ML19311C720

Public Watchdogs - NRC 2.206 Petition Exhibits 1-38, Part 20

ML19311C720
Person / Time
Site:	San Onofre
Issue date:	09/23/2014
From:	Public Watchdogs
To:	Division of Decommissioning, Uranium Recovery and Waste Programs
Cruz Z
Shared Package
ML19311C699	List: ML19311C700 ML19311C701 ML19311C702 ML19311C703 ML19311C704 ML19311C705 ML19311C706 ML19311C707 ML19311C708 ML19311C710 ML19311C711 ML19311C713 ML19311C714 ML19311C715 ML19311C716 ML19311C717 ML19311C718 ML19311C720 ML19311C721 ML19311C722 ML19311C723 ML19311C724 ML19311C725 ML19311C726 ML19311C727 ML19311C728 ML19311C729 ML19311C730 ML19311C731 ML19311C732 ML19311C733 ML19311C734 ML19311C735 ML19311C736 ML19311C737 ML19311C738 ML19311C739 ML19311C740
References
Download: ML19311C720 (45)

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11-16 The terms "minimal," "acceptable," and "not significant" relate to a judgment made regarding the predicted impacts of the facility on the environment. A possible effect ts termed insignificant if, for example, the impact is predicted to only occur locally in a nonunique, or widespread, population community of organisms, etc. When it is not possible to reach a firm conclusion regarding the significance of a projected impact (even under worst-case conditions), mitigation is either recommended immediately or an extensive monitoring program is stipulated.

The study report concerning use of the heat treatment process addresses a matter beyond the NRC's purview in accordance with the federal Water Pollution Control Act Amendments of 1972.

Thus, while the NRC must evaluate and consider the environmental impacts attributable to use of such heat treatment process, such consideration is limited to a determination of the impacts and their significance in terms of the cost-benefit analysis for this facility; any changes in the system or its use must be directed by the California Regional Water Quality Board and/or the Environmental Protection Agency. The applicant will provide the study report directly to those agencies, as well as to the NRC, when available.

For the foregoing reasons, we do not believe that the report itself is an integral part of the Draft Environmental Statement. Of course, as noted above, the NRC will consider the impacts attributable to the heat treatment process in the Final Environmental Statement as stated in Section 5.4.2.1. In this connection, the staff considers it to be no different than any other report of a study or analysis performed by a license applicant in support of its application. The staff is aware of no legal requirement which would give the report independent status such as EPA suggests, tn the context of the NRC's licensing review. The status of this report in terms of the determination to be made under Section 316(a) of the FWPCA is a matter left to that agency charged with making that determination.

Sect. 5.4.2.2 concludes that significant impacts are unlikely, even under worst-case conditions.

The effluent characteristics of SONGS must conform to the State standards prevailing at the time of the operation of the facility.

It is not the purpose of the staff analysis, as provided in the DES, to make rulings regarding statutory requirements, but rather to assess the impacts of proposed operation. In making this analysis it is not assumed that standards will be satisfied and, therefore, the environ-mental consequences of any violations resulting from the proposed plant operation is inherent in the staff's conclusions.

11.10 NEED FOR PLANT (MIL, A-45)

Table 2.2 of the FES relates to projected population growth within 16 km of the San Onofre site for the period 1976 to 2020.

Tables 8.3 and 8.4 are related to the electrical growth projected within the service areas of Southern California Edison Company and San Diego Gas and Electric Company for the periods 1976-1985. The combined annual growth rates for peak demand and energy for this period is 4.3 and 4.6%, respectively.

Population within 16 km of the site does not necessarily reflect electrical growth in the applicant's service areas.

11.11 SEISMOLOGY (EPA, A-40; MIL, A-45; RJW, A-49)

The staff's review and evaluation of the geological and seismological aspects of the San Onofre Nuclear Generating Station Units 2 and 3 is presented in the staff's Safety Evaluation Report, published December 1980. Included in the SER is a discussion of the potential for and nature of seismic activity at the site and its vicinity as well as of the design and construction measures taken by the applicants to prevent damage to the facility and its component parts.

The staff considers that its assessment of the environmental impact of postulated accidents presented in Chapter 7 adequately accounts for the consequences of any accident caused by seismic activity. This chapter discusses the consequences of accidents regardless of cause.

Regarding the potential for affecting water quality and for offsite radiological contamina-tion, to the extent such impacts are the result of airborne transportation of radionuclides, the consequences are included in the discussion in Chapter 7. The liquid pathway, because of the hYdrological environment at the site, does not present a viable transport mechanism which could impact water quality or would otherwise result in offsite radiological consequences.

11-17 11.12 URANIUM PRICES (RJW, A-49)

The cost-benefit analysis in the DES is based on 1976 data, at which time the price of uranium was $18.10/kg ($40/lb) U3 08

• Presuming SCE used the then existing U3 08 price in their cost-benefit analysis for SONGS 2 and 3, they would be using a price that reflected the rapid increase in prices in the 1973-1976 period. To extrapolate future prices on the basis of the 1973-1976 price increase would be erroneous in that uranium prices decreased 9% in real terms during 1977. Thus, it is inappropriate to consider a price escalation which is not even valid for a 5-year period of the uranium market for a cost-benefit analysis which covers the 30-year lifetime of a reactor. It would be just as appropriate (or inappropriate) to extrapolate the recent 9% decrease in uranium prices for use in the analysis. Many factors must be carefully investigated to estimate future uranium prices, and simplistic methods can-not be justified.

Long-term contracts are not generally tied to market prices at time of delivery or a 7% per year escalation, whichever-is greater, based on current data. In fact, most long-term uranium requirements are not under contract, so it is inappropriate to make any generaliza-tion about the nature and terms of those contracts. Even if future contracts were based on the greater of market price or 7%/year escalation, it does not follow that fuel costs will increase to prohibitively high levels. If future prices were related to market prices and market prices do not increase substantially (it has not been established that they will),

then the uranium cost component of fuel costs would not increase very much. And, if prices increase at 7%/year, they would probably just be keeping pace with inflation and thus not be relevant to a constant dollar analysis.

The cost of purchasing uranium is only one component of nuclear fuel costs, the other being, for example, separative work, UF 6 conversion, and fabrication. Thus, overall nuclear fuel costs would not escalate in proportion to the increase in uranium prices.

11.13 ACCIDENTS (HEW, A-10; MIL, A-45; RJW, A-49)

These comments were addressed to the Accident Section (Section 7) published in the Draft Environment Statement (DES), dated November 1978. In January 1981, the staff revised Section 7 and issued it for comment as a supplement to the DES. The January 1981 Supplement is included as Section 7 of this Final Environmental Statement (FES). The staff believes FES Section 7 is responsive to those accident comments previously addressed to the DES.

(FHA, A-53)

Part 50.13 of 10 CFR does not require a licensee "to provide for design features or other measures for the specific purpose of protection against the effects of (a) attacks ... by an enemy of the United States ... or (b) use or deployment of weapons incident to U.S. defense activities." The staff recognizes that acts of war would likely produce severe environmental impacts wherever they might take place.

{RJW, A-56, A-59)

The supplement is based on site-specific data, as described in Section 7.1.4.2. While not specifically stated in the supplement, U.S. average, year 2000 estimated, population data were used beyond 560 km (350 miles). The site-specific meteorological data used included lid heights to account for vertical mixing characteristics.

(RJW, A-58)

Both the staff and SAl used very similar methodologies in their analysis, and they both represent improvements over the Reactor Safety Study. There are some differences, however, in assumptions and data used in each study that lead to the variabilities or uncertainties that are inherent in such calculations. These differences appear in:

0 accident release characteristics - probabilities and magnitudes; 0

emergency response assumptions; 0

meteorological data; and 0

demographic data.

Specific consequence values that commentors quote from the SAI-OES report cannot be directly compared with those reported in the staff's draft supplement since the former are not associated with specified probability levels while the latter are. The staff has not made a

11-18 detailed comparison of the results of the two reports but judges that they are in agreement within the estimated bounds of uncertainties and assumptions associated with the current state of probabilistic risk assessments.

(RJW, A-58, A-59, A-60)

The studies of the San Onofre site relative to earthquake potential is extensively discussed in Section 2.5 of the Safety Evaluation Report (NUREG-0712, December 1980). The staff's position is that the safe shutdown earthquake is correctly determined for this site. A discussion of natural phenomena as initiators of accidents has been added to Section 7.1.4.2.

(RJW, A-58, A-59)

If Unit 1 had a meltdown, the staff agrees that it would impact the operation of Units 2 and

3. However, the ability to shut down both units following an accident at Unit 1 would not be impaired.

(RJW, A-59)

The reactor vessel was installed with its reference mark 180 degrees from the desired location.

As discussed in the Safety Evaluation Report (Section 5.3.4), the flow skirt, which is not symmetrical, was installed in the direction to agree with the vessel's orientation and pro-cedures for fuel handling, which reference the vessel orientation, were modified. No rewiring was necessary as a result of the error.

(RJW, A-59)

The dewatering well cavities were discussed in the Safety Evaluation Report in Section 2.5.

It was determined that there would be no impact on seismic Category I structures.

(RJW, A-59)

The beach visitors were specifically addressed (e.g., Sections 7.1.3.2 and 7.1.4.6 and Table 7.1.4-5).

(RJW, A-60)

The staff has concluded that acts of sabotage, as initiating events, do not contribute significantly to the probability of accidents due to the Commission's safeguards requirements.

Section 7.1.4.2 has been modified to discuss this point.

(RJW, A-60)

While it is true that one-half of the population of the State of California lies within 160 km (100 miles) of the San Onofre site, the staff does not consider this to be a relevant observation. The staff's focus on demographic data for site suitability and site comparison purposes has been traditionally within 80 km (50 miles) of plant sites.

The discussion in Section 7.1.4.3 indicates that most of the accident impacts occur within 50 miles of the site. The staff has compared the total population within 50 miles of the site with the total population within 80 km (50 miles) of other nuclear plant sites and has found that San Onofre does not have a uniquely large population. Moreover, it is important to note that, as stated in Section 7.1.4.2, the site-specific population projected to the year 2000 both in magnitude and distribution has been used in the calculations through all regions to 160 km (100 miles) and beyond. Those fractions of the consequences which take place up to 16, 48, 80, 160. km (10, 30, 50, 100 miles) or beyond, are accounted for in the results presented. The site does not have a uniquely large population contained within any of the above mentioned distances.

(RJW, A-60)

The San Onofre Units 2 and 3 at 3390 MWt are typical of the upcoming generation of reactors.

The power level of each plant was specifically used in determining the inventory of the core for the risk calculations. Salem 1 is presently operating at a comparable power level of 3338 MWt.

(RJW, A-.60)

The production of farm and dairy products is specifically considered in the calculation.

Differences among the states (and countries) potentially impacted are taken into account.

11-19 (RJW, A-60)

The impacts within the Mexican borders were included in the evaluation. The method of determination of data for Mexican agricultural products is discussed in Section 7.1.4.2.

Although not explicitly stated, the population within the Mexican border was included on a site-specific basis out to 560 km (350 miles) from San Onofre.

(RJW, A-61)

The staff recognizes the potential efficacy of drugs in mitigating consequences of offsite exposures. However, in the case of potassium salts of stable iodine, the staff does not require provision for distribution to the public.

(RJW, A-61)

Section 7.1.4.4 discusses that the condemning of foodstuffs was specifically considered and the interdiction of contaminated property " ... until it is either free of contamination or can be economically decontaminated" was assumed.

(RJW, A-61)

The subject of filtered venting systems for the containment is being addressed in rulemaking, as discussed in NUREG-0660, 2.8.8. The whole subject of TMI-2-related improvements and the fact that no credit would be taken for them is discussed in the last paragraph of the section cited.

(RJW, A-61)

It is the staff's position that such a "worst case accident" is much too remote and specu-lative to require analysis under NEPA.

(UCS, A-63)

The staff believes that its treatment of a multiplicity of possible accident scenarios represents a reasonable and appropriate implementation of the guidance provided in the Commission's Statement of Interim Policy.

(UCS, A-63)

The probabilities of occurrence of releases in the nine categories are explicitly given in Table 7.3 and the probabilities of occurrence of specific levels of environmental con-sequences are given in Table 7.4. The staff judges that this is within the intent of the quoted part of the sentence and the additional directive in the Interim Policy which states:

"The environmental consequences of releases whose probability of occurrence has been estimated shall also be discussed in probabilistic terms." See also the staff's answer to Joint Intervenors RJW, A-58.

(UCS, A-64)

The staff has presented a measure of individual risk in Figures 7.7 and 7.8. Table 7.4 and its associated figures and Table 7.5 provide group information. The discussion of relative susceptibility of various sub-groups of the population is given in Section 7.1.1.3. The staff judges that this conforms to the further directive that the discussion be " ... in a manner that fairly reflects the current state of knowledge regarding such risks."

(EPA, A-66)

The Supplement is a replacement for Chapter 7 in the existing Draft Environmental Statement for the Operating License stage (November 1978). It is not a replacement for the accident sections of the Construction Permit stage Environmental Statements of 1973.

(EPA, A-66)

Nine tables could have been provided to show the impact contributions of the nine categories.

It is the staff's judgment, however, that the summary table, reflecting sums of the contri-butions from all of the categories, is sufficient. Information regarding the relative contributions of the release categories is available in the Reactor Safety Study, WASH-1400.

11-20 (EPA, A-66)

The Design Basis Accidents are included because they are used in the Safety Evaluation Report to assess the adequacy of the performance of certain engineered safety features. In the SER, the DBAs are compared to the suitably small fractions of 10 CFR 100 for those accidents that are. considered likely (infrequent accidents).

(EPA, A-66)

The DBAs are judged not to be significant contributors to environmental risks and have not been subjected to the same kind of probabilistic analysis as the more severe accidents that are treated.

(EPA, A-66)

The staff believes that it is more informative to discuss the environmental risks associated with accidents separated from those attributable to normal operations. Both may be found in the Final Environmental Statement. Risks associated with the operation of both Units 2 and 3 are, to a first approximation, the sum of the risks associated with each unit individually.

(EPA, A-67)

We agree certain biological changes in children and adults may be detected occasionally at doses as low as 10 rem (e.g., slight, temporary reductions in circulating lymphocytes).

