ML19199A486
| ML19199A486 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 11/22/1971 |
| From: | US ATOMIC ENERGY COMMISSION (AEC) |
| To: | |
| Shared Package | |
| ML19199A484 | List: |
| References | |
| NUDOCS 7905030003 | |
| Download: ML19199A486 (23) | |
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DISCUSSION AND FINDINGS SY THE DIVISION OF REACTOR LICENSING U. S. ATCMIC ENERGY CCMMISSION RELATING TO CONSIDERATION OF SUSPENSION PENDING NEPA _E G'IRONMENTAL REVIEW OF THE PROVISIOFAL CONSTRUCTION PERMIM FOR THE IHREE MILE ISLAND NUCLEAR GENERATING STATICN UNITS 1 AND 2 METROPOLITAN EDISON COMPANY, AND JERSEY CENTRAL POWER & LICHT COMPAW AEC DOCKET NOS. 50-289 AND 50-320 NOVEM3 ER 2 2, 19 71 r, C, 5" a
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1.0 INTRODUCT ION On September 9, 1971, the Atomic Energy Commission (AEC) published in the FEDERAL RICISTER a revised App 2ndix D to 10 CFR Part 50 setting forth AEC's implementation of the National Environmental Policy Act o f 19 69 (NEPA). Paragraph E (3) of revised Appendix D requires a holder of a construe:1on permit for a production or utilization facility issued prior to January 1,1970, but for which neither an operating license nor opportunity for public hearing on the operating license had been issued before October 31, 1971, to furnish to the AEC within 40 days o f September 9,1971, a written statement of any reasons, with supporting factual submission, why with reference to the critaria in Paragraph E (2) of revised Appendix D the permit should not be sus-pended,.in whole or in part, pending completion o f the NEPA environ-mental review specified in Appendix D.
By letter dated October 19, 1971, Metropolitan Edison Company and Jersey Central Power and Light Company submitted the statement required by Paragraph E (3) of Appendix D.
1.1 Determination In accordance with the requirements of Section E of revised Appendix D, we have determined that certain cons t ruction activit ies for the Three Mile Island Nuclear Generating Station Unit 2 should be suspended pending completion of the NEPA environmental review specified
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Specifically, we have determined that work on the off. :e portions of the transmission lines for Generating Unit No. 2 should be suspended until the ongoing NEPA review is completed.
The time necessary to complete this review will be approximately eight months. With respect to all other cons truction activities for both Units we have balanced the environmental f actors and concluded that these activities need not be suspended.
A formal " Determination" to this effect is being forwarded to the FEDERAL REGISTER for publica-J tion.
In reaching this determination, we have considered and balanced the criteria in Paragraph E (2) of Appendix D.
1.2 Background
on May 3,1967, Metropolitan Edison Company filed an application for* a construction permit for the Three Mile Island Nuclear Generating S tation Unit No. I with the AEC.
This Unit is a pressurized-water nuclear generating station proposed to cperate at p ver levels up to 2452 MWt and is located on Three Mile Island, an island in the Susquehanna River, in Londonderry Township, Dauphin County, Pennsylvania.
An extensive review of the application was made by the AEC regulatory staf f and by the Advisory Committee on Reactor Safeguards. A public hearing was held on April 10-11, 1968, at Middle town, Pennsylvania, before a three member Atomic Safety and Licensing Board.
The hearing
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. was not a contested proceeding. On May 16,19 68, the Atomic Safety and Licensing Board issued its initial decision authorizing the Director of Regulation to issue a construction permit to the applicant.
Provisional Construction Permit No. CPPR-40 was issued by the AEC on May 18, 1968. On June 25, 1970, the Metropolitan Edison Company and Jersey Central Power & Light Company filed an application for an operating license for the Three Mile Island Nuclear Generating Station Unit No.
1.*
On April 29, 1968, Jersey Central Power and Ligh t Company filed and subsequently ammended an application with the AEC for a construc-tion pe rmit to construct a pressurized-water nuclear generating sta-tion to operate at power levels at 2452 MWe ( 810 MWe) ( ul tima t'e maximum capacity 2772 MRt and 920 MWe). This unit was designated as Three Mile Island Nuclear Generating Station, Unit 2.
