ML17037C322
| ML17037C322 | |
| Person / Time | |
|---|---|
| Site: | Nine Mile Point  |
| Issue date: | 11/15/1973 |
| From: | Curran T State of NY, Dept of Environmental Conservation |
| To: | Muller D US Atomic Energy Commission (AEC) |
| References | |
| Download: ML17037C322 (20) | |
Text
ae AEC DI" RXBUTION FOR PART 50 DOCKET MA
.IAL (TEMPORARY FORM)
CONTROL NO'318 FILETS ENVIRO FROM:
NY State Dept of Enviro Conservati Albany, New York 12201 Terrence P. Curran DATE OF DOC n
11-15-73 DATE REC'D 11-19-73 LTR MEMO RPT OTHER TO:
D. R. Muller ORIG 1 signed CC OTHER SENT AEC PDR X
SENT LOCAL PDR X
CLASS UNCLASS PROP INFO INPUT NO C S REC'D DOCKET NO'ESCRIPTION:
Ltr furnishing comments on Draft Enviro Tech Specs...,,
trans the following:
PLANT NAME:
Nine Mile Point Unit 7P 1
50-220 ENCLOSURES:
NY State Comments on 10-5-73 Draft Enviro Tech Specs..
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New York State Department of Environmental Conservation RegUlatory Albany, N. Y. 12201 November 15, 1973 File Cy.
Henry L. Diamond, Commissioner Mr. Daniel R. Muller Assistant Director for Environmental Projects Directorate of Licensing U.S. Atomic Energy Commission Washington, D. C.
20545 a
Dear Mr. Muller:
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le Point Unit=1 (Docket No. 50-220) e
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Enclosed for your information are the New York State agencies'omments on the Draft Environmental Technical Specifications for the Nine Mile Point Unit No. 1;"
These Draft Environmental Technical Specifications were submitted to the U.S. Atomic Energy Commission by the Niagara Mohawk Power Corporation on October 5, 1973.
As you are aware from our August 29, 1973, comments on the Commission's Draft Environmental Statement for Nine Mile Point Unit 1 and from our conditional certifi-cation pursuant to Section 401 of the Federal Water Pollution Control Act Amendments of 1972, of October 12, 1973, for Nine Mile Point Unit 2, it,is felt that the present intake design of Nine Mile Point Unit 1 is unsatisfactory.
Therefore, comments con-cerning the fish monitoring program are made. with the assumption that a satisfactory intake design is forthcoming and should not be considered as condoning the present intake system.
'Ihe environmental technical specifications willprovide adequate environmental protection only if the U.S.'EG staff is, able to interpret these requirements properly and enforce compliance.
The two recently received inspection reports of Nine Mile Point Unit 1, June 11-13,
- 1973, arid of the Ginna Plant on the same days provide no assurance this will be the case; I refer to page five of both reports, the third paragraph of the BIP-1 report and the. second, paragraph of the Ginna report. It seems odd that. two separate
"...licensees explained..."
the alewife impingement problems exactly the same, word for word.
Even assuming this to be the case, it is harder to believe that AEC staff would not comment on these biologically unsound and otheri6se inaccurate statements.
It is encouraging to see that many of the comments we submitted on the environ-mental technical specifications for the James A.FitzPatrick Nuclear Power Plant have been incorporated by Niagara Mohawk in this draft.
We in hew York State appreciate the opportunity the Commission has extended to us to comment on 'this document.
Sine ely yours, erence P. Curran Director of Environmental Analysis
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NBf YORK STATE CQ4IENTS ON
'lM OCTOBER 5, 1973, DRAFT ENVIR026NTAL TECHNICAL SPECIFICATIONS FOR THE NINE MILE POINT UNIT NO.
1 NUCLEAR POWER PLANT 1.
General Comment-From our review of the proposed environmental technical specifications for the subject plant, an additional section is needed to insure adequate, surveillance of possible noise impact.
Suggested. wording for a section is:
Sound Surve OBJECTIVES.
To determine the.sound levels created during normal plant operations at and beyond the plant boundaries.
SPECIFICATIONS A sound survey shall be made around the plant in accordance with Part 75 of Subchapter E of the Interim Rules for Certificates of Environmental Compati-bility and Public Need for Steam Electric Generation Facilities of the NYS Public Service -Commission.
These measurements shall be taken during a one year period following initial full power operation.
At the end of this one year period, the results shall be evaluated by the applicant and a report with the appropriate recommendations as to the future of the program shall be submitted to the, Directorate of Licensing and the NYS Department of Environmental Conservation for consideration.
BASES The sound survey shall show the extent to which the plant affects the ambient noise in surrounding land uses.
This information is needed to insure that the
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plant conforms to noise rules and regulations (proposed) of the New York State Environmental Conservation Department.
