ML18030A005

Forwards Comments on Draft Suppl to Draft EIS Re Operation of Facilities,Specifically Pond Hill Creek Reservoir

ML18030A005
Person / Time
Site:	Susquehanna
Issue date:	05/30/1980
From:	Robert Davis ENVIRONMENTAL PROTECTION AGENCY
To:	Bajwa S Office of Nuclear Reactor Regulation
References
NUDOCS 8006030363
Download: ML18030A005 (5)

Text

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ACCESSION '<BR:8006030363 DOC DATE: 80/05/30 NOTARIZED! NO DOCKET ¹ Electric Stationi Unit ii Pennsylva

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FACIL: - Susquehanna Steam 05000387 50 388 sauehanna Steam Electric Stationi Unit 2i Pennsylva 05000388 A w-;~8 AU THOR AFF ILIAT ION EROSE Envi ronmental Protect i on Agency RECI ~

~ NAME RECIPIENT AFFILTATION Assi stant Di r ector for Environmental Technology HAJAAES ~ ST Assistant Director for Environmental Technology

SUBJECT:

Forwards comments on draft suopl to draft EIS re'peration of facilitiesEspecifically Pond Hill Creek Reservoir, DISTRIBUTION CODE: C0028 COPIES RECEIVED:LTR Q ENCL SIZE:

TITLE: Environ, 4~0 < F~ > CY~

Comments'nTES:

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REC IP IENT COPIES RECIPIENT COPIES IO CODE/NAME LTTR ENCL ID CODE/NAME .LTTR ENCL ACTION: 05 Ph,P.mac@ 1 1 17 BC O'BWW >1 1 18 I AMS+'L AD moog.~ 0 INTERNAL: 1~E.G 1 02 NRC PDR 1 1 0 u,E 2 2 09 ENVN SPEC BR 1 1 10 CST BNFT ANL 1 . 1 12 GEOSCIEN BR 1 1 13 HYDRO METEOR 1 1 1< ACDENT ANALY 1 15 EFLT TRT SYS 1 1 16 RAD ASMT BR 1 1 19 DIR OSE 1 1 AD ENV IRONi TECH 1 0 40 SITE ANALY 1 0 OELD 1 0 EXTERNAL: 03 I POR 1 1 0<1 NS IC 1 1 20 NATL LAB 5 5 ACRS 0 I+.

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,<qf 0 Sly'c UNlTED STATES ENVIRONMENTAL PROTECTION AGENCY mac<+ REGION III 6TH AND WALNUT STREETS PHILADELPHIA. PENNSYLVANIA 19106 I

MAY 30 1980 Director, Division of Site Safety & Environmental Analysis Attn: Mr. S. Singh Bajwa Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, D.C. 20555

Dear Mr. Bagwa:

Thank you for granting us a short extension on the deadline for sub-mitting comments on the Draft Supplement to the Draft ETS related to operation of SSES, Units 1 and 2, specifically the Pond Hill Creek Reservoir.

Our comments are attached and if any questions arise in relation to them please contact us on FTS 597-7188.

Sincerely yours, Robert S. Davis Attachment Q~cV 8006080 8 ~

Below are comments on Draft Supplement EIS SSES for the Pond Hill Reservoir pumped storage facility. We believe an ER-2 rating is justified relative to this document. Please find attached a copy of our system for commenting on EIS's. The ER stands for Environmental Reservations and the 2 indicates Insufficient Information.

Information regarding floods and flooding is sparse. In addition, the map on page 2-7 does not adequately depict the Pond Hill Creek floodplain nor the Susquehanna River Floodplain. No doubt some changes will take place in these areas as a result of the project and such changes should be addressed.

With regard to flooding, our information does not agree with either the applicant's or the NRC's. Calculations based upon the maximum storm of recent years, i.e. hurricance Agnes, indicates a 686 mm precipitation event. It is our belief that this impoundment would be topped in such a storm and, depending upon dam construction, may wash out and compound the downstream damages due to flooding. In addition, thorough information should be presented regarding other effects of storms of lesser intensity so that a complete analysis can be made.

