ML19282C410

Comments on Des:Depth of Analysis Is Far from Conclusive, Athens & Cementon Sites Have Different Characteristics & Environ Alternatives to Proposed Transmission Lines Should Be Explored

ML19282C410
Person / Time
Site:	Green County
Issue date:	04/30/1976
From:	Palmer H AFFILIATION NOT ASSIGNED
To:	Bajwa S Office of Nuclear Reactor Regulation
Shared Package
ML19282C397	List: ML19282C399 ML19282C410 ML19282C413
References
NUDOCS 7903300115
Download: ML19282C410 (7)

Text

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GREENE COUNTY LEGISLATURE COURT HOUSE CATSKILL. N ON YORK 12414 ~

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Mr. Singh Bajwa Division of Site Safety & Environmental Analysis ic 5 ' '

Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, D.C. 20555 ' Of [p(

Re: Draft Environmental Impact Statement on the Greene County Nuclear Power Plant NUREG - 0045

Dear Mr. Bajwa:

The Greene County Power Plant Committee created by the County Legislature and made up of. elected and appointed of-ficials, town and village elected officials, and private citizens, has reviewed the draft Environmental Impact State-ment and would like to offer the following comments:

A. General Comments

1. Although the Draft Environmental Impact Statement covers a wide range of concerns as required by N.R.C. regu-lations, the depth of analysis is far from optimal or conclusive in view of the serious envircnmental issues surrounding the plant.

Title 10 CFR Part 51 requires a " DETAILED STATEMENT OF ENVIRONMENTAL CONSIDERATIONS". This Detailed Statement should reflect detailed and in depth analysis.

It is suggested that the Draft Environmental Statement be redrafted and recirculated to reflect a greater analysis of the environmental issues surrounding this plant so that a more accurate assessment can be made of the proposed plant's environmental impact including its social and eco-ncaic costs and benefits.

The D.E.I.S. analysis should ce independent and should not merely rely on the applicant's data and analysis.

2. The Athens and Cementon site although only a few miles apart, have very differant characteristics and different environmental impacts, parti..ularly with regard to land use, transportation, social and economic factors. The Athens

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site should therefore, be analized and the results of that analysis reported.

3. The need for the plant should be analized and dis-cussed within the context of the 1976 New York Pcwer Pool Report, Article 149B; and in light of the increased atten-tion given to Energy Conservation by U.S. ERDA in recent reports and policy statements.

4. Based on the analysis suggested in 3 abovg could not one base load plant be adequate to meet PASNY's future demands?

5 The concept of " energy conservation

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should be discussed and analized within the context of utilization of " waste heat". If this is done, other sites and other techniques of power generation should be evaluated.so that the large quantities of waste heat that will be generated by the plant can be utilized for industrial processes and residential heating.

6. Small system alternatives should be discussed as well as large systems alternatives. A number of individual energy systems for homes or businesses may be one of the

• answers for reducing the need for large base loading plants.

7. The comparison of alternatives including the above mentioned alternatives should be based on N.R.C.'s independent analysis and not the applicants,since the October 1973 Stone and Webster report entitled Metropoliton Transportation Authority Plant Site Study is based largely on " economics" at one point in time. The N.R.C. should independently evaluate how much of the Stone and Webster report was based on the assumed Blenheim-Gilboa to Leeds line, as a larger part of a grid system from Leeds to Massena. The N.R.C. should evaluate whether it makes sense to build in Greene County if above projects were not built.

