ML19206A970
| ML19206A970 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 08/31/1972 |
| From: | Gilbertson W PENNSYLVANIA, COMMONWEALTH OF |
| To: | Muller D US ATOMIC ENERGY COMMISSION (AEC) |
| References | |
| NUDOCS 7904210667 | |
| Download: ML19206A970 (5) | |
Text
..
m gydOM 8UV A
TW%-)
/'
\\ TN,
'5&$E DEPARTMENT OF ENVIRONMENTAL RESOURCES p
j
- p. O. Box 2351 EP M
Harrisburg 17105 M
M August 31, 1972 NiE E
p f,
.O g
6 -i
'"23 E
5 M s -<
0O e
nepl:=: -
g 5 z M Mr. Danici R. Muller o
Assistant Director for Environmental
~,I
~
Proj ects E,\\j C'N -n'h Directorate of Licensing d, ', -
United States Atomic Energy Co=1ssion
]~C #
Washington, D.C.
20545
~1 t.
~
Re: USAEC Docket Nos. 50-289 and @
kl(;;.~~
Gentlemen:
A 0...,
w"
/
D"N M'
k This is in response to your notice of opportunity to coc=ent on-~
.~
the Applicant's Environmental I= pact Report and the Draft Detailed Statement by the USAEC on the environ = ental considerations related to the proposed issuance of an operating license for the Three Mile Island Station Units 1 and 2.
The co= ents as contained in the attached Staff Report include co=ents as appropriate from the Department of Environ = ental Resources and other pertinent State agencies.
They are submitted for your attention and consideration.
Very truly yours,
^f Cg f l G lL-L:JhJfx WesleyE.Ci$Utson Deputy Secretary for Zavironmental Protection Enclosure G3~287 79042106$7
)
ASS 2
m Septe=ber 1, 1972 PENNSYLVANIA DEPARTMENT OF ENVIRONMENTAL RESOURCES COMMENTS ON ENVIRONMENTAL IMPACT OF ThREE MILE ISLAND UNITS I Ah"U II This report is prepared for submission to the United States Atomic Energy Con =21ssion, pursuant to the Environmental Policy Act of 1969, and in response to a request for com ents from the USAEC. The coc=ents reflected in this report are those received in the Office of Radiological Health on or before Septe=ber 1, 1972.
, 4 ~~2 l '? 1 Specific Cec =ents:
l.
The Department of Environ = ental Resources has issued a per=1t to,the applicant severely 11=iting the level of contaminants in the discharge. This per=it restricts radioactive effluents to less than 1% of present AEC standards. These require =ents are considered maxi =u: limits. The Department's philosophy is that all releases of environ = ental pollutants should be held to the absolute =1nimu=.
The applicant has been previously notified by the Department that it must review any additional measures which could be incorporated into the plant vaste management syste=s and install any and all systems which would further reduce both radioactive and non-radioactive pollutants.
On the basis of the information indicated on page V-14 and V-18, 19 of the draft detailed statement, we believe that chlorine in the effluents should be reduced to non-detectable levels.
In lieu of this, it should be shown that the levels proposed would adversely affect the aquatic ecosyste=.
+
net This position is re-stated as the most important coc=ent on the environ = ental report.
G3'?ES
-s 2.
In reference to page 2.4-5 of the Applicant's Environmental Report and page II-8 of the Draft Detailed State =ent, it is stated that any waters (conta=1nated or not) added to the ground-water of the area would follow the wat:r table gradient to the river and be discharged to the river.
This would be true caly for surface disposal, and not for sub-surface disposal. No sub-surface disposal has been authori:ed by the State for this plant.
3.
On pages V-15, 16, 17 of the Draft Detailed State =ent, there is listed the expected plu=e dispersal to the countryside of salt, copper, cobalt, iron, inc and =anganese. The state =ent in paragraph 4 en page V-17, "If a proble= of copper toxicity should develop, it would be. controllable by the addition of phosphates to the land. The same would be true for zine and manganese."
These remarks cited above indicate, 1) a clear uncertainty in the prediction of what will develop, 2) no consideration of the
- ombined effect resulting from the contaminants ( even though past research may indicate that the dosage of the contaminants individually are acceptable), 3) no consideration of the undesirable aspects of adding phosphates to the water environ =ent, and 4) no stated plans for continuous trace-ele =ent =onitoring of the soils, waters, and organisms.
4 The effects of the cooling tower plume on Harrisburg Inter-national Airport visibility is a question raised previously during the construction permit hearings. The possibility of an f
r es
-s effect on the airport does exist, as reported by the applicant.
The probability is extremely low.
In the unlikely event that airport safety is jeopardired by cooling tower fogging, some remedy to this situation must be inplemented.
5.
With one exception, the neteorological contents of the report appear to be acceptable. In Appendix II of the Environmental Report, a sector average model is used to describe dispersion of radioactive =aterials over a short period of time for deter-mination of concentrations and dose at the site boundar7 The use of sector averaging is acceptable for long ters dispersion phenomena description. In the case of accidental releases (Section 6) of short duration (e.g., 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> doses), center line plume concentration is important in the esti=ating of actual doses under* differing meteorological conditions. Based upon the consideration that high center concentrations and doses could be observed, it appears that the nor=alized doses shown in Tables 6.9.1 and 6.9.2 are low by a factor ranging between 10 and 20.
6.
Section 2.5-3 should be updated to include the June,1972 flood as the flood of record. It is re=arkable how closely the design flood of 1.1 million efs was duplicated by the flood waters produced by Hurricane Agnes. This does not appear to be the =aximus flood that can occur at the site.
It is noted that no infor=ation is given to show what increase in river flow elevations would result from the construction of dikes for the protection of flood plain coccunities on the Susquehanna water shed, thereby eliminating a part of the flood-G3,?SO
m
_4 way.
Based on limited infor=ation it appears that the net back-water condition would not be great.
Applicant should, however, de=enstrate that plant and auxiliary facility integrity will be maintained in the event of a flood to the order of the new flood of record and probable maximum flood in conjunction with adequate dike protection of upstream flood plain co== unities.
ii 3 2.9 1