ML19220A375
| ML19220A375 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 04/17/1979 |
| From: | NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| To: | |
| References | |
| NUDOCS 7904170498 | |
| Download: ML19220A375 (35) | |
Text
Uf!ITED STATE 5 0F 21 ERICA liUC: FAR REGULATCRY CC "tISSI0ft Be fo re t h ' a t-"i c Sa fe
- v.rd L ic on';i nn Bo'rd In the lMtter of
)
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11EiROPOLITAtt EDIS0:1 CCMPA:1Y,
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DOC"ET i;o. 50-320 et al.
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(Three Mile Island !!uclear
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Generating Station, Unit
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!.o. 2)
)
tiRC STAFF'S RESPO!!SES TO E:;'iP.0:: MENT'L ISSUES RAIS FD I:1 L 7"ITO '"EM;l:r~ 07' m'RT':
The following is a list of issues raised by the limited appearance s ta temen ts :
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Issue Person 'N inn S*o ent (Tranteript pages Energy Conservation ?!ot~ Considered Carl Jarboe (195-214)
Mary Swann
( 2576-25 7 :+ )
flilton Lcwentnal (2588-2701)
Mary Douglas (2702-2704)
Increased !bter Temperature in Carl Jarboe (195-214, 2745-275C)
Susquehanna River Caused by Mike Jones (2580-2CE/)
Plant Credibility and Use of Rasmussen Carl Jarboe (195-214, 2745-2756)
Report Larry Arnold (2704-2744)
Decommissioning Costs Are Tco Carl Jarboe (195-212, 2745-2756)
High to ibke f:uclear Pcuer Bob Jeni cn (238-243)
Feasible; Mn.E,ds Used for liary Couglas (2702-2704)
Decommis sioning are Unsa fe Larry Arnold (2704-2744)
Thare is no 3a fe Method for David Levit (221-223)
Transportation of Wastes b,,.
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. Issue Pe r s o n__'l) k i n g S ta t me n t (Pages)
Higher (?ranium Costs Will Be Carl Jarboe (195-214, 2745-2756)
Passed On to Consumers.
Bob Jenison (238-243)
Applicant Has tiot Considered Larry Arnold (2704-2744)
Escalating Uranium Costs Uranium Availability Insufficient Carl Jarboe (2745-2756) for a ifetime of Plant What is Plant's Proposed Carl Jarboe (195-214, 2745-2756)
Capacity Factor Full fiuclear c uel Cycle is not Judith Johnsrud (230-237)
Considered in Plant Licensing Carl Jarboe (195-214, 2745-2756)
Proceedings Long-Term Effects of Low Level Elizabeth Northam (216-220)
Radiation on the Area's Abigail Jarboe (237-233)
Population Power Produced by Th:: Pla n c Bob Jenison (238-243) to be Sent to Other Areas Alternative Energy Sources are Milton Lowenthal (268C-2701 )
Available, So Why Use Nuclear Cost-Benefit Considerations Used Larry Arnold (2704-2744) in Evaluation Ignore Too Many Impomant. Costs Will Rot. tine Sampling for Carl Jarbce (195-214,2745-2756)
Radioactivity be Cone Constitutionality of Price-John Simon (189-195)
Anderson Act.
Carl Jarboe (195-214)
Price-Andc. on Act ?el ies Bob Jenison (228-243)
Plant Owners cf Financial Milton Loaenthal (2623-2701)
, Responsibility for iccidents Larry Arnald (2704-2744)
Cancers from Accidental R ases Carl Jarboe (195-212, 2745-2756) of Radioactivity Mike Jones (2680-2637)
Auxiliary Control Racm Independcrce Carl Jarboe (ISS) frca Main Control Room Cc ciceration e' Ncste Disposal Carl Jarboe (200) in Licensing of This Plant y ', E l D
s s
4 Issue Persor_":kian c t a t
- rrt (Pages)
Adequa-y. of Emergency Plans David Levit (223)
'l Larry Arnold (2717, 2718)
Testing of the ECCS Mike Jones (2633)
Adequacy of Fire Protection Mike Jones (2684)
Measures Larry Arr.old (2729,2730)
Carl Jarboe (2750)
Adequacy of Security Measures Mike Jones (26E4, 2535)
Carl Jarbce (2753)
Assurance That all NRC Regulations Larry Arnold (2730, 2731)
Have Been Adhered to Radiation Effects on Dr.ployees Carl Jarboe (2749,2750)
NRC iTAFF'S '.ESFC"SES TO ISSUrS RAISED "1 LIM'TED A?DE.i?f MCr S T.17 F r1~ c 1.
Conservaticn Section 8.3.2 o f the Final Supplement to the Final Envirormental Statcmant (FSFES) dated December 1976 discusses the impact of energy conservation as follows:
Reccat ercrgy shortages have fccused the Nation's attention on the importance of energy conservation as well as measures to increase the supply of alternative energy sources.
The need to conserve energy and to promote substitution of other energy sources for oil and gas have been recommended by the Renort to the President on the Nation', cocr-"
Fgture as major efforts in re;aining national energy seir-suiticiencj by 1980.
There was a slowdcun in growth in the applicant's service area in 1974 and 1975 as indicated by the data in Table 3.3.
Summer ceak load declined from Sa50 MW in 1973 to 5C52 MU in 1974 and 5157 in 1375.
Energy recuirenents declined fren 30,350 C'..'h in 1973 to 29,931 5.;n i n 1974 a.1d 29,727 GWh in 1975.
'n'hile conserva tion was li s ted aromj tne factors contributing to slower growth, the applicant fu: ther cit.'J the ecLncaic recession and the impact on no. hcme cons truction as other factors.
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Historically, utility rate structures were designed to encourage can-sumption of electricity by using the declining block rates, which reflected the declining average cost of furnishing adoitional Kilcuatt hgars of electrical energy tu each customer.
Until recently, the economic logic for declining block rates was never sericusly disputed.
Tecay, however, under conditions of increasingly scarce fuel rescurces,
declining block rates, by louering the price of each aeditional kilowatt hour, tend to encourage greater use of electricity by individual consumers and also to encourage individual consumers te use more and more electricity instead of other energy sources.
The most commonly mentioned alternatives to declining black rates to demand for electricity are peak load pricing, flat rates., and increasing block rates.
According to the applicant, the GpU System has made it a practice to design rates which are cost based and include costs associated with servicing customers and costs associated with volume of energy supplied.
Costs are recovered through a minimum cnarge for residan-tial rates which do not state 0; mand charges.
In rate chedul s,;ith both energy and de.aand charges, rates are develoced so tha' the small custcmer's charges are stated separately.
The costs are incorpor :ed into the demand and energy charges fcr larger custcmcrs.
The demand costs are usually spread uniformly across the energy blocks in nates where there is no stated demand charge.
Ccmand costs are recoverec by a demand charge where secarate energy and demand rates are prcvided.
Energy costs are designed to be recovered throuch base rates in the form of separate energy charges.
An energy adjustment clause provides for changes in energy costs tnat are' related to fuel costs.
The apolicant provides residential customers with several experimental time-of-day rates on an optional basis.
This serves as part of the applicant's load management progran through which the acclicant is seeking more informa 1cn on wnether to extend time pricing techniques and seasonal differential pricing.
Other expericents include peak load pricing in conjunction with Federal Energy Administratica and State of New Jersey to ascertain the demand price relationship for peak load pricing in residantial power consumption.
The applicant has not conducted any clasticity studies that vould determine the impact of recent rate increases on the demand for electricity and has cited icw industrial activity and high unemploy-ment folicwing the oil embargo for the general dampened growth.
