the tnpact of the plant does not able low dose 1iatts on bmoc health effects. = justify that any further work be done at SESS. tthcn need ls docuncntcd, and Che alternatives for northeast Pennsylvania bcCtcr exanined (conservation. solar Table 6.2 should be revised to reflect thc experfenccs gafnel frca THI. Class 9 postvlated accfdents should be considered fn calculating the costs and benff its projects, btonass. ~ll hydro projects. ctc.) then a better and core conplete envtronnentat fcpact staten>>nt should be prepared. At that pofnt fn tine, and of the plant to the people fn thc area. Their chance nay be snaf1 in the NRC's not before. nuclear power should be considered as an alternattve.

opfnlon. but, the consequences are real and the prtce cast be paid ff a class 8 or 9 accfdent occurs. Thank you.

Section 7 'Need for Plant'alls to document the need for the plant other than to provide excess capacity. The reserve rargtn far exceeds recocc>>ndcd levels. Stnccre1g The projections probably fall to consfder recent shifts to conservation and selected solar hot water projects due to the high costs of electrtctty. Such Crends, including residential wfntcrlzation, will contlnve as the costs of Thooas R. Ouck electrfctty increase. Therefore. building a plant Co provfde fncreastng excess capacity escapes logtc. The need for the plant is not documented by cc: Senator Schwetkcr thfs analysfs'. Senator Heinz Section 8.4I 'Health Effects', cocpartng nuclear and coal fired plants failed to Representative Flood Representative Ertcl include. as previously a>>nctoncd, the effects of a class 9 accident. Ne now realize after THI. that scrtous accidents are tn fact a possibility and should be considered.

The tables in Section 8 dealing wfth the effects of coal versus nuclear plants prcsunably used coal in the general sense. The SESS ls located near the heart of the anthracite coal region. Anthracfte. because lt has been excnpted frow >>any EPA air pollution regulatfons.

is a cleaner burning coal, Since thfs is the coal that should be used at SESS. it .ls the coal that should be used ln any cocparat tve studies.

Section 8.4.4 mentions that there have been no serlovs accidents ln a nuclear

.. plant with which to study no*ibtty and c>>rtality. As a>>nttoncd prevtously, THI has taken the first painful step towards this experience. That experfencc should be carefully studied before the nuclear process continues.

Sectfon 8.5 falls to take tnto consideratton a reported recent GAO study indfcat-ing that OOE nay be off by as such as twenty percent fn their cstfcctes because.

of productfon losses and the declining quality of the orc were not consMercd.

Thfs section should be revised ln light of the GAO report;

ci g a

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28, 1979, the ST THE I6 2 COONCZL OF SORBEASTKRN FESSSTLVATIA (EDCSP)

EDCÃP received a copy of tha Draft Envtrouscntal Scatcsaat C.. J (KZS) oa the Susquehanna Scaas Kleet&e Station, Cnits I 6 2 froa thc U.S. Nuclear Ra julatory Cosstssfoa.

( Septuber 26> 1979 Epos receiving thfs EIS, tha EDCSF noctfLO4 tha follovtag agencies that tc had cha 'teporc they could tevfsv che repute Ln tcs offices during regular uurktnj (F) hours; and they ha4 until Augusc 12, 1979, to fotvard CbcLr co~ca on cha

. Donald E. Sells, Aetiag Sraneh Cbtc! report co Che EDCK?

Cl- C Eavtroescstal Pro)cets Eraneh 2 Dfvtsfoa o! Site Safecy and Laekavacna Causey Flaaafsg Coctafsstoa n

Envfronscatal Analysts 2. Sehaylkill County Planataj Cocsatsston be U.S. Nuclear Rcgulatoty Ccalstssioa 3. Noaroe Causey Pleasing Cotcatsstea Vashfnjtoa, D. C. 20555 0 Ao Susquehalsta Ecccloaic DavalOpscnc Auoeiatio'n Council 0! Covercnaats (S~)

Dear Nr. Sellst Tha KDC(F's Deputy Director orally to14 tha Ezaeuttva Dirae'tor of the Lutatua-Ihts latter ts befng scat to you to forsatly notify you chac che Ezecuttvc Lackavanaa Kavtrounaatal Council (Lu Lac) thee the EDCSP ha4 cba report snd Cooaictee 0! the EcoaosLC Dcvelopacnt Council of Northeastern Pennsylvania thee tc cou14 bc ravteve4 tn our office, The Council dtd aoc aocify tha (EDCIP), at tts regularly sehadula4 seating on Sepceabcr 20, 1979, Luaeraa County Pleasing Coaatsstoa since ft. vas tts understanding, base4 upon aff Ltaattvely ravieved che Nuclear Regulatory Cocscisstoa's drafc envir cha cover letter Lt race'vad froa the NRC, that the Lataraa Couaty P4aaiag oosaatal statcnent relactve to the operation o! che Susquehanna Steas Coostutoa tecetved a copy 0! Che repo'rt La che aatL.

.C Electroatc Station, Ontts I aad 2. Attached you vill find several actaehneacs vhfeh outline the Council's A-95 r<<vicv process, tts aa)or acescence oa thfs draft caviroanantaf staceacat, aad ocher related "poa reeetv~ che rcport, cha Counetl's stat! imdtacely began co rcvtev the 0V correspondence clhfeh the Council uctltte4 ta arriving at 'tts conclusion tcporc. 'AL4 chfs rcvtav vas caking place, tha staff also revteved various A-95 reports an4 efreulars to ueertata hov such as should ba ravtcved aad oa this proposal. tu purvtvvs under cha A-95 hocus. The ace!!, also,KISeoacaccc4 che Scace vflf. help  ! Lnsltra Clearinghouse and cha National, Assoefacfoa 0! Ra jioaal Coun~et (NARC) co Th<<Coucetl trusts cha attached aaccrtal oa chfs you aattert If additional e4rtfteatfoa ts dcstr<<d, plcue coatee.

a dectsioa aa ascertain t'ay other a jcaeccs had perforaed sfsflar ravievs: aad a4o. to alert thea of oar proposed acetose. They both to14 as that they believed ac your carlicsc eoutcatcaee. va vere oac o! cha first ra jfoaal ageactas, co che base of their knovled je, E Tours 'tr cs revtcv aa eavtrooscatsl fspacc scaccacac for a unclear Fever pleat under C tha A-95 Sysces an4 beltcva4 ve vera going about tt tn a raspousibla vay.

0 The seat., raaltc'ag chic revtcv vas oa a potesttal coatroverstsl project ~

CP Hovard J. Crossaaa brought cha natter before cha Council' Policy Cooatttae for poLicy guidance.

Ezccnctva Dtreecor M '?oitcy Comttcea told the Daeucfve Director that tha staf! Shou14 haa44 the pro]eet liae any other fsportant FNRs pro)eec jeacraced ts cha tejfon.

sueby j the scaff y ia adlf trios co rcvtcvtn the draf c ZIS also ru4 or back

~

~ ~ Attaehsants ground Qdormcfcn, cha follov.'ag pubLicatfoas ta ad4tcioa to the Drafc KZ51 E CCC RLek Hates, A-95 Scare Clearinghouse 0 Interne Colscty Pleasing Coosfsstoa Zaekaltaana CouaC7 P14nnfng Coustsstoa

(

0 5IDA~

Paul Stcvar, PFLL I

Cl File clvlav t. cow Aaot tlccetw HowAao 1 esocIAIAIctttccvnt ocatetoc tll sotOTIAVOCA.tA 1ICClltn:Oatt CQI

(1) ~ Final Re zc a Scudr o ch E fec L ess of Cenerel Cauaeucs on the Si ~ (Chapter II)

Procedures Sad ~ 'dnfnfs 4 ian c Re ard to ZCD Pro ans, date4 Sarah 1979 by Peat, Bszvfck~ Hftcbsll 4 Co. The EDCSP staff believes 4 considerable anount of data hss been assenbled and 0ravt adequacely analyzed relscive co cha site, the general environs (Luserne County),

(2) 'Effects ot Suclear Povez PIRnts an Cazenmft 1 b1$ .b ~l,m for L

Che U.S

~~,~O.E.I end Resid l~

Nuclear Regulatory 0mmfssfan.

a and the various public facilities aad utilitfas in the area.

4ete4 Saveaber 15, 1978, Eovevery chere 4'za sane recenc reporcs ~ OTenca ~ an4 'nev institutional relationships vhfch nighc be evalu4t44 prior to th4 Units caning on line These Lnclad41 (I) A Reviev and Study ot the Envfzzumental Lwsct aud Socio-Zcaaonic eat Of the Pzaaosed Philsdel hia Electric Cmasnv Lfnezfck (1) Several scare hospitals (Ssntfcoke, Eszletan, Pittscon, etc.) nsy be Ceuerscfu Station 04LCS 1 and 2 by the Wnfversfty City Science ~ icher phased out or nerged under tha RPW proposal. It night be prudent Center for the ~~tgo~ry County Planning Ccomfssfan, dated to fnitiate progrsns sinilar to the ona currently being undertaken v~h 14, 1974. becueen FPAE snd tha berufckgospital vftk other hospitals in cha area (A) Areas Around SueXeer Facilities Should Re Setter Prepared for (foz exsnple, Ceisi"-ger or the neuly proposed NPW a~la in the WLIkas-ical Znez acies A Repott to Congress by. the Conpcroller Rarre area vhich is currently under construction).

Rsdiolo General f dece4 torch 30> 1979, 444 several other nsvspapsr articles Furtheznore, nore detailed evscuatfon plans should probably be uarked aut ufth che and speeches on chis and related sub]eats.

various Iacal County and State CLTLI Defense and Eaergeacy ?fedfcsl Sezvices (EfS) the staff also talked co Jane Zenney, Agencies. The recenc report issued by che Office of the Controller encitled A In Sddicion to revieving these decussate, Re orc to Cau ress - Areas Around Rucleaz 'Facilities Should Ze Setter'reaazed the Executive Direcco'r of ch4 Souch Essc4111 Ã4v Esnpshfra Regio1141 Planning for Radiala ical P11er enc es xszch 1979, should 54 revfeved ta ascertain potencial 0aanfssfon on ics invalvenenc Ln cbe sicfng, licensing, Snd nonftorfng of the roles an4 responsibilities of various public and private agencies Ln chess efforts.

