ML19242C485

Forwards Technical Reviews of Des. Comments Are Provisional in Nature

ML19242C485
Person / Time
Site:	New England Power
Issue date:	08/03/1979
From:	Kelleher S RHODE ISLAND, STATE OF
To:	Cota P Office of Nuclear Reactor Regulation
References
NUDOCS 7908100474
Download: ML19242C485 (95)

Text

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h ph z sae STATE OF RHODE ISLAND G PROVIDENCE PLANTATIONS E XECUTivE CH AMBE R PROVIDENCE J. JOSEPH G AR R AHY covenson August 3, 1979 Phillip C. Cota, Ph.D.

Environmental Projects Branch 1 Division of Site Safety and Environmental Analysis U.S. Nuclear Regulatory Commission Washington, D. C.

Dear Dr. Cota:

Enclosed are copies of our technical reviews of the Draft Envirormental Statement on NEP 1 and 2.

These comments are to be considered provisional in nature.

Should the NEP 1 and 2 application be reactivated, the State of Rhode Island will submit more extensive com=ents.

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Sean A. Kelleher, Ph.D.

Energy Capability & Management Governor's Energy Office 80 Dean Street Providence, RI 02903 Enclosures A

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REVIEW OF SECTIONS of Draft Environmental Statement dealing with Hydrology William E. Kelly Wakefield, R.I.

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1 General Comments Freshwater bydrology is not adequately described in the DES.

The importance of freshwater inflow to the ponds is dismissed with a statement to the effect that it is small. However, no estimate of ground water or surf ace flow into the pond system is made and no estimate of the effect of the reduced ground water outflow to the pond system is attempted.

No attempt is made to estimate a water budget for the areaother than references to the average annual rainfall. Average annual recharge is not a reliable indicator of sustained aquifer yield for this site.

The proposed use of ground water at the site is significant and its impact cannot properly be evaluated without a water budget.

A slurry trench wall is proposed for dewatering and this will certainly lessen if not eliminate the possiblity of salt water intrusion and interference with offsite wells due to dewatering. However, the concept is presented in a generalized way so that it is difficult to assess its probable effectiveness. Secondary effects of the slurry trench wall are not considered at all. Recharge to the aquifer will be reduced and the impervious trench wall will increase drawdovns from ground water withdrawals during construction which are anticipated to be the largest withdrawals at the site.

Over the long term, the effect of development of ground water for plant use on ground water availability for the town of Charlestown is not considered. Although average usage of ground water at the proposed plant is less than .1 mgd this is a significant part of the estimated .6 mgd estimated available 1970 supply and the .15 mgd 2020 estimated surplus.

Scecific Comments 2.3 -Sands Pond which is reportedly used for water supply on Block Island appears to be slightly closer to the site than Jamestown Pond r,n- q u .. - I -

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2.5.1.1 -No estimate of the freshwater input to the pond system is made. King Tom Pond and Cross Mill Pond are referenced in the text but not shown on Fig. 2.4. which is difficult to read.

2.5.2.1 -Which artesian well is mentioned? South Kingstown has two water table gravel packed wells at Factory Pond. There are no artesian public wells in the area.

-Reference is made to the Pettaquamscutt and Saugatucket Rivers which are misspelled. Flow is generally south; the statement on local modification by the rivers is either irrelevant or incomplete. For example, Fig. 6-3 shows ground water flow varying from a generallywesterly direction near Foster Cove to nearly easterly along the east side of the site.

-If " ground water is recharged by precipitation" then there should be "a close connection between precipitation and increases in level".

-Couldnt a statement about the response of ground water levels to storm-induced flooding be made if the question is relevant? Salt water contamination of fresh ground water would certainly be one result of coastal flooding.

-Is the conclusion that ground water will be sufficient to supply Charlestown through the year 2020 based on ground water availability or maximum pumping capacities?

How would construction of the proposed power plant effect ground water available to Charlestown?

2.5.2.2 -What is the significance of the bedrock aquifer for the pr ased power plant? Couldn't some statements be made on the probable limits of its characteristics from data already available in the PSAR?

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3.3 -The 98,000 gpd withdrawal rate is an average figure.

What are the peak pumping rates expected to be, what are their expected durations, and during what time of the year can they be expected to occur?

-Are the cooling tower basins separate from the ground water system? How and over what period could these basins be resupplied by ground water?

-What are the expected durations of the 200 gpm peaks expected during construction and preoperational testing?

How will the 40 million gallons of freshwater required for preoperational testing be obtained? If from ground water, is this included in the 200 gpm peak estimate?

4.2.1.2 -How will the presence of the slurry wall effect ground water availability during and af ter construction?

4.2.2.1 -The analysis of the impact of dewatering in the absence of the slurry wall is apparently unpublished and was not readily available for this review.

4.2.2.2 -Are the impacts of both the reduction in quantity of the freshwater input to the ponds and the quality change to be considered?

4.2.3 As part of the construction dewatering plan a numerical ground water model should be developed. This should be used to predict effects and for designing a monitoring system to assure limited offsite impacts. Monitoring on the site perimeter wculd not be adequate to insure that chlorides off the site do not rise above 250 mg/1.

Some monitoring off the site would be necessary too.

Also some consideration should be given to levels of other parameters such as sodium levels which may be of concern.

4.6 -The impacts of dewatering during construction of the circulating water tunnel are apparently considered to be minimal since they are not discussed in any detail. Can r >,3- n, Le . 6 -

4 a statement to this affect be made?

4.6.2.1 -The plan to limit chlordie concentrations would have to insure that no offsite wells have concentrations of 250 mg/1. Also as previously noted other parameters such as sodium may be of concern.

5.2.2 -What are the conditions for " extended abnormal operation"?

What would the pumping rates be and for what duration? In the event that a slurry trench wall is installeC and the till area as shown in Fig. 6-3 is an important aquifer boundary, do these statements need to be modified? On the basis of the limited hydrogeologic data available and the limited analysis done so far, aren't these unsupportable conclusions?

-The leaching field proposed is relatively large and will cartainly have some adverse effect on the ground water regime even if it meets the State of Rhode Island Standards.

6.1.2.2 -A complete study of the ground water regime is needed.

In addition to the aquifer recharge characteristics the recharge cycle (quantity, timing variability, etc.) needs to be defined. Also any underflows that may enter the site through the preglacial bedrock valleys need to be defined. A definition of the hydrologic regime adequate to predict offsite effects of construction dewatering and normal plant operation will require some offsite testing and monitoring. offsite testing should include: test boring, geophysical measurements, water level measurements, water quality measurements, pump testing, and stream ficw measurements. offsite monitoring should include: water levels, water quality, and stream flows. Direct measurements of fresh ground water outflow at the f;usnwater salt water interface may also be useful for quantifying current con-ditions and predicting future impacts.

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, 5 6.2.2 -Post-constr" tion monitoring of ground water should include: water quality, water levels and possibly freshwater outflows.

9.2.3.3.11 -The Westerly site appears to fall almcst entirely in the lower Pawcatuck River Basin (see USGS WSP 2033) .

The area certainly is a ground water recharge area al-though it appears to be isolated from major ground water aquifers in the area. Shelter Harbor and Shady Harbor are both in till areas and would have only limited ground water supplies. Salt water intrusion should not be a problem at this site so that Westerly may be and probably is superior to the Charlestown site from a hydrological viewpoint.

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i Review of Sections of NUREG-0529 Draft Environmental Statement related to construction of New England Power Units 1 and 2 (NEP 1-2)

Saul B. Saila Professor of Oceanography and Ch.ef Scientist Division of ',!arine Resources Graduate School of Oceanography Univ- of R,I.

Kingston, R.I. 02581 u g e - <'y om --

This review is restricted to these sections of the Draft 2n..ronmental Statement f o r v. h ic h e c rr.e n t s wer e r e q u e s t ed by the Governer's Energy Office. They are sections 2.7.2, 3.4. 3.6 (as appropriate), 4.3.2, 4.6, 5.3, 5.5.2, G.1.5, 6.2.5. 9.3.2.

9.3.3, 9.3.4, 10.1.2, 10.3 (as appropriate), B.4, Appendix C, and I

. Appendix E. Endorsement or disapproval of other sections of this Draft Environmental Statement or of the proposed prcject is neither expressed nor implied by this review and the comments which follow.

General Comments:

1) To the best of this reviewer's knowledge there is no operational information for the New Fngland area marine environ-ment on the entrapment-impingement impacts of the proposed submerged circulating water intake structures to be located approximately 600 meters (2000 feet) offshore in Rhode Island Sound. Therefore, the applicant's entrapment-impingement predictions for many of the representatise important species are considered to be conjecture. Very little is known regarding the behavioral responses by varicus life history stages and b:. seasons of scoe fishes and motile invertebrates to the proposed 4-take structure. However it is generally reccgnized that large objects located on or near the sea bed serve as attractants for many species of marine life. 1; is the judge-ment of this re'. lewer that because the applicant's entrapment-impingement predictions are not developed from either informa-

on or prior cperational experience cf submerged offshore

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water intake structures in this region or from any substantial experimental data on behavior o' local representative important snecies related to the proposed intake structures, the appli-cant's impact predictions fer entrapment-impingement are not considered adequate for proper evaluation.

2) This reviewer's definition of monitoring includes the purpose of detecting changes from the present state of the biological cccmunity and of the environment. Easeline data are required to provide a standard against which to detect such a change. According to the Draft Environmental Statement (NUREG 0529), such baseline data have been gathered. However, for monitoring to be sensitive to detecting changes, these chances must be specifically defined in terms of particular types and degrees of impact, and the accuracy and precision of the available baseline data must be specified. To the best of this reviewer's knowledge no evidence is presented by the applicant to specificall:, define the nature of the methodolog:,

to be applied to further comparisot.s of marine communities in :4inigret Pond and Rhode Island Sound with existing baseline data. Neither is any indication given of the level of impact which the past baseline studies and proposed monitoring program will be able to detect with reasonable confidence. This reviewer contends that inadequate planning has gone into studies designed to test the null hypothesis that no change due tc the plant imnact have cccurred. For the baseline and proposed monitoring studies, neither the level of r. pact to

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be detected nor the ability of the existing or planned programs te detect change have been defined.

Soecific Cctments:

1) There is a contradiction in the applicant's entrapment-impingement prediction and the EPA's evaluation (E-GO) with data presented on pages 2-33 and 2-42 of the main report (NUREG-0529). According to Raytheon Ccmpany - Juvenile Squid Populations in Block Island Sound, 1977, Final Report (1975) large quantities of all life history stages were found in Block Island Sound. Indeed, squid were a very important part of the otter trawl collections in the vicinity of the intake structure - comprising up to 375 of the catch at BISA (cited frcm 2-42). Also squid eggs and adults were seasonally abundant in the vicinity of the proposed intake structure.

The omission of this information frcm both the applicant's evaluation and the EPA evaluations render the.m completel3 invalid with respect to this species.

2) page 5-3, 5.3.1.1. water intake. No details on the applicant's statement that presious operating experience has demonstrated the effectiveness of the water intakes utilizing a velocity cap in reducing fish entrapment are provided. This reiiewer has been unable to find any such information far the Northwest Atlantic marine en' ironment , and on1; ver; limited information elsewhere. Cne such reference i s 'v. e i g h t , F H-1955, Ocean Cocling Kater System far 500 T-l Steam power Staticn.

proc. ASCE 84(p36): 1855-12. 15S5-16, and another is Richards.

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of fish at water intakes. In: 4th National Workshop on Entrainment and Impingement, L. Jensen (ed.), E. A. Ccrmunica-

ons. Although Inis paper suggests up to a 90 percent reduction in losses, it should be pointed out that a survey of fish impingement at 32 power plants in the U.S. (Stupka and Sherm ANL/ES-56, Vol. III) indicates that impingement data alone provides no basis for decisions on intake technology.

3) page G-10, 6.1.5.2. Aauatic, and page G-14, C.2.5.2.

Aouatic. This information is abbreviated to the point of being meaningless.

4) Page 6-10, Ecological parameters. The changes made in the ecclogical monitoring program include decreasing replicates anu increasing ichthvcplankton sampling stations.

What was the basis and justification for these changes?

5) Page 9-204, 9.3.4 Alternative fish re urr svstem.

This reviewer disagrees with the staff statement that "it is believed that impingement will not be a serious problem at this plant" Totally inadequate information or conjecturo for.,the basis for this opinion, and it is not justifiei Furthermore the staff recommendation that "If impingement rates teccme unacceptably high during operation and sursIval of entrapped fish and shellfish is found to be good. Installation of a return system with Block Island Sound as the receiving location is reccmmended' is considered inapprcpriate. T ". t reas:n is tha: the probability of sucstantial sur:1ral oi representative irrortant species of .sh and sh '1 " h is considered to be cer) e g <r  ;

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lew due to the physical stresses frcm pressure changes and fluid stresses, as well as mechanical injuries.

Instead of considering alternative fish return systems, it is recommended that mitigation measures, such as direct replacement of entrapped-impinged organisms be considered.

3) Pages 4-17, 4.3.2.2 Turbiditt and sedimentation, last paragraph. This reviewer challenges the statement that recovery of areas subjected to dredging or spoil deposition is generally relatively rapid. See: Saila, S. B., 1976, Sedimentation and food resources: animal-sediment relationships. In: !!arine Sediment Triasport and Environmental 'Ja n agemen t , Ed. b:. D. J.

