ML20204C001
| ML20204C001 | |
| Person / Time | |
|---|---|
| Site: | Perkins  |
| Issue date: | 11/07/1978 |
| From: | Gilbert R, Robertson R, Zittel H Office of Nuclear Reactor Regulation, OAK RIDGE NATIONAL LABORATORY |
| To: | |
| Shared Package | |
| ML20204C004 | List: |
| References | |
| NUDOCS 7811270054 | |
| Download: ML20204C001 (42) | |
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UNITED STATES OF AMERICA y
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BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
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DUKE POWER COMPANY
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Docket Nos.
STN 50-488
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STN 50-489 (Perkins Nuclear Station,
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STN 50-490 Units 1, 2, and 3
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SUPPLEMENTARY NRC STAFF TESTIMONY REGARDING THE CRITERIA USED TO SELECT SITE ALTERNATIVES TO THE PERKINS SITE AND THE EXAMINATION OF SITE ALTERNATIVES TO PERKINS We, Robert A. Gilbert, H. E. Zittel, Roy C. Robertson, S. B. Gough, and James F. McBrayer, having been duly sworn, hereby state as follows:
The staff, in a filing dated June 16, 1978, requested, based on recent Atomic Safety and Licensing Appeal Board's decisions on NRC staff alter-native site analyses, that the Perkins record be reopened for the sole purpose of supplementing the staff's alternative site analysis in the environmental review pursuant to the construction permit applications for the Perkins Nuclear Station, Units 1, 2, and 3.
The Board, in an order issued July 14,-1978, supported the staff's request and reopened 501.1270034
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the record on the limited issue of sites alternative to that chosen by the applicant for the Perkins facility.
The above affiants, with the exception of Robert A. Gilbert who is employed by the U. S. Nuclear Regulatory Commission, are employed by the Oak Ridge National Laboratory.
Our professional qualifications are listed on attached qualification sheets.
The applicant, Duke Power Company, has responded to the staff's request for information relating to thei:' selection process for site alternatives with three documents:
"The X-81 and X-82 Site Studies" dated February 1973, a " Phase I Siting Study"* dated January 1978, and a " Response to NRC Staff Request for Additional Information of August 18, 1978," cover i.
letter dated August 31, 1978.
It is the staff's opinion, after examina-tion of these materials, that the latter two not only encompass the material in "The X-81 and X-82 Site Studies," which was used in the original Perkins site selection process, but provides the staff with much additional information and data relevant to our reassessment of sites alternative to Perkins.
We, therefore, have relied on the two more recent documents to a much greater extent than the 1973 study.
n The " Phase I Siting Study" is an updating of the Duke Power Company inventory of possible generating sites.
The study provides an inventory of potential sites for new thermal stations which utilize conventional cooling systems.and compares on a consistent basis such identified
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potential sites.
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- i Both the applicant's information listed above and the staff's sub-sequent independent evaluatioe'are based on reconnaissance-level informa-tion.
Reconnaissance-level information consists of information that is available from open literature, published or unpublished reports, existing records, authoritative sources,.or that can be obtained by brief field surveys performed by recognized experts.
It does not include information that can only be obtained by detailed onsite monitoring programs or studies.
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It is the staff's opinion that the mandate for site alternative reassessment requires more from us than merely a critical examination of site selection criteria presented in the applicant's submittals, although a thorough task group assessment of the applicant's methodology in site selection, screening methods, and final candidate site selection was i
initially performed.
When*we had reached an agreement that the eight sites presented in the Phase I study as sites for 4000-MWe nuclear stations appeared reasonable and potentially licensable, we sought to evaluate our decision by undertaking onsite inspections on September 19-21, 1978.
The staff's analysis resulting from the assessment described above and the site inspections follows:
Staff Analysis of Screening Methodology and Candidate Site Selection The two applicant documents, dated 1978, identified 100 preliminary, potential locations.for nuclear and fossil site plant alternatives in the 2600-4000 MWe range.
These potential, preliminary locations were 3
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' identified through a coarse screening of the Region of Interest
- to identify potential areas and candidate areas, followed by an intermediate screening of candidate areas to identify site areas and potential sites.
The coarse screening process was based upon broad general criteria which. included water availability, land use, geology, demography, meteor-ology, and seismology and was used to exclude portions of the Region of Interest or conversely to identify potential areas and candidate areas.
The staff has examined the criteria used and finds the approach reason-able except for the exclusion of areas on the basis of population density within a 5-mile radius of the potential site.**
The staff, however, has examined such exclusions and finds that the areas thus excluded are minor in comparison to the total area of the Region of Interest examined
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and are typical of areas considered (except for population level) and therefore consider such exclusion as only a minor flaw in the coarse screening process.
The applicant's intermediate screening of candidate areas resulted in
.the identification of site areas and potential sites.
The process was A
Region of Interest - The area including and surrounding the Duke service area.such that construction and' operation of a generating facility is economically feasible.
It encompasses the Duke service area plus por-tions of the States of Georgia, North Carolina, South Carolina, and Virginia not in the service area.
The total area involved is approxi-mately 70,000 sq. mi.
ns Duke used a population density level of greater than approximately 400 persons per sq. mile as an excluder.
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1argely one of evaluation through large scale mapping to produce potential site locations.
Such potential sites were at this time without formal evalua-tion. The process by which each site is further evaluated is based upon visual inspection and further application of the screening paramet'ers' identified previously. This process resulted in the exclusion of 62 sites in the original bank of 100 and in the selection of the 38 sites evaluated and presented in the Phase I study. The 62 sites were excluded for the following reasons:
18 because they were located in an area classified as natural and scenic or state park or national forest.
Several of these areas were some distance from the Duke service area.
12 because o' insufficient land and/or water to support 2600 MWe thermal stat'ans.
2 because they are current power plant sites (Catawba and McGuire).
I because it was inundated by an existing project (Lake Norman).
7 because of conmercial and industrial buildup.
7 because they were redundant to sites carried into the Phase I study as potential sites.
11 because of geolcgical considerations.
3 because they are contingency fossil sites adjacent to existing fossil stations.
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3 1 because of recent development by a municipality for water supply.
The staff has examined the above exclusion criteria for these 62 sites and agrees with them except in two respects. The Phase I study had as its objective the identification of tharmal energy' sites (both nuclear and fossil) rather than just nuclear sites.
