ML20042A423
| ML20042A423 | |
| Person / Time | |
|---|---|
| Site: | 05000514, 05000515 |
| Issue date: | 03/18/1982 |
| From: | Scaletti D, Stull E ARGONNE NATIONAL LABORATORY, NRC, Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20042A409 | List: |
| References | |
| RTR-NUREG-75-025, RTR-NUREG-75-25 NUDOCS 8203230407 | |
| Download: ML20042A423 (34) | |
Text
3 affect the interconnection facilities required for the Pebble Springs, Boardman, Lebanon, Daily Lake, Riderwood or Hanford alternative sites. The attached Figure 3A chows the interconnection facilites required if the Pebble Springs units are located at the Skagit-Hanford site.
3.
Description of the Skagit-Hanford site:
This site is located in sections 28 and 33, TWP.12N. Rng. 27E., WM, approximately 5 miles west of BPA's Ashe Substation. The site is located on desert lands, in the south-central part of the !!anford Reservation.
The integrating transmission would be a 7-mile 500-kV line to Ashe Substation.
Land
Description:
500-kV line to Ashe Substation Corridor length 7.0 miles Desert land 7.0 miles Access roads required 0.0 miles the corridor for this line would pass over level sandy desert land with ver, light vegetation cover. This line is entirely inside the Hanford Recorvation and there are no residences or farmlands in the area. The nearest residences are approximately 5 miles east of Ashe Substation.
Transmission line construction would encounter few problems. Mitigating measures such as seeding with appropriate grasses or placing rock on disturbed soil at tower sites and on access roads would likely be necessary to reduce wind erosion. As this line would parallel the existing Hanford-Ashe line for 4 miles and the proposed 3 mile loop to the Skagit-Hanford site to accommodate the Skagit units, no new access roads are required.
l l
Cost estimate (1979 dollars):
Interconnection Facilities l
Skagit-Hanford Substation
(
5-500 kV circuit breakers
$4,500,000 Ashe Substation 2-500 kV circuit breakers 1,800,000 Skagit-Hanford to Ashe 500 kV line 1-500 kV line, 7 miles 1,750,000 Offsite power Locally available for Skagit units l
Total
$8,0f0,000 8203230407 820318 PDR ADOCK 050005g
4.
Cost estimates:
Cost estimates appear on pages C-3, C-4, C-7, C-10, C-13, C-15, and C-16.
All costs are in 1979 dollars. These costo can be updated to 1981 dollars by use of the GNP Implicit Price Deflator. The price deflators prepared by OMB, April 23, 1981 are 162.77 for 1979 and 193.81 for 1981. The resulting adjustment to c:: press the Appendix C cost estimates in 1981 dollars is a cultiplier of 1.19 or an increase of 19 percent. The costs shown for the Shagit-Hanford site in this Addendum are in 1979 dollars to be consistent with other costs shown in Appendix C.
5.
Table 1, page C-16 Add the following data for the Skagit-Hanford site, (1979 dollars):
Main Grid Cost Interconnection Cost Total Site Zone Annual Cost Investment Annual Cost Annual Cost Skagit-Hanford 4
$8,750,000
$8,050,000 $8,050,000,
$9,555,000 6.
Tabic 2, page C-17:
Add the following data for the Skagit-Hanford site:
Timber Farm Savanna Range Access Site Lands Lands Landscape Lands Roads Total Skagit-7 7
Hanford 7.
Tabic 3, page C-19 Add the following for the Skagit-Hanford site:
Total Miles Total Site of Impact Acres Skagit-Hanford 7
89 8.
Miscellaneous modifications:
- he description of the USCC shown on page C-1 should be changed to a.
reflect the revised structure.
"That council covers all or parts of the 14 western states, British Columbia, Canada, and Alberta, Canada".
b.
Page C-3 second paragra,h:
Add after first sentence, "(Larger conductors have been used for energy conservation)."
c.
Section 6.1, page C-4, first sentence.
The 500 kV line from Ashe Substatio.: to Marion Substation has been completed and is in service.
3
(
FIGURE 3A 500 KV TRANSMISS:Otl SYSTEM CONNECTIONS FOR UNITS 3 & 4 AT THE SKAGIT.HANFORD NUCLEAR SITE AS AN ALTERNATE TO PEBCLE SPRINGS UNITS 1 & 2 O O =1:a' RE11RLD G O D' CJLC.D col *LE8 <
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+ $00 KV EftEAxtR ACDiftON
+ 50n?30 MV TRAVJORP/ER ACHE C
GENERATOR e*s INTERCONFK710N FACluTIES NOTE:
Insert between pages C8 G C9 Of Supplement No. I to the Pebble Springs FES issued April 1980 l
~.
i e e 1
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' NUCLEAR REGULATORY COMMISSION
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4 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
)
)
PORTLAND GENERAL
)
Docket Nos. STN 50-514 ELECTRIC COMPANY
)
50-515
)
(Pebble Springs Nuclear
)
r Plant, Units 1 and 2)
)
TESTIMONY OF ELISABETH A. STULL AND DIN 0 C. SCALETTI*
RELATED TO INTERVENOR'S CONTENTIONS REGARDING THE STAFF'S REVISED ALTERNATIVE SITE ANALYSIS, FINAL SUPPLEMENT NO.1 TO THE PEB8LE SPRINGS NUCLEAR PLANT, UNITS 1 AND 2, FINAL ENVIRONMENTAL STATEMENT, NUREG-75/025.
- As to pages 5 and 11
[
.I23iGEESORIGINAD N (So 1rled By _
[ _.
03/12/82 1
r 88LE SPRINGS TESTIMONY RPT
)
Q.
Please state your respective names and business addresses.
A.
My name is Elisabeth Ann Stull. My address is Environmental Impact Studies Division, Argonne National Laboratory, 9700 South Cass Avenue, Argonne, Illinois.
Q.
Ms. Stull, please state your professional q'ualifications.
A.
I am an aquatic ecologist and project leader in the Environmental Impact Studies Division.
My responsibilities include evaluating environmental impacts of nuclear and fossil power generation and directing the prepara-tion of environmental impact statements.