The AEC regulatory staf f and the Advisory Committee on Reactor Safeguards made extensive studies of the application and supplemental information. The ACRS reported a favorable review by letter dated July 17, 1969. A public hearing was conducted by a three member Atomic Safety and Licensing Board on Octcber 6,1969, at Middletown, Pennsvivania. The hearing was not a contested proceeding.
Th e Jersey Cencral Pcwer and Light Company and Pennsylvania Elactric Cocpany
.tre co-acplicants of Metropolitan Edison Company for an opcrating L1 tense for Jnit No. 1.
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. Atomic Safety and Licensing Board issued the initial decision on O c tobe r 31, 1969, authorizing the Director of Regulation to iss ue a provisional construction permit to the Jersey Central Power and Light Company and the Metropolitan Edison Company.
(Provisional Construction Permit No. CPPR-66 was issued by the AEC on Novemo er 4, 1969.) The Atomic Safety and Licensing Appeals Board reviewed and af firmed the order of the Licensing Board on November 25, 1969.
By letter dated July 15, 1970, the AEC informed the Metropolitan Edison Company of the newly enacted National Environmental Policy Act of 1969 and '4ater Quality Improvement Act of 1970, requiring that certain information be submitted pertaining to the af fects o f the proposed operation of Thr?e Mile Island Nuclear Generating Station.
O n O c t obe r 1, 19 70, the Metropolitan Edison Company submitted the environmental report fo r Units Nos. I and 2 relating to the operating license stage for Three Mile Island Nuclear Generating Station. Th e AEC transmitted the environmental report to other Federal and State agencies for comment on October 26, 1970. The Notice o f Availability of the Environmental Report was also published in the FEDERAL REGISTER on November 6, 1970.
On June 14, 1971, the Metropolitan Edison Compari replied to the comments made on the environmental report by these Federal and S tate agencies.
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. On August 23, 1971, the Commonwealth o f Pennsylvania, Department of Environmental Resources issued a water quality permit to Metropolitan Edison authorizing the discharge of water f rom Three Mile Island Nuclear Generating S tation Units Nos. I and 2.
On September 24, 19 71, AEC transmitted clarifying amendments to the revised Appendix D to 10 CFR Part 50 of the Commission's regula-tions and requested a written statement of reasons why the permits should not be suspended, in whole or in part, pending completion of the environmental review specified in Appendix D.
By letter dated October 19, 1971, Metropolitan Edison Campany responded to this r eq ues t. This was follcwed by a letter dated 19 71, containing additional info rmation concerning Noverb::
4 transmission lines.
2.0 COMPLETION OF NEPA REVIE'4 The time necessary for the completion of the on-going NEPA review for the Three Mile Island Nuclear Generating Station is es timated at 8 months.
The f actors set forth in Section E of Appendix D to 10 CFR Part 50 have been evaluated with this approximate time period in mind.
That is, the environmental impact o f continuing construction at this site, the forecicoure of alternatives of the type that might be required as a result of the full NEPA review, and the cos t o f delay all have been considered with respect to approximately 3 =enths of
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. continuing construction activity. An 8-month suspension of construc-tion could cause a delay of 1-year in the production o f electrical power and, therefore, such costs have been considered.
If construc-tion proceeds uninterrupted and the actual NEPA review period exceeds 8 months, such a longer ti=e period would not significantly add to the environmental impact of const ruction activities. If construction is interrupted until completion of the NEPA review and this period is greater than 8 months, the costs would be increased. We have taken these considerations into account in balancing the factors specified in Para-graph E of Appendix D to 10 CFR Part 50 and have concluded that if a significantly longer time period were required to complete the NEPA review, it would not affect our determinatica that the construction activities at the Three Mile Island Nuclear Generating Station, Units 1 and 2, should not be suspended in their entirety but should be sus-pended in part for Unit 2.
- 3. 0 ENVI RO NMENTAI. IMPACT DURING THE PROSPECTIVE REVIEW PERIOD 3.1 Site Clearing and Earth-Moving All site clearing work has been completed. All excavaticn has been completed and all building foundations have been laid.
Tae remainder o f the earth-moving work consists of backfilling and grading around build-ing foundations, completion of the south dike and completicn o f the intake channel and structure for Unit No. 2.
