ML20054L702
| ML20054L702 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 06/29/1982 |
| From: | Anderson F AFFILIATION NOT ASSIGNED |
| To: | Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 8207080380 | |
| Download: ML20054L702 (7) | |
Text
.
June 29, 1982 U.S. NUCLEAR REGULATORY COMMISSION Washington DC 20555 ATTN:' Director Division of Licensing
Dear Sir:
As a resident of South Hampton, N.H. I would like to take this opportunity to clarify several aspects of the Draf t Environmental Statement - OL Stage.
Chapter 4: AFFECTED ENVIRONMENT Section 4.2 Facility Description 4.2.6 Power Transmission System In its Final Safety Analysis Report (FSAR) the Applicant notes that "two of the three lines to Seabrook Station will be installed and will be in service prior to Unit 1 startup. The third line is scheduled to be available for Unit 2 operation." (FSAR 8.1.1) No mention of this is made in the ER-OL filed by the applicant.
The staff should comment on the environmental impact of the Westerly Seabook-Scobie line vs. the Southerly Seabrook-Tewksbury line, given that the completion of the second plant may be delayed for an extended time or cancelled (note that an NRC staff report that lists Seabrook II as one of 19 unlikely to be completed). The NRC should participate in the decision as to which line will be built next: Seabrook-Scobie or Seabrook-Tewksbury given that a third line may not be required. The NRC should also determine if a third line is required even if the second unit is built.
The staff should also be made aware that NEET, a subsidiary of New England Power, is proposing to construct a high voltage line to Southern New England to bring power from Quebec hydro plants, and also to sell power from Seabrook and other stations. In the future NEET may seek to use the Seabrook-Scobie line as a tie-in to the Quebec line. (The New Hampshire Site Evaluation Committee recently held hearings on Phase I of this project.)
If the Southerly route is selected, the impact of a corridor first heading West and then dropping through South Hampton should be compared with that of other Southerly alternatives.
Section 4.3 Project Related Environment Description 4.3.1 Land It is noted that "the total land area owned by the utility in connection with the Seabrook Station is approximately 363 ha (896 acres). The land area within the site boundary, or exclusion area boundary. is approximately 291 ha (719 acres)."
Goo @
8207080300 920629 PDR ADOCK 05000443 D
Comments on Seabrook Station Draf t Environmental Statement - OL Stage Fred Anderson South Hampton NH Page 2 No specific description, maps, etc. are provided for the area outside the site.
The staff should be provided with a complete description of this land, and a to its future use. The staf f should be made aware that the statement o,
Applicant has on about 11 acres of this land built and is operating a storage area for construction materials for the second plant directly in the path of the state and Federally approved transmission right of way (see attached letter from the N.H. Assistant Attorney General). The applicant applied for state permission to change the transmission route in the vicinity of the storage area (one of the court cases referred to in DES-OL 4.2.6) 4.3.6 Historic and Archeological Sites It was stated that "during consultation with the State Historic Preservation Office" the applicant was notified that local citizens are developing informe; ion with regard to two proposed historic districts in South Hampton for the state's consideration of their possible eligibility for inclusion in the National Register for Historic. Places. The districts are along the path of the approved transmission corridor."
In fac t, the Southerly line would pass right through one historic district (Jewelltown) and within clear view of another (Hilltop) that contains the Town Common, Town 1611, Barnard School and South Hampton Baptist Church. A third dist ric t (Highland Road) would also be impacted by a change in the Westerly / Southerly corridor proposed by the applicant.
These districts have been adooted by the Town of South Hampton, under New Hampshire law, and any furthe e action by the State and the National Register would only add to the status
,f these areas.
