ML20127G996

Forwards Comments from Dept of Interior Re Draft Environ Statement for Review & Response

ML20127G996
Person / Time
Site:	Monticello
Issue date:	09/06/1972
From:	Muller D US ATOMIC ENERGY COMMISSION (AEC)
To:	Dienhart A NORTHERN STATES POWER CO.
References
NUDOCS 9211180355
Download: ML20127G996 (6)

Text

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EP-3 File Docket No. 50-263 RP R/F SEP 6 672 Driuller, L:EP JGallo, 00C j

Northern States Power Company f:0R 3

ATIW: Mr. Arthur V. Dieshort DZiemann, L:OR 5

Tise President, Engineering RBevan L EP-3 I

'I' IIII*t M*II GWilli ms, L'EP-3 Mimocepolis, Minneesta 55401 GentlememI 5

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i As specified in the Coumeil en Bavironmental Quality Guidelines, we how requested Federal, State, and local agencies to cosement in soomection with the Draft Enviroemental Statement for the Hooticello Muclear Gener-ating Plant.

The encleeure to this letter contains comuments from the United States Department of the interior dated August 24, 1972 Flosse review these commsents and submit any respcases you deem appropriate by September 14, 1972. Your reply should consist of three signed origi-nals and 40 additional copies.

Sincerely, Original signeo of Sonial R. Muller D. R. Muller, Assistant Director 9211180355 720906 for Environmental Projects PDR ADOCK 05000263 Directorate of Licensing D

PDR Raciosure:

DOI ltr dtd 8/24/72 cc: w/enel Mr. 5. C. Ward, Direeter p

Engineering Vice Presidential Staff '

g Northern States Poser Sampany

,f 414 Dise11et Mall Niassapelis, Minnesota 35401

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OFFICE OF THE SECRETARY AUG 251972>

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Dear Mr. Munt ing:

This is in response to Mr. Muller's letter of May.26, 1972, requesting our comments on the Atomic Energy Commission's draft statement, dated May 1972, on environ-mental considerations for Monticello Nuc1 car Generating Plant, Unit No. 1, Wright County, Minnesota.

General The Geological Survey of this Department made a safety-oriented review of geologic and hydrologic aspects of the site for the Atomic Energy Commission in 1967.

Comments in regard to this Department's responsibilities under the Fish and Wildlife Coordination Act were expressed in the former Commissioner of the Fish and Wildlife Service letter dated February 23, 1967, and the Secretary of the

' Interior letter dated April 4, 1969.

The Department did not object to construction and operation of the project because the applicant provided assurance that it would conduct the necessary radiological and environmental monitoring and other studies and maintain sufficient flexibility in project operations to adequately protect environmental values.

We commend the applicant for its early decision to

. construct and operate cooling' towers to minimize adverse impacts, for its environmental concern as evidenced by efforts being directed toward' ongoing monitorir.g studies, and for its cooperative spirit in working with this Department in solving past environmental problems asso-ciated with this project.

We are confident that through continuing joint efforts, unforeseen problems that-may develop will be solved to the satisfaction of all parties.

Our comments on specific-subjects are presented in the following paragraphs according to the format of the statement or according to specific subjects.

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s Ecology of Site and Environs i

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It is mentioned on page II-13 that 100 of approximately 220 acres are being allowed to return to native vegetation or planted with conifers.

For esthetic and possibic pathogenic reasons, we do not recommend that pines bc planted on this area ?,,cause of the possibility of.the high water table which eventually leads to slow growing o'r diseased pine trees.

If pine trees are planted on 1

the site, it is recommended that they be planted only

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on well-drained soils.

1 Transmission Lines j

i A'ecording to page III-1 the transmission line routings attempted to avoid active farm areas and where possibic,

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municipalities, county parks, and recreational, natural scenic and historic areas.-

In order to adequately assess the environmental impact of the transmission lines, we b'elieve that the statement should address itself to clucidating this statement.

This additional discussion i

could be in the form of a discussion with maps and illus-trations showing the location of-recreational, natural scenic and historic areas ' traversed by the transmission lines, particularly for the historic landmarks listed o'n page II-51 and the wildlife areas shown in Figure 1-1 of the applicant's environmental report dated November 3, 1971.

