ML19254E366

Proposed Findings of Fact & Conclusions of Law in Form of Partial Initial Decision Permitting Lwa.List of Exhibits & Certificate of Svc Encl

ML19254E366
Person / Time
Site:	Skagit
Issue date:	09/14/1979
From:	Bauser M, Little D, Thomsen F LOWENSTEIN, NEWMAN, REIS, AXELRAD & TOLL, PERKINS, COIE (FORMERLY PERKINS, COIE, STONE, OLSEN, PUGET SOUND POWER & LIGHT CO.
To:
References
NUDOCS 7910310504
Download: ML19254E366 (157)

Text

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q-UNITED STATES OF AMERICA k ;;;ga\S3 Jf,;.

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NUCLEAR REGULATORY COMMISSION Cts y BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )

) Docket Nos. 50-522 PUGET SOUND POWER & LIGHT ) 50-523 COMPANY, et al., )

)

(Skagit Nuclear Power Project, ) September 14, 1979 Units 1 and 2) )

)

APPLICANTS' PROPOSED FINDINGS OF FACT AND CONCLUSIONS OF LAW IN THE FORM OF A PARTIAL INITIAL DECISION AUTHORIZING LIMITED WORK AUTHORIZATION

1. On October 24, 1975, and April 13, 1977, Appli-cants filed in this proceeding proposed findings of fact and conclusions of law on matters which had been heard as of those dates.

2. - Subsequently, additional hearings have been -

held on matters which had been the subject of the earlier sessions, as well as on topics which had not been considered previously.

1247 002 7910310 S D 9c v.

3. Last month the Board prescribed the following schedule for the submission of revised proposed findings:

Environmental and Suit Suitability Issues Upon Which Hearings Have -

Been Completed Not Including Floodplain Management and Financial cualifications.

Applicants September 14, 1979 Other Parties (including NRC Staff) October 5, 1979 NRC Staff & Applicants' Replies October 19, 1979 (Tr. 14,615-616, 14,621-622, 15,026.)

Floodplain Management and Financial Qualificatirns.

Applicants October 8, 1979 Other Parties (except NRC Staff) October 25, 1979 NRC Staff Findings and Replies and Applicants' Replies November 5, 1979 Remaining Issues. -

Not yet scheduled 1247 003

4. Applicants herewith submit their proposed findings on all environmental and site suitability issues upon which hearings have been completed but not ..

including Floodplain Management or Financial Qualifica-tions and request that they be substituted for all of those previously submitted by Applicants.

5. Proposed findings on the other issues will be submitted in accordance with the schedule recited above.

Respectfully submitted, PERKINS, COI', STONE, O EN & WILLIAMS

~

N F. THEODORE THOMSEN Attorneys for Applicants 1900 Washington Building Seatt'.e. Washington 98101 .

Of Counsel: - -

Lowenstein, hewman, Reis,

Axelrad & Toll 1025 Connecticut Avenue, N.W.

Washington, D. C. 20036 1247 004

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD ..

In the Matter of )

PUGET SOUND POWER & LIGHT ) Docket Nos. 50-522 COMPANY, et al. ) 50-523

)

(Skagit Nuclear Power Proj ect, , September 14, 1979 Units 1 and 2) ,

)

APPLICANTS' PROPOSED FINDINGS OF FACT AND CONCLUSIONS OF LAW IN THE FORM OF A PARTIAL INITIAL DECISION AUTHORIZING LIMITED WORK AUTHORIZATION 1247 005

TABLE OF CONTENTS Page I. B AC KG ROU ND . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 -

II. ENVIRONMENTAL MATTERS........................ 6 A. Environmental Impact Statements.......... 6 B. Impacts of Construction.................. 12 C. Impacts of Operation..................... 28

1. Cooling Tower Operation............. 28

2. Visual Impacts...................... 34

3. Project Discharge................... 37

4. Ranney Collector System............. 59

5. Radiological Releases............... 75 D. Effects of Postulated Accidents.......... 82 E. Alternative Sites........................ 86 F. Alternative Energy Sources............... 106 G. Need for Power........................... 107 H. Cost-Benefit Analysis.................... 107 I. Federal Water Polution Control Act....... 108 J. Wild and Scenic Rivers Act............... 109 K. F-loodplain Management.. ................. 111 -

-ii- -

1247 006

Page III. S I TE SU I TAB I LI TY . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 112 A. Geography and Demography................. 112 B. Nearby Industrial, Military and Transportation Facilities............. 112 C. Meteorology.............................. 117 -

D. Hydrology................................ 120 E. Geology and Seismology................... 124 F. Suitdoility for Development of Evacuation Plan....................... 125 IV. RADIOLOG ICAL HEALTH AND SAFETY . . . . . . . . . . . . . . . 125 A. The Application and its Review........... 125 B. Site Criteria............................ 126 C. Facility Design.......................... 126 D. Re s e ar ch & Deve loptuan t . . . . . . . . . . . . . . . . . . . 126 E. Technical Qualifications................. 127 F. Quality Assurance........................ 127 G. Conduct of Operations.................... 128 H. Common Defense and Security.............. 128 I. Financial Qualifications................. 129 J. Emergency Evacuation Plan................ 129 V. CONCLUSIONS OF LAW........................... 130 VI. ORDER........................................ 131

-iii- -

1247 007

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )

PUGET SOUND POWER & LIGHT ) Docket Nos. 50-522 COMPANY, et al. ) 50-523

)

(Skagit Nuclear Power I.roj ect, )

Units 1 and 2) )

APPLICANTS' PROPOSED FINDINGS OF FACT AND CONCLUSIONS OF LAW IN THE FORM OF A PARTIAL INITIAL DECISION AUTHORIZING LIMITED WORK AUTHORIZhTION I. BACKGROUND

1. This proceeding involves an application filed with the Nuclear Regulatory Commission ("NRC" or " Commission") by Puget Sound Power & Light Company ("Puget") for construction permits ""

to build two boiling water reactors, the Skagit Nuclear Power Project, Units 1 and 2 ("the f acility" or "the Proj ect") , at a proposed site ("the site") in Skagit County, Washington, 1247 008

approximately 64 miles north of Seattle.* The application has been filed by Puget en its own behalf and on behalf of the other participar'.s in the Project: Portland General Electric Company ("PGE~), Pacific Power & Light Company (" Pacific"), and The Washington Water Power Company ("WWP ; " collectively, along -

with Puget, referred to as the " Applicants"). Each of the Skagit units will have a nuclear steam supply system with a licensed core ti mal output power level of 3800 MWt. Exh.

175, pp. 1-2.

2. The application includes a request for issuance of a Limited Work Authorization (" LNA" ) pursuant to 10 CFR S 50.10 (e) (1) . The activities that Applicants seek to conduct pursuant to the requested LNA are described in Exhibit H to the application and are all within the scope of those contemplated by the above-cited regulation. Applicants have acknowledged that, as provided by 10 CFR S 50.10 (e) (4) , any activities undertaken pursuant to an LWA will be rntirely at their owt

• The application was filed September 27, 1974 and dock-eted September 30, 1974. Exh. 1. It has since been amended four times, most recently through an amendment dated June 1979. Exh. 175. The application is supported by the twenty-five volume Preliminary Safety Analysis Report ("PSAR") and '

five-volume Environmental Report ("ER") filed in accordance with NRC regulations. Exh. 176; Exh. 4. The application, PSAR and ER have all been received in evidence. Tr. 12,358-363, 12,365, 709, 712.

1247 009 risk. If those activities are undertaken but the construction permits are denied, it would be possible to restore the site at a cost of approximately $1.5 million. Intervenor Skagitonians Concerned Abc .t Nuclear Plar.ts ("SCANP") has stipulated that Applicants have the required financial resources for restora- --

tion and the Board so finds. Myers, fol. Tr. 708, pp. 4-5; Tr. 42-43,

3. On December 20, 1974, the Commission published in the Federal Register (39 F.R. 44,065) a Notice of Hearing on Appli-cation for Construction Permits with respect to the applica-tion. The Notice set forth the requirements that must be met under the Atomic Energy Act of 1954, as amended, and the National Environmental Policy Act of 1969 ("NEPA") before con-struction permits for the facility can be issued . The Notice provided that any person whose interest might be affected by the proceeding could ' lle a petition for leave to intervene in accordance with the requirements of 10 CFR S 2.714. The Notice also announced that the Commission had designaced an Atomic Safety and Licensing Board (" Licensing Board" or " Board") to conduct the proceeding.

4. Subsequently, on March 1,1976, an Amended Notice of -

Hearing on Application for Construction Permits was published in the Federal Register (41 F.R. 8835). The Amended Notice provided, inter alia, a separate opportunity for any person 1247 010

m whose interest might be affected by the addition of PGE and the deletion of the Washington Public Power Supply System as joint applicants to file a petition for leave to intervene in accor-dance with 10 CFR S 2.714.

5. This Partial Initial Decision deals with the environ-mental and site suitability issaes specified in 10 CFR S 50.10 (e) (2) , as well as certain radiological health and safe-ty macters. A decision on the remaining radiological health and safety issues, and the Board's ultimate decision on issu-ance of construction permits for the facility, will be issued af ter concluding public hearings on the remaining radiological health and safety aspects of the application.

6. Two petitioners for intervention were ultimately ad-mitted as parties in the proceedinc They are SCANP and Fore-laws On Board / Coalition For Safe Power (" FOB /CFSP") . In addi-tien, the State of Washington Energy Facility Site Evaluation Council ("EFSEC"), the State of Oregon, and Skagit County sought and were granted participation as non-parties pursuant to 10 CFR S 2.715 (c) .

7. SCANP's contentions are set forth in two documents:

(1) an agreed statement of SCANP's environmental and site suit- '

ability contentions ("SCANP Contentions," fol. Tr. 67), and (2) a document entitled "SCANP Contentions Regarding PSAR" ("SCANP PSAR Contentions"), dated April 15, 1975 and filed pursuant to 1247 011

the Board's order of March 17, 1975. The contentions of FOB /CFSP (" FOB /CFSP Contentions") are set forth in the Board's order of May 26, 1976.

8. Limited appearances were made by a large number of pet. . .. In addition, during the course of this proceeding, -

the Board F.as requested the presentation of additional evidence on a number of j ubj ec ts . The relevant questions have been ad-dressed by the Applicants and NRC Staff, and the Board con-cludes that the answers are fully responsive.

9. This decision is based on the complete record compiled to date.* In making the following findings and conclusions, we reviewed and considered the entire record in this case and all of the parties' proposed findings of fact and conclusions of law. Those proposed findings of fact and conclusions of law submitted by the parties which are not incorporated directly or inferentially in this Partial Initial Decision are rejected as being unsupported in law or fact or as being unnecessary to t'a rendering of this decision.

• A lisc of the exhibits offered in evidence is attached as Appendix %.

6 1247 012 II. ENVIRONMENTAL MATTERS A. Environmental Impact Statements

10. On August 6,1974, in accordance with the req irements of 10 CFR Part 51, Applicants submitted their Environmental -

Report. As ameaded, the ER nas been received into evidence as Exh. 4; Tr. 709., 712. The ER contains detailed infctmation on, and evaluations of, the environmental impacts associated with construction and operation of the facility.

11. Based upon the infonnation submi'*ed by Applicants, its own review and analysis, and other sources, the NRC Staff prepared a Draft Envirncmental Statement (" DES"). Notice of the availability of the DES was published on January 22, 1975, and public comment was invited. 40 F.R. 4195. Copies of the DES were also circulated for comment to appropriate federal, state and local agencies. In May 1975 the Staff published its Final Environmental Statement (" FES" ) , fol. Tr. 2913. All com-ments received on the DES are set forth in Appendix A of the FES. The Staff's consideration of those comments is reflected in revisions in the text of the FES and by discussion in sec-tion 11 thereof. The FES was received in evidence in this ~

proceeding. Tr. 2913.

1247 013

12. The Staff also prepared a Final Supplement to the FES

("FES Final SLpp."), fol. Tr. 7767. The purpose of the supple-ment was to identify and evaluate the potential ef fects of the proposed Project on the Skagit River, which at the time was a

" study" river under the Wild and Scenic Rivers Act, 16 U.S.C. ~

S 1271, et_ seq. It also provided, as part of the NRC's en-vironmental impact statement for the Project, information upon which the Secretary of Agriculture could rely in making his determination pursuant to Section 7 of t!.e Wild and Sranic Rivers Act, 16 U.S.C. S 1278. See Exh. 203. Prior to issuance of the FES Final Supp., a draf t was circulated. Notice of its availability was also published, and comments were invited.

41 F.R. 28,599. As with the FES, comments were bound into Ap-pendix A of the FES Final Supp., and reflected in both textual revisions and discussion in section 11. Tne FES Final Supp, has also been received into evidence. Tr. 7766.

13. In Contention J.1, intervenor SCANP alleges that The DEIS* does not represent the independent work of the NRC.

• We note th3t many of SCAMP's contentions ref arred to the Draft Environmental Statement which was, of course, '

later superseded by the Final Environmental Statement.

Although '.nvited to do so, SCANP did not seek to revisa those contentions following issuance of the final state-ment. Without objection, Applicants and Regulatory Staf f therefore treated the contentions as though they referred to the final statement; we shall do likewise. Tr. 2153, 2163-155.

1247 014

a. It is hardly more than a summary of the applicants' ER, and as such necessarily re-presents the applicants ' point of view. It incorporates many judgments made by the ap-plicants and the applicants ' consultants concerning environmental impacts; it relies entirely on the data base accumulated by the applicants and reflects any deficiencies in that data base or methodologies or judgments involved -

in accumulating it,

b. The preparers of the DEIS failed to make their own independent evaluation and in vestigation with regard to: alternative sites, seismology, and the need for the proj ect.

c. The DEIS was not prepared by the "respon- sible official" as NEPA mandates.

In Conten 4.on J.16, SCANP states further that For the foregoing reasons, [ stated in Contentions J.1 to J.15] the DE!S does not comply with NEPA, the CEQ guidelines, or 10 CFR Part 51.

14. Details of the conrideration given specific matters raised by contentions, both in the environmental impact state-ment and otherwise, are addressed elsewhere in this decision, In general, however, the FES was prapared by the NRC Staff with the aid of its contractor, the Argonne National Laboratory, and under the direction of the NRC's Director of Nuclear Reactor Regulation. Argonne is a Government-owned national laboratory operated by the University of Chicago under a cost-type con-tract. In their work, Staff and Argonne personnel relied upon information supplied by Applicants in the ER and PSAR. Those documents, whi,... must meet the requirements, inter elia, of 10 l247 015 CFR Part 51 and Regulatory Guides 4.2 and 4.7, necessarily con-tain virtually all of the information required to assess the environmental impact of the proposed Project. However, Staff and Argonne personnel also made visits to the proposed and al-ternative sites, requested additional information from Appli- --

cants; and consulted outside experts and other independent sources of information. In addition, they relied upon.their own expertise in various disciplines pertinent to assessment of the environmental impact of the Project. See, e.q., Leech, et al., fol. Tr. 2919, pp. 1-2; Leech, et al., fol. Tr. 12,542, pp. 13-15; Tr. 2914-918, 3018-029, 3189-199, 3295-310.

15. The FES Final Supp. was prepared by the NRC Staff with the assistance of the Forest Service, U. S. Department of Agri-culture. Infotsation presected therein derives largely from an environmental analysis report on the Project written by the Forest Service and submitted to the NRC for its use in prepar-ing the supplement under the " lead agency" concept. Work on the FES Final Supp. by the Staff and Forest Service involved on-site investigations, the collection of information from nu-merous sources, and the application of Staff and Forest Service expertise. FES Final Supp., fol. Tr. 7767, pp. xi, 1-1 to 2; ~

Exh. 119; Tr. 7823-832; 7845-852; 7886-890; 7904-907; 7964-974.

16. In addition, the FES and FES Final Supp, have been updated and amplified in some respects by Staff testimony at 1247 016

, m the hearings. See, e.g., Milsted, fol. Tr. 2913; Leech, et al., fol. Tr. 2919; Leech, et al., fol. Tr. 7767; Leech, et al., fol. 12,542; Taylor, fol. Tr. NFP 650.

17. The FES, together with the FES Final Supp., contain a datailed analysis of the environmental impact of the facility. -

Thay fully describe and analyze the site, the ecology of the site region, the major systems of the facility, the environ-mental eff ects of construction, operation and po .tulated acci-dents, Applicants' environmental monitoring programs, the need for the facility, alternative sites, alternative energy sources, and alternative plant signs. They also present an evaluation of the proposed action, including a cost-benefit analysis.

18. To some extent, SCANP appears to contend that the NRC is precluded from placing any reliance upon factual data assem-bled by an applicant. In the normal course, however, the ER serves as the basis for NRC Staff review of the proposal, dur-ing which it must assure itself that adequate consideration has been given to environmental concerns, but not duplicate the applicants' efforts. See generally, Public Service Company of New Hamphsire (Seabrook Station, Units 1 and 2), CLI-77-8 5 NRC '

503, 524 (Mar . 31, 1977). This process takes place through an exchange with the applicant, which often leads -- as it has in this case -- to the filing of supplements to the ER, and 12A7 017 through the collection of informat'.on which may be in the hands of others, such as other governmental bodies. Id. SCANP also tends to equate "independiat" with " conflicting" in arguing that the NRC Staff's in-depth review was not independent because it did not reveal more disagreements with Applicants' ~

data or conclusions -- a position for which it cites no au-thority in law or logic. We find no merit in either SCANP Contention J.1 or J.16.

19. The Staff concluded -- aCter weighing the environ-mental, economic, technical and other benefits of the proposed f acility against environmental and other costs, and af ter con-sidering available alternatives -- that the appropriate action under NEPA and 10 CFR Part 51 is the issuince of an LWA and construction permits for the f acility, subject to certain limi-tations for protection of the environment.

20. The FES and FES Final Supp. reflect an independent and comprehensive review and analysis by the Staf f of the environ-mental impacts resulting f rom construction and operation of the facility. The Board finds that these documsnts -- as updated and amplified by testimony during the hearing, and as modified by -these findings and conclusions -- comply with the require- '

ments of NEPA as implemented by 10 CFR Part 51. Except to the extent set forth herein, the Board accepts the f acts set forth in the FES and FES Final Supp. , as amended, and concurs in the 24

S taf f 's conclusions . 10 CFR S 51.52 (b) (3) ; Niagara Mohawk Power Corp. (Nine Mlle Point Nuclear Station, Unit 2) , ALAB-264 1 NRC 347, 371-72 (Apr. 8, 1975).

B. Impacts of Construction

21. Site Preparation and offsite Construction. The main impact of the Project on the land will result from the distur-bance of about 260 acres of the 1,500 acre site. Approximately 2,000,000 cubic yards of material will be excavated from the hill northwest of Bacus Hill. Rock blasting will be required after removal of the overburden. Calculations indicate that the excavation and fill vo.1'n cs will be approximately bal-anced. No significant historical or archaeological site,s have becn found within the Project boundaries. Nevertheless, Appli-cants have arranged for an archaelogical consultant to assure appropriate archaeological inspections and invest..gations if discoveries are made during the excavation phase. Myers, fol.

Tr. 2627, p. 3; FES, fol. Tr. 2913, SS 2.3, 4.1.1; Exh. 4, '

SS 2.3.1, 4.1.1.

22. 5,200 feet of Black Creek will be permanently rerouted around the industrial zone, resulting in a change in the con-fluence of Black Creek and Wiseman Creek and some loss of -

1247 019

stream habitat. This, in turn, may occasion the displacement and loss of some cutthroat trout. The diverted portion of Black Creek, half of which does not have a permanent fish popu-lation, represents less than 0.5 percent of the creek habitat in the Skagit River drainage basin between Sedro Woolley and ancrete. The potential loss is, therefore, only a J cion of 1 percent of the estimated salmonid population in this area.

Myers, fol. Tr. 2627, p,. 3-4; Tr. 2839-843, 2893-896; Exh. 4, S 4.1.2 and Fig. 2.5-15; FES, fol. Tr. 2913, S 4.1.1.

23. Culverts will be installed at the access railroad and access road crossings of Wiseman Creek. The access railroad culvert will prevent cutthroat trout spawning and reduce pro-duction of some fish food organisms. The access road culvert will involve rechannelization of 310 feet of Wiseman Creek, affecting about 6 percent of the length of the creek presently used by anadromous salmonids. Measures will be adopted, such as providing gravel on the bottom of the new channel and timing construction to avoid spawning, to minimize the impact on fish and other aquatic life in the area. Myers, fol. Tr. 2627,

p. 4; FES, fol. Tr. 2913, S 4.1.1; Exh. 4, S 4.1.2.

24. Instarlation of the Ranney Collector wells will take place on land adjacent to the Skagit River and, therefore, will not disturb the river. Material removed during installation will be suitably disposed. In accordance with terms of the Department of Agriculture's April 11, 1977 determination pur- -

suant to the Wild and Scenic Rivers Act, discussed below, no 1247 C--

additional riprap will be added to the River bank at the col-lector site. Installation of the collectors will have a mini-mal impact on the biota and wildlif e habitat in che area.

Myers, fol. Tr. 2627, p. 4; FES, fol. Tr. 2913, S 4.2.2.1; FES Final Supp., fol. Tr. 7764, SS 4.1.2, 4.1.4, 4.1.5, 4.1.6, "

4.1.7 and 4.1.8; Tr. 10,637-654, 10,656-657.

25. The route of the access railroad was chosen in order to minimize its visibility f rom SR-20 and its impact on sur-rounding land. About j0 acres of land will be affected by the right-of-way. Most of the excavated material, approximately 450,000 cubic yards, will be used as fill 3.n the right-of-way; the rest will be placed in the site spoils area. Myers, fol.

Tr. 2627, p.5; FES, fol. Tr. 2913, S S 4.1. 2, 4.2.2.3, 4.4.1; Exh. 4, S 4.1.1.

26. The new rights-of-way for offsite transmission lines will occupy about 150 acres of land. While larger trees will have to be removed, ground cover will not be greatly disturbed and no serious erosion problems are expected. Only a small portion of the lines will be visible from SR-20; and none will be visible from the River. There appears to be no need for new permanent access roads. FES, fol. Tr. 2913, pp. 3-25 to 3-28, 4-5 to 4-8; Exh. 4, SS 3.9, 4.2; FES Final Supp., fol.

Tr. 7767, S 4.6.

1247 0-1

27. A sewer pipeline will be constructed from the site to the existing sedro Wooley municipal system. All of the pipe-line, except at three creek crossings, will be buried. Thus, there will be virtually no visual impact. Following burial of the sewer line, the disturbed area will either be reseeded or ~~

otherwise allowed to revegetate, thus allowing any disturbed wildlife to return. As the sewer line approaches each of the bridges over Wiseman, Coal and Hansen Creeks, it will angle up f rom the trench to the ground surf ace near the bridge. The routing is such that the stream banks will not be disturbed with any heavy equipment, thereby preventing the possibility of silt entering the streams from the work. The sewer line will cross the streams on supports attached to existing bridges.

