ML20150E017
| ML20150E017 | |
| Person / Time | |
|---|---|
| Site: | Atlantic Nuclear Power Plant  |
| Issue date: | 11/30/1978 |
| From: | Roisman A National Resources Defense Council |
| To: | |
| Shared Package | |
| ML20150E009 | List: |
| References | |
| NUDOCS 7812110074 | |
| Download: ML20150E017 (32) | |
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N. 8 / UNITED STATES OF AMERICA g/ 7' q't. NUCLEAR REGULATORY COMMISSION r;C (G, , -,
\J ,e Before the Atomic Safety and Licensing Appeal Board > C' , v f*;h' C',j . # ir" Q0 s f In the Matter of : , i ,3 , , ""1,4 OFFSHORE POWER SYSTEMS Docket No. STN 50-437 (Manufacturing License for :
Floating Nuclear Power Plants) : NATURAL RESOURCES DEFENSE COUNCIL REQUEET FOR DIRECTED CERTIFICATION As the Appeal Board is aware, this proceeding is essentially suspended pending resolution by the Commission of the issues raised in ALAB-489 and ALAB-500. During this suspension period, NRDC seen .o resolve the legality of the ASLB decision rejecting as a challenge to the NRC regulations the following contention: The Staff has failed to find any even potentially acceptable estuarine or riverine site for an FNP, has identified serious real problems with such sites, has been advised by EPA that no estuarine, riverine or barrier
, island sites would be acceptable for an FNP and has therefore insufficient basis for concluding that the FNPs can with reasonable assurance be sited at shoreline sites. In effect, the Staff has attempted to justify a programmatic and generic finding of accept-ability without having sufficient evidence upon which to base that finding -- a program-matic conclusion without programmatic findings.
The following provide the bases for this and in all but one instance contain detailed reference to defects in the draft FES Addendum II, which, regrettably, were not corrected er modified in any significant way in the final FES Addendum II:
- 1. NRDC Comments on Draft Addendum to FES Part II (4/27/78), including the June 9, 1978, letter to Mr.
Knighton; 7812110Oli
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- 2. Letter to Knighton from EPA dated May 1, 1978, pp. 1-2;
- 3. Letter to Knighton from EPA dated May 8, 1978, and attachment thereto (pp. 1-2);
;, 4. Letter to Knighton from EPA dated July 5, 1978, pp. 1-2;
- 5. State of New Jersey Coastal Management Program - Bay and Ocean Shore Segment (May 1978), Draft Environmental Impact Statement (United States Department of Commerce (NOAA - Office of Coastal Zone Management)) - Section 7.4 (Energy Use Policies), Subsection 7.4.13, pp. 145-46.
If a license is issued and this contention is eventually determined to be admissible, it will necessitate a re-opened hearing and either a stay of the manufacturing license (an allegedly substan-tial detriment to Applicant) or the license will continue thus increasing sunk costs and making a final cost / benefit balance less likely to result in denial of the license. NRDC sought Irom the licensing board a request for reconsid-eration or alternatively an order of certification with respect to its denial of the NRDC contention. That request was denied by order of the licensing board filed November 13, 1978. The questions to be certified, which are intended to raise the validity of the denial of the contention, are set forth on p. 5 of our September 15, 1978, Request for Reconsideration Or In The Alterna-tive For Certification. A copy of those questions is Attachment H A to this brief. I l
l 3 I. The NRDC Contention Should ' l Be Admitted The NRDC contention has its origin in the fact that OPS has
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sought permission to manufacture floating nuclear plants (FNPs) for siting either offshore or inshore at estuarine, riverine and barrier island sites. The Staff in FES II has concluded that (Final Addendum to Final Environmental StaSement,'Part II, NUREG-0056, p. viii): the eight floating nuclear power plants proposed for manufacture,can, with a reason-
- ~ able degree of assurance;, be sited and operated as electric generating stations at offshore or shoreline sites.
The Environmental Protection Agency has advised the NRC that (letter of May 8, 1978, to George W. Knighton, NRC, from Joseph M. McCabe, EPA, p. 2 of enclosed commenus): The five EPA Regional Offices having jurisdiction for the ent'.re Atlantic cnd Gulf Coast areas have stated that the potential estuarine and barrier island sites located in their regions would net be environmentally acceptable sites. Our regional offices have indicated that future EIS's prepared for specific FNP sites in their appropriate regions will be determined unsatisfactory from the standpoint of environmental quality should estuarine or barrier island locations be proposed. In conclusion, and in view of EPA's Section 404 (b) and Section 316 (a) and (b) criteria under the clean Water Act, we believe the fundamental technical and procedural problems associated with siting FNP's in estuaries are too difficult to overcome. 1/ The document quoted above and three other EPA letters address-ing in part the same subject are Attachment B to this request. The August 11, 1978, letter (p. 2) extends EPA opposition to inshore siting to include riverine sites.
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4 Thus the issue presented is whether it is permissible for the NRC to make a finding at this time approving the hypothetical siting of FNPs at some inshore site and use the alleged benefits of such siting to justify approval of the manufacturing license. An option not pursued by the NRC but one which we urge is that approval for the manufacture of FNPs for certain, classes-of sites should be limited to the number of FNPs which it can now be reasonably assured will be able to be acceptably sited at such sites. Without such a limitation and as a result of the sunk cost rule, the manufactured FNPs could be approved for siting where the environmental disadvantages would be outweighed only by the presence of the sunk costs.
.- In this case the EPA judgment regarding the unacceptability of all estuarine, riverine or barrier island sites is a crucial determination. The EPA judgments in areas of their expertise are ac:orded special and binding effect by the NRC. Section 511(c) (2) of the Federal Water Pollution Control Act; Few England Coalition on Nuclear Power v. Nuclear Regulatorv Commission, F.2d 2/ In its November 13 Order, fn. 1, the ASLB missed the point of our argument. The existence of an already built FNP will be used by the NRC in the cost / benefit analysis for the proposed siting of l the FNP as a benefit which outweighs environmental disadvantages of the site. It will bias alternative site reviews also if the preferable alternate site is one at which a floating nuclear facility could not be sited but some other nuclear or central generating facility could be sited. If the hypothetical site concept, when coupled with the sunk cost doctrine, results in such early irretrievable commitment of resources, then the scheme of Appendix M to separate site review from manufacturing approval would fail because it would violate the NEPA mandate that a major irretrievable commitment of resources be preceded by a complete environmental analysis of the action being taken. Tnus to save the Appendix M scheme, it is necessary to read the term "hypothet-ical" to require that there be evidence that at least as many hypothetical sites as FNPs are reasonably expected to exist.