In addition to price and conservation, the demand for electricity is impacted by such other factors as (1) changes in the regicnal ano national economy; (2) the substituticn of electricity for scarce fueis, (3) growth in population and housenolds', (4) tcchnological change a ffecting suostitute sources of energy, ef ficienc/ in thn use c
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.4 of energy resources, and the development of new uses of electrical energy; (5) market forces af fecting the demand for consumer invest-ment or durable goods which recuire electricity to operate; and (6) challges in consumer values, attitudes and such practices as may be affected by laws, regulations or taxes.
In the face of such a com-plexity of causal forces it is exceedingly difficult to factor out the extent to which price changes alone aould affect the demand for electricity in the apolicant's service area.
The uncertainty exists in analyzing historical data and is even greater in forecasting future develosments because of the perturbations of outTook fostered by the energy crisis and decisions yet to be made by customers and industrial and government
'encies in relatio: to reducing dema, J for scarce fuels or develcoing additional reserves or new sources of energy to substitute for scarce fuels.
Load shedding is an emergency measure to prevent system collaose when peak demand placed upon the system is greater than the system is capabla of providing.
This measure is usually not taken until all other measures are exhausted.
The Federal Power Commission's report on the :2jor load shecoing that occurred during the Northeas: Power Failure of November 9 and 10, 1965, indicates that reliability of service of the electrical distribution systems should be given more emphasis, even at the expense of additional costs.
This report identified several areas that are highly imhacted by loss of power, such as e. levators, traffic lihhts, subway lighting, prison and corrunication facilities.
It's the serious impact on arecs such as these that result in load shedding as only a temporary methoc to overcome a shortage of generating cacacity during an emergency.
Load staggering has also been considered by the staff as a possible conservation measure.
Basically this alternative involves shi f ting the work hours of industrial or c::mmercial firms to avoid diurnal or wee % Jay peaks.
However, the staff considers the interference with customer and worker preferences as well as productivity to be of significant imp 3ct to make such proposals of questionable feasibility.
For interruptible load contracts ta be effective in system planning, the load reduction must be large enough to be effective in system stability planning.
Thus, this type contract is pri 3rily related to industrial custoners. At the present time the applicant has two customers under contracts classified as curtailable service.
The contracts are equal to 2a.3 megawatts and have been included in she applicant's ferecasts.
The acceptability of interruptible icid con-tracts to industrial custcmers depends upon balancing the potential economic loss resulting frca unannounc2d interruptions againtt the 3,s,.ad a
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.6-savings resulting from the reduced price of electricity.
If the frequency or duration of interruptions increase as a result of insufficient installed capacity, the custcmcrs will convert to a nonaal industrial load contract.
e I!6ne of the above measures can be considered as a viable alternative for required additional capacity and does little to solve the energy shortage.
2.
Mcreased Suscuehanna niver Water Tcmcerature The discussion below of the water quality criteria applicable to the Susquehanna River in the vicinity of tne site as established by the Ccm-monweal th of Pennsylvania is taken frcm Sect'on 5.3.3 of the FSFES.
The NRC Staff's recent assessnent of the environmental impact based upon the aater quality criteria established by the Ccmmonwealth of Pennsylvania in its revised 401 certification for Three '4ile Island, Unit 2, issued November 9,1977 (Attacned as Appendix A) is attached as Appendix B.
The Commonwealth of Pennsylvania has established water quality criteria applicable to Suscuehanna River in the vicinit; of the site to protect the water uses which were tabulated in Section 2.2.2.
The applicable criteria are listed below (Pennsylvania Code, Title 25, Part I, Environmental Resources, Chapter 93, Water Quality Criteria):
S 93.4 General water quality criteria.
(a ) 'fater shall not contain substances attributable to municipal, industrial or other waste dischargas in concentration or amounts sufficient to be inimical or harmful to the water uses to be protected or to human, animal, plant or aquatic life.
(b)
Specific substances to be controlled shall include, but shall not be limited to ficating debris, oil, scum and other floating materials, toxic substances and substances which produce color, tastes, odors or settle to form sludge deposits.
5 93.5 Specific water quality criteria.
pH - Not less than 6.0 and not more than 3.5.
Dissolved oxygen - Minimum daily average 5.0 mg/l, no value less than 4.0 mg/1.
- For the epilimnion of lakes, ponds, and imcoundacnts,
minin':m daily average of 5.0 mg/l, no value less than 4.0 mg/1.
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Iron - Total iron not more than 1.5 mg/1.
Tcaperature - l ot more than a 5'F rise above ambient temperature of a maximum of 87', whichever is less', not to be changed by more than 2 F during any one-hour period.
Dissolved Solids - flot more than 500 mg/l as a monthly average value; not more than 750 mg/l at any time.
Bacteria - The focal coliform density in five consecutive samples shall not exceed a geometric mean of 200 per 100 al.
Total !!anaganese - l lot more than 1.0 mg/1.
Pennsylvania Industrial Regulations (Pennsylvania Code, Title 25, Envirormental Resources, Part I, Article 2, Chapter 97, Industrial Wastcs) place the following additional restricticns on the addition of Wa;te heat:
5 97.82 Allowable Discharges (a) The heat content of discharges shall be limited to an amount which could not raise the tem erature of the entire stream at the point of discharge 5 F above ambient temperature or a maximum of 37'F, wFichever is less, nor change the temr.erature by mure than 2 F during any one-hour period, assuming complete mixing, but the heat coritent of discharges may be~ increased. cr further limited.there local conditions ~ would be benefited thereby.
(b)
If downstream circumstances warrant, the soecific area in which the temperature may be artificially raised above 87'F or greater than 5 F above ambient temperature or by more than 2'F during any one-hour period shall be prescribei.
Since ambient temperature may exceed 37 F occasionally, paragraph (b) abc ce may require the prescription of the area in unich temperature r"y be einvatM further.
Pursuant to tne Federal Water Pollution Control Act (FWpCA), on A nuary 1975 Penmylvania has issued a a01 certification indicating that 1-evaluation these water quality criteria will not be violsted by :
plant operation.
In accordance with terms of the Second 51enorandu.
Understanding Regarding Imolementation of Certain !!RC and CPA Respc ties, the staff has accepted Pennsylvania's determination.
The F'.!PCA calls for achievement by July 1,1977, nf ef fluent limitations requiring th: aoplication of the best practicaole control technology currensly available.
By Ju l '/ 1,1933, the act calls for the achievement of ef fluent limitations requiring application of the best availaale technoicoy ecoma-ically achievable.
The effluent limitations for these "technolom es" are f.'
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defined in Title 40 CFR Part 123 - Ste:m Electric Power Generating Point Scurce Category.
The only dif ference in the tuo technolagies applicable to nuclear stations is the requirement for closed cycle cooling hy the later date.
Since TMINS will operate on closed cycle cooling, the 1983 requirement regarding thermal discharge can be met.
The requirements for the 1933 deadline are reproduced in Table 5.2.
Si FUPCA (Section 302) also requires that any other limitations be placed on the operation of the facility which are necessary to protect and propagate a balanced indigenous population and to protect other users.
Again, in accordance with '.he Secand Memorancum of Understanding, the issuarce by the State of Pennsylvania on December 30, 1974 of a permit.under Section 402 of the NPDE3 is accepted as a determination that the requirement for effluent limitations will be met.
The effluent limitations imposed by the NPDES include a value for free available chlorine but do not include a value for total residual chlorine (see Table 5.2). The toxicity of combined forms of chlorine has been recognized and limitations have been recsmmended for total residual (Water Quality Criteria,1972. A report of the Committee on Water Quality Criteria, National Academy of Sciences, National Academy of Engineering, Washington, DC,1972).
