ML18230B017

Responds to 11/21/1972 Letter Requesting Comments on Atomic Energy Commissions Draft Statement, Dated November 1972 on Environmental Consideration for Shearon Harris Nuclear Power Plant Units 1,2,3, and 4

ML18230B017
Person / Time
Site:	Harris
Issue date:	02/22/1973
From:	US Dept of Interior (DOI)
To:	Muller D US Atomic Energy Commission (AEC)
References
Download: ML18230B017 (16)

Text

AEC DI RIBCTION POR PART 0 DOCKET MA -1ZAL Ti'iPORARY 1'ORA>A C

CONTROL'o! 1272 ENVIRO FBONo Dept of Interior Washington, D. C.

20240 W. W. Lyons To'.

R. Mu11er CLASSl U PROP XNro DATE OF DOC:

2-22>>73 ORIG 1.signed INPUT DATE REC'D 2-23-73 CC NO CYS REC'D

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Ltr re our 11-21>>72 1tr....furnishing comment on Draft Enviro Statement......

ENCLOSURES:

KANT NAMES:

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United States Department of the Interior OFFICE OF THE SECRETARY WASHINGTON, D.C.

20240 50-400 50-401 50-402 50-403 ER-72/1349

~cIVIn, FEB 83 1973'S.

ATOMIC EIIEllOT COMMISSIOM RaSalatary Mall Seclloa

Dear Mr. Muller:

OI This is in response to your letter of November 21, 197 cn requesting our comments on the Atomic Energy Commission's draft statement, dated November

1972, on environmental consider ations for Shear on Harr is Nuclear Power Plant, Units 1, 2,

3 and 4, Wake and Chatham Counties, North Carolina.

General 4

We are concerned that coordination among the applicant, AEC, and appropriate bureaus of this Department does not take place early enough and in sufficient depth to permit adequate protection or appropriate enhancement of the en-vironmental resources which are responsibilities of this Department.

Our reviews of.the applicant's environmental reports and AEC's environmental statements do not occur at an early enough time in the project formulation and does not involve sufficient time for an adequate discharge of our overall environmental responsibilities.

Often, at the time these documents are received, large sums of funds have been expended and significant environmental effects have already occurred.

We believe that the public interest will be best served by an earlier and closer coordination between AEC and the appropriate bureaus of this Depax'tment.

The Bureau of Sport Fisheries 8 Wildlife, Bureau of Outdoor Recreation, National Park Service, and the Geological Survey should be consulted in all cases at an early enough time in the site selection and formulation of the project that real and significant inputs can be made by these bureaus.

Xn this par ticular case, the Bur eau of Spor t Fisher ies Wildlife did have some early preliminary input in assessing the population density of various terrestrial fauna.

We appreciate the opportunity for this early involvement but do not consider this reconnaissance study an adequate input.

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We believe that the public interest would be served by an updating of the 1964 Memorandum of Understanding between AEC and Interior.

This updating would provide for studies to be made by various bureaus in the interest of protecting and enhancing the environment in addition to health and safety of the public.

Our detailed comments are presented according to specific subjects or according to the format of the statement.

Histor i;cal 'Si nifi'cance We are pleased that the North Carolina Department of Archives and History, whose Director is the State Liaison Officer for'istoric Preservation, was consulted.

We suggest that a professional archeological survey should be made to establish the presence or absence of archeological resources within the affected area.

The results and recom-mendations for action to protect az'cheological values should be included in an*evaluation of impacts upon cultural resources.

Archeological counsel may be obtained from Dr. Joffxe L. Coe, Professor of Anthropology, University of North Carolina, Chapel Hill, North Carolina 27514.

The proposed action will not directly affect any existing or proposed units of the National Park System, or any sites that are eligible oz recommended for registration as National Historic, Natural, oz Environmental Education Landmarks.

~Geolo The brief description of the geology and seismology presented in the draft statement is inadequate for an independent assess-ment of the geologic environment relevant to the proposed construction of the plant.

