ML18031A236

Opposes Nuclear Reactors & Waste of Electricity

ML18031A236
Person / Time
Site:	Susquehanna
Issue date:	08/14/1979
From:	Moses L AFFILIATION NOT ASSIGNED
To:	Office of Nuclear Reactor Regulation
References
NUDOCS 7908200363
Download: ML18031A236 (60)

Text

REGUL RY INFORMATION DISTRIBUTI SYSTEM (RIDS)

ACCESSION NBR:7908200363 DOC ~ DATE: 79/08/14 NOTARIZED: NO DOCKET FACIL' Susquehanna Steam Electric Station~ Unit lr Pennsylva 05000387

.50 388 usquehanna Steam Electric Stationr Unit 2r Pennsylva 05000388 U AUTHOR Al FILIATION SESgL ~ Affiliation Unknown RFC IP, NAME REC IPIKN'I'FFILIATION Division of Site Safety 8, Environmental Analysis

SUBJECT:

Opposes nuclear reactors I waste of electrical powers DISTRIBUTION COOK: C0028 COPIES RECEIVED:LTR g ENCL ~ SIZE:

TI TLE: ENVIRON COMMENTS ~

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CODE/NAME'CTION:

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Q!fi>7p Io .i'horn it may concern; In response co che 5.'~.'. w~ncina commencs rolaiina to the ooer .cion of .Z .8cL. os.i Suso"ehanna nuclear popover plant, to me nuclea.r oower plants reminZ .ne of :.ussian Roulette, but instead of aamblirsr on one life chey bramble on millions of lives 3 anythina in the'r vay.

~~

uclear po;ver plants up to now are nor.'o ce trustees or the people chat (chinch they are controlling chem. It;vas proven ac the 3 mile plmt near Harrisburg thac up to corlay they Con' ven know wh*t co ".o with tne ra~ioactive w=t r or waste. i'hese nuclear plants a,iso remind. ze of Ceinv hanied. a shrapne~ <<-renal an~ beina coli to pull che pin ani hol.i it is a 'u~ or a live one.

it noc knowing if How io 'ook at Ceins. power conservative no nee~ for nuclear power plots. In the pasc l5 to 20 years people thacmove0 inco che 2ack Mountain wanr. street liahts or. every corner bui w~nt me taxpayer to pay for rhem, an'ct as it was y ars ~go, if a light was seen ro 'oe ne d.e3. by a barn or som'ething the in"iviiual paii for it. '1.'he roaZ I live on is about miles one an" not a, public stree c ia.~p is on ic. - I .ihink .if you.:vant cour.try livira then

'on't look for a ='treet light on verv corner or power pole. An~~ then there is the automatic

vashers ani iryers which some peo "le use ihem every ~ay. I ion' chink that is necessary especially wnen you think of che po

ver chat eoes into ch. elec eric spryer, some exercise ivoulin' hurt. ih n cher are some scor s as I nave seen

';:avon@ about ." ce" ev'siors turner'n ac one time, mZ enouah :irhts curnei or. co use a m'croscope wic.'aout ics irht on. ~his is only a few of the ways I see electrical -.o;ver wasted.

'A />w ~ Truely Yours, Lou Noses

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~<!Ktyyg Io hou it Cay conc!~C r!Lating to ihe op!ration of :-.p.al. ':a.

Iuso ehanna nuclear poser plant, co =e ruclear poser plants remini ae of;ussian Zoulec<<e. but insteai of ganbling on one life chey gamble on millions of Limes ani anythirg in their eay.

'ucl!ar poser plants up to nom are rot co ce ~~m9e .

trus:ei or the~people char. (tnimj they are controlling %em. It mas promen ac the 5 nile plant near Harrisburg that up to corny they ion'c

~en knoe chic co <<o mich che raiioactire eater or taste. Ihese nuclear plants also renini me of ceing ha" iei a snrapne'.enaie a='eing

~:9 toll to ~u11 the ~i ani hoii it not kneeing it a ui or a <<ime one.

Xos to 'ook at being poe!r oonsermatime tn" ii't o neei for nucl!ar poser pla=ts. a the pate 15 to à years people that=ore% ines ch! Zack Xo<<win mant s:r!et lighter, e!ery cor=er but met che tax-ayer to pay for t'iem. eni n it years ego<<<<f Ligh- seen co be

"ne!iel by a barn or something the iniimiiual as mas a mas paii for it fhe roe I lime on is

~ aeon't miles <<ong an<< not a pu~ <<c s rect Lamp is on j

I'cd I thirJc i 7ou mant coL try 1 T~ then ion't look for a creet lighc on every corner rtluESG-f755 8 . g, or vomer pole. in'hen there is he autos tie mashers ani iryers ehich some people use them

!Ter7 ay I ion t chink that is Accessary especially shen you think of the pose: that goes

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o the elec<<ri Ty!T son! ze c se m u ht."t. hen there ar. mone sco!!s as '."~me seen 1.ing atcu ee sions u- e on ac "e tine, eni !nougn Lirhts turnei -- to use ~ca Z mic..sco-e micnout I-J 'irht on..h<<is is only '

a em of the mays I see elec:-.ica poser mast ~

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~~pw ~ lou Roses P..).r~ gaming

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Septenber 4, 1979 9lp~jo>W-iyrgL Mr. Donald E. Sells, Acting branch Chief cJ~ Envitonnental ProJects branch Division of Site Safety and Environnental Nuclear Regulatory Connission Nashington, D.C. 20555 Analysis'.S.

SUSS57EHAh. SA SES DOCRET NOS. $ 0 357 l599EN75 ON DES AND 50 5bb ER 100a50 FILE 991 2 PLA Ssd D<<ar Mr. Solids Attached are PpbL'9 ccnslenta on the Draft Envirlinental Stateoont issued by NRC ln June, 1979.

JSF I557SS Copy tol Mr. Paul Leech Mall Stop P522 U.S. Nuclear Regulatory Connission Nashington, D.C. 20555 T 9090 T0$ ~

1. INIRcooczlcxI 5. THE PLAVT Section L.], pg. 1-1 - The issuance of a National Pollution l. Section $ .2.4.1, pg. 3 The perking area hold up pond has been Discharge Elimination System (NPDES) permit Ls a necessazy deleted. See revls<<l FLgure 2.5 which is attached.

prerequisite for the Issuance of an operating license by the h Nuclear Regulatoxy Ccumlssion. The permit was issued by the 4. ENVIROQKfl'AL EFFEC!8 OF STATICXI OPERATION pennsylvania Department of Environmental Resources on July 51, 1979. Secticn 4.3.1, pg. 4.2 - The effluent Limitations, monitoring requirements, and other standard and special conditions of the

2. THE SITE Ccaxawealth of Pa. Water QwQLty Nanagement Pezmit (No. 407620$ )

have been susperseded by the terms and the conditions of the Section 2.$ .3, pg. 2 Figure 2.5, Water Use Diagram has been hPDES Permit (No. PA<047325). See part C, paragraph B of NPDES revis<<i per the NPDES pezmit. The parking area hold-up pond has peznit.

been deleted (see revisal Figure 2.$ , attached)

Section 4.$ .5.5, pg. 4-5 - Inhibitors containing chromium will be Section 2.3.4.1, pg. 2 On "line 1" - The monitoring schedule used Ln the clos<<l cooling loops.

ranged from twit~ weekly to quarterly. On "line 2" - The monltoxing by Ichthyologicsl Associates since 1971 has been Section 4.4.2.1, Pg. 4 9 Although Lt Ls true that specific pool weekly instead of dally. Line 8 should read total iron "and by pool comparisons have not been made, the applicant's fecal collforms". Figures 2.5 end 2.6 are reversed. consultant, Ichthyological Associates (IA)~ has czmpazed water quality and aquatic organisms (species xmmbezs and relative Section 2.5.1.3, pg. 2 Add to Line 12; "An American abundances) ln the Intake-discharge pool to that at sampling Peregrine falcon was observed Ln 1975.z stations Ln pools up and downrlver. A review of Fhyslocochemlcal, algae, zooplankton, benthos, larval fish, and Section 2.4.2, pg. 2-11 - Local meteorology adult fish data presented Ln IA Annual Reports from 1972 through 1974 will show that ample comparisons have been made. Overall, The statement Ls made that Ln 1975 data recovezy for the )oint the results reveal that aquatic Life Ln the Lntske<lscharge pool frequency data at the 9.6 m level was "only abouz 708." Ls not unique Ln cccyazison to other areas as~led with the Applicant data show about 908. This Ls based on the wind speed exception that this pool Ls an extensive recovezy one caused by and direction from the 9.6 m lovel and the temperature acid aine drainage pollution which enters at various locatlcns differential between 91.7 m and 9.6 m as xhe primary system. If upriver. For example, Ln 1974 Gale snd Noh'1976) eagled fish these temperature differential data were missing, the temperature spawning sites about 6 km up- snd downriver from the intake.

differentials between $ 0.S m and 9.6 were used. They determined that "no species avoided. polluted waters by spawning ln the tributaries or Ln clean water below their The years 1974 and 1975 did have an unusually high occurrence of zzzuxhs.w 'Ikey also found the most kinds of fish eggs ln "shallow unstable conditions. These meteorological conditions are not water with strong currents." Such areas are between river pools.

fully understood. The data may not be representative of long Furthermore, ln 1975 Tuttle (1974) s~led adult fishes with ters conditions but they aze zepresentative of conditions which nearly equal effort at five stations. He captured about three occuzred Ln 1974 and 1975, and therefore, Applicant believeslt tWs as many fish at Falls, a relatively clean water control should not be delet<<l. station about 65 km upriver, than at the Intake-discharge pool (SSES).

For the year 1976 the wind speed and direction data Indicates a predominant wind fiow from the west-southwest (13.501 of the The tezm '"pool" ls pexhaps somewhat misleading. The Susquehanna time). A secondazy flow occurz<<l from the west 12.18\ of the River during low water periods Ls not a series'of pools that are time. These figures differ slightly from those Ln the DES, isolated from one another by shallow riffle areas. Even during although the directions aze Ln agreement. The frequency of caine the lowest flows at which the Susquehanna SES vill be permitted was 1.51\ for 1976 at the 9.6 m level, rather than the 4.6% to operate, there will be ~le flowage between the pools so that frequency shown in the DES. fish and other oxgenims csn pass freely.

References 5. Table 4.1 - This table eoacafns several typographical errors. A copy of the table vith cozrections fail<<at<<4 unior separate cover vill be fozvarded Cele, N. F. and H. N. Mohr, Jr. 1976. Ffsh spavnfng ln a large Pennsylvania River receivfng aine effluents. Proc. Pa.

Acaf. Scf. SO: 160-162. 6. Table 4.5, pg, 4-16 Tuttfe> L. R., Jr. 1974. Fishes. Pages 557<91 in, Aa Staff aslaytlons regazdfng Tuzbfne Sufldfag releases do not ecological study of the North Sranch Susqushama Rfver fa allov credit for the leakoff collection systea.

the Vfcfnfty of Servfek, Pnmsyfvsnfa, Progress Report for the Period Jsxusxy-Dee>mba 1975. Ichthyologlcal Staff as~ious regarding tho off-gas systea releases axo Associates, Inc., Sezvfck, FA. sfgnlffcaatly higher than the ERAL os<<fasces. It appears this fs due co a failure to ad)usc the charcoal absozpcfon factors for

4. Section 4.4.2.1, pg. 4 An <<ntzafzaent snd fapfngeaenc toapozatuze >

progrsa vill be pzovfdod coaslsteat vfth NPDES pezuft (No. PA-0047525) zo>yzfrenencs. Applfeant believes that fodfne releases should be reduced due co tho uso the leakoff colleetioa systea.

The applicant has stated that fapfngeaeat sad entrafzcmnt vill be "zelatfvely snail" because of unpublished studies done by Ichthyological Associates, Inc. at the Hunlock Steaa Electric

. Statioa (Hunlock SES) fn 1974-75 (Ichthyologfcal Associates 1. Table 5.1, pg. 5.5 - This table has been updated to reflecc 1975). The Rmfoek SES fs a saall, coal-fired station operated <<hang<<a fn sszy ling locations and station aouencfature by the Lux<<zan Electric Dfvlsfoa of the UCI Corporation, corrections. 'The lover Ifafts of detection have also been gfagston, Pennsylvania. It fs locaced about 15 ka upriver froa revised per NUREC 0475. A copy of the table vfth cozzoctions indicated vill be fozvardod under separate cover.

che Susquehanna SES Q utilizes a caco thxough cooling systea that dravs about 245 a /aln gf vater through tvo fatske esaals vfth velocftfos up to 0.25 a /s. Once each aoath, froa May 1974 6. EhVIRlZ>MENIAL IMPACT OF POSIUIAIED ACCIDE>ZIS through April 197S, fzyfngeaent ssaples vere collected.

Extrspolatfoa of results fr<<a these Ifafted ssaples shoved that No Cozmencs pproxtta eely 250 kg of fish flesh vore fapfnged throughcuc the oae-year period. It vas therefoxe concluded that fapfagsseat 7. hXED FOR POMER losses of about 0.6 kg/day veuld have a neglfglble effect oa the spore fishery of the Susymhauna River. So<<ause the Susquehanna l. Section 7.1, pg. 7 The present schedule for eozsserciaf SES ac asxfzam generation vill vfthdzav only about 150 a /ala, operation of Unit I fs tufy> 1981 and for Unit 2, Oecober, 1982.

applicant concludes that fapingoneac losses vosfd be sfaflar to Lfae 7 4970 MN ls vftheuc UCI, those experienced at the Hunfoek SES. Larval fish'vere also sssyled ac the Hunlo<<k SES once por nonth fn May, JLme an4 July, 2. Sectfoa 7.5.2; pg. 7-2 - The ammalfzed constzuccioa cost of 105 1974 to evaluate entxsfnaent. Momt densitfos of eatrafned larvae ailllon fs fz<<u FES~. The cost of the plant to PP8L in tho $ ER-vere alvays loss than one laxvae/a . This vas <<oacludod to bo an OL is forecast to be $ 1.9 billion. Nfth an assuned 15\ levelfzed acceptable loss because less thea 58 of the river flov as dxava annual cazrying chsrg ~ rate a earzyiag charge of $ 28S aillfun per into the plant on tho 'days ssspled. Ic weld not soon year results.

unreasonable tn.expect sfaffar results at the Susquehanna SES. A copy of this report to be provfde4 under separate <<over. 5. Table 7.4, pago 7.5 appears to contala tvo errors. First, fiza puz<<hazes are accented for tvlce. Noxaalfy, these transactions References are either added to total <<apacitors or subtracted fxoa peak load. Since 7$ Mxe are facluded in total <<apacftles, this anooat Ichthyologfeal Associates, Inc. 1975. Ifmloek Stean Electric shou14 not be subtracted fx<<u the Hinter Peak. Second, f<<z years Statfoa Ecological Study, Progress Report for the Period Nay 1982 through 1985, only Unit 1 vas subtracted fr<<a the total 1974 through Apzf1 197$ . Ichthyologieal Associates, Inc., capacities to calculate reserves vlthout Susquehanna. Unit 2 Soxvfek, PA 107 pp. shou14 also be deducted.

S EYALUATIOM OF PECPOSED ACTION'

~ Table S I - The listing of nuclear fuel 7IT7~ appears to be one census>>d in hg/day order of nagnitude too high.

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9. SEuEFIT~ ANALYSIS

l. Section 9.a, pg. 9 1 - Econosdc Costs ~ aW441WL

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Tbs fuel cost for the first fuII year of operation should be SS1 nillion as noted on Table CAS 1.2 of the ER4L. ~ se ~ E>N

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2. Table 9.1, pg. 9.2 - SenefitMst Suaaazy The energy and capacity in the Direct Senefits section are for ~ ~ le@<<>

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the vhole plant (2 units) ~ hoeerer the Econoaic Costs are PPIL>s AO400 share of the first year cost of Unit ~ 1 only. the direct bsnefits aad the ecoooaic costs should be stated on ~ consistent basis. >>>WM ~W CCwAL ~$ >>CI

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PPaL Hr. Howard J. Gro~ Seycehcr 10. 1979 244 SOQIII totI*S $ 21 ~ 12, IIASISION~ ~ 4 ISeptember

~ 201 tlI0 II~ I ltl22 424 4441 Otic hospttals tn the area cast be considered 1n emergency 10, 1979 planning, and to insure thts, Pp&L has been actively purstfjng the fornllation of adequate cnsrgcncy plans>>tth the Pennsylvania Bsrgcncy Nnagcsvwlt Agency, the Collnd2ta and Luzerne County Civil Ocfcnse orgqntzattons and others. PP&L Hr. liard J. Gros~n, Executive Otrector believes that area hosptzals are addressed fn the energency Econcntc Ocvelo~ Counctl of plans daveloyed by these agencies.

Horthcastcrn Pennsylvania P. 0. Hox 777 SEE ~Z 4. The Safety Evaluation Report (SER) is prcparef and issued by Avoca,'Pennsylvania 16641 HRC and ts a necessary step prior to begtnn1ng puhl1c hearings on safety-related fssucs tnvotvtng Susquehanna SES. The SER ts unlikely to be issued before Spring. 196. If you request Ocar Howard, a copy of the SER fross NRC, they will forward it to you when tt ts issued.

Your review of the Huclcar Regulatory Ccccltssfon's Oraft Envtror~tal StatcnSnt (OES) ts apprecfatcd. In response to t% qucsttcns If you require additional tnformttcn. please feel free to contact ref Sad fn ycur AuguSt 27, 1979 lettCr. wC Offer the 1'Ollavtngs

l. As noted in the OES, the Susquehanna River ts the source of water neHcd for the operation of Susquehanna SES. In 1976, the SRSC forn2latcd rcgulattons requiring flew auyxntatton by users of Susquelmna Rfvcr water under certain cor4ftttons.

To acct this rcqutremt, PP&L proposed to build the Pord Hill Reservoir Project. An aypl1catton folI Plan approval of the project was subslttted to SREC tn Harch, 1979. Tie SREC has not couplet<<f their revtot at thfs tice.

SRSC recognized that awe projects were well under>>ay when t!>>ltr regulations >>ere issued and that au~tice factltttes cxltd not be built prior to oyerattcn of the user factlt+.

Thc regulations provide flcxtb11tty tn establishing an effective data for each fac111ty consistent with.reservoir approval'nd c."nstructton schedules. ~<dad that apyrovals are granted tn a ttcely canner, PP&L expect to puz tLe Pond 8111 Project tn scrv'.cc 1n 1983.

Z. All the faciltttcs tn the flocd plain relet<<f to operation of the Susquehanna SES are dasfgncd to wtths~ w ICO-year.

. lood and @cain opcrattonal. Exznytcs of such .scil.1 ties are t..e ~sston z~rs and the river water tntake 2~chore.

tcyac: of flcodtng substantially above the 100-year flood level is- yrtnartly plant sh2~ due to loss. of opcrabtltty of the river water tntake. Since t!>>2 Plant elevattcn 1s ayyroxtnatcly 160 fe t above the river level, th~ would be no tcyact and. consequently, no hazard to the public.

3. PP&L has ~e arrangeocnts wt h M Scrwtck Fosottal fcr the

~wee of fn'urcd persons who sltgnt also he radtoacttvely conwtnat~. Ire Icr>>1ck Hosyttat is the neared hosyt tel ts -".e Susquehanna plant and ts the logical chotcc fcr thts type of service.

SUSQUENhhWA SES PPaL CtfLENTS 0'l DRAPT ENVIRONMENT STATBfBlT DES Suersa aad Cocci usioas It Ls suggested that aa additional iten be added to the list of potea-tial inpacts, stating, as indicated in ScctLoa 4, that the project vill have niafnal inpacts oa the Susquehaaua River.

Eay 29, 1980 Sectioa 1 Iatroductiou

1) Section 1.1 Para. 3: A44 "plus coasunptive usc" atter "thc Q7-10 value".

Mt. B. J. Touagblood, Chief Licensing Branch I 2) Section 1.2 Para. 3: The Applicaat vill also obtaia accessary Division of I,lceasing federal petnits (Corps of Eagineers, etc.)

