ML20071H784

Comments on Review of EIS Re Util Application for Site Certification/Environ Rept for Proposed Project.Identifies Areas Where Addl Analyses or More Info Would Strengthen Eis. Detailed Scoping Suggestions Encl

ML20071H784
Person / Time
Site:	Skagit
Issue date:	03/01/1982
From:	Oneal G ENVIRONMENTAL PROTECTION AGENCY
To:	Lewis N, Norris J Office of Nuclear Reactor Regulation, WASHINGTON, STATE OF
References
M-S-443, NUDOCS 8203080535
Download: ML20071H784 (4)

Text

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ENVIRONMENTAL PROTECTION AGENCY REGION X jgo stg gg 1200 SIXTH AVENUE 5

w SEATTLE, W ASHINGTON 98101

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M y M/S 443 1 LMR E2 Mr. Jan tberis G

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Mr. Nicholas D. Lewis, Chairman 4

p Energy Facility Site Evaluation Council f

4 State of Washington 4224 6th Avenue S.E.

Olympia, Washington 98504 RE: Skagit/Hanford thclear Project EIS Scoping Comments

Dear ftssrs. Norris and Lewis:

The Environmental Protection Agency (EPA) has completed its review of the Application for Site Certification / Environmental Report ( ASC/ER) for the proposed Skagit/Hanford Nuclear Project. Our review focused on identi-fying additional information and analyses which should be presented in the planned environmental impact statement (EIS). EPA has the responsibility I

under Section 309 of the Clean Air Act to review and comment on major Federal actions significantly affecting the environment.

In carrying out this responsibility, we approach our review from two separate stand-points.

The first is the adequacy of the information and analysis in areas where EPA has direct statutory or regulatory responsibilities. The second is the adequacy of the proposed EIS in terms of conformance with the CEQ regulations for preparing EIS's.

EPA's rating of the Draf t EIS, therefore, will have two components: one evaluating the environmental impacts of the proposed project, while the other addresses the adequacy of the information presented in the EIS.

1 EPA's principal statutory concerns center on the potential impacts that new power plants may have on the natural environment and on compliance with applicable environmental standards. We therefore look to'the EIS to provide a thorough discussion of the proposed project's compliance with

-applicable environmental standards. The standards of importance for nuclear power plants are the radiological dose standards established in 40 C.F.R.190 et. seq., wastewater effluent standards for steam-electric 0g generating stations, ambient water quality standards 'for surface waters which receive wastewater discharges, and any standards which may apply to M

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the disposal of hazar'dous and/or radioactive waste materials.

The EIS snould also evaluate the water supply intake and wastewater discharge structures' compliance with the Section 404(b)(1) guidelines under the Clean Wa ter Act.

Die to the short time frame available, we were unable to review the water quality thermal effects modeling contained in the ASC/ER. Consequently, we cannot provide comments on the technical aspects of the models used to evaluate the proposed plants' compliance with water quality sttndards. We are reviewing this modeling and will forward any technical comments as soon as possible.

In our review to date, we have identified a few areas where additional analyses or more information would strengthen the environmental impact evaluation.

These are outlined below, while more detailed information and suggestions are provided in the attachment to this letter.

ENVIRONMENTAL INFORmTION NEEDS 1.

Environmental Consequences of Accidents:

The ASC/ER evaluates the environmental and economic consequences of possible nuclear power plant accidents by combining the estimate of the probabili-ty of each potential accident with its estimated environmental and economic impacts.

EPA believes that the probability esti-mates should be separated from the estimates of the impacts for each accident sequence and that a worst-case type analysis of the environmental effects of each such sequence should be presented in the EIS. This type of presentation would give the reader a much better picture of 'the magnitudes of the potential impacts and would be consistent with the provisions of the CEQ regula-tions governing situations n which there are large uncertainties.

2.

Radiological doses from routine operations:

The EIS should pre-sent a complete comparison of radiological doses from routine operations to the 40 C.F.R.190.10(a) standards.

In addition to presenting the total doses attributable to all nuclear power plant operations on the Hanford Reservation, it should present the individual doses attributable to this project, the continued operation of the Hanford Generating Project, and the oper2 tion of the WPPSS nuclear projects.

3.

Radioactive Waste Disposal:

The EIS should evaluate the poten-tial environmental consequences of the alternatives being corsi-dered for disposal of solid radioactive wastes generated by the project.

It should also evaluate the consequences of spent fuel disposal to the extent possible.

4.

Provisions for and Consequences of Decommissioning:

The EIS should discuss the methods which would be used to decommission the two nuclear units when they reach the end of their service lives and the environmental effects of such decommissioning.

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'I OTHER CONSIDERATIONS The CEQ regulations'specify a number of components of an adequate EIS. Of particular importance is the analysis of alternatives.

The EIS should contain a thorough analysis of a reasonable range of alternatives to the proposed action.

In closing we would like to note that because of the short time frames associated with this NEPA review, our comments on the Draf t EIS may dis-cuss issues which have not been identified in this letter. We appreciate the opportunity to participate in this scoping process and apologize for the delay which has occurred in the completion of this scoping review. We would be glad to discuss our suggestions and concerns with you' and your staffs at your convenience. To arrange such discussions you should con-tact Dick Thiel, our Environmental Evaluation Branch Chief, at (206).442-1266 or ( FTS) 399-1266.

Sinc erely, I

c, 0%d Gary L.

'Neal, Director Environmenal Services Division At tachment cc:

Sandy Williams, OFA (with attachment)

Grant Bailey, URS Inc. (with attachment) i i-i

J U.S. Environmental Protection Agency D2 tailed Scoping Suggestions Re:

The Skagit/Hanford Nuclear Project Environmental Impact Statement Environmental Considerations 1.

Groundwater: The EIS should mention the quality of the groundwater in the unconfined aquifer beneath the plant site.

The site appears to be within thgH and NO -N have been noted.

contamination plume from the 200-area where elevated concentra-tions of 3

The EIS might also consider the use of groundwater as an alternative water supply source for construc-tion or emergency use.

If this were to be done, a groundwater monitoring system would be needed.

2.

Sanitary Waste:

The volume of sanitary waste is reported [13.7.1.1l as ranging from 10,325 to 17,325 gallons per day.

These figures are sub-stantially greater than the five gallons per minute (7,200 GPD) reported

[13.3.4 l as the domestic water requirement.

If both sets of figures are correct, the sources of the additional wastewater should be identified.

On page 4.1-6, the text says that the package sewage treatment plant will be used to process the majority of the construction sanitary waste, how-ever Table 3.7-1 shows construction sanitary sewage as greater than twice the design flow rate (17,325 GPD) for five of the 10 construction years.

The EIS should indicate how this excess flow would be treated.

It would also be nelpful to have a diagram of flows entering the sanitary sewage disposal system.

3.

Intake and Discharge Systems:

Site-specific information is needed at the intake and outfall to evaluate both construction and operation im-pacts.

Details on habitat characteristics, construction techniques, and schedules, as well as detailed drawings of both structures should also be presented.

Minor Technical Corrections 1.

Fi gures 2.1-3, 2.1-2, and 2.8-1: Labels on the roads north of the Wye Barricade are inconsistent. Route 4 South is shown as both the road northwest and as the road northeast of the intersection.

2.

Page G-6 Section I11.1.2 - Although the S/HNP site is located on a Federal reservation, the restriction of public access to State Highway 240 which crosses the reservation, is minimal.