I received a Bachelors of Arts degree in biology from Lawrence University, a Masters of Science degree in zoology with a specialization in ecology from the University of Georgia, and a Doctor of Ph'ilosophy degree with a specialization in limnology from the University of California at Davis.
My technical training included studies in freshwater ecology, terrestrial ecology, marine ecology, and fish biology.
From 1971 to 1978, I held positions of Assistant Professor in the Depart-ment of Biological Sciences and the Department of Ecology and Evolutionary Biology at the University of Arizona.
During that period, I taught graduate courses in general ecology, limnology, and aquatic ecology.
I supervised the theses of graduate students in the fields of aquatic productivity, algal floristics, and regional patterns of water quality.
03/12/82 2
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[
/
I am a member of the following professional societies:
American Associa-tion for the Advancement of Science, American Society of Limnology and Oceanography, and Phycological Society of America ~.
A.
My name is Dino C. Scaletti.
My address is the Division of Licensing, U. S. Nuclear Regulatory Commission, Washington, D. C.
20555.
Q.
Mr. Scaletti, please state your professional qualifications.
A.
I am a Licensing Project Manager with the Division of Licensing, U. S.
Nuclear Regulatory Commissions.
My responsibilities include the coordinations of both the safety and environmental reviews evaluating nuclear power plant construction and operation. At present I am the Licensing Project Manager assigned to the Pebble Springs Nuclear Plant Units 1 and 2.
I am also the Licensing Project Manager assigned to the Black Fox Nuclear Plant units 1 and 2.
Since the start of my employment with the NRC, as an Environmental Project Manager, in March 1974, I have been responsible for the environmental reviews and publication of environmental statements for Wolf Creek Generating Station, Sterling Power Project, Yellow Creek Nuclear Plant and the San Onofre Nuclear Plants.
I was also responsible for the alternative
' sites review and the publication of the supplement to the Final Environmental Statement relating to that issue for the Pilgrim Unit 2 application.
Since my assignment as a Licensing Project Manager in April 1980 I have been responsible for the issuance of supplemental Safety Evaluation Reports, evaluating compliance with the requirements imposed on 03/12/82 3
PEBBLE SPRINGS TESTIMONY RPT 5
construction permit applicants for Pilgrim station and Black Fox Station.
From November 1979 to November 1980, in addition to my duties as a project manager, I also served as'a team leader in the Human Factors Engineering Branch doing human factors control room design reviews.
I received a Bachelors of Arts Degree in Zoology i.n 1965 and a Masters of
~
Science degree in Zoology in 1967 from the bniversity of New Hampshire.
I also received a Bachelors of Science degree in Electrical Engineering in 1971 from the University of New Hampshire.
Prior to my start of employment with the NRC in March 1974, I was employed by the Naval Nuclear Power Unit at Fort Belvoir, Va.
My duties involved Engineering and Environmental support for the PM-3A, the Navy's antartic based 2 MWe Nuclear Power Plant, and for the Navy's radioisotopic thermal electric generator program.
Q.
What is the purpose of this testimony?
A.
The purpose of this testimony is to (1) jiesent my responses to Inter-venor's Contentions regarding Supplement No. 1 to the Pebble Springs Final Environmental Statement; (2) provide miscellaneous corrections to Supplement 1; and (3) present my assessment, in light of the proposed change in location of the Skagit Nuclear Power Plant Project, as to the current validity of the Staff's earlier conclusion that none of the alternative sites are clearly environmentally preferable to the Pebble Springs site.
03/12/82 4
PEBBLE SPRINGS TESTIMONY RPT
P c
r Q.
What was the purpose of NUREG-75/025, " Supplement No. 1 to the Final P
Environmental Statement" for Pebble Springs?
A.
Site alternatives were considered in the Pebble Springs Final Environ-mental Statement which was issued in 1975.
However, between 1975 and 1978, the procedures for review of an Applicant's selection of sites were rapidly evolving, as was the recommended mekhodology for an Applicant's
~
alternative-site studies.
Therefore, in late 1978, the Staff, on its own initiative and after approval by this Licensing Board, decided to re-evaluate the Pebble Springs site-selection process in light of the revised procedures regarding alternative-site evaluation.
The purpose of the revised evaluation of the Applicant's site-se'iection process was to add to the Final Environmental Statement in the form of a Supplement a discussion of (3) how we determined whether the Applicant's siting studies resulted in selection of potential sites that are among the best the regions of interest have to offer, (2) whether any of the alternative sites are clearly environmentally preferable to Pebble Springs; and (3) if so, whether any environmentally preferable sites are obviously superior tn Pebble Springs.
Q.
Did you participate in the preparation of the revised alternative-site analysis found in Supplement No. l?
A.
Yes, in late 1978 I was assigned to the Pebble Springs project to evaluata aquatic resources for the alternative site review.
In addition, I was resoonsible, in part, for evaluating the Applicant's site-selection process, col.ecting reconnaissance-level information, preparing plans for 03/12/82 5
PEBBLE SPRINGS TESTIMONY RPT
~~
scope and outline of the document, and preparing the Staff's final conclusion (with concurrence of the other team members) on whether any of the alternative sites are clea.rly environmentally preferable to Pebble Springs.
Q.
What is your current role in the Pebble Springs project?
A.
I am currently the Argonne National Laboratory project leader in charge of environmental-impact analysis for the Pebble Springs application.
Q.
Have you read the " Stipulation Regarding Contentions and Schedriing" filed in this proceeding and the " Order Relative to Stipulation Regarding Contentions and Scheduling" issued by the Atomic Safety.and Licensing Board on June 19, 1981, admitting Intervenor's Contentions AS-1 through AS-5?
A.
Yes, I have read the documents indicated.
Q.
Contention AS-1 states, in part, that "The Staff has used an arbitrary and inconsistent comparison process for environmental impact within the four site comparison categories:
terrestrial, aquatic, geologic / hydrologic, and socioeconomic resources." Do you agree with this assertion?
A.
No, we developed the site-comparison processes used for the resource categories after careful analysis of the kind and quality of reconnais-sance-level information available for the sites.
