ML13322A611

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Proposed Change 84 to Delete Tech Spec 4.3 Re Entrainment from App B Tech Specs
ML13322A611
Person / Time
Site: San Onofre Southern California Edison icon.png
Issue date: 11/02/1979
From:
SAN DIEGO GAS & ELECTRIC CO., SOUTHERN CALIFORNIA EDISON CO.
To:
Shared Package
ML13322A609 List:
References
NUDOCS 7911190456
Download: ML13322A611 (4)


Text

DESCRIPTION OF PROPOSED CHANGE AND ENVIRONMENTAL ANALYSIS PROPOSED CHANGE NO.

84 TO THE TECHNICAL SPECIFICATIONS PROVISIONAL OPERATION LICENSE DPR-13 This is a request to delete Technical Specification 4.3, "Entrainment" from the Appendix B Technical Specifications for San Onofre Unit 1.

REASON FOR PROPOSED CHANGE The proposed change is a request to avoid redundant effort or delay of study implementation due to multiple agency approval and reporting between (1) the entrainment special study required by the ETS, and (2) previously conducted and ongoing SCE studies including the Federal Water Pollution Control Act (FWPCA) section 316(b) demonstration which is administered through the National Pollution Discharge Elimination System (NPDES) permit by the California Regional Water Quality Control Board (CRWQCB).

EXISTING SPECIFICATIONS Environmental Technical Specification 4.3 "Entrainment" currently reads as follows:

Objective:

To detect and quantify major species of phyto plankton, zooplankton, fish eggs and larvae entrained in the circulating water system and to determine the effects of entrainment on productivity and mortality of these biota.

Approach:

Entrainment studies shall be conducted on phyto plankton, zooplankton, fish eggs and larvae.

Biomass by chlorophyll a extraction, productivity by Carbon-14 analysis, and species composition will be determined for phytoplankton. Density and species composition will be determined for zooplankton, fish eggs and larvae.

Mortality due to chlorination, mechanical and thermal effects will also be determined for major species. The studies will determine at a minimum these specific facts concerning plankton, fish eggs and larvae on a seasonal basis.

The special study will con tinue until, it has been determined that the above objec tives have been met. A detailed description of the entrain ment study program, including sampling and analysis tech niques, frequency of sampling, and means of data presenta tion, shall be submitted for Directorate of Licensing approval concurrent with the first Semiannual Operating Report.

REPORTING REQUIREMENT:

Status reports will be provided in each Annual Operating Report until the study is concluded.

7911190

o PROPOSED SPECIFICATION Environmental Technical Specification 4.3 would appear as DELETED.

EVALUATION AND BASIS FOR ENVIRONMENTAL FINDING The proposed revision reflects the fact that the required entrainment studies have already been completed or are in progress.

Entrainment studies already completed are included in the report MBC 1975a on entrained phytoplankton species concentrations, biomass by chlorophyll a extraction, and productivity by Carbon-14 analysis. Additional determination of entrained biomass and effects on productivity collected over several phases of the Unit 1 operating cycle were made over a period of 16 months from September 1972 to January, 1974 (MBC, 1975b).

The two MBC reports also included data on density and species composition of entrained zooplankton, and mortality due to thermal and mechanical effects.

Monthly, diel entrainment samples of fish eggs and larvae were collected from the Unit 1 intake from mid 1978 to mid 1979 in conjunction with offshore ichthyoplankton population sampling as a special study of the Units 2&3 Preoperational Monitoring Program.

A report is presently being prepared and is scheduled to be submitted as part of the Annual San Onofre Report in 1980.

The comprehensive 316(b) studies now in progress (August 1979 to August 1980) will continue monthly, diel inventory of fish eggs and larvae as well as determine loss during transit. Nearshore receiving water population samples throughout the Southern Cali fornia Bight are synoptically taken in order to determine the significance of entrainment loss.

A copy of the following two pertinent 316(b) documents which describe the planned program are attached for reference.

1. 316(b) PROGRAM STUDY PLAN -

APRIL, 1979

2. APPROACH FOR SCE 316(b) ENTRAINMENT STUDIES -

MAY, 1979 These two documents provide the scope of the 316(b) studies and, as such, do not include the specific sampling details of the Entrainment Procedures Manual used by the contractors.

Based on the scope of the 316(b) study plan, the ETS entrain ment study would duplicate a portion of the 316(b) demonstration

effort, This licensing amendment request is submitted to delete ETS Section 4.3 in accordance with the EPA-NRC memorandum of understanding to avoid redundant effort or delay of study implementation due to multiple agency approval and reporting.

-3 ENVIRONMENTAL ANALYSIS This action will not result in a condition which significantly alters the impact of the station on the environment as described in the NRC Final Environmental Statement.

COST-BENEFIT ANALYSIS Deletion of the ETS study requirement will not result in any significant loss of environmental data.

The planned 316(b) demonstration includes studies which will meet the intent of the ETS entrainment requirement as well as determine the significance to the nearshore populations.

It is estimated that a redundant entrainment study to the 316(b) demonstration would cost approximately $350,000 while providing no significant additional benefits.

LITERATURE CITED Marine Biological Consultants, Inc. 1975a. Marine plankton entrain ment studies, San Onofre Nuclear Generating Station and Encina Power Plant. Prepared for Western Energy Supply and Transmission Associates. April, 1975. 35 pp. with appendices.

Marine Biological Consultants, Inc. 1975b. Marine plankton entrain ment studies, San Onofre Nuclear Generating station. Prepared for Southern California Edison Company, December, 1975. 39 pp.

with appendices.

Marine Biological Consultants, Inc. 1979a.

(In prepartion) Assess ment of abundance and distribution of ichthyoplankton offshore San Onofre. Prepared for Southern California Edison Company, Research and Development Series.

Marine Biological Consultants, Inc. 1979b. Proposal for 316(b) ichthyoplankton entrainment inventory and loss study.

Pre pared for Southern California Edison Company, June 1979; 51 pp.