ML19254C652
| ML19254C652 | |
| Person / Time | |
|---|---|
| Site: | Summer  |
| Issue date: | 09/28/1979 |
| From: | Sells D Office of Nuclear Reactor Regulation |
| To: | Crews E SOUTH CAROLINA ELECTRIC & GAS CO. |
| Shared Package | |
| ML19254C653 | List: |
| References | |
| NUDOCS 7910170066 | |
| Download: ML19254C652 (3) | |
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UNITED STATES E 'y 3.f. (
i NUCLEAR REGULATORY COMMISSION
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.. J' SEP 2 8 573 Docket No. 50-395 South Carolina Electric & Gas Ccmpany ATTN: Mr. E. H. Crews, Jr.,
Vice President and Group Executive Engineer & Construction P. O. Box 764 Columbia, South Carolina 29202 Gentlemen:
As specified in the Council on Envircnmental Quality regulations, we have requested Federal, State, and local agencies to co= ent in connection with the Draft Environmental Statement related to operation of the Virgil C. Summer Nuclear Station, Unit No. 1.
The enclosure to this letter contains a list of coments received to date and transmitted herewith.
Please review these coments and submit any responses you deem appropriate by October 15, 1979. Your reply should consist of three signed originals and 40 additional copies.
Sincerely,
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Id E. Sells, Acting Branch Chief Environmental Projects Branch 2 Division of Site Scfety and Environmental Analysis
Enclosure:
List of Comments Transmitted cc: See.next page 1156 110 7 910170 Ob d b
South Carolina Electric & Gas Co. SEP 2 8 7379 cc:
w/ enclosure:
Wallace S. Murphy, Esq.
Mr. O. W. Dixon, Jr.
General Counsel Group Manager, Production Engineering South Carolina Public Service Authority South Carolina Electric & Gas Company 2.23 florth Live Oak Drive P. O. Box 764 aoncks Corner, South Carolina 29461 Columbia, S6uth Carolina 29218 Troy B. Conner, Jr., Esq.
Mr. William A. Williams, Jr.
Conner, Moore & Corber Vice President 1747 Pennsylvania Avenue, fiW South Carolina Public Service Washington, DC 20006 Authority 223 North Live Oak Drive Mr. H. T. Babb, Managing Director, Moncks Corner, South Carolina 29461 Nuclear Project South Carolina Electric & Gas Company Richard P. Wilson, Esq.
P. O. Box 293 Assistant Attorney Gereral Winnsboro, South Carolina 29180 State of South Caroli a 2600 Bull Street Mr. Brett Allen Bursey Columbia, South Carolina 29201 Route 1, Scx 93-C Little Mountain, South Carolina 29201 Mr. Hayward G. Shealy, Chief Bureau of Radiological Health Mr. Charles Kaplan 2e00 Bull Street U. S. Environmental Protection Agency Colurrbia, South Carolina 29201 Pegion IV Office 345 Courtland Street Atlanta, Georgia 3030S Willian C. Mescher President and Chief Executive South Carolina Public Service Authority 223 North Live Oak Drive Moncks Corner, South Carolina 29461 G. H. Fisher, Esq.
Vice President and General Counsel South Carolina Electric & Gas Company P. O. Box 764 Columbia, South Carolina 29218 Mr. Mark B. Whitaker, Jr.
Licensing and Staff Engineer South Carolina Electric & Gas Company P. O. Box 764 Columbia, South Carolina 29218 1156 111
List of Comments Transmitted Name of Facility: Virgil C. Summer Nuclear Station, Unit No. 1 Applicant:
South Carolina Electric and Gas Company Docket No.:
50-395 Comments Transmitted:
1.
Mr. William A. Lockstet letter dated August 19, 1979.
2.
South Carolina Department of Health and Environmental Control letter dated August 24, 1979.
3.
U.S. Environmental Protection Agency letter dated August 24, 1979.
4.
U. S. Department of the Interior letter dated September 18, 1979.
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r 104 Davey Laboratory Penn. State University University Park Pa.,
16802 19 August 1979 Director, Divisien of Site Safety and Environmental Analysis U.S. :h elear Regulatory Cor:missicn t
?lashington, D.C.
20555 Gentlemen:
Enclosed are my cometents on the Draft Environmental Statement for the Virgil C. Summer Nuclear Station, NUREG-0534. Please note that the information presented is my own and not necessarily the position of the Pennsylvania State University, which affiliation is given for identification purposes only.