The data presented are inadequate concerning the'hysical properties of the geologic materials on which the plant and its appurtenant structures will be

founded, and there is no indication of how a knowledge of the physical properties has been used in the design of the facility.

The seismic-design criteria and the methods of their derivation are not mentioned.

Comprehensive discussion of these factors would constitute part of an adequate assess-ment.

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3'he statement references the applicant's Preliminary Safety Analysis Report to the AEC which, with its supplements, treats the details of the geologic and seismologic investi-gation and analysis that have been performed for the project.

We suggest that, as a minimum, a more comprehensive summary of the geologic and seismologic analysis sections of the Preliminary Safety Analysis report be included in the final environmental statement with adequate cross references to appropriate parts of the environmental statement to indicate how the data and analysis, have been utilized for purposes of design and construction of the facility.

As a result of procedures previously established between the Geological Survey and the AEC, we are presently reviewing the geologic aspects of the site that are included in the Preliminary Safety Analysis Report.

Our review is being conducted in terms of the AEC "Seismi'c and Geologic Siting Criteria for Nuclear Power Plants" (10 CFR Part l00, pro-posed Appendix A).

Since we are currently 'reviewing unre-solved aspects of the engineering geologic and soils con-ditions of the plant and the proposed, reservoir, we are unable to provide an. overall assessment of the impact of the geologic environment as related to the construction at this time.

The Geological Survey's,completed review and assessment will be made part of the public record in the AEC licensing procedures.

~Eoolo The table on page'-29 should be accompanied by an explanation of the thoroughness of the data represented.

The Bureau of Sport Fisheries and Wildlife s survey was a brief reconnais-'ance study made during the very early stages of site selection and does not'ontain sufficient data to represent the present productivity, or the long-term future productivity of the project area.

Such data should be determined by continuing studies involving frequent sampling over an extended period of time.

The discussions on pages 2-23 and 2-27'hould be modified to reflect the pr eliminary data upon which it ap-pears to be based.'his section should also indicate that the game species could be.increased with proper management.

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Radioacti've Wa'ste'ys't'e'ms The applicant plans to release low-level liquid radioactive wastes into the circulating water system to be further diluted in the reservoir prior to reaching the Cape Fear River via normal reservoir r'eleases.

Because the circu-lating cooling water discharge is generally much greater than the flow through the reservoir, some buildup in radio-active waste concentrations may be expected in the reservoir The applicant has used annual waste release figures and res-ervoir volume in his environmental report in arriving at equilibrium concentrations which might be expected.

While the method of computing buildup concentrations in such a

flow system is questionable, the method is sufficiently conservative to indicate that 10CFR20 and 10CFRSO criteria will probably be met.

However, according to page 3-11 the AEC staff believes that tritium releases for the four units will be about 14 times that suggested by the applicant.

We suggest that the applicant consider the possible long-term buildup of tritium levels in the reservoir.

He should out-line a detailed monitoring program which will detect any unexpected waste buildup in remote areas of the cooling reservoir Outdoor Recreation Since the proposed project is located within 20 miles of the fast growing Raleigh Standard Metropolitan Statistical Area, the population within a 50-mile radius is currently estimated to be 1,062,000 and projected to exceed 2 million by 2010, and there are only a limited number of recreation areas in the vicinity of the site; we believe that the environmental statement should addressIin much more detail the total impacts on,the outdoor recreational opportunities.

According to page 3-24, the applicant will cooperate with state and local agencies, property owners and the other individuals in creating recreational and wildlife opportu-nities along portions of the transmission line right-of-way.

We hope that this same cooperation will be given to design and po'ssible use of the lake for recreational uses including the maintenance of wildlife refuges presently planned for areas adjacent to.the reservoir.

We believe that the proposed project could offer an excel-lent oppor tunity for Feder al, State, and local gover nments to wor k with the applicant in br inging about the above recommendations.

There is a need for the applicant to insure that reer cation potentials ar e planned, developed, and managed as an integrated element of the project.

A master plan for recreation could help serve this purpose.

