ML19303A299

Comments on NUREG-0813,DES for Facility.Final Research Design Has Been Prepared & Forwarded.Fuel Load Date Changed to June 1983.Clarification Needed Re Issuance of Water Quality Certification Being Required Before OL Issuance

ML19303A299
Person / Time
Site:	Callaway
Issue date:	11/20/1981
From:	Schnell D UNION ELECTRIC CO.
To:	Youngblood B Office of Nuclear Reactor Regulation
References
RTR-NUREG-0813, RTR-NUREG-813 ULNRC-529, NUDOCS 8112040607
Download: ML19303A299 (16)

Text

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.. j UNION ELEcmic COMPANY j

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,, Mr. B. J. Youngblogd, Chief Licensing Branch Ng. 1 Division of Licensing

. . U.S. Nuclear Regulatory Commission .

. Washington, D.C. 20555 . ULNRC-529 Dear Mr. Youngblood-

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'. \ h /k, DOCKET NUMBER 50-483 jp y ,~ ,',p{jji d,'

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l DRAFT ENVIRONMENTAL- STATEMENT *

./.',/ Q8* Q "q CALLAWAY PLANT - UNIT 1 j . ~' \

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t'iC w* CS ug.p# 1 We hjl;ve'.reyiewed the Draf t Environmental State e8

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related to the operction of the Callaway Plant, Unit No Q ,

(NUREG-0813 ) and have the following cc::ments: \ ,'

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41. Summary and Cenclusions, P. tee v, Item 3 - The_7uel load 4 ate for Unit 1 has been changed to June',.;19 C and Unit 2 has been cancelled. ~--

p 2. Su==ary and Conclusions, Pace vii, Item 5f - A final researen cesign nap peen preparec anc,  !

f:rwarded to Mr. Youngblood by letter dated November 9, 1981. " -

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p 3. Chapter 1, Section 1.1, Page 1-1 and 1 The fuel  ;

load date for Unit 1 has been changed to June, 1983 l

," with ec=mercial operation in early, 1984. Unit 2

,,has been cancelled. .

4:$. 4 . I Ch apter 1, Section 1.2, Page 1 This section I

states that the issuance of a water quality certification by the state is a necessary prerequisite for obtaining an operating license from NRC, however, the statement is vague'and ,

misleadinc as to whether this cert fication has COO

• been secured. This statement should be clarified #

to indicate a water quality certificatied has been  ;

gebtained. ~, /l l

. g 5. Pages 4-3, 4-6, 4-11, 5-2, 5-3, 5-8, 5-9 and i Appendix 3 - In April 1980, the Missouri Department of Natural Resources (DNR) published notice of a proposed NPDES permit for Callaway Plant'. The draft j

91120A0607 911120 PDR ADOCK 05000483 .

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j permiti proposed a limitation of 30 mg/l (mont.hly aver, age) and 100 mg/l (daily maximum) of TSS for

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discharge from the water treatment clarifier (out(all #003). These TSS limitations were imposed

.. in the NPDES permit that was issued in fiaal form

-in Adgust 1980.

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In MQ 1980, Union Electric filed with DNR its 4 . formal request for a variance for outfall #003

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,pff s pursuant to 40 C.F.R. Section 423.12(a). In its variance' request,' Union Electric objected tc these ~

i h limitations, since the suspended solids in the- #003 outfall discharge consist mainly of silt from intake water taken from the Missouri River. The

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. _. . variance request noted -that UE qualifie's for a 3

_ varian_ge because the clarified blowdown at callaway

• _ - is " fundamentally different" from t hat was

,.. considered by federal EPA in developing limitations  ;

1 for the steam-electric power generating category.

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Maior differences exist with respect to technical factort (e.g. type of facilities, raw materials),

3 non-water quality environmental impset, costsy- and water quality considerations. On May 23, 19 8_Q:, .-DNR j

forwarded UE's variance ~ request to EPA-Region ~-21I s

_ without recommendation, for EPA's decision. 2 j Uni 8n 11'ectric has already completed construc* .[

of 3 of the 16 sludge retention ponds that wontd be i

required over the life of the plant. A favo'rable

. decision to allow the return of clarifier sludg'e to the riv.er would most p.robably res' ult in the current and future ponds being unneqessary. _

It should be noted throughout the report that, as a

_ result of the variance request, clarifier sludge disposal ponds at callaway may be used as opposed

, to will be used. _

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-$F 6. ~"Pages 4-3, 4-6, 4-11, 5-2, 5-3, 5-8, 5 'i Discussions on these pages should be expanded to .

include information from the attached revised pages 3.6-1, 3.6-9, 4.1-1, 4.1-2, 4.3-1, 10.4-1,. 10.4.2 and Figures 2.1-3, 4.1-2 and 3.3-1 of the .ER-OL.

These revised pages discuss the . method to be used a

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for disposal of Cooling Tower Basin Sediment for

, i Unit-1 only. .