Stanley and D. J. P. Swift, J. Wiley and Sons, pp. 379-492. On the basis of a recolonization model and empirical data derived from Rhode Island Sound the 1 e required for return of a dredge spoil disposal area to 95 percent of its equilibrium popul- 'on was estimated to be approximately 11 years. In certain areas recovery of perturbed areas may be quite slow. The rate of recolonization is site specific and is also related to the extent of the disturbed areas. The inferences drawn by the applicant in the recovery of disturbed sediments for the regicn are considered to be overl:, optimistic.

7) Page 5-39, 5 . 5 . 2 .a.c_ u a t i c . 5.5.2.1 Ircincement. To this :eviewer it seems unreasonable to predict the i.Tpingement rates of the proposed cower plant cased on extranolations from available data and various t :es of multiplier factors. The

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. , U-highl3 unpredictable nature of sericus impingement events should be recognized and a plan should be developed to demonstrate bcw to cope with such a serious event - if it should occur-That is, both the problem of how to minimize the frequency and occurrence of impingement losses and how to cope with a serious impingement event (when it occurs) should receive careful atten-tion.

S) Page 5.65, Table 5.32. This reviewer questions the EPA assessment of operational impacts on long-finned squid and lobster with reference to both entrainment and entrapment-imp;ngement. The reason for these questions is that not enough is yet known of the spatial ana temporal distribution of Icbster larvae in the vicinit:, of the proposed intake, and the inferences drawn for the squid were based on the asst =ption that they were not present in the area.

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T0: Dr. Clem Griscom FROM: Scott Nixon DATE: June 29,1979 Associate Professor of Oceanography RE: Review of NRC Draft Environmental Statement I have reviewed sections 2.7.2; 3.4; 3.6; 4.2; 4.3.2; 4.6; 5.2.1 ; 5.2.2; 5.5.2; 6.1.5; 6.2.5; 9.3.4; 10.1.2 and 10.3 as requested. Because of a lack of time I have given Appendices C, E and F only cursory review. Overall, this is a better prepared and written document than many of the ES manuscripts I have reviewed. It is also much more concise and qualitative in its analysis.

While I have included a list of specific points of question or disagreement, there are three major concerns which I think need to be emphasized.

1. The major impact on Ninigret Pond is likely to come during construction of the plant. While the NRC staff is clearly aware of this, they seem willing to accept at face value the bland assurance that " good construction practices" can eliminate the potential destructive input of sediments, oils, metals, nutrients, etc. that their own analysis indicates as likely to be a problem. I think we should be considerably more skeptical - all it takes to put a real slug of sediment into the ponu or a large dose of oil is one careless bulldozer operator. It seems very unlikely to me that a construction operation of this magnitude could possibly be carried out so close to the pond without a serious adverse impact. Whether or not we are willing 'o accept that impact is another question, but it weake, the credibility of the entire report to suggest that construc ion impact on the pond can be virtually eliminated by being careful. As they say, " wishing don't make i t so. " The ES should be much more specific in this regard in spelling our mitigating measures to be required - e.g., very wide buffer strips of perhaps 500 feet or more.

2. One of the problems with having state regulations is that some people will use them to carry more than they can bear.

Throughout my sections of the ES, the NRC stafs ducks the question of sewage impact from the 3,000 construction workmen by simply assuming that the leachfield used will comply with state laws and therefore be acceptable (see. 3.6.2, p. 3-13).

There are a number of problems with this approach. I cannot imagine that anyone who knows this area would seriously propose that a 3 acre leachfield for 3,000 workers reaching to within 50 ft. of the edge of Ninigret Pond would not have a potentially major impact on water quality. One of the problems is that the soil along the backside of the pond is poorly sorted glacial outwash till through which water moves relatively quickly. Such soil gives a good " perk" test, but the problem is that the water (sewage) will be moving quickly toward the pond. Our thermal IR photographs clearly show groundwater inputs along the back of the pond. It seems to me that this is a potentially ser1ous problem that has not been adequately covered in the ES.

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3. The coupling of Ninigret Pond and Block Island Sound through the breachway means that the pond can be influenced by the cooling water intake and outlet ports, even though they are located offshore. While I have not reviewed the section on hydrodynami.

modeling, the NRC staff states in these sections that the warm water plume from the cooling syste:n will -each to the breachway with a AT of 3-4 C. Given the uncertainty in such calculations, it may be considerably higher under some conditions (strong on-shore wind, etc. ). Is it possible that this warmer water could be carried into the pond and result in an appreciable increase in the average pond temperature? This point is not discussed in these sections of the ES and it seems to me to be something we ought to resolve. A similar concern arises in the discussion of plankton mortality. While I agree with the ES that this factor is probably not important if the volume of water passing through the plant is compared to the volume of Block Island Sound, I wonder about the pond. How much of the water entering the pond will have passed through the cooling system before it gets into the breachway. Similarly, how much of the ebb flow from Ninigret Pond (or possibly the other ponds) will pass through the system?

It seems to me that we ought to know something about the inter-actions between the breachway and the inflow and outflow sites, and not just look at the Sound as a whole.

bbre Specific Comments:

3.6.2, p. 3-13.

How close to edge of pond will leach field for 3,000 workmen be? State standards are probably not adequate here.

Page 3-14. 15 mg/l for oil input tells us only the oil concentration, but not the nunber of liters of such oil discharge water-hence we don't know the oil input.

4.3.2.1, A minimal dredge estimate for Pt. Jude would seem to be

p. 4-16 ca . 8,500 yd3 . Perhaps it should be required for the dredging to be restricted to ebb tides. The time of year should be selected so as not to conflict with fish migration.

4.3.2.2 What are " stringent control measures" for reducing sediment Page 4-18. . input - a major problem in this pond. Where is the sediment going or likely to go if it is input from the site?

4.3.2.3, Page 4-19. Again, in spite of the admission of substantial impact from nutrients,1cw 07 , oil and metals, the staff consistently seems to be willing to accept that " good construction practices" will nake everything all right- but specifically what are these practices, how are they be be mandated?

4.6 Where is the " local area" for the sanitary wastes to be?

Page 4-29 Both Charlestown and South Kingstown are pressed for space.

4,000 people generate a lot of garbage.

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5.2.2 Again, the sewage-groundwater problem is avoided by putting Page 5-3 the responsibility on the state standards' 5.5.2.2 It is not clear that the entire volume of the euphotic zone Page 5-45, of BIS is the appropriate hydrographic unit. The plankton 5-46 dynamics have r.ot been related rigorously to realistic estimates of advection at all, nor do we have the residence time of the water in the vicinity of the intake. How much of the water passing through the system enters or comes from Ninigret Pond?

5.5.2.2 It is not clear to me that the best way to put perspective Page 5-49, on the potential loss of a given amount of fish is to 5-52 ccmpare the loss with the total R.I. landings of that species. For some species, much of the R.I. catch does not come from Block Island Sound. On the other hand, a portion of the BIS stock is landed in Connecticut.

5.5.2.3.3 No reasons at all are given for increasing the estimated Page 5-54 Tautog population by a factor of 10 in making this assessment of power plant impact.

5.5.2.4 If the " avoidance i.emperature" for winter flounder is ca.

Page 5-57 4 C on the basis of laboratory studies, and the " staff's" far-field temperature model predicts AT of 3-4 C over ambient at the mouth of the pond breachway during spring and fall, it seems to me that there is considerable reason to worry that migration between the pond and sound might be disturbed. Af ter all, both estimates are subject to considerable uncertainty. I don't see that their conclusions follow from their own assumptions. Moreover, no avoidance data for other species using the pond are given (e.g.

American eel).

5.5.2.5 Even though there may be not toxic effects of the chlorine, Page 5-63 isn't it possible that migrating fish may avoid areas with elevated chlorine as they do water with high temperature.

If so, the plume of elevated chlorine water near the pond breachway may interfer with spawning migrations between the pond and the sound.

5.5.2.5 Again, we find a great reliance on the R.I. State require-Page 5-63 ments for leachfield operations to protect the pond. This is avoiding the issue. The impact statement should criti-cally review applicable regulations to see if they are adequate.

9.3.4 I agree strongly that the alternate fish return system Page 9-104, should not use Ninigret Pond to return fish and other debris 9-106 to the water. Not only is it possible that such a system would be harmful to the fish (as noted in the report) but it would probably also be disruptive to the ecology of the pond.

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. REVIEW OF SELECTED SECTIONS DRAFT EtP'IRONMENTAL STATEMENT NFW ENGLAND POFER UNITS 1 AND 2 DOCKET NOS. STN-50-568 AND STN-50-569 PREPARFD BY DR. MALCOLP L. SPAULDING DEPARTMENT OF OCEAN ENGINEERING UNIVERSITY OF RHODE ISLAND KINGSTON, RHODE ISLAND 02891 Sections Reviewed: 2.5.1; 2.6.4; 3.4; 4.6; 5.2.1; 5.3; 6.1.1; 6.1.4; 6.2.1; 6.2.4; 9.3.1; 9.3.2; 9.3.3 Section 2.5.1.1 No reference is rade to F. Short's M.S. (Oceanography) thesis on modeling Ninicret Pond circulation dynamics using Leendertse's finite difference hydrodynamic rodel. This study is rather ir-portant in that a first atterot was rade to relate flow resistance to the size and distribution of grass beds that dor.inate the shore-line areas of the cond.

While there have been at least two rodeling studies of Nini-gret Pond and one in depth field investigation by conover, our understanding of the pond circulation dynarics is still very peor.

Frcr scre of the sirple modelina tasks it has been shown that wind induced forcing can rarkedly chance the pond flow dynamics and Short has also noted the irportance of the nurerous crass beds.

In addition, Conover noted tires when the ficw in the pond displayed a distinct two layer pattern. This could be attributed to abnorral fresh water runoff as well as the nurerous fresh water springs alona the nocthern edce of the western basin of the pond. C:: f e r tun a te ly ,

no consistent data set is available as of this tire to sort out

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which are the processes c7ntrolling circulation in the pond. This is not the impression one gets reading the presentation oiven here.

Section 2.5.1.2 No corrent.

Section 2.5.1.3 Another impc. tant bathymetric feature of Block Island Sound is a channel of approximately 80 feet in depth running frcr the northern tip of Block Island and terminating at the Race. The channel is bounded on the north by a cently sloping bottom and on the south by the Southwest Ledce and the Endeavor Shoals. This channel-like structure can be better seen in the three dirensional plot shown in Fig. 1 and the conteur plot (Fig. 2).

Section 2.5.1.4 It would be extremely helpful to have a plot shcwing exactly where the coastal flood plain and in particular the 100 year flood plain is located relative to the barrier beach and the oro-posed plant site. Sirply statino the definition is not very help-ful.

Section 2.6.4 The purpose of this discussion on dispersion is not clear.

After a lencthy discussion on data sources, rodel selection, and modeled scenarios, no results are civen.

Section 3.4 Cccd concise presentation.

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Section 5.2.1 No comrent.

Section 5.3 It should be noted that the currents used in Alden's near field physical model were sinusoidal with the ebb and flood speeds of equal magnitude but separated by approximately 6.2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />. This re-presentaticn is therefore only a first order approximation to the tidally induced flows in the study area.

It seems rather strange that given all the model tests per-forned by Alden for the near field simulations that a full tidal cycle test case for the exact discharge, and intake configuration of the pcoposed design was not run. It would appear that this test run is needed in order to perform an in dep:h evaluation of the near field temperature rise.

The value of velocity chosen for the near field case is open to questions. Typical surface currents in the area of the discharge syster are on the order of .45 - .85 ft/sec (Faytheon, 1975). Run-ning the physical rodel simulations at 1 ft/sec (Fic. 5.1 in the DEIS) which is rouchly 601 higher than the values normally observed, leads to a significant lowering of the areas in the higher surface temperature rise isotherns compared to values typical of the aver-age conditicns. Unfortunately this representation in the near field is carried into the interrediate and far field analysis since the physical rodel provides initial condition information for these subsecuent rodels.

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, i The transient longshore current tests performed by Alden appear to be in question because of the short duration of the test runs coupled with the plume interactina with the boundaries of the modeled area. As shown in Fio. 5.2 (DEIS) the simulation was run for approximately 1/8 of a tidal cycle and already the plume is beginning to interact with the boundaries of the physi-cal model. Based on these observations, it is difficult to feel confident that the values predicted for the near field isotherr surface area are adeguate for any more than a first estirate.

The effects of heat buildup, as noted in the staff's analysis, are clearly missing.

The applicant's far field therral rodel takes al= cst no account of the study area. While their procedure has all the important heat transfer and dissipation rechanisrs several of the assumptions made appear to rake the rodel a sirple nurerical exercise. Assur-ing that neated water will not move shoreward of a given line seems to be an arbitrary assumption unsupported by any data. In fact, Dr. Griscom (UPI Division of Marine Resources) has shcwn that sur-face drifters released at approxirately the intake site location nove onshore very rapidly (in a ratter of hours) during cashcre wind events. Heated effluent could be expected to do the sare thinc.

Observation of tidal currents also sucgest that the tidal ellipses are not parallel to the shcre in the ricinity of the discharce site (Paytheon, 1975). The tidal currents could, therefore, be expected to transport heated water shoreward durinc at lease sore cortion of the tidal cycle. Therefore, the applicant 's analysis is of ques-ticnable value due to the numerous unsubstantiated assurpticns ir developinc his simple far field therral cdel, e qw>< wq Lo u' s s

Section 5.3.2.1 Good analysis and presentation.