Note also that over a year age the Advisory Council on Historic Preservation wrote to larold Denton of the hRC and I believe also to the applicant informing them of the requirement to " evaluate the significance of such p ro pe rt ie s. " (See attachment)
RAI 310.15 In RAI 310.15 the applicant claims that "the operation and maintenance of the line would have no unacceptable impact on these historical resources. In o pe ra t io n, the lines are silent except during inclement weather when under the worst case conditions (heavy precipitation) corona associated noise could reach 50 to 55 dB (A) at the transmission corridor edge. Whereas this noise level is the equivalent of moderate rainfall on foliage 4 ts intuitively obvious that the imposition of this transmission line oc ce uould be imperceptible over natural noises. It would also h+ ' (
unlikely that one v
would choose such weather to view the exterior 's r><
/ such historical re sou rce s. "
The Applicant seems to ignore the visual impact that 70-100 f oot dual and triple steel or wooden poles would have on the districts. South Hampton, like other towns, maintains rigid controls on any exterior modification to structures and new construction within a historic district (see attachment) and such structures would without question do irreparable harm to these districts.
Comments on Seabrook Station Draf t Environmental Statement - OL Stage Fred Anderson South Hampton NH Page 3 Also in RAI 310.15 the Applicant refers to Indian Ground Hill statirg that "no systematic excavation has been performed in this area. Transmission line operation and maintenance will not disturb the topsoil and therefore should not impact archeological resources." The Applicant ignores the impact that construction would have (the Southerly line would pass right over Indian Ground Hill) and also ignores the damage that operation and maintenance would have on any potential future public use of this area. During the 1972 State hearings the applicant was made aware of the possible significance of Indian Ground Hill via questioning by the Assistant Attorney General and yet it has not studied the area further. The Applicant should be immediately required to undertake a systematic excavation of this area.
Section 4.1.2 of the FES-CP examined the lines with reference to criteria established by the Federal Power Commission (" Electric Power Transmission and the Environment" 1971). In addition to the avoidance of historic sites, it suggested the avoidance of scenic or recreation areas and the desire to achieve
" minimum possible view by the general public."
All three criteria would be abridged if the Southerly line were erected within direct view of the center of South Hampton and its historic district. Fu rt he rmo re, the Jewelltown historic district contains the Pow Wow River, used for canoeing, fishing, ice skating and other recreational activities.
Chapter 5: ENIRONMENTAL CONSEQUENCES AND MITIGATING ACTIONS 5.5.1.2 Induced Voltage and Low-Level Electric Fields
" The staf f believes that humans would not chronically be exposed to field gradients in excess of the maximum edge of right of way value (2 kV/m) because people are not permitted to live on the right of way and therefore, would not receive a long te rm, constant exposure."
The staf f should be aware that some of the apartments in the Whitehall Village complex in Amesbury, Massachusetts (just over the state line f rom South Hampton) are within 20 feet of the edge of the right of way, and that the specific exposure that residents will have is not known (and may be altered by a number of conditions). Thi staff suggests that a value of 4-20 kV/m is the equivalent to the 100 kV/m exposure of laboratory animals that resulted in "significant effects", and it concludes that humans will not be exposed to ha rmful levels.
However, a slightly dif ferent scaling factor would result in a different conclusion - that harmful ef fects f rom low-level electric fields may result.
Those living along the right of way should not be a part of experimentation without their consent.
Comments on Seabrook Station Draf t Environmental Statement - OL Stage Fred Anderson South Hampton NH Page 4 The staf f notes that "if ongoing research were to conclude that protective measures were warranted, a variety of actions could be considered including, but not limited to: increasing the width of rights-of-way to limit the field strengths to which the public would be exposed at the edge of the right-of-way; giving potential right-of-way users specific warnings of possible risks; and using shield wires or other types of retrofitting techniques that could reduce field gradients to a prescribed level."
As noted earlier apartments in the Whitehall Village complex are already extremely close to the Right of Way, and any widening would still leave other residents subject to their ef fects (even if some apartments were condemned).
Warning signs would not be effective with children, many of whom live in Whitehall Village.
The staf f should note that another alternative lies in placing the lines underground in certain sensitive areas, and that if this might be ordered at a later time it should be required now before the lines are erected. The Massachusetts DPU has before it a proposal to place part of the Southerly line underground.
Finally, it should be asked who will assume the responsibility for judging that ongoing research has reached the stage where mitigating actions are required? The Applicant?