The recommendec limitation for total residual chlorine, applica-ble to receiving water rather than to the effluent, is as folicws:
"Acuatic life should be protected where tne concentration of residual chlorine in the receiving system does not exceed 0.003 mg/l at any time or place.
Aquatic organisms will tol'erate short term exposure to high levels bf chlorine. Until.mcre is kaozn about the short term effects. i t is reccm-mended that total ' residual chlorine should not exceed 0.05 mg/l for a period up to 30 minutes in any 24-hour period."
Based on experience with Unit 1 (see Section 3.3.2) a free chlorine concen-tration of 0.5 mg/l as allowed by the permit might corresscnd to a total chlorine residual as high as 1.5 mg/1.
Hcwever, it was noted tl at experience with Unit 1 has shown the actual total residual to exceed a concentration of 0.2 mg/l only rarely.
Diluticn with river flow and further chemical reduction of chlorine residuals will reduce the concentrations produced at Unit 2 below the recommended value of 0.05 mg/l within a short distance of the outfall.
The applicant has not been totally successful at meeting the objecti'.e of controlling biological growth within plant systems and is likely to change the chlorination program (see Section 3.3.2).
Therefore, staff rec mmended that monitoring of total residual chlorine in the plant discharge be perfonced until the concentrations required for optimal chlorination can be established and evaluated.
If it is necessary to operate at the per-mitted level of chlorinatirn, then the applicant should monitor totai residuals in the river to determine the extent of the region in drich concentration exceeds the value reccmmended to protect acuatic life, a.c q.
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This is prcuably tecause cmbient concentration; only rarely approach this level. As developnent of the river for stea.:. electric power production and other uses continues, it is likely tFat additional consideration will be given to the discnarge of sulfate.
Sayed on average river conditions. statinn operation will increase sul fate concentration by less than 0.4 mg/l.
For the conditions which prevailed Sehen the highest am :ient sulfate concentration was reported (2C;.3 ag/1, see Section 2.4.3),
operation could have increased sul fa'e concentration by as much as 3.3 ng/1.
These increases should not have a ncticeable effect on downstream users under present conditions.
Other proposed uses of chemicals will hava an insignificant effect on water quality.
3.
Credibility and U e c# Rasmesson Recnrt As stated in Section 11.1.7.1 of the FSFES, the staff's overall assessment of the Reactor Safety Study is *. hat it provides an objective and meaningful estimate of the probable risks associated with the aceration of present-d2y light-wat 2r nualear power plants in t:
U.S.
The staff believes the :tucy's a
methodol.gy as it applies to the calculation of both accident probabilities and cor,equences has received a broad and incre: sing endortenent by the infoc.ed scientific community.
It should be notad that the stud;. aas refererced as a source of data and did not by itself form the basis for the
. sta f f's eyalaation of the' concequence: of postulated accident, in the Draft Supolemen'. to the Final Envircrmental Statement or the Safety
~.
Evaluation Report.
4.
Decommissioning As discussed in Section 9.6 of the FSFES, the staff's position regarding decommissioning of the Three Mile Island Mucle;r Station, 'Jnit No. 2, is as follows :
In the long-term, beyond the useful life of the proposed generatirr station, this site may continue to be used for generation of electrical energy. At the termination of such use, the land areas occuoied by the nuclear facilities would be removed from productive use, unles: de-com.missioning measures included removal of all radioactiva ecuirmert are adopted. Although the detail; of doccanissioning m3y not be.orked out for several years, the varicus al ternatives shouid r.ot be diminished by the proposed action of licensing operation.
The range c f benef 4cial uses of the site by future generations will not be curtailed, provi_ed the applicant has the cacability for removing all radioactively con-taminated equipment if and wnen that step nay be desirable.
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A /%/ ) // hy ?)g'\\ 9,,,, y , NRC. regulations prescribe procedures whereby a license may volueitarily surrbnder a license and obtain authority to dismantle a facility and dispose of its component parts. Such authorizatica would normally be sought near the end of t ne nuclear plant's useful life. In any event, the Commission requires that a qualified licensee maintain valid licenses appropriate to the type of facility and materials involved. Under current regulations, the Commission gercrally requires that all quantities of sourne, special nuclear, and by-product materials not exempt frca licensing under Parts 30, 40 an 70 of Title 10, Code of Federal Regulations, either be removed icom the site or secured and kept undcc strveillance. To date, experience has been gained w4 th decommissioning of six nuclear electric generating stations which are operated as part of the At:mic Energy Cormission's scwer reactor develosment program: Hallam Nuclear Power Facility, Piqua Nuclear Power Facility, Soiling Nuclear Superneat Power Station, Elk River Reactor, Carolinas-Virginia Tube Reactor, and Pathfinder Atomic Power Plant. The last two facilities were licensed under 10 CFR Part 50; the others were Atomic Energy Ccmaission-cwnea and operated under the provisions of the Part 115. ~ Several alternative modes of decommissioning have been experienced in ~ those cases. They may be summarized generally as four alternative levels of restoration of the plant site, each with a distinct level of effort and cost. In decommissioning at any level, econ:mically salvageable equipment and all reactor fuel elements would be removed, some equipment would be decontaminated, and wastes of the type normally shipped during ocera-tion would be sant to waste repositories. In addition, the respective levels of restoration would involve the folicwing measures-Lowest level, fhere would be minimal dismantling and relocation of equipment. All radica;tive material would be sealed in containment structures (primarily existing enes), which would require perpetual, continual surveillance for security and effectiveness. Second level. Some radioactive equipment and materials would be moved into existing containment structures to reduce the extent of long-term contamination. Surveillance as in the lowest level wo:id be required. Third level. Radioactive equipment and materials would be placed in a containment facility approaching a practically minimum volume. All unbound contamination wculd have beep removed. The contair. ment struc-ture would be designed to need minimdl perpetual maintenance, surycillance, and security. Tooict Hinhest level. All radioactive equipment and materials wevid be re-moved troa :ne site. Structures would be dismantled and a ;;:osed o f onsite by ::urial or offsite to the extent desired by the tenant. No furfgte Ccmmission license would be required. Estimated costs of decommissioning at the lowest level are about $1 million plus an annual maintanance charge on the order of $100,000. Comple'.c restoration, including regrading, has been estimated to cost $70 million. Hence, there is wide variation, arising frca differing assumptions as to level of restoration. At present land values, it is not likely that censider. tion of an ecoremic balance alone would justify a high level of restoration. Planning required of the apoli-cant at this stage will assure, hcuever, that variety of choice for restoration is maintained until the end of useful plant life. Units 1 and 2 of the Three Mile Island Nuclear Station are designed to operate for about 30 years, and the end of their useful life will be approximately in the year 2008. The apolicant has made no firm plans for decommissioning but asstmes that tre following steos would be taken as minirum precautions for maintaining a safe condition. .1. All fue.1 would be removed from the facility and shipped offsite for disposi tion.. 2. All radioactive wastes - solid, liquid, and gas - would be packaged and removed from the site insofar as practical. 