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5 (1st Cir. 1978). Although the EPA judgment is admittedly a generic one and made in the context of a policy statement by EPA, it is nonetheless required to be treated as hard evidence by the NRC. Northern States Power Co. et al., ALAB-455, 7 NRC 41, appeal pending in the U.S. Court of Appeals for the District of Columbia Circuit sub nom. State of Minnesota, By the Minn. Pollution Control Agency, et al. v. NRC, et al. (Nos. 78-1269 and 78-2032). Of course, for purposes of the admission of the NRDC con-tention, it is not necessary to prove that the contention will ultimately prevail. It is sufficient for the Board to find that the contention has been clearly articulated and has an articulated and rational basis. Mississippi Power and Licht (Grand Gulf), ALAB-130, 6 AEC 423, 426; Northern States Pcwer Co. (Prairie Island), CLI-73-12, 6 AEC 241, 242. Nonetheless the licensing board rejected the NRDC contention c.1 the merits without providing adequate opportunity for NRDC to brief the merits. See NRDC Motion For Leave To File A Response And For Extension Of Time (September 8, 1978), denied as moot October 6, 1978. The Licensing Board rejection of the contention is based upon the conclusion that it violates S 2.758 because Paragraph 3 of Appendix M to Part 50 contemplates an analysis of construction and operation of the FNP only at " hypothetical site or sites having characteristics that fall within the postulated site parameters." To conclude, as the ASLB, that this language allows manufacturing reactors to be sited at hypothetical sites which do not exist is a gross distortion of logic and the regulation. In promulgating
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6 Appendix M. the Commission had in mind only ocean sita? and not estuarine, riverine or barrier island sites (38 Fed. Reg. 30251, l November 2, 1973): The amendments which follow contemplate the manufacture of several nuclear power
* - reactors of standard design at an industrial location. The reactors thus manufactured will eventually be located and operated at utility sites. Some of these sites may be
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ocean sites,~ created by the construction of , breakwaters, at which pruvi :usly manufactured barge-mounted reactors coula de installed and operated. Because of the size of the ocean,'the Commission may have assumed that finding hypothetical sites which met postulated site para-meters would not be a problem. The inshore siting proposed by OPS and'the Staff is far different. First, although not included
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by the Staff, at least one postulated site parameter should be tentative EPA approval of the kind of site. Appendix M does not limit the postulated site parameters and the details of such parameters is certainly an issue open to litigation in the pro-ceeding. Second, hypothetical is not the equivalent of fanciful. A. hypothetical question in cross-examination must have some foundation in facts in the record. Similarly the hypothetical FNP site must have some factual basis in the record. To date, all l l we have is an unchallenged statement by EPA that no inshore sites will be acceptable. Third, the Staff in FES II does not merely , analyze the hypothetical inshore site but gives conditional approval to it. What is occurring is the bootstrapping of a proposal to site FNPs at hypothetical sites into a Staff approval
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7 of such hypothetical sites based on the Staff ignoring the real world unacceptability of the site because the siting is only hypothetical. Viewed from the perspective of Kleppe v. Sierra Club, 427 U.S. 390 (1976), the Staff is not able to speak to inshore siting because it is not a concrete proposal for action
-- EPA's rejection of such siting negates the proposed action.
Finally, at least implicit in the concept of hypothetical is that it could be heal. The EPA position makes all'insho're siting impossible and destroys the hypothetical. If the potential that the hypothetical site be a real s te is not present, the Appendix M license would be used to authorize building nuclear plants to be hypothetically sited in National Parks, on Wild and Scenic Rivers, in the homes of endangered species or in any other environmentally unavailable site. The Staff is abusing the hypothetical concept in Appendix M to substitute its judgment ihat inshore si':ing for FNPs is acceptable for the EPA judgment that it is not. The Staff, having successfully argued that it must defer to EPA on water matters (New Encland Coalition on Nuclear Power v. Nuclear Reculatory Commission, supra), must now accept both edges of that sword.
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8 II. The Board Should Direct Cetbification The fact that a contention has been wrongly rejected has not been a sufficient basis for granting certification. The standard, as articulated in this case (Appeal Board Order, April 19, 1978,
- p. 2), is that there be:
an important legal question, not previously decided by this Board or the Commission, which if not promptly resolved may result in unusual delay and injury to the public interest. The requested certification in this case relates to the denial of the admission of a contention based upon a first impression interpretation of the meaning of Paragraph 3 of Appendix M. l The possible increase in requests for manufacturing approvals for FNPs or other standardized plants makes it important to clarify this legal issue at an early date. In addition, for this case it is extreme:y relevant to know whether FNPs may be built to be sited at inst. ore sites. Without the availability of inshore siting, the number of plants proposed to be built may be drasti-cally reduced -- or even eliminated. In a broader context, this case represents an important application of the doctrine articulated in both the St. Lucie and Pilgrim proceedings regarding the duty of the Staff to evaluate real and not fanciful sites in its NEPA review. In Florida Power and Light (St. Lucie No. 2), LBP-77-27, 5 NRC 1038, 1044 (1976), affirmed ALAB-435, 6 NRC 541, 543-44, the Staff alternate site analysis focused on a hypothetical rather than a real alternative site, and the licensing board held:
# 4 We have no doubt, however, that NEPA's " rule of reason" contemplates the taking of such minimal steps as may be necessary to assure a real and practical factual knowledce of the matters to be evaluated. And these " minimal steps" consist of the evaluators doing all of that directed to those ends which, at lease, can readily and easily be accomplished-in the circumstances.in which they work. We are not able to conclude that the elaborately constructed alternate sites evaluation "meth-odology" employed by the Staff met that standard.
Actual inspection of particular alternate sites could readily and easily have been performed by the Staff and was called for in the circum-stance of this case. (Emphasis. added. ) In Boston Edison Co. (Pilgrim No.*2), ALAE-479, 7 NRC 774, the i Appeal Board rejected the Staff analysis of alternate sites because it was overly generalized. In the instant case NRDC raises the issue of whether the analysis of the proposed action itself may be based upon even less concrete-facts than the analysis of, alternatives. If not, then the FNP proposed inshore siting must be based upon substantial evidence that inshore siting is reasonably available. If reasonable availability is a standard by which alternatives are tested, surely it is a standard by which the proposed action must be tested. The question of " unusual delay and injury to the public interest" is a less precise standard. Frequent denials of re- ! quested certification by intervenors with respect to rejected contentions suggest that the kind of showing required may be inappropriate for an intervenor. The intervenor seeks to add a contention which if accepted will usually delay the hearing, although the purpose of the contention is not delay but resolu-tion of an important issue resulting in denial or modification l l l I e- - . - - . - . . . . .- . - - . - . - - - - - - - - - - -
10 of the license requested. The denial of the contention harms the intervenor and the public primarily to the extent the conten-tion is valid. When an applicant appeals admission of a conten-tion or challenges any decision to explore an issue, it claims that the exploration of t;he issue will delay the hearings and cost a lot of money. That allegation frequently carries the day if the "important legal question" test is met. Intervenors must usually rely upon the harm which will ensue if they are vindicated after the heoling is completed. Prior to
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the sunk cost doctrine, an intervenor had little to rely upon except delay to the applicant if the hearing were reopened and the license suspended. Now, we believe the application of the sunk cost doctrine, the immediate effectiveness rule, and the difficulty of obtaining a stay make the injury to an intervenor of having a basic contention rejected far clearer. We are not a- are of any case where the Appeal Board has essentially accorded this combination of circumstances the status of irreparable injury whicn it accords the applicant's allegation of the cost of delay, . but surely the time has come for such recognition. To illustrate the concept of sunk costs graphically, Attachment C is a copy of the OPS Newsletter for May/ June 1974 detailing how costs are sunk prior to NRC approval. Of course in the ensuing years much more has been spent and will be spent in the future. Finally, as we noted at the outset, this case is now in a period of suspension and will remain in this period for an indef-inite time. Applicant has announced that it will not only pursue
11 the Class 9 accident on the present legal challenge but w1_' also seek to challenge on the merits the Staff imposition of Class 9 accident mitigation measures. See Motion to Plead a Matter in Controversy and Establish a Discovery and Hearing Schedule for Such Matter (September 5, 1978). At the July 27, 1978, Conference, Applicant advised that it would not provide certain data requested by the Staff on the Class 9 mitigation mechanisms until it was established both legally and substantively that such mitigation was required in this case. At the same Conference, the Staff advised that'it would not complete the FES Addendum III until it had the data. By Order dated August 2, 1978, the licensing board established the date for briefing NRDC's one admitted legal contention on the adequacy of the NEPA review 30 days afrer publication of the FES III. In short, this hearing will not be concluded for a long time. No party will be disad-vantaged if the validity of the rejection of ;he NRDC contention is litigated while we wait. Conclusion For the reasons stated, we believe there is reason to believe the licensing board erred in rejecting the NRDC contention and that unless directed certification is granted NRDC will be severely prejudiced and no other party will be prejudiced. Respectfully submitted,
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Anthony Z. Pcksmak y Natural Res,& rces Defense Council 917 15th 1 reet, N.W. Washington, D.C. 20005 (202)737-5000 Dated: November 30, 1978
i QUESTIONS FOR WHICH CERTIFICATION IS REQUESTED
- 1. May a party contend in an Appendix M proceeding that approval of a manufacturing license and a finding that there is reasonable assurance that FNPs can be sited in a certain category of sites are not permissible where there are no possible sites within the identified category?