"Seabrook Nuclear Paver Plane."

this EIS are a 4irecc outgravth of these ravievs and Fuzthernore, the ED0SP belLeves cha zmsc recent Section 208 Caaprehensfva Water Tha follouing comsents on 0uallty Bsnsgenent Progrsn (00WA:9) reports for the Lover Susquehanna River Resin conversaCicus1 should be evaluace4 in Light of sny patencial inpact che plane and irs ancillary The Council 4 st4ff 414 noc b41LSTO Lc hsd sufficient cfue nar tha facilities ufll have on current aster an4 severage facflftias and other vater Setters.

brea4th 444 level of ezpertfse to reviev an4 ccmaac on may ol che cechnical aspeccs of the EIS and Lts attawents. Eovever, the Also, cha Council believes nore Lnforwtfon oa che plant'4 location zelstiva to Council'4 staff believed Lt hs4 sufficfenc ezpettise snd tine to cha floo4 plain should be ezplained in nore detail. Zc Ls diffim1lc to ascertain cannenc an che olloufng item vhfch liars discussed vich che Council'4 Lf any of tha propose4 fscLILWS aza Ln che 100 year floo4 plain sndlor Lf the PXRS Coanfttee, Lcs Policy Cacnf cree ~ fts Zzecutfva ~cree <<onscruction ef che Tioga Bazaoa4 Dens vill affect the site and fscLILCLOS Ln gosr4 of Df~tozs. question (L.e. Cha fncske and savage treacnent plane) ~ The staff realizes chis topic is discussed in noze decafl in Chapter 4; but belfeves, this itcs should ba thoroughly coardinace4 vith the Susquehanna River gssfn Camefssfan. (SZS0).

Smmsrv of ZDCTP'4 Cazneuts Anochez ftea vhich needs attention fs cba prepar4Cion of ~ syscsnstfc suzT47 of ceaersl counents on ziscazv of che Pra ect (chapcer I) historic, ethnabiscoric, and prehistoric culcuzal resources ac che plant site filed ufth ea4 along cha proposed trsnsafssfon corridors. Tha Council believes a )oint State - County - 0CLILzy scu4y of Chess pocential resources should be undertaken This EIS'is an'update af previous reports the Zuclesr Regulatory Comsfs sf on. as soon ss possible. Potencial sources af funding nfght inclada1 the Pennsylvania Zvaluatiaa R<<porc (SZR) vill be Issued after tha revfev sn4 approval of Efstorfcal 8:ameun Cosssfssfon, the Pennsylvania Endaunenc for the Arts, the A Safecy Rational Endavaant of the Arts, che Appalachian Progran, en4 possibly other local this EIS an4 PPLL'4 Final Safety Analysis Reporc (PSAR).

foundations. This progzan and any findings could conceivably beccme a parr. Of the propose4 recreation area sndlor part of the progrsns af local colleges (WLIkes, hezefoze, nany of the concerns vhich the Council ac4 other cL iten groups my have lu er ~ Co@sty Camsanf ty College, Rloonsbuzg Scice College, snd Suckn411.

• on safety related issues associated vith chis plane (especia'ly Ln lighc of che Three Ke Island (~Q) AccLden ) vill be evaluated snd cemted upon sc a lacer dace if the Council is involved Ln chac SEX revieu.

2

The Councf1 also strongly encourages PPCI to perfozn the appropriate scudies on che Cenersl ~eats on the Plant (Chapter III) operation of ths Lntkke as currently style4 an4 designed, since Lc appears Lt OLII have sn adverse effect on Che scquatfc life within the vicinicy of wing walls snd Eased upon che 4sca presented fn che Efg> ic appears che Susquehanna River RssLn riprap, These sra crucial ~ since shad ns7 be reinczoduced Ln zhe lover reaches of Cocssfssfon vLII uoc pernfc PPLL co vfchdrsw the necessaz7 voiune of vacer ftoa chs che Susquehanna RLver snd various fish Ladders are beiag contmlsted on sow of the river during periods oi'ow flow. f dens 4owns creen ron this proposed facility.

ipparantly Pygmy is considering tba construction of a reservoir or sa alternate Llso> Lc appears there are sons incousiscencies Ln the evaluacLons on whether the water Source. The 0ouncLI trusts chat thLS reservoir wLII be capable of not only shed wLII renafn in the nsLa channel or use the pool areas for rsstfng. If

~ hsd 4scLde to 'zesc Ln che pool near che incske, this ns7 have significant negscive the supplying tha eater needs ec tha peqesed plant, but also be of sufffcfent size to rasulcs as t5ey nigrste up an4 douu the river. In essence, the Council's augssnc the flow ot the river to insure sn adequate water iupply for che wecsr Lncskes on the river for the Cicies of Dsnvflle> gezwfck> snd Rloonsbuzg. the potentfal shad pzoblen shoul4 be studied in nore detail snd sol~tions stat'elLeves The Council would appreciate receiving a copy of chis zeport oa tba found ss soon ss possible co assist fn the reintroduction of shs4 in the pzopose4 reservoit ae either the utility or RRC g usquehauns River.

The Council applauds PPLI for Lts pzoposed.recrestioa centers sroun4 the plants, It, also, appears thee the proposed ri~er iatska structure will only be .3 of s however> Lt wonders if PM also plans co peznft public reczescfsnal use azor 4 necer (approninscaly.l foot) above the Standard Pro)ecc Ploo4 (SPP). The placenant of chLO fscflic7 should bo close17 evaluste4 Ln light of che region s experience ics propose4 lou flow sugsentsc&ll ress vofr in 1972 4urfng Tropical gtocn Lgnes snd che saounc of pzocsction, if sny, which the proposed Tfoga Esnnond Dan will have on an area thfs far downstresn froa tha The Council again believes Lc Ls ~ztsnt to scress chat the local ~ties above nencione4 dsa. also, the construccfon ot the riprap at this sice shou14 be should receive sufficient tates oz paysents Ln lie'u of Cares to cope wiC5 Che csrefu117 avaluace4 fn terna of cbe pocencial force of tho floo4 way increased level of services snd asnpower (police> fLre, etc.) vhich will be a 100 year or greata flood. require4 due to tba inpecc of chis fscfifty. The Council believes the Iuzerne County Planning Coco>Lesion or galen Township should subaiz. Sn application co IKD or FR0 to nore fu117 ascertain these fiscal Lnpleaentstfon strategies.

~ts and also co develop spp'zopzisca also, tha Council belLeves a survey of cultural resources (IS4Lsn relics, etc.) in 0eneral Co>wants on the Envfzo<<sental>Effects of Station zscioo (ChsptozD) cba vicinity of che plant should be nsde as soon as possible in order to quantify che eztent snd value of chess resources Ln che area of che plant.

Ths Council s scsff believes nore scu47 Lnnecessszy on che +act of thLO fscLILty on publfc ozpeudfzuzes fot police, fire, and other special enezgency equf~t be neede4 noc only Ln t5e Lnne4fate areas buc also for backups in che event of a which asy The Council scsf> also o>nd it Lncerescing thee sppronfnsteiy g0 percenc of opera-tional work force which was hire4 by Kovanbez, 197g vere La~grants serious radiological accfdenc local workers. The Council believes PNI should investfgate the 4evelopoant rather then of Qso> che RRC staff notes there night be additional Iaaf use +sots snd that.PM Czsfnfnglenpioyaent progzm (for ~ie, under PIC or OJT) wich Local QA agencies such u the Iu-ez e Co>szcy Eunsn Resources Agency in ozder co encourage che should cake these Lt~ inco consideration in its socio-econonfc nonitoring buc che RRC staff does noc poinc out who will have t5e responsibility to ~lenent pro~, of nore "local" people. biting the enc'cipecs4 pzogrm,which to adverse land uses

~t be necessary co A 'gaea che effects zelscive simurgh che coral csn bLII for the zm gusquehaaa units will be sbouc $ 5.5 CL>>fcn very little of this vilL be distributed locally. (955,000 to Luzetne County snd The ~>

coord~to encourages PPLL to ffnsILCO its rsplsc<<sant water plans as sooa as possible chose plans w>Ah che InzerM County Planning ~sion>

910,000 to Colusbfa C<<>Sty dua to cuz.enc scare 4w.

sn4 Pecnsylvanfa Depeztnsnc of Envfzo~tsl Resources (DER) snd the SRRC.

tho,EDCRP ~ che >>e Council's scaM believes LC nssns possible anendnents sons nore equitable co che fondle sboul4 be Pe~ivaufs Public Realty Tax pursued, even Iaw.

if The Council also believes che Interne County Planning ~sion s~c f~

should an application to che U.S. Envfronnsntal Protection Agency under ue 0ufet CcmaCCLOS genera'ow s on zbe vov'rou-entsl wenftozi ot the?Isnc Site (Chapter 9)

Pzogzsn to secure che nacessaty to buy the noise nonftoz>ing equi~>C and co acquire the necessary ezpertise to develop s history of che noise level generated ac snd near the plant.

he Coecfl's staff concurs with QC findings szd reccwndstfons Ln chis Chapter end strongly uzges PPQ. to ezpedite nsny of c5en (i. ~ ., che noise nonitor>ing pzogrsn nentione4 earlier).

Ceoersl Coanants on Cl ~ Envtroccmatal I ect of?ostulated Accidents (Chapter VI)

UNITED STATES ENVIRONMEIITALPROTECTION AGENCY The CouacQcs 2K accidaat.

scsft balLevas the curreat Tha Council EIS is deficient ta statt believes chat since sa accident Chat it dtd aot aote such u the REGION Ill TNZ ts Scv ANO WAI NUT STREETS possible, tt be1iaves ic vould ba prudent tor P?4L aadlor tha SEC Co develop a PHIIACELPHCA PENNSYLVANIA lsc04 plan tor a Class 9 failure st chis tacQtty, esyactally since an acctdeat ot chts aagottude vaa aoc considered ta chio EZS. Al!817 >79 Again, tha CouacQ'4 scstf recccmads thee SEC and PP4L ravtev the Office ot the Coaczoller's repor aa4 the other publications aotad urlier on this su)fact.

Nr, Voss 4. booze Ceoersi Comeots on the Seed for the?lant (Chapter VZZ) Asstscsac Director Eavirocmatsl Pzoj acts The O(uncQ's scaft tomd t)ts Chapter very tutor~tive aad geaarally concurs c5sc Suclear Eegulstory Cocsctsstoa T-518 Chere ts a need tor the plsnC even though scà stay Question tha aeelt Co have tha .Vashtogcoa, DC 20555 ylsac since PP4L vould scill have a 24 perceac reserve aaron ta che tt s~r vtthouc lit)ough c)a Dear Hr. Eoorac tc ia 1985; sad a 30 ?arcane reserve nszgfn'a tbe viator vitbout ~

aazgtm ara significantly shove the 5 'percent resezve nargtu usigned co P?4L as tts resyoastbiltty in- tha PJE tacarcoanacctoa; tt appears P?4L acted tn good faith V<<have con?lated our reviev of the Drafc Eavtroumatst Lspact State-ia the late 1960's and uzly 1970'4 vhea tt Ae the decfstoa co go ahud vtth tha teat caoceraiag tbe Suscy>>haec>> Stean Eleccrtc Station, gaits I aad I, tactlLty, since ir. vas usigned a 20 percent reserve aargtn ac thar. Ctup. Qso,'PP4L Luseraa Countyc Pennsylvania ~

an?ected considerably nore grovth ia tts service area and tha iatercoanecttoa st that. Ctm. Fuzz)ernore, tc aov appears tha State and tha tntercocnect are indeed Oa che basis ot our zaviev and concerns ve have clssstffe4 t5e docu-fortunate thee P?4L is ~ viator peaking utility aad bas this reserve aargin tn light saot snd propoul EE 2. This mans ve have eavtroaaentsl reservsttoas ot tha yocaactsl closing dova o! CPD's Three Htla Island plant, snd also, tha coacenLag che yro]act and ve do oot believe the in?act staceaeut hss sufi'icienc Lntolusttoa co assess tully the <<avtzonmatsl in?act of the CO tacraasiag need for eaergy La the Dotted States due to cha OPEC oQ crisis tn I 1973-74 sa4 1978 action. Ve have eaoloeed our cocoaaats cha CocsccQ's scott believes chLs resezve aargta ts a plus in ths The E?4 classification aad che date o! our comeats vill bs published 79'uzchermre, La the tederal Register La accordsaca vtch our nsyoastbtltty to to-region's stteapts to revitalize the acocony of tha region vhi<<5 co 4ata has acetous uader Section 309 o!

azpezteacad high caenployauct rates an4 little ecoaontc gzovth aad dtverstttcatton. tem cha public ot ouz revtev on proposa4 the Ciun Air Jcc Za essence, cha ComcQ,'4 staff baIieves che addtt~al reserve aargta vhtch t5e Susq>>)sama pleat vill provide (47 percent reserve mzgtn tn vtater and 29 percent resezve nargtn tn scat>>r) by 1985 is a plus co che ecoaoay o! t5e gute acd our region.

