ML19275A056
| ML19275A056 | |
| Person / Time | |
|---|---|
| Site: | Summer  |
| Issue date: | 08/24/1979 |
| From: | Joel Jenkins SOUTH CAROLINA, STATE OF |
| To: | Ballard R Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 7908300654 | |
| Download: ML19275A056 (3) | |
Text
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BOARD
- SOU, Wlham M. Wilson, Gairrran Wiliam C. Moore, Jr., D.M D., ViceCairrrun I. DeOuincey Newman, Secretary Leonard W. Douglas, M.D.
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C. Maunco Patterson
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Albert G. Randall, M.D., M.P.H.
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2000 Bull Street Colurroa, S.C. 29201 August 24, 1979 Mr. Ronald L. Ballard, Chief Environmental Projects Branch 1 Division of Site Safety and Environmental Analysis United States Nuclear Regulatory Commission Washington, D.C. 20555 RE: Draft Environmental Statement V.C. Summer Nuclear Station, Unit I Fairfield County
Dear Mr. Ballard:
This letter is in response to the Draf t Environmental Statement related to the opantion of the above mentioned facility, This Agency in general concurs with the conclusions of the Draft Environmental Statement; however, there are statements in the document with which the Agency must take issue and on which the Agency would like to :oment.
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 thermal 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 compatability between the environment and the operation of the V.C. Summer Nuclear Station through compliance with permit limitations. The Department feels that many of the recommendations, which are commented on in mot, 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 compliance of the AT=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 will be outside the influence of the thermal plume. Placing the ambient monitoring location at Station 18 (inside the upper impoundment) would cause 7eoss ootsy
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Mr. Ronald L. Ballard, Chief August 24, 1979 Page 2 elevated readings for temperature because of the relatively restricted movement and shallower depths 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 6T is more practical. The background temperature information that is now being gathered will aid us greatly in determining the natural temperature fluctuations of Monticello Reservoir without the influence of the thermal discharge from the nuclear plant, this information will be considered in enforcement actions if and when a violation might occur after the nuclear plant becomes operational.
In reference to Appendix G, page G-5,Section I.B.l. and after considering the alternative methods, the Department concurs that the pheophyton corrected chlorophyll a parapeter will give adequate data to show trends that are occurring within the phytoplankton community. 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 B.2.,
the Department concurs with adding the monthly sampling of ichthyoplankton f rom 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 times which is an increase of approximately 15% (increase from 26 samplings to 30 samplings). The study plan will be modified to include this work.
In reference to Appendix G, page 5,Section I.B.3., the Department maintains that the proposed sampling schedule is sufficient to determine any trends occurring within the fish community. Monthly sampling would 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 5.3.5.1. and Appendix G, page G-5,Section I.B.4.,
the Department feels that requiring impingement monitoring to begin before commercial operation would yield information of little value in determining compliance with Section 316 (b) of the Clean Water 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 may be caused by the design, location, and capacity of the intake structure.
In reference to Appendix G, page G-5,Section I.B.5., documentation of fish impingement in this State and this area of the South show thac impingement events which are pulsed in nature are adequately detected with biweekly sampling. The only exception would be in a system where a significant spawning run occurs and the intake is located in such a way that it may impinge great numbers of fish. The spawning at the V.C. Summer plant intake is not considered significant nor is the intake structure located so as to create impingement problems. Adequate information to evaluate fish impingement will be available under the present schedule of sampling.
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Mr. Ronald L. Ballard, Chief August 24, 1979 Page 3 In reference to Appendix G, page C-5,Section I.B.6., this is standard operating procedure. All rotenoning in South Carolina is overseen by the South Carolina Wildlife & Marine Resources Department who has very strict guidelines concerning the use of rotenone.
As you are aware, the NPDES p armit expires in July,1981, at which time the project will be reevaluated with I aspec.t to the permit, and necessary up-dates will be made. NRC is strongly urged to participate (pursuant to the " Agreement between the State of South Carolina and the U.S. Nuclear Regulatory Commission" - dated April 21, 1978) in the reissuance process of the permit. Any additions that the NRC staff wants to make will be considered at the time of reissuance unless a significant finding warrants a modification before that time.
We appreciate this opportunity to comment on the Draft Environmental Statement and look forward to a cont. hued cooperative effort.
Sin.:erely, QA(
John E. Jenkins, P.E.
Deputy Commissioner for Environmertal Quality Control JEJ/JP/cs cc: Charles Jeter 203l 325