Section 5.3.2.2 Note that the surface heat transfer value also includes con-vective heat fluxes from the sea surface.

The envelope of staff's analysis shown in Fig. 6.8 is not entirely clear. It appears to represent the upper and lower bounds of surface area for a given isotherm due to the variation of tidal velocity during the tidal cycle. Better labe31ing would rake this a much more easily understood illustration. It would also help to have the values used by the staff and the applicant noted on the graoh.

Since the initial ". lock Island Sound circulation modeling effort perforred by Isaji and Spauldina was completed, additional rodeling has been performed by Beauchamp (1978) and Gordon and Spauldinc (1979) on predicting the tidally induced circulation in Block Island Sound along with the adjacent coastal waters. Figure 3 shows the nested grid structure of the nodel developed by Gordon and Spaulding (1979) while Figs. 4, 5, and 6 show a corparison of the computed to observed range, Greenwich .aich water interval, and Greenwich low water interval, respectively.

. It is clear from this corparison that the model adequately reproduces the observed tidal behavior in the study area. Comparison of the nested rodel to that em'loyed for the staff's analysis shcws cenerally cood agreerent in the study area thus providing further confidence in the staf f 's analysis o f the coastal hydrodynamics.

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Section 6.1.1 No comment.

Section 6.1.4 No comment.

Section 6.2.1 No comment.

Section 6.2.4 No comment.

Section 9.3

-One should note that 12 tidal cycles corresponds to approxi-rately steady state conditions after starting the discharge at time zero.

-Labeling of Fig. 9.6 and in narticular the nurbers on the graph are not clear.

-The statement that "the size of the excess isotherns cor-pared to the proposed desian is approxirately 10"s" is nis-leading. The real influence of increased discharce flow is to decrease the area enclosed by the hicher temperature isotheres and slightly increase the area of the icwer terpera-ture isotherms.

Section 9.3.1.2 and 3 Good presentation.

Section 9.3.1.4 P: hat is the definition of flushinc employed? Since Fanc's rodel is driven by a seri diurnal tidal heicht boundary it appears i q , e -

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that all the flushing must be caused by the wind. That raises the question as to how sensitive the flushing rates are to winds from directions other than the southwest. Would the impacts change if another wind direction were chosen?

Section 9.3.1.5 It is not clear why one would use the Quonset Point Naval Station wind data as input to the salt drift and deposition model unless the applicant can show the similarity in wind fields between the two areas.

In order to better evaluate the results of ORFAD it is abso-lutely necessary to have more details presented on hcw the ex-perimental law extrapolation is applied. Are data points at all three levels used (10 m, 58 r, 91 m) and fit with a sirple experi-mental profile or is only one point used? The difference betwee.n these two techniques could cause substantial changes in depositien predictions.

After a review of the Ouonset Point Naval Air Station data, it appears that the information contains serious local effects or the wind rose shown in Fig. 9.9 is not correct. Ficure 7 shcts a comparison between the i cbservation of wind for a aiven direction between the Ouonset data (9 year record) and a 5 year record taken at Greene Airport. Also shown are typical yearly data for the Greene Airport station indicating the year to year variation. It is clear frcm this comparison that while the winds at Cuenset are doninated by the N, NNE, NE, and SP, S Si .' , S, the winds at Greene (approxirately 5 kr to the north) shcv considerably -cre winds frcr the '!? quadrant. The Greene Airport station is also -cre typical r 3,,,,

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of the Charlestown site and the U.S. Coast Guard observations at Point Judith Light House. In the absence of significant topo-graphic features such as rountains, valleys, etc., it would appear that the wind patterns at Greene, Quonset, Charlestcwn and Point Judith would display sinilar patterns over a aiven year. Indeed this is the case except for the Quonset record.

Given that the Quonset data has been employed to " reflect long term meterological informstion", no indication has been given as to the likely year to year variations. b'hy couldn ' t the depc-sition patterns be run tor several one year records at Oucnset and these values compared to the lonc term prediction? This would at least give scre indication as to the significance of year to year variation in predicted deposition patterrs.

Because of the large difference between the applicant's estirates of deposition and these performed by the staff, it seers that some resolution should be rade in order to realistically as-sess ccoling towers as an alternative cooling system. Certainly the applicant could present the detailed justification for his calculations to include assurptions, use of available meteroloyi-cal data, and model forrulation in order that the staff could re-solve the discrepancy in deposition estirates.

It is not c1'ar e hcw the staff determined the ambient drift deposition from Block Irland Sound. This point needs to be docu-mented by references, data and/or calculaticns.

Section 9.3.1.6, 7, 8, 9 and 10 Peasonable analysis and conclusions noting the cemrents pre-viously rade on the application of the ORDAD code to the stud, site.

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-1f-Section 9.3.1.11 No conr.ent.

Section 9.3.2.1 Good analysis and presentation.

Section 9.3.2.2 Good analysis and presentation.

Section 9.3.3 Good analysis and presentation.

It appears that the staff has correctly identified an cbvious need to consider an alternative r.ultiport subrerced discharge 1c-cated further offshore.

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REFE RENCES Beauchamp, C., "A Two Dimensional Vertically Averaged Nurerical Model of Tidal Dynamics in the Southern New Enaland Intra Coastal System", M.S. Thesis in Ocean Engineering, University of Rhode Island, 1978.

Charlestown Hydrocraphic Study, April-September 1974, Semi Annual Report, Raytheon Company Oceanographic and Environrental Services, Portsmouth, Rhode Island, 1974.

Short, Red, "Ellgrass Production in Charlestown Pond, An Ecolcai-cal Analysis and Simulation Model", M.S. Thesis, Oceanography, University of Rhode Island, 1975.

Cordon, R. and M. Spaulding, "A Nested Numerical Tidal Model of the Southern New England Bight", NASA Langley Research Center, Harpton, Virginia, 1979.

Griscon, Clement, Division of . Marine Resources, University of Rhode Island (personal communication), June 1979.

u 4 .p_

5 REVIEW OF Tile NUCI. EAR RZGUL\ TORY CO:0!ISSION's D.E.I.S. SEP 1 & 2 Niels West Department of Geography and Marine Affairs University of Rhode Island .

June, 27. 1979 i -

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I have carefully read the DEIS NEP 1 & 2 and found it to vary greatly in quality. A number of critical comments covering the entire document will be made first, immediately followed by more specific points in the text. Where appropriate, these have been referenced.

General Comments:

It is quite clear that the reviewing agency (N.R.C.) has relied very extensively on the applicant's environmental assessment and only on occasion co.lucted independent analysis. This deficiency is particularly obvious .in the sections cealing with socio-economic charac-teristics and potential impacts. While the socio-economic icpact methodologies may not be as well advanced as those of the natural scientists, significant developments have nonetheless been made in recent years which, . had they been applied, wculd have improved the document immensely.

It is curious that neither the applicant nor the N.R.C. has ad-dressed the so-called "No Project" alternative as is required under NEP.' and CEQ guidelines. This very serious omission gives the reviewer the impression that the decision to construct the proposed plant has been made apriori, the only outstanding issue being to identify the most appropriate geographical site. From a socio-environmental point of view, the impacts associated with the "no project" alternative could very well surpass all others should it be decided not to proceed with construction. This section should incleic a detailed remporal as well as spatial (geographical) analysis of future energy demand, in addition

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to the assumptions taken in making these projections. The "no project" alternative presumably would include social impacts caused by a given shortfall in electric power generation. This reviewer urges that the N.R.C. take the necessary steps to ensure that this and future DEISs include this important section.

Another critical general (overall) comment concerns the organiza-tion of the material presented. While it is recognized that the EIS has evolved immensely over its relatively short life and is likely to undergo still other drastic changes, common practice for nearly all agencies involved with N.E.P.A. and the EIS process is to describe the existing conditinns and using these brought forward in time as the base line from which all subsequent impacts can be assessed. The existing cenditions are not static (as is implied by the present document) but very dynamic. To properly assess the conditions which are likely to occur in 1987 against the conditions prevailing in 1978 or 1979 with-out projecting these forward in time under the "no project" alternative is clearly invalid. It is of course true that this complicates the analysis by requiring two sets of independent projections, one dealing with the existing conditicos brought forward in time where comparative analysis can be made in the same timeframe between the " proposed" and the "no projcct" alternatives. An analysis that essentially compares socio-environmental impacts occurring at dif ferent time periods is more likely to obfuscate matters than to facilitate the environmental decision-making process which is one of the objectives of N.E.P.A.

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Since the present DEIS is largely based on comparisons between dif-f e r ent timeperiods it obviously rendersmost of the findings and conclusions highly suspect.

A final general criticism concerns the incompleteness of the analysis.

A good example, but by no means an isolated one, concerns the limited transmission line alignment assessment present in this document. It appears that great emphasis has been placed on describing and analyzing the impacts to the 604 acres which make up the NAPL site, yet the area which will be impacted by the transmission line alignment covers a much larger area (1754 acres) and appears not to have received close scrutiny by N.R.C. (4.1.3.). This portion of the DEIS recognizes the need for the

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analysis but assumes that these impacts can be minimized or at least satisfactorily mitigated (3.7.5.). The point is important and relates to the apriori decision discussed above. The proposed plant can not be licensed to operate unless and until it has been tied into new and/or existing transmission lines. Thus the nuclea'. plant and transmission line alignment should be ascessed together and in as much detail as is required to identify and assess the total socio-environmental impacts.

The courts have addressed this problem generically, although not as it relates to nuclear power plan:s. A comprehensive assessment of all the impacts likely to result from both power generating plant and such facilities as are required to operate it as a system must be completed before approval can b2 granted. It is clear that the courts now require applicant's to take a holistic view, analyzing not only the site specific impacts, but also the impacts which the total project is likely t nom - c Gw,_ ,

to cause. By specifying that the transmission line impacts will be analyzed at some later date inplies that these can be mitigated and will not seriously affect the decision to construct the proposed project. It is therefore recommended that detailed on-site trans-mission line assessments be included in the DEIS by N.R.C. or its designate. This is particularly important in light of the several threatened or endangered plant and animal species which may find suitable environments on or in close proximity to the proposed transmisrion line alignment (2.7.1.4).

Specific Co=ments The descriptive sections dealing with the socio-economic char-acteristics of the three towns appear deficient in several respects.

The analysis of the housing stock within the three towns' proximal area is made more complicated by virtue Of the fact that the towns are popular summer recreational spots and to a varying degree are in the process of becoming suburbanized. The recult is that a sin-nificant portion of the housing stock is being " recycled" into year-round housing. These conversicas have long been popular with the large student pcpulation residing off campus in Washington County during the winter. These arrangements represent a viable symbiotic relationship between summer residents, real estate interests and the students. 'ihile recreational homes are still being built in South County ('a'ashington County) the larger proportion of recent additions to the housiag stock consists of year-round homes occupied by either locals or commuters. The net impact is a tiantening of both the c n r -

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recreational housing inventory as well as year-round homes for reasons outlined above.

It is thus highly questionable how much " vacant" housing stock can be found locally to serve a portion of the transient project related labor force indicated for the three town area without seriously impacting the local lower income segment of the permanent population (4-20).

The DEIS is deficient in its assessment of the current school population (2.8.3.3) within the proximal study area. Two points bear noting. As has been stated (Table 2.10), all three towns grew between 1970 and 1977, a trend which is projected to continue although not at rates comparable to those of the immediate past.

It is indeed curious that no private (parochial) school population was included in this analysis (2.3.3.3). This point is equally true for the Environmental Report Vol. 1. from which the N.R.C. apparently ab-stracted its information. Both applicant and the N.R.C. completely failed to incorporate the sizeable private school population which is being serviced by several religious schools and a growing number of private schools offering alternative educational opportunities to the school aged children. The omission seriously affects the conclusion which sugges ts that the " project induced" school population wil] not seriously impact any of the three systems. While population growth due to natural increases has declined nationally, such trends are not likely in areas which are being impacted by extensive employment opportunities as will be the case during the construction period of the Charlestown nuclear

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facility. Most of the families moving into South Kingstown, Charlestown and Westerly in search of employmec* are likely to be below median age and include school aged children. These families are likely to require educational space within the respective school systems.

As is correctly stated, most of the growth ascribed to both Charles-town and South Kingstown is projected to occur as a result of inmigration rather than as the result of natural increases (2.43) . It is indeed curious that no analysis has been conducted by either applicant or reviewer regarding the rate of residential development in the Washington County area. It is recommended that steps be taken to validate the sources and methodology used by both the R.I. D.O.E. and R.I. D.E.D. for tables 2.13 and 2.9.

The South County Hospital has recently added a new wing to its facilities (2.8.3.4). This should further increase this hospital's capacity to serve the project related increase in population.

No attempt has been made to assess the project-related demand for increased law enforcement and fire protection for the three towns (2.8.3.5). This section only describes the existing conditions and does not pursue the topic further. Specific attempts should have been

> to project the manpower needs in the four basic services (police, fire, education and town administration) caused by the increased population projected for the three towns. This analysis could have been based on existing population / service manpower ratios, assuming that the in-movers would be socio-economically indistinguisable frca r yc . ,

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the population existing in the communities. In the opinion of this reviewer this section is one of the weakest and should be extensively reworked.

Much has recently been written about the appropriateness of al-lowing construction activities on the floodplain. These concerns cover both the coastal zone and the river. It is noted that the elevation of the proposed site will be raised through fill and ex-cavation to 20 feet above MSL (4.4), some four feet above what is currently required under Executive Order 11988 (1977). It has been noted that extensive excavation will be required by the applicant yet no detailed topographic map (one or two foot contour) has been enclosed identifying in detail the areal extent and location of fill and excavation relative to the highest known storm surge line.

