ML19206A823
| ML19206A823 | |
| Person / Time | |
|---|---|
| Site: | Oconee, Crane  |
| Issue date: | 01/20/1971 |
| From: | Horton J INTERIOR, DEPT. OF |
| To: | Price H US ATOMIC ENERGY COMMISSION (AEC) |
| References | |
| NUDOCS 7904210500 | |
| Download: ML19206A823 (6) | |
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'..m United States Department of the InteriomP.
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OFFICE OF TIIE SECRETAiW
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- * 'M ek Mr. Price:
iW g> j l t ro On October 28 you requested our commer.ts on the draft environmental statement prepared by Metropolitan Edison Company and Jersey Central Powe:c and Light Companf for AEC (Docket Nos. 50-289 and 50-320. ) The report was furnished in accordance with Section 102(2)(c) of the National Environmental Policy Act of 1969 in conjunction with a recuest for an operating license for Three Mile Island Nuclear Station (Unit No.1), Dauphin County, Pennsylvania. Unit No.1 is scheduled to begin operation in the fall of 1972 and Unit No. 2 in 1974 The discussion of Unit 2 in the environmental report is for iriormational purpos es only.
This report has been reviewed by various units of this Depart-ment having special expertise in fields covered by the draft statement and their somments are included in this letter. ---
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Also, included are the comments of the Federal Water Quality Adminis+ ration whi ch was transferred from this Depsrtment to the Environmental Protection Agency, Decem-ber 2,1970, pursuant to Reorganization Plan No. 3 of 1970.
The companies are to be commended for the job they did in preparing the draft environmental statement. Land use, fish and wildlife resources, historical and archeological values are adequately covered in the environmental statement so we will have no comment on these subjects. Since con-struction of the facility is well advanced comments on aesthetic considerations would also not seem warranted although the statement does not provide sufficient irformation for such an evaluation. It is our opinion that every environmental
~ - ~ ~ - - - - - - - - statement should be a complete documentation of the environ-mental impact of a propos ed action. We are furnishing for your consideration our comments on areas in the statemert
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where additional information is needed.
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m The companies' statement stated that the proposed revised Appendix D of 10CFR50 exempted any detailed discussion of water quality aspects, it is our opinion that Section 21(b) of the Federal Water Pollution Control Act is an addition to and not a supersedure of Section 102 of the National Favironmental Policy Act of 196 9.
Additional info rmation should be included in the statement on chemical, thermal and radiological wastes and monitoring.
Chemical Wastes--Additional discussion is needed on the quan-tity and chemical composition of cooling tower blowdown and other chemical discharges from the plant. Conc ent rations, and the effects of all chemical release operations on water quality and the biota should be presented. Chlorine and corrosion inhibitors at various concentration levels have been found to be detrimental to aquatic life.
Thermal Wastes-- The assurance that under most atmospheric conditions this water will be the same temperature as the river is inadequate, since the equipment cooling ' vater is expected to be the oni? water that is returned to the river. Appropriate safeguards against extreme or very adverse atmospheric con-ditions that might result in thermal pollution of the river should be part of the construction and should also be fully discussed in
_the. s tat ement._
Radiological Wastes-- In the discussion of the liquid radwaste effluent, the statement should include estimt.ter of the maximum and annual average radionuclide concentrations, the effluent composition, and the expected quantities of effluent. To ade-quately protect the Susquehanna River, total radioactivity buildup from all sources must be considered and radioactive wastes must be kept within a small percentage of the 10CFR.20 limits.
The section in the report on the liquid radwaste disposal system should list numerical concentration limits used in determining if the radwastes are to be r le eased to the receiving water or are to be retreated.
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Monitorinc-- A summary of the preliminary findings of the biological survef begun in 1967 of the Susquehanna River should be included in tne statement. These data would permit greater comprehension of the potential effects of the project on the fish population and fauna in the river water and sediments and would allow easy followup of these studies as progress on the power station proceeds. The routine sampling programs mentioned in the statement suo d be documented as to specific location and frequency. Moreover, no mention of the ultimate disposition of these data is made.
