ML18026A318
| ML18026A318 | |
| Person / Time | |
|---|---|
| Site: | Susquehanna  |
| Issue date: | 12/02/1980 |
| From: | Lehr J Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML17138B637 | List: |
| References | |
| ISSUANCES-OL, NUDOCS 8012170663 | |
| Download: ML18026A318 (20) | |
Text
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
)
)
PENNSYLVANIA POWER 5 LIGHT COMPANY
)
AND
)
ALLEGHENY ELECTRIC COOPERATIVE, INC.
)
(Susquehanna Steam Electric
)
- Station, Units 1 and 2)
)
Docket Nos.
50-387 O.L.
50-388 O.L.
AFFIDAVIT OF JOHN C.
LEHR I, John Lehr, being duly sworn, dispose and state:
By whom are you employed, and describe the work you performs A:
I am employed by the Environmental Engineering Branch, Division of Engineering, Office of Nuclear Reactor Regulation, U.S. Nuclear Regulatory Commission.
A copy of my professional qualifications is attached to the affidavit.
Have you read "Applicants'otion for Summary Disposition of Contention 2 (Chlorine)", filed November 6, 1980, and the documents attached
- thereto, including the affidavit of James Rios?
A:
Yes.
g:
Would you describe the scope of the subject matter addressed in your affidavit?
A:
I have been asked to evaluate the potential health effects of chlorine.
The major use of chlorine in the Susquehanna facility will be to control biofouling of the heat exchange surfaces in the main circulating water system.
The build up of organisms on heat transferring surfaces can adversely affect the condenser heat transfer rate and thus the plant efficiency and can adversely affect the performance of cooling towers.
In extreme
- cases, massive build up of organic materials in the cooling tower can lead to failure of cooling tower fill. There are other comparatively minor uses of chlorine at the facility, such as disin-fecting the potable water supply and the sewage effluent.
- Thus, I have not addressed the use of chlorine for disinfection of sewage or for production of potable water.
g:
Will the Susquehanna Steam Electric Station use chlorine for biofouling control?
A:
Yes.
According to the application filed with the U.S.
Environmental Protection Agency for a permit under the National Pollutant Discharge Elimination System (NPDES),
the station will utilize gaseous chlorine for biofouling control.
g:
What effect will the presence of acid mine drainage in the Susquehanna River have on the use of chlorine for biofouling controls A:
Acid mine drainage will tend to decrease the biological productivi ty of the receiving water through direct toxic action on the biota and through indirect actions, such as depletion of dissolved oxygen to the extent that the organisms could no longer survive.
Therefore, the biotic content of the plant's influent water would tend to decrease under the conditions described in CAND's response to NRC's discovery requests.
Thus, if the condi tions alleged by CAND came into existence, these conditions would tend to decrease the need to chlorinate.
g:
What effect will the presence of toxic chemicals in the Susquehanna River have on the use of chlorine for biofouling control' A:
Without additional specific information on the particular toxic chemi-cals alleged to be present, the Staff cannot make a judgment as to the need to alter the chlorination level proposed by Applicants.
The Staff does note, however, that chlorination is not generally used as a mechanism for the removal of toxic chemicals from water.
Does'this use represent a pathway for chlorine to the offsite environment?
A:
Yes.
By far the most significant liquid pathway to the offsite environ-ment for chlorinated water is the cooling tower blowdown.
The principle
form of chlorine present in the plant blowdown will be chloride ion.
This is because elemental chlorine and its reaction products, hypo-chlorous acid and hypochlorite ion, react very rapidly with substances in the cooling water to form chloride compounds, chloramines, and other chlorine-containing compounds such as trihalomethanes.
The applicant has indicated in the NPDES application that a dechlorination system using sulfur dioxide will be employed for treatment of cooling tower blowdown.
That system will reduce these active chlorine chemical species to below detectable limits (i.e., less than 0.05 mg/1 maximum).
