ML20127J449

Comments on Fes Re Facility Operation.Modified Plan for Routing High Voltage Transmission Line Through Ebeneezer Creek Swamp Utilizing Taller Towers Should Minimize Impact

ML20127J449
Person / Time
Site:	Vogtle
Issue date:	05/15/1985
From:	Scott Moore ENVIRONMENTAL PROTECTION AGENCY
To:	Mark Miller Office of Nuclear Reactor Regulation
References
NUDOCS 8505210471
Download: ML20127J449 (3)

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} UNITED STATES ENVIRONMENTAL PROTECTION AGENCY byg REGloN IV 345 COURTLAND STREET ATLANTA, GEORGIA 30365 4PM-EA/CH Ms. Melanie Miller Division of Licensing U.S. Nuclear Regulatory Commission-

• Washington, D.C. 20555

Dear Ms. Miller:

Pursuant to Section 309 of the Clean Air Act and Section 102(2)(C) of the National Environmental Policy Act (NEPA), the U.S. Environmental Protection Agency (EPA) has reviewed the Final Environmental Impact Statement (FEIS) entitled " Final Environmental Statement related to the operation of Vogtle Electric Generating Plant, Units 1 and 2" (EPA Log No. F-NRC-E00004-GA). Our review of this project has primarily concentrated on water quality, noise, wetlands, and air quality. We encourage you to al'so coordinate with other agencies regarding any new or remaining environmental or non-environtaental factors.

As you recall, EPA's main concerns expressed in our comment letter on the Draft Environmental Impact Statement (DEIS) dated January 10, 1985, involved water quality and noise impacts.

WATER ~OUALITY/ WETLANDS Our comments regarding plant water quality (e.g., discharge; chlorination) have been adequately addressed in the FEIS. We appreciate your response efforts.

Regarding wetlands and water quality, EPA would like to emphasize the need to minimize wetland construction impacts in areas in or adjacent to the Ebenezer Creek Swamp, especially since the Swamp is designated by the National Park Service as a National Natural Landmark and as a state scenic river by the State of Georgia. Best Management Practices such as erosion control should be implemented with supervision and maintenance to reduce impacts on the water quality of wetlands. Access roads for construction should avoid filling wetland areas.

Use of any fill should be minimized and coordinated through the Savannah District of the U.S. Army Corps of Engineers relative to the need for Section 404 permits. Any permanent sloughs and water channels should be crossed by bridging or open-bottom culverts adequately sized to accommodate the natural flow.

Silt curtains should be employed at waterway crossings during construction. To minimize additional clearing, existing logging roads should be used whenever possible for access roads. In addition, for areas in or adjacent to the Swamp, we would prefer mechanical means used for any necessary right-of-way bV C"oO 8505210471 850515 PDR ADOCK 05000424 $(), 23I I9 D PDR

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maintenance. Any-herbicides used should be EPA approved and applied in.accordance with label directions. If herbicides are anticipated, the FEIS could have been improved by including the specific herbicides that will be used (e.g., X chemical, a registered-herbicide, will be used at X lbs. active ingredient per acre / roadway mile for plant control).

EPA' believes that the modified plan for routing the high voltage transmission line through Ebenezer Creek Swamp utilizing taller transmission line towers should minimize the impact on the Swamp compared to the original alternative to clear-cut a 150-foot corridor. We encourage the use of a helicopter / crane to install towers in wetland areas to reduce access clearing, as indicated for the_ tower at Station 124.00 on page 5-3 of the FEIS.

NOISE In our comments.at the DEIS stage, EPA recommended that feasible mitigation measures for an off-site residence be considered by the applicant and the U.S. Nuclear Regulatory Commission (NRC) since the residence is predicted to be elevated 12 to 20 dBA by the transmission line. Although we acknowledge that the FEIS (pg. xi) states that "The application will be required to report annually in the Environmental Protection Plan any noise complaints received related to_the high voltage line and their resolutions,"

EPA remains concerned about noise mitigation for this hone

. site since no mitigation measures are listed for implementation (methods for resolving general complaints are also not presented).

We believe the expected 12 to 20 dBA elevation is significant, despite the fact that the resultant noise level is a moderate 49 dBA L10 (however, this is equivalent to 58 dBA in terms of intrusion and annoyance when evaluated against standard criteria, according-to page 5-70 of the FEIS). Although we recognize that noise mitigation can be difficult and expensive, that only one receptor is involved and that. noise levels are usually worst during precipitation periods and shortly thereafter, some relief ~ should ultimately be - provided -(unless the resident does not wish any mitigation).-~In our view, such. relief should be initiated by the applicant-and/or the NRC.(even if no formal complaint is received)-and should-be mutually acceptable to the resident and applicant /NRC.~ ' If a barrier wall is not feasible or functional,1then receptor' acquisition, receptor insulation (if' noise. levels _within the residences have' increased by 10 dBA or more), installation of central air conditioning in the residence (if not already so equipped), noise source reduction, or innovative methods should be censidered.

In addition to requesting noise mitigation, we offer the following noise comments:

o Since. noise from transmission lines is associated with wet periods,.the FEIS could have been improved through the addition of an estimate for the number of days in a year such~ periods exist locally.

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, o Assessment of 'the noise' impact of'the transmission line

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?* couldlprobably be improved, since Figure 5.22 and:5.24.. -

indicate that the nearest. ambient monitoring stations are rather distant from the.above-mentioned home site. We

, recommend that' additional ambient noise measurements'be:made along the transmission line (particularly near the home

> site) to predict noise impacts to this and possibly other receptors. . Determining the need for nois'e, mitigation depends

'on-such~ measurements,

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o We recommen'd that on-site noise monitoring measurements'be

-made after implementation of noise mitigation methods to assure noise attenuation.

We were' pleased to review the FEIS. With the exception of the remaining noise comments.and request for noise mitigation, we believe the~FEIS is generally a well developed document. We will look forward to your comments and request that they (at.

least comments regarding noise mitigation) be referenced in the

- . " Record of-Decision. Should you have questions, my staff contact for'this' project is Chris Hoberg who is available at FTS/257-7901 or commercial 404/881-7901.

Sincerely yours,

'She ed bih rd-N. Moore, Chief;

-NEPA' Review Staff Environmental ~ Assessment-Branch cc:- Mr. W.- Thomas Brown Associate Regional-Director Planning and. External Affairs U.S. Department of:the Interior National Park Service Southeast-Regional Office 175 Spring Street, S.W.

' Atlanta, Georgia 30303 L Colonel Daniel W. Christman

. District Engineer U.S. Army Corps of Engineers, Savannah P.O. Box 889 Savannah, Georgia 31402 Mr.'Edwin M. Eudaly Acting Field Supervisor U.S. Department of the Interior Fish and Wildlife Service ^

Federal Building .

'N 810 Gloucester Street- ,

Brunswick, Georgia- 31520- <

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