ML20148J812

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Responds to 780927 NRC Request for Info Re 3 Ma Sites Being Considered as Alternatives for Subj Facil.Gill & Erving Sites Had More Attention than Rowe,As Rowe Is Less Desirable from Water Availability Standpoint.W/Encl Documentation
ML20148J812
Person / Time
Site: New England Power
Issue date: 11/01/1978
From: Dailey E
MASSACHUSETTS, COMMONWEALTH OF
To: Ballard R
Office of Nuclear Reactor Regulation
References
NUDOCS 7811160126
Download: ML20148J812 (25)


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I g THE COMMONWEALTH OF MASSACHUSETTS b( ,,

7 iW ENERGY FACILITIES O &#

SITING COUNCIL L M/e d -

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MICHAEL S. DUKAKIS ##

GoVCRNoR C H RISTIN E B. S U LLIV A N CH AlH M AN Ronald L. Ballard, Chief dnvironmental Projects Branch 1 Division of Site Safety and Environmental Analysis U.S. Nuclear Regulatory Commission Washington, D.C. 20555 1 November 1978 Re: Docket Nos. STN 50-568 and 569 Mr. Ballard:

Thank you for your letter of 27 September requesting information about the three sites in Massachusetts being considered as alternatives for NEP 1 and 2. The Siting Council Staff appreciates the opportunity to assist NRC staff in its review of Rowe, Gill and Erving at this early stage in your process.

Attached is a brief report outlining some of the major resource characteristics of the three sites.

Highlighted are several possible environmental impacts which your staff may wish to focus on in your review.

As you will note in our report, most of our effort was directed toward the Gill and Erving sites rather than Rowe. Given the limited time period within which we were working and our judgement that Rowe appears to be a far less viable site from a water availability per-spective, we decided to devote more resources toward reviewing Gill and Erving.

e The research for this report was completed in two --

weeks and is, therefore, only a cursory review. We @

bk would also caution that the opinions expressed here are those of the Siting Council Staff and do not neces-sarily ref lect the thinking of the Siting Council.

If we can be of any further assistance, please contact Ma y Beth Gentleman of our staff.

~

\t EDW J. DAILEY O Di ector x 7811160lM #

Room 1413 One Ashburton Place Bo'ston, Massachusetts 02108 (617) 727-1136

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UNITED STATES'OF AMERICA' NUCLEAR REGULATORY COMMISSION

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In the Matter of )

) Docket Nos. STN 50-568 NEW ENGLAND POWER COMPANY, ) STN 50-569

_et _al. (NEP 1 and 2) )

~ RESPONSE TO REQUEST FOR INFORMATION CONCERNING ROWE, GILL, AND ERVING ALTERNATIVE SITES j i

l 1.0 Rowe. Site (Bear Swamp) 4 The Rowe site is located in the Deerfield River Basin,. adjacent to the Bear Swamp Pumped Storage Upper Reservoir and the Deerfield River at a point approxi- i mately three river miles downstream of the Bear Swamp Lower Reservoir (see map on next page). The Deerfield River is a tributary of the Connecticut River, flowing in from the west at a point approximately three river

! miles downstream of the Turners Falls Dam. The Rowe site is approximately twenty miles in a westerly direc- ,

tion from.the Turners Falls' Dam. This location suggests that the D'eerfield River would be the source of cooling water for a plant on that site. .

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-The Deerfield River is an extensively coordinated l

hydraulic' system.1 .Two upstream reservoirs (approxi -

mately 7.6 billion cubic feet of usable capacity 2).

regulate the flow in the river for the operation of a series.of automated, run-of-the-river hydro-electric plants (98.4 MW 3). In addition, the Bear Swamp Pumped Storage Facility (600 MW )4 .and the Yankee Rowe Nuclear Power Plant (175 MWS ) , which1is located approximately five river. miles upstream from the Bear Swamp Lower Reservoir, utilize the Deerfield River for power produc-tion purposes. The Siting Council is not aware of any major proposals for future water uses in the Deerfield  ;

1 Basin.

The' major water resource issue in locating a 2400 FM plant at the Rowe site would be flow availability.

1 Federal Power Commission, Connecticut River Basin, i December, 1976, pp. 3-15. l 2 U.S.G.S., Water Resources Data for-Massachusetts, e New Hampshire, Rhode Island, Vermont, 1970, p. 211.

