ML19220A908
| ML19220A908 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 09/21/1976 |
| From: | Bielo R SUSQUEHANNA RIVER BASIN COMMISSION |
| To: | Regan W Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 7904250083 | |
| Download: ML19220A908 (12) | |
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- fM a SUSQUEHANNA RIVER BASIN CO3 3IISSION 2012 Len<er Stree:
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'Y Mr. William H.
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\\j' Environmental Projects - Eranch 3 s-Div. of Site Safety & Env. Analysis AI
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j U.S. Nuclear Regulatory Cc=missicn 1717 "E"
Street, NW Washington, CC 205c5 In re:
Cocket No. 50-320 -- Three Mile Island Nuclear Pcwer Plant, Pennsylvania
Dear Mr. Reagan:
This is in reply to ycur letter of July 22, 1976, trans-mitting a draf t supplement to the final envircr. mental impact sraterent en the referenccd project.
As vou are aware frcm our earlier telephone conversatiens with you and other mem-bers of your staff, this staff reply has been pending until there was an opportunity to bring the matter formally before our Ccemissioners for their attention and action at our Sep-terier 14, 1976 meeting.
The proposed administrative acticn by the Nuclear Regula-tery Ccenission necessitating an EIS relates to the continua-tien of a construction permit and the issuance of an operating license to Metropolitan Edison Ccmpany, Jersey Central Pcwer and Light Company, and the Philadel;.hia Electric Ccmpany (the applicants) for the operation of the Three Mile Island Nuclear Staticn, Unit 42, near Harrisburg in Cauphin Count Pennsyl-vania.
The facility is cceprised of two reactors with Unit il having been on-line since 1974.
Unit #2 is scheduled for ser-vice in 1978.
While the draft supplement EIS is cnly for im-
. pacts frem Unit #2, the thrust and focas of cur cccments are directed toward the entire facility.
The first issue that concerns this agency is to state cur inrention to exercise the regulatcry authcrity and powers granted to the Susquehanna River Basin Cc=missicn ccncerning all pro-jects located within the Susquehanna River basin.
Therefore, the Ccmmissier will review this project for the purpcses cf cen-trolling withtrawals and diversiens frem surface waters cf the basin sr.ch as new exists and/cr is being proposed for the pre-ject so that all basin water user interests are ascured ade-
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79041250033 3
TITLE IS - CONSERVATICt: CF PCWER AND WATER RESOURCES CHAPTER VIII SUSQUEHK;NA RIVER EASIN COMMISSION PART 803 - REVIEW OF PROJECTS CCNSUMPTIVE USES OF WATER The Commission is chargee with the responsibility for overall management of the water and related resources of the Susquehanna River Basin.
A Comprehensive Plan to cc-ordinate,. direct and reelew public and private planning, management, use and development of the water resources of the basin was issued as required by the Susquehanna River Basin Compact.
The Plan identifies objectives and goals for all program areas of water use and management and is designed to provide for the optimum use or ccmbination of uses of the basin's water resources in an effort to meet all foreseeable immediate and long-range demands in an ef-ficient and timely manner.
Guidelines and criteria as presented in the Plan are mar.agement principles that the Commission had determined to be necessary to achieve optic m utilization of the water re-sources.
The guidelines ar.d ;riteria are includ(d in the Plan to be used to evaluate proposed projects ana programs.
Review and approval of proposed projects in the basin by the Crmmission as required by Ccmpact Section 3.10 will assure implementation of these water management principles.
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Mr.
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H.
Reagan, Jr. -
September 21, 1976 and fa lity and operational safety procedures in the event of ficcdit, which exceeds the design capacity of the levee system intended to protect the project.
The levee flocd protection scheme for this project is designed against a recurrence of the Agnes-type fleed or a dischcrge of about 1,100,000 cfs.
This ficed has a recurrence interval cf about 300 years.
For a facil-ity of this type it might be advisable to ccnsider presiding ficcd protection against the maximum probable fleed (1,625,000 cfs) which other information suggests that the SRC requires new in the Tennessee Valley.
The Final Safety Analysis Report on the prcject assunes that "the (levee; freetcard is ample".
There la no indication newever, cf what problems wculd result frcm flocds exceeding the levec design.
The rationale fer the flecd protection scheme seems seme-what weak in the statements referring to the infrequeat affect that hurricanes and tropical storms would have on the project site.
Considering that five hurricanes have passed thrcugh Scuthcentral Pennsylvania during the past eighty years, each could have affected the site.
Regardless of che probability of occurrence of hurricanes or frequency of floeds of certain magnitude, the EIS should con-tain more detail on the flood protection scher..e, the waterprcef-ing system, and shutdown procedures in the event of a major flood.
