ML19317F301
| ML19317F301 | |
| Person / Time | |
|---|---|
| Site: | Oconee  |
| Issue date: | 01/19/1972 |
| From: | Thies A DUKE POWER CO. |
| To: | US ATOMIC ENERGY COMMISSION (AEC) |
| References | |
| NUDOCS 8001100669 | |
| Download: ML19317F301 (7) | |
Text
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Reference:
Oconee Nuclear Station Unit 1 g
Docket No. 50-259
Dear Sir:
In reply to the notice in the Federal Register, Volume 36, No. 245 - Tuesday, December 21, 1971, we offer the following comments on the " Draft Detail State-ment on the Environmental Considerations by the U. S. Atomic Energy Commission, Division of Radiological and Environmental Protection, Related to the Proposed Issuance of an Operating License to Duke Power Company for the Oconee Nuclear Station, Unit 1, Docket No. 50-269" issued December 13, 1971.
1.
Page 8, Paragraph 2 - Additional information should be included to the effect that application for certification as required by Section 21(b) of the Federal Water Pollution and Control Act has been sub-mitted.
2.
Page 13, Paragraph 4 - The fencing will surround the plant site area not the entire exclusion area.
3.
Page 17, Paragraph 2 - Bachelors' quarters referred to under " Population" are temporary quarters and will be removed after construction is com-pleted.
(Reference Technical Specification 3.9.3.11, Page 3.9-4, Section 15 of the Oconee Nuclear Station Final Safety Analysis Report.)
4.
Page 21, Paragraph 2 - The design discharge rate of the spillway for Lake Jocassee is 46,000 cfs not 70,500 cfs as reported.
5.
Page 37, Paragraph 1 - The correct number of fuel rods is 36,816.
6.
Page 38, Paragraph 5 - The fluctuation limits identified as three feet for Keowee and six feet for Jocassee are for pumped-storage operation only and do not include the draw-down for hydroelectric operation.
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Director Division of Radiological and Environmental Proteciion Page 2 January 19, 1972 1
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7.
Page 44, Paragraph 1 - Tha 4,733-cfs maximum condenser circulating water flow includes 233 cfs service water which does not flow through the condenser.
- 8.
Page 46 Table III This table is from the Velz study which estimates maximum discharge temperature 100.2*F.
Duke's study based on later information estimates maximum discharge temperature of 93*F (reference Table 2, Supplement to Environmental Quality Features of Keowee-Toxaway Proj ect, October,1971).
9.
Page 49, Paragraph 2 - South Carolina water quality criteria governing impoundments, see definition on Page 3 of " Water Classification -
Standards System for the State of South Carolina" approved by Environmental Protection Agency, December 23, 1971, allows compliance to be checked under provisions in Paragraph F, Page 8, thus providing a tailrace excess temperature of 5*F.
10.
Page 52, Paragraph Small fractions of gaseous liquid radioactive materials produced during reactor operation can enter the primary coolant system only if fuel defects are present.
i 11.
Page 52, Paragraph 4 - Coolant accumulates some fission products that may have leaked from nuclear fuel only if the fuel has defects.
I 12.
Page 53, Table III The table describes calculated annual releases from radioactive material and effluent from the Oconee Nuclear Station only in the case of 1 percent defective fuel in each reactor. Anti-cipated annual releases will be much lower. Liquid effluents, ex-4 cluding Tritium, reported as 30 curies should be three curies.
(Reference Table 5, Supplement to the Environmental Quality Features of Keowee-Toxaway Project, October, 1971.) Gaseous effluent activities reported as a 30-day hold-up, are calculated based on varying hold-up times according to source.
(See Table 6, Supplement to Environmental Quality Features of Keowee-Toxaway Project, October, 1971.) For clarification, this table should show by suitable sub-titles or foot-notes that the values shown are not those. anticipated during normal operation, but are values which are not likely to be exceeded during simultaneous full power operation of all three units and with 1 percent failed fuel.
4 13.
Page 57, Last Paragraph - In addition to the drumming provisions 2
described, there is an alternate drumming station for low level wastes, and there also is provision for direct transfer of wastes such as ion exchange resins to shielded transport casks.
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Director Division of Radiological and Environmental Protection Page 3 January 19, 1972 14.
Page 63, Paragraph 1 - The reference to placement of fuel elements in the storage pool should indicate that this storage is for radioactive decay and cooling.
Page 63, Paragraph 2 - The reference to fuel shipments should show that the shipments may be by truck or rail.
Page 63, Paragraph 3 - The number of fuel shipments would more accurately be described as "up to 89."
15.
Page 68, Paragraph 1 - The maximum rate of evaporation for a total of three reactor units operating on a hot, dry day would be about 5 percent of the average river flow to the lake of 1,100 cfs.
16.
Page 68, Paragraph 4 - Intake and discharge cooling water will be sampled periodically for temperature and dissolved oxygen.
17.
Page 70, Paragraph 4 - Duke does not expect any species to be eliminated from habitat changes due to transmission line con-struction.
18.