However, at doses of 25 rem or greater, such effects become measurable in nearly all exposed persons. In addition, although such changes have no physiologically significant impact, they can be clinically measured. We selected 25 rem as a point above which potentially serious effects due to radiation exposure (e.g., prodromal vomiting) become apparent to physicians and a point below which no difference between exposed and unexposed populations is apparent in terms of latent cancer incidence.

(EPA, A-67)

The NRC State liaison Officer has informed us that the Region IX RAC has completed its review of the local plan~ for the environs of San Onofre. The licensee has transmitted to the NRC copies of emergency plans for the following:

San Onofre, San Clemente and Daheny State Park and Beach Areas San Juan Capistrano City Camp Pendleton Orange County Unified San Diego County Interagency Agreement between San Diego County, Orange County, City .of San Clemente, City of San Juan Capistrano; Marine Corps, Camp Pendleton; State Department of Parks, Pendleton Coast Area.

The staff preliminary review of these documents affirms its judgment that the plans are, in fact, in an advanced stage of development even though they have not been submitted for formal review. A full-scale exercise for the San Onofre site and its environs is scheduled for May 13, 1981.

(EPA, A-67)

The NRC staff Safety Evaluation Report, dated February 1981, states that the San Onofre onsite emergency plan, when revised in accordance with the applicant's commitments, will provide an adequate planning basis for an acceptable state of emergency preparedness, and will meet the requirements of 10 CFR Part 50 and Appendix E, thereto. This is still the staff's conclusion.

The SER states that the plan must be revised to address the final criteria and implementa-tion schedule for the emergency centers and their functions, emergency manpower levels, and upgraded meteorological program, and to address the impact of earthquakes on emergency plans for the site and its environs. The NRC staff position is that the emergency plans are sufficiently complete to justify the estimates of parameters used in the consequence model.

11-21 It is true that the State of California does not use the U.S. EPA Protective Action Guides (PAGs). The State of California has elected to base its Protective Action Guides on the concept that no member of the general public should receive more than 500 millirem per year.

The emergency plans of the local authorities in the environs of the San Onofre plant have followed the State's guidance. This guidance is more conservative than the EPA guidance, i.e., protective actions would be recommended at a lower projected dose. Consequently, it is reasonable to expect that if protective *actions were to be taken at a lower value of projected dose, then exposures would be reduced.

(EPA, A-67)

The figure has been revised to present a more meaningful directional risk. The meaning of the new figures is discussed in Section 7.1.4.6. The scale of the figures has been expanded (a smaller distance from the plant shown) and it has been redrawn in an attempt to improve legibility.

(EPA, A-67)

Standard methods for estimating costs of reactor building cleanup and decontamination and replacement power for the economic risk calculations are under development. Reasonable estimates of plant decontamination and replacement power have been made, however, and are discussed in Section 7.1.4.6. Staff conclusions on the benefit cost balance are reported in Section 10 of the FES.

(SCE, A-68)

It is clearly stated in the third paragraph of Section 7.1.4.1 that the evaluations of the limiting faults and infrequent accidents are used to implement the provisions of 10 CFR 100.

The conclusions regarding siting are in the Safety Evaluation Report and its supplements.

(SCE, A-69)

Section 7.1.4.2 states that the estimates of the consequences may have as large error bounds as for the probabilities. Any uncertainty in the fractions of nuclides released contributes to the error bounds on the consequences, as well as uncertainties in the meteorological and health effects models. The subject of releases of certain nuclides, mainly the radioiodines, is presently under review by the staff.

APPENDIX A COMMENTS ON DRAFT ENVIRONMENTAl STATEMENT

Table of Contents u.s. Department of Agriculture, Science and Education Administration ..................................... A-2 U.S. Department of Agriculture, Economics, Statistics and Cooperatives Service ****************************** A-2 Department of Housing and Urban Development ************************ A-3 Department of the Army, Corps of Engineers ************************* A-3 U.S. Department of Agriculture, Soil APPENDIX A Conservation Service ............................................. A-4 Federal Energy Regulatory Commission ............................... A-4 COMMENTS ON u.s. Department of the Interior ************************************ A-5 DRAFT ENVIRONMENTAL STATEMENT Rourke and Woodruff Law Offices ***********.************************ A-6 r

- U.S. Department of Commerce ........................................ A-7 Department of Health, Education, and Welfare *********************** A-10 Southern California Edison Company ................................. A-11 U.S. Environmental Protection Agency ............................... A-38 Mr. Marvin I. lewis,., ............... , ............................. A-45 Southern California Edison Company ................................. A-45 Richard J. Wharton ................................................. A-46

UNITED STATES DEPARTMENT OF AGRICUI.TURE SCIENCE AND EDUCATION ADMINISTRATION U.S. DEPARTMENT OF AGRICULTURE OPFICI! OP 'n<E 0111'1./TY OIA&CTOR FOA AGFUCIJLTUAAL A!SEARCH liCONCMICS. ITATII'TICS, and COOPI!RAnVU SIIMCI!

WASHIMClTOH, O.C. 202tO w-~o.c.-

Subject:

NRC Draft EnviromHntal Stata~~U~D.t December 8, 1978 To: William ll. Regan, Jr.

U.S. Nuclear Regulatory Collllllisaion Erxltironmental Projects Branch 2 Division of Site Safety and Env. Analysis Waabingcon, D.C. 20S55

SUBJECT:

Draft Environmental Statement We have reviewed the draft eaviroUIICltal impact atatlliii8Dt 1111titled TO: Willima H. Regan, Jr., Chief San Onofre Nuclear Ganerating Station, Units 2 and 3, Southern Califomia Environmental Projects Branch 2 Edison Company, San Diego Gas & !Uectric Company, dated November 1978. Division of Site Safety and EnviroJUDental Analysis We have uo em=eucs to add to the evaluation provided by your staff.

do sppreeiate the opportullity of tevieving chis atat..,ent.

We u.S. Nuclear Regulatoey Collllission Washington, D.C. 20SSS

,;;:"(?.Z::.,.c.,-~- We have no COliiiiiOilts on the Draft Environmental Statement

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ll. L. 1IAlUtOWS Acting Deputy Assistant Adm1niatrator related to operation of San Onofre Nuclear Generating Station, Units 2 md 3 by Southam Califomia Edison and San Diego Gas md Electric C~anies.

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P.O. 84¥ JIOOj S*n ftaact*eo. t::.-.'.u;~ ')t.\01 December 19, 1978 362..0 IS "fil.'tlfi..Y ~~ ... " ":'01 S?LE!l-E 2 January 1979 MJ:, Win. H. ~tegan, Jr., Chief en~iro~ntal Projects Branah 2 u.s. Nuclea>: R~l&t.Ol:)' COIIlalia&ton Dirision of Si.ta safety and li:ltvi.t<ltlll>>ntal l\lllllysis l.t.tentton: Dtucccrr, O:l.Vidon of Site Safety On~ted States Nuclear Rsqulatory C~ssion and Envtroll!llental Anlllysh l'luhinqton, o.c. 2DS55

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Subject:

San Qnofr~ Nuclear Generating Station trnits 2 an<) 3 Tllis is in respo~tse to a lett.>l: fl:Olll. your office da.ted 30 llovall:t>"r Draft tn~ironmental Statmuent 1!}78 whiah r&<~.uested reVi"" and COI!It!lents on the Or"'ft. Snvironi!Mitltal Docket Nos. S0-361 and 50-362 :tmpact Statement tor tha San <mofn GeneratintJ Station, llnits 2 and 3, pt't>posed lly Southern C1l.ifoxnia Edison Company and San Diego Ga.<

We have nview..d the caption4d document and have and flectrio Company.

> no eomm.ertts to offer on it. ~ere is no need to 'l'he ptepo5ed plan dou I:'J:>t. =nflic:t with el<ist:inq or authodz.ad plans w

send this office a copy of tne Final Environmental of the Cotps of Engine""". "'" have no eollll!ll!nts on the envirorunental statement for the p~e~d ~ction.

Statement. Thank you for the oppol::t\IDit:1 to reviow and comment on this statement.

Sincerely yours,

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UNITED STATES DEPARTMENT OF AGRICULTURE FEDERAL ENERGY REGULATORY COMMISIIION

. SOIL CONSERVATION HlWlC£ WASHIH<JTON, C.C. 20426 2828 Chiles Road, Davis, CA 95616 IN IIIJtiiiLY IIID'IDt TOt January 17, 1979 January 9, 1979 William H. Regan, Jr., Chief Enviro~~meneal Projects Branch 2 Division of Site Safety and

• Environmental Analysis United States Nuclear Regulatory Mr. William H. Regan Comm1seion Division of Site Safety and Washington, D. c. 20535 Environmental Analysis Docket No.: SD-361 Nuclear Regulatory Commission and 50-362 Washington, D. c. 20555

Dear Mr. Regan:

We acknowledge receipt of the draft environmental statement for San I am replying to your request of November*30, 1978 to the Onofre Nuclear Generating Station, Units 2 and 3, Southern California Federal Energy Regulatory Commission for comments on the Draft Edison Company, San Diego Gas & Electric Company in San Diego County, Environmental Impact Statement for the San Onofre Nuclear Station California, that was addressed to USDA Soil Conservation Service on Units 2 and 3, California. This Draft £IS has been reviewed Nav.,..ber 30, 1978, for review and c'""""'nt. by appropriate FERC Staff components upon whose independent evaluation this response is based.

r.... We have revieved the above draft and have the following c"""""nts.

1) Provisions for erosion control and water management during The staff concentrates its review of other agencies' environ~

mental impact statements basically on those areas of the electric conscruction as well as conservation treatlilent of disturbed areas power, natural gas, and oil pipeline industries for which the following construction ware inadequately addressed. We suggest t:hat Commission has jurisdiction by law, or where staff has special an erosion control plan be developed to adequately address the erosion expertise fn evaluating environmental impacts involved with the hazard both during and following construction. proposed action. It does nat appear that there would be any significant impacts in tnese areas of concern nor serious con~

2) Approximately 10 ac:.;es of prime land will be lost to access roads flicts with this agency's responsibilities should this action be and transmission ta'Wers. Mitigation or projected impacts from this loss undertaken.

'Were not adequately discussed. l<e suggest further discussion in the staCil!lle1lt to address the pri111e land issue. Thank you for the opportunity to review this statement.

We appreciate the opportunity to review and calll!lleilt on this proposed Sincer:!ly, project.

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Sincerely,

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vJacR M. Heinemann

~~..,:. a/.;t.J FRA.'iC!S c. H. LUM Advisor on Environmental Quality State Conservationist f\Qo?-

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.<5it::ff,:/ WASHINGTON, D.C. 20240 Cultural Resources We are pleased that the NRC staff has directed the applicant to JAN 1 G 1979 consider historic, archeological, and Native American cultural*

In Reply Refer To: resources in its planning process. We understand that existing ER 78/1161 and possible new t~ansmission corridors will be surveyed for such resources~ However; we strongly urge that the applicant allow enough flexibility in its planning to actually take the results of these surveys into account in its final placement of Mr. William H. Regan, Jr. tower bases, access roads, and proposed substations. This would Chiaf, Environmental Projects Branch 2 include allowing the State Historic ?reservation Officer enough Diviaion of Site Safety and time to properly evaluate the surveys results and make appropriate Environmental Analysis recommendations. In addition, any nev land used for. material U.S. Nuclear Regulatory Commission storage or other project activities outside the transmission Washington, D.C. 20555 corridors should also be checked for cultural resources.

Dear Mr. Regan:

We hope these comments will assist your efforts in preparing the final environmental statemenr.

The Department of the Interior has completed its review of the draft environmental statement for San Onofre Nuclear Generating Station Units 2 and 3. We have comments in only two areas of our jurisdictional concern as set forth below.

f t.11 Recreation Resources De~ As:!~ta!lt The discussion of recreation impacts states that restrictive use of the beach area wa* unanticipated at the time issuance of the construction permit was being considered. Since no explanation is given, it is unclear to us how such a significant impact, the loss of recreational and scenic open space, could have been overlooked during the earlier planning stages. The final statement should disclose the reasons which nov require restrictions upon beach use.

Al~hough there ia nov recognition of the impact, we sea no attempt being made by the applicant to mitigate tho loss of recreation space and opportunity. With respect to the scenic quality of the area, we find the intended plan to construct an eight foot chain-link fence extending over three-fourths of a mile along the beach quite objectionable. Design of the walkway deserves

~ueh more attention. Given the fact taat this stretch of beach is rather removed from the developed portions of the state park units and therefore receives minimal use and given the 1cenic nature of the beach area and bluffs it would certainly seem more pref~rable and pe~haps sufficient to consider posting the area as to ita rest=ictive use. If a barrier is still needed, a more aesthetically sensitive, light railing ~ay best fulfill the need to restrict access. /'

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• uu..onc4

• JI******,.,..7 fC&.CCCjlltCIIt i'tf""t .;, ...

of their ener8)' requirements from SCE. Anaheim and Riverside have agreements with Nevada Power Com?lllly wherein eacfl City purchases economy non-firm energy JtOeCitT ""I,.AYCIC from Nevada Power Company. These agreements wiU expire by their own terms O.JUitiC'- 11* *,.ACUH in 1930. Anaheim and Riverside do not currently own any generating resources.

lllfi1JllrY 19, 1979 In 1973 Anaheim's peak demand was 338 megawatts. The estimated peak demand for 1973 was 39~ megawatts. Durlns 1978 Anaheim purc::llased two billion kilowatt United States Nuclear Regulatory Cammmlon hours of energy. For the period 1979 throuzh 1990 it ls estimated the peak demand Washinaton, D. C. 20"' for Anaheim wllllnc:rease In diff~ amounts. The smallest amount of Incntase for electrlc:al demand In any year during that period is estimated to be 3.1 percent Attentlom Director, Division ot Site, Safety and Environmental Analysis and the highest amount of Increase for any year ~.ll percent. lt ls also estimated for the same period of tlme that energy requirements for Anaheim will lnaease Gentlemen: with the lowest estimated annual. ~!~crease being 3.6 perc:ent and the highest est!*

mated annual .Jnc:reasa belns '*0 percent.