5.7 Historic and Archeological Sites The DES states in full that "the operation and maintenance activities of the undertaking are not expected to affect any cultural resource sites in or eligible for the National Register of Historic Places."
As noted earlier, several sites in South Hampton are awaiting a ruling on their eligibility. Further, the NRC should not limit its consideration to only sites in the Federal Register, but also those designated by Towns acting under State law. Mitigating actions are definetly required to minimize the impact on these historic and archeological sites.
5.8 Socioeconomics No statements are made with regard to the socioeconomic impact of the overhead lines. The proposed Southerly line will cut through South Hampton, dramatically affecting current property values of many homes and also any potential for future residential developmant. Given that the town has no appreciable commercial base the socioeconomic impact could be devastating.
OTHER ISSUES The following excerpt from the FES-CP indicates a significant area in which the Applicant has changed the method of construction of the transmission lines.
Comments on Seabrook Station Draf t Environmental Statement - OL Stage Fred Anderson South Hampton NH Page 5 Section 4.5 MEASURES AND CONTROLS TO LIMIT ADVERSE EFFECTS DURING CONSTRUCTION 4.5.1 Applicant Commitments
" 8. The use of wood H-f rame supports and preservation of screening vegetation at road crossings will be used to minimize ground level view of the transmission system when possible."
The wooden structures are also referred o in FES-CP Section 3.8.4.
The Applicant has in fact not lived up to its " commitment" but has installed steel H-f rame towers along the Seabrook-Newington right of way (except single steel towers along the B&M R0W and at the Interstate 95 crossing). Wooden H-frames were described by PSC's environmental consultant in the original State hearing (Page 499): " Pole selection. Wood pole H-frame compatible to low land landscape because of low profile. Wood is appropriate to the rural character. In built up urban areas expressing technology such as Portsmouth interchange and related residential commercial-industrial area, are more sophisticated pole factors appropriate." Steel H-f rames have never been proposed to State or Federal authorities. The Applicant should be required to use wooden poles in all rural areas.
In summa ry, it is my contention that the NRC should evaluate the environmental impacts of the Westerly vs. Southerly line and determine which should be built next (given that a third line may not be required).
If the Southerly line (Seabrook-Tewksbury) is built, alternative routes or methods of construction (underground in sensitive areas) should be ordered in order to avoid the impact the operation of high voltage lines along new rights-of-way weit 1d have on Historic Districts, archeological sites, areas of public assembly, recreation areas, and the health of citizens.
Thank you for this opportunity to respond to the DES-OL.
Rega rd s,
[
L rederick H. Anderson, J Jewell Street South Hampton NH 03827
s THE STATE OF NEW HAMPSHIRE aC?tNO Af70RNEY CENTRAL A33r$TAtt? ATTORNEYS OEMEAAL ohEoORY H. SMITH DONALD J PERRAULT RICHARD C. NELSON g
w JEFFREY R COHEN amarrrAwr ATTORMEYS CENERAL N
PAUL W HODES
. J-l 4 * 'Af}5 JOHN T. PAPPAS EDWARD N. DAMON WILBUR A. oLAHN. !!!
3
MAh41N R JENKINS PETER W. MOSSEAU E. TUPPER KINDER DEBORAH J. COOPER BETSY S. WES10 ATE MARTHA v. oORDON ANDREW R. oRAINoER PETER C. SCOTT. JR JAM S.
W SE THOMAS P. COLANTUoNo arroRurys WILLIAM B. ROBERTS THE ATTORNEY GENERAL MICHAEL A. P!GNATELLI DAVID W. JORDAN BRIAN T. TUCKER STATE HOUSE ANNEX DAVID !. HARR!o AN PAUL BARBADORo MARK H. PUFFER as CAPITOI. STREET LoRET"'A S. PLATT A E C CONCORD. NEW MAMPSMIRE Ouot December 30, 1980 Frederick J. Coolbrgth, Esq.
