ML19289F637

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Forwards June 1979 Response to Dept of Natural Resources Specific Comments on Amends 11 & 12 Environ Rept.
ML19289F637
Person / Time
Site: 05000502, 05000503, 05000504, 05000505, 05000506, 05000507
Issue date: 05/29/1979
From: Burstein S
WISCONSIN ELECTRIC POWER CO.
To: Druckenmiller H
WISCONSIN, STATE OF
References
NUDOCS 7906150216
Download: ML19289F637 (25)
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WISCONSIN UTILITIES PROJECT APPLICANTS' RESPONSE TO DEPARTMENT OF NATURAL RESOURCES' SPECIFIC COMMENTS ON AMENDMENTS II AND 12 THE ENVIRONMENTAL REPORT HAVEN NUCLEAR PLANT 2229 303 WISCONSIN ELECTRIC POWER COMPANY WISCONSlH POWER & LIGHT COMPANY WISCONSIN PUBLIC SERVICE CORPORATION ;UNe i979 79061502/4

Dear Mr. Druckenmiller:

WISCONSIN UTILITIES PROJECT HAVEN NUCLEAR PLANT DEPARTMENT OF NATURAL RESOURCES SPECIFIC COMMENTS ON AMENDMENTS 11 AND 12 TO THE ENVIRONMENTAL REPORT This is in response to your letter of April 18, 1979, transmitting the Department of Natural Resources review comments of Amendments 11 and 12 to the Environmental Report for the proposed Haven Nuclear Plant. Our responses to your comments are enclosed.

Fifteen (15) additional copies are being transmitted under separate cover. We are also providing three (3) copies of our~ responses to the Public Service Commission of Wisconsin and five (5) copies to the U.S. Nuclear Regulatory Commission.

Should you have any questions regarding the enclosed responses to your comments, please contact us.

Very truly yours, U

Exe utive Vice President Sol Burstein Copies to: Public Service Commission of Wisconsin U.S. Nuclear Regulatory Commission 2229 304

APPLICANTS' RESPONSE TO DEPARTMENT OF NATURAL RESOURCES' SPECIFIC COMMENTS ON AMENDMENTS 11 AND 12 TO THE ENVIRONMENTAL REPORT HAVEN NUCLEAR PLANT JUNE, 1979 2229 305

PREFACE Wisconsin Electric Power Company, Wisconsin Power and Light Company and Wisconsin Public Service Corporation hereby submit responses to the specific comments made by the Department of Natural Resources (DNR) as a result of their review of Amendments 11 and 12 to the Applicants' Environmen-tal Report (ER) for the proposed Haven Nuclear Plant. These specific comments were transmitted by a letter dated April 18, 1979, from Mr. H. S. Druckenmiller of the DNR to Mr. Sol Burstein of Wisconsin Electric Power Company.

2229 506 ii

DNR COMMENT (Page 2.7-25, Species of Special Status and Tables 2.7-27A and 2.7-27B)

~

Chapter 27, Wisconsin Administrative Code, is presently being revised and is expected to go into effect in summer, 1979. Changes in classifications that are being proposed include the following:

1. Northern Ribbon Snake (Thamnophis sauritus) will be added as an endangered species.
2. Status of Blandings Turtle will be threatened.
3. Status of Yellow Rail will be " watch".
4. Status of Piping Plover will be endangered.
5. Status of Migrant (Loggerhead) Shrike will be threatened.
6. Five-lined Skink will be removed from the " watch" status list.
7. Marsh Hawk will be removed from the " watch" status list.

RESPONSE

The Applicants appreciate receiving the above information.

Changes in Section 2.7.1.3 as a result of this revision in classifications will be made in a future amendment.

2229 307 1

DNR COMMENT (Page 3.6-5, paragraph 4)

What is the present and anticipated (at the time of proposed operation) availability of disposal sites that would accept this oil collected from the Haven site? Has WEPCo experienced any problems disposing of oil wastes, solid wastes resulting from the sanitary treatment facilities (described on page 3.7-2) or any other similar non-radioactive wastes that may require off-site disposal from the operation of their Point Beach Nuclear Power Plant?

RESPONSE

It is anticipated that oil wastes removed from oil separators would be collected and disposed of offsite by a licensed solid waste contractor. A number of these type of contractors who are capable of handling non-radioactive solid wastes are available in the Sheboygan, Manitowoc, and Green Bay area.

The small quantities of non-radioactive solid waste, such as sludge from the sanitary treatment facility produced at the Point Beach Nuclear Plant are currently handled by licensed contractors in accordance with applicable regulations. There have been no problems with disposal of oil wastes or other solid wastes at Point Beach.