Are any of the chemical forms in the cooling tower blowdown of public health significance?
A:
Yes.
It is possible that the action of chlorine on organic substances in the influent cooling waters may result in the formation of chlorinated organics in the plant discharge that will not be removed by the dechlori-nation system.
(Of the three types of compounds mentioned earlier, chloramines will be removed by the dechlorination system.
There is no perceived threat to public health from chlorides at the levels likely to be discharged.)
Studies conducted on raw waters treated with chlorine for=disinfection and studies on cooling tower waters and once through 2
waters treated with chlorine for biofouling control have revealed the subsequent presence of trihalomethanes in the treated waters.
In a summary of studies, EPA reports that trihalomethanes, listed as toxic under the Clean Water Act, were found in greater amounts in a power plant effluent than in the influent in at least one reported study of recirculating cooling systems.
The principle health effect of the trihalomethanes and the halomethanes involves their suspected carcinogenicity.
These compounds have been eva'juated by EPA in order to establish criteria for the protection of 5
human health.
A maximum level of 6 /Jg/1 in raw and finished waters "could be considered acceptable for bromomethane, chloromethane, dichloromethane, tribromomethane and bromodichloromethane",
exclusive of contribution to total exposure from air and food.
Furthermore, EPA has proposed a water quality criterion of 2 pg/1 for this group of halomethanes, based on the structure and biological activity of chloro-form, as (1) providing an adequate margi n of safety in the absence of sufficient data for quantitative risk assessment, and (2) taking into account the fact that exposure to halomethanes also occurs through foods and via inhalation.
g:
Can you estimate the likely levels of trihalomethanes to be produced at the Susquehanna Steam Electric Station?
A:
A quantitative estimate of trihalomethane concentrations in the plant discharge has not been made by the applicants.
The specific water chemistry that will exist under operating conditions, with concentrated river water in the treated plant system cannot be predicted accurately.
Active chlorine behavior is dependent on this chemistry.
Thus, the
conditions in the blowdown are largely unknown at this time.
- However, some insight may be obtained from an NRC sponsored
- study, which examined 6
the products of low level chlorination (i.e., in the range used in power plant cooling water chlorination, 2-5 mg/1 residual chlorine at one hour contact time) of various natural waters in the United States.
Chloroform was found to be the principal trihalomethane product of freshwater chlorination, with concentrations of haloforms found in these studies ranging from 2 to 55 yg/1.
Chloroform production in chlorinated freshwater samples ranged from 2 yg/1 to 25yg/1.
Significantly, in a study of chlorinated closed cycle cooling systems at Oak Ridge National Laboratory, Jolley, et al.
showed a volitization 3
loss of chloroform and other trihalomethanes to the atmosphere in samples collected from cooling tower basins.
At a calculated applied chlorine residual of 2 mg/1, the chloroform concentration was seen to drop from 38pg/1 to 6.2pg/1 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> after chlorine addition.
Have trihalomethanes been found in treated U.S. water supplies?
A:
Yes.
In a study of 80 U.S. cities, a number of trihalomethane compounds 7
were found in drinking water.
Chloroform was always found to be the major trihalomethane present.
How do the concentrations of chloroform in these public water supplies compare with the values cited for protection of public health and with
7 those noted in association with chlorination of recirculating cooling I
waters?
A:
The average value of chloroform in the sampled public water supplies was 21pg/1, with 10$ of the samples exceeding 100pg/1.
In the EPA Interim Primary Drinking Water Regulations, EPA has established that 8
total trihalomethanes in community drinking water systems serving 75,000 or more individuals not exceed 100 yg/1.
These values are considerably above the value cited for protection of public health in the water quality criteria and range from comparable to well above those associated with the reported values in chlorinated surface-and cooling tower waters.
Q:
Given that the data presently available indicate that chlorination of raw surface waters in a recirculating cooling system will lead to the discharge of potentially carcinogenic compounds to the environment, do limitations on the discharge of these compounds exist in the applicable EPA Effluent Guidelines?
