ML20112H800

Forwards Detailed Comments on Des Re Air Quality,Water Quality,Wetland Impacts & Noise.Addl Info & Clarification Requested Re Water Quality & Supplemental Measures Suggested for Potential Wetland & Noise Impacts

ML20112H800
Person / Time
Site:	Vogtle
Issue date:	01/10/1985
From:	Scott Moore ENVIRONMENTAL PROTECTION AGENCY
To:	Mark Miller Office of Nuclear Reactor Regulation
References
4PM-EA-HOM, NUDOCS 8501180045
Download: ML20112H800 (4)

Text

a f to sm, f AMb g y UNITED STATES ENVIRONMENTAL PROTECTION AGENCY g gc REGloN IV 345 COURTLAND STREET ATLANTA GEORGIA 30365 7 JAN 101935 5$ /

4PM-EA/HOM Ms. Melanie Miller Division of Licensing U.S. Nuclear Regulatory Commission Washington, D.C. 20555

SUBJECT:

Draft Environmental Impact Statement Related to the operation of Vogtle Electric Generating Plant, Units 1 & 2 EPA Log No.: D-NRC-E0004-GA .

Dear Ms. Miller:

Pursuant to Section 309 of the Clean Air Act and Section 102(2)(C) of NEPA, EPA has reviewed the Draft Environmental Impact Statement (DEIS) on the operation of the Vogtle Electric Generating Plant, Units 1 and 2. Our review of this project has primarily concentrated oa air quality, water quality, wetland impacts, and noise. We encourage you to also coordinate with other agencies for their review of other environmental and non-environmental factors.

Based on the discussion in the attached " Detailed Comsnents," we rate this DEIS an "LO-2", i.e., lack of major objections to the proposed action. However, some additional information and clarification has been requested in the attachment for water quality as well as supplemental mitigation measures suggested for potential wetland and noise impacts.

We appreciate the opportunity of commenting on.this DEIS.

Please contact us if you have any questions regarding our comments. The contact person on my staff for this project is Chris Hoberg at FTS 257-7901.

Sincerely yours,

'Sheppard N. Moore, W/

ief W

-NEPA Review Staff Environmental Assessment Branch

Attachment:

" Detailed Comments" h

8501180045 850110 '

I fI PDR ADOCK 05000424 D PDR

l cc: Mr.~W. Thomas Brown Associate Regional Director ,

Planning and External Affairs

'U.S. Department.of_the Interior National Park Service Southeast Regional Office 75 Spring Street,'S.W.

Atlanta,' Georgia 30303 Mr'. Edwin M. Eudaly Acting Field Supervisor U.S. Department of the Interior Fish and Wildlife. Service Federal Building.

810 Gloucester Street Brunswick,' Georgia 31520 d

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• DETAILED' COMMENTS AIR"OUALITY We have reviewed the DEIS for non-nuclear, ambient air quality impacts. Since this is a nuclear plant, the only non-radioactive pollutants (e.g., sulfur dioxide and nitrogen oxides) are those produced by the operation of.the emergency diesel generators and auxiliary boilers. The emissions from these sources are suffi-ciently low and the diesel generators are exempt from the State of Georgia air quality permitting requirements. -The auxiliary boilers are proposed to.be operated in accordance with Georgia permit emission limitations. Visible emissions from the cooling towers should not degrade visibility of any class I area with the plume dissipating near the plant.

We, therefore, find no ambient air quality concerns for any non-nuclear pollutants if the plant is operated as proposed.

WETLANDS Our major wetland concern involves the proposed routing of a high

. voltage transmission line through Ebenezer Creek Swamp, an area designated by the U.S. Park Service as a National Natural Landmark.

The original alternative to clear-cut a ISO-foot wide corridor through the swamp would have had a significant adverse environmental impact on the ecosystem. However, the modified plan, developed by the applicant in response to the concerns of the U.S. Fish and Wildlife Service and the National Park Service, should minimize the impact on the swamp. By the use of taller towers, the clearing can be limited to a 100 by 100 foot area for the base of the tower at Station 124.00.

Best Management Practices should be used to minimize construction impacts on the water quality of wetlands adjacent to the work site.

Access roads for construction should avoid filling wetland. areas.

Any permanent sloughs and water channels should be crossed by bridging or open-bottom box culverts adequately sized to accommodate the natural flow. To minimize additional clearing, existing logging roads should be used whenever possible for access roads.

In addition, for areas in or adjacent to the swamp, we would prefer mechanical means used for any necessary right-of-way maintenance.

.Any herbicides used, of course, should be EPA approved and applied in accordance with label directions.

WATER' OUALITY Our water quality review has identified the need.for some additional clarification and information. Our detailed water quality concerns are as follows:

o Outfall Serial No. 001B7 of the NPDES permit' limit's the non-radiological components of the radwaste discharge and should be discussed in Section 4.2.5, page 4-5 or Section 4.2.6, page 4-6.

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w o Page 4-6 and 4-7, Section 4. 2.6. Under 40 CPR Part 423, " chemical metal cleaning wastes" are not included in the " low volume waste" category. To.the extent that " start up and equipment cleaning" wastes are conducted using chemicals such as acids, alkaline phosphate solutions, etc., they are prc'erly designated " chemical 1 metal cleaning. wastes" and not " low volume wastes." If wastes result from water wash only, they would properly be designated low volume wastes and could be combined with other low volume wastes for co-treatment in one of the designated facilities.

However, " chemical metal cleaning wastes" are designated for treatment in the start-up pond prior to combination with treated

" low volume wastes." Metal cleaning wastes are limited in terms of total iron, total copper, and oil and grease as well as total suspended solids (See Part III.B.3, page 14 of the NPDES permit).

(Note: Effluent' guidelines limitations are properly presented in Table'5.1.)

o Section 5.3.2.3., page 5-7 and 5-8. Discussions should include assessments of the impact of continuous chlorination for Asiatic clam control on concentrations of chlorine released as well as time of detectable discharge of total residual chlorine (TRC).

This discussion should address one unit operation where dilution from the second unit is not available and assume a limit of detection of 0.03 mg/1.

NOISE The DEIS considered both'on-site generated noise and off-site transmission line noise impacts. On-site noise generators, based on model predictions, are expected to increase noise levels at receptor sites located at the perimeter of the facility from 1 to 12 dBA over ambient levels. None of the sites, however, are pre-dicted to experience noise levels exceeding 40 dBA. Using the composite noise rating versus community response scale (DEIS, Figure 5.23), Sites No. 5 and 6 would be expected to generate considerable community complaints based on noise level increases of 11 and 12 dBA, respectively. However, since no residential receptors are currently located near'these' sites, no noise impacts are expected.

One off-site residential receptor along the transmission line corridor is expected to experience noise level increases of 12 to 20 dBA over ambient levels. These noise level increases.are expected to be generated by the transmission line-during and for several hours after_ wet weather conditions. Because'of its hearing-frequency range and tonal nature, the expected 49 dBA L10:le' vel at the home site can be considered to be. equivalent to a 58-dBA level in terms of intrusion and annoyance. The magnitude of the noise' level increase and its intrusive nature may result in considerable annoyance, and we would consider it to be a significant ~ impact.- Therefore,~ feasible mitigation' measures for this residentiala site should be considered by the' applicant and the U.S. Nuclear-Regulatory Commission.

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