3 A decision a; to whether the facility would be further dismantled would require an econcaic study involving the value of the land and scrap value versus the cost of ccmplete demolition and removal of the complex. However, no additional work would be done unless it is in accordance with rules and regulations in effect at the time. In addition to personnel required to guard and secure the facility, concrete and steel would be used to prevent ingress into any building, particularly the radioactive areas. The applicant's position as stated in Section 11.1.9.1 is: "Since we do not anticipate having to deccmmission TMI-2 until the ye3r 2010, it is difficult to fcrecast regulatory requiremnts which may be imposed cit that time. There will be many changes in technciog;. and social conccens between 1975 and 2010 ahich will influer:e plans ror deccmmissioning. The Applicant is convinced that when the time cores to decommission TMI-2, tnis accivity will be accomplished ~ n3 socially, environenntally, and econcmically acce:: table mnne,r consiste,t w1:n the regulatory requirements in effect at that tim." $e]'DC2 eee $ 1. Title 10, " Atomic Energy," Code of r deral Regulations, Part 50, e ,Licensino of Production and litiliza tion Facili ties, Section 50.32, " Applications for Terminations of Licenses.' 2.d Atomic Energy Clearing House, Congressional Information Bureau, Inc., Washington,CC,17(6): 42, 17 (10 ) : 4, 17 (l a ) : 7, 16 ( 35 ) : 12. Financial aspects of decommissioning are discussed in Section 20 of Supplement No.1 to the SER, pertinent parts of which are quoted below. "In estimating the costs of permanently shutting doven the facility, the applicant considered three alt rnatives: dismantling, entomb-ment, and mothball ng. Dismantling the unit, which involses removing all fuel asstablies, radioactive fluids and waste, and other materials having radioactive activities above unrestricted activity levels [and apparently dismantling the _t.ur,bine building and miscellaneous equipment], is es ' mate.1 to cost apcroximately $117 million. Expenditures fer entuament are projected to be 5 5 nillion initially, with an annual surveillance expense of $63,000 thereafter. Entembment consists of sealing all remaining highly radioactive ca.1ponen s within a biologically secure structure after having remover all fuel assemblies and radicactive fluids and waste. The estimated expense of putting the facility in a state of protectivr: storage, or mothballing the unit, is $5.3 .millien, wi.th an e dditi.cnal expendi ture c f $200.000 annually for. radiation monitoring, environmental surveillance, and appropriate security procedu'es. All deccmmissioning costs are stated in.'975 dellars. " Metropolitan ~.dison, Jarsey Central, and Pennsylvania Electric expect to covar all operating ex;enses, including taxes, and interest pap ents through revenues generated from their systen-wide sales of electricity. The owners have consistently exhibi ted the ability :o cover all coerating expenses as evidenced by the revenue to expense ratio presented in Table 20.3. The.ta f f assumes that shutdown and subsequent maintenance casts vill either be expensed in the year incurred or amortized over a pe" icd of years, depending on the rate-making policy of the regul. tory authorities. "In accordance with the regulations cited in the Safet.s Evaluation Report, there must be reasonable assurance that the culers can obtain the necessary funcs to cover the estimated costs of the activities contemplated under thc licenre. Msed on our analysis, we have concluded that Metropolitan Edison Comcany, Jersey Central Power and Light Ccmpany, and Pennsylvania Electric Ccmpany sa tisfy this reasonable assuranca standard and, therefore are financially qualified to opera:e and, if necessary, shut dcun and safeiy main-tain Three Mile Island Nuclear Statica Unit C. Our conclusion is 43~003 w kh ~ 13 - supported by the following factors as discussed above: (1) the ability to earn revenues sufficient to cover all operating er.penses, including interest pay.nents and taxes; and (2) the projected cutput of lower unit cost electricity from this facility, as conpared with the utilities present average price of p]ectricity." 5. Transnartation of Wastes The environmental effects of the transnortation of radioactive waste material are shown in Table 5.8 and discussed in Section 5.4.1.2 of the FSFES. Transrortation of Radioictive "aterial The transportation of cold fuel to a reactor, of irradiated fuel.from the reactor to a fuel recrocessing plant, and of solid radioactive wastes from the reactor to burial grounds is within the scope of the NRC report entitled, " Environmental Survey of Transportatio.; of Radioactive Materials to and fran Nuclear Power Piants." The environmental effects of such transportation are sumnarincd in Table 5.8. TABLE 5.8 ENVIRONMENTAL IMPACT OF TPANSPORTATION OF FUEL AND WASTE TO 4 AND FRCM ONE LICHT-WATER-CCCLED NUCLEAR FC'.lER REACTOR Normal conditio' ,f transpo.rt Heat (per irradiated fuel cask in transit) 250,000 Stu/hr Weight (governed by Federal or State restrictions) 73,000 lbs. per truck, ICC to. per cask per rail car Traf fic density <1 per day Rail <3 oer month Exposed population Estinated Range of doses Cumulative dose to number oi to exposed exposed populatisn persons individuals (man-rems per reactor yr)~ (millirems per reactor yr) Transportation Worker 200 0.01 to 300 4 General Public Onicokers 1,100 0.003 to 1.3 Along Route 600,000 0.0001 to 0.05 3 Accidents in transport d Radio!acical effects Smali Cc.;non (non,adiological) causes 1 fatal injury in 100 reactor yearc; I nonfate.i injury in 10 reac:or,, ears, $457 pcarct:ty damage per reactor year 43~004 Data suoporting this table are given in the Commission's Environmental a Surv_y of Transportation of Radioacti ce Materials to and frcm Nuclear ower Plants, UA5H-1233, Deccaber 1972, and Supp. I, NUREG 75/033, April 1975. bThe federal Radiation Council has recommended that the radiation doses frob'all sources of radiation other than natural background and medical exposures should be limited to 5,000 millirems / year for individuals as a result of occupational exposure and should be limited to 500 millicems/ year for individuals in the ceneral population. The dose to individuals due to average natural background radiation is about 102 millirems / year. Man-rem is an expression for the summation of whole-body doses to c individuals in a group. Thus, if each member of a population group of 1,000 penole were to receive a dose of 0,001 rem (1 nillirem), or i f 2 people wer e to receive a dose of 0.5 rem (500 millircms) each, the total man-rem in each case would be 1 man-rem. dAlthough the environmental risk of radiological e#fects stemming frca transportation accidents is currently incapable of being numerically quantified, the risk remains small regardless of whether it is being applied to a single reactor or a multi-reactor site. Transportation accidents involving radioactive materials are covered in .Section 7.3 as follows: TRfqPyTATfCNACFIDENTSINVCLVINGRADICACTIVE.FATERIALS The transportation of cold fuel to the plant, of irradiated fuel from the r react to a fuel reprocessing plant, and solid radicactive wastes frca the reactor to burial grounds is within the sccpe of the GRC repor; entitled, " Environmental Survey of Transportation of Radioactive Materials to and from Nuclear Power Plants," December 1972. Tha environmental risks of accidents in transportation are summarized in Table 7.3. Ta bl e 7.3. Environmental Risks of Accidents in Transport of Fuel and Ulste to and frca a Typical Light-Water-Cooled Nuclear Pcwer Reactor tavironmental Risk 5 all* Radiological effects Common (nonradiological) causes 1 fatal injary in 100 jears 1 nonfatal injury in 10 jea $475 property damage r.er ye of radiological ef fects stcmming frca trans cetat
- Although the environmental risk a:cidents is currently incapable of ceing nunerically cuantified, the risk ;o73in muiti-sa.;ll regardless of whether it is being app'ied to a single reactor cr a reactor site, d3 MS e
. 6. Uranium Costs, Uranium ' 'abili+". and +he Nuclear ruel Cycle Section 9',5.3 of the FSFES
- atains a discussion of these issues.
