ML19242B458

Comments on Draft EIS Submitted by Conservation Law Foundation of Ri.Statement on long-term Negative Impact on Terrestial & Aquatic Wildlife Made W/Paucity of Data. Unclear Justification for Use of once-through Cooling Sys

ML19242B458
Person / Time
Site:	New England Power
Issue date:	07/30/1979
From:	Violet S CONSERVATIVE LAW FOUNDATION OF RHODE ISLAND
To:	NRC COMMISSION (OCM)
References
NUDOCS 7908080556
Download: ML19242B458 (3)

Text

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The (Consertration 3 Info founbation of Klebe i 3slanh 70 SOUTH MAIN STREET PROVIDENCE, RHODE ISLAND 02903 (401) 861-7550 S. Arlene Violet.

Counsel July 30, 1979 Comments to U.S. Nuclear Regulatory Commission Re: Draf t Environmental Impact Statement on NF" # 1&2 By: The Conservation Law Foundation of Rhode Island These coceents are in response to the Draf t Environmental Impact Statemant (DEIS) issued by the Nuclear Regulat.ry Commission (NRC) on the proposed New England Power (NEP) Units 1 & 2. They are submitted despite knowledge of the motion by Concerned Citizenc of RI (CCRI)

(7-13-79) for reconsideration of acceptability of the NEPCO application, in the event that a decision favorable to CCRI is not found.

CLF/RI's ccaments and questions encompass several points.

1. Although the statement claims a long-term negative impact on terrestrial and aquatic wildlife if the nuclear power plant is built, this assessment is made with a paucity of data on the ecological effects of thermal backflushing. On page 10-11, it is stated that such back-flushing will cause short (two hour) periods of elevated temperature up to 120 F either once or twice monthly. The hot water would be expected to mix rapidly with the Sound water as it i ' discharged, so to decrease the temperature. Also, the statement adds that organisms should be able to endure brief thermal shocks. This assertion is presented without supporting scientific data, as to how high a temperature might be withstood, or for how long. We would maintain that a two hour expulsion of 120'F water would pose serious ecological threats to marine life in Block Island Sound, and that further data is needed to disclose the actual impact on the system.

2. It is not clear under what justification the applicant is re-questing an exception from EPA to use a once-through cooling system.

This system does not satisfy the Federal Water Pollution Act guide-lines for best available technology, as it would pump water used for aCl D

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Comments to U.S. Nuclear Regulatory Commission July 30, 1979 Page 2 cooling back into the Sound with no controls. The thermal effects of this discharge on the ecology of the Sound, again, is not adequately discussed.

3. Figures from local and statewide polls are presented on pages c 50, 51, which show that more people both locally (in Charlestown) and statewide oppose the construction of NEP 1 & 2 than approve. No mention is made as to whether these opinions constitute a social impact which must be weighed in the final decision. We would maintain that public opinion of the facility would effect the working environment and effecient running of such a plant in this state, and should be considered a social impact in the EIS.

4 Rate rea tructuring is discussed to the point that the DEIS ad-mits that incen ives may be created to shif t use from periods of peak demand to off-peak periods, but notes that participation in such programs is optional. However, further duscussion of the potential benefits of mandatory participation in these programs should be considered as a partial alternative to building NEP 1 & 2.

In the same section, the statement clains that, while rate restruct-uring may reduce peak generating capacity, this would have no bearing on the need for base load generatiag facilities such as NEP 1 & 2. We feel that, should there become am excess in peak power, all..efforcs to divert that power to base load use should be made before building any additional facilities. The feasibility of such a diversion was not addressed, yet is a pertinent factor in the determination of the need for new facilities.

5. The Staff recognizes only two types of conservation which may affect demand for electricity: (1) voluntary conservation in response to higher prices, or (2) mandated government programs. First, this ignores less ' painful' conservation measures more easily implemented through consumer educatisr., such as use of insulation, reduccd wastage, and wise use cf appliances. Secondly, Even without conservation measures which could result frca such an educational program, the DEIS acknow-ledges the importance of conservation as an alternative to the NEP units.

"From this review, staff concludes that although mandated conservation programs are uncertain, if enacted they could result in significantly l alaying the need for generation capacity represented by NEP #1 & 2 beyond the period which staff has forecast in Section 5. 5.1. "( 5- 10 ) Such a delay could then make acceptable and timely the use of solar space and water heating (as discussed in Section S.2.3), which, without conservation, would not have been economically feasible at the time of need for NEP 1 & 2.

The option for empicying canservation measures until such time that solar technology is feasible and prudent, is implied to be a viable alternative according to the DEIS, if one correlates statements from two sections.

However, the statement fails to address this option as a comprehensive energy strategy.

{g 509

Comments to U.S. Nuclear Regulatory Commission July 30, 1979 Pg. 3

6. CLF/RI has entered the NRC hearings on NEP 1 & 2, on the grounds that the facilities are of questionable need, even without the aid of conservation measures. Utility forecasts of demand have proven too high when checked against figures of actual consumption. For one example, the 1970 peak load forecast for the 1973 NEPOOL system was 177. over the actual 1973 load. (Booz, Allen, & Hamilton, Electric Power Demand and Supolv in New Enzland: A Review of Trends and Forecasts, Jan. 15, 1975, p. III-3) As is further outlined in our Petition to Intervene, February, 1977, our contention is that excessive reserves will be produced in the mid 1980's in New England, due to overesticated peak loads, and uncertain demand forecasting.

Also, the DEIS recognizes (page 3-17) "from the standpoint of the applicant's required reserve margins, the NEP 1&2 plants are not needed for reliability until sor..etime af ter 1990 at the earliest."

The justification for al. lowing their construction for an earlier target date is that early operation eill substitute for the use of imported oil. This ignores the f act ..... excess reserves are a real possibility and therefore, that the NEP units may be unnecessary and economically unsound.

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