ML19290A312

Submits Comments Re Biological Impacts of Proposed Plant on Fish Populations,In Response to AEC 670606 & 0726 Requests

ML19290A312
Person / Time
Site:	Three Mile Island
Issue date:	09/26/1967
From:	Pautzke C INTERIOR, DEPT. OF, FISH & WILDLIFE SERVICE
To:	Price H US ATOMIC ENERGY COMMISSION (AEC)
References
NUDOCS 7911060553
Download: ML19290A312 (5)

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3D gn 94 UNITED STATES m a w a a u ra ro:

1. 56M DEPARTMENT OF THE INTERIOR

{.Q.$9;{ FISH AND WILDLIFE SERVICE p,!fW, i d.

y.1 WASHINGTON. D. C. 20240 s

Mr. Hamid L. Price ba 0 0 7987 Director of Regulations i g U. S. Atomic Energy Ccamission ,Mh il-Washington, D. C. 20$h5 I UUll UllI

Dear Mr. Price:

This is in response to Mr. Boyd's letters of June 6 and July 26 requesting our co=nents on the application by the Metropolitan Edison Company for a construction pemit and operating license for the proposed Three Mile Is-lanc Nuclear Power Station, Unit No.1, Susquehanna River, Dauphin County, Pennsylvania, Docket No. $0-289 The proposed plant would be located on Three Mile Island in the Susquehanna River about six miles south of Harrisburg, Pennsylvania, and approximately three miles upstream from the York Haven dam.

Principal features of the station would include _a pressurized water reactor designed for an ulthate output of 2,535 themal megawatts, a radioactive waste disposal system, and other on-site facilities required for a complete and operable nuclear power plant. Cooling water requirements would be pro-viced for in three separate cooling systems: (1) a nuclear service system for all nuclear and fuel handling requirements, (2) a secondarf system for all non-nuclear-related requirements, and (3) a condenser circulating water system for the main surface condenser and feedwater pump turbine condensers.

The condensers would be cooled with water circulated through two hyperbolic natural draft cooling towers. Makeup for tower evaporation, Lind loss, and blowdown will be obtained from the secondary and nuclear services cooling systems. Water for the secondarf and nuclear service coolers would be ob-tained frcm the river and after use be mixed with the condenser cooling water prior to entering the towers. Slowdown from the cooling towers would be discharged to the Susquehanna River ana used to dilute the nuclear wastes. The intake structure would be provided with trash rakes, traveling screens, and a recirculating line from the condenser discharge to prevent i i":- 1555 211 The average discharge of the Susquehanna F.iver at the Earrisburg gauge during the perioa 1890-1966 was 3h,CCO c.f.c. During this perioc the meas-ured ficws varied from a minhum of 1,600 c.f.s. during a freeze-up of the

• river to a maximum of 7h0,CCO c.f.s. during flood conditions.

A valuable sport fisher / exists within the project arca which includes blue-gill, crappies, walleye, yellow perch, bullheads, muskellunge, large=outh bass, smallmouth bass, and white perch. This fisher / receives hear / fishing 7911060 @ 3

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{W pressure and is one of the better fisheries occurring in the Susqhehanna River. The Pennsylvania Fish Commission owns land along Conewago Creek in the vicinity of York Haven tailwater outlet which provides access and boat launching facilities.

Biological studies were conducted by the Fish and Wildu fe Service in co-operation with the States of Pennsylvania, New York, and Maryland, from 1963 to 1966 to determine the suitability of the Susquehanna River and its principal tributaries for the restoration of runs of the anadromous American shad. It appears from the studies that much of the river is suitable and that there is a good possibility that American shad runs could be restored to the river.

The application indicates that the release of radioactive wastes would not emceed maximum permissible limits prescribed in Title 10, Part 20, of the Code of Federal Regulations. Although these limits refer to mamimum levels of radioactivity that can occur in drinking water for man without resulting in any known harmful effects, operation within the limits may not always guarantee that fish and wildlife will be protected from adverse effects. If the concentration in the receiving water were the only consideration, ma ci-mum permissible limits would be adequate criteria for determining the safe rate of discharge. However, radioisotopes of many elements are concentrated and stored by organisms that require these elements for their no =al meta-bolic activities. Some organisms concentrate and store radioisotopes of elements not normally required but which are chemically similar to elements essential for metabolism. In both cases, the radionuclides are transferred from one organism to another through various levels of the food chain just as are the nonradioactive elements. These transfers may result in further concentration of radionuclides and a wide dispersion frcm the project area particularly by migratory fish, mammals, and birds.

In view of the above, we believe that pre- and post-operational radio-logical surveys should be conducted by the applicant and include studies of the effects of radionuclides on selected organisms which require the vaste elements or similar elements for metabolic activities. These sur-voys should be planned in cooperation with the Fish and Wildlife Service, the Federal Water Pollution Control Administration, the Ibnnsylvania Fish Com.dssion, and the Pennsylvania Sanitary Water Board.

If it is detemined from the pre-operational surveys that the release of radioactive effluent at levels permitted under Title 10, Part 20, Ccde of Federal Regulations, would result in hamful concentration of radioactivity in fish and wildlife, plans should be made to reduce the discharge of radio-activity to acceptable levels. Post-operational surveys should be conducted to evaluate the predictions based on the pre-operational surveys and to en-sure that no unforeseen damage occurs.