U. S. Nuclcat Regulatory Cosrsissfon

'Mashiagtoa, DC 20555 Section 2 The Site and Its Environs SUSQlXELVNA 8ES Docket Nos. 50-387 I) Section 2.3.3: It should be noted that one property ovaer has COMMQCS ON POND EIIE DES aad 50-388 developed a spring vithia the proposed ptojcct boundary, as a ER 100450 PIIE 991 source of vates during part of the year. This spring is ia the PIA-490 vicinity of the iaaundatcd arcs aad, depeading oa its erect location, nay be fecundated. This vas shovn as the spring oa the

Dear Mr. Touagblood:

south side of thc reservoir on plate 17 of ow Novecher D, 1979 tespoasc Attached are PPSE's cosueats on the Draft Supplencat to the Draft Eaviroaneatal Statcnent related to operation of the Susquehanna Stean Use of this spring as a vatcr supply coatee vould be discoatiaucd Electric Station (NUREG-0564). If you have aay questioas oa these after project conplction.

coerscats, please contact U. E. Barbcrich (Phoae 21S-821-5833).

2) SectLoa 2.S.2.1 Para. I: Ue are uaavare of aay sanpliag by DER La Very truly yours, Poad EL11 Crash. Sanpling of Poad Eill Creat referee<<e4 ia Appendix E vas by coasultaats to PPSE. The tefereace to the ERNE shoul4 probably be to Appendix E of the ERNE. This reference iih)

N. U.

M Cuttis 3) should also be added oa the footnotes to Tables 2.2, 2.3, 2.4 aad 2.5.

Page 2-22, Reference 29: This reference 24, vhich specifie4 thc date cortectly.

is redundant to reference gTR:ng 1Q Section 3 Reservoir Descri tion Attaches at 1) Section 3.1 Para. 2: This paragraph should be clarified to iadicatc the 287 a (940 ft.) norsal vater ptface project vould have an active storage voluae of 12.5 x 10 n (10,100 hc ft.) and eevvsrevAIIIA rows ~ a LI Ocr CONsavr

a total storage volens of 16.0 u 10 6 ~3 (13,000 Ac-ft.). The Section 4 Envirosaental Effects of Constructtou and aration higher, 299 ~ (981 ft.) HSL noxnal vatcr s>/rfxJce proJect, vould 10 a (22,000 Ac-ft.) and have an active storage voluae of 2761 y

a total storage voluae of 29.7 a 10 a (24,000 Ac Ct.). Based on Section 4.3.1 vill be Para 5x As significant voluaes of reaoved froa the borrow areas, fillaatcrtal tt vill be taposstble to a study of the opttaea daa height, storage capacity of the stte is reestablish the original contours; hovever, the areas vill be topographically liatted to a daa viP g crest clevatioa of 310.9 ~ regraded so that they vill drain properly, topsoil vill be replaced (1020 ft.) HSL> providing 38.S r 10 ~ (31,200 AC-ft.) total and suitable landscaping vill be provided.

storage. This study indicated thc aost ccoaoaical pro Jeer, vould have a noxaal vater surface elevatioa of 299 a (981 ft) HSL., The vill design for the proJect is being prepared based ou this height of 2) Section 4.3.1 Para 6x Drainage features such as culverxs be Des.

provided tn the final design for the access road vhere necessary to control ruaoff froa the road as vali as xunotf interceptc4 by the Section 3.1 Para 3x The last sentence should be clarified to note road.

2) that the dravtags provided in the DES are for the larger proJect. 3) Section 4.3.2.3 Para. 2x As indtcatcd above, the inlet-outlet Revised Plates A-l, 2, 5, 6> 17, 19, 4 Ptguze 3-2 shoving the latest proJcct concepts are attached. structure concept has been revised. Ihe revised dcstga vill provide 3 outlet ports vtth the top outlet port of clew. 956 ft.

Sccttoa 3.1.1 Para 2x Thc last sentence should be revised to (291.4a) HSL or 25 ft. (7.6a) belov the aornal vater surface.

3) state that the tapexvious subsurface cutoff vill be re>inixed to Nodal data indicates that this port. vill be tn the eptltauton>

prevent seepage thru the saddle rather than in thc saddle. thereby eltatnattng the problcaa associated with thc vithdraval of hypoltantttc vater. Tables 1 4 2 (attached) shov the results oC

4) Section 3.1.3x The proJect concept Cor thc inlet outlet structure tcaperature aodcl studies of the revised inlet outlet structure.

has recently been revised froa the inclined structure previously concept. These studies are based on aetcorological conditions aa4 proposed to a coavcatioaal aultt~rt vertical tover. Three outlet streaa tcaperatures occurring in 1964 and 1S75 and assuae 1964 ports vill be provided, at Elev. SS6, 925, 850 HSL. Ihc attached release patterns.

Plate 6 shove the revised tnlctmutlct structure concept. Section 4.3.2.3 Para. Sx Ihe average release velocity thru the vill convey flov of 3.0 scrceas vill only be about 0.4 fps (0.9 ca/s) (aeasuxed 1 foot. froa

6) patton 3.1.4 Para lx The pipe an average the scrccas) and the scrccns vill bc about 2 ft. (0.6 a) above thc a sec. (106 cfs) but vtll be capable of conveying higher flow.

river bed. It is, therefore, aot believed any significant scour Thc tvo subaerged discharge sleeve valves in the pap station vill vill resalt froa coupensatton releases.

~ ach be capable of dtschargtng up to 150 cfs. This vill be the ltniting feature of the design.

5) Sccttoa 4.4.2.2 Para 3x Htntaua flov releases to Pond Hill Creat

1) Section 3.2.2 Para 2x Average annual vatcr use of SSES during a vill be 5.1 1/s (0.2 cfs) aad not 5 L/s (0.18 cfs).

repeat of the aetcoxological conditions occurring during the Section 4.4.2.3x We arc currcatly revievtag the destga coacept Cor drought oC recogd has baca <<stiaated at 52.5 cfs (1.S a /sec) not 6) 49.S cfs (1.4 ~ /sec.). the sptllvay, aad vill coasidex the NRC's <<agents tn this revicv.

As design approval for the proJect vill rest vith the Peaasylvaaia Sectioa 3.2.2 Para 3x We suggest that this sectioa be retitled Dcpartaeat of Eavirocaental Resources, the ftasl spillway destgn 8)

"Ccapensattoa Releases" and vherever the tera "augacntatton vill eeet their criteria. We vill tnfoxa the NRC of any rcvistoas releases" appears ta the report it be replaced by "cocxpcusatton vill to the spillvay concept.

releases". 'Ihe purpose of releases froa Pond Hill Reservoir be to provide coupensatton for vater consuaed by dovnstreaa users.

The tera augaeatation releases aay be aisintexpretcd to inply that the relcsscs vill be solely to increase flow in the river.

Section 2) 5 Alternatives Need for yactli aud Beneflt Anal sts Section $ .1.3x In Febxuary, 1980, tba SRDC ectablia af July 1. 1984 as t'.xx deadline for cxcpltanoa with tha ~>aa

~tzcnaxxta (SRDC pagulattcns, Sectirxx 803.61) .

xatar ~

Secttm S.3.1 Para lx The sc>cxxxt xtatcc>xxx states ttat the applicant ze-would have to puzchase zcplaocrccxxt power if Susctucdanna veza dcs>n dua to Iov flea>. Tbia tn not cozzect stnoe, dacrxttxx7 on ppQ>/ÃR czadittcns. tt xxxy be that "sales~ vr>uM be lost rather tpxux "puz

~ naadad Tba scntcnoa shcsxid zend "Wader tba river follcsc

3) of Ocnezatfcn due cn the shutdown Sect1cn 5.3.1 Para 2s sfetcsst with Table 5.3.

4), Sectfm

'Ihe 14 dey ~

altesnativu, the epfslfcant would 1ncur cddcd costs because of SSES" cf the loss zncbebflfty aEccezs fsxxn-5.3.3s 'Ibe cost repeated bere (847 sffffona) is for the mailer POND RILL RESERVOIR 1964 DATA TABLE I DISCHARGE TBSPERATURE 3-PORT STRUCTURE (oC)

~

rasezvoiz design. 'Ihe ccet is estfzuted to be 565 nfllfcn (1983 dolIars) AUGUST SEPTEMBER OCTOBER NOVBQKR for the larger reservoir assessed in the DES. 1

5) Secticn 5.3.4 Para 3s Since EP&L is a winter pesdsfnp sIstesa 1n the Tesp. Efflusus. (oC) 19.6 20.6 21.5 16.7 17.8 15.8 13.4 11.8 10.8 '10.2 9.0 ssxssssr-EoakfsXI WN power pool asd since pp&L bes Ocnezatfcn avaflebflfty zaLetive to WN, the zeserve razgin wit)act Suscpsabenna Teep. River (4C) 26.0 24.0 20.0 9.0 8.0

~

22.0 18.0 17.0 15.0 13.0 11.0 will exes<<l thfs zeserve requirccrnt for reliability tbzcugb about 1986.

I&xsever. should Suscpsehanna be ahstdoses because of Icw rfver ficus, EP&L Outlet Discharge

~

(CES) asd EUN are both ezpcsei to capacity zcductfczss of other mits cn the suscpsefesnna River and other rivers for the serac zeascn. In Outlet No. 1) El. 956 102 102 99 ~ 0 0 0 0 0 0 0 0 addfticn, because RN currently bes about 45z off-fired capacfty, the 2) El. 925 0 0 0 99 99 102 102 0 0 0 0 added to Icw reserves due to fuel cuztaiizecst also exfsts. 3) El. 850 0 0 0 0 0 0 0 102 102 102 102

6) Tcsbhs 5.4s Tbe 1980 QDC Reserve'E<<rgfn NLI)32EE Sussclucbecna should be 34Z.

NOIEs Outflow rates of the sodel deviate froe the speci ffed 102 cfa flow fa order to coepeeaate for averagfug tachafsfuea.