- 2. In promulgating Paragraph 3 of 10 C.F.R. Part 50, Appendix M, did the Commission consider whether " hypothetical site or sites having characteristics that fall within the postulated site parameters" could include non-existent sites and, if not, does the non-existence of such sites constitute "special circumstances" within the meaning of 10 C.F.R. S 2.758?
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- 3. Where the opposition to a contention is based upon its legal invalidity, as opposed to its procedural deficiency, should the contending party at least be provided with a reasonable opportunity to reply to the answer? '
- 4. Prior to rejecting a contention as a challenge to a Commission regulation, should the contending party be provided an opportunity to demonstrate that "
special circumstances" exist 1 warranting application of the provisions of 10 C.F.R. S 2.7587 i s
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>y ggc,7 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY WASHINGTON, D.C. 20460
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- N $ OFFICE OF THE v A D MINIS TR A TOR J
'A ' Mr. George W. Knighton I
Chief, Environmental Projects Branch Division of Site Safety & Environmental
- . 3 Analysis 1+ a Nuclear Regulatory Commission
>M Washington, D.C. 20555 ,
Dear Mr. Knighton:
~7hg M With this letter we are transmitting our detailed comments N on the Draft Addendum to the FES on Floating Nuclear ,?(s# Power Plants -- Part II as mentioned in our letter to im you of May 1, 1978 (see attached).
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- As was discussed in that letter, we find the siting of FNP's islandsintoestuarine areas as alternatives well as on nearsh' ore barrier y
1.T be unacceptable to offshore w siting. '
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3M4 This letter concludes EPA's ceview on this draft addendum.
$M We appreciate the opportunity to comment and -g are willing to discuss any of these comments at your convenience. Please contact Florence Munter of my staff g' if you have any questions.
7 f.la Sincerely urs,
, e . ?' E - # 5 voseph M. McCabe
[$ Acting Director sq Office of Federal Activities (A-104)
.'.' Enclosure s.
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u l i - ., 8 1 0 @ l 4 I l I ; Detailed Comments on the Draft 1 Addendum to the FES on Floating Nuclear ! i 3 Power Plants -- Part II p,, - 3 p Dredging and Placement of FNPS e A The environmental impacts which would ensue from
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dredging large areas (possibly over 7,000,000 cubic feet
; of dredged material) for the access channel and placement
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of an FNP would be considerable. These environmental impacts [ include degradation of water cuality as well as changing the physical features of an ecosystem. Specifically, the impacts it.'lude -
- 4 the effects of resuspension of sediment
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particles, possibly some laden with toxic
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metals, pesticides, and organohalogens; {.
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l interruption of littoral currents;
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- artificial sedimentation of areas subject to current changes; ij%
4 erosion and deposition changes on nearby beaches; loss of productivity in c.stuarine z.nd wetland - areas; g?g 5{. f - - destruction of barrier islands; 2 destruction of shoal areas, mangrove swamps,
' and wetlands.
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?, These impacts threaten long term and potentially ; 3 irretrievable degradation of some of our most productive natural resources. ': . Although extraordinary mitigative measures are suggested to safeguard 3, ' these valuable resource areas, we believe L estuarine and barrier island ecosystems are so susceptible to the physical stresses accompanying FNP construction and ,[qd fg operation, that they should be withdrawn from consideration by NRC as FNP siting alternatives.
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Conclusion-jkgl .#,Q) a The five EPA Regional Offices having jurisdiction for the entire Atlantic and Gulf Coast areas have stated that f the potential estuarine and barrier island sites located in their. regions would not be environmentally acceptable g y y sites. I Our regional offices have indicated that future EIS's prepared for specific FNP sites in their appropriate (j
. , , _; regions will be determined unsatisfactory from the standpoin:
of environmental quality should estuarine or barrier island Ogj locations be proposed. In conclusion, and in view of EPA's. 4l.
? ^' "' Section 4 04 (b) and Section 316 (a) and (b) criteria under the
; : ' Clean Water Act, we believe the fundamental technical and
( procedural problems associated with siting FNP's in estuaries are too difficult to; overcome. pi We would also like to have the following radiological comments considered in the final updating of the addendum. , 1 Radiological Impact
- . .a The, draft addendum states that the radiological impact of a nu. clear power plant at a given site is dependent only on the source te,rms and dispersion after release; hence,
;hfh, the radiological impacts of a LBP and FNP are similar. It
- gd should be noted that radiological impact also depends on the Ng( recipients of the radiation, population distribution, ecolo.it make-up and lard use of the area.
STd s, These factors for an adequate assessment of radiological impact.are necessar:
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' d E The dose estimates in section 2.5.5.1, do not indicate
; where to find the parameters used in calculating these doses.
- A reference, or brief discussion of these parameters, would
'~ I " U support the population doses stated in this section; also,
; the most critical pathways for the estuarine-sited FNP. Some necessary parameters are: distance from the plant to a i [ -
population area, population distribution, dispersion model 1 t
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. used as well as water and land use models.
i m' ,1 In comparing the dose commitments to maximally exposed individuals from cooling liquid' effluents systems, for once-through ecoling and closed-cycle the addendum states that 3
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<; although the initial radionuclide concentration from cooling tower blowdown is higher, good mixing in an estuary
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believes that such a dependence on estuary dilution should be considered very carefully because sediment uptake and L f dilution patterns would change once access canals, and finally, discharge structures are constructed in an estuary.
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e No quantitative population dose commitments are given for liquid effluents. i A statement is made that the dose commitments might be two orders of magnitude dif ferent, depending upon the cooling system, but no estimates are given to apply the range of the two orders of magnitude. L $
' The final addendum should discuss all of these points and present complete dose and dose commitment estimates along with ranges of estimates fo'r various assumptions.
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, O i; UNITED STATES ENVIRONMENTAL PROTECTION AGENCY l k\ h~ k j 5 % mv,$ W ASHINGTON. D.C. 204GO 2 G JUN 1978 ofTICE Or inc if r . A.P. 7,echella , President ofishore Power Systems 3000 Arlington Expressway Bo:: 8000 '
Jacksonville, Florida 32211
Dear Mr. Zechella:
- 1 have been asked to respond to your letter of June 9, 1978 to Administrator Costic concerningsEPA's recent comments on the thic.lcar Regulatory Conmission's draf t addendum to the Cinci CIS on Floating tiucicar Power Plants (Part II).
