AEC
- AEC-OR-710362-B1
DETAILED STATEMENT ON THE ENVIRONMENTAL CONSIDERATIONS
BY THE
DIVISION OF REACTOR LICENSING
U. S. ATOMIC ENERGY COMMISSION
RELATED TO THE PROPOSED CONSTRUCTION
OF THE TROJAN NUCLEAR PLANT
BY THE PORTLAND GENERAL ELECTRIC COMPANY
CITY OF EUGENE, OREGON AND
PACIFIC POWER AND LIGHT COMPANY
che
GA
1970
dance of the couvert
Issued: November 13, 1970
NEPA COLLECTION
Transportation Library
Northwestern University Library
Evanston, IL 60201
70 - 905
[
:
WYMIENIA
3 5556 031 208879
FOREWORD
This detailed statement of environmental considerations associated
with the proposed construction and operation of the Trojan Nuclear
Plant by the Portland General Electric Company, City of Eugene, Oregon,
acting through the Eugene Water and Electric Board, and Pacific
Power and Light Company (hereinafter collectively referred to as
the applicants) has been prepared by the U. S. Atomic Energy
Commission's regulatory staff pursuant to the requirements of the
National Environmental Policy Act of 1969 which was enacted on
January 1, 1970.
It follows procedures published by the Atomic
Energy Commission in the Federal Register on June 3, 1970 (35 FR 8594),
as proposed amendments to its regulations in 10 CFR Part 50, Appendix D,
and reflects the guidance of the Council on Environmental Quality,
as contained in the Interim Guidelines which were published by
the Council in the Federal Register on May 12, 1970 (35 FR 7390).
The detailed statement is based upon the applicants' environ-
mental report dated May 29, 1970 (Appendix A); the comments received
from Federal agencies regarding the applicants' report (Appendices B,
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C, D, E, and F); additional information furnished to the AEC by the
applicants (Appendix G); information contained in the Preliminary
Safety Analysis Report furnished with the applicants' application
for a construction permit, and the AEC regulatory staff's Safety
Evaluation.
As stated in paragraph 9 of the Commission's proposed Appendix D
to 10 CFR Part 50, "Statement of General Policy and Procedure:
Implementation of the National Environmental Policy Act of 1969
(Public Law 91-190)" (published in the Federal Register on June 3,
1970), the filing of the applicant's environmental report and of
the detailed statement shall not be construed as extending the
licensing or regulatory jurisdiction of the Commission to making
independent determinations on matters other than those specified
in Part 50 for construction permit or operating license applications.
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TABLE OF CONTENTS
Subject
Page
1.0 INTRODUCTION
.
1
2.0 THE TROJAN NUCLEAR PLANT
6
2.1 Site Location
.
6
.
2.2
Description of Reactor.
7
3.0
THE NEED FOR POWER .
.
9
4.0
REQUIREMENTS OF THE NATIONAL ENVIRONMENTAL POLICY ACT.
12
5.0 ENVIRONMENTAL IMPACT OF THE PROPOSED ACTION.
13
.
5.1 Radiological Effects.
13
5.1.1
Radwaste Treatment System.
.
14
5.1.2
Radiological Monitoring in the Environment
15
.
5.1.3
Federal Agency Comments.
16
5.2
Water Quality Aspects.
19
.
5.2.1 Legislation.
.
19
5.2.2
Thermal Effects.
20
5.2.3
Effect of Cooling Tower.
22
5.2.4
Chemical Effluents
23
5.3
Other Environmental Effects
25
5.3.1
Intake Structure Design.
25
O
5.3.2
National and Historical Landmarks.
28
5.3.3
Sewage Disposal. ..
28
5.3.4
Regional Impact of the Plant .
29
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Subject
Page
5.4
Enhancement of Environmental Amenities. .
31
.
5.4.1
Recreational and Visitor Facilities.
31
5.4.2
Ecology Facilities .
31
.
6.0
ALTERNATIVES TO THE PROPOSED ACTION.
32
6.1
Alternate Type of Plant
33
.
6.2.
Power Imports
35
6.3
Alternate Sites
36
.
7.0
ADVERSE ENVIRONMENTAL EFFECTS.
38
8.0
RELATIONSHIP BETWEEN LOCAL SHORT-TERM USES OF MAN'S ENVIRON-
MENT AND THE MAINTENANCE AND ENHANCEMENT OF LONG-TERM
PRODUCTIVITY
39
9.0
IRREVERSIBLE AND IRRETRIEVABLE COMMITMENTS OF RESOURCES.
40
Appendices
APPENDIX A - Environmental Report Trojan Nuclear Plant, dtd
A
May 29, 1970 .
41
APPENDIX B - Comments from Department of Defense, dtd
August 4, 1970.
...
53
-
APPENDIX C - Comments from Department of the Interior,
dtd August 18, 1970. .
54
APPENDIX D
Comments from Department of Health, Education,
and Welfare, dtd August 25, 1970.
59
.
APPENDIX E
Comments from Department of Housing and Urban
Development, dtd August 26, 1970.
79
>
APPENDIX F
Comments from the Federal Power Commission,
dtd October 9, 1970. .
...
81
-V-
Subject
Page
Paz
3:
APPENDIX G
Comments from Applicant, dtd October 12, 1970. ..
86
31
APPENDIX H - Comments by the Board of County Commissioners, Cowlitz
County, Washington, dtd October 28, 1970.
94
.
3
3
APPENDIX I - Waste Discharge Permit issued by the Oregon State
Sanitary Authority to the Portland General Electric
Company.
95
33
APPENDIX J - Letter from the Washington Water Pollution Control
Commission, dtd June 25, 1969. .
33
98
APPENDIX K - Letter from the Federal Water Pollution Control
Administration, Northwest Region, dtd June 24, 1969. ...
99
>
1
APPENDIX L - Chronology
Environmental Statement
.105
39
53
81
1.0
INTRODUCTION
By application dated June 25, 1969, and amendments thereto (the
application), the Portland General Electric Company, City of Eugene,
Oregon, acting through the Eugene Water and Electric Board, and
Pacific Power and Light Company applied for necessary licenses to
construct and operate a nuclear power reactor at the applicants'
site located near Rainier, Oregon.
The application is available
for public inspection at the AEC's Public Document Room at
1717 H Street, N.W., Washington, D. C., and at the Law Library of the
Columbia County Courthouse, St. Helens, Oregon.
The application has been
forwarded to appropriate Oregon State and local officials.
The application has been evaluated by the AEC regulatory staff
and the Commission's independent Advisory Committee on Reactor Safe-
guards, both of which concluded that there is reasonable assurance
that the facility could be constructed and operated at the proposed
site without undue risk to the health and safety of the public.
The AEC regulatory staff's evaluation of the application is set
forth in a document entitled "Safety Evaluation by the Division of
Reactor Licensing," dated October 19, 1970 (hereinafter referred to
as Safety Evaluation).
The report of the Advisory Committee on
Reactor Safeguards is set forth in a letter to Chairman Seaborg,
dated July 17, 1970, and attached to the Safety Evaluation as
Appendix B.
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Pursuant to existing inter-agency arrangements, the Atomic
Energy Commission's regulatory staff sent copies of the application,
shortly after it was received, to the U. S. Fish and Wildlife
Service, the U. S. Geological Survey, the Environmental Science
Services Administration, and the U. S. Coast and Geodetic
Survey.
Expert advice and comments from each of these Federal
departments or agencies are attached to the Safety Evaluation as
Appendices C through F.
The Safety Evaluation is available for inspection both at the
Commission's Public Document Room and at the Law Library of the
Columbia County Courthouse.
A copy of the application also was sent to the Department of
Health, Education, and Welfare's Public Health Service.
In accordance with the National Environmental Policy Act of
1969 and the Council on Environmental Quality's Interim Guidelines,
the Commission published in the Federal Register proposed amendments
to its regulations, 10 CFR Part 50, Appendix D.
The proposed
>
revised Statement of General Policy provides, among other things,
that applicants for construction permits for nuclear power reactors
-3-
will be required to submit a report on specified environmental consider-
ations, and that copies of such reports would then be transmitted
by the Commission to appropriate Federal agencies for comment.
A
summary notice of availability of the report will be published in
the Federal Register, with a request for comments on the proposed
action and on the report from State and local agencies of any affected
State (with respect to matters within their jurisiiction) which are
authorized to develop and enforce environmental standards.
After
receipt of the comments of the Federal, State, and local agencies,
the Commission's Director of Regulation or his designee will prepare
a detailed statement on environmental considerations.
The policy statement also provides that each construction
permit would contain a condition to the effect that:
The applicants shall observe such standards and require-
ments for the protection of the environment as are
1
validly imposed pursuant to authority established
under Federal and State law and as are determined by
the Commission to be applicable to the facility
covered by this construction permit.
This condition
does not apply to (a) radiological effects since
such effects are dealt: with in other provisions of
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this construction permit or (b) matters of water
quality covered by Section 21 (b) of the Federal
Water Pollution Control Act.
On May 29, 1970, the applicants submitted an environmental
report on the Trojan Nuclear Plant.
A copy of the report was
transmitted to the Governor of Oregon on June 30, 1970.
A notice
of availability of the document along with a request for comments
from appropriate State and local agencies was published in the
Federal Register on June 29, 1970 (35 FR 10530).
In addition,
copies of the report were transmitted, with a request for comments
within 30 days, to those applicable.
Federal agencies listed in
the Interim Guidelines; namely, the Department of Agriculture, the
Department of Commerce, the Department of Defense, the Department of
Health, Education, and Welfare, the Department of Housing and Urban
Development, the Department of the Interior, the Department of
Transportation, and the Federal Power Commission.
Copies of all the comments received from Federal agencies are
attached to this statement as Appendices B through F.
The
applicants's response to the agencies' comments is attached as
Appendix G.
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It is the AEC's understanding that copies of the applicants
environmental report were forwarded to the various agencies of the
State of Oregon by the Governor's Nuclear Development Coordinating
Committee; however, no comments were received from the Committee
or from any other State agency on the applicants' environmental
report.
A complete chronology of the correspondence related to the
applicants' environmental report is attached as Appendix L.
4
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2.0
THE TROJAN NUCLEAR PLANT
2.1
Site Location
The site is located on the west bank of the Columbia River
about 30 miles northwest of Portland, Oregon.
The site contains
approximately 623 acres and is owned by the applicants.
The nearest site boundary on land is 2172 feet from the nuclear
reactor.
Within a five mile radius of the reactor site there are
two towns (Rainier, Oregon, four miles north and Kalama, Washington,
two and one half miles southeast) and three small unincorporated
communities (Prescott, Oregon, one half mile north; Goble, Oregon,
one and one half miles south; and Carrolls, Washington, two and
one half miles north-northeast).
The total 1968 population within
five miles of the site is 6400.
The nearest urban complex is the
cities of Longview and Kelso, Washington, the nearest corporate
boundary of which is six miles north of the site.
Within a six mile radius of the site more than 80% of the land
is in timber and brush.
None of the land is classified as prime
farm land and only 2% is classified as good farm land or pasture.
Based on data obtained by the applicants from the Washington State
Planning and Community Affairs Agency and the Oregon State Center
for Population Research and Census, there is no indication that
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there will be any change in land use in the near future other than
a normal rate of industrial growth and attendent population increase.
2.2 Description of Reactor
The nuclear power plant will utilize a four-loop pressurized
water reactor nuclear steam supply system supplied by Westinghouse
Corporation.
General Electric Company will supply the turbine
generator
The balance of the facility will be designed by the
Bechtel Corporation who also will act as construction manager.
The proposed nuclear reactor will utilize slightly enriched
uranium dioxide fuel in the form of pellets contained in Zircaloy
tubes and is designed to operate at an initial power level of
3411 thermal megawatts with an expected ultimate power level of
3570 thermal megawatts. Light water serves as both the moderator
and the coolant.
Boric acid dissolved in the coolant is used as
a neutron absorber to provide long-term reactivity control.
A
reactor coolant pump in each of the four main loops circulate the
borated water through the reactor vessel and core.
The heated
water then flows through a steam generator in each loop where heat
is transferred to the secondary (steam) system and back to the
pumps to repeat the cycle.
The secondary steam produced in the
steam generators is used to drive the turbine generator which produces
electrical power for distribution within the Pacific northwest.
-8-
The nuclear reactor, steam generators, primary coolant system,
and the pressurizer are housed inside the containment structure, a
steel-lined prestressed and reinforced concrete cylindrical structure.
The containment structure provides a barrier to the release to the
environs of radioactive fission products that could be released inside
the containment following an accident.
The auxiliary building houses
the waste treatment facilities, control room, components of engineered
safety features, fuel handling facilities, and various related
A separate turbine building houses the power
auxiliary systems.
conversion equipment.
-9-
**
3.0 THE NEED FOR POWER
As indicated in the comments of the Federal Power Commission,
the 1,130-megawatt electric Trojan Nuclear Plant is the second major
thermal power plant construction project sponsored by the Joint
Power Planning Council of the Pacific Northwest, whose members are
the Portland General Electric Company, three other private utility
systems, 104 public utility systems and the Bonneville Power
Administration.
Construction of the plant is part of the Council's
plan entitled "A Ten-Year Hydro-Thermal Program for the Pacific
Northwest" which calls for the construction of possibly seven major
thermal electric power plants to meet the increasing power requirements
of the Pacific Northwest during the next ten years.
The 1,400-
megawatt electric coal-fired Centralia plant, currently under
construction, is the first major thermal electric power plant
in the program.
While the Trojan Nuclear Plant is intended to be constructed
and operated by the Portland General Electric Company and while the
Company is expected to hold majority ownership, other members of the
Council will participate in the ownership.
Thus, in accordance
with the design philosophy of the Joint Power Planning Council,
the size of the Trojan nuclear plant and its function as a
5
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regional resource was dictated not so much by the needs of the
Portland General Electric Company, as by the immediate needs for
base load thermal capacity in the Pacific Northwest to supplement
the predominately hydroelectric power resources of the region.
The 1970-1971 winter peak load of the West Group Area of the
Northwest Power Pool is expected to reach 19,216 megawatts electric,
while the resources of the Group are expected to be 19,236 megawatts
electric.
The service area of the West Group companies of the
Northwest Power Pool is equivalent to the service areas of the
utility systems who are participating in the Joint Power Planning
Council.
Lack of generating capacity during the past summer forced
some of the utility systems in the Pacific Northwest to drop portions
of the industrial interruptible load.
Similar action is anticipated
during the coming peaking season.
The current load-supply situation
in the area with its lack of support from thermal base-load generating
capacity, is untenable and must be altered as soon as possible if
the area is not to suffer irreparable economic damage.
The Pacific Northwest is unique with respect to capacity reserves
because of its primary reliance on hydroelectric generation for its
electric power needs.
What is critical in the area is not so much
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generating capacity installed and ready for service at times of peak
load, but the amount of water available at the dams for generation
of power.
This fact is the basis for a vulnerability to variations
in stream flows which can be corrected only by the construction of
thermal generating capacity whose dependability at times of peak
demand is relatively assured.
According to the revised plan of the West Group dated June 22,
1970, the Pacific Northwest is expecting to enter three of the next
five peaking seasons with negative reserves.
The peak load during
the 1974-1975 winter peaking season is expected to be 24,422 megawatts
electric, exclusive of 1,229 megawatts of interruptible load which
is mostly industrial.
Total resources at this time are expected to
be 24,766 megawatts electric.
Thus, the area's reserve margin even
after the Trojan nuclear plant comes on the line will be less than
two percent.
The Federal Power Commission concludes:
"Under these circumstances,
there can be no question about the need for the capacity of the
Trojan Nuclear Plant to aid in serving the growing electric power
loads of the Pacific Northwest.'
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4.0
REQUIREMENTS OF THE NATIONAL ENVIRONMENTAL POLICY ACT
The following sections discuss, within the context of the
applicants' environmental report and the comments made by the
various Federal agencies, the following environmental factors specified
in section 102 (2) (C) of the National Environmental Policy Act
of 1969:
a.
the environmental impact of the proposed action,
b.
any adverse environmental effects which cannot be avoided
should the proposal be implemented,
C.
alternatives to the proposed action,
d.
the relationship between local short-term uses of man's
environment and the maintenance and enhancement of long-
term productivity, and
e.
any irreversible and irretrievable commitments of resources
which would be involved in the proposed action should it be
implemented.
Additional detail on each of these items is contained in the applicants
environmental report.
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5.0 ENVIRONMENTAL IMPACT OF THE PROPOSED ACTION
The environmental impact associated with the construction
and operation of the Trojan Nuclear Plant include those actions which
may have a potentially detrimental effect on the present state of
the environment and those actions which may potentially enhance
environmental amenities.
In the former group are such actions as
the release of low levels of radioactivity to the environment and
the discharge of effluents to the Columbia River after withdrawal,
treatment, and use in the various plant systems.
In the latter
group are the recreational facilities planned for the site and
the use of the heated water for fish rearing ponds on the site
by the State of Oregon.
These and other effects are described
in the pages that follow.
5.1 Radiological Releases
The operation of any nuclear power reactor results in the
production of radioactive materials that for the most part are
contained within the fuel
elements in the reactor vessel.
The
radioactive materials are produced as a direct result of the fission
process or are activated materials resulting from nuclear reactions.
Small quantities of gaseous and liquid radioactive wastes are
released to the environment by a controlled process following
appropriate procedures, treatment, and sampling.
The maximum
S
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allowable amount of radioactivity that may be released is
established in accordance with the Commission's regulations as
set forth in 10 CFR Part 20.
The applicants have indicated that
releases will be a small percentage of these limits.
Experience
with operating nuclear plants of design similar to that of the
Trojan Nuclear Plant supports the applicants contention that
releases will be a small percentage of 10 CFR Part 20 limits.
5.1.1 Radwaste Treatment System
Radioactive waste treatment systems which are to be incorporated
into the facility are described in Section 9.0 of the Safety Evaluation.
Processes for liquid wastes include holdup, filtration, evaporation,
and demineralization.
After suitable treatment and sampling to
assure that releases are within the limits established in the
Commission's regulations, 10 CFR Part 20, liquid wastes are
released on a batch basis to the discharge canal which empties
into the Columbia River.
A minimum dilution of 1000-to-l is provided
in the discharge canal.
The applicant has estimated that the
maximum expected routine concentration of radioactivity in the
discharge canal will be approximately one percent of the limits
specified in 10 CFR Part 20.