Such an apprcach could have eliminated a
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potential nuclear site when the procedure eliminated a site as unsuitable for l
a fossil plant. The applicant has not, however, used the unsuitability of any given site for fossil as a means of eliminating any of the 62 sites as a nuclear site.
Therefore, the staff does not consider this to be a flaw in the process.
The applicant has also excluded several sites in the 100 originally in the site bank primarily because of the distance from the Duke service area.
If the number of sites examined had been small or if the applicant had not examined such a relatively large region of interest, the staff would consider such exclusion a flaw in the process.
However, since the above is not true, the flaw, if it indeed exists, is considered minor.
Finally, the staff examined the geographical distribution of the 38 remaining potential sites. This examination led the staff to the conclusion that these 38 sites are distributed throughout the region of interest in such a manner that sites for further o n-1 sideration remained in each of the candidate areas initially established in the early, phase of the studies.
Therefore, these 38 sites are representative of all the resource areas in the region of interest.
With the above in mind, the staff now focused on the data presented in the Phase I siting study dealing with the slate of 38 potential sites.
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The staff recognizes that this study was carried out to produce a prelimi-nary decision document for use by the applicant for choosing future sites.
However, relative to the Perkins review, it has a unique independence for two reasons'.
First, thr.cudy was made with the assumption that Perkins would pass muster in the present staff licensing process and the Perkins site was excluded from consideration.
The matrix and brief 4
description of Perkins in the same form as presented for other sites in the study, which are part of the reference documents used in the staff I
review and distributed to the board and parties, were prepared by the applicant on request from the staff in August 1978.
Second, the study I
was issued in January 1978 before alternative sites became an issue in 1
the Perkins review.
The staff, therefore, is of the opinion that the study has no bias toward Perkins, either pro or con.
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'ihe staff next examined the fine screening criteria used by the applicant.
The rating factors used are defined in attachments 2 and 5 of the siting study.
It is the staff's opinion that, for our purposes, two main defects exist in the rating process.
First, there is no rating factor given for land use.
The staff believas that land use character-f istics are extremely important in evaluating environmental impacts.
Second, the staff attaches no weight to the land holdings of the appli-j j
cant as a valid concern for rejection or acceptance of any particular I
site..It is, however, the staff's opinion that inclusion of land use characteristics coupled with a brief environmental analysis based on them
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might have'had the effect of eliminating some sites that were in fact i
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Thus, the lack of such data may have left a larger bank of j
i sites available for staff examination than otherwise might have occurred.
With the above caveats, the staff agrecs that the remaining rating factors are reasonable.
The rating factors were used in conjunction with weighting factors.
The use of the latter are described on pages 7 and 8 of the siting study.
With the exception of the weighting factor for seismology (listed as 1),
the staff agrees that the weighting factors are reasonable.
For seismol-ogy, although the effects of seismic activity can be " engineered out" at an increased cost to the applicant, the staff believes that, with the large area available to the applicant for siting, this particular economic penalty should not be imposed on the rate payers and that seismology should be given a weighting factor of 3 (the higher the t
I weighting factor the more important the parameter is considered to be).
Finally, it must be emphasized that all dollar costs discussed in the siting study have not been given weight by the staff as sole, first-order criteria for site selection.
Direct environmental and site suitabil-ity factors were the initial parameters considered by the staff in its review of the siting study.
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The staff finally came to the following conclusions:
1.
The siting study and additional information constitute a valid basis for determining candidate sites for 4000-MWe nuclear stations to serve the applicant's needs.
2.
The only cooling option available to the applicant at this time is closed cycle (i.e., cooling towers).
This has been confirmed by staff consultation with the State of North Carolina which assures the staff that the State will not license once-through cooling due to its greater n
heat discharge,into receiving State waters.1 3.
The applicant's reluctance to site on reservoirs controlled by third parties was rejected by the staff as a valid criterion for staff analysis.
4.
The eight candidate sites listed in Table 6 of the siting study as capable of supporting a 4000-MWe nuclear station with cooling towers are all viable and potentially licensable sites.
The staff rejected the applicant's reasons for elimination of two of these eight sites (Table 6 of the siting study, footnotes 4 and 6).
It became obvious to the staff, upon closer examination of the siting study, that a second Lake Hartwell site should be included in the list in Table 6 of that study.
This i.s the Lower Hartwell site.
It is listed in Table 1 of the siting study as a potential site but was not carried over into Table 5.
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A visit to these nine sites and the Perkins site must be made by staff personnel qualified to evaluate, on a reconnaissance level, land use characteristics, potential aquatic impacts, and water use impacts.
Staff Analysis of Candidate Sites Following the visit to the sites, the staff prepared analyses of the candidate sites in the areas of terrestrial ecology and land use, l
water availability and thermal hydrology.and potential aquatic impacts.
As a part of these analyses, the staff assessed the accuracy of the popula-tion and hydrology data presented by the applicant by independent reference 2-3 to available data banks and found such data to be reasonable.
These analyses, presented by discipline, are shown below.
Terrestrial Ecology and Land Use Ten candidate sites for a 4000-MWe nuclear power plant were visited
~by the NRC staff, including the Perkins site.
These ten sites and the characteristics used to compare them are listed in Table 1.
The identifi-cation numbers are similar to those used by the applicant except that the last digit is 2 in all cases, since the staff examined only the wet-l
' tower cooling alternative.
Site factor is a qualitative figure of merit based on the technical experience ar.d judgment of the staff terrestrial ecologist.
Sites were ranked relative to the Perkins site with a ranking of 2 being an equivalent site and 1 or 3 being better or poorer, respectively.
Key land-use criteria 9
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Table 1.
Perkins alternative site study staff analysis and comparisons for terrestrial ecology and land use.
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8 Site Identification
!,ite People eransmission Forest Railroad Rare or Code factor sq. mi.
- ines (miles) transmission right-o f-way Endangered land ecology
'"5 kV 230 kV line right-of-way Species plant animal -
Fishing Creek Reservoir 250612 1
1 114 215 0
4480 73 1
Lake Norman "E" 150512 3
2 64 33 0
500 85 1
3 Bateree 250812 2
2 24 240 0
5180 145 1
1 Clinchfield 160102 2
2 33 109 0
2460 230 4
1 Broad 160302 2
2 174 45 0
780 6,
1 Middleton Shoals 280312 2
2 71 65 85 2200 42 1
Hartwell-LaFrance 280512 3
2 138 116 9
2300 121 1
Lower Hartwell 280612 3
2 141 117 12 2350 121 1
Tuckertown 140612 2
2 51 70 50 1570 85 6
Perkins 58 8
8 260 74 1
a 1 = better than Perkins site 2 = equivalent to Perkins site 3 = inferior to Perkins site bacres
focused on current economic value of the land (retroactive to pre-acquisition for Perkins) as shown by the land being farmed versus being abandoned farmland or similar indices of land value, such as businesses or new homes.