As you have noted in your 1cteer, EPA has recommended to the iuclear Regulatory Commission (?!RC) that any floating nuclear power plant (F';P) siting in estuarine areas as well as on or near barrier islands be clininated as an option prior to the granting of a license to manufacture eight FNP's. EPA believes estuaries and barrier islands, specifically wetland areas, arc very productive ecosystems which are highly sensitive to physical changes. EPA has reviewed and comneated sn the MRC's cr.vironmentn impact statement in acccedance with our responsibilities under Section 3s' of tha Clean Air Act. This Act requires the Administrator of F.?A to review and comment on any major Federal acrion. In addition, Sectico 102 of the National Environmental Policy Act (NEPA) states that " Prior to makirg any detailed statenent, the responsible Federal official shall consult with and obtain the comments of any Federal agency which hac jurisdiction by law or special expertisc with respect to any environmental impact involved." As you may be aware, EPA, along with the U.S. Army Corps of Engineers, has an active roic in the issuance of dredge and fill permits (Section 404 of the Clean Water Act, formally the F1TPCA), and we have an advisory role in the Corps' lssuance of a permit to alter or obstruct an'y navigabic water of the U.S. (Section 10 of the River and llarbor Act of 1899). Both of these permit processes provide that particular consideration ce given to wetlando and water quality. ,
g-..- EPA has further responsibilitics in accordance with Section 316(a) and (b) of the Clean Water Act regardina critoria to be applied in the issuance of a permit under the National Pollutant Discharge Elimination System (N?DCS). , In view of our regulatory responsibilitics, EPA's com.ments on NRC's draft addendum, specific to the siting of FNP's, were to alert the ':RC that sites other than estuaries and barrier islands should be considered for the placement of FNP's. From the evidence available, CPA believes that the environmental impacts of locating an FNP in an estuary or near a barrier island cannot be effectively mitigated. Other alternative sites (alongshore, inshore, and nearshore) should be investigated as these sites may possibly suffer 1 css environmental damage. Furthermore, EPA has a wetlands policy which states our Agency's intent to preserve and protect wetland resources from potential irreversible damage. , Specifically, this policy guides EPA in protecting wetlands from advers,e effects from dredging or filling practices, siltation, and the discharge of toxic materials ensuing from construction activitics; and to " prevent violation of applicabic water quality standards" from these activition. In carrying out this policy, EPA has a responsibility to advise applicants for water quality permits, or in this case the NRC, that the most environmentally acceptable alternative to siting FMP's in estuaries and near barrier islands should be selected in an effort to minimize destruction I of some of our most valuable resources. We believe EPA has not violated NEPA, nor its statutcry authority; to the contrary, the Agency has carried out its statutory responsibilities by commenting on the NRC EIS uithin our arcas of jurisdicti,n and expertisc. If you have any questions or would like to discuss this cat"cr further, please let us know. Sincercly yours 9 William D. Dickcrcon N% Acting Director i Office of Federal Activities (A-104) 1 e t
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e m e 49 e6 f UNITED STATES ENVIRONMENTAL PROTECTION AGENCY k'%,g$((7 g . WASHINGTON D.C. 20.:60 11 AUG 1978 CFr!CC Or THE AC Mitel5 f A ATOR Mr. Daniel R. Muller Acting Director, Site Safety & Environmental Analysis Division Office of Nuclear Regulatory Regulation U.S. Nuclear Regulatory Commission Washington, D.C. 20555
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Dear Mr. Muller:
Enclosed are the Environmental Protection Agency's detailed comments on the Nuclear Regulatory Commission's revised draft environmental impact statement related to the Manufacture of Floating Nuclear Power Plants -- Part III. '"hese comments expand upon and supplement our letter of July 5, 1978, which discussed our major concerns and conclusions. If you or your staff have any questions concerning our ccmments, please contact Florence Munter (755-0770) of my staff. Sin.erely v urs, k / tv _ William D. Dickerson Acting Director Office of Federal Activities (A-104) Enclosure .
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, EPA's comments on the Revised Draft Environmental Impact Statement related to the manufacture of Floating Nuclear Power Plants (FNP's) -- PaJ:t III (NUREG-012 7 ) May 1978 Our review of NUREG-0127 resulted in the following major conclusions:
- 1. The NRC staff has not provided an analysis of the effectiveness of the sotrce interdictive measures that are proposed to be included as conditions of the license to manufacture. The effectiveness of these measures should be
, evaluated in the final EIS.
;- 2. The comparison of 'the airborne source terms for ice condenser and non-ice condenser containments is based on unreferenced studies. Documentation should be made available to support the NRC staff's findings.
- 3. The riverine siting option, which we understood to have been eliminated from consideration in the addendum to Part II of the EIS, is discussed as a viable option in Part III. If'riterine siting is an option the applicant intends to pursue, then NRC should include an analysis of this option in Part II which discusses siting impacts and considerations. As stated previously, we believe that riverine and estuarine areas (as well as barrier islands) are environmentally unsatisfactory siting alternatives.
General Comments Source Interdiction l The NRC staff has proposed two conditions for issuance of a license to rianuf acture which would increase the potential to interdict the liquid pathway at the source in the event of a core-melt accident. These are: a) the replacement of the concrete pad under the reactor vessel with a material that j will delay a melt-through, and b) modification of estuarine and riverine sites :o contain any radioactive material that could be released from a core-melt accident. The NRC staff has not noted the available assessments which would indicate how ( these conditior.s may be met or, more importantly, how t effective any anterdictive material may be in reducing the liquid pathway and in protecting the environment. We recommend that the NRC staff provide an analysis in the final environmental impact statement indicating the state-of-the-art and the effectiveness of the proposals. l r _ _ _ - . ~ - -- - - - - -- -
2 Documentation of Accident Analysis The EIS refers to ongoing research (pages 2-4 and 3-45) that has contributed to.the accident analysis in the EIS. Preliminary results are given, but no' documents or references are provided. The EIS should describe the ongoing research, identify the results to date, and give current references and the schedule for documenting any findings. Any conclusions formed in .this EIS should be contingent upon the possible outcome of such research. River Sites In Part II (Addendum to the EIS), the NRC staff stated that riverine siting had been excluded by the app.licant and that therefore, the EIS had' focused on open ocean and estuarine shore siting options.as well as offshore estuarine areas. However, in Part III, it appears that riverine sites are still being considered with the possibility that these sites might be utilized if the potential consequences of a core-melt accident could be reduced. Independent of the safety related issues, EPA believes the environmental impacts from normal construction and operation of FNP's in rivers contribute to the undesirability of using river sites. Specific Comments Page 3 The statement indicates that the distance ;f a floating plant from the shore by two or three miles does not markedly affect the health related impacts from the air pathway due to a core-melt accident. We agree that this may be true for long term health effects but we believe that the severity of immediate impacts from an accident would be less at a site farther offshore because of the greater plant distance from a population center. -' Page 3 Table 3-1 and Table 3.4-4 are inconsistent with regard to atmospheric releases for the " expected" accident scenarios. Page 3 For the source interdiction measures, the staff stated that the direct costs of interdiction for near shore citing would be identical to those for open ocean siting. If the condition of the license (as is suggested in this
1
.- , 1 i
3 draft EIS) is to modify the shore zone to insure timely source , interdiction, how will the implementation of this condition ' compare to the cost of open ocean source interdiction? The analysis presented in the final EIS should clarify this issue. Page 3 NRC has noted in the EIS that there may be sites for LBP's (land based plants) that are susceptible to severe-liquid pathway contamination in the event of a core-melt accident. We recommend that further discussion be provid.ed in the final EIS to indicate the range of potential consequences of LBP's located very close to water bodies and that the discussion include a comparison with potential FNP accidents. Page 3 The use o'( " expected" consequences on page 3-31 and other places in the statement should be carefully explained to avoid misleading the reader. He suggest that the terms used to describe a particular kind of accident , be defined and that a footnote be added explaining that
" expected" or "most probable accident" consequences do not necessarily indicate the full range'of potential consequences that. exist.