If no historic, scenic, county parks or recreational l

areas are traversed by the transmission lines, it should I

be so stated.

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Wesuggestthattheapplicant!makeprovisionsforvildlife l

management including public access for hunting to the extent compatible with project purposes.

Also, since J

herbicides, Tordon 155, will be used, the publication entitled, " Chemical Vegetatiop Control Manual for Fish Programs," issued in January 1968 and Wildlife Management l

as Resource Publication 48 by the Bureau of Sport Fisheries l

and Wildlife, should be consulted for policy on the use of posticides, herbicides, and related chemicals.

This publication should also bc referenced in the statement.

Chemical and Sanitary Wastes i

Although the average residual chlorine concentration in the discharge canal-is less than 0.05 ppm, it is about 10 times that amount for short durations.

Generally, we 2

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l think that a maximum residual chlorine concentration of 1

more than 0.1 ppm snould not take place anc that chlorine should be completely climinated if possible.

It has been found that concentrations of 0.03 ppm are toxic to some j

aquatic organisms.

The statement should discuss changes in methods of operation or structural design that could 1

be employed to climinate chlorine from the effluent.

Cooling Tower Drift The statement does not include a discussion of the dissolved 1

j solids which would be carried from the tower in the drift.

Sbch solids could cause offsite deposition and corrosion i

j problems; therefore, an estimate should be included in the report as to the amount of solids which may be contained l

j in the drift, and reference should be made to procedures to be followed in minimizing their environmental impact.

j Land Use We suggest that consideration be given to a fish and wildlife management and public use plan for Thompson Island and the remainder of the 1,325-acre project site to assure maximum use of project lands and waters to the extent compatible with project purposes.

Water Use The thermal effects on the Mississippi River of the various modes of condenser cooling have been predicted in the statement.

Since accurate prddictions of this type are difficult, a detailed temperature monitoring. program of the river beginning at the plant and extending several i

miles downstream should be inittiated so that the type of cooling system operation to be, selected for various j

temperature and discharge conditions may be based on accurate data.

l Effects of Intake Structure We do not think that material that collects on the screens, such as debris, fish, and other accumulations should be washed from the screens and returned directly to the river.

In order to. minimize degradation of the river water, it is suggested that these accumulations be handled I

as noncontaminated solid wastes, and the method of disposal described in the report.

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Environmental Impact of Postulated Accidents i

This section contains an adequate evaluation of impacts i

resulting from accidents through Clasu 8 for airborne j

emissions.

However, the environmental effects of releases 1

to water are lacking.

Many of these postulated accidents i

listed in tables VI-1 and VI-2 could result in releases to the Mississippi River and should be evaluated in detail.

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l We also think that Class 9 accidents resulting in both air 4

and water releases should be described and the impact on i

human life and the remaining environment discussed as long i

as there is any possibility of occurrence.

The conse-quences of an accident ot this severity could have far-reaching effects on land and in the Mississippi River i

which could persist for centuries.

1 The subject of transportation accidents is discussed extensively, but little mention is made of the means for i

handling spills of low-1cyc1 wastes.

It is suggested that emergency procedures be developed for maximum containment of low-level wastes,-as well as minimized personnel con-l tamination under the circumstances where a severe accident might occur and result in spillage of such low-level wastes.

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Adverse Effects Which Cannot be Avoided This section should discuss the extent and type of wildlife i

and the loss in animal populations due to project con-struction and operation.

i Short-Term Uses and Lonn-Term' Productivity i

i i

Short-term uses of the land and water should be compared to the plant's operational impact on the long-term productivity of fish and wildlife.

Irreversible and Irretrievable Commitment-of Resources i

4 According to page IX-1, if the reactor is dismantled at j

the end of its useful life, some land would be required to permanently store _ highly radioactive structural com-ponents of the reactor facilities as well as other

- radioactive wastes.

The Monticello site, on the flood plain of the-Mississippi River, would be a particularly unsuitable location for the burial of highly radioactive materials, particularly if they contain long lived 8

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These burial materials would be exposed radionuclides.

i to ground water which could become contaminated, and also to flooding and possibly crosion.