Work on the south dike will not occur during the review period.
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'p a t e r Intake Ccnstruction An intake channel 30 feet wide that extends 340 feet out in the river will be used for both units.
The blasting for the channel has been completed except in the immediate area of the cof ferdam around the in take structure for Unit No. 2.
The dredging of loosened mate rial is expected to be comp leted 'n November 19 71.
Further work that remai ns to be done on the intake channel will not be done until November 1972, af ter the cof ferdam has been removed.
- 3. 3 Princinal S truct u re s No cons truction remains to be done on bridges, roads, or railroads on the site.
A number of temporary roads will eventually be replaced, but not during the review period.
The cons truction of all buildings for Unit No. 1 is nearly ccmnlete and construction of buildings for Unit No. 2 has begun.
The buildings for Unit No. I have risen to full height.
The containment building for Unit No. 2 has risen to greater than half its full
.e i gh t. Of the four natural draf t cooling towers being e rected on the site, two are at full height, the third is nearly full height and the fourth is at approximately 2/3 of its finished height.
3.4 Transmiss ion Lines Th ree transmission lines have been completed and are ready for service in conjunction with the operation of Unit No.
1.
In con j unction..th Uni t No.
2, three 500 k'l lines will connect to the 4 ~T
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'lh !ines wIll run to the extsting l'e :t ch !!o t t i nn
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One vilI he 6.I miles long and the other will be 11.I miles long.
A third line, to Bechte tsville, will be 6 7. 3 miles long.
Ap p ro,x i ma t e ly 15 miles of right-o f-way have been acqui red for the two lines to the exis ting Peach Bottom - Juniata lines, the re fo re the route of approximately 2 miles of right-of-way remain un de fine d.
Although no hearing has occurred to date, completion of land acqui-sition and some clearing of the ri gh t o f way for these lines is scheduled during the review pe riod.
The 6 7. 3 mile long line to Be ch te lville is currently under cons truction.
The clearing of additional land and construction for transmission Ilnes may have a s igni fican t impact on the environment. The pe rmi t holder has proposed some measures for the preservation of plants and trees and p reven tion of soil e rosion. Mcweve r, without more complete knowledge of the righ ts-o f-way o f the transmission lines for Unit 2, and the p ro tective me as ures to be taken, the envirenmental inoact cannot be fully evaluated.
3.5 Soit Erosion and Sedimentation Measures have been taken to prevent soll erosion and minimize the resultant sedimentation of the river.
Cons t ruction control o rovisions for on-river f acilities such as b ri d ges, channe ls and in take structures are subject to the re gula t ions
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of the Commonwe al th of Pennsvivania as adopted hv a Resolution of the Water and Power Resources Hoard on May 12, 1970. and a condition o f a pe rmi t issued for these facilities.
Censtruction forces are under orders not to discharge or dispose of was te o f any nature into the river.
Sorrcw nits f rom wh ich dike material was ob tained have been graded to o revent drainage to the ri ve r.
In the main plant area, drainage is contained by the pericheral dikes and is discharged to the river by peripheral ditches into the 60-inch diame te r culve rt on the eas t side of the island. Temoc ra ry impoundment behind the culvert and minimum slope of ditches to the culvert s e rve to control the amount of sediment contained in drainage to the rive r.
- 3. 6 S ani tari Was te Disnosal During the construction period, sanitary was tes are being handled in beo wavs:
1.
The was te from the large construction of fice buildings and the plant of fice buildings, as they are put into se rvice,
are fed into a septic tank and tile field arrangement.
Diis sys tem was designed in accordance with the app licab le S ta te regulations.
2.
Portable sanitary f acilities are situated th roughout the site f o r use by the cons truc tion pe rsonnel.
The was tes collected in these f acilities are trucked of fsi 2 by a licensed contractor who disposes of them in accordance with ac o li cab le State regulations.
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. Both of these systems are scheduled for continued use, at es sen ti a l ly the same load factor, th roughou t the review pe riod.
- 3. 7 Preooe rational Testing As cons t ruction nears comp le tion, p reope rational cle aning an d tAs ting will be performed on the components of linit No.
1.
During the review period, waste water will be generated on the alte as a result of preoperational system s tartup, testing, and f lush in g.