The gaseous radwaste system includes
.
capability for 45 days holdup and filtration prior to release
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from the facility vent stack.
Thus, advantage is taken of both
holdup in decay tanks and a controlled elevated release.
Solid
wastes are placed in Federally approved containers for offsite
shipment to a licensed burial ground.
5.1.2 Radiological Monitoring in the Environment
A preoperational environmental radioactivity monitoring program
will be conducted by the applicants to determine the magnitude and
nature of the radioactivity in the environment surrounding the
site at least two years prior to the startup of the plant.
The
information obtained will serve as a base line for evaluating
any changes in environmental radioactivity level that may possibly
be attributed to the plant operation. Sampling stations and sites
will be established on the basis of population density and distri-
bution, meteorological, hydrological and topography conditions.
The items collected for monitoring will include samples of river
and well water, soil, air particles, farm and dairy products,
natural vegetation, fish and shellfish, and river bottom sediments
from the vicinity of the plant.
The applicants' operational environmental radioactivity program
will be similar to the preoperational program; however, the sampling
and analysis schedule will be modified from time to time based on
the level of radioactivity found in the plant effluents and on the
results of the environmental radioactivity program.
Results of the
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sample analyses will be evaluated to ensure the effectiveness of
plant radiation control and compliance with the requirements of all
regulatory agencies, both Federal and State.
On the basis of the type and size of equipment provided to
control effluent releases, and general experience with currently
licensed and operating power reactors, there is reasonable assurance
that the radioactive waste treatment system will perform as designed
and that the radioactivity levels in liquid or gaseous releases
from the Trojan facility will be well below the levels specified in
the Commission's regulation, 10 CFR Part 20, "Standards for
Protection Against Radiation.
The extensive environmental
monitoring program to be carried out by the licensee will assure that
information and environmental levels of radioactivity are developed
on a continuing basis.
There also is reasonable assurance that
there will be no adverse effects from the release of radioactivity
which will prevent normal utilization of the environment.
5.1.3 Federal Agency Comments
As noted earlier, the Department of Health, Education, and
Welfare's Public Health Service was sent a copy of the PSAR with
subsequent amendments.
A copy of the applicants' environmental
report also was sent to the Department for comment, and in their
-17-
response the Department concluded, "... that the Trojan Nuclear Plant
can be built and operated without significant effect on the environ-
ment or the public.'
In its comments, the Department of Health, Education, and
Welfare also urged that the applicants' philosophy reflect the need
to keep radioactive discharges to the lowest level practicable.
The applicants agree with this and have stated that it is their
policy and intent to maintain radioactive exposures and releases
as far below the applicable AEC limits as is practical.
To aid
in accomplishing this, the applicants have included in the proposed
plant design capabilities to monitor and treat radioactive wastes
by filtration, evaporation, and demineralization, and to holdup
these wastes prior to release.
The Department of Health, Education, and Welfare also pointed
out that due to the radioactive concentrations now existing in the
river resulting from discharges at the Hanford facility, it would
be necessary for the Trojan discharges to be based on specific
radionuclides rather than
a gross-beta analysis basis.
However, the
AEC notes that the radioactive concentrations in the Columbia River
due to discharges at the Hanford facility have decreased since 1967
due to reduced operation at Hanford.
Since liquid releases from
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Trojan will be on a batch basis, a radioisotopic analysis can be
made prior to release if it is determined to be necessary by the
environmental monitoring program.
In any event the applicants will
permit releases only within the limits of applicable regulations.
The Department of Defense noted in its comments that insufficient
information is available in the Environmental Report on normal
radwaste releases and releases following accidents at the proposed
plant.
However, information regarding radioactive releases from
normal operation and during potential accidents has been provided
in the applicants' PSAR.
This information has been evaluated by
the AEC and is within the limits of applicable regulations.
These
types of releases are treated more fully in Section 9.0 of the
staff's Safety Evaluation.
The Department of Defense also mentioned the meteorological
measurements program and how it related to gaseous radwaste releases.
The applicants' onsite meteorological program was initiated in 1969
and has since been in continuous operation.
The data being
accumulated include wind speed, wind direction, and temperature at
various elevations on a 500 ft meteorological tower.
This program
will continue in operation after the plant becomes operational and
will provide the necessary meteorological information to establish
The meteorology program is described
gaseous waste release limits.
more fully in Section 2 of the PSAR.
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5.2
Water Quality Aspects
5.2.1 Legislation
Section 21(b) of the Federal Water Pollution Control Act, as
amended by the Water Quality Improvement Act of 1970, requires
applicants for Federal licenses or permits to conduct any activity,
including the construction of a facility such as a nuclear power
plant, which may result in any discharge into the navigable waters of
the United States, to provide the Federal licensing agency with
certification from the State, or interstate water pollution control
agency, or the. Secretary of the Interior, as appropriate, that
>
there is reasonable assurance, as determined by such certifying
authority, that the activity will be conducted in a manner which
will not violate applicable water quality standards.
Where an
application was pending on the date of enactment of the Act, as
it was in the case of the Trojan plant, section 21(b) (8) of the
Federal Water Pollution Control Act, as amended, provides that
if a construction permit is issued before April 3, 1971, the
applicants must obtain a certification within one year following
issuance of the permit.
A Waste Discharge Permit for the Trojan plant was issued to
the Portland General Electric Company on June 27, 1969, by the
Oregon State Sanitary Authority (now titled the Department of
Environmental Quality), which contains a number of requirements,
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limitations, and conditions for maintaining the quality of the
Columbia River (Appendix I).
The permit was reviewed by the
Water Pollution Control Commission of the State of Washington
(Appendix J) and by the Northwest Regional Office of the Federal
Water Pollution Control Administration (now titled the Federal
Water Quality Administration) (Appendix K).
The Washington Water
Pollution Control Commission found that it was "in general agreement with
the proposed permit conditions".
In its comments, the Federal
Water Quality Administration stated:
In our opinion, the "recommended Waste Discharge Conditions":
should provide for maintenance of the existing high water
quality in the Columbia River and for all present
and future uses.
As required by Section 21(b) of the Federal Water Pollution Control
Act, as amended, the applicants also indicate that they will apply for
the required water quality certification within the time allotted.
5.2.2
Thermal Effects
All steam-electric generating plants must release heat to the
environment as an inevitable consequence of producing useful electricity.
Heat from the fission of nuclear fuel in a reactor or combustion
from fossil fuel in a boiler is used to produce high temperature and
pressure steam which in turn drives a turbine connected to a generator.
When a portion of the thermal energy in the steam has been converted to
mechanical energy in the turbine, the remaining steam is converted back
into water in a condenser.
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Condensation is accomplished by passing large amounts of cooling
water through the cooling coils in the condenser.
In the least costly
and most widely used method, the condenser cooling water is taken
directly from nearby rivers, lakes, estuaries, or the ocean.
The
cooling water is heated 10 to 30 degrees F.
depending on plant design
and operation
and then usually returned to the same source.
Thermal
effects is a term which is used to describe the impact that the heated
water may have on the source body of water.
To reduce thermal effects on the Columbia River, the applicants
propose to install a single, natural draft cooling tower which
the applicants estimate will dissipate between 98.8 to 99.8 percent of
the waste heat generated by the facility to the atmosphere rather than
to the river.
Since the cooling tower will employ the natural draft
principle of cooling and will be approximately 500 feet high, only
under the most unusual atmospheric conditions would the vapor plume
from the top of the cooling tower come in contact with the ground
before its dissipation.
The applicants state that less than two percent of the waste
heat generated by the plant will be discharged to the river.
The
sources of this discharge will be the cooling tower blowdown and
the service water discharge which will return water to the river
at an average rate of seven cubic feet per second.
The average
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river flow rate at the site is over 100,000 cubic feet per second,
therefore, even with only minimum mixing in the river the applicants
report that the thermal effect will be insignificant.
5.2.3
Effect of Cooling Tower
In their letter of October 28, 1970, the Board of County
Commissioners of Cowlitz County, Washington questioned the effect
that the cooling tower would have on the surrounding airshed
(Appendix H).
In its environmental report, the applicants indicate
that a major concern while contemplating the use of a cooling tower
was whether it might cause ground level fog or icing on the
relatively few days freezing conditions are experienced.
Another
was whether the water vapor in the plume would combine with
pollutants in the local atmosphere, causing an increase in deleterious
precipitation.
The NUS Corporation was engaged to study these specific
questions as well as the entire range of possible environmental
effects of a cooling tower located at the Trojan site.
The report
which was developed from this study concluded that:
(a)
There would be no calculable increase of ground level fog
from the cooling tower operation.
The top of the Trojan
tower will be approximately 590 feet above the river and
because the plume is bouyant due to its large heat content
and has momentum as it emerges, the effective height of
the tower is even greater.
The inversion which normally
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ond,
prevents dissipation of ground fog will occur at a sufficiently
Scart
low level to be penetrated by a natural draft cooling tower
plume.
(b)
The cooling tower operation will create a visible, white
vapor plume or cloud aloft which will disperse as it is
transported down-wind.
Under the less favorable meteorological
Ect
conditions experienced in autumn, plumes may remain visible
for a considerable distance down-wind.
cate
Under no condition can
Owe!
a region-wide, semi-permanent cloud cover resulting from the
cooling tower operation be anticipated.
er
(c) Atmospheric contaminants are known to exist in the ambient air
of the region around the site.
Water vapor in the plume will
teric
not interact to any significant degree with these contaminants.
SPEC
In fact air drawn through the tower will be washed by contact
with the circulating water.
5.2.4
ort
Chemical Effluents
As in the case of other power plants, various chemicals will be
utilized for maintenance of plant water quality, corrosion inhibition
in certain closed loop systems, regeneration of demineralizers, and
the prevention of marine fouling of condenser and other tubing.
Additionally, in this nuclear station, part of the nuclear
reactivity control is accomplished by the addition or deletion of
-24-
boron compounds to the reactor cooling water; thus the chemicals
used can include boric acid, sulfuric acid, potassium dichromate,
various laboratory chemicals, and chlorine.
In the course of normal
plant operation, small amounts of these chemicals will be discharged
to the river.
The concentrations of these chemicals will not exceed
the limits specified in the Trojan plant's Waste Discharge Permit.
These limits are:
Polyphosphate (PO,)
.. 21 ppm
Free residual chlorine
1.5 ppm
Sulfate
824 ppm
Chromate
14 ppm
.
Zinc
2 ppm
.
.
Orthophosphates (POL)
3.9 ppm
Volatile amines
0.1 ppm
.
Boron
0.48 ppm
.
Lithium
0.002 ppm
Sodium
172 ppm
.
In their comments, the Department of Interior requested that
the proposed liquid discharges from the Trojan plant be submitted to
the State of Washington for assurance that their water quality standards
would not be violated.
As noted previously, the Waste Discharge Permit
has been reviewed by the Washington Water Pollution Control Commission.
-25-
Furthermore, as provided in section 21(b) (2) of the Federal Water
Pollution Control Act, as amended, when the AEC receives a water
quality certification from the applicants, the AEC will notify the
Secretary of Interior.
If the Secretary determines that the
discharge may affect the quality of the waters of any other State
(i.e., the State of Washington), the Secretary shall so notify the
State.
If within 60 days after the receipt of such notification
the State determines that such discharge will affect the quality
of its waters, it may request, and the AEC will hold, a public
hearing.
Based upon the recommendations of the State, the
Secretary, and upon any additional evidence presented at the
hearing, the AEC would be required to condition the permit or
license in such manner as may be necessary to ensure compliance
with applicable water quality standards.
5.3
Other Environmental Effects
5.3.1
Intake Structure Design
The intake structure designed for this facility incorporates
engineering and technological features to guard against trapping of
fish at the intake.
This design has been formulated incorporating
the comments of several agencies including the U. S. Bureau of
Commercial Fisheries, the Fish Commission of Oregon, and the Oregon
Game Commission.
Based upon the advice of the applicants' consultants
-26-
and the comments of these agencies, the applicants believe that
the proposed intake structure design will provide the required
protection for fish life in the Columbia River.
The applicants have described the features of the intake
structure to include the following:
(1) a design which limits the
intake water velocities to not more than one foot per second;
(2) elimination of recess from the adjacent shoreline; and (3)
provisions for lateral exit passages for fish.
The intake structure will be a concrete structure housing
service water pumps and other miscellaneous makeup water pumps.
The front (water side) of the intake structure includes open
bays through which the water enters.
These bays contain trash
racks and traveling screen panels utilizing openings of five
mesh per inch to prevent fish or debris from entering the
pump and cooling water systems.
In the arrangement of these
various components, the applicants indicate they have employed
the latest design criteria to prevent entrapment of fish.
-27-
In its comments the Department of Interior concluded that
while everything possible and feasible will be done to protect the
environment and they have no objection to the issuance of a
construction permit, they suggested that the following condition
be included in the construction permit:
The Permittee shall make such modifications in project
structures and operation for protective screening of
all water intakes to exclude fish, and for reduction
in the concentration of toxic chemicals resulting
from plant discharges as may be found by the Atomic
Energy Commission to be needed to prevent damage to
fish and wildlife resources following recommendation
by the Department of the Interior after operation of
the plant beings.
The regulatory staff does not believe that it is necessary to
include such a condition in the construction permit since the
commitments made by the applicants are responsive to the concerns
expressed by the Department.
The proposed design of the intake
structure has included consideration of the potentially harmful
effect in fishlife, and the applicants indicate that the proposed
-28-
design has been approved by biologists and engineers for both State
and Federal agencies. Further, specific chemical concentrations
are specified in the Waste Discharge Permit, and the applicants have
assured the Federal Water Quality Administration that the least
toxic chemicals will be used for corrosion and marine growth control.
5.3.2
National and Historical Landmarks
The site for the facility has been considered in accordance
with the requirements of the National Historical Preservation Act
to determine whether any historic landmarks will be affected by
the location of the nuclear plant at the Trojan site.
In this
regard the AEC requested the Advisory Council on Historic Preserva-
tion to comment on the proposed plant.
Their report stated
that "...there are no National Register properties which will be
affected."
5.3.3 Sewage Disposal
The applicants have stated that an appropriate sewage disposal
system will be provided in conformance with the applicable State
regulations.
The construction of this system will be one of the
first permanent installations at the site and thus will be available
during the major construction period.
The system will be sized
to accommodate the plant operating staff plus the largest number
of visitors expected at the site at one time.
-29-
5.3.4 Regional Impact of the Plant
In its comments on the applicants' environmental report, the
Department of Housing and Urban Development commented upon the
relationship of the facility to regional economic development
plans, and stated that local, regional, or state planning
agencies should be consulted early in the development of the
project.
The applicants have been and will continue to coordinate
the project development with the Columbia County Board of
Commissioners.
This Board has reported favorably on the project
to the Governor's Nuclear Plant Sitting Task Force.
The Department of Health, Education and Welfare commented on
the lack of an emergency plan for the Trojan plant and expressed
the need for including authorities of the State of Washington on
the plan when it is developed.
During the AEC's construction
review of each nuclear plant, the applicant is required to present
preliminary plans for coping with emergencies.
These preliminary
plans must contain sufficient information to assure the
compatibility of proposed emergency plans with facility design
features, site layout, and site location with respect to such
considerations as access routes, surrounding population
distributions, and land use.
In addition, these plans must
include preliminary information on the organization for coping
-30-
with emergencies, contacts and arrangements to be made with agencies
responsible for coping with emergencies, measures to be taken in
the event of an accident to protect health and safety and prevent
damage to property, provisions for emergency treatment of individuals,
special training for persons whose services are required in
coping with an emergency, and features of the facility provided
to assure the capability for carrying out actions to mitigate
the consequences of an accident.
The applicants have provided the AEC with a summary description
of the principal elements of the emergency plan in Section 12 of
the PSAR.
The proposed plan compares satisfactorily to the
requirements of the proposed amendment to 10 CFR Part 50.34,
published in the Federal Register, May 21, 1970 (35 F.R. 7818).
The information provided is sufficient assurance that an acceptable
emergency plan will be developed before the plant becomes opera-
tional, and the plan will be coordinated with local officials
from both the State of Washington and the State of Oregon.
The
detailed emergency plan will be reviewed by the AEC when the plant
is completed in the context of its review prior to issuance of an
operating license.
-31-
5.4 Enhancement of Environmental Amenities
Prior to acquisition of the land by the applicants for the
construction of the Trojan plant, the land was owned and utilized
by the Trojan Powder Company for warehousing explosives. More
recently the Oregon State Parks Department had considered the site
for development as a state park but this proposal was not adopted.
The applicants have consulted environmental designers in an effort
to preserve, as much as possible, the natural beauty of the
site during and following the construction of the facility.
5.4.1
Recreational and Visitor Facilities
A portion of the site will be developed for general public,
daytime use.
Facilities will be provided for picnicking, swimming,
boating, hiking, and fishing.
A visitors center will be erected early in construction.
The
center will include audio-visual presentations on nuclear energy
for educational and visitor uses.
5.4.2 Ecology Facilities
An area of the site has been offered to the State of Oregon
for fish rearing. Waste heat from the plant will provide for
accelerated growth of sport fish which would then be deposited
in offsite waters.
A large pond on the site is the present winter nesting ground
This pond will be preserved in its natural
of whistling swans.
state.
-32-
6.0
ALTERNATIVES TO THE PROPOSED ACTION
The site characteristics as noted in the regulatory staff's
Safety Evaluation, have been thoroughly studied and evaluated by
the regulatory staff and certain expert consultants, including
other Federal agencies, and are considered adequate to support the
activities associated with the construction and operation of the
Trojan Nuclear Plant.
The need for the additional generating
capacity which will be derived from the Trojan plant has been
discussed with the applicants and with the Federal Power Commission,
and the applicants indicate that the plant is necessary to provide
additional base load generating capacity to meet regional load
conditions and reserve requirements projected for 1974.
In the
Federal Power Commission's response to the AEC's request for
comments on the proposed Trojan plant, they concluded:
"there can be no question about the need for the
capacity of the Trojan nuclear plant to aid in
serving the growing electric power loads of the
Pacific Northwest."
Alternatives to the proposed Trojan plant have been con-
sidered and these include:
(1) building an alternate type of
plant such as a fossil fueled plant or a hydroelectric plant,
(2) importing the power from another system, and (3) locating
the plant at another site.
-33-
6.1 Alternate Type of Plant
The electric generating capacity of the Pacific Northwest
is predominately hydro.