Page 71, Paragraph 5 - Since Oconee is located on a large reservoir, reference 5 to a laboratory study on the effect of warm water on river bottom plants and animals by the Federal Water Pollution Control Administration is not appropriate. Moreover, bottom temperature of Lake Keowee is not expected to reach 86*F.
19.
Page 72, Paragraph 1 - Reference 6 relating to a study involving effective heated water effluent upon the macroinvertebrate riffle fauna of the Delaware River has no direct relation to Oconee because of the dissimilarity of the two locations.
20.
Page 80, Paragraph 1, Second Sentence - The word " maximum" should be inserted to show that Table III-4 presents identities and' maximum quantities of radioactive material, etc.
21.
Page 81, Paragraph 1, Third Sentence - The dose of 12 man-rem should be identified as being an annual dose.
22.
Page 82, Table V The doses reported in Table V-2 are design basis doses for one percent failed fuel.
Annual average doses are estimated to be lower.
23.
Page 87, Paragraph 1 - A primary coolant source of one percent failed fuel is used in evaluating steam generator tube leak.
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Director Division of Radiological and Environmental Protection Page 4 January 19, 1972 24.
Page 102, Paragraph 1 - The installed capacity is greater than 7,000 megawatts.
The peak load as yet has not exceeded 7,000 megawatts.
25.
Page 107, Paragraph 4 - The condenser cooling water supply of 4,400 cfs is adequate for dissipating 4,950 megawatts of waste heat for three units or 1,650 megawarts per unit.
26.
Page 112, Paragraph 2 - Several statements in this paragraph are misleading and confusing. For example, proposed guide lines are referred to as stated requirements; and it is implied that the items being discussed are questions yet to be resolved. Duke considers that the items in this paragraph already have been resolved by the Technical Specifications and by the fact that the applicant must comply with 10CFR50 Appendix I as adopted.
Twelve containment ourges per year are not scheduled, however, approximately '
per year are anticipated.
27.
Table X To facilitate reference in these comments, the six alternatives for power generation are designated as follous:
Alternative Number For Nuclear For Fossil Description of Fueled Steam Fueled Steam Alternative Generation Generation With Pumped Storage Hydro Peaking and Impcunded Lake Once through Cooling N1 F1 With Wet Cooling Tower and Gas Turbine Peaking N2 F2 With Wet Cooling Tower and Pumped Storage at Separate Location N3 F3 Land Use, Agriculture, Line 1 - The annual loss of agricultural production due to land inundated by the Keowee-Toxaway project is estimated at $220,000 as given in Table 14 of the Supplement to Environmental Quality Features of Keowee-Toxaway Project, October, 1971. Therefore, the costs to environment of $108,000 shown under alternatives N1, N3, F1 and F3 are low. Assuming thdt only 10 percent as much land will be required for alternatives N2 and F2, the costs under each of these alternatives should be $22,000.
Director Division of Radiological and Environmental Protection Page 5 January 19, 1972 Land Use, Industrial Power, Line 9 - It is presumed that amounts shown as ' Benefit' under all eix alternatives represent the capital investment on the powerhouse including cooling lake, cooling towers, etc.
In Duke's opinion, such capital costs of project should be treated as ' Costs' rather than ' Benefits.'
Apparently, the cost of the initial nuclear fuel core of $61,400,000 has been included in the investment under alternatives N1, N2, and N3, whereas a similar cost for fossil fuel does not appear in the investment under alternatives F1, F2, and F3.
This does not afford a fair economic comparison of the different alternatives. Duke, therefore, contends that the costs of initial nuclear fuel core if included under alternatives N1, N2, and N3 should rightly be excluded. Also, it would be erroneous to ignore the economic impact of the yearly operating, maintenance, and fuel cost ysc~
taining to an alternative. Due credit should also be giv en to alternatives N1 and F1 for the cooling capacity and potent.ial for pumped storage by adding capitalized cost of cooling towers and pumped storage reservoir capacity to -iternatives N2, N3. F2, and F3, which would necessitate thesa addL;1onal facilities.
To bring out clearly the overall economic impact of the various alternatives, the capitalized coetr, of fuel, operating sud main-tenance expenses should be added to the capital investmenc as shown in the following table and then compared with bent. fits.
Costs Under Alternatives (million do: lars)
N1 N2 N3 F1 F2 F3 DRL's estimate as shown in Table X-4 (as ' Benefit')
639 588 664 534 488 554 Duke's estimate Capital investment excluding fuel costs 569 519 535 479 423 439 Capitalized cost of Fuel, Operating & Maintenance 239 282 250 490 533 501 Capitalized cost of Additional Wet Cooling Towers & Pumped Storage Reservoir 49 49 49 49 Total Duke estimate of costs 808 850 834 969 1005 989
s Director Division of Radiological and Environmental Protection Page 6 January 19, 1972 Power, Cormodity Value, Line 31 and 32 - It is suggested that the benefit / cost comparison would be more meaningful if shown in close proximity on Table X-4.
The benefit of power would be the same for each of the alternatives considered.
Sincerely, A. C. Thies ACT:vr s
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