Pursuant 10 the notice pub.IJ.shed In the Federal Resister with respec1: to comments on the 011111: i!.rwlrcnmental Statement (DES), the Cities ot Anaheim and Riverside, In 1978 Riverside's peak demand was 27S megawatts. 1be estimated peak demand Califoml4 wish 10 submit the followlns comments. for 1978 was 260 megawatts. Durlns 1978 Riverside purc:hased over one blllion kUowatt hours of energy. For the period 1979 through 1990 It Is estimated the Anaheim and Riverslde beUeve the !'lnaJ Environmental Statement !Pt!S) should peak demand for R.iverslde will lnc:rease with the smallest annuatlnc:rease to be be amended In Seet1on ll, entitled "Need for the Station", 10 reflect probable owner- ~.0 percent and the highest annuallnerease to be 5.(J: perc:ent. lt Is also estimeted ship by the Cities of a portion of Sou1:bern Califoml4 Edison Company (SCE>, a~ for the same period ot tlme"that the energy requltements for Rlvemde will lnereue Interest In Units 2 and 3. with the lowest annuallnc:rease to be ~.o percent and the highest annua.l lnaeasa to be '*~ percent.

1be AllPiicutts and Anaheim and Riverside, entered ln10 a Letter Agreement dated November 1, 1977 wi1ldllncorpora.ted other prcpost!d ~ents, lnc:Judlns a Partld* The acquisition of an ownership Interest In Units :Z and 3 by Anaheim and Riverside

! paticn A&reement whfcfl provides for Anaheim to ao:!Uire 1.66~ of SCE's liO~ In-terest In Units 2 and 3, and for Riverside to acquire 1.7996 of Edison's S0\16 interest ln Units 2 and 3. The Lett<<' Agreement was entered Into by the Parties because does not cflanse the c:oncluslon that the Units are needed to meet the e!ectrlc:al load served by SCI!, Anaheim and Riverside. The load forecasts of see Include the loads served by Anaheim and Riven!de. Therefore, whether you lnc:Jude the loads ot A.nahe1m and Riverside In the SCE forec:ast of loads or break them out a question was raised as 10 whether SCE or SOC&:E would lose the Investment tax credit with respect to its ownership share ot Units 2 and 3 due to Anaheim and and Identify them sep&rate!y, the need for the station Is the same.

Riverside, publlc: agencies, own1nz an undlvided interest In Units 2 and 3. The Letter Agreement further provides, however, tha't when this question Is satlsfaetarlly re- Very truly youn, solved In the oplnicn of eacfl party to said ~ent, the Participation Agreement atuched thereto '111111 be executed bY the Parties. ~v j{. ZtJ/at;;-

The Internal Revenue Service has Issued Revenue Rl.lllns78-263, whicfl holds that ALA.N R. WATTS unc:llv1ded ownership In property by exempt and IIOIM!lfempt entitles does not of Spe<:!al Counsel Itself cf1squallfy the portion ot the property owned by the non-exempt entity from Cities ot Anaheim and Riverside takJng Investment tax credlt with respect 10 Its share of sucfl property. ~loreover, SCf and SOC&:E recelved a private letter ruling, dated August 16, 1973 whidl holds with respect to San Onofre Nuclear Ceneratins Station, Units 2 and 3, that SC!

and SDG&:E will not lose Investment tax credlt with respect 10 their undivided In-

n terest Units :Z and 3 after the sale ot the Interest to Anaheim and Riverside. ARW:jm:D:ll Howt!Ver, that Private Letter Ruling contained langUage whldl SCE and SOC&! cc: Att<<ched Ustlng believe to be ambiguous and therefore on O<:tobar 27, 1!178 they filed a Request tor Clarification of the Private Letter R.ul.lng of Ausust 16, 1973. The Request for Clarlflc:ation ls still pending before the Internal Revenue Service, but we belleve it will be favorably ¥:ted upon In the next several weeks.

Anaheim and Riverside are omently, and have for some years, been wholesale (\ cP t--

c;~"o

'1901240120 \1 A

Mr. John Bury Southern Ca.Lifomla edison Company 224/j. Walnut Grove Avenue P;o. Box soo ~ ~ .

• i*

UNITID STATI!S DIJIIAATMENT OF COMMIUICI Rosemead, California 9Jno TIM! Aulatant !lllot'lltllry for Sclaftt:e *lid T..,.natogy Wllahington. D.C. <D2:l0 Mr. Mark Me<lford \...._,;/ 12021377- 4335 Southern California Edison Company 224/j. Walnut Grove Avenue P. 0. BoxSOO so- 3(c(

Rosemead, Calf!omia 926n January 22, 1979

'"3"2-Mr. Robert J. Pate U. S. Nuclear Regulatory Commwlon Director, Oivision.of Site Safety P. 0. Box ~167 and Environmental Analysis San Clemente. California 92672 U.S. Nuclear Regulatory Commission Washington, D.c. 20555 Samuel B. Calley, ~q.

David R. Pigott, ~q.

Dear Sir:

Chickering IX Gregory Three Embarcadero Center, This is in reference to your dra~t environmental impact Suite 2300 statement entitled *san Onofre Nuclear Generating San Francisco, CA. 94111 Station, Units 2 and 3, Southern California Edison Janice E. Ke!1", E$q.

Company, San Diego Gas & Electric Company. " The

3. Calvin Simpson, Esq.

enclosed comments from the National Oceanic and Lawrence Q. Carc:la, Esq. Atmospheric Administration are forwarded for your

$066 State Building consideration.

San FranciJco, Cali1omla 94102 Thank you for giving us an opportunity to provide these comments, which we hope will be of assistance to you.

T'...., Wm. H. Regan, Jr.

Environmental ProjectS Branch 2 Division of Site Safety and Environmental We would appreciate receiving lO copies of the final Analysis statement.

United States Nuclear Regulatory Commission Washington, 0. C. 20$" Sincerely, Richard J. Wharton, E$q, 46" Cass Street San Diego, California 92109 David W. Gilman Rober-t C. l.acy ctl....~~ Ql_.g~

Deputy Assistant ~~ry A

San Diego Cas &: Electric Company for Environmental Affairs P. 0. Box 1331 San Diego, Callfomla 92112 Enclosures from: Gordon G. Lill.--Natianal Ocean Survey Gerald v. Howard--National Harine Fisheries Ser1.*

Phyllis M. Gallagher, Esq.

Suite 220 61' Civic Center Drive West 5.t.nta Ana, C:ilitornia 92701 Gordon W. Hoyt Utilities Director P. 0. Box 32:22 Anaheim, CA. 92S03 Qoe~, \'

Everett C. Ross Public Utilities Director City of Riverside 3900 Main Street Riverside, CA. 92522 7 9 01 3 I 0 O'f7

flY\. I'I

~. ~ UNITED STATES DEPARTMENT OF COMMERCE

• ~}-.~ l} ~~~.L~!!~I E.';~~.n~c J!~~ Aemospheric Administration.

~ j ::*;, :- / ; .. ~~-~?$::;- . -

i OA/C52x6

~ U.S. DllPARTMI!NT 01' C'OMMI!RCII!

~

Natlenat OUania DJO.tA~ Adlnlfl ...

NctfloriQI Mall"* Plohorioo s.mc.

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blwtd, Callfomla 9tlr.l' TO: PP - Richa1JI L. Lehman ...- Date January 8* 197 9 FSW33/JJS FR<Jf: ./:,J..,. -~- /} d.t OA/Cxl - G<ifdOn G. L1l1 To t £t.Off1ce of Ecology and Conservation

SUBJECT:

OEIS #781Z.06 - San Onofre Nuclear Generating Station, .zm'&l!.~

Units 2 and 3 .Tltru  : ff. ~nnetll~.M:s. Acting Dii"'ICtor, Office of H.t.b1t&t p~*'

~l!!. Aoo<~1 CIJ'

• __}-* '

The subject statement has been reviewed within the areas of NOS responsi- ,\. .. u /{l:f-' '

bility and expertise, and in terms of the impact of the proposed action on NOS activities and projects.

The following comments are offered for your consideration.

FI'Oll subjK :

f:,

R.r::t Y* ...;.;.,,

oEts Mo. 1su.OG - San onofrt Nuclear Generating Station. Units t and 3 (NRCl Section 2.3.1, Surface-water hydrology, has been found to be very adequate for the purposes intended. the authors are to be commended for the Tile SUbject. DElS whfdl IC!;III'fi1)1R1td .)IOUI' IHI'IIOrandUII Of lltcUibel' 8, 1978,

> thorough bibliography on the subject. has bien r'IYiawed by the National Marintt F1sheriu Service. The followin I CCIIIIII!nts are offered for' .)IOU,. consideration:

00 NOS concurs with and encourages the oceanographic monitoring program de-scribed ln Section 6.Z.2. We feel this program wilT ensure environmental sssc1f1c COmm!nts protection and help allay public concern.

s. Env1ro~ntal Effects of Station Operation 5.4 Env 1ron11111nta l Ifllllac:ts 5.4.2 Impacts on the aquatic: environment Page 5-26, paragraph 7, Kelp In paragraph 7 little information ts included doc:umentfng the importance of kelp ~ coastal commercial fis" species. Information available 1n the ta\1fornia Department of Ffsh and Game Fish Bulletin 139 (Quast, 1968}

provides SOII!t insight in that r.egard.

Data developed by Jay Quast of the then u.s. Bureau of Commercial Fl&heries, and included in that publfc:at1on, indicate that in his studfes he found more than twenty commere1ally important flsh speciea occurring in the kelp beds off southern CalifOrnfa. According to those $tudfes the relationship of many of those spec:fes to the kelp habitat was mort extensive than indicated by the ffnal sentence of the !Ubject paragr1ph.

_This should be refhcted fn ttte text of the final EIS,

6. Enviromaental llon1tor1ng 6.3 O~rational ~nftoring Programs

~.3,3 Aqu.tic biological monitoring liTERATURE CIT!D Page 6-7. paragraph 1 Quast. Jay c. t968. B. Observations on the food of the kelp-bed fishes.

The concept of continuing a kelp study program into the operational stage In: California Department of Fish and Game. Fish Bulletin 139, of SONGS is a good one. However. should those studies determine that Pp 109-142,

• S1gn1f1cant harm is occurring to that resource. then some method of compensation satisfactory to the National Marine F1sherfes Service would need to be developed. This should also apply to the studies being conducted on fish impingement at SONGS 2 and 3.

tf such measures are not adopted and ad~erse Impacts do appear the monitoring program may be merely documenting the demise of a valuable eoastal.resource,

10. Benefit-Cost Summary 10.7 Sum.&rY of Benefit-Cost Page 10-J, p!ragraph 3 Th! potential additional cost of compensating for loss of biological

.. resour~s due to the operation of SOHGS Z and 3 should be addressed.

I U)

.~ Page. -z- .lilt. f.IJ.i..UiJl11J Regan

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~

DEPARTME!'lT OF \"lEALTH. EOUC).TION. AND WELF).R£ PUBLIC HEAL.. TH SltAVIC:&;

fl'OOO .\NO DRUG AOMINISTRA'ICN S<.eti.on 6. Z. 5 Rad.i.oiag.i.ca.t .llon.i;ta.Wtg PltCgiUU!I FIOCXVU,.t.,£. '"AAVLANO 208!17 The p!<~p~na.i. monUoJLbtg plt0gl!ill7! p!te.le.n.ted .i.n Se.e.ti.on 6. I. 5 o6 .the

]ilJlJ.IAJI.fJ 25, 1979 cnv.i.tanme.n.tal. Repo'Lt i.J ade.qt.utte. 6al!. me.e..ting the. objec.U.ve. ~.ta.ted .i.n

.thi.J ~ec..ti.pn. Tlte. C1.4.tabli.Jhment a6 the. .tad.i.otag.i.C!ti. manUolW!g pJtDgiUU!I

'{l~U..olt .to 6.taJt.t a6 ape-tctti.ctt4 41tou.td p!<CV.i.cte the nec.C/.441lit!f da:ta. .to ve;Li.~y

.the e6oec.t.i.ve.tte.44 o6 .i.n-ptM.t c.on.Vtoti and tD p!<OV.i.de. ct44WUIItC~ .tM.t wu1e.te.c.te.d Jtctd.i.oaeti.v.i.ty wU.t. 11.0.t b!l.U.d.-u.p ht the e.nv-Utottmen.t.

til Mit. fJI.iLUam H. Regan, JJt.., Cit.le6 See.ti.ott 7 Env.UWMe.n.tal Zmpaet o6 Po~ Aee.i.de.nU Env.UWIUlltntat PM j eet6 '81r.attch 2 1U.vi.J.i.on a6 UU S¢6<<11 The. e.stimcz.te.d e.xpc<~Wte. o6 the. po~n tUi.:thht a so mi.l.e. .r.a.riU.J..! aa .the and Env.i-tolllfte11.td AntW,t4i.J plan.t ~ltown ht Table 7. Z camtO.t be. ade.qu.a.tdy evdwtte.d without ~ame.

u.s. Nuc..Ua!t Regula.talt.IJ Cc!llll4i..i.on .1peci.6.(.c. da.ta ht .the. .te.x.t on the .lau.tee. .te.Jtm. OIU:Jtau.t .1uch da:ta. .U i.J

&kt61W!g.ton, o.c. tasss pou.w.te .to ~umot. .dta.t the. e.nv.il!.oltllltntat COMe.q!Wic.e <14 a .te.JuU o6 <X da.\.1 8 ac.e.i.de.n.t c.otdd be. ma~t.e Jeve.Jte. .than i.nd.i.c.a..te.d ht .the. WtUI:.d.y OeAJt. ,Ill!.. Regan: event o6 4uch an ac.dde.tt.t.

