ML19210A585

Responds to NRC 670726 & 0606 Requests for Comments on Met Ed CP & OL Application.Discusses Potential Radiological & Nonradiological Effects

ML19210A585
Person / Time
Site:	Three Mile Island
Issue date:	09/26/1967
From:	Pautzke C INTERIOR, DEPT. OF
To:	Price H US ATOMIC ENERGY COMMISSION (AEC)
Shared Package
ML19210A584	List: ML19210A585
References
NUDOCS 7910300625
Download: ML19210A585 (5)

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4 UNITED STATES IN REPLY REFE 10:

• ' %c . . ? ' DEPARTMENT OF THE INTERIOR

. - I FISH AND WILDLIFE SERVICE

_ WASHINGTON, D. C. 20240 Mr. Harold L. Price b'EP OF E6.7 Director of Regulations U. S. Atomic Energy Commission Washington, D. C. 20$h5

Dear Mr. Price:

This is in response to Mr. Boyd's letters of June 6 and July 26 requesting Tur comynents' on the application by the Metropolitan Edison Company for a construction pemit and operating license for the proposed Three Mile Is-land Huclear Power Station, Unit No.1, Susquehanna River, Dauphin County, iennsylvania, Docket No. 50-289.

The proposed plant would be located on Three Nile Island in the Susquehanna River about six miles south of Harrisburg, Pennsylvania, and approximately three miles upstream from the York Haven dam.

Frincipal features of the station would include a pressurized water reactor designed for an ultimate output of 2,535 themal megawatts, a radioactive waste disposal system, and other on-site fac 'lities required for a complete and operable nuclear power plant. Cooling w ter requirements would be pro-viced for in three separate cooling systems: (1) a nuclear service system for all nuclear and fuel handling requirementa, (2) a secondarf system for all non-nuclear-related requirements, and (3) a condenser circulating water system for the main surface condenser and feedwater pump turbine condensors.

The condensers would be cooled with water circulated through two hyperbolic natural draft cooling towers. Makeup for tower evaporation, wind loss, and blowdown systems. will be obtained from the secondary and nuclear services cooling Water for the secondarf and nuclear service coolers would be ob-toined from the river and after use be mixed with the condenser cooling water prior to entering the towers. Blowdown from the cooling towers would be discharged to the Susquehanna River and used to dilute the nuclear vastes.

The intake structure would be provided uith trash rakes, traveling screens, icing. and a recirculating line from the condenser discharge to prevent The average during discharge of the Susquehanna River at the Harrisburg gauge the period 1890-1966 was 3h,000 c.f.s. During this period the meas-ured ficws varied from a minimum of 1,600 c.f.s. during a free::e-up of the river to a maximum of 7h0,000 c.f.s. during flood conditions.

A valuable sport fishery exists within the project area which includes blue-gill, crapples, walleye, yellow perch, bullheads, muskellunge, largemouth bass, smallmouth bass, and white perch. This fisher / receives heavy fishing 1492 021 N8@Q[M 4

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pressure and is one of the better fisheries occurring in the Susquonanna River. The Pennsylvania Fish Comission ouns land along Conewago Creek in the vicinity of York Haven tailwater outlet whien provides access and boat launching facilities.

Biological studies were conducted by the Fish and 'clildlife Service in co-operation with the States of Pennsylvania, New York, and Maryland, from 1963 to 1966 to determine the suitability of the Susquehanna River and its principal tributaries for the restoration of runs of the anadromous American shad. It appears from the studies that much of the river is suitable and thu,there is a good possibility that American shad runs could be restored to the river.

The application indicates that the release of radioactive wastes uould not exceed maximum permissible limits prescribed in Title 10, Part 20, of the Code of Federal Regulations. Although these limits refer to maximum levels of radioactivity that can occur in drinking water for man without resulting in any known hamful effects, operation within the limits may not always guarantee that fish and wildlife will be protected from adterse effects. If the concentration in the receiving water were the only consideration, maxi-mum permissible limits would be adequate criteria for detemining the safe rate of discharge. However, radioisotopes of many elements are concentrated and stored by organisms that require these elements for their nomal meta-bolic activities. Some organisms concentrate and store radioisotopes of elements not normally required but which are chemically similar to elements essential for metabolism. In both cases, the radionuclides are transferred from one organism to another through various levels of the food chain just as are the nonradioactive elements. These transfers may result in further concentration of radionuclides and a wide dispersion from the project area particularly by migratory fish, mammals, and birds.

In view of the above, we believe thet pre- and post-operational radio-logical surveys should be conducted by the applicant and include studies of the effects of radionuclides on selected organisms which require the waste elements or similar elements for metabolic activities. These sur-veys should be phnned in cooperation with the Fish and Wildlife Service, the Fe'deral Water Pollution Control Administration, the Ibansylvania Fish Comission, and the Pennsylvania Sanitary ;;ater Board.

If it is determined from the pre-operational surveys that, the release of radioactive effluent at levels permitted under Title 10, Part 20, Code of Federal Regulations, would result in hamful concentration of radioactivity in fish and wildlife, plans should be made to reduce the discharge of radio-activity to acceptable levels. Post-operational surveys should be conducted to evaluate the predictions based on the pre-operational surveys and to en-sure that no unforeseen damage occurs.