The comparison processes were individually tailored to each resource category and section of the 02/02/82 6
PEBBLE SPRINGS TESTIMONY RPT
i c
alternative-site review in order to reflect environmental differences between the sites in a manner consistent with our perception of standard NRC Staff practice in the environmental review of impacts of nuclear power plant construction and operation.
While the comparison ' processes for the various resource categories were necesssarily different, they were not inco sistent with the kind of information available for review by the Staff, with the discussions of Staff methodology for alternative site reviews as stated in NUREG-0499, Supplement 1, " General Considerations and Issues of Significance on the Evaluation of Alternative Sites for Nuclear Generating Stations Under NEPA," or with the purpose of this alternative-site review.
The major difference in 'the two comparison, processes used to select alternative sites from potential sites (Sec. 2.4) is the location in the text where
'the rankings are given--in the " Criteria and Methodology" section for terrestrial resources and in the "Results and Discussion" section for aquatic resources.
Therefore the comparison processes are essentially similar and consistent.
To place the evaluation of "+",
"0",
and " " for aquatic resources in the criteria methodology settion would have been difficult since marine and freshwater sites criteria are evaluated by different standards.
I concluded that one set of criteria standards for both would have been unreasonable and unprofessional.
Q.
The third sentence of Contention AS-1 states:
"For aquatic resources the Staff arbitrarily chose to evaluate 'the potential sites being considered within each candidate area on a comparative basis rather than absolute 02/02/82 7
PEBBLE SPRINGS TESTIMONY RPT
e terms' and without consideration of site specific plant designs (FES-SUPP.,
2.4.2.2.2 Criteria and Methods)." Do you agree with this assertion?
A.
No, not to the extent that any choice was arbitrary, as I have already
~
testified.
A comparative evaluation process was used for aquatic re-sources, as was the case for much of the evaluation process for terres-trial, socioeconomic,andgeologic/hydrolodicresources.
The rating criteria were established after site analysis and description in order to distinguish between the environmental advantages and disadvantages of the sites.
No detailed, site-specific plant designs were used because none were available for the majority of potential sites.
To use detailed, site-specific designs for only some of the potential sites would violate t;w principle of equal treatment of potential sites.
Please note, however, that generalized plant designs (such as type of cooling, access, transmission facilities) were included wherever appropriate.
In addition, for an alternative site review, we use reconnaissance-level information.
As defined in NUREG-0499, Supplement 1 (" General Consider-ations and Issues of Significance On the Evaluation of Alternative Sites for Nuclear Generating Stations Under NEPA"), reconnaissance-level infor-mation is "information obtained from published reports, public records, public and private agencies, individuals knowledgeable about the area or site, and from a short field investigation of a site." Use of reconnais-sance-level information often results in an uneven amount of detail for each criterion in each resource category.
The unevenness of reconnaissance-level information is further compounded by the fact that 02/03/81 8
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i c
some potential sites are in areas that have not been subjected to any detailed studies.
For these reasons, I believe it is not realistic to expect that equal detail of information will be available for all sites and all criteria.
Q.
Contention AS-1 further states that the use of the criteria described in FES-SUPP.2.4.2affectedtheo,veralloutcoMeofthefinalsitealternative analysis.
Do you agree?
A.
No, the overall outcome of the final alternative-site analysis in Sec-tion 2.6 (whether any alternative site was clearly environmentally pre-ferable to Pebble Springs) could not have been affected by the potential site analysis in Section 2.4, because the criteria described in Section 2.4 do not describe those used in the Section 2.5 and Section 2.6 alternative-site analysis.
The alternative-site study consisted of two analyses, which were presented separately in Section 2.4 and in Sections 2.5 and 2.6 of Supplement 1.
Section 2.4 addressed the selection of the best of the potential sites for alternative-site status.
Once the alternative sites were selected, they were compared individually and separately to the proposed site using the criteria described in Section 2.5 to determine if any of the alternative sites are clearly
-environmentally preferable to the proposed site.
Since each alternative site considered in Section 2.5 was compared separately to the Pebble Springs site, the rankings among ootential sites as presented in Sec-tion 2.4 were irrelevant in the comparison of each of the alternative sites to the proposed site.
02/02/82 9
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Q.
Contention AS-2 questions the inclusion of the Boardman site as an after-native site on the basis of the presence of the U.S. Navy's Weapons System Training Facility and a clause in the State Certification agreement forbidding construction of a nuclear plant at Boardman until the Navy decides to terminate the use of that facility.
Please explain why you did not remove the Boardman site from the analysis?
A.
We used a two part, sequential test for obvious superiority.
The first stageofthetestwastodeterminewhetherthereisanenvironmentIally preferred site.
If such a site had existed, the second stage of the test would have been to consider economics, technology, and the institutional factors.
Elimination of Boardman at the first stage of the alternative site analysis because of institutional barriers would have contradicted the Staff's own stated methodology.
Q.
Contention AS-2 further states:
"Yet the Staff has proceede'd to use the Boardman site for comparison with other site alternatives which have unfairly weighted the outcome of their analysis in the comparative rating under aquatic resources on Table 2.4 (against the Hanford site) a'nd thus is carried over in the final analyses."
Is this statement correct?
A.
No, this statement is in error because Table 2.4 refers to the screening of potential sites for selection of alternative sites, not the comparison of alternative sites to the proposed site.
Sites designated as alterna-tive sites as a result of the analysis in Section 2.4 were compared separately and independently only with the proposed site, Pebble Springs, in Sections 2.5 and 2.6.
02/02/82 10 PEBBLE SPRINGS TESTIMONY RPT
e v
Q.
Mr. Scaletti: Contention AS-3 states:
"The Staff, both in its analysis of the impacts of effluent discharges in Table 2.4 of the FES-SUPP in which it considers no discharges from the Boardman Reservoir, and Table 2.13 of the FES-SUPP in which it considers no discharges from the Pebble Springs Reser-voir, fails to' consider dewatering of these reservoirs due to accidents, other than Class 9 accidents, or final decommissioning of the proposed facilities.
Thus under aquatic resources the Staff's analysis is unfairly weighted to the advantage of the Pebble Springs site." Why was the possi-bility of dewatering of the Boardman and Pe'bble Springs reservoirs not considered in any part of Supplement No. 1?