1 3 Massachdsetts Electric Co., et al., Supplement 1B for the Ten Year Period 1977-1987 to the Long Range Fore- l cast filed with the Energy Facilities Siting Council. l l

4 Ibid. l 5 Ibid. l 1

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A U.S'.G.S. gaging station was established just down-stream of the Bear Swamp Lower. Reservoir in 1974, which is centered in a five mile reach of the'Deerfield River _

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likely'to include intake and discharge structures for this 2400 MW plant. This limited data source indicates a mean flow in the range of 500 to 1000 cfs and a mini- 1 mum flow in the range of 25 to 100 cfs. These estimated l

ranges are supported by data collected at the Charlemont gaging station, located approximately ten river miles downstream of the Bear Swamp Lower Reservoir Dam. An f

estimate of natural minimum flow on the order of 50 cfs i past the site can be obtained by using the .20 cfs per square mile of drainage area guideline developed for the l l

Connecticut River.6 Using the water use data for the proposed Montague Nuclear Power Plnnt (2300 MW) for illustrative purposes, l

! a natural draft cooling system at Rowe would require an > '

l average intake of 64.5 cfs and represent an average con-sumption of 51 cfs.7 These numbers indicate that 100 -

l 6 For a discussion ^of the standard see Environmental Research and Technology, Inc., Potential Impacts on the l Connecticut River of the Proposed Montague Nuclear Power.

Plant, Nov., 1977, prepared for the Energy Facilities Siting Council, pp. 2-40. This study has been submitted -

l to NRC in Docket Nos. 50-496, 50-497. - .

7 85.8 cfs intake, 68.6 cfs consump-Maximum values: l tion. Values from Monta_gue Final Environmental Statement, 1 l

NUREG-0084, February, 1977. 1

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.k' to 120-cfs would have to be provided continuously to the Rowe site just-to achieve the .20 cfs standard downstream-

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of the plant.- Consideration of entrainment, thermal, and other -localized flow problems could dictate a larger , min-imum flow requirement.

The river system operational changes necessary'to achieve such a continuous minimum flow would substantial-ly reduce the peaking power value of the conventional and pumped storage hydropower capacity installed in the basin.

The net effect would be a reduction in the energy benefits

> achieved by constructing the plant at the Rowe site.

Based!.upon what appears to be a significant lack of water at the site,'our Staff has concluded that Bear Swamp is neither viable nor desirable as a site for twin units in the 2400 MW range. Facilities of that size, in general, will be difficult to site inland in Massachusetts due to the present high rate of utilization of the region's ._

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rivers. Smaller facilities or plants which require less ,

water for make-up and cooling would be more consistent with the water resources available inland in this state.

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2.0 ' Gill and;Erving The map on the following page shows the location of the Gill and Erving sites on the Connecticut River.'

Given.their close proximity, they have many environ-mental similarities'. - Therefore, several of the analy-ses which follow treat both sites jointly.

The' environmental-impact areas discussed below include the following:

- water resources, including impacts on existing hydropower facilities

- water quality

- fisheries, including impacts on the shortnosed sturgeon,-an' endangered species

- terrestrial

- land use

- visual-

- socioeconomic

- transmission lines

- public health.

2.1 Water Resources The: Gill and Erving sites border on the Turners Falls Pool _section of the Connecticut River. This body g of wat'er would be the most likely source of cooling water .

for; a' plant at' either site. Being located in essentially i 4

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the same portion of the Turners Falls; Pool, these sites -

will incur water resource impacts c f a very lsimilar nature. Therefore, the observations below apply to a.

both sites. [l The-flow of-the Connecticut River in the Turners I

Falls Pool isaffected by several; factors. The outflow of the pool (average discharge = 11,670 cfs8 ) is regu-lated by the Turners Falls Dam and the operation of its associated hydroelectric facilities. The Millers River (average discharge = 610 cfs9) is the only major tribu-tary flowing directly into the Turners Falls Pool,'en-tering at a location just downstream of the Gill /Erving sites. The Northfield Mountain Pumped Storage Facility _

(1000 MW installed . capacity) uses the Turners Falls Pool L

P as its lower reservoir, with the intake / discharge facil-ity located on the east bank, directly upstream from the Erving site and directly across from the Gill site. _ :_

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-j The upstream inflow is regulated by several reservoirs ..

r with a combined usable capacity of about thirty-five billion cubic feet.10 The primary use of the mainstream -

8 U.S.G.S., Water Resources Data for Massachusetts, '

New Hampshire, Rhode Island, Vermont, 1970, p. 178 _.