Page 3 The assessments of source interdiction measures at FNPs should be referenced to indicate the engineering feasibility of delaying a core-melt-through for one week at a moderate cost of " lass than one million dollars." Any developmental sad /or testing costs should also be ncted and included in the cost estimates. Page 4 The first paragraph presents the impacts associated with the siting and operation of FNPs. The third paragraph indicates that these impacts are "relatively mild" and that these impacts would occur in relatively small areas compared to the general area affected. Such a conclusion is inconsistent with the NRC finding (in Part II and in the summary of Part III) that " dredging and disposal of dredged [ material related to the construction of access channels and ' the protective basin or lagoon for a FNP, and the maintenance of those areas, can have significant potential for adverse environmental impact" (page xiii, Part III.). l Page 4 The last sentence states that loss of life by acute fatalities is not predicted for the liquid pathway from a core-melt accident but that there could be substantial environmental contamination. However, we note that environ-montal contamination could lead to chronic exposure, resulting in adverse health impacts, including an early death for l some individuals. ,
& 7 " F
4 , f jo sr ,, s A r3 , M
%g, g UNITED STATES ENVIRONMENTAL PROTECTION AGENCY WASHINGTON, D.C. 20460 2-8 AUG 1978 CFFICE CF THE I ADMINISTRATCR Mr. Harold R. Denton
' Office of Nuclear Reactor Regulation -
U.S. Nuclear Regulatory Commission Washington, D.C. 20555
Dear Mr. Denton:
The Environmental Protection Agency has reviewed the final addendum to the environmental' impact statement (EIS) related to the manufacture of TloatingENuclear Power Plants -- Part II. In general, we believe tha( the analysis of site impacts
.is adequate but does not support the conclusions presented.
The summary and conclusions presented by. the staff in the addendum to Part II are the same as those presented in the final EIS to Part II; namely that from the staff's analysis of the proposed action "the eight floating nuclear power plants proposed fc manufacture can, with a reasonable degree of assurans be sited and operated as electric generating stations either at offshore or shoreline sites," The staff has designated shoreline sites to include estuaries and barrier islands. EPA does not believe that estuarine and barrier island sites can be reasonably assured. On the contrary, we believe that the analysis provided in the addendum supports our conclusion that the fundamental technical problems associated.with siting floating nuclear power plants (FNP's) in estuaries and near barrier islands would be too difficult to overcome. Furthermore, these siting alternatives appear to f ail EPA's and the Corps of Engineers 404 (b) criteria which provide guidance for evaluating proposed discharges of dredged and/or fill material. Specifically, one of the criteria for permitting discharges in wetlands states: l the activity associated with the fill must l have direct access or proximity to, or be located in, the water resources in order to fulfill its basic purpose, or that other site I
e-e , .. 2 or construction alternatives are not practicable;* Since 404 permits are necessary, this in itself indicates a very low probability of locating in these areas. There are also water quality criteria that must be satisfied beLire an NPDES permit can be issued by our Agency (Section 316(a) & (b) of the Clean Water Act). The EIS analysis shows that environmental impacts from estuarine and barrier island siting could cause extensive, and long term damage to and loss of some of the nation's most productive natural resources. Although the analysis suggests that viable mitigative techniques are available, these have not been discussed in any detail nor, in our opinion, have they been demonstrated as being effective. Specifically, the analysis has not shown that there are:
- 1. demonstrated techniques for restoring the bathymetric characteristics of the dredged areas; 2.demonstratedtechniquesforresboringhydrological characteristics of the estuary and barrier island ecosystem, including such factors as the circulation patterns, salinity gradients, and the transport and deposition of sediment (without the continual need for maintenance dredging);
- 3. demonstrated techniques for re-establishing original plant communities and wildlife habitat to self- l sufficiency (without the added problems associated !
with the continual need of fertilization or , repeated planting) in areas where wetlands have l been disturbed or destroyed; ( i 1
- 4. demonstrated techniques for re-populating and j establishing brackish / marine water areas with original marine species, including diadremous species; j
- 5. demonstrated techniques for re-establishing barrier island natural processes such as " dune building," beich " retreating," and overwash and inlet development.
Our concern for the applicant's ability to successfully i mitigate such impacts is based on past experience with l
. mitigation attemp ts. For example, construction activities l
*Section 404(b) of the Clean Water Act, Part 2 30. 5 (b) Sii(a) . I l
- - . ~ - _ _
V '
. ~
3 (such as errecting breakwaters) seldom act in concert with beach dynamics. Rather, such activities generally require further construction and continual maintenance, resulting in repeated habitat destruction and reductions in the diversity of coastal species. In particular, we note that.recent studies have shown past efforts to stabilise retreating shorelines and prevent beach erosion, as well as dune migration,- have caused more problems than these efforts have solved.* ,
'Further, it is well documented that a particular loss of wetlands (from construction activities)_ in one. ecosystem can have further detrimental effects on water quality on the nearby downstream coastline.
In our discussion with you on August. 8, '1978, you indicated that the staff's final conclusions and summary of the proposed action, including siting considerations, will be presented in the. final EIS on Part III and that the staff is in the process of preparing r'ecommended conditions of the manufacturing license which will also be included in Part III. Since the NRC's final conclusions concerning siting of FNP's are unknown at this time, EPA is reserving
. final judgement on this action until Part III is reviewed.
In preparing the recommendations for inclusion in Part III, we strongly urge NRC to re-evaluate the conclusions concerning estuarine and bar'rier island siting. Because the EIS analysis shows that estuarine and barrier island siting will be very difficult, if possible at all, we believe that the decision :a license should be based on the availability of sites la areas other than estuaries - and barrier islands. As a consequence of this, we do not believe these siting options should be included in the cost / benefit analysis (Part III) . The cost / benefit analysis should consider only the most probable siting alternatives. As was discussed in our letter of January 26, 1977, which I commented on the final EIS related to FNP's -- Part II (copy enclosed), one of EPA's primary concerns with Part II i was that an adequate generic environmental asses'sment had not been provided for the placement of floating nuclear power plants. Since Part III'will encompass the sum of-the conclusions from Part II and III, we believe NRC should indicate the status of their effo'rt to collect environmental impact information on the overall use of the FMP technology. ,
*Pnul J. Godfrey, " Barrier Beaches of.the East Coast," .
Oceanus 19 (5) , 1976.
. 1
e
., 0 *
, s 4 If some of this general a'ssessment information is available, it:should be included in Part III. We believe that this information is necessary in order to fully assess both the long term and cumulative effects of the proposed action as;well as any future applications to manufacture'FMP's.