A.
The staff interprets the National Environmental Policy Act (NEPA) as requiring an assessment of the environmental impacts from nuclear power plant construction and normal operation.
In addition, the staff provides in its environmental statements an assessment of the radiological impacts which might result from a range of plant accidents.
However, the staff has not conceived of any plant-incited accident which would create the necessity for dewatering the Pebble Springs reservoir.
If such a dewatering eventually is a proposed as part of the applicant's plan for decommissioning the facility, the environmental impacts of that action would be addressed toward the conclusion of the plant operating life. We do not consider hypothetical, improbable accidents such as dam failures
-which would not affect safe operation or shutdown of the plant.
O.
Contention AS-3 further states: "Also, under neither aquatic nor terres-trial resources does the Staff consider the impact upon bird populations and terrestrial wildlife of effluent c.ischarges into the water contained 03/12/82 11 PEBBLE SPRINGS TESTIMONY RPT
in the reservoirs on the Boardman and Pebble Springs sites. Why was this topic not considered in Supplement No. 1?
A.
We did not identify any impact on birds and other wildlife from effluent discharges to cooling reservoirs at the Pebble Springs site or the Board-man site as a criterion that would distinguish between the environmental qualitiesofthealternativeandproposedbites.
None of the maximum chemical concentrations projected for the water in the Pebble Springs Reservoir, as liste' in Table 3.5 of the Pebble Springs.FES-CP (USNRC, d
1975), would exceed the U.S. EPA's recommended maximum concentrations of elements in livestock drinking water ~ (NAS/NEA,1974).
Presumably, these criteria would also protect wildlife. We do not expect any adverse effects to waterfowl or other wildlife due to consumption of water from the reservoir.
Q.
Contention AS-4 concludes that the final comparison of the Hanford site and the Pebble Springs site is at fault because the " adjustment of the environmental ranking for aquatic resources serves to prevent a fair treatment of the Hanford site as the obviously superior alternative to Pebble Springs within the pre-established parameters set forth by the Staff in the consideration of the four site comparison parameters." Was there an adjustment of the environmental ranking for aquatic resources?
A.
No, in the final comparison (Sec. 2.6) the environmental ranking of aquatic resources as " inferior" for Hanford in comparison to Pebble Springs was not adjusted.
What was adjusted was the raw sum of the environmental rankings:
two " superiors", one " equal", and one " inferior".
02/02/82 12 PEBBLE SPRINGS TESTIMONY RPT
5 s
c In order for an alternative site to be evaluated according to its economic and institutional characteristics in the second part of the test for obvious superiority, the site must be shown to be " clearly environmentally preferable." We had no pre-established parameters for determining environmental preferability at this level of analysis where " superiors",
" equals", and " inferiors" describe the relative environmental preferability of a site.
Therefore,wewehefacedwithofferingan opinion of whether the differences between the alternative site and proposed site are trivial, minor, and/or equivocal or whether they are significant, major, and/or unequivocal. We evaluated the " inferior" and
" superior" ratings for Hanford to determine whether the differences in site characteristics between Hanford and Pebble Springs were clear. We concluded that to simply add superiors and subtract inferiors at this stage of the analysis would grossly misrepresent the relative environmental characteristics and suitability of the two sites for nuclear power plant installa'tions.
The " inferior" rating for aquatic resources at the Hanford site was considered to be very important, while the " superior" ranking for terres-trial resources at the Hanford site was considered to be relatively trivial for the following reasons:
.a.
The terrestrial ecology at the two sites is very similar and belongs to a plant ana animal community type common in eastecn Washington and Oregon.
The disturbances to terrestrial resources predicted at both sites are very small compared with the total extent of that habitat.
On the other hand, the fish habitat in the Hanford Reach is the last 02/02/82 13 PEBBLE SPRINGS TESTIMONY RPT
\\
natural spawning area of the fall chinook salmon in the Columbia River and as such is a unique natural resource.
As a migratory species, the fall chinook salmon is not only important in the Hanford area, but also supports fishing throughout the lower Columbia and the Pacific Ocean near the mouth of the Columbia.
Salmon are culturally as well as commercially important fish in the Pacific Northwest.
They have played an impor, tant part in the history of people of both European and Native American ancestry in the Columbia River basin.
b.
The magnitude of terrestrial impacts from nuclear plant siting at Hanford would be highly dependent on whether the location selected at Hanford is adjacent to the WPPSS units, as assumed in Supplement 1, or is elsewhere on the Hanford Reservation.
Selection of a site on another part of the Reservation would remove the terrestrial environ-mental advantage of the Hanford site.
c.
Terrestrial impacts from nuclear plant siting are primarily of short duration during plant construction or small in areal extent (such as preemption of habitat by plant facilities) in comparison to total habitat.
However, aquatic impacts (entrainment and impingement of biota, thermal discharges, chemical discharges) are primarily effects which occur throughout the life of the plant.
At present, I know of no reason why this nuclear plant could not be operated at Hanford simultaneously with planned and operating units with-out significant aquatic impacts.
However, neither can I verify that this would be the case without detailed description of all plant sites, 03/12/82 14 PEBBLE SPRINGS TESTIMONY RPT
p f
plant designs, and operational parameters.
Thus the ranking of the Hanford site is based on pre-existing site characteristics.
Q.
The last part of contention AS-5 states: "the site comparison analysis fails to go into enough detail so that the differences in environmental consequences can be clearly understood." What level of detail is appro-priate for alternative-site analysis?
A.
The significant environmental differences among sites should be fairly
~
obvious and not require extremely detailed examination of either site characteristics or plant design characteristics for each site.
The staff found the information available adequate to determine that none of the alternative sites is clearly preferable to the proposed site.
The purpose of our review was not to perform an independent siting study or to recom-mend sites.
We have shown clearly and concisely in Supplement No. I why we considered the Pebble Springs site among the best the region had to offer and why we concluded that no environmentally preferable site was found.
Q.
To the best of your knowledge, is Supplement No. I true and correct?
A.