9 Ibid.,.p. 177.

10 Ibid., p. 17's.

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reservoirs is for. hydropower production (approximately 380 MW installed capacity). .The reservoirs on the tributaries are operated for flood control, and to a 1

lesser extent, power, water supply ani. recreation. ..

There'are two major water resource-related pro-jects.which are proposed for the region. One involves the diversion of Connecticut River water to Quabbin Reservoir. The Quabbin diversion plan would skim the spring floods of the Connecticut, utilizing the North- l l

field Mountain Pumped Storage facility as a means for l 1

diverting;this water.12 l

The other major proposal is the 2300 MW Montague j l

Nuclear Power Plant. As proposed, this facility would r.

have its intake and discharge facilities located in the Holyoke Pool (approximately four river miles below the Turners Falls Dam). However, potential impacts -

- " -l from that plant on the shortnosed sturgeon population 1

(an endangered species) within the Holyoke Pool may i.

I require'the selection of an alternative intake location. - _

i 11 -Environmental Research, Potential Impacts, op. -

cit., p. 2-3, Table 2.3-1.

12 For more information concerning this project, see Army Corps of Engineers, Final Environmental State- g ment, Northfield Mountain and Millers River Diversion

~

August, 1976 and the-paper enclosed with this report entitled "Brief Description of Northfield Water Supply Project." See also the enclosed Metropolitan District Commission brochure on the significance of this pro-ject with respect to provision of potable water for . .

. major' portions of'the state.

m 10 -

The Horse Race area'of the Turners Falls Pool is one possible alternative.13 In addition to these proposed projects, an ongoing - -

program to reestablish anadromous fish runs in the Con-necticut River will' include requirements for low flow augmentation. For this purpose, the Federal Energy Regulatory Commission plans to include in future Connec-ticut River hydropower licenses a requirement that the plants' pass, at all times, a minimum flow equivalent to

.20 cfs per square mile of drainage area. This formula _

translates into a minimum release of 1430 cfs at the Turners Falls Dam, which Western Massachusetts Electric Company intends to implement in the event that Montague .

Nuclear Power Plant becomes operational.15 Tne major water resource issues associated with -

the Gill /Erving sites will be very similar to those identified for the'Montague proposal because the plant ;c ,.:1 ci designs and locations, as currently discussed, are very ..

similar. A detailed discussion of many of these issues can be found'in a report prepared for the Siting Council 13 Environmental Research and Technology, Potential '

Impacts, op. cit., p. S-18. _ _

14 Ibid., p. 2-40.

15 Ibid., p. 6-1.

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1 entitled Potential Impacts on the Connecticut River of the Proposed Montague Nuclear Power Plant, a copy of which is enclosed. Sections of particular importance within that report and errata sheet are indicated by asterisks. '

l The consumptive use of a plant of this size may introduce significant additional operating constraints during periods of low flow for the purpose of meeting minimum release requirements at.the Turners Falls Dam.16 The proximity of the Gill /Erving intake to the North-field Pumped Storage intake (and possibly the Montague Nuclear Power Plant intake) may create significant en- ..

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trainment, recirculation and other localized flow pro-  :: :__ -

blems. These issues will be of major importance in the event that a 2400 MW plant is proposed in either Gill or Erving.

2.2 Water Quality Impacts .

The major potential environmental impacts of i intake-discharge structures associated with a nuclear power plant sited on a pool along the Connecticut River affect water quality and' fisheries. For example, during <

t low-flow periods, the proposed Montague Nuclear Plant -

_ _ ._q 16 U.S. NRC, Montague FES, op. cit.

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- - -l would increase the concentration of total. dissolved solids between Turners Falls and the Holyoke Dam by 40%. Further- . i more, based on literature values of-lethal' concentrations .. . .:

of copper for rainbow trout, EPA (1976) water quality criteria for copper (Massachusetts' future standards) are -

already being exceeded at times in-the Holyoke Pool. In the event that the Montague Nuclear Station commences opera-tion as currently designed, the criteria will be violated all of the time if the present water quality (hardness) of the Connecticut River remains as it is today. If future ambient concentrations improve (decline), violations of l

the standards would occur at times due to the operation of Montague alone.17 -- -

Similarly, based on the values for rainbow trout, ambient concentrations of zine exceed the criteria at - .-

I all times. If the ambient concentration of zinc were  : _ _

negligible, there would also be violations due to the operation of Montague alone. Before definite conclu-sions about th'e. impact of copper and zinc are drawn, r_-.- -

however, bioassays of the connecticut River must be nr.u v completed to determine if the literature values are representative of the Connecticut. .

