ML20062L294
| ML20062L294 | |
| Person / Time | |
|---|---|
| Site: | Allens Creek File:Houston Lighting and Power Company icon.png |
| Issue date: | 01/15/1981 |
| From: | Doherty J AFFILIATION NOT ASSIGNED |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| ISSUANCES-CP, NUDOCS 8101270289 | |
| Download: ML20062L294 (12) | |
Text
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1 UNI?2D STATa3 C7 ?Ji2RICA Jan./S p(984 !
NUCLEAR REGU~LiTORY CC?U4ISSION / NV 9,
N l 327022 TH2 AT::IC SAFITY MID LICE:!3I"G BOAEJ s, '7 I.& 7
) i In the flatter of: ) @ 9 @g\ et: '
ECU320'i LIGHTI:TG & OC'd3R CD. ) l4
\ bq .a ?' #' '
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(Allens Creek Huclear Genera- Docket No.30-466 %G e% i '.
ting Station, Unit 1) 'N 3
) '0
) 8i JOHN F. DOHERTY'S CONTENTIONS # 51, 52, 53, and 54.
John F. Doherty, Intervenor pro-se in the above Construc-bion License proceeding now files these contentions in response to Staff's release of UURZG-470, Supp. No. 2, " Era 't Sunnlement to Final Enviroamental Statement related to -he Constnction of Allens Cree': Iiuclear Generating Station, Unit Fo. 1", (hereafter:
Draft). This docuaent was available according to Staff on De: caber 17, '930. Hence Int 1rvenor has treated his o': 14. 7a t io n tc file Contentions based on the Draft as granting his 30 da7s from December 12, 1980. He furth3r bases his right to file these, on new information provided b.7 the Draft. The Boad in ite 7rder 6f December '7, '930 (Ps.2 ), stated, " Staff _
s'vi. sed that the second sun.lemeat to the FiS .o' lid be issued '
07an (T2. '3*?-15) nd tha 3 cart observed 9.nd Staff agreed that said issuance nicht ':3nerate a-endaents to sanitio .s to iatervene..." (Tr 1818).
C;;iTEXTION 51 ,,,
x g, -
Intenenar contends that for the reasons list 3d below the Site lesien stei Li-3 in the Jraft is a superior site, with less environmental imoact for the same benefit,as the site prdposed b7 .ipplicant in fallis, Texas. Hence, said Li-3 site must be to used for the proposed boiling water reactor ^ fulfill the aims fg o f the National Environ = ental iolic;- Act (I; EPA). Intenenor W ko s does not contend Onat necessarily each of the below reasonbny#[
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is sufficient to conclude the Li-3 sit,s is environ =entallg; N, Mo n.
sup3rior and hence preferable, but that a combination cf;hli,, ,y'o/9h or co=binations do so. .g In$cy, 6 g,\ M d 4 '-~w '
510127o929 A
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Contention SS1 (Parts t'a) to ( c)) l (a) Intervenor contenis there is no significant difference in the amount of dissolves oxy:;en in the Brazos River at Rosharon and Trinity 2iver at Roma7or accordhg to 1979 figures from U. S J-nartment of Int 3rior Recort: fator Ren urces Data fnr Tazas, 70lume 2 (Page iO4, for Brazos River) and Volume 1 (Page c?8, for Trinity River). The average nonthly difference for 1979, is but 15 millirrams/ liter and this difference is not sufficient to use in an7 determination of difference in environmental impact of a BWR system operating on either ,
river for the ACMGS or Li-3 site.
(b) Intarranar coats ds Staff errod by comparing 3razos River
- ualic7 in its current coadi;ian with Trinity River water quality in ccmoaring the ACI!GS site to tha Li-3 site (Drnft, Table 0.'1, Page 2-61 ) . This is bacnuce (particularly rich rerard to Chloride) the 3ranca 2iver will be further deteriorated by blaciden from the Commanche 7eak Units I and II, bl:w'own c37 ting la'.:e water. Impact on water cuality .:f the .J.:GS on the Brazos River will be nore severe because the threshold of iclerance for chloriies and heavy metals in much of the aquatic life of the Brazos will be exceeded unlihe the Trinity liver uhich is at this point of better qtclity and less close to the tollarance thrasholds for chlorif.es and heavy metals.
(c) Intervenor contends Staff has underestimated the survival ability of the Trinity Ba7 and Galveston Bay shrimp to both water emnerature changas and increased salinity, (Draft,, Page ?-32).
