ML18354A357
| ML18354A357 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 10/09/1970 |
| From: | Bacon J Consumers Power Co |
| To: | Morris P US Atomic Energy Commission (AEC) |
| References | |
| Download: ML18354A357 (23) | |
Text
'
LEGAL DEPARTMENT I
H. P. Graves Vice President and General Counsel
"~
i1
- 1
- J.. e 1 &=alah~~ :.
General,Attorney 1 ;I*
\\
- 1 *,
<: *ii~,: t:~:r~r:-
[
- c*..,E. **Merritt i l> ~-r~~f "*~:'.: £~:;:~~.'
.; *.~.. *;senior Attorneys
,.. *}. t. B~con:
~, A. B. Bass L
- A. Esckilsen R
- F
- Godbout
. B. E. Hagen W *. A. Kirkby,
- '; __ tcc.,,}:' *! ~. M~C~llum
""..,:.;,.;,_Lw.q=~.. Mills
- iJ~--1~~~~~; :~::rick i
\\_.
D *. R. Rood J.-* M. Smith A. T; Udrys Attorneys
- 1'
,/,,
f
~.:
'I
~..,!
..._".:t
- cocms~mers Pmrier
-*GQmp&Yny General Office;o: 212 West Michigan,O.venue,.Jackson, Michigan 49201
- Area Code 517 788-0550
\\ '
Re;. Docket No. 50-255
'(\\
Dr: Pet'er A. Morris~. Directoi- _.
Di vision of *Reactor Lic:e:qsing *
- U. s*. Atom:j.c Energy Coinroission Washington~(.D. C.
- 20545.>>
Dear Dr. Morris:
- ir.
. I
\\
\\
I \\
\\
.. I I ':i, *~j~ l
\\
,}
October 9, 1970 3296
- 1.
'.r*,
/
I MEMO, * *
- from * *
- K. A. Swarts
~
~~~~
!J54~ G 7 fz_,o
.;.!\\','
.* :'(.--:!;1;
A.
Introduction RESPONSE TO COMMENTS ON THE ENVIRONMENTAL REPORT PALISADES NUCLEAR PLANT Several comments on the Palisades Plant Environmental Report have been received from the United States Department of the Interior; the Department of Health, Edu~ation and Welfare; and the Assistant Secretary of Defense.
Letters concerning the report have alosbeen received from the Department of Agriculture, Federal Power Conunission, and the State of Michigan Department of Natural Resources.
The last three letters did not contain specific comments.
Since a majority of the comments referred to the radio-activity and heat release to La.ke Michigan and the subsequent effects on public health and the ecology, it should be emphasized a.t the outset that* Consumers Power Company will make extensive mddifica.-
tions to the plant to alleviate some of the concerns in these areas.
Although the Company firmly believes that the existirig design of the radioactive waste system and the condensor cooling system are more then adequate to protect the health and safety of the public and the ecology, we will install a more extensive radioactive liquid waste processing system to maintain the radioactivity release as low ow<
as pre.ctica.bleA a. closed cycle condenser cooling system employing cooling towers to minimize the heat reiease to the iake.
A brief description of these systems are as follows:
i C)
2
- 1.
Liguid Radioactive Waste Processing Systems Modifications The modified radioactive waste processing system will be designed to collect, store, process, monitor and dispose of essen-tially all liquid radioa.ctive wastes from the Palisades Plant.
The integra.ted system will be basically comprised of three subsystems:.
clean waste, dirty waste and laund:r;y.
The clean waste system processes high-activity, high-purity (low solids) liquid wastes collected from four basic sources:
the letdown from the primary coolant system, the primary system drain tank, the radioactive-chemical laboratory drain.tank and the equip-ment drain tank.
The letdown from the primary coolant system is the largest source of both radioactivity and liquid to the clean radwaste system.
The main sources of this liquid are thermal expansion of the primary coolant system and dilution of the primary coolant for boron concentration control.