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~, 17 Environmental Research and Technology, Potential -

Impacts, op. cit., p. 9-4. .

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l Heavy metals are also of special significance be- . l cause of their toxicity to aqu'atic life. Water quality -

data 18 indicate that ambient concentration; of heavy 1 1

metals in the' river at-times exceed criteria recommended --

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by EPA (1976) for cadmium.and mercury.

2.3 Fisheries Impacts The impacts on fish and other aquatic life i

in the Connecticut River include thermal, entrainment, _f  :

heavy metals, and flow regime. Of these, entrainment, a major impact has not been previously discussed. _ _.

Entrainment impacts associated with a nuclear power plant in the vicinity of the Holyoke and Turners Falls .. _

l pools are of major concern because of the number of u- ~ , .

species which spawn in or near these pools. The larvae  : -y l

i, of most species are planktonic and would be subject to -- -

entrainment.19 These include the economically-important . . . ., ._;

American shad and the endangered shortnosed sturgeon. ( _ 2726 Shad eggs, for example, do not settle to the bottom im- y;. ...: _

t mediately after spawning and may float up to five miles --

depending upon current conditions.

Further,'the Holyoke Pool may be considered a _

" critical habitat" for the shortnosed sturgeon according V

18. Ibid., p. 2-56-60.

19 Ibid., p. 6-31 i

7

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to the United' States Endangered Species Act of 1973 & - '

(P.L. 93-05).20 The shortnosed sturgeon. spawn demersal I eggs which are'not adhesive, and which could therefore~ ="-

1 pose a potential egg entrainment problem as the stur- ~

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geon larvae drift downstream as they mature.

1 After the new fish ladder now under construction l

at the Turners Falls Dam is completed (estimated for l

1981), shortnosed sturgeon may ascend to the Turners Falls Pool as well. This theory is supported by ob- l servations of sturgeon species ascending fish ladders  ::r .-

ir, California.21 -

The state fish and game agencies conduct costly -;

stocking programs throughout the Connecticut River and s- c:scr" its tributaries. In 1976, Massachusetts stocked approx-  :-- r--

imately 170,000 browns, brooks and rainbow trout of --

catchable size in the tributaries of the Connecticut - u_

River. The U.S. Fish and Wildlife Service conducts d. -

an extensive stocking program for Atlantic salmon.22 ,1 = __ ;,_L, A new-federal hatchery.is under construction upstream at Bethel, Vermont, at a cost of $5.3 million.

Fishways 20 , Ibid., p.

8-16.

. 21 Ibid., p.

8-17. '

_ Ibid., p. 2-37.

y .

1 operated by that federal program in cooperation with -...__.1 New England Power Company and Western Massachusetts - -l Electric Company range in cost from $1.2 million for - - -

the Holyoke Dam fish elevator to $10 million for the 1

vertical-slot fishways at Turners Falls' Dam.23 Sport l l

and commercial fishing (shad) is expected to increase __

.l 1

i in the future. l The combined effects on aquatic ecology of the Northfield Pumped Storage facility, the proposed Montague Nuclear Power Plant, and'a possible addi- . . _ __ ._ . . ;

1 tional facility at Gill or Erving are unknown but I merit careful assessment. The co nbination of entrain- . . .

ment plus increased concentrations of copper and --

heavy metals could result in harmful effects felt .

throughout the food chain. - el 2.4 Terrestrial Impacts .

< A brief site observation indicated that the eastern half of the Gill site is on a flood plain of E._

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the Connecticut River, about fifteen to twenty feet i

above the river (in late October) in unconsolidated glacial outwash. It is currently being used for pro- __

duction of corn and potatoes. The western portion of --

the site is a hilly, wooded area. _.