Finally; as a point of information, we do not believe the
' NRC staff has correctly represented EPA's position with the reference to presently coastal-sited land plants (p. 6-16 of'the addendum). As stated.previously, there
~
are a number of coastal plants where larval entrainment mortality is a problem. EPA remains concerned about this as well as other water quality impacts associated with coastal plants sited near estuaries. We appreciated the opportunity'to discuss these issues with you at an early time in the decision-making process. If you or your staff would like to discuss these comments further, please contact Florence Munter of my staff (755-0770). Sincerely yours, ,
'.' v-
/)
TIL yt William D. Dickerson Acting Director Office of Federal Activities (A-104) Enclosure 6 S e
.,._y. .r ., - -~
" dffshore Power Systems A Westinghouse-Tenneco' Enterprise -
l I ATTACHMENT C t ! P P MA RK5 TING OEPARTMENT *
! 'eWSleuer JACKCONVt L.LE. F LO RID A
- MAY/ JUNE.19N
- NO.15 f
MARKETING NOTES 7 d El GRAVING DOCK CONTRACT AWARDED US) Offshore Power Systems awarded a letter contract in June for the construction
%. y- J of the graving dock and slipway for its manufacturing facihty on Blount Island. The
'M f 1 award was made to Kiewit-Tidewater, a joint venture of Peter Kiewit (Nebraska)
By Joe k.] M - a ] and the Tidewater Construction Companysite, (Virgmia). Stadelman UMkdp Referred to as the heart of the 900 acre manufacturing slipway which measure 400 feet by approximately 1200 feet, represent a capital the graving dock and expenditure f ver $40 mdlion, which will be the largest commitment by OPS on The Jacksonvil!e E!cetric Authority's Let-the Island. ter of Intent for two floating nuc! car , plants has been extended to July 2 in The award was one of several made by Offshore Power Systems during the past order to permit continuation of contract few weeks which included placements of contracts for five other buildings valued at negotutions. In early June, the JEA ap. over $$ million. These encompassed the Quality Control Administration Budding, the proved a resolution to contract with the Mamtenance Facility, the Central Ware-Atomic Energy Commission for delivery STEEL PANELS F0R house, the cuality Control weiding Schooi of nucicar fuel emiching services between and the Steel Fabrication Shop July 1,1980 and June 30,1981. Also ap- FNP'S ON ORDER proved was a resolution to contract with SITE WORK PROGRESSES Westim; house Electric Corporation to fab. The f.irst Floating Nuclear Plants moved ricate 'the nuclear fuel assemblies. The closer to reality this month as Offshore The pace of construction stepped up execution of the fuel contract at this Power Systems awarded a letter comract considerably in the May-June period on time wdl save Jacksonville some million to American Bridge Division of U.S. Steel Blount Island, highlighted by the erection dollars in escalating costs. for the steel panels that will form the plat. of structural steel for the first building .
. . . forms for Atlantic ! and 2.The Contract the 60 x 300 foot QC Welding Laburatory Discussions w'th utihty executives at the represents an order of $37 mi!! ion. which will be completed this fall' rece it eel Conference in New York City The initial ., hip.nent of the steel panels contum many of the OPS contention's is scheduled for receipt in November of Excavation for the Quality Control about the benefits of the standard 2cd 1975. Atlantic I which wdl go on the Admmistration Budding was accomplished Floating Nuclear P! ant manufactured in a assembly line at the manufacturing facility and erection of steel was scheduled to facility remote from the uhimate site. at the end of 1975, will be dehvered to begin M late June. Foundatmns for the Parucularly significant were: (a) com- Public Service Eleetnc and Gas Company Pipe Shop, Maintenance Facility and Ware.
parison of the escalating construction in July of 1970. Atlantic 2 is scheduled house are also scheduled for this month. manhours per KW of a land based plant for delivery the following year. (Continued on Page 3) n b) i .
. clear plants may well reach 5900 Mia.rr W 'W4 nW by the mid 1980's,(c) the capital pJ . -
, . s ".W ' ;,_..4 W}"- TO ' -
g' cost of a coal. fired plant with its inherent envuonmental problems,is now approach.
- g. -
(
,gg-7,?","". .y mg that or a nuclear plant, and (d) the W .j .- , < i.a ......,,a ,
%4
, .4
%2 W+[MT y~ Wy M dekscred cost of low sulfur coal on the N' ' ? " . s cast coast is fast reaching the cost of oil fM,,g # 34'nlN,g -
y' ' '
. $j ,
which in turn wdl most hkely conimue to 4 - - - -
- " $ p I~K' i
ose. N $7y+- ,
-g I
The FNP model w s exh bited at the June American Nuclear Society meeting in Phd-
.;+b" g " ] $ 4 M'- 4 adelpha as part of their Techmcal Infor- ,
I N matmn Exchange (TIE) Program. A sec- . ond TIE exhiba wd1 be held m Washmg- i , ton D C. in October and the model wi11 Floating Nuclear Plant Energy Park . . . An artist 's concept depicts four Floating Nuclear aho be on display at that sessmn. The Plants. capable of generating a total of.IG00 megmcatts of power, wahin a single break. Washincton Confetence will be held con- water. Tire four in a breaewater concept which would provide enot.gh electrical energy currently wah the 1474 Annual Confer- for a cdy of well over 2 million pecple, represents a considerable savings in site de-ence of the Atomic Industnal Forum. eelopment costs end time.
i.., OFFSHORE POWER SYSTEMS-A HISTORY OF PROGRESS 1970 September (18) - The first contract is suspends and conditionally revokes the I August At the request of Public Service signed with PSE&G for two FNP'S (At- COE Permit. Electric and Gas Company (PSE&G) of lantic 1 and 2) to be sited off the New New Jersey, Westinghouse Electric Cor- Jersey coast, about 12 miles northeast of October (2) The Jacksonville Electric poration begins studies on the conceptual Atlantic City. The $750 million contract Authority signs a letter of intent to pur-design and feasibility of the Floating is the largest single equipment order in chase two FNP's for operation in 1982 Nuclear P! ant (FNP). the history of the electric utility industry. and 1984 at a still toke determined site , off the Northeast Florida coast. l December Study team preliminary report November - OPS is advised by the ACRS presented to Westinghouse Management that the FNP concept is feasible. The AEC October (15) The Corps of Engineers saying concept feasible. Regulatory Staff and Coast Guard had also holds a public hearing on its issuance of written favorable letters. the Dredae and Fill Permit to the Jack. 1971 sonville fort Authority. April 1 - Westinghouse forms the Special November (20) - The New Jersey Ocean Project Division to develop the concept Sanctuary Bill is passed by the State November (8)-PSE&G exercises its option of the FNP.PSE&G and five other utilities Assembly. to purchase two additicmal FNP's for op-form a joint study group to provide eration in 1985 and 1986. general guidance and consultation on de. December - Surveying and soil investiga-sign criteria. tions begin on Blount Island in the St. November - An order for the world's larg-Johns River, the proposed site of the OPS est crane is placed with Krupp industries June Newport News assigns personnel to manufacturing facility, of West Germany for the OPS manufactur-
. Pittsburgh team. ing facHhy.