The ecological menitoring program, after operation begins should be more comprehensive than the precperational program.
For example, in addition to the gross radioactivit'f measure-ments, surface water should be analyzed monthly, using com-posites from weekly grab samples the first year, for CS-137, S r-90, Co-6 0, and tritium. CS-137 and Sr-90 should also be included in analyses of well water, bottom sediments, and aquatic biota. Strategic monitoring locations mentioned in the statement should be more precis ely located. It would be pos-sible to locate these on exhibits 2 and 3, if appropriate.
Geologic and Hydroloric Safetv-- Geological Survey of the Depart. tent aas reviewed geologic and hydrologic aspecto of the site for the Atomic Energ'f Commis sion, Division of Reg-lation, in connection with th~e ~ construction lic ens e applications
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u for both Un.c 1 and Unit 2 At AEC:s request, thes e reviews i
pertainetl to safetf aspects of the site such as faulting, earth-quake effects, foundation conditions, and flood protection.
The geologic considerations section in the statement does not present sufficient data for an evaluation of the geology of the site that might have a bearing on environmental effects. The statement is deficient in both the regional geology and the engineering geology of the construction site. Much of the section on the geology is given to discussions of the topography, relief, soil and vegetation.
The site of the power plant is located on an island near the out-side of a sharp bend in the Susquehanna River, rd the major hydrologic problem concerns the ficod protection of s'fstems 3
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vital to the safetf of the reactors. While this is not discussed in the draft statement, it has been dealt with in other parus of AEC Dockets 50-239 and 320. The Safety Evaluation (Dccket 50-320 dated 9-5-70) by the Division of Reactor Licensing indicates that flood protection would be provided to protect both units against the effects of a probable maximum flood as calculated by the U.S. Army Corps of Engineers for this reach of the Suscuchanna River. As of November 1970, these figures have not been pu'alished by the Corps. The Safctf Evaluation indicates that a further review of the proposed flood protection will be made when the proba' ole maximum ficod computations become officiallf available.
On basis of preliminary estimates of the probable maximum flood, it appears that its stage v.culd overtop the natural ground elevation of Three Miles Island and thus the flood protection would depend on artificial dikes. Daring majo r flood thes e dikes would be exposed to erosive water velocities, wave action and the debris load of the river. The further review of the ficod protection of the site should take these aspects into con-sideration, as well as the problem of providing protection should the dikes be breached.
Environmental Standards--It is imperative that the company consider the possiole need for alternate or-supplementa ry-con-trol facilities. Establishment of more stringent water quality standards or the detection cf unanticipated advers e environ-mental effects, may make it neces sary to incorporate additional waste control facilities. For these reasons, it should be shown that the proces ses provide sufficient flexibility so that additional controls can be added.
Alternative Solutions--In the section dealing with alternatives to the proposed nuclear power station, we also believe that a nuclear station may at this time be a more favorable alternative.
However, the broad statements made concerning fossil fuel supply shortages, fossil-fueled power plants, and the impli-cation that such plants will necessarily pose greater environmental problems needs further clarification so that all the alternatives
can be prope rly evaluated.
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In regard to coal availability, it is the principal fuel source for power generation in the Nation and especially in this region.
Although the share of the utility market supplied by coal may diminish, the total quantit3 used is expected to increase to the year 2000 and beycnd. Coal plants do pre.5 ent environmental problems and there is a current supply problem with respect to low-sulfur coals. However, the res erves of coal in Pennsylvania having a sulfur content of less than 1. 0 percent are estimated at '. 2 billion tons. These could 'oe developed as a source. Also, there are huge reserves of low-cost coals of higher sulfur content. Much research and development work is in progress to develop precombustion
> cess es for the removal of sulfur from coal. As a resu' this effo rt, technical improvement proces s es are expet ed to be com-mercially available within three to five years.
We appreciate the opportunity of commenting upon this state-ment and hope our suggestions will be helpful in preparing a complete Environmental Impact Statement.
Sincerely yours,
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Jack O. Horton,., /
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Assistant to the Secretary Mr. Harold L. Price Director of Regulation U.S. Atomic Energy Commission Washington, D. C.
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