ML18031A254

Comments on Des.Suggests Effect of Consumptive Withdrawal on Aquatic Habitat During Prolonged Periods of Low Flow Be Addressed & That Monitoring Program Include Plant Intake & Discharge Flows

ML18031A254
Person / Time
Site:	Susquehanna
Issue date:	08/30/1979
From:	Bielo R SUSQUEHANNA RIVER BASIN COMMISSION
To:	Regan W Office of Nuclear Reactor Regulation
References
NUDOCS 7909070365
Download: ML18031A254 (9)

Text

g Milt rlrp/p OlC I~ ~ ~ Pi ttt ~ ~+ (,, r SUSQUKHAivNA RIVER BASIN CQMlvIISSIO:i t721 North Front Street Her! isourg, Pennsylvania 17! 02 4

I+ ~ ~a F!om the Office of the August 30, 1979 Executive Director

'Mr. William H. Regan, Jr., Chief Environmental Projects Branch 2 Division of Site Safety and Environmental Analysis Nuclear Regulatory Commission Washington, DC 20555 Re: Docket No. 50-387, 50-388

Dear Mr. Regan:

Reference is made to your letter dated June 22, 1979 trans-mitting the draft Environmental Statement for Susquehanna Steam Electric Station presently under construction by Pennsylvania Pow'er and Light Company. The Commission staff has the following comments on this draft.

l. water Zn section 3.2.1, page 3-1, it is stated that station requirements have increased since the construc-tion permit stage. Apparently the basis for this state-ment is the river intake flow shown in Table 3.1 which ih,P,5 is shown as increasing by 0.45 cms (about 15 cfs) . How-ever, we cannot verify the 1972 figure shown in Table 3.1 nor can we determine the reason for the increased water withdrawals. Also, the text states that water withdrawal will be at. a rate of 1.8 to 2.2 cms, but the table shows 2.Q5 cms. Please clarify the discrepancy and the reasons for increased water withdrawal. Also please clarify the text to indicate whether the increase pertains to water withdrawal or consumptive use.

2. Zn section 3.2.1, the discussion of the SRBC regulation is incorrect. The applicant will still be permitted to withdraw water during periods of low flow, but the amount gl"t> of the consumptive use must be replaced. The proposed reservoir is not an alternative source of water but only a source of makeup water. The regulation is correctly stated in section 4.3.2.1 except that the third sentence should read, "The regulation requires replacement of consumative use..."

3. Zt is stated on page maximum consumptive use iiiisandestimated again in Table 3-1 to be 1.81 that the cms (63.9

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Mr. W. H. Regan, Jr. August 30, 1979 cfs).

appears The basis for that number is not clear, but it to be based on four years of climatic data col-lected at the site. If so, it may not he representative of actual worst evaporative conditions experienced at the site. The Commission's concern, from the viewpoint of water management, is the pxobability of maximum con-sumptive use, expected under the worst set of climatic conditions, occurring concurrently with low flow. The draft EIS statement has not addressed this concern.

Also, the pxocedures and assumptions used in making the calculation of maximum and average consumptive use should be clearly stated.

4. It is stated on page iii that the river flow at which consumptive use must be replaced is 23.2 cms (819.0 cfs) .

This figure should be equal to the 7-day, 10-year low flow plus the consumptive use. Our analysis of 7-day average low flow frequency at Wilkes-Baxre, based on the period of record 1900-76, shows that the 7-day, 10-year low flow is 800 cfs. The applicant has used the value of 770 cfs which is based on an analysis by USGS for the shorter period 1900-72. We believe our analysis is moxe correct by virtue of including additional x'ecord.

Also, we believe that the consumptive use value used should be the maximum consumptive use, which is stated to be 64 cfs, rather than the average consumptive use used in your report. This is important in detexmining the storage required for consumptive loss makeup. The applicant has stated that they have computations show-ing that the design of the reservoir based on the 50 cfs average loss will provide adequate storage in a re-peat of the 1964 drought of x'ecord. We have as yet not seen that data.

5. In section 3.2.2.3, page 3-8, the 7-day, 10-year low flow is identified as 23.2 cms (819.0 cfs). That appears to

'(qP be inconsistent with the above comments, and with section 4.3.2.1, page 4-2 where the 7-day, 10-year low flow is stated as 21.8 cms (769.8 cfs).

6. The proposed intake structure may not, meet the require-ments of section 316(b) of PL 92-500. According to the Environmental Statement, the "embayment intake will re-move more biomass than an altexnative intake..." SRBC staff xecommends that an intake structure be designed using best available technology before the plant is is-sued an operating license.

E Mr. W. H. Regan, Jr. 3 August 30, 1979

7. Staff is concerned about the effect of the consumptive withdrawal on acmatic habitat during prolonged periods of low flow. This concern should be addressed in the draft statement.

8. The post-operational monitoring programs do not include any provision for metering plant intake and discharge flows. We recommended to Pennsylvania DER that such flow meters be recpxired in connection with approval of the encroachment permit for the intake and discharge structures,. but these are not addressed in the Environ-mental Statement. We still believe that metering flows is an essential part of the environmental monitoring program.

Thank you for the opportunity to comment on this environmental statement.

truly yours, r,,

Very J./Bielo

/'('obert Executive Director

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