The proposed environmental modification created by the barge traf fic (4.1.2) to the head of Salt Pond raises serious questions concerning the environmental impact cf this operation. It is noted that this site only serves recreational boaters yet it is unlikely that commercial fishing vessels would utilize this facility to any great extent following excavation of a channel in a substantial portion of Salt Pond. The environmental impact caused by this has not been addressed. While disposal is mentioned as a problem which needs

'e resolved, no discussion has been included which proposes solutisns to this particular problem. It represents one additional example of la few seasonal small inshore lobster boats also frequent this portion of the bay particularly in the wintertime.

EiE1RT 1. Il3

an impact which assessment has been deferred.

It is stated in several places that wildlife which is being dis-turbed by noise, excavation and construction activities (4.3.1.1 and 4.3.1.3) will occupy adjoining habitats. This statement does not agree with current ecological knowledge. When established ecosystems are intruded upon on the scale proposed in Section 4.3.1.1 the disturbed wildlife will attempt to establish a new equilibrium. The total biomass may be larger or smaller than before and may in part be made up of the displaced wildlife, however such ecological changes are likely to dis-place existing biomass in adjoining ecosystems. There is very little opportunity for displaced wildlife to temporarily occupy adjoining ecosystems without seriously impacting the of ten f ragile ecological balance. Thus the implied statement in 4.3.1.1. simply is not true and cannot be supported.

The analysis of the Housing and Residential distribution of workers (4.4.2) should have been modeled. Many basic assumptions have been stated. It would not appear an impossible task to develop an empirical model which would project the location of the worker population. While such an effort is likely to be far from foolproof, it does retain one critical advantage over the procedure used in the DEIS which alone abould prove worth the additional effort. By modeling these impacts, the various factors hypothesized to influence the locational aspect of the employee's resi.dential location behavior have bee. ,oth identified and quantified. Any errors can be corrected for or fine-tuned as new and qualitatively superior information becomes available. To estimate the 694119

i 4 location cf existing housing vacancies in 1984-1985 on the basis of the availability of vacant housing in 1977 simply is not valid.

The American population is a nighly mobile ene approximating 20 percent per year nationally. This means that a significant pro-portion of the population living in the three town impact area vill have changed residence between 1977 and 1984-1985. The estimate made by N.R.C. does not take into consideration the er. tensive residential developments which have characterized all three towns.

It would appear that an environmental suitability analysis would have been a r:re appropriate means by which this very important problem could have been assessed. Efforts made by Greenberg represents a suitable starting point for estimating the future population in the three towns.

It is clear that the temporary population impact caused by construction activities will significantly impact the existing muni-cipalities, and while the cost of these may be covered by the in-creased rateables, the fact is that no attempt has been made to address these except in a very general manner. This omission seems peculiar in view of the importance which CEQ places on addressing socio-economic impacts on par with those impacting the natural environment.

The reviewer agrees with 'i.R.C. that recreation constitutes an important contribution to the South County economy. The recreational opportunities span vir*.ually the total range of activities associated with a water environment from surf and off-shore fishing through swimming, surfing, diving, racing and ex n * ...)

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cruising including such popular passive activities as sightseeing. The recreational impact analysis constitutes approximately one very descriptive page (4.4.6) in which it is concluded that the impact on recreation will be minor. No discussion of the methodology utilized, samples taken etc.

have been included. Considering the great importance which Rhode Island places on outdoor recreation,particularly marine recreation,and con-sidering the substantial sums of money the state derivesfrom visitors, this reviewer takes issue with both conclusion as well as the manner in which the " analysis" has been conducted. No attempt has been made to analyze the impact the proposed project will have on the various recreational users. The connection between sports fishing and the severe reduction in the tautog and cunner population is not made let alone analyzed in detail (5.5.2.3.3). As mentioned elsewhere (Sisson) the two species constitute one of the mainstays of both surf and of f-shore sportsfishing in Rhode Island.

Some of the impact statements have been misplaced within tl e text, e.g. 5.1. This section discusses impacts of transmission line operation. Most of the potential impacts discussed in this section relate not to the operation of the line but its construction. What is not included in this section is the economic impacts which the trans-mission line may have on adjoining real estate. While a tight methodology may not yet exist, an attempt should have been made to develop estimates for key land uses rather than discarding these in-pacts by a statement implying few if any.

While this reviewer was not specifically requested to review t ~ c . g r., a L~% ..%.

the demand estimation sections (8.2) a careful review of these pages was made. The N.R.C. staff is to be commended for the overall thorough comparative analysis, particularly the evaluation of the projections made by NEES and NERA. In this context it should be remembered that the external conditions have changed significantly in the few months since these sections apparently were vritten (8.2.2). It is noted that the National Research Association (NERA) projects growth in the region's total electric demand ranging between 5.2 per cent and 7.7 per cent between 1975-1985. These estimates have been based on regression analysis which apparently incorporates pre-OPEC blockade consumption data. These estimates were modified downward by the N.R.C.

staff, and closely match the "no project" alternative by the Demand Subcommittee of the recently completed New England Energy Congress (NEEC).

The comparative analysis between electric power and solar for space heating (8.2.1) is encouraging even though much more effort should have been made to analyze this and other forms of alternative forms of energy. The underlying assumptions of this DEIS are indeed remiss in not assessing the demand for energy based on a dispersed population model.

The brief section dealing with conservation (8.2.5) corresponds well with NEEC conclusions on energy demand in the short term (1985).

Appendix N is a brief description of a constraint which according to N.R.C. has been used as a criterion in siting nuclear facilities r pc.,m U m. %, .. a

(N.R.C. Regulatory Guide 4.7., Rev.1, Nov. 1975). Two criteria are used to determine if a given site is suitable. The first requires that the population density extending to a distance of 30 miles from the pro-posed site should have a population density of less than 500 persons per square mile at the time of initial operation. If this requirement can not be met, N.R.C. and the applicant is obligated to give special attention to considering alternative sites with lower population densities.

N.R.C. did not review and address this point in great detail.

A rough calculation of the population density in the four Rhode Island counties which are likely to be included (all or in part) within 30 miles of the proposed site suggests that the existing population den-sity exceeds this criteria. This calculation is based on conservative R.I. Department of Economic Development (1977) population estimates which for Charlestown, South Kingstown and Westerly fell below those reported by N.R.C. Nor do these figures include the sizeable transient population which visits the southern portion of the state during the summer.

N.R.C. discarded the guidelines almost immediately after having stated them (N-4) by requiring population densities at alternative sites to be lower than those characterizing the present site by a factor of two. No discussion is presented which justifies this particular function. The point is significant and bears upon a philosophically potentially= ore important point which will be touched upon next.

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t If indeed safety considerations deem it necessary to locate nuclear facilities in areas of low population density, that portion of the population who live in the hinterland of such a facility has in fact been denied equal protection under the law. The risk (however small) is carried by a specific segment of the population who (a) are not being compensated for this increased risk, and (b) who have not in-dividually or collectively had an opportunity to affect the siting decision in any meaningful way. While it is recognized that several attitudinal surveys have been taken in Charlestown and vicinity, these appear not to have affected either positively or negatively the decision-making process.

NOTES New England Energy Congress, Final Reoort of the New England Energy Concress: A Blueprint for Energy Action, Tufts University, Medford, MA, 1979 Greenberg, Michael R., "A Test of Combinations of Models for Projecting the Population of Minor Civil Divisions,"

Economic Ceography, (April, 1972), 48,2,179-18S Sisson, Richard T. , "A Preliminary Evaluation of the Magnitude of the Sport Fisheries in Narragansett Bay, 1970." Rhode Island Division of Fish and Wildlife, Marine Fisheries Section Leaflet # 34, Providence, n.d.

i y n a, -

Le o % s . __

, t Comments on NUREG - 0529 Draft Environmental Statement (USNRC)

Related to Construction of NEW ENGLAND POWER UNITS 1 and 2 Published May 1979 Prepared by:

James E. Hickey and James Nolan Division of Occupational Health and Radiation Control 28 June 1979 c .,,s . , _

L- u u_. s. _1

General Comments

1) Radiological Impact of Routine Operation:

The Nuclear Regulatory Commission (NRC) staff's general findings indicate that, barring a major accidental release, the expected radiological impact on man and biota of the construction and operation of the proposed facility will be negli-gible. To arrive at this finding, the NRC staff compared the information submitted by the Applicant in his Environmental Report (ER) and Preliminary Safety Analysis Report (PSAR) against the requirements of NRC regulatory guides. A major determi-nation in this matter relates to the ability of the proposed liquid and gaseous radioactive waste systems (RWS) to control radioactive effluents from the facility within the design objectives for radiation dose in accordance with Appendix I, 10 CFR 50. The NRC staff found that the proposed systems, if manufactured, installed and operated properly, promise to control radioactive effluents to a fraction of the Appendix I guidelines. This, they conclude, will result in radiation doses to individuals and to the population within 50 miles of the facility which are insig-nificant when compared with the existing natural background radiation in Rhode Island of 100 millirem per year per person.

While we are in general agreement with the staff's determination, we take note of the preliminary nature of this determination. The actual performance of the RWS is dependent upon many factors other than design criteria and can only be judam under long tem operational conditions. One of these factors relates to the number of unscheduled releases which may occur at the facility and for which the RWS may not always be sufficient to limit releases to Appendix I guidelines. Although historical data for similar plants would indicate that these conditions occur on a periodic basis, their impact is not included in the routine Appendix I analysis.

The staff alludes to this matter when mentioning that actual license conditions may allow releases greater than those presently projected. We, therefore, believe that a routine radiological monitoring program which goes beyond that presently planned is indicated to assess the impact of facility operation on the environment.

We also believe that data produced by the monitoring program should be available to our agency without prior screening by the Applicant. Specific comments on the Applicant's proposed monitoring program are provided later.

2) Radiological Emergency Planning and Response In Chapter 7 of the Environmental Statement the NRC staff finds that, "the environmental risks due to postulated radiological accidents are exceedingly small..." This finding is based upon: the very low probability of major postulated accidents as confirmed by experience; the Rasmussen Reactor Safety Study; and, the design capabilities of the Applicant's engineered safety syrtems to limit radio-active releases should major accidents occur.

We defer to the NRC staff's technical judgement on this matter. However, we wish to mention several points relating to this matter which are perhaps outside the staff's consideration and responsibility under present guidelines. One is the questionable reliability of the postulated accident scenarios in predicting actual accident sequences, personnel responses to accident situations and resultant consequences of accidents. Preliminary information on the Three Mile Island (TMI) accident casts doubt tpon the reliability of postulated accident scenarios. Another point regarding the environmental impact of accidents relates to the readiness both in terms of training and equipment, of off-site personnel to evaluate environ-mental imoact from accidental releases, especially short-tem impact. When accidents or incidents occur, the state government has the responsibility to inform and, it appropriate, to reassure the public concerning radiological consequences, c, - - c ,

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. i We now know that theoretical projections of impact are not sufficient during these episodes, and that reliable real time measurements of environmental levels together with on-line facility status information are necessary. Informed decision making by State Government authorities regarding immediate protective actions requires the ability to quickly measure the radiological levels in the environment inde-pendently of the facility. This, in turn, requires very early notification to off-site authorities when potential accident sequences are discovered by facility personnel.

We, therefore, believe that there is a need for the Applicant to provide detailed emergency response planning infomation both in tems of the measurement equipment in place and available, and in terms of his assurances to fully inform and cooperate with off-site authorities who have emergency responsibilities.

Specific Coments (J. Hickey)

1) The Applicant in the Introduction to his latest revision of his Environmental Report (ER) continues to indicate that he has followed the outdated Revision 1 of Regulatory Guide 4.2 in preparing the ER. We suggest that the Applicant clarify which Revision he has followed. In any case we believe that the Applicant should be required to conform to the latest guides and regulations.

2) Various statements by the Applicant in his latest Revision of his ER are confusing regarding his response to the requirement for Appendix I, cost-benefit evaluations on alternative Radioactive Waste Systems (RWS). The Applicant has revised Section 5.2.4.4 of his ER to indicate that the necessary infomation is contained in Appendix C.3 of the ER. However, the Applicant further comments in Section 10.7 and 10.8 of the ER that Appendix I evaluations for liquid and gaseous RWS are unnecessary. Further, the NRC Environmental Statement in Section 3.5 refers the reader to the Chapter 11 of the NRC Safety Analysis Report for a discussion of the RWS cost-benefit analysis required by Appendix I. No such specific discussion was found. We suggest that the area of costs versus benefits of alternative RWS be specifically discussed by the NRC in the final Environmental Statement; that a statement appear regarding the staff's opinien on the adequacy of the Applicant's analysis; and that the Applicant be required to clarify, correct and/or delete any contradictory statements or infomation contained in his Environmental Report on this subject.

3)9 In Table 15.4-3 of the PSAR, the Applicant continues to indicate that 1.09 x 10 Ci of 85Kr would be released in the realistic case during the first two hours of a loss of coolant accident. This appears to be an error inasmuchas the amount of 85Kr indicated to be released is greater than the combined facility inventory of 85K r. Also it is greater than tl.a 3.87 x 103 Ci to be released during the first thirty days in the same accident situation. The Applicant should correct this table and any dose calculations based thereon.