The Oepclll.t!l!ent a6 Hu.Uh., Eduea.t.i.on, and WU6Me hcu. Jt.ev.ww.ti. the. The.Jte. i.J 11.0 ~I!! ht .thi.J o~e.eti.on 011. pl!.e.v.i.oiL6 ~ an em£1!9e.ttey h.u.Uh. 44Pec.b o~ 01!46.t EnvLtanmw.tat. sta.teme.n.t .te.Wed .to opeJr,O;t.i.on lt.UpaMe. pt.ann,iJtg tl1 tr!U<.ga.te. the. c.oMe.q!Wiee.s o6 an ac.e.i.de.n.t .that eauid a6 the San Ona~ Ge.n~ S:tt:tW!tt, Utt.i.U t and ;, Sau.tlteJt.tt i.mpac.t on the. a66<1.Ue. poputa.tian. A dJAc.u.u.i.on o6 the. aMall!Jement .that Ca.U.6alf.lf..ia &Ut.on Company and San tU.ega G40 and ~'r.i.c. Compr:uuf and hcu. been mack w.Wt S.ta.te. and !Dc.al. llJJ.thalti..ti..e.s o~hou.ld be. htc..lude.d .<n

=r..... hcu. the. 6o~ comen.t4 .to a66e~t. .thi.J .oe.eti.on*

= Sf.eti.Dn 5. s Rad.i.o!Dg.ic4t. 1mpcu;.t'4 The d.iAcu..\.\iDM .in paJtagJUt.pit 4, page. 1-Z an .the. Re.ac.t1111. Sa6<<!/ St:udiJ (CI/ASif-1400) l!.elctti.ve. tD d.iAC/.1.\.\i!Jn w.Wt EPA .U ou.t.dirte.d {79731, and Tile .btd.l.v.idu.a.t. doiJ e.1 a4 ~.ie.d ht Tabte 5. 3 <lite. <htce. .U WC/.1.\.\e.l o~c.cpe. o6 .the. 4.tud.rJ, and nc.t ~te.~u.tt&, o~ltou.td be Jte.-

Appt.nd.U 1, IOCFRSO de.s~n objeeti.ve.s and 4hou.t.d. 444Wte. cukqt.utte mave.d. ,llolte i.mpal!.tan:U..tj, a .1.ta.te.ment .ohotdd be. .i.nc..lude.d on the .tech-

~tt p!tO.teeti.on o5 the pub.Uc. 6oJt Mu.tine .te.t.e.a4e.s. Howeve.lt, ttic.al. Jt.evi..w all. eonc.lu..I.WM .that lutve be.e.n pltOv.i.de.d btJ EPA, othu U 4hou.t.d. be. .ucogn.ize.d ht .dti.J JJeeti.on .dta:t. 10Cl'Rt90 p!tOI!IU.tga.te.d Fe.dWU: age.ttde.s oil. buie.pe.ttden.t ~t.ev~. Sud!. ct .1.ta.tente.tt.t would be b!f EPA be.c:ame. e.66e.c:ti.ve. ht JllJlJ.IA/I.!f 1919. A 4-t:a.teme.n.t ~hordd be. he.l.p6u.l .in ac.c.ept&tg .the. low f.II.V.iJtonme.ntal. lti.J/1.4 aJ.ooc.i.o.te.d w.Wt the

.i.rtc..tJ.ui.e ~ .dta:t. SONG t and 3 wU.t. at.! o me.e.t .dti.J 4.tartda.td. po~ IWI.i.oiogi.t:al. ~.

!.t i.J ~teeognh:e.d .tha.t thf.ltf. <lite. mi!Jt!f va1t.iable.s .dta:t. &!6-lue.ttee oc.cupa.- On the. b44i.J a6 .thi.J ltev.WU .U i.J eattc..!uded .tha;t the. San OttOo*te. .Vu.c.lea.t

.ti.onal. f.XPC.\W<f. 3011. ct 4ped6U:, ptM.t. flowevu, .t Jte:c.ent A.tcm.i.c. Gvtl1.i!<l.tiHg s.t<X.t:tcn, ~ Z attd 3 c.an be ape,ta.ted tD mee.t eu."!.tC!tt

!ndu.l.:tlr.1.4.t. FaiU.Ult ~J:t;u/.y a& oc.cupa..t.i.onal. txpO.\W<e.4 Jhowe.d. ~alt. .:t PWR a .'tJt.d.ia.t<.cn p!<O:te.eti.on gu.idanee and p!tOV.i.de. ade.qt.utte. p!<O.te.e.ti.on al the

tD.t;z.t. o5 694 matt-ltf.nr pve yea/f. 44 a lt~p!<e.lmta.t

ive. PWR expo<~u.te. pa.tte.'Ot. )'Ub.Ue ;,uUJr. and 6a6 <<!/. .

Ao a C.CMf.ltvctti.ve. e.s.:Uma.te. the. p!<Oje.c..ted ~c.cupa..t.i.onal. e.xpcJu.te .(mpac..t a6 the. .two-w.i.t San 011.06/f.e S.tctti.on wou.t.d. be. 1400 man-Jt.e.m pe-t yeA/f.. S.inc.~ IJCU!t4' * .

(.' '" ij .* * '

The. 4UJ1'1/11JJr.!f a~ f.II.V.iJtoltli!VIbt c.oM.i.de.ltctti.an 6al!. Wl4ll.ium 5ue.t c.!lc.le.

<~"-' .in Table. S. 8 appea,t .to be. wi.th.in. ac.eepUble. ~n p.\a.te.eti.on

,~._ :<2'~-! -(r/

UmU:4. floweve.lt, .\ame. adclU.i.onal. explal!.a.t.i.an '-'li.th.in the. .te.s.t alt btJ Chllltee.s L. flle.ave.t '

ct 6aatna.te. i.J nee.de.d 6aJt .the. d.iApo.~.tl o5 .!>c.udb. !lt ~. the CcMu.ltant

.!.ta.te.ment .dta.t TRU and HUll wau.l:J. be. buJUe.d at a Fe.de.tctl Rtpol..Ualt.IJ 8wuuu.c. a& Rad.i.oiog-U:a.l flu.Uh.

4houid oe. mod.i-6-Wi .to .incLi.i!a.te. aLte.ltna.tive.s SoJt wpo<~al.

u.w.te ht .tlte event the Fe.de.tcte .te.pc.~.UOit.IJ i.J nc.t ope,tctti.cnal. when on .the.4e

~tequ.i.ted by plan.t apvea.ti.oM.

'J-t&~f:7\o

\ \

7902010 {(,5

ATTACBMEN'l'S Southern Cllllfornls Edison Company

,_ o..axeoo sa= A Figure 6.14, page 61 of Reference (5)

DoW WALHIJT' OJIIOVE AVJ:NIJC B Figure 6.29, page 76 of Reference (5)

J. H. DRAKE fltOSCMUD, CAUP'O"NIA 01170 February 2, 1979

.113*.,..._.UWe c Figure 6.34, page 81 of Reference (5) 0 Figure A-7, page A-15 of Reference (5)

E Figure 6.8, page 47 of Reference (5)

F NOAA Climatological Data, July 1975 Director, Office of Nuclear Reactor Regulation Attention: William H. Reaan, Jr., Chief G July 1976 Environmental- Projects !!ranch 2 .

Division of Site Safety and Environmental Analysis H April and July 1977

u. s. Nuclear Regulatory Commission Nashington, D. c. 20555 I July 1978 Gentlemen: J Air Temperatures at SONGS

Subject:

San Onofre Muclear Generatino Station K Del Mar Current Meter and Temperature Data, May-December 1978 Units 2 and *3 Docket Nos *. 50-361 and 50-362 San Onofre Area current and Temperature Data, May-August 1978 L

f In accordance with your reauest of November 30, 1978, the Southern California Edison Company and the San Diego Gas M Pages 103-106 of DES reference 8

& Electric company have reviewed the Draft environmental N Figure 1 Surface Isotherms for 0.0 knots Statement (DES) related to the operation of San Onofre Nuclear Generating Station, Units 2 and 3. Enclosed are 0 Figure 2 * *

• 0.1 comments generated from this review.

p Figure 3 0.25 Should have any questions or require clarification regarding these comments, please contact me. Q Reference (19)

Very ~Y yoqrs, R Reference (20)

/,.h/J{~ s

.. .:-;/7! ,<;A/ Reference (21)

T Temperature Data from References (8), (22), (23) and (24)

Enclosure

f u v

Reference (2)

Bottom (30') Water Temperatures at san Onofre, July and Aug. 1976-78

'190308025C.. C.d'J\' \ w l(

Pages 41 and 71 of Reference (16) and page 42 of Reference (17)

Revised DES Table S.l

'0 Y Revised DES Table 8.3 z Revised DES Figure 3.5

AA Reference (lJ BB (12) cc {13)

DD (14)

EE (18)

COMMENTS BY SOUTHERN CALIFORNIA EDISON COMPANY SAfl DIEGO GAS & ELECTRIC COMPANY ON THE DRAFT ENVIRONMENTAL STATEMENT RELATED TO THE OPERATION OF

r;::; SAN ONOFRE NUCLEAR GENERATING STATION, UNITS 2 AND 3 DOCKET NOS. 50-361 AND 50-362 PREPARED BY THE U. S. NUCLEAR REGULATORY COMMISSION OFFICE OF NUCLEAR REACTOR REGULATION

TABLE OF CON~

PAGE Comment 5-25 29 INTRODUCTION 1 S-26 29 Comment A-1 2 S-27 30 A-2 2 S-28 31 A-3 3 5-29 31 Comment 1-1 4 5-30 33 Comment 2-1 5 S-31 33 2-2 s 5-32 34 Comment 3-1 6 5-33 34 3-2 6 5-34 34 3-3 6 5-35 35 3-4 6 5-36 35 3-5 7 Comrnent 6-1 39 3-6 7 6-2 39 3-7 7 6-3 40 3-8 7 6-4 41 3-9 7 6-5 41 3-10 8 6-6 41 3-11 8 Comment 8-1 43 3-12 8 8-2 43 3-13 8 8-3 43 3-14 8 8-4 44 3-15 9 8-5 44 3-16 9 Comment 10-1 45 3-17 9 10-2 45 3-18 9 REFERENCE 46

P 3-19 10 I comment 5-1 11 5-2 11 c..J 5-3 13 5-4 14 5-5 15 5-6 16 5-7 17 5-8 18 5-9 19 5-10 19 5-11 20 5-12 21 5-13 21 5-14 21 5-15 21 5-16 22 5-17 22 5-18 23 5-19 24 5-20 25 5-21 26 5-22 27 5-23 27 5-24 28

SUMMARY

AND COI!CLUSIONS INTRODUCTION Comment A-1 The Draft Environmental Statement (DES) has been reviewed by (page iii, item 2) the Southern California Edison Company and the San Diego Gas &

Electric Company (hereinafter referred to as Applicants). The- DES states, "Each unit will produce up to 3q10 MWe and a net electrical output of 1057 MWe".

Comments resulting from this review are to identifY inaccuracies in the data or discussion and provide It should be noted that 1057 M\~e as stated in the applicants' clarification or correction. The comments follow the ER-OLS* and in the DES was calculated using the Turbine-organization and numbering in the DES and should be read in Generator (T-G) manufacturer's guaranteed output of 1127 MWe, conjunction with the referenced section. which corresponds to an NSSS output of 3266 MI-le, and an estimated in-plant consumption of 70 MWe.

However, when the NSSS is operating at 3410 Mlie, and the T-G is at the wide-open valve condition (normal operatin~

condition) the T-G output will be 11B1 MWe. Current estimates of in-plant consumption have been revised to 75 ~lHe.

Therefore, it is suggested that the net electrical output value be expressed as being in the range of 1052 ~~1e to 1106 MWe per unit when the NSSS is operating in the 3266 MWe to 3410 MWe range respectively.

• ER-OLS will be revised to reflect the range of 1052 MWe to

.r...

1106 MWe output per unit, in a future amendment.

Comment A-2 (page iii, item 3a)

The applicants do not agree with the conclusion reached by the staff on the possible destruction of at least a portion of the San Onofre kelp bed as a result of the thermal discharge from San Onofre Nuclear Generating Station. The assessment of impacts to the aquatic environment is invalid because of the-use of inappropriate data from the staff's numerical model. A reassessment of the impacts is needed using ambient temperatures from actual field data. Actual field data are appended to these comments. Using appropriate ambient tempera-tures in the assessment, the excess temperature from thermal plume predictions made by either the applicants or staff will not create adverse effects on the San Onofre kelp bed.

(Attachment T)

Comment A*3

1. INTRODUCTION (page iv, item 6(B)(2))

The preoperational monitoring program outlined in Section 6 1.1 HISTORY goes beyond the applicants* program approved by the NRC by letter dated July 6, 1978, and is apparently based on Comment 1-1 inappropriate predictions of impact to the San Onofre kelp bed. The operational monitoring program outlined in Section (page 1-1, paragraph 2) 6 is an extension of the preoperational monitoring program.

The operational environmental monitoring programs are under The net electrical output for each unit is in the range development for Units 2 and 3 Environmental Technical of 1052 to 1106 MWe. Refer to Comment A-1 for discussion.

Specifications (ETS) and will be submitted in the near future.

lit I

Ul

3. THE PLANT

2. THE SITE 3.2 DESIGN AND OTHER SIGNIFICANT CHANGES 2.ll METEOROLOGY 3.2.1 Plant water use 2.4.11 AtmosPheric dispersion Comment 3-1 Comment 2-1 (page 3-1, paragraph 2)

(page 2-~) Delete the words, "makeup to," in the second sentence.

The DES indicates that the onshore tracer test conducted by SCE substantiates the acceptability of data measured on Comment 3-2 the San Onofre onsite (bluff} tower for use in calculating atmospheric dispersion. However, the DES does not . (page 3-1, paragraph 3) consider the enhanced dispersion estimates derived *from the onshore tracer test results. Consideration should be The word, "makeup" should be corrected to "cooling," in the given to the enhanced dispersion estimates derived from second sentence.

the onshore tracer test results.

Comment 3-3 2.5 SITE ECOLOGY

=r 2.5.2 Aquatic ecology (page 3-1, paragraphs 2 and 3) en In the discussion of plant water use, the flushing of traveling bars and screens is incorrectly described.

Comment 2-2 Seawater will be used for the flushing of the traveling bars and screens, not fresh water.

(page 2-9)

Oceanographic data reports from the past have incorrect 3.2.2 Heat dissipation system consultant sources referenced. The first source in the list of three sources should be:

"(1) a thermal effects study performed jointly by Comment 3-ll Environmental Quality Analysts, Inc. and Marine Biological (page 3-1)

Consultants, Inc. in 1973 using data and results obtained from 19oll-1972 by Bendix Marine Advisors, Inc., and The discussion should also include a description of the Intersea Research Corporation." Seismic Category I ftuxiliary Intake*Structure of the circulating water system. The description or this design change can be round in Section 3.4.1 of the ER-OLS and Section 9.2.5 Of the FSAR.

Comment 3-5 2.3.1 Liquid Radioactive Waste Treatment System (page 3-1, paragraphs 4 and 5)

The seawater used for "cooling" has been incorrectly Comment 3-10 labeled "makeup." This error appears in the second sentence of paragraph 4 and the first sentence of paragraph (page 3-7, paragraph 7) 5.