Of the 98,868 million kilowatt-hours
of electric energy generated in the States of Washington and
Oregon during 1969, less than four percent was generated by non-hydro
plants (fossil and nuclear steam, gas-turbine, and internal
>
>
combustion).
At the end of 1969, only seven percent of the
.
installed generating capacity in these two states was non-hydro
and of this 4.7 percent was accounted for by the 800-megawatt
electric Hanford nuclear plant.
According to the Federal Power Commission, the area is
singularly lacking in native oil and gas resources.
Some coal
deposits exist, but these are mostly of the bituminious and
sub-bituminous rank and of a quality too low to have encouraged
construction of coal-burning steam generation as long as favorable
hydroelectric sites were available and awaiting development.
Thus,
the Federal Power Commission concluded, the construction of a
fossil-fuel plant as a substitute for the Trojan nuclear plant
does not appear to be an economically superior choice at this
time as a source of needed thermal generation to supplement the
hydroelectric resources of the Pacific Northwest.
-34-
Consideration of a substitute for the Trojan nuclear plant
must also take into account the fact that the best hydro sites in
the Pacific Northwest have already been developed.
Some good
sites are still undeveloped, but their future is dimmed by the high
cost of development and by environmental controversies.
Some
sites have been eliminated entirely as future hydro sites by
the 1965 Wild and Scenic Rivers Act which sets aside stretches of
the Rogue, Salmon and Clearwater Rivers for preservation in their
wild state.
Other stretches of these and other rivers having
favorable hydró sites were also designated by the Act for study for
possible preservation as Wild River areas.
Some of the existing hydroelectric installations are at sites
suitable for further development.
Because of available water
limitations, additional capacity at these sites would necessarily be
operated at low capacity factor and, therefore, would be suitable
only for peaking purposes.
Hydroelectric installations are eminently
suitable for peaking purposes, a characteristic which endows the
Pacific Northwest with an abundance of existing and potential
peaking capacity.
In providing for future loads of the region,
electric utility systems must add base-load generating capacity to
supplement existing hydroelectric capacity.
This needed base-load
capacity can, according to the FPC, most appropriately be provided
by thermal facilities such as the Centralia coal-fired plant and
by the program of nuclear plant construction drawn up by the Joint
Power Planning Council, which includes the Trojan plant.
-35-
6.2 Power Imports
The import of firm power from other utility systems in the
West Region as a substitute for the Trojan nuclear station also
does not appear to be feasible within the time period under considera-
tion.
This conclusion is based on a review by the Federal Power
Commission of the reserve margins of the systems from which such
power would have to come and from an estimate of the reserve
situation as it is expected to develop in the FPC West Region
which comprises essentially the eleven western states during
the next five years.
According to the Federal Power Commission, the 1970-1971
winter reserve margins of the most likely power exporting system
in the West Region, before allowance for maintenance, are as
follows:
Winter 1970-1971
Reserve Margin
Megawatts
Percent
System
PSA
Montana Power Company
30
75
8.9
Idaho Power Company
41
-57
-6.4
Utah Power & Light Company 41
157
12.7
Pacific Gas & Electric
Company and City of
San Francisco
46
25.9
2,345
1,109
36.4
City of Los Angeles
47
Southern California Edison
47
Co.
1,716
19.4
-36-
It is evident, the FPC said, that the systems in PSA 30 and 41
>
to the east and southeast of the Pacific Northwest do not have
enough reserve margin to support firm power exports to the West
Group Area.
The reserve margins of the systems to the south in PSA
46 and 47 on the other hand, are markedly superior, but because
of the special circumstances of power development and interchanges in
the West Region, the systems in these PSA's are similarly not in
a position to help the Pacific Northwest.
In general, the FPC feels that the Pacific Northwest stands
to gain an important advantage from a reliability point of view by
the construction of the Trojan nuclear plant within its service
area rather than seeking to rely on non-indigenous sources.
Furthermore, the construction of needed additional capacity
outside the FPC West Region would not lessen the overall impact
of power facilities on the environment.
6.3
Alternate Sites
Potential sites for the applicants' service territory exist in
three general geographic areas: the Northern Oregon Coast; the Mid-
Willamette Valley and the Lower Columbia River.
Portland General
Electric Company commissioned Bechtel Corporation to make site
evaluation studies.
-37-
As a result of the conclusions reached in these studies and
the applicants' evaluation of other environmental and economic factors,
the Trojan site was selected.
The Northern Oregon Coastal sites were
ruled out because much of this coast is uniformly populated
with beach homes and resorts; and most of the remainder is State or
Federal land.
Transmission lines would have to cross the Coast
Range through scenic areas which, as the Department of Housing and
Urban Development indicated in its comments, should be avoided.
Although it was determined that sites in the Mid-Willamette Valley
would be suitable for plants with cooling towers or cooling ponds,
much greater supply of water in the Columbia River made it appear that
there were advantages in locating the plant on that River.
The
applicants considered it undesirable to locate a plant in the
Columbia River Gorge because of its scenic values, and sites east
of the Cascade Range were not considered because of the concern
over constructing more transmission lines through public forest
in the mountains.
-38-
7.0
ADVERSE ENVIRONMENTAL EFFECTS
As discussed in the previous section on the environmental impact
of the Trojan facility, there are certain potentially detrimental
environmental effects associated with the construction and operation
of the facility.
In view of the AEC's detailed evaluation of
the radiological impact of the plant on the environs, the AEC
does not expect radiological effects to be significant.
Further
the applicants report that other effects such as thermal effects,
effects on wildlife, chemical waste releases, and sewage disposal
will not produce a significant effect on the environment.
The applicants have indicated that they will comply with all
Federal and State regulations applicable to the unit which are
designed to protect the environment.
Furthermore, the applicants
have stated that if any adverse effects attributable to the operation
of the plant were to become evident through the environmental
monitoring programs during plant operation, appropriate steps
would be taken by the applicants to correct the situation.
-39-
8.0
RELATIONSHIP BETWEEN LOCAL SHORT-TERM USES OF MAN'S ENVIRONMENT AND
THE MAINTENANCE AND ENHANCEMENT OF LONG-TERM PRODUCTIVITY
The local short-term effects on the environment are those
associated with the construction of any large industrial facility,
and during facility operation, those associated with the radioactive,
thermal, and chemical discharges of the Trojan plant.
The plant's
liquid and gaseous radioactive effluents are expected to be about
one percent of the 10 CFR Part 20 limits and the applicant
reports that the thermal and chemical discharges are expected to
be negligible.
In addition, the applicants have proposed an
environmental monitoring program which will include the sampling
and analysis of surface and ground water, bottom sediments, soil,
fish, air and river water.
This program will be used to provide a
basis for detecting and evaluating any radiological impact which
might lead to long-term effects in order that timely corrective
action can be taken if required.
-40-
9.0
IRREVERSIBLE AND IRRETRIEVABLE COMMITMENTS OF RESOURCES
In recent years prior to the applicants' purchase of the site,
the land was not in use.
The applicants report that it would
undoubtedly have been developed as an industrial site eventually.
Curtailment of the use of the area as a result of plant construction
and operation should not be as severe as that incident to many other
heavy industrial facilities.
The recreational and other beneficial
uses of the surrounding area should not be impaired.
In fact, as
1
previously noted, new recreational facilities will be created.
1
|
-41-
APPENDIX A
PORTLAND) GENERAL ELECTRIC COMPANY
ELECTRIC BUILDING
e site,
PORTLAND, OREGON 97205
E.C.ITSCHNER
VICE PRESIDENT
May 29, 1970
lly.
Docket No. 50-344
DO
ruction
y other
ficial
Dr. Peter A. Morris, Director
Division of Reactor Licensing
Atomic Energy Commission
Washington, D.C. 20545
har
, as
TES
.
Dear Dr. Morris,
In compliance with your letter dated April 24, 1970, I am pleased to
furnish information required by the National Environmental Policy Act
as an enclosure herewith.
Please call upon me if you desire any additional information.
Sincerely,
Ee Fischner
sunt
-42-
Docket No. 50-344
May 29, 1970
TROJAN NUCLEAR PLANT
The following information is intended to provide the basis for the preparation of a detailed
environment statement as required by the National Environmental Policy Act of 1970.
The Trojan Nuclear Plant of Portland General Electric Company will be a pressurized
water type of nuclear power plant with a single generating unit of 1130 megawatts net
electrical capacity. It will be located on the Oregon bank of the Columbia River 42
miles from Portland and immediately south of the small community of Prescott, Oregon.
The following comments are keyed to the AEC letter.
a.
The environmental impact of the Trojan Plant
Portland General Electric Company believes that no adverse environmental
effects will result from the construction and operation of the Trojan Plant.
The addition to the landscape of several large structures associated with the
plant no doubt will have some impact upon the scenery. We believe, however
that the care taken in its design will result in a favorable impression. The
Company has retained the services of several of the nation's leading architectural
firms to create an unusually imposing and esthetically pleasing installation. In
addition, the Company will develop a large public recreation area in conjunction
with the project which will result in an overall enhancement of the scenic and
recreational values in the area. Specific environmental effects are noted here-
after.
1.
Releases to the atmosphere
i.
Thermal releases
To reduce thermal effects on the Columbia River a single large
natural draft cooling tower will be used to dissipate to the air
almost all of the waste heat generated by the project. From
98.8 to 99.8 percent of the heat which would have been added
to the river by direct once-through cooling will instead be
dissipated by the cooling tower. The percentage will vary within
this range and weather conditions and the water temperature of
the Columbia River.
A major concern while contemplating the use of a cooling tower
was whether it might cause ground level fog or icing on the
relatively few days freezing conditions are experienced. Another
-43-
- 2 -
was whether the water vapor in the plume would combine with
pollutants in the local atmosphere, causing an increase in
deleterious precipitation. The NUS Corporation was engaged
to study these specific questions as well as the entire range of
possible environmental effects of a cooling tower located at
the Trojan site. The report (1) which was developed from this
study concluded that:
(a) There would be no calculable increase of ground
level fog from the cooling tower operation. The
top of the Trojan tower will be approximately 590
feet above the river and because the plume is
bouyant due to its large heat content and has
momentum as it emerges, the effective height of
the tower is even greater. The inversion which
normally prevents dissipation of ground fog will
occur at a sufficiently low level to be penetrated
by a natural draft cooling tower plume.
7
(b) The cooling tower operation will create a visible,
white vapor plume or cloud aloft which will disperse
as it is transported down-wind. Under the less
favorable meteorological conditions experienced in
autumn, plumes may remain visible for a considerable
distance down-wind. Under no condition can a
region-wide, semi-permanent cloud cover resulting
from the cooling tower operation be anticipated.
(c) Atmospheric contaminants are known to exist in the
ambient air of the region around the site. Water
vapor in the plume will not interact to any significant
degree with these contaminants. In fact air drawn
through the tower will be washed by contact with the
circulating water.
ii.
Radioactive releases
All radioactive discharges from the Trojan Plant will be well within
the limits established by the goveming Atomic Energy Commission
regulations, 10 CFR part 20. To assure meeting these requirements,
a radioactive waste disposal system is being provided. The system
is being designed specifically to control the release of radioactive
material to the environment. Recycling of gases within the plant
-44-
- 3 -
and use of gas decay holdup tanks to permit decay of radioactivity
and release of the gases under favorable atmospheric conditions
will ensure achieving the lowest practical level of effect on the
environment.
It is contemplated that the plant will be operated on base load
rather than load following. This method will reduce greatly the
amount of boron evaporation required, thus minimizing radioactive
releases.
2.
Releases to the Columbia River
i.
Thermal releases
Since the cooling in the tower is accomplished largely by evaporation,
the loss of water must be replenished. Also, due to the evaporation,
natural salts and other contaminants in the circulating water system
received from the river are concentrated so that some of the circulating
water must be bled off continuously as "blowdown" while the tower is
in operation in order to maintain an acceptable quality of water in the
cooling system. The ratio of streamflow to blowdown is expected to be
a minimum of 10,000 to one when averaged over one tidal cycle. This
would occur only under low flow and high ambient temperature
conditions; during most of the year the ratio would be considerably
greater. The blowdown from the cooling tower will carry with it some
heat, but to reduce the already slight effect of this small flow on the
Columbia River, it will be taken from the coldest portion of the cooling
system. On the hottest summer day (102° F air temperature) the blow-
down during normal operation would amount to 12.6 cfs (cubic feet per
second) at 95° F; the average would be 7.9 cfs at 80° F, and on the
coldest days of winter it would be 2.3 cfs at 65° F. Under the most
unfavorable ambient temperature, river flow and tidal conditions, the
Columbia River temperature would be raised due to the blowdown
from the Trojan Plant after complete mixing about 0.01° F. This
compares with a diurnal increase under natural conditions due to the
heat of the sun of about 1° F on a clear day in summer.
ii.
Chemical releases
Some chemicals will be added to the cooling water system and most of
them will be neutralized as they serve their purpose of correcting
deficiencies in natural Columbia River water for this special use.
Unavoidably a small residue will be present in the cooling tower blow-
-4-
-45-
down. These chemical additives are used for the control of scale and
corrosion, and are necessary for the protection of the plant and to
insure its integrity. River studies (2, 3) by Battelle Memorial Institute,
Pacific Northwest Laboratory, concluded that the effluent from the
Plant would be completely mixed with the river water 12,000 feet below
the site. The concentration of the blowdown chemicals in the Columbia
River after dilution by a factor of at least 10,000, combined with further
reaction with the natural river water will, of course, be extremely small.
iii.
Radioactive releases
Radioactive liquid releases will be well within the limits established
by 10 CFR and generally will be considerably less than one percent of
their respective maximum permissible concentration levels for an
uncontrolled area. Liquids will be processed in evaporators and
demineralizers to remove nearly all of the removable radioactive material
prior to release of such liquids from the plant. After such release and
dilution in the river, concentrations of specific radioisotopes in the river
water will be essentially unchanged from present levels.
iv.
Sanitary wastes
Wastes from sanitary facilities serving construction forces, operating
personnel and visitors will receive secondary treatment consistent with
Oregon State requirements.
.
3.
Solid Wastes
Solid radioactive wastes of moderately low level will be disposed of by shipping
them to AEC approved and licensed disposal areas. Such wastes will consist
principally of residues (used ion-exchange resins or evaporator concentrates) and
contaminated equipment and materials, such as worn-out clothing, filter elements,
glassware, blotting paper and other debris.
Normal practice will be to minimize the volume and physical freedom of the
solid waste material. Consequently, a large proportion will either be
compressed and baled or mixed in concrete prior to insertion in shipping
containers for transport to the land disposal areas. Some items, e.g., filters,
which do not lend themselves to this treatment, will be packaged in shipping
containers. However, in all cases the shipping of solid wastes will be done
in accordance with the appropriate Atomic Energy Commission and Department
of Transportation regulations.
-46-
- 5 -
b. Any adverse environmental effects which cannot be avoided should the Trojan Plant
be implemented.
Portland General Electric Company believes that the environmental effects of the
Trojan Nuclear Plant will not be adverse. A description of the thermal and radiation
effects follows.
1.
Thermal
The use of a natural draft cooling tower as the means of dissipating waste hed
will result in a minimal thermal effect upon the environment. The Columbia
River at the site is one of the largest rivers in the United States and it is the
coldest in summer of our major rivers. Nevertheless the application of the
State of Oregon Sanitary Authority (now the Department of Environmental
Quality) for a Waste Discharge Permit was predicated upon the use of a cooling
a
tower in order to avoid any conceivable adverse effect upon the runs of
anadromous fish in the Columbia River. It is significant that there was not a
single intervener in the public hearing at which the Sanitary Authority heard
and approved the application. The National Wildlife Federation adopted a
resolution at a national meeting commending the Company for deciding to use
a cooling tower instead of once-through cooling. The cooling tower without
the river intake structure, pumps and piping outside of the perimenter of the
tower will cost about $8,000,000. Once-through cooling would have cost at
least $5,000,000 less and the turbine efficiency achieved would have been
significantly greater.
2.
Radiation
Equipment designed to treat and hold radioactive wastes will be chosen carefully
so as to provide the highest attainable effectiveness in minimizing the impact on
the environment. It is contemplated that the plant normally will be operated
at or near full load except when an adequate amount of hydro power is available
or during shutdown for refueling or maintenance, thus avoiding the problems
inherent in frequent changes of boron content of the primary coolant characteristic
of a load-following type of operation. Here again there was no opposition to
the release of the small amounts of radiation stated in the application for a Waste
Discharge Permit. The good ventilation of the Columbia Valley and the tremendous
dilution capabilities of the river reinforce the conclusion that there will be no
adverse environmental effects from the plant.
-47-
- 6 -
C.
Alternatives to the proposed action
The electric power capacity of the Pacific Northwest is predominantly hydro. Few
suitable new sites for developing additional hydro power exist and there is some
opposition to using them. Expansion of existing sites is feasible in many cases,
but usually this will provide only additional peaking capacity rather than the
additional firm energy which will need to be added at the rate of about 800,000 kw
per year starting in 1974-75.
The region within the borders of the United States is deficient in fossil fuels. There
are no known deposits of oil or gas in quantities sufficient to warrant development
on a scale required for large thermal plants, and the only known coal deposits which
justify exploitation will be mined for use in a power plant (Centralia, Washington)
now under construction.
It therefore appears that the Pacific Northwest, as a region, should meet most of its
power requirements in the future by constructing nuclear plants for energy and
installing additional hydro units for peaking purposes. To accomplish this develop-
ment the Hydro-Thermal Program has been sponsored jointly by Bonneville Power
Administration and all of the investor-owned and public utilities in the region. The
Centralia coal-fired plant and the Trojan Nuclear Plant are the first two units in
this program.
After determining that a nuclear plant was the most feasible way of providing energy
a
requirements, alternative sites were evaluated.
Potential sites for the Company's service territory exist in three general geographic
areas: The Northern Oregon Coast; the Mid-Willamette Valley and the Lower
Columbia River. The Company commissioned Bechtel Corporation to make site
evaluation studies.
As a result of the conclusions reached in these studies and the Company's evaluation
of other environmental and economic factors the Trojan site was selected. The
Northern Oregon Coastal sites were ruled out because much of this coast is uniformly
populated with beach homes and resorts; most of the remainder is State or Federal
land. Transmission lines would have to cross the Coast Range through scenic areas,
which should be avoided. Although it was determined that sites in the Mid-Willamette
Valley would be suitable for plants with cooling towers or cooling ponds, much greater
supply of water in the Columbia River made it appear that there were advantages in
locating the plant on that river. It was considered undesirable to locate a plant in
the Columbia River Gorge because of its scenic values. Sites east of the Cascade
Range were not considered because of the concern over constructing more transmission
lines through public forest in the mountains.