Hanging of the pipe will generate only a miniscule amount of concrete dust and, therefore, poses no environmental hazard.

Installation of the sewer line will not interfere with traffic except f rom the occasional movement of construction equipment.

Myers, fol. Tr. 2627, p. 5; Goettge, fol. Tr. 6598, pp. 2-4 and App. A, pp. 2-4, 6; Finnegan, fol. Tr. 6591, pp. 2, 4; Tr. 6701, 6705, 7043-049, 7070; Exhs 104 and 113. ~

28. A majo'r portion of the pipelines required for makeup and discharge water will be buried, either under existing rights-of-way or in areas that will rapidly revert to their natural state after completion of construction. The trenching IN. C'2

operations will produce temporary disturbance of land use along the entire length (13. 6 miles) cf the pipeline routes, but there will be no permanent impact after restoration. Care will be taken to minimize surf ace runoff , silting and blockage of drainage patterns. Myers, fol. Tr. 2627, p. 5; FES, fol. ~~

Tr. 2913, SS 4.1.2, 4.2.2.1, 4.4.1; Exh. 4, SS 4.1.2.5, 4.1.2.6.

29. Major improvements will be required at the intersec-tion of SR-20 and both the new access road planned for the site, and Bacus Road. MacIsaac, fol. Tr. 2296, p. 11. The improvement work will consist of widening 3,000 feet of SR-20 in the vicinity of the plant site; realigning Bacus Road to a new intersection with SR-20; providing an intersection with SR-20 for the proposed new access road; and installing traf fic channelization and signs at and in the vicinity of the two in-tersections. Most of the work will be within existing state and county road rights-of-way. There will be a loss of about 3.3 acres of grass, f orest and forest edge habitat and of organisms associated with the habitat in this relatively small area. The habitats and organisms af fected, however, are abun-dant and common in the area and, hence, the impact on the terrestrial environment will be small. Goettge, fol. Tr. 6598,

p. 5 and App . B , pp. 8-9; Finnegan, fol. Tr. 6591~, pp. 1-2; Tr. 6618, 6633, 6697, 6706-707, 6713, 6722, 6749-751, 6760, 7043-048, 7070; Exhs 107, 108. There is little danger that 1247 023

harmful siltation will occur as a result of the road improve-ment work. Excavation will take place only where drainage is distant from creeks. Only a minimal amount of fill work will be done in surf ace areas which drain toward Wiseman Creek; none will be done on the stream bank and little work will be per- -

formed near the bank. Finnegan, fol. Tr. 6591, p. 3; Tr. 6742-744, 6748, 6813-815, 6820-825, 7028-037; Exhs 106, 107 and 108. The road work will cause reduced traffic speeds through the area while work is being done on the aboulders and a few days of one-lane traffic during paving operations.

Goettge, fol. Tr. 6598, App. A, p. 11; Tr. 6701. Such traffic interference would be minimal.

30. Construction of the discharge diffuser in the bed of the river near Sedro Woolley will cause some local siltation, increase turbidity for approximately three months, and may cause some loss of aquatic biota. Construction activities will be limited in scope and duration and will be timed to minimize any loss. A rapid return to the normal pattern of aquatic life in the Skagit River can be expected. Myers, fol. Tr. 2627-

p. 5; FES, fol. Tr. 2913, SS 4.1.2, 4.2.2.1, 4.4.2; FES Final Supp., fol. Tr. 7767, 4.3.1; Exh. 4, S 4.1.2. -

31. A temporary barge offloading f acility will be needed for delivery of the reactor pressure vessels. It will be loca-ted near the foot of Fruitdale Road, just east of Sedro i247 024 Woolley. Construction of the facility, which will require about 1.5 acres of land adjacent to the river and will distur b

~

approximately 250 feet of shoreline, will cause some local siltation and turbidity in the river for a short period and may cause some loss of aquatic habitat. However, construction -

activities will be planned and carried out in a manner which f ully considers and minimizes ef fects on the river and impor-tant biota. Techniques will be used to minimize surface run-of f, silting, erosion, and blockage of drainage patterns. Con-struction, which will take approximately 60-90 days, will be timed to minimize any loss of important aquatic life. Con-struction of the offloading facility will not have a signifi-cant impact on the environment. Upon completion of delivery, the disturbed shoreline area will be restored, or the facility may possibly be lef t for public use. Myers, fol. Tr. 2627, p.

6; FES, fol. Tr. 2913, S S 4.1. 2, 4.4.2; FES Final Supp., fol.

Tr. 7767, S 4.4.1; Exh. 4, S 4.1.1, Supp. 1, pp. 221a and 1216, Fig. 49A-1.

32. The site and of fsite construction areas contain no unique terrestrial biota habitats, and no known rare or endan-gered species will be affected by construction. There will be the loss of some habitat and of some less mobile f auna due to the clearing of vegetation. However, the terrestrial habitats on the site are a minute fraction of such habitats in Skagit 6

1247 025

County. Animals in the affected areas will ei?her emigrate to r,imilar surrounding habitats or succumb due to exposure, pieda-tion, starvation, etc. The displacement of wildlife may in-directly affect adjacent habitats. Since forty-five percent (45%) of the cleared area will undergo revegetation following -

construction, m;ch of the habitat loss will be temporary, and many species of f auna will return to and inhabit the site.

Myers, fol. Tr. 2627, p. 2; FES, fol. Tr. 2913, SS 4.4.1, 5.1; FES Final Supp., fol. Tr. 7767, SS 5.4, 5.5, 5.6; Exh. 4, SS 4.1.1.1, 4.3.

33- For a number of years, significant numbers of northern bald eagles have sintered along the Skagit River, particularly the reaches upstream from Rockport. Exh. 4, S 2.7.4.1.4.

s SCANP witness Ellingson testified that construction would in-terfere with the behavior of the eagles. He identified a slide into the river as one possible example of interference with the food supply for the eagles; however, there is no evidence that construction cc:.ld possibly cause such an event. Exh. 42, pp. 12-15, 33-34. Further, most 7f the eagle activity in the area is at some cistance from the site; eagles have dem-onstrated (Exh 42, pp. 13, 14, 35-37, 50, 51, _T , 57 and 68) ,

a high degree of tolerance for the presence of humans; and the NRC Staf f believes that construction activities will have no 1247 026 impact on the eagles food supply. Exh. 42, pp. 13-14, 35-37, 56-58; Exh. 4, S 2. 7. 4.1. 4 ; FES Final Supp . , f ol . Tr . 7767, S 11.6.1. These f actors, plus the topography of the area and observed behavior of eagles along the Skagit River (e.g.,

Exh. 42, pp. 35-37), lead us to conclude that construction '

activities will neither adversely affect the bald eagles, nor inter fere with the Skagit River Bald Eagle Natural Area up-stream from the site.

34. Construction activities may affect stream and river ecology by altering drainage systems and stream flows, increas-ing the rate of siltation and reducing aquatic habitat. Inter-venor SCANP offered testimony suggesting that construction activities will be detrimental to the environment, especially to the salmonid population. E.g., Brubaker, fol. Tr. 2925, pp. 14, 21-22; Brubaker, fol. Tr. 8211, pp. 2-3. The principal witness for SCANP, who was not an expert in fich biology, had, in effect, done a literature search (devoted largely to the effects of thermal and chemical discharges, subjects addressed belcw). He had conducted no studies in the vicinity of the site, or sampled fish populations, and indicated that his opin-ions were generated on the basis of what he had read. '

Tr. 2950, 2959, 6945-946, 8280-281, 8300-301. He had no 1247 027

studies to rely on when he predicted a reduction in salmon pop-ulation as a result of the Project and could not quantify his predictio . Tr. 2973-974.

35. Applicants and the NRC Staf f presented extensive evi-dence showing that the construction activities will not have a significant effect on the aquatic environment. E. g . , Exh. 4, S 4.1.2.1; Dvorak, et al., fol. Tr. s732; Tr. 7037-041, 7570.

The Staff's evaluation confirms that effects on the aquatic environment will be slight; we agree. FES, fol. Tr. 2913, S 4.4.2; FES Final Supp., fol. Tr. 7767, SS 4.1.4, 4.2.4, 4.3.4, 4.4.3, 4.4.4, 4.7.3, 4.7.4; Milsted, et al., Tr. of 31 July 1975 (Vol . II) .

36. The impact on tquatic biota from siltation attribut-able to construction will be minim 11. Construction will be temporary and will involve limited drainage areas. Applicants have planned an erosion control program, including the re-routing of Black Creek, four sediment retention ponds, diver-sion of surf ace runoff, and vegetative stabilization of graded and spoils areas. The program, which will be checked during construction by monitoring, should largely eliminate silt in-troduction during critical low-flow periods and reduce silt input curing high-runoff conditions. Myers, fol. Tr. 2627, pg . 3 , 4; FES, fol. Tr. 2913, SS 4.1.1, 4.4.2.1; Exh. 4, S 4.1.2.1.2, Supp. 1, pp. 52-54, 218-220.

1247 028

37. Largely in response to a Board question, particular attention has been given to the matter of sedimentation in the Skagit River associated with construction of the discharge dif-fuser, the barge offloading facility, and riprapping. The evi-dence established that there would be no significant impact on

~

the salmonid fishery in the River. The bases for this conclu-sion are the short duration of the activities and the rela-tively small areas affected, the timing of work to have the least possible effect on spawning activity, the location of construction areas generally downstream of major spawning areas, similarities in the type and deposition of siltation produced by construction activity and by natural events, the large volume of sediments normally present in the river, and the conatruction practices proposed. Derickson, Tr. of 31 July 1975 (Vol . II) , pp. 1-3; Tr. 2635-671, 3199-216, 3260-266, 3288-289; FES Final Supp., fol. Tr. 7767, SS 4.2.4, 4.3.4, 4.4.3, 4.4.4.

38. The Board also inquired into details of Reactor Pres-sure Vessel (RPV) delivery to the site. In response, the NRC Staf f assessed -- in detail -- the potential impacts, including those resulting' f rom barge travel up the Skagit River and installation of the necessary culverts at stream crossings to accommodate the overland portion of the RPV delivery route.

NRC Staff Assessment of Impacts Associated with the Delivery of 247 029

the Reactor Pressure Vessel, fol. Tr. 12,216. Based on that asses sment , the evaluation of impacts resulting f rom barge slip construction contained in Section 4.4 of the FES Final Supp. ,

fol. Tr. 7767, and the discussion in paragraph 31, above, we conclude that the potential impacts of RPV delivery have been ~

adequately considered and are acceptable.

39. Noise. Noise produced by construction activities will depend upon factors such as day-to-day schedules, variations in equipment operation, and weather conditions . Site preparation is expected to be the noisiest phase of construction, due to rock blasting and the greater use of haavy equipment. The low frequency explosive blasting and other noise may cause some intermittent annoyance , but the estimated maximum construction noise levels at the site boundary fall within the range deemed to be normally acceptable to humans. Myers, fol. Tr. 2627, pp. 6-7; FES, fol. Tr. 2913, S 4.5.3; FES Final Supp., fol.

Tr. 7767, SS 4.1.11, 4.2.10, 4.3.10, 4.4.10, 4.5.10, 4.7.10, 5.9; Exh. 4, S 4.1.1.4.

40. Dust and other Emissions to the Air. During construc-tion there will be emissions resulting from operation of heavy equipment (engi'ne exhaust and road dust) , the concrete batch '

plant (particulates) and from permitted open burning (combus-tion products). Control will be exercised to reduce these emissions to the lowest levels practicable.

For example, 1247 030

internal combustion engines will be kept in good mechanical condition; areas traversed regularly by heavy equipment will be dampened and in some cases, covered with gravel; all applicable burning regulations will be complied with and precautions taken to prevent accidental fires; and control techniques reflecting the best engineering practices will be used to limit dust from the concrete batch plant. FES, fol. Tr. 2913, S 4.5.3; Exh. 4, S 4.1.1.5; Myers, fol. Tr. 2627, p. 7.

41. Socioeconomic Impacts. Construction of the Project is not expected to cause a housing shortage in the county or other, significant " boomtown" ef f ects . In spite of some testi-many suggesting otherwise, the Board believes that the impact on the area will be minor.

42. Although the Sedro Woolley Police Department may require additional time , equipment , and manpower to control traf fic and, to a lesser exter', f or peace-keeping activities ,

the construction impact pay nts to be made by Applicants to law enforcement agencies in the county pursuant .to the Rezone Contract should serve to mitigate these impacts. The impact on schools is expected to be minimal. A large proportion of those expected to work on the Project already reside in the general '

vicinity, from Sedro Woolley to as far away as Seattle and Bellingham, and will commute to the site. The number of new res(dents in the area should be relatively small and no school

'I247 031

district will bear the entire burden of new students. The con-struction impact payments to be made by Applicants to the school districts in the county pursuant to the Rezone Contract should effectively mitigate whatever impacts may occur. Con-struction is not expected to have a significant adverse impact -

on local community services such as area hospitals, water and wastewater systems, or fire districts. Myers, fol. Tr. 2627, pp. 7-8; FES, fol. Tr. 2913, SS 4.5.1, 4.5.4; FES Final Supp.,

fol. Tr. 7767, S 11.3.10; Exh. 4, S 8.2.2 and App. K, Part 4, Articles 5.2, 5.3; Winters, fol. Tr. 13,361, pp. 3-14; Tr. 8151-154, 13,822-827. The socioeconomic impact monitoring and claim payment procedures under the Site Certification Agreement between Applicants and the State of Washington should also be helpf ul in avoiding or minimizing socioeconomic im-pacts, and in mitigating any impacts which do occur. Exh. 83, Art. VI . C , pp . 32-34.

43. Traffic. The construction workforce, which will range as high as 3,100 workers, will commute to and from the site each work day. Deliveries of materials to the site will in-volve an estimated 200 truck trips per day in both directions combined. The impact of this Project-related traffic on the '

existing road system with its anticipated non-Project-related load has been assessed. FES, fol. Tr. 2913, S 4.5.2; FES Final 1247 032 Supp., fol. Tr. 7767, S 11.8.16; MacIsaac, fol. Tr. 2296; Exh. 4, S 8.2.2.1.2'; Tr. 2360-364 and 2425-426.

44. Prior to the July 1975 hearings which were held in this proceeding, Applicants' traffic engineering consultant performed a detailed analysis. In brief , he utilirrd data ob- "

tained f rom the Washington State Highway Department and f rom Skagit County for the baseline traf fic condition and best esti-mate of traffic growth rates. From this information he derived an upper level estimate of the non-Project traffic volumes anticipated to occur at the time the construction workforce was expected to peak. MacIsaac, fol. Tr. 2296, pp. 2-4, Figs. 1, 2, 3, 4; Tr. 2306-311, 2335-336, 2416.

45. In assessing Proj ect constr'iction traf fic, Applicants' expert axamined both the 3,100-man peak work force and the "80 percentile" leve? of 2,000 workers; the workforce level that is not exceeded in eight of the ten strs of Project construc-tion. He applied cert sin assumptions regarding car pooling, work shifts and distribution of worker residences to arrive at estimates of the number of trips generated by :he commuting work force and the routes they would take. Truck traffic at-tributable to materials deliveries to the site was included as '

part of the Project-related traffic. MacIsaac, fol. Tr. 2296, pp. 4-7, Figs. 5, 6; Tr. 2307-308, 2311-312, 2343-355, 2365-366, 2414-416.

1247 033

46. The estimated Proj ect and non-Project traffic volumes were combined for both the 80 percentile and peak workforce caces. The resulting total traf fic estimates were compared to the theoretical capacities of the highways in q2estion. The analysis reveazed the necessity for certair improvements such -

as left-turn channelization at a number of points along SR-20.

Major imprcvements will be required at the intersections of both Bacus Road and the Project access road with SR-20; these improvements have been designed, and we have already approved portions of the work. Further measures to reduce congestion on SR-20 could range up to an expansion of the roadway to four lanes between State and Township Streets in Sedro Woolley.

However , Project construction traf fic will result in a notable impact, causing potential overloads on portions of the road system serving the Project site. MacIsaac, fol. Tr. 2296, pp. 7-12, Figs. 7, 8; Tr. 2312-319, 2321-334, 2364-365, 2416-418; Paget Sound Power & Light Company (Skagit Nuclear Power Project, Units 1 and 2) , ALAB-446 6 NRC 870 (Dec. 9, 1977); LBP-77-72 6 NRC 1308 (Dec. 23,1977) .

47. ': ore recently, the NRC Staff analyzed traffic impacts a3 part of its ' cost-benefit analysis.

While not precisely com-parable to Applicants' traffic analysis, the Staff concluded --

as did Applicants' consultant -- that construction could, at 1247 034 t'mes, result in traf fic volumes in excess of highway capa-city. Winters, fol. Tr. 13,361, pp. 14-18; Tr. 13,632-634.

48. The record indicates that traffic attributable to the construction of the Skagit Project will contribute to the crowded traffic conditions which can be expected to develop in ~~

any event by virtue of anticipated growth in traffic volume.

The impact will be temporary and limited almost exclusively to rush hours on work days. However, it may result in decis' s by local residents to travel at other hours of the day and/or on alternative routes. This impact may be termed adverse, but can be further mitigated by such simple means as increased car-pooling and the staggering of work hours. In any event, it cannot be said to threaten a subst *.ntial chsnge in the life style of local residents. We have included it in our cost-benefit analysis. MacIsaac, fol. Tr. 2296, pp. 10-12; Winters fol. Tr. 13,361 pp. 17-18.

C. Impacts of Operation

1. Cooling Tower Operation

49. The two natural draf t cooling towers will release large quantities of heat and water vapor to the environment.

As the warm, moist air condenses , cloud-like plumes will form.

1247 035

Due to bouyancy and momentum, the plunes will usually rise f ar above the towers. The cooling towers will also release a small amount of water in the form of droplets or drif t, which will either evaporate or precipitate on the ground. FES, fol.

Tr. 2913, S 5.3.1; Exh. 4, S 5.1.3. "

50. The length of the visible plumes will vary depending upon the meteorological conditions and tile plant heat load.

The maximum predicted length, which would occur very infre-quently in the wintertime, would be 12,500 f eet. The average summer and winter lengths are expected to be 980 and 4,300 feet, r espectively . Due to the errors in windspeed measurement (discussed below in Part III under " Meteorology"), these maxi-mum plume lengths hhv. been c::: gredicted. FES, fol.

Tr. 2913, S 5.3.1; Exh. 4, S 5.1.3.2; Tr. 2631.

51. The longest plumes will tend to form during conditions most conducive to cloud formation. Therefore, the visual im-pact of the plumes will be obscured by the naturally cloudy condi tions . Reduction in sunshine due to the plumes will be negligible. While it is expected that the plumes wil] contri-bute to low-level clouds and their persistence, there is no evidence that natural draft cooling towers '.esult in weather '

modification. The buoyancy of the plumes, the elevation of the plant site and the height of the towers will preclude ground level fogging f rom the plumes in the valley below the plant.

Myers, fol. Tr. 2627, p. 10; FES, fol. Tr. 2913, SS 5.3.1, 11.2.1; Exh. 4, S 5.1.3; Tr. 3250-260.

52. The major portion of the drift will be deposited within the plant site boundaries. The errors in windspeed -

measurement referred to above will have a very small effect in the drift distribution set forth in Figure 5.1.1 of the ER.

Exh. 4, S 5.1.3; Tr. 2631. Under some conditions, the wind could carry the drif t to SR-20, which could then result in a small amount of icing when temperatures are below freezing.

The combination of wind and sub-freezing temperatures necessary for the possibility of icing occurs 117 hours0.00135 days <br />0.0325 hours <br />1.934524e-4 weeks <br />4.45185e-5 months <br /> during the year.

Furthermore, it is very possible that the rate of precipitation f rom the drif t will be too low to vir ~ :ly wet the road surf ace and cause an icing problem. Myers, fol. Tr. 2627, p. 11; FES, fol. Tr. 2913, SS 5.3.1.2, 11.18.9; Exh. 4, S 5.1.3, App. H.2; Tr. 3252.

53. The drif t contains dissolved salts, which are present in the cooling water. These salts will be deposited on the surrounding terrain, mostly within the plant site boundaries.

Calculations by the NRC Staff, which nuld only be very slight- ~

ly affected by the windspeed measurement errors, indicate that salt deposition from the drif t is less than the normal deposi-tion from rainfall. FES, fol. Tr. 2913, SS 5.3.1.2, 11.18.9; 1247 037

Exn. 4, SS 3.6 ' 5.1.3.3; Tr. 2631. Nevertheless, concetn ~

was exprar ad during the hearir.cF, particularly by SCANP, over the post o.1 - economic censequences of damage to vegetation re-311 ting t.om cooling '.ower operation; especially drift. SCANP Contention J.4. -

54. The chief components of the drif t are sulf ates, which are also common constituents of f ertilizer- . Therefore, no adverse effect on the soil is expected. Furthermore, the high rainf all in the area will tend to prevent accumulation of salts in surf ace soil or in pl ant. tissues. There will be no adverse impact on animals. FES, fol. Tr. 2913, SS 5.3.12, 5.5.1; Exh. 4, SS 5.1.3.3, 5.4.4; Tr. 2865, 2875.

55. The concentration of salts in the drift will be greater than that in rain and, if suf ficiently high, could cause " salt burn" on salt-sensitive foliage if not washed off by rain. The NRC Staf f concluded that spotting of foilage in the area of maximum drif t may be observed, but that such damage will not endanger whole trees and that any damage to commercial agriculture will be so small as to be undetectable. FES, fol.

Tr. 2913, SS 5.3.1.2, 11.18.9; Milsted, et al., Tr. of 31 July 1975 (Vol. II) , p. 2; Erh. 4, S 5.4.4; Tr. 2863, 2867. ~

56. This conclusion is also generally supported by experi-ments concerning the salt tolerance of strawberries, which are the most sensitive agricultural species within the vicinity of 1247 038

the site. While the experiments are not precisely comparable to the postulated drift deposition, they show that strawberries appear to be unaffected by concentrations of chloride consid-erably higher than the maximum to be found in the drif t. Other studies, including those of operating cooling towers, confirm -

the conclusion that damage, if any, results from much higher salt concentrations . Tr. 2867-872, 2889, 3231-239, 3245-246, 3269-283.

57. SCANP contention J.6 alleges that there has been a f ailure in the FES to evaluate the impact of the plant on birds using the Pacific flyway. Considerable evidence concerning this topic was presented during the proceeding. E.g., Milsted, et al., Tr. of 31 July 1975 (Vol. II) ; FES, fol. Tr. 2913, 5 2.7.1.2; Exh. 4, Supp. 1, pp. 197-199; Exh. 42. Specifi-cally, with respect to the migratory path of waterfowl in the site area, baseline data collected by Applicants showr that the predominant migratory path is at a lower elevation along the Skagit River and the flood plain. Furthermore, data collected at the site of the Davis-Besse nuclear power plant, which was located directly in a migratien path, shows that the impact of

~

large, tall structures on migrating birds is not severe.