The re are five sources o f was te wate r:
(1) cooling water will be taken from the river at a rate of 5.000 to 18,000 gom, passe d th rough se rvi ce heat exchangers, and re turned to the river,
but with a negligible :emperature increase ; (2) 100 to 450 gnm of the above cooling water will be diverted to a clarifier and filter system.
Chemicals will be fed to the clarifier to precipitate suspended solids, th us forming a sludge.
The sludge will be compressed in to b lock form, collected, and Sauled o f fs ite to a S tate aoproved sanitarv land fill : (3) Makeup demine ralize r was te regenerant solution containing dilute sulfuric acid and sodium hydroxide will he neutralized and blended with the cooling water discharge.
Dissolved solids and pH in the was te discharge will be checked and keot within acceptable State limits.
Regeneration was te solution will contain no suspended solids: (4) The various cower plant pioing and equipment sys tems will be cleaned and flushed with clear water.
The ini tial dirty flushing wastes, expected to con tain iron rust, will he Lmoounded.
Following a settling ceriod, this was te will be
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t a reclaimed or discharged at a controlled rate.
The dic charged quan tit ies of solids and iron as well as pH will be checked and kept within the app rop riate State standards : (5) Hot phosphate and hydroxace tic-formic 1cid at less than 3% concentration will be used to clean p lan t s ys t e ms.
These chemical solutions will be held in a suitable container following use to pe rmit settling.
S ub s eq uen t1v, th e solution will either be treated to reclaim the phosphate, hauled of fst te for processing by a licensed contractor, or diluted and discharged following analyses to make sure that pH, solids, choschorus and iron are within the limits es tablished by the Commonwealth o f Pennsylvania.
- 3. 8 Reactor Ope ration Since cons truction of the plant will not be completed during the forecast NEPA review period, there will be no environmental impact f rom radioactive water, or water vapor ef fluents which would be rele ased as a result of operation of the plant.
The handling of unirradiated fuel will present no significant hazard or impact to the environnen t.
a.0 FORECLOSURE OF ALTERf ATIVES Di'RI% THE PROSPECTIVE REVIE'J PF? Inn The incremental environmental impact of continued cons truction of the f acility, as discussed above, could be largelv redressed by leveling of s t ructures and resons titution of the lands cape in the event th a t the full NEPA review so required. However, re fores tation would take decades and removal of s truc tural features added during 1 -~ O
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,e the rematoder of the NEPA review period would be c os t l".
Except for the impact o f t ransmission line construction, the major adve rse environmental impact of construction has already been =ade.
Alternatives that potentially could be af fected by continued cons truction are those related to e f fluent control measures and t rans m i s s i on lines.
'4e have examined the environmental imoset of routine and accident radiological releases, the rmal and chemi cal e f fects of water released, and water vapor f rom the cooling towe rs t o de te rmine the al te rna tives that might be foreclosed as a res ul t o f const ruction during the NEPA review period.
The radiological e f fects involve both anticioated low-level re le ases associated with operation of the plant and with potential releases o f radioactivity at somewhat higher levels that could result f rom an acciden t.
Die liquid radwaste treatment system for the plant is designed to be capab le o f recycling liquid radioactive was tes generated during ope ra t i on.
The stated design cb jectives of the system for liquid e f fluents a,e comnarab le to the nume rical gui de lines for routine releases contained in Proposed Appendix I to 10 CFR Part 50.
In addition, construction during the prospective NEPA review period would not preclude any necessary modifications to piping systems be fore or af ter their completien. Modifications requiring addf tional building space could involve substantial ces ts but would not be p re clud e d.
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. The gas eo us radwaste treatmen t sys tem is p resently designed to allow a 40-day h o '. d up.
The option of inclusion of additional holdup or treatment capability ha.s not been f o re c l os e d.
'4e conclude th a t mod i fic a t ions to the liquid and gaseous radwas te sys tem would not be precluded by con tinued cons truction.
1here is re asonab le assurance that a plant und r construction can be modified to incorporate any radwaste t re ttmen t systems found necessary to r2 strict environmental releases of radioactive waste to the levels stated la Proposed Appendix 1 to 10 CF'4 Part 50, including the addition of building space if req ui red.