The flashed steam is routed to the "third point heater",

not the "main condenser hotwell".

Comment 3-b Comment 'l-11 (page 3-1, paragraphs 5 and 6)

(page 3-8, Fig. 3.5)

The word "screenwell" should refer to the intake screenwell structure shown in Figure 3.3 and not the traveling The figure should be changed to reflect the correction screens. Lines 6 and 7 of paragraph 5 use "screenwells" identified in Comment 3-10. See revised Fig. 3.5 where "traveling bars and screens" are being described. (Attachment Z).

Also, in the second sentence of paragraph 6 "screenwells" is used ins£ead of *traveling screens* and should be corrected.

Comment 3-12 Comment 3-7 (page 3-11, line 1)

The discussion on steam generator blowdown is incorrect.

> (page 3-3, Fig. 3.2)

There are two steam generators for each unit, not four.

I Figure 3.2 has been revised by the applicants to include the design details of the Auxiliary Intake Structure (Comment 3-4) and show the elimination of the manhole on Comment 3-13 the velocity cap. The revised figure can be found in Section 3.4 of the ER-OLS, Figure 3.4-2. (page 3-13)

The discussion on the containment ventilat on svstem should Comment 3-tl include a description of the 2,000 cfm min -purge system.

The description of this design change can e found in (page 3-5, paragraph 1) Section 9.4.1 of the FSAR.

The seawater used for "cooling" has been incorrectly labeled "makeup." This error occurs on lines 2 and 5, and 2.4.1 Chemical Effluents should be corrected.

Comment 3-9 Comment 3-14 (page 3-5, paragraph 1) (page 3-16, paragraph 1 1 line 4)

The third sentence should read: The statement, "maintain a clean circulating water system,"

"To achieve the temoerature required to control should be changed to read, "maintain a clean condenser biofouling each unit has a recirculation and crossover system."

gate."

~**

Comment 3-15 3.2.6 Probable Maximum Flood Berm (page 3-16, paragraph 3, line 11)

The applicants will use a nitrite base compound or Comment 3-19 potassium chromate <K,CrOul as the corrosion inhibitor for the turbine and comportent cooling water system. The (page 3-23, line 1) statement in line 11, "will be treated with Nalco 39 to inhibit corrosion," should be changed to read, "will be The reference number for the letter to the NRC should be treated with a nitrite based compound or potassium chromate "5" not "4."

to inhibit corrosion."

3.2.5 Transmission Lines 3.2.5.1 SCE Transmission Lines Comment 3-16 (page 3-19, line 31 The reference number for the description of retrofitting should be "4" not "1."

f Comment 3-17

(page 3-20, Fig. 3.9)

An additional note should be added to the figure as follows:

"The drawing depicts the four-circuit structure that will be used by SCE. SDG&E will use a similar structure with five circuits."

3.2.5.2 SDG&E Transmission Lines Comment 3-18 (page 3-20, paragraph 1)

In the discussion or SDG&E's transmission lines, Talega Substation has been misspelled consistently throughout.

-10*

5. ENVIRONMEHTAL EFFECTS OF STATION OPERATION an increase in simulation time would likely have resulted in predicted excess temperatures that violate state thermal 5.3 IMPACTS ON WATER USE standards." The applieants do not agree with these state-ments. The assumption that the si%e of the model basin limits 5.3.1 Thermal discharges the ability of the model in terms of representing valid results for longer time duration conditions are not considered General Comment Concerning Section 5.3 to be valid. The conditions represented in DES Figure 5.3 represent a worst case condition and it is illustrated in Applicants and the NRC both have evaluated the thermal effects the following paragraph that equilibrium had already been of the diffuser system proposed for SONGS 2&3. The applicants reached. An increase in simulation time would not have applied a physical hydraulic model study. The NRC staff changed the predicted results.

applied a depth-averaged numerical model. Applicants* model predicts compliance with all state and federal water quality In Figure 6.14, page 61 of Reference (5} (Attachment A) it requirements. The NRC Staff model predicts similar compliance is shown that for the circumstances represented in the DES for all realistic conditions but predicts potential violations Fig. 5.3, the hydraulic model had clearly reached an of state thermal regulations for certain admittedly equilibrium peak temperature. The prototype period of time unrealistic conditions. represented in this hydraulic model test of a zero drift situation is in excess of 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br /> of continuous operation For reasons inherent in the input and methodology of the NRC at full load. Referring to Attachment A it can be seen staff model, applicants do not consider the staff's that the peak temperature measured in the hydraulic model predictions to be valid. Further, applicants' model does basin (the upper curve) quickly reaches-an equilibrium level not predict violations of the State Thermal Plan even under in a time of approximately 12 prototype hours. For the the unrealistic conditions postulated by NRC staff. subsequent 1B hours of operation at zero drift velocity, the Specific comments on DES Section 5.3 are discussed below: only variation in temperature is that associated with the experimental fluctuations. The behavior is similar for the

IIIII lower curve, which is the peak temperature measured at a I 5.3.1.1 Aoplicant's thermal analysis distance equivalent to anywhere beyond 1000 ft. from the point c.D of discharge.

Comment 5-1 The results given in Attachment A, and the detailed error analysis performed in Reference<S~ show quite clearly that (page 5-1, paragraph b) there is no basis for the assertion that the hydraulic simulation represented in Fig. 5.3 of the DES, if continued, In the discussion of the physical model, the temperatur would lead to a violation of the state thermal standards.

difference of the discharged water is reposted to be 300F To the contrary, it is clear that in a no-drift situation higher than the surrounding water. The 30 F delta T was an equilibrium peak temperature of 2.3°F (beyond 1000 ft.)

necessary to achieve dynamically correct scaling of the would be reached within about 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and this peak actual delta T of 20 0 F and this fact should be mentioned temperature would not be exceeded for longer durations.

in the discussion to avoid confusion.

The DES further states, "Once the thermal plume reaches a lateral boundary of the tank, the simulation must be Comment 5-2 terminated. The length of the simulation is thus dictated by the size of the model basin rather than by the natural (page 5-2, paragraph 3) time scales of the problem."

The statements are made, "The staff has reviewed the The tests do not have to stop when the thermal plume reaches applicant's thermal analysis and believes that the physical a boundary because a large prototype area is represented by model does not adequately represent certain hydrodynamic the model basin and the maximum temperatures are close to mechanisms and certain physical features of the prototype. the diffusers. Furthermore, the natural time scale of the The most significant of these is the limitation of the problem is that associated with the initial jet mixing and duration of the simulation by the size of the model basin." establishment of the steady induced offshore drift of the and "In fact, for the conditions represented in Figure 5.3, thermal field. The time scale associated with the 5.3.1.2 Staff's thermal analvsis establishment of steady state conditions in the model was found to be 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> at the most. The size of the basin does not limit the results until more than ~0 hours, as shown in Comment 5-4 Attachment A. It is also confirmed by the results given in Figures 6.29 and 6.3~. pages 76 and ~1 of Reference (5) (pages 5-3, 5-4, and Fig. 5.6)

(Attachments B and C). The results shown are for a situation where the hydraulic model was operated for the accelerating Atmospheric data purported to be typical of July are used current pattern given on Attachment B. The outcome of the in the NRC mathematical model to predict ocean temperatures.

model is shown in Attachment C. It can be seen that the peak Specifically, aiS temperatures with a eaximum of temperature rapidly reduces as the current velocity increases, approximately ~2 F and a minimum of 65 F were used in the showing that the natural time scale or response time is only model (see DES Fig. 5.6, page 5-7).

a few hours. Indeed, it is because of the short time scales of the problem that the hydraulic model is appropriate. Actual field data measured at coastal sites in Southern The reason for the short time scale can be seen in Figure California for July show mean daily maxima and mean daily A-7, page A-15, of Reference (5) (Attachment D) and in Figure minima substantially lower than these temperatures. In 6.~. page ~7, of Reference (5) (Attachment E) which both addition, temperature summaries for the San Onofre site clearly show a surface layer of warm water overlying a cooler presented in Table 2.3-6 of the FSAR and Table 2.3.2-4 of bottom layer. The diluting water for the discharge jets is the Applicants* Environmental Report OL Stage show mean daily always drawn from this cooler bottom layer so the dilution ma~ima and eean daily minima temperatures on the order of is fixed by the rate of supply of bottom water. When there 67 F and 61 F respectively.

is no drift the bottom flow is generated by the jet entrainment. When an ambient current is present the flow Published u.s. Climatological Data for July 1975, 1976, 1977, of diluting water is even greater so the peak temperatures 1978 (Attachments F, G, Hand I) give temperatures for two are reduced. coastal stations {Newport Beach Harbor and Santa Monica Pier).

Data at San Onofre are from the meteorological tower

Bia maintained at the site: (Attachment J),

I Comment 5-3

~ Actual Air Temoeratures For The Month Of Julv (page 5-2, paragraph ~)

Newport Beach Santa Monica The DES states, "Although the problem of underprediction is Harbor Pier San Onofre inherent in all the applicant's results, it is less signifi- mean daily mean daily mean daily cant for the realistic cases." It cannot be concluded that ..!!!!!.,_, -.!!!!.!L ~ ....!!!.!!!__ ..!!!!,!._ ....!!!.!!!__

the hydraulic model consistently underpredicts delta T's with respect to what will really occur; rather, the only conclusion 1975 69.~~F 62. 1~F 68.0~F 61.5~F 66.6~F 59.5~F that can be .drawn is that the math model gives consistently 1976 71.1 0 F 70.7 00 F 61.4 00 F 72.~ F 64.~ F 63.5 0 F 67.6 F 63.3 0 F higher values than the*pbysical model. 1977 67.9 F 61.2 F 67.5 F 61.5 F 197t! 70.7 F 62.0 F 68.1 0 F 59.8 0 F 67.5 F 61.2 0 F The basic hydraulic model report (Reference (5)) discusses possible errors in hydraulic mgdeling and deduces a The indication is clear that a typical July daily atmospheric laboratory target value of 2.5 F so Shat all possible ma~imum temperature at San Onofre shoulg be in the order of errors will be included within the 4 F limit; but the report 6~ F with a typical minimum of about 61 F.

does not imply that there is an expected bias in the results as the errors could as well be negative as positive.

-14*

These atmospheric data are an important feature of the Comment 5-b numerical model since high air temperatures will lead to high ambient water temperatures being produced by the numerical (page 5-7, paragraph 2) model in the inshore region. An indication that this has in fact occurred, are the water temperatures used in Section The DES states, "The net downcoast drift used for these 5.11 (in the benthic gectiog ambient depth-averaged simulations is based on limited data for mid-July. During temperatures of 27.~ C (e2 F) and in thg kelp section ambient other times of the year, the data indicate that an absense bottom temperatures of 21.5-211 C (71-75 F)). These of drift can persist for up to several days.

temperatures are considerably higher than have actually been Although there are no data to confirm a no-drift assumption measured in the field (References (8), (22} and (23)). High during mid-July, the staff believes that this situation is ambient *water temperatures in the inshore region will, in at least possible, and therefore, should be considered."

turn, be reflected as high temperature increments offshore Applicants disagree with the assumpation that a no-drift due to the inshore water being transported offshore by the situation is possible.

.net offshore drift produced by the diffusers. It is quite likely that these features of the numerical model could be Current data analyses have been previously supplied to NRC responsible for the possible temperature excess violations (References (3) and (q)). In Reference (3), pages 59 and predicted by the staff's numerical modeling. 60, it was concluded that current speeds are higher in summer than in winter and that, during winter, periods of very low currents could exist lasting a few days, but that tracks Comment 5-5 indicated no evidence of currents with no net transport during this period. The available current record*for summer, (page 5-11, paragraph 2) published in Reference (3), shows no evidence of any period of no net drift.

lilt The DES omits computed ambient temperature maps (without

-I heated water discharge) and computed temperature maps with In Reference (It) more*recent data obtained by Winant and N Severance for the Marine Review Committee were analyzed.

thermal discharge from which the delta T maps were derived as presented in DES Figures 5.8, 5.10, 5.12, 5.111, 5.16, 5.18, These data were collected using a newer type of current meter 5.20, 5.22. DES Section 5.4, environmental impacts, refers less susceptible to clogging than the meters used for the to this section (5.3.1) and discusses absolute values of data previously analyzed (obtained from Intersea Research ambient temperatures. Corporation). Reference (ij) makes it clear that at no time in the current meter records are there data to indicate that Since the basis for the prediction of temperature excess there is a period of zero drift. In fact, the records associated with the operation of SONGS Units 2 and 3 is the indicate a substantial drift either upcoast or downcoast with difference between the numerically predicted temperature a speed of the order of 0.1 to 0.2 knots (5-10 ems/sec).

distributions for operating and ambient conditions, these The data therefore confirm the drogue and current meter data temperature maps should be made available to the applicants initially obtained by Intersea Research Corporation (IRC).

for evaluation and interpretation, or included in the FES. The data appear to indicate that in fact IRC's meters may In addition, these temperature maps are essential to the have been underrecording the magnitude of the currents.

assessment of impacts on marine life and necessary to provide the basis for much of DES Section 5.11.

Referring to pages 103-106 of DES Reference IS (Attachment M)

In the past year (1978) more data have been collected at Del it is clear that the hydrodynamic instability claimed as the Mar (15 miles downcoast from San Onofre) by Winant of Scripps basis for application of* depth-averaged numerical. modeling Institution of Oceanography and also at San Onofre by Brown definitely will not occur with the San Onofre diffusers.

and Caldwell Engineers under contract to the Marine Review It is therefore evident that depth-averaged modeling is Committee of the California Coastal Commission. Winant's inappropriate to the San Onofre configuration so that drawing data (Attachment K) show substantial longshore currents conclusions about violation of the California thermal always occur at Del Mar. The Brown and Caldwell data obtained standards on the basis of the results of such a model is not at the San Onofre site appear to be well correlated with the valid. It cannot be concluded that depth-averaged predictions Del Mar data and also indicate strong drift currents either are reasonable representations of surface temperatures. For upcoast or downcoast for periods of several days. The change the same reasons, the bottom temperatures *cannot be predicted in direction is always a rapid process. These most recent correctly from the NRC depth-averaged numerical model.

data further corroborate the previous conclusion that there exist no periods of zero drift (Attachment L). A zero drift period is not considered to be credible, and should not be postulated for evaluating compliance with the state thermal Comment 5-B requirements.