, 8. The N.R.C. should evaluate the environmental impact of the proposed plant and its necessary ancillary facilities such as the treatment plant, highway improvements, etc as one comprehensive project. At the same time, the N.R.C. should evaluate the impacts of the system of which the power plant is but part so that the aggregate environmental impact of the total system is understood and not just one piece.1

9. The Social and Economic impacts of the plant, because of their direct bearing on people, should be analized, documented and reported in quantifiable terms so that local residents 1

See the Supreme Court Case Decision

and other interested parties will understand the plant's impact. Some of the questions that should be answered are as follows:

a. . What are the social and economic costs of a plant during construction and, thereafter, on housing, food, other private services and goods, government services, police pro-tection, traffic control, social service, school system, office of civil preparedness, general government - town, village -

county?

b. . What are the benefits of a plant?

c. . What is likely to be spent locally in Greene County, Columbia County? Illustrate by giving several examples of small businesses (i.e. food shop, ' restaurant, car dealer, clothing store.) Should not PASNY be required to pay for the increased costs of government services due to the plant? The D.E.I.S. should address this issue, d .- . What happens after the construction tapers. off?

What happens to the multiplier effect and the additional jobs generated by the construction workers after construction? If this means an increased load for Social Services, should not the N.R.C. require PASNY to alleviate this negative impact?

e. . What can be done to ameliorate the negative impacts of the plant?

f. What specific ancillary projects should be built that will have lasting economic and social value to the towns, county and region?

g. . What is the recommended timing of these ancillary projects to maximize the socio-economic benefits?

h. . What would be the effect on PASNY's electric rates if they apid taxes or made payments in lieu of taxes? What would be a fair annual amount?

i. Does the N.R.C. have any other recommended and feasible approach to provide the towns, counties or region with benefits?

j. Af ter weighing the costs and benefits of the plant as proposed by PASNY, what is the net result in terms of costs and benefits?

k. How will real estate values be impacted by plant and cooling tower operation ?

1. Is it reasonable to develop manpower training programs to enable area residents, namely residents frcm Columbia and Greene Counties, to receive training and pre-ferential treatment for employment during the construction and operation of the plant?

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m... What degree of impact can be expected on existing agricultural activities? Can any benefits to agriculture be anticipated? What will the market response be to crops grown in the vicinity of a nuclear power plant? Specifically what are the impacts on the apple and mushroom crops?

n.. . What would be the impact on the recreational and tourist industries in Greene County?

10. Cooling towers are of great concern to the residents of Greene County and the issues surrounding them should be fully discussed

a. There are a number of possibilities that have been mentioned in the literature for using the waste heat of the power plant including agriculture and aquaculture, space heat-ing and air conditioning, sewage treatment, greenhouse heating, airport defogging and deicing, desalinization, deicing of roads, inducing algae growths which can be used for .vestock feed, waste water treatment, and other industrial processes. These alternatives should be discussed including which types of industries might feasibly utilize the waste heat? What are the most feasible uses of the waste heat, how much would they cost and what steps should be taken for implimentation? What would be the economic benefits to the county and the region to developing industries based on " waste heat"?

The N.R.C. should determine if it is reasonable, in view of recent state legislation, " Safe Energy Act", to expect PASNY to try some innovative approaches to waste heat?

b. The D.E.I.S. should discuss what can be done to reduce or eliminate the visual impact of the proposed cooling towers particularly the view from Olana, the Fredrick E. Church House, since the view was the inspiration for many Hudson River School paintings.

c. The impact of the cooling towers should be analyzed, discussed and documented including the impact of the plume and of the additional moisture that will be added to the atmosphere by the cooling towers on: climate, weather, the raising of mushrooms, the amount of orchards spraying, the impact on the resort and recreation luxuries,

11. The cement plants are a significant source of taxes and employment in Greene County and any adverse impact on their operation because of loss of land, increased traffic congestion, strict enforcement of National air quality standards that other plants may not conform to, or restrictions on blasting, may cause the closing of one or more cement plants. The N.R.C.

should therefore, carefully address, analize and dccument the following so that the impact on the cement plants can be under-3tood.

1. The extent to which the safe and efficient opera-tion of the proposed power plant and its ancillary facilities

. require conformance to the National Air qualit; standards should be discussed.

2. Blasting by the cement plants is necessary for the efficient operation of the cement plants. How pro-bable is it that this blasting could adversely affect the plant in some way or perhaps cause an earthquake? Is it possible? Would N.R.C. or some other regulatory agency be likely to restrict blasting because it might affect the operation of the plant, thus forcing the closing of the cement plants and resulting in the loss of jobs and tax revenue?