Milsted, et al., Tr. of 31 July 1975 (Vol. II). The Board 1247 039 therefore concludes that the f acility, during either construc-tion or operation, will not have a significant impact on birds using the Pacific flyway.*

58. SCANP witness Ellingson has suggested that the size of the completed Project and the cooling tower plumes could dis- -

rupt the migratory pattern of bald eagles and drive them away peananently. Exh. 42, pp. 15-18, 60. However, eagles pre-sently toler ate a good deal of hinan activity on both land and the river. Exh. 42, pp. 13-14, 35-37, 50-51, 56-58. Also, eagles are believed to migrate at high altitudes. Exh. 42, pp. 4 3 - 4 /. , 65-66. We conclude that the presence of the Project will not disrupt their migration.

59. Witness Ellingson also expressed concern that the bald eagle population would be endangered by exposure to radioactive Iodine-131, an effluent of the facility. He suggested that Iodine-131 would be concentrated in the eagles ' thyroids by virtue of their eating spawned-out salmon, which he presumed woulu contain a significant amount of Iodine-131. Exh. 42, pp.16-17, 30-32, 63-64, 69-72, 77-89. Since there are no

• We note that the NRC Staf f , in reviewing Applicants ' ER, specifically inquired concerning the effect of plant structures on bird lif e. Exh. 4, Supp. 1, pp. 197-199. This, alone, dem-onstrates that, in preparing the environmental statement, the Staf f performed the very evaulation suggested by Contention J.6.

1247 040 liquid radiological releases from the plant, however, any expo-sure -- at all -- to salmon would necessarily occur only through the entrainmant of gaseous releases by the cooling towere. Such releases , however , are small; and any resulting exposure would likely be insignificant. Tosetti, fol. -

Tr. 2629; FES, fol. Tr. 2913, S '. 4 . See also the discussion below under " Radiological Releases." More importantly, con-sidering that spawning sabnon do not normally feed as they travel upstream, and that the half-life of Iodine-131 is ap-proximately eight days (not " hundreds of years" as Ellingson opined, Exh. 42, p. 45), any Iodine-131 ingested by juvenile salmon while in the Skagit River will have lcng since decayed when they return to spawn and are consumed by eagles.

Tr. 3397, 3399-401.

60. In sum, the Board finds that adequate consideration has been given to the matters raised in SCANP Contentions J.4 and J.6, and that they are without merit.

2. Visual Impacts

. ~

61. The prominent structures of the facility will be the reactor and turbine buildings and the cooling towers. There will be other buildings, but one of Applicants' design objec-tivas is to reduce the number of minor structures. Another 1247 04i

design objective is the use of simplified forms, finishes, and colors, to harmonize with the natural features of the valley.

Bacus Hill and the tree-covered terrain on and around the site will provide some screening. The taller structures, including the symmetrical 520-foot cooling towers , will be visable but -

seen against the 4,000-foot mountains to the .' orth.

. Transmis-sion lines will largely be shielded by the natural topography from the view of observers in the valley. Myers, fol.

Tr. 2627, p. 3; FES, fol. Tr. 2913, pp. 3-1, 5-1; Exh. 4, SS 3.1, 3.9; Tr. 2779-787.

62. Some viewers will regard the facility, and particular-ly the cooling towers, as a visual intrusion on the landscape.

See, e.g., Heilman, fol. Tr. 3098, pp. 2-6. Other viewers will regard the structures as visually pleasing. Tr. 2785. The Board has taken considerable evidence concerning the matter.

See, e.g., FES, fol. Tr. 2913, SS 3.1, 5.14; Milsted, et al.,

Tr. of 31 July 1975 (Volume II) , pp. 1-2; FES Final Supp., fol.

Tr. 7767, SS 4.5.8, 7.1, 11.8.8; Leech, et al., fol. Tr. 7767, pp. 4-6, 8; Tr. 7886-894, 8066-069. The Board believes that the beauty or unattractiveness of the facility will be in the eye of the beholder . It will be a personal matter , and reac-tions will vary f rom individual to individual. We note, how-ever , that the local topography, as well as design features,

_35_ 1247 042

will tend to lessen the aesthetic impact considerably; and we conclude chat, overall, such impact will not be substantial.

63. In contention J.8 SCANP suggests that, in violation of NEPA, the visual impact of the plant has not been considered.

SCANP thus apparently ignores the description of the external -

appearance of the proposed facility, and the visual impact of that appearance in the final environmental statement which, in fact, includes visual impact among the " unavoidable adverse environmental effects of the proposed facility." FES, fol.

Tr. 2913, SS 3.1, 5.1.4, 10.1.1.4 and Table 10.1. Further, it is clear that the Staff, in preparing the environmental state-ment, considered the visual impact of the plant structures, including the cooling towers and their plumes, f rom several vantage points. See, Milsted, et al., Tr. of 31 July 1975 (Volume II). See also, FES Final Supp., fol. Tr. 7767, SS 4.5.8, 11.8.8. In addition, as indicated above, we have considered the visual impact of the facility and have found that, while there will be an aesthetic impact, it will not be a significant adverse impact. For these reasons, we find that the visual impact of the plant on the recreational values of the Skagit River and surrounding terrain have been considered '

and that contention J.8 is without merit.

e 1247 043

3. Project Discharge

64. Characteristics of the Project Discharge. The Project discharge will consist of the combined flow of all plant water ~

effluent streams except for the plant sanitary sewage' which will be routed separately to the Sedro Woolley municipal sewer-age system. These streams will include the main cooling tower blowdown, the low volume waste after treatment, the fish rear-ing facility effluent, and the dilution water. Berthrong, fol.

Tr. 3382, p.1; FES, fol. Tr. 2913, Table 3.5; Exh. 4, Fig. 3.3-1.

65. The flow rates of each of the above effluent streams will vary with plant operating conditions. Applicants used the maximum flow rates that will occur in each stream during opera-tion of the Pr sject to determine the " worst case" potential environmental impacts from the Project discharge. Berthrong, fol. Tr. 3382,, p. 2.

66. The main cooling tower blowdown will be the only sig-nificant contributor to raising the temperature of the Project discharge above the temperature of the makeup water for the '

Project. The maximum Project discharge temperature of 70*F was calculated assuming that the following conditions occur simul-taneously: both units operating at maximum rated power level; wet bulb temperature = 69'F; relative humidity = 50%; blowdown -

1247 044

/

from " cold leg"; no temperature change across the fish rearing f acility or in any of the pipes routing the water from point to point; cycles of concentration = '

,; makeup water temperature =

64*F. Berthrong, fol. Tr. 3382, pp. 2-3; FES, fol. Tr. 2913, SS 3.6.2; 5.5.3.2; Tr. 3379-380. -

67. Assuming that blowdown will be made only f rom the cold leg of the cooling towers, the maximum differential temperature between the Project discharge and the Skagit River would be 16*F. This maximum diff erential temperature was calculated assuming the following conditions: both units operating at maximum rated power level; wet bulb temperature = 50*F, rela-tive humidity = 70% (these are the most limiting conditions that occur simultaneous.y with minimum river temperature);

maagit River temperature = 34*F; cycles of concentration = 12.

Under these conditions, the Froject discharge temperature would be 50*F. Berthrong, fol. Tr. 3382, p. 3; FES, fol. Tr. 2913, S 5. 3. 2 ; FES Final Supp . , f ol . Tr . 7/67, p. 4-15; Exh. 119,

p. 15.

68. It may be desirable to use blowdown from the hot leg of one unit in order to optimize the temperatures in the fish rearing f acility, if such blowdown is permitted at some future '

date. Assuming the simultaneous conditions used in the calcu-lation of the maximum differential temperature for coid leg 1247 045

blowdown, the maximum dif ferential temperature between the Pro-ject discharge and the Skagit River would be 21'F if blowdown is taken f rom the hot leg of one unit. Under these conditions, the Project discharge temperature would be 55'F. Berthrong, fol. Tr. 3382, p. 4. --

69. Applicants' witness Berthrong corrected certain errors appearing in the ER and FES. Since the errors involved tem-peratures existing only within the plant and since the data bearing on environmental effects were correct, the errors do not change the analyses of environmental impact. Ber thr ong ,

fol. Tr. 3382, pp. 4, 5.

70. The Project discharge will flow by pipeline to che Skagit River and be discharged through a 65-foot moltiport dif-fuser. A port orientation of 60* f rom the horizontal in the direction of the river flow was selected to avoid the jet con-tact with the river bottom. The diffuser will be located at the river bottom about 100 feet from the north bank. The dis-charge velocity will be about 6 fps and 13 fps for one- and two-unit operation, respectively. The ports will be 4 inches in diameter, spaced on 1.5 foot centers. The diffuser system is designed to' achieve rapid dilution as compared to other ~

types of discharge schemes, such as surface discharge. Of the possible submerged discharge methods, the multiport diffuser yields the greatest dilution, and is therefore the preferred

_39_ 1247 046

system for use at this facility. Scott, fol. Tr. 3382, p. 9 and Fig . 1; FES , f ol . Tr . 2913, S 9.3.3.2; Exh. 4, SS 3.4.6, 5.1.2.1, Figs. 2.5-7, H.1-1; Tr. 3389-391.

71. Impact on Water Quality. Chemicals will be used in the plant for the control of water quality, scale control, re-generation of demineralizers and the control of biological fouling. Chakravorti, fol. Tr. 3382, p. 5; Exh. 4, S 3. 6.1 and Table 3.6-1. The Project discharge will consist of intake water modified by the addition of chemicals and by evaporation of the circulating water in the cooling towers. Both the chemical treatments that will cause changes in the constituent concentrations and the resulting estimated maximum and nominal (average) daily discharges are described in the ER. The esti-mated maximum concentrations of the various constituents in the Project discharge have also been identified. Chakravorti, fol.

Tr. 3382, pp. 5, 6, 8, and Table 2; Exh. 4, S 3.6.3.1 and Tables 3.6-3, 3.6-4 and 3.6-5. The Staff's independent esti-mates of chemical composition in the discharge agree very well with those of Applicants. FES, fol. Tr. 2913, S 5.5.3.2.

72. Three sources of information were used to describe the ambient water quality of the Skagit River. Information from the U.S. Environmental Protection Agency-STORET computer file for the period 1959-70 was used in the ER. The second source was newer STORET data for the period 1970-74. The third source 1247 047 was the water quality data collected by Applicants ' consultant Dames & Moore. Because review of the three data sets showed that they are generally consistent, each may be used to ade-quately describe the river's water quality. However, there are three disparities concerning reported concentrations of copper, "

zinc and ammonia. Applicants' witness Houghton explained the bases upon which he resolved these three disparities and pre-cented the maximum expected concentrations of these constitu-ents in the river. Applicants' witness Chakravorti supple-mented the ER with regard to the concentrations of copper, zinc and ammonia which can be expected in the cooling tower blow-down, the Project discharge and in the river under conditions of maximum ef fluent concentration and minimum low flow (using the 10-year, 7-day low flow value of 4740 cfs). Chakravorti, fol. Tr. 3382, p. 618; Houghton, fol. Tr. 3382, pp. 6-8 and Table 2; Tr. 3436-438.

73. One percent sodium hypochlorite solution will, when necessary, be added to the circulating water upstream of the condensers daily for a maximum period of 30 minutes. The amount will be controlled so as to achieve a free availcole chlorine concen'tration of 0.5 mg/l (maximum) and 0.2 mg/l (average) at the condenser outlet. Residual chlorine includes f ree avai.'.able and combined chlorine. The latter basically appear as chloramines, the compounds formed by reactions '

_41_ 1247 04"

between chlorine and nitrogen-containing organic and inorganic compounds. Chakravorti, fol. Tr. 3382, p. 8; FES, fol.

Tr. 2913, S 3.6.3; FES Final Supp., fol. Tr. 7767, p. 4-15; Exh. 4, S 3.6.3.4.

74. SCANP contended, in PSAR Contention 1.d, that "the ~~

operation of the Project will result in the discharge into the Skagit River of biocides in addition to those evaluated by the ER and PSAR." SCANP PSAR Contentions, p. 1. It presented no evidence in support of this contention. SCANP's letter dated March 17, 1975, connencing on the NRC DEIS, suggested that

" supplemental shock biocide dosages" will be used because

" chlorine will not be sufficient after a few years."

Applicants' plan to use chlorine in the form of sodium hypo-chlorite solution. In view of the fact that chlorine is the only biocide in general use in steam-electric generating plants, there is no reason to believe that any other biocide will have to be used at this facility. The Board finds that the only biocide that will be discharged in connection with the operation of the f acility will be chlorine, the ef fect of which has been thoroughly evaluated in Applicants' documents , in the FES and at the' evidentiary hearing. For this reason, the Board finds that SCANP's PSAR Contention 1.d is without merit.

Chakravorti, fol. Tr. 3382, p. 8; FES, follows Tr. 2913, S 11.18.6 and pp. A-70 to A-76; Exh. 4, SS 3.6, 5.4. EFSEC's 1247 04/

findings regarding Applicants' NPDES permit support this conclusion. Exh. 57, p. 16,

75. The cooling tower blowdown will be diluted with fish rearing facility effluent and dilution water. Due to this dilution, the chlorine demand of the dilution water, and the ~

residence time of the discharge water within the pipeline, only a very small amount of total residual chlorine concentration will appear at the point of Project discharge. An extremely conservative estimate of the total residual chlorine concen-tration at that point is 0.09 mg/1. This estimate is based on the maximum value of ammonia observed in the Skagit River (0.31 mg/1). Chakravorti, fol. Tr. 3382, pp. 8, 9; Exh. 57, pp. 16,

17. The Staf f concluded that the total residual chlorine in the Project discharge will not be detectable. FES, fol. Tr.

2913, p. 3-23,

76. Effluent from the fish-rearing f acility will con-tribute to the suspended solids, turbidity, biological oxygen demand, and a lower dissolved oxygen in the river. Apart from residual suspended solids, the only measurable changes in water quality resulting f rom the operation of the fish f acility will be small increa'ses in nitrate, phosphate, ammonia and bioleg- ~

ical oxygen demand, and a decrease in dissolved oxygen. These changes will be small when compared to those introduced by the chemical additives and the ef fect on the discharge composition

~4 -

1247 050

will be negligible. Milstead, fol. Tr. 3345, p. 2; FES, fol.

Tr. 2913, SS 3.7.3, 5~.5.3.2; Exh. 45. Ammonia production in the fish-rearing facility has not been taken into consideration in relation to biocide discharges because ammonia in the ex-pected concentrations (maximum of 1.7 mg/1) is neither toxic in ~

itself , nor expected to contribute to chloramine formation due to the absence of free chlorine in the blowdown. The residual chloramines in the fish-rearing f acility would be reduced to zero within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. Consequently, levels of chloramines ,

which could prove toxic to aquatic biota, are not expected to be approached. Milsted, fol. Tr. 3345, pp. 2-4; Tr. 3348, 3352, 3357.

77. Thermal Effects. Two examples of thermal impact on the Skagit River were analyzed and presented by Applicants.

First, the maximum recorded river temperature of 64 *F repre-sents the critical condition for design of the diff er because it requires the maximum dilution to meet the state water quality criteria. Second, the minimum river temperature of 34'F and the corresponding Project discharge temperature of 50*F represent the largest temperature difference between the Project dischar'ge and the river. Scott, fol. Tr. 3382, pp. 9, 10.

78. The mean annual flow and 10-year , 7-day low flow of the Skagit River at Sedro Woolley are estimated by the USGS to 1247 051

be about 16,200 cfs and 4,740 cfs, respectively. For the 10-year, 7-day low flow and the mean flow, the flow depths at the diffuser location are estimated to be about 10 and 14 feet, respectively. The river :elocities are estimated to be about 1.5 fps for the 10-year, 7-day low flow and 3 fps for the mean flow. Scott, fol. Tr. 3382, p. 10.

79. Applicants analyzed the chemical and thermal plumes associated with the Project discharge, based on models which provide the best estimate presently available of diffuser per-formance. 10-year, 7-day low flow conditions were aste.ned for the analyses. " Worst case" summer and winter thermal plumes were presented, together with the " worst case" dilution plume.

Scott, fol. Tr. 3382, pp. 10, 11, and Figs. 2 through 5; Tr. 3391-397. Extreme conditions were assumed, leading to overestimates of the changes in water quality parameters. FES, fol. Tr. 2913, p. 5-19.

80. SCANP's witness Dr. Brubaker testified that fish might suffer adverse effects by virtue of the thermal discharge to the Skagit River. Brubaker, fol. Tr. 29 25, p. 18 ; Brubaker, fol. Tr. 8211, p. 4; Tr. 2926-928. His literature search had

~

revealed report's that an increase in predation rates for fish resulted from " thermal doses of about 10 to 20 percent less than those required to incur visual disequilibrim." Tr. 2829.

However, he was unable to relate the "10 to 20 percent less" to 1247 052

any specific figure and it is therefore impossible to evaluate the allegation in the Skagit case. Tr. 2829-832.

81. From an environmental point of view, the worst case condition associated with the thermal discharge from the Pro-ject would be that where the largest possible temperature dif- -

ference (delta T) between the Project discharge and the Skagit River coincides with low flow in the Skagit River. The largjst delta T can be uxpected to occur in the winter; when the mini-mum Skagit River temperature is 34*F, the Project discharge trmperature could be as high as 50*F, giving rise to a delta T cf 16*F. Assucing the river to be flowing at the 10-year, 7-day low flow of 4740 cfs, dilution within approximately four f eet downstream of the dif fuser would reduce the delta T to 46*F. An organism carried at the low flow river velocity of 1.5 fps would travel through this four-foot distance in approx-imately three seconds. Within 100 feet of the diffuser, the elapsed time would be 67 seconds and the delta T would be ruduced to 0.8'F, under low flow conditions. Juvenile sal-monids migrating downstream are not always carried passively downstream. Rather they tend *to swim weakly into the current to maintain their orientation while being carried downstream. '

The maximum sustainable cruising speed for these fish is on the order of 1 fps. If it is assumed that they are swimming up-stream at this velocity under the 10-year, 7-day low flow, the 1247 053

effective downstreaa velocity of the fish is reduced to 0.5 fps and expccure times are tripled. A fish subjected to this worst case thermal transient as described should not experience any lasting stress. Houghton, fol. Tr. 3362, pp. 11, 12; Exh. 4, at.S 5.1.2.3; FES, fol. Tr. 2913, p. 5-19; Tr. 3429, 8246, 13,207.

82. The worst case summertime condition corresponds tc a Skagit River temperature of 64*F and a discharge temperature of 70*F, yielding a delta T of 6*F. Since a fish acclimated to 64*F water can be placed in 70*F water with very little stress c rer a period of several hours, the relatively brief exposure to the maximum summertime thermal transient certainly should cause no lasting stress. Houghton, fol. Tr. 3382, p. 13; Exh. 4, S 5.1.2.3.

83. SCANP's witnass Brubaker suggested that fish would be attracted into the discharge plume and would remain there suf-ficiently long to become adversely affected either by various constituents of the Project discharge or by " cold shock" resulting from a ceasing of thermal effluent when the plant shuts down. He suggested that both the temperature and chlorine compon'ents of the Project were capable of attracting '

fish. Dr. Brubaker presented no evidence relating to thermal attraction which could be used to assess the possibility that such attraction would occur at this facility. Dr. Brubaker 1247 054'

made a general reference to a study by Sprague and Drury in suppcct of his contention that fish would be attracted to the chlorine content of the project discharge. Brubaker, fol.

Tr. 2925, p. 19; Tr. 2928-92.'. 2932-933, 2936, 2956, 2959, 2975.

84. Applicants' witness Houghton testified that the physical configuration and location of the discharge plume negates the possibility of attraction of fish to the thermal component of the plume. For example, under the warst case winter condition, the delta T would be 4*F at a point 4 feet downstream from the diffuser. This region would be elevated f rem the river bottom and in an area of relatively high cur-rent. Because the maximum sustained cruising speed of juvenile salmonids is less than the velocity in the river at the 10-year, 7-day low flow, it is extremely unlikely that a juve-nile salmonid would be able to remain within the plume for any substantial length of time. Further, the jet velocity of the discharge, which is 6 or 13 feet per second at the diffuser during one or two-unit operation, respectively, would cause the water in the vicinity of the diffuser to move even faster than the average river flow, thus making it even more unlikely that a juvenile salmoid wc'11d remain the discharge plume. The water

~

velocity is also too great to allow planktonic food sources to concentrate in the plume. While adult fish are capable of a higher maximum cruising speed than juveniles, adults have a

_,,_ 1247 055

known tendency to remain near the bottom. Therefore, it is unlikely that they would leave the bottom and prefer to remain in the elevated discharge plume. Milsted, et al., Tr. of 31 July, 1975 (vol. II) , p. 2; Houghton, fol. Tr. 3382, pp. 18, 19; FES, fol. Tr. 2913, p. 5 19; Tr. 3402-404. Returning to "

Dr. Brubaker's suggestion that salmonids 5 ould be attracted to the thermal plume, we note that he did not know the cruising speed of juvenile salmonids. He further had no idea of whether they could maintain themselves in the plume at all, let alone for the time required before the fist would become acclimated.

Tr. 2949-950, 2952-957. For the above reasons, we cannot agree with Dr. Brubaker. As a footnote, we observe that EFSEC also did not accept Dr. Brubaker's opinion in this regard. Exh. 57,

p. 22.

85. According to Dr. Houghton, ths Sprague and Drury study mentioned by Dr. Brubaker , which relates to attraction to chlorine, showed that fish were attracted to a chlorine level of 0.1 mg/1, and showed an avoidance for all other chlorine levels tested, both higher and lower. Because the maximum ex-pected chlorine concentration at the Project diffuser (0.09 mg/l is just below the level at which attraction was shown to '

e xist , and because that maximum level will be very rapidly diluted by mixing with the river, the fish would have to trav-erse a large region of the lower chlorine concentrations ". hey 1247 056

have been shown to avoid before they could reach the relatively small region near the diffuser where attractive concentations could exist. Further, any fish that did reach the area of at-tractive concentrations would be quickly displaced from that region by the river current and by the jet velocity of the dif- -

fuser discharge.

Tr. 3405-407.

86. Dr. Brubaker suggested the possibility that the dis-charge plume might constitute a block to upstream salmon migra-tion. Brubaker, fol. Tr. 2925, p. 10. During the 10-year, 7-day low flow, the diffuser and dilution zone would occupy only about 15 percent of the total river width. Because adult salmonids swimming actively upstream are able to detect and avoid any potentially harmful conditions , they are capable of avoiding the discharge plume; such avoidance has been o bser ved . Studies reporting interference with migration on the Columbia River indicate such interference occurreo when the river temperature reached about 70*F, a condition which will not exist in the vicinity of the Skagit discharge. The Project discharge will not result in a blockage of upstream migration.