Further discussions of the environmental effects of the uranium fuel cycle is found in Section 5.4.3 and additional discussion of the environmental costs of the uranium fuel cycle is found in Section 10.6. These are lengthy discussions and, therefore, not repeated here. Copies of the FSFES are available at $9.75 for printed copies and $3.C3 for microfiche from the Naticnal Technical Information Service, Springfied, Virginia 22161. 7. Low Level 0.adiation Section 5.4 of the FSFES contains a discussion on radiological impacts. Again, this is a lengthy discussion and will not be repeated here. 8. Power Se_n_t_', Other Areas _ The following discussion of the applicant's service area and regional relationships is found in Section S.2 of the F3FES. Acolicant's Service Area The General Public Utilities Corporation' with the subsidiaries of the ~ f Metropclitian Edison Cencany, the Pennsylvania Electric Company, and the Jersey Central Pcwer and Light Company supplies electricity to an area of about 24,000 square miles in parts of Pennsylvania, and New Jersey with a population of about 4,0C0,0C0 (see Figure 8.1). Metrocolitan Edison Ccmpany operates in an area of 3,274 square mil 7s in eaotern Pennsylvania. Pennsylvania Electric Company supplies an ar.;a of l',600 square miles in western, northern, and south central Pennsylvania with Jersey Central Power and Light Company cperating in an area of 3,255 square miles in north central, east central, northwestern and western New ,ersey. Recional Relatinnshios The General Public Utilities (GPU) system service area is included in the Federal Pcwer Commission (FPC) Martheast Pcwer Surve; Regica and located within the FPC's power sucaly area, PSA5. The GPU system is a member of the Pennsylvania-Mew Jersey-Maryland Interconnections (PJM) which is a formii pcwer pool that serves three-quarters of Pennsylvania, most of New Jerscy, more than half of "aryland, a small part of Virginia ar.d all of the 'istrict of Columbia, and Delaware. In addition to coordination of planning, the C;00s companies in PJM conduct econenic dispatch within the pool and share in any load curtailment or voltage reduction if conditions warrant it. r1 The appli ant is a member of the Mid-Atlantic Area Coordination Council (MAAC). The companies which ccmpose DJ:1 are also included in the membership o f MAlsC. IfAAC is concerned primarily with reviewing and evaluating plans from the standpoint of bulk power reliability. 9. Alternative Enerny Sources Section 9.2 of the FSFES and Section XI.A.2 of the Final Environmental Statement (FES) dated Decc=ber 1972 discuss alternative energy sources. ALTER"ATIVE ENERGY SCUPCES AMD SITES In the following section from the FES of December 1972, the staff evaluated the alternative energy sources and sites. Al ternative energy sources considered wcre h drcelectric potential, fossil-fired generating clants, 3 including oil, natural gas and coal-fired plants, and the purchase of pcuer frc. otne.' companies. The applicant's site selection was also evaluated. There have been no major changes in the information relied upon by the staff for the previous evaluations that aould materially alter the consideration of alternative energy sources and alternative sites at the operating license revicw stage. No feasible alternative energy source, recuiring capi tal investment as aeli as ocerating and fuel cost is econcaically competitive with TMINS-2. XI. -AtTER"AT'VE: TO THE PROPOSED SCTIO" AND COST rc':EFIT ANALYSIS OF THEIR ~T!IRG'." ENTAL IF'ECTS The Applicants have provided a discussion of alternatives and a cost benefit analysis in their Environmental Report. In many cases the staff found the Applicants' estimates adequate and these were used in the discussion. In other cases the estimates were made indepcndently. A.
SUMMARY
nr ALTSNATIVES 1.
Aba rH,nment o f The Pro iect Abandonment of the project is an alternative to be ccnsidered in evaluating the impact of both clant construction and subse;uent plant operation.
In the case of Three Mile Island Station we have concluded that abandonment of the project is not a practicable alternative for the following reasons:
Construction of the Station has progressed to the point uhere envrionmental impact associa ted wi th.his phat e lo s already bcen absorbed.
43 007
~
@ The identifiable environmental costs of plant operation are insignificant when compared with the unsalvageable cost of r9
$350 million involved in abandonment (see 3.1. below).
2.
Al terna tive Pouar Sourc_e_s_
a.
Purchase of Power The Applicants state that there was and is no possibility of a power purchase in an amount equivalent to the capacity and energy of the TMI project.
The staff notes that while PCM pool reserves appear substantial (Table 22), such pool reserves do not generally include provisions for long term f4 " cower transactions.
In addition, projected PCM reserves ar _ JnCCrtain, beCause of the possibility to delay in new generating capacity now under construction.
The uncertainties of maintaining construction schedules and the steady e.cten-sion of demand on this arel make dependence on this enernai baseload power source highiy cuestionable.
Ir. addition, the Applicants state that no nearb, public or private utilities outside of the PCM pool have large amounts of power for sale on a long term continuing basis.
I b.
Alternatiye keth6ds of Gene ~r.atih' Power Coal Fired. Base load Genoration Economic studie.e performed by the Applicants ig 1965 indicated that mine mouth coal fired generation in western Pennsylvania provided short term economic advantages over an ecuivalent nuclear unit located in the eastern portion of the state.
Basad on these studies a decision u.> made to proceed eith cor.ctruction of the Homer City unit, a coal-fired mine month gencrating plant 5 western Pennsylunia.
In 1966 the Applicants re-examined the econcaics of additiona' nuclear generation but this time in ccmcarision with a coal-fired uni: at the sane site as would br selected for the nuclear unit.
The Applicants state that there were tv:a reasons for this shift in the basis of ccmparison:
(1 ) The particularly attractive conditions applicable to the Homer City plant were no longer available as an alternative, and (2)
Coal suppliers had suggested that fuel might be delivered to the GN site for 20 cents per million Stu,, aIthot.gh this was not a firm of fet of such a supply.
43-(Jeg Even the basis of this low delivered fuel price, a nuclear unit installation wcs found to be advantegeous.
In November 1966, the decision was made to prucced with a nuclear installation for service in 1971, in Deccaber 1966, the Thi s.ite was selected for this installation.
r';
A comparison of a coal-fired plant with the Three Mile Island Nuclear Plant is given in part B of this section.
Oil-Fired. Base load Generatinn The Applicants did not consider this alternative in the 1965-66 economic studies, because of the relatively high cost of oil fuel as compared to coal delivered in the area for which the unit was then planned.
A comparison of an oil burnin: plant with the Three Mile Island "uclear Plant is given in part B of tr.is secticn.
Hydroelectric Generation Ti.e geography and flow the Su:quehanna River are such that is is impossible to find the ccmbination of head and water quantity that can produce the capacity and energy equivalent of TMI.
Gas-Fired Generni a The Applicants. stat,e and the staff agrees that this fuel ca; be dismissed from further consideration, since gas fuel is not available for' boiler use within the ccmpany's service territory.
Thermal'Peakinn Cacacity The Applicants state that peaking capacity is not considered as an alterna-tive because of the high cost and inefficient use of fuel, if such units are used for long hours of generation, comparable to those expected of a nuclear plant.
Combustion turbines, ccmbined cycle units and oil-fired cycling units are intended for a different type of rarvice and GPU is planning on a long-term basis for limited use of such capacity to provide for a baicnced development of its system. Currently, however, very large combustion turbine installations are being mace because of delays in installations of other capacity.
The environmental cost of such peaking units are quite similar to thost for an oil-fired base load unit.
The staff concurs with this evaluation and notes that is is etrential to add to base load generating capacity at the present time if the applicant is to be capable of meeting its projected loads.
43 009
Other Sources The production of energy by MHD, solar heat, fuel cells, wind power or tidal pouer must be dismissed as not feasible in the time period and in the area tha t will be served by TMI.