-. Ceneral Ccxaeu ou tha Evslusttea o! CHs?reposed Action (C)ayCer VIII)

Ant)ratite dt4 aoi. ay?ear to be cmsLdare4 as aa altansciva. Zc nay be a nore 'Jettsads Eeviev Sectioa

-.vtk)4 fllel tn the.tutun ta that it ts emnyc tron t5a mst teceac 802 relIuiramats ETS 4 yromlgatad by EPL Other 4sts vas very technical an4 our. o! the CouncQ'4 smtf azperttse or aoc 4Lrectly relsta4 co the EIS statueat.

General Coments oa the gel.a!it Coer. Analysts (Chapter 0)

The CouacQ 4 ~ Csft geaeraQy concurs vtth C)e "bottoa Qaa ot thts Chsyter and the Council'4 stat! believes that tt voucct be possible to oyerate tha scsttoa vtth oaly atntnsl eavtzocnenta1 4~acts tf che apyltcsac (PP4L aad Allegheny EISCMC Cooperative, Iac.) tollov through vie) che racomandsttoas aote4 )y the SEC scat! in A IIS aad th cornea 4 o! ths IDCf? vh'ch are noted ta chts zavtev.

6-

Radial ical Tssues We reCuest Che RRO to explain the chsaSes vhich ellowd a fire co se>en fo14 increase fn projecced Ssseous fod(ne releases.(found by conperisoa of Che Ststeaeats of 1973 snd 1979) snd co explain vhy the increases 4id noc result in any substantial cheese (n the sssociate4 doses co a chi14 s ch7roid (por decsils> see Che Drefc Scsteaenc>

pate 6 16 versus peSe 0 56 ~ and 6-1S versus 0 75, 77.)

la support of this request> ic nay be noted that our 1973 ccmnnts on ~

projected Ssseous iodine releases snd associated doses vere sharply critical, snd ve recur>>ended the use of eaSineere4 iodine control syn-tone snd o>her disiSa uodiffcatfons to reduce iodine release such chsc r Drsfc Enrlronaental ~set Scaceneat the offsite dose to ~ child' thyroid did aoc exceed 5 nQlkren per year. Our cosauncs are reproduced fn che Drsfc Staten>at, psS<ssenCs> shove on pete 0 123>

iten 11.13, stipulated use of desiSn nodiflcscions, snd referenced a Lnserne County, pennsylvania revised rsdioloS(csl fnpect as 4escribed on psfe 0 77, section 5.4.1.

Ewn thcuth section 5.4.1 noted the existence of uncertainties ia the calculscionsl nodal > and che dose (upset hss nov baca recslculsce4 usinS aev source tern cslculat(oos> per pace 6 1>buc che Staten>ac 4oes not contain sny specific 4(scusskon of lesseaed (upset per unit of iodine release. This discussion of lessene4 (apace per unit of iodine release ause be incorporated in the pinal Eavirosnsntsl Tnpsct S Cate>ant Reactor Accidents The Epk hss exsn(ned Che KRO's essessnent of sccidencs snd their potential rfshs. The asses>mats wre developed by NRC ia the coarse of ics enS(neerinS erslustkon of ructor safety fn che des(En of na clear plsntso Slate these issues are co>ann to sll cuclesr plants of a Siren cype, ZPA concurs vith NRC's Seneric approach to accideac risk e>slant(on, The IC (s erpects4 co continue to ensure ssfecy thrcuth sicinS> plane des(En snd accident asses>vents in cbe licensinS process on a c~~sse basis ln 1972, the AEC initiated sn effort to exsaine resccor wfety sn4 the resultsnc en>(ronwntal cense>(osnces sad rishs on e nore qaancits&e beefs. The final report of this effort vas issued in October 1975 by che U.S, Suclesr ReSulscory Oosadss(on as che Reactor Sefscy Seedy, WCSE 1400 (ÃJREO/75/014) ~ The Epd' reviev of che'eedy included ia house aad contractual efforts> snd our cocnnnts sere released fn ~

report in June 1976 ~

porste the projected releasee over the I(f<<tisN of che facility (rath-In Jaly 1977 the RRC chartered the Ris'k Ass<<sea<<at Revi<<v Croup to er than jusc the <<annal release),.(2) eztend to several geo<<tati<<as b<<yond the perio4 of release, (3)'onsider, sc leuc qmlitatively or provide advice sad Lnfora<<cion to the RZC on VASR IA00 in re<<posse to g<<ner(cally, the wori&4le in!la<<ac s on the total <<nv(robot<<I letters faa Cougr<<ssasn Mall ezprsssing aisgiv(ngs <<bouc the rap<<re inpscc or sp<<cify the Iinitatfons of the and<<i us<<4.

aad in parti<<ala about the Rr<<curie<< Sun<<sty published vith the re-port, Tbe RLst Asses<<vent Reviev Croup Lssu<<4 its f(nd(ngs Ln S<<pt<<n yu<<l C 1<< snd Ion T<<rs Dose Ass<<ssn<<nts ber 1978 sn4 the RRC accepa4 the findiags during January 1979 ~ The RRC also vlthdrev sny ezplicit or Laplicic pisa <<odors<<vent of the Zzscutive Sussssrys geng other specific actions ZPA agrees vith th>>

ZPA is responsible for escsblishing generally spplicabL<< environs<<nt<<I RZC' position in this ascter We also cones@ vlth the SRC's con radiation protection standards to Linit usa<<<<<<ss<<ry radiac(on <<zpo sures snd radioactive asteri<<L<< in the gen<<raL <<nvirona<<at resulting tiresd suppose for the use of prob<<bill<<tin r(sb sss<<<<seance Ln regu- !ron nota<<i opsrscions of fscilici<<s thee are parr. of the uranian fu<<L latory d<<<<i<<iona<<kings with tb<<sdnonisbaent that such decisions b<< cyclei The ZpA hss coaclud<<4 chat env(roe<<sat<<1 rsdf<<cion standards bss<<4 on several !secor<< scca<<passing social, technical snd econ<<<<in for nuclear pov<<r industry opsrsrioas should tate into sccouac che issues Ln sd4ition to scold<<ac r(sh sss<<ssaents total rsdiscLon dose co tbe populations the nsziaua Lndfvidu<<I dose, The reactor scold<<nc ac Cte Three HLI<< Island-2 reactor on Ketch 28, Se risk of health eff<<cts attributable to these dos<<s (Including th ~

1979 hss focus<<4 art<<ation oa the greet ne<<d for a thorough r<<<<zsnins future risks <<riding froa the rel<<sse of long ILv<<d ts4(onuclldss to the ecv(roc<<nut), snd the effectiv<<n<<ss snd costs of effluent controL tioa of reactor safety Ve are oonc<<tn<<4 about th ~ effectiv<<n<<ss of technology. ZFA's Dr<<nina Tuel Cycl: standards sre ezpr<<sse4 in terna the procedures by which reactor opsrsting <<zp<<ri<<nce is crsaslst<<d into Laproved reactor d<<signs or op<<rat(on<<I practices. W<<believe ic of dose liaics to individuals a<<nb<<rs o! the general public and ILiits on Wssncities of certain Iong Lived radioactive asterisls reless<<4 to Lncuab<<nt on the RRC co carefully tevi<<w its curtest procedures for the general environ<<mat Ld<<ntffy(ng, ass<<ssing and ecting on potential scci4<<nc sequences as operating ezp<<riant<<with reactors Lucre<<s<<s ~ A do<<un<<nc <<acicl<<4 "Zavirnunental S.~y of the Craniun teel Cycle" Con<<id<<rat(on of occident scenarios sbou14 of course incla4<< Class 9 (VASR 12lg) vss i<<su<<4 by AZC Ln cocionction vith a r<<gal<<cion (10 C)R ac<<id<<ntss b<<cause their ezist<<nc<<was 4<<non<<czar<<d et TVI The SSZS 50, Appendiz D) tor sppllcatioa in co<<pl<<ting the cost-benefit scaly ststcmnt does aoc coasider such et<<ideate As SSZS is on the Su<<pa s(s for in4(vidual Light-voter re<<teer eaviroaantai rev(evs (39 S.R.

hsnnag upstrssn fr<<a Thre<<RLI<<L<<lands snd 75 nil<<a <<ways the <<cate 14188) ~ This do<<On<<nc Ls used by ZRC Ln drefc <<nvironaentai state

~ aacs to assess the incr<<sacral <<nv(roamntal inp<<cts tbsc <<sn be

~ aat sho<<14 re<<i<<v tbe possible emulative effects of a secon4 Class 9 accident La <<estral p<<nnsylvsnia eccributed to feel cycle coupon<<nts which support nuclear pover pl<<ats, posulstlon Dose Cow<<its<<ncs Re<<encl j the SZC d<<cid<<4 to update the WASR-1248 surv<<y We b<<IL<<ve this is a prod<<nt step snd coaend the SRC on Lnltisting this updsce We are <<neo<<raged that the RRC is now calcalsring snaasl population 4ose cosssicsnts to the V.S population, wb(ch is a partial <<valuation Ia providing coanencs to che mC on this subject, dst<<4 Soveab<<r 14, of the toC<<l pot<<atisl env(roun<<at<<i dos ~ <<sess(tn<<nts (ZDC) of R-3, 1978, we eacoarsg<<d ZRC to ezpress env(recant<<i Lap<<et<< Ln terna of