Houghton, fol. Tr. 3382, p. 18, 19; FES, fol. Tr. 2913,

p. 5-19; FES Final Supp., fol. Tr. 7767, p. 4-18; Exh. 4, S 5.1.2.3; Exh. 57, p. 22; Exh. 119, p. 33; Tr. 2970-973, 3409.

87. In response to a postulation by SCANP, the Staff eval-uated the possible effects of the Project discharge should 1247 057

fewer than 12 cycles of concentration be used. The Staff analyzed operation of the cooling system at 6 cycles of concen-tration under extreme conditions (i .e . , maximum blowdown tem-perature and low flow conditions). The result of this worst case analysis is that 25 feet fr,om the diffuser, the fully -

mixed temperature increase would be only about 0.55'F (as com-pared to 0.34*F. in the case of 12 cycles of concentration) .

This very slight change in delta T is most likely not detect-able and is an order of magnitude less than diurnal variations in river temperature. With respect to chemicals, the dif-ferences in concentrations in the fully mixed region in either 6 or 12 cycle operating modes are indistinguishable.

Schreiber, et al., fol. Tr. 12,226, pp. 14-18. Therefore, we find that operation of the cooling system at fewer than 12 cycles of concentration (and as low as 6 cycles of concentra-tion) would not affect our findings on the potential thermal and chemical effects of the Project discharge.

88. Chemical Effects. Dr. Brubaker also expressed the opinion that various constituents of the Project discharge would be capable of adversely affecting aquatic organisms, even

• to the point of death. He cited concentrations of chlorine, -

copper, zinc and other metals that had been shown to produce deleterious effects, either singly or in combination. In con-trast to the testimony of Dr. Houghton, which included con-sideration of the time of exposure of an organism to a -

1247 058

chemical, Dr. Brubaker rarely made any reference to an exposure period. Brubaker, fol. Tr. 2925, pp. 17-22; Brubaker, fol.

Tr. 8211, p. 3; Tr. 2934-936. While Dr. Brubaker 's testimony did serve to call attention to the potentially toxic nature of the Project discharge, the Board is satisfied that Dr. "

Houghton's analysis has fully explored these possibilities.

89. Chlorine is among the most toxic agents potentially present in the Project discharge. The conservatively estimated maximum level of total residual chlorine at the point of dis-charge is 0.09 mg/1, for up to 30 minutes per day with one unit operating. Within four feet of the diffuser, the concentration will be diluted to 0.03 mg/1; this corresponds to an elapsed time of three seconds for a passively transported orssnism. A level of 0.04 mg/l is a level appearing in the literature as affording protection to most species of fish for exposure periods of up to two hours per day. The Blue Book (Water Quality Criteria 1972, A Report of the Committee on Water Quality Criteria, Environmental Studies Board, National Academy of Sciences, National Academy of Engineering, Washington, D.C.,

(1972)) states that a limit of 0.05 mg/l should protect most species of fish' for exposure periods of up to 30 minutes per '

day. Within 100 feet of the diffuser, corresponding'to an elapsed time of 67 seconds, the concentration will be less than 1247 059

O 0.005 mg/1. Since this concentration of chlorine can only ap-pear intermittently and since it approaches the level (0.003 mg/1) cited in the literature as adequate to protect most species for continuous exposure, no adverse impact is ex-pected. Houghton, fol. Tr. 3382, pp. 13, 14, Figs. 2 and 5; -

FES, fol. Tr. 2913, p. 5-19; Exh. 4, S 5.4.3.

90. Of the other components of the Project discharge po-tentially toxic to fish, only ammonia is increased substan-tially by chemical additions during operation of the facility.

The others, including several heavy metals, are simply concen-trated in the cooling towers and released to the river. The maximum level of ammonia to be expected at the point of dis-charge is 1.23 mg/1, based on a maximum Skagit River concentra-tion of 0.31 mg/1. That concentration at the point of dis-charge is below the level reported in the literature as allow-ing survival of steelhead for a period of several hours. Since this concentration will be very rapidly diluted, no biological stress is expected to occur. Houghton, fol. Tr. 3382, p. 14; FES Final Supp., fo' Tr. 7767, p. 4-18; Exh. 119, p. 32; Tr. 3436-437.

91. Other -Project discharge consitutents including copper ~

and zinc are naturally present in the Skagit River. The opera-tion of the cooling towers will concentrate these natural con-stituents by twelve times, as a maximum, in the cooling tower 1247 060

olowdowns . However, following dilution of the cooling tower blowdown with the other components of the Project discharge, the ratio of (1) the concentration in the Project discharge to (2) the concentration in the Skagit River of a naturally present constituent will be approximately four , at the --

ma ximum . Chakravorti, fol. Tr. 3382, pp. 5, 6 and Table 2; Exh. 4, Table 3.6-5, S 5.4.1.1.

92. Aquatic organisms will be exposed to these elevated concentrations for a relatively brief length of time. For example, within 67 seconds, an organism carried at the low flow river velocity will have passed through the portion of the plume where the volume of the Project discharge relative to the volume of ambient river water is greater than five percent.

Af ter complete mixing of the Project discharge with the Skagit River at the 10-year 7-day low flow, the concentration of a naturally occurring constituent will be increased by 1.6 percent over natural conditions. Because of the brief periods of exposure to the relatively concentrated levels of these chemicals, and the very slight increase of concentrations existing during longer term exposure, no acute biological shock to aquatic organisms is predicted, nor is any measurable ad-verse effect on the aquatic environment expected to occur.

Houghton, fol. Tr. 3382, pp. 14-16; Scott, fol. Tr. 3382, Figs . 2 and 5 ; FES , f ol. Tr . 2913, p. 5-19; FES Final Supp.,

1247 061

fol. Tr. 7767, p. 4-18; Exh. 4, S 5.4.2; Exh. 119, pp. 32-33; Tr. 3407-408.

93. In addition to the effects of the constituents of the Project discharge taken separately, additive and synergistic interactions must also be considered. There is considerable documentation of synergism between relatively concentrated mix-tures of copper and zinc in solution. At lower levels, such as those which were shown to be the maximum that may exist 100 f eet downstream from the dif fuser, no synergism is expected and the effects are additive. At the point of discharge, the con-centrations of cooper and zinc under the worst case conditions are at levels where possible synergistic interactions might occur under longterm exposure, i .e., on the order of several hours. However, the rapid dilution of these concentrations and the short exposure time of any biota, which will be on the order of seconds, ccmbined with the low probability of coinci-dent high concentrations, lead to the conclusion that there will be no measurable impact resulting from the combined ef-f ects of copper and zinc. Houghton, fol. Tr. 3382, pp. 16-17.

94. It is also documented in the literature that increased temperature can increase the toxicity of various pollutants, '

including chlorine and heavy metals. While there are no laboratory studies researching the ef fect of all the various constituents in the Project discharge, it is clear that the 1247 062 increased toxicity of the various constituents due to increased Memper?ture will not be such as to cause acute biological shock, doe to the extremely brief exposure time. Houghton, f ol . *.T . 3 3 8 2, y . 17.

95. Dr. Brubaker cited research into the combined and -

synergistic effects of heat and chlorine showing that effects may be synergistic at a temperature of 20*C. However, he did not know the period of exposure required to produce the ef-

-fect. ,

Earlier published work by the same researcher (Thatcher) showed that a delta T of 10'C (18'F) , which is higher than the maximum calculated for the f acility, was necessary before synergy between heat and chlorine was noted. Brubaker, fol.

Tr. 2925, p. 19; Tr. 2929, 2933-936, 2947-949, 2950-952, 2962-965, 3404-405.

96. Juvenile salmonid out-migration coincides with periods of high river flow in the Skagit River. Most of these juve-niles travel in near-shore areas and near the surface. Since the discharge diffuser has been located so as to avoid plume contact with these areas, it is expected that very few juve-niles will enter the plume at all. Of those that do enter the plume, few, if -any, will pass through the limited area within -

four feet of the diffuser where the highest temperatures and concentrations will exist. If we assume the extreme case where 1247 063 all of the worst conditions coincide that is the highest con-centration of heavy metals and ammonia in the river , the highest delta T condition, the lowest river flow, all coinci-dent with plant chlorination -- it is possible that a juvenile swimming upstream against the current while passing through the ~

f ull strength of the plume would suffer some stress. The like-lihood of this is extremely low and it would not cause a measurable reduction in the total population of any fish species. Houghton, fol. Tr. 3382, pp. 17-18.

97. The Board finds that there will be no substantial ad-verse ef fect on the aquatic bioca as a result of the Project discharge, and that any damage to the Skagit River fishery will be so slight as to be undetectable. Milsted, et al., Tr. of 31 July 1975 (Vol. II) , p. 2; FES, fol. Tr. 2913, p. 5-19; FES Final Supp., fol. Tr. 7767, p. 4-19; Exh. 119, p. 33.

98. SCANP Contentions. In view of the fact that the ther-mal component of the f acility's proposed discharge, acting either separately or together with.other constituents of the discharge, is not expected to result in any substantial adverse effects, the Board finds that SCANP's contention that " thermal discharges into' the Skagit River will be excessively high ~

levels" is unfounded. SCANP PSAR Contention ,1.b.

1247 064

99. We have previously addressed SCANP PSAR Contention 1.d, alleging the discharge of supplemental biocides, and found it to be without merit. SCANP's final contention regarding aquatic impacts is Contention J.3:

3. The DEIS completely ignores the economic signifi- ~

cance of the fishery based in the Skagit River.

There is no dollar value placed on the fishery, and no attempt is made to reflect the potential economic and social harm of any damage to the fishery which may be caused by normal or abnormal plant operations.

100. The Staff, in both the FES and the FES Final Supple-ment, thoroughly evaluated the aquatic ecology in the site vicinity and the ef fects of both construction and operation of the Project on the aquatic ecciogy, including the fishery based in the Skagit River. FES, fol. Tr. 2913, SS 2.7.2, 4.3.1, 4.4.2, 5.3.2, 5.5.3, 10.1.2.2; FES Final Supp., fol. Tr. 7767, Ch. 4 and SS 5.3, 11.5.3, 11.8.9. We previously found that the damage to the fishery from construction and operation will be so slight as to be undetectable. Furthermore, the record con-tains no evidence of abnormal operations which could have an adverse impact on the aquatic ecology of the river. Therefore, the Board finds that Staff was correct in not including any cost figure for- the fishery in its cost-benefit analysis. -

Milsted, et al., Tr. of 31 July 1975 (Vol . II), pp. 1-2. The Staff has conservatively estimated that the possible total eccnomic loss in the fishery of the creeks due to the Project 1247 065

would be $5,350, which we consider to be an insignificaat por-tion of the value of the Skagit River fishery. Id., pp. 3-4.

We find no merit in Contention J.3.

4. Ranney Collector System 101. Fotr Ranney Collectors will supply the cooling water for the proposed facility. A Ranney Collector consists of a vertical caisson with slotted lateral pipes, which radiate horirontally from the caisson. The collectors will be installed near the banks of the Skagit River at River Mile 39. The collectors are designed to infiltrate water originating from the Skagit River through the sand and gravel aquif er at that location. Exh. 4, S 3.4.5, App. G; FES, fol. Tr. 2913, S 3.3.5.

102. Many aspects of the Ranney Collector system received attention during these proceedings. These aspects included (1) environmental effects of operation, (2) yield, (3) quality of water to be produced, and (4) reliability of the system. Each of these subjects is discussed below.

103. Environmental Effects of operation. The pumps for the water supply will be located in a pumphouse on top of each cais-son. The pumps and ventilating equipment will cause a quiet hum (about 40 dba) immediitely outside the pumphouse. At the edge of

_33_ i247 066

the river the noise from operation of the collector system will be about the same as leaves rustling on trees. Such noise should have no adverse effects on or along the river. Tr. 10,654-656; Exh. 207, pp. 7, 8.

104. The pumphouses will extend to a height of tao feet above ~

the 100-year flood level and will be located between 130 to 150 feet from the river 's edge, behind the dike. As such the pump-houses will not be visible from the river, except perhaps during high water conditions. In addition, the exterior of the pump-houses will be covered with coarsely textured wood siding to blend in with the surroundings. Vegetation will be planted to screen the pumphouses. Based on these plans, we find that the Ranney Collectors will have essentially no visual impact.

Exhs 159-162, 204; Exh. 207, p. 7; FES, fol. Tr. 2913, App. D.;

FES Final Supp., fol. Tr. 7767, pp. 4- ; Tr. 10,652-653.

105. When operating, the Ranney Collectors will induce the infiltration of river water through the aquifer. Witness Orrell suggested the possibility that salmon fry would be attracted by water moving into the aquifer and thus be drawn into the system.

He assumed a velocity of water movement which is the swimming rate for salmon- fry of a least 0.5 feet per second. Exh. 40, pp. 84-85, 93-95; see also, Tr. 8246. However, based upon the results of pumping tests, the velocities into the aquifer will be approximately 0.001 feet per second. Mikels, fol. Tr. 3041, 1247 067

p. 3; Tr. 3052-057. Orrell also assumed that the laterals would extend under the river when, in fact, they end at or before the river's normal edge. Exh. 164, 165; Tr. 3046-047. Therefore, we do not anticipate that salmon fry will be attracted by or drawn

~

into the Ranney Collector system. FES Final Supp., fol.

Tr, 7767, pp. 4-7, 4-8.

106. Operation of the Ranney Collector system will cause drawdown ot the water table. At 800 and 1600 feet from the col-lectors the maximum drawdown wil.'. not exceed 4 feet and 2 feet respectively. Exh. 4, Supp. 1, pp. 208-209. The drawdowns will not materially affect local wells. Id.; FES, fol. Tr. 2913,

p. 5-2. Concerns were : Iso raised by SCANP witness Weber about what effect the water table drawdowns might hr.ve on two nearby streams--Muddy Creek and Red Cabin Creek. Weber, fol.

Tr. 12,378, p. 4. However, the dcta indicate that these two creeks are perched above the groundwamer table. Mikels, fol.

Tr. 10,688, pp. 9, 10.; Anderson, fol Tr. 10,735, pp. 7, 8; Schre iber , et al . , fol . Tr . 12,226, pp. 18-20; Schreiber, fol.

Tr. 12,227, pp. 6-8, Fig. 1. Weber agreed that the creeks are perched. Tr. 12,509. Hence, drawdown of groundwater due tc pumping of the Ranney Collectors will have no effect on the water levels in the nearby creeks. Tr. 10,849-850. Furthermore, even 187 0(3B

if the groundwater table were at or above the stream level, the influence on the creeks ~would be small. Schreiber, et al., fol.

Tr. 12,226, pp. 19, 20.

107. Yield of the Ranney Collectors. The maximum water de-mand (68.4 million gallons per day or MGD) for the plant will be "

in summer, when the Ranney Collector system would produce in ex-cess of 115 MGD. In the winter, when the plant demand would be about 49.2 MGD, the capacity of the Ranney system would be at its minimum of approximately 80.7 MGD. Under condit.ons of average water temperature and average river stage, the Ranney system could produce 104.3 MGD, while the average plant demand would be about 57.9 MGD. Therefore, the predicted yield of the Ranney Collector system will exceed plant requiremente by at least 60%

under summer, winter, or average conditions. Mikels, fol.

Tr. 3041, pp. 2, 3; Mikels, fol. Tr. 10,691, p. 5; Schreiber, fol. Tr. 12,227, p. 4.

108. The Board inquired as to whether the results of the pumping tests conducted during the hydrogeological survey of the Ranney Collector site could be used to predict the yield of the system. Tr. 8,389-390. The flow rates during the pumping tests were 1.3 to 1.5'MGD while the maximum plant demand frcm the ~

Ranney system will be 68.4 MGD. Mikels, fol. Tr. 10,691, p. 2.

The pumping tests produced data for the computation of the perme-ability of the aquifer area that includes the area to be influ-enced by the proposed Ranney Collectors. Id., pp. 4, 5, and Att. A; Tr. 10,695-700, 12,321-322, 12,335. Yield was calculated

~

using the permeabilities of the aquifer.

109. The methodology, which was used by Applicants' consul-tant Mikels for predicting the yield and was based on Darcy's law, is widely accepted by groundwater hydrologists. An inda"en-dent check of this methodology by the NRC Staff's hydrologist produced estimated yields quite similar to those of Mikels.

Mikels, fol. Tr. 10,631, pp. 3,4; Schre iber , fol . Tr . 12,227,

p. 3; Tr. 10,737, 12,466. A comparison of predicted yields (based on relatively small rate pumping tests) with actual yields for all Ranney Collectors constructed in the western United States over the last 10 years indicated that the actual yield is equal to or exceeds the predicted yields. Mikels, fol.

Tr. 10,691, p. 6; Att. C; Tr. 10,701-704. This demonstrates that the methodology used by Applicants here is conservative and reliable.

110. SCANP"s witness Weber expressed several doubts about the ~

estimated yields from the Ranney Collectors. He said there might be a 50% variation in yields based on his engineering judgment.

1247 070

Tr. 12,388, 12,450, 12,505. However, he neither had performed any calculations to support his claim, nor had any prior experi-ence with Ranney Collectors. Tr. 12,435, 12,450, 12,466.

111. Weber stated that there was limited uncertainty about the application of Darcy's law, which was used for the yield cal- ~

culation at this site. He reasoned that turbulent flow might develop in what he described as coarse gravels and cobbles in the aquifer at the Ranney Collectors site. Tr. 12,381-382. His opinion was based solely upon a textbook reference by Cedergren, not upon any case examples. He was not able to identify when Darcy's law begins to break down in the manner he describe >.

Tr. 12,432, 12,453-454, 12,468. The Cedergren reference per-tained to the design of filter drains with manmade materials (crushed gravels) from which all fine material such as sand had been removed. The materia? at the collector site is a naturally deposited sandy gravel aquifer, which is not at all comparable to the artificial material described by Cedergren. Tr. 14,263-266.

The permeability for the smallest manmade materials described by Cedergren was 30 to 100 times larger than the permeabilities measured at the collector site.' Id.

112. Undisputed among the witnesses was the f act that the '

aquifer at the collector site is highly permeable. Mikels, fol.

Tr. 3041, p. 3; Exh. 4, App. G; Anderson, fol. fr. 10,735, p. 3; 1247 07I

Tr. 12,258, 12,433-434. As compared with permeabilities en-countered at several other Ranney Collector and vertical well sites, the permeabilities involved here are not unusual. Devia-tion from laminar flow has not been observed elsewhere.

Tr. 10,841, 12,258, 14,260-262, 14,315. Based upon the maximum ~

groundwater velocities for the proposed design, the Ranney Col-lectors will be operated well within the laminar flow range for which Darcy's law is valid. Additional conservatism regarding the yield calculations arises from the f act that the pumping tests, which provided the data to compute the yields, were run at even higher groundwater velocities, though still witnin the laminar flow regime. Mikels, fol. Tr. 10,691, pp. 2, 3, Att. B; Tr. 12,519-522, 14,266. 14,314-315. Therefore, we find Weber's concerns about turbulent flow conditions occurring at the Skagit collector site to be without foundation.

113. Weber further criticized Applicants' yield predictions because a line of observation wells perpendicular to the river was not used during the pumping tests. Tr. 12,382. Mikels ex-plained that when he started performing hydrogeological investi-gations for potential Ranney Collector sites, in the 1950's, a perpendicular l'ine was used to determine whether water infiltra- ~

ted from a river. In the early 1960's this procedure was dropped due to the availability of less costly means of determining recharge. His considerable experience since then demonstrates 1247 072

that a perpendicular line of wells is not needed to predict the yield from a proposed collector system. Mikels, fol. Tr. 10,691, Att. C; Tr. 14,259, 14,293-294, 14,306-312. Witness Schreiber agreed that perpendicular observation wells were not needed.

Tr. 12,233. We agree.

114. Weber further criticized the yield predictions as being affected by the relocation of the caissons 50 feet further in-land. Tr. 12,392-393. Applicants relocated the caissons for the collectors to reduce the visibility of the collectors from the river. Tr. 10,641-643. Weber concluded that this relocation had the effect of shifting the drawdown cone for each collector 50 feet inland. Tr. 12,392-393, 12,459-462; Exh. 178. Weber, how-ever, did not understand the cone of drawdown for a Ranney Col-lector. Instead, when asked, he drew a cone of drawdown center-ing on the caisson as though it were a vertical well, even though caisson location has no bearing on the cone of drawdown. He ignored the horizontal laterals from which the water is obtained, and which therefore control the shape of the cone of drawdown.

Id.; Exhs 209, 210; Tr. 14,266-273. The same area of the aquifer will be developed under both the' original and revised design.

Therefore, we f'ind that Applicants' revision of the Ranney Col-lector design will not change the predicted yields, the quality M

1247 073

of water to be produced or the effects on the groundwater table.

Schreiber, fol. Tr. 12,227, pp. 5, 6; Tr. 10,671-683, 10,736; Exhs 164-167.

115. Weber's final criticism of the yield computationc in-volved Applicants' use of permeability from the site of collector -

number one to compute the yield at collector number two.

Tr. 12,382-385. The sole basis for his criticism was his inter-pretation from an aerial photograph of an ancient riverbed with finer grained sediments located between collectors one and two.

Id.; Tr. 12,434-435; 12,442-449, 12,481-485; Exh. 177. However, Weber had never inspected the Ranney Collector site. Tr.

12,441. While no detailed pumpi.g test was conducted at the location of collector two, similar materials were found during drilling at sites one and two. Small rate pumping tests at both sites also produced similar drawdowns, especially when compared to drawdowns at the other two collector sites which had less per-meable aquifers. Exh. 4, App. G, p. 15, Fig. SW-67-5; Tr. 10,705, 14,274-276. The Staff's hydrologist concurred in Applicants' approach. Tr. 12,264-272. The comparability of per-meability at the two sites was later confirmed during a higher rate pumping test at site two which demonstrated a relatively -

lower drawdown than. encountered during the detailed pumping test

)2k

at site one. Tr. 14,276-277. This suggests a higher permeability at site two than at site one. For all of the above reasons, we consider Applicants' predicted yield at collector site two to be reasonable.

116. Water Quality. Applicants determined that the composi- __

tion of water to be produced from the Ranney Collectors will be approximately 90% river water and 10% groundwater. Hence, the water quality should approximate that of the river. Mikels, fol.

Tr. 3041, p. 3; Mikels, fol. Tr. 10,688, pp. 2, 12-13; Exh. 4, App. G, 'p. 18-19. All witnesses agreed that the aquifer is hydraulically well connected with the river. Id.; Weber, fol.

Tr. 12,378, p. 2; Anderson, fol. Tr. 10,735, pp. 12, 13; Schreiber, et al., fol. Tr. 12,226, p. 14; Tr. 12,470-472.

117. Several methods were used to estimate the composition (ratio of river water to groundwater) of the water that the Ranney Collectors will supply. Using the Theis equation, Ap-plicants computed that the percentage of pumped water being di-verted from the river will be 92% after only 30 days of pumping.