In Biolemical 3u11etin, 129 ('965),199-215, " Growth end Sur-viral of Penneuc aztnets under Controlled Caudizie:.s of resper-ature and Salinity", Coin-Elden and ..ldrich concluded, " Salinity nar ne had little effect on either survival or growth at extreme tenperatures"(Page 215) for this shrimp species, thich along with Penaeus setiferus make up the ca.jority of shrimo harvest in the bay ccmple:: to which the Trinity River ficsia.
(d) Intervenor contends 5'affc has unde estinate" the survival ability of the syster (Os rea vircinica) from c iances in salinity.
caused b7 ' tater loss to Trinity 2iver estuary fron the-operation of a 3'dB at the Li-3 site. In Bu'.letin of the 3urosu of Fisheries, No. 21, ( U. S. Department of Jammerce, 9935, "Alaptation of the .
reesing n..echanism of the Oyster (Ostraa ci: as) to chances in I
Contaction 491 (Continued) Parts (c) to (t)
Calinity", <936, A. E. Hophings concluded this soecies can adapt to a rise in salinity r27til7 but more slowly when salinity decreases (2.363) and tolerat:s salinity as hirh as 3Tt carts 7er m_lle. Tha author believet this research ap'licable to Ustrea virrinica (Ibid. 2. 3a3). Acccrdingly staff's decision that intacts on spa >ning or nur-sery grounds, water quality and to "important" ar,uatic biota should be changed to favoring the Li-3 site due to less impact. (Note:it is inocsaible to determine if this issue applies to all three of these areas of aquatic ecolo y or less, so Intervonor has chosen to anp17 it to all three.
This is becauce there is co .siderable lack of clarity in where the dividing line for these three nrcas e:cist. It is carticularly difficult to separate "Inpacts en spawning or nurserg grounts" fron "inpacts to 'inportant' aquatic biota".)
'd) Intervenor contonic Staff has erred in its Occclusion with regard t3 the inoact on the nursery grounds of the An3rican oyster, Crassstrea vir-inica Onelin, caused bv cancu:7tive water loss caused by ::aration of a 3dR at the Li-3 site, thi:h ect1d be i_. Trinit: 111~3alvestan
?ays. In Tec.c.ical daries '2:7:rt) p2a, 2rer's ia 70,-
ulation Levels of the Aacricun Cvster. pub".ished by the Texas Parks a dililife Department (1977) p. iii, R. R.
Hofstetter, recorted, "Although more spat (Hote: 37at cre 'rnun o rster or ot'1er bivalys 2:11ust) set i. fears of abava nornal riv7r flori, curviv7.1 is bet;e .' ten river floe- is belov normal. In ' wet' years about 3556 af tha s7at survive tc market 0rster size comra~ci to 17; surviving in dry years.C (e) Intervencr contends the cctagory "Inpacts to coa.rning er nursery grounds" in Tabte 2.11 (Draft Ps. 2-61) should not be " ", but "+" in accordance eith Technical Series (Report)
- 24, " Trends in Foculatio.t Levels of the American Ovster,
Conteation #54 (Continued) Parts (e) to (h )
published bv the Te/.as Pe.rks & ilililife Department (1977),There (c. . 26) R. R. Hofet,ecter, reportad, that these o7 ster (Crass-ostrea vir-inica Gmelin) spawn . tith a tenpercrure rise such as wou'.d occur or be aided by the thornal dischar:es to the to the Trinity Eav and Galvestoa Bay from the Trinit7 River from a nuclear plant at Li-3 site.
(f) Intervenor contends Staff has presented no information that niE ration of an7 aquatic species will be impacted by location of a BYR of ACUGS capacity at site Li-3, in the Draft. Ther3 fore Staff's conclusion in Table 2.11 (Draft 2-61) that the '.C"7S site 'lill have less innect to " feeling ereas or airration r:utes" is unsu ported ani should s'.ou otharvise.
(g) 3taff's ccnclusica the e:'fect o f onerati3n of Li-3 on Trinity River vould be greater than the effect of operation of a sane-ca'acity BNR on the Bras:s River has led it to e; c'_uie Y.e aquatic habitat -uality louti 52 ;reat:r innac-ted. ::o isv?r. nollutioc. on the 3razos River is "li 2t to toderata" as ialicated be specias divorsity, ( J.pplicant 's ZR, Appendix 3, pg. 4-33). The Trinity River is described as moderate 17 nelluted (Draft, 3ec. 2.3.2.2, Zage 2-31).