The primary system drain tank serves as a C()llection point in the containment building for seven sources of liquid:
chemical and volume control system heat exchanger drains, reactor shield cooling drains, safety injection tank drains, primary coolant pump seal leakage, primary loop drains, quench tank drains and.reactor flange leakage drains.
The radioactive chemical-laboratory drain tank serves as a collection point for the sample sink drains and the clean radio-active chemical-laboratory drains.
3 The equipment drain tank serves as a collection point for the spent resin shipping cask drains, radioactive steam generator blowdown, spent fU.el pool heat exchanger drains, spent fuel pool drain, spent resin stoi-age tank drains,.charging pumps relief line and drains, chemical and Yolume control system ion exchangers and filter drains, volume control tank drains and waste gas surge tank drain.
The liquids from t~e primary system drain tank and the letdown pass through the vacuum degasifier where they are joined by the liquids from the radioactive chemical-laboratory drain tank and the equipment drain.tank.
These liquids are then collected and may be held up for natural decay in the clean waste receiver tanks.
After sufficient decay the liquids are pumped out of the clean waste receiver tanks, through the clean waste filter, the radw~ste ion-exchengers and the treated waste monitoring tanks to an evaporator.
The evaporator will serve to further clean the demineralized liquids and to separate out the boric acid.
The distillate from the evapor-ator will be stored in the primary coolant system make-up tank for reuse.
The concentrate from the evaporator ~ill be essentially pure boric acid and will be stored in the boric acid tank for further use or sent to the* solid waste drumming station for packaging and even-tual off-site disposal. **
T.he dirty waste system collects low activity, high solids liquid from the engineered safeguards rooms, the volume control tank relief, access control area sink, emergency shower, containment
4 sump drains, vent stack drains, pump leak-off, decontamina.tion_pit drains, spent fuel cask wash-down drains, contaminated lab drains, boric acid area drains, component cooling loop drains, floor drains, treated waste-monitor tank drains and the component cooling water
. surge tank.. These liquids are collected in the dirty waste drain tank from which they are passed through the dirty waste filter to the filtered waste monitor tank.
The filtered liquids will then be processed through an evaporator to further clean up the liquids and to separate out any boric acid or other solids.
Like the clean waste distillate, the distillate from the dirty waste evaporator will be recycled for reuse in the plant.
The concentrate wi;Ll be reused as boric acid (if pure enough) or sent to the solid waste drumming station for packaging and eventual off-site disposal.
The laundry wastes consist of the used wash.water from the plant laundry facility.
This liquid may have picked up some solids from clothing and is, therefore, filtered to remove contaminates.
The liquid will be. processed through the dirty waste system unless it contains materials which cannot be so processed without the possi-
- . bili ty of impairing the function of dirty waste system equipment.
The.radioactivity in the laundry waste which. may be released _to Lake Michigan shall not exceed 2 ~.5 x io-8 A Ci/ cc on an :~annual average
. basis.
In the event of abnormal plant operation, such as operating with steam generator tube leakage, the steam generator blowdown water containing radionuclides and chemicals will be processed through the
. dirty waste evaporator.
The distillate from -the. evaporator will be released to the lake and the concentrate.will.be sent to the solid waste drumming station for packaging and e-irentual off-site disposal.
The radioactivity release to the lake dtiring* these.abnormal condi-
. tions shall not exceed, on quarterly average bases, l<Y/o of 10 CFR Part 20 limits.
Operation under these conditions.shall not be ex-tended for longer than* 60 days..
The modified radioactive waste processing system will be installed and pla.cai in operation no later than the resumption.of operation of.the plan~.after its first schedu.l.ed refueling *
. 2.
Closed.Cycle Condenser*cooling Systems
- The modified condenser cooling system shall be* a closed cycle system in which the condenser cooling water. is contim,ia.lly recycled, except for cooling system makeup water from and blowdown
~
to Lake Michigan.