Pumped storage is not a viable alternative since such facilities are net consumers of electrical energy.
- 10. Cost Banefit There is a complete and lengthy Benefit-Cost Analysis found in Section 10 of the FSFES and Section XI.B of the FES.
11.
Routine Samoling Chapter 6 of the FSFES covers the environmental mcnitoring programs for the proposed Three Mile Island Nuclear Station, Unit No. 2.
Since it is quite a lengthy chapter, it is not being repeated here.
12.
Price-Anderson Act The Price-Anderson Act is discussed in Section 11.1.8.3 of the FSFES as follous:
The comment discusses Subsection 17Cb. cf the Atomic Enerhy Act of 1954, as amended.
This subsection along with other'subse'ctions of Section 170, the Price-Anderson Act, was modified by Fublic Law 94-197, enacted into law on Decemcer 31, 1975.
This. legislation, which extends the present Price-Anderson lesiglation for ten years to Augusc 1,1987 provid;s, among other things, for the phasing cut of Government ind:mnity through a mechanism whereby the utility industry aculd collectively share in the risk of damages from a nuclear incident exceeding the basic amount of private insurance available through the payment of a retrospective premium to the insurance pools.
The Commission must establish, before December 31, 1976, a retrospective Ca premium figure of between 52 million and $5 million per reactor.
Septcmber 20, 1976 the Commission published in the Federal Register (al (41 F.R. 40512) a notice of proposed rule making which would, among other things, establish this premium figure at 55 million per reactor.
retrospective occmium of $5 million per reactor per incident..ould Th e be paid in the event of a nuclear incident resulting in damages exceeding This the amount of the current 5125 million primary i.aurance layer.
premium was not meant to replace the indemnity fee of 530 a thermal megawatt paid by reretv operators.
The premium.:as established to There is also prcvi:, ion, phase out Government indemnity by the -id-1930s.
however, in P.L. 94-1g7 uhich authoriaes the Ccmmission to reduca th" annual indemnity fee as the financial protection in er increases aJ Gover'.acnt indemnity is reduced.
43~010
20 -
i l
"one-time fee," there is a in the notice of pro;,osed rule While the retrospective premium is not. a h t can be assessed in any oned in the not maximum amount proposed by Commission making of $10 million per reactor t a This figure was chosen, as explaine12), not so muc lendar year, an occurrence proposed, ale naking (41 F.R. 405a second nuc ar.
cal'endar which we feel is extremely remote, arising from a n rlier year.
t,
}
Accidental Rel eas_e_s_
l impact of postalated accidents is i
13.
i A lengthy discussion of the environmenta found in Section 7.2 of the FSFta.
s routine releases irca th2 In adcition, Section 11 of the SER addressees due to l
plant, ac.d Section 15 discusses re easThe probability of occurrence to be postulated.is considered sufficiently low that they n Auxiliary Control Rcom Desian 4 2 of the Sa fety Evaluaticn Report, 14.
This subject is addressed in Section 7..
ovided cutside of the main
.as folicws:
These con-Essential instrumentation and controls are pr ing a shutdoiin condition.
in a het to achi<me and maintain the uni i
control room for the purpose of ach ev 3
trols and instruments are adequateshutdown cond ab
'Je hav e con-ppropriate operator actions.licable crit ten supplemented by a cluded that this design meets the appof the NRC staff to the Licensing condition t f !tems Addressed in *:URE Mr. Silver's testimony entitled "ResponsaIssue ddressed this Board Question about the Applicability o
-0153 to thi s Plant,"
subject and is reproduced below.
Issue No. 11 Interpretation of GDC 19 " Control Rnom in Abstract nf Staff position t which both damages ecuipment t
erator to shut down the reacta A serious accident resulting frcm an even bability as to be of negligible the control rcom and forces the opside the cont 43:011
_ 21 _
risk.
The probability is considered low because the control room is required to be manned at al' times and to remain habitable under haaardous conditions,
the equipment in the control room is redundant, the reactor is protected by automatic systems, the other means of safely shutting dcan the reactor are available.
Desian of Three Milo Islard Unit 2 The control room is designed to remain habitable under hazardous conditions, and the equi cmen'
'he control room is redundant.
The reactor is protected by B&M automatic arotective systems.
The plant includes provisions to shut down and maintain J e reactor in a safe hot condition after shutdown if dCcess to the Controi room is denied.
Subsequently, the Olant.Can be brCught to a cold shutdown condition from outside the control room.
- 15. Haste Ciscosal Aspects of this concern have been addressed in Section 5.4.3 of the FSFES and in the testimony of Dr. Gotchy in this proceeding following Tr 2091.
16.
Emergency Pl ans The. applicants' Radiological Eoergency Plan (FSAR Accendix 13A), Section 13.3
. of the SER, and a considerable. amount of testimony at the i', caring addressed most as. pacts of emergency planning in question.
Section 11 of the SER and the prepared testimony on Issue 2P of the "MUREG issues" discuss radiation monitoring.
(following Tr 1322) 17.
ECCS' Tes tinc Early tests in the so-called semi-scale facility (really 1/200 scale) did produce some ancmolous results, but these.cere fully explainable by test peculiarities.
Results did not indicate any need to modify ECCS models.
A larger (1/5) scale program, designated LCFT, is well underway.
The fif th non-nuclear test in this series was run in May, 1977.
il valid tests thus far have 1dicated that the ECCS systems perform as inte-ad.
Based on these resu ts, it is expected that the nuclear test series, planned c start i n 1 '78, '.o.1 essentially confirm present models and permit verification of pred:_winn rc'hniques used in reactor safety analysis.
18.
Fire Drotection Our original review of the plant's iire protection syste:, was reported in Section 9.5 of the SER. As noted in Item (5) of Section 13 of Sunplement No. I to the SER, we issued to th.e applicant in la te 1976 our updated recui, e-ments on fire protection, and requested performance of a fire haaards analysis 43~012
and a re-evaluation of the fire protection system in accordance with these requirements. This information was furnished to "RC in Jur.e,1977 He will review this information and identify any required changes 3s exneditiously as possible. We expect to complete the review prior to f he scheduled fuel loading, and we will of course require that a'i necessary nodifications and procedural and administrative changes be made as early as teasible to improve the capability of the fire protection system.
- 19. Security Since the time of the alleged events noted in Jor.as' questions, adherer.c3 to existing security procedures at Three !!ile Island has bc en demonstra ted and is considered acceptable.
In addition, we have repaire<1 this plant ind all others to conform to the requirements -f 10 CFR 73.55, which sets forth the requirements for physical protection of licensec activities in nuclear :c ;ar reactors agciost industrial sabotage.
With regard to the April 7, 1977 GAO report on security, since that report is a public document the specific plants visited have not becn identified for obvious security reasons.
- 20. Assurance of Adherence to NRC Reculations The NRC performs many functions by many different orgIni;$tions to assure f
that the, applicant conforms with NRC regulations.
In trief and partial summary these include:
1.
A thorough review of the design of the plant to assure consistency with NRC criteria.
2.
A review of the qualifications of the applicant and his major sub-contractors to help assure their Capability to perform their function.
3.
A complete review of the Quality Assurance program of the applicant and his principal contractors.
4.
Field inspections by trained NRC personnel to:
a.
review the applicant's QA performance, b.
review anu witness construccion practices and inspect the facility.
c.
review the qualificatians and training of OA and construction personnel.
43:013
V
~ d.
review construction and preoperational test and opera ting procedures, witness appropriate tests, nd review test records.
- 5. p' Continued monitoring by NRC personnel throughout the life of the plant.
