ML18192A221

Comments on NRCs Final Environmental Impact Statement Forwarded with Letter of Sept. 25, 1975

ML18192A221
Person / Time
Site:	Palo Verde
Issue date:	12/30/1975
From:	Doremus S US Dept of Interior, Office of the Secretary
To:	Regan W Office of Nuclear Reactor Regulation
References
PEP ER 75/393
Download: ML18192A221 (10)

Text

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.r Dear Mr.

Regan:

Thank you for your letter of September 25, 1975, forwarding the Nuclear Regulatory Commission's final environmental impact statement on the Palo Verde Nuclear Generating, Station, Units 1, 2, and 3, Maricopa County, Arizonan We have several comments presented according to s

d Fish and Wildlife OE 4p We find that many of our comments on the draft ha@

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<g been r esponded to in the final statement.

Relative to our comments on pages A60 and A62, no men was made in the final statement of a fish and wildlife p or possible coordination with Federal, State and local agencies.

The monitoring program was not adequately changed to reflect environmental concerns.

The final statement only suggests that the applicant sample invertebrates.

The previous suggestion that soil microorganisms be sampled has been eliminated.

We believe that both these groups should be sampled.

The NRC staff states that density measurements have been made for reptiles and amphibians (Table 6.2, page 6-5) and -herbaceous plants (Section 6..1.3.1, page 6-2).

No data have been presented in either the environmental state-ment or the applicant's environmental report to describe these populations for subsequent evaluation.

There still is no mention that baseline and operational monitoring of fish and wildlife will be carried out along the Salt and Gila Rivers downstream from the cooling water diver sion.

As stated in our comments on the draft statement, this is where the greatest adverse impacts on fish and wildlife may occur.

Also, there still is no meaningful radiological monitoring program for wildlife and native plants, since only the jackrabbit would be monitored.

Native plants and a spectrum of wildlife at various levels of the food chain should be monitored.

CONSERVE

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We have made various comments on thr eatened and endangered species.

Relative to this, Section 5.5.1.1, page 5-14, par agr aph 3, states:

"Water diversion by PVNGS will result in decreased water availability below Gillespie Dam.

This may adversely impact the Gila topminnow, an endangered species thought to inhabit pools in this region of the Gila River.

The,staff believes that the extent to which these fish and other riparian biota are impacted by water diversion by PVNGS will depend upon water use for irrigation below Gilles-pie Dam and the d'egree of river recharge from

.groundwater."

We believe that the.extent to which Gila topminnows and other animals are impacted by water diversion by PVNGS depends strictly on PVNGS's water diver sion.

Furthermore, the final statement ignores our comment on the draft statement

.that there is a high probability that this fish also exists above Gi.'llespie Dam.

We bel'ieve that the occupied habitat of this fish should be identified, and if found to exist within the project area, that necessary mitigation should'e developed.

The final statement fails to respond to our recommendation that. biologists be hired by the applicant to determine endangered species habitats (such as raptor nesting areas or small springs with unique animal populations) in the ultimately selected trans-mission line routes.

It is our contention that post-EIS biological work is necessary along proposed transmission line routes to delineate specific important habitats.

We note that in the mitigation section on page 4-18, No. 7, the staff has already required that the applicant do this for endangered or threatened annual and perennial herbaceous plants.

We believe it is at least equally important that it be done for wzldlz.fe,.

No clarification has been offered concerning our comment on the large discrepancies between the environmental statement and the applicant's environmental reports regarding the amount of habitat that will be disturbed by the project.

Table 10.3'f the final statement still shows that 1,600 acres of habitat is being disturbed by the project,, at least 1,000 acres less than shown in the applicant'.s environmental reports.

This

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should be resolved.

As we stated in our comments on the draft statement, reasonably accurate figures should be given for the amount of habitat disturbed by each project feature and the total amount disturbed.

Insufficient information on water availability after the applicants divert cooling water is one of our major concerns which the NRC staff has dealt with significantly in the final statement.

Section 11.1.5.1, page 11-5, states, "Because of questions raised from several quarters',

the applicant has commissioned two further independent detailed studies to better characterize the area water use/balance, and how these will be affected by the project."

We believe these studies have considerable merit.

TRANSMISSION CORRI'DORS Relative to our comments on page 'A-57, the final statement has no discussion of,alternative transmission line corridors, except for the. Kyrene line system, as was the case in the draft statement.,

In Section 3.8, page 3-28, paragraph 2, the final statement notes that, "The proposed alignments have alterna-tives which might be employed if the preferred alignments are not acceptable to any governmental agency having jurisdiction in such matters."

Transmission line alternatives, especially when the transmission line system is as extensive as in this

project, should be properly displayed and discussed in the environmental impact statement in order that the environmental impacts can be assessed.

ARCHEOLOGICAL AND CULTURAL RESOURCES Although the final statement provides information on cultural resources, it is incomplete in significant areas.

It fails to fully identify and evaluate those resources which may potentially be eligible for nomination to the National Register of Histoiic Places in accordance with the National Historic Preservation Act of 1966 and Executive Order 11593.

If such steps have been taken to determine the eligibility of

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these sites, this is not evident in the final statement.

One site in question is the Sasco Ruin through which it is indicated that Link f47 of the transmission line will pass.

This resource as described appears to be eligible for inclusion in the National Register.

Our comment, page A-49, was as follows:

The final statement'should incorporate this information and include a copy of the comments by the Arizona and New Mexico State Historic Preservation Officers, regarding the effects of the project upon properties either listed on or in the process of nomination to the National Register of Historic Places."

No comments or other information from the State Historic Preservation Officer are supplied in the final statement.

Xn view of the importance of the Historic Preservation Officer in these procedures, it is recommended that in future environ-mental statements of this nature that the draft statement be sent directly to this officer fox comment.

We hope these comments will be helpful to you.

Sincerely yours, DGPut7 hssist>>c Secretary of the gnterior Mr. William H. Regan, Jr.

Chief, Environmental Projects Branch 4

Division of Reactor Licensing Nuclear Regulatory Commission Washington, D.

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