~5 potenti<<I con<<ego<<nc<<s co huaca b<<<<14, since for radioactive neceri-

$ <<rciculstes This Ls a big step toward

~ C I4<< io4in<<s and evsL<<sting the ZDC, vhich va have urged for several years Sow<<ver, <<Is sa4 i<<airing radiation the nose Lsrporrsnt inpects are those uiti-Lc sho<<14 be recogn(sad that several of these rsd(onsciides (parti nstely effsccLng huaca health V>> believe thar. pres<<at<<cion of en<<i culerly c-14 snd zt-85) vill contribuce co Iong<< t<<ra population dose roc<<ant<<I Lapser in terra ot hamn health Lap<<ct !oscars a barter aridly<< understand(ng of the radiation prot<<<<cion afford<<4 che public (upsets on a basis, rather chan just Ln che U.S To the,

~ zc<<ac that chis drstc staten<<nt (I) bss Lin(tsd the ZDC to che annual discharge of these rsdions<<LL4<<s, (2) Ls b<<sed on the usuapcfon of ~ A second nsjor coacera of ZyA 4<<sls with the 4ischsrge sn4 dispersal population o! coascsac site, snd (3) us<<sees che 4oses during 50 of loag lived radio<<<<elide<< taco the general env(rona<<at. Ia the years only folloving each release, Lt does aot fully prov(de the toc<<L areas <<4dress<<d Ln VASE-IZAS, there are sever<<I cases in which radio

~ arizona<<acsl Lap<<et Asses<<a<<or of the total Lnpscc vo<<14 (I) incor ective ass<<rial<< oi'ong persistence are released into the environ

nant. Ihe resulcing <<one<<>(oaa<<es aay ent<<ad over aany gee<<rations an4 cacscitata irreversible yublic health <<omkznants. Ibis long tera DOE baaed a draft ELS, San<<Scout of Cow<<r<<kakky C<<oersted Radio poteazial knpcct should be consider<<4 ia any ass<<sea<<at oa health ~ ctive Waste," daring April ot 1979 ZPA ks <<onducting a coaprehea-Layact ZPA has coasistently toun4 Load<<>ysato the SZC's astinates of ~ be revL<<v of chis EZS, aad vill sub>sit coca<<ate to DOE upon <<onylc population doses tor chose persisceat rsdLoactbe net<<rial<< Za zion of she rcriev particular> the ERC has generally liaited their analyses co the popu-latioa vithia 50 okla<< ot a facility, or ia tars cases, to che D.S EPA b cooperatiag rich both mC aa4 DOE to d<<velop aa enrkronoeatally population and co doses <<oaakttod for a 50 y<<ar perio4 by aa aaaual acceptable prograa for radioactLve vast<< snnag<<neat. La t5ks regard>

release. Those Lknktatkons produ<<e kn<<<<apl<<to estknatas of aariron- EPA has published proposed <<arizona<<at<<1 radiac(on protectioa criteria saatal kapacts aa4 voder<<szkaazo the Lap<<et ia soae cases, such as Cor tha aanagcaeat of all radioactive vast<< aad vill establish aavk-rocaeataL rsdiatioa prot<<ctioa standards for high level vast<< in tzoa releases ot trick>ss> krypton 85> carbon 14> t<<chaotkM9 and iodine-129 The totaL kapact of these persistent radioouclkdas ihould 1979 We have conclud<<4 thee the continued 4<<v<<lope<<at ot the be us<<so<<d, >psakktykag such <<<<tinct<<<< u appropriate to reflect the Nation's nuclear powr industry is acceycabl ~ fran aa eavirocnantal uacertakntku. Za this regard, ve aote thee t5<< Nu<<L<<ar Energy Agency point during the perio4 required co satisfactorily resolve the vast<<

is add<<<<<<slag thLs approach ia a<<bing asses<<nants aad that thd SRC is aanageaeat >(<<<<scion.

rept<<seat<<4 in this effort.

Trsasooztatioo Anocher aajor <<on<<id<<ration ia updating WASR-1248 is tho health kapa<<t fras radon 222 tr<<a she uranian aiakag and aillkag industry. Esci- Za its earlier reek<<vs of t5<< cavkromnt<<L kupa<<ts <<C transportation aaccs cade by ZPA snoag others kndk<<ate that radon-222 contributes the of radioactbe ass<<rial, EPA agz<<<<4 vith AEC <<5at aaay aspects of t5is peat<<st fra<<tkoa of the total health Lnpacc fzoa sssckoar yovor gener pzogzsa <<ould best be truted oa a generic basks. The SRC has codk-

<<cion ~ Zn preparing aa updated WASR 1248> ve b<<LL<<vc ERC shou14 tied this generic syproach (40 F R, 100$ ) by adding a table to kts regulations (10 CFR Part 51) vhich s>us<<rises the envkrocaantak a Include the radoa-222 <<ontrkbutkoa Crea both the uzaaiun nkn- Lap<<<<to resultiag frca the traasporcatioa ot radioactive asterisks co iag cad akkkkng industries ~ nd trna light~ter reactors 5, Dot<<raine the health iayact to Larg<<r populations than oaly Tbe knpact raine for routine traasporcat(oa oC radioaccive aaterials

<<5<< local population. hu be<<a sec ac a l<<v<<L vhich <<overs 90 porc<<at ot the zeactozs cuz rcntly operating or und<<r con<<auction The basis tor chc knpa<<t> or c, Re<<ognkaa the pes'sist<<at nature ot the zadoa 222 pre<<ursozs risk, ot tracsyortacion ac<<id<<nts ks aot as clearly defined. Ac yre

(~>2$ 0 an4 Ra-228) by estkaatkag the health knyect for a scat, EPA> DOE aad SRC are each act<<opting to naze tuLIy asses<< the period r<<Clccckag oak<<i~aeration tbas. rsdkologi<<al iapact ot traasportatioa rksbs. The EPA vill its rlevs oa any envkrocnentalky una<<capt<<5k ~ coaditioas relaced co nake bacon Ri 5~<<1 Waste 'Nsns anent cranspsrtatioa. Oa the basb ot pro<<one knfoznatkoa, EPA believes thee there Ls ao uadue rkst ot transportation accidents asso<<iat<<d Ihe cechak>ps<<a and yzo<<<<dure<< used to asaage high level radioactive vish she SSES ~

vast<<a vill have aa iayact oa the enrico>nant. To a cettaia <<at<<ac, these knpacts can be dkte<<cly related to the indkvidusL prof<<<<ts because CS<< reprocessing ot spent fuel tr>sa each aev facility vill contribute to the cecal vast<< Tho AEC> oa Sept<<aber 10> 1974> iuued Tbe ERC has published a proposed rul<<asking oC De<<osssksskoakng Cri-Coz <<<<>nant a draft st<<taunt entitled "The Nsaag<<nant of Co<<>sar<<i<<1 \ > *>l>d > > ~>> ll>

Rkgh 1<<vel cnd Tzsasuzaak~tsaknatad Radkoactbe 'Waste" (WASR- 1978 EPA <<omaents vere seat to SRC on July 5, 1978, d<<sling vkth <<5<<

15$ 9), In this regard, ZPA pzorided cnteasive <<os>seats oa WASR 1559 d<<c<<essks ~ konkog isaac<<a oa Ear<<aber 21, 1974. Our a<<$ <<r <<rick<<isa vas thee tho drafc state-snnt La<<bad ~ psogrsa for arriving ac a eacL<<factory ae<<5<<4 of "ulti In s>snsary> ve believe that one of cbo nose kayo<<tant issue kn the sate" high level vesta disposal, 4<<<<<<sssksskonkag ot nuclear facilities ks t5<< devel<<pa<<ac ot scaadards

tor rsdiseloa cryo<<ore Ifnfcs tor nctcrials, fs<<fifties sn4 sites co south of the pl<<ac It is also seated thee Wont<< Carlo te<<hnfeucs be released for unrestricted use, We hc>> iacludcd che devel<<poco<< of >>re used co <<clculcrc dfzc<<c rsdiccioo <<nd shyshhe dose rates oa the

~ uch stsadsrds cnoog our ylcnned psojeccs. Theatre vill retufse c order of 20 orealyesr per unity at a typksl ~ it<< boundary dfsesn<<e of thor<<ugh stu4y eo provide the nc<<em<<cry hfonsathn, in<<lu4ing c <<esc- 0.6bn ttas the turbhc bufldhg It is nocsd that the dizecc radia a ffectfv<<ness analysis toz various Levels ot de<<on<<ash<<Cion. cion dose is noe listed on Tables 4.9 aul 4.10, chat there are resi-dences ct 610 n cn4 156n trna thc plane, end thee the Sg sc<<tos vich Thc dcvalopocnc ot ccsodcrds for 4<<<<onsissbning ouse ~ of <<our<<of tbe resides<<c ct 610n also hes a garden an4 acsc anhsi st 644n Ln<<I<<4<< coaslderacion of the aany concurs<<at activities in rsdfocctLve These bc<<ore <<ould <<<<eve to osnfnixe doses h these sectors cnd vesta snaegcasat cn4 radlologi<<sl proc<<<<tbn gp4 hss d<<<<eloped pro cher<<tore sb Id b nore fully dfs~s<<4 in che tinil RIS.

pos<<4 Criterb for Radios<<cLve waste fos a<<nag<<nant of sll rsdfos<<cise vs<<tee vhhh vill provide guidance for de<<osaisshnfng standards Wealth Rfst Conversiou pe<<toss yrae the d<<co<<saissioning viev probably the oust Lap<<reset criterion is that linitiag reliance oo hstftutbncl coact<<is co a gyves tfnita period. The health risk <<<<user<<Leo fscC<<rs listed oa page 4 2y sypesr Iov cnd RPJ believes that the use of Lasticutioasl coatroL to protect chc are io<<on<<bc<<ac vfth tha fs<<tore used h the Ccneri<<RIS on Uzanf<<a p<<bif<< tras retired nuclear fc<<LILCL<<s, until they <<cn be decant<<uf- Mfllhg (SCRtCr0511). These values should be oaf<< <<os<<be<<at vlch o<<cad sa4 4<<co<<aissioned, shoold be Ihfted cc che aost co 100 years thos us<<4 h acegm511.

cn4 psefessbly less than 50 years ~ This inclu4<<s ea<<I<<sr reactors

~ hut dovn snd os<<hall<<4 os cut<<abed for a period ot tine under pro-tecti>> storage 4ftsr the ciiovabie Lnseitutbnsl <<src yerio4 is ov<<r, the sic<< vill have to acct r<<4iosccfve protection levels <<ac<<b- Coon<<ate gelatin to Wsccr slitv ibbed for Calcu<< tor unrestricted use. We b<<IL<<vc proposed

<<thesis vould b<<4isecely cpplf<<able, ss cbov<<, co 4<<coaabsiooing of Peg<< 2 12, Eigure 2.3 ted I

sn<<I<<cr fs<<ilLcfcs cad should be gi>>a serious <<onsiderstfon by the po Suc'I<<sr Rsgulacosy Coon(scion (ÃRC). yfger<< 2 3 depicts the Water Use Diegran for Susquehanna Daft<< I cn4