The crux of the concern here should not focus entirely on complete conformance with the regulations, but in addition onplant safety-The approach fellowed in plant licensing consists essentially of conservative design to avoid accidents, cnd provision of conservatively designed redundant systcms to mitigate the consequences of an accident if for some reason one faes occur.
It is felt that this approach to safety coup 1 =d with the review functions briefly described above will assure the health and safety of the public.
21. Radiation Effec'.s on Emolayen Although employee exposure rect.'ds are maintained, there is no regulatory requirement to maintain employee family health records.
ERDA is funding a study at the University of Pittsburgh (the Mancuso Sttdy) to determine family health histories for present and former employees at Hanford and Cak Ridge.
MRC Office of Inspection and Enforcement will assure that cualifications of maintenance workers are in accordance with Code ~and Cuality Assurance program requ i remen ts.
10 CFR part's 19 and 20 cover instructions and standards for protection against radiati~on.
~
Information in regulations, studies, etc., on allowable employee coses and justification therefore is available to the general public although tnere is no regulatory requirement to notify the General public specifically of these matters.
There is no regulatory requirement to inform the general oublic as to possible increased genetic risk to offspring of plant employees.
Reports of past family and social di:ruptions allegedly due to contamination of an employee are available to the public, but there is no regulatory requirement to notify the general public of these matters.
43~014
O e
t.
APPENDIX A f
43:015
MRC STI.rT'S ASSESSMEN P OF REVISED 101 C E RTIFI C.\\TIO.'!
Introduction o
On No%mber 9,1977, the Commonwealth of Pennsylvania revised the 401 Certification previous 1f ssued on June 22, 1977 for the Tht ce Mile Island i
Nuclear Station, Unit 2 (copy attached). The revised sections. pertain to thermal effluent limitations, each of which is Jiscussed below in relation to potential environmental impact and prev.cus NRC Staff impact assess-ments. It should be recogni: ed that these thermal effluent limitations are maxima which are not to be exce-ded. In addition, the revised 401 Certifi-cation provides that the licensee "shall at all times maintain in good working order and operate the '.!c.chanical Dr. aft Cc. cling Towers (MDCT's) as effi-ciently as possible so as to minimiae tempernture differential between a:nbient river temperature and the temperature of the dischar;;e." The analfscs of the potential impacts of thermal effluent discharged at the maximum allowable limi.
therefore represents a conservative or worst case assessment. Operation at less than the maxima should result in reduced potential for impact.
Assessment 1.
Section 3.c.2.b.
"The temperature of the discharge shall never exceed a maximum of 870F, except when the ambient river temperature exceeds 57 F, in which case, the discharge temperature shall not exceed the ambient river temperature, the temperature of the discharge shall not change b'f more than SoF dur:ng any one hour period."
4 43 016
h These thermal effluent limitations.' Iso appeared in the previous 401 Certi-fication, issued July 22, 1977. The potential impacts of an 87 F (30.6oC) 2 maximurn discharge temperature have prc' iously been reviewed by the Staff and found acceptable See FES s V.B.2, pp. V-10 to V-12, and "NRC Staff Response to Licensing Board's Question Relating to Aquatic Impacts by Clarence R. Hickey, Jr.," follos ing transcript page 988, at pp. 36-38.
~
The previous rate of tempet ature change assessed bf the Staff was 20F per hour (1972 FES. pages V-11 and V-12). The present limitation of SoF (2. SCC) rate of change per hour should not impose an environmental risk upon the fish' species present in the Sus.quehanna River.near Three Mi!c Island.
Since the mani:num discharge te:nperature allowable during normal opera-tion (30.6:C) is within the tolerance-limits of important river species, the 2.2cC per hour rate of change should not result in an unacceptabic impact Only during perieds of maximum and minimum ambient temperature and reactor cooldown would the excess temperature and rate of change possess the potential for impact, and then only to those species in the immediate vicinity of the discharge. This potential impact was reviewed previously and found not to pose an unacceptable situation. (Hicke, on Acuatic Impacts at 37-38.)
O Q~01?
s The revised 401 Certification has deleted a requirement the t the temperature of the discharge shall be no more then SoF above the ambient temperature of the receiving stream. Instead, the Commonwealth has expanded the appli-r3 cability of what were previously exceptions to the So temperature rise limi-tation. The effects of these new limitations are discussed below.
2.
Section 3.c.2.c.1 "During the period of November 1 through April 30, the temperature of the discharge shall not exceed 12oF above amnient river temperature."
During the peried of November 1 through April 30, the range of ambient temperatures to be expected in the Susquehanna River (Hichey en Aquatic e
rir Impacts, Table 16, p. 42) and the incremental increase r 12oF (6.70C)
D would be as follows:
Minimum Mean Low Mr mun Mean His Ambient 0.6, 1.5 14.0 8.9
~
Ambient & AT 6.7o 7.3 8.2 20.7 15.6 These temperatures fall within the tolerance limits of the fish species in the Susquehanna River and should not result in unacceptable impact.
This degree of excess temperature could result in attraction of scme species to the discharge area during the cool winter months, but should not impose undue stress upon them. During a planned reactor shutdown, 43~018
-4_
the potential for cold shoch will be minimized due to the rate of change limi-t atio n. Since the discharge is common to both Units 1 and 2, thermal effluent from one unit would continue to flow during shutdown of the other unit. Any d
stress to fishes as a result of shutdown wculd be confined to the immediate discharge area.
3.
Section 3.c.2.c.2 "During the period May 1 through October 31, the temperature of the dis-charge shall not aceed ToF above ambient river temperature."
The potential effects cf a discharge temperature of 7CF (3.90C) above ambient were discussed in the December 1976 Final Supplement to the FES (Sectic.-
5.5.2.3, p. 5-23) and in Staff testimony (Hickey on Aquatic hnpacts, p. 37) and fcund to.be acceptable. This lower permissible discharge temperr;ture coincides with periods of maximum fish spawning (May-June), young-of-The low the year appearance (summer-fall), and low annual river flows.
discharge temperatures of 3.9 C during this period should adequatelf pro-tect the resident fishes from unacceptable environmental impact.
4.
Section 3.c.2.c.3 "During plant cooldown operations, the temperature of the discharge "shall not exceed 12 F above ambient river temperature."
A temperature rise of 12oF (6.7oC) during cooldown was assessed by the Staff (Hickey on Aquatic Impacts, p. 37-38) and found to be acceptable.
Other potential consequences of cooldown are discussed above in para-graph 1.43-019
~
C_o nclu sion The Staff has reviewed the potential environmental impacts of the thermal effluenl limitations contained in revised 401 Certification, issued November 9,1977, and tinds th:. the changes made in previous thermal effluent limitations do notOJfect the Staff's original conclusions that the effects of the thermal discharge from the TMI-2 faci'.t'f will net pose an unaccept-able adverse impact on the aquatic ecosystem of the Susquehanna River O
9 9
d 0
4 43 020
s O
r.
APPENDIX B 9
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v DEPARTMErJT OF ENVIRONMENTAL RESOURCES Roor 1C02 Health f. Uelfarc Euilding llarrisburg, Pennr.ylvania 17120 A'
(717) 757-9665 Nove bcr 9, 1977
\\
Mr. Bruce P. Smith EPA Application PA000920 Perrits Eranch Metropolitan Edisen Ccapany U.S. Environmental Protecticu Agency Three Mile Icicud nuclear Statica Sixth and Walnut Streets Luadenderry Tc.caship Philadelphia, Pennsylvania 19106 Dauphin County.