A:
No.
Limitations on chlorinated organics are not now a part of the applicable effluent guidelines or new source performance standards for the steam electric generating point source category.
In the EPA Proposed Pretreatment and New Source Rules for the Steam Electric Power Generating
- Category, organic and inorganic priority
pollutants, including the trihalomethanes chloroform, dichlorobromomethane and dichloromethane, were cited as being present in cooling tower blow-down due to chlorination of circulating water.
Specific limitations on these pollutants were excluded from EPA rules on the bases that:
Sufficient protection is already provided by the Agency's guidelines and standards under the Act, and the pollutant is present in amounts too small to be effectively reduced by technologies known to the Agency.
g:
Are means available that will provide for the protection of public health with regard to the potential presence of these compounds in the Susquehanna River downstream of the Susquehanna Steam Electric Station?
A:
Yes.
There are several process
'changes that can be made at water treatment plants that are capable of reducing the amount of trihalo-methanes that occur in finished drinking water.
The exact
- process, changes, or chemical treatments to be employed would vary according to the specific characteristics of the influent water, plant design and desired level of trihalomethanes in the effluent as compared to that in the influent.
Recent studies at operating treatment plants 10, 11 indicate that the point of disinfection (with chlorine) in the plant, II increasing the amount of pretreatment of raw water prior to disinfection, changing the disinfectant, use of ammoniation, and treatment of raw water for removal of trihalomethane precursors, are effective in reducing
the amounts of trihalomethanes produced.
Also, steps such as use of activated
- carbon, aeration and coagulation are effective for removal of trihalomethanes after they are formed in the processed water.
A study reported by Blanck indicated reductions of up to 59-90K in trihalo-10
~
methanes in finished water supplies can be achieved by these methods.
g:
What effect would the use of chlorine for biofouling control at the Susquehanna Steam Electric Station have on public health?
A:
The use of chlorine at the plant for biofouling control would likely result in the release of trihalomethanes, principally chloroform, in amounts at the plant discharge that are on the order or less than those that have been found to be present in drinking water supplies to U.S.
cities.
The trihalomethane content of the discharge may be below the 7
maximum contaminant level by EPA under the Safe Drinking Mater Act.
The discharge flow of the plant is a small fraction of the river flow under normal conditions, which will serve to reduce the concentrations even further prior to the withdrawal of river water for treatment for potable use downstream.
In addition, means have been shown to be readily available that are capable of greatly reducing the trihalo-methane content of water delivered to customers.
In the development document for the proposed EPA effluent limitations for the steam elect ic point source category,
,the non-water quality 12 aspects of chlorination and subsequent dechlorination of cooling tower blowdown have been evaluated and are "not expected to result in any non-water quality environmental effects" (Section VIII).
Based on the above mentioned considerations, I conclude that the use of chlorine for biofouling control at the site will not result in a signifi-cant impact with respect to public health.
I hereby certify that the above statements are true and correct to the best of my knowledge and belief.
c 4 C. Lehr Subscribed and sworn to before me this 2nd day of December, 1980 Notary Pub ic l1y Commission expires:
July 1, 1982
References Pennsylvania Power and Light Company; National Pollutant Discharge Elimination System Application for Permit to Discharge Wastewater; June 14, 1978.
M. D. Arguello, et al "Trihalomethanes in Water:
A Report on the Occurrence, Seasonal Variation in Concentrations, and Precursors of Trihalomethanes";
Journal AWWA, September 1979.
R. L. Jolley, et al; "An Experimental Assessment of Halogenated Or-ganics in Waters from Cooling Towers and Once Through Systems",
in Water Chlorination Environmental Im act and Health Effects Volume 2; ed.
by R. J. Jolley, H. Gorchev and D.
H. Hamilton, Jr.;
Ann Arbor, Mich., Ann Arbor Publishers, Inc.,
1978.