2) bove>>r, a vates balance <<annot be <<elculsted for nsny of the unit The svellsbilicy ot cd<<pc<<to funds Mn thc cfac co deco<<abel<<a pro<<<<secs shove oa Che dbgras due to lnsufficienc Lnfornctfon. yor arrives b also oost Lap<<stan<<I Lc sbou14 be th<<re<<possibility of the ~ ssnpI<<, ic b hpossible to deceznine the ask<<up of the vest<< creat-RRC Co assure that such pro<<i<<Laos cre sade. W<<re<<ognbe the geese ocnC discharge since the flov rates of. the dhhersifzer en4 rsv vstcr co<<pi<<atty ot providing funds for such c<<tfvftfes at seas che in che trecesant pl<<ac dlschsrgu are ooc hdicatcd.

future, petti<<ulsrly vh<<re utflief<<a crc Lovel>>d 4ue to the controls Lopes<<4 by Scscc cnd local utLlity <<o<<ate<<fons. Sou<<vers if Lt csn be por purposes of <<Icrfty end future yesnfttfng, a revised dbgras tlzaly est<<bibbed char. Che total cost of dc<<oaxbsfoohg h current should be subnitt<<4 vbf<<h clearly shove ell 4bcharge pohts snd 4ollsrs b e very sacl'I trs<<thn of hftfil csphsl <<osu, provisioa hclodcs a coaplccc vscer balance. This tee<<en<<at <<chas<< <<ould also ot <<s<<zov funding ney not bc nccuuzy. Therefore, vs urge che BRC to be bccter ucilbcd lf Lt vere Ln<<luded in SectLon 3<<2 4 eneitlcd conduce the oe<<csury stodies snd ca<<<<sac<<ate to detcznhe un<<gat- Chcnl<<<<1, Ssnhsry, cnd Other West<< Treeca<<nt.

v<<<<siiy Ae costs ot decoaeL<<cbeing'sn4 to <<aspera sech costs co Lofti<<I cspical <<oscs Zc Ls only through e defhielve cnslysb, cnd yet<<graph 2.3 4 relates ehsc the Susquehanna ce the pl<<nc site aces perhaps through rcalbci<<dcsooscrsefon, chat this bsuc <<co be sc vse<<r quality stan!cede for cll para<<<<ters exc<<yc iron. In 4<<scribing solved o the db<<berg<<, on pages 4.4 snd the pages foll<<vine, the iapresshn Ls given chat the discharge vtll dcgr<<4<< ehe river beyon4 vates quality Disc<<t Radiation pron Dier<< n 16 Ifnfts for several <<ontanfnsncs. Table 4-3 shove cher. the chloride ioo b cstrcordhsrfly hLgh. The quantity of Che Lon Ls noc. the nsjor The case<<as<<at ot the dire<<r. radiation fzoo th<<nitzog<<n 16 is noc <<one<<ra but ics occur<< b, particularly eben you consider the stol 4b<<assed in sutficienc detail co <<11<<v aesningfol hccryretccbn (see <<bias<<try ot thc various Lone thee cse on the lbc of the State' pays 4 16 to 4-21). por casopb, h is stated chat the cyplicsnc vsccr qoalfty per<<net<<re, chose aching uy the eff In<<ac of chc plcnc

<<slculcted a 4hect rs4iscion dose of 2 7 vr<<nip<<sr psr unit sc 0.55bn cn4 chose Lone snd <<<<op<<unde noc Ln<<iud<<4 but nsy be ysesenc in the lice of vates @<silty p<<rsn<<ters.

Pig<<re 2-3 does ooc clearly illustracc vhether thc. savage ere<<exeat pleat eff>luaac fs dis<<barged into the Susquehanna Riwr. The pleat is 4. Page 3 8, Section 3.2.4,1 aoc des<<ribed in sufffcfcac detail Tbe lack oC design or op<<reef<<a ss>de docs aoc give the ae<<<<suey sssuraa<<e thee ic vill operate efff

<<fencly at. 1/S cape<<ity vlthouc adverse fapa<<ts upoa che river. Many Tbc first paragraph of $ <<ctfoa 3.2.4.L, Zadustrfal Vastas, states that sulturf<<a<<f4 added co thc <<freulatfag vacar sysc<<a fs the ac joe treatnaac sysecas taLL >d>cn they are aoc oyerated ac <<spacicy. sour<<e ot fadustrfaL <<bcafcaL vesta a<<4 ot yoteatial faye<<t co the.

a>L<<atf<<cnvfronnsat. This section does aot dfi<<ass >4>at eau<<res or tale 2-17, Table 2.8 erect>>eat the applf<<aat has <<aployed co el fain<<Ca or afafnfee this

inya<<t This section ah<<aid bc expanded to address this point.

TabL<< 2.8 Lises specific Vatar Quality Criteria applf<<able co te<<al coliCoas, totaL iron, as<<ganesa, dissolved oxygen> pR, aad cecal The sc<<oad paragraph <<C Chic se<<tfoa sesCes Chat vas'Css froa rav vatar 4fisolved solids bur. has aot included ehe applfcablc <<rfteria for Creen>cue vill be dis<<barged vfth rooC 4rains, et<<. co the holdup yond taspsracure. Spc<<fff<< t<<sparse<<re criteria tor aoae 03.010> North fa tbe parking loc. Ro fadfcstioa is nade, hovcver, if aay additional gran<<h Sus>luchanna River> crc u follovs> treaeaeac vill Cake place fa Chic poad If so> aay proposed tree<<scat should be outlined. Zf aot, Che applf<<sne vfIL nose likely have to 0

Rot are chan a 5<<p rise above snbfcac cusp<<rat<<re or a naxfaux ot <<lean out the yond as a result oC che build ay of seep><<dad solids 87<

vhf<<haver is Le>el noc to be <<hanged by aors thea 2<

Psonsylvaafa Code, Titl~ 25, Part I, Envfroaxcattl Re>our<<cs> Chapter 9S, Vstcr Quality Crfterfa Ave<<dad Sap<<saber 16, 1976; Effective 0<<caber Page 3-3,. 3 2.2.2 ll, 1976. SPTCA a<<<<ordfag co P.L 92-500 't Sc<<cfoa 4>3>4> ZFA gffluanc Cold<<lines aad Lfnftacfoas states the sta-tion shall a<<hicve efflusnc lfaitacf<<ns re>y>frfag the applf<<atioa of should also bc aote4 chat an<<ad snacs to this lsv (Clean Vatcr A<<t of 1977, P.l 95-217) vill re>y>fre the station to a<<hfcve ef!Lucae Lfnftatfoas vhf<<h ra>y>fre the fastall-acfoa ot gest Conventional Te<<baology ao later than July I, 19841 gcsc Sc<<cion 3.2.2.2 dcs<<ribes the iatake stra<<tare vhi<<h,vill bc cnploye4 at Chc pleat A <<<<nyarfsoa o! this intake and iatake dufgns LLLus-Available Te<<ha<<logy tor aoa-<<oavcatfoaaL pollutaats by July I, 1984 or three years after linita'Clone arc ucabffshcd> vhi<<hevu'r fs 1 'ar> cratcd in ZPA Do<<uncut 660/2-73<16 Revicvln gnvfrooaeotal Zaoace buc.never later than July 1, L987l aad gest Available Te<<haoLogy tor Statceeaes powr plant Co<<lan Cyst<<us Eo insert<< As e<<ts show the those 129 toxf<< pollutants vhf<<h appeared ac 43 Pederal Regiscer 410S ~ slga o the p aac s acaxe as general un>acts a<<tory. >he do<<u-ncut states chac travelling screens vithy<<oacfauous-aovesaat arc pra ao later thea July 1, 1984, u ayplf<<able. furred eo those vfth fntcrafttcat aovcaant Za ad4itfoa, cceded chat scatioaary l<<uvcrs tor fish by pass or <<oLle<<cfoa aad ft fs re<<o>a- 6 Page ~ rcs>oval ta<<ilitfes should be provid<<4 fa the $ <<rceavcLL. These cvo Zc fs >y>astfoaable as to the practlcsbLlfty of rcfacroducing sha4 eo aodftfcacfoas co the proposed iatakc structure ac SSZS should bs <<oa the rive. Duc co the >n>aber ot dans betvcea Coaovingo aad ch<<gus sidercd fa che ffn<<L dcsfga, esp<<<<ially in light of chc SRC staCC's ca<<hanna St<<ca tlc<<eric sita, it does aoc appear cbcc this aaadroaous con<<era o! adverse a!is<<ca to the aqsacf<< <<o>csunfty vichfa the fs>udf fish could sur>ive. The <<ost <<C gettiag Che afgratfng fish over the ate vf<<laity of the viag vali'nd a>so<<fated rip-rap. It should also dans wuld be exorbftaat aa4 4lfff<<ult co justify. be noccd that Se<<tfoa 316(b) of the Clean Vater Acc of 1977 rs>p>free che lo<<a<<foe design <<<<astra<<tfoa snd <<ayacfcy of <<oolfag vatsr fatake scruccurcs re!le<<t Sesc Available Te<<ha<<logy for ainfnfafag adverse eavfroaaeatal faye<<e by July I> 1984. Table S-I rv>eels thee Cha average casual i<<cake trna the tivcr cr- <<eeds the aaxinun aoachly intake. These figures are conf<<cfog aad ~ houl4 be clarified. c UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION lll l<<lov sre co>s>cats on Drafc Supplcacac EISSSES for che pond Hill Reservoir d>>> AND WALNUT STREETS punpcd storage Cacility. Uc believe aa ER 2 rating is justified relative to PNILAOCLPNIA.PENNSYLVANIA 19105 this docuncac. Please fied attached a copy of oor ay>ten Cor consenting on EIS's, The ER staods Cor Environsental Reservations and the 2 indicates lasufficleat Infornatioa. MAY 3 0 ~ca Infmnatioa regarding floods aad floodiag is sparse. Ii addition, thc nap oa page 2-7 docs aoc adequately depict the Poad Hill Creek floodplaia aor the Sasqushaaaa River Ploodplain. Ho doubt soae changes vill take place in Director, Division of Site these areas as a result of the projecc and such changes should bc addressed. Safccy 6 Atcal Eavf~tal Aaalysis With regard to floodiag, our infornatioa does aot agree vith eicber the Pw. 5 ~ Siagh Salva Office of Huclear Reactor'cgulatioa ~ pplicsnt's or thc IIC's. Calcalatioas based upoa the naxfn>sa stone of U.S. Huclesr Reyalatory Connissfcn reseat years, i. ~ . hurricanes Agaes> iadicates a 686 >ss precipitatioa Vashington, D.C. 20SSS eveat. It is our belief chat this fnpouadaeat vould be copped ia such a >tora aad, dcpeadiag upon dcn coastructioa, nay vash out snd coapouad t'e

Dear Hr. Rajva> dovnstrea> ~ dsnagcs due to floodiag. Ia addition,

thorough iafornatioa should be preseated regardiag other ~ CCects of stores of lesser intensity so Thank you for granting us a short axteasioa on tbe deadliae Eor sub- that ~ couplete caalysis caa be nade.