The flooding impact potentials as well as the floodplain effects may in themselves indicate that the impoundment should not be built; however, one other point should be more thoroughly presented. This is the frequency analysis of low flows that would interrupt the operation of the power sta-tion. In this context, the use of such terminology as "... in some years..." and "... require several shutdowns..." is too inspecific for ade-quate evaluation. The reasons for not using the river follow alternative, then, based upon information here, are inadequate.

Around the saddle from the "top of the ridge"~ where a dike is to be placed>

is another saddle. This second saddle appears to be within the same contour lines as the "saddle" to be diked yet no mention is made either of its potential as an "accidental" spillway in times of severe flooding or of the necessity of a dike in this area. (Re. fig. 3.2, p 3-3). Furthermore, no mention is made of the severe flooding potential associated with the Lily Lake'a very low saddle between these two sites indicates a possible spill over into Pond Run watershed during severe storm periods.

The discussions on wildlife resources is acceptable, but shows some defi-ciencies with regard to periodicities exhibited by some animals. For exam-ple, it is stated with far too much assurance that the eastern cottontail is of minor importance. However, this animal is currently near or at the low point in its seven year cycle. (p 2-11). As the cottontail is a major com-ponent of the food web further decreases in its population may be signifi-cant.

The operational parameters discussed on pages 3-4 and 4-10 & 11 fail to des-cribe adequately the frequency of intakes and releases and their effects on the reservoir itself and upon the Susquehanna River. For example, this

reservoir may have multiple uses among them being recreation. The worst possible case should be described when the level is dropped to an extreme where such activities are curtailed. Also, during these low levels what will the effects be upon the Susquehanna at the point where reduced flows in the river are augmented by the maintenance from the reservoirs During low flow periods, when the reservoir intake cannot be used, and the river must be augmented by flows from the impoundment, will evaporative losses be significant'vaporative losses during hot weather are large.

These losses coupled with drawdown may indicate a shorter useful storage capacity than is indicated in the document.

In sum, this supplementary document does not adequately discuss alternative measures other than providing flows from the river itself or other reser-voirs. Alternative sites to the one presented here are given only cursory attention. Under the new CEQ guidelines, such docunents as this are sup-posed to describe the decisionmaking process and not merely represent the most favorable arguments for choosing this alternative.

CHAPTER 3 REVIEW OP FEDERAL PREPARATION, APPROVAL AND ACTIONS IKPACTING DISTRIBUTION OF CONHENTS THE BPIRONHENT ON FEDERAL ACTIONS Environmental Impact of the Action Lo Lack of Objections EPA has no objections to the proposed action as described in the draft impact statement or suggests only minor changes in the proposed action.

ER Environmental Reservations EPA has reservations concerning the environmental effects of certain aspects of the proposed action. EPA believes that further study of suggested alternatives or modifica-tions is requ'red and has asked the originating Federal agency to reassess these aspects.

EU Environmentally Unsatisfactory EPA believes that. the proposed action is unsatisfactory because of its potentially harmful effect on the environ-ment. Furthermore, the Agency believes that the potential safeguards which might be utilized may not adequately pro-tect, the environment from hazards arising from this action. The Agency recommends that alternatives to the action be analyzed further {including the possibility of no action at all) .

Category 1 Adequate The draft impact statement adequately sets forth the environmental impact of the proposed project or action as well as alternatives reasonably available to the project or action.

Category 2 Znsufficient information EPA believes that the draft impact statement does not contain sufficient information to assess fully the environmental impact of the proposed project or action.

However, from the information submitted, the Agency is able to make a preliminary determination of the impact on the environment. EPA has requested that the originator provide the information that was not included in the draft statement.

Category 3 Znadequate EPA believes that the draft. impact statement does not adequately assess the environmental impact of the" pro-posed project or action, or that the statement inadequately analyzes reasonably available alternatives. The Agency has requested more information and analysis concerning the potential environmental hazards and has asked that sub-stantial revision be made to the draft statement.

Zf a draft impact statement is assigned a Category 3,

~rdinarily no rating will be made of the project or action, since a basis does not generally exist on which to make such a determination.

CHAP 3 Figure 3-1. Notification of EPA's Classification ]-)S of Comments 3 Page 2 of 2