.The system shall include one or more wet-type cooling towers which may be of either the natural or the mechanical draft type.
To.accommodate*this closed circuit system, the existing cooling water intake structure will be modified so that. the present lake inlet will go only to the service water pump bay.
.The existing service, water pumps 1111 "Iii~ iiO will take suction from the cooiing tower basin and from the la.ke; with the lake providing cooling t,awer makeup. water.. The existing circulating water. pumps will be isolated from the lake inietand instead will receive water from the cooling
6 tower basin and discharge to the condenser.
New _circulating water pumps will be installed to carry the condenser discharge flow to the cooling tower inlet.
The circulating water will pass through the tower into the basin below and then on to the modified intake struc-ture where it will again be pumped through the condenser using the existing circulating water PUlll{)S.
Some water must be discharged from the cooling tower basin to the lake in order to control the concentration of salts or other impurities which a.re contained in the. lake makeup ~ater. This dis-
- charge is termed the tower "blowdown.
11 Dilution pumps will be in-stalled to add lake water to the blowdown prior to discharge into the lake.
'l'he dilution water flow will be such that the temperature of the mixed dilution water and blowdown will not exceed the ambient temperature of the receiving water at the shoreline by more than 5°F.
The design heat rejection to the Lake as a result of.this discharge will be as low as practicable consistent with available equipment, Palisades Plant and Consumers Power electrical system operating 1'.equirements,_design optimization and other condenser.
cooling system design objectives, and will in no event exceed 500,000,000 BTU/hr.
The modified system shall be placed.in operation within about forty-two months following the. initial startup of the plant.
The specific comments and Consumers Power Company's 4(.
response to these comments are presented below:
- -r.
B.
United States Department of Interior
- l. Comment:
The report should list numerical concentration.limits used.in determinin'5 if the.radwastes are to be re-leased to the receiving water or retreated.
Response
. Prior to tlre in_stallation of the. modified. redwaste system, the radionuclide concentration in the condenser cooling water befo~e it enters LB.ke Michigan shail not exceed
. 1.Cf/o pf _the* concentrations specified in 10 CFR Part
- 20.
Following installation and operation of the modi-
. fied system, the concen.tration. shall not exceed those specified in Item-*A1 above.
- 2.
- Comment:
The statement did not present an adequate description.
of the the~L discharge. system, the predicted*
results or the effects on the. environment~
Response
A SOP_histicated mathematical model,~~. not developed for the existing system to. accurately predict the area-depth-temperature frequency relationships as affected by the*plant discharge.
The general extent of the thermal plume* can _be inferred' by extrapolating measurements made at the j. H. Campbell. Plant and the Black River discharges on the eastern shore of Lake Michigan; data which ~en made available to the regulatory agencies, including the Department
of the Interior, in various reports. It has not been shown that aquatic species that could be ad-versely affected by a thermal pltime are present in ecologically significant numbers in the general region of the plant.
Therefore, it does not appear that precise predictions of the thermal influence of the plant discharges have any particular rele-va.nce.
The heat release from the clof!ed cycle condenser cooling *
- system is discussed in Item A2..
3; *Comment:
Alternative methods for cooling the thermal discharge should be given further consideration.
Response
See Item A2.
- 4.
Comment:
Additional information is needed in chemical releases.
Response
Present System Chlorine is added periodically (approxima,tely 2.5 hr/wk) to the condenser cooling water.
During
. the time it is being added, the concentration entering the lake is expected to be about l to 2 ppm and will never exceed 6 ppm.
Phosphates and sulfites are. added to the steam generator condensate. Assuming a maximum blowdown rate of 50.gpm and dilution.in the condenser cooling water, the concentrations entering the la,ke.will not exceed 0.003 ppm and 0.0013 ppm for phosphates and sulfites
- respecti veiy.
The concentration of*boric acid entering the iake shall not exceed 5 ppm.