2229 308 2

DNR COMMENT (Page 4.1-2, paragraph 2)

An updated construction / operation schedule for the once-through cooling option should be provided.

RESPONSE

The construction / operation schedule for the once-through cooling system has been provided in Section 14.4.1 of Amendment 13 to the Environmental Report.

222'l .509 3

DNR COMMENT (Page 4.1-5, paragraph 3)

When will the rail line be surveyed for structural adequacy so costa for possible upgrading can be estimated?

RESPONSE

Significant numbers of rail shipments will not begin until 1982. These shipments are not expected to require upgrading of the rail line. The rail line will be inspected prior to shipment of heavy components such as the main generator; however, this is not expected to occur until much later in the construction period. Therefore, rail line inspection will probably not be required before 1985.

2229 310 4

DNR COMMENT (Page 4.1-6, paragraph 1)

Will the topsoil from the spoils area be removed and stock-piled for potential use to revegetate the spoils area?

RESPONSE

Topsoil from the spoils area will be stockpiled for use in revegetating the spoils area.

2229 311 5

DNR COMMENT (Page 4.1-14, paragraph 4)

More than " consideration" should be given to the fugitive dust control measures that are listed,especially covering the material on the trucks since emission estimates assumed this control. A more definite proposal would be appropriate.

RESPONSE

A detailed enforcement program will be formulated to achieve implementation of precautionary and mitigative measures for controlling potential environmental impacts during the construction of the Haven Nuclear Plant. As stated in Section 4.5, this enforcement program will be established prior to the initiation of plant construction including the borrow area activities.

Fugitive dust control measures listed on pages 4.1-14 and

-15 that will be included in this enforcement program are as follows:

1. The material on trucks will be covered to reduce particulate emissions when material and weather conditions warrant.
2. An effective watering program for unpaved roads will be implemented for dust control.
3. Areas that are exposed in the borrow area will be minimizad.
4. Vegetative cover will be provided for exposed borrow areas after completion of the excavation activities.

2229 312 6

DNR COMMENT (Page 4.1-23)

What effects, if any, would there be from construction runoff on the wetland area just north of the spoils area?

RESPONSE

As stated in Section 4.1.1.6, the spoils area will be graded and seeded to prevent erosion. A settling basin and perimeter drainage berm will be used to control runoff.

There fore, it is not expected that there will be any effects on the wetland area due to construction runoff.

2229 313 e

7

DNR COMMENT (Figure 4.1-6)

The service water intake lines have been improperly identified.

RESPONSE

The comment is correct. The service water intake lines are perpendicular to the shoreline at the center of the service water pumphouse. Figure 4.1-6 will be corrected in a future amendment.

2229 314 8

DNR COMMENT (Figure 4.1-26)

This figure indicates that several culverts would lead to the shore for discharging construction runoff. How would the cul-verts be anchored in place and how would these areas be pro-tected from wave damage or ice push if necessary? Will there be a need for erosion protection devices such as aprons which would protect against scour from pipe discharges? The need for protection devices would depend upon the size of rock at the discharge point.

RESPONSE

The shorefront culverts shown on Figure 4.1-26 discharge in some cases at the finished shore protection area and in other cases at the natural embankment. In the cases where the discharge is at the natural embankment, wing walls will be provided and the stone aprons will be used for erosion protection. The invert of the pipe will be high enough to avoid damage from ordinary wave action or ice push.

In the case where the discharge is at the finished shore protection area, the culvert will be constructed as an integral part of the stone work. A combination of smaller stones and some concrete work will be utilized to protect the culvert from damage during armor stone placement. The flow from the culverts will not cause erosion of either the armor stone or the underlayers. The finished shore protec-tion is designed to resist wave action and ice damage.

2229 315 9

DNR COMMENT (Page 4.5-4, paragraph 2)

Have reprocessors been contacted as to the acceptability of these waste chemicals and oils resulting from construction?

What are alternative acceptable disposal methods?

RESPONSE

The use of licensed reprocessors to collect and reprocess waste chemicals and oils is well established. No contacts have been made at this time.

The alternative acceptable disposal method will be to contract out with commercial licensed disposal companies to haul away and dispose of all waste chemicals and oils from the construction site. As discussed in the response to DNR Comment, Page 3.6-5, paragraph 4, commercial contractors are available to perform this service.

2229 316 10

DNR COMMENT (Page 4.5-4, paragraph 3)

What plans are proposed for proper abandonment of the air curtain destructor after the site construction phase?