1S75 DATA TABIE 2 POND RILL RESERVOIR DISCEARCE TBIPERATURE (oC) 3 PORT SIRUCIURE NOVBIBER AUGUST

~~~333BUKR 29 2

SEPT 3

OCTOBER 3 29 ~~222 ~22 Tcep. Ef fluent (oC) 21.6, 22.5 18.7 18.6 16 ' 16.4 15.1 13.4 12.9 11.4 9.6 Tcssp. River (iC) 21.6 22.6 19.0 >9.0 17.0 16.6 16.3 16.0 15.0 14.0 14.0 Outlet Dfachazge (CPS)

Outlet No. 1) El. S56 91.8 96.8 75.3 0 0 0 0 0 0 0 0

2) El. 925 0 0 0 99 86.5 99.2 102 0 0 0 0

3) El. 850 15.2 10.2 23.7 .- 0 12.5 2.8 0 102 102 102 102 NOTEs Outflow rates of the nodal deviate froe the specified 102 cfa flow fu ozdaz to cocpeeaate for averaging techufgl1aa ~

PpaL

'IWO NOIIN NININ 51 ~ II'I, AIIINIOWN,tA. IIIDI tNONI UIOSII~ IIII NOANJN W. Otus ace Awctc IAVNtwe 1 CwwwNN Nwev

~ ININ1 January 7, 1980 PAL SCX 1222 - MASRLQUAILPA 12120 - tt121 7550122 ysydOSS 11r. 5. J. Ycunlbl~, Chief covsssoau otttcs Liceosin8 Sranch So. 1 OttICT Ot TIIS NIOCST August 20 1579 Division of Liccnsin8 U 5 Suclcar RSSulatory Connission

~

Uasbin8ton, D.C. 205SS Director ~

Division of site Safety and Envlmsuental Analysis 50500254554 STEAM ELECTRTC 5242105 U 5 sosclear Regulatory Coscdssion LCM RTVER PLCU 0PERATT055 SIashingtont D C 20SS5 ER 100450 PTLE 841 2 PLA S92 zhe penn~lvania state clearinghouse has received Dear Mr. Tounlblood I fzon your office o~ics of the Drift Rnvtronttsntal Tnpact Statencnt zelated to the operation of Susquehanna Electric The follovind infosnation on Susquehanna operations durinS lov river flov Station Units l anl 2 conditions vss requested by Mr. Richaz4 Stark:

. These cozies have been transnitte4 for various Stato PP4L plsos to replace vater taken fron the Susquehanna River durinS agencies for their reviev and cosnant.

periods of lov flcv by utilisin5 vster iron either sn existinz reservoir or iron the toad Rill Reservoir to be constructed by PP4L. Should a lov Attache4 please find the czntssnts of our Departncnt flov situation occur prior to the availability of a nakcup vatcr source, of Envtzocnental Resources zelatlve to the above EZS.

PP4L vill cosrply vith all SRSC directives rcSardinz vatcr vitbdraval please consider these cocnents the official response iron the Susquehanna River.

of the State Cleazinghouse Additional cosstcnts received fron lf you require additioaal inforuation, please call. State agencies vill he trsnsnitte4 to your office for response and inclusion in the rinal 525 as appzopriate.

Very truly yours, 5,

'<4J W

~

Curtis Vice President-ECSinccrinS 4 CocstruCticn Suclear Thank you for your cooperation S incezely, Supervisor tINNSTIVANIAIOWIC A IIONT CONtANT

ccwaIDMIcALTNoc pclooYLYANw tuxtuct 20c 1979 (3) Rad(aticn SectLm 4.5.2

~ - Direct Rndiaticn - d(rect zadisticn

~ 2.7.~ The dose 5-~~ of calculated by the aEplicant could be order of zngnitude

)Axc by about scphisticatad type of analysis.

~

an based cn a coze Draft - ~nona ES Stean E)ectzio If this Ls &Heed the case, the site could exceed a libezal. inter Stat(cn Duits 1 4 2 operating yzetaticn of 40 CER 190. It wuuM cqpcar that these var)zxzs rcdels caQd be ccnfizmd or refined by reasuzccnnts taken near several

~

Richard Reise c Supervisor Pconsylvan(a Clearinghouse

~~

of the cpezating bafILng water Table 4.5 - It'gpem (ShR's).

fnm this table of expected conual that abcut 103 of the Xe-133, 231 of the I-131 md abcut 51 of tha Cs-137 is relearn thxough cpczation of tba g)and seal ccxi zeciuudcal vacxxxx Lxrp. Since this is an yat)snyr tha

~~ted and unfiltered of this effluent t'.cough the cff gas tzea~

~

systcn, a seedily sL~)e design c."n~, would significantly reduce the yearly zoutire staticn effluent. In adiiticn, Lt has been the

~ cqerience of other boi)Lng water reactors Ln the Cccrzxnnalth Ihe DcEezcnccN feels the Dzaft Euvtzccurntal statccent (Es) for its having sinLIar systox azruqcrxnts, that the Lnstanta~ todmical

~ ~

, the Qmga&anna Stean Electric Staticn shcuid Lnobde a coze detaDcxl syecificaticn have been by cput(rg the'zechanical

~, ~

discxcssicn of several Lryoztcuu: ccncezns, especially Ln Eight of the recent acctdmt at 'Ihzee HLIe Islandc I) .the cccvizccrental of a Class 9 nuclear

~mxs

2) ccntingccxies for Icc~zn storage vacuux Exzp &1)cwing certain tlpes of plant sbutdcvns.

Secticn 3.1 and 3.2.3 Sec~ 3.1 states that the aEp)Leant

~

of spent fuel, 3) xuutine zadiaticn nQeascs, 4) aspects, ani 5) izpacts cn fish pcpQaticns.

(I) water quality has the liquid, gaseous and solLd tzeacnent systcccc.

~.

Since these systems were described in acro detail in the Pinal Environ rental Statczccnt (Ccnstzucticn pcznit), tha re)or desLgn changes and their izpacts slrxQd be desccibcd Ln mars detail Ln this

~, ~

Pcafdmt 7his is especially tzua of the gaseous zabeste truant systxxa which SectLcn 6.2 .- Table 6.2 ILsts the radiological ccncopxures has changed fzcn a czyogcrdo distillaticn systen to coe utilizing of all yochQated acc(de. Since tha cxxucequccrns of tba Xhzea charcoal delay beds.

HLIe Is)and (ENZ) vnze gzeater than those listed'ani since the selucnce og failures were roze seveze then analyzed as a design basis Lt could be crnsidczed as a Class 9 ecch)cut.

7hezefoze, this tEye of scnazLo desezves mxe attenticn than a footnote in Tcble 6.2. A suncazy discussLon of lessens learned.

(4) w~ater

'Ihe ml~j Draft ES Ls ~t outdated with zespcct to the Naticnal pollution Discharge EUninaticn Systna (NKES) peznit issued by fnxs tha EEEE accident which aze aEplicahle to this plant should S~

pccxnylvan(a cn JRQy 31, 1979, the Naticusl Intezin Dri~ Rater be incluied in the FLnal Euvizcccxantal Statccent (Cyezating Pezxdt) c with a cctce Table 5.1 detailed discussicn

- Sccticn

~,

in the staff safety evaluaticn.

5.3.6 states that the preagonticnal xcnitoring yzogzan deUneatoi in Table 5.1 will be continued during the cpezat(coal yezicd. Raced cn exyeriea>> ga(ncd as a zesult of the Three NLIe Is)and the cauher of.direct zadiaticn

~

S~

Ehocuzces.

of tu (Attached are the latest zcxrcuabded s~

for SyccLfio Rcdiccsmlides ani Rccccrec(Ad Rater c3zc3Lty (Chapter 93) of the pennsylvania ".paztrunt of Envizccrnntal which aze be nkpted by the Euvizccnental (qua)Lty Roazd cn tuxtust 21, 1979) .

7he NPDES Penxit Lssucd by Pcnroylvania limited fan 7 xEDq. ani an average of 4.6 mg/l. The Drai't ES cn page to a rexirczx

~ at rcnituzs (TED's) wculd ba totally ncadaiuate for accident ccnsideza- table 4.2 is not cons(strut with this yeznit xcqu(resent regarding tbe

~

ticns. disc)nzge Dcpartnx< that the ~

The calculated zcdhxxmBde zeleaaw'n liquhi efflucczts Ls discxmscd Ln team of duce ccccdtmnts (pages 4-14, 4-15) of reiicxxxQLde releases aud zesulting river quality cxxxxcntzaticns s)auld be ccupared to the Naticnal

(@inking Rater Staniazds.

4.5.5; - This soutien Soutien Pad(oactive Rcstes expended to LnchQe ccntingencies foz'he spent. fuel cRI site. 7his nay be required

~na shaQd be stucage of Lf a decisicn has nut been cede cn tba final disyceiticn of spent. fuel after the plant bas been cpazating for a few years.

~talyquality to tba water 103

~ ~,

gha su)fata ccczx.ntzaticn a value in tha river would be ~~~

of 244 cg/1 as a eaxhan which ty of 250 zegi1. 3ha Depaztnxa wcuM c:zxuzage that su15xic acM be utilized such that tha Satuzaticn Izdex is a lPSBMp SQi+!IPSESRQi@.$

positive value, insofar as to zdntuizo sulfates in the disdnzge.

tiah~laticn SCaete 5) ig CWeme &ag3bemee

~.

3ha Depertzeee feels that cdditizeal studies aze needed cn

~ ~

~ utzainecnt and ir4dee7ecnnt zelative to water intakes ani that nktigative steps identif)Aed by tho studies be P.O. SOX 1333,HASH>SSURC<<PA. 17130 l717) 78MOOS iidicates that tnztulsnce censed by tba )ettad water Tbe zepozt fzoa tha will scour tba rivezbed that there zny ho scun less of

~taly dzamtzean euz) habitat- Tha Depart:ent 7833i33 sepf believes that tha effect of tha dischazge zeczoinveztebrata should s~/0'79'Se on be evaluated. ol slee svocsr AtteeSnrnt PSCXS l~ +77<70 d+.

M'1<<<<<<, [gz /g J<<k<<<<gBe014+

~~ e<<e syf'yoni PP03SCr ggg gVg~uC4e~i e, M

e Ef~cb(~ Sj4.

'PA)(fi /a~4 2 Dear applicante attached are additional contents conceining your'tatd Clearinghouse subnission zefcrenccd above.

Please includ these coanents with our correspondence to you da o r97$

Ihanh you fo your cooperation sincezelye

+c~~ W~c~

)larian L. Elhy<<

pzo)ect Clearance Coordinator Pennsylvania State Clearingl.ouse

6 PS 07&08 ca- e) 'osr ccv<<on<<caus>> oe ecunaucuarnn Pannrrnarda Cdnrlheua>>

Ooremors Sudcer Otece

~

P.O. San 1222 Henlsburg. PA 1712O 717 7ZTC)OCS FIRST STAGE REVIEW su~en 5-~~3to Occnxn)ts cc) Draft ED)-

Praappllcauon/Nod ficauon of In)ant Su~)a~ Stean Electric Stat)ca)

AGENCY REVIEW COhCIAENTS Ridnzr) R. Heine, Supervisor ,.)

INSTRUCTIOlCs To bs co>>placed by review aaency and rsrurned lo Slsre Ca)doghouse. Cwct one or more appropr Pennsylynrda Stats sm ~

Incor)re commence below. Rerum copy I, 2 and 2 lo d>> Scare Ceadngou>>. Ra))br copy a for your Anacn rrfplkare sheen lf eceesaay.

olrnki'eocrds.

/ecu Cp',

CLIF)DPD Secnatazy L r c)'-

Depart of tal Resources PART Ir Dec))radon of In)areal t Comp)a>> Pan V and Irner>>1 Declared-Comp)step)nell, III, IV and Vs>>i

'Ibn fo)Rcsrirs) coc)oezn shou)r) be csMee) to the Dcs)arfnentrs cznanants f) No In)ere)1 Dec)and f ) on t)ds Emft Envtzccnus)tal Statrns)nc-rsuun copy I and copy 2 ro Sea>> Ceabgeuso. >>nun copy I aad copy 2 lo sra>> ceabtnepunnn pART n)

~ a Idendrnadon OI Aaency Reriew Crlrrrla IACency )dana, proarams. pandas and/or lewd ra)NLa ~n C .<<1 4 Sfccrc QccfrfcSfnr; e+Ifocnrnrcr Nc>>'- Rcguforfnry Cornprfc)Lr otffccr'a rofe'fr) t!+.Ahdacr (6)

Ihe ~

Air Quality ES s)zsu)s) consider the pass)Ms systcerccfl)s effects of use of tbe Susqxharz)a Ste)ca Electric Statics) as a ne)r base-loaf facdlity. Ibs Depeztnnnt a)ou)r) entfcdgats ou rcvfear fr ft ccccrdcncc wfc) seel ion Jdd of fhe'Hfsforfc Preacrvcffon that cns or zozs coal- stat)one in the systsca aron)ri Cpu+I) on lro:.-Ic Preacrycff-~PPnc>>zrar'cr.! f Proiccftor.of >Let <<= r:." r:icc. conscc)rsz)tly beocne aeehiny or steer)-by faculties.

rely cause increased cndss)or)s mines zsasuzes ers taken to PART I I I) coMMENT5 (Induce reruns of prefimdnary con)ac)nude wl)h appscam end s)eidden for npprwbba pro)sec poposafi sued)K znzs fzequmt coll)

~ality of coze-frequent sta~.

sta~ Ibe effects cn antdent at such babfzz)s shou)ri roanarrea fn the Pre)SCI Cae be studbx).

, )nfc rCPOrt OOCCu)CC)y a!ore)cue Cui~r pART Ivr Recocnmendedsralscearnchou>>Acdon f) Rnaress e>> ~

ffhlsacdonwlsnocbrhonoredbye>> sra>>cesrlngf>>u>>un4seprrcli Pars IIIshore hers been conekS4

) ) Reste>>t dw opponuniry so rerww reul eppncsdon.

'4 co reriew enw'ronmenrd bnpacc a))mern)a aml PART V) Cerdncadon Aue>>rued Apency Spa)cue n fllfA.YHf VOn I 'N'-e2 Apency TS core a. rcccw core s<<<<a w r>><<rum>> srrro cu<<near<<e

jPPg~rr g'gdBDSME COMMONWEALTH OF PENNSYLVANIA m

DEPARTMENT OF ENVlRONMENTAL RESOURCES dpte@f, P. O. Box 2063 Harrisburg, PA 17120 Clefg0'&d g&QBSSS May 20, 19SO RG. SGX 1222 HARRISSURG, tA. 17120 1717) 7SM04s of PSCH s~

Caaaearwat&

~I COVZSWOIVS OS/IC S 7SS2122 SUaJECI1 Review and Evaluation No.z 3-80-04-002 Draft Supplement to the DEIS - Susquehanna Stean Electric Station, Units 1 0 2, Pennsylvania Pcwer and Light Cccpsny Allege>>ny os>>ca ol'wz suocsz Electric Cooperative, Luzezno County RE l PSC-SAZe $ 8004002 TO: Richani Heiss, Supezvisor APPEECARr, nuclear Regulatory comsdssion Pennsylvania State Cleaiinghuse PSZAZECrz DRArr EZS - Susquehanna Stesm Electric Station Enzezne County FRM1 CLIFFORD L. JCZS Secretazy of Enviroonentaa nesources Enclosed with this letter please find ths ~ts following State Agencies zelstiw to the prefect identified shovel of the The Departs>>nt l~ reviewed the draft stpplement to the draft environ-zental Lq>>ct statement as prepared by the Pennsylvania Power and Light Cccpsny for tb>> proposed Poni Hill Resenvlir. I believe our original cccz>>nts on the Department of Environmental Resources Pond Hill protect znde in a letter to Robert Bielo, Executive Director, Susquehanna River Basin Ccccdssion, dated May 21, 1979, are still pertinent.

please consider these t."w comments of the pennsylvania state I will restate thea below.

clearinghouse at this time.

The concept of czz>>zzucting the resezvoir appears to z>>et the thank yo'll foz ya coopczstion regulations of the Depart of Fnvirczz>>ntal esoauzces as related to dzn safety (Chapter 105). 'Ihe applicant should be informed of the need to slfzait

~

an appli'cation for a permit to the Bureau of Dzms and Watezwny Mznagczent when Sincerely, final design plans and specifications have been et>>plated.

The Deparcnent notes that although the plant is scheduled to begin operation in 19S1, the insezvice date for augmentation operation is 1983.

Anne G. Xstchlzs 'Ihe Department notes that the Pennsylvania Fish Consission has not Supervisor been incluied on the list of agencies for review of thLs pzoposal. 'Ihe Dcparnsznt recent>>nds tlat the Pennsylvuzia Fish Commission be given an opporuahzy to cccz>>nt on this project.

8 0061 ED~~I I Donald E. Sells, Acting Szsnch Chief Environmental pzo)sets Sranch 2 Division of site safety snd Envfzonmsntsz Analysts Rcclesz Rsgclstozy commission

'washington. D.C. 205SS L

Mr. Joseph M. Hendrie DCCELI EUQBUL A~<> '7~+

Augusc 30, 1979 a pret SUUf.fe Page 2 Moreover, the boiling reaccor cores ac tha Bezvick plant are untried and un-August 30, 1979 proven as to their overall safety and functioning. It does noc meeter hou remote an accident of any kind may be, a chance Ls still there, especially vith a nav design. It only cakes one accident to release dangerous radLation. Tha safety 424 Laurel Drive equipment and men ac the Bezvick plant ara untried and unproven just as they vere Hershey, Ph 17033 at 'K Lastly, 1st us use honest, stzafghtfozuard language and tall the tzuth.

Nr. Joseph M. Hendrl>>

Chairman

~ty "Tbe temporary loss of habitat nay have significant adverse impacts on the aquacic and in vildlifa the vicinity of the sita," really currently living near tba site.

means that it vould kill all fish U. S. Nuclear Regulatory Cocmission Vashington, D.C. 20$ $ $ In shmmazy> tha Bezuick plant is another threat to the Susquehanna River Valley, an added burden and danger noc needed by the people of Central Pennsylvania. The plant,

Dear Nr. Handrie:

as a nuclear facility, should noz. be license4 and operated. Ic is not safe to the normal environment of the people in Central Pennsylvsnii.

I note uith much apprehension, that zhe NRC has recomaended licensing of the

~ Md 2! 2<<22 i lh ~ 28 li . 2 \h " ~lif2 from normal operational releases of radioaccive It is Lncumbenc the public" to tell on tha NRC in its charge "to protect the health and safety of us the truth abouc the Bezvick plant and the other nuclear poser environmental Lzfpacts are ~agjRated materials." plants. Please inform ma in ubatever scientific or non-scientific terms you vish:

I find this statement to be both arrogant and misluding to the public. PLrst.

!or me uhat "significant" means. Any lou level radiation releases are 2 llhhi 2 d<f&hl f~ffff, dh 2 2 d 2 please define significant as has been admitte4 and proven, even by the old AEC and the MRC's oun 2. d 2 2! 2 2 2 l 2 lh "~ff 2" to ba incorrect.

2 studies. There is no safe level of radiation exposure. Hov can you say then chat The Rasmwsen Report has alzeady been proven releases ara of "no sLSMLficancet"

3. Hou do you defLne "nozwl"7 Normal operational levels of radiation Secondly, you "anticipate" no environmental impacts. Nay I remind you that ~ mLssion are quite different and separate from normal background levels Three MLIe Island vas not "anticipated" or planned for either. Nhere man is in- of radiation already existing in tha environsant. Also, because of volved, there vill never be a safe nuclear paver plane. The nuclear vay is an bomb Casting and puffer plants che "normal" levels of background radiation unforgiving vay. Once the undnticipate4, happens, it stays vith us for generations have increased over the past 30 years.

Thirdly, it is time to tall the public tha truth regarding the "nocti operational 4. begat Lndividuals, by nua, sec these "normal" levels2 releu<<s" from nuclear plants. Hov much "normal" radiation vill be or is projected to be releued by the Bezuick plane, hov much "normal" radiation is currencly being $. Hou much "nor~i" radiation vill be expected to ba released in Bezuick7 relaued by the operating plants in this countzyf and vbo sets these, and hou are these "normal" release ceiling levels sat7 6. Shat are the MRC's recorded, docwanzed levels of "normal" radiation releases from che operating plants in the United States2 Tbe current standards vere Lnitially set in order to justify atonic bomb testing.

Those standards vere kept in order to justify nuclear paver plants because tha nuclear industry amd our government recognizes thee no plant operates uithout "normal" releues of radiation.

Recognizing that the AEC, NRC, and other scientific studies have proven thar.

there is no safe level of radLation exposure, negates the "normal" release standards" currently used. Normal may be normal for a nuclear plant, but not for a clean enviroaasnt and certainly not for the health and safety of tha public.

dt

Its. Joseph H. Hendrie Aususc 30, 1979 Pose 3 ': >>> SCDh- COUNCIL OF GOQCRHNCHTS

"..van ~ vsceik~al eo ~ ~ ag*hn Ki tpAS>t:tzva Irssv ~ fr $ 2a.

'9'eptmd:er

26. 1979 Thank you for your anticipated prompt response to the above.

Sincerely, Warren L. Prelesnik cc: Richard T. Kennedy, Commissioner Ib. S. Slngh Sa)ua John P. Ahearne, Connissionar Dlvlslon of Site Safety and Environ>>otal Analysts Peter h. Bradford, Coumissioner Office of Nuclear Reactor Regulation United States Nuclear Regulatory Coral ssfon Victor Cilinsky. Coomisaionsr Mashfngton, O.C. 20555 Richard S. Schueiker H. John Heine, III Dear Nr. Saduas Allen E. Ertel CeorSe V. Cakes SEDAKOG is the Areaufde A-95 Clearinghouse for a tcnwounty region In Rudolph Dfnfnni Central pcnnsylvanfa. Actfng ln Its role of A 95 Clearinghouse, the Stephen R. Reed staff of SEDA~ has rcvfcucd the Draft Environmental Statement related Pennsylvania Poser 8 118ht to operation of the Susquehanna Stcam Electric Station (SSES). Units 1 and 2 (Docket No's. 50 387 and 50-388). SEDA~'s Interest ls related to the proximity of thc SSES to our region, and thc potential lnpact of the SSES In the region. It ls our contention that one endor omission sccds to be addressed ln the cnvfronncntal statement. According to the ncu regulations of the Council of Envlreaental Iluallty:

'(c) Agencies:

(1) Shall prepare supplant to etCher draft or fina'I cnvlronncntal stata>>nt I f (ll) There are significant ncu circumstances or Infection relevant to envfronccntal concerns and bearing on the proposed action and Its lrpact. (43 Federal Register 55978, 1502.9 (c)

)'he accident at the Three Nile Island nuclear facf1 I ty.cemfnly qualifies as a significant ncu circumstance. Ve believe It ls Icperatfvs, therefore.

that the envfromscntal statement Include an analysis of the natural and furnn envfromsnta1 lrpacts associated with the TNI accident as a basis for evaluatfng potential Isoacts at the SSES, should an accident cver TOIO160

Hr. 5. 51ngh ~va Septenber 26. 1979 occur. The add1tlon of this 1nfomatlon All greatly strengthen the envlronnantal statenent, and u111 help reassure the publ1c that Pennsyl-vania Power and L1ght Coapany and the Nuclear Regulatory Conslsston are thoroughly evaluat1ng and nltlgatlng the effects of any potential accident.

.8-A~

Sincerely, Oenn1s E. Robinson Executtve 0lrector

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kngnet 20, 1979 yn. H. Began Zr., Chief RzvfronnentaL?rodects Branch, 2 Division of Site Safe~ and.

Mvirocnents1 lnaiysis g>>S ~ Bncl eat Regulatory Co~scion dasbington, D.C 20555 Dear Rr Begone

~ "2LL?Z MZBCtMPM FM~T>>

sonl4 lihe 'to thenk following ara ny'ts cn sane coy'f ~

/on for sending of SSBS ~

ne a The Zt is cnbelievabla that so such of the report is>>&en ny bp ssndles on the is Kos ccnyletalg ~e4 Zt 4ces tend to ~>>

flora and. fonna vhil~ the hcnen aspect treatnent of those who 40 live s4thin this MIse According th ~

to W reyow re 4on't hs~ ezist. The reycr. goes on to sca.=e4 ~

sons lengA before Beach Baven is even nentione4 Zt gL'ves the Lntneseicn mt thLs is ~ very s~e'Ly yoyolate4 area M vith a ver high tneayloynent rate aA e-early ef ecte4 by the agnes flood. ?yhL save4 the area by deciding to bo>>>>4 their nuclear plant here. Boo exch better off re scnl4 aU. have been if p?4D eon14 have @de.t their So ~

plan scnevhero else>>

space is devot<<L to ths conoesn for cn"ent, bn abera ess that concern shen the site v4th. trees bolldose4 onto yila ~

as high as hcnses an4 set clea".e4 afire to born for seeks Xissitg -on ths report was the fact thai mh blast>>>>g sonl4 be necessary to preps= ~ the s'te for the bail~>>" s c scion zesolted. frcn ~

coo14 exyIain thei= relnctsnca to adnit m". 4~as blasting eff~

i. local proyertiae. Zn Wer to resolve the si-.wtion ves necessary to go one step sho . of a corn +La . The reevlt~ sg~tion, he~snoot ak s=ess on the property ovners cs" never be neasn"e4.

gest to set "e recorg s~>>ght, not that it w"'c facts cones. ~

gq>>>>ac cn tha 1Lcens< a-ea

~e yeacerol area before the this s~ ~

o SQ tbe fa~IorLg a ~

was a vary beantifeJ.,

of cons~~on o Ms poser yia t ye 'Were esyerien~ a reside A~1 gowN that

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vas ex-.end>>>>g into the rory areas at a very fast yacc. Bone a".eas vere taben b7 the cant e'te.

the ae-Loci~ activi.p ~>> decreased~because men cnt of yrodnctivity bp tbe plant site. Zt is of a

far f being the 4eeolate area yictv"e4 in the reyor.. Bag hoes a". ~ vithin a sDe radix. of wtw ~>>- si. ~ an4 Z an str ~

the aber wcu14 be -ch greater '= ~ a"ea '

fcr tce plant be~~ here, LyyroM;~ teeny' h=nes.hare it <<ere not bee" dao" abe4 bp =K fo= the e'. ~ . Cr- area consists of

free COVered fsa sca~

rclLng h 115 aad Can~