3ince no such reocrts are referenced for Trinity River, 3taff shouli htv3 co :cluist such a difficult con 7arison on habitat ~uality coul" not be nade, ani iniicat31such in Table 2.11 of the Draft.
fh) Intervenor contends Staff has erred in concluding that a detrimental onv5 ronneatal in7act to "Incortant" ac,uatic biota will Sc;ur (Draft 2-32, and Tc',le 2-11, _z2c.:e '-61 ) if salinit of Galvestoa 1_ nn3 Trinitr 327 is increnssd as a result of o7eratir.n of a F.!R at the Li-3 site. A stud-bv the coactiti^g enrineerinr firm of Lockwood, 1nirews and Ne'ina.n Inc. for tha Texts Mater Developnen Board (1366), ,
titled:A New Concent: :!ater For Preservation of 3avs and 2ntuaries, concluded that for Galveston 3a7, the State of .
1 Texas shoult, " Enlarge Rollovar ? ass at the east end of Zast !
Contention #51 (Continued) Parts (h) to (d)
Galveston Bay to improve circulation and increase salinity (P.33, emphasis Intervenor's). Accordingly conclusions shown in Table 2.11 of the Draft should be revised iith regard to "Imoacts to 'iscortant' aquatic biota" and other catagories where increased salinity due to the operation of a BWR at site Li-3 were included as part of the environmental impact.
- 1) Intervenor contends " Freshwater flow" for the Li-3 site .
(Draft, Table 2.11, Page 2-61) should have been . judged "+"
or "0", not " " because the Final Supplement to the Final Environmental Impact Statement (? age 3 3-3) states only that the intake flows for ACNGS (a single unit) will be less than 10% during low flow conditions, .ihich is not significantly different from the statement in the Draft (Page 2-32, Sec. 2 3.2.2) which states during low flow conditions Li-3 will require 9-115 of the river flow.
Waterflow at the Li-3 site (Measured at Roma or, Texas) for the Trinity River and at the ACliGS site (Measured near Rosharon, Texas) are close to the saae. For the Li-3 site average flow for the Trinity River (Regulated by the Livincstone Reservoir) from 1069-1979 was 7,528 cfs, and for the ACEGS site average floei for the 3racos River
- from 1963 to 1979 was 8,017 cfs. (Data from: Jater Resources Data for Texas, U. S. Department of Interior, Geological Sur-ve7, 1979, V 1umes I and II, page 597 and rage a73 respectively).
j) Intervenor contends Staff has underestinated the environmental i=cact to vinter feeding habitat for waterfowl by indicating the renoval f 5,270 acreh of land at AC::GS is cerely equal to the removal of fee'_ing habitat lost b7 construction at the Li-3 site (at nost 6a0 acres). See Draft ( 3ec. 2.3.1.2, Page 2-20 and Sec. 2.3.2.1, Page 2-27) Intervenor acccrdingly maintains Table 2.10 should indicate "less ic'act than at Allens Creek" with regard to terrestrial habitat.
Centention 51 (Continued) Parts (k) to (m)
(k) Staff has underestimated the ability of the species Brevoortia oatronus (Gulf Menhaden) to tollerate salinity and high reaperatures in the Trinity Bay and Galveston Bay.
In Fishor7 Bulletin, 77(4), 1980, a publication of the U. S.
Department of Commerce, iTational Marine Fisheries Service,
- 3. P. Ferraro in " Embryonic development of Atlantic menhaden, Brevoortia tyrannus, and a fish embryo estimation method,"
~
observed salinity between 10% and 30% had no effect on embryonic mortality and no noticeable effect on rate of development. Temperature was significant below 15 C. only.
Although the common Gulf menhaden is bravoortia catronus, Intervenor contends this species is sufficiently similar to the study'~s species to establish a nexus for the con-tention, and that Siaff's concerns expressed in the Draft
( Sec. 2.3 2.2, ' page 2-32, and in Table 2.11, page 2-61) uith. regard to "I: pacts to soawning and nursery grounds" are incorrect.
(1) Intervenor contents Staff errod in its cenclusion environ-cental impact on terrestrial species from ooeration of a BWR at the Li-3 site would be the sase as that of'the ACHGS on "Thraatened or endangere:1 species" (Draft , Table 2.10, Fg 2 53). The Final Supplement to the Final Znvironmental Impact Statement, 1978 (Table S. 2.5) lists six species from the " Endangered and Threatened Wildlife and Plants" of the Department of Interior of 1977, for ACNGS, but the Traft mentions but a single species, the alligator (Pg. 2-31).