Yes, except for the following minor corrections that need to be made:
On pg. 2-24, the last line of the first paragraph should read:
" performed on the sites on the plateaus."
,,...o.
02/02/82 15 PEBBLE SPRINGS TESTIMONY RPT
'I On pg. 2-26, in the first line of the third paragraph of the Results and Discussion, " Jerry Creek" should read " Jetty Creek."
On pg. 2-32, the fourth paragraph, beginning "In the comparison...",
should be eliminated.
On pg. 2-36, make the following changb in the first paragraph:
The rating for impingement and entrainment for Ryderwood should be "+"
instead of "o" since use of Ranney collectors for water intake appears feasible for the Ryderwood site.
Ranney collectors are expected to have near-zero impingement and entrainment rates, while slotted pipes are expected to have relatively low impingement and entrainment rates.
This change would result in a conclusion that the Ryderwood site is " equal" to the Pebble Springs site for aquatic resources (Table 2.13).
The overall conclusion that the Ryderwood site is " inferior" to the Pebble Springs site would not change j
(Table 2.16).
On pg. B-4, Section 1.3, the last sentence of the fourth paragraph should read "These would probably include non-native warmwater fish."
On pg. B-22, the last sentence of the first paragraph should read "The Chukanut forn.ation in the vicinity of the site contains some i
coal beds which have been mined."
Q.
With these minor corrections is Supplemant No. 1 true and correct, to the best of your knowledge?
,4 02/02/82 16 PEBBLE SPRINGS TESTIMONY RPT
2 A.
To the best of my knowledge Supplement No. 1 was true and correct as of the date of its publication.
Since the time that Supplement No. I was drafted, however, Puget Sound Power & Light Company (PSP &L) has changed the proposed location of the Skagit Nuclear Power Project from a site near Sedro-Woolley in the Skagit River Valley to the Hanford Reservation.
In addition, PSP &L's preferred site at Hanford is not adjacent to the WashingtonPublicPowerSystemSupplyunits(WNP1,2and4)aswas assumed for any additional Hanford units in Supplement No. 1, but instead is some miles to the west of the WPPSS sites.
None of the screening criteria used to select alternative sites from potential sites (Supplement 1, FES-CP, Sec. 2.4) is affected by a change in the number of units planned for each site, and I still believe that both the Skagit and Hanford sites are among the best that can reasonably be found in their respective candidate areas.
To properly reflect t.he above plant-siting decisions, I have prepared the following testimony reevaluating Section 2.5 and 2.6 of Supplement No. 1 to determine if any changes are necessary in the conclusions of the alternative site comparison between (1) Pebble Springs and Skagit sites and (2) Pebble Springs and Hanford sites.
Q.
Please describe any changes in siting scenarios that should be made in Supplement 1 as a result of the Skagit change in location.
A.
The Pebble Springs vs. Skagit case cnanges from (a) comparison of two units at an unde'zeloped Pebble Springs site with a third and fourth unit at an already-developed Skagit site to (b) comparison of two units at an undeveloped Pebble Springs site with the two units at an undeveloped 02/02/82 17 PEBBLE SPRINGS TESTIMONY RPT
Skagit site.
The Pebble Springs vs. Hanford case changes from (a) com-parison of two units at an undeveloped Pebble Springs site with.the fourth and fifth units in the Hanford area at an undeveloped, unspecified site to (b) comparison of two units at an undeveloped Pebble Springs site with the sixth and seventh units in the Hanford area at an undeveloped, unspecified i
t site (Table 1).
Q.
What changes should be made in the terrestrial resources evaluation as a result of the proposed change in the site of PSP &L units?
1 A.
In Supplement 1 to the Pebble Springs FES-CP we concluded that in terms of the effects of construction and operation of the two PGE nuclear' units on terrestrial resources, the Hanford site would be superior to the Pebble Springs site, and the Skagit site would be inferior to the Pebble Springs site. These conclusions were based on the assumptions that (1) the Skagit site would already contain two PSP &L units and the Hanford area would contain three Washington Public Power Supply Service (WPPSS) units, and (2) at the Hanford area the PGE units would be located adjacent to the three WPPSS units.
Both of thess assumptions have now changed, as discussed above.
1 Site characteristics related to evaluation of impacts to terrestrial I
resources are summarized in Table 2.
Details on each item can be found in the cited references.
The criteria and approach used by the Staff in this analysis are similar to those used in Supplement 1 to the Pebble Springs FES-CP. that is, the major sources of impact to terrestrial resources are (1) loss and/or alteration of wildlife habitat, and (2) loss of the soil sc...
02/02/82 18 PEBBLE SPRINGS TESTIMONY RPT
/
2:-
c resource due to erosion. The rationale for this approach is discussed in Supplement 1.
Table 1.
Alternative Site Scenario Changes Site Owner Total Units if or Project Units Proposed Site Used Instead Site Name Sponsor for the Site of Pebble Springs Sitet!
I.
1979 (as developed in Supplement 1)
Hanford WPPSS 3
5 Skagit PSP &L 2
4
~
II.
1981 (as presented in this testimony)
Hanford WPPSS and 5
2 t18ased on the number of units specified in Construction Permit applications.
i 02/02/82 19 PEBBLE SPRINGS TESTIMONY RPT a
1 Table 2.
Terrestrial Characteristics of the Pebble Springs, Skagit, and flanford Sites 1 Characteristic Pebble Springs Skagit llanford Vegetallun zone Semi-arid steppe vegetation Mesic Conifer and boreal Semi-arid steppe vegetation forest Piesent dt.minant vegetation Clieratgrass and sandberg blue-Pasture, mixed hardwood /
Cheatgrass. Ungrazed, species grass (characteristic of conifers (characteristic unburned steppes.!:
ovesgrazed steppe) of logged forest and paper and pulp production H aw.a l s 7 species, including 26 species, including Black 19 species, including Mule rayute, mule deer bear, black-tailed deer deer, coyote, bubcat
~
flirds to species, including 99 species, including 57 species, including marsh long-eared owl, Swainson's bald eagle, red-tailed hawk, red-tailed hawk, hawk, red-tailed hawk, prairie hawk, marsh hawk, sparrow Swainson's hawk, golden falcon, gniden eagle, marsh hawk, Cooper's hawk, eagle, bald eagle, osprey, hawk sharp-shinned hawk, great prairie falcon, sparrow horned owl, barn owl, hawk osprey Site is in the Pacific fly-.