EPA Proposed Pretreatment, New Source Rules for the Steam Electric Power Generating Category; 45FR68328, October 14, 1980; U.S. Environ-mental Protection Agency.
Water guality Criteria: Request for Comments; 44FR43678, July 25, 1979; U.S.
Environmental Protection Agency.
R.
M.Bean, et al; Anal sis of Or anohalo en Products from Chlorination of NaturalWaters Under Simulated Biofoulin Control Conditions; NUREG/
CR-1301; U.S. Nuclear Regulatory Commission, June 1980.
U.S. EnvironmentalProtection Agency; "Pr eliminary Assessment of Sus-pected Carcinogens in Drinking Water", Report to Congress, Washington, D.C., 1975.
Interim Primar Drinkin Water Re ulations:
Control of Or anic Chemical Contamsnants in rsnkin Water; 4FR68 23, November 29, l979; U.S. Environ mental Protection Agency.
U.S.
Envi rormental Protection Agency; "Proposed Pretreatment, New Source Rules for the Steam Electric Power Generating Category; 45FR68238, October 14, 1980.
C. A.Blanck; "Trihalomethane Reduction in Operating Water Treatment Plants"; Journal AWWA, September 1979.
D. T. Duke, et. al.; "Control of Trihalomethanes in Drinking Water"'ournal AWPIA, August 1980.
U.S. Envirormental Protection Agency; Develo ment Document for Effluent Limitations Guidelines and Standards for the Steam Electric Point Source Cat or Pro osed; EPA 440/1-80/029-b; September 1980.
SUPPLEMENT TO APPLICANTS'TATEMENT OF MATERIAL FACTS 1.
Acid mine drainage will tend to decrease the biological productivity of the receiving water through direct toxic action on the biota and through indirect actions, such as depletion of dissolved oxygen to the extent that the organisms could no longer survive.
2.
Chlorination is not generally used as a mechanism for the removal of toxic chemicals from water.
3.
The principle form of chlorine present in the plant blowdown will be chloride ion.
4.
Applicants dechlorination system will reduce active chlorine chemical species to below detectable limits (i.e., less than 0.05 mg/1 maximum).
5.
The action of chlorine on organic substances in the influent cooling waters may result in the formation of chlorinated organics in the plant discharge that will not be removed by the dechlorination system.
Studies conducted on raw waters treated with chlorine for disinfection and studies on cooling tower waters and once through waters treated with chlorine for biofouling control have revealed the subsequent presence of trihalomethanes in the treated waters.
In a summary of
- studies, EPA reports that trihalomethanes, listed as toxic under the
Clean Water Act, were found in greater amounts in power plant eff1uent than in the influent in at least one reported study of recirculating cooling systems.
6.
The principle health effect of the trihalomethanes and the halomethanes in general involves their suspected carcinogenicity.
7.
EPA has proposed a water quality criterion of 2pg/1 for this group of halomethanes.
EPA further stated that a maximum level of'6pg/1 in raw and finished waters "could be considered acceptable for bromethane, chloromethane, dichloromethane, tribromomethane and bromodichloro-methane,"
exclusive of contribution to total exposure from air and food.
8.
An NRC sponsored study, which examined the products of low level chlorination of various natural waters in the United States, found that chloroform was the principal trihalomethane product of freshwater chlorination, with concentrations ranging from 2 to 25 /Jg/l.
A study by R.L. Jolley showed a volitization loss of chloroform and other trihalomethanes to the atmosphere in samples collected from cooling tower basins.
At a calculated applied chlorine residual of 2 mg/1, the chloroform concentration dropped from 38yg/1 to 6.2 yg/1 two hours after chlorine addition.
9.
In a study of 80 U.S. cities,,sampled public water contained a number of trihalomethane compounds, with a mean of 21 pg/1, with 10K of the samples in excess of 100pg/1 for chloroform.
10.