Eence, Intervenor contends the Li-3 site will have less 17act to andangered or threatened terrestrial species from an operacing 3iiR and its construction than the inpact of the proposed ACIIG3 on its site.
l (m) Intervenor contends that since the coeling towers for l
1 l the Li-3 site will accomolish the same task as a cooline l l
lake for the AC:!G3 site, these two different cooling systems l
must be coroared for "onsite i: pacts," (Draft, Table 2.10,
(
l ' age 2-$8). Intervenor contends the use of circular mechanical l
l draft cooling towers as described in ITUR2G-0574, " Final .
?
Contention 51 (Continued) Parts (m) to (0) l Environmental Impact Statement Related to selection of the preferred closed cycle cooling system at Indian Point Unit no. 3 (Dec. 1979, Sec. 2.4.3.31 at the Li-3 site would have less environmental impact on Trinity River than a cooling lake at ACNGS, because of less land use, less visual impact, less loss of habitat for protection of terrestrial fauna, and increased availability of land for residences.
(n) Intervenor contends Staff has erred in its calculations of the amount of land to be taken for powerline trens-ission right of ways for the Li-3 site. Using 63 miles (Draft. Page 2-29,)
transmission line length, and using typical right- of-way width froa Table 4.1, (Pg. 24) of Mana ement of Transmissio3,_Line Richts-of ~ day for Fish 2nd :lildlife, Vol.1, U. S. Depart . tent of Interior, Fish a 'liidlife Service,1979, the typical right of way for a 345 kv line is 150-170 feet or 13.2 to 20.6 acres cer mile. Staff used a 200 foot corridor without explaination to arrive at 1,524 acres removed for this purpose. Staff has required 378 acres unnecessarily in its calculation for the Li-3 site. Using a 150 ft. corrider the Li-3 site will require 750 acres less than than the ACNGS. Hence the offsite intact of transmission line corridors for Li-3 site will be less -
than the^ impact for a nuclear plant at the ACHGS site, which should be reflected in Table 2.10 of the Draft.
(o) Intervenor contends the Staff has erred by not considering the possibility cf meander cut-off (as a result of flooding) on the 3razos 2iver at a point arproxi.rately . 1 miles upstream fro.n a point marked "31" in Figure S. 2.3 (Page S.2-8) of the Final Supplement to the Final Invironmen al Impact Statement.
(The transcript of the 2:e-hearing Conference pp. 984-989 covering a Bishop Centention has more on this;.its date is 10/16/79)
If the river takes this new course, construction of a pipeline to the make-uo pumphouse in excess of two miles would be re-quired. In addition, a mile of piping from the spillway to o
~8-Cant 8ction 51 (Continued) Parts (o) to (c)
'ile"Brazos, t wonIt probably b's required unless the prior anillway were closed and a.new one constructed. An addi-tional ccat would be down tine of the ACliGS, caused by low cooling pond water level while the new nake up piping and other facilities were constructed. Intervenor contends failure to include this in the comparison between Li-3 " makeup and discharge pipeline" impacts (Draft, Table 2.10, Pg. 2-58) and ACNGS was in error and that the Li-3 site is equal to or superior to the ACNG3 site with regard to environnental impacts from this feature of the two EWR plants.
(p) Intervenor contends Staff's conclusion "In-migration" (Drnft, Table 2.12, Pg. 2-64) will have a greater impact on the Li-3 site than in-migration on the ACNGS site is not denonstrated by comparing the text in the Draft (Sec. 2.3.2.2, page 2-33) which pertains to Li-3 and the text in the Draft (3ec. 2 3 1.2 ,Pg. 2-24)which pertains '
to the ACUG3 cite. 3ecause of this, Staff's only conclu-sien options are that the two sites are equal, uncertain, or that the Li-3 site is superior in tcis socioeconomic characteristic.
(q) Intervenor contends the continued westward growth of Houston residential districts which result in increased populations as reflected in tastimony of Aoplicant's witness ~:lilliam T. inite, submittei on December 18, '980, to these ?roceedings,shows that Staff's conclusion the the intact of the proposed 3HR on the ACNGS site denography will be equal to that on the Li-3 cite (Draft, Table 2.12, Page 2-64) is in error because current land use patterns and population growth patterns both present and emerging
! indicate the appearance of the ACNGS and its cooling lake will impinse a dapidly growing residential area, where on the other hand the land use andpopulation patterns at or l
near the Li-3 site indicate little recent changear emerging pattern changes.
t
~
9-j Contention'51 (Cont.) Parts (r) to (~t)
,,(r) .Intervenor contends Staff erred in deciding the nimpact on the site democranhv of the ACNGS would be equal
- .to that at the site of Li-3 This is because staff did l not consider the imoact of having a 200,ft tall reactor '
l l building and associated' structures dn the; conduct of
,the " Concentrated student det pilot, training areas ,
[(w'h ich) are located oE I4atagorkia' ' Island and directly "to' the north of I4atagorda Island-,"(Draft, Pg 2-2: and Figs. 2.2, pg. 2-5, arid Fig. 2.6, pg. 5-11) . The plant
~ ~
and its cooling lake both offer severe'hasards to such l trainees in the event of emergency landings or other student errors in the form of collision; drowning'or other injery or damage which would not ' occur if the i l
terrain of the ACNGS site were not disturbed.