-48-
-7-
-
Thus limited, six sites were evaluated on the Lower Columbia River, one upstream
from Trojan and four downstream from Trojan. The land at the upstream site was
not available at any price. The downstream sites offered no advantages over
Trojan and would have required substantially longer transmission lines. They also
had higher tidal ranges, some had less favorable foundations and the sites farthest
downstream had an undesirable salt water wedge in the river.
Having selected the Trojan site and in view of the State of Oregon's adoption of
Federal Water Quality Standards, which limited the use of once-through cooling,
alterative methods of cooling were evaluated. Consideration was given to pumping
the cooling water in excess of 35 miles to the Tualatin River Valley for irrigation,
industrial and municipal uses. It was determined in consultation with the appropriate
County Commissioners that there was not a market for the quantity of water involved
and that the project was not economically justified. A cooling pond was ruled out
because of topography. Various types of mechanical draft and natural draft cooling
towers were studied prior to deciding that a natural draft cooling tower was the
alterative most compatible with the environment of the site.
d.
The relationship between local short-term uses of man's environment and the
maintenance and enhancement of long-term productivity.
The effect of the Trojan Plant upon the environment, combined with that of all other
nuclear plants likely to be built in the Pacific Northwest during the era of fission
power plants will be so small that it probably will be incapable of measurement. In
the absence of additional hydro-generating energy, it will have less impact on the
environment than any other method of power generation, and there are many ecologists
who believe that nuclear plants have less effect on the environment than hydro plants.
The high standard of living in the United States cannot be achieved without a bountiful
and inexpensive supply of electric power. This is especially true in the Pacific North-
west, where much of the economy is founded on exceptionally low-cost power. Ever
increasing quantities of electrical energy will be required to maintain a status quo in
out standard of living as our population increases and as our uses of electric power
multiply. Even greater quantities will be needed to increase productivity and provide
for important new uses, including waste treatment and air and water quality enhance-
ment. The employment of electric energy has no ill effects upon environment, in
contrast to most other means of using energy for man's purposes. From the standpoint
of the effect upon the environment, nuclear generation is the best way to produce
electricity, the cleanest form of energy.
Any irreversible and irretrievable commitments of resources which would be involved
in the proposed Trojan Plant should it be implemented.
The only resource which will be irretrievable is a small portion of the uranium fuel
used in the production of heat. The plant will evaporate water in the cooling tower,
but by natural processes this resource will again return to liquid form.
.
-49-
- 8 -
-
ADDITIONAL REQUESTED INFORMATION
la. The environmental studies you are conducting or plan to conduct.
NUS's study
(1)
on the environmental effects of cooling tower operation and its
conclusions have been previously stated.
The Company also sponsored two research studies by Battelle-Northwest (2,
(2, 3)
and
one by the USGS to predict the temperatures and flow conditions of the Columbia
River at the Trojan site. During this period, four thermographs and one stage
recorder were installed and maintained on the Columbia River. After the decision
was made to provide plant cooling by use of a cooling tower, the number of
thermographs was reduced to one and the arrangement for the stage recorder was
terminated. Plans have not been completed for temperature studies after the
plant is in operation.
1
In addition to temperature studies, the Company sponsored two aquatic biological
studies at the Trojan site, also by Battelle-Northwest. These were commissioned
to determine the types of fish at the site and their response to elevated temperatures.
It was determined that the great majority of the fish are migratory; few fish are
resident in this reach of the river. Anadromous species comprise the important
commercial and sport fishery species. Copies of the studies by Battelle-Northwest
have been previously forwarded to Mr. Harold L. Price, Director of Regulation,
Atomic Energy Commission. (4, 5)
The Company has on its staff a Chief Aquatic Biologist who spends much time
researching the literature on the effect of nuclear plant discharges on the environ-
ment, especially on fishes and aquatic biota and generally keeping familiar with
current research and thinking in this field.
Plans for an environmental radiation monitoring program that will be initiated prior
to operation of the plant and will continue throughout its operation are described
in Section 11 of the Preliminary Safety Analysis Report. This plan has received
substantial approval by the Oregon State Board of Health.
1b. Any compatible recreation uses planned for the site, or present recreational uses
which will be impaired or damaged by the facility.
!
Recreational development of the Trojan site is an important element of a master
plan prepared by Lawrence Halprin and Associates of San Francisco, nationally
recognized environmental designers.
-50-
-9-
They investigated and analyzed the various physical and visual aspects of the land
and the Trojan Nuclear Plant buildings and conducted an ecological survey. From
these studies evolved a pattern of development of the site that would preserve in
its beautiful natural state as much of the property as possible and confine intensive
development to a relatively small portion of the land.
A large pond presently frequented by whistling swans in winter is being preserved
in its natural condition. This preserve for the swans and other shallow water-
oriented bird life will provide recreational enjoyment to the public.
A successful search for Indian artifacts has been organized under trained supervision
in likely portions of the site prior to and during site development.
Planned utilization of waste heat from the plant for accelerated fish rearing at the
site by the State of Oregon will provide a recreational fish viewing facility and
an increased supply of sport fish in the off-site waters in which they will be planted.
The site will be landscaped and the appropriate facilities will be constructed to
afford daytime recreational use of the site area by the public for:
Family and group picnicking
Swimming in warmed water
Boating
Hiking
Sports and games
Fishing
Birdwatching
Fish rearing pond visits
A Visitors' Center will be constructed at the site during 1971. It will be operated
as an educational facility and tourist attraction. It will place a heavy emphasis
on audio-visual presentations which can be changed flexibly as future requirements
indicate. A proposed feature is computerized "teaching machine" which viewers
would operate to acquire knowledge of nuclear energy.
Prior to acquisition of the land by the Company for power plant use, a portion of
the site had been studied by the Oregon State Parks Department for development
as a State park. A proposal for this State park development was not adopted,
primarily because of the extent of pollution of the Columbia River. The Trojan
development will include an artificial lake large enough to accommodate most
water-oriented recreational uses, thus overcoming the restrictions imposed by the
polluted condition of the adjacent river.
The only recreational use made of the site prior to its acqusition for the Trojan
Plant was a small amount of duck hunting and perhaps occasional hunting of
small game and deer, although most of the area had been posted against hunting
in recent years.
-51-
- 10 -
-
Ic. Those pollution control measures which were instituted, or are expected to be
instituted during construction of the facility.
One of the first permanent installations at the site will be the sewage treatment
plant described earlier. This plant will be in operation during the period of major
construction of the plant. Its capacity is sized to accommodate the operating staff
plus the largest number of visitors expected to visit the site at one time.
By providing a natural draft cooling tower for dissipation of the plant waste heat,
and by the conservative installation of known effective equipment in our radwaste
system, pollution control measures are being provided which are expected to
reduce to a minimum the amount of pollutants released to the environment.
ld. The state and local agencies from which licenses, permits, or other approvals relating
to the environmental matters must be obtained before operation of the facility may
begin.
The Trojan Plant has received a Waste Discharge Permit from the Oregon Department
of Environmental Quality (DEQ). The application for the permit and the detailed
report accompanying it were fumished by the DEQ to all concemed State and Federal
agencies, including all of the agencies having responsibilities in the environmental
area. A permit was granted after our application was completely reviewed by the
staff of the DEQ and by the several agencies concerned.
.
The State of Oregon has recently created a Goveror's Nuclear Plant Siting Task
Force. It is the responsibility of this group to recommend to the Governor the
approval or disapproval of a nuclear plant site. It is composed of the heads of
all State departments concerned with the environment, as well as a few others.
This agency has been kept fully informed of progress made in obtaining a Construction
Permit for the plant and in its design and site preparation. It held a public meeting
on May 21, 1970, at which the project was formally described to them. Following
this session they will hold a public hearing on July 2, 1970, at which the public,
including the various organizations interested in environmental protection, will be
invited to present their views and ask questions regarding the Trojan Nuclear Plant.
A water right permit is required from the State Engineer and the Company is keeping
him informed on all matters of his interest. Permits for construction of all structures
in the Columbia River, such as water inlets and outlets, the recreational boat harbor
and piers, and the temporary barge unloading facility are required from the Corps
of Engineers and a request for these is in progress. The Federal Water Quality
Administration has been asked by the Corps of Engineers to comment on this
application and the Company has agreed to furnish them with detailed design
information on all parts of the plant having an impact on the river, including the
intake and discharge structures.
-52-
- 11 -
REFERENCES
1.
Environmental Effects of Cooling Tower Operation at the Trojan Site
For Portland General Electric Company, January 1969.
2. Research Related to the Development of a Power Reactor Site on the
Lower Columbia River, June 15, 1968.
3. Research Related to the Prediction of Temperature at a Power Reactor
Site on the Lower Columbia River, March 1, 1969.
4. Timing and Abundance of Fishes Near Prescott, Oregon Important to
the Commercial or Sport Fisheries of the Columbia River, February 1968.
5. Responses to Elevated Temperature of Fishes near Prescott, Oregon
Important to the Commercial or Sport Fishery of the Columbia River,
May 1968.
-53-
APPENDIX B
ASSISTANT SECRETARY OF DEFENSE
WASHINGTON, DC. 20301
OSTATES
OF AMERICU
HEALTH AND
ENVIRONMENT
4 AUG 1970
4
Mr. Harold L. Price
Director of Regulation
Atomic Energy Commission
Washington, D. C. 20545
Dear Mr. Price:
A review has been made of the environmental report prepared by the
Portland General Electric Company for the Trojan Nuclear Plant as
requested by your letter of 29 June 1970. The review has included
an examination of the supporting documents prepared by Batelle
Memorial Institute. In addition, the preliminary safety analysis
report for the Trojan Plant has been reviewed for the purpose of
evaluating potential accident impact on the environment.
The following comments on the environmental statement are provided:
1. Page 2, paragraph a.l.ii. and page 4, paragraph 2.2.iii.
Radioactive releases. Insufficient information is presented within
the statement to permit evaluation of the environmental impact.
Estimated radioactive releases during normal operations and accident
conditions should be presented and related to the AEC limits of
10 CFR 20 and 10 CFR 100. It is noted, however, that this information
is derivable from the preliminary safety analysis report.
2. There is no indication that meterological survey data of the
area are available or that any provisions have been made to have
meterological instrumentation installed near the off-gas release
point. The capability to determine the least desirable conditions
for releasing off gases would be an added safety factor to man and
bis environment.
Sincerely,
Hanca
GeorgoJ.'Hayes
Brigadier General MC USA
Principal Deputy
APPENDIX C
50 -3
United States 544 ime i of the Interior
:
OROCC OR TU! SLCRETARY
WASHINGTON, DC. 202,10
19PS
요​.
GEGEN
AUG 20 1921
U.S. ITO!"
CER
AUG 18 1970
E
TUTTI
l'ail S:11
Dear Mr. Price:
This is in response to your letter of June 29 requesting our comments
on inc drait environmental statement prepared for the Atomic Energy
Commission by the Portland General Electric Company for the Trojan
Nuclear Plant now being construciet at a site adjacent to the Columbia
River in Oregon. The statement suismitted by the Portland General
Electric Company on May 29 and supplemented by letter of July 9 was
reviewed by the several bureaus within this Department which have
special expertise with respect to the environmental impact of the
project.
The views of the Fish and Wildlife Service on the Trojan Nuclear Plant
were provided to your office by letters dated May 6, June 26, and
July 28. These letters explain the concern of this Department for pro-
tection of the important sport and commercial fisheries that coulů ve
affected by the project if adequate safeguards are not taken. We
commend the company for its decision to install cooling towers for
the prevention of thermal pollution. We remain concerned, however,
about the possible mechanical hazards to fish posed by the cooling
water intake structure and by the release of plant wastes to the
Columbia River. Even though greatly diluted, toxic chemicals, in-
cluding radionuclides, may impose unnecessary hazards to fish.
Mechanical injuries to fish at the cooling water intake could be a
problem if adequate screening facilities are not installed. Adequate
environmental monitoring programs will be needed to determine
whether or not the facility is operated in a manner that will protect
fish and wildlife resources satisfactorily.
We note that the Portland General Electric Company has provided
information on water use and probable effects of the proposed plant
on water quality. Even though paragraph 7(b) of the Council on
Environmental Quality Intering Guidelines provide that water quality
considerations may be covered by the water quality certification from
the appropriate State(s), interstate, or Federal pollution control agency,
we are convinced that the intent of the National Environmental Policy
-55-
Aci of 1969 is io assure a coordiüated consideration of all relevant
factors, Ifor this reason we believe that water quality considerations
should be covered and we have included them in our comments. This
is in no way intended to indicate that the Environmental Report and
comments thereon are a substituie for the thorough review of the pro-
posed facililies and certification by the Oregon water pollution control
agency and the concurrence of the Washington water pollution control
agency
It is noted iha: the Columbia River is a boundary stream and that
waters of the State of Washington üre likely to be affected by any dis-
charge from the Trojan Nuclear Prant. Information on proposed dis-
charges must therefore be submitted to the State of Washington for
their determination as to whether their water quality standards may
be violated.
While not a permit, per se, the discussion of "The state and local
agencies from which licenses, permits, or other approvals relating
to the environmental matters must be obtained before operation of
the facility may begin" is inadequate in its failure to reference (1) the
need for certification by the State of Oregon that it can be expected
that the plant will meet applicable water quality standards, (2) the
need for appraisal by ile Secretary of the Interior as to whether there
may be an interstate effect, and (3) the need for an appraisal by the
State of Washington that it can be expected that plant discharges will
meet their water quality standards, all as required by Section 21(b)
of the Federal Water Pollution Control Act, as amended by the Water
Quality Improvement Act of 1970.
The determination of the company to install and use a natural draft
cooling tower to dispose of essentially all of the waste heat generated
by the project covers the major concerns of the Federal Water Quality
Administration regarding water use and consequent effects on water
quality in the Columbia River. Together with assurances that the
facilities will be operated to minimize releases of (1) chemicals used
for control of tower and condenser scale and corrosion, (2) liquid
radioactive wastes resulting from fission in the reactor and (3) sani -
tary wastes from operating personnel, construction forces and visitors,
the control facilities would appear to meet or exceed the minimum re-
quirements necessary to meet water quality standards now in effect or
which may be adopted in the foreseeable future.
2
-56-
Comincnts on the geologic and hydrologic aspects of the project were
provided to your office by the Geological Survey on July 9. Based on
material submitted by the Portlanci General Electric Company, there
appears to be adequate evaluation of those aspects of hydrology and
geology that would aífect construction and operation of the plant.
'No mineral resource would be adversely affected by the proposed
construction,
The information in the Environmental Report appears reasonable so
far as it goes but the consideration of alternative measures and effects
are inadequately presented. An essential requirement of the National
Environmental Policy Act of 1969 is that alternative courses of action
and their implications be clearly presented and appraised for public
evaluation. The Environmental Report emphasizes conclusions, with
passing reference to alternatives considered in some cases, rather
than the evaluation and presentation of the effects of the alternatives
considered which lead to the conclusions.
In a number of cases, as for example the discussion of chemical
releases, radioactive releases and sanitary wa stes on pages 3 and
4 of the Report, only the assertion that releases will be well within
applicable standards, that State requirements will be met, or that
the resulting concentrations will be extremely small is presented.
Such assurances are desirable but they are not considered sufficient
to base a conclusion that appropriate consideration has been given to
all relevant factors.
Information on the energy and economic commitment to waste control
and the anticipated improvements in environmental quality does not
appear possible for adequate appraisal from the material submitted
by the company.
In its present form, the.draft environmental statement inadequately
describes the environmental impact of this proposed nuclear power
station. It has been only through extensive correspondence with
our field offices and supplemental information submitted by the
.
3
...
-57-
Portland General Electric Company that we have learned the Company
plans to do everything possiölc and feasible to protect the environment
in connecíion with the Trojan Plant. On this basis, we expressed no
objection to the issuance of the construction permit provided it contain
the condition proposed in the letter to you from the Commissioner of
Fish and Wildlife Service dated July 28. Further, we have the Company's
assurance that they will contiruz to work closely with our field people
during the construction of the plant.
We hope these commcnts vil help you in the development of an environ --
mental impact statement thai gives proper consicieration to the arcas
of concern. Accordingly, we look forward to the opportunity oí reviewing
the revised environmental impact statement.
Sincerely yours,
Leslie L. Blasgan
Assistany Secretary of the Interior
Mr. Harold L. Price
Director of Regulation
U.. S. Atomic Energy Commission
Washington, D. C. 20545
--
4
es
-58-
IN REPLY REFER TO:
UNITED STATES
DEPARTIMENT OF THE INTERIOR
FISH AND WILDLIFE SERVICE
WASHINGTON, D. C. 20240
نه
!!
1 2 8 1970
Mr. Harold L. Price
Director of Regulation
U.S. Atomic Energy Commission
Washington, D.C. 20545
Dear Mr. Price:
This will supplement our letters of May 6 and June 25 cominenting on
the application by the Portland General Electric Company for a
construction permit for the proposed Trojan Nuclear Plant, to be
located on the Columbia River, Oregon, AEC Docket No. 50-344.
We have reviewed the Applicant's environmental report of May 29 and
the supplemental material submitted to your office by Mr. E. C. Itschner,
Vice President of the Portland General Electric Company, in his letter
of July 9. He furnished a copy of this letter of July 9 to this
Department's Pacific Northwest Regional Coordinator, Mr. L. B. Day,
who in tum furnished it to the Department's Washington office.
In view of the assurances on water quality and fish protection furnished
by the Company, we now have no objection to the issuance of a construction
permit for this project.
There remains sore concern, however, regarding (a) the effect on fish
and wildlife of chemical discharge from the plant, and (b) the possible
damage to fishery resources resulting from unscreened or inadequately
screened diversions of water from the Columbia River.
We request that the Atomic Energy Commission incorporate the following
condition in the permit and assure that the Company adheres to it:
The Permittee shall make such modifications in project
structures and operation for protective screening of
all water intakes to exclude fish, and for reduction
in the concentration of toxic chemicals resulting
from plant discharges as may be found by the Atomic
Energy Commission to be needed to prevent damage to
fish and wildlife resources following recommendation
by the Department of the Interior after operation
of the plant begins.