la"d. wept for sand W gavel ezcavation w'h of Le ~caps inters'pa been dc e by 222K Ced W the onb othe rhe czz..~r SlEMM CLUB PKHNSYLvhNIh ~~e.

i" mL of power" lines $ 11 d'"actin ch".cuffh oz= beazz.ifal az=~f" .

Le ~f "r refe.=od .0 tn the report is '" the N(ZOS-35=0 RRpty~z Theme Ar Drazdcvaki area and LS Wt Vis!.ble hare. Mere LS rO unde~4 Of CL'5 Chatraznf Ncrcheaecoza Croup a".Oa. "he <<f ecrs of Ac-es was ~f "f" '" ~LS a".ea v" fact, 1 donf=. t~~-'h>>4 Wus Cne Mlf t rhe 34aoh EOVen 3ers Ck a"ea wt was Mplaced by the floodr (L~ they were e fected, RrDr82f BOX 99B Nicholacaf Pi 18446 AuguoC 19f 1979 they have med bach into rths'>> bones.) Eccnc"'cazvy we wars cn bette off bo cro the Swr of cow acticn of tha HK yla"t. Ztth "0 Mnz 0 workers cd. t plod.'dh~~La zz"f on workers, ths rents doubled ~ CL yay scale fdr area is now cne of tho ncs. oxyaotvo places to zestdo. V~ rfewwLO Ow the 30WCtn a-.ea cn tho cast~ wc%ex is a".0 enylcyed a M plant vs S'te.

dis~yr ve to loca'estdets.

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zes'den.s LC DL~Cor.

DLvioioa of Stria Safety azut En~stol Aaalyoto AS fo the recrea i M a ea barry developed by 22hZ 'zrcld not have bean ntssed t" ny opinion. 3efcra the acro'st~ on Office of Nuclear Reactor Rogutattoa Nuclear Regulatory Coaatosica Saohingaaf DfCr 2O999 of land by 2BL wo hud .he best zauz~~ aad Crappy"- a"ea for es arena rffr WO 5 0 nest C~l Od a CIZS>>O DOSS Dear St>z Of 7 ance with ZBC ~es t$ nest ayyzehKs 74 0 ILf -he Xcrtheaocoza Croup of Che Stem Clu'b, which ccmiooo Lckavanaaf Luoez ~,

~ zyE <ayaef and Sycatag counties, io very concerned about the draft Ea-race .s a: wczzld cene fran 22K in case of an accident. 3 cs" . SusZue~f

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hsfp bzzt beltova,. Me wcu1d, be no reyoz=

acciden cczzld 'bo covereft ay. 2'th tho ~~t~ tf they t~augh: sn o a yeznt- to vircmazat Statcaeat for Che PEST Bcrotck Nuclear Ptaatr A Preltatnary review fhdo Che aport freed and tao~ate ta the folloviagz 0!cre m spear M. cn the plant 5'to ts M a".Oa dos!r=ed 1 ~ Ere Nile Zelaad ta only nenttoaod ta a fcotnote Chat Statee it zzz I

.0 beccno &

rolease of zadtcacttv'cy into W e~~

spot fo= azzcleaz wasCOV Recent reports of plants across the thzttoft States antt tho "acc'denw &2Lfg cn ac1ear power haa not bean <<caoidervd, Of RCC 2~'f what can we ezzyect d ~

can wa Ozpect ho"02 Eow ~

galloaa Of nadtcaottVO water by the Cys'ter Crestt"aZZC1ea "0 I'ae of ~~f accidents 0 ~

5

2. Diocuooioa of Che health effects of radtatica and radoaccive mate disposal do aot aoCe cho present controversy aacag scientists cca cerning risks, sate dosage, and waste dtspcoal cochafrtuco.

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10 ~ or cnof a 4 AS yoZZ knOW OL laalh oo close o tho yls hcrders Che Si'C4 rc si ~

0 Scl h ar yr The prefect oi'ce aat archvologtcal ourveyr

~tcn ltnvo have noc had 4 c~coac scat'estf

~n w th che c uses'c cz-- lard. To date ths amezwent tect cs cr cc popery. Ca" we Ozpect coo~ tower Syprc~tely 99c

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to pro-protec='on Nn the 4r "he ner ~tca linc will crees the gorge a pennsylvania Sceatc River caadtdace.

0! the Lchtgh River, dove ff 4 ~ cz' 0 wo N CA cs bio c 0$ - ~ scuo 0 c Nuclear energy io ccaparvd Co coal ua!atrly because the potentially

~ nozacuo benefits cf revitalLstag the an~tte area are aoc calcu-Respect~~. ycz-s, Latodf Nzs o~ey Sac--s Please ahe m~oo ccmeato yart o! CLha offtctal rtccrdr Thank ycu for your co-3~clef 2~ Acff3 RvD szl Rc RS6 o'pezuCioar

.hzcao A. Dracdcvoki Chat~

Ncr ~Lac cora Group

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Susquehanna AIILaace 2 PO Box 249 Levisburg, Pa 17837 associated pro)acts. The staff specLffcally aentfoas ths zsczea-tioaal area near the river. Zt Ls ouz understanding that August 17, 1979 applicaat has recently begun .coast~tfon there without a the cultural Daniel Nailer resource survey having been coapleted. CufdelfnesS~~Z Dizector, Divisfon ot Site Safety and Rational Eavfzoaaental policy Act and established th"ough onthethe Eavfzoaaeatal Analysf s Couacil oa Envfronasatal Quality an4 the Advisozy Council oa Otfice of Nuclear Reactor Rsgulatfon HLstorical Preservation zequize not only the pzotectLoa ot US Nuclear Regulatory Ccccafssfon properties'isted La ths National Register but also those eligible.

Washington, D.C. 20555 Furthsraoze, ff no systematic survey of the area has been coapleted, ft aust be initiated aad the data suhafttsd to the Dear Nr Nullerc Otfice ot Azchaelogy aad HLstosLc Preservation for a detezaination ot eligibility. We teel these actions should be undertaken

7. I Za a of the publfc foz the Draft c~t perfod Statsxent letter to you, dated August Eavfzcnaeatal on behalf of the zequeste4 aa Susquehanna exteasfon Alliaace, related to the opezation of Laaedf ately. ~

2) The dLscussfon ot the effects.ot the uzaafua fuel cycle appears Susquehanna Stean Elsctzic Statioas I aad 2 {Docket Sos 50-387 and to be incomplete. Table 4.14 does not list any value, for the 50-388). I had Indicated Ln that letter that the Susquehanaa Allfance effect of Radoa 222. The statt notes ths absence ot thfs tfguze vas unCeztakirg a zevfev of the state eat and tele that an extension aad thea yzocesds to develop their ova czitezfa toz evaluating should be granted to allow tf=s tor Inclusion of deca nov befag collected on the causes sad effects cf the accident at Three Nile the effect of Radon. What they tail to asation Ls that this amber was vacate4 tzcxs the table'as the result of evfdence Zsland. Spscitically, ve felt that the period should he extend<<i produced duzing the hearings for the lfcsnsLng ot Three Nile beyond October 25, 1979 at which tfae ths Pzesfdent's Comfssfon fs Zslaad Unit ZZ fn which Dr Chauncey Eeptord, aa intervenor, allow tf=e for vidar public c~t expected to issue their tinal report. Tris extension. would also oa tee stat~at.

of aany citfzens vho oaly learaed of ths avaLlability ot the We kaow LndLcatsd that the value previously used was La ezror by aa ozder of aagaftude of well over 100,000. His calculations vere based oa the previous aMer used but extended over the full period docc=ent Curing the past couple vaska ani have not had suffLcLsnt duzfng which Radon would he saftted to the atnosphere. This toyic tfas to obtain a copy and review Lt Ls stfll under coasideration by the cosxcfssfon an& their fiaal report should be included fa the snvfzoaxental stateasnt.

Za a coavszstfoa oa August 16 vfah:a Leech, Pro)sot Naaagez, Z submitting to you a ~

learned that ay letter had not yet been rscefve4 and that Lt vas unlfksly that a dscLsion would be aade on ths extensLon uatfl sftsz the Lnitfal deadlLne, August 21, had pass<<i. Z aa therefore aatLcfyats that your offLce

vill, ot the areas of concern that the Susquehanna Alliaace has rsgardiag the Draft Envfzo~tal Statement. We vill grant the requested extension aad vs Cuziag that tLe, continue our zevLew and tLle noze detailed The staff dravs the conclasion that, of high level vastes, there vill be aodispite the extzeas toxicity envizoaaental Lxpact related to theiz storage La a tederal zepositozy. This not take Into account ths current controversy over vhethsr or aot a 1008 safe repository can be tound {or developed). There does aze reports froa sevezal govezaneat ageacfes Lndicatfng that ao dsacnstrably safe aethod exists ot dfsyosing of these vastes.

explanations ot cur concerns. Hare, then, are our initLal cocc"entsi The Caaags doae to the snvironaent by leaks at the Haaford lov level dfsyosal site aad the reyrocsssing pleat at West Valley I) Several cc=ents La the state-snt vith regard to the preservation should be sufticisat to raise ot cultural resources cause coaceza. The staff LndLcatss that ot 4svelopiag such a zepositozy.suspicioas about the feasibility theze have bssa indications that cultural resources aay exist on the plant site and on assocfate4 ppsL propertLes and that Lf 3) Zn the discussioa of the poteatial radiological effects of they exist they night qualify for Laclusion in the Rational accideaas at the ylant 'sita there Ls only a footaote, about the accfdent at Three Nile.Island indicating Register. Ho systsaatic survey has been undertaken to detezaiae Lt such sites exist yet the staff seem to feel strongly enough about the possible sxisteace of such sites to include a waraLag La,

'these not take into consfderation the expezfsacs gainedcalculations aze those that contend that the accident vas La fact a class do There their actuary that such sftes coulC be daaaged Lt ao preventative nine accidear. To our knowledge ao tLaal ruling has been Lssu<<f aze taken. 'easures on this. Sfnce ths 'Laprobable sezfes of events did hayysn at Three Nfle Zslaad, ths effects of other Lapzobabl~eaccfdeats Yet the staff doss rot rsqu'-e a cults al zesou ce su~ay be should be considered. The ull ef acts of this accident should ezta)cen to detszafae what s'tea nay exfsr. aad vill be {or have alzaady been) daaaged by the constmcrfon of the plant and he studied aad included ia any envcmr=ental hq>act accident issued fn zelatLoa to the operation {or construction) ot a nuclear plant.

4) The report does not fafrIy represent the gzovLng controversy over the etfocts ot low level radiation. Tine after tine tho assunytion Ls nade that as long as the zadfation cont"Lbuted Co The benoiLt-cost aaalysfs also assunes 2100 MN of electrical energy Ls enough t&t che yroductfon ot to offset the accunulated the envfzo~t Ls sut Lciently lover than aoznai background costs. This asst-es that tho additional capacity Ls needed.

levels or fs'belov existing tederal standards. chat the health Hovever, cables 7.4 and 7.$ seen to fndfcate c&t vithout the

~ ifects will be ahdual. This does not take fnto account the operation of the pleat there would stfll be suf LcLent reserves to .

grovfng feeling ~ng the scfeatfffc co~cy that theze fs aot a ra4fatfoa level below vhich theze are no Lll effects.

eet boch the rogufrenents ot the fnterchange agre~t aad the zeccnneadatfons of the Pederal Econonfc Regulatory Ccnnfssfon.

Mention should be nade of the reports which indicate that Therefore< the benefit ot the addftfoaal power soens guestfonable.

continue4 exposure to eveb Iow levels of radiation caa be danagiag aad chose chat propose Chat Ln lfght ot recent studfesp 7) In the July 23 Pederal Register there vas a notice that listed the federal standards be lowered. Nuclear Regulatory Ccmfssfon as one of those agencies that had not published proposed procedures to brLag thea in alfgnneat vith

5) Tho reyort does aot fairly treat, the possfbflity ot the uso of Che new National Envfzonneatal policy Act regulations adopted by an aathzacite fired plant as an alteznatLve. The use of such the Couacfl oa Envfroaneacal Quality and etfectLve July 30, 1979.

a plant Ln the nLdst of .PeaasylvaaLa's anthracite fields could have a Cze=eadous beaetfcial Lnyact on the area. Tho uso of lt Ls our ass~~cfoa, thea, that this draft of che envfrora~eatal stat<<seat nay not follov these aev regulations aad ve feel the nodera technology to sine tho anthracite fn tho area would ofter ccmfssfon should publish theM yzoyosed procedures and have then opporteNtfes tor the revitilization of aa econonfcally 4epzessed approved pzfor to releasing the ffnal version of this report.

area, 'reQanatfon ot lands prevfously surface ninod aad fnprovenent of Che vatez gualLty. The obvfous beaefLts of lover Caxes an4 nore gobs should be weighed. Zn addition, the nunbers used to Lllusc"ate che cost of operatLng a coal fired plant aad the As ve stated above, ve aro going to continue zeseazch on these eavizonneatal inyacc of fts operacfoa should be based upon the topics. Nfch the anticipated exteasion co the revfev period aad the opezatLoa ot aa anthracite fired plant. help of various local agencies ve hope to nore conyletely evaluato the draft eavfzoaneatal stateneat. za the vako of this count~'s The report 4oes indLcate that at the opozatLng )fcease stage> worst nuclear accident Lt Ls, ve feoI, advantageous co provide as considerations of alternatives favolves only tho &ecisLon as thorough, aa aaalysfs as possLble of tho potential etfects tho operation to>>bother the plan should operate or not. However> as can be ot thfs pleat could have on the envfzoanent.

seen tron the pzo)ected reserve nargfas shown Ln tables 7.4 aa4 7.5, the oyeratioa of che susquehanna station as a nuclear plant vfll preclude cho uee4 tor an aathracite facility for nany yeazs to cone ard vfll therefore yzeclude the possfbi.li.ty of the area receiving the benefits Mt would be associated vfth such a pleat. A tull dLscussfon ot this alternative should be Included. David Harm foz he Susguehanaa Alliance

6) The benefit~oat analysts should, ot course, be atfected by all the above connents. In addition Lc fs LntezestLng co note the LnclusLoa of a deconnfssfonfn'g cost of 59 nillfon dollazs. Is this an ostinato based on a realistic plea foz deconnfssfoafng?

In ILght ot che escfnaced 3400 nillfon to cleaa up'hree Nffe Island Daft Zz, ft aeons unrealistic to expect co be able to deccnnfssfoa two units for the stated pries. Aa outlfne ot the expected nethod of docccnsissioaing should be Included.

The benefit~st aaalysis does aot include any Lnfoznatfon vith zogazds to the psychological effects on Che zesideats of the area Lf the plant Ls allowe4 to oyezate. Suzveys at a business locace4 near the pleat showed t&t 509 ot the enployees would guft the).r gobs it the pleat was allowed to oyezato. Naay area zesideacs have al=eady begun to ~~e plans to leave che a=ca. An analysis of these effects shou14 be included.

CCN>>TS5 ON DPAPT SUPPLER>>T TO DRAPT EIS POR TEE SUS(IUEEAXXA SZEA>( ELECTRIC STATION Susquehanna Aliiaace P 0 Eox 249 1) Ono ot tbe conclusions Cram by the Staft oj tho RRC's attica ot g>uclear Reactor Lovfsbmg, Pa 17837 Regulatioa and ot paraaecat coaceza to zosMents of tho vicinity Ls that construction of the Peed Eff1 vater storage reservoir vfll have a signifLcantly negative Lapact

~ June 10, 1980 oa vatez <taalfty. Zn yartieulaz, the suppiosent states thee nutrient levels, spocffically phosphorous, - vill considerably exceed the czitoria establisho4 by the Eavftynaontal U S >luclear Regulatory Cccsfssfon Protection Agency for nutrient lewis aad thus the potential that eutzoyhle conditions Vashfngcoa, D.C. 20555 Act> Dizoccor, Division ot Site safety 6 vill occm in the Pe>d ELII reservoir Ls relatiwly hfgh . >(Lssfag fzes tbe statesent Ls a polutLoa abstinent ez sftfgatioa plan by tho apylfcant. Until such a plan Ls Environmental 1nalysis included, this draft scppl<<sent Ls Laceeploto.

2) The safety analysis ot the project Ls clearly LnsuffLcfent, especially givea the

Dear Sir/Radar,

unpredictable aatmo ef the sue<(uohaaaa River and Lts tributaries an4 the fact. that seveze flooCLng has gccured Ln the r<<gion tvfco vithia the 4sv eight years as a result Wo are enclosing sovoial dec<a>>nts vbich vo hope vill bs ot ho'lp in Lxprovfng of extraordinarily heavy rains Crea tropical sterno Agnes (1972) aad Eleiso (1975) Ln the <(ualfty of 6>> Draft Envfronaontal Stateaent.ed Lts Suppl<<>ant vhich have boon unprocedeat<<L concentrations. Tbo saxi>e>s flood 4angez an4 Lupacts of overtopping the prepared La relation to the pl<<mod opezatfoa of the Sue<(uohaana Stean Electric das have nov. been adoguately assessed, a rather glaring ccsfssfea La lfght of tho Statioa Units 1 4 2 (Docket No<a 50-387 aa4 50-3S8). On >(ay 26 ve regoested and RRC>>>ft these cccsoats by noted La sectioa 4.4.2.3 that>

>(r Singh Sajva, tho'}U<C Eavfronaeatal Pzoject >(anagoz for t!>> project.

Zt tho das vore to be overtopped tbo statf bolLevos that tho das eouM fail.

he Ce<<a>>nts enclosed include 1} a smsazy ot the reasons ve feel the Draft The flooding that voul4 result tres talluro of tho Cas vould produce rayidly Supploseat to the Draft Enviroauental Least Scat<<>>nt vfth regard to tho Pond Nfll rfsfag vater elevatLons devasczeas ot t}>> das site. Tho tontial exfscs to Rssozvofr Ls Laad<<gusto aa4 Lnceeplete> 2) ceeaonts on the Dratt Statozent itself to tza and drove orsons and vildlifo Ln t}>> dovnstroas flood lain der(a such suppl<<sa~c ouz ceo<sents su}x>fttod on August 17 vhich refaforce eur belLef t?~t as an ~tloodln (<<>phasis addo4). The potential for bars to persons using Route Envfze>u>>ntal Ixpac States<<<c thfs docuneat Ls inadequate and Laceepfeto, and 239 and tho railroad Curiag such tlo<dfag also exists.

3) a copy ef a recent PpaL novo release vhLch holsters om contention that an Lead<<(nate asses+ant of t!>> need for the plant has been Cone. .- The issue ot satety should be settlo4 oa the conservative side, vith the aaxham benetit to aa4 pzotactLoa of the public the overriding ceasMoratfen. Those haxaxds aro not

>>o hope that those <<xsonts vill be of value to the staft La continuing the acceptable aad a plan to sitigaca those dangers shouM be included.

pzocess of tally and diligently ovaluatfag the full rance of Lx<pacts of the proposed operation of the Susquehanna Stean Eloctrfc Station. Zt Ls em opfnioa that Ln orCer 3) Tho report does not ad<<guacefy address the coasfderatfea of alternatives to the to adequately adCress tho areas et concern rais<>r cemoncozs ~ ex onsfvj constr>stion ot the Pond Efll Reservoir. Tho use ot M>> Azay Corp of Engineers Cevanesquo zevisfons to t)>> Craft aust be sade. Zn this contexc ve r<<(nest t?>>c a second Craft Reservoir nov under construction Ln Peamylvanfa has not been tully explored, especially be Lsxued and be sado avaLlahlo for fuzthez public cccsent before t!>> final E S ~ s Ln light of the applicant's em adsissLon that tho costs ot this alternatLw over a aCoptod. Please 1st us knev Lf this re<(cost vill be t<>razed. 30 year porio4 veu14 bo $ 12 sfllion (as ceepared vfth the $ 48-50 sillLon cost ot Pond Rill. $ 63 sillfoa Lt property taxes are treated as aa aCdftional project cost). Zn tac.

Stafffhas concluded thats Sincerely, The best oconcsfc alternative vouM a ar to be t?e use-an-exi<stfne zesorvofz-alternative (eaphssfs aCCed} ~ Eased en t}>> fnfoznacion available, Cevanes<(ue spg>>ars to bo tho soot oceacsic asoag all al'toznative zesezvof s< gfven c,>>t concussed authorities groat tho use of vator for flov augsontatioa.

Tbo Saltfsoro District Corps ot Engineers Ls currently studying tho toasibility of sodffyfng the exfstfag pzojecc to include voter supply storage as a projecc pmpose for the Sue<(ue}>>naa Alliance fn additioa to flood control and roczoatien. Zt Ls felt t!>>t thLs aedftf cation vouM Lacrosse tbo ecenosfe efticfency of the Cevsnes<(us Lake Project. Pzelfafnazy tindiags fadfcato that chfs ceuM be deco vithout affecting the tlood control capabilities, that substantial releases could be provided Lnto the Sos<(uohanna River during lov stress flov periods aad these releases vouM geaezally fxprove the riverine envfrezzenc Curia<g aaturally lev stroasflov perio4s. Rather thea expand over $ 63 sillLoa oa vhac say beceao a yutzM< stfakfag lake at Pond Rill, the utility aa4 the public veul4 be bottez served by tho applicant's aggressive.Lavestigatiea of the resemcos rogufzod to eftec<<>ate

ADDZTZOMAZs CCNRCi S CM DRAFT EMVZPDbuEMTAL STATEHZNZ FOR SSES SCPPIEBRaT 0QIO(ZHTS CDMTZÃCED the necessary approval for their use of the Covanesque project. 1) The zepozt does not ad<<Nately address the contLnuing and even escalating contzovezsy regarding the health effects of continued exposure to lov lwel radiation. Zn additlon-Zn 44LLCLon Co tbe foregoing czLCLOLSS regarding alteznatiws to CP>> proposed no nention Ls given to vhat has been dubbed the Heidelberg Report vhich has also project, the applicant and staff haw nob fairly treated the Ho Action'r "River been translated and printed by the HRC as Radioecological Assessz>>nt of the Mhyl Polloving'lternatives vhezehy SSES vould nezely shur. dovn during tines of lov flov Mucleaz Pover Plant Zn studying existing dace on the transfer factors to plant in the Susguehanna River. Sase4 on an average annual occuzence of lov flou of 4 days life (and ultixately hunan tLssue) of certain radioactive isotopes esanating fros (a roughly 904 probability according to table S.3) the cost of Pond Hill Pesezwir operating nuclear powr reactors, the authozs of the riport concluded that the NRCss alteznatiw vould be vexy close to the zeplacenent cost of electricity under the judg>>nuts on hov nuch pluconiun, cesLIzs, strontiu>>, etc vas picked up fron the soil fiver folloving altersatiw . divan the excess capacity fLgures of both the applicant vere between 10 and 1,000 tines to lov . Ewn nore outrageous than the error factor and the PSH interconnection, the staff conclud<>rs even. during a short interval of shut dossn of SS?S". The attespc to nollify critics of earlier nuclear policy, deliberately rigged the attached press release fzc>> PPSL provides support foz this statenent. ~ zperinents to zdnLSLze the high transfer factors Lnherent Ln the isotopes. The steps include, but wze not linited to1

4) T)>> final area of con>>ant Ln regard to this project cc>>carne the Lzspact of the project on tl>> cultural resources of the area. Although the applicant Ls cc>>nitted a. Pre testing and selection of soils so as to choose those vhich absorbed to carzy out an arcbeological surwy and ceztain preventative neasures Lf resources the ninL>>I>> anouut of the isotope 4ze discowzeds the applicant does not Ln sufficient detail vhat those neasuzes vill be and vhat, Lf any, action vill bespecify taken (including halting construction) Lf b. addLng radiotoxic substanoee tO the soil shortly befoze harvesting, thereby substantial resources are Ln fact discovered..his suzvey should he perfozz>>d before

~

avoiding zealistic conditions, vheze plants vould grov fzou seeds*in the an EZS Ls prepared and t)>> results included. The applicant has LZZustxated in the contaninat<<1 soil construction cndaztaken at the recreation area near the plant that Lt has no regard for cultural resources. A repeat oZ this perfozuance aust not he alloved. c. the soil Ln ovens to r<<(uce the bacteriological effect upon the isotope and thus assure lover readings The Heidelherg Repose Ls Che first tiz>> thee independent scientists have exanined