Th e p roh r.h t l i ty of occurrence of acciden ts and the spectrum of thei r consequences to be considered frcn an environmental offects s tandpoin t will be analv zed using bes t estimates o f p rob ab i li t ie s and realistic fission product re le ase s and transport assumptions.
For nite evaluation in our safety review extremely c on s e rva t i ve assump tions were used for the purpose o f comparing calculated doses resulting f rom a hypothetical release of fission p ro d u c ts f rom the fuel, agains t the 10 CFR P att 100 siting guidelines.
1h e computed doses that would be received b:, the population and environment f rom actual accidents would be significant1v less than t
I than those presented in our Safety Evaluations 1/
Although the environmental ef fects of radiological accidents are anticipated to be small, if further reduction in pcstulated accidental releases is requi re<! as a result of the full 'IEPA review, additional engineered safe ty systems could be added.
In any even t, operation of the plant will be required to be such that the environmental impact of pos tulated accidental releases will be within Comnission guidelines.
'Je conclule tha t al te rna tives related to mitigation of accident consequences would not be precluded hv the continuation during the prospective review period.
Some discharges from the cooling towers will he necessary to prevent fouling, because of the accumulation of solids during the evaporatien process.
Some sulfates, that are used to control solids depositten in the cooling tewer, world be discharged, but in relatively small quantities. Alte rna.ive chemical agents or f urther treatment of the discharge f rom ei the r a chemical or thermal standpoint would not be orecluded by the centinuation of construction.
1/ Safety Evaluation by the Division of Reactor Licensing, U.S. Atomic Ene rgy Commission in the mat te r o f Me tropolitan Edison Cenpany,
Three Mile Island Nuclear Generating Station Unit No.
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50-2 89, Feb ruary 5,196 8, pages 43-51; Met ropoli tan Edison Ccmoanv and.Je rsey Cen t ra l P owe r
- Li gh t Company, Three Mile Is land Nuclear Generating Station Unit No. 2, Docke t No. 50-320 September 5, l969, pages 54-57.
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. A potentially significant environnental ef fect resulting f rcm plant discharges is f rom the water vapor released from the top o f the cooling t owe rs. Ground fogging or icing is less likely with this natural-draft tower than wi th the shorte r forced-draft tvne of cooling towe r.
The incremental addition of moisture to the wate rshed is ve rt small when considered in te rms of additional r sin f all.
A s ign i f i c an t additional dollar cos t would be incurred if a dif ferent cooling method were required as a result of the NEPA review.
An alternate route f or the transmission lines of Unit No. 2 would not be precluded by clearing land on the present rights-of' way but additional costs and a measurable environmental impact will have been incurred by continuance of the land clearing and construction of these transmission lines.
In sumnarv, no alternatives would be foreclosed by con tinue d cons truction at the site p roper, f rom the standpoint of technical fe as ib i li ty.
The clearing of transmission line righ t-of-way fo r Unit No. 2 would involve a significant inves tnent and measurable environ-mental impact which could conceivable influence a later decision to recommend use of alternative rights-of-wav.
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5.0 [0STS OF DELAYS If the permit were to be suspended in its entirety pending completion cif the NEPA review, the delay in construction would:
(1) reduce the reserve captcity required for a reliable electric power system, (2) increase the averall monetary cost of the f acility, resulting in higher rates for the consumer, (3) have an economic impact on the area due to the loss o f s al-artes o f those employed in ccnstruction, and (4) incur environmental costs from pollution by part iculate and gaseous effluents f rom older,
fossil fuel fired generating units.
5.1 Res erve caoacity In a letter to the Director of Regulation dated February 16, 1971, the Federal Power Commission forwarded their comments relative to the need for the electrical capac'ity o f these units and alternate means of obtaining the power represented by this unit.
The Federal Power Commission s tates :
"The availability o f the Three Mile Island Nuclear Genera:Ing S tation units en schedule is necessary to provide needed reserve ma rgi ns in the PJM* pool during 1973 and thereaf ter.
Due to unanticipated load growth, delayn in placing new generating facilities in service, and high forced outage rates of several new large unit s, tne pool has been f aced with less than desi red reserves for the las t f ew years. This trend is expected to con-tinue.
The pool has been forced to resort to road reductic, me as u res at times o f heaviest demands for the pas t several years.