A ranking of 1 indicates that the land has generally lower value and might, for example, derive from the land being abandoned farmland.
A ranking
,4 of 3 indicates greater value and might derive from the presence of businesses, new homes, or obviously properous agriculture.
Ecological criteria valued mature forest over early succession and diversity of plant communities and habitats over uniformity.
A ranking of 1 indicates lower ecological value and might derive from uninterrupted pine plantation or 4
uninterrupted farmland.
A ranking of 3 indicates higher ecological value j
and might derive from a mixture of mature forests, old-field succession, l
and agriculture.
Since none of these factors can be quantified at the level studied, they have been grouped into qualitative indices of land use and ecological site value.
People / square mile was calculated by the population within five miles figure, given by Duke Power and confirmed by the staff from the data bank previously referenced, being divided by 78.5, the number of square miles in a circle having a five-mile radius.
While this figure is not expected to accurately reflect the actual population of a potential site, the number 4
provides a relative estimate of the number of people who would be affected by a nuclear plant ~being sited there.
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Forest transmission line right-of-way indicates the acreage requiring clearing.
It was assumed that lines would avoid urban areas and would 4
not interfere significantly with use of rights-of-way for highway crossings, crops, or pasture.
Consequently, forest clearing was viewed as the primary adverse impact of transmission lines.
Acreages were based on the applicant's estimates of length required, R0W width (250 ft for 525 kV, 150 ft for 230 kV), and proportion of counties crossed which is forest land.
The latter data were obtained from the applicant's transmission system diagrams and the ORNL Geoecology Data Base.
Railroad ROW is considered to be a pre-emptive land use lasting for the life of the plant and beyond. Areas calculated assume a 100-ft R0W or 12.1 acres / mile.
Rare or endangered species include listings at the Federal and State levels for North Carolina and at the Federal level only for South Carolina.
With the data available, it cannot be stated that a rare or endangered species does or does not occur at one of the sites; only that it potentially occurs in the area.
Only one site had a superior site-factor rating compared to the Perkins site.
The Fishing Creek Reservoir (250612) site is abandoned farmland with early second growth (cid-field) forest on it.
A substantial portion had been cleared, but the ultimate disposition of the land was not evident.
The method of clearing was consistent with site preparation for a pine 12
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plantation.
The area population density is nearly twice that of the Perkins site but few potentially affected residences were observed.
The bald eagle (Haliaeetus leucocephalus) has been reported to over-winter on the lower Catawba River but would not be significantly impacted by a nuclear plant at this site if transmission lines were to avoid open water.
The Fishing Creek Reservoir site would require 215 miles of 525-kV transmission lines with an estimated clearing of 4480 forest acres, 17 times.the amount required for Perkins.
Railroad lengths are similar between the two sites.
Assuming similar acreages for the site proper, plus 1400 acres for the Carter Creek impoundment (a unique feature at Perkins), total land pre-emption at Fishing Creek Reservoir would be 2.2 times that at Perkins. Therefore, although the Fishing Creek Reservoir site has a higher site factor than the Perkins site, the increased forest clearing as a result of transmission line requirements obviates that advantage. The Fishing Creek Reservoir site is not considered to be obviously superior to the Perkins site from a terrestrial ecology and land-use standpoint.
i Three sites appeared to be less desirable than the Perkins site on the basis of site factors:
Lake Norman "E" (150512), Hartwell-LaFrance (280512),
and Lower Hartwell (280612).
I The Lake Norman "E" site has a moderate population with businesses and new homes.
Soma abandoned farmland is evident but considerable areas 13
r are in pasture.
Population density and forest clearing are similar to
. Perkins.
The bog turtle (Clemmys muhlenbergi), red-cockaded woodpecker 1,/g456..(Den $$ocoposborealis),cerculeanwarbler(Dendroicacerulea)anda
- i by hkrasitic shrub (Nestronia umbellula) all potentially occur in the area.
None can be said to be absent without a more detailed search, wv
..The Hartwell-LaFrance site has a considerably greater population and evidence of recent growth.
Forest clearing for transmission lines would be some nine times that required for Perkins.
Other factors are j
l similar.
The Lower Hartwell site is the most intensively farmed site visited, indicating that soils there may be superior to the Perkins site and giving the site a lower site-factor rating.
Approximately nine times as much forest would have to be cleared for transmission lines.
Other factors
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are similar.
Site factors for the remaining five sites were rated equivalent to Perkins.
The Wateree site (250812) is mixed agricultural land and managed forest, with the bald eagle being the only identified endangered species with potential conflict.
The major weakness of the site is the requirement for clearing 20 times as much forest for transmission lines.
The Clinch-field site (160102) is sparsely populated, second growth forest.
Four plant and one animal species have been listed for possible concern.
The
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Carolina scorpion (Vejovis carolinianus) is the only eastern scorpion 14
but is widespread in the southeast.
It is listed by the State of North 4
Carolina as of "special concern".
One listed plant, bigleaf scurfpea (Psaralea macrophila), is considered to be extinct.
Ginseng (Panax quinquefolium) is considered to be threatened,4 primarily due to overharvest-ing.
Both Corpeopis latifolia and Senecio millefolium have limited ranges.4 In addition, nine times as much forest would have to be cleared for transmis-l sion lines.
The Broad site (160302) did not appear to be significantly i
'different from the Perkins site except that three times as much forest would be cleared for transmission lines.
The Tuckertown site (140612) was also similar in land use but would require six times as much forest clearing for transmission lines.
Six rare plants listed at the State level potentially occur at the site.
The Middleton Shoals site (280312) is a mixture of old-field succession and young pine plantation.
Land use reflects Duke PoweT ownership for a future electrical generation facility.
If used instead of Perkins, 8.5 times as much forest would be cleared for transmission lines but only 57% as much land would be used for railroad access.
Whenever this site is developed for power produc-tion, 26,560 acres will be flooded for the necessary reservoir.
None of these five site < is obviously superior to the Perkins site.
In conclusion, ten sites including Perkins were compared for potential location of a 4000-MWe nuclear power plant.
