ML20099D581
| ML20099D581 | |
| Person / Time | |
|---|---|
| Site: | Salem  |
| Issue date: | 05/07/1973 |
| From: | Arbesman P ENVIRONMENTAL PROTECTION AGENCY |
| To: | Muntzing L US ATOMIC ENERGY COMMISSION (AEC) |
| Shared Package | |
| ML20099D115 | List: |
| References | |
| NUDOCS 9208060178 | |
| Download: ML20099D581 (2) | |
Text
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50-272 50-311
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- '.r. L. Manning P.untzing NJ / l' -y 'O,.c.'.r Director of I agulation
%.O.1 U.S. Atcmic Energy Commission Washington,'D.C.
20545
Dear Mr. Muntzing:
pp..y in our previous review of the draft envircrmental impact statement
' for the Sale" i:uclear Generatinc Station Units 1 and-2, we raised several$ulitionsconcerning-edverseenvironmentaleffects. Generally l,
the responscs to these questions in the final statement fall short of providing ccTplete answars to the quest:ons and of guaranteeing that af the effects will be minimize:i.
The final environmental impact statement (EIS) is not conclusive tM -( -
as to whether operaung procecmmfill be implemented which will reduc ~e
. liquid radioactive discharges to "as low as practicable" levels.
If-the-plant technical specifications designate annual releases not
=to exceed those listed in Table 3.2 of the Final Statement, the environ-Such re-mental impact frcm this-source is expected to-be very small.
leases could be censidered "as lcw as practicable" and representative of'
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M However, if the technical speci.
.the limitatiens of current technology.
p$4 ficatiens allow releases to the limits of " existing regulations" (page Allowing such 3) discharge cuantities could be significantly larger, specifications would_ not represent full-utilization-of the stated capa -
my bility of the system and could not therefore be considered "as icw as L
It'is recommended that the former course be followed.
n practicable."
In accordance with Section 303(a) of the Federal Water Pollution inna Control Act-trendments (UPC/A) cf 1972, presently adopted water quality
~ tandards of the State of Lcw Jersey have been reviewed and their revi-Such revisions include those standards applicable s
sion-requested by EPA.
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The recomnended revisions include the to the Delaware River estuary.
following thermal allowances:
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No heat may be added, except in designated mixing zones, which would cause temperatures to exceed 85*F., or which would cause the monthly mean of the maximum daily temperature at eny site, prior tc the addition of any heat, to be exceeded by more than 4 F. during Septer.ber through May, or more than 1.5 F. during June through August. The rate of temperature change in desig-nated mixing zones shall not cause mortality of the biot 3 2.
As a guideline, mixing zones should be limited to nn more than
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1/4 of the cross-sectional area and/or volume of flow of stream or estuary, leaving at least 3/4 free as a zone of passage.
"" ' l The Delaware River Basin Commission (DRBC) has assigned a mixing I
zone for the thermal effluent of the Salem plant bat,ed on surface 4
distance frem the c'ischarna.
The applicent's enclysis of thermal iepact presented only surnce isothcrns in accordance with the DREC tj mixing zone designation. The raco:rrani d revised standards, however, call for the analysis of thermal effects on a two and/or three dicen-
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sional basis (cross sectional area and/or volume of flow). This will necessitate the reanalysis of the applicant's data to include stirface and depth tcrqcrature profiles in order to determine ccmpliance with 6
revised standards.
This type of analysis should be provided to EPA for our consideration in issuing a discharge permit for this facility.
Sincerely yours,
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L Paul H. Arbesman Chief
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Environmental Impact i
Statement Branch L
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19 Mr. L. Manning Munt ing (s-7'":,,73 'g Director of~ Regulation
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20545
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Dear Mr. Muntzing:
y We have reviewed the final environmental impact n
L statement for the Indian Point N_o. 2 nuclear power plant
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-and have identifie'd severe.L major concerns which have not
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.been. resolved.
Our detailed comments are enclosed.
. In general, tl.a final. statement is. commendable in
'p9 its identification of the possible environmental impacts I
from.the full power operation of the Indian Point No. 2 employing the proposed once-through cooling system.
As indicated in our comments on the draft statement, however, this= operation may well lead to a violation of New York State's' water quality standards with regard to thermal
. loading, dissolved' oxygen levels, and biological damage, ljiL
'As a-consequence, we note that the AEC is.now requiring i
the applicant -(Consolidated Edison) to adopt a closed-j %p' _}AlL cycle cooling system in order to reduce such impacts and' comply with the applicable' standards.
We understand
'that it is the intention of the AEC that this system be h..
installed by,1978.-
Although we support..the adoption of a closed-cycle system for Indian Point No. 2, the Federal' Water Pollution Control.Act Amendments (P.L.92-500), recently passed by Congress, sets July 1, 1977, as' the latest date for the
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installation of best practicable-control technology for all point sources.. Thus, in the event that. closed-cycle
-cooling is required as best practicable control technology under Section 301 of this Act, we recommend that the AEC 3
and EPA staffs meet to develop a schedule for installation of 'the closed-cycle system which meets all rdquirements of P.L.92-500.