RESPONSE

Upon completion of construction activities, the air curtain destructor will be dismantled. The blower unit appurtenances will be sold for salvage, or scrapped by a licensed disposal contractor. Since the facility will be maintained and operated in accordance with the Wisconsin Administrative Code, Sectica NR 151.14 " Solid Waste Disposal Operation:

Air Curtain Destructor," no more than 3 feet of ashes will remain in the burning pit upon completion of its use. Upon abandonment, the burning pit will be backfilled, covered with topsoil, and either seeded or permitted to return to its natural vegetation.

2229 317 11

DNR COMMENT (Page 5.5-7 to 5.5-9)

We believe that the containment structure would have down-wash effects for two reasons. First of all, using the 2.5 times equation to determine the farthest extent of the containment structure-induced cavity region and a height of 175 feet for the containment structure, a distance of 437.5 feet is determined. Using Figure 2.1-4, the distance from the auxiliary boiler building vent to the nearest edge of the containment structure facade is approximately 325 feet.

This would put the stack within the aerodynamic effects of the reactor containment building. Secondly, in U. S. EPA Proposed Regulations to (40CFR51) Implement Section 123 (stack heights) of the 1977 Clean Air Act Amendments it is stated that "for all structures that have a maximum width less than ten times their height, adverse downwash effects may be expected to extend downwind to a distance five times the height or width of the structure (perpendicular to the plume), whichever is less" (U. S. 1978 Proposed Regulations to (40CFR51) Implement Section 123 (Stack Heights) of the 1977 Clean Air Amendments (Federal Register 1/12/79, pages 2608-2614). For the reactor containment building the width is approximately 325 feet so the auxiliary boiler stacks would be well within the distance where downwash effects may be expected to occur based upon a height of 175 feet.

The equations used were derived from work performed by Meroney and Yang. Their wind study examined the influence of an isolated, simple cubical structure on the dispersion of a tracer gas released from short stacks at varying heights and exhaust velocities. In the study, they found that building orientation aggravates entrainment even for a single cubical structure, and that for more complicated building complexes, the influences may be more significant (U. S. EPA, 1978B, Draft Technical Support Document for Determination of Good Engineering Practice Stack Height).

Since the influences of the buildings at Haven could cause an even more complicated influence on air flow than flow over a simple cube, we suggest that you perform two other downwash calculations and compare those results to the analysis based on the work of Meroney and Yang. The two suggested approaches would be: 1) G. Brigg's Diffusion Estimation for Small Emissions, Air Resources Atmospheric Turbulence and Diffusion Laboratory, NOAA, Oak Ridge, Tennessee, 1973 and 2) Huber's " Incorporating Building /

Terrain Wake Effects on Stack Effluents," from the Joint Conference on Air Pollution Meteorology Applications, Salt Lake City, Utah, American Meteorological Society, Boston, Massachusetts, pp. 353-356, 1977. Other references which may be helpful include:

2229 318 12

Huber, A. H. 1979: An evaluation of obstacle wake effects on plume dispersion. From Fourth Symposium on Turbulence, Diffusion and Air Pollution, Reno, Nevada. American Meteorological Society, Boston, Massachusetts (late paper - not in Preprint Volume).

Huber, A., and W. Snyder, 1976: Building Wake Effects on Short Stack Effluents, Third Symposium on Atmospheric Turbulence, Diffusion and Air Quality, Raleigh, North Carolina, American Meteor-ological Society, Boston, Massachusetts, pp. 235-242.

RESPONSE

On the basis of the location of the auxiliary boiler building vent with respect to the nearest edge of the reactor containment building facade for the proposed plant we agree that, according to US EPA Proposed Regulations on Good Engineering Practice Stack Heights (44 FR; pages 2608-2614

[1/12/78]), aerodynamic effects of the reactor containment building could conceivably result in downwash of auxiliary boiler plumes under certain conditions. Based upon the EPA five scale lengths criterion, the minimum extent of the zone of influence downwind of the reactor containment building would be approximately five building widths, i.e. 220 meters.

According to our calculations, referring to Figure 14.2.1-1 of Amendment 15 to the Environmental Report, the downwind distance from the nearest edge of the reactor containment building facade to the auxiliary boiler building vent is approximately 125 meters.

Although, based on the five scale lengths cri-terion, aerodynamic downwash of auxiliary boiler emissions 2229 319 13

due to reactor containment building-induced turbulence is possible, it should be emphasized that the vent is situated at the extreme downwind fringe of the reactor containment building-induced cavity region. The cavity region is calcu-lated to extend approximately 133 meters downwind based upon the 2.5 building height rule, whereas the auxiliary boiler vent downwind distance from the nearest edge of the reactor containment building facade is 125 meters. Therefore, cavitation of auxiliary boiler plumes is not expected.