3 view of the importance of the present sport and commercial fisheries of the Susquehanna River and the future potential of runs of anadrcmous fish, 1555 212 2

, c it is imperative that every possible effort be made to protect these valu-able resources from radioactive contamination. Therefore, it is reco= ended that the Metropolitan Edison Company be required to:

1. Cooperate with the Fish and Wildlife Service, the Federal Water Pollution Control Acministration, the Pennsylvania Fish Cc=is-sion, the Pennsylvania Sanitary ' dater Board, and other inter-ested State agencies in developing plans for radiological sur-veys.

2. Conduct or arrange for the conduct of pre-operational radio-logical surveys of selected organisms indigenous to the area that concentrate and store radioactive isotopes, and of the environment including water and sediment samples. These sur-voys should be conducted by scientists knowledgeable in the fish and wildlife field.

3 Prepare a report of the pre-operational radiological surveys and provide five copies to the Secretary of the Interior for evaluation prior to project operation.

h. Make modifications in project structures and operations to reduce the discharge of radioactive wastes to acceptable level if it is detemined in the pre-operational or the post-operational surveys that the release of radioactive effluent pomitted under Title 10, Part 20, Code of Federal Regulations, would result in harmful concentrations of radioactivity in fish and wildlife. .

5 Conduct radiological surveys, sw ar to those specified in recc=endation 2 above, analyze the data, and prepare and submit reports every three months during the first year of reactor operation and every six months thereafter or until it has been conclusively demonstrated that no significant adverse conditions exist. Submit five copies of these re-ports to the Secretary of the Interior for distribution to the appropriate State and Federal agencies for evalu-ation.

We understand it is the Co=ission's opinion that its regulator /- authority over nuclear power plants involves only those hasards associated with radioactive materials. Ecwever, ne reco=end and urge that before the permit is issued, thernal pollution and any other detrimental effects to fish and wildlife which may result from plant construction and operation be called to the applicant's attention. We recc=cnd further that the applicant be requested to discuss this matter with appropriate State conservation officials and the Fish and Wildlife Service and to develop

=easures to minimize these hasards.

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(W l Althou(;h cooling towers have bcon planned for this plant, it is not stated in the application what the temporature of the effluent would be.

Unless the temperature of the effluent is near the temperature of the receiving waters, there may be damage to aquatic life. Increased water temperatures may not only be detrimental to fish life directly but also may affect these resources indirectly through changes affecting the en-vironment. Higher temperatures diminish the solubility of dissolved oxygen and thus decrease the availability of this essential gas. The elevated temperatures increase the metabolism, respiration and oxygen demand of fish and other squatic life; hence the demand for oxygen is increased under conditiom where the supply is lowered. Any thermal barriers that occur could idversely affect migration of anadromous

1. ishes in the river. The thermal effects of this project should be ap-praised in combination with other proposed and existing nuclear and fossil fueled plants discharging these heated effluents into the same receiving waters.

In view of the above, we believe that, unless it is determined that the temperatures of the effluent would be near that of the receiving waters, ecological surveys should be conducted prior to and following plant operation to measure the effect of plant operation on aquatic life in the river. These surveys should be planned in cooperation with the ap-propriate Federal and State agencies. If it is determined from the pre-operational investigations that the heated water or chemical effluent from plant operation to be discharged into the river would result in changes in the environment that would be significantly detrimental to fish and wildlife, plans should be made to reduce the temperature of the effluent to acceptable levels. Post-operational surveys should be con-ducted to evaluate the predictions based'en the pre-operational surveys and to ensure that' no unforeseen damage occurs.

Another potential hazard to fishery resources in the river is the cooling water intake. Unless the intake is adequately screened, fish, fish eggs and larvae, plankton and other food organisms, may be drawn in and de-stroyed. The loss of a significant nunber of fish or food organisms to fulfill their needs at this point may prevent the successful re-restablishment of anadromous fish to the river. Suitable fish protec-tive fc_cilities should be installed to prevent loss of fish through the intrue structure.

3 via of the Administration's policy to maintain, protect, and improve the quality of our environment and most particularly the water and air

.r.edia, we request that the Commission urge the Metropolitan Ediscn Com-pany to:

1. Cooperate with the Fish and Uildlifo Service, the Federal Water Pollution Control Administration, the Fennsylvania Fish Cc= mission, the Pennsylvania Sanitary Water Ecard, and other interested State agencies in developing plans

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(87) for ecological surveys, initiate these surveys at least two years before reactor operation, and continue them on a regular basis or until it has been conclusively demon-strated that no significant adverse conditions exist.

2. Meet with the above mentioned Fedsral and State agencies at frequent intervals to discuss _ new plans and to evaluate results of existing surveys.

3 Construct, operate, and maintain auch fish protective facilities over the intake structures as needed to prevent significant damage to fishery resources.

h. Make such modifications in project structure and operation including additional facilities for cooling discharge waters as may be determined necessary as a result of the pre-operational or post-operational surveys to protect the fish and wildlife resources of the area.

The opportunity for presenting our views on this proposed project is ap-preciated.

/~*Sincerelyyours0

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Ul ecce Y hlaukzke/ '

Commissioner

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