The EPA Interim Primary Drinking Water Regulations establish that total trihalomethanes in community drinking water systems serving 75,000 or more individuals should not exceed 100 pg/l.
11.
Through a number of readily available process changes or chemical treatments, water treatment plants can reduce trihalomethane levels in finished drinking water by as much as 59 to 90 percent.
PROFESS IONL> flllhf I F I CATI ONS JOHN C.
LEHR U.S. Nuclear Regulatory Commission I
am currently employed as Senior Environmental Engineer in the Office of Nuclear Reactor Regulation, Division of Site Safety and Environmental
- Analysis, in the Environmental Specialists Branch.
I have the responsibili.y or the independent review and analysis of the proposed site, alternative sites, site selection methodology, station construction, and design and operation of those features of nuclear power plants as they may affect natural water resources, existing water quality and use, water quality and usage goals as established by the responsible agency and other impacts on the aquatic environment.
In this capacity, I have prepared the abiotic aquatic impact sections for NRC environmental impact statements (EIS) on numerous construction permit and operating license applications.
For,operating license applications, I have provided the technical specifications in the area of water quality and chemical discharge limitations and monitoring requirements.
I have provided the technical expertise in the NRC overview function of contractor prepared EIS's in the area o
abiotic aquatic impact assessments,
.including the need for mitigative ac.ions and establishment of coordination with state and regional EPA offices.
In the above capacities, I have been responsible for the water quality related aspects of NRC licensing actions for over 70 applications.
I have also been responsible for the water quality related sections of several NRC NEPA alternate site investigations of proposed nuclear power plants, including he Seabrook Units 1
and 2 plant.
I have acted as a consultant to other NRC branches and provide analyses of water ouality problems through technical assistance
- requests, particularly to the Division of Operating Reactors on matters pertaining to assessment o
chemical effluent impacts and changes in abiotic effluent limitations and w'ater chemistry monitoring programs for operating plants.
I have served as the coordinator and principal investigator in an in-house study to determine actual releases of residual chlorine from operating nuclear power plants.
In addition, I
am the Division technical representative on several inter-office NPC Research Review Groups.
As such, I
am responsible for defin-ing and coordinating research needs in the area of abiotic aquatic environmental concerns and for providing the technical guidance for on-going research programs in this area.
Examples of research activities governed by, the~ review groups are asbestos in cooling tower waters, residual chlorine and chlorination by-products in power plant discharges in fresh and marine waters and investigation of the occurrence of pathogenic organisms in power plant cooling waters.
I have been designated as the in-house technical originator responsible for development of Environmental Standard Review Plans addressing staff HEPA reviews of site water quality, plant water uses, plant chemical and sanitary wastes, water quality related impacts of plant operation, abiotic aquatic monitoring and chemical treatment system alternatives.
In a related activity, I have participated as a member of the Standard Environmental Technical Specifications Task Group responsible for the abiotic aquatic monitoring sections of the NcGuire Units 1
and 2 and the Three Nile Island Unit 2 FTS.
I have participated in technical conferences with and coordinated water quality related activities with the U.S.
Environmental Protection Agency, the U.S.
Army Corps o, Engineers, and other Federal, State and local agencies regarding implementation of the tiational Environmental Policy Act, the, Federal Mater Pollution Control Act and its amendmen+s, the Toxic Substances Act, the Drinking Mater Act and the memoranda of understanding between the liRC and EPA and COE.
I have also developed expertise and been designated as the responsible technical specialist in the areas of sound level prediction techniques for power plants and their transmission lines and techniques for estimation of community response to environmental sound levels, as influenced by power plant construction and operation.
I have been responsible for sections o
hRC environmental impact sta;ements addressing these areas for several proposed and operating nuclear power plants.
I have a Bachelor of Science degree in Nechanical Engineering
=rom Drexel Institute of Technology (1969) and a Naster of Science degree in Environmental Engineering from Drexel University (1972) specializing in wa+er associated problems in the environment.