Public Service Company of New Hampshire 1000 Elm Street, P.O. Box 330 Manchester, New Hampshire 03105 Re:
Public Service Company Transmission Line Route:
Kensington/ South Hamoton
Dear Mr. Coolbroth:
This letter is to confirm our telephone conversation of December 22, 1980.
At that time, I advised you 6f my telephone conversation with Fred Anderson of South Hampton in which he advised me that the Public Service Company was seeking site plan approval from the Kensington Planning Board for an ll-acre tract to serve as an equipment storage area for the Seabrook nuclear plant.
It was Mr. Anderson's under-standing that the ll-acre tract was directly under the transmission line route approved in 1972 by the New Hampshire Site Evaluation Committee.
As per our telephone conversation, you have detemined that the tract in question is, in fact, on the presently approved transmission line route.
Therefore, it is my feeling that Public Service Company should immediately advise the Site Evaluation Committee of its intent to dedicate the parcel to a use potentially inconsistent with the transmission line.
Although it is my understanding that the Company plans to request a route change from the Site Evaluation Comittee, the change is by no means a foregone conclusion.
If a change is not approved by the Committee, the Public Service Company, obviously, will have to accept any risks that the use of the parcel in question may be inconsistent with the location of the transmission line.
I assume that under no circumstances would the Company assert that the trans-mission line route must change because of its own actions, such as the equipment storage use discussed above.
vv g.,
Come-mer Pr =u
(.au m.3 tech t?l.X30 1
Cnmanal Jesuee goon r73 3473 4 c,,,,,g Chan e h (803) 271,Ehts Em. ness Domata (sos 371-3875 Aautrues Secues (403) 278,M40 Eavarsamental Protocues geagi r73 3673 8E138 278 JB83 Empaoyment Security Comass! (903) 3734713
l s
OFFICE OF THE ATTORNEY GENERAL FACE 2 Frederick J. Coolbroth, Esq.
December 30, 1980 Please provide me with additional information concerning this matter and the Company's intentions regarding use of the presently approved transmission line route at your earliest convenience.
Very truly yours, T.Ty W E. Tupper Kinder Assistant Attorney General Environmental Protection Division jlh cc: William A. Healy, Chairman Site Evaluation Committee Martin L. Gross, Esq.
Sulloway, Hollis & Soden Ired Anderson, Jr.
a
Advisorv r
Council On Historic Preservation l' 22 6 $'re..* NV.
- . d.m g '. o D. :n e.,!
e I
P:ay 5,1%1 Mr. Harold benton Director, Office cf Nuclear beact or hs g ulation L.S. Suchar Regulatory Cor ssion WatrinEton, DC 20555
Dear Mr. Denton:
e We have been informed that the placement of transmission lines associated with const ruction on the Seabrook Station, an undertaking of the Nuclear Regulatory Cor=nission, cay have an ef fect on the South Hampton Historic District, South Hampton, New Hampshire.
This property cay possess historical and architectural significance and therefore may be eligible for inclusion in the National Register of Historic Places.
Sect ion 800. 4(a) of the Council's regulations, " Protect ion c: Hirterir and Cultural Properties" (36 CFR Part 600), sets forth the a thod cf evaluatine the significance of such properties.
We request that yee initiate this evaluation and infore us of your f in d in g s.
If the e -i c..
s t r u t., in a deterr.ination by the Secretary of ths. Inter: r : hat t!.e ps._,:y is eligible for inclusion in the National Regist er, you shouic follow the remaining steps in Section 600. 4 to evaluate the e f f ect of the undertak :ng on thc property and, if appropriate, request the Council'.
cor:mn t s.
Should you havc any questions er require additioncl arr.i.-tatoi please call Joseph F. Hough at 254-3495.
Thank you for your cooperation.
Sinccrtly, hs N
Jc m E. Tannenteur Chief, Eastern Division of Project Review Enclosure
_s
~_.s
f South flampton liistorical District Commission Purposes and Procedures SECTI(N 1 PURPOSES To preserve for generations to come the unique collections of historically, architecturally and culturally significant buildings and structures which characterize the town of South flampton, to encourage their maintenance and restoration, and to insure that new buildings and structures, and alterations, to existing buildings and structures, and uses of buildings and structures within the Districts are in visual harmony with their neighbors in order that districts be preserved which will reflect the cultural, social, economic, political and architectural history of the town of South flampton, conserve and maintain property values in such Districts, foster civic beat.y, strengthen the local economy, and generally provide an opportunity to benefit the education, pleasure and welfare of all citizens of the municipality.