In view ofgthe importance of the present sport and commercial fisheries of the Susquehanna River and the future potential of runs of anadromous fish, 2 1492 022

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it is imperative that every possible effort be made to protect these valu-able resources from radioactive contamination. Tnerefore, it is recommended that the Metropolitan Edison Company be required to:

1. Cooperate with the Fish and Wildlife 3ervice, the Federal Uater Pollution Control Administration, the Ibnnsylvania Fish Cocais-sion, the Pennsylvania Sanitary Water Ecard, and other inter-ested State agencies in developing plans for radiological sur-veys.

2. Conduct or arrange for the conduct of pre-operational radio-

- logical surveys cf selected organisms in11[;enous to the area that concentrate and store radioactive isotopes, and of the envircnment including water and sediment samples. These sur-vcys snould be conducted by scientists knowledgeable in the fish and wildlife field.

3 Prepare a report of the pre-operational radiological surveys and provide five copies to the Secretary of the Interior for evaluation prior to project operation.

h. Make modifications in project structures and operations to reduce the disenarge of radioactive wastes to acceptable lvvel if it is determined in the pre-operational or the post-operational surveys that the release of radioactive effluent permitted under Title 10, Part 20, Code of Federal Regulations, would result in harmful concentrations of radioactivity in fish and wildlife.

5 Conduct radiological surveys, similar to those specified in

- recommendation 2 above, analyze the data, and prepare and submit reports every three months during the first year of reactor operation and every six months thereafter or until it has been conclusively demonstrated that no significant adverse conditions exist. Submit five copies of these re-ports to the Secretary of the Interior for distribution to the appropriate State and Federal agencies for evalu-ation.

vie understand it is the Commission's opinion that its regulatory authority over nuclear power plants involves only those hazards associated uith radioactive materials. However, we recouaend and urge that before the permit is issued, thermal pollution and any other detrimental effects to fish and wildlife which may result from plant construction and operation be called to the applicant's attention. Ue recommend further that the applicant be requested to discuss this matter with appropriate State conservation officials and the Fish and Wildlife Service and to develop measures to n W mMze these hazards.

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cw dj . __'d a Although coollng towers have been planned for enis plant, it u act sta.ted in the application what the temperature oC tae efnuent would oe.

Unless the temperature of the effluent 2.s near che temperaLure of tue receiving waters, there may be damage to equatic life. Increased '.;ater temperatures may not only be detrimental to fish life directly but also may affect these resources indirectly through changes affecting the en-vironment. Higher temperatures amMish the soluoility of dissolved oxygen and thus decrease the availa'oility of this essential gas. Tua 31evated temperatures increase the metabolism, respiration and oxyden demand of fish and other aquatic life; hence the demand for o:Uden is increased under conditions where the supply is lowered. Any thermal barriers that occur could adversely affect migration of anadromous fishes in the river. The thermal effects of this project should be ap-praised in combination witi. other proposed and existing nuclear and fossil fueled receiving plants discharging these heated effluents into the sans waters.

In view of the above, we believe that, unless it is determined tnat the temperatures of the effluent would be near that of the receiving atters, ecological surveys should be conducted prior to and following plant operation the river. to measure the effect of plant operation on aquatic life in These surveys should ~oe planned in cooperation witn the ap-propriate Federal and State agencies. If it is determined from the pre-operational investigations that the heated water or chemical effluent from plant operatica a be discharded into the river would result in changes in the environmeni that would be significantly detrimental to fish and wildlife, plans should be made to reduce the temperature of the effluent to acceptable levels. Post-operational surveys should be con-ducted to evaluate the predictions based on the pre-operational surveys and to ensure that no unforeseen damage occuas.

Another water potential hazard to fishery resources in the river is the cooling intake.

Unless the intake is adequately screened, fish, fish eggs and larvae, stroyed.

plankton and other food organisms, may be drawn in and de-The loss of a significant ramber of fish or food organisms to fulfill their needs at this point ny prevent the successful re-restablishmen'. of anadromous fish uo the river. Suitable fish protec-tive facilities intake structure. should be installed to prevent loss of fish through the In view of the Administration's policy to maintain, protect, and improve the quality of our environment and most particularly the vater and air media, pany to: we 19 quest that the Commission urge the Eetropolitan Edison Com-1.

Cooperate with the Fish and 'Jildlife Service, the Federal Water Pollution Control Administration, the Fennsylvania Fish Comission, the Ibnnsylvania Sanitary ' dater Eoard, and other interested State agencies in developing plans 1492 024 h

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for ecological surveys, initiate these surveys at least two years before reactor operaLion, and continue them on a regular basis or until it nas been conclusively comon-strated that no significant adverse conditions exist.

2. Keet with the above mentioned Federal cnd State egencies at frequent intervals to discuss new plans and to evaluate results of existing surveys.

3 Construct, operate, and maintain such fish protective facilities over the intake structures as needed to prevent significant damage to fishery resources.

h. Make such modifications in project structure and cperation including additional facilities for cooling diseaarge waters as may be determined necessary as a result of the pre-operational or post-operational surveys to protect the fish and wildlife resources of the area.

The opportunity for presenting our views on this proposed project is ap-preciated.

Sincerely yours, -) ,

• 'l d IP 1 k(b 5 d ClarenceT/ autzke i Commissioner i s

D**D "'O 33.1 S

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