Sincerely yours,
ما میا بی بی بال و بختیاری در
-
-59-
APPENDIX D
IDE
MALIN
のり
​DEPARTMENT OF HEALTH, EDUCATION, AND WELFARE
CITANTS
WASHINGTON, D.C.
20201
Ai4G 251970
ORIROCOI THL SECRETARY
.
Mr. Harold L. Price
Director of Regulation
U.S. Atomic Energy Commission
Washington, D.C. 20545
Dear Mr. Price:
>
Thank you for your letter of June 29, 1970., to Mr. Roger Strelow
transmitting the "Environmental Statement" for the proposed Trojan
Nuclear Plant. We have considered this statement in our review of
the facility as required by the provisions of the National Environ-
mental Policy Act of 1969. In response to your request for comments,
we are pleased to provide the enclosed report by our Bureau of
Radiological Health which states our position on the Trojan Nuclear
Plant based on an evaluation of the public health and environmental
aspects of the facility.
.
The Bureau's review is based primarily on information contained in
the Preliminary Safety Analysis Report. It is recognized that
other design information may become available before a construction
permit decision is made, but we believe our environmental evaluation
is substantially completed at this time, unless, of course, major
changes occur.
We appreciate the opportunity to comment on the proposed Trojan
Nuclear Plant environmental statement. When the other agency
comments are compiled, we would be most happy to receive them.
If this Department can assist you further in this matter, we would
be happy to do so.
Сл
Sincerely yours
C
being
dor
Roger 0. Egeberg, M.D.
Assistant Secretary
for Health and Scientific Affairs
Enclosure
>
(
.
-60-
191
PUBLIC HEALTII REVIEW
TROJAN NUCLEAR PLANT
LL
August 1970
£
Enell
Project orficer:
Approved :
E.J. Vineber
Ernest D. Harward
Chief, Nuclear Facilities
Branch
U.S. DEPARTMENT OF HEALTH, EDUCATION, AND WELFARE
Public llcalth Service
Environmental llealth Service
Bureau of Radiological Health
Division of Environmental Radiation
Nuclcar Facilities Branch
2051
INTRODUCTION AND CONCLUSIONS
-61-
The purpose of this report is lo summarize the results of an evaluation
by the Public Health Service of the cnvironmental effects of the Trojan
Nuclear Plant proposed for construction near Prescott, Oregon.
The
evaluation is based on a site survey and information provided by the
Portland General Electric Company in the Preliminary Safety Analysis
Report (PSAR)
(1)
and the Company's "Environmental Statement" relative
to the National Environmental Policy Act.
The technical review of
these documents was conducted by the staff of the Nuclear Facilities
Branch of the Service's Bureau of Radiological Health.
The review and evaluation covered by this report are directly responsive
to requirements placed on Federal agencies by the National Environmental
Policy Act and as such are intended to state the position of the Federal
health agency on the environmental effects of this facility.
The report
is also intended, in the traditional role of the Public Health Service,
to provide information to the Oregon State Board of Health for use in
developing their radiological health program for the facility.
A number
of technical documents, listed as references 2, 3, 4, 5, and 6 have
>
>
been developed to expand the details of and support the discussions
presented.
Extensive reviews were made of site suitability, radioactive waste
handling, environnental surveillance, emergency planning, and potential
radiation doses to the public.
Considerablc use was made of data
-62-
2
reported by the Oregon State Board of Health from a radiological survey
(7)
of the lower Columbia River.
The major conclusions reached are as follows:
1.
The Trojan site has an adequate cxclusion distance and the population
density in the vicinity of the site is approximately the same as the
average for 21 other nuclear power plant sites already approved by the
AEC.
Thus, the Trojan site is considered suitable for the facility for
these reasons and because of favorable meteorological and hydrological
conditions.
2. Although our review indicates that discharged radioactivity will
have a negligible effect on the environment, the applicant has not stated
in his environmental statement a philosophy of waste management that
radioactivity discharges will be processed by plant systems so as to
kecp them to the lowest level practicable.
We strongly encourage that
his statement reflect such a philosophy because radioactivity concentrations
in the Columbia River are already measurably above natural background due
to radioactive waste discharges to the river from the Hanford reactors
upstream.
This situation makes it imperative in the health interest
for the AEC to consider the Trojan plant in the context of multiple
siting of nuclear reactors and to require the best waste management
practicable to reduce the overlapping effects of the two sites.
Federal
regulations clearly state that maximim permissible concentrations are
to be applied above natural background, not above existing levels.
-63-
3
3.
Reconcentration of expected Trojan discharges in freshwater fish will
be minimal compared to that which already exists due to the radioactive
waste discharges to the river from the Hanford reactors upstream.
4.
The effects of gascous waste discharges on population dose are
concluded to be both immeasurable and insignificant.
5.
Surveillance of liquid waste discharges both at the point of discharge
and in the river must, because of the existing river background, clcarly
determine specific radionuclides prior to and during operation.
Since
the river contains radionuclides which differ from those expected from
the Trojan plant, discharges from Trojan must be interpreted on an analysis
of specific radionuclides rather than a gross-beta analysis basis.
6.
The applicant has yet to submit an emergency plan for the facility.
Sucli a plan should be developed recognizing the States authority and
responsibility for protection of the public in the event of all non-routine
situations.
The State of Orcgon should take the lead in the development
of the plan and the interests of the State of Washington should be
integrated into the plan,
1.
Within the context of the above we are of the opinion that the
Trojan Nuclcar Plant can be built and operated without significant
effect on the environment or the public. The only alternates to the
facility appear to be a fossil fuel plant or no plant at all.
Since
the anticipated radiological effects are so small, neither of these
alternates appears necessary. Although some buildup of radioactivity in
the natural resources of the region may occur, the effects on the
4
-64-
FACILITY INFORMATION
The plant will employ a pressurized water reactor and will have a maximum
net power output of 1153 MWe.
It will occupy a 623 acre site located
31 air miles from Portland, Oregon and four miles from Rainier in
Columbia County, Oregon on the Columbia River.
Westinghouse Electric Corporation will supply the nuclear steam supply
system and will, along with the Bechtel Corporation, aid the applicant
in the design construction, testing, and startup of the plant.
Site
preparation is scheduled to begin around June 1, 1970, and construction
is scheduled for completion in time for fuel loading to begin by February 1,
1974.
The plant is scheduled for commercial power generation by
>
September 1, 1974, The only major feature of the Trojan Nuclear Plant
not described in the PWR repor??s the cooling tower employed at the
(2)
Trojan site. Trojan will employ one natural-draft cooling tower.
(4)
capable of operation in either a closed-cycle or a helper-cycle mode.
The design features (see Appendix I) are generally the same as other PWR's
manufactured by the Westinghouse Electric Corporation. The various sytems
have previously been reviewed in detail
ed in detail(2) and on the basis of this
experience, we are satisfied that the facility contains the best safety
and waste control cquipment available at the time the design was selected
for control of radioactivity discharges during routine operation as well as
for accidents.
Although more efficient technology has recently become
available for PWR systems, it is not reasonable at this time to require
the design changes necessary to use all of these systems.
Some of the
systems such as additional treatment of gaseous and liquid wastes may be
feasible and should be encouraged where practicable.
-65-
5
Appendix II compares the Trojan site with other PWR sites that have been
approved,
From the data in Table 3 of Appendix II the ratio of the
actual exclusion radius to the calculated value for Trojan is 0.265,
a
value typical of those for the other sites presented.
The values of
this ratio for the low population zone and population center distances
for the Trojan site are 0.102 and 0.183, respectively, and are somewhat
less than the correspond inx: values for the other sites.
As a rule,
however, it is the exclusion radius wliich is the limiting distance
factor when evaluating the potential consequences of a reactor accident.
Therefore, even though the relative low population zone and population
center distances are somewhat less for Trojan than for the other sites
in the comparison, this is not considered sufficient reason to classify
the Trojan site as unsuitable.
LIQUID WASTE DISCHARGES
There are two significant areas of consideration associated with liquid
waste disposal at the Trojan site.
The first of thesc is that there are
appreciable concentrations of radionuclides from other sources already
present in the Columbia River.
The second is that because Trojan
will operate with a cooling tower in either a closed-cycle or helper-
cycle mode, there will be little water available for dilution of the
liquid waste prior to discharge into the Columbia River.
Each of these
will have an important effect on liquid waste management procedures at
the Trojan plant.
-66-
6
Table 1 lists the significant radionuclides and their respective
concentrations observed by the Oregon State Board of Health in studies of
the lower Columbia River from 1961 to 1967.
The concentrations shown in
Table 1 are averages of 52 samples taken and analyzed from August 1962
to July 1967.
l'lic samples upon which the data are based were taken at
Goble, about 1.5 miles upstream of the Trojan site.
The data show that
the average gross radionuclide concentration in the Columbia River over
the period from 1961 through 1967 from other than natural sources is
1.44x10-6 uCi/cm3 (7) which exceeds the gross discharge limit of
10-7 _Ci/cm? specified by 10CFR20. For this reason, the Trojan waste
3
discharge limit will have to be based on a specific radionuclide analysis.
This practice is also advisable since the radionuclides from Hanford
will be appreciably different from those discharged from Trojan.
It is
recognized that many of the Hanford reactors have coased operation since
the 1967 measurements, but we believe the data are indicative of situations
that could rccur making the specific analysis technique a valid one to
apply routine ly.
In Table 11.1-3 of the PSAR, the applicant has specified by radionuclide
the estimated annual discharge rates.
The applicant has also specified
an annual average cooling tower blowdown rate of 3,000 gpm and 290 days
of operation per year.
Discharge concentrations have been calculated
from these data. The concentration in the discharge water, less tritium,
will be 1.56x10-9 „Ci/cm3, and the tritium concentration will be 1.01x10-4
uCi/cm3. These values do not include the existing 1.44x10-6 uCi/cm3
1
67-
7.
Table 1
Average Radionuclide Concentrations in the
Columbia River, 1961 through 1967 (7)
Nuclide
Concentration
(uCi/cm3)
MPCW
(uCi/cm3)
Fraction
of MPCW
P-32
Cr-51
3.3x10-8
1.35x10-6
3.6x10-8
Zn-65
2x10-5
2x10-3
1x10-4
6x10-5
1x10-5
1.65x10-3
6.75x10-4
3.60x10-4
2.17x10-4
1.00x10-3
Zr-95-Nb-95
1.3x10-8
1.0x10-8
Ru-103-Ru-106
-
Totals
1.44x10-6
3.90x10-3
$
-68-
8
activity concentration in the Columbia River, Expressed in terms of the
maximum permissible concentration, Trojan liquid waste discharges will be
at 0.5 percent of the MPCW, exclusive of tritium.
The tritium concentration
is 34 percent of its respective MPCw. Again, these values do not include
the 0.4 percent of MPCw which has been reported in the Columbia River due
to Hanford discharges and fallout activity.
The discharge concentration corresponding to the annual average cooling
tower blowdown rate of 3,000 gpm and 290 days of operation per year would
be at 1.6 percent of the discharge concentration limit for an unidentified
mixture of radionuclides excluding tritium.
This value is somewhat higher
than the corresponding value reported for presently operating PWR plants
because of the relatively small amount of on-site dilution which will be
available at Trojan. Typically, liquid waste discharges from a PWR plant
are at <1 percent of the 10-7 uči/cm3 discharge concentration limit.
(5)
This condition is not particularly significant, however, since considerable
dilution will rapidly occur in the Columbia River.
.
With reference to reported liquid waste discharges for presently operating
PWR'S, Trojan's estimated total annual liquid waste discharge of 2 mi/yr,
excluding tritium, seems low unless the applicant plans to add treatment
facilities not included in present design reports. The values reported
for operating PWR's typically range from ~ 10 mCi/yr to ~ 1 Ci/yr excluding
~
tritium.
(5)
It therefore seems likely that the applicant's estimate of
-69-
9
Trojan's liquid waste discharges significantly underestimates what the
actual discharges will be.
This conclusion is further supported by the
fact that the power levels of the presently operating PWR's are signifi-
cantly lower than Trojan's power level.
The estimated tritium discharge
values are reasonably comparable with the reported values for presently
operating PWR facilities.
ENVIRONMENTAL SURVEILLANCE
In the past, extensive radiological surveillance programs have been
(7)
conducted along the Columbia River by the Oregon State Board of Health,
It is suggested that these programs be continued and expanded to monitor
both the effluents and the river for specific radionuclides which will
be discharged and which could be significant in terms of reconcentration
in freshwater fish.
Specifically, the program should include monitoring
of liquid effluents, river water, and fish samples for Sr-89, Sr-90,
I-131, Cs-134, and Cs-137.
Should detectable concentrations be found,
the Sr-89 to Sr-90 and Cs-134 to Cs-137 ratios will provide an indication
as to the relative contributions of fallout and Trojan discharges. Also,
since radionuclides will be present in the river from Hanford discharges,
the surveillance program should document these by nuclide prior to and
during operation especially for the nuclide P-32.
As indicated in the section on reconcentration in freshwater fish,
a
conservative dilution factor for points downstream of the Trojan discharge
canal is 1.57x10-14 uči/cm² per uCi/day discharged from the plant.
3
Applying this dilution factor to the expected activity concentration
-70-
10
at the discharge point yields concentrations of 2.49x10-12 uCi/cm3 for
gross activity other than tritium and 1.46x10-7 HCi/cm3 for tritium.
From this it is concluded that the radioactivity concentrations in the
river water due to operation of the plant will be well below detectable
levels.
Also, whatever activity might be present due to Trojan discharges
will be masked by activity concentration already in the river due to
Hanford discharges, 1.44x10-6 dCi/cm3 as shown earlier. Nevertheless,
it is important that the surveillance program for the facility confirm this
conclusion.
Such a program should be developed in such a way that the
State of Oregon will be able to use the data to determine population doses
from all sources including the facility.
.
RADIOLOGICAL ASSISTANCE PLANNING
Public health programs involving the nuclear power industry must provide
for protective action plans for uncontrolled releases of radioactivity
whether from a small incident or a major accident.
Failure to develop
adequate plans could result in unnecessary risk to the public.
The
health department and the applicant are strongly encouraged to work jointly
to develop plans to detect, evaluate, and resolve the consequences of a
full spectrum of uncontrolled releases of radioactivity to the environment
and to incorporate the details of such a plan in a written agreement.
The
requirements and considerations of such plans are discussed in reference 6.
It is suggested that cooperative agreements also be reached with Washington
State and that all such agreements be reached prior to the construction
permit hearing in order that the State may make its position known to
the public.
-71-
11
APPENDIX I
GENERAL INHORVATTON
The 101 lainny i :il
::100mly on the lonjor che::is: 1) and openinling characlar-
izcicios
Ilır: pl.1111:
Rinted Electrical Power Output ();ros)
1198 MWe
Rited Electrical Power Output (net)
11.53 MWC
Rated Thermal Power Level (nuix i mun)
3570 MWC
Maximum Overpower
12%
Nominal Primary System Pressure
2250 psia
Coolant Flow Rate
132.7x10° 1b/hr
7x106 /
Number of Fucl Assemblies
193
Fuel Cladding Material
Zircaloy 4
Fuel Rod Array in Assembly
15x15
Total Number of Fuel Rods
39,372
Fuel Loading Technique
3 region
nonuniform
Nuinber of Rod Cluster Control Assemblies
Full Length
53
Partial Length
8
Control Mirterial
B, C
4
,C
Number of Absorber Elements per RCCA
20
Maximum Fucl Clad Surface Temperature
at Nominal Pressure
657°F
Maximum Fuel Center Temperature at 100% Power
4140°F
-72-
Average Thermal Output
7.0 Kw/it
Maximum Thermal Output
18.8 Kwist
Number of Primary Coolant Loops
4
Reactor Coolant Pumps Capacity
88,500 gpm/pump
Reactor Inlet Temperature, at 100% Power
552.50F
Reactor Outlet Temperiture, at 100% Power
616.70F
Reactor Coolinnt System Design Pressure
2500 psia
Reactor Coolant System Design Temperature
650°F
Containinent
Volume
1,980,000 ft3
Design Pressure
60 psig
Maximum Allowable Containment Leak Rate
0.2% per day
:
13
-73-
APPENDIX II
COMI:11:1::ON WITIL OTHER PICTUARE LOWER I'LANT ::111:::
Table ? presiills it
i oma ison of the population density lound the Trojan site
with several other nuclear power stations. The populations within 10 miles
and within 50 miles, when listed in the safety analysis report for the given
power station, were tabulated in the table.
The populations within 10 miles
and within 50 miles of Trojan are both approximately cqual to the corresponding
averages for the other 21 sites listed.
The exclusion radius, low population
zone, and population center distance were calculated as
a function of power
level based on a worst-case accident, a highly conservative meteorological
dilution conditions, no active (only passive) engineered safeguard systems
working, and a 300 rem thyroid inhalation dose limit, Table 3 compares the
values calculated by methods used in TID-14844(12) with the actual values for these
three parameters as given in the safety analysis reports for Trojan and 14
other PWR nuclear power plant sites. In order to make the comparisons independent
of power level, the unit of feet/megawatt-thermal was used for the three siting
parameters.
In those cases where the actual distance is less than the
calculated distance, compensating engineered safeguards must be installed.
Table 2
Comparison of Population Density Around Nuclear Power Plants
Power Level
(MWC)
Year of
Population
Estimate
Year
Operational
Location
Population Populatior
< 10 miles < 50 mile
Type
Athens, Alabama
BWR
3293
1970, 71, 72
1960
22,040
523,940
Prince Federick, Md.
PWR
2450
1972, 73
1965
13, 180
2,371,880
Haddam Neck, Connecticut
PWR
1473
1967
1960
NA
49,640
45,959
Bridgman, Michigan
PWR
3250
1972, 73
1965
1,066,849
PWR
3250
1971, 72
1960
San Luis Obispo County,
California
151,490
Morris, Illinois
BWR
700
1959
1950
NA
Weld County, Colorado
HTGR
841.7
1973
1960
NA î
Buchanan, New York
PWR
615.0
1962
1960
NA
111stone Point Unit 1
New London, Connecticut
BWR
2010
1969
1965
2,270, 042
1 1,5701
3,5002
21,000
8,420
155,420
95,8641
118, 0002
9,712
36, 334
37,456
25,743
15,292
1469
1970
1960
NA
onee Units 1,2, & 3
2452
1970, 72,73
1965
692,501
Monticello, Minnesota BWR
Keowee Dam, South Carolina PWR
Lacey Township, New Jersey BWR
South Haven, Michigan PWR
Red Wing, Minnesota
PWR
1600
1969
1960
NA
2121
1970
1960
870,51.