3. With or without the construction of 9W there will be impacts on the cement plants. The impacts and their implications should be discussed.

B. Specific Comments By Key Section and/or Page2 2.2 The Athens site should be shown on maps as well as analyzed. See comment A 2.2.2 Mushrooms are an important crop in Greene County.

2.3.1 The conclusions are erroneous. The proposed cool-ing towers will have a:significant visual impact on the views, from Fredrick E. Church House, Olana.

3.7 Alternatives to the applicant's proposed transmission line routes should be explored, including crossing the river at Cementon and using an underwater cable in the Hudson River.

The applicant's proposal for steel lattice towers is not ccm-plimentary to the existing Central Hudson's towers where PASNY proposes parallel routes.

3.7 The N.R.C. should impose conditions on the design and construction of the power lines similar to those that the F.P.C. imposed on PASNY on the Gilboa-Leeds line. 7.P.C.

Project No. 2685.

3.8 Route 9W should be rebuilt from the Saugerties Thruway Interchange to the Catskill Interchange on a route worked out by local and county planning boards. The negative environmental impact on existing residential uses frcm additional traffic would be unacceptible. The environmental impacts of a new 9W should be addressed in the D.E.I.S.

4. Local residents should be permitted supervise d utilization of existing timber resources in areas where removal of trees is necessary.

2 The comment may apply to m ore than one heading er page but the reference is meant to serve primarily as a beginning reference for the sake of simplicity.

. 4.0 The local Soil and Water Conservation District and the local U.S. SCS should be given an opportunity to comment on the proposed Erosion and Sediment Control measures proposed by the applicant. The results should be incorporated into the E.I.S.

4.4.1 The increased traffic is more than a " temporary inconvenience" but a negative environmental impact. -

4.5.2 The details on how to preserve the area along the Hudson should be spelled out, including ways to permit public enjoyment of this resource.

4.5.2 Specific recommendations for payments in lieu of taxes should be- made to lessen the negative impact on local governments and taxpayers.

5.1.1.1 States "The plumes of moist air resulting from cooling tower operation are not expected to have any serious effect on land use." The last paragraph of 5.3.2.1 states "The cooling tower plume will also have some visual impact.

From Figures 5.8 and 5.9, it is apparent that the visible plume can extend to several thousand feet. Therefore, during certain meteorlogical conditions, the cooling tower plume will be visible from many locations."

In simplist terms, the D.E.I.S. should describe hcw much more cloud cover can be expected, where, and what percentage of the time.

The D.E.I.S. should then quantify the impact of the cool-ing tower plume on land use, the economy and the natural '

aesthetics of the area.

5.3.3.2 If the E.P.A. or other agency standards can be exceeded, such as for chlorine, the question must be raised as to why have the standards unless they are to be used only as guidelines. If that is the case, then the D.E.I.S. should analize the impacts and not merely state it is in conformity with standards.

5.5.2.2 Similarly, the cumulative environmental impact of a number of plants, as proposed by the power pool and others, should also be evaluated. Thermal discharge is but one example.

5.5.2.2. It is not clear if this, the statements on sewage plant, is sufficient to meet E.P.A.'s requirement for a E.I.S.

No mention has been made of the environmental effects of the proposed sewage connections to the hamlet of Cementon.

6. Monitoring programs should be established for social and economic impacts since PASNY does not pay taxes on improve-ments. PASNY could then be required to pay for the additional costs of service and other social and econcmic costs. Local government shculd not have to pay additional costs because of PASNY's projects.

8.3.1 Table 8.1 footnote of, is inccmplete and should reflect the proposed Arthur Kill Plant.

8.9 Sections'O shculd be rewritten to reflect the requests for more in depth analysis.

Sincerely yours, 7 '

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Harry Li Palmer, Chairman Power Plant Committee Greene County

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