1973 August (10) - Westinghouse and Tenneco, January (23)-OPS files its application for December (19) PSE&G files a Site Con-Inc., announce plans to jointly build alicense to manufacture eight FNP's with struction Permit Application with the FNP's for offshore installation. the AEC. The application includes a com. AEC. prehensive report on the environmental September -The group of six utilities pre- effects of the manufacturing facility. I974 sents the overall concept of the FNP to January (10) Site development work be-some twenty federal agencies, thereby April (25)-The AEC publishes regulations gins on Blount Island. initiating government liaison efforts on providing for the granting of a manufact-the new project, uring license for multiple standardized January (29) The U.S. District Court nuclear plants and authorizes the licensed Judge. Charles R. Scott dismisses the November .The Westinghouse Special Pro- manufacture of a nuclear power reactor at Florida Audubon Society restraining order. ject Division begins discussions with At- a site different from that of its ultimate omic Energy Commission (Al) regula operation. February PSE&G's application to con-tory staffs regarding the licer g precess struct the frst FNP site is docketed for for the FNP. April (26)- The New Jersey Ocean Sanc- detailed technical review by the AEC. tuary Bili is defeated by tL: State Senate. December - A preliminary prcposal for March (22)-The Florida Audubon Society FNP's is submitted by Westinghouse to May An agreement isapproved and signed withdraws its appeal of the U.S. District Public Service Electric and Gas. by the Jacksonville Portt Authority .by Court ruling of January 29 as well as its which OPS may purchase two tracts of pending petition with the AEC opposing 1972 land on Blount Island. the graruing of a license to manufacture February PSE&G signs a letter ofintent FNP's. for two FNP's. July (5) - The AEC dockets for compre. hensive technicaireview OPS's application June - OPS awards Letter Contract to March (13) The New Jerr.ey Ocean Sanc. for a license to manufacture eight FNP's. Kiewit Tidewater for construction of the tuary Bill, providing for the protection of Graving Dock and Slipway for its manu-the State's coastal waterways within the August (1) - PSE&G begins initial testing facturing facility on Blount Island. three mtie limit,is introduced in the State of breakwater and plant scale models of Assembly. Atlantic 1 and 2 at the University of EXPECTED DATES: Florida's Gainesville campus. The wave July 1975 - The AEC issues a license to April (20) - The boards of directors of action and ship colhsion tests will proceed OPS for the manufacture of eight FNP's. Westmgtiouse and Tenneco authorize the for about 18 months. formation of thejoint venture,to be called December 1975 - The AEC issues approvai Offshore Power Systems (OPS). September - An extensive educational and to PSE&G for the start of breakwater con-vocational training program begins in the struction at the site of the first two FNP's May (1) A Prehminary Design Report on high schools and junior colleges in the off the New Jersey Coast, the FNP is submitted to the AEC. Jacksonville area in preparation for the more than 10,000 employes needed at full November 1975 Initial operations begin May (25) . Jacksonville. Florida. is selected production at the OPS . manufacturing at the OPS manufacturing facility. I as the site for the OPS manufacturing fa- facihtv.
~
cility and announced m Jacksonville. ~ Aucust 1976.PSE&G be2 ins construction September (4) - The Army Corps of Eng- of ihe breakwater for Atfantic 1 and 2. August (1) Official opening of new OPS ineers issues a Dredge and Fill Permit to headquarters. OPS personnel begin moving the Jacksonville Port Authority authoriz- July 1979 - The first FNP is ready for de. to their new six. story headquarters build. ing the start of construction on Blount livery to PSE1G. ing at 8000 Arlington Spressway in Island. The Florida Audubon Society is Jacksonvdle, argnud a Mmporary restraminnerdu en - 19m 1k fiumFMP henamunine
i .. ,
= .4 - .. s z. .y.g SITE WORK PROGRESSES
. ;v . y~-mv . .. . .. (Continued from Page 1)
< ~.w , ~.
g m.
. y ' -4 fi ; Earlier in Jtme, some 1400 tons of
.. . , t.F y sheet steel pilings were unloaded from bar.
47 wm ^? ' g,.f GrW.#. . . 4 > s . ges at the Jacksonville Port Authority's l MQ-{'.fN.y r:- (7 W-;Ndg @ . wharf on Blount Island.The the permanent material will
? Q-w.p.
vye- '%rN P ..i ~h4 . % be used to form in the construction slip within the manu. bulkhead o . F : <. ~ ,- . j. yg ,7 7 g e. v . p. /s? W
., C facturing site. The steel, manufactured in
-X
' ' y Tb - Belgium, was initially unloaded in Savan-
;,% h " .'? $- p'
; ,N ,. n;, f.] 4 ' nah, Georgia in five LASH (lighter aboard l
.1. - 5.,.y.'4 # jiA.,
;.. . - ,s ship barges) and brought by tug to Blount 7.; . ,. 3 ;. ; .]7 9
- e ;,q 7 ., . . LT ' Island. The barges were shipped to this L . ;.., . _. c .. ?s .- E3 tT'f $ country already containing the steel on O;;;. . ; s ,.
., ' ; - -A
+ c l; { A . '. board ship.
W, P. - - , - (. . . . 1 - , .. . - . .
- p. .
;, s _ . - c " ."
BOTH DREDGES AT WORK arial view af Dayson Spoil Area receiving much from the large dredge BT-51. On May 1, the second dredge BT.5l arrived at the site, and at 9:00 A.M. on
, May 19 started demucking the channel, Pumping the spoil to the Dayson area. By
* ..--.._c-. - _
the end of May, the Bobby James had dredged over 830,000 cubic yards of muck y ' G:,. C.K' to spoil area "C" while the BT-51 had yq b $ , deposited 275,000 cubic yards to Day. y X , 1
.. son, the combined total going well past
~
N 4%4 t
- . the million cubic yards of spoil.
. . . 2.5 ^ Earthwork on the Island continued at ik 7:,- -5 a rapid pace with a total of over one and a i E=
. half million cubir yards leveled and placed !
. m dike areas by June 1.
M'i y~
,j ~-
To maintain the pace 2nd schedule, over 150 contract'r people are at work on l
# r. v e g D_ W A ,.-
r;.amr.q , the isb.d utilizing 120 pieces of equip-N] k %, ment n.ich inch.de scrapers, bulldozers,
--% w% 'Ekhh.-
v' ' m z. _._ _ trucks, graders, draglines, barges, tugs, ;
~
p -R ; G i M W,,. egg, e,e' O_. _~ ~pi WR dredges and boats. _a---
@.~. M g{ q MIDA; Dure %"a - ---
Allaspects of the operation - building l
- . foundations, site preparation, dredging, l structural steel erection were essentially I Dredge at work in channel silhouettes the structural steel of Welding Laboratory. on schedule 1s the second half of the "*at began. -
f j- ( x vfdt. . ( '\ u ~ p.. R. . l h \' .; [. ) f k, Q p m;rl.! yk .q[y.!. , g l i *d y , [.$.
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ip t. j c [. . [ ^ N'ifjw,,, l * " ' ' - ' t i f ' b[ Nh3hp.* '
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~
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fr~ w L [iN ed -7t q Yhf,,,g[ Ew -- ! ,=: . -; ( b ( D '$ $% Steel workers assemble the structure of the Welding Laboratory- Sheet steelpilings for the permanent buikhead in the construc. l
, _ , the first building to be erected at the manufacturing site. tion slip are unloaded from barges. l
OPS SPONSORS BOAT TOUR OF BLOUNT ISLAND FOR FLOR!DA MUNICIPAL UTILITIES ASSOCIATION rr-, -...w + ,
, As part of a three day Conference held V
bQ^
^ ;'
%yc I"q f - '
g .
! by the Florida Municipal Utilities Associa.
, : tion (FMUA) in Jacksonville on June 5 7,
. Yd.... .p i J 1 Offshore Power Systems hosted an after-j
,) . .. q (-(l
~
-a t' '4 noon boat tour of the Blount Island site i,, . .