Th ese included reduced voltage un four occasions in 1969 and cn seven occations in 1970 to maintain suf ficient operating reserves.
Occasionally mere drastic measures have been required.
To avoid
- The PJM system serves an area of 48,000 square miles with a population of over 20 million people in Pennsylvania, Ma ryland, New Jersey, Delaware and the Dis trict o f Colutbia.
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unduly small generating capacity reserve margins and related problems of system reliability, it is imperative that the Th ree Mile Island Nuclear Generating Station and other scheduled gen-erating facilities be placed in service on time."
5.2 Monetary Cos t o f Suscension The permit holder states that a delay of one year in the commercial operation of the Three Mile Island Nuclear Power Plants would result in
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an addtional cost of 161,700,000 dolla rsi.
The breakdown of these costs is as fo llcws :
TMT ril TMI '12 1.
Additional labor and material costs due to shutdown, standby and startup S 5,100,000 S 1,600,000 2.
Additional escalation and con tin gencies 4,300,000 13,500,000 3.
Additional interest during cons t ruct ion 17,800,000 16,400,000 4.
Net cos t of generating capacity 4,300,000 S(2,500,000) 5.
Net ccs : of replacement ener gy 50,100,000 51,100,000 Totals 81,600,000 50,100,000 Comb ined 161,700,000 1/ "S tatement o f reasons why the Construction Permits for the Three Mile Island Nuclear Generating Station should not be suspended.
." dated Oc tob er 19, 1971.
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-1E-Items 1, 2 and 3 represent ccnstruction ecsts that would be incurred due to delay and amount to approximately 60 million dollars. We have assumed fc rhe purposes of making the required balance that the cost of delay cours e as low as 60 million dollars.
The AEC's Di ton of Cons truction has independently reviewed these construction dela!
sts and has concluded that :he es timate by th e applicant o f the overall increase in costs associated with such a delay falls within the general range of what could be expected.
5.3 Economic E f f ect The permit holder has assessed the ef fect of the loss of income to construction workers. During the projected 8 month review period, it is expected that the payroll for the construction workers who live within 50 miles of the site will amcunt to $23,600,000.
If the cons truction were to be suspended for 8 months, the force would be decreased to approx-imately 115 people with a resultant reduction in payroll to $1,700,000.
This loss of $22,000,000 in payroll would have a significant impact on the economy o f the area.
In addition to the dollars injected into the local economy th rou r,h payroll, records indicate that over the las t four years an average of
$ 5,000,000 a year has been spent on materials and equipment within a 100-mile radius of the site.
It is projected that a similar amount will be spent during the review period if construction is not suspended.
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Delay in completing the Diree Mile Island Nuclear Generating Station units also will impose environmen tal ces ts. The need to utilize older fossil fuel-fired generating units = ore intensvely will result in greater atmospheric pollution by particulate and gaseous ef fluents than would occur otherwis e.
The permit holder has estimated the amount of additional pollutants resulting from a one year delay in the commercial operation of the Three Mile Island Nuclear Generating Station generating units.
TMI #1 TMI #2 Delayed capacity 830 MW 950 MW Loss o f nuclear generatioa for one year's delay (at 802 load) 5,816,000 MWH 6,,65 7,000 MJH Approximate required use of additional fossil fuel Coal - Tens 600,000 800,000 011 - Barrels 10,600,000 9,800,000 Approximate stack dis charges S0 - T ns 29,000 31,000 2
Particulates - Tens 2,680 2,490 5.5 Suseension of Work for Transmission Lines The permit holders quote the "MAAC* Sys tem Reliability Review - Fall 19 71" as s tating "all delays ja tj} the Bechtelsville-Souderton line beyond Mid-Atlantic Area Coordinating Council 4
1i Jun e 1, 1974, will result in the f ailure o f PJM to meet th e MAAc re?
- ability criteria." Hewever, the permit holders have not es t ab lish ed the relationship between the Bechtelsville-Souderton line and the line f rom Three Mile Island Nuclear Generating Station, Unit 2, to Sechtelsville and what ef fect an immediate delay of eight months in the construction o f this line would have on the completion date of June 1,1974 Als o, the permit holders have not presented an estimate of the monetary cost of delaying construction of the transmission lines. Th e re f o re, for the pur-pose of making the NEPA balance on transmission lines, we believe that the monetary cost of such a delay could be assimilated and the ef fect on system reliability could be minimized by an accelerated construction
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schedule put into effect af ter an eight month delay period.