SECTION 2 IROCEDURES: CERTIFICATE OF APPROVAL NOTICE OF DISAPPROVAL Any person wishing to construct, alter, repair, move, demolish, or otherwise change the exterior appearance of a structure within a district or construct a new structure within a district or institute a new use of land or buildings within a district must obtain a Certificate of Approval from the Historic District Commission before any other building permits otherwise required by
)
the town are obtained.
A Application forms are available from the Building Inspector or llistoric District Commission.
B Upon the receipt of an application form the Ilistoric District Commission
]
shall within fifteen days, 1 determine that the application is of no interest and notify the applicant in writing that he may proceed
. -O R 2 determine that the application is of interest and schedule a public hearing.
C Notice of Public flearings shall be advertised at Icast 15 days in advance in a newspaper of general circulation in the municipality, shall be posted in at least three public places, and shall be sent by registered mail to abutting property owners and those owning property directly across the street.
D Public hearing shall be open to the general public and testimony may be received from any party.
E Certificates of Approval or Notices of Denial shall be issued. within 45 days of the filing of an application in accord with RSA 31-89 a-f.
F A;)p l-icat ions from Applicants for a Certificate of Approval shall show:
1 Name of owner of land l
2 Description of land and buildings involved 3 Names and addresses of abutting property owners and those directly across the street.
4 A description of work proposed to be donc, which should include all information as required for a building permit and any other information as deemed necessary by the Ilistorical District Commission.
G Decision of the Ilistoric District Commission shall be made in accord with the guideli for decisions listed below.
3 11 Deci.ons of the liistoric District Commission shall be appealabic to the Board of Adjustment as provided for in RSA 31-89 h.
I En fo rcement shall be as provided for in RSA 31-89 j and k.
SECTION 3 GUIDELINES FOR DECISIONS ON APPROPRIATEM ESS: The following principles shall be followed in the granting of a Certificate of Approval within an Ilistoric District:
A If proposed construction will not have any visable impact on the exterior of the building or structure it shall be deemed of no interest.
B Painting of the same color and routine repair to existing structures not involving any other exterior changes shall be deemed of no interest.
Parties interested in promoting the spirit and intent of the District should come before the Commission for guidance in the selection of historically appropriate colors, or details.
\\
y, h' hen determining the appropriateness of all other alterations, restorations, C
or remodeling of existing structures the following criteria shall be used:
1 Structures of importance because of their date of construction of their architecture should be altered to restore features to their original appearance.
2 Structures merely typical of their age and style should be altered in a fashion typical of that age or style, if in keeping with the character of the District.
D New structures, or buildings moved in from outside the District, must conform in general size, scale, and style to the existing structures within l
the District.
In addition, it shall conform to the general style of the I
district by being similar to neighboring structures in the follcuing criteria:
1 Openings within the facade or a percentage of the facade: i.e. doors and windows.
2 Similarity of construction materials and surface texture: i.e. rough, smooth, wood, brick, etc.
3 Si'nilarity of roofs: i.e. slopes and shapes.
4 Similarity of architectural details: i.e. cornices, lintels, arches, porches, balustrades, wrought iron work, chimney, etc.
5 Similarity of landscaping and ground covering: i.e. grass, brick, granite, etc.
E Before a building or other structure is demolished or moved out the a District, the applicant shall in good faith prepare a detailed plan for the reuse of the site and the Commission may grant a Certificate of Approval Such Certificate of Approval shall only be granted upon a showing by the applicant that to deny such a Certificate would result in a hardship unique to the property in question, and that such hardship is not common to neighboring properties, within the District.
South Hampton Historic Commission Passed by a vote of the town at the Town Hall July 3, 1974
_.-