-. ai 4 @W l for the attending members representing utilities throughout the State. Jim Turner, 7 y
%-- - ^ g ,. + , ,
Vice President of Operations, using the
, gM~ J5
,;, I v -
boat's PA system, described the activities
- IM
'. r .
Ve'. i on the Island where site preparation, Y 3y[ pomma ~_ ,l V.. v " m { l j i dredging and the structural steel for the l Welding Laboratory were in evidence. p' Over two hundred and fifty' guests in-W""* --" 'Q?s M,'i ciuding local dignitaries, were on board to
-~
4 ' ' *#7 bR ' witness the progress activity at the manu.
~+
_." ' facturing facility site. On one deck of the "8 -- boat, the 3-dimensional model of the com-pleted facility was on display for compar. State Utilities Representatives board boat for afternoon cruise to OPS manufacturing Site. ison to the site's present status. Earlier in the day, the FMUA members 3,,,__.
'T"'?"5 w .w.. .W P'?
- i heard Joe Stadelman, Vice President of Marketing, present "The Role of the
\ Th.. . o, df @.I.ie5.%. . ,,f .
N Floating Nuclear Plant m Meeting [d
;8!) .,,. Q c+
Florida's Energy Needs"
. s %a -
9 Stadelman outhned the mary problems [ M ^<
.m.., *y f,A k. D facing the Utilities: the grov ing scarcity 4n
/, ,[$l y ,7 . - -]N' ,
j/N :d.jq[? . q of suitable land sites, increa ing costs of fossil fuels that are diminish ng in availa-
,g) 7. - [~$.C ,
pd.':jii Mb [* ;. g r. N . (i: _ j, bility, and environmental aspects such as y# fresh water supp!ies, and then went on to
.g k *h- hM' .4 d'Y MN!p; r ; .- '. y relate the important role the FNP will
.. .- [ Q'._caa. k lif -
A _ j fy -
^
u j M; % -) play in !orida's f uture.
' ' d I ,
,.. _ e ?$ G% M e.+ The ,roposed Jacksonviile Electric
- - b, 1
. Nj Authority's two unit site and the possi-
'k
'"Y ! s,;? M bihty of a four unit site were reviewed.
Mt9-@g t 'i JEA has solicited other FMUA members
,. MSW RN for the purchase of electricity. In answer Dunne the tnp to Blount Island, guests study 3D model of manufacturing facility on to pesnons fr m the floor, Stadelman display on upper deck, p inted out that economics dictated that a sinde major generation sourcetbe used Q U y f M K E Yd Pr T ?@ gQSW y for p oled purchasing of power rather pd.FUb' 1.M . G I.L@
- ggMirF . wg:.,, .hh.y@hggapg/M fg than constructing small 50 to 100 mega-bM,4p(MPT fu. .o %q gr watt plants throughout the state. Refer-
{Q h5 M y [ ~f2 k. g / C 9 $ g q g;M'.',%
,phe n -f ence was made to the success of similar i aINhN ii .1
- b_.W I_N k d ik ...[ h h NMer9eM. -J<" MMWJM .h5. '
col lective purchasing in the Northeast, such as /$hh' [,' f ventures. the New England w p~--#-~.-.wr ~
, _ _ _ _.g y:
pp., & -- ___ .
-a The ecor omics of fossil fuel vs nuclear t'~@f W4. )"'N Ed5dt? " 3; 7:R h plants was also discussed. Stade! man pre.
Y W
- MlT .,,
A
- Q dicted the cost of fuel oil could reach $20
. W ;;, je" *
-. 5 h a barrel by 1o85. The FNP breaks even L
{ { 4C ' - C " p M T;M',:=.6 M
; w -
" NM. with 53.5d to 54.00 per bbi oil.
Concluding, the OPS Vice President
- J@ '
/
8, N stated, "The nuclear electric economy is
*4p the only direction we have to go and the
. Floating Nuclear Plant represents the low-6
' g t-est cost nuclear generation with the least
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Viewers crowd on bow as boat approacnes Blount 1.stard for close up sight oflacchty A copy of Mr. Stadel man's paper is actwiry. available upon request.
, es a UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 1
In the Matter of ) '
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OFFSHORE POWER SYSTEMS ) Docket No. STN 50-437
)
(Manufacturing License for ) Floating Nuclear Power Plants) ) CERTIFICATE OF SERVICE I hereby certify that copies of NRDC REQUEST FOR DIRECTED CERTIFICATION were mailed today, November 30, 1978, first class postage prepaid, to the persons whose names appear on the attached list. Anthony Z. o'smfn
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r .. . Richard S. Salzman, Chairman Stephen M. Schinki, Esq. Atanic Safety and Licensing Appeal Board Office of Executive Iegal Director U.S. Nuclear Regulatory Camtission U.S. Nuclear Pegulatory Ca mission Washington, D.C. 20055 Washington, D.C. 20555 Dr. John H. Buck Carl Valore, Jr., Esq. Atomic Safety and Licensing Ippeal Board Valore, McAllister, DeBrier, Aron & U.S. Nuclear Pegulatory Carrmission Westmcreland Washington, D.C. 20555 535 Tilton Fbad P. O. Box 152 Michael C. Farrar Northfield, New Jersey 08225 Atomic Safety and Licensing Appeal Board U.S. Nuclear Fbgulatory Canmission Peter Bradford Washington, D.C. 20555 Cammissioner ' U.S. Nuclear Pegulatory Cam'n Sboldnn J. Wolfe, Esq., Chairman Washington, D.C. 20555 ' Atcmic Safety and Licensing Ibard U.S. Nuclear Pegulatory Ccumission , R. William Potter, Esq. Washington, D.C. 20555 % Assistant Deputy Public Advocate State of New Jersey Dr. David R. Schink P. O. Box 141 Atomic Safety and Licensing Board Trentan, New Jersey 08601 Departrent of Oceanography Texas A&M University College Station, Texas 77840 Iester Kornblith, Jr. Atomic Safety and Licensing Board U.S. Nuclear Pegulatory Cm mission Mr. George B. Ward Washington, D.C. 20555 Nuclear Power Plant Ccmnittee City Hall Dr. David L. Hetrick Brigantine, New Jersey 08203 Atomic Safety and Licensing Board University of Arizona Harold P. Abrams, President Tucson, Arizona 85721 Atlantic 03unty Citizens Cbuncil on Environnent I 9100 Amherst Avenue Joseph Hendrie Margate, New Jersey 08402 Omirman i U.S. Nuclear Pegulatory Cccm'n ' Docketing and Service Section Washington, D.C. 20555 ' office of the Secretary U.S. Nuclear Ibgulatory Cmmission Barton Z. Cowan, Esq. , Washingten, D.C. 20555 John R. Kenrick, Esq. Eckert, Seamans, Cherin & Mellott Plchard M. Hluchan 600 Grant Street Deputy Attorney General Pittsburgh, Pennsylvania 15219 State of New Jersey 36 West State Street John Ahearne ' Trenton, New Jersey 08625 Ccnmissioner U.S. Nuclear Ibgulatory Cmm'n i Victor Gilinsky, Camnissioner Washington, D.C. 20555
, U.S. Nuclear Pegulatory Ca m'n Washington, D.C. 20555 Richard Kennedy, Ccrmissioner U.S. Nuclear Pegulatory Ccnn'n Washington, D.C. 20555
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