4) The Applicant has not yet clarified to cur satisfaction whether he will notify the State Radiation Control Agency in the event of unscheduled releases of radio-active materials to the environment below the level necessary to declare a General Emergency. It is our position that such notifications are essential to our timely participation in the off-site assessment of the consequences of such releases. Furthermore, it is our desire that the Applicant agree to notify the Agency at the earliest possible time of any transient operational condition, whether scheduled or unscheduled, which could produce transient radioactive releases.

While necessary assurances can undoubtedly be obtained by regulatory or other means, we prefer that the Apolicant make the necessary assurances by appropriate statements in his ER and PSAR.

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5) Natural Background Radiation A significant source of natural radioactivity in Rhode Island has been found to be drinking water from wells which extend into granite formations. These types of wells are the major source of water in the area around the proposed facility and will most likely be the type of wells used by the facility for other-than cooling purposes. We suggest that the preoperational environmental evaluations include a radiological evaluation of appropriate water sources for natural radio-active materials.

Comnents on Subsections 6.1.3 and 6.2.3 and Section 7 of the Charlestown EIS J. Nolan 10 CFR 50.34 (a) contains provisions designed to assure that releases of radio-active material from nuclear power reactors to unrestricted areas during normal

eactor operations, including expected operational occurrences, are kept "as low as reasonably achievable" (ALARA). As part of this effort, Appendix I of 10 CFR, Part 50, contains specific guidance on design objectives and requirements for monitoring both the effluents from a nuclear power plant and the environment surrounding the facility. This radiation monitoring program must provide data on measurable levels of radiation and radioactive materials in the environment and the plant emissions to evaluate the relationship between quantities of radio-active materials released in effluents during normal operations and the resultant radiation doses to individuals from principal pathways of exposure.

Further guidance on environmental surveillance is also contained in Regulatory Guide 4.8 (December 1975), " Environmental Technical Specifications for Nuclear Power Plants," particularly Table 2, whicn outlines the scope of an acceptable environmental surveillance program for monitoring routine releases of radioactive ma te ri al s . The pre-operational and operational environmental radiological moni-toring program of the applicant contained in Table 6.2 of the EIS follows the Regulatory Guide quite closely and seems to satisfy the minimum requirements for monitoring routine releases.

Each applicant for a construction permit is required by 10 CFR 50.34 (a) to include a discussion of preliminary plans for coping with emergencies, and Appendix E of 10 CFR, Part 50, establishes minimum requirements for these emergency plans.

Subsection C of Appendix E deals with environmental monitoring and requires that the applicant have means for determining the magnitude of the release of radio-active materials, including criteria for determining when protective measures within and outside the site boundary must be taken to protect the public health and safety and prevent property damage.

To aid the applicant in developing a plan, the NRC has developed Regulatory Guide 1.011 entitled " Emergency Planning for Nuclear Power Plants." In this document the NRC recognizes that an important element of emergency planning is the active participation in the planning process by those state and local agencies who have emergency response roles. The Radiation Control Agency is responsible by Rhode Island law to advise the Governor regarding the degree of potential hazard to the public and the need for protective actions resulting from releases of raoio-active materials. As a result, we are particularly interested in the assessment actions to be performed by the applicant in case of an accident. Specifically, we feel the applicant should give reasonable assurance that the magnitude of releases of radioactive materials can be determined, that the magnitude of any resulting radioactive contamination can be 'ietermined, that projected exposure to persons off-site can be estimated, and that emergency action levels specified in the Rhode Island Protective Action Guides can be determined, all in a timely manner. We do not believe the radiological environmental monitoring program proposed by the Applicant will meet the objectives outlined above and therefore b~~ Ebli

e does not meet the criteria established in Appendix E of 10 CFR, Part 50, and Regulatory Guide 1.011.

In the wake of the Three Mile Island incident, it is clear that the probability of a major accident at a nuclear power facility is not vanishingly small. The conclusion in Section 7 of the EIS that, when the consequences of each type of accident are weighted by probability, the environmental risk is very low is probably quite true, but it is impcrtant that the consequences of non-routine releases be evaluated as promptly and as accurately as possible. We have learned as a result of Three Mile Island, that the protective action decision makers need the best information possible, either to allay the fears of the public, or to recommend prcmpt and decisive action where indicated. In order to achieve this objective, we feel the Applicant's program should also include, at a minimum, the following:

1) Increased number of TLD sites for more accurate external dose estimates.

2) Standby air particulate and gas samplers located at each TLD site for more accurate internal dose estimates.

3) An off-site radiation monitoring system with detectors capable of measuring exposure rates from tenths of an mR/hr to thousands of R/hr. This system should have real time capability and should consist of a sufficient number of detectors such that off-site dose rates and plume location should be accurately determine.

4) These real time dose rates, the source term from the plant, and the mete-rological data from the site should be provided to the Radiation Control Agency at a terminal to be located at the Health Department along with access to the Department of Energy ARAC model.

We feel these modifications will provide the .Tgency sienificant additional info-mation with which to make protective action evaluations and therefore fulfill its legal responsibilities if a non-routine off-site release should occur. We also feel these additional requirements are necessary to meet the criteria of Appendix E of 10 CFR, Part 50.

3 Low O o

REVIEW SOCIO-ECONOMIC IMPACTS OF PLANT CONSTRUCTION AND OPERATION (Secs. 2.8, 4.4, 4.6, 5.6, 10.3 and 10.4) of Draft Environmental Statement

'ew England Pcwer Units 1 and 2 NUREG-0529 May, 1979 Dennis W. Callaghan, Ph. D.

M-mber, Technical Review Team R.I. Governors Energy Office L

Associate Professor College of Business Administration University of Rhode Island Kingston, RI 02991 June, 1979 n . , r: q yam ..U- --

General Comments:

I. Significant, localized, socio-economic impacts resulting from the large scale construction and operation of nuclear power plants are a function of at least three fundamental parameters: (1) inmigration patterns of construction employees (including the mix of commuters, travelers and inmovers): (2) tax revenues and distribution thereof, provided by the facility; and (3) expenditures for direct construction-related materials and services provided by local suppliers.

From these and the area's socio-economic base, the bulk of indirect and induced impacts arise.

In the present CES, each of these three fundamental parameters is estimated univariately -- according to a single forecasted scenario. Thus, the CES provides us with only a very narrow corridor of anticipated happenings, when we should expect the possibility of a very broad range. For example, the single assumption of an inmigration ratio of 10% of total construction employees " drives" much of the DES analysis of impacts on housing, schools and community services and leads to rather minimal impact conclusions. The justification given in Sec 4.4.1 for the 101 inmigration rate is hardly adecuate to suggest that this estimate is

" reasonable", much less the "mosc probable" as is called for in the CEQ guidelines, para. 15 0 0. 8 (a) ( 2 ' .

Consecuently, the CES fails to address the spectrum 3c.,

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of inmigration induced impacts amongst which the most yrobable case would fall. And since the magnitude of the impacts are not simple multiples or fractions of the magnitude of inmigration, adequate information for assessing the impacts of higher or lower inmi-gration rates is absent.

II. In those sections dealing with socio-economic impact, no consideration is given to the cumulative influence that the possible simultaneous construction of NEP I

& II, Millstone III, Pilgrim II, Scabrook I & II, and/or Montague coulc have on anticipated patterns of labor migration and naterials/ services expenditures.

Further, no mention is made of pending offshore oil development which could impact the study area as uell.

III. Secondari-social and,cconcmic effects are given only cursory treatment. For example, population changes that could ensue frem secondary economic effects (the creation of additional retail and service trade jobs) are not addressed, although the CEO guidelines state: "Such secondary effects ... may often to ~ ore substantial than the primary ef fects of the original action itself." (Para 1500.2 ( a) ( 3 ): al))

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Specific Comments:

Section 2.8 Social Profile

1. Para 2.8.3.1 In referring to year- round housing, the DES states," ... the market in all three towns is tightening." To this point, the DES should address not only relative reductions in the number of vacant units, but also the inflationary pressures that this phenomenon is Paving on residential prices. This could then be carried forward in subsequent discussions of construction-related impacts on housing (4.4.2).

2. Para 2.8.3.7 In discussions of sanitary landfill sites, the report mThes no mention of existing capacities, nor of the tremendous difficulties that the impact towns, parti-cularly South Fingstown, are having with solid vaste management.

Section 2.S Attitudes To"ard "F.P 1& 2

1. This represents an interesting and rather complete summary of major opinion polis conducted to date as 'iell as reference to opposition and ongoing debates. The DES states that these points and tre uncertaint-;

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associated with the use of the MACF, "...

have caused a noteworthy social impact."

Yet this " noteworthy social impact" is ignored in the benefit-cost summary of the DES (Section 10.4).

Section 4.4 Community Impacts

1. (4.4.1) The DES improperly reflects the Department of Labor's Construction Manpower (Labor) Demand System labor force projections, even thoug' they are correctly presented as much PigPer than t'o.se estimates given bv the acclicant.

. .. First,the CMDS estimates do not acccunt for absenteeisr and less than full time workers, for the CMDS estimates are based on work-months and vork-years.

Secondly, the increasing craft labor requirements do not include additional labor needed to meet tiRC and EPA standards that may ensue af ter 19 81. Dr. ".R. Shriver, one of the principal authors of CMDS, estimates that the CMDS figures underestimate the emplcfrent of labor for the proposed project by about 10%. (See DES reference 64-3, p. 26).

Thus, we might expect that labor figures contained ir the DE." are lov b; 101 and that subsequent labor-related impacts are corres-pendingly (althougP not er:ualc-) underes-timated. t 9 .n . ' <'

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2. ( 4. 4.1) The DES staff considars the applicants 10% labor inmigration rate reasonable based on the experiences of other New England nuclear plants, particularly Millstone I & II.

During the course of a major construction labor study co-conducted by this reviewer (DES reference 4-3) , power company spokesmen for Millstone I & II, Pilgri.T I, and Seabrook I & II indicated that they kept no direct records of labor inmigration. Since the DES pro jections are justified as " experiences" which were apparently not empirically documented, and which may be based on estimates for a sample of one (Millstone), a priori we can hardly consider the rate " reasonable,"

much less most probable. That estimates of this rate are critical to subsequent analyses involving population-induced impacts is obvious.

3. (4. 4 .1) The distribution of labor force requirements across the construction period (Table 4. 4) should be qualified b3 noting the recent experiences of at least two nuclear riant projects. At Millstone III, the construction schedule re: labor requirements has been dramatical:; decellerated and at Seabrook I & II dramatically accellerated.

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s Variances in attendant socio-economic impacts as a function of labor demand schedules should at least be enerally mentioned.

4. ( 4. 4. 4.1) The DES states that "All three communities have adequate sanitary landfill sites... "At least one cf the three touns, South Kingstown, is presently e::periencing critical difficulties with its landfill site and solid waste disposal in general.

5. (4.4.7.2) Additions to regional employment and income resultinc, from construction-related materials and service expenditures should he estimated. Regional employment and income multipliers available through the Harris Regional Economic Input-output model could prove useful in making very rough approximations.

6. (4.4.7.3) The DES states, "The c. rec. e r tv.

tax impact of NEP 1& 2 would also change if tre plant were to cease operating prior to the preiected vear of full decreciation."

This statement needs mueb fuller explanation, possibly including a tax revenue schedule for varying duraticns of operation.

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Section 4.6 Measures and Controls to Limit Adverse Impacts

1. ( 4 . 6.1.1. 21) Offsite trash disposal areas should be identified if the applicant intends to make use of such.

Section 5.6 Community Imnacts - Operation

1. ( 5. 6.1) "Accroximatel"

.. 2 780 operational workers, plus families ..." should read

" including families."

Section 10.4 Benefit Cost Summary

1. (10.4.1.7) The 5% inflation rate referred to here is apparently the anticipated annual escalation in o.ceratinc. c a "2 roll.

. In section 4.4.7.1, the escalation rate for construction payroll was estimated at (61 rer L vear).

Is there justification for either or both of these figures? Does the discounting procedure used in calculating the 1985 present vorth of the total operating payroll su gest that payrolls are estimated to increase at only Palf the overall econcmic inflationary rate (" discount rate"), or does " discount rate" refer to the applicants cost of capital er some other notion? In eseence, to what spe ci f ica ll,< does discount rate refer?

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2. (10.4.2) Again, escalations of costs are set at only half the discount rate. If present value is used in its common sense to refer to discounted purchasing power of revenues, or expenses, then apparently it is anticipated that the utilit*; will hold energy generation cost escalations to one Falf of the anticipated inflationary rate. Is this reasonable? If so, how is it justified? If this is fully explained in reference D c, then that explanation should be st=marized in a footnote in the DES.

This comment applies to Appendix D as vell.

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. UNIVERSITY OF RHODE ISLAND KINGSTON, R. I. 02881 College of Business Administration + Organizational Afanagement. Industrial Relations . 401 ~92 2714 June 28, 1979 Ceneral Comments The site selection evaluation sections are not sufficiently objec-tive as to the methodology employed to be analyzed by approach. One must either agree or disagree with the staff's conc.lusions.

A significant improvement would be to explain the methodology used and obj ectify it. As explained in the specific comments section of this review, the Comerford site seems to be "obviously superior" to Charles-town given the Callaghan- .omerford employment study results.

The staff's treatment of the " eliminated alternatives" was very impressive. However I would like to have a list of all eliminated sites included in the EIS along with statements about why each one was climi-nated from consideration.