The information will also be useful to the surrounding communities for land use planning decisions.
In addition, if additional units are proposed the data willbe needed for preparation of the Environmental Impact Statement for that plant, 2.
General. Comment-In many places through the specification Nine Mile Point Unit No. 1 is referred to as Nine Mile Point Station as it was correctly identified=prior to the issuance of Amendment'o.
3 to Provisional Operating License DPR-17 (e.g. in paragraph 5.1.2).
Thus, whenever used in this context Nine Mile Point Station should be corrected to read Nine Mile Point Unit No. 1.,
3.
General Comment-Reports required as a result of technical specifications being violated should also be promptly sent to the N.Y:S. Department of Environmental Conservation.
4.
General Comment-The date when the augmented liquid and gaseous rad waste systems become operable should be specified.
Although there willprobably be some unplanned delays, there should be a cut-off time.
5.
Section 2.2.4 -
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The classification of the lake is Class A - special (International Boundary Water) rather than Class - A.
Therefore, the pH of the discharge should be between 6.7 and 8.5 instead of pH 6.0 to 9.0'.
6.
Section 2.2.3-The suspended solids, T.D.S., phosphorous, and chromium, etc., from the waste-water treatment facilities should be sampled before dilution with the cooling water.
The effluent from each'individual waste treatment process should be
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sampled immediately after discharge from the treatment device.
7.
Para ra h 2.3.A'.3.a, Pa e 12:
This sub-paragraph should, be expanded to include the statement that the effluent control monitor shall be set to alarm and-automaticall shut the waste dischar e
valve prior to exceeding the protection limits of 2.3.A.l.
8.
Para ra h 2.3.A.3 Pa e 12:
A new sub-paragraph should be added between existing 2.3.A.3a and b which states that:
"Liquid waste activity and flow rate shall be continuously monitored and recorded during release."
9.
Para ra h 2.3.A.4 Pa e 13:
The existing paragraph should be modified by adding the sentence:
"When it appears that the projected cumulative discharge will exceed 1.25 curies during any calendar quarter, the equipment shall be operated to the fullest capacity."
10.
Section 2.3 Pa e 13:
A new paragraph should be added which states "The maximum activity to be contained in one liquid radwaste tank that can be discharged directly to the environs 'shall not exceed 10 curies."
ll.
Section 2.3.A.4 - Monitorin Re uirement The tech spec states "Isotopic analysis of a representative batch of liquid waste shall be performed at least once per quarter."
'Measuring and Reporting of Effluents from Nuclear Power Plants" requires this be done on a monthly basis.
The monthly analysis is recommended.
12.
Section 3.1 Pa e 25 - Intake S stem'-
The description of the intake system should be revised to note the following:
(1) that the noted tunnel velocity of 8 fps is a rated value at maximum cooling
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water flow, and (2) that the total condenser circulating pump capacity of 250,000 GPM is a rated pump flow.
13.
Section 3.1 Intake S stem a e 25 4th ara ra h last sentence.-
Licensee states that, "The system design is flexible and partial flow can be maintained
.." At a meeting with the licensee on October 4 he stated that the system was "inflexible" and that their only options were no flow, one pump, or two pumps, and that the pumps. were either on or off with no speed control available.
These statements seem at odds and a-clarification of "flexible" is needed.
14.
Section 3.2 Pa e 26
-, Dischar e stem-It is noted that the discharge structure is located at a point about 535 ft.
north of the screenwell.
Figure 3.4,-in the Draft Environmental Statement reflects
'hat it is about '585 ft. north of the screenwell.
Thi:s apparent discrepancy should be corrected,.
The temperature rise of 31.2F should be clarified by noting it is a maximum combined cooling and circulating water flow temperature rise.
The "Exit velocity is approximately 4 ft. per second" should be clarified to read
'Velocity through the exit ports is approximately,4 ft. per second."
The Draft Environmental Statement for Nine Mile Point Unit 1 and FitzPatrick';s Environmental Technical Specifications note that the maximum recorded temperature of the lake is 77F.
Thus, it is not clear why the last sentence in paragraph three notes a maximum intake temperature of 80F.
The Draft Environmental Statement for Nine hEle Point Unit -1 notes that the cooling water travel time from the condenserto the discharge structure is Um minutes, while paragraph four notes that it is three minutes.
'Ibis apparent discrepancy should be resolved.
1S.
Section 3.3.D Pa e 27'-Diesel 'Gener'ator'Coolant-The statement is made that any disposal is performed in a manner which ensures that no chromate is released to Lake Ontario..
The specifications should be expanded to explain the surveillance method(s) used to ensure that.Gris is accomplished.
16.
Section 3.4, Pa e 30-It is suggested that an area south of Lake, Road also be designated as a wildlife management area and be managed in cooperation with the State Department of Environmental Conservation.