Arid Lands Ecology ite-Special considerat ions way; Minkler take is rest-serve; site is in the g
ing and feeding area for Columbia River flyway.
c) migratory waterfowl; resi-Riparian vegetation dent species include herons, is poorly developed but sandpipers, and grebes.
provides some resting areas Site land use Dry range and agriculture forest products Reserved land on large multi-
/. use sitet Average asuiual 1:e er igi.
9 inches 46 inches 6 inches Helief flat to gently rolling Hilly to steep flat to gently rolling teosion hatard during a.nis t o uc t ion Moderate to severe (wind)
Severe (water)
Moderate to severe (wind) 8 New pipeline riuht or way 5 miles or less 14 miles or less 9 miles or lesst tiew tsansmisslan right-of-5.S miles Up to 96 miles (requires Undetermined length between w.e y crossing Columbia River in site and ashe substation
- w. Washington to wheel power to Oregon) luformation simimarized from: ff5 Pebble Springs Units 1 and 2. April 1975, NUREG-M/025; FES Skagit Units 1 and 2, M.sy 1975, Nuk[G 75/OSS; it S, W.sshington Pul.lic ' Power Supply System Nuclear Projects 1 and 4 March 1975, NUREG-75/012; Leech et al.1979; Suppl. Ih.. 1. Pel.ule Spr ings F ES, Appendix C.
13 0.il a for llantne.1 t is.it ham leen modified for proposed site location of PSP &L utilts.
Skagit vs. Pebble Springs Loss of terrestrial habitat would be greater at the Pebble Springs site because of.the need-to construct a cooling reservoir; however, this loss of terrestrial habitat would result in a gain of aquatic and wetland habitat. On the other hand, land at Skagit occupied by cooling towers would represent a comparatively small net loss of habitat.
Disruption of habitat at Skagit for the pipeline and transmission rights-of-way will be greater than at Pebble Springs.
Similarly, because of the steeper relief at Skagit, soil erosion is expected to be greater than at Pebble Springs, although, as discussed in Supplement 1, quantitative comparison of water erosion at Skagit versus wind erosion at Pebble Springs cannot be accomplished with reconnaissance-level information.
Proximity to Minkler Lake of construction activities at the Skagit site makes some disruption of wetland habitat at Minkler Lake possible as a result of onsite stream alterations. Wetland habitats are essential to migratory waterfowl.
In summary, there is no clear preferability of the Skagit site over the Pebble Springs site in terms of site ecological resources or land-use capabilities.
In terms of impacts from soil erosion during construction, disturbance of wetland habitats, and magnitude of new rights-of-way for pipelines and transmission of power, the Skagit site is clearly inferior to the Pebble Springs site for installation of two nuclear units.
,, c ;., o.
02/02/82 21 PEBBLE SPRINGS TESTIMONY RPT
Hanford vs. Pebble Springs In the original alternative-site analysis presented in Supplement 1, FES-CP, we assumed that the additional units at Hanford would be con-structed in the vicinity of the existing WPPSS units in an area of burned, disturbed desert steppe committed to industrial development.
Current PSP &L plans, however, are to cpnstruct their two units about five miles west of the three WPPSS units (Fig. 1).
This site is presumed to be located in unburned, ungrazed land not close to other industrial installa-tions.
PSP &L's action makes plausible the conclusion that PGE might also find that the most advantageous site at Hanford would be some distance away frcm the WPPSS units.
If this were the case, the only clear environmental differences between the Hanford and Pebble Springs sites would be the acreage required for the facilities and the uses to which the site areas are dedicated.
As a result, the rating of Hanford vs. Pebble Springs would be changed in the following way:
Habitat and Construction Areas.
At Hanford, areas away from the WPPSS units are unburned, relatively undisturbed desert steppe habitat.
More species of birds and mammals have been observed at Hanford, but the difference is probably due more to the years of ecological research on the large Hanford Reservation in comparison to short-term surveys at the Pebble Springs site than to any major differences in site characteristics.
Therefore, Pebble Springs and
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02/02/82 22 PEBBLE SPRINGS TESTIMONY RPT
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.igure 1.
Location of Procosed Site for two PSP &L Units on the Hanford Reservation.
(Star indicates oroposed sita.)
23'
Hanford sites are considered to be sir.i ur except for the land area preempted by station fa.cilities.
Because of the preference for a cooling lake at the Pebble Springs site (2000 acres), more than twice the area would be required there than at' the Hanford site, where cooling, towers would be used.
On the other hand, construction of cooling towers precludes the use of preempted land by wildlife, while a cooling lake creates a nb habitat resource for wildlife.
Thus, the "+" rating for Hanford for habitat has changed to a "0" rating, while the rating for area disturbed at Hanford remains n+n, New Rights-of-Way.
Locat' ion of PCE units at an alternative site west of the WPPSS units would lengthen the rights-of-way neaded for water conveyance, and probably none of the WPPSS access facilities could be used for the PGE units.
Under these conditions there would be no substantial differences between the Pebble Springs and Hanford sites (see Table 2) and the rating for new rights-of-way should be changed from "+" to "0".
Land Use.
The Pebble Springs site is rangeland used for year-round cattle and winter sheep pasturage. Within 5 to 10 miles of the, site dryland farming is also practiced.
Sprinkle irriga-tion of grains might be possible in the Pebble Springs site vicinity if water were available.
Early in the permit application process, PGE proposed to deliver irrigation water for nearby crop production, thus enhancing the land-use capabilities of the site.
There are no land-use disadvantages f
02/02/82 24 PEBBLE SPRINGS TESTIMONY RPT
in the Pebble Springs site and some land-use advantages.
The
,Hanford Reservation has been retired from agriculture use.
Nearby land use in similar areas includes rangeland and sprinkle-irrigated agriculture.