Mikels, fol. 10,688, p. 2, Exh. B. The Theis equation has been used widely and successfully by groundwater hydrologists for many years. Id., p 12; Anderson, fol. Tr. 10,735, p. 12; Schreiber, -

et al., follows Tr. 12,226, pp. 12, 13. Applicants further demonstrated the validity of their prediction

• of a 9:1 ratio of river to groundwater based upon water quality (total hardness) data from several operating Ranney Collector installations. _

1247 075

Mikels, fol. Tr. 10,688, pp. 4, 5; Exh. 168. Finally, the Staff's hydrologist, employing the current U.S. Geological Survey method., es timated that the Ranney Collectors should supply water containing 86% to 95% river water. Schreiber, et al., fol.

Tr. 12,226, p. 13. SCANP's witness agreed that the proportion of infiltrated river water to stored groundwater will be high.

Weber, fol. Tr. 12,378, p. 2. Therefore, we conclude that the water to be suppliec' by the Ranney Collectors should be quite close in quality to that of Skagit River water, which is excel-lent. Mikels, fol. Tr. 3041, pp. 5,6; Anderson, fol. Tr. 10,735,

p. 5; FES, fol. Tr. 2913, pp. 2-15, 2-16.

118. System Reliabilitv. The Ranney Collector system is not a safety system. A 30-day supply of water for reactor shutdown will be stored in the ultimate heatsink at the site proper.

Exh. 4, p. 3.4-3; FES, fol. Tr. 2913, p. 3-7. For reasons of economics and not of health, safety or environmental impacts, however, the reliability of the Ranney Collector sys tem has been explored. Tr. 12,512-517.

119. SCANP contended that "the provision made for intake of cooling water is inadequate and temporary." SCANP PSAR Conten-tion 4. As we,previously found, the predicted yield, which is .

reasonable, of the Ranney Collector system will greatly exceed (by about 60%) the plant requirements. Hence, the system will be adequate from the standpoint of yield. Ranney Collectors have 1247 076

been used for over 40 years with minimal problems. Mikels, fol.

Tr. 3041, pp. 3, 4; Tr. 3061. In this regard, we take official notice of the EPA's Develocment Document for Best Technology Available for the Locat,'gn, Design, Construction and Capacity of Cooling Water Intake Structures for Minimizing Adverse Environ-mental Impact, (April. 1976). In that document (p. 139), the EPA noted that radial well intake systems are the "most environ-mentally sound intake system" and "have been in service for over 35 years and have been reliable.*

120. SCANP's witness Weber contended that there was a suf-ficient iron content in both river and groundwater near the col-lector site to permit the formation of enough iron bacteria to clog some of the laterals. Weber, fol. Tr. 12,378, pp. 2, 3.

His contention was based only upon a German reference in a report by Jeffrey Haley. Weber had not read the German reference.

Tr. 12,370-376, 12,429. In addition, Haley was a law student, not an expert. Tr. 10,760-761. His report was not placed in evidence. Weber's comments on iron content were also based in

• See, Applicants' Memorandum in Reply to Intervenor SCANP's Memorancum Re the Application of Section 7(b) of the Wild and Scenic Rivers Act to the Proposed Skagit Nuclear Power Project, dated August 8, 1977, p. 13.

~

1247 077

part on his claim that "a well 200' from the collector site cc/ tained objectionably high iron (p. 10,825 review board)."

Weber, follows Tr. 12,378, p. 3. However, Weber misread the transcript. The well "200' from the collector site" was in fact a well 200' from the Ranney Collector at Marysville, which is far distant from the Skagit site. Tr. 10,825, 12,429-430.

Therefore, Weber had no sound basis for his suggestions that iron bacteria could develop at the proposed collector site.

121. Iron bacteria problems have been encountered at two Ranney Collectors (Skagit County PUD and Anacortes) in the western United States. Mikels, fol. Tr. 10,688, p. 7. The hydrogeologic conditions at these sites (flat riverbed gradient plus sandy and silty aquifer within tidal reach) differ greatly from the conditions at the proposed site more than 22 miles up-stream. Moreovery the iron content (greater than 2.0 ppm) in groundwater at these two downstream sites substantially exceeded the icw dissolved iron content (less than 0.1 ppm) in the water near the proposed site. Id., pp. 3, 5-7, Exh. L; Anderson, fol. Tr. 10,735, pp. 6-7; Schreiber, et al., fol.

Tr. 12,226, pp. 2-6. None of the Ranney Collectors in the -

western United States with iron conter.ts in the range found at .

the proposed site has experienced the growth of iron bacteria.

1247 078

Mikels, fol. Tr. 10,688, p. 7, Exh. D. Therefore, we find that the growth of iron bacteria at the proposed collector site is very unlikely.

122. Should a growth of iron bacteria ever occur, a proven method of treatment is available. A measured volume of chlorine solution would be allowed to percolate by gravity into the laterals and surrounding gravel packs. After standing in the laterals for 16 to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to destroy the bacteria, the solution would be pumped to waste. Mikels, fol. Tr. 10,688,

p. 7; Schreiber, et al., fol. Tr. 12,226, pp. 8, 9. Weber ex-pressed a worry that calorine solution, if ever used, might reach the river. Tr. 12,403-406. However, the solution would be unlikely to move very far via molecular diffusion and would be largely consumed by iron bacteria and organic matter. There will be a time lag in the potential spread of the solution.

When one collector is shut down for treatment, the hydraulic gradient will be away from the river and toward other operating collectors. Mikels, fol. Tr. 10,688, pp. 5-7; Schreiber, et al., fol. Tr. 12,226, p. 8; Tr. 12,229-231, 12,488, 12,501.

For these reasons, we agree with Applicants and Staff that the chlorine solution , if ever needed, would not seep into the -

river. We also note that Weber indicated that any chlorine solution would , if it reached the river, be rapidly mixed and diluted with river water.

1247 079

123. The only other problem which has been experienced with Ranney Collectors is encrustation due to highly mineralized water, i.e., 1,000 ppm total dissolved solids or 600 ppm hard-ness. This problem is not anticipated at the proposed site because both surf ace and groundwater contain less than 100 ppm total dissolved solids and 50 ppm hardness and have a low dis-solved mineral content. Mikels, fol. Tr. 3,041, pp. 5, 6; Mikels, fol. Tr. 10,688, pp. 8, 9; Schreiber, et al., fol.

Tr. 12,226, pp. 1, 2; Tr. 3,062-064.

124. SCANP witness Weber foresaw two additional threats to the Ranney Collector system: (1) removal of part of the system by bank scour during a flood, and '2) development of a new channel which would take the river south of the proposed site.

Weber, fol. Tr. 12,378, p. 5; Tr. 12,394-398. While Weber viewed these possibilities as not having been discussed, he failed to review the portion of the transcript where Applicants expressly addressed these matters. Weber, fol. Tr. 12,378,

p. 6 (His reference No. 15 indicates reading Tr. 10,762 et sea., whereas Applicants' presentation was at Tr. 10,660-668.i 125. During a large flood (e.g., a 100-year flood), some of the riprap alo.ng the collector site could possibly erode. .

Tr. 10,663-664. In the area behind the dike, 7 to 9 feet of ground could be removed. Tr. 10,667, 10,777-779. This amount 1247 080

of scour would not threaten the laterals which are located at depths of at least 36 feet below ground surface. Exh. 4, App.

G, Fig. SW-67-24; Tr. 10,666, 10,790-791. Neither would it be likely to harm the water discharge lines from the collectors since they will be buried at least 8 feet deep, sited no closer .

than 150 feet to the river bank and routed away from the river. Tr. 10,656, 10,667, 10,951-952; Exh. 158. Finally, flooding should pose no threat to the caissons since they are designed to extend about two feet above the 100-year flood level. Tr. 10,656. Ranney Ccliectors, which number over 400 and are usually sited next to a river without riprap protec-tion, have never been lost during a flood. Tr. 14,319-322.

126. The possibility of riverbed movement is also quite remote. The collector site has been protected by riprap for the last 20 years. During this time the river has stayed in its present position. Exh. 4, App . L , pp . L-6, L-7. Appli-cants' plan to maintain, inspect and retain the existing riprap in good condition. Exh. 204; Tr. 10,656. While some of the riprap could be breached during a flood, repair of any damage is quite feasible. Tr. 7799, 10,664-666, 12,437. Finally, the possibility of the river cutting a new channel through the bend south of the collector site has been con- sidered and found to be very remote. Exh. 4, App. L, p. L-7; Tr. 10,948-949, 10,963.

1247 081

127. For the above reasons, we find that the proposed Ranney Collector system will reliably supply an adequate amount of water for the plant. We accordingly reject SCANP's contention.

5. Radiological Releases 128. During routine operation the f acility will emit small amounts of radioactive material. These releases must be con-trolled in accordance with 10 CFR Part 20. In addition, an applicant for a construction permit must identify "the design objectives , and the means to be employed, f or keeping levels of radioactive material ir ef fluents to unrestricted aren; as low as is reasonably achievable." 10 CFR S 50.34a. Appendix I to 10 CFR Part 50 provides numerical guides for design objectives and limiting conditions for operation to meet the "as low as is reasonably achievable" criterion for light-water-cooled nuclear power reactor effluents.

129. In conformance with the requirements of Appendix I, Puget filed the necessary information with the Commission to permit an evaluation of the Proj ect. With respect to Section II.D of Appendix I, Puget has chosen to demonstrate conformance by the method prescribed in the Commission's September 4, 1975 mmendment to the regulations (40 F.R. 40,816), rather than 1247 082

using the cost-benefit approach. The NRC S taf f has perf ormed a detailed analysis of the Applicants' submittals and has con-cluded that the radwaste treatment systems to be installed at the Project will be capable of reducing releases of radioactive materials in liquid and gaseous ef fluents to "as low as is rea-sonable achievable" levels. Since this is in accordance with the requirements of 10 CFR S 50.34a, the radwaste treatment systems are acceptable. Safety Evaluation Report Supplement No. 1 ("SER Supp. 1"), fol. Tr. 14,441, pp. 11-1, 11-7.

130. Radvaste treatment and effluent control systems, plus estimated population doses, were described at a relatively early stage in this proceeding. See, e.g., FES, fol. Tr. 2913, SS 3.5, 5.4; Leech, fol. Tr. 2722; Hewitt, fol. Tr. 2722; Essig, fol. Tr. 2722; Safety Evaluation Report ("SER"), fol.

Tr. 14,441, S 11.0. Based on more recent data at other operat-ing nuclear power reactors , applicable to the Project, and on changes in the Staf f's calculation models, new liquid and gaseous source terms were generated to determine conformance with the requirements of Appendir I. In making its determina-tions, the Staff considered waste flow rates, concentrations of radioactive marerials in the primary system, and equipment -

decontamination factors consistent with those expected over the j}47 083

30-year operating life of the plant for normal operation, in-cluding anticipated operational occurrences. SER Supp. 1, fol.

Tr. 14,441, p. 11-2.

131. A summary of the calculated doses resulting f rom the Staff's evaluation is presented in the tables below, which replace Tables 5.5 and 5.6 of the FES.

1247 084

COMPARISON OF CALCULATED DOSES TO A MAXIMUM INDIVIDUAL FROM SKAGIT NUCLEAR POWER PROJECT OPERATION WITH SECTIONS II.A, II.B, AND II.C OF APPENDIX I TO PART 50 Appendix I Dose Calculated Criterion Design Objective Dose Liquid Effluents Dose to total body 3 mrem per year 0 mrem per year from all pathways per reactor per reactori Dose to any organ 10 mrem per year 0 mrem per year from all pathways per reactor per reactori (adult-bone)

Noble Gas Effluents (at site boundary)

Gamma dose in air 10 mrad per year 4.6 mrad per year per reactor per reactor Beta dose in air 20 mrad per year 5.6 mrad per year per reactor per reactor Dose to total body 5 mrem per year 1.1 mrem per year of an individual per reactor per reactor Dose to skin of 15 mrem per year 3.1 mrem per year an individual per reactor per reactor Radiciodine and Particulates2 (at maximum individual)

Dose to any organ 15 mrem per year 7.6 mrem per year from all pathways per reactor per reactor NOTES:

1 No liquid radioactive releases 2 Includes Carbon-14 and Tritium 1247 085 _

COMPARISON OF CALCULATED DOSES TO A MAXIMUM INDIVIDUAL FROM SKAGIT NUCLEAR POWER PROJECT, UNITS NOS. 1 AND 2 OPERATION WITH GUIDES FOR DESIGN OBJECTIVES PROPOSED BY THE STAFF RM-50-2 Dose Calculated Criterion Design Objectivel Dose Liquid Effluents Dose to total body or 5 mrem per year 0 mrem per year any organ from all per site per site 2 pathways (adult-bone)

Noble Gas Effluents (at site boundary)

Gamma dose in air 10 mrad per year 9.2 mrad per year per site per site Beta dose in air 20 mrad per year 11 mrad per year per site per site Dose to total body 5 mrem per year 2.2 mrem per year of an individual per site per site Dose to skin of 15 mrem per year 6.3 mrem per year an individual per site per site Radiciodine and Particulates3 (at maximum individual)

Doses to any organ 15 mrem per year 15 mrem per year from all pathways per site per site NOTES: - -

1 Applied as a design objective pursuant to Section II.D of Appendix I 2 No liquid radioactive releases 3

Includes Carbon-14 and Tritium 1247 086

As the com, trison presented in the tables indicates, the Staff's calculations indicate conformance with the requirements of Sections II.A, II.B, II.C and II.D of Appendix I. SER Supp.

1, fol.-Tr. 14,441, pp. 11-7 to 9.

132. SCANP has contended, in PSAR Contention 1.c, that "the present plant design will cause radiological contamination of cooling tower blowdown." SCANP PSAR Contentions, p. 1.

While it is possible, under certain meterological conditions, for a portion of the gaseous radioactive wastes released to be entrained in the cooling tower blowdown and subsequently dis-charged to the Skagit River, the record indicates that re-sulting doses will be extremely small and that exposure through this pathway is insignificant. Tosetti, fol. Tr. 2629; FES, fol. Tr. 2913, S 11.18.5.

133. SCANP has also alleged, in Contention J.9, that There is no discussion of the statistical probability of genetic, or somatic or other forms of injury to life forms which will result from normal, and acci-dental, chemical and radiological releases, and of the nature of such injury.

The Staff has, however, included an estimate of genetic and somatic risks in the FES and offered additional testimony on the subject at, the hearing. Milsted, et al., fol. i'r. 2983; .

FES, fol. Tr. 2913, S 11.17; Tr. 2979-981.

134. The Staff concluded, based on an upper bound estimate, that the range of calculated genetic effects to the U.S. popu-lation under normal operating conditions is about 0.93 to 22 1247 087

ef f ects based on a 30-year period of operation. The Staff cal-culated the range of somatic effects for non-occupational expo-sure to plant ef fluents under normal operating conditions to be 0.17 to 0.86 deaths. These results, for both genetic and somatic ef fects, are only a tiny f raction of one percent of the effects of doses caused by natural background. Milsted, et al., fol. Tr. 2983, p. 2; Tr. 2979-980, 2995-998, 3007-014.

135. With respect to genetic and somatic effects from acci-dental radiological releases, the Staff estimated effects for the highest population dose listed in FES Table 7.2, " Summary of Radiological Consequences of Postulated Accidents," and con-cluded that there would be 0.0001 to 0.0019 genetic effects on the first generation following such a release, and 0.0015 to 0.0075 deaths f rom somatic effects. The estimated effects for other accidents listed in Table 7.2 would be proportional, based on the dose delivered. Milsted, et al., fol. Tr. 2983,

p. 3; Tr. 2980.

136. With regard to the genetic and somatic ef fects f rom normal and accidental chemical releases f rom the f acility, the Staff has fully analyzed such effects in the FES and testimony presented at the hearing. Their conclusion, with which we con- -

cur (see the discussion of Cooling Tower Operation and Project Discharge, above) , was that the effects of chemical discharges on terrestrial and aquatic biota will be very slight. Milsted, et al., fol. Tr. 2982, p. 4; Tr. 2981-982.

1247 088

137. To summarize, the Board finds that the as low as is reasonably achievable requirementa of the Commission's regula-tions have been met, and that the matters raised in SCANP Con-tention J.9 and PSAR Contention 1.c have been adequately con-sidered and are acceptable.

D. Effects of Postulated Accidents 138. During the proceeding, intervenor SCANP questioned the adequacy of consideration given by the Staff to the environ-mental consequences of possible accidents. In particular, SCANP alleges in Contention J.7 that the environmental state-ment for the Project " entirely ignores the likelihood and con-sequences of accidents of any kind," and that It is unreasonable . . . to ignore the consequences of -

accidents for purposes of environmental and economic impact evaluation since the consequences of accidents are evaluated with respect to other aspects of the licensing process, including the safety analysis.

SCANP Contentions, fol. Tr. 67, p. 9.

1247 089

139. This contention, however, is without foundation in fact. Chapter 7 of the FES evaluates the environmental impact of postulated plant and transportation accidents involving radioactive materials. The Staff has concluded that the environmental risk due to postulated radiological accidents is small. Grimes, fol. Tr. 2895, p. 3; FES, fol. Tr. 2913, SS 7.1 and 7.2. The Board agrees.

1247 090 e

• m 140. During the hearings, it became clear that SCANP desired that Class 9 accidents

• also be considered. In a mo-tion dated December 3, 1975, SCANP sought to expand contention J.7 to encompass Class 9 accidents. After responses by Appli-cants and the Staff and oral argument, the motion was denied.

Tr. 4729-745, 4854-855. Later, on April 27, 1979, SCANP served a " Motion for Order Dirs; ting Review of Staff Position Regarding Pelevance of Class 9 Accidents and Renewing Motion to Consider Class 9 Accider.ts." By order dated July 11, 1979, the Board again declined to require consideration of Class 9 acci-dents and denied the motion. We now reaffirm our earlier decisions and find that, absent a showing -- not made here --

that special circumstances render a Class 9 accident credible

• The phrase " Class 9 accident" is a term of art stemming from a 1971 Commission proposal to adopt standard assumptions concerning nuclear power plant accidents for use in preparing environmental impact statements. Proposed Annex to Appendix D to 10 CFR Part 50, 36 F.R. 22,851 (December 1,1971) ; 1 Nuclear Regulation Reporter (CCH) 1 7469. See also, 39 F.R. 26,279 (July 18, 1974). The accidents groupea in Class 9 are of the most severe kind, involving occurrences such as " breach of containment" and " core-melt" accidents. Although the conse-quences of a Class 9 accident might be extremely severe, the likelihood of one occurring is deemed to be so improbable that a nuclear power plant need not be designed with protective sys-tems or safety features to guard against it. Offshore Power Systems (Floating Nuclear Plants), ALAB-489, 8 NRC 194, 209 (1978), cert. accepted by the Comm'n, Order, December 8,1978.

1247 091

or more likely at the reactors in question than at power reactors generally, the conside. :ation of such accidents is not required and has been properly excluded.*

141. In sum, the Board concludes that a sufficient analysis of the environmental consequences of radiological accidents has been performed, and that the environmental risks associated with such accidents are acceptably low.

• In this same general connection, on January 19, 1979 the Commission issued a statement of policy concerning the Reactor Safety Study (WASH-14 0 0 ) . The statement provided. inter alia, that the absclute values of the risks presented in tne Reactor Safety Study shall not be used uncritically in the regulatory process, and that any such use in the past will be corrected as appropriate. The NRC Staff has stated that, in evaluating the environmental risks associated with accidents related to the Project, there has been no reliance on WASH-1400. See Letter from Richard L. Black to the Board, and enclosures, Xpril 4, 1979; Tr. 2071. Accordingly, no corrective action is required.

1247 092 E. Alternative Sites 142. The subject of alternative sites was explored inten-sively in this proceeding. > articular attention has been directed to Applicants' site selection process, to the indepen-dence of the Staf f's review of alternative sites, and to de-tailed comparisons by Applicants and Staff of a number of can-didate sites.

143. Part of the extensive record on this subject was developed in response to the following contentions by SCANP:

C. The studies conducted by Applicant in eval-uating alternative sites for the proposed power plant were insufficient. More suit-able sites, sites such as Hanford, exist within the State of Washington and these were not fully studied by Applicant. The comparative analysis of the alternative sites that were studied is biased and insufficient.

J.l. The DEIS does not represent the independent work of the NRC.

b. The preparers of the DEIS failed to make their own independent evaluation and in-vestigation with regard to: alternative

, sites, . . . -

J.12. The discussion of alternatives in the DEIS is completely inadequate.

~

l247 093 -

a. The preparers of the DEIS did no independent evaluation of alternative sites and they included insufficient information about alternative sites. All information that is included about alternative sites was sup-plied by the Applicant.

b. There is absolutely no discussion of --

Hanford, which is an obvious and readily available alternative site.

c. The tabular comparison of three sites is grossly inadequate and pre-ordains the out-come. The comparison of sites does not give any weight to the unique scenic and recrea-tional values, which have been nationally recognized, of the Skagit River and its set-ting. Furthermore, the seismicity values assigned to the Skagit site are clearly er-roneous. Even using the tabular comparison presented in the DEIS, if proper values were utilized, the Skagit site would turn out to be the least desirable.

144. Applicants' Site Selection Process. The lead Appli-cant is Puget Sound Power & Light Company (Puget), which will own 40% of the electrical output of the Project. As the originator and sponsor of the project, Puget is responsible for its design, construction and operation. Jacobsen, et al., fol.

Tr. 6012, p. 3; Exh. 175, pp. 2, 12; FES, fol. Tr. 2913, p. 1-1.

145. Puget selected the Skagit site based upon a number of thermal power plant siting studies. The earliest studies, in 1966, covered Puget's service territory, which is almost -

entirely within Western Washington. These studies, which con-centrated on once-through cooling sites, found the Cherry Point site to be the best. Cherry Point is located on the shoreline 6

1247 094

of the Strait of Georgia, about 40 miles northwest of the Skagit site. Jacobsen, fol. Tr. 3687, pp. 3, 2; Leech, et al.,

fol. Tr. 12,542, op. 6, 7; Tr. 5881.

146. Despite the viability of Cherry Point site, Puget anticipated problems in developing it. These problems included difficulties in property acquisition, doubts about the licens-ability of a once-through cooling plant, and potential safety hazards inherent in the operation of adjacent petroleum in-dustry facilities. For these reasons, Puget continued to look elsewhere for a site. Jacobsen, fol. Tr. 4940; Tr. 3713.

147. In 1970, Puget and three other western Washington utilities commissioned a comprehensive study of thermal power plant sites in western Washington and the Hanford area of central Washington. The study identified 117 potential site areas. Based on this study, Puget concluded that the Skagit, Nooksack and Cowlitz River regions in western Washington were among the most promising regions and warranted further study.