A fish and wildlife management and public use plan for the project area should be prepared by the app18.cant in cooper-ation with the North Carolina Wildlife Resour'ces Commission and the Bureau of Sport Fisheries and Wildlife and the Bureau of Outdoor Recreation "of this Department and'nclu-ded in the final environmental statement.

We understand that the State of North Carolina has recom-

mended, through its 1972 North Carolina Statewide Compre-hensive Outdoor Recreation Plan, that a master plan for recreation be required for all reservoirs of 1,000 acres or move in surface acres and in view of rapidly rising land costs and urban population increases, State and local governments and outdoor recreation systems adjacent to metr opolitan areas while the oppor tunity exists.

Water Use The applicant has performed an analysis of the worst com-bination of Cape Fear R'iver flow, Buckhorn Creek basin in-flow, rainfall, natural and forced evaporation, seepage losses and demand from the auxiliary heat sink pond as it effects operation of.the main cooling reservoir.

We agree with the applicant's analysis except that his monthly consumptive use value figure of 52cfs for forced evaporation appears to be slightly low.

Conversely, the AEC monthly figure of 130cfs for forced evaporation during a critical summer month appears to be far above a realistic estimate even if 100~~ of the heat is assumed lost through the evaporative process.

In our opinion, at no time would more than about 100cfs be lost as forced evaporation and during most of the year an average of about 70cfs would be lost.

We agree that relatively high temperatures will be reached in the reservoir, but that the temperature of the water entering the Cape Fear River will probably not be excessive.

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But, because ther e are considerable uncer tainties as to makeup flows available and ultimate water temperatures which will be realized, an operational monitoring program is es-sential.

AEC has indicated on page iiithat a comprehensive environmental monitoring program will be a condition to the issuance of construction permits.

Based on the data presented, vertical percolation and horizontal movement of water in the Triassic rock aquifer beneath the site is expected to be slow.

Most ground-water movement will be toward White Oak Creek, presently a tribu-tary of Buckhorn Creek.

With completion of the reservoir, ground-water movement in the plant site area would be toward the reservoir.

No wells presently exist in the plant site area which would conceivably be contaminated by direct leakage or spillage of liquid radioactive wastes from the plant.

A uatic Ecolo This section does not adequately treat'he impact of operation of this plant on the fish population expected to develop in the reservoir.

The statement mentions crowding, trapping, reduction in food supply, disease, predation and heat but does not indicate the number or type of fish that are expected to inhabit the reservoir.

Even though the primary puipose of the reservoir is to constitute a cooling medium, the aquatic re-sources expected to be developed should be assessed.

Plant 0 er'ation Accidents This section contains an adequate evaluation of impacts re-sulting from plant accidents through Class 8 for airborne emissions.

However, the environmental effects of releases to water is lacking.

Many of these postulated accidents listed in Table 7.1 could result in releases to the Cape Fear River and should be evaluated.

We also think that Class 9 accidents resulting in both air and water releases should be described and the impacts on human life and the remaining environment discussed as long as there is any possibility of occurrence.,

The consequences of an ac-cident of this severity could have far-reaching effects on land and in the Cape Fear River basin which could persist for centuries.

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'a'nd Irr'e't'r'i'e'v'ab'1'e'Comm'i'tme'n't'o'f Res'our ces This section does not acknowledge the commitment of fish and wildlife and'ecx.cation resouxces.

The loss of terrestial flora and fauna, their habitat and str earn fishing on Buckhor n Cx eek should be x ecognized as ixr ever sible commitments a

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Atlexnative Znex',-Sour ces We suggest that,~the positive aspects of using either'oal or oil should be"mentioned on pages

'9-8 through'-10.

Two of these would be no radioactive emissions and elimination of handling xadioa'ctive fuel or wastes.

F We hope these comments will be helpful in the preparation of the final environmental statement.

Sincer e ur Deputy Assistant Seer etax'y of the Interi Mx. Daniel R. Muller Assistant Director for Environmental Projects Directorate of Licensing U.S. Atomic Energy Commission Washington, D.

C.

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