New Systems (as Discussed.in Item A)
Based on the"conceptual design of the. closed cycle condenser cooling system, it is estimated that
. the blowdown from.the cooling tower. will* be from lOOO'gpm to 8000 gpm and diluted by a fldw
.so. fWJ"O rate of ~m from the lake.
The closed cycle water and thus the blowdown water ( a.ssuming 8000 gpm) will contain meta-f1osphates and zinc. After dilution, the concentration entering the lake is
~.
not expected to exceed 1. 9. ppm. of. metaf1'1oshate.
and 0.19 ppm of zinc.
A more precise concentra-.
tion of chemicals to be released will be developed after the.final design of.this system has been completed.
The major change in the chemical concentration re-leased to.the lake from steam generator blowdown 9
x
is due to the change in the dilution flciw from 390,000 gal/min to 50,0oo gal/min. *Thus the
~oncentrat:i.ons ente~ing th~ lake.based on 50,000 gal/min dilution will 'Qe 0.025 ppm of phosphates and 0.01 ppm of sulfates.
The boric acid release to the lake w:i.ll*be essen-tially*zero.
- 5.
Comment:
Intake structure is not adequateiy.designed to protect fish *..
Response
The description of the. cooling water intake should have mentioned that it is of a submerged* crib~type
- design with steel plate covering the top.
Therefore, the only direct.velocities are in.a h~rizontal direction and vertical velocities are limited to
... those induced by. horizontal flow or* by wave or eddy effects.
While.the Company has only.re.rely exp~rienced large numbers of fish' at the intake screens of other plants on the Great Lakes, s.tudies *have been ini tie.ted to
- evaluate the effectiveness of various types of fish screens that*could be installed to.divert or repel fish without harming them.
10
- '--~.
- _~
It is believed the closed cycle condenser cooling system will significantly reduce, if not eliminate, the po-tential for damage.
- 6. *Comment:
Lake water should be analyzed monthly during the first
_year of operation and Co-60.s}J.ould be added to the anafysis list. Crops should also be* analyzed for Sr-90, Cs-137 and I-131 around harvest tiln~ each year *.
.*Response:
Lake water will be analyzed* for at least the f'.irst year
- of operation of* the Palisades Plant for Co-60 on a routine monthly basis if the gross activity of the
- . sample. is sufficiently high to merit i~divid{ial iso-.
topic analysis.
The gross level in lake water must 11
. exceed '1 x lo-8 uCi/ml before* individU:a1 nuclides such
>(
as Co-60 can be meaningfully identifi~d. Similarly,
~divid~al samples ~i' maj~r ~rops harvested will be.
analyzed for strontium, cesium and iodine content if gross analysis.indicates a level above 5*x lo-8 uCi/ml.
These analyses will also be performed for a.t least the
- first year of operation of the Palisades Plant.*
- 7.
Comment:
Should be shown that enough flexibility is provided to meet more stringent water quality standards.
/"
Response
It is believed tha_t the upgre.ding of the radioactive waste system and the heat removal system* as described in Item A will provide the*flexibility referred to in
.this con.nnent.
- 8.
Comment:
'It has ;not been shown in the "Final.Safety AnaJ.ysis Report" and ".Amendments" that the deposition and accumulation of a portion of the cesirun-i37 expected 12..
to be released operationally (assuming. l percent failed-fuel ratio) or which*may be released accidentally may not produce potential problema.
Studies which would reasonably predict the potential movement, dis-persion arid accumulation of the released cesium-137 and which would relate these results to an assessment of the radiation leveis* presented to the public should be made.
In addition, the environmental monitoring.
- . program outlined in the "Final Safety Analysi~ Reporti*
- and.
11Amendments 11 should include_ *reliable and regular periodic monitoring of lake-bottom sediments.