)DC 4 Safety assurances about ruutine e>>SLSSLCOS frou Operating plants ~ Althoughs Ln 431 falzness, Lt. Should be note4 that the report>>ay have cos>> into tbe MRDss hands after oz only shortly before the release of the Draft Envirozs>>SCSI Stater>>nt for SSES ~ Lts conclusions vazrant a thorough zeviev of the issues rais<<i, not only by the HRCs but n~taa sa 8

~

a. ss as before Lt can be considered ccoplete.

ls ~ass . s aa a s

1) Zt Ls interest(ng to note that Ln the Draft Supples>>nt to the Draft EZS, the applicant pzosdses that Lt is ccs>>Ltted to carzy out an azchaeological survey and to take vhatever preventatlw neasuzes are necessaxy to protect cultural resources. The irony inherent Ln that position Ls that no such survey vas Izldezcaken or even allude4 to For tl>> original project Ltselfs one thar. Lnvolws considerable sore expense, area,

.and intensity of constzuction than the Pond Hill Resezwir. Zn additic>>, part of the plant'4 secondary construction involves escablis~t of 4 recreation 4rea on the lov-Tying flatlands 44 jacent to the Su<<(uehanna River, SL>>LIar areas of vhich have pxovan to be azcheological >>otherlodes of Lnforz>>CLOS on and relLcs of pzewzisting indigenous populatLons. As the applicant itself notes Ln Appendix H to the Draft Supple>>est ..

Scca assess>>ants "(inventories of historic or archeological resources vhLch nay be Lnpacted by the proposed construction are to he sade pursuant to 36 CFR 600, Section 106 of the Rational Historic PresezvatLon Act of 1966 as as>>nded (16 QSC 470) by Executive Order 11593, Hay 13, 1971, Protection 444 EnhanoenenC Of Che Cultural ESVLZOSZ>>nt ~ 444 by the Preswant 4 Me>>ozandlza on Environs>>Otal (tuality and Mater Resources Manages>>nt, July 13, '78.

The applicant should be z<<(uized to conduct such an invenCory in cozpli4nce vith the

ccyNzpzs !xi DRATT 'Ezs

~Lted ccÃzze~

Legislation> regulations, and ezecutiw pronoonc<<>ants> before construction

~ 08 DRAZT EZS CCTTRDZD of nuclear accMents on ~ health, the natural environment, an4 local continues an4 an operating license is granted. Zn addition a plan for mitigating the ~ cononiosonce again> this Criticism seems to $ 'tem from the ballot that EIS s as damage done by construction shouM bo L.pie<<anted. currently prepared are sLyly genezal reguzgitations of prating data and positions that bear limited it any relevance to paxtLculaz and unL>pl% OLta specitic Lnfoxxktion

3) The Stat! and applicant's cost-benefit analysis do not adoguately reflect the of a renoved anthzacite industzy on the region. Zn an analysis prepared recently for

~ct he inabLlity to translate this interaction Ln ncn-technical terms easily ccspzehonsible to the general public also meets vith C)Z)> ~ disapprowl, the Su<<D>>hanna Alliance entitled Scone<<ic, Social and Emoixonsental Impacts of Reneved )lining in the AnthracLte Region, lt vas found that a revitalization of this all TLnally> Spoth suggests that the SRC vigorously psrsue the goal of fulfLIILngto the LVustzy, especially one employing nev open-pit mining technologies, couM r<<szw u<<<<lst ext<<lt tho ro>plizemontsof tho Rational Envizonxontkl protection Act <<I4 the

~ cononically extractable coal and restore presently unusable'reas to productLve land , legitimate public interest Ln full disclosure of nuclear lant hazards (emphasis uses, improve vater quality beyond the reguiz<<>ants of t)>> Pennsylvania Clean Streams added) ln the obvious belLat that such disclosure has not been a top priority of the Iev> create 1500 nev 500$ in mining and related industries, and st<<a the ouzmigration ÃRC's agenda in preparing Envirccmental Zxg>>ct Stataeats for the operation of nuclear of young people from the area. All of this could be accacplishe4 in tho process of pover plants.

producing ~ fuel costwoxpetiw D>ased on Mi <<Zeivalents) vith those currently in use.

Again ve state ocz belief that the operation ot SSES vill preclude the need tor such an Industry and the loss o! these benetits shoul4 he Included in tbe coat-benefit ve believe it Ls the responsibility of the RRc to Bring the EIS'0 they prepare vithLn the gcidolinas set by CEO. Dntil this 1$ 400$ tor the draft EIE Ln >zoastion here, lt analysis, I renains vholly Lnado>Lusts and Incomplete.

$ ) As vith all other Environmental ~act Statements relating to the construction of reactors'mpacts nuclear pover plants, tbe Statt and the utility concerned have dismissed out of hand tho possiblity ot a serious, oz Class ZX accident and the health et!acts ot such a catastrophe on the Local populatLon. Although this omission of the entize EZS,pzocess, at ~ it vill be addresse4 shortly Ln a $ ><<mary of the Pzesident's CouncL1 on Environmental >>taallty'0 generic cziticL~

is especially glazing both in light of the recast events and SSES's proxioity to that crippl< A thorough revLev of the possihLILties of such an occuzrence at SSES should be made that Ls site-specific not only to the nature ot the technology esplcyed by the applicant in the constzuctLon of the plant and certain geographic and geologic features bu't vhich also thzoughly zevievs> <<>>lyxes ~ and $ $ $ $ $ $ $$ the pzobability of success of a Large-scale evacuation ot area resMents shouM such a measure be necessitated by exaaoxdinaxy events at the site. If the SRC Ls to own begLn to restore public confidence Ln its ability to safely regulate the nuclear industry, the attitude

'it can't happen bere must no longer be standar4 operating proce4ure.

mt

5) Zn a zecent letter to John Aheaxne, Chairman ot the NRC. Cus Speth of t?>> president's Cornell on Environmental Quality outlLned sewxal generic deficiencies, vhich he characterized as disturbing'Ln the NRC Zzpact Statement Process of nuclear pover T~ most darning of C)X)>s criticisms vas that the discussion of potential accidents and their environmental Impacts in these Impact stat<<lents vas perfunctory> remarkably standardized> and uninfozmative to the public . Speth found that despite vide wriations in the size, Location, and design of nuclear pover plants that have 'been

.ILcensed by the ÃRC, virtually owxy EZS contaLns essentially Mentical boilerplate language vzltten in an unvarying toxmat . The failure to consider the versa case.

oz Class ZX accident is ex<<xplified Ln the Statssent prepared for the licensing of T.C Colts I s ZZ. vhere no consideration is given to the Class ZX scenario. This omission loons >Zuite large in vier of the Staft's ovn visv t.'>>t such an accLdent did 0CCur On )larch ZS, 1979.

!path also urges the Ccc<<Lesion to 'broaden.its rage of variables le.g. radiation pathvays) in determining accMent's Impacts, an4 ezpand its dLscussions Ln EZS's of the

v-Contacts 2 Source: Al Craven (2I 3) 22l-3JIO So, he said, PpfrL is offering flat to sell part ownership-imerests in the plant and then, if more should be sold, portions of the elec rdty it will produce through the l9SOs wUI be offered. He emphasised that, despite the sales of part ownership, PAL wUI retain control of the plan and be responsible for its operadcn.

PpfcL now has about a 40 percent generating capadty reserve.

Assuming that the *mand for ef~idty grows as PpftL expects it to, the company will have about a 43 percent reserve when the fil t generating unit at An opportunity to own part of a nuclear power plant or a percentage sharply tss of the efectridty it wUI generate during the first several years after it begins gus~hanna begins operation. PpfcL's agreement with PJM Is ~t it will maintain s cn 4 reserve of at least 6 percent operation has been offered in letters sent by Pennsylvania Power dt Light Co. to electric utiUtles ln Virginia, Vest Virginia, Ohio, New York, western Pennsylvania AUegheny Elec+le Cooperative'fnc a Harrisburg~ed power and New England. Similar letters had already been sent to the other companies ln cooperative, already owns IO percent of the)plant. A~sic CIty Eiecwfc Co., a the Pennsyfvan)a-New Jersey-Maryland Interconnection (PJSI), of which PPJtL is a private utiUty serving customers in the Atisnac City and southern New Jersey member.

area, has agrewf to buy about 6 percent of Susquehanna's electrical rxrput untU l99!. The sales to AUegheny Electric and Athntic City El~le total about ViUlam Hecht, manager of System Planning for PAL, said the 333,000 of Susquehar~'s 2.l milUon kUowatts.

company wUI be In a position to make a portion of the capacity or electric energy from Its Susque)mrna Steam Electr)c Station avaUable, since the company's 06C"40AI generating capadty will be greater than Its obUgations to the PJM power pool when NUCLEAR the nuclear plant near Eerwick begins operating. "The rate of growth for people' use of electr fdty has Popped considerably since we decided to buUd the plant," he explained.

SUSQUEHANNA RIVER BASIN CO>!I>IISSION Mr W H Rag an - 2 August 30< 1979 Pj 172l Marin Fsani Sissies Hssrisburg, Pssnsyivbnia itl02 Fme ee t%'ce ol the EIKwto OvK$0I August 30, 1979 cfs) ~ The basis for that umber is not clear, but appeazs to be based on four years of climatic data col-it lected at, the si.te. If so, it may not he representative of actual worst evaporative conditions experienced at Mr. William H. Regan, Jr., ChLef the site. The Commission's concerns f cga the viewpoint Envizo~ntal Pzof ccts Branch 2 oi water management, is the pzobability of maximum con-DLvision of SLte Safety and sumptive use, expected under the wozst set of clastic EnvLronaental Analysis conditLons, occurrLng concuzrently with low flow. The Nuclear Regulatozy Co~Ssion dzaft EIS statement has not. addressed this concern.

WashLngton, DC 20555 Also, the pzoceduzes and assumptions used in making the calculation of maximum and average consumptive use should Res Docket No. 50-387, 50-388 be clearly stated.

Dear Mr. Regans iii It is stated on page that the river flaw at which consunptive use aust be replaced is 23.2 cms (819 ~ 0 cfs).

Reference is made to your letter dated June 22, 1979 trans- This figure should be equal to the 7-day, 10-year low mitting the draft EnvLronmental Statement for Susquehanna Steam flow plus the consunptive use. Our analysis of 7&ay Electzic Station presently under constzuction by PaunsylvanLa average low flow frequency at WLlkes-Bazze, based on the Pc~sr and Light Ccmpany. The Ccmmission staff has the following perLod of zecord 1900-76, shows that the 7<ay, 10-year comments on this draft. low flow Ls 800 cfs. The applLcant has used the value of 770 cfs which is based on an analysis by USCF for

l. water In section 3.2.1, page 3-1< it is stated that station requirements have increased since the construc-the shorter period 1900-72. We believe our analysis is more correct by vLrtue of including additional record.

~t tLon permit stage. Apparently the basis for this state-Ls the rLver intake flow shown in Table 3.1 which is shown as increasing by 0.45 cms (about 15 cfs). How-Also, we believe that the consumptive use value used should be the maximum consumptive use, which is stated ever, we cannot verify the 1972 figure shown in Table to be 64 cfs, rather than the average consumptive use 3.1 nor can we detezmine the reason for the Lncreased uied in your report. This Ls Lssportant in detezminissg water witMrawals. Also, the text states that water the storage required for consumptive loss makeup. The withdrawal will be at a rate of 1.8 to 2.2 cas, but the applicant has stated that they have computations show-table shows 2.45 cms. Please clarify the dLsc=epancy ing that the desLgn of the zesezvoir based on the 50 and the reasons for Lncreased water witMzawal. Also cfs avezage loss will provide adequate storage Ln a re-please clarify the text to indicate whether the increase peat of the 1964 dzought of record. We have as yet not pe tains to watez wLthdrawal or conssrsptive use. seen that data.

2. In section 3.2.1, the discussion of the SRBC regulation In section 3.2.2.3, page 3-8, the 7-day, 10-year low flow is Lncozzect. The applicant will still be permitted to is identified as 23.2 cms (819.0 cfs) . That. appears to wi.thdraw water during periods of low flow, but the aaount be inconsistent with the above comments, and with section of the consumptive use aust be replaced. The pzoposed '4.3.2.1, page 4-2 where the 7-day, 10-yeaz low flow is resezvoir is not an alternative souzce of water but only stated as 21.8 cas (769 ~ 8 cfs).

a source of ~cup water. The regulation Ls correctly stated in section 4.3.2.1 except that the third sentence 6. The proposed intake structure may not meet the require-should read, 'The regulation zequires zeplace=ant of ments of sectLon 316(b) of pl,92-500. According to the consumotive use.. Envizonacntal Statement, the cmbaynent Lntake will re-move more biomass than an alteznative Lntake...'RBC

~

It is stated on page LLL and again in Table 3-1 that the ~ staff zeco ends that an Lntake stzucture be designed using hest available techrology before the plant is is-3

~inurn consmpuive use Ls estimated to be 1.81 cns (63.9 sued an opezatLng licenke.

800@ 0 Hr. W. H. Regan, Jr. 3 August 30, 1979 V"OS'.

~ ~ 4g Staff is concerned about the effect of the consumptive withdrawal on aquatic habitat during prolonged perLods or's oo SUSQUEHAi eNA RIVER BASIiI COiXDIISSIOih 1721 North Front Street Nerrtstorg. Pennsyrvenre 17102 oE low flow. This concern should be addzesse4 in the draft statementR fR12o e3o olreo or

8. The post operational monitorLng programs do not include eR~ Orooror ~ e3 AprLl 302 1980 any provision for metering plant intake and dLscharge flows. We zeco ended to PennsylvanLa DER that such of flow meters be required in connectLon with approval the encroachment permLt foz the intake and discharge Director structuresr but these are not addzessed Ln the Euviron- Division of Site Safety 8

~tal Statement. We still believe that meterLng flows is an essential pazt of the environmental monitoring Environ-enta1 Analysis Office of Nuclear Reactor RegulatLon progress ~ DRS. Nuclear Regulatozy Cession WashLngton, DC 20555 Thank you for the opportunity to comment on thLs environmental StaCCA1lt Ret Docket Nos. 50-387, 388 Very truly yours, Dear SLr/Madams Robert J. Lelo sLon, are The following co ants, prepared hy the staff o! this in zesponse to the Draft Supplement to the Dzaft En-

~s-ExecutLve DLrector virormental Statement'NURES-0564) zelating to the Susquehanna Steam Electric Station. They focus primarily on clazification of positions attributed to the Commission an4 apparent errozs of fact or methodology. The cc cats aze keyed to the section numbers of the 'Draft Supplement'.

Section 3. 1-Introduction We believe that the second sentence of the secon4 pazagraph would more accurately ref)ect tha circumstances if it follower 'Zn response to ccx ants by the Pennsylvania Dept. of read as Environrental Resources and SRBC regazdLng the desirability of optiml development of the sLte to meet watez supply needs sub- in addition to those of the Susquehanna plant, the applicant tlitted ....'learly, water conservacion.

our cct ants have, nothing to do with We note also that we have not seen copies of any of the coz espondence refezenced in the second pazagraph.

2 K 3.2.2-~2- 2 22 2 3 There Ls a mooor Hastate=ant of the SRBC consumptive use make-up requr "e-ent. The first sentence refezs to the 'average ccnstmqrtive use ... by SSES Ln defining the low Llaw czitezion, whezeas the regulaticn specif'es 'the 7'0~ca lcw flow plus

Dizector 2- April 30, 1980 Dizector - 3 AprL1 30, 1980 the project's total coasumptlve use and dedicated augmentation. design criteria of having multiple outlets '... so that zeleases (18 cPR 803.61(c) (1) (i)) As we Lntezpret the regulation, the can be made from the resezvoLz level vheze the vator temperatuze appropriate value is tho actual zather than the ave~ra e consump- most closely matches that of the Susquehanna River (TAVE g De tive use. This notioa is stated correctly in Seccoa .4.2.1. sign Report-Pond Rill Reservoir, Pebzuazy, 1979, p. 3-4) ~

Zt ihould be corzecte4 here.

Wo do note that tho flaal paragraphs of the Soctioa conclude Section 4 '-Zmuacts on Water Use that the release vL11 cause cold shock, contain large amouats of organic materials, be high Ln iroa, and may be anoxic. We have The last sentence refers to aa application for a NPDES per- three comments with zegazc( to these conclusions.

mit applicable to reservoir discharges. We aze not aware of any such yezmLts. 1. We find them difficult to reconcile with the assortion of Section 4 2 that all quality criteria, except foz iron, The section also concludes that '... the quality of the water will be met.

dLscharged from the Pond EL11 Resezvoir vL11 moot applicable DER and EPA criteria except for an occasional high level of Lzon. 2. Wo cannot accept the conclusion that such releases This conclusioa should be zeviewed La 1Lght of the comeats zo- ~should have little impact oa the Susquehanna RLver, lating to Sectioa 4.3.2 below. since augmentation releases mall in volume'p. 4-9). This bo vill iafzoquent and usually S ci i.3 2 2 Z..d-t1 i ~th \ ~t* argument seems to haag on a long time average concept. Under mlaimm Cally flov of record conditloas compensation releases would Oa page 4-5, Lt is stated, '... the potentLal that eutrophic represent about 10% of the river flow. Moreover, the conditions will occur Ln Pond EL11 Resezvoiz is zelatively hLgh. SRBC consumptive use requirements specify that, 'The suggesting that water quality yroblms are quite. likely. Later physicalt chemical an4 biological quality of water'sed on that page sedLments, very it islittle stated, ... once phosphozus reaches the bottom of it usually returns to the epillmnion.

foz compensatLon shall meet the quality yuzposes for (protection of publLc health4 stream quality controls The analysLs concludes that productivity levels time as '... vill nutzieats are lost to bottom sedLments.'e are Cecline over economic developaentg pzotectioa of fisheriesg zeczea-tioag dilation an4 abatement of pollution,) 'ong less optimistic that such vL11 be the casa. Zf the bottom vater others (18 CFR 803.61(h) (1) and (e)). Zt isn't clear becomes aaoxic, vhLch seems to be a distinct possLbility, phosphorus aad ~nia vill be released from the sediments. Duzlng turnovezs, that this requirement vill be met. PLaally, it bo note4 that ouz consumptive use regulations require should these nutrients vould be returned to the epL1Lmaion. compensation foz vatez rmoved fzcca the river and not returneK to it. A~umentation carries the idea of in-czeasLag the flow above Gie amount available under Section 4.3.2.3-Disc)are(a ~Sstem natural flow conditions.

Zn the fLzst paragraph under 0~rational Zmuacts, there is the statement, vill be vithdrawn.

'... as presently desagne~oa y y~TLmnetic water The zepozt thea goes on to point out that Lf

3. We feel that the applicant should more fully iavesti-gate vater quality problems assocLated vith the releases this is the case, tho result will be cold shock to many of the and pzesent procedures for meliorating them.

organims. The only way vo caa see that such a coaclusioa is possLble is to assume that foz the Cm presently yzopose4 the spacing SectLon 4.4.1Wonstzuctioa and elovatLoa of the Lnlet structures rmaia as planned for the orlgiaal dm vith top elevatioa at 950'sl. Do you kaov this to We have reservations about certain of the parameters used Ln the temperature modeling. The origLaal analysis by the applL-be the case? As zecently as April 19, 1980, PP4L has zeported to us that the project desiga has been revised to reflect tho 'full- cents'onsultant used 1975 climatic data to simulate the 1964 sise'esorvoiz (Elevatioa 990'sl top of dsm). Purthor< that correspondence states that the Lnletwutlet structure has been ze-drawdown. We feel 1964 climatic data.

it vould have beaa raze apyropriate to use Moreover, ve feel that tha results aze even vised fzom inclined to a conventional multiport veztical tover less appropriate for the larger zeservoir. Zt Ls our judgment that.

structure ~ We assume that the applicant intends to adhere to Lts a aev analysis shou14 be made of the larger resezvoir, using more .

appropriate parmetezs.

Director ApzL1 30, 1980 Director April 30, 1980 g ti ~ .).2dl g ~thd td I! i Zt is also stated that the pumpiag statLoa lies outside the 100-year flood plain. We aze unable to vezify that statement be- A statcmeat in the second paragraph misconstzues this Com-cause of the level of detail used in Piguze 2.5. Hoveverd the mission's position regarding tho use of existing reservoirs. The pumping station clearly lies outside of tho floodway. statement 'SRBC's zesponse to this request vas that the Covanesque Reservoir is not now a timely alternative,'isLntezprets the Section 4.4.2.1-Watdr ~Su 1 statement on p. 2-3, AppendLx H of the Environmental Report-Operating License Stage. The applicant correctly sum)arised the The secon4 and third paragraphs contain statements that. cormcats of our April 17, 1978 letter which suggested that a re-are incomplete and potentially misleading. The second pazagraph study of all potential vater supply uses, the impact ot these uses Lgaores the fact that the larger reservoir Ls planned to meet not on other project functions, aad detezminaCLon of the necessity only the consumptive use requirements of SSES during peziods of tor reauthorisation be made. Tho 4pplicaat then dzev its ovn

'e coa-

.low flov but also similar needs by other'ovastream users who clusion that, SRBC coments indicate that Covanesque Reservoir might contract for a portLon of the Pon4 Hill Water Supply. To is aot nov a timely alternative.'Ep)vlsis added) The draft state wLthout explanation that the applicaat has assumed a release rate of 2.9 cms, as against Lts ovn needs of up to 1.8 cmsg is un-suppl~t sets forth the as the positioa of this Commission a coa-applicant. of our April 17, 1978 clusion reached by (A copy fair to tho applicant, making Lt appear they aze planning a re- letter to the Corps of Eagineezs is attached.)