(page 5-7, paragraph 4)

Comment 5-7 The DES states that, "The model numerical is inadequate for addressing she issue Of bottom temperature. However, (page 5-7, paragraph 3) at worst, the 4 F excess temperature shoul~ only touch the bott.om over a very limited area in the vicinity of the Unit The DES states, "Although the thermal numerical model is 2 and 3 diffusers."

depth-averaged, it is still possible to address the state

~

standards with model results because the buoyancy and shear The applicants agree that the numerical model is inadequate generated by the diffuser discharge produce a hydrodynamic for'addressing the bottom temperature issue as noted above.

instability, resulting in the water column's beigg well mixed In view of the staff's admission of 'this i~adequacy0 there is within several diffuser lengths of the discharge

• Therefore, no.basis for the staff's statement concerning the 4 F excess within the specified mixing zone, the depth-averaged bottom temperatures. In the assessment of San Onofre 2&3 predictions are reasonable representations of surface diffuser plume extent, Figures 1, 2 and 3 have been formulated temperatures." from Reference (5) (Attachments N, 0 and P). These show hydraulic modeling results in the horizontal and vertical Reference 1:!. C. w. Alllquiat and K. D~ Stolzl!llbach, and with respect to the San Onofre kelp bed area under Staged Dit't'Users in Shallow Water, Report No. 213, conditions of no ambient currents, and two typically Ralph M. Parsons Laboratory far Water Resources and en~ountered downcoast ambient currents.

Hydrodyrlamios, Mu!sacllusetts Institute of Teolmology, C:allbriclge, Hll!sachusetts, 197b. It should be noted that the vertical profiles in Figures 1, 2 and 3 (Attachments N, 0 and P) stop at a depth of 35 feet but the actual bottom depth is deeger. These figures show no indication o*r impingment of a 4 F isotherm on the bottom or even present in the water column.

The applicants do nos agree that the state thermal standards Figure A-7 (Attachment D) shows an actual vertical limitation for the 4 F surface isotherm beyond 1000 ft. for cross-section of the modeling results from surface to bottom more than one half of a tidal cycle will be violated in the along the centerline of the San Onofre 2 & 3 diffusers. This absence of drift or under any other circumstance. The figure shows that the thermal plume does not impinge applicants* thermal modeling studies addressed a no-drift substantially aaywhereoon the bottom and that a temperature condition, showing no violation of state thermal standards increase of 0.~ C (0.~ F) is not exceeded on the bottom. (DES Figure 5.3). It is the position of the applicants that the mathematical model predictions are excessively high, Comment 5-9 mainly as a result of inappropriate inputs and assumptions.

The staf6 selected inputs include air temperatures that are (pages 5-2 through 5-2~) about 10 F too high (see Comment 5-~), unsubstantiated two day no-drift conditions along the open coast at San Onofre The DES omits any reference to error analysis for either in July (see Comment 5-o), and modeled ambient depth average applicants* hydraulic modeling or the staff's numerical water temperatures that are higher than ever recorded in the modeling. Such an analysis is essential in determining the area's field data (see Comment 5-~). Also, such violations bounds within which the results are accurate or applicable. predicted (as remote) by the staff are derived from output of their mathematical model when the model itself could be The applicants* modeling has been subjected to a comprehensive approaching its limits of validity. Yet, this can not be error analysis, Reference (7), which discussed possible sources proven, mainly because an error analysis that would of error and determined appropriate error margins. This error substantiate the claimed applicability of the numerical model analysis should be referenced in the DES. is not included in the DES (see Comment 5-9).

There is no discussion of errors for the staff's math model. For these reasons, the staff's conclus;on, that even a remote As with all math models, various assumptions and coefficients possibility of a violation of the state thermal standard r

N w

are necessary and the results must be viewed with consideration of the potential error inherent in the model. It is a particular concern with this math model which appears to be 5.~

exists, cannot be justified on a technical basis.

ENVIRONMENTAL IMPACTS deficient in representing the real phenomenon occurring, specifically two-layer stratified shear flow and individual 5.4.1 Terrestrial environment jet mixing. Because of this, the range of' possible error for the math model is considered to be greater than for the Comment 5-11 hydraulic model. An error analysis for the staff's math model should be presented, or at least referenced and made available (page 5-24) to the applicants.

The discussion on environmental impacts to the terrestrial Comment 5-10 environment should also include an assessment of the Probable Maximum Flood (PMF) berm. The applicants submitted an (page 5-7, paragraph 5) environmental assessment of the PHF berm, by letter dated (page 5-2~, paragraph 1) February 14, 197~. The assessment indicated that the PMF berm should have no adverse environmental impact on the The DES states, "In the absence of drift, the 4°F excess terrestrial ecological characteristics.

temperature will not reach the shore. §owever, state thermal standards would be violated since the ~ F surface isotherm will extend beyond the 1000 ft. radius during most of the tidal cycle. The staff concludes that although there exists a remote possibility that state thermal standards could be violated by the operation of Units 2 and 3, violations would, at worst, be infrequent and for short periods. There is no evidence in available drift data to indicate that such an occurrence would take place during the summer when thermal impacts would be the most severe."

This appears to be an oversimplification since the thermal 5,q,2 Impacts on the aquatic environment plume will not be uniformly distributed with depth but rather the more buoyant heated water will be on the surface 5.4.2.1 Effects or the heat dissipation system with the bottom water remaining unaffected. This means that an increase in the surface area of the plume would only effect Thermal ef'fects fish species which inhabit the upper water column and no additional effect would be expected for fish associated with the bottom. Fish are not uniformly distributed within the water column and-actually exhibit a distribution opposite Comment 5-12 to that of the thermal plume, that is with a greater concentration of fish associated with the bottom and fewer (page 5-24, paragraph 8) fish associated with the surface. During the 1976 ETS studies a comparison of surface versus bottom gill net data showed The discussion of the proposed heat treatment states, "the that 88J of the fish were found on the bottom and only 12J applicant proposes to heat treat portions of the .intake system in the surface waters. Therefore, the area potentially to remove biological growth (Sect. 3.2.2)." This statement effected by a larger plume would be only the surface waters, is incomplete since the applicants also propose to heat treat which have a relatively small percentage of the total fish the discharge system. The text should be changed to reflect abundance.

this point.

Benthic fauna Comment 5-13 Comment 5-16 (page 5-25, paragraph 2)

(page 5-25, paragraph 8)

While the applicants do not agree that the area to be affected (page 5-26, paragraph 1}

by thermal discharges will* be greater than previously thought, the applicants do concur that even assuming a larger plume, In the discussion of DES reference 11 (Ford, et al., 1976),

the impact to the aquatic environment is expected to be it is not made clear that effects upon growth and mortality minimal and or an acceptable nature. of s. francisoanus, P. ochraceus and R. poulsoni occurred

=r only in the experiment simulating a location 84 meters from

~ the discharge and not at 335 m away.

llih The applicants recommend that clarification be added to these paragraphs in order that the reader ~e clearly informed that Comment 5-14 the effects discussed in the DES were limited to the simulation or the Slf location meter distant from the point (page 5-25, paragraph 5) of discharge.

The applicants agree that cold kills of fish are not likely to occur, *but for the reason that the extent of the thermal Benthic fauna plume is relatively small, and the difference between the ambient and the induced temperatures is less than the rapid Comment 5-17 temperature changes that occur naturally.

(page 5-26, paragraph 2)

Comment 5-15 Ambient water temperatures in DES Section 5.3.1 are referenced (page 5-25, paragraph 4) here but no ambient temperatures are included in that section.

As previously noted, in Comment 5-5, maps of these ambient It is stated that, "However, with more area to be influenced temperatures should be presented.

by the effluent, more fish potentiallY will be affected."

ong month or more or where daily temperatures reach or exceed The ambient temperatures used in the discussion of the 24 C. It is 0 not, however, anticipated that temperatures assessment of benthic fauna are apparently taken from the averaging 22 C will occur for more than 2 to 3 weeks or that staff's mathematical model. The ambient temperatures used the areas experiencing temperatures of 24°C or greater as are clearly too high, as example, "temperatures potentially a result of SONGS operation will be considerably larger than as high as 27.6 0 C (62 0 F) may occur naturally, *.* " This is the area experiencing these temperatures under natural far in excess of actual measurement of natural ambient water conditions."

for the area.

Based upon historical temperature records between 1975 and The maximum surface water tempera~ure reported in the vicinity 197M {References (8), (22) and (23))the use of weekly mean of San .onofre is approximately 23 C (References (8), (22), bottom temperatures of 52°c appears to be inappropriate and (23), (16) and (17)). Mean San Onofre natural surface should be lowered to 17 c.

temperatures for July ~nd August of the past three years are on the order of 19 C ~nd the corresponding bottom The applicants recommend, therefore, that the sentence temperatures are about 17 C. indicating 22 C weekly mean temperature could exist on the bottom for 2 to 3 weeks be changed and that a summary sentence University of California Scripps Institution of Oceanography be added to indicate that the components of the benthic fauna (SIO) data reports entitled "Surface Water temperatures at previously discussed will not be adversely affected.

Shore Stations - United States West Coast" give mean surface water temperatures at San Clemente pier, five miles North Also, the date of DES reference 11 (Ford,.et. al.) is 1976, of San Onofre, References (16) and {17)): not 1977, as stated in the first sentence of the paragraph.

Mean Surface water temperatures at San Clemente Kelp July August September Comment 5-19 1977 18.27 20.48 18.53°C (page 5-26, paragraph 5)

Ill I 1976 19.59 17.95 19.77 The DES states, "Although this deterioration may have been N

U'1 partially a result of overharvesting, much of it is probably 1975 18.58 17.01 17.91 caused by the increased alteration of the near-shore environment by human.activities. In particular increased 3 year mean 18.8 18.5 18. 7°C temperatures and increased turbidity have been shown to be inimical to kelp survival."

With surface temperatures in the 18-19°C range it should further be noted (for benthic assessment) that corresponding The thermal effects on kelp cited in Phillips (1974) were for bottom temperatures will be even lower: all San Onofre field naturally occurring events and not as induced by human data support the existence of vertical temperature activities. Man induced thermal effects on kelp have not been stratification in depths greater than about 30 feet when demonstrated.

surface temperatures are in this range. (see Attachment T1 The turbidity comment by Phillips (1974)(Reference (15)J was in reference to work conducted by North (1960)(Reference (12))

on effects of sewage outfalls on kelp health. The type of Comment 5-16 turbidity generated by a sewage outfall is not equivalent to the surface turbidity which may be ass.ociated with a (page 5-26, paragraph 3) cooling water discharge.

11 It is recommended that the discussion be changed to reflect The DES states, "On the basis of the 1977* study the staff concludes that several components of the benthic fauna in that the deterioration may have been partially a result of the vicinity of SONGS would probably be advergely affected overharvesting, much or it is probably caused by increased in areas where weekly mean temperatures of 22 C prevail for alteration of the near-shore environment by human activities, in particular, sewage treatment facilities and industrial/

chemical discharges. The toxic element of each discharge Comment 5-21 has not been isolated to date, i.e., heavy metals, (page 5-26, paragraph 7J sedimentation, oils, turbidity, etc.

The DES states, "It is estimated that the larval, juvenile, and adult stages of 25 main sport fish use kelp beds for Comment 5-20 refuge and food gathering (eating the associated invertebrates, the kelp itself, or other algae) and the (page 5-26, paragraph 6) average standing crop of fish is estimated to be 300 kg/ha (300 pounds per acre)."

The DES states, "Typically, canopy tissue deteriorates during the warmest time of the year leaving the basal portion of the For many years it was believed that the kelp beds, especially plant (which is in cooler water) for regeneration when the canopy region, represented spawning and nursery grounds temperature and light *conditions permit." of many sport and forage fish (Reference (1)). No evidence

• is available to support the therory that the canopy is widely It has been documented that kelp deterioration occasionally used as a spawning area (Reference (b)). Larvae of a few occurs when (apparently) surface temperatures exceed critical fishes are found in greater abundance in kelp beds than thermal limits. However, i t appears* that seasonal kelp elsewhere. These include the topsmelt, kelp goby, kelp deterioration may be due to synergistic effects and not just clingfish and striped kelpfish ( Reference (1) ) ; species to a thermal component. In the open coast setting, an inverse not considered important sport fish.

relation often.occurs between temperature and dissolved Many juvenile fishes inhabit the kelp canopy. However,- those nutrients. As the temperature increases, the nutrient content of recreational or commercial value are found to be more often decreases, to or perhaps below levels critical to kelp. numerous in rocky areas away from kelp, i.e., kelp bass. The Additionally, the highest nutrient concentration is found

>I on the bottom near the basal tissues and the lowest only common juvenile fish that are reported to be at higher concentrations within kelp beds are kelp surfperch, kelp concentration near the surface where most kelp deterioration pipefish and kelp clingfish (Reference (1)).

~ occurs {Reference (2)).

• Only one adult species, the kelp clingfish, is considered Other evidence {Reference (13)) impl!es that when Macrocvstis to be obligate to kelp plants. All other fish species will pyrifera is placed in a bay, *which are typically much higher persist in the environment with or without kelp plants in nutrients than found in the open coast, the kelp remains present. Diversity of fish species is not altered in the h15althy stste even when the entire plant ts subjected significantly by the presence or absence of kelp. A highly to 25-26 C (77-79 F) for extended periods. varied bottom topography appears to be the most important factor for extensive fish-life and to be of greater At this time, it is not known clear'!y if temperature, significance in this respect than kelp (Reference (14)).

nutrients, and/or other unknown components of the water contribute the most to kelp deterioration. However,there The DES should be changed to reflect the fact the kelp beds is a possibility of a beneficial effect from Units 2 & 3 do not appear to be spawning grounds, rearing grounds, or operation if. outfall upwelling creates a surface nutrient refuge areas for recreationally or commerciallY important*

plume that will occasionally come in contact with kelp plants *fish species (Reference (1} and (14)). Only the kelp during the warm water months. clingfish appears to be obligate to kelp beds for survival.

It is recommended that the DES be changed to reflect the fact that typically, canopy tissue deteriorates during the warmest time of the year leaving the basal portion of the plant (which 1s in the cooler water) for regeneration when temperature and light conditions permit; and that reduced surface nutrients and higher bottom nutrient concentrations may contribute to canopy deterioration and basal tissue regeneration,

~espectively (Reference (2)).