nirting c<rzxats on the Drafc Supplencnt ro the Draft EIS relatc4 to operation of SSES, Dbfts 1 and 2, specifically the Poad Hill Creek Thc flooding Inpact potentials as vali as tbe floodplain effects nay ia Reservoir. thenselvcs iadicate that the Inpoundnent should aot be builtl hovcvcr, oae other point should be nore thoroughly presented. This is the frequency

~ aalysls of lov Clove chat vopld iaterrupt the operation of the pover sta-Our coaocats are attached and if aay questioas then please contacc us on PTS 597-2188.

arise in relacion to cion. Ia this context> the usa of such terniooiogy as ". ~ . ia sons yeats, ~ , an4 "... require several shutdovns. ~ , Is too IaspeciTte for ade-Sincerely yours, quate evaluatioa. The ress~one or aot using thc river follov alternative, thea, based upon info>nation herc> are inadequate, Around the sad4le frau the "top oC the ridge" vhere a dike is to be place4 Robert S. Davis is saochsr saddle. This second saddle appears co be vithia the sane coatour lines as cbe "saddle" to be diked yct ao neation is sado either of its AttacILeat poteatial as ca "accidental" spillvay ia tines OC severe floodiag or of the necessity of a dike ia this crea <Rc. Cig. 3.2, p 3-3) Purthcrvore> no nention is sade of the severe flooding poteatial associated vitb the Lily Later ~ very lov saddle betveea these tvo sites iadicstas a possible spill over into Pood Rua vs'tetched during severe stot!s periods>

The 4iscussioas on vildlife resources is acceptable> but shove sons defl-cicncies vith regard to pcriodiclcies exhibited by sc>><< iaI>sale. Por exsn-ple> it is stated vith far coo nuch assurance that the cascara cottontail is of visor fnportance. Hovevcr> this sainal is currently near or at the lov point ia its seven year cycle. (p 2 ll), As thc cottoncall is a nsjor coa-poaeat oC the Eood vsb further decreases ia its population nay be signifi-cant ~

Tbe opcracional parsnctars discussed oa pages 3-4 and 4 10 4 ll fail to des-cribe adsquacely the frequeacy of iatakcs aad releases aad chair cffccts oa the reservoir itself and upon the Susquehanna River. Por <<xanple, this

IIQPIIA S zzrIIS ct IISIIJL tzffszATICS lzfR7TAL lan JCT105$ sISIIIKTIOS ot caeuats Itzaat Iztsats'az tzvIznaaz cs JCTIezs reservoir ssy have sultiple uses cnong thea being tecrestion The vorst ElrtzoTJOSCSI Irooct of t Io Actial possible eas ~ should bs described vhcn thc level is dropped to sn cztrase chere such activities ate curtailed. these lov levels chat IO Lack of Cbjoctions vill the effects be upon tha gusfuohannaACSO,st during the point vhere reduced flora in SPA hss no ob'joctions to tho ptopssod ection ss Cosct1bod tho ther are sugacnted by the saintensnee fros thc ressrvoirf in the Czaft inpoct ststenont or sucfosts oaly sinor chucos in tho 'propoud acticu During lov flov periods, vhcn the reservoir intake cannot be used, ond thc Xn tnritonaontsl Reservations river aust be augncntcd by flove ftos thc CnpoundncntI vill cvaporstCve losses bs sjgnC!Ccantj Evaporative losses during hot vuther are large. hss reservations concetnino tho onvtzonaontal effects These losses coupled vith dravdovn say indicate a shorter useful storage ZPA of ce~ aspects of tho proposo4 action.

M~t .Sztbet study of sucsosted alternatives ZSA believes or sodifics capacity than is indicated in the docuscut tisu is recuj cd ond hss asked tho oriflasting yocozsl

<<fancy to zeusoss thosi aspects.

Za sua, this supplcncntary docussnt does not adequately discase alternstire scssures other thaI providing flove fras the rirer itself or other reser su fnvtzcnsutaDy Cautlsfsetozy voCrs, Alternative ~ Ctes to th<<one presented hera are given only cursory SSA believes that the pzoposo4 actioa 1$ unsstisfsctoxy attentioa. Under thc nev CZQ guidelines, such docusents ss this are sup because of its potcncially hsznful offset on the envtzcu-posed to describe tho CCCCSConsshing process snd not sorely represent the ssnt. yuzthotnote, the Afoney believes thst tho potential

~ sf<<fssrds vbich niche bo utilized ssy not sdotestely pro-soot farorable agusents for choosing thCS alternstivo. tect the environaont fros hazards uisinc fras this action The Aconcy'roeosaonds that alternatives to the actiIuI be onolyzc4 further (inclu41SC tbc pos$ 1bility of no action at all1 of tbo Inesct Stotosoat Catstury 1 AC<<faata Tho Craft ispsct ststesont aeoeustely sots forth thc envizonsontaI inpoct of the pzoposo4 project or sctiua ss veil u alternatives reuensbly avs1lsble to the projecc et action catosozy I Insuf Iisiont cnfoznatcon zsA believes that tho Craft inpcct ststosont does not contain sufficient iaferastion to auou fully tho urizennentsl ispset of the proposed project or iction.

Eoveroz, fzas the iaforsotioa subaittod. the Aconcy is able to soke a prslininary Cetetninotion of tho iapset en the onviroassat. SSA bss zoqeostod that tho oricinstor pzorido tha 1nfozsstion thsc vas not lnclc4o4 in W Ctaf t statossnt fpA believes that tbo 4zoft inpset statossat Coos not sdoqcotely ossoss tho onvironnontal iapoet of the pro-posed project or oerion. or that ths ststoaoet Inseoeeotoly ualyzes tossoasbly avsiloblo oltornstivos. .he Aceney hss z<<pIosted sore Infoznstion sai analysis eoncerni<<I the potential envirouontsl hszuds an4 hu ssko4 that subr stsntisl revision be sade to the draft ststossnt If a draft inpoct ststesent is usicsod

~jnarDy no tstinc vill bs node of the project ot action

~ cstosozy S,

~

~ ines a basis docs not fourally exist on vnich to asks sack a Cotozsinstion rleute II ~ no'siricstlon Of SPA's Clsssif icstlai of Cosaeata

~ sfef of I

FEDERAL ENEROY RECUCATORY COMMlsslaw WAxw<<<ave<<. O.C. Ca<Re In Reply Refer To:

DEPRESS Cooperative Studies Oraf. Supplant ta DEIS Susquehanna Stean-Efcctrfc Station Units I and 2 Oarrcl G. Dscnhut, Director ccnstdered ts thc U.S. Army Corps of Engineers'awanesquc project, presently under construction and scheduled for coaptation tn Junc 1981. Thc report Darrel G. Ktsenhut, Ofrectar states that the Corps of Engtneers pointed out uncertalnt1es regarding the Ofvfstan of Licensfng avaf)abtltty of storage due to the need for Congressional approval for reallo-Huclear Regulatory Carr<tssion cation of starage capactty, and according ta the Susquehanna River Basin Coa-Hashtngcan, O.C. 20555 <etsstan, the Cawanesque project cannot be considered as a tfncly alternattve.

The repart fnpltes that Che Pond Hill project could be dcsfgned, constructed,

Dear Hr. Etscnhut:

and placed tn opcratton fn less ttae Chan thc Congress cauld effcc. changes tn the Ccwanesque projcc. cperattons. Ve qucsCton Chfs topffcatton.

This ls tn response to ycur recent request for carrents on the draft supplcaent to the draft envfro<ncntaf f-pact state.-ant for the Susquehanna Steaa-Klcctrfc Accordfng to the Corps of Engineers, the preconstruction planning of the station (ssEs) Units I and 2, Pennsylvania. Cowancsque project included approxtatcly 31,000 acre-feet'f storage far water supply but ft was not included as a project purpose due to lack of local support The draft supplant addrcsscs thc subject of low flow augaentatton required to at the ttoe. However, >>e have been tnfo~d by the Corps that a dctafled supply water to the Susquehanna Rtver to replace water cansmpcfvely used by the S600,000 plus study ls currently underway Co deterxfnc he availability of SSKS during periods of very low streanflcw. Thc average cons<~tive use at the storage ln the Cowanesque projcc. for supply nake-up water far the Susquehanna SSKS would be about 1.4 cubic netcrS Per second or approxiaately 6 percent of Stean-Electrfc Station. Th1s extensive study, initiated fn Harch 1979, fs thc seven consecutive day, 10-year frequency law flow oi'2.7 cubfc nccers pet scheduled far caopletfon tn carly 1552.

second at the Htlkes-Barre gage. 1'hen the discharge at the gage is belcw this level, Pennsylvania law prahtbtcs water wfchdrawals frc<a thc river. Thts would Based on our review of the draf suppIcaent re ort and cansultatton wtth the result ln SSES being shutdown far the duration of thc strcanflcw deffcfency. Corps of Kngfncers, ft appears that the use of the Cawanesque proJect, naw under canstruc.ton, instead of thc proposed Pand Hill project would: save an The applicants, Pennsylvania ?ower and Light Caxpany and thc Allegheny Oectrfc equivalent of 4,00D barrels of oil annually, avotd the cnvfror,cental cffccCs Ccopcratlve, Inc., have studied two alternatfves for providing lcw flc>> nor=ally associated with daR COnttruC:lon, eltatnatc possible objections frc<c auycntacfcn cne, a new sfngIc-purpose rescrvofr and another, whfch would Iccal residents or proper.'y owners, increase bcneffts to recreation and fish utilize storage frca an existing rcscrvolr. Another option would be to river and wildlife resources during low flow ccndftfans, and perhaps provide hc lcw fallow'r accept and accccradace the cccastcnal shutdowns necessary during flow regulatfon sooner than Pond Hill. Therefore, lt appears to be tn both the lcw strcanflaw. The applicants have recccrended constructlan of the ?and Hill ratepayers'nd taxpayers'nterests to frclude storage <n che Corps af low flow au~ntattan reservoir. The prcposed single-pumse reservoir would (under ccnstructlan) rather than build a ncw reservoir.

Knglneers'roject bC 1CCated On a headwater tributary ta the SuSCuehanna RtVer, With lnSuffiCfent natural StreanflaW far ttS fntendCd PurvOSe; CanSequently, P< Ping energy Sincerely, ccounting to about 2,417 ~awatt-hours pcr year would be required ta oatntafn ltS required fnflaw. This fs equivalent to the acaunt af electricity that cauld be generated fran using chan 4,000 barrels of ofl.

T< he repor.'ccagntzes that the case ccan<xxtc alternative to augaant lcw flcws would be the aadtffed operation of an cx!stfng upstreaa reservoir. However< >>e Office of Electric Power Peguiattan believe that the draft supplant did nat adequately explore that cppar.untty, whfch appears ta us co be CLc est pr actfcat altcrnatlve. The prfoary proJec.