17.
Section 3.4(c)-
The phrase "and the NYS Department of Environmental Conservation" should be inserted'after the "Environmental Protection Agency" to assure compliance to State herbicide regulations.
18.
Section 3.4 should be changed to read "As soon as the Administrator of EPA and the NYS De artment of Environmental Conservation issue standards for pesticide applicators, all spraying must be done by an individual meeting these standards or under his immediate supervision."
19.
Section 3.4 Land Mana ement a e 30-It is assumed that the 130 acres were posted to hunting as
'a safety precaution around the parking areas and visitor center.
- However, we see no need for posting to prevent recreational use of this-land if the posting was not the result of safety precautions.
Recreational uses of the remaining land should be encouraged.
20.
Section 3.4 - Land Mana ement-It is recommended that the Commission staff review the NYS comments on the Nine Mile Point Unit 1 Draft Environmental, Statement concerning land management.
The Environmental Technical Specifications, should reflect these comments.
'E L
21.
Section 4.0, Environmental Surveillance and ecial Stud Pro rams There is no mention made, in the objectives or any of the sections on fish, of any program to identify a fish kill in the plume.
There should be a plan established to determine if a fish kill occurs when the plant goes off-line.
In addition, there is now sufficient plume data to make some judgements as to those weather conditions that might cause a.fish, gill in the plume.
This should be investigated when the conditions occur.
22.
Section 4.1.1.A.1, a e 32 P.,
It is encouraging to see the applicant recognizing the need for>comparable data with the I.F.Y.G.L. and DEC.
Ne assume that his statement explains why detailed methods and net sizes are not spelled out in Section 4.1.1.A.6, page 35.
23.
Section 4.1.1.A.l,-
The Department of Environmental Conservation has held the position that while any facility should be evaluated in tems of its individual characteristics and the site in question, it is the total effects of all operations on a water body 4
that are important to the environment. It is good to see the licensee accept this philosophy, recognizing that protection limits must be based on the operation of both Nine Mile Point Unit 1 and the FitzPatrick Power Plant.
To this should be added Nine Mile Point 8'( (tvhen it becomes operational) the Ox~ego stations, and in fact all users of Lake Ontario.
24.
Section 4.1.1.A.3, Zoo lankton a e 35-Thephrase "...properly sampled..."
should be explained.
25.
Section 4.1.1.A.3 Zoo lankton a e 35-Zooplankton sampling is proposed with "...vertical tows from the bottom to the surface of the lake...", while objective'l of the Ecological Survey, page 31 is to determine "...distribution and relative abundance of species in space and
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time..." Vertical tows, as suggested without &u'ther clarification as to methodology, will mask rather than provide spacial distributions.
26.
Section 4.2.1.A Thermal Plume Ma in Results of these studies should be forwarded to the Power Authority of the State o$ New York (PASNY) as completed. It is apparent from the results to date that the plume of Nine Mile Point 81 affects the area of discharge of the FitzPatrick Plant.
27.
Section 4.1.1.A.6, Fish age 35-Every effort should be made to fish one or two trapnets for a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> period each week from early May to early June, in addition to supplemental use of trapnets the rest of the year.
28.
Section 4.1.1.A.6, a e 36-Station 3 at 3-mile radius would be in about 200 feet of water, rather than the 100 feet as indicated.
29.
Section 4.1.1.C.1 Sampling locations and a schedule for evaluating entrainment of plankton, fish egg and larvae are proposed.
The five locations seem to be adequate,
- however, those locations where laboratory simulation will be used should be listed here.
These are not unknowns at this time.
Section 4.1.1.C.4 seems to indicate that the only real sampling will be at the intake forebay, and that simulation will be used for discharge forebay, at 'discharge before mixing with ambient water, in the mixing zone, and in the plume 2'F.
above ambient.
30.
Section 5.1, Pa e 49 - Or anization and Re onsibili The organization for Nine Mile Point Unit No.
1 and its relationship for pro-viding continuing protection to the environment by the site organization is shown in Figure 5.1.1-1.
Related to this continuing protection is the quality assurance
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program for operation.
Thus, Figure 5.1.1 1 should be expanded to reflect the role of the manager of quality assurance..
31.
Section 4.0 "Environmental Kirveillance 'and 'cial Stud Pro am" The specifications of the meteorological surveillance program should be presented.
32.
Section 5.5 "Station Re ortin Re uirements" Provision should be made for general reporting summaries of the meteorological data.
ln addition, in Section 5.5.1, "Semi-Annual Reports" the analysis of environmental data should include,,where appropriate, compatible meteorological data to facilitate the interpretation of the data.
33.
Section 5.5.2, "Non-Routine Re orts" Provision should be made for documentation and presentation of the pertinent meteorological parameters during the period of violation.
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