Jacobsen, fol. Tr. 3687, pp. 2, 3; Exh. 4, S 9.2, App. 0; Exh. 46.

148. A further study was conducted in 1972. Of the pight sites identified within the three watersheds, the Skagit site -

was found to be the most promising. The most significant fac-tors underlying this conclusion were the rock foundation, the location of the site well above the floodplain, the natural 1247 095

screening provided by the terrain, the availability of an ample supply of cooling water, the f avorable location within the northwest power grid, and *he proximity to existing transmis-sion lines, rail lines and highways. A detailed geotechnical evaluation was then made of the Skagit site. This confirmed the suitability of the Skagit site and, as a result, Puget publicly announced the Project in January 1973. Jacobsen, fol.

Tr. 3687, pp. 3, 4; Leech, et al., fol. Tr. 12,542, p. 12; Exh. 47.

149. A subsequent siting study was performed in 1973 for Puget Power as a result of delay in obtaining zoning approval from Skagit County. This study identified the most promising sites in the Cowlitz and Nooksack River areas, which were, respectively, the Ryderwood and Goshen sites. A detailed eval-uation was.then made of Skagit in comparison with Goshen and Ryderwood. Jacobsen, fol. Tr. 3687, p. 4; Leech, et al., fol.

Tr. 12,542, pp. 12, 13; Exh. 4, S 9.2.

150. Staff Review of Alternative Sites. The Staff care-fully evaluated Applicants' site selection process. Its objec-tivi as to determine first, whether the final list of candi

• date sites were among the best that could reasonably be found -

in the region and second, whether any sites obviously superior to the Skagit site are likely to be found withic the region of interest. Leech, et al., fol. Tr. 4124; Leech, et al., fol.

1247 096

Tr. 12,542, pp. 1-16; FES, fol. Tr. 2913, S 9.2; Tr. 13,027, 13,123.

151. Tn performing its review, the Staff often went beyond the studies performed for Applicants. Staff witness Stull redid the comparative analysis of 117 sites, which had been identified in the 1970 siting study for Puget. Her purpose was to determine whether any of these sites were preferable to Skagit. Stull visited all of the resource areas in which the 117 sites were located, physically setting foot on about 40 sites. She also gathered and relied upon information not in-cluded in the 1970 report. Tr. 13,173-180. Further evidence of the Staff's independent review of Applicants' site selection is its evaluation of the geotechnical aspects of 33 sites that had been identified in Puget's siting studi's. These sites were compared to the Skagit site based on econnaisance level data. Exh. 181; Tr. 12,834-887. The Staff also evaluated hydrologic engiraering factors (e.g., adequacy of water supply) for most of these same sites. Exh. 192.

152. The second phase of the Staf f 's review involved the detailed comparison by the Staff of Skagit with five alterna-tive sites. S.everal environmental and economic factors were -

utilized. The five alternative sites were Goshen, Ryderwood, Cherry Point, Pebble Springs and Hanford. Dvorak, et al., fol.

1247 097

Tr. 7336; Leech, et al., fol. Tr. 12,542, pp. 17 et seg. The Staff's comparisons are addressed below.

153. In performing its review, the Staff drew from several sources of information. Staff witnesses, including those from Argonne National Laboratory, inspected the six candidate sites that were compared in detail as well as many other resource areas and sites. Dvorak, et al., fol. Tr. 7336, p. 1; Leech, et al, fol. Tr. 12,542, pp. 13, 61; Tr. 7,347-350, 12,666-667, 13,175. They reviewed pertinent literature and obtained infor-mation f rom state and local agencies. Leech, et al., fol.

Tr. 4124, p. 3; Laech, et al., fol. Tr. 12,542, pp. 36-40 and references at end; Tr. 7351-354, 7,367, 12,668-671, 13,179.

They looked at siting studies done for other utilities and the State of Oregon. Tr. 13,125. They utilized the expertise the Bonneville Power Administration on the transmission system and transmission costs. Gens, fol. Tr. 5222; Leech, et al., fol.

Tr. 12,542, App. B; Tr. 7468-471. Information from ERs, PSARS, NRC environmental impact statements, and NPDES permits for other dockets was used. Leech, et al., fol. Tr. 12,542, pp.

17, 38, 39, 44, 53, 61; Tr. 7395. The Staff also evaluated data supplied by Applicants, and requested further data from Applicants. Dvorak, et al., fol. Tr. 7336, p. 1; Leech, et al., fol. Tr. 12,542, p. 61; Exh. 116; Tr. 7,347, '2,668, 13,028, 13,122. Many man-months of effort were invested by the 1247 098

Staf f in its review of the information on alternative sites.

Tr. 7624, 7629. In the Staff's view, the consideration c'.

alternative sites in this proceeding was unique and more detailed than on other proposed nuclear projects. Tr. 7347, 7626.

154. The Staff's evaluation of alternative sites has, with-out a doubt, been thorough and detailed. They have gathered and evaluated information from a wide r.ange of sources. Their assessment of alternative sites, both in the FES and subsequent studies, has been independent. Therefore: we find no basis for the SCANP's contentions J.l.b and J.12.a.

155. Region of Interest. The Staff concluded that western Washington was the reasonable region of interest for considera-tion of alternative sites for the Skagit Project. Tr. 12,650, 13,120. Several factors support this conclusion. First, western Washington is deficient in generating rescurces. Ap-proximately 75% of the regional load is west of the Cascade 3; however , most of the generation is located east of the Cas-cades. In western Washington, the load is more than twice as large as the generation. This serious imbalance is likely to continue until. thermal power plants are located west of the -

Cascades. Knight, fol. Tr. 6013, pp. 2, 3; Gens, fol.

Tr. 5222, pp. 2, 5, 6; Leech, et al., fol. Tr. 12,542, pp. 4, 5 and App. B, pp. 2, 3.

156. Second, the western Washington area depends upon a few cross-mountain transmission lines for its supply of electri-city. These long lines are vulnerable to various disasters such as lightning, avalanches, and ice storms. Knight, fol.

Tr. 3687, pp. 5, 6; Knight, fol. Tr. 6018, pp. 1-4; Tr. 12,580-585. On several occasions, western Washington has been close to a blackout due to failures in cross-mountain transmission capability. Knight, supra. Therefore, reli-ability of the regional transmission system would be enhanced by locating new generating plants near load centers, such as in western Washington, thus avoiding long transmission lines.

Gens, fol. Tr. 5222, p. 3; Tr. 12,584, 12,746-747.

157. Third, locating new generation close to the western Washington load center minimizes the transmission line losses.

Such losses would be quite significant for an alternative site east of the Cascades. For example, the loss would be about 100 megawatts during the heavy load period in the winter. The average incremental cost of transmission losses for sites loca-ted east versus west of the Cascades would be 59,000,000 to

$23,000,000 per year, using 1979 oil prices. Gens, fol.

Tr. 5222, p. 13; Knight, fol. Tr. 6018, p. 6; Leech, et al., -

fol. Tr. 12,542, App. B, pp. 18, 20. The cost penalty over the

)2k

lif e of a project could run between S234 million and $593 million in present value dollars. Leech, et al., fol.

Tr. 12,542, p. 97 (corrected).

158. Finally, siting of the plant west of the Cascades postpones the need for constructing new transmission capacity across the Cascades. If the two Skagit units were relocated east of the moun'.ains , the capacity of the cross-mountain transmission system that is presently existing or under con-struction would be partially filled. This would accelerate the need for new cross-mountain capacity. Leech, et al., fol.

Tr. 12,542, pp. 5, 6; Tr. 12,587-589. Cross-mountain lines are extremely expensive to build, presently costing about $600,000 per mile. Tr. 5289. A new line could cost between $92 and S115 million. Knight, fol. Tr. 6018, pp. 5, 6; Tr. 6,014, 6,183.

159. As previously described, Puget Power's siting studies concentrated primarily on western Washington. Within this area are a great variety of land and water resource areas which are of sufficient size to contain a large number of alternative candidate sites. From the standpoint of the regional electric power system,. western Washington is the appropriate region of -

interest. Leech, et al., fol. Tr. 12,542, pp. 5, 6, 10. In this regard, we note that the state of Washington siting council (CFSEC), in its consideration of alternative sites for 1247 101

the Skagit Project, concluded that "All factors considered, it is desirable and in the public interest to locate additional generation west of the Cascade Mountains." Exh. 84, p. 66.

Their conclusion, which is entitled to substantial weight, was based on the factors of system reliability and transmission losses. Id. Hence, we accept the Staff's designation of western Washington as the region of _ interest for reasonable alternative sites to Skagit.

160. Within western Washington, Applicants identified three candidate sites: Skagit, Goshen (on the Nooksack River, about 6 miles northeast of Bellingham in northwest Washington), and Ryderwood ( on the Cowlit: River in southwest Washington).

FES, fol. Tr. 2913, p. 9-6; Exh. 4, S 9.2, App. O. At the request of the Board, the Cherry Point site (on the coastline about 12 miles northwest of Bellingham) was evaluated by Appli-cants and the Staff as an alternative site for the Skagit units. Jacobsen, fol. Tr. 4940 and fol. Tr. 5869; Dvorak, et al., fol. Tr. 7336. These four sites adequately represent the range of available environmental alternatives (three different watersheds plus one marine site) and are among the best sites that can be f ound west of the Cascades. Leech, et al., fol. -

Tr. 12,542, pp. 13-15.

161. Applicants and Staff also evaluated sites east of the Cascades at Hanford (on the Columbia River in south central 1247 102

Washington) and Pebble Springs (on the Columbia River in north central Oregon). Pebble Springs was considered at the Board's r eque s t . Applicants studied Hanford in their 1970 siting study. Exh. 46. The Staff assessed the Hanford site early in this proceeding in response to SCANP's contentions. Leech, et al., fol. Tr. 4124, pp. 4, 5. Furthermore, specifically in response to the Appeal Board's decision in the Pilgrim pro-ceeding (ALAB-479), the Staff reexamined not only Applicants' site selection process but also the Hanford And Pebble Springs sites. Leech, et al., fol. Tr. 12,542. Therefore, the Skagit site plus five alternative sites, some of which are outside the region of interest, have been compared in extensive detail.

162. Comparison of Alternative Candidate Sites. The five sites to be compared with the Skagit site are Cherry Point, Goshen, Ryderwood, Pebble Springs and Hanford. The comparisons of each site with Skagit are reviewed below.

163. a. Skagit versus Cherry Point. Because Cherry Point is adjacent to salt water, the Staff analyzed it in terms of both fresh water (Nooksack River) and salt water cooling systems. Skagit is environmentally preferable to Cherry Point on several fac. tors: (1) water supply (if fresh water were to -

be used at Cherry Point); (2) land use; (3) length of new transmission lines; (4) aquatic impacts (if once-through salt water cooling or f resh water cooling towers were used at Cherr y 1247 103

Point); and (5) terrestrial impacts (if cooling towers were used at Cherry Point). Cherry Point's only environmental advantage , according to the Staf f, would be an aesthetic one, but only if once-through cooling were used. Dvorak, et al.,

fol. Tr. 7336, pp. 9-17, Table 1; Jacobsen, fol. Tr. 5869.

Cherry Point also ranks lower than Skagit on several non-environmental siting factors, such as geology and foundations, population density, seismicity, nearby industrial facilities, and hydrology. Id.; Leech, et al., fol. Tr. 12,542, pp. 25-27, 34, 35. Hence, we agree with the Staff's conclusion that Cherry Point with any type of cooling ranks lower than Skagit by a considerable margin.

164. b. Skagit vers us Goshen. With respect to environ-mental factors, Geshen is less desirable than Skagit with respect to (1) water supply (the Nooksack is a much smaller river than the Skagit), (2) site access, (3) land use, (4) aquatic impacts , and (5) terrestrial impacts. The Staff ranked Goshen more f avorab'.y en traffic congestion and community im-pacts during construction. On aesthetics, the Staff ranked Goshen higher while Applicants rated Skagit higher. Dvorak, et al., fol. Tr. 7336, pp. 9-17, Table 1; Jacobsen, fol. Tr. 5869, -

Table 1; Exh. 4, App. O. In sum, the Goshen site does not offer environmental preference over the Skagit site. We fur-ther note that with respect to other siting factors, Goshen 1247 104

ranks below Skagit, particularly as to demography, geology, seismicity, and labor supply. Id.; Leech, et al., fol.

Tr. 12,542, pp. 20-23, 32. EFSEC found that the Skagit site was pref erable to the Goshen site. Exh. 84, p. 67. We agree.

165. c. Skagit versus Ryderwood. Of the alternative sites in western Washington, Ryderwood received the highest rating next to Skagit. Dvorak, et al., fol. Tr. 7336, p. 16.

Ryderwood was less desirable than Skagit on several environ-mental factors: (1) water supply; (2) site access; (3) labor supply; and (4) socioeconomic impacts. The Staff rated Ryder-wood more highly than Skagit on aesthetics, while Applicants rated them evenly. Id., pp. 9-17, Table 1 Jacobsen, fol.

Tr. 5869, Table 1; Exh. 4, App. O,. Hence, we find the Skagit site to be environmentally preferable tc the Ryderwood site.

J.

As to other siting factors, Skagit received higher ratings on geology and foundations, meteorology, and hydrology and a lower _, g o:.

rating on the f actor of nearby industrial, transportation and ,

jp'.

military facilities. Id., Leech, et al., fol. Tr. 12,542, pp. 23-25, 32.

S[

Our conclusion on the preferability of Skagit

[

over Ryderwood agrees with EFSEC's finding on this subject. '

Exh. 84, p. 67..

166. The Goshen and Ryderwood sites are suitable sites for -

a nuclear power plant. Cherry Point, although less desirable, ".

m. '1 is also a suitable site, provided once-through cooling is not 1247 10; s

utilized. No sites obviously superior to these as tc Skagit are likely to be available within the region of interest, western Washington. Dvorak, et al., fol. Tr. 7336, pp. 16, 17; Leech, et al., fol. Tr. 12,542, p. 15. The Skagit site, how-ever, is a superior site to the Goshen, Ryderwood, and Cherry Point sites from the standpoint of both environmental and non-environmental factors. SCANP alleged, in contention J 12.c.

and partially in Contention C, that the comparison between the Skagit, Goshen and Ryderwood sites was inadequate. Admittedly, sites cannot be precisely compared because selecting the siting f actors and the weight for each f actor, and rating such f ac-tors at each site are somewhat subjective processes. See, e.g., Jacobsen, et al . , f ol . Tr . 6012, p. 4 ; FES, fol.

Tr. 2913, p. 9-5. Despite this element of uncertainty, the detailed comparisons of the three sites by both Applicants and the Staff have been more than sufficient to support their independent conclusions that Skagit is the best choice of the three sites. We have previously agreed with this conclusion.

Hence, we reject SCANP's position in Contentions C and J.12.c that Applicants' site selection studies and methodology were insufficient or biased, or produced an erroneous result. -

167. SCANP also alleged that no attention had been given to scenic and recreational values of the Skagit River and that the 1247 106

seismicity value for Skagit was clearly erroneous. SCANP Con-tention J.12.c. The Staff has clearly evaluated the impact of the Skagit Project on scenic and recreational values of the Skagit River and weighed that consideration into its compcrison of sites. Dvorak, et al., fol. Tr. 7336, p. 11; FES Final Supp., fol. Tr. 7767. The seismicity of not only tne Shagit site but also the alternative candidate sites has also been evaluated in reasonable depth by the Staff. Leech, et al.,

fol. Tr. 12,542, pp. 17-40. The Staff found that the Pebble Springs and Hanford sites had an advantage over the Skagit site in terms of design ground motion, quantified the resulting cost impact, and weighed the cost disadvantage at Skagit into its economic com- parison of those sites. Id., pp. 33,102. While the Board has not determined an appropriate seismicity value for the Skagit site, we do find that the Staff's evaluation of seismicity at Skagit relative to that at other sites has been reasonable. For the above reasons, we reject SCANP Contention J.12.c.

168. d. Skagit versus either Pebble Springs or Hanford.

The Pebble Springs and Hanford sites, east of the Cascades, have many simi,larities; hence, there is no need to compare each -

separately with Skagit. Both were compared with Skagit based upon potential aquatic, terrestrial and socioeconomic ef fects at each site. The evaluation covered numerous aspects of the

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}f] )Q)

aquatic ecology and resources and terrestrial ecology. On these important environmental subjects, Pebble Springs and Hanford are comparable to Skagit. Leech, et al., fol.

Tr. 12,542, pp. 61-92.

169. Pebble Springs and Hanford, however, offer some advan-tages on some socioeconomic matters. Both have extremely low population densities and hence rank among the best sites in the nation in terms of remote siting. Id., p. 77. While Skagit has a relatively higher population density, it still enjoys a low population density based on the Reg. Guide 4.7 guideline of 500 people per square mile. Myers, et al., fol. Tr. 728, pp. 4-5; SSR, fol. Tr. 1888, p. 2; Exh. 183; Tr. 13,862-63.

170. A second socioeconomic factor on which the Staff thought that Hanf ord and Pebble Springs might be pref erable is compatibility with land use. The Staff's reasoning appears to be that there is some controversy on the future development of the Skagit Valley yet no controversy at the other sites.

Leech, et al., fol. Tr. 12,542, pp. 79-82. Such reasoning seems speculative. We also note that the Staff has found that construction and operation of the Skagit Project will have insignificant , impact on land use. FES, fol. Tr. 2913, pp. 1, .

4-5, 5-1. Similar conclusions have been reached by Skagit County and the Department of Agriculture. Leech, et al., fol.

Tr. 12,542, pp. 80-81. Although Hanford and Pebble Springs

-101-1247 108

appear optimum in terms of compatibility with surrounding land use, Skagit suff ers no infirmity on this f actor.

171. The Staff also ranked Skagit lower than Hanford or Pebble Springs because there is a wider interest in cultural resources in the Skagit valley and the aesthetic impact of cooling towers at Skagit would be greater. Leech, et al., fol.

Tr. 12,542, pp. 86-89. Both of these ef fects are by their nature subjective and, hence, conjectural. Moreover, construc-tion activities will have no adverse effects on historical or archaeological resources in the Skagit Valley. Exh. 4, S 2.3; FES, fol. Tr. 2913, p. 2-11.

172. The Board believes that the foregoing socioeconomic advantages of Hanford and Pebble Springs over Skagit should be given little weight, particularly relative to comparisons of potential biological impacts at these sites. These socio-economic impacts pose no potential threat of measurable damage to the environment. Furthermore, such effects are by their nature speculative. While socioeconomic considerations point to small diff erences between Skagit and the other two sites, they do not disclose any environmental infirmities about the Skagit Project. ,

We conclude that, based solely on environ- .

mental factors, the Skagit, Pebble Springs and Hanford sites are all comparable, with none being superior to any other one.

-102-1247 109

173. At the Board's reques t , the Staff evaluated the cost impacts of moving the Skagit units to either Pebble Springs or Hanford. Leech, et al., fol. Tr. 12,542, pp.93-110. Both sites were found to be measurably more expensive than skagit.

Id., p. 110. The cost impacts include capital, transmission and replacement power costs.

174. The Staf f concluded that moving the Skagit units would increase capital costs, except in two respects. Id., p. 100.

First, they calculated that $63 million would be saved by changing the seismic design level (0.3 5g at Skagit) to 0.25g at either Pebble Springs or Hanford. Id., p. 102. They assumed that such costs were recoverable should the Project be moved to these sites. The S63 million estimate , however , was based in part on f actors other than additional materials and equipment.

Ferguson, fol. Tr. 5917, Table 1. Hence, some costs may not be fully recoverable, as the Staff assumed.

175. The other f actor, on which the Staf f thoaght capital costs might decrease, is escalation. Leech, et al., fol.

Tr. 12,542; p. 103. With the 3-year delay to be expected if Skagit were moved, the construction costs would escalate by over $900 million.

, The Staff excluded this cost and instead .

measured the cost of delay by the cost of replacement power.

The Staff then proceeded, however , to subtract a f actor said to

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)247 \\D

represent the decrease in the present worth of the capital investment f or a project dela'fed three years. Its estimated "se"ings" of $265 million appear entirely theoretical in that neithe- the Applicants nor their ratepayers would actually have the capital which they could invest (at a 10% rate of return) ~

elsewhere during a 3-year delay in construction.

Tr. 12,600-604. The Staff's estimated " savings" is based on its assumptions of a 7% rate of inflation and a 10% rate for the opportunity cost of money in 1987 to 1990. Bota rates are obviously speculative. Were the rates reversed (i.e., 10%

inflation and 7% opportunity cost), the " savings" would swing to a S265 million cost under the Staff's analysis. Since we have substantial doubts as to the soundness cf the methodology and the input assumptions, we place little weight on the Staff's estimated $265 million savings.

176. The transmission costs that would be impacted by mov-ing the Skagit units involve new transmission lines, wheeling costs and transmission losses. The transmission losses would range between 57 MW and 144 MW and would add an estimated $234 million to $593 million (both are present value) to the costs over the lif e of the plants.

Leech, et al . , f ol . Tr . 12,542, pp. 96, 97 (corrected). The wheeling costs at Hanford or Pebble Springs would exceed those at Skagit by about $140 mil-lion (present value). Only a small part of this differential

-104-1247 III

would be offset by the dif ferential for the capital cost of transmission interferes with the BPA system. Id., p. 95.

177. ?!;9 final cost increase attributable to moving the Skagit units is the cost of replacement power during an antici-pated three-year delay in operatica dates for the Skagit units. The energy to be replaced would amount to 5,796 megawatt-years , assuming critical water conditions or 3,320 megawatt-ytars, assuming average water conditions. Knight, fol. Tr. 14,329, pp. 1-3; Leech, et al., fol. Tr. 12,542,

p. 107; Tr. 12,606-610. Replacement of this energy would come from additional oil-fired generation located either in the no. n<est or southwest. A minimum of 84 million barrels of oil would be cons umed , at a tremendous cost to society. The cost of replacement power to Applicants' ratepayers would run from

$2,819 million to $3,300 million. Knight, fol. Tr. 14,329, pp. 4-6.

178. The hypothetical movement of the Skagit units to either the Pebble Springs or Hanford sites would have a drastic cost impact totaling several billion dollars on both society and Applicants' ratepayers. Frem either an economic standpoint or a combined environmental and economic standpoint, the Skefit site is obviously superior to sites east of the Cascades, in-cluding the Pebble Springs and Hanford sites.

-105-1247 112

179. In its Contentions C and J.12.b, SCANP claimed that Hanford was a more suitable site and had not been discussed in the DEIS. We find the former claim to be erroneous. Skagit is preferable to Hanford for the reasons discussed previously.

Second, while the FES may not have explicitly addressed the Han~ord site, subsequently, the Staff thoroughly studied it as an altec:.ative. Hence, we find tuese contentions by SCANP to be without merit.

F. Alternative Energy Sources 180. [This paragraph is reserved. Findings will be filed after completion of hearings on this subject.]