Dear Mr. Scith:
The Cc_.anwealth of Pennsylvania hereby certifics to the folicwing and thus invalidates all past certifica tiot.s :
1.
The Acendments os. I and 2 issued 12/29/76 and 5/20/77 respectively for the Naticnal Pollutant DiscF~.rge.:licinatica Syster Per:10 for subject dischcrger were forward.. to the Correnwealth cf Pennsf vania l
pursuant to the prc.iciens of Section 40,1 of the Federal Water
. Pollution Centrol Act e-a-/ ents of 1972.
2.
The effluent limitations and other licitaticns, and co.nitori'ng
~.
require ents as preposed in the tentative pe=it c:endments subritted for cur review:
a.
Assure that the applicant will ec=pl'f with applicable cffluent 11 citations under Section 301 cr 302, standards of perfo mance under Section 306, or prohibitica, effluent standards, or pre-treat = cut standards undar Sectica 307 of the FUFCA Acend ents of 1972 where they are presently
- plicable; b.
Shall bect.nc a conditica of a Federal Fi' DES pe=it pursuant to Section 402 of the FWPCA Amend:ents.
3.
This certification is subject to the following conditiens:
That the Pe = ittee cceplies with Per:cylvania's Clean Strencs c.
Law.
b.
That the Pc=ittee cc plies with Industrial Waste Permits 2270C'.
and 2272202, and Sewerar,e Pe =it 2273419 issued by the Depart:2nt of Envircrc_ ental Ilecources.
43:022
Metro; vli.
t Company t
c.
The fol]owing effluent limitations nhould be i.mpoced:
1.
Discharge 101 - Effluent of cewage treatment facilities
'n Total phosphorus shall not exceed 2.23/1 on an averege basic, nor 4 ng/l at any ti=c.
2.
Discharge 001 - Cctbined Mechanical Draft Cooling Tower Blowdown.
The pcF=ittec -hall at all ti=es raintain in good a.
working crder at.d operate the "echanical Draft Ccoling Towers (:OCT's) as efficiently as possible_ so as to minimize tecperature differential betvcen ambient river tecperature and the tc=perature of the discharge; providec, however, the FOCT's cay be shut dczn when in the Jud; tent of the recpencible TMINS persennel a combinaticn of attacpheric conditiens and river terperaturc may exist which cauces the vaste water to be heated as it pasces through the :CCT's or ice for:ation is cbserved to cacur within the MDCT 's.
b.
The tc perature of the discharge shall never exceed a caximun of 870 F, except sacn the a:Sient river te perature exceeds 870 F, in which case, the diccharge terperature
~
shall not exceed the ambient river te=perature; the terpcrature of the diccharge shall not change by ::r: than 50 F during any one hour period.
Anbient river tc perature is the temperature of the river upstreat of the heated waste discharge.
The anbient terperature campling point shculd be unaffected by any sources of vaste heat.
The terperature of the intake water will be considered as anbient river tenperature so long as the intake water is unaffected by TMI's or any other nearby heated water discharge.
TFc following tenperature limitations shall never be e.
exceeded:
1.
During the period November 1 through April 20. the 0 ?
tcaperature of the discharge chall not axeced 12 nbove ambient river te=perature.
i 2.
During the period May 1 through Octcher 31, the tc perature of the diccharge chal] not execed 7 F above anbicut river te=perature.
e 43 023
MPDES P/1 "
-3~
November 9, 19 H P
8, t!c t ropolita;
- irca Coupany 3.
During plant cecidcun ope.ations the tc=perature of th:t.d is char;;e chall not enceed 12 F above ambient' 9
river tenperanure.
r i
d.
At no time chall the discharge exceed the rate of 150 tillion s
gallons per day.
c.
The Chief of the Operatictm Section c'f the Harrisburg Regicnal Office of the Bureau of Water Quality Manacccent shall be adviced by telephanc within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> unen the MDCT's are chut dcun for reasons other than thoca specified in conditien 2(a) above and again sehen tower cperatiun is recured; aball be notified within 24 hcurs. hen the discharge licitations specified in paragraph 2(c) above arc exceeded and again when the discharge is in cenpliance with cuch limitatienc; and shall be nctified, at least thirty (30) days in advance, whenever,p_cscibic of all scheduled plant cooldown cperations.
==
f.
Within two vcars af ter both nuclear reactor units cre in 4
cornercial operation, the Metropolitan-Edicca Cc=pany vill collect and submit to the Department of En'.ironnental Rcscurces strean data which accurately definas the thc =cl pitre cr scr-of impact frer the TMINS aented 5as;e diccharge.
As a cinitun. the tal a.lt.=e car.c.in' date cellectea to meet the o
Muclear Regulatory Cornicaion'c recuircacnts chall be,iccitted to the Pennsylvania Depart ent of Environ =cutal Resourccc.
g.
That the.'ermittee submit to tb1 Pernsylvcnia Department of Environ 12ntal Resources within ninety (90) days of incuance of Arend en; No. I to the MPLES pentit, an application for a new Pennsylvcnic '..'ater Quality l'2n ncrent permit for the facilities associated uith the thermal ecupenest of discharge 001.
4.
We certif,y that the final effluent licitaticas contained herein and in the setached NPDES permit, to the extent that they are not incen-sictent with the limitations herein, ar2 those effluent licitations v1._ch cre required to achieve the federally cpproved water cualit,,
criteri; for the receiving stream.
We also certify that the cccolicnce ochedulc therein is rescenabic. - We do not certif y-that--th2 cr11 cant for an NPDES pe =it is now in ec=pliance with cur cffluant linitaticcu cr permit requirements established pursuant to the C]can Strccc.s Law, Act of June 22, 1937, P.L.
1037, ao c= ended, 33 P.S.
691.1 or t'; -:
auch scurce is discharging in co pliance with the terra or cond'ticna of a state permit.
Nor do we certir; ti.at by nt aining the inte in ctandardc contained in the NPDES permit t b.. t auch source vill be in coupliance with the afcrecenticued Clean Streana Llw and the 'sules 48 024
- dDl.S P/,"909 m
~4-lluveube; 9,
l '; / 7
,,,,',3 lietropolita lison Company and Ilegulatfens thereunder.
Ey certifying the final effluent utendatas and the schedule for coupliance to be containu! in the thiZS permit, we;do not waive our rir,ht to prosecute either civilly cr erini.. ally all past, present and future violations of our Clean Strenna La
.,-.d the 11ules and regulations thereunder.
- or do we valve our right to riodify final effluent requirements as ic necessary to couply with Penncylvania Law.
\\
5.
This certification by the Departnent r ay be appealed to the Environ-tental Hearing Coard, First Floor Annex, Llcckatene Building, 112
. Market Street, Harrisburg, PA (717) 737-3403, by any acr.tieved percon pursuant to the Act of Dececher 3. 1970, P.L.
334, 71 Pa. Stat.
Anno. 9510-1 et seq. and the Ad=inirtratise /,ency Law, the Ar-of June 13, 1945, P.L.
1388, as a, ended 71 Pa. Stat. Anno. 3171C.~ et seq.
Appeal nust be filed with the En< iron = ental Hearing Cecrd withia thirty (30) days of set,.r!ce of this certification ualecc the appropriate statute prevides a dif f e':cnt tira peried.
Copies
~
of the appeal form and the D2partment's regulaticus governing practica and procedure before the Ecard nay be cbtsited frca the Ecard.
Very truly yours,
. g% C x k.
WDOW Frederick A. "arrocca, Chief Planning Section Harrisburg regional Offica PAM: hew cc: Metropolitan Edicen Ccupany l
t 43~0r^ov
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