Recent developments in the nuclear area and changes in public opinion may generate criticisms of the EIS which might never have been voiced otherwise, I feel the final section might be more critically received now. But this is outside the realm of the review, Possibly a policy statement from the NRC should address needed changes in the review process to reflect new developments.

Sincerely,

' WA Rf Y c.obert A. Comerford /

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Assistant Professor / -

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1. Sec. 9.2.1, p. 9-23 In explaining the staff's site selection evaluation methodology in paragraph 4, e.he variables used to measure each dimension are not intro-duced. More specifically, it would be helpful to present the variables used to measure each of the dimensions (" aspects") in table ot ma trix form. The reader would then be able to evaluate the comprehensiveness of the methodology used by the staff to evaluate the applicant's site selection process.

In Sec., 9.2.3.3, pp. 9-38 to 9-79, the following variable _ were used to evaluate 12 candidate sites and compare them with Charlestown.

General characteristics, hydrology, water quality, aquatic ecology, terrestrial resources, socioeconomic impact, and population. These bases of comparison could be introduced and compared with tae applicant's variables. Then, summaries of similar methodologies gleaned from the litera* are cr'sid be presented for comparison.

Additionally, a si=ilar table or matrix of the criteria used by the applicant could be included so that both parties' approaches could be compared. Essentially it bothers me that both anoroaches have face validity but the reader is in the dark about thir construct validity.

2. Sec. 9.2.1, p. 9-29 Ref., "3. the fact that a clear and substantial superiority should exist in the magnitude of environmental impacts. . . ,"

What is meant by " magnitude?" There must be a more objective way to ex-plain what the NRC looks fer to determine whether a site should be rej ected.

Similarly, "obviously superior," the overall criterion for selecting an alternative site is too subj ective for a " cost benefit" analysis. If L30* , T) u ~ o .. -

it's really a cost benefit model, specify the relationship between costs and benefits in dollar or percentage terms which would be the criterion for rej ecting the applicant 's site.

3. Sec. 9.2.3.1, Evaluation of Applicant's Site Selection Process In table 9.9, p. 9-33, it is indicated that the applicant estimated labor availability at Charlestown site as follows:

" Excellent supply of skilled 1sbor in a high unemployment area."

The Callaghan & Comerford labor study for the R.I. Governor's Energy Office did not support this optimistic assessment. The Comerford, Bear Swamp, Shelburne and Litchfield sites were f elt by the staf f to have less favorable employment environments than Charlestown. Could the Callaghan-Comerford findings, which showed less favorable employment prospects for Charlestown than the applicant implied, move any of these four sites into a more "obviously superior" position?

According to this reviewer's reading, less than favorable employment circumstances for Charlestown would eliminate the major non-financial factor (and employment problems are, at least, partly financial in nature) acting against the Comerford facility and make it "obviously superior" to Charlestown Gncidentally, there is no connection, to my knowledge, between my name and the name of this alternative site!).

Furthermore, from Table 9.9, p. 9-33, the Comerford site would in-volve $200 million more than Charlestown in total cost diff erential.

Relative to inflation effects on initial cost es t ima t e s , this is a small aucunt.

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4 Sec. 9.2.3.1, pp. 9-32 to 9-35 I think the staff has done a commendable job of handling the so-called "elhainated sites." But it would be helpful for the public to know all of these sites and the major reasons why each was eliminated.

5. Sec.10.2 Relationship Between Short-term and Long-term Productivity, p, 10-3 It is unclear in the introductory portions of this section whose pro-ductivity the section addresses. Is NEPCO's productivity at issue, the region's , America 's, or man-kind 's?

If productivity is defined as some measure of output per unit of capital investment, NEPCO's investment to date in this proj ect should be considered. Also, other construction-related firms have made investments either directly and indirectly related to this proj ect.

The point is that the beneficial effects on the area's economy of investments made to date have probably been significant and could be dis-cussed to give a more accurate depiction of the project's advantages.

6. Sec. 10.2.2.1 Land Use In estimating possible lost agricultural production, however small the affected area might be, dollar costs should be estimated.

Many of the icens in Appendix 0 should be re-evaluated and rephrased in light of recent developments in the industry. Public opinion might flare up at some of the opinicas presented by the staff in this section.

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Richard Hellman Professor of Econcuics University of Rhode Island -

REVIEW OF ECONOMIC ANALYSIS OF ALTERNATIVES FOR CHARLESTOWN NUCLEAR POWER PLANT AS SET FORTH IN DRAFT ENVIRONMENTAL STATEMENT OF NUCLEAR REGULATORY COMMISSION, MAY 1979 (NUREG 0529)

For Governor's Energy Office, Rhode Island Submitted June 26, 1979

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MY ASSIGNMENT I have been asked to review the sections of the DES on the com-parative economics of the proposed Charlestown nuclear plant with generation by coal and other alternatives. My sections are:

9.1, 10.2, 10.4, 10.5 and Appendix D.

My review is structured as follows:

1. A brief background statement of the scope of the project and the appropriate response f r an economic analysis of costs.

11. An itemination of the essential factors that must be specified in an NRC economic analysis, and a parallel evaluation of how far each of these items has been covered, or not covered by NRC staff. This is done on a scale of 10 for the optimum response and showing for each item what part of 10 has been covered by NRC, in my estimation. These quantifications are necessarily approxi-mate, but relatively valid.

III. An item by item review of the sections assigned to me on the sections assigned to me on the alternatives to nuclear power other than coal.

IV. Nuclear and coal generation V. Conclusion f>te se u s. w . .

-2 I. BACKGROUND The DES is for a 2 unit nuclear power plant of 1150 F4 costing S2.8 billion. Since this assumes a 5% escalation to 1988, and inflation rates have been higher, we may take a rounded cost of $3 billion. Also, since provision is made on the site for another 2 units, the cost in 1988 dollars could go to $6 billion.

The investment, at either the 3 or 6 billion levels, more than justifies a thorough, comprehensive and adequate study of the comparative (ccmpetitive) economics of the proposed plants versus coal and other alternatives.

Under certain circumstances, the economic study can be crucial to the question of whether to build a nuclear power plant. If the economics for nuclear were no better at best, or worse, than coal, say, then the cost-benefit question arises of why build the nuclear plant and subject RI and neighboring states to the costs and risks of possible meltdowns, low level radiation during routine operation, and the presently unsolved waste storage for thousands of years. This economic possibility happens to be well within the range of the best economic studies I have seen, even including that of the NRC in its DES.

Contrariwise, if nuclear were clearly and substantially cheaper than coal or other alternatives, there would then be the massive, cften subjective, task of measuring against this benefit the costs noted in the above paragraph. This possibility appears to be much more remote than the opposite possibility.

I will new address myself to the question of the adequacy of the SRC Staff's " independent" economic analysis.

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II. REQUISITES OF AN ADEOUATE ECONOMIC ANALYSIS Factors which are essential to a comprehensive statistical and qualitative analysis are isted in Table 1. The explanatory adequacy of the NRC sta-- -.alysis as contained in the DES is rated for each factor on a scale of 10. The number 10 represents optimal adequacy.

The rating can only be approximate, but is an indicator of the area of adequacy. A 2, for example, says that the staff's treatment of the factor is not far from "0", but has some small amount of explana-tory and analytical value.

My matrix shows 10 factors for nuclear and coal. Half have been given virtually no qualitative analysis in depth. Except for O & M, the other are close to zero. The average for nuclear is 1.3, for coal 0.7. Just what these low ratings mean is now explained for item.

1. Capacity factor definition etc. How this is defined can make a 3 to 5 percentage point difference. For Millstone 2 nuclear power plant at Waterford, Connecticut, eg, the monthly " Gray Book" re-port shows the following capacities:

Nameplate rating 910 MW Design electrical rating, net 830 Maximum Dependable Capacity, 842 (gross)

Maximum Dependable Capacity, 810 (net)

Unit capacity factors are shown for MCC net and DER net, but not for nameplate. In this case, the MDC capacity factor is ll; less than that based on nameplate rating.

The curious fact is that the Federal Power Commission frcm the beginning has expressed capacity factors enl; in terms of net genera-tien and nameplate rating. The problem for individual plants and

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4 Other capacity factor definitions has arisen pretty much only since the nuclear power plants have come in.

The only objective capacity is the nameplate rating fixed to the generator by the manufacturer, It is true that companies may unintentionally misreport nameplate ratings, but on the whole errors will be symmetric for other definitions, so that nameplate remains the best single basis for capacity factor.

The NRC staff estimates do not specify which basis is used for capacity factor, but I believe that MDC net is used, because this is the definition which NRC appears to favor in, eg, the Gray Book when calculating actual versus potential energy production monthly.

I would recommend that nameplate ratings be used by NRC.

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TABLE 1: EXPLANATORY ADEQUACY OF NRC STAFF ANALYSIS ITEM 10 = cotimal adecuate NUCLEAR COAL

1. Capacity factor: a conceptual, defi- 1 1 nitio r.al , functional and methodological examination

2. Senescence: of plant & capacity factors 2 0

3. Economic life of plant 2  ?

4. Lifetime capacity factor (1+2+3) 2 1

5. YoYo effect, with histograms. More Important, perhaps, than capacity factor 0 0

6. Operation and maint9 nance costs:

historical vs design 5 5

7. Scale (size) effects: for primary and secondary nuclear circuits 0 0

8. Technological constraints - cost & safety 0 0 welding art for containient vessels and ntoing and tubing, valving, pumps, metering etc

9. Human factor constraints, costs, safety: 0 0

a. management & labor at power plants

b. Similarly at equipment manufacturer

c. Similarly on construction site

10. Low sulfur Eastern coal, as alternate for Western coal in New England N.A. 0 Simple arithmetic average 1.3 0.7 e ,; - . <4 u, _ u - -

2. Senescence This is the decline in capacity facto 4 with age of the plant.

It has been given virtually no attention in American literature.

New England Power (NEP) assumes a rise in CF to the 6th year and a leveling off thereafter at 76.2%:

Year 1 ............ 59.2%

Year 2 60.9%

3 66.8%

4 & 5 71.0%

6+ 76.2%

30 yr. average 74.5-40 74.9 28 74.34 20 73.6 NRC staff assumes a 60% CF with a range of 50% and 70% but does not specify any senescence factor.

ERDA (Energy Research and Development Administration) in a 1975 publicat. inn assumed the follcwing senescence:

Year 1 & 2 .......... 65%

3 to 15 ........ 75% high 70% low 16 to 30 ........ minus 21 per year to a minimum of 40%

Source: ERDA, " Total Energy, Electric Energy, and Nuclear Power Projections, United States" (Feb. 1975) p6.

In my discussions with EWE, the largest German electric utiliti they felt that senescence was a correct principle, but iculd start the decline in CF at the 18th year.

It is obvious that senescence is a crucial factor in the 11ferire econcmics of a nuclear power plant, or coal plant and that the ab-sence of any consideration in the DES is a sericus flaw.

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3. ECONOMIC LIFE OF PLANT With the high capital intensity in a nuclear plant, and a high but somewhat lesser intensity for coal plants, the life assumed for the plant is vital in any economic analysis. The standard assumption of government and utilities is 30 years for both plant types, and this is the assumption of the NRC staff. The assumption, however, is not pure. At pages 7-1, 10-12 and 10-15 the staff also uses 40 years. Some utilities, including NEP, have begun to use a 40 year life, apparently in order te make nuclear costs seem lower, but this is unsystematic. NEP's assumed life in the DES is not specified, and is perhaps 30 years.

A most significant deviation from the 30 year assumption for nuclear is embodied in the study done for NEP by Arthur D. Little Company in 1975, which is understcod to be the basis on which the NEP directors decided to build the RI nuclear plants. This report does not state the assumed lives of coal and nuclear, but at my request NEP found out from ADL that a 30 year life was assumed for the coal plant, but 28 years for nuclear.

This drop to 28 years for nuclear is important not so much for that particular number, but as an indicator that ADL felt that nuclear would have technological problems which would shorten its life. The 28 is simply a proxy for this principle, and not significant as that particular number by itself.

The French use a 20 to 21 year economic life for nuclear, the UK 20 years at a derated CF, the Germans 20 years. RWE, the German utility, uses a technical life o5 30 to 32 years, but an economic life, based on internal calculations, of 20 years,both for nuclear and for coal. Dr. Schcch, who is manager of the generating staticn at Mannheim in Germany and head of the national TUV as well ag;tpa.. ,z u _ _. u '_

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Saden TUV, has told me that he thinks the nuclear plant life is under 20 years, and would have to cost more to bring it up to 20 years.

I have tried to give some idea of the importance of the assumed life of a nuclear versus a coal plant in the comparative cost analysis. The omission of any analysis on this point in the DES is serious.

4. Lifetime capacity factor This is dependent on points 1,2,3, above and nothing more need be added here.

5. YoYo effect If one looks at the annual chart of daily CF's for nuclear power plants, which are known as histograms, he will see that these CF's rise and fall like a yoyo with considerable frequency. This fluctuation factor can be more important than the CF itself.

Thus, two plants with 55% CFs could be entirely different if in one the ava-lability can se controlled to be had at the peak, but if in the other this available was only poorly predictable. An example is the cold spell in March 1978, when there was an auxiliary peak, but both Millstone nuclear plants were shut down.

Dr. Schoch, who must sell his power wholesale competitively, told me he could not operate with the nuclear histogram patterns.

He must have 901 availability at the peak in winter, with 3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> overload capability. The screwhat stochastic quality of the nuclear histogram is one of the main reasons, he told me, for his not buyin7 a nuclear plant.