1650
1972, 74
1960
NA
Lad cities Vaits 1&2
BWR
2255
1970, 71
1966
NA
PWR
2452
1973
1965
Cordova, Illinois
Clay Station, California
Russellville, Arkansas
Daisy, Tennessee
39,488
4,060
22,993
24,920
actor
cowns Ferry
Inits 1, 2, & 3
lvert Cliffs
Units 1 and 2
.
onnecticut Yankee
nald C. Cook
Units 1 and 2
Cablo Canyon
Units 1 and 2
esden Unit 1
Saint Vrain
idlaa Point Voit i
>nticello
ister Creek Unit 1
lisades
airie Island
Inits 1 and 2
ncho Seco
issellville
PWR
2452
1972
1967
1,348,54
155,47
604,12
quoyah Units 1 & 2
PWR
3423
1973, 74
1960
71
77.
Gravel Neck, Virginia
PWR
2441
1970, 71
Rainier, Oregon
PWR
3423
1960
1968
1974
399, 460
58,148
919,317
1,101,291
Homestead, Florida
PWR
2097
1970, 71
1966
42,397
1,378,938
Zion, Illinois
PWR
3391
1972, 73
1960
188,860
5,664,515
erage Population < 10 miles
59,903
Surry Units 1 & 2
"ROJAN
urkey Point
hits 3 & 4
con Units 1 & 2
erage Population < 50 miles
1,471,579
ermanent
- 75-
ummer
· Not Available
15
Table 3
Comparison of Actual and Calculated* Siting Distances
for Soine Selected PWR Plants
Reactor
Power Level
(MWC)
Exclusion Radius
(ft/MWC)
Calculated Actual
Low Population
Zone (ft/mc)
Calculated Actual
Population Center
Distance (ft/MC)
Calculated Actual
Connecticut
Yankee
1473
3.03
1.181
48.9
25.450
65.2
34.05
9.747
51.3
19.49
Indian Point Unit 1
615
4.48
2.276
69.5
NA
92.7
21.46
Oconee Units 1,2,&3
2452
2.55
2.153
40.2
12.920
53.6
45.22
-76-
43.3
38.585
57.8
39.83 T
2450
Calvert Cliffs
Units 1 and 2
2.55
1.538
38.9
31.4
51.9
41.8
Donald C. Cook
Units 1 and 2
3250
2.43
0.615
38.5
12.996
51.3
12.99
Diablo Canyon
Units 1 and 2
3250
2.43
0.812
38.5
Palisades
2121
2.64
1.084
Prairie Island
Units 1 and 2
1650
2.79
1.212
47.8
NA
63.7
83.19
Rancho Seco
2452
2.55
.856
40.2
NA
53.6
36.82
Russellville
2452
2.55
1.399
40.2
8.613
53.6
118.43
Sequoyah Units 1 and 2
3423
2.39
0.560
37.9
10.797
50.5
18.51
Surry Units 1 and 2
2441
2.56
0.675
40.3
NA
53.7
30.28
TROJAN
3423
2.39
0.633
37.9
3.85
50.5
9.26
Turkey Point Units 3 & 4
2097
2.74
2.517
43.4
12.589
57.9
22.66
Zion Units 1 and 2
3391
2.42
0.386
38.0
4.204
50.7
9.34
16
NA - Not Available.
*Assuming no operation of engineered safeguards according to the methods of AEC Report TID-14844
-77-
17
REFERENCES
1.
Portland General Electric (PGE), Preliminary Safety Analysis
Report--Trojan Nuclear Plant, Volumes 1, 2, and 3.
2.
"A Pressurized Water Reactor Nuclear Power Station," U.S.
Department of Health, Education, and Welfare, Public Health Service,
Bureau of Radiological Health, Division of Environmental Radiation,
Nuclear Facilities Branch, September 1967.
3.
"Guide for Environmental Surveillance Around Nuclear Facilities,"
U.S. Department of Health, Education, and Welfare, Public Health
Service, Bureau of Radiological Health, Division of Environmental
Radiation, Nuclear Facilities Branch, December
1967.
4.
Mills, Glen R. and William L. Brinck, "Cooling Towers for Nuclear
•
Facilities," September
September 1968.
5.
Logsdon, Joe E. and Robert I. Chissler, "Radioactive Waste
Discharges to the Environment from Nuclear Power Facilities,"
Division of Environmental Radiation, BRH/ DER 70-2.
6.
Martin, James E., "Establishing Off-Site Emergency Plans for
Nuclear Power Reactors," Public Health Service, Bureau of Radio-
logical Health, presented at the Midyear Topical Symposium of the
Health Physics Society, January 29-31, 1969.
-78-
18
7. Oregon State Board of Health, Division of Sanitation and Engineering,
Lower Columbia River Environmental Radiological Survey in Oregon,
Comprehensive l'inal Repori, 1961-1967, February 1968.
8. Chapman, William H., et al., "Concentration Factors of Chemical
>
Elements in Edible Aquatic Organisms," UCRL-50564, TID-4500, UC-48
(December 30, 1968).
9. Weaver, C.L., "A Proposed Radioactivity Concentration Guide for
Shellfish," Radiological Health Data and Reports, Volume 8, Number 9
(September 1967).
.
.
10. "Report of Committee II on Permissible Dose for Internal Radiation,"
International Commission on Radiological Protection (ICRP),
Publication 2 (1959).
11.
"Evaluation of Radiological Conditions in the Vicinity of Hanford for
1967," BNWL-983, UC-41 (March 1969).
12.
DiNunno, J.J., et al., "Calculation of Distance Factors for Power and
Test Reactor Sites," USAEC, TID-14844 (March 23, 1962).
13.
Code of Federal Regulations, Title 10, Part 20, Standards for Protection
Against Radiation, Appendix B, Table II, "Concentration in Air and
War Above Natural Background."
-79-
APPENDIX E
☺
OF
OCPARTMENT
US
HOUSING
S?ngti.ZXT OF HOUSING AND UREAN DEVELOPMENT
LOPMEN
AHOURS
WASHINGTOV, D. C. 20410
7anzo
Arown
$ ;
AUG 2 6 1370
OFFICE OF THE UNDER SECRETARY
IN REP
Y PEFER TO:
STELE
D
Mr. Harola Price
Director of Reguiations
U.S. Atomic Energy Commission
Washington, D. C. 20545
Dear Mr. Price:
This is ii rep.y to your letier of June 29, 1970, asking for our comments
on the preliminary erironmental statement of the Portland General Electric
Company ior its proposed Trojan Nuclear Plant near Prescott, Oregon.
The Trojan iuclear Piant vill be a pressurized water type nuclear power
piant with a single generating unit of 1730 megawatts net electrical
capacity. It will be located on the Oregon bank of the Columbia River,
42 miles from Portland, and immediately south of the small community of
Prescúir, Oregon,
HUD Connenc
This project is of particular interest because of the proposed use of a
coori tower and recirculation rather than the traditional method of
once-t rough cooiing in order to eliminate thermal pollution. Although
trere has not been enough experience with the environmental effects of
this type of instaliation to make specific comments, the discussion of che
er ironmental impact from the water vapor discharge indicates no serious
problems are expected from fog or ice formation in this location. However,
no ievailed meteorological data were submitted with the statement.
.ie cefer to other departments and agencies on safety and radiation standards.
He wi?! cafe: any comments on air or water quality standards to state and
Fecerai ne güiütory agencies. After reviewing the discussion of land use
-80-
· 2
iucrs Csicerca i čia Croja: site selection, we concur in trie Compari's
conciusic.i ürac transmissica 11.85 trough the sceric portions of cia
ccasi Rairge and pcie: pranë sites in ine Columbia River gorce should be
Choice
loubcriave, with the reservacions noted back, that portiand General
Slectric's statemei: indicates reasonable creatment of environmental cor -
Sequences.
HUD Reservations
5
1. The environmental statemen c as well as planning of the projects
shouiú be discussed with locui, regional or state planning agencies in
the eariy stage of development. The construction of this plantill hive
a significant impact on the future development and growth or the Lower
Corumbia River area. The regional planning agency is probably the best
source of information or forecasts of growth aid the potential impact on a
possible shortage of energy for urban requirements if the capacity planrid
for this piant is not made available on schedule. We believe it is impcrtant
to have this state.ent is viered by some means such as those established by
c?e Bureau ci the Budsiv in Circular A-95 and that the comments of the
regional agency, if any, be inciuded in the final envirormental statemer i.
In this case the designated A-95 agency is:
Columbia Region Association of Governments
429 S. W. 4 Th Avenue
Portiand, Oregon 97204
2. Consistency with local zoning should be discussed altrough after
reviewing the statement, it would appear that no zoning changes or iand
use permits are required in order to proceed with the construction of the
Trojan piant.
3. Tie usefuiness of the final environmental statement will be incrcased
if it contains a report or., or summary of, July 2, 1970, public hearing hield
by the Governoris Task Force on Power Plant siting.
4. When the final environmental impacü statement is publicly distributed
We would appreciate having a copy seni co our Regional Administra or,
Oscar Pecarson, Room 226, Arcade Plaza Building, Seattle, Washing on 9 101.
Sincerely yours,
04620 wh
Charles j.r Oriebeke
Deputy Under Secretary
-81-
APPENDIX F
FEDERAL POWER COiviviiSSION
WASHINGTON, D.C. 20426
IN REPLY REFCR TO:
OCT 9 023
Honorable Glenn T. Seaborg
Chairman
U. S. Atomic Energy Commission
Washington, D. C. 20545
Dear Dr. Seaborg:
This is in reply to Mr. Price's letter of September 4, 1970,
requesting comments of the Federal Power Commission on the en-
vironmental impact of the Trojan Nuclear station of the Portland
General Electric Company, AEC Docket No. 50-344.
Although the Federal Power Commission does not generally
have licensing jurisdiction over thermal power plants constructed
by electric utilities, the Commission does have a real and continuing
interest in the timely construction of generating and transmission
facilities to meet growing electric loads and the impact of the
facilities upon the environment in matters relating to air pollution,
water quality, and other factors.
Our comments on pertinent factors relating to the proposed
environmental state on the Trojan Nuclear station are enclosed.
Sincerely,
John
film. N. Nimekia
John N, Nassikas
Chairman
Enclosure
Comments on the AEC
Environmental Statement
stijenih
9
Providins for Tomorrow's Goals”
-82-
Federal Power Commission
Comments Relative to the Environmental Statement
on the Trojan Nuclear Plant of the Portland
General Electric Company
The comments herewith are directed to the relationship of the
electrical capacity of this unit to the prospective power supply and
demand situation of the system and region involved; to the fuel
supply situation related to the type of plant and its environmental
effects; and comments on the alternative means of meeting the power
supply needs for which this unit is proposed. It is understood that
other agencies will review and comrasrt on specific aspects relating
to effects of the unit on air and water quality and other environmental
factors.
Ihe. Need for Power
The 1,130-megawatt Trojan nuclear plant is the second major
thermal power plant construction project sponsored by the Joint Power
Planning Council of the Pacific Northwest, whose members are the
Portland General Electric Company, three other private utility systems,
104 public utility systems and the Bonneville Power Administration.
Construction of the plant is part of the Council's plan entitled
"A Ten-Year Hydro-Thermal Program for the Pacific Northwest" which
calls for the construction of possibly seven major thermal electric
power plants to meet the increasing power requirements of the Pacific
Northwest during the next ten years. The 1,400-megawatt coal-fired
Centralia plant, currently under construction, is the first major
therinal electric power plant in the program.
While the Trojan nuclear plant is intended to be constructed
and operated by the Portland General Electric Company and while the
Company is expected to hold majority ownership, other members of the
Council are expected to participate in the ownership. Among these
will be the City of Eugene, Oregon, the Pacific Power and Light
Compary and 13 other public and cooperative utility systems.
Thus,
in accordance with the design philosophy of ühe Joint Power Planning
Council, the size of the Trojan iuclear plant and its function as a
regional resource was dictated not so much by the needs of the
Portland General Electric Ccripany, as by the immediate needs for
base load thermal capacity in the Pacific Northwest to supplement the
predominaiely hydroelectric power resources of the region.
-83-
- 2 -
The 1970-1971 winter peak load of the West Group Area of the
Northwest Power Pool is expected to reach 19,216 megawatts, while
the resources of the Group are expected to be 19, 236 megawatts.
The service area of the West Group companies of the Northwest Power
Pool is equivalent to the service areas of the utility systems who
are participating in the Joint Power Planning Council.
1
Lack of generating capacity during the past summer forced some
of the utility systems in the Pacific Northwest to drop portions of
the industrial interruptible load. Similar action is anticipated
during the coming peaking season. The current load-supply situation
in the area with its lack of support from thermal base-load generating
capacity, is untenable and must be altered as soon as possible if the
area is not to suffer irreparable economic damage.
The Pacific Northwest is unique with respect to capacity reserves
because of its primary reliance on hydroelectric generation for its
electric power needs. What is critical in the area is not so much
generating capacity installed and ready for service at times of
peak load, but the amount of water available at the dams for generation
of power.
This fact is the basis for a vulnerability to variations in
stream flows which can be corrected only by the construction of
thermal generating capacity whose dependability at times of peak
demand is relatively assured.
.
According to the revised plan of the West Group dated June 22,
1970, the Pacific Northwest is expecting to enter three of the next
five peaking seasons with negative reserves. The peak load during
the 1974-1975 winter peaking season is expected to be 24,422 megawatts,
exclusive of 1,229 megawatts of interruptible load which is mostly
industrial. Total resources at this time are expected to be 24,766
megawatts. Thus, the area's reserve margin even after the Trojan
nuclear plant comes on the line will be less than two percent. Under
these circumstances, there can be no question about the need for the
capacity of the Trojan nuclear plant to aid in serving the growing
electric power loads of the Pacific Northwest.
The Fuels Situation
The electric generating capacity of the Pacific Northwest is
predominantly hydro. The area is singularly lacking in native oil
and gas resources. Some coal deposits exist but these are mostly of
the bituminous and sub-bituminous rank and of a quality too low to
have encouraged construction of coal burning steam generation as
long as favorable hydroelectric sites were available and awaiting
development.
-84-
- 3 -
Of the 98,868 million kilowatt-hours of electric energy generated
in the States of Washington and Oregon during 1969, less than four
percent was generated by non-hydro plants (Fossil and nuclear steam,
gas-turbire, and internal combustion). At the end of 1969, only
seven percent of the installed generating capacity in these two
States was non-hydro and of this 4.7 percent was accounted for by
the 800-megawatt Harford nuclear plant.
1
.
The 1,400-megawatt Centralia coal fueled plant will exploit
the deposits of the Centralia-Chehalis field in Thurston and Lewis
Counties, one of the more economically accessible coal deposits in
the Washington-Oregon area. The Roslyn-Cle Elum field in Kittitas
County offers the region a second base for coal fueled generation,
but the economics of exploitation are less favorable and no coal-
fired plant in this area was included among the seven major plants
designated in the Council's original plan for meeting the thermal
generation needs of the Pacific Northwest during the next ten years.
Large supplies of natural gas exist in Western Canada, but these
supplies are not now available to the United States in amounts
sufficient to be useful to the electric utility industry south of
the border. Gas imports from Canada depend on approval of Alberta
authorities and the Canadian National Energy Board. These authorities
are not expected to release large blocks of Canadian gas on a long
term basis until supplies of gas sufficient to meet Canadian needs
for the next 25 years are assured. Even if Canadian gas were to be
made available for export in increasing amounts in the future, it
does not appear that ühese amounts would be sufficient to meet the
requirements of a base load steam-electric generation station with
a capacity approaching that of the Trojan nuclear plant. Moreover,
imports of liquefied natural gas from foreign countries during the
next five years are not expected to be competitive.
Similarly Alaskan oil and gas resources may in the future encourage
more fossil fuel generation in the Pacific Norchwest, but during the
next five years, fuels from this source are not expected to be
economically competitive with nuclear fuels. Thus, the construction
of a fossil-fuel plant as a substitute for the Trojan nuclear plant
does not appear to be an economically superior choice at this time
as a source of needed thermal generation to supplement the hydro-
electric resources of the Pacific Northwest.
Porter Imports
Tie irpori o firm pouer [rom other utility systems in the West
Pigi. 25 g suite for the Trojan nuclear station also does not
).
-85-
- 5 -
While the Federal Power Commission is in favor of interconnections
and the coordination of system operations on a regional basis as a
sound practice in gaining the advantages of economies of scale and
providing inter-system support in emergency situations, it does not
overlook the penalty in terms of reliability of supply which is
imposed when sites of generation are selected at long distances from
major service areas. In general, the Commission feels that the
Pacific Northwest stands to gain an important advantage from a
reliability point of view by the construction of the Trojan nuclear
plant within its service area rather than seeking to rely on non-
indigenous sources. Furthermore, the copstruction of needed additional
capacity outside the FPC West Region would not lessen the overall
impact of power facilities on the environment.
Hydro Power Alternative
Consideration of a substitute for the Trojan nuclear plant must
take into account the fact that the best hydro sites in the Pacific
Northwest have already been developed. Some good sites are still
undeveloped, but their future is dimmed by the high cost of development
and by environmental controversies. Some sites have been eliminated
entirely as future hydro sites by the 1965 Wild and Scenic Rivers
Act which sets aside stretches of the Rogue, Salmon and Clearwater
Rivers for preservation in their wild state. Other stretches of
these and other rivers having favorable hydro sites were also desig-
nated by the Act for study for possible preservation as Wild River
areas.
.
agi
Some of the existing hydroelectric installations are at sites
suitable for further development. Because of available water limita-
tions, additional capacity at these sites would necessarily be
operated at low capacity factor and, therefore, would be suitable
only for peaking purposes. Hydroelectric installations are eminently
suitable for peaking purposes, a characteristic which endows the
Pacific Northwest with an abundance of existing and potential
peaking capacity. In providing for future loads of the region,
electric utility systems must add base-load generating capacity to
supplement existing hydroelectric capacity. This needed base-load
capacity can most appropriately be provided by thermal facilities
such as the Centralia coal-fired plant and by the program of nuclear
plant construction drawn up by the Joint Power Planning Council,
which includes the Trojan plant.