Monitoring would be required for an indefinitely long ceriod of time.

1 If permanent burial of radioactive materials at this site l

is a possibility, the environmental consequences should be considered at this time.

This section should also describe the fish and wildlife i

zesources lost annually because of the project construction and operation.

Resources foregonc are generally irre-trievabic for all practical purposes.

We hope these comments will be helpful in the preparation of the final environmental statement.

Sincerely yours) j i

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Deputy 1.ssistant Secretary of the In erior f

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.Mr. L. Manning Munt:ing Director of Regulation U. S. Atomic Energy Commission Washington, D. C.

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UNITED STATES F2.\\.)g'S ATOMIC ENERGY COMMISSION l'f3*L WASHINGTON, D.C. 20S45

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Docket No. 50-263

$i,? 6N Northern States Power Company ATTN:

Mr. Arthur V. Dienhart Vice President, Engineering

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414 Nicollet Mall Minneapolis, Minnesota 55401 Gentlemen:

As specified in the Council on Environmental Quality Guidelines, we have requested Federal, State, and local agencies to comment in connection 1

with the Draft Environmental Statement for the Monticello Nuclear Gener-ating Plant.

The enclosure to this letter contains comments from the United States.

Department of the Interior dated August 24, 1972.

Please review these comments and submit any responses you deem appropriate by September 14, 1972. Your reply should consist of three signed origi-nals and 40 additional copics.

Sincerely, y

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i D. R. Muller, Assistant Director for Environmental Projects Directorate of Licensing i

Enclosure:

DOI ltr dtd 8/24/72 cc: w/ enc 1 Mr. E. C. Ward, Director Engineering Vice Presidential Staff Northern States Power Company 414 Nicollet Mall Minneapolis, Minnesota 55401 Mr. Gerald Charnoff Shaw, Pittman, Potts, Trowbridge 6; Madden 910 17th Street, N. W.

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United States Department of the Interior g[\\{)

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t..g. :...r y ER-72/055 g.g g 4 g 50-263 1

Dear Mr. Munt ing:

l This is in response to Mr. Muller's letter of May 26, 1972, requesting our comments on the Atomic Energy Commission's draft statement, dated May 1972, on environ-mental considerations for Monticello Nuclear Generating Plant, Unit No. 1, Wright County, Minnesota.

J l

General The Geological Survey of this Department made a safety-oriented review of geologic and hydrologic aspects of the site for the Atomic Energy Commission in 1967.

Comments in regard to this Department's recponsibilities under the Fish and Wildlife Coordination Act were expressed in the former Commissioner of the Fish and Wildlife Service letter dated February 23, 1967, and the Secretary of the

" Interior letter dated April 4, 1969.

The Department did not object to construction and operation of the project because the applicant provided assurance that it would conduct the necessary radiological and environmental monitoring and other studies and maintain sufficient ficxibility in project operations to adequately protect environmental values.

We commend the applicant for its early decision to 3

construct and operate cooling' towers to minimize adverse impacts, for its environmental concern as evidenced by ef forts being directed toward' ongoing monitoring studies, and for its cooperative spirit in working with this Department in solving past environmental problems asso-l ciated with this project.

We are confident that through continuing joint efforts, unforeseen problems that may develop will be solved to the satisfaction of all parties.

i

)

i Our comments on specific subjects are presented in the following paragraphs according to the format of the statement or-according to specific subjects, i

4692 f

Ecology of Site and Environs It is mentioned on page Il-13 that 100 of approximately 220 acres are being allowed to return to native vegetation or plcnted with conifers.

For esthetic and possible pathogenic reasons, we do not recommend that pines be planted on this area because of the possibility of the high water table which eventually leads to slow growing

,l or diseased pine trees.

If pine trees are planted on the site, it is recommended that they be planted only on well-drained soils.

Transmission Lines A'ecording to page III-1 the transmission line routings i

attempted to avoid active farm areas and where possible, municipalities, county parks, and recreational, natural scenic and historic areas.

In order to adequately assess the environmental impact of the transmission lines, we b'elieve that the statement should address itself to e'lucidating this statement.