_Response:
The annual dose to the* public from* eating* 40 pounds of
- fish per year and drinking 2200 cc of water per day contiiiniDg cesium'."'137 from the.Palisades Plant is calculated to be 3.2 x lcr4 rem and 1.4. x 10-5 rem
- 13 respectively.
This dose is based on the assumption that the plant operates the entire year with 13 fuel defects, tpe released concentration is the same as that shown in Table 11-3 of the Final Safety Analysis Report, the concentration in the condensor cooling water is diluted by a factor of 1000 in the lake,.and the.re is a recon-centration of a factor of 1000 ili. the flesh of fish *
. Pr.edictions.have also been made of doses from cesium-137 to people swimming in the lake.* near the Palisades Plant. For the postulated ca.Se where the plant operates for f~rty years with 13 defective fuel and lu/o of the cesiunr released is deposited in the bottom sediment over an area 1,mile long and 0~5.mile wide, the dose woU:ld not exceed 4 x lo-7 r~m/hr. In addition, the dose from the* 99"/o of* cesium-137 dissolved in the water would not exceed 8 x 10-7 rem/tJ.r.
The upgrading of the radioactive waste system will reduce these exposures to essentially zero.
'It is. inconceivable that an accidental release of radio-
- nuclide.a from the radioactive 'waste system could occur which would exceed concentrations specified in AEC Standard 10.CFR 20.
The system*contains radiation monitors on outlet line from the radioactive waste discharge tank, on the serV'ice, water discharge and on the condenser cooling water before it enters the lake.
14
concentration factors for aquatic biota and sediment will be available in early 1972.
Based upon the results of this study meaningful. measurements can be made of movement, dispersion and accumulation of radionuclides within the lake.
C.
United States Department of Health, Education and Welfare
- 1. Comment:
15 Some method of treating high-solids-content waste, such as by evaporation, should be designed and installed in the Palisades liquid waste treatment system prior to com-pletion of the fuel cycle in order to maintain*radio-activity discharges at the lm-iest practicable levels.
The time period specified for gaseous waste holdup should be the D1Sximum possible with the cape.city provided in the waste gas holdup system.
Response
The upgraded liquid radwaste system discussed in Item A **
will provide capability for *extensive processing, by evaporation, the high*solids-content waste as well as the low-solids*content waste.
Th~ radioactivity re-lease to the lake will be reduced to as low as practicable.
Capability is provided for thirty days holdup of radioactive gases to permit the decay of the xenon isotopes.
- 2.
Comment:
Treated water from the municipal water treatment plant loca.ted at South Haven,.Michigen, five miles north of Palisades, should be sampled and analyzed as part of the environmental surveillance program.
Response
The radiological environmental surveillance program in-cludes routine da.ily and monthly compos:i.. te water sample analysis of the plant intake and outfall. The outfall sample analysis is particularly appropriate 16 as it is the point of maximum concentration.
The intake sample analysis is used for comparative background purposes. Dilution factors shown for Lake Michigan in the Final Safety Analysis Report indicate a factor of greater than 1000 from the plant outfall to the South Haven municipal water treatment plant. Hence, concentrations of radioactive materials above back-ground at this point are not exi)ected.. However, for the purpose of assurance that no member of the public using this municipal water supply is being unduly exposed to ionizing radiation of plant origin, a monthly composite sample of treated water f:rom the South Haven municipal water treatment plant will be collected and analyzed for radioactive content.
- 3.
Connnent:
Prior 'j;o operation of the facility, an off-site radia-tion emergency plan should be developed and agreed upon between. the applicant and *the Michigan State Department of Public Health.
Response
The emergency action plan has been revised to comply with the May 1970 AEC guides.
The plan is being reviewed by the Division of Compliance and is being coordinated with the various State and local.agency
- plans.
- 4.
Comment:
A population dose assessment should be presented which is bas.ed on calculations of potential total doses from
. all.critical pathw~ys for:.1) Individuals residing in*
the. plant's. immediate env~rons, and 2) The exposed
... populati.on within 50 miles of the plant expressed as man - rem/yr, taking into consideration environmental and demographic factors.