At the reconnaissance level of information upon which the comparison was based, there were obvious differences in characteristics relating to terrestrial ecology and land 15
use among sites, but'no alternative site was judged by the staff to be obviously superior to the Perkins site with respect to these factors.
Water Availability and Thermal Hydrology Based on a total. net capacity of 3840 MWe, the Perkins Nuclear Station will dissipate about 26 x 10 Btu /hr to the atmosphere using nine circular mechanical-draft cooling towers.
These towers will evaporate water at a maximum rate of 108 cfs and will require from 120-139 cfs of makeup water depending on the number of cycles of concentrations used during cooling tower use at this rate.
About 12-31 cfs of blowdown water will be discharged from the towers at temperatures ranging from about 15 F above ambient water temperature in the summer to about 30 F above ambient temperatures in the winter.
The average makeup requirements will be about 75% of the maximum rates mentioned above (see FES Fig. 3.2 anj Table 3.2).
l The environmental impacts of the cooling tower plumes would vary
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from site to site onir by the differences in the meteorology and the j
configuration of the cooling tower layout.
Both of these aspects do not differ enough between each dlternative site and the Perkins site to alter the conclusions to be drawn when comparing the alternative sites to Perkins.
There would be some difference among the sites as to the lengths of pipe and the pumping head required to supply makeup water to the cooling towers.
These aspects cannot be evaluated with any certainty because the facilities as they would appear at these alternative sites have not been laid out in 16
detail, but the difference between the costs involved at each site will not be sufficient to make site selection hinge on this aspect.
The thermal effects of the discharge of blowdown water into a stream or reservoir of sufficient size to have been an approved source of makeup water will be small and environmentally acceptable regardless of the alternative site under. consideration.
As will be seen below,_only the Broad site may not possess an acceptable source of makeup water.
On the basis of these several considerations, the staff concludes that the major thermal and hydrological aspect in evaluating an alternative site is the availability of sufficient water for cooling tower makeup.
The staff also concludes, as did the applicant, that one of the useful criteria in evaluating. reservoir sources of water is whether the station makeup withdrawal would cause the impoundment to be excessively drawn down during periods of drought.
The staff has examined the applicant's methodology and concludes that the method used by the applicant to estimate this effect is sufficient and reasonable for alternative site analysis.
The method considers the basin drainage flowrates of record, the likely surfa'ce areas and storage volumes of the reservoir, the estimated natural evaporation rates from the surface, and the makeup withdrawal rate.
The'results are summated over the period for which historical data is available to determine a worst-case condition for depletion of the reservoir.
All of the eight alternative sites that are located on reservoirs were satisfactory in this respect.
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Comments regarding and/or data rela.tive to each of the alternative sites-considered, in the order in which they were visited, are given below.
All of the sites, except the Broad, could provide adequate makeup water for a 4000-MWe nuclear facility utilizing mechanical-draft cooling towers.
1.
Fishing Creek.
This site is on the Fishing Creek Reservoir which has an average input flow of about 4,860 cfs from the Catawba River basin and a 7Q10 flow rate of 440 cfs.
The storage volume is 60,000 acre-ft.
2.
Wateree.
This site is on the Wateree Reservoir, downstream of the Fishing Creek Reservoir on the Catawba River.
The input flow is estimated to average 5825 cfs and the 7Q10 flowrate is given as 446 cfs.
The storage volume of the impoundment is 303,900 acre-ft at full pond elevation.
3.
Middleton Shoals.
This site is on the Savannah River downstream of Lake Hartwell.
Location of the site takes.into account the possibility of the Richard B. Russell project impounding the river downstream of the site, but the adequacy of the makeup supply.is not contingent on comple-tion of the downstream dam.
The average stream flow in the Savannah River is 4214 cfs at the site and the 7Q10 flow is given as 1200 cfs.
The up-stream storage capacity is sufficient to assure an adequate flow.
4.
Hartwell.
The following comments as to the hydrology of this alternative site apply to both the Hartwell-LaFrance site north of I 18 n
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- and to the Lower Hartwell site south of the highway.
Lake Hartwell is a large reservoir having a storage volume of about 2,563,000 acre-ft and an average input flow of about 4400 cfs.
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Clinchfield.
This alternative site would be on the shoreline
- of the proposed U.S. Army Corps of Engineers' Clinchfield Reservoir, which would impound the Broad River downstream of its confluence with the Green River.
The storage volume of this reservoir would be about 820,000 acre-ft and the average input flow is estimated to be about 970 cfs.
The 7Q10 flowrate of-269 cfs is the sum of the rates for the Green River and the Broad River at this location.
The supply for a 4000-MWe nuclear facility depends on the creation of the Clinchfield Reservoir.
6.
Broad.
This alternative site, on the Broad River downstream of the Clinchfield alternative site, is the only one of the nine alternative site that would not be on an existing or planned reservoir.
The Broad site would therefore require impoundment of a nearby stream to augment the Broad River as required during periods of low flow, similar to the i
purposes of the Carter Creek impoundment at the Perkins site.
The flow in the Broad River at the alternate site has a 7Q10 rate of 331 cfs, which is marginal for the makeup water supply, t
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Tuckertown.
This alternative site is located on the Tuckertown Lake, which is on the Yadkin River downstream of High Rock Lake and just upstream from Badin Lake.
The storage volume is given as 42,500 acre-ft Y
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i and the average input flow as 4684.cfs.
The 7Q10 flowrate of 1400 cfs is essentially the quantity of water that must be released from High Rock Lake to follow the rule curves for power generation at High Rock Dam.
b Tuckertown Lake is essentially a run-of-the-river type reservoir.
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Perkins.
The site is located on the Yadkin River upstream of High Rock Lake.
The average flow is 2880 cfs and the applicant has i
committed to building of Carter Creek impoundment to prevent the con-sumptive water use by the nuclear plant from contributing to low flows below 1000 cfs.
The water supply,-with such a commitment, is sufficient for the makeup requirements of a 4000-MWe nuclear station.
9.
Lake Norman "E".
This alternative site is on a peninsula on the north side of Lake Norman in the Catawba River drainage basin.
The i
storage volume.of the reservoir is about 1,093,600 acre-ft and the estimated average input flow is about 1600 cfs.
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The staff concludes, based on the above hydrologic analysis, that of the alternative sites, only one, the Broad site, has a marginal quantity of water available for cooling tower makeup.
As indicated, the adequacy of the Clinchfield site would. depend upon construction'of the Clinchfield Reservoir or a similar impoundment.