:
-86-
. وزلال این لغت نار
بوت و نیم
APPENDIX G
Regulatory
File Cy.
PORTLV) GEXERS ELECTIC COMPANY
ELECTRIC BUILD!iVG
PORTLAND, OREGON 97225
E. C. ITSCHNER
VICE PRESENT
October 12, 1970
mor
Dr. Peter A. Morris, Director
Division of Reactor Licensing
U. S. Atomic Energy Commission
Washington, D. C. 20545
1,9701
1922
Dear Doctor Morris,
This letter is in response to your letter with attachments of September 15, 1970,
regarding the Environmental Statement prepared by Portland General Electric
Company (PGE) for the Trojan Nuclear Plant. We wish to clarify and comment
on the remarks made in the letters from the other Federal agencies.
Department of Interior Letter, Dated August 18, 1970
The Department of Interior states that they are concerned about the possible
mechanical hazards to fish posed by the cooling water intake structure and by the
release of plant wastes to the Columbia River. We are pleased to comment that
on July 17, 1970, at a meeting attended by biologists and engineers representing
the U. S. Bureau of Commercial Fisheries, the Fish Commission of Oregon, the
Oregon Game Commission and PGE, complete accord on all of the details of the
intake structure was reached. It was agreed that the general plan as shown in
drawings previously submitted was satisfactory, including travelling screen panels
utilizing five mesh per inch, 16 gauge stainless steel wire, as well as escape
ports on either side and in front of the screens to allow fish egress from the in-
take. The velocities of less than one foot per second which were proposed were
more than satisfactory to prevent impingement of fish on the screens. An additional
provision resulting from the meeting was to place the trash racks at the outer
extremity of the intake in order to make them easily swept by the river current
at all times.
In regard to chemical additions, pH control will require the addition of only
enough sulfuric acid to bring the water in the system to a neutral condition. This
is not regarded as being of a harmful nature to fish. A blend of polyphosphates,
chromates and zinc will be employed, as well as some chlorine. These chemicals
HELT
HIDALINTA
DOCKETED
USAEC
T 14 1970
E3
-87-
PORT! ANO GENERAL ELECTRIC COMPANY
Dr. Peter A. Morris
October 12, 1970
Page two
have been used similarly at plants elsewhere in the small concentrations
contemplated without damage to fish. Environmental monitoring programs will
continue after the project is placed in operation in order to verify the expected
effect on all organisms resident in the river.
The Department of Interior felt that the environmental report should reference:
1.
A certification by the State of Oregon that the plant will meet
applicable water quality standards.
2.
An appraisal by the Secretary of Interior as to whether there may
be an interstate effect, and
3.
An appraisal by the State of Washington that it can be expected
that the plant discharge will meet the water quality standards.
The staff of the Oregon State Sanitary Authority, now the Department of
Environmental Quality, completely reviewed the proposed facilities and pre-
pared a staff report on them. The staff concluded that the proposed heated
water discharge would comply with the temperature standards for the Columbia
River and that the chemical discharges should not result in measurable increases
or deleterious effects in the river. Following a public meeting of the Oregon
State Sanitary Authority on June 27, 1969, Portland General Electric Company
was granted a Waste Discharge Permit which states in part "The detailed plans
and specifications for the air and water quality control facilities must be approved
by the Sanitary Authority before actual construction of said facilities is begun.
Facilities with control of air and water quality will be designed, con-
structed and operated at all times so as to keep heated water, radioisotopes and
residue chemical discharges to the river to the lowest practical level." PGE
continues to work with the staff of the Department of Environmental Quality by
providing details and plans of environmental control facilities to them for their
comments. This continuing review procedure obviously goes farther toward
answering this concern than was suggested by the Secretary of Interior's comment.
The Governor of the State of Oregon has designated the Department of Environmental
Quality as the certifying agency for the State of Oregon in compliance with the
Federal Water Pollution Control Act. In addition, he has determined that the Waste
Discharge Permit constitutes the required certification by the State of Oregon for
the Trojan Nuclear Plant.
-88-
PORTLAND GENERAL (CEIC COMPANY
Dr. Peter A. Morris
October 12, 1970
Page three
The Washington State Pollution Control Commission, along with other Federal
and State agencies, received a copy of the application for the Waste Discharge
Permit. Their comments were considered and read at the public meeting on
June 27, 1969. The Washington State Pollution Contro! Commission stated in
their letter, "While we have several detail items which will require clarification
in due course, we are in general agreement with the proposed permit conditions."
In conjunction with the application to the Corps of Engineers for construction of
facilities in the Columbia River, the Department of Interior, Pacific Northwest
Region, approved the permit after a review of the outfall plans by the Federal
Water Quality Administration. A letter from the Regional Coordinator of the
Department of the Interior to the Corps of Engineers stated in part: "It is with
a great deal of satisfaction that we recomment approval of this particular
application. It should be noted that Portland General Electric Company has
worked very diligently and very hard to insure that environmental controls are
being built in the construction of this particular facility."
The Department of Interior comments that the environmental statement presented
conclusions as to the alternative courses of action to the facility rather than
presenting the effects of the alternatives which would lead to the conclusions.
It is felt that the alternatives presented in the environmental statement are the
ones that are pertinent to the environmental quality of the area and the concerns
of the nation. There are three other alternatives which are less desirable than
building nuclear plants in the Pacific Northwest. These are:
1.
Not build any additional generating facilities. This would result
in a shortage of power in the region and PGE might be compelled
to reduce service to its present customers and decline to accept
new customers at some point in the 1970's.
2.
Build a fossil fuel generating plant in or near the PGE service area,
which would require importation of fuel to the plant. However,
PGE firmly believes that nuclear energy production is clearly the
cleanest, most desirable alternative method from all standpoints,
including the effect on the environment.
3.
Build a plant outside of the region and transmit electrical energy
to the area. To supply the same amount of energy to the North-
west, the plant located elsewhere would have to be somewhat
larger than that located at the Trojan site because of transmission
-89-
PORTLAND GENERAL ELECTRIC COMF'ANY
Dr. Peter A Morris
October 12, 1970
Page four
losses. In addition, it would be necessary to build additional
transmission lines through the forests of the region with a
significant environmental impact.
It appears from the wording of their letter that the Department of Interior is
asking for specific isotopic releases from the plant. They also comment that
the statement that we will design the facility to State requirements and will
stay well within applicable standards is not satisfactory.
The Trojan Nuclear Plant is still in the design stage. The Water Quality standards
and other Federal and State requirements are the guide to the design. Section 11
of the Preliminary Safety Analysis Report (PSAR) gives present anticipated radio-
active waste release limits and shows that they are well below the AEC allowable
limits. The Waste Discharge Permit issued by the Oregon State Department of
Environmental Quality states the following with regard to chemicals: "The
residual chemicals in the waste discharges shall be kept at as low as practical
concentrations at all times, and shall not exceed the following maximum level
in the plant blowdown stream:
Polyphosphate as P04-21 ppm
Free residual chlorine-1.5 ppm
Sulfate-824 ppm
Chromate-14
ppm
Zinc-2 ppm
Orthophosphates as PO4-3.9 ppm
Volatile amines-0.1 ppm
Boron-0.48 ppm
Lithium-0.002 ppm
Sodium-170 ppm
"It should be understood that the above concentrations may be adjusted up or down
based on either more refined estimates or actual operating experience consistent
with the philosophy of highest and best practical treatment and control and no
allowable degradation of existing water quality which would interfere with any
present or potential beneficial use." In addition to committing ourselves to meet
this requirement, we have given the Federal Water Quality Commission our
assurance that we will use the least toxic corrosion and slimicide control inhibitors
available which will insure the integrity of the systems.
-90-
PORTLAND GENERAL ELECTRIC COMPANY
Dr. Peter A. Morris
Ocicher 12, 1970
Page five
The Department of Health, Education and Welfare Letter, Dated August 25, 1970
HEW concludes, in Item No. 2 of their letter, that the PGE environmental statement
does not include a commitment to keep radioactive material discharges at "the
lowest level practicable." PGE does, in fact, intend to keep radioactive material
discharges at the lowest level practicable. The PGE environmental statement on
Page 3 in discussing design for radioactive releases concludes: "(This). will
ensure achieving the lowest practical level of effect on the environment." Again
on Page 5 of the Environmental Statement: "Equipment designed to treat and hold
radioactive wastes will be chosen carefully so as to provide the highest attainable
effectiveness in minimizing the impact on the environment." More recently the
following commitment was made to the Oregon Nuclear Plant Siting Task Force
and is repeated here for the AEC and HEW record:
"It is the policy of Portland General Electric Company to make every reasonable
effort to maintain radiation exposures and releases of radioactive materials in
effluents to the environment as far below the applicable AEC permissible limits
as is practical.
"Consistent with this policy, PGE is designing the Trojan Nuclear Plant with a
radioactive waste treatment system that includes the best methods available at
the time of the design. As the Trojan design progresses, new methods and equip-
ment for radioactive waste treatment are being proposed and developed. To assure
that the Trojan Nuclear Plant, when constructed and operated, will continue to
reflect the best practical solution to control of radioactive effluents, we are
constantly evaluating developments in this area to see if we can further reduce
any potential radiation exposure or radioactive effluents from Trojan.
"PGE will establish rules of operation to assure that equipment will be used in an
effective manner. These rules will clearly state the manner in which radioactive
material is to be processed and disposed of in order to reduce radiation expɔsures
to the lowest reasonably practical levels."
HEW Item 5 calls for liquid radwaste discharges to be controlled by analysis for
specific radionuclides rather than using limits for unidentified mixtures of
radioisotopes. PGE recognizes the problem that occurs because of radioactive
waste discharges to the Columbia River from AEC's Hanford plants and indicates
in the Trojan PSAR that discharges will be done on a batch basis after analysis.
-91-
DCOTLAND GENERAL
FI.ECTRIC COVPATY
Dr. Peter A. Morris
October 12, 1970
Page six
The extent of the necessary analysis will be the subject of written operating
procedures developed during detailed plant design. In every case the limits of
10 CFR 20 will be met.
HEW Item 6 asks for development of an emergency plan for the facility. It is not
clear what Trojan PSAR Amendments were available to HEW at the time of their
review; however, Amendment 7, doted June 10, 1970, includes a "Trojan
Emergency Plan" developed in accordance with criteria proposed as a change in
10 CFR 50 to be designated as Appendix Ē. This Trojan Emergency Plan is an
outline from which the final plan will be developed. This outline shows, among
other things, which Federal, State and local authorities and agencies are available
for assistance in the event of a radiation accident at the plant, and that liaison
with such authorities and agencies will be established in order to obtain assistance
if necessary. In this manner, the final plan will reflect the combined efforts and
coordination of all responsible organizations.
a
The HEW review of the Trojan design indicates several areas where misunderstanding
may exist. The following clarifications are therefore provided:
1.
The Trojan estimated total annual liquid waste discharge excluding
tritium is 4.5 mCi/yr. This includes 1.99 mCi/yr of unidentified
isotopes and 2,5 m.Ci/yr of identified isotopes. This number is
based on an assumed failure of the cladding on 1% of the fuel rods
and use of specified equipment (PSAR Table 11.1-3). PGE does
not expect fuel defects to reach nearly the 1% level. Comparison
with other earlier units is not always useful since, as stated in
Reference 5 of the HEW review for radioactive waste data from
existing plants, "there is generally no indication as to the types
of waste treatment that were used."
2.
Data of Appendix 1 for Trojan should be updated as follows:
Containment
Volume
Leak Rate
2 x 106 ft 3
(Amendment 5)
0.1% per day (Amendment 6)
-92-
PORTLAND GENERAL ELECTRIC COMO ANY
Dr. Peter A. ivorris
October 12, 1970
Page seven
3.
Concentrations of radioisotopes in the Columbia River have
decreased from 1.5 x 10-6 pCi/rol in 1967 to 0.5 x 10-6uCi/ml
at present. PGE is following the environmental monitoring work
in this area and isotopic identification of waste will be compatible
with other river and environmental monitoring programs.
HEW points out that the radioactivity concentrations in water attributable to the
operation of the Trojan Plant will be well below detectable levels because of the
activity in the river caused by Hanford. They concluded that a surveillance
program for the facility is important to confirm this conclusion and that the
program should be developed to aid the State of Oregon in their calculation of
population doses from all sources. We are in agreement with HEW concerning
the need for a surveillance program. In Section 2.10.4 of the PSAR, we state
"Due to the presence of the AEC reactors at Richland, Washington, an extensive
environmental radiation monitoring program on the Columbia River is currently
being conducted by both states, Oregon and Washington. Nevertheless, the
Trojan Nuclear Plant Environmental Radiation Monitoring Progam is being planned
to be self-sufficient. Liaison will be maintained with state and local as well as
national governmental organizations in regard to the program and agreements to
obtain joint samples, trade samples and joint review of data are planned to be
made with these public organizations. Data from the other surveillance programs
will also be used to supplement that obtained by the Trojan Plant program."
The Assistant Secretary of Defense Letter, Dated August 4, 1970
The letter states that the Environmental Statement does not contain sufficient
radiological release data to evaluate the plant's impact on the environment, then
points out that the PSAR provides all of the information necessary to relate the
estimated radioactive releases during normal and accident conditions to the AEC
limits of 10 CFR 20 and 10 CFR 1CO.
The letter also comments that the statement did not indicate that any local area
meteorological data were available or that meteorological instrumentation was
being installed at the site. An on-site meteorological data system was installed
at the site in the latter part of 1969. The system consists of wind speed and
direction instrumentation at three levels on a 500 ft. tower and on the top of a
separate 50 ft. tower. Four dry-bulb sensors are also located on the same three
levels of the 500 ft. tower and on the roof of an instrument shelter located near
the base of the 500 ft. tower. In addition, one dew-point temperature sensor is
located in the instrument shelter.
-93-
ORLAND CINERAL ELECTRIC COMPANY
Dr. Peter A. Morris
October 12, 1970
Page nine
We hope these comments will help you in inierpretting our Environmental
Statement.
Sincerely,
El Tischner
APPENDIX M
BOARD OF COUNTY COMMISSIONERS
Ryderwood
Toutia
COWLITZ
• Sivor los
LE
COUNTY
Cortio toca
• Oot Point
James F. BERXY.
CHAS. S. XondsTNOM
Dist. No. 1
Dist. No. 2
L2
C. F. GARDNER.
Dist. No. 3
SARAH (SALLIE) IVIE......
CLERK or BOARD
• Yol
• Kolome
• Anal
роіром
KELSO, WASHINGTON 98626
AIRMAIL
October 28, 1970
PA
United States Atomic Energy Commission
Office of the Secretary
Washington, D. C.
20545
Attention: Chief, Public Proceedings Branch
Gentlemen:
le
As per the notice of hearing for a construction permit, Docket No. 50-344, for
Trojan Electric Generating Power Plant, the people of Southwest Washington and
more especially of Cowlitz County, whom I represent, are greatly concerned about
the potential health hazard that will surely be created by the cooling tower of
the Trojan nuclear reactor. As per Section 4, Page 3 of the hearing notice, it
is your responsibility to decide whether the issuance of the permit for the con-
struction of the facilities will be inimical to the common defense and security
or to the health and safety of the public.
2.
3.
The information that we now have concerning the amount of steam to be released
from the cooling tower is that it will be equal to 25 cu. ft. of water per sec-
ond. As you know, Southwest Washington does have considerable rain, with the
average annual rainfall being around sixty inches. Certainly, a release of 25
cu. ft. per second will have an adverse effect on the humidity in the surround-
ing area of the cooling chimney. This is equal to 187 gallons per second, or
90,000 cu. ft. per hour, which is equal to 673,200 gals. per hour or 16,156,800
gallons per day. This is a great increase of moisture in the airshed over South-
west Washington.
5
I therefore respectfully request the Atomic Energy Commission to consider the
extreme health hazard that will surely arise once the Trojan site is operative.
I would question the granting of this permit without further study which will
prove beyond a shadow of doubt that no health hazard shall exist in our airshed
with the construction of the new power plant.
Yours very truly,
BOARD OF COUNTY COMMISSIONERS
OF COWLITZ COUNTY, WASHINGTON
Č. F. Gardner, ChrĖcaa8st
. Dir. of Reg.
Rec'd
cc: Mrs. Harvey B. Hunter
The Honorable Julia Butler Hansen
Senators Warren G. Magnuson and Henry M. Jackson
Date_4424420
Time 7:30
w
Issued by the
OREGON STATE SANITARY AUTHORITY
in accordance with the provisions of
ORS 449.083
Permit Number: 456
Expiration Date:_12-31-13
Page_l_of_3_
APPENDIX I
ISSUED
TO:
-95-
REFERENCE
INFORMATION
Portland General Electric Company
621 S. W. Alder Street
Portland, Oregon 27205
File Number: 71052
Appl. No. :
751 Received: 4-9-69
Major Bn:
Columbia Minor Bn:
Receiving Stream: Columbia River
River Mile: 72.5
County: Columbia
Re: Trojan Nuclear Power Plant near Prescott
Until such time as this permit expires or is modified or revoked, Portland General
Electric Company is herewith permitted to proceed with the design, construction and
installation of facilities as described in its application No. 751, dated April 9, 1969.
The above activities must be carried out so as to comply with the requirements,
limitations and conditions which follow.
l. Detailed plans and specifications for air and water quality control facilities
must be approved by the Sanitary Authority before actual construction of said
facilities is begun. The detailed plans for the radioactive waste treatment
and control facilities must be accompanied by estimates of specific radioisotope
concentrations in the liquid and gaseous waste streams.
2. Copies of all Facilities Description and Safety Analysis Reports shall be made
known and available to the Sanitary Authority as soon as they are available for
distribution to anyone.
3.
Facilities for control of air and water quality shall be designed, constructed
and operated at all times so as to keep heated waters, radioisotopes and residual
chemical discharges to the river to the lowest practicable levels.
4.
Heated water discharges shall not exceed 8.5 MGD or 101° F except during shutdown
of the reactor.
5.
Heated water discharges shall not exceed 50 MGD or 15° F above background river
water temperatures during reactor cooldown operations. Routine shutdown of the
reactor shall not be scheduled when Columbia River water temperatures adjacent
to the Trojan site exceed 66° F unless the heated water discharges to the river
are controlled so that the amount of heat added to the river per unit of time
does not exceed the amount that would have been allowed to be added to the river
during the same time interval had the plant continued in operation.
6.