M7 comments consist of one page of s:ain text ( beyond this page) and ten pages of appendix, which I would like to have considered in entirety.
Sincerely, y& aLut
'W;t. A. Lochstet DUPLICATE DOCUMENT Entire document previously entered into system under:
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9CAPO SoUn aroina Wiliam C. Moore, Jr. D.M.D., ViceCamun
- 1. DeOuincey Nerun, caretary Leonard W. Douglas. M.D.
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2600 But Street Coitnna. S.C. 292C1 August 24, 1979 Mr. Ronald L. Ballard, Chief Environmental Projects Branch 1 Division of Site Safety and Environmental Analysis United States Nuclear Regulatory Con: mission Washington, D.C. 20553 RE: Draft Environmental Statem nt V.C. Sur:mer Nuclear Station, Unit I Fairfield County
Dear Mr. Ballard:
This letter is in response to the Draf t Environmental Statement related to the operation of the above mentioned facility, This Agency in general concurs with the conclusions of the Draf t Environmental Statement; however, there are statements in the docu=ent with which the Agency must take issue and on which the Agency would like to co ent.
The sentence on page 5-11 of the DES states, "The staff reviewed the applicant's monitoring program and believes that it may not be capable of reliably determining compliances with the State thermal requirement........"
It is the opinion of this Agency that the ther:tal monitoring requirements described in the NPDES permit will adequately and practically allow us to determine compliance with our State thermal water quality standards. The intent of the monitoring program is to determine cempatability between the environ: cent and the operation of the V.C. Su=mer Nuclear Station through compliance with permit limitations. The Depart =ent feels that many of the recon:mendations, which are comented on in more detail below, would be an additional effort which is burdensome and unnecessary.
In reference to Appendix G, page G-6,Section II A, this Agency has reviewed carefully the location of the ambient monitoring station and the ccupliance of the 3>3 F requirement. We agree with the NRC staff that the Alden Model was very conservative in its prediction of the thermal plume location and we contend that Station 17 vill be outside the influence of the thermal plume. Placing the ambient monitoring location at Station 13 (inside the upper i=poundment) wuld cause 7 9083 0 06fM,
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Mr. Ronald L. Ballard, Chief August 24, 1979 Page 2 elevated readings for temperature because of the relatively restricted =ovement and shallower dept'as in the upper impoundment. This would allow a higher temperature to be discharged at the Fairfield Pumped Storage intake. Using Stations 17 and 18 as ambient control locations and performing a regression analyses is definitely more sophisticated; however, for the sake of reporting and analyzing the monitoring results a simple aT is more practical. The background te=perature infor=ation that is now being gathered will aid us greatly in deter,intng the natural temperature fluctuations of Monticello Reservoir vithout the influence of the thermal discharge from the nuclear plant. This information vill be e nsidered in enforcement actions if and when a violation might occur after the nucl er plant becomes operational.
In reference to Appendix G, page G-5,Section I.3.1. and af ter considering the alternative methods, the Depart =ent concurs that the pheophyton corrected chlorophyll a_ para =eter will give adequate data to show trends that are occurring within the phytoplankton comm nity. Although we concur that this parameter should be added, we do not feel that NRC's argument supports its necessity.
In reference to Appendix G, page G-5,Section I.3.2., the Department concurs with adding the monthly sampling of ichthyoplankton from October to January.
Although from historical data in South Carolina lakes shows little or no spawning during these months (even those lakes with thermal discharges), it may be necessary to have this background information. It requires only the addition of four (4) sampling ti=es which is an increase of approxi=ately 15 (increase from 26 samplings to 30 sa=plings). The study plan will be modified to include this work.
In reference to Appendix G, page 5,Section I.3.3., the Department maintnf m that the proposed sampling schedule is sufficient to determine any trends occurring within the fish e m unity. Monthly sampling wuld be excessive as far as collection of information is concerned. All analysis objectives that are requested can be adequately answered with the proposed study program.
In reference to paragraph 3.3.5.1. a d Appendix G, page G-5,Section I.3.4.,
the Department feels that requiring impingement monitoring to begin before co==ercial operation vould yield information of little value in deter =ining cc=pliance with Section 316 (b) of the Clean ~4ater Act since it is a one-time (pre-operation) situation.
All pre-operational " bugs" should be worked out before the monitoring activities begin in order to give a more accurate indication of the long term effects which _ay be caused by the design, location, and capacity of the intake structure.