Response
The potential radiation exposures to the.general public from the Palisades Plant have been* calculated and the results, con~idering the liquid releases to Lake*
Michigan and the release from the plant in the gaseous form, are as follows:
17
-* -..., : _:.:_..:____--~:. ____ /
- 1.
Annual dose per person ea.ting 40 lb. of fish *per year
- 0.00042 rem/yr l.B
- 2.
Annual dose per person drinking 2200 cc/._day of wat_er Q.000018 rem/yr
- tJf"("f'l""'"t'~' --~~-
- 3.
- AnnU&.l/\\dose from radioactive gases e,t *site boundary *
- 4.
To.tal to individual residing at site
- boundary Total mtm-rems/yr within t?.oosr
&:OOOB rem/yr.
CJ, tJt1b 0.6012-rem/yr 50 mile radiusp I 7.,,~""'
~ --
ea~?fish and drinkf water from the Lake near the.. plant
- 61. 8
- 5.
Total man-rem/y~ l'lithin 50 mile ra.dius from radioactive.
gases Total 49~4 111.2 The above exposures are based on the assµmption that the plant operates a_full year with 1% defective fuel and the radionuciide concentrations shown in Table.11-3 and Table 11.:.4 of the Palisades Final S~fety Analysis
- _Report* are r~lee.sed to the environment. *Thirty-two different ra.dionuclides are conside~ed in pr~icting the dose from eating fish and drinking water. It is also assumed that. the concentratio~ entering the lRke is diluted. by a factor of-1000.*.. Tile.man'-rems/yr dose w-if.._iirt x
x K
- 3. VY.JD"',£8.t,, pf fish e 3'1iii&MJFiiiiR'i'ie; is ha~ed on the assumption that.-._
/5 t!~,,;5 CJ ;.;,red OYJr"\\iJofly by_ ~~~~/~ /11h~19 111 1.4~ ~?:> tt*f.lle..
>""~~-'.!:!.,
01r1 cl 7 J..of all fA of?.G';:.Je /{ 19 *i'14'-) *
!il81!SOfiC~d" W~?,)
- 11. a A~
wai;Mt"°fli!'Glil 'M!~e 1
C!'
Ji vJll1 ?nu;.
Q~.!'at -~6'/&1;-1g Cll 7'. 'P.l'"r" 4k7'/:e~ f'>"n,,., ~.4a.hire.
r1~07**
.-Pie* dose from the gas is diffused as a function of
distance as represented by the yearly average X/Q and the estimated population for the Year 1980 as shown in Figure II-4 and II-5 of the F~nal Safety Analysis Report.
The wind persistency in any one direction is assumed to be 12.5%.
With the upgraded* radwast.e pro¢essille; system discU,ssed.**
in Item A, the release of radionuclides in the iiquid will be ess<<;intia.lly zero. Subsequently, the.dose to the public during normal plant operation will only be from the radioactive gases and, therefore, will
.6-9 not exceed o.oQt9 rem/yr at the s~te boundary or a total man-rem/yr within a 50 Mii.e ra'.dius of 49.4.
Since the annual dose from natural background* radiation at the site b~undary is about* 0.125 rem/yr anc1 the total man-rem/yr from natural background radiation within.a 50inile radius is about 148,453, it is con-eluded that the operation of the Palisades will not significantly increase the radiation exposure to the public and, subsequently,.* the* radiation *risk to *the public.
D.
Assistant Secretary of Def.ense
- l. Comment:
It was stated ** tha.t the Palisades Plant circulating water system*izitake wasdesigried*to call,se only low hori.;.
zontal velocities to minimize the potential of fish being drawn through the intake. *Haweve:r, nothing was said about the magnitude of vertical velocities.
19
20
Response
See Item B5.