ML19206A818
| ML19206A818 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 08/05/1975 |
| From: | Olds W INTERIOR, DEPT. OF, FISH & WILDLIFE SERVICE |
| To: | Muller D US ATOMIC ENERGY COMMISSION (AEC) |
| References | |
| ER-75-476, NUDOCS 7904210494 | |
| Download: ML19206A818 (3) | |
Text
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United States Department of the Interior F:$H AN: #CL:F1 $t4#:1
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FISH AND WILDLIFE 5ERVICE WA5HINGTON, D.C.
3:240 In Reply Refer To:
AUG 5 1975 WS/ES ER-75/476
_~_
Mr. Daniel R. Muller Assistant Director for J
s Environ = ental Projects Division of Reactor Licensing Nuclear Regulatory Cc _.ission
_ _ _.. J
'a'a s hin g t on, D. C. 20555
Dear Mr. Muller:
The following c.: :=ents are provided in respense to Mr. Regan's letter of May 13, 1975, relative to Supple =ent 2 to environ = ental report (Operating License State), for Three-Mile Island Nuc'. ear Station, Unit 2, Dauphin County, Pennsylvania (Docket No. 50-320).
The second paragraph en Page 2.5-2 states that the proposed pumped storage project on Stony Creek in Dauphin Ccunty would have a genera-tien capability of 1100 MW.
The state =ent conflicts with information in the October 1973 Pro 4ect Concent Recort (Stony Creek Project), which lists the generating capacity at 1710.Y4.
Tha 1100-T4 figure appears also in the fifth paragraph on Page 5.4-3.
The discussion on Pages 2.5-2 and 2.5-3 does not mentien the proposed Fulton Generating Stacion (NN Dockets 50-463 and -464), which would withdraw about 96 cfs from the Susquehanna River for cooling purposes.
Section 2.7.1 lacks quantitative and qualitative details that are essential for co=parisons of pre-and pos -eperating conditions in the vicinity of the intake and discharge. There is no figure to shcw the location of sa=pling stations with respect to intake and discharge.
There are ne data about water depths and bottom types, trap net resh size, seasonal density and distribution of individual species, nor the " basic groups" listed on Page 2.7-1.
The format of Table 2.7-1
=akes it impossible to assess variations accng stations or between Spring and Fall at a given station. Data on individual stations, preferably on the basis of fish catch / unit effort, would be more useful.
If sa=pling at invertebrate Stations 3 and 4 was stopped in 1970 and g;.
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c 1971, as stated on Page 2.7-4, what is the source of 1971 and 1972 data for both stations that appear in Table 2.7-3?
Lections 3.6.4.1 and 3.6.4.4 refer to "an AIC approved burial (disposal) facility" for radioactive solids. The statements imply that such a f acility now exists. The state =ents see: dsleading since an envircn-mentally sound means of per=anent disposal has not been developed.
Section 3.6.4.6 refers to a fuel recovery plant where radioactive-spent fuel would be reprocessed. The state ent i= plies that such a plant is operaticnal and capable of handling =aterial fro: IMI. The state =ent see=s =isleading since U. S. Gover==ent plants at Hanford, Washington, and Savannah River, South Carolina, are for the exclusive use of Federal agencies and the only cc==ercial reprocessing plant in the country (at West Valley, New York) has been inactive for several conths.
According to Sections 3.7.1 and 5.3.1, chlorination of cooling systers will be done in such a way that total residual chlorine at the plant's discharge dos not exceed applicable regulatory requirements. It is clear fro: the final environmental state:ent, dated Dece:ber 1972, that the Enviren= ental Protection Agency (EPA) and the Nuclear Regulatory Co==ission (for=erly AEC) feel that total residual chlorine concentration in the discharge should not exceed 0.1 pp: for more than thirty minutes per day.
Nonetheless, a March 1975 su--ary of IMI discharge cocitoring refers to the "0.2 pp: li=1t for total chlorine residual." The chlorine cencentration authorized by Per=1t PA.-0009920, which EPA issued for TMI in January 1975, shculd be centioned in Supplement II to the enviren= ental report to clarify the =atter.
Section 5.2 does not cention the unsolved proble: of finding environmentally sound ways to dispose of wastes that will be lethally radioactive for hun-dreds or thousands of years. The proble: gets more serious as the number of nuclear plants and the a=ourt of such vastes increase. The Section does not cention that te=porary storage methods are i= perfect, as e-idenced by the structural failure of storage facilities at Hanford, Washington, with subsequent leakage of radioactive waste.
The fifth paragraph on Page 5,4-3 states that the Steny Creek project is under construction. The statement is false. The necessary construction license has not been issued by the Federal Pcwer Cc=21ssien and, indeed, application for a license has not been rade. Ecwever, under a Federal Pcwer Co==issien preli=inary per=it, issued December 1972, the ccepanies have been conducting feasibility studies.
Section 5.5.1 deals with post-cperational =cnitoring studies of Unit 1 by Ichthyological Associates, Inc.
It fails to cention the operational status of the plant when sa pling was in progress. Lacking this infor:ation, the reader cannot draw conclusions as to what effects, if any, the plant's waste heat and che=1cals are having on impinged and entrained fishes and plankton and en =acroinvertebrates dcwnstreat fre the discharge.
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sa e criticis applies to An Ecological Study of the Suscuehanna River in the Vicinity of the Three-M.ile Island Nuclear Station. That document was issued by Ichthyological Associates in February 1975.
It is not
=entioned in the environ = ental report, although it is far more detailed insofar as aquatic ecology ic canea*r.ed.
Subsequent reports of =enitoring will be core useful, in our opinien, if they specify the concentration of residual chlorine at sampling statices and, relative to sampling times, the plant's percentage power production, discharge flow rate and chlorinaticn schedule.
The opportunity to review the subject document is appreciated.
Sincerely yours,
(
8 ye;ut7 AO ociate Director
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