The remaining seven alternative sites would have' sufficient water available to supply the cooling tower makeup requirements without causing significant environmental impacts.
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Aquatic Ecoloqy The aquatic assessment is based on visits to the alternative sites and the Perkins primary site by NRC and ORNL specialists and reconnaissance-j level information available for the alternative locations.
This information j
consists of (1) basic hydrological data (e.g., streamflows) from the docu-ments supplied by the applicant as a result of staff requests as independ-2 ently verified by the staff; (2) impact statements completed for projects which are (or will be) located on the same or similar river systems as the sites being evaluated; (3) government reports on the limnology and l
fisheries of the region and on the occurrence of endangered species; and (4) miscellaneous reports on the biology of Piedmont streams and reservoirs.
The list of references cited contains the major sources which were consulted.
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The rivers and reservoirs of the Carolina Piedmont are typically turbid, soft, and relatively unproductive.5-11 The impoundments are generally quite similar to each other in major physicochemical and biotic characteristics.
Thus, most display high dissolved oxygen (D.O.) demands,
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are not fully stratified in the summer (due to flow manipulation), have a shallow euphotic zone, and contain large deposits of allochthonous sedi-
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,12,13 ment.
Fish production is relatively low compared to the less turbid waters in the Coastal Plain, and the community composition is typical of warm water impoundments; dominant species are threadfin and gizzard shad, catfish, largemouth bass, sunfish, crappie, carp, gar, and buffalo.5,7,13 The larger streams are likewise quite similar.
They all contain large 21
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sediment loads and support less. fish'than the clearer, harder waters toward the coast.
Prevalent species' include suckers, carp, sunfish, gizzard shad, and " minnows".(e.g., shiners).5,6,7,14 L
None of the sites should contain any endangered aquatic species since the habitats for these organisms.in the Carolinas occur in the mountainous l
western portion.4,20 Surveys conducted in support of the preparation of 1
l environmental impact statements for facilities on Piedmont river systems 1
also indicate'that endangered' species are unlikely to occur.13-14,16-19 None of the river systems involved are a part of the Wild and Scenic River System.21 The reservoirs are all heavily used recreationally and the rivers are heavily fished in some areas.12-14,16-19 The Perkins site and Broad site (both river sites) appear to contain similar aquatic habitats.10,14 However, location of the station at the Broad site would result in the entrainment of a greater percentage of the average river flow (Table 2).
Thus, the Broad site appears to be inferior to Perkins since location of the facility there would, in the opinion of the staff, result in a greater adverse impact to the biota.
The reservoir sites could probably all support a 4000-MWe nuclear station (with' cooling towers) without significant impact to the aquatic 22-
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Table.2.. Selected hydrological and aquatic ecological data for the-Perkins site and nine alternative sites.
Average Flow in river-Water.
Endangered Part of wild and or through Site
' type spp. likely?
scenic river system?
reservoir, CFS
'Perkins River no no 2880'
' Fishing Creek Reservoir Reservoir lo no 4860 Lake Norman "E" Reservoir no no 2600
~
.Wateree Reservoir no nc 5825 Clinctifield Reservoir no no-970 h
Broad River no no 1470 Middleton Shoals Reservoir no no 4214 Lake Hartwell-LaFrance Reservoir no no 4400 Lake Hartwell-Lower Reservoir no no 4400 Tuckertown Reservoir no no 4684 i
Source:
References 4, 12-14, 16-21; Duke Power Co. Phase I Siting Study; Duke Power Co.
submittal to NRC of 8/31/78.
=.
biota.
The small volume of blowdown (12-31 cfs) and withdrawal (120-139 cfs max.) relative to the volumes of the reservoirs should cause any effects to be localized.
However, during prolonged periods of drought the impacts would, as usual, become more pronounced since the reduction in water volume would increase the discharge and intake effects (although they still might not be significant).
From an aquatic ecological standpoint, the Perkins site has been shown to be an acceptable location for the facility since no significant impacts are predicted to occur at that site.14 It is possible that.loca-tion of the plant at one of the alternative sites would result in even less of an impact than that which is predicted for Perkins.
It is, however, the staff view that such lesser impact would not be of such major propor-tions as to make that site clearly preferable to the Perkins site.
l Conclusions The staff, on the basis of the overall analysis presented above, has agreed that alternatives to the Perkins site should be ranked relative to the latter as follows:
i Sites slightly better:
Fishing Creek, Wateree, and Middleton
-Shoals Sites roughly equal:
Tuckertown and Clinchfield 24
4 f
Sites slightly worse:
Lake Norman "E", Broad, Lake Hartwell-LaFrance, and Lake Hartwell-Lower No alternative site stands out as one which could be rated as obviously superior.
All of_the sites examined, with the possible exception of the Broad, are reasonable and potentially licensable to support a 4000-MWe nuclear station with cooling towers.
Differences between all the sites are subtle and gradations between them-are minor.
We therefore, have reaffirmed our conclusions contained in the FES that none of the alternatives considered is obviously superior to the Perkins site as a reasonable and licensable site for the 3840-MWe (net) nuclear station proposed by the applicant, Duke Power Company, based on environmental considerations.*
A The North Carolina Utilities Commission also reached the conclusion, af ter 11 days lof public hearing and upon evidence of its staff, the applicant, and intervenors, that, considering the available alter-native sites, Perkins is the most appropriate site (Certificate of Convenience and Necessity, Perkins transcript page 1455).
25
I REFERENCES 1.
Letter from L. P. Benton, Chief, Environmental Operations Section, Division of Environmental Management, North Carolina Department of Natural Resources and Community Develcpment, dated October 19, 1978, addressed to Charles A. Barth, Counsel for NRC Staff, U. S.
Nuclear Regulatory Commission, Washington, D. C.
20555.
2.
U. S. G. S. Water Quantity within STORET.
3.
ORNL-TM 3923, 1972.
PANS - A program to Tally Population by by Annuli and Sectors by P. R. Coleman and A. A. Brooks.
4.
Cooper, J. E., S. S. Robinson, and J. B. Funderburg.
1977.
Endangered and threatened plants and animals of North Carolina.
North Carolina State Museum of Natural History, Raleigh, North Carolina, 444p.
5.
Fish, F. F. 1968. A catalog of the inland fishing waters in North Carolina.
North Carolina Wildlife Resources Commission, Div. of Inland Fisheries.
6.
Duke Power Co 1962.
The Catawba River:
Limnological and water quality studies, April to hovember,1960.