Residual chemicals in the waste discharges shall be kept at lowest practicable
concentrations at all times and shall not exceed the following maximum levels
in the plant blowdown stream:
Polyphosphate as PO4
Free resiguai chlorine
Sulfate
Chromate
Zinc
Othophosphates 25 POL
21
1.5
824
14
2.0
3.9
pon
ppm
ppm
рр.
ppm
pom
: 'WASTE DISCHARGE DORMIT
-96-
OREGON STATE SANITARY AUTHORITY
Permit Number: 456
Expiration Date: 12-31-73.
Page 2
of__3__
0.1
ppm
Volatile amines
Boron
Lithium
Sodium
0.48 PPI
0.002 ppm
170
ppm
It should be understood that the above concentrations may be adjusted up or doim
based on either more refined estimates or actual operating experience consistent
with the philosophy of highest and best practicable treatment and control and no
allowable degradation of existing water quality which would interfere with any
present or potential beneficial use.
7. The phi of the total plant discharge shall be maintained between 6.5 and 8.0.
8. Specific radioisotope concentrations in liquid and gaseous discharges shall be
kept at lowest practicable levels and shall not exceed in the liquid or gaseous
discharge strears the limits for individual or combined radioisotopes prescribed
by AEC in 10 CFR Part 20 and by the Oregon State Board of Health in Appendix A.,
Part C of its regulations for the control of Sources of Ionizing Radiation. It
should be understood that prior to actual start-up of the power plant, discharge
limits will be established for specific radioisotopes based on estimates submitted
by PGE and the quality of effluents normally expected from experiences at other
installations.
j
>
9. Miscellaneous radioactive and other vestes including solid wastes shall be
handled, stored, transported and disposed of in accordance with AEC, USPHS,
U. S. Departnent of Transportation, U. S. Dept. of Commerce and Oregon Board of
Health regulations and in a manner not to cause air or water pollution. The
permittee shall give notice to the Sanitary Authority regardins proposed waste
handling, storage and transportation methods including times for transporting
radioactive and other waste materials..
10. A pre-operational monitoring program shall be developed in conjunction with the
Sanitary Authority and State Board of Health staff and shall be conducted by
the permittee to determine background radioactivity levels in pertinent environ-
mental media at suitable locations in the Columbia River and around the plant
boundary, including especially agricultural operations, and at the communities
of Prescott, Goble and Rainier. All results of the monitoring program shall be
promptly submitted to the Sanitary Authority and the State Board of Health.
ll.
No sewage wastes shall be discharged without said wastes first receiving secondary
treatment and disinfection adequate to meet the following effluent standards:
a.
The average daily flow shall not exceed the design flow of the facility.
p.
The monthly average 5-day 20º C Biochemical Oxygen Demand (BOD) shall not
exceed 30 milligrams per liter (mg/1).
C.
The monthly average Suspended Solids concentraion shall not exceed 30 mg/
a.
The effectiveness of disinfection shall be equivalent to that obtained by
adequately mixins sufficient chlorine with the treated waste to provide
a minimum residual of 0.5 mg/l after 60 minutes contact time at averase
design flow.
O
WASTE DISCHARGE
PERMIT
Permit Number:_456
Expiration Date: 12-31-73
Page__3_of_3_
OREGON STATE SANITARY AUTHORITY
2.
No petroleum base products or other substances which might cause the Water Quality
standards of the State of Oregon to be violated shall be discharged or otherwise
allowed to reach any of the waters of the state.
13.
In the event the permittee is unable to comply with any of the conditions of this
permit, for any reason, the permittee shall immediately so notify the Sanitary
Authority.
14.
This permit is subject to change or modification if the Sanitary Authority finds :
&..
That it was procured by misrepresentation of any material fact or by
lack of full disclosure in the application.
b.
That there has been a violation of any of the conditions contained herein.
C.
That there has been a material change in quantity or character of waste
or method of waste disposal.
15.
In the event that a change in the conditions of the recei ing waters results in
a dangerous degree of pollution, the Sanitary Authority 1 i specify additional
conditions to this permit.
OREGA STATE SANITARY AUTHORITY
OBECS
Genne H fries
By
Title
Secretary and Chief Engineer
Date
June 27, 1969
WATES POLLUTION COXTROL CO2 issios
2u
OLYMPIA 9350? 8
Qw
P. O. Box 829
-98-
Phone 206.733.6574
APPENDIX J
KIS
STATE
TEL J. Evans
Governor
1. OP
OF THE
Commission
H. Mau?!CE AMQ 157
Jous BIGGS
WALLACE LASE, M.D.
DOXALD W. Moos
THOR C. TOLLEFSO:
TES P. BCHLKE
Director
TESTACION
T!ll. Si
19:3
3-34
/
1:06s
June 25, 1969
Siia Oy
Mr. Kenneth H, Spies
Secretary and Chief Engineer
Oregon State Sanitary Authority
1400 Southwest 5th Avenue
Portland, Oregon 97201
L'.S.
TETTO
E.
:
78
17:10
*
Dear Mr. Spies:
090
The Washington State Water Pollution Control Commission appreciates the
opportunity to comment on the application and proposed permit conditions
being considered in reference to the Portland General Electric Company's
proposed nuclear power development near Prescott, Oregon.
While we have several detail items which will require clarification in due
course, we are in general agreement with the proposed permit conditions.
In reference to condition 10, however, we would recommend a preoperational
monitoring program be carried out to determine the base line information
on the biota to include biolozical surveys of the resident and migratory
species which will be affected. Portland General Electric Company should
show, by these studies, that the waste discharge will not degrade the
existing water quality or interfere with any present or potential bene-
ficial use.
Very truly yours,
JAMES P. BEHLKE
Director
JPB:c;
..... 5
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KEEP VASIUNGTON WATERS CLEAY
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-99-30
04
APPENDIX: K
"
Toil
RIMELE
UNITED STATES
DEPARTMENT OF THE INTERIOR
FEDERAL WATER POLLUTION CONTROL ADMINISTRATION.
LRCH
3849
NORTHWEST REGION
June 24, 1969
N REPLYIN ADDRESS:
REGIOZAL OFFICE
Roon Vi PITTOCK BLOCK
PORTLAND, OREGON 97:35
QULELE
Fle
ما k
Test
E
Mr. Kenneth Spies
Secretary and Chief Engineer
Oregon State Sanitary Authority
P. 0. Box 231
Portland, Oregon 97207
La Soci:c7
Piccio
C.
U.S. 6. Iwi
JUL151890
milio
LIETTE
Dear Mr. Spies:
.
We have completed our review of the material you transmitted
to our office on June 6, 1969, regarding the Portland General
Electric Company's waste discharge permit application for a pro-
posed 1118 megawatt nuclear power plant to be located on the Lover
Columbia River near Prescott, Oregon. We were pleased to note the
incorporation of a natural draft cooling tower for "treatment" of
the condenser cooling water discharges. We believe this method
of treatment to be the best available alternative for the Trojan
site and one which involves the least risk to either air or water
quality.
We are in general agreement with the "Recommended Waste
Discharge Conditions" and have no serious criticism to make, either
of the application or of the Oregon State Sanitary Authority staff
review. The following comments and suggestions are offered:
11
1, On Page 3 of the application, reference is made to blowdown
discharge through . two 24-inch diameter perforated pipes sub-
merged at 20 to 40 feet." If the implied design is to obtain locally
complete dispersion of the discharge, we completely agree with this
approach. Less than complete dispersion would involve the risk of
undesirably high local concentrations of pollutants. Even with
complete dispersion, the dilutions will not be as great as indicated
on Page 4 of the application during periods of slack tide.
.
2. The applicant on Page 5".. requests a permit to discharge
radioactive wastes within the limits prescribed by AEC in 10CFR
Part 20. . ." The stated limits in 10C FR 20 refer only to effluent
concentrations. Alternatively, we suggest consideration, perhaps
at the time when detailed plant specifications are being reviewed,
of the standards for receiving waters being cooperatively developed
hy
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2.
10
3. A comment is made on Page 8 to the effect that very few shut-
downs will occur during critical temperature periods. Because of the
indicated higher "cooldo:n mode" discharges, we concur with your
recommendations that these shutdow:ns for refueling be restricted to
periods when the receiving stream temperature is less than 66°F.
PROS
4. References to chemical additions in the application do not
indicate precautionary measures to minimize their toxicity when
discharged. We suggest, for example, that any hexavalent chromium
in the system be reduced to trivalent chromium before discharge.
5. The plant specifications should define adequate safeguards
against spillage, leakage, or other accidental incidents involving
the risk of temporary high pollutant concentrations in the receiving
stream. For example, is the drum storage area for radioactive wastes
on Drawing 8 a point of ultimate disposal? If so, what safeguards
against leakage and spillage are provided? If not, what and where
is the method of final disposal?
>
6. Our review of the NUS report and the Portland General Electric
Company's application noted several inconsistencies in the proposed
design for the cooling tower. Although these discrepancies do not
appear to be serious, we are unable to do a detailed tower analysis
without better design data. This problem is discussed in more
detail in the enclosed review memorandum from Mr. Rainwater, Chief
of our National Thermal Pollution Research Program. When the suf-
ficient confirmed data are available, our mathematical model of
cooling tower performance can be used as an evaluation tool.
In our opinion, the "recommended Waste Discharge Conditions"
should provide for maintenance of the existing high water quality
in the Columbia River and for all present and future uses. Your
staff has done an excellent revier of the proposal and is to be
complimented.
If we can be of further assistance to you, please do not
hesitate to let us know.
Sincerely yours,
Sellai
James L. Agee
Regional Director
Doningen.neErospinerisse
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UNITED STATES GOVERNMENT
Memorandum
-101-
Pacific Northwest Water Laboratory, FWPCA
200 S. 35th St., Corvallis, Oregon 97330
TO
:
Regional Director, Northwest Region, FWPCA
DATE: June 13, 1969
FROST
:
Chief, National Thermal Follution Research Program
SUBJECT:
Evaluation of PGE's Trojan Plant Plans (undated Preliminary Engineering
Report)
Dr. Tichenor has reviewed the following material:
1.
Environmental Effects of Cooling Tower Operation at the Trojan
Site by NUS.
2.
Exhibit A-
.
Preliminary Engineering Report by PGE.
3.
OSSA Staff Evaluation of PGE application.
4.
OSSA Preliminary Waste Discharge Permit Conditions.
Only thermal pollution aspects were considered; no attempt was made to
evaluate radiological and sanitary waste disposal.
In comparing the NUS report with the PGE report several inconsistencies
were found. The NUS report was based upon a crossflow natural draft
tower 410 feet high and 450 feet in diameter (see page 28). The associated
performance curves (Fig. 36, page 90) were based on a water flo: rate of
520,000 gpm and a heat load of 8.25 x 109 6TU/hr. This gives a cooling
range (or at across the condenser if 100% heat dissipation occurs) of.
31.70F. Assuming an overall thermal efficiency of .33% with 5% in-plant
losses, the calculated electric output from this plant would be 1290 Mill.
The PGE report does not specify whether the tower will be crossflo:/ or
counterflo: nor is information on tower size given (the OSSA staff report .
tentions a tower size of 400 feet high and .350 feet in diameter vihich
indicates a counterflo: design as does the cooling tower shown in drawing
2 of the PGE report). Drawing 2 also indicates a cooling water flow of
370,000 gpm. Using the plant output of 1118 Me with 33% overall efficiency
i and 5% in-plant losses, a waste heat load of 7.15 x 100 BTU/hr is obtained.
This heat load associated with the 370,000 gpm cooling water flow gives
a temperature rise across the condenser of 38.70F. This figure seems
somewhat high, especially when associated with the maximum summer operation
mode which produces an inlet condenser temperature of 1000F. The high
cooling range provides the opportunity for a smaller cooling tower at
the expense of overall plant efficiency.
By, U.S. Savines Bords Recularly on the Payroll Savings Plan
0
0
-102-
2
Comparing the NUS and PGE reports points out the obvious fact that they
deal with two different tower designs. Besides the discrepancies men-
tioned above, it is not possible to use the Marley performance curves
from the NUS report to obtain the blowdown tenperatures reported in
the PGE report when the appropriate meteorological data are used.
He cannot at this tine provide quantitative evaluation of plume
characteristics as described in the NUS report. Such competency is
being developed under contract with EG&G. Some qualitative observations
are offered, however. The fact that the NUS report deals with a larger
waste heat load biases their results to some extent. The equations
which are used to predict the initial plunia rise and the stabilized
height of the plume (page 32 of the NUS report) indicate that a decrease
in the sensible heat emission rate will result in lower plures. Also,
Figures 41 and 42 indicate that the ability of a plume to penetrate the
top of an inversion will be dininished by a reduction in the amount of
sensible heat available. On page 42, the authors suggest that changing
the tower design would not change their answers. They say that this is
true "because the quantity of heat to be dissipated remains essentially
unchanged and the design must adequately satisfy the heat load." Unfortu-
nately, the total waste heat load of 8.25 x 109 BTU/hr used in the NUS
report should be closer to 7.15 x 109 BTU/hr as calculated above. This
is 13.3% lower than the NUS figure.
The following tabulation summarizes the differences between the NUS and
PGE reports:
NUS
PGE
Cooling tower type
Crossf10:1
Not specified
Cooling tower height, ft.
410
• 400**
Cooling tower diameter, ft.
450
350**
Cooling water flow, gpm
520,000
370,000
Temp. rise across condenser, °F
31.7.
38.7*
Waste heat load, BTU/hr
8.25 x 109
7.15 x 109*
Plant output, Mwe
1290*
1118
:
The effect of the discrepancies between the PGE and NUS reports is not
'serious. The NUS results are conservative anyiray, so a slightly lower and
Not given explicitly in report; calculated from available data.
**
From the OSSA evaluation statement.
O
-103-
3
less "energetic" plume should not change their basic conclusions. The
PGE report gives essentially no information on the proposed cooling
towers, so their values will have to be taken at face value until more
details are available. As an informal check, we ran our cooling toer
computer program using the reteorologic data given in the PGE report
assuming a 400 foot high by 350 foot dianeter counterflo: tower.
Assumptions were also made about packing configuration and friction
losses. The model results suggest that for the three operational modes
given in the PGE report, the assured to:er would perforni adequately
except for the maximum sunurer condition when the cooling range would
be too small.
Further evaluation of the cooling tower will have to avait design data.
When PGE makes these data available, our mathematical model of cooling
tower performance can be used as an evaluation tool. The following data
are required as input to the model:
1. Hater loading (1b/hr).
2.
Inlet water temperature.
3.
Desired cooling range.
Atmospheric design conditions (i.e. dry-bulb air temperatura,
relative humidity).
4.
5.
Tower height.
6.
Height of the air inlet.
Inside to. er diameter at base (for crossf10:4 towers we also
need the outside diameter of the packing ring).
7.
.
in order to estimate the heat transfer and friction coefficient, the
follo:ving information about the packing is required:
8.
Shape.
9.
Arrangement.
10. Spacing.
11. Thickness of packing material.
12. Depth of packing.
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-104- ·
4
In addition, the manufacturer's estimates for the heat and mass transfer
coefficients and the pressure drop or friction coefficient of the packing
would be useful,
13.
In order to estimate the pressure drop due to obstructions, the
size, shape, and number of supports and distribution pipes are
needed.
Although not required as input data, the following information would be
useful in checking the accuracy of the model results:
14. Dry-bulb temperature of the air above the packing.
15.
Vet-bulb temperature or relative humidity of the air above the
packing.
16. Air flow rate or air velocity above the packing.
17. Manufacturer's performance chart and characteristic curves.
In summary, the OSSA statenient is a well written and fair evaluation of
the PGE preiiminary report. We have no specific comments to make about
the OSSA evaluation. It is interesting to note, however, that the con-
cept of a mixing zone is introduced on page 3, where they state: "These
,
heated waste discharges are not expected to cause any measurable increase
in river water temperatures except possibly in the immediate vicinity of
the effluent diffuser.
The recommended discharge conditions spelled out in the preliminary permit
provide adequate protection from thermal pollution. The consequences of
statements 1, 3, 4, 5, 13, and 14 all conibine to prevent excessive waste.
heat from entering the Columbia River. The OSSA staff has done a good
job in evaluating the problem and in providing for adequate control of
thermal pollution through the waste discharge permit conditions.
Incidentally, in providing technical assistance to other regional offices
of FWPCA we have developed the attached list of "Engineering Data Require-
ments for Review of Thermal Power Plant Plans." Although the list isn't
perfected, it may be useful to you and the State in such exercises. We
should have the EG&G contract report in hand about November 1969 and
would be glad to take another look at the meteorologic aspects if OSSA
so desires.
:
특
​ark
Frank H. Rainwater
Enclosure
i
CC:
Dr. Zeller
-105-
APPENDIX L
CHRONOLOGY
ENVIRONMENTAL DATA
TROJAN NUCLEAR PLANT
DOCKET NO. 50-344
4/24/ 70
AEC letter requesting environmental data pursuant to
the provisions of the National Environmental Policy
Act of 1969.
6/1/70
Applicants' environmental report submitted.
6/29/70
Notice of availability of applicants' environmental
report published in the Federal Register (35 F.R.
10530).
6/30/70
Copies of applicants' environmental report sent to
the Governor of Oregon, the Council on Environmental
Quality, and the Federal Agencies requesting comments.
8/7/70
Comments from the Department of Defense (DOD).
8/20/70
Comments from U. S. Department of the Interior (DOI).
8/27/70
Comments from Department of Health, Education, and
Welfare (HEW).
8/27/70
Comments from Department of Housing and Urban Develop-
ment (HUD).
9/4/70
Copy of the applicants' environmental report sent to
the Federal Power Commission with a request for comment.
9/15/70
AEC letter to Portland General Electric Company trans-
mitting comments from DOD, DOI, HUD, and HEW.
.
10/7/70
AEC letter to Dept. of Transportation, Dept. of Commerce,
and Dept. of Agriculture advising that since no comments
have been received from the respective agencies, it is
presumed that no comments are forthcoming, and AEC is
proceeding with the preparation of a detailed environ-
mental statement.

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10/12/70
Comments from the Federal Power Commission.
10/12/70
Letter from Portland General Electric Company to AEC
in response to the comments of DOD, DOI, HUD, and HEW.
10/30/70
AEC letter to Portland General Electric Company
transmitting the comments received from the Federal
Power Commission.
11/2/70
Comments received from Cowlitz County Washington
Board of Commissioners on regional effects of cooling
tower operation.
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