There is no attention to the ycyo, or reliability, effect, as distinguished from CF, ir the DES and zirtually ncne elsewhere ir the literature. It T.ust be an essential of any valif economic analysis of nuclear power.

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6. Operation and maintenance costs O& M costs are available for nuclear and fossil fuel plants in the necessary detail mainly in the FPC/FERC Form-1 reports of utilities. Since so much of the low capacity factor below the 80%

design for nuclear plants is due to technological problems, they should be reflected in erratic patterns of O & M from year to year as CF fluctuates. As CF drops, O& M, if fully reflected in utility accounts should rise. Conversely, for fossil plants, assuming in general that lower CFs are due to load following (ie. drops in de-mand), O& M should drop.

Staff uses a comparison of 2 x 1150 .W nuclear units with 3 x 767 coal units with flue gas desulfurization (w/FGD). O& M is given as follows:

Mills per Kwh

_C_F_ NUCLEAR COAL NUCLEAP = 100 50 7.4 11.2 151 60 6.2 16.1 260 70 5.4 9.4 174 To see what comparisons of actual plants look like, I prepared the following table for the Millstone nuclear power plant #1, 662 MW, commercial in 1970, with the Canal fossil fuel plant in Massachusetts, 542 :rd, commercial in 1968.

Mills /kwh Nuclear CF Year Nuclear Canal = 100 , Nuclear Canal 1976 3.73 1.45 39 65 73 5 3.09 1.00 32 67 81 4 2.72 1.38 51 62 71 3 4.07 .74 13 32 S1 2 2.42 .72 30 55 73 1 .91 (*) .73 86 6? 78

(*) First year of operaticn, which is usually low in O & M.

I've also compared 3 ".idwestern plants burning coal with the Kewaunee nuclear plant. The ccal units range frcm 460 to 662 :r7, the nuc Mh E T

is 535 BM. Kewaunee O & M was 3.17 mills /kwh in 1976, compared with .66, .69 and .84 mills for the 3 coal plants. With Kewaunee at 100, the coals were 21,22 and 26. CFs for coal were 60%, 52%

and 49%, and for Kewaunee 72%. Point Beach nuclear plant, one of the better managed apparently, operated at .92 mills, with the coals then being 72, 75 and 91 percent respectively of Point Beach.

What this means is that the actual numbers, sel3cted at random, are opposite to the O & M relationships of nuclear and fossil fuel

p. .cs assumed by the NRC staff. This illustrated my point that some qualitative analysis of O&M is essential in an economic analysis of nuclear versus coal, and that this is entirely missing from the DES.

7. Scale Scaling up of size of nuclear power plants has engendered two problems, large jumps in size without first exploring on prototypes the effects of moving well up the line on size; and the aggravation of this risk in m. clear plants as opposed to those using fossil fuel.

I asked Siemens, which has made all nuclear power plants in Germany, why the non-nuclear part of the plant seemed to have more casualties than the primary nuclear circuit -- something I had observed in review-ing the individual plant data from the International Atomic Energy Agency. The answer is that since pressures and temperatures of steam in nuclear plants are a fraction of those in fossil fuel plants, the cine of the equipment such as boilers and turbogenerators must ce much larger, and has breached the experienced limits of scale. I g i'le examoles I have selected at random in Table 2.

This factor must oc considered in a comprehensiee analysis of future plant economics, but has been overlcoked in the CES.

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TAHIJ: 2: Pressures and Temperatures of Coal and fluclear li7..cr Plants .

COAL IJUCLEAR Mana- Hans- Mans- Bull. Browns St. Indian IltJ I T tee ley field Run Ferry Trojan lleaver V Lucie Point 3 Company F1 PL GaPC PaPL TVA TVA Ptlnd PA FlPL PAStJY

!!W 863 952 914 950 1152 1216 923 850 1125 Year Built '76 '76 '76 '67 '74 '76 '76 '76 '76 Type IlWR PWR PWR PWR PWR Turbine:

a. PSI 2400 3500 3500 -

950 873 735 750 715

b. OP 1000 1000 1000 -

575 533 517 513 507

c. ItPM 3600 3600 3600 -

1800 1800 1800 1800 1800 Bo i l e rr. :

a. tJumbe r 1 1 1 2

b. PSI 2500 3625 3785 3650 1005 895 781 750 '

c. OP 1000 1000 1000 1003 575 533 51" 513 507 *; '

Source: FPC/FEllC , Statistics of Steam Electric Plants, 1976 and earlier years.

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- The effect of using dcmstic sources of alternatives to nuclear pcwer en military expenditures, balance of paymnt pryble:rs ard inflation due to OPEC pricing, is vital in today's centext to an econcnic analysis of such use. Some serious attention should be given in the DES to these factors.

8. Technolocical constraints There are sericus questions of corrosien in nuclear power plants, in-cluding leakages frcm the pri:rary into the secondary circuits. The test state of the art of welding is in questien for the centainmnt vessels. The metallurgy and welding and wall thicknesses of piping and tubing is also in questien. The quality ard adequacy of valving, pu ps, metering etc. are also uncertain. The Ger ans and British, particularly, have been uneasy on these points and have cc.T .issicned extensive studies of the factcrs involved. The DES gives no mntion of these risk factors in prediction of cperation of a nuclear plant, but such mention is essential.

9. Hu an Factor ccnstraints A certain high level of quality centrol is essential at all levels of nuclear pcwer tranufacture, constructicn and cperatica and this depends en labor, ranagemnt and design perscnnel, as much as cn pure technology. There are sericus questiens of the level of h=an excellence in those areas in terms of quantity available, adequacy for the requiremants of the sensitive nuclear technology, and willingness to work in the nuclear power industry. Three Mile Island caly brought s

these factors to the public attentien, but cnly recre in degree than the Browns Fe r! Fire. T".ese questions go to the heart of the real '.crld feasibility and costs of nuclear pswer. However, no reccgniticn has been given to it in the DES.

10. Ina sulfur Eastern coal, as alte nate for h'estern Coal in '.:ew Enclanf The CES is ccuied entirely in terms of eider high sulfur Eastern coal with FO, cr Icw sulfur Western coal widcut FC. Tne e is anoder real pcssihi'*ti los sulfur Eastern coal. "here are billions cf tens of dis ccal. At rinin = de CES dould mnticn and evaluate 6i3 pcssibility.

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III. SPECIFIC COMMENTS ON DES I now comment on specific items referring to the page in the DES. Six general comments can be made by way of the DES frame of reference.

-- It uses a strict time horizon of 1986-90. Any alternative whien will not produce 2300 MW by that time is eliminated as a possible substitute for nuclear power plants. For several of the alternatives, however, their additive effect exceeds the output of at least one, possibly the two nuclear units, but this has not been considered by the DES. Also, there is substantial evidence that there is conventional non-nuclear fossil fuel supply oil, coal hydro which, with a reasonable degree of conservation, will carry us through a 50 year time horizon. Therefore, it is not necessary to posit nuclear plants for 1990 if other costs, such as risks and radioactivity are considered primary. I am not advocating that position here, but making the point that it should have been given some recognition in the time frame of the DES.

-- The DES bases its economic analysis on a 60% + 103 capacity factor. Operation and maintenance costs are then keyed to this as the normal expecta. tion in planning the nuclear capacity. There is a possible error of assumption here. If the compa:y ordering the nuclear plant assumes a higher CF, and bases its power supply planning on that assumption, then any serious shortfall requires it to purchase power to replace the deficit. The cost of purchased power is very high because it generally is from older and less efficient fossil fuel plants. This is the case at hand.  :.EP assumes a 741 CF. The shortfall when 601 is achieved, or 50 to 55%, engenders two enpenses not included in the DES staff analysis: purchased pcwer, and high costs of repairing the casualties or other defects which cause the wq,.-

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_14 shortfall. On this ground, the DES analysis is seriously defective.

If corrections are made for purchased power and maintenance, the excess of 15% for coal generating costs over nuclear costs estimated by the staff at 60% CF (at p. 9-27) more than disappears, and on these two points alone coal becomes cheaper.

-- The DES assumes that coal and nuclear will be paired at the same CFs. This is an error. Nuclear power must be treated as close to run-of-stream hydro, therefore used whenever available (with few exceptions). Coal is load following and will be shut down in regions such as upstate NY (where the Niagara and St.

Lawrence hydrcelectric projects, run-of-stream, supply half the energy) whenever demand is less than run-of-stream supply. This will occur 11 pm to 6 am, and weekends and holidays. When con-sidering new plants, a baseload coal plant can consistently average 75 to 85 percent, as shown by actual data of large units. The 50 to 60 percent limitation on nuclear is entirely due to technolo-gical shortfalls below the 803 design. If these shortfalls can be corrected, the costs would rise substantially for nuclear power. The DES has completely ignored the considerations in this paragraph.

-- The DES overlooks the purely fuel savings value of substituting cheap power on a non-base load arrangement in certain situations. This is due to the reversed ratio of fuel to total generating cost between 1968 and 1979. In '68 this ratio was about 401, today it is about 600.

Therefore, substitution of Canadian pcwer when it is available, if the rates are low enough or wind, solar and solid waste alternatives. Ther; should be a good degree of analysis of this factor.

-- The des is flawed in not looking at the total interrelated energy picture. For example, the high use of geothermal, solar, cil shale, etc. in other areas reduces the world and US demand for high

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marginally priced oil and other synthetic substitutes, and thus reduces the cost of, say, oil to New England. This in turn would reduce the economic value of nuclear power in comparison with coal or oil.

The NRC staff eliminates as feasible substitutions for the 2 nuclear power plants all alternatives except coal. In Table 3, I indicate, on a scale of 10 optimum, my evaluation of the adequacy of the staff analysis, and in some items my agreement with the Staff conclusion. I afd specific comments below.

Power purchased from Canada: the incremental hydro unit is so large relatively to the small Canadian market, that there is advantage for the Canadian provinces to send this power to US cheaply for several years. This would affect the amount and timing of nuclear power in New England, depending on prices and estimates of future need by Canadians of their hydro. The DES needs more analysis.

Modernization, in view of the reversed fuel to total generating cost of power, should be given more attention in the DES.

Natural Gas: the DES is not aware that in the past 3 years the natural gas deficit has become a surplus, and that in New England eg, the gas companies are advertising for new customers. The DES should revise its analysis.

Solar: The DES treatment here is not too profound. For example, I use 1100 kwh a month in my house. Half is for electric hot water. If I can get 60 to 80 percent of this frca solar, the drop in need for electricity is great. Even if the solar sub-stitutes for oil or gas, the interrelated demands for fuel will affect the supply and price of oil or coal for electricity genera-tion.

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TABLE 3: Non-Coal alternatives to Nuclear Power, Evaluation of NRC Staff Positions Adequacy of Stj ,:csitica en Approx. NFC Analysis NPC staff re-Al'.ernative & Page No. Value BM 10=Cotica:n jecticn 9-2 Pcwer purchase frcrn Canada 8 agree, ge.erally 9-2 Fcdernizatien of older fcssil plants 600 4 ?tre anal. neM ed 9-2 P.aseloading peaking capacity 8 9-3 Oil 0 8 9-4 Natural Gas 0 7 Analysis too sparse and superficial 9-5 Hydro 2300 5 9-5 Pagnetohydrodynamics (MHD) 9 I agree 9-6 Fuel Cells, 1990 4 I acree with reser vations 9-7 Oil Shale 2. 5 >2D 5 NFC ten Negative 9-7 Gactheral 8 I agree with reservations 9-3 Solid Waste, municipal 2300 6 NFC too negativa 9-9 Fusicn, camercial by ' ,C')0 AD 9 agree generally 9-10 Solar 9 too negative 9-12 Photovoltaics 8 9-13 Wind 7 9-15 Coacneraticn 7 Total 5200

+ 2.5 MBD oil

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IV. COMPARATIVE ECONOMICS OF NUCLEAR AMD COAL GENERATION As a general comment on the health effects of nuclear and coal plants, particularly coal, they are too nebulous, too little is known as yet today, to factor them into cost comparisons. I am not sure these areas are for me to comment on, in any case.

(pp. 9-17 to 9-26).

My main comment will be on Appendix D on the coal-nuclear comparison. I will not repeat comments where they have already been made above.

1. No of units. The DES assumes 2 x 1150 MW nuclear units and 3 x 767 units for coal. There are already 1350 coal units, and a number at a 1,000 +. Using 2 x 1150 for coal as well would pari passu with nuclear, reduce the relative cost of coal, and might come close to eliminating the advantage of nuclear given by NRC staff (15% at 60% CF).

2. The only mention of using Eastern coal (p. D-9) is for high sulfur coal. There are billions of tons of low sulfur coal, and this availability should have been analyzed.

3. Capital costs: the NRC comparison is of a high sulfur Eastern coal with FGD with nuclear. The investment cost ratio of coal to nuclear by Exxon's Research and Engineering Division. This private internal study was made available to me. Unlimited rescurces were put into the study by Ex:on. It shows an investment ratic for a

'ew England plant for nuclear and high sulfur Eastern coal of 721.

I suggest further analysis by DES of the investment factor, because the Ex:en ratio would come close to wiping out the nuclear advantage of NRC staff. Furthermore, for Appalachian l o'.. sulfur coal .ithcu~. FCC -

a pcssibility I have criticised the ':RC study for neglecting -- its ratio is only 531. ,; ; c . - -

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4. O& M: I have already comr.ented on this above, and need not repeat here.