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G. Need for Power 181. [This paragraph is reserved. Extensive findings have __

previously been filed on this subject. Following resolution of the pending motion to reopen, findings will be filed on this subject.]

H. Cost-Benefit Analysis 182. [This paragraph is reserved. Findings will be filed after completion of hearings on this subject.]

e

• 1247 114

-107-

i I. Federal Water Polution Control Act 183. In accordance with Section 402 of the Federal Water _.

Pollution Control Act Amendments of 1972 (FWPCA), Pub. L.

No.92-500, 86 Stat. 816, and the Second Memorandum of Under-

. standing between the NRC and EPA, 40 F.R. 60,115, Applicants have received a final NPDES permit for the Skagit Project. In addition, Applicants have obtained the State of Washington certification required by Section 401 of the FWPCA. Both the permit and certification have been admitted into evidence and form part of the record now before the Board. Exhs 57, 83, 84, 85; Tr. 4907-910; NFP 1755-766. Accordingly, we find that the provisions of the FWPCA applicable to this proceeding have been satisfied. See generally, Public Service Company of Oklahoma (Black Fox Station, Units 1 and 2) , LBP-78-26 8 NRC 102, 121-26 (Jul. 24, 1978); Tennessee valley Au,thority (Yellow Creek Nuclear Plant, Units 1 and 2), LBP-78-7 7 NRC 215, 229-36 (Feb.

3, 1978), aff'd, ALAB-515 8 NRC 702 (Dec. 27, 1978).

~

\247 \\5 _

-108-

J. Wild and Scenic Rivers Act 184. Certain aspects of the Project lie along or downstream ..

of that portion of the Skagit River which forms a part of the National Wild and Scenic Rivers System. FES Final Supp., fol.

Tr. 7767; National Parks and Recreation Act of 1978 S 703, Pub.

L.95-625, Pub. L. 9 5-6 25, 16 U. S.C . S 1274 (a) (18) . This matter has been reviewed extensively, both by this Board -- which con-sidered the various impacts of the Project on the Skagit River in detail -- and by the Secretary of Agriculture. See, e.g., FES Final Supp., fol. Tr. 7767; Tr. 7762-922, 7925-958, 7961-8099, 8121-129, 8135-193, 8206-324, 10,635-717, 10,729-964; Exh. 203.

185. On April 11, 1978 the Department of Agriculture issued its determination, pursuant to Section 7 of the Wild and Scenic Rivers Act, as to the possible effects of the Project on the Skagit River. Exh. 203. The determination, which included con-sideration of environmental impacts as examined in this proceed-ing , concluded that the Commission could not license the Project so long as the Skagit River remained a " study" river under the Wild and Sceni'c Rivers Act. Id., p. 10. However, it was also determined that "[i]f the Congress adopts the President's recom-mendation to designate the river above the Sedro Woolley pipeline crossing as a component of the Wild and Scenic Rivers System,"

-109-1247 i16

Board is bound to accept it. As for the question of fact, the environmental impact statement -- particularly the FES Final Supp. -- fully considered the status of the River and provided information used by the Department of Agriculture in making its determination. The Board finds that the consideration of envi-ronmental matters, as revealed by the record of the proceeding, is suf ficient under NEPA. Accordingly, we reject Contention I as being without merit.

K. Floodplain Management 188. [This paragraph is reserved. Under the present sched-ule, Applicants will file its findings on this subject on October 8, 1979.]

1247 117

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III. SITE SUITABILITY A. Geography and Demography -

189. [This paragraph is reserved. Findings will be filed af ter completion of hearings on the subject of evacuation plan-ning, since a portion of that will deal with population esti-mates.]

B. Nearby Industrial, Military and Transportation Facilities 190. The facility can be designed to adequately protect the health and safety of the public from hazards associated with nearby industrial, military and transportation facilities.

Military facilities and airports ptesent no safety ht:ard due to their distance from the site. No ha .us materials are transported by rail or water within five miles of the reac-tors. The major transportation hazards are associated with transport of high explosives of petroleum products past the site on SR-20.' These hazara; have been evaluated. We conclude that the f acility can be designed to withstand the consequences of accidents along SR-20. Myers, fol. Tr. 728, pp. 6-7; Report 2-1247 118

of the NRC Jtaff on Site Suitability ("SSR"), fol. Tr. 1888, pp. 4-5; PSAR, S 2.2; SER fol. Tr. 14,441, S 2.2.

191. The nearest pipelines are two natural gas pipelines about five miles west of the site. The impact of accidental releases of gas from the simultaneous rupture of both pipelines has been analyzed. The analysis shows that such rupture poses no hazard to the f acility and need not be considered in design of the Project. Myers, fol. Tr. 728, p. 7; SSR, fol. Tr. 1888, pp. 4-6; PSAR, pp. 2.2-3, 2.2-7 to 8, 2.2-10a to 10c; SER, fol.

Tr. 14,441, S 2.2.

192. The nearest industrial plants and petroleum storage facilities are about five miles west-southwest of the site.

The hazard from explosion or fire at these facilities is clearly less than similar potential hazards at the site or along SR-20 adjacent to the site. Myers, fol. Tr. 728, p. 7; SSR, fol. Tr. 1888, p. 5; PSAR, pp. 2.2-1 to 2a, 2.2-3 to 5; SER, fol. Tr. 14,441, S 2.2.

193. The potential fire hazard has also been evaluated.

With respect to a forest fire, the cleared area around the plant structures will form a natural firebreak. A second potential fire hazard is an accident to a tank truck during .

delivery of diesel fuel to the storage area on the site. The fuel storage area poses no hazard since it is underground. In both cases there would be no direct effect on the plant from

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heat or smoke. Further, the control room will be provided with ventilation system features to protect habitability from the effects of particulates. Myers, fol. Tr. 728, pp. 7-8; SSR, fol. Tr. 1888, p. 6; Tr. 1898; PSAR, pp. 2.2-10c to 12, S 9.4.1; SER, fol. Tr. 14,441, SS 2.2, 6.5.3, 9.4.1; SER Supp. 1, fol. Tr. 14,441, S 6.4.

194. In a motion dated December 3,1975, intervenor SCANP asserted, in part, that a statement in the PSAR to the effect that no military air routes existed within 20 miles of the site was incorrect. Applicants, in their response of December 15, 1975, agreed that the statement was in error and undertook to provide corrected, current information. This Board's response was to call for an evidentiary presentation concerning the matter. Tr. 4749-751.

195. Applicants and the Staf f both presented testimony on the subject of military aviation. Commander Cobb, USN, ap-peared on behalf of Applicants and explained that a number of military air routes exist within the vicinity of the site. The closest of these are low level training routes TR-400 and TR-415. Department of Defense policy prescribes that such routes be aligned so that they are clear of nuclear power .

plants. Consistent with this policy, the centerline of routes TR-400 and TR-415 (sometimes referred to as TR-400/415, as they are the same route in the area of interest) is located 6 NM

_yy4_

f rom the site. The nearest perimeter of these routes, which are 8 NM wide, is 2 NM away. Tr. 5141-150; Exhs 61, 62.

196. The Staff's witness, Dr. Jacques B. J. Read, performed on analysis of military aircraft hazards to the site. Dr. Read calculated an impact probability of 1 x 10 -10 per flight.

Under the NRC's Standard Review Plan (NUREG-75/087), if the probability of a plane crash is shown to be less than 1 x 10~7 (i.e. , less than one chance in 10 million per year) ,

such events are deemed by the Staff to be of sufficiently low likelihood that their ef fects may be ignored. Accordingly, up to 1,000 flights per year in the training routes near the sits would still render the Project an acceptable risk. Read, fol.

Tr. 5539, pp. 2-5; Read, fol. Tr. 8325, pp. 2-11.

197. In ceder to account for uncertainties, Dr. Read incor-potated a number of conservatisms into his analysis, tending to overestimate crash risk. For example, it is clearly impossible to specify what type or types of military aircraft will be in service during the lifetime of the plant, which may extend well into the 21st century.* To be guaranteed of conservatism, Dr.

Read assumed a mean time to total crash loss of any aircraf t of 10,000 flight, hours in peacetime training missions; .

• Assuming commercial operation dates of 1987 and 1989, for Units 1 and 2 respectively, (see, Application for Construc-tion Permits and Operating Licenses for Skagit Nuclear Power Project, Units 1 and 2, Exh . 175, p . 14 ) , and a 30-year opera-ting lifetime, the facility will be producing power from 1997 until 2019. -

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even though recent history indicates that such a loss rate would not be tolerated, and actual experience is about ten times more f avorable. In addition, most military aircraft ac-cidents occur during take-of fs, landings and exercises. Risk to the A6 aircraf t in the Pacific Fleet, for example, is domi-nated by the small fraction of their time spent in carrier operations and practice bombing. Nevertheless, Dr. Read con-servatively assumed that accidents were uniformly distributed over the entire flight time. Read, fol. Tr. 8325, pp. 8-10.

198. We conclude that the risk of an aircraft crash is ac-ceptably low insofar as the Skagit site is concerned. Use of TR-400/415 amounts to less tnan 300 flights per year. Read, fol. Tr. 5539, Att., p. 2; Tr. 5564. As a result, the proba-bility of an aircraft crash which might affect the facility is considerably less than 1 x 10 -7 . Accordingly, the site is acceptable and the facility need not be specially designed and hardened to withstand such crashes.

199. We conclude . hat there are no nearby industrial, military, or transportarion activities which preclude either

, site acceptability or a finding that the site is suitable for reactors of th,e general type and size proposed. .

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C. Meteorology 200. The Skagit Valley climate is moderate with cool summers, mild winters, and rain in all seasons. The area is dominated by the influence of the Pacific Ocean and Puget Sound to the west.

Extreme. weather conditions are possible -- e.g., heavy snowfalls, ice storms, thunderstorms, tornadoes, extreme winds. However, none of these possibilities could endanger safe operation of the proposed facility. Myers, fol. Tr. 728, p. 8; PSAR, S 2.3.1.

201. The climate of the region near the site is highly varied from one location to another. Much of this variation is caused by the sharply defined topography. However, the position and intensity of the high and low semipermanent pressure centers ever the north Pacific, and the distance and direction from the ocean, are also important influences. The local meteorology of the site, therefore, is best described by essentially one source, the onsite meteorological measuring station. Myers, fol. Tr. 728, pp. 8-9; PSAR, S 2.3.1.

~

202. The dnsite meteorological measuring program began opera-tion in May 1973, with instrumentation installed at 10 , 35- and 60-meter levels on a 60-meter tower located in an open field at approxiraately the same ground elevation as, and 4,800 feet east

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of, the-reactors. Myers, fol. Tr. 728, p. 9; PSAR, S 2.3.3.

This onsite program conforms to the recommendations of Regulatory Guide 1.23, "Onsite Meteorological Program." SER, fol.

Tr. 14,441, S 2.3.3.

203. Witness Badgley criticized the meteorological data col-lection program and suggestsd the desirability of obtaining addi-tional information. For example, data might be collected regard-ir.g 'nds above the 60-meter level t';ough use of balloon- or aircraft-borne instruments. The data collection period might be longer thsn one year.* Studies might be done to evaluate in greater detail the influence of local topography on atmospheric factors. Badgley, fol. Tr. 3120, pp. 2-4; Tr. 3167-172.

204. We note, however, that the Staf f views one year of on-site meteorological data as sufficient at the PSAR stage of review. Standard Format and Content of Safety Analysis Reports for Nuclear Power Plants, CNR Edition, Regulatory Guide 1.70, S 2.3.3. Further, Dr. Badgley acknowledged that the data ob-tained f rota the onsite meteorological tower is appropriate for determination of dispersion characteristics at the site, and that it has been properly used with conventional methods to predict the dispersion of the cooling tower plume a.id radioactive .

• In fact, the PSAR has been amended to include data for a two-year period. PSAR, S 2.3.

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releases. Tr. 3126, 3135, 3149, 3178. He termed himself " satis-fied" with the data which had been collected at the 10- and 60-meter elevations to define Pasquill stability classes.

Tr. 3160. His doubts about the suitability of the Pasquill pro-cedure for a valley site related only to dispersion at a consid-erable distance from the site, and he admitted that any restric-tions imposed by the valley would come into play only at a distance of some miles. Tr. 3163-167. The data which might be collected with additional instrumentation would be " marginal,"

and " nice background information but probably not immediately applicable" to dispersion of releases within 2-3 miles.

Tr. 3175-176. Data obtained at higher elevations could be useful for predicting transport and dispersion at elevations above 60 meters and up to about 3,000 feet and 20 or more miles distadt f rom the site. Tr. 3127-128, 3135-136, 3169-170, 3175-177 and 3180.

205. Shortly before the site suitability hearing, it was dis-covered that the anemometer, the instrument which measures wind speed, was defective. An investigation showed that, as a result, wind speec. had been improperly recorded. The nature and magni-tude of the er,ror in recordation were identified, as well as an .

acceptable method by which the erroneous wind speed data could be corrected. The corrected data, which now appears in the PSAR, was used by the Staff in its evaluation of radiological doses.

1247 125

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Tr. 737-757, 3076-091; Exhs 13, 14, 15; PSAR, S 2.3; SER, fol.

Tr. 14,441, S 2.3.3; SER Supp. 1, fol. ~ . 14,441, S 2.3.5. The meteorological program will be continued, with an equipment modi-fication to eliminate the windspeed error, during operation of the facility to provide real-time meteorological information.

Myers, fol. Tr. 728, p. 9; SER, fol. Tr. 14,441, S 2.3.3.

206. We find that the meteorological information has been properly compiled. It indicates that the site experiences no unusual meteorological phenomena which would prevent safe opera-tion of the facility. Similarly, the diffusion capabilities of the atmosphere in the site area are good. Thus, the proposed site is suitable with respect to meteorology for reactors of the general size and type proposed. FES, fol. Tr. 2913, S 2.6; SSR, fol. Tr. 1888, pp. 7-8; PSAR, S 2.3; Exh. 4, S 2.6; Tr. 1899; SER, fol. Tr. 14,441, S 2.3; SER Supp. 1, fol. Tr. 14,441, S 2.3.5.

D. Hydrology 207. The s,ite is approximately 300 feet above Skagit River flood plain. It encompasses parts of the drainage areas of 1247 126

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Wiseman, Black, and Tank Creeks, all of which empty, eventu-ally, into the Skagit River. The river will furnish approxi-mately 90% of the f acility's water requirements and receive its effluents. In the site vicinity the Skagit River, draining an area of about 2,960 square miles, meanders over a three-mile wide flood plain. The low-water channel is heavily braided and has numerous sloughs and side channels. Myers, fol. Tr. 728,

p. 10; SSR, fol. Tr. 1888, p. 8; PSAR, pp. 2.4-1 to 2; SER, fol. Tr. 14,441, S 2.4.1.

208. Make-up water for the Project will be obtained through Ranney Collectors, located near the bank of the Skagit River approximately five miles southeast (ups tr eam) of the site.

Their pumps will be on platforms surrounded by sealed concrete walls extending above the 100-year flood elevation. The col-lectors are designed to induce flow from the river, using the alluvial deposits as a natural filter. Myers, fol. Tr. 728,

p. 10; SSR, fol. Tr. 1888, pp. 9-10; PSAR, p. 2.4-16; SER, fol.

Tr. 14,441, 5 2.4.1; Tr. 10,654, 10,656; Exh. 204, p. 2.

209. Probable maximum floods on the Skagit Rive; cannot reach the site. The floods, postulated include those occasioned by f ailure of all existing upstream dams. Slack Creek will be -

rerouted into a channel designed for a 100-year flood flow estimated in accordance with United States Geological Survey procedures. The maximum runup elevation was determined to be

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6 feet below the grade of safety-related structures. Surge and seiche phenomena cannot occur at this site. The effect of tsunamis may travel up the Skagit River but the site elevation above the flood plain precludes damage from this source. Ice formation can cause flooding on the river but cannot damage the safety-related facilities because of their location above the flood plain. It is concluded that the site saf ety-related buildings and structures will not be subject to flooding f rom any source. Myers, fol. Tr. 728, pp. 10-11; SSR, fol.

Tr. 1888, pp. 9-10; PSAR, pp. 2.4-3 to 10; SER, fol.

Tr. 14,441, S 2.4.2.

210. Channel diversions have been examined. The river bend at the Ranney Collector location has been fairly stable since .

riprap bank protection was placed there in 1958. Riprap will be maintained to provide for continual stability. Complete blockage of the river could result from rock or landslides up-stream. Such blockage would be temporary because the river flow would fill the natural reservoir so created and downstream flow would resume in a few days. In sucn an event, the reac-tors would be shut down until flow resumed. Myers, fol. Tr.

728, p. 11; Ex,h. 2J4, p. 1; Tr. 10,660-664 .

211. Historical low-water occurrences have been deter-ati ne d . Emergency and normal shutdcwn flow requirements for each unit are approximately 15,000 gpm. The required water is

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stored onsite in the Standby Service Water cooling tower basins, which are designed to seismic Category I. Thus, make-up water for the facility is not required for emergency shut-down, and analysis of the effects of low-water conditions in the Skagit niver is not required. We conclude that an adequate saf ety-related water supply will be available at the proposed site. Myet; fol. Tr. 728, p. 12; SSR, fol. Tr. 1888, pp. 9-10; PSAR, pp. 2.4-11 to 13; SER, fol. Tr. 14,441, S 2.4.3.

212. Accidental spillage of radioactive liquids on the ground during aperation is unlikely. If it should occur, some radioactive material may infiltrate to the water table and migrate with ground water flow. Analysis shows that probable g flow paths could result in discharge to Wiseman Creek after ten years' travel time, or into a spring in about four years. Both discharge points are within the exclusion area, and a monitor-ing program would define the migration of radioactivity in the event of an accident. Myers, fol. Tr. 728, p. 12; PSAR, pp.

2.4-21 to 23.

213. The NRC Staf f has conservatively estimated the time required for ground water to move along the most critical, 3100 foot ficw path to the nearest downgradient water user to .

be about six years. In developing its estimate, the Staff conservatively neglected radionuclide holdup ef fects and concentrarien reductions resulting f rom ion exchange with the

_123- 1247 129

solid parcicles of the aquifer medium, except for Strontium-90 and Cesium-137. The travel times from the plant to the well for these two radionuclides were estimated to be about 210 years and 2100 years, respectively. All other radionuclides were assumed to move to the well in six years (groundwater travel time). Utilizing a dilution factor at the wel.

resulting from dispersion and dilution of postulated containments conserva- tively estimated to be about 2600, the resultant postulated contamination of the well water would be significantly lower than the limits prescribed in 10 CFR Part 20 for releases to unrestricted areas. SER, fol. Tr. 14,441, SS 2.4.4, 15.3.5.

214. We conclude that the proposed site is suitable, from the standpoint of hydrological conditions, for reactors of the general size and type proposed.

E. Geology and Seismology 215. (This paragraph is reserved. Findings will be filed af ter completion of hearings on this subject.]

1247 130

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F. Suitability for Development of Evacuation Plan 216. (This paragraph is reserved. Findings will be filed af ter completion of hearings on this subject.] --

IV. RADIOLOGICAL HEALTH AND SAFETY A. The Application and its Review 217. [This paragraph is reserved. Findings will be filed upon completion of the construction permit hearings.]

1241 \5\

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B. Site Criteria 218. (This paragraph is reserved. Findings will be filed upon completion of the construction permit hearings.]

C. Facility Design 219. (This paragraph is reserved. Findings will be filed upon completion of the construction permit hearings.]

D. Research & Development 220. (This, paragraph is reserved. Findings will be filed .

upon completion of the construction permit hearings.]

1247 132

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E. Technical Qualifications 221. [This paragraph is reserved. Findings will be filed apon completion of the construction permit hearings.]

\

F. Quality Assurance 222. [This paragraph is reserved. Findings will be filed after completion of hearings on this subject.]

1247 133

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G. Conduct of Operations 223. (This paragraph is reserved. Findings will be filed upon completion of the construction permit hearings.]

H. Common Defense and Security 224. (This paragraph is reserved. Findings will be filed upon completion of the construction permit hearings.]

\241 \bh m

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I. Financial Qualifications 225. (This paragraph is reserved. Under the present sched-ule, Applicants will file its findings on this subject on October 8, 1979.]

J. Emergency Evacuation Plan 226. (This paragraph is reserved. Findings will be filed af ter completion of hearings on this subject.]

1247 135 e

6

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V. CONCLUSIONS OF LAW --

227. [This paragraph is reserved. Conclusions of law will be filed, as appropriate, upon completion of hearings on LWA subjects and construction permit issues.]

1247 136 m

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VI. ORDER

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228. [This paragraph is reserved. A proposed order will be filed, as appropriate, upon completion of hearings on LWA sub-jects and construction permit issues.]

Respectfully submitted, PERKINS, COIE, STONE, OLSEN & WIL .MS By -

N F. Theocore Thomsen l

Douglas S. Litrie Attorneys for Applicant 1900 Washington Building Seattle, Washington 98101 Phone (206) 682-8770 Of Counsel:

Lowenstein, Ne'wman, Reis, Axelrad & Toll 1025 Connecticut Avenue N.W.

Washington, D. C. 20036 (202) 862-8400 By /l41dS-Michael A. Bauser 1247 137

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APPENDIX A September 14, 1979 EXHIBITS No. Description Identified Received JULY - AUGUST 1975 HEARING 1 Application (General Information volume) 710 712 2 Chapter 2 of the Preliminary Safety 710 712 Analysis Report 3 Section 13.3 of the Preliminary 710 712 Safety Analysis Report 4 Environmental Report 710 712 5 Slides (photographs) 645 647 4.1 through 4. 9 6 General Site Plan 649 653 7 Letter from U.S. Forest Service 444 444 to Leed, 6/18/75 8 Skagit DES, U.S. Forest Service, 446 446 6/16/75, with letter 6/26/75 and notice 6/30/75 9 Pamphlet "The Skagit, A Proposal 446 446 1975", U.S. Forest Service 10 Report "The Skagit Wild and Scenic 446 446 River Study Report", U.S. Forest Service 11 Decree Adjydicating Public Use 730 731 .

and Necessity, 7/9/75, with drawing, "Skagit Nuclear Power Project", 7/15/75 12 Photograph No. 72-3111, 1/9/73, 733 734 depicting site 6

1247 138

No. Descriotion Identified Received 13 Sheet containing three equations 740 743 of witness Lou 14 Figure 1, Error vs. Wind Speed, and 745 754 Figure 2, Error vs. Wind Speed 15 Figures 2.3-12 and 2/3-13 748 754 16 Two relief maps (Concrete and 861 862 Victoria) 17 Topographic map of Mount Baker 865 865 18 Seven slides of Mount Daker -

868 869 (photographs A through G) 19 USGS press release and attachment 879 882 20 USGS document, " Origin and Age of 883 8C6 Postglacial Deposits and Assessment of Potential Hazards from Future Eruptions of Mount Baker, Washingten", Open-file report 75-286, 1975 21 Memo from USGS (Meier) to Milhous, 889 1473 et al., 5/30/75 22 Letter from U.S. Forest Service to 1147 1148 Pug e t , 1/22/73 23 Letter from Puget to U.S. Forest 1147 1148 Service, 2/12/73 24 Brochure "The Skagit River", U.S. 1147 1148 Forest Service 25 Report "Skagit River Study", U.S. 1147 1148 Forest Serv. ice .