This additional discussion could be in the form of a discussion with maps and illus-trations showing the location of recreational, natural scenic and historic areas traversed by the transmission

~

lines, particularly for the historic 1andmarks listed on page 11-51 and the wildlife areas shown in Figure 1-1 of the applicant's environmental report dated November 3, 1971.

If no historic, scenic, county parks or recreational areas are traversed by the transmission lines, it should be so stated.

We suggest that the applicant make provisions for wildlife management including public access for hunting to the extent compatible with project purposes.

Also, since

-herbicides, Tordon 155, will be used, the publication entitled, " Chemical Vegetation Control Manual for Fish and Wildlife Management Programs," issued in January 196 6 as Resource Publication 48 by the Bureau of Sport Fisheries and Wildlife, should be consulted for policy on the use of pesticides, herbicides, and related chemicals.

This publication should also be referenced in the statement.

Chemical and Sanitary Wastes Although the average residual chlorine concentration in the discharge canal is less than 0.05 ppm, it is about 10 times that amount for short durations.

Generally, we l

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s

I

'p w

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think that a maximum residual chlorine concentration of d

more than 0.1 ppm should not take place ano that chlorine.

i should be completely climinated if possible.

It has been found that concentrations of 0.03 ppm are toxic to some aquatic organisms.

The statement should discuss changes in methods of operation or structural design that could be employed to eliminate chlorine'from the effluent.

Cooling Tower Drift J

The statement does not include a discussion of the. dissolved

)

l solids which would be carried from the tower in the drift.

Such solids could cause offsite deposition and corrosion 4

problems; therefore, an estimate should be included in the report as to the amount of solids which may be contained in the drift, and reference should be made to procedures j;

to-be followed in minimizing their environmental impact.

)

Land Use W6 suggest that consideration.be given to a fish and wildlife management and public use plan for Thompson Island and the remainder of the 1,325-acre project site to assure maximum use of project lands and waters to the 1

extent compatible with project purposes.

t Water Use The thermal effects on the Mississippi River of the various modes of condenser cooling have been predicted in the statement.

Since accurate predictions of this type are difficult, a detailed temperature monitoring progrma of i

the river beginning at the plant and extending several j

miles downstream should be initiated so that the type of cooling system operation to be, selected for various temperature and discharge conditions may be based on t

accurate data.

Effects of Intake Structure I

We do not think that material.that collects on the ccreens, i

such as debris,. fish, and other accumulations should be

~

washed from the screens and returned directly to the river.

In order to minimize degradation of the river water, it is suggested that these accumulations be' handled ac noncontaminated solid wastes, and the method of disposal described in the report.

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~...

t

)

'I 4

Environmental Impact of Postulated Accidents

~

This section contains an adequate evaluation of impacts resulting from accidents through Class 8 for airborne emissions.

However, the environmental effects of releases to water are lacking.

Many of these postulated accidents listed in tables VI-1 and VI-2 could result in releases 4

to the Mississippi River and should be evaluated in detail.

We also think that Class 9 accidents resulting in both air and water releases should be described and the impact on human life and the remaining environment discussed as long as there is any possibility of occurrence.

The conse-quences of an accident ot this severity could have far-reaching effects on land and in the Mississippi River which could persist for centuries.

The subject of transportation accidents is discussed extensively, but little mention is made of the means for handling spills of low-level wastes.

It is suggested that emergency procedures be developed for maximum containment of low-level wastes, as well as minimized personnel con-tamination under the circumstances where a severe accident might occur and result in spillage of such low-level wastes.

Adverse Effects Which Cannot be Avoided This section should discuss the extent and type of wildlife and the loss in animal populations due to project con-struction and operation.

Short-Term Uses and Long-Term Productivity Short-term uses of the land and water should be compared to the plant's operational impact on the long-term productivity of fish and wildlife.

Irreversible and Irretrievable Commitment of Resources According to page IX-1, if the reactor is dismantled at the end of its useful life, some land would be required to permanently store highly radioactive structural com-ponents of the reactor facilities as well as other radioactive wastes.

The Monticello site, on the flood plain of the Mississippi River, would be a particularly unsuitable location for the burial of highly radioactive materials, particularly if they contain long lived 4

_