We appreciatie your ccoperation and coordinative efforts cen-cerning cur interests on this project.
Very truly yours, N
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Robert J.
Bielo Executive Director Attachment e 1 c...
Mr. W.
H.
Reagan, Jr. September 21, 1976 quate supplies of water for present and future needs.
Tcward that river basin management goal, you should be aware of cngeing activity by this Commissicn as regards recently adepted regula-tiens that establish requirements and procedures for ccmpensa-tien for censumptive withdrawals of basin wrter resources dur-ing lcw ficw periods.
The Three Mile Island prcject will be affected by the regulations.
(Cepy attached)
It is the inten-tien of this Cermission to apply these regulaticns to the pro-ject (both units).
The findings of our review, in terms of impact on surface stream ficw conditions due to consumptive withdrawals, will determine the appropriate operational ccndi-tiens for issuance of a permit by this agency.
Nith regard to the technical content of the supplemental EIS on the project for Unit #2, staff review fccuses en two areas:
- 1) water consumption; and
- 2) the adequacy of flood protection.
Concerning consumptive withdrawals for water fcr cooling purposes, part of the problem has been discussed already rela-tive to Cctaission regulations requiring ccmpensarion for cen-sumptive uses during 1cw flow periods.
Additionally, the EIS suggests that ample ficws cf water are available for project operation (in Sections 5 and 9).
Ecwever, there is no deter-mination about the impact of the project's consumptive less of 44 cfs or relationships to the cumulative impact or synergisms with other consumptive withdrawals, part'cularly at and during icw river flew perieds.
Available data indicates the project's detrimental impact is " minimal" during " average" ccnditions.
An effective evalua-tion should be made of the proj ect's impact on the river, re-lated aquatic ecosystems and other water resource users during critical or system stress situations such as during river lcw flow periods.
Part of Section 9 (5.2) could be interpreted to mean that the SREC has already allocated water fer power production by the project.
This is not yet the case as indicated earlier wherein we stated that the Ccmmission will exercise its regula-tory authority and review the project in the near future.
It should be noted that the Cctmission's ccmprehensive Plan states that "Dcmestic water supply purpcses shall have priority for surface and groundwater sources" (Guideline 416).
Therefore, any potential miscenception related to these issues shculd be clarified appropriately in the EIS.
Under the tcpic of ficed protection for the project, staff review concerns the adequacy or sufficiency of the levee scheme, lack of detail within the EIS cn the flood protection system, m.
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m The regulation amplifies one of these Guidelines -
Guideline 13 which states that "Ccmpensation shall be re-quired for consumptive uses during periods of low flow".
An understanding of the Cot =ission's intention with re-spect to Guideline 13 will facilitate planning by future consumptive users.
On June 4, 1976, these proposed rules appeared in the FEDERAL REGISTER (41 FR 22598).
Cc==ents here re-ceived at four public hearings and by letters.
The final date for submission of cec =ents was August 16, 1976.
In consideration of the foregoing and all comments received, 18 CFR 803 is amended to read as follows:
Subpart D - Standards for Review 803.60 Purpose of this Subpart 803.61 Consumptive Uses of Water Authority:
Sec. 3.4, 3.10 and 15. 2, Pub. L.91-575 (84 Stat. 1509 et seq.)
- 1. By revising paragraph (a) (2) of 5803.3 to read as fol-lows:
5803.2 Projects requiring applications.
(a) (2) Any project involving either the censumptive use of water (as described in S803.61), or the transfer of water into or frem the basin. '/,T ~ L.C*)
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2.
By revising paragraph (a) (2) of 5303.4 to read as fol-lcws:
5803.4 Projects recuiring review.
(a) (2) Any project involving either the consumptive use of water (as described in 5803.61), or the trans-fer of water into or frca the basin.
3.
By adding a new subpart to Part 803 to read as fol-lcws:
Subpart D - Standards for Review 5803.60 Purpose of this subpart.
The purpose of this subpart is to set forth standards that shall be used by the Commission to evaluate proposed projects pursuant to its authority detailed in sections 803.1 to 803.6.
This subpart does not identify all the as-pects of a proposed project that will be evaluated.
Nor should it be construed as a self-imposed limitation upon the Cemnission's authority and scope of review.
These stand-ards shall be used for review of projects in conjunction with and in addition to the Ccmpact, Comprehensive Plan, Water Resources Program, and appropriate regulations.
S803.61 Consumptive Uses of Water (a) Definitions.
For purposes of this section the words listed belcw are defined as felicws:,.
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s (1) Consumptive Use.
Water withdrawn frcm its source, via a man-made conveyance system, but not directly returned thereto making it unavailable for other water users.
(2) Dedicatec Augmentaticn.