23 Ibid., p. 2.38.

- If-the. plant were-sited in the eastern section, we would anticipate that special construction proce- ---

dures would be used as generally required for build- r- - -

ing on flood plains or any' unconsolidated materials.24 The Erving site, which includes sections of both the towns of Erving and Northfield, is mainly hilly and: wooded, with some flatter ' land in the southern portion'of the site. A major-transmission line, which -

spans the Connecticut River, traverses the site's southern section. _.

Outcrops identified on the Gill and Erving sites --

include well-indurated feldspathic sandstone (arkose),

a pebble conglomerate, a schist (Joshua), and a gneiss - - _ :--

(Poplar Mountain). '

We urge the NRC staff to consider the impacts, if -

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any, which drilling and blasting at either site would have on the Northfield Mountain Pumped Storage Facility .' __

and its associated underground tunnels. Gneisses and --- _.__

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schists are often friable and fissile and have been

- - ~ ~ ~ ~ ~

known to separate along micaceous zones. The excava-24 ~

For more information concerning Massachusetts wetlands restrictions, contact the Water Resources -

Division of the Department of Environmental Management -

and the Wetlands Division of the Department of Environ- ' " '

mental Quality Engineering. See G.L.c. 131 SS40, 40A. -

tions in the bedrock at Northfield Mountainare currently .__1 2 held together to a great extent by pin bolts and metal  :-

plates which are commonly-used mining techniques for fri-  : .= _f;.

able and' fissile rock. In the event that either site were chosen, preventive measures would have to be taken to prevent cave-ins and dislocations throughout the.

Northfield Project area.

2.5 Land Use Impacts-Use of the Gill site for a power plant would result in taking agricultural land out of production. _ . .

Gill's " Local Growth Policy Statement", a copy of which is-enclosed, indicates that the town considers loss of - _ _ _ _

farmland to be a problem which.it is attempting to con- _ 22 .2 _ _.

trol. In the:early 1970's, the creation of a state park __

(Grassy. Hill State Park) on the Gill site was opposed, in part, because it would have entailed the-loss of agricultural land.25 . .

I With respect to the Erving site, the Town of Erving is currently researching the feasibility of establishing

j. -

r an industrial park on land' adjacent to the southern u _ _ _

' boundary line'of the site. As part of its planning effort, the town has asked NEPCO about the availability __ _. .

.25 For'information on the status of that proposal, contact the Forest and Parks Division of the Department - --

of Environmental Management.

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.l 1 aof about twenty acres of the Erving site which abut the _.

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park site. NEPCO has indicated that the land may be . _ ._

available, but further discussion of the matter will be _ - _ _ . .__4 1

needed. At present, Erving is searching for funding to .. -

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i assist with the park' development costs, particularly the  !

cost of getting' water to the site. Because of the un- j l

certainty with funding, the town has no firm timetable  ;

I for the establishment of the park. l l

2.6 Visual Impact t I

i The Gill and Erving sites are located within j i

ten miles of fourteen state forests and parks utilized _j I

year-round for fishing, hiking, hunting, snowmobiling j l

and skiing. Both sites are within the viewshed of the -

j Mohawk Trail (Route 2) which is a designated tourist f route. The photo on the next page shows a view of the ~. .

two sites from the Mohawk Trail as one crosses the cm - ._ t 1

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-- Connecticut River over'the French King Bridge. 0.____::q Due to the nature of the region, the contour of l i

% the land, and the location of the Mohawk Trail, it is - ame _owj our opinion that a plant at either site would have a ---

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significant adverse visual impact on the region. Re- --

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gardless of whether natural draft or circular mechani- .-_ _ . a cal draft towers were to be installed, the facility

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use of natural draft towers would extend the viewshed _m _

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distance even further into the surrounding region and may_ constitute an unacceptable visual impact.

We urge the staff to'assers the social and economic impacts' associated with the visual impact which a plant at either site would create. While tourism does not -

dominate the economic base of Franklin County, in recent years it has been one of the few growth industries in _ _ .

the region. Therefore, it is critical that a rigorous - -.

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visual impact assessment be done to ascertain the extent to which tourism may be affected by siting a plant in the Mohawk Trail viewshed.26 --,,_,n 2.7 Socioeconomic Impacts c. ,

The property tax structure of Massachusetts is such that all property tax revenues from power plants go to the host town. Some further distribution of revenues _ __ e occurs via county tax payments by the host town, but  : c. __ _ c ,

that tends to involve only a small fraction of the tax T;r. .  : :

revenues from the plant.