Duke Power, Charlotte, North Carolina.
7.
Yount, J. L. 1966.
South Atlantic States.,In:
P. G. Frey (ed.), Limnology in North American, pp. 269-286.
8.
U. S. Army Corps of Engineers.
1969.
Development of water resources in Appalachia. Main report. Part III.
Project analyses.
Chps. 5-7.
Office of Appalachian Studies, Cincinnati,
, 9.
Economic R e arch Service, Forest Service, Soil Conservation Service.
1973. 5..cee River Basin: Water and land resources (North Carolina, South Carolina), U. S. Department of Agriculture.
10.
State of North Carolina Departiaent of Natur31 and Economic Resources.
1976. Classifications and water quality standards assigned to the waters of the Broad River basin. Division of Environmental Management, Water Quality S(ction.
- 11. Weiss, C. M.,
P. H. Campbell, T. F. Anderson, and S. L. Phaender.
1975. The lower Catawba Lakes: Characterization of phyto-and zooplankton communities and their relationships to environmental factors. Department of Environmental Sciences and Engineering.
School of Public Health. University of North Carolina at Chapel Hill.
12.
U. S. Army Corps of Engineers.
1974. FES for the Richard B.
J Russel Dam and Lake (formerly Trotter's Shoals Lake), Savannah j
River, Georgia and South Carolina.
13.
U. S. Nuclear Regulatory Commission, 1972. FES-OL for Oconee Nuclear Station Units 1, 2, and 3.
(Duke Power).
14.
V. S. Nuclear Regulatory Commission.
1975.
FES-CP for Perkins Nuclear Station Units 1, ?, and 3.
(Duke Power).
NUREG-75/088, f
- 15. Hynes, H. B. N.
1970. The ecology of running waters. University of Toror to Press.
16.
U. S. Nuclear Regulatory Commission.
1975. FES-CP for Cherokee Nuclear Station Units 1, 2, and 3.
(Duke Power'.
NUREG-75/089.
17.
U. S. Nuclear Regulatory Commission. 1972.
FES-CP for William B.
McGuire Nuclear Station, Units 1 and 2.
(Duke Power)
4 3-l 18.
U. S. Nuclear Regulatory Commission.
1973. FES-CP for Catawba l
Nuclear Station Units 1 and 2.
(Duke Power).
l l
19.
V. S. Nuclear Regulatory Commission.
1976. FES-OL for William B.
McGuire Nuclear Station Units 1 and 2.
(Duke Power). NUREG-0063.
20.
U. S. Fish and Wildlife Service, Federal Register of Sept. 25, 1975, June 14, 1976, July 14, 1977, August 11, 1977, August 23, 1977. Sept. 9, 1977, Sept. 22, 1977, March 27, 1978, April 13, j
1978, April 18, 1978.
21.
U. S. Department of the Interior.
1977. Outdoor recreation action No. 43. Bureau of Outdoor Recreation, Washington, D. C.
i l
d 8
s
PROFESSIONAL QUALIFICATIONS ROBEP.T A. GILBERT ENVIRO?1 ENTAL PROJECTS 3PANCH NO. 2 DIVISION OF SITE SAFETY ff!D ENVIROFENTAL ANALYSIS
'iv name is Pobert A. Gilbert.
I am employed by the U. S. Nuclear Regulatory Co".tnission, !!ashington, D. C. 20555.
I an an Environnental Project ilanager, and, as such, ac sponsible for nanaging and coordinating (1) the review of the Environmenta tports, (2) the evaluation of the environmental impacts of nuclear power 01,.
- onstruction and operation, and (3) the preparation of the Environnental aatenents describing those impacts.
I received an AB degree from !1 abash College, Crawfordsville, Indiana, with a snlit nathematics-chemistry major and a Ph.D. in physical-inorganic chenistry from the Ohio State University, Columbus, Ohio.'
From 1949 to 1956, I was enployed by Battelle Menorial Institute, Columbus, Ohio, as a research engineer.
I carried out high accuracy physical pro-perty neasurements on inorganic compounds and produced high-purity metals using modified Van Arkel-de Boer iodide process.
In 1956 1 accepted a position as a research chemist at the Oak Ridge National Laboratory (ORNL).
Siy research interests have involved calorimetry, thermochemistry, and the themodynamics of fused salts, particularly in relation to the Aircraf t Nuclear Prr~ ilsion Progran and the Molten Salt Peactor.
In July,1972, I transferred to the Impact Statement Project at ORML and
^
wrote sections of the Environmental Statements for Arkansas 1 and 2 Voqtle and Comanche Peak.
I also participeted in applicant Environmental Report reviews for Vogtle, Ginna, Douglas Point'and Comanche Peak.
I assuned my duties as an Environmental Project Manager in September,1973.
Since that ' time, I have participated in the construction permit reviews of the following nuclear plants, Catawba, Perry, Perkins, Cherokee, Palo Verde and Jauesport, the coerating license review of the Shorehan Nuclear Power Station and the review leading toward the issuance of a full-tern license for the Oyster Creek Nuclear Generating Station.
I am also involved in the pretendering activit;es for nuclear facilities proposed by New York State Electric and Gas Corporation.
I have testified in hearings for the Catawba, Perrv, Cherokee, Perkins and Palo Verde stations.
I have been responsible for the Perkins and Shoreham reviews fron the receipt of the applications to the present and coordinated the issuance of the Draft and Final Environmental Statements.
I also issued the Final Environmental Statements for Catawba and Cherokee.
For the past several years I have been engaged in an examination of the current status of solar and other alternate energy technologies.
This has included visits to solar demonstration facilities located at the University of Tennessee and at the University of Delaware, and participation in alternate enercy seminars.
"y involvenent has included consideration of the use of such technologies in reducina the demand for electrical power as an alternative to larqe base load generating plants, the use of solar energy to provide electrical 1
. pover and the teaching of a connunity service course in alternate energy technologies at 'lontgomery College, Rockville, '1aryland.
~
My honors include Phi Beta ' Kappa, Sigma Xi, and Phi Lambda Upsilen.
I am the author or co-author of several papers involving physical measure-ments, calorimetry and themodynamics.
I have been an ORNL traveling lecturer and a guest lecturer at Wayne State University in their
" Frontiers of Chemistry" series.
o
l
- 11. E. Zitt el Professional Qualifications Oak Ridge National Laboratory Energy Division I am at present Manager of the Environmental Impact Statements Project at the Oak Ridge National Laboratory and the Shoreham Environmental j
Impact Statement was prepared under my supervision.