My academic background includes studies in water chemistry, domestic and industrial waste treatment, and water resources management.
From 1969 to 1972, I was a mechanical engineer at the U.S.
Armv Frank or d Arsenal, Philadelphia, Pennsylvania.
I was assigned as Project Nanager of materials
- handling, and pollution control efforts for the Small Caliber Ammunition Nodernization Program.
I participated in the development of solid and liquid waste management and noise control programs for metal parts manufacturing facilities.
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of PENNSYLVANIA POWER AND LIGHT CO.
ALLEGHENY ELECTRIC COOPERATIVE, INC.
)
)
(Susquehanna Steam Electric Station,
)
Units 1 and 2)
)
Docket Nos.
50-387 50-388 CERTIFICATE OF SERVICE I hereby certify that copies of "NRC STAFF ANSWER IN SUPPORT OF APPLICANTS'OTION FOR
SUMMARY
DISPOSITION OF CONTENTION 2 (CHLORINE)," dated December 2, 1980, in the above-captioned proceeding, have been served on the following, by deposit in the United States mail, first class, or, as indicated by an asterisk through deposit in the Nuclear Regulatory Commission's internal mail system, this 2nd day of December, 1980:
- Charles Bechhoefer, Esq.,
Chairman Atomic Safety 8 Licensing Board U.S. Nuclear Regulatory Commission Washington, D.C.
20555
- Mr. Glenn 0. Bright, Member Atomic Safety 5 Licensing Board U.S. Nuclear Regulatory Commission Washington, D.C.
20555
- Dr. Oscar H. Paris, Member Atomic Safety 8 Licensing Board U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Jay Silberg, Esq.
Shaw, Pittman, Potts and Trowbridge 1800 M Street, N.W.
Washington, D.C.
20036 Bryan A. Snapp, Esq.
Pennsylvania Power 8 Light Company Two f/orth Ninth Street Allentown, Pennsylvania 18101 Dr. Judith H. Johnsrud Co-Director Environmental Coalition on Nuclear Power 433 Orlando Avenue State College, Pennsylvania 16801 Mr. Thomas M. Gerusky, Director Bureau of Radiation Protection Department of Environmental Resources Commonwealth of Pennsylvania P. 0.
Box 2063 Harrisburg, Pennsylvania 17120 Ms. Colleen Marsh Box 538A, RD84 Mountain Top, Pennsylvania 17120 Mrs. Irene Lemanowicz, Chairperson The Citizens Against Nuclear Dangers P. 0.
Box 377 RDA'1 Berwick, Pennsylvania 18503
- Richard S.
- Salzman, Esq.,
Chairman Atomic Safety 8 Licensing Appeal Board U.S. Nuclear Regulatory Commission Washington, D.C.
20555
- Dr. John H. Buck, Member Atomic Safety 8 Licensing Appeal Boa'rd U.S. Nuclear Regulatory Commission Washington, D.C.
20555 "Mr. Thomas S. Moore, Member Atomic Safety 8 Licensing Appeal Board U.S. Nuclear Regulatory Commission Washington, D.C.
20555 "Atomic Safety 8 Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, D.C.
20555 "Atomic Safety 5 Licensing Appeal Board Panel U.S. Nuclear Regulatory Commission Washington, D.C.
20555
- Secretary U.S. Nuclear Regulatory Commission ATTN:
Chief, Docketing 8 Service Branch Washington, D.C.
20555 Susquehanna Environmental Advocates P. 0.
Box 1560 Wi lkes-Barre, Pennsylvania 18703 Mr. Robert M. Gallo Resident Inspector P. 0.
Box 52 Shickshinny, Pennsylvania 18655 Karin W. Carter, Esq.
Department of Environmental Resources 505 Executive House P. 0.
Box 2357 Harrisburg, Pennsylvania 17120 Jhssica H. Laverty Counsel for NRC Staff