A series of aerodynamic downwash calculations of auxiliary boiler emissions, based upon full load conditions, was performed following the techniques of Huber (1979) . The downwind distances from the reactor containment building at which ground level concentrations were calculated ranged from 160 meters to 533 meters, corresponding to a range of 3-10 reactor containment building heights. In this zone, horizontal and vertical dispersion rates specified by Huber are insensitive to atmospheric turbulence and are wholly dependent upon building-generated turbulence. Therefore, ground level concentrations are not dependent upon atmos-pheric stability assumptions.

The wind speed selected for the purpose of perform-ing the calculations was five meters per second. This value was chosen for the following reasons:

1. It corresponds to a moderate wind speed for which it is reasonable to assume that aerodynamic wakes 2229 320 14

would be induced downwind of the reactor contain-ment building. The degree of meandering of the mean wind vector increases for lighter wind speeds.

2. Based upon guidance presented in USNRC Regulatory Guide 1.111, kevision 1 (1977) elevated releases are assumed from vents or other points at the level of or above adjacent solid structures when-ever vertical exit velocities exceed horizontal wind speeds by at least a factor of five. This criterion is based upon the work of Johnson et al.

(1975), and is used as a modeling basis for radio-active releases. During full load operating condi-tions, auxiliary boiler vent exit velocities are approximately 27 meters per second, therefore ex-ceeding a 5 meter per second horizontal wind speed by at least the required factor of five.

No plume rise credit was taken since the effective stack height was conservatively assumed to equal the physical stack height when performing the calculations.

The following table presents hourly average concen-tration estimates at various downwind distances during aerody-namic downwashing of auxiliary boiler emissions at full load operating conditions:

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ds ' (m ) X(pgm/m )

Distance (m) 69'(m) 37.3 390.3 160 15.4 200 18.1 40.0 336.9 300 24.8 46.7 244.5 400 31.5 53.4 185.4 500 38.2 60.1 145.2 533 42.1 64.0 127.4 On the basis of these calculations, conservatively assuming persistence for three consecutive hours, applicable sulfur dioxide ambient air quality standards and prevention of significant deterioration increments are met. It should be noted that the concentration estimates resulting from aerodynamic downwash of auxiliary boiler emissions at the plant's property line are significantly lower than the maxi-mum values expected to occur in the near downwind vicinity of the reactor containment building onsite.

Calculations of auxiliary boiler downwash concen-trations using Briggs' (1973) technique were previously pre-sented in Amendment 9 to the Environmental Report. Huber's technique is currently considered state-of-the-art by the U. S.

Environmental Protection Agency.

References Huber, A. H., 1979: An Evaluation of Obstacle Wake Effects on Plume Dispersion. From Fourth Syruposium on Turbulence, Diffusion and Air Pollution, Reno, Nevada. American Meteorological Society, Boston, Massachusetts. (late paper - not in preprint volume).

2229 322 16

U.S. Nuclear Regulatory Commission, 1977: Methods for Estimating Atmospheric Transport and Dispersion of Gaseous Effluents in Routine Releases from Light-Water-Cooled Reactors, Regulatory Guide 1.111, Revision 1. Washington, D.C.

Johnson, W. B., et al., 1975; Gas Tracer Study of Roof-Vent Effluent Diffusion at Millstone Nuclear Power Station. Atomic Industrial Forum, Inc., AIF/NESP-007b.

Briggs, G., 1973: Diffusion Estimation for Small Emissions.

Air Resources Atmospheric Turbulence and Diffusion Laboratory, NOAA, Oak Ridge, Tennessee.

2229 323 17

DNR COMMENT (Page 10.4-3, paragraph 2)

What would be the final deposition of solid wastes resulting from this alternative chemical waste treatment system?

RESPONSE

The dewatered solids resulting from the alternative chemical waste treatment system would be stored in an on-site storage facility. This facility is sized to accommodate all of the solids produced by the treatment system for the life of the plant.

It is expected that these solids would ultimately be removed from the facility and disposed of in an approved landfill by a licensed contractor.

2229 324 18

DNR COMMENT (Table 12.1-1)

The permit for the concrete batch plant required under NR 154.11(3)(b)l.i. and the permit for the air curtain destructor required under NR 151.14 as specified in the Department's May 25, 1978 letter to you should be included in this table.

RESPONSE

Table 12.1-1 will be revised to include these two permits in a future amendment.

2229 325 19

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