Since.1972 I have actively participated both in the development of the methodology of assessing the environmental impact of nuclear power f
reactors and the writing of sections of Environmental Statements, primarily in the area of chemical effluents.
I have acted as Task Grcup Leader in the preparation of Environmental Statements for the last several years, supervising the preparation of statements on various reactors and have personally prepared various sections of these reports.
My formal education includes a Bachelor of Science degree in Chemistry received in 1948, a Master of Science degree in Chemistry received in 1951, and a Ph.D. in Chemistry received in 1953, all from Vanderbilt University.
Following my Ph.D. degree I taught Physical and Analytical Chemistry at the undergraduate IcVel and directed research at the graduate level (primarily non-aqueous electrochemistry) for five years.
In June of 1958 I joined the staff of Oak Ridge National Laboratory as a Research Scientist in the Analytical Chemistry Division.
During the following ten years I conducted or supervised research in the areas of
'clectrochemistry, spectrosocopy and radiation chemistry.
During this period I headed a section developing new methods for the analysis of reactor materials.
In 1968 I began research in the nucicar safety field with emphasis on the effects of radiation on nuclear safety sprays.
These research efforts have resulted in forty odd open literature publications on subjects ranging from electro-chemical studies on the halides to the generation of radiolytic hydrogen following a loss-of-coolant accident.
In 1972 I began working with an interdisciplinary group on the Environmental Impact Statements Project, transferring to the Energy Division in 1974.
I have been a consultant to the ACRS for the last six years.
I am a member of Sigma Xi, the American Chemical Society, and the American Association for the Advancement of Science.
a
)
J Statement of Pre.csional Qualification ROY C. R33CRfSON My residence is at 2117 Indian Hills Drive, Knoxville, Tenneasce, 37919 I am presently employed in the Thermal-Hydraulics Group of the Energy Division, Oak Ridge National Laboratory (ORHL), Oak Ridge, Tennessee, 37830. I hold BS and FS degrees from the University of Tennessee and am a licensed engineer in the State of Tennessee. Past experience in the engineering field has included writin6, design, develop-ment, consulting, teaching, and special studies. I served four years on the Tennessee State Board of Boiler Rules.
I was a liational Vice-President of the American Society of Mechanical Engineers for three years and am.a Fellow in the Society.
My experience (ten years as an Associate Professor of Mechanical Engineering at the University of Tennessee and twenty-two years at ORNL) has largely been in the areas requirin5 thencodynamics, fluid flow and heat transfer analysis and design, such as in steam power stations, re-f;igeration, air conditionAng, and heat dissipation systems. Most of my experience at' ORfL has be m. in the fluid reactor field (ho::.ogenecus,
j slurry, molten-salt, etc.) and I was associated with the molten-salt re-actor project for ten years. I have worked for more than four years at making th'ermal analyses of nuclear power plant heat dissipation systems and writing the appropriate sections for the environmental statements prepared at ORNL for the Nuclear Regulatory Commission. These plants have included Shorehma, Newbold Island, Fulton, Indian Point 1, Indian Point 3, Tyrone, Perkins, Cherokee, North Coast, and Sundesert. A list of major publicationa is attached.
s March, 1977.
Major Publications 1
Rent Power Cycles and Prime Movers for nuclear Power Plants, ORIL I
1 CF h6-10-77, October 1956, 88 p.
Refrigerating a Romogeneous Reactor, Journal American Society of Heatin6s Refrigerating and Air Conditioning Engineers, Febmary 1960. '
Terwinal Report - Design of a Darex Dissolution Facility in ORIL Bldg.
3019 for Enriched Power Reactor Fuel Elements, CRIL CF 59-11-26, November 1959,102 p.
MSRE Design and Opera' ions Report, Part I, Description of Reactor Design, OTdL TM-728, January 1965, 536 p.
Design Studica of 1000-MW(e) Molten-Salt Breeder Reactors (with P. R. Kanten and E. S. Bettis), ORIL-3996, Augurt 1966, 150 p.
Review of Methods of Mitigating Spread of Radioactivity from a Failed' Containment System, ORIL-IGIC-27, Sept.,1963,103 p.
Molten-Salt Breeder Reactors (with M. W. Rocenthal and E. S. Ecttis),
Nuclear Engineering, May 1969 The De gn and Perforuance of Molten-Salt Breeder Recetors (with M. U. Rosenthal and L S. Bettis), Nuclear Engineering International (London), June 1969, pp 420-425 Assessment of Molton Salts as Intermediate Coolants for lh1FBR's (with H. F. McDuffic, H. E. McCoy, Dunlap Scott, and R. E. Thoma), ORIL TM-2696, September 1969, 38 p.
Graphite Behavior and Its Effects on MSDR Performance, (with P. R.
I Kasten, E. S'. Bettis, W. R. Cook, W. P. Eatherly, D. K. Holmes, R. J. Medl,,C. R. Kennedy, S. S. Krislis, H. E. McCoy, A...M. Perry, D. Scott, and H. A. Strehlow), Naclear Engineering and Desig.9, 9, 1969, pp 157-195.
MSBR Design and Perfomance Features (with E. S. Bettis), Nuclear Applications, Fall 1969 i
'The Design and Performance Featurec of a Sing 1c-Fluid Molten-Salt Breeder Reactor (with E. S. Bettis), Uuclear Applications and Technology, February 1970, pp 190-207 Two-Fluid Molten-Salt Breeder Reactor Design Study (Status as of January 1,1968), (with R. B. Briggs, O. L. Smith, ar.d E. S. Bettic),
ORIL-4528, August 1970, 79 p.
Conceptun1 Design Study of a Sing 1c-Fluid Molten-Salt Breeder Reactor, Editor, (with contributions by M. W. Rosenthal and 29 others), OR?L-45hl, June 1971, 190 p.
Initial Comparisons of Modular-Sized Integrated Utility Systems and Con-ventional Sys tems, O!UL RUD 12U3-6 (with A. J. Miller and 8 others),
, June 1972, 247 p.
I i
PR0f'sSSIONAL QUALIFICATICUS DR. STEPHEN B. COUGH e
I an employed as a Research Associate in the Environmental Sciences Division at Oak Ridge Untional Laboratory, Oak Ridge, Tennessee.
I received a B.S.
(Iiegna l
i Cum Laude) from Carroll College (WI) in 1972 vith a major in biology and a minor in chemistry.