lease that bears ao relation to their ovn needs.

Section 5.1.3-~S

'ocher uses'ze recognized ia passing ia the third para- co graph. Hovever, vithout aay oxplanatLon as to the nature of Zn recent months, vo have been vorkLng closely with both the I Chose other uses g thc discussioa could leave the impression that ot Eagineers and Pa. Povez 4 Light Co. to explore the use they aze scmehov associated with the Susquehanna plant. Also, would be more accurate to note that, based oa the average consump-it Cozps of the Ccvaacsque project and an expaaded Poa4 Hill pzoject (en-lazge4 to approximately 22,000 acze-feet of active water supply tive use during the design dzought, 1.5 cas SSES for zeplacement of consumed vatez aa&.6 cms vill vill be neede4 by, Cho bc avail-stozage) as complementary vater supply sources to moot several needs in Chc basin, including SSES. The Corps has completed Stage able to other users. (A similar misstated zegazding the avezage COINWB~Sghg ) th <<d g g gh ) Itheofentire its Ccvaacsque Lake Reformulation Study and expects to have study completed by wazch, 1982. ppsL estimates at this gg time that vith coatinued work on the Pond Hill pzojcctg Cho com-last paragraph of the Section relates to the zefLlling pletion date tor ppsL storage only is suamerg 1983 and vith maximum The ot the reservoir. Tou state correctly that the planned opera-tional procedure calls for no pumping from the river when river stozage, s~r 1984. As you aze avare, ppsL has announced the in-service date for Unit 1 is aov Januazy, 1982 and Januazyg 1983 flov is below SS cms (3,000 cfs). Tou should be aware that ve for Unit 2. At its march, 1980 meeting, tho Susquehanna River which Peach have as yet unresolved concerns about possible environmental im- Basin Commission adopto4 July 1, 1984 as tho date by pacts ot pumping at such a lov level of river flov. Bottom Wucle4r Ccaor4tiag Statioug Three MLIO Zs14ad Nuclo4Z Ccn orating Stationg aad Susquehanna Steam Electric Station must be We assume Chat the refilliag rate of 3.7 cms refers to La compliance with the conceptive vater makeup requirements.

the pmping capacity of the cnlazged project. We have not seea these specifications Section 5. 2-AltomaCLvo Sites Section 4.6.2.3-~Hdrol)od(lc Des~can ot Dam The first paragraph specifies ceztaia parametezs relating to tho usable vater storage requirement La the Pond Hill Rcsezvoiz We note vith concern that the dam design does not meet NRC that a"e no longer relevaat. Za response to questions raised by czitczia and that your staff is concerne4 about poteatial ovez- ouz staff, PPCL estimated that the full load coasumpcive'uso at topping. We feel that the design criteria problem Ls a matter tor the Pa. Dept. of Environmental Resources and the applicant SSES vill be 52.S cts (1.49 cms) base4 on the drought of record>

the 07-10 at the Wilkes-Bazro gage is 800 cfs (24.06 'cms) l an4 to resolve. the consumptive use make~ storage for the full load operation at SSES consumiag 52.S cfs for 106 days Ls 11,030 acre-feet.

Director April 30, 1980 DLzector 7 April 30, 1980 PP4L stated further 'that the Poa4 Hill Pm)oct, if intended tive loss would stL11 be continuing for some tLme (uatLl colC shutdown Ls obtaLaed) and the consumptive use would solely for SSES flow compensatton, will be constructed to pzo- he decayiag from its value prior to the beginning of the vide an active storage of 11,600 acze-feet (11,030 acro-feet for shutdown.

SSES plus 570 acre-feet foz losses aad downstream consezvatLon flow). (Letter from H. W. Curtis, PP4L, to R. J. BLelo, SRBC, The poLat is that Lf our understanding is corzectg hot shut Septuor 4, 1979) Ccwn is not a viable alternative to cons~ttve Loss make up, first sentence to 'a because tEe cons~tive loss continues until cold shutdown Ls The of tho second paragraph zefezs 1970 SRBC study'. Tho study La question Ls oae made by the Sus- reached. That further L-plies that Ln order to we the river fol-

~tteo, lower method, coll shutdowa would have to exLst on the fLrst day quehaana RLver BasLa Study Coordinating aa interagency task fozce made up of repzeseatatLves from seven tedezal Cepazt- that the flow goes below 07-10'nd hot shutdown would have had mmts and agencies and the three basta states. Zt was chaize4 by to start some considerable period of ttmo prior to zhat date.

the Corps of EngLneezs. The report was co~lated and released PLaally, under the brief periods of shutdown postulated for several months before thts C~sston cuba into existence. The applicant cites the study correctly in the ERAL, Appendix H, the analysts< it is not obvious to us why there should be aay sigaificant savings in the costs of opezating SSES. While wo Sectioa 2.4. do not know the coapoaeats of the 'Nuclear Generating Price',

S ti 5.3.1-B sita t 1~1 ~1 -N ~'river .11'L following'lterna-surely they are not eatLzely vaziable operating costs. Xt ap-pears that zhts aspect of the analysis needs to be recoasLdered.

tive The benefit-cost analysis for the developed Ln this section poses several probleas. Pizst, the S tl S.S.2W f ~ht*tl I analysis presente4 La Tables 5.1 an4 5.2 is baso4 on the asaumpttoa The matter of cost of water fzcca the Cowaaesque Lake pzo]ect of a 4&ay shutdown occurring every year. This Ls the average Ls not resolved and will not bo for some tLme to ccma. This Ccm-a~or of days the plant would be shutdown based upoa the flow mission is Ln the process of developing a water supply maaage-duration cuzve. Tho latter asst~tton implies that aa average meat program, one ccmpoaeat of which Ls a watez pztciag plea. Tho flew year will occur Ln each yeaz of the life of the pro)oct. But pzeswptton is that SRBC wL11 serve as the wholesale vendor of

=hydrology Coesn't work that way. The analysis should have been any water supply storage developed La the basin. Until this sa-based upoa the expocte4 value of the present worth of the cost of tire natter is nore fully developed, no oao can make any meaningful pleat shutdown for diffezeat flow sequences. The aaalysis dis" ~ sttmates of the cost of ohtaLniag water from existing zesezvoLrs ~

played La Table 5.3 apparentLy uttltses raze realistic zepreseata-tion of the flows Certainly it would not be correct at thLs point to apply either the prLces oz pricing scheme of the Delaware River Basin Comntsston Second, the calculations whLch produced the 160,000 WH, to'he Cowanesque Lake pro)acti 170,000 WWH, aad 146,000 R values meationo4 ia the fi graph of the section aze aot evLdent to us. We feel this should st para- Section 5.3.3-Pond Hill Resezvotz be clarified. There Ls an error Ln the statemoat about the cost of elec

'Thizd, the analysts assumes an equal pzobabtlity of hot an4 tzLctty for p~tng wats= into the resezvotz. The annual pumping cold shutdown. Our understanding of these tezms Ls as followsc cost is tho orna of a capacLty chazge and an enezgy charge. T'e 4,500 hp of pmptng capacity Ls equLvalent to 3,357 XW. As<<

sumtag a (mLd-1978) capacity charge of $ 12/XW, the anaual capacL-

a. Cold shutdown means the aucleaz reaction Ls ossea- ty charge Ls (3,357 XW x $ 12/XW) ~ $ 40,300. The energy charge, tially stopped, an4 no heat is being geaerated) assuming 30 days of pumping, and an energy cost of $ 0.025 por XWH

b. Hot shutdown means that the reactor coatrol zcds have Ls 3>357 XW x 30 days x 24 hrs./day x $ 0.025/XWH ~ $ 60,400. Thus, been Lnserted to stop the reaction but the zea'ction has the total annual pumptag cost Ls ($ 60,400 + $ 40,300) ~ $ 100,700.

(See MLS Design Report, Pond Hill Reservoir, p. 7 2 and Figure not actually ceased, heat is still being generated, 15,)

an4 both prLmazy aad secoadary coolLng loops aze carzy-iag away the heat. Under this ctzcmstaace, the cons~-

Dfrector 8 April 30, 1980 1 n ~ ~ n SUSQUEHANNA RfV"R BASIN COMV.'-55ioi"'721 North Front Strcot ~ Ftcrrisburg. Pcnnsytvsn:o 17102 We appreciate thc opportunity to c>smcat on the Draft April 17> 1978 Supplcacat. We hope that our ccuncasa are helpful. fro>> o> Or!> at tn>

E>> t>t>>> oi>ct>t Very trull> yours>

Colonel G. K. Withers Robert . Bielo U.S. Dept. of the Amy Executive Director Corps of Engineers Baltfaore District P.O. Box 1715 Baltfnore, Maryland 21203 Dear Colonel Wftherst Thank you for providing us with a copy of a request froa PPCL asking your o!fice to detemfne vhether the use of the Cowanesque Reservoir's potential seasoaal storage capability to nee- Susque-hanna Ssean Electric Station's consuned water nake-up aeeds vould be coapatfble with Covanesques'ther functions aad whether such use would be practicable and ecoaoafcally justified. Wc nose froa the PP4L request that ii ft is dcscmfned such storage aad water use is pemfssible the conpaay intends to seek a contract with the Corps for -the use of Cowanesque water and to subaft such contracs to SRBC for'pproval.

I have polled the Conafssfoa alternates on the ~stud proposal and would advise that the Cornfssfon recognftes the ncaa for the coapany (PPBL) to explore various alternative acasures to obsafn snake-up water to conpensate for consu=psfve losses of water at fts Susquehanna Stean Electrfc Station during certain periods of low strean flow. Further, the Cornissfoa rccognf es a need to deternfne the potential for seasonal water supply storage fn the Cowanesque Reservofr for uses other than as outlined by tho conpany.

Fsseatially the Commission believes that any review of the srorage capabflfty of the Cowanesque Reservoir should include: a range oi vater supply and other water use storage alternatives at the site, a detem.natfon of the effects such alteraatfves would have on flood storage and other project uses, ard a deteraiaatfcn vhether such alternatives vould require reau:hori=ctfon or could be acconplfshcd under current project authorization cnd Corps'uthority.

'TS0 Rest Second Col. C. X. Withers April ly>> 197S PA 19515 Street'locasburg, 20 August 1979 Director, Divisioa of Site Safety ard Bcvironaental Aaalyeis The Connission also wishes to note that if as a result, of the 0ffioe of Wuclear Reactoz Regulation study a positive detezainazion is nade of the potential capability II.S>> Hucleer Regulatory Cccmieeioa of Cowancsque Reservoir to neet the water storage coeds outlined by Raebingtoa>> IZ 20555 PPSL in its request that such finding doos not Ln any way pze)udice futuro Commission ection regarding allocation of water fzoa this The followLg connects acacew the Draft ZavironaeateI Stateaeat project. foz P-'PL's Suecsxehenaa Stem Rlectric Station> Waits I end R We will look'forward to your fLndLngs sad will be pleased to I'rge the Ceaiel of ea operating license fo the PPK pleat foz the following reasonsz nosiest'ower cooperate ia any wey possible.

Yezy truly yours, 1>> Reed

/dc./.'/? c:.i a>> the pro)ection of the PJR ~er petit (Table 7>>5) shows Robert . Bielo Executive Director ~

a Sf% Lnoreasez the national average Le, La acreeILty>>

slightLy over 2$ , a mre reasonable projection en4 one that decreases need> pushing becIt the dzop La z'eeerve over b

ven peale>>

while needs of the PJR power grid a.e a naia reason for the need co buLIC the 2PdrX nuclea. Power pleat SS 1 Sc 2) those aeeCs oea be bypassed end PPPX cea eelI direct to amber ccapanies (e>>g>> ~ sales to QP0 to replaoe-TRg electrioity) ~ PPK's growth elonee with a geaerating czar I

capaoity Ln exoess of 4'( cvez'eeIt Ceaead (Table 'F>>4) e does not show conclusive aced for ncz' generating cepac if ity

~

by 1981, especially the strong conservation neasures of the service area continue. Zn faot, Lf the aee4 were real, PAL be obliged to conduct a oraab, progzm to build a co~solid waste/solar (or whee-have-you) plea, since the nuciosr pleat asy very we11 not be in operation by thea>>

c. t"e stateaeat tha. wadditionel reierve capacity above 20~ ney be desirable foz' eyetea with units which ere large in relatioa to eystea siss (as will be the oase with gn zhe Susquehanna facility La servioe) ~ (p 7-5) rather then showing the need fcr the plaate shows that the plant, ia feote creates need lees ~

2, Rvelua.ioa of zhe Proposed Aotioa reaching the coa'clusioa that the nuclear power cycle Ls to nea thea the coal cycle> Lasufficieat nttea >

tica was peiC to the aouatiag evidence of the effects of low-level radiatiorI the unknown effects o rad'oactive waste Cis poealI an4 the reliability of evidence suppAed eInest eatizrely

~>> ~,

auc ea. Powe. indus~ ~ While Rgeeh~ebl ~ sots ney) at present, point to the coal cycle as nore

~~e for hara rendezs the nuclear oycle W aoz ~ Cestrzctive

~~ ~ote ~

S~ Seaeff~ost Laalysfs ai The benefit of LLANO - L2i9 bfLLfoa Qh of eloctrLo powez'o the PR interohaage is base4 oa a not necess ar<<Jy valid asmytion of a ylant capaoity factor of fcrnsaco averages less b The addition of

~

Ct0-70$ , when, ia actuilfty, nuclear power pleat yez 1S90 Mg g(74 of geaeratfng capacity to the PJM

~s a interchange and 210 )I to the oooyezative is Listed beaefLt thea, fa reality, it night be coastrue4 as a cost since powez'se ~

it noy encourage additional eleoMcal c The saviags of 7S nfllfoa (1980 0) fn yrodcctioa oosts per unit yer year oan be ~caged if total coatee fnclud-ing Sew~at subsiCies of the nuclear power indus~,

sro included Za nore concrete tersse the weavers" would accrue oaly if radioactive waste disposal fs not pirated into the coatee snd if tho plant-operates at 50 70fe efff cfoacy> wfCou sccfdeate for its pro)ected lifotfaez there are no nodels that would l.ea4 to the belief that th's wiLl happeni 4 The conolusioa that there am no si~~fcaat socioeco acnfc costs tc be ezyeoted frcn statioa oye atfoa Coca cze I

aot give sufficent weight to the very real s~ss cryo~ ~

Vl i<<aced sfaco QK by those LLviag ia a 20 nile radfus of the plant the.oonstant feeliag of a radioactive volcsao wfLL costi Lf~ on the ed-e of ei The ecoacafo casts are preseated fn absolute tezas raM~r than as ccayarod to not operating the pleat Cal culaticas frees sources ethos~ the utility have not been tshea fully'nto accountz Ec"a"off, ~ hagi, pro)ecto Zn ~~,

gow thea ~

~ lectz" ofty geaeraco4 Tron coaL-fired plants as c"capo ruclear sad the 4'or<<ace wfLL Lnereasei I urge the Xuclea. Regulatory CMssfcn to Cony sa operatiag License to 22$ foz'usquehaan Stesa (Ãuclea ) Z.ectrfc Statfoae Units 1 snC 2, because operating the nuclea" plant will advez'eely effect ao> as a PPK coamer eccncafcally, eavfwaaen tally sad eaotionallye saC because, t e ~need for aCditfoaal gener atfag oayacity has~ dfnfafshede there is eno~ lead. tfae to develop alternate energy sources (Lnclu~ the use of increased coaservatLoa sad ef icfcacy). to suyyly the elec~ c2ty aeeCeC fa nona en eccnccfcaLLye or ~

env'~eatally au4 ~ foaMy acceytable Sincez'ely,

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Ploreaco ~~son (>s. L.P.)

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APPENDIX C. ENVIRONMENTAL ASSESSMENT BY THE DIVISION OF SITE SAFETY AND ENVIRONMENTAL ANALYSIS FOR PROPOSED. MODIFICATIONS TO THE TRANSMISSION LINE SYSTEM, SUSQUEHANNA STEAM ELECTRIC STATION UNITS 1 AND 2 (PENNSYLVANIA POWER & LIGHT COMPANY CONSTRUCTION PERMIT NOS. CPPR-101'AND CPPR-102 DOCKET NOS. 50-387 AND'50-388)

C.l. INTRODUCTION By letter received on 15 Octob'er 1975, the Pennsylvania Power & Light Company proposed changes in the transmission routes previously evaluated for the Susquehanna Steam Electric Station.

The proposed changes involve:

a. Shortening of the Susquehanna-Lackawanna 500-kV line and resulting in the Susquehanna-Stanton 500 kV line.

b. Elimination of the Susquehanna-Frackville 500-kV line and replacement with a 500-kV line between SSES and Sunbury Substation and a 500-kV line between SSES and the Wescosville-Siegfried Substation.'~,z k

r Additional details concerning these changes were provided in Amendments 4 and 5 to the SSES Environmental Report, construction permit stage, submitted on 26 February 1976 and 30 June 1976.

C.2. REASON FOR THE PROPOSED CHANGE PP&L is a member of the Pennsylvania-New Jersey-Maryland (PJM) power pool. Prior to 1974, the reliability of the PJM bulk power transmission system was considered inadequate without the network addition of a 500-kV line from Lackawanna 500-kV substation to an existing 500-kV system in northern New Jersey. This line, which would have been jointly owned by PP&L and two other PJM utilities, was approximately 121; km long and was expected to be placed. in service by 1982 to provide overall improvement in the reliability of'he PJM bulk power network. This line was not analyzed in the Final Environmental Statement (June 1973). Based on the data provided by the applicant (ER-CP, Amendment No. 5) it appears that these 121-km transmission lines from Lackawanna to an existing system in northern New Jersey would be more environmentally sensitive than the proposed addition of 90 km of transmission lines.'ixty percent of the 121-km transmission lines was expected to pass through the Pocono Mountains. The staff did analyze the environmental impacts of the Lackawanna transmission line and related facilities that were to be constructed between the Susquehanna Nuclear Power Plant and the proposed Lackawanna Substation. In late 1974, modifications were made in the planned development of the PJM bulk power network due to changing patterns of load growth and capacity expansion of other companies. As a result, the proposed 121-km line was canceled. Without this line, the appli-cant has stated that a single contingency failure of the Susquehanna-Frackville 500-kV line would cause electrical instability of the Susquehanna generators and would necessitate restrict-ing output of SSES. Therefore, in order to obtain an adequate level of reliability, the pre-viously planned transmission system for SSES needs to be modified (ER-CP, Amendment No. 5, Sec. 3.9.1) ~

C.3. ENVIRONMENTAL IMPACT OF THE PROPOSED CHANGE The staff's,evaluation of the two proposed changes is as follows:

a. The staff analyzed the impacts associated with changes detailed in Amendment No. 4 (Susquehanna-Stanton 500-kV line) and it was concluded that modifications proposed in Amendment No. 4 are acceptable, as discussed in a letter to PP&L, dated March 8, 1976.s

b. The staff has analyzed the .impacts associated with changes detailed in Amendment No. 5 (proposed Susquehanna-Sunbury and proposed Susquehanna-Siegfried 500-kV lines), and this evaluation is detailed below. The review included a helicopter overflight by C-l

C-2 the staff on September 3, 1976, of the proposed Susquehanna-Sunbury line and tlie pro- '

posed Susquehanna-Siegfried line. Alternative routes were also investigated.

Descri tion of Line Routin and Transmission Corridor Environment Two lines are being proposed to replace the Susquehanna-Frackville 500 kV. The Sunbury-Susquehanna 500-kV line, shown in Figure BE 1, will terminate at the existing Sunbury 500-,230 kV substation. This line is approximately 71 km long and proceeds in a southerly direction from SSES, crossing the Susquehanna River where it intersects with the existing Sunbury-Susquehanna 230-kV route. From this intersection, the route parallels this existing line before terminating at the Sunbury Substation. This line will cross parts of Columbia, Nontour, and Northumberland counties. At a point 1.9 km south of Sunbury, the proposed line will again cross the Susquehanna River to the Sunbury Substation on the west bank in Snyder County.

The Susquehanna-Siegfried 500-kV line crosses approximately 87 km between SSES and the Siegfried Substation north of Northampton, Pennsylvania (Figure C.l). The line traverses parts of Columbia, Lucerne, Carbon, and Northampton counties.

Right-of-way data as supplied by the applicant are included in Tables C.l and CD 2.

The study areas for the Sunbury and Siegfried lines encompass characteristic steep forested ridges and valleys and gently rolling farmland. The proposed Sunbury-Susquehanna line routes would traverse approximately 55Ã crop and pasture lands and about 33% forested lands. The proposed Susquehanna-Siegfried line would occupy nearly 66K forest cover and 33K crop and pasture cover.

The forest cover is primarily comprised of a mixture of oaks and pines. In general, ridges and high plateaus are composed of scrub oak (Quercus ilicifolia), white oak (Quercus alhx), red oak (Quercus ruba), pitch pine (Eiinus rigida), and short-leaf pine (pinus echinata). Valleys are composed primarily of red, white, and chestnut oaks (guercus prinus), white pine (Pinus strcbus),

hemlock (Tsuga candufensis), several types of birch (Betula spp.), red maple (Acer rubrum), and yellow poplar (Stwiodendron tutipcferal The .slopes contain a diverse mixture of hardwoods and conifers; oaks, red birch (Betula nigra), white pine, hemlock, pitch pine, and white ash (Pnxzinue ame~ana) are dominant species.

~

Dominant understory species include azalea and rhododendron (Bhodcdenchcn spp.), mountain laurel (Zalmia Zatifclia). blueberry (Vaccinium spp.), and willow (SaHa spp.) (ER-CP, Amend-ment No. 5).

The applicant has listed a wide variety of terrestrial and aquatic fauna within the Sunbury and Siegfried study areas (ER-CP, Amendment No. 5). The staff and the applicant have consulted the Pennsylvania Game Commission, the Pennsylvania Department of Environmental Resources, and the U.S. Department of the Interior. Local resource agencies, such as Bloomburg State College, have individually determined that the proposed routes do not cross areas contafning any known unique floral or faunal habitats or state forest natural areas and wild areas.4 Threatened and Endan ered S ecies The State of Pennsylvania lists no birds, maw@Is, or floral species as being threatened or en-dangered in the state. The Department of the Interior lists two endangered mamnals and three endangered birds whose range encompass the study area.s These are the eastern cougar (PeZis -.