At present the Hanford Reservation is dedicated to multiple uses, including industrial research and development, as well as preservation of natural areas and ecological research.
in' Supplement 1,Hanfordwas rated "+".with respect to lan'd use because of an assumption that the Hanford alternative site for the PGE units was adjacent to the WPPSS site in an ar'ea of industrial development..Since PSP &L has chosen a site some distance,from the WPPSS sites, the land-use advantage of Hanford becomes much less certain, since siting nuclear plants in certain areas could conflict with the dedication of some areas to natural areas and ecological research. Therefore no clear advantage to Hanford is seen, and the rating for Hanford for land use is changed from "+" to "0".
Summary Comparison On the basis of reconnaissance-level information, I find that the Skagit site with two units and cooling towers is inferior to the Pebble Springs site with two units and a cooling lake for terrestrial 1
resources.
Hanford is no longer superior to Pebble Springs with two units; the environmental advantage of Hanford is now limited to the smaller size of the site required there.
Since both sites are small in comparison with the amount of similar habitat in the vicinity of the sites, I have no clear p & 1rence for either site.
Therefore, I I
I 02/02/82 25 PEBBLE SPRINGS TESTIMONY RPT
e i
conclude that Hanford is equal to Pebble Springs on the basis of terrestrial resources.
Q.
What changes should be made in the aquatic resources evaluation as a result of the proposed change in the site of the PSP &L units?
A.
Supplement 1 concluded that in terms of aqbatic resources the Skagit and the Hanford site's would be inferior to the Pebble Springs site for the construction of the two PGE units.
The factors used to compare Pebble Springs to the alternative sites were sedimentation; rare, endangered and protected species; fishery resources; impingement and entrainment; water quality; impacts of effluents on water bodies; and competing water use.
For each of these factors, a "+, 0, or " rating system was used to indicate whether the alternate site was environmentally preferable to (+);
+
no clear prefere'ce to (0), or environmentally less preferable than (-)
n the Pebble Springs site.
Skagit vs. Pebble Springs My reanalysis indicates that none of the ratings given the Skagit site in Supplement 1 should be changed.
The ratings given the Skagit site for rare, endangered, and protected species; fishery resources; water quality; and competing water uses (0, 0, and 0, respectively) are not changed because they are nearly indepen-dent of the number of units at each site.
02/02/82 26 PEBBLE SPRINGS TESTIMONY RPT
p g
Impacts from sedimentation in the rivers or tributary creeks are short-te'rm effects sustained during the ' period of plant construction and during periods of soil erosion on disturbed areas of the site.
These impacts would occur at the Skagit site whether or not that site had previously been developed.
Therefore I conclude that the rating of "0" for the Skagit alternative site in Supplement 1 should not be changed.
Operation of two instead of four nuclear units at Skagit reinforces the Skagit rating of "+" in comparison with Pebble Springs for impingement and entrainment because fewer Ranney wells and less water withdrawal would be required at the Skagit site.
The " " rating for Skagit on impacts from effluents does not change.
The rating is based on plans to discharge blowdown from the PSP &L units to the Skagit River at the Skagit site, while no effluents would be released from the PGE units to the Columbia River at the Pebble Springs site.
Hanford vs. Pebble Springs The Staff's comparative evaluation of the Hanford and Pebble Springs sites in terms of aquatic resources is not changed by the possible addition of PSP &L's nuclear units at the Hanford site.
Impacts from sedimentation and turbidity are still expected to be trivial at both sites and largely limited to short-term turbidity impacts from construction of the intakes (both sites) and discnarge structure (Hanford site only).
Both Hanford and Pebble Springs sites were originally rated l
02/02/82 27 PEBBLE SPRINGS TESTIMONY RPT l
equal in terms of impingement and entrainment potential.
This rating was based on the expectations that (1) although small juvenile salmon and steelhead trout are present in the Hanford area, the perforated pipe intake design should afford the fish protection from impingement and entrainment, and (2) while the sidewall collection at Pebble Springs is expected to have greater impingement and entrainment potential, small
~
salmonandsteelheadjuvenilesarenotexpItctedtooccurinthatportion of the river.
Thus, the Staff's conclusion is still the same with seven instead of five units at Hanford, but the degree of_ uncertainty is greater.
In Supplement 1 Hanford was rated " " in comparison with Pebble Springs on the basis of impact from effluents. This rating was based on the expectation that no effluents in blowdown from the units at. Pebble Springs would be released to the Columbia River, while blowdown from five units at Hanford would be released to the Columbia. With PSP &L's proposal to construct their two units at Hanford instead of the Skagit site, as many.
as seven units might release effluents to the Columbia if the PGE units were also moved to Hanford.
Therefore, the " " rating given Hanford for impacts from effluents given in Supplement 1 is reinforced.
Summary Comparison On the basis of aquatic resources, none of the ratings given Skagit or Hanford in comparison with Pebble Springs has changed.
Therefore, the PSP &L proposal to construct its two units at Hanford rather than Skagit does not change the conclusion in Supplement No. I that relative to 02/02/82 28 PEBBLE SPRINGS TESTIMONY RPT
/
impacts on aquatic resources, both the Skagit and Hanford alternative sites are inferior to the Pebble Springs site for the construction of the PGE units.
'Q.
What changes should.be made in the geologic and hydrologic resource evaluation as a result of the proposed change in the site of the PSP &L units?
A.
The descriptions of geologic and hydrologic resources for both the Skagit and Hanford alternative sites were given in Appendix t of Supplement 1 to i
the FES-CP.
As stated in Supplement 1, geologic criteria in the alterna-tive-site review were judged in an environmental context, not in the context of safety.
The eruption of Mt. St. Helens, which is about 160 miles south of the Skagit site and 140 miles west of the Hanford site, has occurred since the publication of Supplement 1.
However, since the eruption did not produce any significant effects on the geohydrologic resources at either site, no changes are necessary in Supplement 1.
Since the characteristics used to evaluate the geologic and hydrologic resources of the alternative sites in Supplement 1 are nearly independent of the number of units on the sites, no changes are necessary in Supplement 1 as a result of PSP &L's site change proposal.
Q.
What changes should be made in the socioeconomic resource evsluation as a result of the proposed change in site of the PSP &L units?
A.