In 1976, I received the Ph.D. degree from the University of Wisconsin-Madison with a major in botany and a minor in oceanography and limnology.
From 1970-1972 I was employed as a part-time consultant in a veter quality consulting firm (Bionomics, Inc. ) in Waukesha, WI.
My work encompassed lake restoration / enhancement projects and industrial effluent monitoring. During the summer of 1972 I administered a National Science Foundation grant en farm feedlot runoff at Carroll College. At the University of Wisconsin I was employed as a Research Assistant in the Botany Department from 1972-1975 My duties involved research in algal ecology, with an emphasis on the green algae of southern Wisconsin hard water lakes. From 1975-197r I served as a Teaching Assistant and assisted it the instruction of courses in jnycology and general botany.
My doctoral thesis at the University of Wisconsin was entitled:
" Studies on I
l Wisecusin Desmide (Desmidiales, Chlorophyta) with Emphasis on Those Occurrin6 in Hard Waters." I have several publications in the open literature and have assisted in the preparation of several impact statements.
I have been in the Ecolo61 cal Analyses and Applications Program of the Environmental Sciences Division at Oak Ridge National laboratory since June, 1976.
My duties have primarily involved the assessment of aquatic ecological impacts attributable to various segments of the nuclear fuel cycle.
I am a member of the American Association for the Advancement of Science, the American Instituta of Biological Sciences, the American Society of Limnology and Oceanography, Inc., the Botanical Society of America, the British Phycological
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w PROFESS 10tlAL QUALIFICATI0M OF DR. JAMES F. McBRAYER
'I am employed as a Research As" icte in the Environmental Sciences Division at Oak Ridge itational L. aora'.ory, Oak Ridge, Tennessee.
My educational background includes a B.S.Ed. (biology) from Miami University in 1963, M.S. (entomology) from Purdue University in 1970, and Ph.D.
(ecology) from the University of Tennessee in 1973.
I taught biology at Anderson High School, Cincinnati, Ohio, from 1963 to 1967.
From 1967 to 1969, I was graduate research assistant and National Science Foundation trainee at Purdue University where I managed a research project on effects of agricultural management practices on turnover of field-crop residues.
My thesis research on trophic structure of forest soil invertebrates was done in cooperation with the Radiation l
Ecology Section of Oak Ridge National Laboratory.
From 1969 to 1973, I was supported by grants from the National Aeronautics and Space. Adminis-tration and the Eastern Deciduous Forest Biome (IBP) to the University of Tennessee.
During that period I conducted research on decomposition and elemental cycling in a deciduous forest on the Oak Ridge ERDA Reservation.
In March 1973, I was appointed Assistant Research Ecologist at the Labora-tory of Nuclear Medicine and Radiation Biology, University of California at Los Angeles, where I conducted research on radionuclide cycling and terrestrial invertebrate ecology in northern Mojave Desert.
From 1974 to 1976, I was Assistant Professor of Ecology at the University of Minnesota-
. Twin Cities, where I taught " Energy and nutrients in terrestrial ecosystems" and " Introductory ecology".
My research was on the effect of snow pack on decomposition in northern, oak savanna :and the role of fossorial animals in community succession.
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I joined the staff of the Oak P.iJge National Laboratory in 1976 as a menber of the Ecological Analyses and Applications Program of the Environmental Sciences Division.
In this position, my primary respon-sibilities include the assessment of potential impacts on terrestrial ecosystems and land uses from construction and operation of nuclear power plants.
I am a member of the American Association for the Advancement of Science, the American Institute of Biological Sciences, the Ecological, i
Society of America, the Entomological Society of America, and Sigma Xi, The Scientific Research Society of florth America.
~
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GNtb Robert A. Gilbert
.f Sworn before me this 1. 7.. ([f<,j day, o}f October.,1978
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- NY h.Rs H.E.Zigel Sworn before me this d 'I day of October, 1978 flotary Public, State of Tennessee
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'My Ccmmission expires October, 1979
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Roy 'CTRobertson
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Sworn before me this _2 f_
day of October,1978 tiotary Public SrmE uF re"Nasci cou ~rv of Runc W
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UNITED STATES OF AMERICA UUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
')
)
Docket Nos. STN 50-488 DUKE POWER COMPANY
)
STN 50-489
)
STN 50-490 (PerkinsNuclearStation
)
Units 1, 2 and 3)
)
CERTIFICATE OF SERVICE I hereby certify that copies of proposed staff testimony entitled " SUPPLE-MENTARYNRCQTAFFTESTIMONYREGARDINGTHECRITERIAIlSEDTOSELECTSITE ALTERNATIVES TO THE PERKINS SITE AND THE EXAMINATION OF SITE ALTERNATIVES TO PERKINS" in the above-captioned proceeding have been served on the following by deposit in the United States mail, first class, or, as indicated by an asterisk, through deoosit in the Nuclear Regulatory Commission's internal mail system, this 7th day of November,1978:
- Elizabeth S. Bowers, Esq,, Chainnan William A. Raney, Jr., Esq.
Atomic Safety and Licensing Board Special Deputy Attorney General U.S. Nuclear Regulatory Commission P. O.
Box 629 Washington, D.C.
20555 Raleigh, North Carolina 27602 Dr. Donald P. deSylva William L. Porter, Esq.
Associate Professor of Marine Associate General Counsel Science Duke Power Company Rosenstiel School of Marine 422 South Church Street and Atmospheric Science Charlotte, North Carolina 28242 University of Miami Miami, Florida 33149 Willisa G. Pfefferkorn, Esq.
P. O. Box 43 Dr. Walter H. Jordan Winston-Salem, North Carolina 27102 881 W. Outer Drive Oak Ridge, Tennessee 37830 Mrs. Mary Davis Route 4 J. Michael McGarry, III, Esq.
Box 261 Debevoise and Liberman Mocksville, North Carolina 2702S 700 Sh rcham Building 15th and H Streets, N.W.
Washington, D.C.
20005
- 9 Nw.
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Perkins fluclear Station
- Atomic Safety and Licensing Board Panel U.S. fluclear Regulatory Commisri'on Washington, D.C.
20555
- Atomic Safety and Licensing Appeal Coard Panel U.S. fluclear Regulatory Commission Washington, D.C.
20555
- Docketing and Service Section Office of the Secretary U.S. fluclear Regulatory Commission Washington, D.C.
20555 i
n M
Charles A. Barth Counsel for NRC Staff b
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