ccncclcr cougar), Indiana bat (Myotis scdaZis), arctic peregrine falcon (Paleo peregrinus tunchius), American peregrine falcon (Paleo peregrinus anatum), and bald eagle (Haliacetus Zeucccephalus). The applicant indicates that no endangered or threatened mamnals have been observed in the study area. Critical habitats have been identified for the Indiana bat.7 No areas fn Pennsylvania have been identified as critical habitats for this species. Peregrine falcons have been sighted at Hawk Mountain, south of the study area (ER-CP, Amendment No. 5).

The bog turtle (CZimmys muhlenbergii) is the only endangered herpetile listed on the Pennsylvania Fish Commission list whose range falls within the study area. The applicant indicates that two endangered and two rare fish are listed by the Pennsylvania Fish Commission as having ranges falling within the study area for the proposed transmission line (ER-CP, Amendment No. 5). The applicant has provided the staff with its construction specifications program and vegetative management program and, based upon the mitigative and construction measures detailed, staff's position that any rare and endangered fish species that may inhabit the general area it is the along the applicant's preferred routes will not be affected by construction of SSES transmission lines.

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C-4 Table C.l. Right-of-way Data: Susquehanna-Sunbury Line Required Required Width of Width of Width of Area'f Existing New Additional Additional Lengt) Lineb Config. ROW Required ROW Required Segment of Line (ft) (ft) (ft)b (ft)b (acres)b Parallels existing Sunbury-Susquehanna 230 kV 222,600 150 325 175 894.3 Parallels proposed Susquehanna-Siegfried 500 kV 9,000 162.5 325 162.5c 33.6 Total 231 $ 600 927.9 Source: ER-CP, Amendment No, 5, Table 3.9-A1.

Conversion factors:

ft to m, multiply by 0.3048.

acres to ha, multiply by 0.40469.

With respect to the Sunbury line, the Siegfried line is considered to be existing and the required 325-ft right-of-way is equally divided between the two lines.

Table C.2. Right-of-way Data: Susquehanna-Siegfried Line Required Required Width of Width of Width of Area of Existing New Additional Additional Lenqth Line Confiq. ROW Required ROW Required Segment of Line (ftJb ft)b (ft)b (ft)b ( cres)b Parallels proposed Sunbury-Susquehanna 500 kV 9,000 152.5 325 162.5 33.6 Parallels existing Sunbury-Susquehanna 230 kV 4,400 150 325 175 17.7 New right-of-way 184,400 200 200 846.6 Parallels existing East Palmerton-L. Harmony (outside of BWAd land) 32,800 100 300 200 150:6 Parallels existing (north) Siegfried Harwood 230 kv 20,000 150 325 175 80.3 Parallels existing (south) Siegfried Harwood 230 kv 27,000 150 300 150 93.0 Parallels existing East Palmerton-L. Harmony (within BWAd land) 6,400 100 200 100 14.7 Total 284,000 1,236.5 Source: ER-CP, Amendment No, 5, Table 3.9-A2.

Conversion factors:

ft to m, multiply by 0.3048.

acres to ha, multiply by 0 '0469.

With respect to the Siegfried line, the Sunbury line is considered to be existing and the required 325-ft right-of-way is equally divided between the two lines.

BWA = Bethlehem Water Authority.

C-5 The applicant indicates that the only unique flora noted in the area, American chestnut (Caetenea The staff has dentata), is not endangered and will not be affected by the proposed routes. threatened or en-investigated the possibility of existence of any critical habitat containing dangered floral species as proposed by the Department of the Interior.a Ho critical The staff habitats have yet been determined for any proposed threatened or endangered floral species.

and the applicant, in response to staff questions (see Reference 24), have found no evidence that any threatened or endangered floral species are located along the proposed transmission routes.

Effects of Transmission Line Construction on Land Use and Im acts to the Land and Mater

1. Land Usa The Sunbury-Susquehanna line crosses approximately 38 km of open land, predominantly utilized for crops or pastures. A small orchard will be traversed as well as 4.3 km of land classified as small farm woodlots (ER-CP, Amendment Ho. 5). The remaining portion of the route crosses 24.3 km of forest land and 2.6 km of state game lands. The applicant has submitted a detailed inventory of residential and commercial units; institutional and historic features; river, stream, railroad and major road crossings; as well as selected environmentally sensitive features such as wetlands, game and~forest lands, etc., for each route.

The proposed Susquehanna-Siegfried line crosses 58.4 km of forest land, which includes state game land and state forest land. The line crosses a section of the Beltzville Reservoir in Beltzville State Park. At the crossing of the Lehigh River Gorge, the line will traverse 915 m of a proposed state park involving the crossing of an existing canoe trail and a proposed foot trail along an abandoned railroad right-of-way (ER-CP, Amendment Ho. 5). The line also crosses the Appalachian Trail at Blue Hountain while paralleling an existing 230-kV line. It is the staff's opinion that proposed paralleling 500-kV lines will not cause additional adverse impact to the Appalachian Trail. Approximately 25 km of agricultural land (29K of the total length) will be crossed by the proposed Siegfried-Susquehanna line.

2. ~tn acts The staff's analysis of the originally proposed Susquehanna-Frackville 500-kV line in the FES-CP (Sec. 5.5.1) indicated that approximately 23.4 km of this route would traverse forested land requiring the alteration of 143 ha of forest cover. Approximately 14.8 km of agricultural .land (79 ha) would also be temporarily impacted. Replacement of the Susquehanna-Frackville line with the Susquehanna-Sunbury and Susquehanna-Siegfried lines will result in an increase in both total forest and agricultural acreages required for new rights-of-way.

Impacts to the vegetative comnunities along the proposed paralleling Sunbury-Susquehanna line will be primarily limited to the selective removal of approximately 153 ha of forest cover along the proposed paralleling Sunbury-Susquehanna line. An additional 13.75 ha of state game lands will be disturbed, but the applicant will minimize impacts by preserving to the greatest extent possible all existing vegetation within rights-of-way limits except where removal is required for erection of line structures or installation of conductors (ER-CP, Amendment 5, Appendix I, Exhibit 8, p. 11). In addition, the applicant indicates that planting and reseeding will be undertaken where required by the Pennsylvania Game Commission.

The applicant indicates that the Siegfried-Susquehanna proposed route would traverse 54.3 km of forest cover requiring 61 m of new right-of-way and 6.9 km of paralleling line requiring an average width of 52 m. The applicant estimates that the proposed Susquehanna-Siegfried right-of-way will impact 367 ha of forest land. Host of the land will be cleared by selective cutting, which will remove all trees except specified low-growing varieties (ER-CP, Amendment No. 5).

Impacts to animals along the corridor may take several forms. Host directly, some less mobile animals may be killed by construction equipment. Loss or partial alteration of habitat will result in the displacement of some faunal residences and may result in the loss of some animals.

Disturbance of fauna will temporarily result from increased human activity during con-struction. This type of impact is not expected to extend beyond the construction phase of the project. s s ~

D ata on aquatic ecology, geology, and soil can be found in the ER-CP, Amendment No. 5. To reduce and minimize erosion and siltation problems the applicant has committed to detailed mitigative action specified in the ER: "Transmission Construction Specifications:

Development of Erosion Control Plan for Line Construction" (ER-CP, Amendment No. 5, Appen-dix 1, Exhibit A) and "Vegetation Management" (ER-CP, Amendment No. 5, Appendix 1, Exhibits B and C).

Measures and Controls to Limit Adverse Effects Durin and From Construction The applicant has submitted detailed erosion control plans (ER-CP, Amendment No. 5, Exhibit 8) for staff review. It is the staff's conclusion that all actions outlined by the applicant will result in acceptable soil erosion control. The staff concurs with the applicant's plans to notify in advance the Soil Conservation Service (SCS) at the Conservation District of the county in which line construction activities will involve any earth-moving work. It is the staff's opinion that such contact with SCS will further reduce the possibility of serious erosion problems.

The applicant has selected two clearing methods, "selective" or "tailored" (ER-CP, Amendment No. 5, Appendix 1, Exhibit B), which the staff concludes will minimize construction impacts associated with more severe methods of clearing as well as reduce visual impacts. The applicant has provided a plan for corridor redress (ER-CP, Amendment No. 5, Appendix 1, Exhibits B and C). The staff has reviewed these plans and finds that they are acceptable as proposed; there-fore, the staff does not recommend additional steps for redress.

The applicant states that no known archeological sites are crossed by either line and indicates that if any objects of possible archeological importance are unearthed, the Pennsylvania State Archeologist will be notified for an evaluation of the site.

Neither of the lines crosses or passes in the near vicinity of any registered historic site (ER-CP, Amendment No. 5, 3.9-13).

Effects of Transmission Line 0 eration on Land Use and on the Environment The assessment of those impacts of station operation discussed in the FES-CP are still valid.

Additional or new information is presented in this sections

l. Environmental Im a'ct Transmission line inspection and maintenance will not impact the involved ecosystems, especially since periodic inspections will be conducted by aircraft or on foot.

Use of hand clearing and selective sprayirg of herbicides are planned for routine mainte-nance. Chemical control of vegetation will conform to state and federal regulations and will be applied as directed by these authorities.

All chemicals, when used, will be applied by hand. The applicant has specified numerous precautions so that the possibility of chemical herbicides entering into water bodies will be remote. Herbicides will not be applied aerially (ER-CP, Amendment No. 5).

Ozone and other gaseous pollutants, such as nitrogen oxides, are formei as a result of ionization of air molecules that surround the cylindrical conductors use'd for transmitting electrical energy at high voltages. This ionization is caused by electrical discharge that is termed "corona." The, degree of ionization depends on voltage, humidity, conductor diameter, surface roughness, and spacing between conductors. Calculations indicate that ozone production could be 45 times higher in foul than fair weather. Measurements at 765-kV lines show, however, that at ground level beneath the conductors the ozone concentration does not rise above ambient; furthermore, ground level concentration of ozone is the same on foul days as fair days, presumably because factors favoring increased production rates also favor increased destruction rates. ~ o Recently, experiments were run over a one-year period in Jefferson County, Indiana, on 765-kV lines running over open, flat corn-fields. When instruments were placed six meters downwind from the 765-kV conductors at conductor height, where corona-produced ozone concentration should be greatest, "no ozone attributable to the transmission lines was detectable during the test."'o The natural increase in ozone concentration of 2 to 3 ppb for an increase of 30 m in elevation was observed.

The sensitivity of measuring instruments is about +2 ppb; hence, increases in ozone concen-tration above ambient due to corona from 765-kV lines are within the sensitivities of measuring instruments.'~

C-7 The national, primary air-quality standard for photochemical oxidants prescribes a level of 80 ppb as a maximum one-hour arithmetic mean not to be exceeded more than once per year. Susceptible plant species show damage symptoms from ozone exposure at concentrations as low as 30 ppb,'z~~~ but over prolonged periods ozone is not considered injurious to vegetation, animals, or human beings unless concentrations exceed 50 ppb.~4 On the basis of these considerations, the staff concludes that ozone from SSES's 500-kV lines will be environmentally inconsequential. p There is a possibility that electrical fields set up around transmission lines could affect persons in the .field. Studies have been performed to determine the effects of electrostatic fields on humans. s ~e These studies did not incorporate controls and are limited in both scope and time. For example, cases are known of adults who were unaffected by doses of agents that are teratological or lethal to the fetus or child, and lag times between dose and effect of 20 years or more are known. Since the above studies do not consider children, since children may play beneath the transmission lines, and since controlled studies of long duration have not been carried out, the long-term effect of high voltage transmission lines is currently unknown. However, the staff is not aware of any reported observable effects on humans resulting from exposure to electric fields radiated from high voltage power, lines. The physiological effects reported by the Russians>s were observed on maintenance workers in EHV substations, not on individuals below transmission lines. A recent Russian paper~s stressed that present standards apply only to maintenance personnel working on electrical installations. Russian standards permitting higher voltage gradients for local populations and agricultural workers are currently being considered since these populations will be exposed only infrequently.

The applicant will install a phasing arrangement and increase structure height, if neces-sary, at highway crossings to limit the electrostatic field strength at ground level to 7.5 kV/m. Where the applicant predicted the worst potential gradients (11 kV/m on a single circuit and double circuit 500-kV corridor), a phasing arrangement that will result in a worst-case gradient no greater than 7.83 kV/m at 11 '8 m ground clearance will be used. Significantly lower field gradients will exist at highway crossings where a 16.5-m clearance will be maintained (ER-CP, Amendment No. 5, Section 5.5.1.5 and Applicant's Response to Staff guestions of October 15 and November 18, 1976). Field gradient levels at the edge of rights-of-way will be on the order of 2.4 kV/m or less.

If these gradients occur, using the more consei vative Russian study ~ intended for mainte-nance personnel, a person could spend three hours daily working beneath the lines without adverse effects. The general public is not expected to spend significant amounts of time in the transmission line~right-of-way corridors.

Staff's literature survey indicates that adverse health effects on switchyard workers have been observed, but no such observations were reported from studies on transmission line workers and on individuals outside the switchyard environment exposed to voltage gradients well above 7.5 kV/m.

The staff has analyzed data on the effects of high voltage electric lines on plants and animals and has found no evidence to date indicating hazardous effects to plants or animals from present levels of fields generated from existing transmission line technology.zo In the absence of such observations, the staff believes that there should be no changes in the applicant's proposed design. A number of carefully designed studies of the biological effects of electric fields are currently underway and 'additional studies are planned.

These research projects are being sponsored by Federal agencies, including NRC, to study the effects of transmission line voltage gradients along with long-term effects on the general popu'iation. The staff will keep abreast of these studies and of any guidelines resulting from them and will consider the impacts of the transmission line operation prior to or at the time of the Operating License stage review, taking into consideration any new information (Sec. 4.4.1.2).

Induced currents are unlikely to ignite fuel vapors. but currents capable of shocking people could be induced in vehicles without grounding straps. Any stationary structure with metal parts in and along the right-of-way will be limited to a maximum electrostatic short circuit current of 5 millfamperes (rms);"any object not meeting this criterion will be grounded by the applicant, especia'Ily such objects as metal fences or rail lines that run parallel to the right-of-way. In such objects that are ungrounded, shock causing involuntary muscle reaction may,occur, but no permanent physiological harm is likely.>>

The staff believes grounding measures wil'1 reduce the likelihood of shock to a level that is of no concern.

A transmission line design guideline pertaining to induced currents which the applicant plans to follow, and which the staff considers prudent, fs that ground clearances should

C-8 be maintained so that a maximum induced current of 5 milliamperes (rms) is not exceeded under conditions of maximum line sag when the largest anticipated truck, vehicle, or equipment under the line is short-circuited to ground (ER-CP, Amendment No. 5, Secs.

3.9.5.5 and 5.5.1.5).

The applicant estimates that foul-weather noise (maximum) produced at the edge of the right-of-way of a 500-kV line will be 59 dB(A) (ER-CP, Amendment No. 5, Sec. 5.5.1.2).

However, these worst case conditions will not occur frequently and noise levels will diminish as soon as the conductors begin to dry. The applicant states, and the staff concurs, that the area traversed is very sparsely populated and, therefore, impact due to noise will be minimal.

The applicant addressed the potential impacts of transmission operation on radio and TV reception interference and indicates that investigation and correction of reception problems due to radio interferences will be done on an individual basis as each problem will be unique. Corona-produced television interference is not foreseen for those areas where good television reception is presently obtained during fair weather-. There may be some foul-weather phenomena, but the applicant indicates that the low precipitation type television influence has been found to be less than two percent of foul-weather radio influence at a point 61 m from the outermost conductor; therefore, lines are not expected to cause any significant television disturbances (ER-CP, Amendment No. 5, Sec. 3.9.5.4).

Sunbury-Susquehanna will parallel'n existing 230-kV transmission line for 67.9 km or 96K of its length. In addition, it is proposed that 2.7 km of the line (or the remaining 4X) will parallel the proposed Susquehanna-Siegfried 500-kV line. The staff believes that the paralleling nature of this route, as outlined by Federal guidelines, z a will assure that

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all visual impacts will be on an acceptable level. In addition, it is the staff's opinion that the applicant's right-of-way clearing and maintenance practices will further aid in reducing any potential visual impact associated with both the Sunbury-Susquehanna line and Siegfried-Susquehanna line (ER-CP, Amendment No. 5, Appendix I, Exhibits 8 and C).

The Siegfried-Susquehanna line will cross several esthetically sensitive areas; zamely, the Lehigh River Gorge crossing being considered for use as a state park and Beltzville Reservoir and State Park.

In both cases, the applicant is designing the line to minimize visual impacts. At the Lehigh River crossing, the tower structures will be set back from the gorge, being screened from the canoe run and hiking trail at the bottom of the gorge by the natural terrain.

The applicant has received approval from the Pennsylvania Oepartment of Environmental Resources for this crossing (Applicant's Response to Staff I)uestions, November 18, 1976).

The applicant conducted a feasibility study regarding crossing of Beltzville Reservoir by using new double circuit tubular steel poles instead of existing 66-kU tower structure in front of scenic view. The study concluded, and the U.S. Corps of Engineers agreed, that such a combined crossing presents serious reliability problems. The staff believes that the parallel crossing will not create additional adverse visual impacts to the area.

Based upon the implementation of the applicant's proposed mitigative measures, such as tailored clearing or feather cutting at improved road crossings, parks, peaks and ridges, and stream and river crossings (ER-CP, Amendment No. 5, Sec. 5.5.4.2.b and Appendix 1, Exhibit B), combined with the remote location of large portions of this route, making it unlikely that many people would be affected by it, the staff does not expect unacceptable esthetic impact along the Susquehanna-Siegfried proposed corridor.

Alternatives to the Pro osed Routes The applicant has considered a variety of alternative routes, analyzing both predicted minimum impact routes and minimum cost routes. Three routes were fully examined and compared for each

1. Sunbur -Sus uehanna Line Alternatives Two alternatives to the proposed Sunbury-Susquehanna route (Alternative Rout e A) are co nsi d ered (Figure C.2). Alternative Route 8 leaves the Sunbury Substation in a no th 1 d'Irection and crosses the west branch of the Susquehanna about 3.2 km above the confluence of the Susquehanna. It then proceeds eastward, paralleling the north branch of the Susquehanna, until it passes north of Berwick where it heads southeast to SSES. Alter-native Route C parallels the applicant's preferred corridor out of Sunbury for approxim ox ma t e 1 y 20 km and then leads north, where it jointly crosses the north branch of the Susquehanna