• 26*

• 25*

Temperatures taken in the vicinity of San Onofre between July Comments 5-22 and September over a thrse year periog show a range of (page 5-26, paragraph 8) averages of 18.5 to 18.8 C (65.3-65.8 F) for the surface waters (References (16) and {17)~ g1early, the predicted The DES states, "Kelp is an important commercial commodity maximum temperature increase of 0.9 C from plant operation

• • • harvested yearly at a landed value of $2 million." when added to the ambient temperature in the vicinity of San Onofre of 18.8 C will not exceed the critical thermal limits The commercial value of kelp is well documented, although, established by North. The DES should be revised to reflect a kelp bed is only considered commercially important when it this fact.

has: high stand density, extensive areal coverage and close proximity to a commercial harbor. The San Onofre kelp bed does not now nor has it ever met these criteria because of Comment 5-24 the limited extent of substrate suitable for attachment. The DES shoul.d be revised to reflect the fact that the kelp beds (page 5-27, paragraph 3) in the vicinity of San Onofre are not commercially harvested.

The DES states, 0 "Altsough daily natural temperature Comment 5-23 variations of 1 C (2 F) are not uncommon in the area (ER page 2.2-28) they would not be continuous in nature and would (page 5-27 ,. paragraph 2) thus not affect the bed as severely as the continuous SONGS discharges would. Prediction of the degree to which canopy The DES .states, "It has geen rather well established that disappearance would be prolonged is impossible. Regeneration temperatures above 18-20 C (b4-b8 F) cause deterioration or would be quicker in years with naturally cooler ocean kelp, and the degree of degradation is directly related to temperatures, assuming the regenerative tissues remain

> the duration of exposure to these temperatures. Increased unaffected (see below)."

I N surface temperatures caused by SONGS operation (all three units) would have the effect of extending the period of canopy The operation of SONGS 1, 2, and 3 will not have a continuous absence. During the hottest time of the year, data in Section effect on the San Onofre kelp bed. Power p~ant thermal 5.3.1 suggests that the closest kelp bed (San Onofre bed) discharges will contribute no more than 0.9 C surface will experience an average surf~ce temperature increase (over temperature increases to the kelp bed and thus will only occur a 24-hour period) of 1.4 0 C (2.6 F); the range of temperature with downccast currents. The more recent current meter data, increase will be 0.6-2.2 C (1-4°F)." as discussed in Comment 5-6 must be considered in regard to this kelp section. It is seen from these data that summer The statement in Reference (15), of 18-20°C (64-68°F) thermal upcoast currents, which would result in no kelp bed plume exposure causing kelp deterioration was based on comments impingement, occur during approximately half of the summer made in Reference (12), which refers to the colder water season. Further, the increase in temperature will be variety of kelp found near Monterey, California. For kelp dependent on the strength and duration of the current.

plants located in southern California waters, 0 the crit 0cal Increased surface temperatures due to the operation of SONGS thermal maximum is more in the range of 20-22 C (68-72 F) 1, 2 and 3 will always be. less than the measured natural (Reference (21)). surface temperature variations of the area, and will be sporadic.

During the warm water months of the year, data in Section

5. 3. 1 suggests that the closest kelp bed (San Onofre bed) The staff is requested to revise the DES to reflect the fact will experience average surface water temperatgres oncreases that increased nutrients brought to the kelp bed surface due to the operation of SONGS 0 of less ~han 0.6 C (1 Fl; the waters by outfall induced upwelling may help resist the range of temperature is 0-0.9 C (0-1.5 Fl. natural seasonal canopy deterioration and provide beneficial effects from station operation when an outfall induced nutrient plume drifts over the kel.p bed during warm water months.

-zs-

Comments 5-25 Comment 5-27

{page 5-27, paragraph~)

(page 5-27, paragraph 5>

The DES shows amgient bot~om temperatures in July reacging as gigh as 2a-2Q c (7~-76 F) with temperature or 22-23 c This paragraph summarizes the staff's conclusions tgat, based (72 F and 73 F) for a week at a time. These temperatures are on assumed natural bottom temperatures of 21.5- 24 C (71 -*

the outcome of the staff mathematical model (DES Section 75°FJ and bottgm temperature increases in the San Onofre kelp 5.3.1) and are an inaccurate representation of existing bed of 1 - 1.5 C (2- 3 F) due to operation of Units 1, 2 natural conditions occurring at san Onofre. Applican~s' & 3, damage to the kelp basal tissue might result if slack Cojient 5-17 suggests that a bottom temperature of 17 C currents occur for several days. Further, if this scenerio (6 F) is a more realistic representation. occurs frequently, the bed might not recover fully, resulting in long term damage. While the staff admits this is unlikely, Also, this section referenc~s DES Section 5.3.6 as a basis for it recommends additional extensive monitoring of the a typical bottom temperature range of up to 19 C (66 0 F) in San Onofre kelp bed.

August and September, however, these referenced temperatures are not round in DES Section 5.3.1. Such a temperature It is the applicants* conclusion that. an asgessment based on appears to represent more adequately the extreme or high end appropriate ambient bottom temperatures (17 Cor 63 0 F) derived of the range of summer bottom temperatures at San Onofre. from actual field data, and temperature increages regognizing As indicated above, an appropriate representa~ion ob a monthly that the thermal plume will be stratified (0.6 C/1.0 F or weekly mean bottom temperature would be 17 C (63 F). maximum) will yield a conclusion that damage to basal tissues will not occur, even under worse case conditions. Also, there is no evidence to support the use of an assumption that a

Ill Comment 5-26 condition of several days of slack current will ever occur, I or that it would occur frequently. The applicants believe

~ (page 5-27, paragraph 4) that the proper conclusion to be drawn from the relevant data is that the operation of San Onofre Units 1, 2 & 3 will have The DES states, " *** a several week period could exist in which no significant adverse effects on the San Onofre kelp bed.

temperatures exceed 19 C."

The greatest adverse effect which could be expected is a Results or the applicants* thermal analysis demonstrates that slight prolongation of the natural summer surface canopy the temperature increase at thg botsom in the San Onofre kelp deterioration period which does not effect the basal tissues bed will be much less than 0.6 C (1 F) under any current or the regeneration of the kelp in the fall.

condition. Under most conditions it is predicted that there will be no increase in bottom temperature in any portion of Based on the above evaluation, the extensive monitoring the kelp bed. Bottom temperatures measured at San Onofre recommended by the staff is not justified, and monitoring during July and Augugt over a three year period show a range presently being accomplished is sufficient to assess potential of averageg of 12-18 C (55-64°F). The addition of less than effects of San Onofre Units 1, 2 & 3. Specific comments on O.b C *(1.0 F) to measured ambient temperatures should have the monitoring are contained in Comment 6-3.

no adverse effects to kelp basal tissues from which the canopy is regenerated annually.

• 29*

A surface plume can be seen at Unit 1 when the surface waters are relatively clear and the bottom water is turbid. The 5.4.2.1 Turbidity and Sediment Transport Effects intake and outfall withdraws and upwells, respectively, portions of the bottom turbid layer and pumps it to the Comment 5-2!l surface. The bottom turbid layer qualitatively appears to be essentially a nearshore phenonemon that is generated from (page 5-27, paragraph 6) wave agitated bottom sediments. Units 2 and 3 outfalls are located in deeper and clearer ocean waters, *although the The DES is deficient in that it fails to substantiate the intakes are at a depth comparable with Unit 1. It is assertion that larger thermal plumes directly imply larger predicted that on occasions when naturally occurring turbidity turbid plumes. is present the Units 2 and 3 intakes will withdraw turbid bottom water like Unit 1, however, the Units 2 and 3 outfalls will be upwelling clearer bottom waters. Additionally, Units Comment 5-29 2 and 3 effluent will be initially diffused through 63 ports each and then mixed with the receiving water at an estimated (page 5-2!l, *paragraph 1) ratio of 10:1 (Unit 1 dilution ratio is approximately 3:1).

Given the situation of clearer water at the outfalls and The DES states, "The effect on the kelp would potentially increased mixing of effluent, it is predicted that a turbid be decreased photosynthesis, possibly causing many of the plume will not normally be detected.

plants to die if the exposu~e is continuous ta 1$ increase in the absorption coefficient has been f9~nd to result in In terms of effects, Unit 1 can be viewed as potentially a 20% loss in net photosynthesis at 15m) and burial of the creating more severe effects than Units 2 and 3, i.e., single holdfasts in particles which settle out, inhibiting port outfall and reduced mixing (3:1). The environmental regeneration and recolonization. Regardless of the magnitude evidence indicates that there is no adverse impact on benthic faunal or floral groups near the outfall. In fact, results

a:- of these effects, their presence would add to the probability from the Environmental Technical Specifications benthic 1 that the kelp bed WJuld be adversely affected (seP. preceding program demonstrate that the fauna and flora near the Unit N section)". 1 outfall are more abundant than those from the control

"" As discussed in Comment 5-24, the plume from SONGS 1, 2 and station (References (8), (9) and (10)~

3 will not have continuous contact with the San Onofre kelp *No relationship has been established between a turbid plume bed. and thermal plume. The factors that influence the intensity and extent of each constituent are different and may not be Reductions in photosynthesis from power plant induced interrelated.

turbidity has not been demonstrated. The net reduction in photosynthesis referred to by Phillips (1974)(Reference (15)J The applicants' conclusions are that a turbid plume emanating

, was based on work by North (1958)(Reference (18)). The from Units 2 and 3 operation may occur under certain model (computation) was based on a uniform dispersal of light oceanographic conditions, however, it should be less intense absorbtive material throughout the water column. This model than observed at Unit .1 because (1) of increased mixing of was designed for the turbidity generated by a sewage outfall. the discharge and (2) the diffusers are located in deeper, For thermal diffusers, there would be an uneven distribution clearer waters. Environ.mental Technical Specifications of natural turbidity and the equation does not apply. benthos study results show that redistributing a natural turbid layer has no adverse effects on faunal and floral Sewage outfalls generate a substantial amount of turbidity groups for Unit 1 (References (ti), (9) and (10)). Therefore, that is dispersed throughout the water column. A thermal no adverse effects on faunal or floral biota are predicted.

outfall does not create turbidity, but rather, can occasionally redistribute portions of a naturally occurring dense bottom turbid layer to the surface. Therefore, there is no net gain in the amount of suspended matter in the .water.

The major effect is that the turbidity on such occasions can be seen on the surface. Further, the turbid plume characteristics sometimes experienced at Unit 1 should not be applied to Units 2 and 3.

Offshore Current Induction Entrainment Comment 5-32 Comment 5-30 (page 5-29 paragraph 5)

(page 5-29, paragraph 2)

The applicants agree that there are no detrimental effects The DES states, "The staff's analysis of entrainment effects of induced circulation on the aquatic environment. However, in the FES-CP remains valid (FES-CP, p. 5-7 to 5-12). A the discussion of the analysis in the DES concerning the program on the mortality experienced by entrained effects of the induced circulation on the aquatic environment ichthyoplankton is being planned currently at SONGS 1 and should mention that the analysis is based on the diffuser is expected to be submitted to the NRC staff in December, design described in Section 3.4 of the ER-OLS and Section 1978, for approval." 9.2 of FSAR.

Refer to (applicants' Comment 6*5).

5.5 RADIOLOGICAL. IMPACTS Impingement Comment 5~33 Comment 5-31 (page 5-33, Table 5.4)

(page 5-29, paragraph 4)

Table 5.4 of the DES shows calculated annual doses nearly The DES_ states, "The majority of the fish impinged at SONGS a factor of 3 greater than the values provided by the 1 are anchovy, *** " applicants in Table 5.2~12 of the Environmental Report -

Operating License Stage (ER-OLS). The doses shown in Table

1111 A review of last three years (1975-1977) of ETS in-plant 5.2-12 of the ER-OLS were calculated using annual average I impingement monitoring reveals that the Queenfiah, Seriphus meteorology.

~ solitus has been the most predominant species impinged at nit 1 in terms of both numbers and weight. It appears that the staff bas used short term 15th percentile meteorology (valid only for purge releases instead ot Entrainment of anchovy has been sporadic and shows occasional continuous long-term releases) in calculating the doses shown high numbers entrapped probably reflecting the schooling in Table 5.4 of the DES. The starr is requested to revise behavior of the species. Early impingement information the doses consistent with Table 5.2-12 of the ER~OLS.

(pre-ETS-1975) indicating high impingement of anchovy may have been biased by a combination of sampling frequency and these chance occurrences. Comment 5-34 It is recommended that the word anchovy be replaced with (page 5-34, Table 5.6)

"Queenfish" to reflect the most r,cent data available. This change does not effect the overall assessment result Table 5.6 of the DES shows that the dilution factor used for indicating no significant effect on recreational or commercial the dispersion of liquid release is 1. However, Section fishing resources. 5.2.4.3 of the applicants* Environmental Report-Operating License Stage (ER-OLS) shows that the dilution factor is 10 between 0-10 miles and 12.5 between 10-50 miles. The values reported by the applicants were derived consistent with Regulatory Guide 1.112.

The staff is requested to revise the values in Table 5.6 of the DES to be consistent with the dilution factors shown in Section 5.2.4.3 ot the ER-OLS.

5.6 SOCIOECONOMIC IMPACTS The NRC Staff evaluated applicants' assessment of potential 5.6.1 Introduction beach use as provided in Amendment No. 22 to the PSAR and concluded that applicants' estimates of the maximum number of people on the beach or in the water within the proposed Comment 5-35 reduced exclusion area were conservative.

(page 5-40, paragraph 8) The ASLAB Memorandum of Order dated January 22, 1976 (ALAB-308) resolved the issue concerning authority to control The second sentence should read: activities within portions of the new reduced exclusion area landward of the mean high tide line in the applicants' favor.

However, the Board declined to deal with the question "The central portion of Orange County *** ". concerning the tidal beach and remanded this issue to the ASLB.

5.6.5 Impact on recreational resources !he ASLB held hearings on May 19-21, 1976, at which time evidence was heard on several issues concerning the tidal beach, including the anticipated public use of the beach.