The conclusions expressed in Supplement 1 in regards to socioeconomic resources have been partially changed by additional information and the 02/02/82 29 PEBBLE SPRINGS TESTIMONY RPT
decision of PSP &L to amend its NRC application to substitute a site at the Hanford Reservation for the previously planned site in Skagit County, Washington.
The rating of the Skagit site in Supplement 1 must now be changed to " inferior" from " equal", while the Hanford site continues to be rated as " superior" to the Pebble Springs site.
Skagit vs. Pebble Springs Some of the Staff's ratings of the Skagit site relative to specific socioeconomic factors have been changed because of the fact that the Skagit location would be an undeveloped site. These assessments have altered the original conclusion that the Skagit site was " equal" to the Pebble Springs site in terms of socioeconomic resources.
A developed site (i.e., one with nuclear powe,r plant (s) operating or under construction) is generally a better site in regards to socioeconomic parameters than an undeveloped site.
At the Skagit site, the access facilities (roads, rail spurs) and transmissior, lines would have been built, the community infrastructure would have experienced the impact of a large construction force in the area, and visual impacts would already have been present if construction of PSP &L's proposed Skagit nuclear project had been untaken prior to the construction of the Pebble Springs units.
Now, however, these advantages would not exist at the Skagit site if that location were selected for the Pebble Springs units.
In addition, other data have become available to assess the Skagit site.
An " advisory ballot" was held in Skagit County in 1979, and the majority 02/02/82 30 PEBBLE SPRINGS TESTIMONY RPT
^
P c
/
of local voters (71.4%) expressed their disapproval of the Skagit (PSP &L) nuclear project." Since the PGE project would be very similar to the
~
PSP &L project, local opposition may also exist if the PGE project were moved to the Skagit site.
Local communities may have more difficulty in adjusting to the influx of workers and their families under these circum-stances.
A reanalysis of the ratings given the Skagit site in Supplement 1 indicates the following changes should be made as a result of the proposed relocation of the PSP &L project and the " advisory ballot":
Supplement 1 Testimony Access and Transmission Facility Impacts
+
0 Esthetics 0
Community Infrastructure
+
Cultural, Historical, and Recreational Sites Demography Labor Supply
+
+
According to the rating system implemented in Supplement 1, the Skagit site would now be ranked " inferior" to the Pebble Springs site.
- Residents were asked "Do you favor the construction and operation of the two nuclear power generating plants on Bacus Hill in Skagit County as proposed by Puget Sound Power and Light Company et al.?"
Approximately 72% of the country's eligible voters voted the day of the advisory ballot.
02/02/82 31 PEBBLE SPRINGS TESTIMONY RPT
e Hanford vs. Pebble Springs The proposed siting of PSP &i.'s units at the Hanford Reservation would not alter the socioeconomic resource ratings for the site.
As discussed in the terrestrial resources section, if the proposed PGE units were sited at Hanford, they might not be located near the WPPSS units on the reser-vation, and thus additional access and transmission facilities would be required.
In Supplement 1 it was assumed that the WPPSS access and transmission facilities could be used for the PGE units; however, the reservation is a restricted area and the construction of additional facilities will not ir =ct the general public.
Thus, constructing the additional units at the Hanford Reservation and siting them away from existing access and transmission facilities does not affect the " superior" rating of the site for socioeconomic impact.
Q.
In the final comparison do you still conclude that neither the Skagit nor Hanford site is clearly environmentally preferable to the Pebble Springs Site?
A.
Yes.
A summary of the Staff's revised evaluations of the Hanford and Skagit alternative sites in comparison to the Pebble Springs site is presented in Table 3.
The overall conclusion is that neither alternative site is clearly environmentally preferable to Pebble Springs, the same conclusion reached in Supplement 1 prior to PSP &L's proposal to construct its two-unit station at Hanford instead of Skagit.
This is not to say that either alternative site is not suitable as a location for a nuclear generating station, but rather that there is no clear environmental 02/02/82 32 PEBBLE SPRINGS TESTIMONY RPT
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/
advantage to either alternative site, relative to the Pebble Springs site, which is not balanced by some environmental disadvantages.
For Skagit, the change in Table 3 is an evaluation of " inferior" for socioeconomic impacts, which reinforces the overall environmental con-clusion that Skagit is environmentally inferior to Pebble Springs.
In the Hanford evaluation, the terres. trial resourbe evaluation of " superior" was changed to " equal", and the aquatic resources evaluation of " inferior" was reinforced.
Therefore, the overall environmental conclusion that Hanford is " equal" on an environmental basis to Pebble Springs is not changed.
In the context of this alternative site analysis " equal" does not mean "the same", but instead means that there is no clear environmental preferability to the alternative site (Hanford) over the proposed site (Pebble Springs).
Table 3.
Revised Staff Evaluation of the Suitability of the Skagit and Hanford Alternative Sites Relative to Pebble Springs Geological and Terrestrial Aquatic Hydrological Socioeconomic Environmental Site Resources Resources Resources Resources Conclusion Hanford Equal Inferior Equal (No Superior Equal (No (Change)
(No change) change)
(No change) change)
Skagit Inferior Inferior Inferior Inferior Inferior (No cnange) (No cnange) (No change)
(Change)
(No change) 02/02/82 33 PEBBLE SPRINGS TESTIMONY RPT
.t ia References National Academy of Sciences, National Academy of Engineering (NAS/ NAE).
1974.
" Water Quality Criteria 1972," U.S. Government Printing Office, Washing-ton, D.C.
U.S. Nuclear Regulatory Commission.(USNRC).
1975.
" Final Environmental Statement Related to Construction of Pebble Springs Nuclear Plant Units 1 and 2, Portland General Electric Company," Docket Nos. 50-514 and 50-515 NUREG 75/025.
U.S. Nuclear Regulatory Commission (USNRC).
1980.
" Supplement.No. 1 to the Final Environmental Statement Related to Construction of Pebble Springs
~
Nuclear Plant Units 1 and 2,. Portland General Electric Company," Docket i
Nos. 50-514 and 50-515.
02/03/81 34 PEBBLE SPRINGS TESTIMONY RPT