V. CONCLUSION I could submit numerous significant annotations on the DES, but have covered the more important ones.

The conclusion of my analysis of the DES is that its ommissions of coverage, and its defects of assumptions, methodologies, numbers, note of other studies such as the Exxon study, and overall coverage are so great as to require a rejection of the study as it now stands.

With investments of 3 to 5 billion dollars, a more adequate NRC study is warratned. After 28 years of commercial nuclear power in the US, it is time for NRC and/or DOE to mount and come forth with such a study.

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? i REVI_EW Chapter 8 - Need for Plant Chap te r 9 (9.1.1 & 9.1.2) - Alte rna tives of Draft Environmental Statement NEP 1 & 2 NUREG-0529 May 1979 Clement A. Griccom, Ph.D.

Member, Technical Review Team R. I. Covernors Energy Of fice Associate Chief Scientist Division of Marine Resources, CSO University of Rhode Island Kingsten. RI 02831 July 1979

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Review of Chapter 8 and 9 (9.1.1.-9.1.2)

Draft Environmental Statement NEP 1 & 2 (NUREG-0529)

I. General The NRC review team is to be commended for the vastly improved quality of the writing and analytical techniques employed in Chapter 8 of NUREG-0529 compared to previous impact statements read by the reviewer. The reader receives the distinct impression that no longer is the review process merely a rubber stamp procedure, rather that the various assumptions put forth by the developer are subjected to ra.her rigorous and objective scrutiny by the NRC staff. Yet, in spite of this improvement in the quality of the review process, it remains true that the entire process is organized as a nuclear permitting procedure. Unfortunately the review process is not organized as an optimizing procedure to detarmine the best socio-economic-environmental mix of fuels, plant sizes, and plant locations to meet various demand scenarios. Rather the process is constructed to review, and if necessary fine-tune, nuclear proposals only. As such the use of available information on non-nuclear power sources even between chapters S and 9 of the DEIS, leaves much to be desired. No mention is made of the present day ef forts of the New England gove rnors through the N.E. Regional Com-mission to bring in Canadian hydro power. In fact it is stated (p. 9-1 bottom) that "a mutually advantageous energy or capability diversity between the applicant and the Quebec Hydro-Electric Commission is not likely."

Additionally no mention is made of the ef forts or results of the New England Energy Congress (NEEC). It is of interest to note that the plan issued by NEEC was, in fact, the result of an optimizing procedure. referr2d to previously, which considered the best socio-economic-environmental mix o f f uels , plant sizes and plant locations to meet various demand scenarios. The optimizatica tz q n.- nn t,--.~. . /

2 of the plan was obtained by a consensus procedure encompassing the significant constituencies of the region (utility industry, environmental small business, low income, R & D, gove rn=ent consumer education, labor, and finance).

In summarizing these general observations it can be said tha: the NRC review of the Chapter 8, Need for the Plant, and Chapter 9, Alterna-tives, is a marked improvement over previous impact statements , but that it still suffers from a lack of integration of information from within the report itself and f rom plans and ef forts within the region since mid-1978. Thus there are presently serious omissions in these chapters, which are addressed in more detail in the following section of this critique.

II. Specific This section is divided into two parts, one concerned with the integration of information contained within Chapters 8 and 9, and the other concerned with the integration of information available in the region since early 1979 but not mentioned in the DEIS.

A. Inteeration of Information From Within the DEIS:

In Chapter 8 a schedule used by New England Electric System is reproduced (Table 8.18, p. 8-22). The only hydro-electric facilities mentioned are a series of Pumped Hydro totalling 1500 MN. These do not appear to come on-line until 2002 A.D. (300 MW in 2002: 600 'M in 2005; and. 600 :id in 2007) . There is no mentien of bringing these on-line sooner, and the effect that would have on the need for NEP 1 5 2.

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3 In Chapter 9 a series of alternatives are discussed (see p. 9-1 to 9-17). Each is discussed separ .tely, its potential compared to projected need, and then each is rejected as being inadequate bv itself to fulfill the projected need. There is no attempt to arrive at a mix of alternatives in order to assess their potential as a group for supplying power to the region. The only alternative source discussed in Chapter 8 is residential active solar (p. 3-8) and that is based on a 1976 Mitre Corp. study comparing solar with electrical resistence and heat pump systems for space heating. On the other hand, Chapter 9 residential active solar is given rudimentary treatment (p. 9-12) and space heating is aggregated with domestic hot water in en unclear manner. Electrical heating of domestic hot water is nowhere segregated and analyzed. Passive solar is not mentioned.

The following table has been constructed f rom the quantified information provided in Chapters 8 and 9 and indicates one estimate of alte rnate sources, based on the integration of data used by NRC staf f in the two chapters.

Alte rnate Source (DEIS reference onge) Capaci ty-Vk!

Pumped Hydro 8-22 1500 MW Hydro-Quebec 9-1 1200 Upgrade Older Plants 9-2 560-Upgrade Existing Hydro 9-5 2300 Municipal Solid Waste 9-9 1000 Total 65c0 MUe Tae impact of rescheduling proposed additions to capacity and of includin.; capacity from non-nuclear fuel sources must be considered b:; JRC staf: in their review of the application far ';EP 1 & 2.

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4 B. Integration of Information f rom the New England Region:

1. A detailed strategy for cutting New England's dependence on foreign oil was announced June 11,1979 by the 25 members of the New England Congressional Caucus. The plan was the product of over a year's work by the 120 me:bers of the New England Energy Congress (NEEC) which represented the twelve significant constituencies of the region. The 500 page "New England Blueprint for Energy Action and a package of 25 bills being introduced in the U.S. House of Ecpresentatives were the result of a "first in the nation" effort to develop a regional energy plan.

Some of the findings from this concerted effort were :

- f rom 1965-75 the demand for energy in New England grew at an annual rate of 1.8% per year

- with the conservation programs now in place the growth rate was predicted to be 1.5% between 1978 and 1985.

- if a major commitment to conserve energy is made the rate can be reduced even further.

- 25% of New England's energy needs can be met in the year 2000 by the region's own renewable sources: wood, solid waste, hydro, solar. e tc.

- natural gas can be increased f rom the current 8% to 13% of energy needs by the year 2000.

- coal, in contrast to other regions, vill likely play a relatively minor role, and provide 3-b% of the total This could chan;;e if Jarragansett Basin reserves are proven and can be extracted economicall:,

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- oil which will still be the largest source of supply in 2000 can be reduced f rom the current S0% to under 50% of total energy supply.

- nuclear will provide about 10%. This will require an additional 3450 MWe of capacity by 2000.

The following table has been excerpted from that report (p. 41 Table 8) to yield an estimate of the contribution that a mix of regional renewable sources can make to the generation of electricity-Regional Renewable Resource - 109 kua/ year -

1973 1985 2000 Wood 0.8 1.7 9.5 Municipal Solid Waste 0.2 0.3 4.6 Tidal 0 0.04 1.8 Ilydro 5.7 6.9 11.1 Wind 0 0.4 4.3 Photovoltairs 0 0 12.0 Peat 0 0.2 4.8 6.7 10.0 48.6 Equivalent Capacity 1275MW 1900 :!N 9200 :Ri (0.6 capacity factor)

Of note is that the 1200 ICJ froa Hydro Queboc is not included in the New England regional resource estimate.

2. Since the writing of the NRC staf f review of :'EPl & 2 additional socio-economic information is available regarding the future supply of electricity to the 1.aw England region.

In June 1979 the governors of Rhode Island. :,ew Hampshire and Ve rmont made direct contact with Quebec premier Rene L2vesque conceming the purchase of Canadian hydro. This commit tee acte d th rough e ;c * '

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the Northeast International Committee of Energy an arm of the New England Regional Commission. Subsequent to the committee's contact with Premier Levesque, Governor Garrahy of Rhode Island met with him in Quebec, and is expected to meet with him again in Providence. Public utility commission chairmen of the three states have discussed in tentative te rms the formation of a New England public power authority to enter into negotiations for Canact an electricity. With the political pressure growing,MEP00L has authorized six top executives to discuss these possibilities with the premier. It has been stated (15 July Boston Globe) that utility company planners believe a transmission line capab'.e of carrying a minimum of 750 lN is needed to make any hook-up economically feasible. Construction of such a line is estimated to cost $200 million and require two years. LaGrande-2, the first of three large dams nearing completion in the vicinity of James Bay, will be put into service in October, and as early as the cummer of 1980 up to 1000 SN will be available for export f rom Canada. By the mid-1930's when the entire p roj e ct is c,apleted the surplus for sale each summer could equal 6000 MW.

3. The feasibility of large capital intensive projects such as NEP 1 & 2, in times of uncertainty, such as those of today , is under rigorous scrutiny. From a planning standpoint if the future is unclear it is often best to take small steps. If the rate of growth of demand for electricity has changed f rom 5-7% per year to 1-3% it seems wise to add capacity in smaller increments in order to maintain flexi-bility and subject the investment to less riak. It is also true that snaller additions to generating capacity, when using non-nuclear fuels n < - c .e ,

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in particular, can be located closer to load centers, thereby reducing transmission line losses as well as providing opportunities for cogeneration. The financial community, or the source of funds for NEP 1 & 2, abhors uncertainty. From their viewpoint today's uncontrollable inflation coupled with unknowns in the wake of Three Mile Island make a project such as NEP 1 & 2 unattractive. On 21 June 1979 in Providence, a spokesman for Kidder, Peabody & Co. , a major Wall Street firm, said at an investment seminar "We think the nuclear power industry is dead and it may be dead forever". The spokesman went on to say, "there isn' t a board of directors of any public utilit, company in the country that is going to undertake a nuclear plant".

The impact of non-utility energy planning and of socio-econcmic decisions pertinent to the region must be considered by NRC staf f in their review of the application for NEP 1 & 2.

C. Conclusion It is apparent that the rather substantial socio -political forces at wo rk in the region have been largely ignored, or at least overlooked by the NRC staf f in their review of the NEP 1 12 proposal. Some of these have been discussed in this critique. According to the Council on Environmental Quality (CEQ) guidelines on content of environmental statements, especially Section 1500.3 (a) (3), (4) and (5), these factors must be adequately addressed.

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y c f(fi~,o upe.f REVIEW CF CHAPTER 8 MD SECTICNS 10.4 AND 10.5 OF THE NEP 1 & 2 DES Glen Ran.say Associate Professor Arthur Mead Assistant Professor Department of Economics University of Rhece Island

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The central elements in the impact study's assessment of both the need for and the benefits associated with the construction and operation of New England Power Units 1 and 2 are projections of electricity generating capacity and consumption. The analysis of supply is straightforward and needs no comment. Projec-icns of supply simply involve an inventory of the existing plant capacities and planned additions.

A review of the demand forecasts, however, reveals some potential problems. NERA, ORNL, and staff have all used econometric forecasting to determine the need fer electric power.

Econometric forecasting is often extremely sensitive to underlying assumptiens. The price-sensitivity analysis and the section on forecast comparisons are both cuite interesting and point out the dependency on assumptiens. The report treats assumptions individcally rather than combining them, it would be considerably more informative if scenarios were developed that changed a variety of assumptiens simultaneously. For example, a " worst case" might be a combination of successful conservation, high price, and slow regional growth. It would also be interesting to see what set of assumptions (if any) will make the ORN L model produce the N ERA results.

The projections of energy consumption formulated by the staff and by N ERA that appear in Table 3-11 indicate that there is considerable disagreement on the growth in demand.

The " Comparison of Forecasts" Section attempts to identify the fac crs responsible for this disagreement, but the reader is left with the distinc impression that all forecasts are meaningless. The validity of the forecasts could be better seen if a variety of scenaries were presented with each model and the results plotted out in the same graph.

The benefit-cest summary presented in Sections 10.4 and 10.5 generally suffers form a Icck of careful consideration of alternatives. Including both employment and taxes as benefits is simply not proper unless one is aware of the alternatives. The section is simply a summary of the rest of the volume. Although it is organized as a cost-benefit analysis, it is not, from an econcmist's perspective, a cost-benefit analysis.

Specific Comments

1. It is impossible to compare the N ERA, ORN L, and staff models. These medels shculd be presented in an appendix.

2. The wide variation of parameter estimates reported in Section 3 are dificult to interpret without any information on statistical significance.

3.

Section 3.2.3 discusses the substitution of new technologies. While it dispenses with solar as uneconomic, it also indicates that the heat pump is an attractive alternative. How does the forecast change if the growth of electricity demand for heating is based on the heat pump rather than resistance heating? This seems to be ignored in the forecast.

4 Sec:icn 3.2.5 indicates a dramatic reduction in demand :hrough manda: cry conserva:icn, ye :his pessibill:y is :ctally igncred in the forecast.

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5. Much of the increase in residential demand is based on electric heat users. Section 8.2.1.1 is confusing. The forecasts of rew electric heat customers seems widely divergent. What is the staff estimate, and how was it derived?

6. Both population and residential customers are included as determinants of commercial demand. While the role of population is clear, the indeoendent role of residential customers is not. I would certainly expect disastrous multicellinearity in any estimation attempt.

7. Estimation of the parameters of the staff model used 1955-1974 data. It is difficult to believe there has not been a significant structural shift in energy consumption since 1973. How does the model track from 1975-1979?

3. How were the values of the economic and demographic variables " inputted" to the model obtained? How sensitive are the results to forecast errors of these exogenous variables?

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