ML19296D431

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Notifies That Util Has No Comments on Usda Ltrs to NRC Re Alternative Plant Sites.Agrees W/Advisory Council on Historic Preservation & or Dept of Land Conservation & Development Comments to Nrc.Response to Doi 800118 Ltr Encl
ML19296D431
Person / Time
Site: 05000514, 05000515
Issue date: 02/25/1980
From: Lindblad W
PORTLAND GENERAL ELECTRIC CO.
To: Ballard R
Office of Nuclear Reactor Regulation
References
NUDOCS 8003040577
Download: ML19296D431 (4)


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-a Fe brua ry 25, 1980 Pebble Springs Nuclear Plant Dockets 50-514 50-515 Office of Nuclear Reactor Regulation ATTN: Mr. Ron L. Ballard, Chief Environmental Projects Branch #1 Division of Site Safety and Environmental Analysis U. S. Nuclear Regulatory Commission Washington, D. C. 20555

Dear Sir:

Portland General Electric Company has reviewed Enclosure 2 of your letter dated January 30, 1980 which contained commente received from Federal and State agencies related to your review of alternative sites to the Pebble Springs Nuclear Plant. Please be advised that we have no comments on the two letters transmitted to you f rom the U. S. Department of Agri-culture and we agree with the comments you received in letters from the Advisory Council on Historic Preservation and the State of Oregon Depart-ment of Land Conservation and Development. Our responses to comments contained in the U. S. Department of Interior's letter dated January 18, 1980 are attached.

Sincerely, A, ~ My w_ s "Y i n d "Vice President Engineering-Construction c: Mr. Lynn Frank Kathleen Shea, Esq.

Richard M. Sandvik, Esq. Mr. J. Carl Friedman Mr. Donald W. Godard Elizabeth S. Bowers, Esq.

Mr. Lloyd K. Marbet Dr. William E. Martin Ms. Bernice Ireland Dr. Walter H. Jordan Frank Josselson, Esq. Richard S. Salzman, Esq.

Mr. Thomas P. Davis Honorable Leo Barnett Mr. Patrick A. Parenteau Arlington Public School District William L. Hallmark, Esq.

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PORTLAND GENERAL ELECTRIC COMPANY Response to U. S. Department of Interior's Letter Comments of January 18, 1980 on the Pebble Springs Draft Supplement to the Final Environmental Statement Dockets 50-514 and 50-515 February 25, 1980 Portland General Electric Company's (PGE) response to the U. S. Department of Interior's comments, which are enumerated verbatim, are given below:

1. When we previously commented on this project, we were con-cerned with the impact that could occur on the Columbia River if the water withdrawal required for Pebble Springs Nuclear Plant is initiated. Although not a large amount in comparison with the river flow, it is potentially a portion of cumulative withdrawals that could adversely impact the anadromous fishery. Since that time, a drought has brought flows low enough so that serious impairment of temperature levels for fishery survival has already occurred. There-fore, we continue to be concerned about this aspect of the proposal.

Response

Initial filling of the cooling reservoir for the Pebble Springs Nuclear Plant can be timed to avoid low flow periods, thus minimizing impacts f rom this activity. tiake up water for the reservoir is scheduled to be withdrawn from the Columbia River during wcrmer months, but this withdrawal is from the impoundment behind John Day Dam with flow and water level already being controlled by John Day Dam and others upstream. The intake structure on the Columbia River has been designed to minimize the impact of water withdrawal on migrating salmonids. Approach velocities to the intake screens are low, thus reducing the probability of impinging fish. Paths are provided to allow fish to escape from the intake structure in front of the screens. Studies have also shown this to be an area where salmonid densities are not high (see our response to Item 2 below).

2. Another statement which appears to be misleading occurs on Page B-4 in Section 1.3. Aquatic Resources. On the first line, second paragraph '

is stated: "...none of the species present are rare, endangered, or protected." This simple statement is misleading in that some of the Columbia River anadromous stocks have declined drastically, an' there is concern that re-turning adults have reached such a low level in certain instances that the ability to regener-ate may be impaired. This statement should be verified.

Response

The statement referred to on Page B-4 is a simple assertion of fact, but we agree that further verification of this statement should be provided in light of current trends.

However, Section 1.3 should also refer to the results of two reports prepared for PGE by Beak Consultants, Inc.:

Preconstruction Ecological Studies for the Pebble Springs Site - Final Report, dated May 1978, and Preconstruction Ecological Studies for the Pebble Springs Site - Supplement to May 1978 Final Report, dated February 1979. These reports were transmitted by PGE to the NRC under cover letters dated July 7,1978 and April 12, 1979, respe-tively, with copies provided to all parties to the Pebble Spt;.ags ASLB proceedings.

The May 1978 Final Report describes ecological studies con-ducted from April 1977 to March 1978 and concluded that the Pebble Springs intake site is not in an area of high fish densities as compared to upstream and downstream areas. The February 1979 supplement to the final report describes the continuation of the 1977-78 monitoring program on salmonid smolts, long-billed curlews and raptors. The additional studies of salmonid smolts support the conclusions reached in the 1978 Final Report and indicate that the proposed Petble Springs intake would not pose a serious threat to downstream migratory salmonids.

Therefore, based upon the current situation, Columbia River anadromous fish are not classified as rare,. endangered or protected. However, if they were, the design and location of the intake structure is such that there would be negligible impact on these fish.

3. It is noted on Page 2-11, Paragraph 3, that the Staff's evaluation of an applicant's site selection process depends on certain key issues, yet these issues do not seem to be idcntified. We feel that site-specific consequences of reactor accidents should be among the key issues, both in the applicant's site selection process and Jtaff's evalua-tion of that process.

Response

PGE believes the "kay issues" have been identified within the scope of the NRC's review of our site selection process.

Because of perceived deficiencies in the applicant's site selection process stemming from a failure to conduct a more explicit environmental comparison, the scope of the NRC's review was primarily delimited to an environmental evalua-tion and comparison of alternative sites to Pebble Springs.

In the context of site selection, site-specific consequences of reactor accidents are related to population density and distribution surrounding a reactor site. PGE considered population as a criterion in identifying potential sites as discussed in Section 2.3.1 of the Draft Supplement to the Final Environmental Statement. The fact that the Pebble Springs site is in an area of extremely low population density confirms that this issue was adequately considered in the applicant's site selection process and, therefore, did not require further evaluation.

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