Release from an upstream storage facility which is intended for another instream or withdrawal use.
(b) Requirement.
(1) Compensation shall be required for consumptive uses of water during periods of low ficw.
Compensation is required during perieds of 1cw flow for the purpcses of protection of public health; stream quality con-trol; ecencmic development; protection of fisheries; re-creation; dilution and abatement of pollution; the prevention of undue salinity; protection of the Chesapeake Bay; and other purposes as determined by the Ccmmission.
(2) Consumptive uses by a project not exceeding 20,000 gpd from a totcl withdrawal of less than 100,000 gpd frc= surface or groundwaters are exempt frem the requirement unless such uses adversely effect the purposes outlined in (1).
(c) M<1chud a'
tm..pensation.
(1) Methods of compensation acceptable to
-h Ccmmissicn will depend upon the character of the project's source of water supply and other factors noted below.,
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(i) Stream scurce.
Compensaticr in an anvent equal to the project's total censumptive use shall te required when the stream ficw at the point of taking equals or is anticipated to equal the icw ficw criterien which is the 7-day 10-year 1cw ficw plus the project's total cen-sumptive use and dedicated augmentation.
The Commission reserves the right to apply a higher low flow criterion for a particular stream reach when it finds, as the result of evidence presented at a public hearing, that it is needed to serve the purpcses cut-lined in (b) (1).
(ii) Groundwater source.
Compensatien shall be re-quired for censumptive use from acuifers hy-draulically related to stream flows when the stream flew is less than the applicable icw ficw criterion.
For the purposes of imple-menting this regulatien, withdrawals from limestene or uncenselidated alluvial aquifers shall be considered hydraulically related to surface stream ficws.
(iii) The required amount of ccrpensation shall be provided by the applicant er project spenser or-s g
s at the point of takir.g or another appropriate site if satisfactory evidence is presented that the purposes outlined in (b) (1) are not adversely affected thereby.
If compensation is to be provided upstream frem the point of taking such compensation shall maintain the flow downstream from the point of taking in the amount which would exist naturally, plus any other dedicated augmentation, were there no censumptive use by the project and no re-placement therefor.
Ccmpensation may be pro-vided by one, or a ccmbinaticn of the follow-ing:
- a. Construction or acquisition of storage facilities.
- b. Purchase of available water supply stor-age in existing public or private stor-age facilities, or in public or private facilities scheduled for cc.mpletion prior to completion of the applicant's project.
- c. Purchase of water to be released as re-quired frcm a water purveyor.
- d. Releases frcm an existing facility cwned and operated by the applicant. rq o rag g.
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- e. Cther alternatives.
(2) Alternatives to ccmpensation may be appropriate such as discontinuance of that part of the project's opera-tien that consumes water, imposition of conservation meas-ures, or utili:ation of an alternative source that is unaffected by the ccmpensation requirement.
(3) The Commission sha:_l, in its sole discre-tien, determine the acceptable alternatives to or manner of ccmpensation for censumptive uses by a project.
Such a determination will be made after censidering the pro-ject location, anticipated amount of consumptive use and its effect on the purposes set forth in (b) (1), and any other pertinent factors.
(d) Quantity of Consumptive Use.
For purposes of evaluating a proposed project the Ccmmission shall require estimates of anticipated consumptive use from the project sponsor.
The Ccmmission, as part of the project review, shall evaluate the proposed methodology for monitoring consump-tive losses and compensating ficws including ficw meter-ing devices, stream gages, and other facilities used to measure the censumptive use of the project or the rate of streamficw.
If the Cccmission determines that additional aryo e,i
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ficw measuring devices are required these shall be pro-vided at the expense of the applicant and shall be subject to inspection by the Commission at any time.
When the project is ' operational, the project spon-ser shall be responsible for determining when compensation is required and shall notify the Ccemission immediately when ecmpensation releases ccmmence and cease.
The pro-ject sponsor shall provide the Commission with periodic reports in the time and manner as it requires showing actual censumptive uses associated with the project.
The Cc= mission may use this data to modify, as appropriate, the magnitade and timing of the compensating releases ini-tially required when the project was approved.
(e) Quality of compensation Water.
The physical, chemical and biological quality of water used for compen-sation shall at all times =eet the quality requirements for the purposes listed in (b) (1), as applicable.
(f) Effective Date.
This section shall apply to all cen-sumptive uses initiated since January 23, 1971.
Any project that has initiated censumptive use after the effective date is subject to this requirement.
Such users or projects which will begin consumptive uses in the near future must ccmply rb - cr g t~
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with the requirement within a time period to be set by the Co=:tissicn for individual proj ects.
Dated:
September 14, 1976
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6 Robert J. pielo, Executive Director Susquehanna River Basin Connission
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