ML17275B252

Comments on NUREG-0812,DES for Facility

ML17275B252
Person / Time
Site:	Columbia
Issue date:	09/23/1981
From:	Bouchey G WASHINGTON PUBLIC POWER SUPPLY SYSTEM
To:	Schwencer A Office of Nuclear Reactor Regulation
References
RTR-NUREG-0812, RTR-NUREG-812 GO-2-81-309, NUDOCS 8109290269
Download: ML17275B252 (8)

Text

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Washington Public Power Supply System P.O. Box 968 3000George Washington Way Richland, Washington 99352 (509) 372-5000 September 23, 1981 GO-2-81-309 Docket No. 50-397 Mr. A. Schwencer, Chief Licensing Branch No.

2 Division of Licensing U. S. Nuclear Regulatory Commission Washington D. C.

20555

Subject:

WPPSS Nuclear Project No.

2 Draft Environmental Statement

'UREG-0812 r

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Reference:

Ltr., A. Schwencer, NRC, to R. L. Ferguson,

WPPSS, same subject, dated August 7, 1981 We have reviewed the subject document and offer the following comments which you may wish to consider in the preparation of a Final Environ-mental Statement.

Introduction Pa e l-l It would be more accurate to reword the first paragraph as follows: "The proposed action is... to the Washington Public Power Supply System (WPPSS),

a municipal corporation and joint operating agency of the State of Washington, for startup and..."

Also the maximum design power level (third paragraph) is 3468 MWt as opposed to 3458 MWt noted in the FES-CP (see also FSAR Sec. 1.1.7).

Water Use Sections 4.2.2.1, 4.3.2.2, 5.3.1, and 5.3.5 The current situation with respect to the local groundwater supply is that there are three wells onsite; two are completed to the unconfined aquifer and the third well draws from the deeper confined aquifer.

One of the two shallow wells periodically provides water for dust suppres-sion and the other is not used.

The deep well provides water for construction, fire suppression, and drinking.

A filter system is presently being installed on the river makeup water system and, when completed, potable water will be obtained from the river.

During opera-tion, normal water supply will be from the river and the deep well will be maintained as a standby source; the two shallow wells will not be used.

With respect to monitoring, the Supply System believes sampling and analysis of well water, if it is used, will detect contamination

~l and verify conformance with applicable drinking water standards.

The frequency of monitoring should be related to usage; as noted above, the 5

two shallow wells will not be used and the deeper well will be used very infrequently.

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Hr. A. Schwencer Page Two September 23, 1981 WPPSS Nuclear Project No.

2 Draft Environmental Statement (NUREG-0812)

Threatened S ecies Sections 4.3.4.3 and 5.5.1.2 A survey of threatened species in the Hanford Reach was performed in 1980 D.H. Fickeisen, R.

E. Fitzner, R.

H. Sauer, J.

L. Warren, Wildlife Usa e, Threatened and, Endan ered S ecies and Habitat Studies of the Hanford Reach Columbia River, Washin ton, Prepared for U. S.

Army Corps of Engineers by Battelle Pacific Northwest Laboratories,

Richland, Washington 1980).

All.ium robinsonii was generally found on silty and usually stoneless so>l 20 - 30 feet from the river.

Studies performed 1975 - 1980 have not documented the presence of the'pecies in the vicinity of WNP-2 (Prep erational Terrestrial Monitorin Studies Near WNP-1,-2, and -4,, Ma throu h December

1980, Beak Consultants, Inc.,

Portland, Oregon, January 1981 Historic and. Archeolo ical, Sites Section 4.3.5)

The last property listed in Table 4.4, the Poison House, is in Grays Harbor County not Franklin County.

Corrosion Products Section,4.2.4.2 and 5.3.4.3)

We believe the Section 5.3.4.3 considerably overestimates the in-river, after mixing concentration of copper, especially when compared to the blowdown concentrations of total copper'ited in Section 4.2.4.2.

Coolin Tower Drift Sections 5.4.2," 5.5.1.1, 5.5.3.1)

The DES correctly notes that, the Supply'ystem is very conservative in its estimates of cooling tower, drift (e.g.,

assumed drift rate of 0.05%).

Notwithstanding this conservatism and low probability'of quantifiable impacts (DES, P. 5-8), the Supply System intends to conduct a soil chemistry and vegetation analysis program at least during the initial phase of cooling system operation (ER-OL Section 6.1.4.1).

The Supply System's previously stated intention of using aerial photography to assess drift effects was deleted by Amendment 5 (July 1981) to the ER-OL.

The reason for deleting this approach is that aerial photographs taken to date are not useful to differentiate plant community charac-teristics.

Specific problems are that individual plant species cannot always be distinguished and changes in 'productivity cannot be assessed because of.the great amount of standing dead material near WNP-2 and the relatively low growth form of the dominant species.

The Energy Facility Site Evaluation Council (EFSEC) concurred with this program change (ER-OL Ref. 6.1-53).

Heteorolo ical Monitorin Section 5.4.3)

We should note that the WNP-2 meteorological-measurement system is not inactive; it was reactivated on October 1, 1979 to support WNP-1 and remains operating in support of the Fast Flux Test Facility (FFTF).

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Nr. A. Schwencer Page Three September 23.,

1981 WPPSS Nuclear Project No.

2 Draft Environmental Statement'(NUREG-0812) e Radiolo ical Im acts Section 5.8 and su ortin a

endices)

While individual and general population dose commitments'resulting from the operation of WNP-2 will indeed be very small (DES P.

5-23 and L-2),

we believe the DES. may overestimate the doses.

We note, for instance, that the atmospheric'dilution factors are an. order of magnitude greater than the Supply System's estimates without explanation.

We should also note that site restricted area boundary is described in ER-OL Section 2.1.1.3 and FSAR Section 2.1.1.3.

This boundary is not the same as the exclusion area boundary (1950 meter radius) and 'the DES may be confusing in'regard to these definitions (e.g.,

DES P. 5-35).

With respect to Section 5.8.1.4.1, the Supply System has established 32 dosimetry stations:

one ring of,l6 at the exclusion area

boundary, 7 at 4-6 miles i'n sectors across the Columbia River in Franklin County, and 9 in special interest areas.

These, combined with'the extensive network maintained by Battelle Northwest Laboratories for DOE, should fulfillthe plant requirements.

In Table 5.7, reference to Appendix'"H" should instead be to "D".

The transfer of information, from Figure 5.7 to Table 5.9 is not clear and, in particular, the 1,920/21,000 cancers for a probability of 10

~ seems in error.

Socioeconomic Benefits and Costs Sections 2.2 5.7, and Cha ter 6)

A general, and perhaps

obvious, comment is that numbers on both sides of the benefit/cost ledger have increased since the Supply System applied for an operating license or last responded to NRC questions on the subject.

These increases would not, however, al-ter the relevant conclusions.

We have appreciated the opportunity to comment on this Draft Environmental Statement.

Very truly yours, G.

D. Bouchey Director, Nuclear Safety CC cc:

N. Reynolds, Debevoise 5 Liberman J.

R. Lewis, BPA R. Auluck, NRC A. D. Toth, NRC J. Plunkett, NUS Corp.

E.

E. Beckett, NPI

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