6 The NRC staff will notice on site visit that while part of the Northfield Mountain facility is lo- . _. ,

cated.at the same point of the river, it is not visi- .:

ble-from the Mohawk Trail. . . _ ,

27 In the event that the Erving site is selected, the. tax distribution situation will be more complex 4 because that site spans sections of two_ towns, Erving and Northfield.

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As a result of this narrow distribution.of tax bene- . .

fits, the county and the municipalities surrounding the - - -

host town receive little direct benefit from the plant, despite the fact that they may have to bear costs tradi- .I tionally associated with large influxes of workers into a -.  : _ i region.28 The degree to which the neighboring towns are q l

impacted is, of course, a function of the extent to which -

._ l l

the construction force must inmigrate instead of commute. l l

l The rate of commutation, in turn, is a function of the size of the available labor pool within commuting distance _

of the project.

In calculating the extent of inmigration which con-struction of a plant at the Gill or Erving sites would 7 c ~ .. _ __ ;

entail, we urge the staff to consider the possibility i

that one or two other major construction projects may  : - . 1.

be occurring simultaneously in the region, namely the __ . .

5'

!-- _ . Quabbin Water Diversion and/or the Montague Nuclear Power __=>---

Plant. If either one of these projects were under con-

_ struction at the same time that units were being built - u m_ __

It in Gill or Erving, we would anticipate a much higher rate .: < m_2.

28 A complete discussion of our view of the problem of cost dissociations over space and time can be found c in Section 3.3.2 of the enclosed staff document entitled -

"EFSC Staff Review and Findings: Northeast Nuclear Energy _

Company's Socioecor.omic Impact Analysis of the Proposed - - - -

.- Montague Nuclear Station." This study has been filed in ._ _

Docket Nos. 50-406, 50-497.

- ~ - a ;. .=..n.-...

4.r 4

of inmigration into the region due to the finite amount. --

of available labor within'the commuter shed.

Unusually low vacancy rates in housing, part-time -

town governments, and strained town budgets in the region indicate that, in general, the capacity of the In l area to absorb a large influx of workers is poor. -

the event that two or more major construction projects were planned to be underway simultaneously, somewhat complex mitigation agreements should be required of the l

applicants to protect the county and neighboring towns - - -I from fiscal loss and undesirable changes in their quality ,

l of life. _. .{

2.8 Transmission Line Impacts .-

l The suitability of the Gill and Erving sites ] i 1

would, in part, be contingent upon the' acceptability of the impacts of the transmission lines required. Enclosed , , .,

I is a document entitled "High Voltage Transmission Facili- ,

my ties, Informational Requirements for Proposed Facilities" r;,21 , a which details the factors which we believe should be considered in evaluating transmission lines, l

At the alternative sites level of_ review, our staff _

would be particularly interested in knowing the length ,

and width of new rights-of-way required, the terrestrial _ . _ _ ,,

and visual impacts anticipated, and the location of the

.. l

. load center to be served. All of those factors were con- ...;;; r sidered in our review of the ninety-mile transmission - - - , - - -

line proposed with the Montague Nuclear Station, and we -

-q would anticipate.doing a similar review for any-facilities --

2

-i proposed at either Gill or_Erving.

2.9 Public Health Impacts .

A final area of concern, one over which the Siting Council has no jurisdiction, is the potential for public health impacts and increased risk which a concen-tration of nuclear facilities may pose to the region. 1-The area already hosts one 175 MW nuclear plant in Rowe, +- -

which lies twenty-one miles west north west of the Gill / . . _ _ _ . _ _.q Erving sites, and another 540 MW nuclear station in u rr.

Vernon, Vermont, only fourteen miles north of the sites. .f.

An additional- 2300 MW station is proposed for Montague .

Plains, about three miles away in a southwesterly direc-tion. The possibility of yet another 2400 MW station in - -

the same region naturally raises some questions as.to e, x--4 j

the synergistic impact that the sum of these units may .-

have on the health of the area residents and the risk - - -

that that number of units poses.

. We urge the' staff to clearly address this issue in . . .

the.DEIS, outlining the' risks associated with plant ,

operation, decommissioning, and on-site waste storage.

--___ _ __m _1_____L_____________~ _ _ . _ _

- .1. .::4 .'

The residents of the area will need an accurate assess- .

ment of the synergistic risks involved in order to par-ticipate, in an informed manner

, in.the NEPA process.

,-_=