(s) Intervenor contends the Staff erred in concluding' a BWR of the proposed capacity at site LI-3 would have greater impact than a replicate BNR at the ACNG3 site with regard to impacts on spawning grounds and to "impor'-
tant aquatic biota" (Draft, Table 2.11, Pg.2-61). The in-( pact of increased salinity from this location would improve osmore.rulation of mature female crabs (Callinectes sanidus Rathbun), because this species does not function as well '
in'this stage of its life cycle in low. salinity, as repo.rted in' Technical Series (Report) #1, A Contribution to the Biolorry of the Blue Crab in Texas, Texas Parks & Wildlife Department, 1969.
(t) Intervenor coctends the Staff erred.in concluding a BWR of.the proposed canacity at site Li-3 uould have greater impact than a replicate BWR at the ACNGS' site with regard to impacts on " habitat quality" and " feeding grounds" (Draft Tablet 2.11, Pg. 2-61). It has been shown operation of a plant at'Li-3 would increase salinity in the. Trinity and Galveston Bays, yet,;for productivity of a wide varie'ty of detritus ,
food for various aquatic creatures,'"Only under extreme con-ditions, i..e. in hypersaline waters, does salinity seem to
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This war su:yes;e 1 in Iw..'Mn o f Ern..cairni 7:' ti.aen on
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The use of l titi ation of t' ic 'a rm facul. - 50 cxcidured />r the Je-3 ani Ho-3 citac See:us? of the Cr.:ac ;i,yi ci . ce attached to locating a E'.F.! of the uro,' sed car.ucity ' lit.'.i re ar-i t; t"ci r orctirr.mentcl 17 ' acts ca terre- tri.nl oc . ' o -" thrm h the trr: 'cmiccion liaec re-uirei.
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1 CJ TE TIO:' 54 The Drnft, which comparen for tha "irst "ine the nocio-economic connenuencon of conntruc' ion of 'b' nroroneu s+ntion n' +"O O~!? ri'e with the consequenem' of c onn tru e '. i cn n' the Allenn OreM< ni'c han unrennonabl:/ cor.cluded 'hn' 'he 1 pact of in mi~r"* ion o' "torkorn n? the .C: ; 3 ni Po will i>e lann 'b'n '- +"e li':IF ni'e and the En-1 ni'O. Cea b l e 2.12, nom 2-64 h i r is wenure nfP han <mmed "no workern on 3T'!? ! and 2 vill ra-ain in *he r n 'o work or a thiri uni' at STNP". As of December 31, 1979, STNP #2 was-17% constructed and STNP #1 was 525 completed , and fuel loading was planne'd for STNP #1 in 3ept.1985 and for STUP #2 in April 1985 accordin- to NUa20-oo30, Vol. 3, #1. Delays have since occured.
In ta r~nor c ot: ter. .n in-mier, tion will hocr" : - innne t ('from the above) at S*MP nnd *.'a-3 lendiner to the cor.clusion thn * .o'h i n - 3 ' r. 't S".'!F are nunerior ni'.er in in-migration impacts and that given S*nff'n o+her 'indinen ./ith re cn rd to STNP, that sit'e is a numerior mi'o 'o "SWG1.
Copies of: "JOHU F. DOHERTY'S CONTENTIONS #51,52,53,and 54,"
were served on the parties below this /fJ" of January, 1981 at Houston, Texas.
Sheldon J. 'dolfe, Esq. Chair, ASLB; Gustave A. Linenberger, Administrative Jud.Te, Dr. E Leonard Cheatum, Esq., Administrative Judge; Richard A. Black, Esq. for Staff; Jack R. Newman, J. Greg-ory Copeland, Esqs. for Applicant; Atomic Gafet? Licensing a g Appeal Board, Richard Prioster, Susan Plettman, for State of Texas; and Docketing & Service Branch, N.R.C.
lespectfully Submitted,
.ohn F. Doherty, Intervenor
.