Tbonas B. Zalligan FO+ Box 5 Soranton. Pa. 18501 August 18, 1979 Director Div Site safet? 4 Envirocnental Anal?sis U.S: Buclear Regulator? Ccnnissioh Va shington, D, C. 20555 Recent decisions of the Federal Courts have held that tbe

Dear D2rector:

yiecenealing of a nalor pro)ec4 such as Ber>>icg for purposes of Reference Draft Bnvircnnental Statenent environnental assessnent, is not yernissible under BBPA. You are BUBm-0564, A'une, 1979 Relate4 to tbe operation of the advise4 that the DES (BURDS-0564) cannot be considere4 ~

Ber>>ick Atonio Po>>er Plant (Susquehanna Units BRC I 4 2)

Docket Bos. 50-587/588 conyrehensive assessnent of Ber>>ick unless au4 until 't takes The folio>>ing coaents are subnitted on behalf of the Cit'secs into account the ~ulative effects of all relate4 actions. Zn or4er Acainst Buclear Dangers, Ber>>ick, Penna?lvauia, interveners before to be acceytable, BURBS 0564 nust address the inyacts of the yreZesed tbe BRC Atonic Safet? and idcensing Board in the above proceedings. ?Io>> Augsentation Reservoir and all other pro)acts 2nextricablF The Ayplicants, >>ho are responsible for tbe preparation of the linked to the 3er>>ick atonio yo>>er plant, but >>bich have not been Draft Rnrironnental Statenent (DAS), have failed to satisfy certain include4 in tbe Ayylicsnts ~ to 4ate These piecenealed yro)acta requirenents of the Rational uvirounentai Polio? Act (~) an4 na? seen individuall? Iinited, but they are cunulativeIF of a ~ is significant.ecenealing thereb? p2sce in )eoyard? the vaI242tF of tbe DBS in its present fern. illegal.'ailure he Ayplicants ere attenyting to cirawent BBPA be yiecenealing on the part of ths BRC to rectifF this fmdanentaL defect their assessnent of the Ber>>ick atonic plant's overall inyact on the in the DBS na? invite s Ia>>suit in Federal Distriot Court to halt bc=an envircnnent. The Ayylicsnts are preparing a separate DBS for the yrocess of environnental rev2e>> bF tbe BRC unt21 the Applicants tbe so-called Pond Hill Flo>> Augneutation Peservoir, >>hich is a ccnyiF>>itb BBPA as it reIates to yiecenealing violations.

transparent attenyt to circunvent B&A. The subnission of a separate H bF Alleghen? Blectric on sections of he W trsnsnissicn lines

~7 fron Ber>>ick is another exsnyle of yieceneaiing. The Applicants Corresyon4 t

>>211 kno>> doubt, at sane Iatter da ~, prepare other IL5's, am-a: ~ t:, a <<m'. X Sa at lt a yiecensal'ng such integral prospects as tbe ursniun fuel c?cle, t .-1 t. =a*or

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803 Forth Street

'geatherly< PA 18255 August 8, 1979 D<mector< Div'sion or Site Safety and Envt~ental Analysis

~ ~~P4l Huclear Regulatory C~<ssicn 4:R.<. W<<dZ< ~( Washington<

Dear s'ac D. C. ZO555

<<o~.~ ~~em.e<V<;<, S~y, Sc,4.+,

e a.~ ~4.W C4sa4 N y4.

'A wan to strcngly pretest your M>> B'av'~entaL Statist rec~en~<g that Pennsylvania Power 2< 1'ght Co be an oneratL".g license fcr the Berwick, ?A. ruclea= plant. Ln Section 6) onvi or total Upset of ?Osculated. Accidents<+

~ e4 SC~ ~S A Q~ LA.Qliwu you s~ate that the env'~entaL risk Wn a CLass 9 acc'Cent i> $ ii~ ~ M f1<.M CL.POc ~(

need not be ccrsidereC, because acc'Cent is fa" too low.

he procabil'ty o a ~<or the low probabUity< as you are aware Cid not Prevent the S~~~ ~ Peas,H accident f=.n ha"p~<g a. =hree PMe sIand cn~Pmch 28 in

~

Ba~sburg. <nat accifen<: brought out the ootentiaL fcr h~ and nechan'cal er.or in any nuclear'?Lant< no meter

~ ~~~ ~~~ ~~h t-~ ~k. how carefully built, ard we feel that no one shculd have o Live with <<he fear of another acciCent. Me advocate i.-.creased use of our oNn ah+Cant Pennsylvania coal, anC -he Cevelop-nent of synthetic and solar sources of energy to cc=-at our co I

energy cr'sis.

p J'C Sd CW p4c<.+ Q<s w 4gj.~ 'Ce have been A<<'ance in active <a he wsleton B=anch of the Suscuetma

-otesti-g the Licens<ag of "he Be.~ch =Lan

<sb.4L.~~ W-

~

wiLL ccn flue to voice ou-. cones~. Zn spec'cy"g bo ot!iers, ajcri<:y o. the ceo?is fn c< - a."ea a=e Ve we "' tha'-he ags'-st he opera-'on of the planb< ud.ess ~ ~ is converted

<'o anc her

/

source of e argy.

~~ + cpqoc.S~

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A

~~

A< ~,. ~su. <<K<L t-'4@4" .'// < ~

~ ~

P.. a.".4 < "s. F~cld C. Jeppsen

~~ po~ ~

104 Darey Laboratory Penn. State University University Park PPl i. Pa16802 19 August 1979 4 ~m )~~- Director, Division of Site Safety iQ)ca~ ~ PP',

and Earironnental Analysis U.S. Nuclear Regulatory Cenaission Washington, D.C

~~

pea.~. R.i ~

o L

20555 o~~ Centlenen:

gnclosed are ny connents on the Draft Enrironnental Stateaent for the Suscuebanna Stean Elebtric Station Un'ts 1 and 2,

.HUR3'564 ( Docket Nos. 50-3S7 and 50-38S ) ~ Please note that P

Q~

~c~

~~aodaL~

the informtion presented is hy oen and not necessarily the

~~c ~~~~

Q Pauacn )a4 ~, gc,

~ l~ position of is given The Pennsylvania for identification

Ãy connents consist of State Unirersity, which purposes one page of appendix, only.