In reference to Appendix G, page G-5,Section I.3.5., documentation of fish impingement in this State and this area of the South show that i=pingement events which are pulsed in nature are adequately detected with biweekly sa= cling. Tne caly exception would "ae in a system where a significant spawning run occurs and the intake is located in such a way that it say i=pinge g-eat nu=bers o f fish. Tae spawning at the 7.C. Su=cer plant intake is not considered significant nor is the intake structure located so as to create ispingement proble=s. Adequate information to evaluate fish i=pingement vill be available under the present schedcle of samoling.
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Mr. Ronald L. Ballard, Chief August 24, 1979 Page 3 In reference to Appendix G, page G-5,Section I.3.6., this is standard operating procedure. All roEenoning in South Carolina is overseen by the South Carolina
'411dlife & Marine Resources Depart =ent who has very strict guidelines concerning the use of rotenone.
As you are aware, the NPDES per=1t expires in July,1981, at which time the project will be reevaluated with respect to the permit, and necessary up-dates vill be made. NRC is strongly urged to participate (pursuant to the " Agreement between the State of South Carolina and the U.S. Nuclear Regulatory Cc=rdssion" - dated April 21, 1978) in the reissuance process of the permit. Any additions that the NRC staff wants to ma'<.e will be considered at the ti=e of reissuance unless a significant finding warrants a modification before that time.
'4e appreciate this opportunity to comment on the Draft Environmental Statement and look forward to a continued cooperative ef fort.
Sincerely, ML John E. Jenkins, P.E.
Deputy Commissioner for Environmental Quality Control JEJ/JP/cs cc: Charles Jeter 11C(
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i g i UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
%.o M REGION IV 345 COURTLANO STREET ATLANTA. GECRGI A 30308 August 24, 1979 4SA-EIS Mr. Ronald L. Ballard Chief, Environmental Projects Branch 1 Nuclear Regulatory Cc=sission
'Jashingtcn, D. C. 20555
Dear Mr. Ballard:
'4e have reviewed t.m Draf t Environmental Imcact Statement on the operation of Virgil C. Su==er Nuclear Station (Unit #1) in Fairfield County, South Carolina, and offer these eccments:
Page 3-11, Section 3.2. 6.7, Sewage and Sanitary '4aste Sanitary waste water treatment systems can readily meet the 30 =g/ liter
=cnthly average stipulated in the NPDES permit. If necessary, the present system say have to be redesigned to meet this requirement.
Section 4.2, Imoacts on Land Use Appropriate data shculd be included in the Final Statement describing all wetlands which exist at the plant site and along the transmission lines as well as the impact of the facility on these plant communities.
It is indicated that the transmission corridors and the plant site occupy 2,217 acres of original forestland, but there is no indication what portion of these forestlands can be classified as wetlands.
To retain the integrity of streams / wetlands and to maintain water quality we recoc=end that these sensitive areas be spanned and that a buffer zone of undisturbed vegetation (at least 50 feet wide) be left on the crossing.
Tall trees which might interfere with the transcissien lines may be re-noved but other vegetation should be left intact.
Our review of the document indicates that the plant should be capable of operation in accordance with EPA 40 CFR 190. Environmental Radiation Standards for Nuclear Power Operations, and the radionuclide portion of 40 CFR 140, Interis Drinking ~4ater Regulations. However, the reactor acci-dent at the Three Mile Island has focused attention on the need for a thorough re-examination of reactor safety.
'4e believe it is incu= bent on the NRC to carefully review its progra=s and procedures for identifying,
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2 assessing and acting on potential accident sequences as operating ex-perience with reactors increases.
We are particularly concerned about the States' energency response preparations. Those States having reactors should be urged to develop adequate emergency response preparations. Those plans that have re-ceived NRC concurrence should be updated as necessary.
E=ergency preparedness at every level of responsibility (including licenses com-pliance with Reg. Guide. 1.101) is imperative to protect the public health and safety in the event of a severe nuclear power plant accident.
We will have additional coc=ents on the in-stream effects of the plant as soon as the 316A/3 Studies are completed. On the basis of our review a rating of LO-2 was assigned, i.e., we have no significant reservations, but so=e additional information is requested.
If we can be of further assistance, feel free to call on us.
Sincerely yours, Sw
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E. Hagan, II
.jfChief, EIi Branch
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