ML19210B690
| ML19210B690 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 01/20/1971 |
| From: | Horton J INTERIOR, DEPT. OF |
| To: | Price H US ATOMIC ENERGY COMMISSION (AEC) |
| References | |
| NUDOCS 7911110156 | |
| Download: ML19210B690 (6) | |
Text
FActa UJ. Department of the Interior 1-20-71 1-22-71 281
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Ltr re our 10-28-70 1er...furnishinn Long 1-26-71 (ORIG FOR MATE) comments on Enviro Report for w/4 cys for hCTIOM (Orig to be ret Olt')
Three Mile Island Units 1 & 2.
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Dear Mr. Price:
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J On October 28 you requested our comments on the draft environmental statement prepared by Metropolitan Edison Company and Jersey Central Power and Light Company 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 request for an operating license for Three Mile Island Nuclear Station (Unit No.1), Dauphin County, Pennsylvania. Unit No.1is 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 informational purposes only.
This report has been reviewed by various units of this Depart-ment having special expertise in fields covered by the draft sts.tement and their comments are included in this letter.
Also, included are the comments of the Federal Water Quality Administration which was transferred from this Department 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 information for such an evaluation. It is our opinion that every environmental statement should be a complete documentation of the environ-mentalimpact of a proposed action. We are furnishing for your consideration our comments on areas in the statement where additional information is needed.
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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 Environmental Policy Act of 1969. Additional information should be included in the statement on chemical, thermal and radiological wastes and monitoring.
Chemical Wastes--Additional discussion is needed on the quan-l tity and chemical composition of cooling tower blowdown and other chemical discharges from the plant. Concentrations, 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 water is expected to be the only 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 discuased in the statement.
_ Radiological Wastes-- In the discussion of the liquid radwaste effluent, the statement should include estimates of the maximum and annual average radionuclide concentrations, the effluent i
comppaition, and the expected quantities of effluent. To ade-l quately protect the Susqus'aanna River, tota,1 radioactivity buildup from all sources must be considered and radioactive l
wastes must be kept within a small percentage of the 10CFR20 l
limits.
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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 released to the receiving water or are to be retreated.
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Monitoring-- A summary of the preliminary findings of the-f biological survey begun in 1967 of the Susquehanna River should be included in the statement. These data would permit greater j
comprehension of the potential effects of the project on the fish l
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 f
mentioned in the statement should be documented as to specific l
location and frequency. Moreover, no mention of the ultimate disposition of these data is made.
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l The ecological monitoring program, after operation begins should be more comprehensive than the preoperational program.
a For example, in addition to the gross radioactivity measure-I ments, surface water should be analyzed monthly, using com-posites from weekly grab samples the first year, for CS-137, i
Sr-90, Co-60, 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 precisely located, It would be pos-sible txalacate these on exhibits 2 and 3, if appropriate.
l Geologic and Hydrologic Safety--Geological Survey of the l
Department has reviewed geologic and hydrologic aspects of I
the site for the Atomic Energy Commission, Division of Reg-ulation, in connection with the construction license applications for both Unit 1 and Unit 2.
At AEC's request, these reviews pertained to safety aspects of the site such as faulting, earth-l quake effects, foundation conditions, and flood protection.
l The geologic considerations section in the statement does not l
present sufficient data for an evaluation of the geology of the site that might have a bearing on environmental effects. The j
statement is deficient in both the regional geology and the I
engineering geology of the construction site. Much of the j
section on the geology is given to discussions of the topography, i
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, and the major hydrologic problem concerns the flood protection of systems 1566 1.2 3
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vital to the safety of the reactors. While this is not discussed in the draft statement, it has been dealt with in other parts of i
AEC Dockets 50-289 and 320. The Safety Evaluation (Docket 50-320 dated 9-5-70) by the Division of Reactor Licensing i
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 Susquehanna River. As of November 1970, these figures have not been published by the Corps. The Safety Evaluation i
indicates that a further review of the proposed flood protection will be made when the probable maximum flood computations become officially available.
On basis of preliminary estimates of the probable maximum flood, it appears that its stage would overtop the natural ground i
elevation of Three Miles Island and thus the flood protection would depend on artificial dikes. During major flood these dikes would be exposed to eroelve water velocities, wave action and the debris load of the river. The further review of the l
flood protection of the site should take these aspects into con sideration, as well as the problem of providing protection i
should the dikes be breached.
i Environmental Standards--It is imperative that the company l
consider the possible need for alternate or supplementary con-trol facilities. Establishment of more stringent water quality standards or the detection of unanticipated adverse environ-mental effects, may make it necessary to incorporate additional waste control facilities. For these reasons, it should be shown that the processes 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 properly evaluated.
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In regard to coal availability, it is the principal fuel source j
for power generation in the Nation and especially in this region.
j Although the share of the utility market supplied by coal may diminish, the total quantity used is expected to increase to the I
year 2000 and beyond. Coal plants do present environmental problems and there is a current supply problem with respect to low-sulfur coals. However, the reserves of coal in Pennsylvania having a sulfur content of less than 1.0 percent are estimated at 1. 2 billion tons. These could be developed as a source. J.lso, there are huge reserves of low-cost coals of higher sulfur content. Much research and development work is in progress to develop precombustion processes for the removal of sulfur from coal. As a result of this effort, technicalimprovement processes are expected to be com-mercia11y 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, (sgd)hek0.U":"
l Jack O. Horton l
Assistant to the Secretary l
Mr. Harold L. Price I
Director of Regulation U.S. Atomic Energy Commission i
Washington, D. C.
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