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just east of Reeds Island (southeast of Danville) with an existing line. It proceeds in a basically nor therly direction until it meets with Alternative Route B and then follows the Alternative B corridor into the plant.

It appears to the staff that the applicant has endeavored to utilize existing corridors wherever practical in selection of preferred and alternative routes for the Sunbury-Susquehanna corridor. The preferred route (Alternative A) parallels an existing line (a 230-kV Sunbury-Susquehanna line) for more than 67 km and the remaining 2.7 km will parallel the proposed Susquehanna-Siegfried 500-kV line. Interpretation of the available data indicates that all three alternatives recoamended by the applicant are acceptable and that the applicant's preferred route would be the most environmentally acceptable in terms of fine tuning of environmental impact reduction due to extensive "parallelin9."

2. Sus uehanna-Sie fried Route Alternative figure C.3 shows the three routes examined for termination at the Siegfried Substation.

Alternative B proceeds in a southeasterly direction from the plant, paralleling an existing 230-kV line for almost its entire length until it joins Alternative routes A, the preferred route, and C just north of the Siegfried Substation. Alternative Route C is similar to the preferred corridor except that it departs from the preferred corridor approximately 1.6 km northwest of the intersect'ion of Interstates 80 and 81 and proceeds easterly until it rejoins Alternative A southwest of White Haven. According to the applicant, this route was originally investigated and selected as the prime connection to the Siegfried Sub-station, but a potential generating plant north of White Haven resulted in modification of Alternative C to form Alternative A. It is the staff's evaluation that there are few major differences between alternative routes A and C. The applicant's analysis (Table 10.9-Az) indicates only marginal differences between alternatives A and C. The major difference is that Route C will approach more residential units than Route A. The appli-cant indicates that, from an environmental standpoint, Route B is more desirable. The staff's own analysis also concludes that the paralleling nature of Route 8 would cause a reduction in 68.3 ha of primary forest land needed for additional right-of-way. However, it appears to the staff that none of the corridors pass through any areas requiring unique siting constraints and that the additional acreage required for Alternative A will be an insignificant impact to the large inventory of forested lands in the region. The staff has assessed the applicant's proposed mitigative measures to insure minimal environmental impact and has concluded that these will reduce construction and operating impacts to an acceptable level.

The applicant has provided the staff with more detailed estimates of the length and land area requirements for the above alternatives (Table C.3). Alternative B requires less land area 68.3 ha than the applicant's preferred route (A). Land area requirements for alternatives A and C are judged by the staff to be of similar magnitude. However, Alter-native C does approach approximately twice the number of residences (607) as alternatives A (359} and B (342}. The staff concludes that based on this residential impact, Alter-native C is not preferable to alternatives A or B. Therefore, the staff's environmental analysis of impacts associated with construction of the preferred route (A) and two alter-native routes (B and C) indicates that 1) the applicant's preferred route is environ-mentally acceptable and 2} that selection of Alternative B would cause a slight reduction in terrestrial impacts primarily due to lower right-of-way land requirements.

Table C.3. Right-of-way Data for Alternative Analysis Alternative Length (km) 86.6 81.6 82.4 Area for total right-of-way (ha) 500.4 432.1 474.4 Source: Applicant's Response to Staff guestions, November 18, 1976 (Reference No. 24).

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The applicant has supplied data for the economic costs of the three alternatives.z4 Route A is estimated to cost $ 28,586.522; Route 8 is estimated to cost $ 29,273,095, and Route C is estimated to cost $ 28,346,991. Interpretation of the available data indicates that all three alternative routes for, the Susquehanna-Siegfried line recomnended by the applicant are acceptable. AlternaOve A provides an economic advantage over Alternative B, even though Alternative B would require 68.3 ha less land area to construct. The estimated construction cost'for Alternative C is slightly lower than that for Alternative A; Alterna-tive C would approach more residential units and does not appear to offer unique advantages over Alternative A. In conclusion, although Alternative A does not represent the minimum environmental pat),in the Susquehanna-Siegfried line, from an overall point of view it" does offer the best compromise>bf economic and environmental. considerations. Therefore, the applicant's selection of Route A is reasonable.

II Unavoidable Adverse Environmental Im acts

1. Land Except for small land areas used for tower bases, land will be available for multiple use within the transmission line right-of-way.

2. Water No impacts on water are expected since extensive mitigative measures will be in effect at all water-body cro'ssings ~

3. Air

", Construction activities may cause some dust and emissions of particulates. However, with the applicant's mitigative measures, little air quality deterioration will occur. Little ozone should be produced during operation of the lines.

4. Noise No unacceptable noise levels are expected during construction and operation of SSES trans-mission lines.

C.4. CONCLUSIONS On the basis of the foregoing analysis, the staff has determined that modifications proposed in Amendment No. 4 and 5 combined involve greater environmental impact primarily with respect to the increase in total line lengths from 116 km to 206 km. On a region-wide basis, however, the net environmental impact could be considered lessened, since the additional 90 km of lines are necessitated by the cancellation of a proposed 121-km long line, The proposed transmission routes would pass through areas similar to the Susquehanna-Frackville lines; therefore, the environmental impact evaluation conducted in connection with the initial application still characterizes the nature -of the impacts, and the extent of impacts associated with the proposed change has been analyzed in this assessment. The staff concludes that impacts associated with=the newly proposed transmission routes are acceptable and not substantial.

O Further, impacts of the proposed change in transmission lines discussed above are sufficiently small so that, when they are superimposed upon the other environmental impacts assessed with respect to construction of the plant, the changes in the overall .environmental impact from construction of the plant are not significant, After considering the impacts attributable to the proposed changes, the staff concludes the overall cost-benefit balance previously developed in the FES-CP remain unaltered.

l. "Susquehanna Steam Electric Station: Applicant's Environmental Report," Amendment No. 4, Revised July 1972, Pennsylvania Power & Light, Company, February 1976.

2. "Susquehanna Steam Electric Station: Applicant's Environmental Report, Amendment No. 5, Revised July 1972, July 1976.

3.. Letter dated 8 March 1976, from W. H. Regan, Environmental Projects Branch No. 3, Nuclear Regulatory Commission, to M. W. Cur tis; Pennsylvania Power and Light Company.

I 4, Comnonwealth of Pennsylvania, Department of Environmental Resources, "Pennsylvania State Forest Natural Areas and Wild Areas," August 16, 1976.

5. U.S. Department of the Interior, Federal Register, Vol. 40(188):44418-44423, September 26, 1975.

6. U.S. Department of the Interior, Federal Register, July 12, 1976.

7. U.S. Department of the Interior, Federal Register, Vol. 41(187):41914-41916, September 24, 1976,

8. U.S. Department of the Interior, Federal Register, Vol. 40(127):27824-27924, July 1, 1975. k 9," S. A. Sebo, J, T. Heibel, M. Frydman, and C. H. Shih; "Examination of Ozone Emanating from EHV Lines Corona Discharges"; IEEE Trans. PES 95(2):693-703; March/April 1976.

10. M. Frydman, et al., "Oxidant Measurements in the Vicinity of Energized 765-kV Lines,"

IEEE Transactions on Power Apparatus and Systems, Vol. PAS-92(3):1141-1148, 1973.

W. Davis, Jr., "Ozone Formation by High-Voltage Transmission Line Coronas," Oak Ridge National Laboratory, Central Files Report No. 72-7-25, 19 July 1972.

12. A. C. Costonis and W. A. Sinclair, "Relationships of Atmospheric Ozone to Needle Blight of Eastern White Pine," Phytopathology 59:1566-1574, 1969.

13. P. R. Miller, J. R. Parameter, Jr., B. H. Flich, and C. W. Martinex, "Ozone Dosage Response of Ponderosa Pine Seedlings," University of California, Berkeley Press, 1969.

14. "Coranunity Air guality Guides, Ozone," J. Am. Ind. Hyg. Assoc., 29:299-303, 1968.

15. W. B. Kouwenhoven, et al., "Medical Evaluation of Man Working in AC Electric Fields," IEEE Transactions on Power Apparatus and Systems, Vol. PAS-86, No. 4, April 1967.

16. V. P. Korobkova, et al., "Influence of the Electric Field in 500- and 750-kV Switchyards on Maintenance Staff and Means for Its Protection," Paper 23-06, International Conference on Large High Tension Electric Systems, 25 August - 6 September 1972.

17. M, L. Singewald, et al., "Medical Follow-up Study of High Voltage Linemen Working in AC Fields," IEEE Power Engineering Society Transactions, New York Meeting, 28 January 1973

18. Joint American-Soviet Comnittee on Cooperation in the Field of Energy. "Discussion of Papers Presented at the Symposium on EHV AC Power Transmission," U.S. Department of the Interior, Bonneville Power Administration, Washington, DC, February 1975.

19. Y. I. Lyskov, Y. S. Emma, and M. D. Stolyarov; "Electr ical Field as a Parameter Considered in Designing Electric Power Transmission of 750-1150 kV; the Measuring Methods, the Design Practices and Direction of Further Research"; US-USSR Symposium on EHV AC Power Transmission; Bonneville Power Administration; Washington, DC; February 1975.

20. J. W. Bankoski, A. B. Graves, and G. W. Meku; "The Effects of High Voltage Electric Lines on the Growth -and Development of Plants and Animals!', Proceedings of the First National Symposium on Environmental Concerns in Right-of-Way Management; Mississippi State University; 1976.

21. L. 0. Barthold, et al., "Electrostatic Effects of Overhead Transmission Lines," IEEE Working Group on Electrostatic Effect of Transmission Lines, Paper No. TP 644-PWR, August 1971.

22. Federal Power Coranission, "Electric Power Transmission and the Environment," 1970.

23. United States Oepartment of the Interior and United States Oepartment of Agriculture, "Environmental Criteria for Electric Transmission Systems," 1970.

24. "Susquehanna Steam-Electric'tation: "

Applicant's Environmental Report, Amendment No. 5,"

guestion and Responses,, November 18, 1976.

APPENDIX D. NEPA POPULATION DOSE ASSESSMENT Employing the same models used for individual doses, population dose commitments are for all individuals living within 80 km of the facility (see Regulatory Guide 1.109, Rev.

In addition, population doses associated with the export of food crops produced within the Bb.

region and the atmospheric and hydrospheric transport of the more mobile effluent species such as noble gases, tritium, and carbon-14 have been considered.

NOBLE GAS EFFLUENTS For locations within 80 km of the reactor facility, exposures to these effluents are calculated using the atmosphere dispersion models in Regulatory Guide 1.111, Rev. l., and the dose models described in Section 4.5 and Regulatory Guide 1.109, Rev. 1. Beyond 80 km, and until the efflu-ent reaches the northeastern corner of the United States, it is assumed that all the noble gases are dispersed uniformly in the lowest 1000 m of the atmosphere. Decay in transit was also considered. Beyond this point, noble gases having a half-life greater than one year (e.g.,

Kr-85) were assumed to completely mix in the troposphere of the world with no removal mechanisms operating.

Transfer of tropospheric air between the northern and southern hemispheres, although inhibited by wind patterns in the equatorial region, is considered to yield a hemisphere average tropo-spheric residence time of about two years with respect to hemispheric mixing. Since this time constant is quite short with respect to the expected midpoint of plant life (15 yr), mixing in both hemispheres can be assumed for evaluations over the life of the nuclear facility. This additional population dose coranitment to the U.S. population was also evaluated.

IODINES AND PARTICULATES RELEASED TO THE ATMOSPHERE Effluent nuclides in this category deposit onto the ground as the effluent moves downwind; this continuously reduces the concentration remaining in the plume. Within 80 km of the facility, the deposition model in Regulatory Guide 1.111, Rev. 1, was used in conjunction with the dose models in Regulatory Guide 1.109, Rev. 1. Site-specific data concerning production, transport, and consumption of foods within 80 km of the reactor were used. Beyond 80 km, the deposition model was extended until no effluent remained in the plume. Excess food not consumed within the 80-km distance was accounted for, and additional food production and consumption representative of the eastern half of the country was assumed. Doses obtained in this manner were then assumed to be received by the number of individuals living within the direction sector and distance described. The population density in this sector is taken to be representative of the eastern United States, i.e., about 62 people per square km.

CARBON-14 AND TRITIUM RELEASED TO THE ATMOSPHERE Carbon-14 and tritium were assumed to disperse without deposition in the same manner as krypton-85 over land. However, these nuclides do interact with the oceans. This causes the carbon-14 to be removed with an atmospheric residence time from four to six years, with the oceans being the major sink. From this, the equilibrium ratio of the carbon-14 to natural carbon in the atmosphere was determined. The same ratio was then assumed to exist in humans so that the dose received by the entire population of the United States could be estimated. Tritium was assumed to mix uniformly in the world's hydrosphere, which was assumed to include all the water in the atmosphere and in the upper 70 m of the oceans. With this model, the equilibrium ratio of tritium to hydrogen in the environment can be calculated. The same ratio was assumed to exist in humans and was used to calculate the population dose in the same manner as carbon-14.

Concentrations of effluents in the receiving water within 80 km of the facility were calculated in the same manner as described for the Appendix I calculations. No depletion of the nuclides D-1

D-2 present in the receiving water by deposipion on the bottom of the Susquehanna River was assumed.

The assumption that aquatic biota co>centrate radioactivity in the same manner as was assumed for the Appendix I evaluation w~6 also made. However, food consumption values appropriate for the average individual, r>ther'han the maximum, were used. It was assumed that all the sport and coranercial fish and.shellfish caught within the 80-km area were eaten by the U.S. population.

Beyond 80 km~1 was assumed that all liquid effluent nuclides ~ with the exception of tr itium, have d ~ted on the sediments so they make no further contribution to population exposures.

T ~ritium was assumed to mix uniformly in the world's hydrosphere and to result in an exposure the U.S. population in the same manner as discussed for tritium in gaseous effluents.

APPENDIX E. EXPLANATION AND REFERENCES FOR BENEFIT-COST SUHHARY Economic Im act of Plant 0 eration Direct Benefits - The staff has evaluated the total direct benefit of the Susquehanna Nuclear Station production of baseload energy by calculating entire -"

output of the facility at 60K capacity factor. Applicant owns 90%

of the facility. Refer to Section 7.

Indirect Benefits - A small portion of the state tax is provided to the impacted local, counties ($ 65,000). Refer to Sections 4.6.6.1 and 4.6.6.2.

Economic Costs - Operating costs: Supplied by applicant.

Decommissioning costs: The staff has estimated decoranissioning costs in 1975 dollars at $ 59 million.

1. Deactivating the reactors

2. Decontaminating of process systems and areas of plant

3. Removing all nuclear fuel from the site for recovery of fuel materials and ultimate disposal of radioactive wastes

4. Sealing of building or portion of building containing activated process piping and components by means of blocking, bolting, or welding plates over openings, etc.

5. Dismantling and sealing of all gaseous and liquid waste systems and effluent lines

6. Haintaining some security and fire systems

7. Ultimate dismantling of station Environmental Im act of Plant*

Item 1 - Impact on water Item 1.1 - Consumption (nuclear station consumption): The amount of water consumed by the applicant for operation is estimated to average 1.4 ms/s. This amounts to 26,000,000 m~/yr at a 60K capacity factor.

,, Item 1,2 - Heat discharge to natural water body 1.2.1 - Cooling capacity of water body: J/hr rejected heat 3.4 x 10 (max) 1.2.2 - Aquatic biota: insignificant.

1 2.3 - Higratory fish:

~ insignificant.

Item 1.3 - Chemical discharge to natural water body (Includes Items 1.3.1, 1.3.2, 1.3.3, and 1.3.4): chemicals will be discharged to the Susquehanna River. The 1,400,000 kg/yr chemical discharge is an annual average, mainly sulfate.

Item 1.4 - Radionuclide contamination of natural water body: See Sec. 4.5.

Item 1.5 - Chemical contamination of groundwater: see Item 1.3, above.

Item 1.6 - Radionuclide contamination of groundwater: See Sec. 4.5.

• The index numbers used in this and the next section correspond to those used in Table 9.1.

E-1

E-2 Item 1.7 - Raising/lowering of groundwater levels ( Includes is expected.

Items 1.7.1 and 1.7.2): no effect ~

Item 1.8 - Effects on natural water body of intake structure and condenser cooling systems:

unknown.

1.8.1 - Primary producers and consumers: chemical discharges are discernible (Sec. 4.3.3).

1.8.2 - Fisheries: additional studies are warranted relative to the effect of construction and operation of the intake structure upon fish productivity.

Item 1.9 - Natural water drainage 1.9.1 - Flood control: no damage to station or immediate vicinity.

1.9.2 - Erosion control: no significant erosion is expected.

Item 2 - Impact on air Item 2.1 - Chemical discharge to ambient air 2.1.1 - Air quality-chemical: no impact. Entries for CO, NOx, and HC are non-zero because of operation of diesel equipment several hours per month.

2 '.2 - Air quality--,odor. no impact.

Item 2.2 - Radionuclides discharged to ambient air 2.2.1 - Noble gases: See Sec. 4.5.

Item 2.3 - Fogging and icing: offsite icing may occur when the spray pond is operating (Sec. 4.4.1).

Item 2.4 - Salt discharge from cooling system 2.4.1 - People: see FES-CP, p. 3-41.

2.4 ' - Plants and soil: See ER-OL, p. 5.3-5.

Item 3 - Impacts on terrestrial systems Item 3.1 - Station area: acceptable. See ER-OL, Section 3.1-5.

Item 3.2 - Bird impingement on station facilities: should be monitored. See Sec. 5.3.6.

Item 4 - Transmission line corridors Item 4.1 - Right-of-way maintenance and inspection: See Sec. 4.5 and Appendix C.

Item 4.2 - Production of ozone, other gaseous pollutants: See Sec. 4.5 and Appendix C.

Item 4.3 - Audible noise: See Sec. 4.5 and Appendix C.

Item 4.4 - Radio and TV interference: See Sec. 4.5 and Appendix C.

Item 4.5 - Electrical field effects: See Sec. 4.5 and Appendix C.

Item 5 - Total body dose commitments to UPS. population general public, unrestricted area:

See Sec. 4.5 and Appendix C.

Societal Im act of Plant Item 1 - Operational fuel disposition Item 1.1 - Fuel Transport: Ten truck shipments of new fuel plus 13'rain shipments of radio-active spent fuel assemblies per year.

Item 1.2 - Fuel Storage: The staff assumes storage of new fuel to be provided for in plant design within the reactor building.

Item 1.3 - Waste Products: Onsite storage of spent fuel assemblies is normal and is assumed for SSES.

E-3 Item 3 - Historical arid archeological sites: (see Sec. A.2.7).

Item 4 - Station operational noise: exceeds EPA standard but is to be- monitored by applicant.

Refer to Section 5.3.5.

Item 5 - Social costs: include social stresses, demand on public services, and housing.

Item 6 - Esthetics: acceptable. Refer to Section 4.4.1.1.

J" "it1iJ3 3,.

C. ~

'(

i

APPENDIX F. APPLICATION FOR NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM (NPDES) PERMIT TO DISCHARGE TO STATE WATERS NPDES Application No. PA-0047325

F-2 DEPARTMENT OF ENVIRONMENTAL RESOURCES Bureau of Water Quality Management Wilj:es Barze Regional Office 90 East Union Street - 2nd Ploor Wilkes Bazre, Pa. 18701 July 31, 1979 Zndustzial Waste NPDES Permit No. PA-0047325 Pennsylvania Power s Light Company Susquehanna Steam Electric Salem Township RECEIVED Luserne County AI3G' 1979 Pivla IiIcalzg,g Pennsylvania Power S Light Company Susquehanna Steam Electric c/oNr. John T. Kauffman Executive Vice President, Operations Two North Ninth Street Allentown, Pa. 18101 Gentlemen'he subject permit is enclosed.

Please study the perad.t carefully and direct any questions to this office. Our telephone number is (717) 826-2553.

V truly yo, g wrence A. Pawlush Regional Water Quality ttanager LAP:JPLihp Enclosures - NPDES Permit NPDES Discharge Honitoring Repozt DMt Znstructions

,cc: Pile Program Services Richard L. Constrisciano Environmental Engineer Water Enforcement Branch Pennsylvania Section 3EN22 U.S. Environmental Protection Agency Si"th S Walnut Streets Philadelphia, Pa. 19106.,