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udC 7. Chapter 4, Section 4.2.4.1, Page 4 The' list l sentence of the second paragraph on this page ntates that for one unit operation, the intake i velocities (for the intake structure) would be {

( about one-half the previously stated values for two '

I unit operation. Since each intake water. pump is l L located in its own pump bcy and operation of the i

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i 4( 7, I pump gI velo,is'at cities design capacaty across the screensatwould all times, inta$ke be the same gpgardless of the number of pumps in operation.

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, , . Chapter 4, Section 4.3.4.1, Page 4 The

. construction monitoring program will continue until 4

the end of construction and not "up to May, 1981"

, as indicated.

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gg 9. Ichapter 5, Section i .

5.1., Page 5 In the fourth paragraph of this Section NRC states that in

• accordance with the Environmental Protection Plan, Union . Electric must report violations of conditic as r.tated in the NPDES permit. We feel that

' ~~ violations need -only .be_ reported to the NPDES perni( issuing authority which is the Missouri

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Dep'artfent of Natural Resources.. This duplication j [. ,of,repbrting is an unreasonable regulatory burden.

. gyp .10. " Chapter 5, Section 5.2, Pace 5' The second A .

-sentence tf paragraph 2 stgtes that 2000 acres will be unavailable for public use during'the . . _ .

operational lifetime of the plant. This is not the intent.of our land management plan. Those lan'd 2

designated as "Public Uhe Not Authorized" on EEPOL 3 Figure 2.1-34 are so designated only through the __ t l' con h etion period. -During Operation, - these Qnd,s ---

will be added to that already under the management of the Missouri Department of Conservation for-low

{intensitypublicuse. >

q$.11. fChapter5, Secticn 5.5*.1.2, Pace 5 In the paragraph under " Drift Fallout" a comparison of cooling tower drift deposition is made to the 15 ton /mi per month settleable particulate standard 1 established by the State of Missouri. Missouri has I

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.' ' since deleted this settleable particulate standard Lf rom the state regulations..

.pr 12. Ichacter 5, Section 5.5.1.6, Page 5 The NRC evaluated tne potential operational impacts from Callaway Plant - Unit 1 and concluded that "the potential for damage to the surrounding ec'esystem cauced by the water and chemicals in the drift expected from the cooling tower will be small" neverthelers the staff recommended that Union

. Electric conduct a limited-term inspection program.

NRC also stated that an acceptable program-is best

, accomplished by means of infrared aerial photography with accompanying ground truth and that this progran would be specified in Appendix B of the operating license. ,

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- ' While Union Electric does not have a strong objei-tion to some moderate ' form of monitoring for

. terrestrial operational impacts, we question why it is necessary to include such a low-key program as

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- is ne[of the operating license and why NRC feels it cessary to specify a methodology. As part of g the operating license there is the possibility that gh - certa,:.n meaningful, scientifically valid modif.j. cations of .the monitoring program could not

, ,' be made without first going through the formal license modificat; ion process including possible publig hearings and Federal Register notice. This

' , process is unnecessary and represents an excessive regulatory burden for both the Commission and the Cospany. Therefore, -it- is recommended that this monitoring program .not be included as part of Appen@ix B of the operafiii~g license.

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...- *  ; 4 Uni'on Electric is in the process of developing a

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moliitoring program that will adequately measure Tmpac(1.s Unit caused by operation of Callaway Plant .- ~

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- This prograin will include procedures for repo~rQng to NRC any occurrence of important events that-potentially could result in significant environmental impact causally related to plant$~ E- --

., operation. -

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M 13..PChapter 5. Table 5.4. Pace 5-31, 5 All sample  ;

quantit;.es are sub]ec* td change depending upon analysis techniques utilized in the future. .

g 14,i Chapter 5. Section 5.9.4.3. Pace 5 The second

_ paragrapn under site Features states that activities within the exclusion area are limited to

, ., agricultural activities. Our, intent is that no 1 developments attracting uncontrolled public l activity in or encouraging casual.public entry into the exclusion area be permitted. This does not  ;

, limit the use to agricultural activities.

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g 15. Chapter 5. Section 5.9.4.3, Page 5-41, Emergencv Preparedness - The Callaway Plant Radiological

~ Emergency Response Plan is complete and a conclusion has been made by NRC that the plan meets the planning standards of 10 CFR 50.47(b) _and the requirements of 10 CFR Part 50, Appendix E (3UREG-0830, Safety Evaluation Report related to the operation of Callaway Plant, Unit No. 1, October, 1981, Appendix F).

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• l g 16 - Chapter 5, Section 5.9.4.4, Page 5 In the .

third paragraph, Item 1, Columbia is 30 miles from ,

._ the s.ite rather than 15 miles as stated.

- If you have any questions, please do not hesitate to contact us. 4 4

very truly yours,

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