Comment 5-36 Applicants' expert witnesses provided testimony regarding

{page 5-44 and 5-45) activities within the beac*h areas in the vicinity or the San Onofre Nuclear Generating Station and the projected number The NRC staff concludes in this section and other sections of persons that would be anticipated within the reduced (5.6.5, 9.1, 10.5, and 10.7) of the Draft Environmental exclusion area. With respect to activities within the beach Statement (DES), that the applicants* current plan to restrict areas, applicants' expert witness indicated that distances fro~ parking and beach access points to the area in front the public use of the beach in front of the San Onofre Nuclear

D of the station are such that there will be a low level of

-I Generating Station, within the exclusion area, is a w significant*cost of the project unanticipated*at the issuance activity on beaches within the reduced exclusion area as of the construction permit. Applicants disagree with the compared to other beach areas !n the San Onofre State Beach cQnclusion that there will be any significant loss of because beach users tend to remain relatively close to their recreation area. point of beach access. With respect to the projected number of persons within the reduced exclusion area, the applicants*

expert witness conservatively assumed the total number of Subsequent to the issuance of the Final Environmeptal persons which could ultimately be accommodated by all park Statement (FES) required for the construction permits of SONGS facilities developed to their planned ultimate capacity would 2 and 3, the ASLAB in its initial decision dated December 24, occupy the beach at the same time. Based upon a probabilistic 1974 (ALAB-248) questioned whether recreational activities distribution of that population , an estimated 35 persons within portions or the exclusion area should be permitted, would be located within the reduced exclusion area. Further, and the adequacy of the applicants* authority to control based upon actual observations of persons using the San Onofre activities in the exclusion area. By Decision dated April State Beach, in addition to similar observations on other 25, 1975 (ALAB-268) the ASLAB ruled that the applicants* beaches, it was predicted that the average and maximum number authority to control activities within the exclusion area or people using the beach in front of the station, within was insufficient *and remanded the issue for further hearing. the exclusion area, would be 7 and 31, respectively.

On October 10, 1975, the applicants submitted Amendment No. 22 to the PSAR consisting of information conaerning a proposal for a reduced exalusion area. *Amendment No. 22 also provided estimates of the number of persons anticipated within the proposed reduced exclusion area. Applicants' experts esti-mated the maximum number or persons within the proposed reduced exclusion area would be 31.

2. The ASLAB and ASLB have give*n detailed consideration, NRC Staff supported the applicants' contentions and indicated in hearings, regarding usage of the beach in front of in both written and oral testimony that the area directly the San Onofre Nuclear Generating Station within the in front of the plant was the least desirable both from an exclusion area.

aesthetic point of view and for swimming, surfing or sunbathing, and also indicated that when one is laden with 3. The applicants provided expert testimony supporting the beach blankets and other recreational gear, migration up or fact that the beach in front of the station was the least down the beach would be discouraged, therefore, beach users desirable from the standpoint of aesthetics for swimming, would congregate relatively close to the paths up the bluffs surfing or*sunbathing and does not receive significant of the San Onofre State Beach. usage and that people tended to congregate near the paths of the state beach away from the exclusion area.

ASLB Order dated January 6, 1977, ordered applicant to provide all data collected since March 14, 1976, reflecting the actual 4. The staff supported the applicants' contention regarding daily count of persons using the beach within the applicants' minimal beach usage and undesirability of the beach in exclusion area, including the tidal beach. Oral Arguments front of the station.

were held on February 1, 1977, during which the applicants*

provided an analysis of the daily counts previously submitted In view of the above, the appropriate sections of the DES to the ASLB. That analysis showed less than 10 persons were should be revised to conclude that limiting the use of the observed on the beach in the exclusion area for approximately beach within the exclusion area boundary and above the mean 57.6 percent of the time, and that, on the average, only 12 high tide line to a passage way does not represent a to 15 percent of the total number ot people observed in the significant loss of recreational space.

study area (area in front of the station and adjacent areas 1/4 mile north and 1/4 mile south) were in the exclusion area.

There *Was a peak number of 108 persons observed in the exclusion area, however, the 108 persons (40 percent stationary, 19 percent in transit, 20 percent swimming, and 21 percent surfing) represent about 36 percent of the total number observed in the study area. *It should be noted that

Ia the administrative features proposed in Amendment 22 will I only effect stationary persons within the exclusion area.

~ Transit through the exclusion area as well as activities below the mean high tide line such as, swimming, fishing and surfing will remain unrestricted.

The ASLB Initial Decision dated May 20, 1977, ruled in the applicants* favor ordering that the Construction Permits shall be continued in effect.

Given the following facts that:

1. The conclusions drawn by the NRC staff in the DES appear to be based upon the Final Environmental Statement Construction Permit Stage.

• 37-

b. ENVIRONMENTAL MONITORING o.2.1.b Reguirements Comment 6-3 (page 6-3, requirement 2) 6.2 PREOPERATIONAL MONTIORING PROGRAM The staff requires extensive monitoring of the San Onofre kelp bed based on prediction~ made in Section 5.~.2.1.

Comment b-1 Kelp inve~tigations are currently in progress with the (page 6-2, Fig. 6.1) Construction Monitoring Program, which is a special study of the Preoperational Monitoring Program. Detailed methods The legend is in error, the triangle symbol ~hould represent are outlined in Reference (11). A brief outline of the scope DO, pH and Heavy Metals. The square symbol should represent of effort, at all three San Onofre region beds, is a~ follows:

continuous temperature.

1. Three benthic station~ are located in and about the San Onofre kelp bed and one each at Barn kelp and San Mateo 6.2.1.5 Intertidal Organisms kelp. Stations are quantatively asse~sed quarterly.

2. Kelp canopies and rock sub~trate are mapped for areal Comment 6-2 extent on a quarterly basis.

(page 6-3, paragraph 5 and 6) 3. Water nutrient analysis for ammonia, nitrates, nitrites and phosphate taken monthly at all three beds. Water The monitoring described in the first paragraph was a samples are taken for the surface and bottom from within requirement for Unit 1 which was deleted in September, 1977, each bed and offshore of each bed. An additional offshore because no effects had been detected. Although this study station serves as a monitoring area for upwelling.

has been deleted as a requirement, SCE has continued an intertidal study program somewhat reduced in scope. The 4. Kelp tissue analysis for nutrient content is conducted

=r w

applicants contend continued conduct of this present cobble on a monthly basis at all three kelp beds. Each leaf is w intertidal sampling program as described below will meet the analyzed for nitrogen content.

objectives outlined in the second paragraph of Section 6.2.1.5 of the DES. 5. Assessments of the health of kelp plants in the San Onofre region beds are made on a quarterly basi~. Parameters The applicants recommend replacing the existing paragrpah assessed include: success of juvenile recruitment, density with the following paragraph: of kelp plants, amount of encrusting organisms and grazing by herbivores and abundance of senile and diseased plants.

"Although not a required component of the monitoring programs, quarterly observations are made along cobble intertidal Based upon the applicants' extensive comments dealing with transects at four monitoring stations and one control the predicted impact of the San Onofre thermal plume on the station. Predominant macroscopic species and substrate San Onofre kelp bed, the applicants contend that requirement composition are 2 identified 2and enumerated within three number 2 in Section 6.2.1.b is unwarranted and should be.

permanent 0.25m (2.69-ft. J quadrats along a line deleted.

perpendicular to the beach. Photograph~ are also taken or each quadrat for a permanent record of ecological changes."

• 39* *40*

o.3.1 Water quality monitoring program kelp preoperational program should be continued during operation of the facility until such time as it is possible Comment 6-li to state credibly that no significant impacts result from the facility."

(page 6-6)

The ichthyoplankton study being conducted is a one year The entire section is in error and should be deleted. The program to provide a baseline for comparison with the program that the staff discusses in the DES is actually a operational ichthyoplankton study which is also envisioned 197o draft of the applicants* proposed preoperational to be a one year program. Further, as stated in applicants*

oceanographic program. An operational program for San Onofre Comment 6-11, the required kelp preoperational program is 2 and 3 has not yet been established. considered to be unwarranted and the requirement should be deleted.

6.3.3 Aouatic biological monitoring Comment 6-5 (page 6-7, paragraph 2)

This paragraph states, "The applicant intends to forward a description of the study with a schedule for completion to NRC by December, 1978, (see ER, Suppl._ 1, p. S1-31L" In keeping with efforts to avoid duplication and utilize the 316(b) study results, the study plan submittal to the NRC will be made after the completion of the methods development r

~

phase of 316(b). We presently anticipate that the 316(b) method development phase will be completed in early 1979, and, therefore, the study plan should be submitted to the NRC by mid-1979.

6.3.3 Aquatic biological monitoring, and 6.3.5 Requirements for Environmental Technical Specifications Comment 6-6 (page 6-6 and 6-7)

The DES states in Section 6.3.3, paragraph 2 and in requirement number 3, Section 6.3.5, that n *** the icbtbyoplankton study now being conducted and the required

• 41-

8. NEED FOR THE STATION Comment 8-4 (page 8-4, paragraph 3 and Table 8.3) 8.2 APPLICANT'S SERVICE AREAS AND REGIONAL RELATIONSHIPS The staff's evaluation is based on the 1976 forecast data provided by the appli£ants in their ER-OLS. The data found 8.2.1 Apolicant's service areas on ER-OLS Table 1.4-1 is based on an early 1976 forecast and does not reflect the revised forecast (July 23, 1976) b data found on ER-OLS Table 1.1-1. SCE has revised Table 8.3 Comment 8-1 of the DES based on ER-OLS Table 1.1-1 and their revised 1976 forecast. The last line in the second paragraph has been (page 8-1, paragraph 2) changed by the applicants to be consistent with the revised data and reads as follows:

The reference number used in the discussion appears to be incorrect. "SCE's revised 197b forecast shows a oeak demand growth rate of 3.9~ from 1976 to 1985~ and energy requirements are expected to experience a growth rate of ~.3~ in the same period."

8.3 BENEFITS OF STATION OPERATION

a. ER-OLS Table 1.4-1 will be revised in a future amendment 8.3.1 Minimization of production costs to the ER-OLS.

b. Revised Table 8. 3 (Attachment Y).

Comment 8-2 (page B-3, Table 8.1) Comment 8-5

Jilt Table 8.1 was derived from the applicants' ER-OLS, Table (page 8-5)

I 1.1-3 and page S.2-188. However, the data found on ER-OLS w Table 1.1-3 is not the most current for 1976 and will be The discussion of the three forecasts that states, "their U!

updated in a future amendment to the ER-OLS. The applicants projections do not reflect non-price-induced conserva-have revised Table 8.1 of the DES to reflect changes in data tion *** ," this does not consider current SCE forecast as reported to the Federal Power Commision on Form 1, Annual methodology. Non-price-induced standards were incorporated Operating Report for Southern California Edison Company for into SCE's peak demand forecasts, e.g., the peak demand for the year ending December 31, 1976. 1985 includes a 2.~~ reduction due to load management and (Revised Table 8.1 (Attachment X)) the "weather sensitive demand" for 1985 was reduced 29~

because of building insulation and air conditioning effi-8.3.2 Energy demand ciency standards (Reference 19 and 20). Therefore, the discussion on page 8-5, specifically paragraphs 1, 3 and 4 should be modified.

Comment 8-3 (see Attachments Q and Rl (page B-4, paragraph 2)

The discussion on the overestimation of peak demands in the 1973 forecast should also mention load management programs.

The applicants suggest the.last sentence be rewritten as follows:

"These peak demands were overestimated because th~

1973 forecast did not foresee the Arab oil embargo, the following period of economic recession, the nationwide effort to promote energy conservation, and load management."

REFERENCES 10, BENEFIT-COST

SUMMARY

1. Feder, H. M., C. H. Turner and C. Limbaugh. 1974.

Observations on Fishes Associated with Kelp Beds in 10.2 BENEFITS Southern California. Califoria Department of Fish and Game, Fish Bull. (160): 1-144.

Comment 10-1

2. Jackson, G. A., 1977, Nutrients and production of giant (page 10-1, paragraph 2, and page 10-2,. Table 10.1) kelp, Macrocystis E!rifera§ off Southern California.

Limnol. Oceanogr. (6) 97 -995.

The net power output for each unit is estimated to be in the range of 1052 to 110b MWe (see Comment A-1 for discussion). 3. Koh, R.C.Y. and List, E. J. Further Analysis Related The regional generating capacity will be increased 2104 to Thermal Discharges at San Onofre Nuclear Generating to 2212 MWe with the addition of Units 2 and 3. The Station. Report to Southern California Edison Company, discussion on the primary benefit and Table 10.1 should be Sept. 30, 1974, 116 p.

revised to reflect the estimated net power output.

4. Koh, R.C.Y. Estimation of Drift Flow at San Onofre.

Memorandum to SCE, June 12, 1978, 23 p.

10.1

SUMMARY

OF BENEFIT-COST

5. Koh, R.C.Y., Brooks, N. H., List, E. J. and Wolanski, CoDUIIent 10-2 E. J. Hydraulic Modeling or the Outfall Diffusers for the San Onofre Nuclear Power Plant. Tech. Rept. KH-R-30, (page 10-3, item (2)) w. M. Keck Laboratory of Hydraulics and Water Resources, California Institute of Technology, Pasadena, California,

a:. The flpossible destruction of at least a portion of the San January 1974, 168 p.

I Onofre Kelp Bed during summer months by the heated water dischargefl is listed as an additional environmental cost. 6. Limbaugh, c., 1955, Fish Life in the kelp beds and the

~ Because this cost is based on an assessment performed by the effects of harvesting. Univ. California Inst. Mar. Res.,

staff using disputed data, the applicants request that this IMR Ref. 55-9:1-158.

cost be deleted if the reassessment of Section 5.4.2.1 Effects of the heat dissipation system warrants such a change. ------- 7. List, E. J. and Koh, R.C.Y. Interpretations of Results from Hydraulic Modeling of Thermal Outfall Diffusers for the San Onofre Nuclear Generating Plant. Tech. Rept.

KH-R-31, November 1974, 90 p.

8. Lockheed Center for Marine Research (LCMR). 1976. San Onofre Nuclear Generating Station Unit 1, Annual Analysis Report, Environmental Technical Specifications. Prepared for Southern California Edison Company, 257 p.

9. Lockheed Center for Marine Research (LCMR). 1977. San Onofre Nuclear Generating Station Unit 1, Environmental Technical Specifications, Annual Operating Report, Volume IV - Biological Data Analysis - 1976. Prepared for Southern California Edison Company, 257 p.

• 45*