of nain text

~ch I ~d like te affiliation

( beyond this

~~cLo ~~ aa

~

page) and ten pages considered in entirety have

~w @Le stop Sincerely, no

~t ~~ c4cLuJ slabs 4n. L ~ Lochstet a

$~ rv~ 4'4O

@we~~

~~~~ a~ ~

p4 veal

C~ents on HUH&-0332 The Long Term Health Consequences of Susquehanna Steam Electric Station JL Lochstet by'lliam Dr. Hilliam i. Lochstet The Pennsylvania State Universitye The Pennsylvania State Univezsity ingest 1979 November 1977 The Huclear Regulatory Ccmmission has attempted to evaluate the health consequences of operation of the J Susquehanna Steam Electric Station, Units 1 and 2 in its In the document NM -0332 (Draft), the HRC estimates the draft envirecmental statczent RKK - 05@

The health consequences of ra4on-222 re)eases from the excess-deaths per 0.8 gigawatt-year electric (GVy(e)) to bm uranium fuel chicle are estimated for the first 1000 years about 0.5 for an all nuclear economy and about 15 to 120 in section g.5.5. Xn evaluating the radon-222 omissions frcm the coal fuel cycle in section .8eoLoL ~ ( item Sz7 on page 8-10)> for the use of coal(Ref. 1) ~ These estM es are much too the staff recognises that the emissions continue for emillions of years"e Heithez aPProach is correct. Pootnote 12 email because they'gnore the health effects due to the of HRDC v. USHRC, 5t 7 F.2d 633 (1976) requires that the wastes slow release of radon-222 resulting.from the decay of be considered for their a~tire toxic life. Thus, the only radioactive components of the coal, uranium mill tailings, proper evaluation is with ne temporal cutoff. Such an evaluation is attached as an appendix to this statement ("Comments on HUREG- and of the tailings from the uraniu enrid='ent process 0332") This evaluation shows that the Staff has underestimate4 the health consequences ef both the coal and uranium fuel cycles. If'he health effects are est~ted by'he procedure used The HRC apparently Justifies its allowing of health consequences by comparison with background ( P. 4-'27 to 4 28) ~

by the ERG'hen the excess deaths are about 600,000 in the This is totally irrblevant and contrary to HEPTA, HEPL requizas nuclear case and .twentythousand for coal The estimates presented an evaluation of the benefits and all of the costs of the here are all based on the production of 0,8 GHy(e) ~

Pederal action under consideration ( Susquehanna 1 4 2) ~

Badcground ra4iation is not a )ustified federal action. The Radon Produced b the Uranium Fuel C le term caused by bacbground cannot,'uscify other hara. This impreper comparison'f. costs to badc~und is contrary te The prod~ction of 0.8 GWy of'lectricity by a DHR wQ1 the decision in Calvert Cliffs Coo~ting Committee v. USiv",

449 P.24 1109,%15 (1971) ~

require about 29 metric tons of enriched uranium for fuse Vith uranium enrichment plants ooerating with a 0,24 tails The opinions and calculations presented here are my own, and not necessarQy those of The Pennsylvan'a State University. assay, 146 metric tons of natural uranium w~ be required.

Ãy affQiation is given here fer identification purposes only In the absence of the Q~z R, 117 metric tons of depleted ursus would be left, over, Viith a uranium miQ which extracts 96/ of

Radon?roduced by the Coal Fuel Cycle the uranium fron the ore ( Ref. 2), a total of 90,0CO zzetric tons of ore is nined, containing 152 netMc tons of uraniun, Zten 2 i of Appendix A of RURBG-0332 ( Ref 1) assunes a The uraniun zd11 tailings will contain 2.6 kiho~ of 75)( capacity factor, which foz a 1000 Kfe plant would produce thoriun 230 and 6 metric tons of uraniun. As Pohl has pointed oun onvy 0 75 GWy(e) ~ A capacity factor of SZyf will be. used here, (Ref 3) the thoriuzz -'230'decays to radiun - 226, which in turn The production of 0.8 G'iy(e) by a coal plant operating at 40)(

decays to radon <<222'his process results in the generation of 3 9x10 8 caries of radon-222v with che ttue scale deternined efficiency, using 12,000 BTU pez pound coal would require by the, 8x10 year half life of thoriun - 230 2,5 nillion short tons of coal. This is close to the value of

'the 6 zzetric tons of uraniun contained in the nil1 tailings 3 nillion tons suggested on page 9 of HUREG-0332 ( Ref 1) decay by'everal steps to radon - 222 thru chorion - 230, This There is great variability in the anount of uraniun orocess occuzs on a time scale governed by the 4.5x109 year half life of uraniun - 238z the na5or isotope present ( 99.3g. contained in coal. An analysis of coal sanples at one T'FA plant The total anount of radon - 222 which vill result fron this reported by the BPA ( Ref. 4) indicates a range of aixost a decay is S.6x 10 curies.. factor of ten in uraniuzz content EXsenbud and Petrow (Ref. 5)

The 117 zzetric tons of depleated uraniun EZun the enrichnent report a value of about 1 part per nillion. A recent survey process is also uainly uraniuzz - 238 which also decays. The by the USGS based on several hundred 'san?les suggests that decay of these enrichnent tailings tesults in a total of in the United States coal contains an average of 1.S part 1,7xlO caries of radon <<222 This is listed in Table 1, per nillion of uranizuz( Ref 6) ~ Both values of 1.0 and 1,8 p?cz along with the other radon yields wQZ be used here Thus 2 5 thousand ulllion tons of coal will contain 1

Zt is instructive to cozzpare these quantities of activity between 2 3 and 4,lgkilogzaus of uraniun Using the assunption to the activity of the fission oroducts which result fron of HURBG-0332 (Ref, 1) that there is 99)( zarticulate rcooval

-the use of the fuel which they are associated with The total Erozz plant eaissions, 1C of this uraniuzz will be:dispersed fission product inventory z'esulting fron O.SGby(e) with half into the air and the renainder carted away as ashes for land Lives of 25 years or nore is about 10 7 curies, This is nuch burial Table 1 indicates that with 1 0 ppu coal the uraniun less than any of the numbers in Table 1, Ve should be noze careful with these tailings, in the resulting ash will decay to a total of 3 2x10 curiae

of radon - 222, while the stack cmfsslons will lead to 3.2x109 Evaluation of Health Effects - Nuclear curiae+ yor 1.8 pyn coal the values are 5igxlO~curfes from ash At present,some recent uranium mill tailings piles have and 5.8x10 9 curiae from enf asians 2 feet of dirt covering. Xn this case the EPA estimate (Ref. 8)

Evaluation of the Health Effects is that about 1/20 of the radon produced escapes into the air.

It is necessary to evaluate the number of deaths which result This factor of 20 is lfsted in Table 1 and is use'd to ffnd the from the release of one curie of radon - 222. Foz,the ouryose of effective releases. Thus the 3.9x10 8 curfcs of radon which results this evaluation the population and population distributions from thorium in the nill tailings results in a release of ara assumed to remain at the present values, This should provide 1.9xl07 curiae into the atmosphere, which with ths NRC estimate a good first estimatei of 4.8xl0 deaths par curie results in 90 deaths. With the EPA estimate 1900 deaths result A similar treatment aoplied to NUR15-0332 (Ref. 1) suggests that a release of 4 i800 curios of radon - 222 fro". ths nines ( page 114 would result in 0.023 8 6xlO curiae of radon from the uranium in the mill tailings excess deaths ( Tuole la, page 18). This orovides a ratio of results in 200,000 dead for the NRC estimate and 4.3 million 4,8x10 deaths pe: curie, Data from chapter Iv of ogsNO (Ref, 7) for the EPA estimate. It is here'ssumed that no future generation suggests a value of 1 7xlO deaths pcr nate as a lower Xfnft will sca fit to take any better care of the nill tailings than Ths value of 4 8x10 deaths per curie will be used here as the is presently practiced.

The uranium enrichment tailings are presently located in the NRC estfmatai It is understood that this is very ayproxlnate.

eastern oart of the country. It is assumed that these az'e buried

'The EPA has e'blunted the health effects of a model uranium near their present locations. Radon will not escape so easily mill tailings pile They estimate a total of 2CO health effects through wet soil. P reduction factor of 100 is used to estimate (Ref. 8, page 73) foz a yfle which emits at most.20,CCO curfes this effect. The accuracy of this estimate depends on the particulars of radon - 222 for 100 years. The resultfng estimate is of ths burial which <<an only be pro5ectcd. An" additional factor 1.0x10 deaths pcr curie and will be used here as the EPA of 2 is used to reduce the effect due to ths.fact that much~

estfmateo of this radon would decay over the ocean rather than populated

coaoensation is taken for the greater population IK cll Si laad areas. Ho density near che poiat of release as coapared to che uranfuu aill It is obviously very difficult co estate with aay orecisioa tailfags pQ.es of the western states Hfth this cotal reductfon hov aaay beseech effects result frca che release of a gfvea curie factor of 200 the HRC estfaate is 400,000 dead while the EPA of radon - 222 fran soae specific site in the west The est~tee value is 8 afllfon presented here differ by a factor of 20. This aigat best be used as a range of expected deaths The reduction factors used Evaluation of Health Effects - Coal here are ~e estfaates in soae cases, aad could be iaproved It is assuaed that the ashes froa the coal plants will be upoa. Changes ia public polfcy could also c)~ge che aaaner buried ia a nanaer siailar to the tailings frou the uranian in which this aaterial is disposed, thus greatly chaaging these factors. In particular deep burial could practically

~ arichnent process, Thus a reduction factor of 200 is used fa chis elfafaace the escape of radon to the ataosphere (Ref. 8) ~

case also. Lgafa the higher population density is ignored. It is Laportant co coapare Table 1 here with Table 1 of The particulate which is released iato the air by tbsp coal HUM-0332 tRef l)e which shows 0.47 dead for tbe nuclear case pleat is taken co contain 1$ of the contained uranfua Siace shd at aost 120 dead for coals'hese last nuabers totally ignore aost such plants are in the eastera part of the country it is the ~ fects of long tera radon eaissioas, whfoh result in

~ stfaated that half will fall into che ocean rather chan oato ac least 100 cfaes higher aorcalfty These long csra effects

?and A second factor of 2 is used to reduce the effect of are aot oaly sigafg.canc, but doaiaate the effect, the resulting radon due co the fact that soae of this radon It is fuportaat to use Table 1 to coupure the relati,ve will decay over ocean as with the radon fron the uranian ia che risk of the auclear aad coal ootfoa in their present focus

~ nrLchaent tailings. Lgafa no coapensatioa is taken for the In thks case deaths due to all causes considered ia HUREG-0332 greater population deas'cy near the point of release This caa be ignor<<i as insignificant, since they are so saaU. ~

gives the total reduction factor of 4 showa Ln table l. .The absolute au=bar of deaths per curie released is ir"elevant Pith these reduction factors applied to che radoa released it enters in both cases. The relatfvs risk is deterained since by the ashes and eafssfons, in the two cases of 1.0 ppa aad solely by the qsatfcies of radon - 222 generated ard the reductfon 1.8ppa uranic coateat coal, the health effaces are calculated. factors. Unless there fs a clear decision to treat s coal ashes These are showa in table 1, aad range fros 7,700 dead froa ashes dffferea ly froa uraniua earichaeat tailings, the health effects and 3 ~ 800additioaal dead froa airbora eafssfoas for 1.0 pus thea the tailiags will be 50 tines greater since there fs coal in the HRC estimate to 290,000dead fron ashes aad 140,000 dead froa airbora releases in the case of 1.8 ppa coal ia the Epf est~te.

50 tines rore uraniun there. The nuclear option renains nore Table 1 hatardous than coal unless the releases fron all of the tailings Energy Source Excess Hortality per O.S GNy( ~ )

piles can bt reduced below the releases fron the airborn due to Radon - 222 enissions particulates of th <<oal olant. This is not the present policy Origin of Radon Reduction Deaths Additional Cogent Radon Generated Pactor NRC There is a typographical error on page 25 of NUREG-0332 ~ Curiae Peference p33 is listed there as being in volune AS of Scinnce, wher eas it appears in volune 144. 3.9xlOS 20 . 90 1900 Acknowledgnent The above co=ants were inspired by the 5 July 1977 S.F11 200,000 I .3xlO testinony of Dr Chauncey R. Kepford in the natter of the Uraniun in Three File Island Unit 2 (Docket No 50-320) operating license Enrichneut 1 7xlO entitled: " Yealth effects Conparison for Coal and Nuclear Tails Power"~

Coal 1 0 pps U Ashes 3+2xlO 7 >700 1,6xl05 3o2x109 3,SCO Particulate Coal 1 S ppn U Ashes 5,Sx10 1A,,OOO L 2 e9xlO IL L Air ea 9 5,Sx10 6,SCO 1,4x10 Particulate

10 LUZERNE COUNTY PLANNING COMMISSION References CNTCR5TATC HICNWAY SYSTCM

~ <<<<<<<<<<

JOHN L I<<OONAuc cl<<L NHealth Effects Attributable to Coal and.Nuclear FueL NOCL n CAVCALY Cycle Alcernativese HUREG-0332,DraftF U.S. Nuclear Reguiahory LVJC <<AC COVII OONALO J. NVMANSFS W mFNN <<Yecsl Cocnission (September 1977) JONN O<<FNNOO SO <<LIT 2 NEnvironnental Analysis of The Uranflzn Fuel Cycle, Part I- SCANAAO J ALLAONCN SFAIASY LSSIOS ALLAN NAJON STSIFS AAVLOVCN L L<<nzF<<NS cess<<FY cousz Novae VFSXCS.SAAAL FCNNSVLVAFCA FQll Fuel Supply" EPA-520/9-73-003-BF U.S. Environnental Protection JONN WALOI AFA<<ICI c<<F, ln CFF Agency, (October 1973) ~

Jaguar 10, 1979 R.O. Pohl, "Health Effects of Radon - 222 fron Uraniun IFdJlinga Search, 7(5) ~ 3L5-350 (August 1976)

P.IJ. Bedrosian, D.G. Easterly, and S.L. CunningsFNRgdiological Survey Around Power Plants Using Fossil Fuel" HERL 71-3; United SzaCea Xuclur Eagulazozy Commission U.S. SEnvironnontal protection Agency, (July 1970) uashfngcon, D. C. 20555 H. Eisenbud, and H.G. Petrow," Radioactivity in the Atzsospheric kccancionc Dizeccor, Dfvfsfon of Slee Saiacy and Envfronnencal inalysfs.

5 Effluents of Power Plants that Use Fossil Fuels, Science Cenclenen c

~LLSC288 289 (1964) The Sustuehsnna Scean Electric Station is locace4 in Lucezna County. Tha 6 V.E. Swanson et al,"Collection, Chcnkcal Analysis, and Evaluation Draft Environmental Scacemanc (ECEEC-O544) oi the D. S. EOOLaar Eagelacory of Coal Sanples in 1975", Open-file resort 76-L68, U.S.

Department of the In erior, Geological Survey, (1976) Cozndufon eu reviaved by che Luzezna County tlanning Conaiasion cnl Augur 9 ~

1979, ac ics zegular nonchly nearing at Which a <<Dslrcn eaa present<<

7 Final Generic Environnental Statenent on the Use of Recycle Plutoniun in Hixed Oxide Fuel in Light A'ster Cooled Reactors," NUR5D-0002. U.S. Nuclear Airer dua consideration, a notion vas sade, ascended, an4 unanfnously Regulatory Corzmissionl (August 1976) carria4 co mate Lvo (2) zecocsnndacfons co chs U. 5, Nuclear Eagulacozy coonfs 8 See Ref, 2 ~ loni 1~ Thar an Emergency Evacuation Plan be conyleced by chs Lusazna Councy Civil Defense Agency before cha Sustua-hanna Scean Electric Session goes into oyeracfonC and