6.0 DETERMINATION AND BALANCING OF FACTORS Pursuant ta Section E of Appendix D to 10 CFR Part 50, we have taken into consideraticn and balanced the following f actors in making a deter-mination whether to suspend the construction permits f o r th e Th re e. Mile Island Nuclear Generating Station pending completion of the NEPA envircn-mental review.
6.1 Suspension of Work on the Entire Plant The impac t on environment of the onsite construction ef fort has already taken place. The incremental additional impact f rom onsite con-struction activities to be cenducted d tr'ag the NEPA review period is not 4
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/ estimated to oe substantial or unduly adverse. As discussed in Section 3 ab ov e, the environmental ef fects are limited to those associated with con-struction and do not include the ef fects of plant operations. Redress o f sudt environmental impact as mi gh t result f rom further cons truction could be achieved by removal of above grade structures and reconstitution of the landscape.
Continued construction of onsite structures during the prospective NEPA review period would not foreclose subsequent adoption of alterna-tives to currently proposed design features f rem the standpoint o f tech-nical feasibility, although substantial additional dollar costs would be incurred as a result of ongoing construction activities if major struc-
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tural modifications were required at the end o f the NEPA review.
The ef fects of complete suspension o f the construction activities would be subs tantial. Increased construction and interest costs would result from stoppage and later resumption of construction.
Th e cos t of obtaining power f rom alternative sources if it were available is also substantial. Moreover, the Federal Power Ccemission has stated that in order to maintain sufficient operating reserves, it is imperative that the Three Mile Island Nuclear Generating Station be placed in service on time.
Part of the expenditure to support centinued cons truction conceivably could influence a later decision whether to require major modifications to the plant.
'4e conclude that the large certain cos t o f delay outweighs A
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. the unlikely possibility that expenditures during the period of continued construction will affect substantially a subsequent decision regarding modification of the facility to reduce environmental impact.
After balancing the f actors described above as to environmental impact of continued construction o f onsite f acilities, and the potential for foreclosure o f alternatives as a result of further cons truction, against the effect of delay costs, we conclude that the cons tructicn activities at the Three Mile Island Nuclear Generating Station should not b e s us-pended, in their entirety, pending completion of the ongoing NEPA review.
However, a partial suspension of construction activities as outlined in the next section is recommended.
Pending completion of the full NEPA review, the holders of Construction Permits Nos. CPPR-40 and CPPR-66 proceed with onsite construction at thei r own risk. The discussion and findings herein do not preclude the AEC, as a result of its ongoing NEPA environmental review, f rom con:inuing, mod-ifying, or terminating the ecnstruction permits or their appropriate con-ditioning to protect environmental values.
6.2 Suspension of 'Jork on Transmission Lines The incremental impact on the environment of continuing construction of transmission lines for Unit 2 may be significant. Some environmental impact already has taken place, but a significant additional impact may ensue f rom cons t ructing the transmission lines.
The clearing of land and continued constructicn on the of f-site trans-mission lines would make the adoption of alternative routings and/or changes IO 1
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- in design significantiv more dif ficul t, should this be the rnnetusion of the NEPA review.
The ef fects of suspending construction of these transnission lines for a period of eight months is not expected to delav plant startun or significantly delav the production of electrical oever.
We halieve the applicant can accommodate the suspension of work on these facilities hv suitable re-programming of its cons truction e f forts, thouch admitted 1v at some additional cost. We expect to review the environmental impact
- ranan.ssion lines on an expedited schedule conoared to the of the i
complete NEPA review schedule.
Af ter balancing the factors described above as to the environmental inpact of clearing land and continuing construction of transmission lines.
and the potential for foreclosure of alternatives as a result of futher construction against the effect of delav costs, we conclude that certain construction activities associated with the Three Mile Island Nuclear Gene rating Station should be suspended, in part, p3nding completion of the ongoing NEPA review of these items. Scecifically, the clearing of land for and construction of the 500 kV transnission lines f or Unit No. 2 should he suspended pending completion of our review.
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