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' In a'ddition, we are concerned about possibic impacts during the period of operation prior to completion of the closed-cycle _ system (i.e., the period when the Indian Point No. 2 plant may be operated at, or near, full power using-the proposed once-through cooling system).
During this period, the AEC staf f predicts that a " sizable damage" to aquatic biota will occur.
We agree with this assessment and recommend that every effort be made to reduce _these impacts to a minimum.
This is particularly critical when such impacts are considered in conjunction with the possible cumulative effects of other plants
[*1 which are operating (or planned for the near future) on the river near.the1 Indian Point complex.
In our opinion,
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when'these combined impacts are considered, the " sizable l,
damage"'may indeed prove to be irreversible.
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'In this regard, we believe that it is likely that
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. plant-operation-during the interim period may need to be restricted to the degree-appropriate to provide adequate t7 protection for aquatic biota.
This possibility prompted-
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ourl request in comments on the draft statement that the expected " environmental damage for various levels of power L
output be included ~in the final' statement.
Although this information was not provided, we request that it be made available to us as soon as'possible in order that the necessary discharge permit can be conditioned to protect the aquatic' biota in-the Hudson River.
We will be happy l,
to meet with you'or members.of your staff ts accomplish m.
Jr this task..
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Should'you have.any questions concerning our comments,
+j please contact:Mr. Sheldon Meyers, Director of EPA's Office l"[*
of Federal Activities.
itw Sincerely yours, V _v Robert W. Fri Deputy Administrator-
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Enclosure G
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Water Quality and-Biological Effects Effect on the biota:
a.
~ The final statement describes a potentially enornious effect on the biota of the Hudson River.
However, it i
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is stated'that, "The staff assessment indicates that, a
during the_ short term (up to about 5 years),
rej-l u u-sizeable damage to the aquatic biota will-occur but f,
~it.is not expected-to be irreversible."
In doing such 1
w Lan. impact analysis,.it is necessary to consider the t
tn fact that by'the end of_the-five-year period, other
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-jh (generating stations in the area (currently under construction). will be operating with the result that the " sizeable" damage'may-prove.to be irreversible.
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1These other-generating stations are:.
Iw iMlh (a)l Indian 1 Point #3, on-same-site 7
jy (b) Danskammer -- 23_ miles. upstream (c)- Roseton numbers 1~ and = 2 -- 22 miles upstream ansa
--(d)4 Lovett -- 1 mile downstream
. e) Bowline numbers.1 and 2
---5 miles downstream
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All indications are that many Hudson River species in o
,the region of Indian Point are: fast approaching their tolerance limits with respect to thermal and mechanical Further operation of ence-through cooling
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7 systems, in conjunction with new additions (such as l
B u ine 1 and 2), may exceed these limits with obvious results for stream biota.
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Thermal considerations:
The AEC expresses doubt thu* thermal conditions p>
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caused-by operation of Indian Point #2 will meet existing
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state regulations.
Regulations allow the 4 degree
}h; isotherm to extend 2/. of the distance across the river; e
w;c the AEC estimates that under transient peak tide k~
conditions, the isotherm may extend the entire distance across the river.
If this estimate is correct, opera-
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' tion (at least at full power) of Indian Point #2 would n,
violate New York State proposed regulatione.
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The final EIS thoroughly reviews the history of New ws
-York State's Thermal Criteria.- However, on page III-ll,
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the EIS states that EPA recommended a specific revision
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.to the regulations on thermal discharges regarding 1
estuaries.
EPA in fact said, "...that the July 25, 1969 criteria adopted by New York State with changes as j
recommended by a majority of the Federal Thermal Task i
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Force members would be approvable."
EPA's current
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i opinion was expressed in our comments on the draft
'EIS andl appear in Volume'II of=the final on pages i
-1 : 30.,.These comments represent our current position l
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-RADIOLOGICAL EFFECTS
.Due.to the fact that there are multiple units planned tjupvig.
' 0' for the Indian Point site and-because of the impact of 4 ';, M -
the discharge of radioactive material, particularly the IDW g
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-cesium isotopes, into the estuarine environment, it is
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N!!iji{h extremely-important.that the AEC assure that all radio-
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active waste treatment-systems, particularly the steam generator blowdown system,: achieve "as low as practicable" J)pft !.
The isotopic make-up of the contaminated discharges..
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1 steam generator-blowdown, as estimated by the AEC in the b
N statement,: consists of about 35 Ci of radioactivity per r-
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year, approximately 21 Ci of'which is due to Cs-134,
'l""i"i' Cs-136, Cs-137, an'd'Mo-99.
In our opinion, ti s zmount
.of radioactivity-exceeds the 5 Ci/ year limit-on liquid discharges contained in the proposed Appendix I to 10 CFR 50.
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