26 Document " Review of ERTS Imagery of 1169 3890 Northwestern Washington and Southern British Columbia" 1247 139 No. Description Identified Received 27 Bouguer Gravity Anomaly Map, 1172 3888 Major Earthquake Epicenters 28 USGS Topographic Maps 1213 (Victoria and Seattle) 29 Report " Summary of Geologic and 1249 3890 Seismologic Investigations of the Skagit Nuclear Power Project Site",

3/29/75 30 Report " Evaluation of the December 15, 1249 3890 1974, Earthquake in Skagit Valley",

3/29/75 31 ERTS Imagery, Band 5, Western 1334 1335 Washington 32 ERTS Imagery, Band 6, Western 1334 1335 Washington 33 ERTS Imagery, Band 7, Western 1334 1335 Washington 34 ERTS Imagery, Color Composite , 1334 1335 Western Washington 35 Dr. Cheney's Resume 1344 1345 36 Rasmussen slides which accompanied 1538 1873 his testimony before TPPSEC 37 Rasmussen report presented to 1540-A TPPSEC 38 Map of Skagit County, Washington 2304 2305 39 " Compilation of Earthquake Hypo- 2437 2438 centers in Western Washington",

1974, by Crosson -

40 Stipulated TPPSEC testimony of Orrell 2898 2899 41 Stipulated TPPSEC testimony of Norton 2898 2899 1247 140

No. Description Identified Received 42 Stipulated TPPSEC testimony of 2898 2899 Ellingson 43 References to testimony of 2923 2976 Brubaker 44 President's Budget, FY '76 3294 3294 45 Fish Facility Contributions to 3387 3388 Project Discharge 46 Documen t " Thermal Power Plant Siting 3688 3691 Study", September 1970 47 Letter from Bechtel to Puget (Bush), 3688 3691 1/20/72 48 Geer report, " Proposed Use of Skagit 3742 3743 County Coal for Large-scale Electric Power Generation" and letter 6/13/75 49 Letter, 4/4/75, Ehrhcen to Hall, 3768 3769 with Report on Black Diamond-Franklin Coal Deposits 50 Map, Complete Bouguer Gravity 3884 3889 Anomaly Map of Washington, Bonini, Hughes and Danes, 1974 51 Map, Thickness of Unconsolidated 3891 3894 Sediments, Puget Lowland, Washington, Hall and Othberg 52 Topographic Map, USGS, Victoria 38.96 3896 and Concrete 53 Map, World Astronautical Chart, 3917 ICAO, July 1973 54 Plant site profile 3951 3954

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55 Stipulated TPPSEC Testimony of 3955 3955 Milne 56 Article re Solar Power, Christian 4709 4710 Science Monitor, 4/23/75 1247 141 No. Description Identified Received JUNE 1976 HEARING 57 Certificate dated May 7, 1976, 4908 4910 signed by Roger Polzin. (401 -

Certification, Council Order No. 7, and NPDES Permit. )

58 Application (General Information 4935 4936 volume) as amended through Amendment 2, Feb. 9, 1976 59 Chapter 2 of the Preliminary Safety 4935 4936 Analysis Report, incorporating all revisions through Amendment 12, April 21, 1976 60 Section 13.3 of the Preliminary 4935 4936 Safety Analysis Report, incorporating all revisions through Amendment 12, April 21, 1976 61 Aviation sectional map, Seattle 5145 5219 Sector 62 DOD Flight Information Publication, 5150 5219

, Area Planning, Military Training Rou te s , Nor th and Sou th Amer ica ,

effective 20 May 1976 63 Aviation sectional map, Seattle 5145 5219 Sector with circle JULY 1976 HEARING 64 Map of U.S. coastline " Reference-- 5779 5780 -

Silver 1971" 65 Portion of state highway map showing 5959 5979 Puget Sound area 1247 142 No. Description Identified Received 66 Aerial photo of Cherry Point, 5979 5981 September 11, 1973 67 Map entitled " Electric Power Plants" 6019 6021 68 Western Systems Coordinating Council 6019 6021 -

69 Variation in Cost of Power with 6303 6305 Capacity Factor 70 Washington State Parks' Visitors, 6544 6545 June 1974 to May 1976 AUGUST 1976 JOINT NFP HEARING Exhibit No.

Peoble NFP Transcript Skagit Springs Description IdentIlled Received 71 0-4 Energy Reserve Planning Model 300 300 Input Data - West Group Annual Average Streamflow Capability 72 0-5 1976 West Group Forecast, 321 619 March 1, 1976 73 A-9 Pages 1, 15, 26, 27 and 30 of 636 1263 Sixth supplemental Order of WUTC in Cause No. U-73-57 74 Portions of Pebble Springs trans- 752 , 754 cript containing testimony of Charles L. Heinrich, Charles R.

McClellan and Fred Weber (pp. 306-328; 945-970; 1000-1001; 1128-1132; 1147-1156; 1170-1178; 1183-1223; 1278-1287; 1292-1319; 1324- -

1343; 1345-1358)

S-8 Portions of Skagit transcript 752 754 containing testimony of Richard H. Swartzell (pp. 4241-4277; 4281-4289; 4312-4315; 4320-4332; 4338-4343; 4404-4407; 4434-4442) 1247 143 Exhibit No.

Pebble NFP Transcript Skacit Springs Description Identified Received 75 P-2 Bonneville Power Administration 1397 1402 Electric Energy Conservation Study, July 1976, Skidmore, Owings & Merrill (SOM Repor t) --

76 A-10 Bonneville Power Administration 1403 1404 letter of August 18, 1976 77 M-16 Testimony of Stephen Lambert, 1673 1673 Energy Conservation Organization (Rejected) 78 M-17 Appendix B entitled " Project 1677 1673 Description" to testimony of Stephen Lambert 79 M-19 Testimony of William Boly 1713 1714 80 M-19 Energy Costs of Using Columbia 1717 1724 River Water for Irrigation (13 pp.)

81 M-20 Can NW Afford More Irrigation, 1717 1726 Oregon Journal, March 29, 1976 (Rejected) 82 M-21 New Power Required to Develop 1717 1726 Irrigation, Oregonian, (Rejected)

April 17, 1976 MARCH 1977 JOINT NFP HEARING 83 22 Site Certification Agreement 1757 1766 for Skagit Units, January 5, 1977 84 23 Council Order No. 512, 1757 1766 .

September 13, 1976 85 24 Order Approving Application 1757 1766 for Certification signed by Governor Evans, December 6, 1976 1247 144 -

Exhibit No.

Pebble NFP Transcript Skagit Springs Description Identified Received 86 25 Chapter'80.50 Revised Code 1758 1766 of Washington 87 26 1977 West Group Forecast, 1758 1760 -

February 15, 1977 88 27 Choosing an Electrical Energy 2175 2191 Future for the Pacific North-west: An Alternative Scenario, January 31, 1977 (NRDC Scenario) 89 28 Portion of "An Economic Analysis 2543 2544 of Solar Water & Space Heating",

selected by Bruce C. Netschert (MITRE Report) 90 29 An Electricity Sales Forecasting 2757 2757 Model for the States of Wash-ington, Oregon, Montana and Idaho, prepared for Pacific Northwest Utilities Conference Committee by Kent P. Anderson, January 30,1976, amended July 1976 (NERA PNUCC Model) 91 30 Residential Customers Energy 3013 3015 Use Survey, Puget Sound Power

& Light Company, January 11-12, 1977 92 31 The Economic Effect of 3126 3129 Electricity Conservation by the Residential Customers of Pacific Power & Light Company 93 32 Bonneville Power Administration, 3350 3367 Power Situation Statement, .

Monthly Summary, January 1977 94 33 January Power Situation 3350 3367 Report, January 1977 1247 145 Exhibit No.

Pebble NFP Transcript Skagit Springs Description Identified Received 95 34 Summary Table, West Group 3351 3367 Area Imports and Exports 96 35 Imports, computer printout 3351 3367 --

(4 pp.)

97 36 Pacific Northwest Coordination 3407 3408 Agreement 98 37 Attachment I to Dr. Miller's 3455 3457 testimony with handwritten figures added by Applicant 99 38 Comparison of Energy Load 3532 3545 Growth Rates - Historical and Forecast 100 39 Table D to Testimony of 3533 3545 David H. Knight, February 15, 1977 with hand-written additions (2 pp.)

101 40 Population Growth by County 3551 3559 102 41 Population Comparisons, 3551 3559 1970-1976 103 42 Home Insulation Questionnaire, 3713 3713 September-November, 1976 Puget Sound Power & Light Company, Market and Rates Depar tment No. Description Identified Received MAY 1977 PRE-LWA WORK HEARING 104 Sanitary Sewer Line, Photographs 6602 6606 of Stream Crossings and Sewer Line Routing, April 18, 1977 1247 146 No. Description Identified Received 105 Highway Intersection Improvements, 6602 6606 Photographs of Various Portions of Road Work 106 Drawing " Vicinity Map", Proposed 6607 6612 Road Work, Sheet 1 of 14 --

107 Drawing " Plan", Proposed Road Work, 6608 6612

" Plan", Sheet 5 of 14 108 Drawing " Plan", Proposed Road Work, 6608 6612 Sheet 6 of 14 109 Drawing " Profile, Station 356 Plus 6609 6612 00 to Station 586 Plus 50",

Proposed Road Work, Sheet 7 of 14 110 Drawings of Proposed Road Work, 6684 6685 14 sheets--full set 111 Map labeled Township 35, north, 6795 6817 range 5, east-west meridian, 7 photographs and a road mapping 112 10 photographs 6795 6817 113 Construction layout drawings for 6841 6869 the sewer line, 15 sheets 114 Data on stream flows, and total 7038 7134 suspended solids for Wiseman Creek JULY 1977 HEARING 115 Chapter 2 of PSAR as amended 7174 through Amendment 18 7179 116 Puget letter, June 27, 1977 7632 763a to NRC 117 Skagit FES (Forest Service) 7771 7772 1247 F47 No. Description Identified Received 118 Wild and Scenic River Study 7771 7772 Report (Forest Service) 119 Skagit Nuclear Power Project 7828 7829 Environmental Analysis Report by Mount Baker-Snoqualmie National ..

Forest, May 1976 120 Potential Impact of Skagit Nuclear 7848 Power Project, Units 1 and 2, on Skagit River Fisheries, by Fred H. Everest, Research Fisheries Biologist, July 12, 1977 121 Photograph, from Skagit River 8090 8116 looking toward Bacus Hill from Rivermile 32.5 122 Photograph, Bacus Hill from Skagit 8091 8117 River looking northwesterly, Rivermile 32, June 19, 1977 123 Photograph, Bacus Hill from Skagit 8092 8118 River looking tiesterly, Rivermile 32 124 Photograph, Mouth of Hansen Creek 8096 8208 from Skagit River, Rivermile 24, June 19, 1977 125 Pages 3574 through 3721 of the 8203 Pebble Springs transcript for January 19, 1977 and pages 3728 through 3861 of the Pebble Springs transcript for January 20, 1977 126 Sheet 5, attached to 8344 8345 Goettge affidavit 127 Sheet 6, attached to 8344 8345 Goettge affidavit 128 Sheet 6, full size 8344 8345 129 Sheet 6, overlay 8344 8345 6

1247 148 No. Description Identified Received MARCH 1978 HEARING 130 Amendment 19 to Skagit PSAR 8705 8706 (filed December 9, 1977) _.

131 The Pictorial Land Form Map of 8711 8713 the State of Washington, Including Adjacent Parts of Oregon, Idaho, and British Columbia 132 Composite geologic map of plant 8715 8731 site area showing mapping done by Bechtel 133 Dr. Gerald Miller's geologic map 8910 (proprietary) 134 Whetten's geologic map of 9068 San Juan Islands 135 LANDSAT imagery of northwest 9068 Washington and southwest British Columbia 136 Side-looking airborne radar image 9094 entitled "Mt. Vernon Area" 137 Geologic map showing Devil's Mountain 9094 Fault (Whetten) 138 Seven-page USGS aeromagnetic survey 9104 139 Preliminary Whetten map 9116 140 Reduction of Exhibit 138 9134 141 Reduction df Exhibit 132 9154 142 Whetten geologic map (1:250,000) 9166 of Devil's Mountain Fault i247 149 -

No. Descriotion Identified Receive,d 143 BB&N High Resolution Seismic Profile 9285 Locations - 3/25/76. Map of San Juans f rom Whidbey Island north 144 Western Geophysical data, Line A 9293 145 Western Geophysical data, Line B 9293 146 Western Geophysical data, Line C 9293 147 Western Geophysical data, Line E 9293 148 Western Geophysical data, Line G 9293 149 BB&N data, Line 1 9311 150 BB&N data, Line 2 9312 151 USGS data, Line D-1 9313 152 Edcon index map with major 9330 geologic features 153 Map: USGS quads for Hamilton, 9994 Oso, Wickersham, Clear Lake 154 Memo to Record by William Hays 10064 of USGS, May 9, 1977 155 Enlarged portion of Rogers' map 10106 156 Five photographs by Bolt of 10301 '

Rumanian earthquake JUNE 1978 HEARING 157 Fig. 1, 6/12/78 old snd new 10644 10659 .

caisson locations 158 Fig. 1, 5/22/78 Ranney 10645 10659 collector site, new location 159 Cross-section No. 3, 5/22/78 10646 10659 1247 150

No. Description Identified Received 160 Cross-section No. 2, 6/16/78 10646 10659 161 Cross-section at switch gear 10647 10659 162 Colored rendition of Ranney 10648 10659 collector pumphouse _

163 Ranney collector design drawing -

10672 10684 164 Collectors 1 and 2 lateral layout, 10674 10684 original design and proposed design 165 Collectors 3 and 4 lateral layout, 10674 10684 original design and proposed design 166 Mikels letter to Bechtel, S/10/78 10683 10684 167 Mikels letter to 3echtel, 6/14/78 10683 10684 168 Table 2, " Estimated Percentage 10744 10754 of pumped water diverted from a River Based upon Water Quality Data" 169 Enc. to FTT ltr. to Leed, 6/19/78, 10833 10834 2 pgs. test runs by Carrier Corp.

& Johnston Pump Co.

170 Updating of Exh. 132, 5/23/78 11026 11046 (Comp. Geo map, 5/23 version) 171 Blunden review of bore hole 11042 11046 logging 172 Beck: " Gravity Faulting as a 11182 11183 Mechanism of Topographic Adjustment" 173 Core Drilling & Logging Procedures 11247 11249 ,

& Core Storage for Skagit, by Bechtel, Inc. , March 1978 174 Staff letter 6/16/78 to Puget 11260 11261 transmitting questions 1247 151 No. Description Identified Received JULY 1979 HEARING 175 Application (General Information 12359 12365 volume) as amended through -

Amendment 4, June 1979 176 Preliminary Safety Analysis Report 12359 12365 as amended through Amendment 20, January 31, 1978, including a facsimile of the General Electric Standard Safety Analysis Report for the 251 inch reactor vessel BWR/6 as amended through Supplement 18, March 4, 1977 177 Photo, Walker and Associates, 12446 12449 Negative No. SWl-69-18-10, 1969 178 Sketch of cone of depression by 12461 12465 P. R. Weber 179 Four Company Composite, Table E 12,606 12623 180 Replacement Power 12606 181 Staff memo for Regan from Jackson, 13005 13005 6/29/79, Staff Ref. 3 182 Preliminary Environmental Standard 13011 13013 Review Plan, Section 9.2, February 1979 183 Staff memo for Leech from Kantor, 13104 13105 March 22, 1979, Staff Ref. 52 184 Funding Requirements, Nuclear 13247 Projects Nos. 1 through 5, 3/79 185 1979 West Group Forecast 13260 13261 1247 152 No. Description Identified Received 186 Western System Coordinating Council 13276 13952 (WSCC) Table 2 187 WSCC, Figure 6 13278 13952 188 WSCC, Table 13 13282 13952 .

189 WSCC, 4 pp., Tables 13284 13952 17, 21, 25 and 29 190 Page 26, First Mortgage Bond 13300 13949 Issue, Pacific P & L, 3/28/79 191 Page B-5, Western Economic Indicators , 13320 13950 March - April '79, Fed. Res. Bank, San Francisco 192 Staff memo for Regan from Hulman, 13231A 13233A 3/8/79 193 Staff memo re floodplain management 13264A 13951 194 Pages from Application for Site 13612 13952 Certification to EFSEC by Northern Tier Pipeline Company 195 Cook - Alte.rnative sites 13663 196 Cook - RFV 13663 197 We be r - RP 1, 7/24/79 13664 198 Cheney - Additional Supplemental 13686 Alternative Sites, 7/25/79 199 Darland - four pages of data 13805 13956 200 Puget Estimated Loads and Resources 14047 14176 Table A, 1/19/79 .

201 WSCC - Ten-Year Coordinated Plan 14151 14151 Summery 1979-1988, May 1979 202 WSCC - Summary of Estimated Loads 14151 L4151 and Resources 1247 153

No. Description Identified Received 203 Letter frow Cutler to Gossic 14153 14155 (undated) and enclosed determination (April 11, 1978) pursuant to Section 7 (bs of the Wild & Scenic Rivers Act 204 Letter from Mecca to Regan, May 22, 1978 14153 14155 -

and attached page 32 of site Certifica-tion Agreement 205 Letter from Moore to Cutler, 14154 14155 June 5, 1978 206 Letter from Bergland to Deale, 14154 14155 March 8, 1979 207 Letter from Bergland to Moore, 14154 14155 May 2, 1979 and enclosed Environmental Assessment 208 Darland - Alternative Site 14181 Selection Cr iteria, 7/26/79 209 Four sketches of Ranney Collector 14267 14324 210 Two cross-sections of 14272 14324 Ranney Collector 211 WSCC Figure 6 14330 14387 212 WSCC Resources Planned 14330 14387 213 Skagit Safety Evaluation Report (SER), 14441 NUREG - 0309, September 1977 214 SER, Suppl. No. 1, October 1978 14441 215 SER Errata Sheet 14441 216 Flood Hazard Boundary Map 14534 14546 .

217 Letter from Shelver to FIA, 14540 14546 July 30, 1979 218 Document (3 pages; rejected) and 14573 14583 attached Hanauer Memo of 9/20/72 (4 pages; received) 1747 154

No. Description Identified Received 219 UCS Document dated December 14573 14586 1978 and attachments (Rejected) 220 WUTC , Second Supp . Order , U-78-21, 14756 14875 Puget's last rate case 221 Excerpt, WPPSS study, April 1979, 14726 14735

~

p. 10, graph 6 222 Graph, CPIS, Source: Rand, 14731 14735 R-2304-DOE, p. 32 223 Solomon Bros. July Report 14842 14872 224 Puget 1978 10-K report 14879 14881 225 PGE 1978 10-K report 14879 14881 226 Pacific 1978 10-K report 14879 14881 227 Water power 1978 10-K report 14880 14881 1247 155 m

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION

BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )

)

PUGET SOUND POWER & LIGHT COMPANY,) DOCKET NOS.

et al. )

' ) 50-522 (Skagit Nuclear Power Project, ) 50-523 Units 1 and 2) )

)

CERTIFICATE OF SERVICE I hereby certify that the following:

APPLICANTS' PROPOSED FINDINGS OF FACT AND CONCLUSIONS OF LAW IN THE FORM OF A PARTIAL INITIAL DECISION AUTHORIZING LIMITED WORK AUTHORIZATION, dated September 14, 1979 in the above-captioned proceeding have been served upon the persons shown on the attached list by depositing copies thereof in the United States mail on e,7*.-w o- 14 to74 with proper postage affixed for first class mail.

DATED: September 14, 1979. ,

• je .

_*)J:

i Counsel for Puget Sound Power &

Light Company 1900 Washington Building Seattle, Washington 98101 -

! 1247 156

Date: September 14, 1979 Valentine B. Deale, Chairman Robert C. Schofield, Director Atomic Safety and Licensing Board Skagit County Planning Department 1001 Connecticut Avenue, N.W. 218 County Admlaistration Building Washington, D. C. 20036 Mount vernon, WA 98273 Dr. Frank F. Hooper, Member Richard M. Sandvik, Esq.

Chairman of Resource, Ecology, Assistant Attorney General Fisheries and Wildlife 500 Pacific Building University of Michigan 520 S.W. Yamhill School of Natural Resources Portland, OR 97204 Ann Arbor, MI 48109 Roger M. Leed, Esq.

Gustave A. Linenberger, Member Room 610 "

Atomic Safety and Licensing Board 1411 Fourth Avenue Building U.S. Nuclear Regulatory Commission Seattle, WA 98101 Washington, D. C. 20555 CFSP and FOB Alan S. Rosenthal, Chairman Eric Stachon Atomic Safety and Licensing 2345 S.E. Yamhill Appeal Board Portland, OR 97214 U.S. Nuclear Regulatory Commission Washington, D. C. 20555 Robert Lowenstein, Esq.

Lowenstein, Newman, Reis, Dr. John H. Buck, Member Axelrad & Toll Atomic Safety and Licensing 1025 Connecticut Avenue, N.W.

Appeal Board Washington, D. C. 20036 U.S. Nuclear Regulatory Commission Washington, D. C. 20555 Warren Hastings, Esq.

Associate Corporate Counsel Michael C. Farrar, Member Portland General Electric Company Atomic Safety and Licensing 121 S.W. Salmon Street Appeal Board Portland, OR 97204 U.S. Nuclear Regulatory Commission Washington, D. C. 20555 James W. Durham Portland General Electric Company Docketing and Service Section 121 S.W. Salmon Street Office of the Secretary Portland, OR 97204 U.S. Nuclear Regulatory Commission Washington, D. C. 20555 Richard D. Bach, Esq.

(original and 20 copies) Rives, Bonyhadi, Drummond & Smith 1400 Public Service Building Richard L. Black, Esq. 920 S.W. 6th Avenue Counsel for NRC Staff Portland, OR 97204 U.S. Nuclear Regulatory Commission Office of the Executive Legal Canadian Consulate General Director , Donald Martens, Consul -

Washington, D. C. 20555 412 Plaza 600 6th and Stewart Street Nicholas D. Lewis, Chairman Seattle, WA 98101 Energy Facility Site Evaluation Council Patrick R. McMullen, Esq.

820 East Fifth Avenue Skagit County Prosecuting Attorney Olympia, WA 98504 Courthouse Annex Mount Vernon, WA 98273 Thomas F. Carr, Esq. ,

Assistant Attorney General Temple of Justice Olympia, WA 98504 1247 157 8/22/79