ML19317F385

Discussion & Findings by Div of Reactor Licensing Re Consideration of Suspension Pending NEPA Environ Review of CPs for Units 2 & 3

ML19317F385
Person / Time
Site:	Oconee
Issue date:	11/19/1971
From:	US ATOMIC ENERGY COMMISSION (AEC)
To:
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ML19317F382	List: ML19317F381 ML19317F385
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NUDOCS 8001140638
Download: ML19317F385 (20)

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DISCUSSION AND FINDINGS BY THE DIVISION OF REACTOR LICENSING.

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CDNSIDERATION OF SUSPENSION PENDING NEPA ENVIRONMENTAL REVIEW

. OF THE CONSTRUCTION PERMITS FOR THE 000 NEE NUCLEAR STATION UNITS 2 AND 3 DUKE POWER COMPANY AEC DOCKET -NOS. 50-270 AND 50-287 November 19, 1971 7

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' 1. 0 Introduction

' On September 9,1971, the' Atomic Energy Commission (AEC) published in the Federal Register a revised Appendix D to 10 CFR Part ~50 setting forth AEC's-implementation of the National Environmental Policy Act of 1969 (NEPA).O Paragraph E(3) of revised Appendix D generally requires a holder of a construction permit issued prior to January 1, 1970, for which neither an operating license nor an opportunity for

- hearing on the operating license had been issued before October 31, 1971, to' furnish to the AEC within 40 days after September 9,1971, a written statement of any reasons, with supporting factual submission, why with reference to the criteria in paragraph E(2) of revised Appendix D 'the permit should not be suspended, in whole o't in part, pending cornpletion of the NEPA environmental review specified in Appendix D.

On November 6,1967, the AEC issu24 construction permits to the Duke Power Company for the Oconee Nuclear Station Units 1, 2, r.nd 3..On

October 18, 1971, the Duke Power Company filed with the AEC the state-ment required by Paragraph E(3) of Appendix D for Units 2 and 3.~

Duke Power Company has 'also supplied additional supporti.ng 11 formation..

1/ Amendments to.this revision were published in the Federal Register'

' September 30, 1971 and November 11, 1971.

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In accordance with the requirements of Section E of Appendix D we have

-determined that.the construction permits for Units 2 and 3 of the Oconee Nuclear Station should not be suspended' pending completion of the NEPA environmental review specified in Appendix D.

A formal " Determination" to this effect is being forwarded to the Office of the Federal Register for publication.

In reaching this determination we have considered and balanced the criteria in Paragraph E(2) of Appendix D.

1.2 Background

On November 29, 1966, Duke Power Company flied an application with the AEC for authority to construct and operate Units 1, 2, and 3 of the Oconee Nuclear Power Station.

An extensive review of the application was made by the AEC's regulatory staff and by the Advisory Committee on Reactor - Safeguards '(ACRS). A public hearing was held before a three man Atomic Safety and Licensing Board at Walhalla, South Carolina, on August 29-30, 1967, and September 12, 1967. On November 6,1967, on the basis of the authorization from the Board, the Director of Regula-tion issued Cons truction Permits CPPR-33

-34, and -35 for Units 1, 2, j

and 3, respectively. On June 2,1969, the applicant filed the Final Safe ty ' Analysis Report (FSAR) covering al' three' units. This document was extensively reviewed by the AEC's regulatory staff as it applied to all three units and by the ACRS in connection with Unit 1 only.

On July jl0,.1970, the applicant submitted an environmental report, avail-ability-of which was noted in the Federcl Register on July 2'5, 1970.

y On November 19, 1970, the South Carolina Pollution Control Agency

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8 w ' issued a permit to construct the cooling water system for the Oconee Nuclear Stat' ion citing compliance with the Rules and Regulations of the State Board ~of Heal'th and the South Carolina Pollution Control Au thori ty. On January 8,1971, the AEC gave notice in the Federal

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Register of its intent to issue an operating license for 0:once Nuclear Station Unit 1.

Oplortunity was provided for public hearings; however, none was requested. The construction of Unit 1 is now essen-tially complete. On October, 18, 1971, the applicant submitted a Supple-mental Environmental Report, covering all three units, required by AEC in accordance with the September 9,1971, revised Appendix D to 10 CFR Part 50.

2.0 ~ Completion of NEPA Review The time necessary for the completion of the on-gcing NEPA review for Units 2 Land 3' of the Oconee Nuclear Station is estimated at six months and the criteria s'et forth.in Section E of Appendix D to 10 CFR Part 50 have been evaluated with this approximate time period in mind. That Lis', the environmental impact of continuing construction, the foreclo-sure of alternatives of the type that might be required as a. result of the full NEPA review, and the cost of delay all have been considered with respect to approximately' six. months of continuing construction

. astivity. Should.the actual NEPA review for this case exceed six -

. months, such a. longer time period would not significantly add to the environmental impact which construction activities have caused to date,

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.but would substantially increase the cost of delay if the construction

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-. s were now suspended. A -longer review period would also increase the

. total actual plant expenditures at completion of the NEPA review if the construction permit were not now suspended. We have taken these considerations into account in balancing the factors specified in Paragraph E of Appendix D to 10 CFR Part 50 and have concluded that if a significantly longer time period were required to complete the NEPA review it would not af fect our determination that the construction permit for Units 2 and 3 of Oconee Nuclear Station should not be suspended at this time.

3.0 Environmental Impact During the Prospective Review Period Units 2 and 3 will not become operational during the forecast NEPA review period. Therefore, there will be no environmental impact from radioactive water, or water vapor effluents which would be released as a result of operation of these units. Construction of Unit 2 is

-approximately 65% complete; Unit 3 is about 35% complete. Construction to be accomplished during the prospective review period on these two units. falls basically into these categories :

(1) completion of the exterior of the structures, (2) the continuation of installation work inside the structures,' (3)- redressing construction damage to the sur-rounding terrain and (4) continuation of work on transmission lines.

The current construction status and anticipated activities during:the next six months are described below for each of these areas. All q.

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.: principal site preparation, excavation and foundation work is complete for Unita 1, 2, and 3.

This includes relocation of highways, bridge construction, construction of two najor dams, filling of Lake Keowee, construction of the Keowee Hydro plant, a visitor's center, the intake

. canal and' intake structure, all cooling water conduits and the discharge structure.. The Unit l 'and 2 containment, auxiliary building and turbine building exteriors are complete.

All turbine-generator pedestals are in place.

The 230 Kv and 115 Kv electrical switchyards are complete and the 500 Kv switchyard is approximately 10% complete.

Work is com-plete or underway on all five of the transmission lines associated with supplying power from the Oconee Nuclear Station.

Two lines (to Central and to North 'Greenv111e) are complete.

The'line to Newport is 100%

cleared with 50% of the towers erected.

For the line to Tiger about 25% of the right-of-way has been cleared and 16 parcels (89 acres) are in the process of being acquired for. this line.

For the.line to McGuire.

d>out 50% of the right-of-way has been cleared with some' towers erected and 26 parcels (196 acres) are in the process of being acquired.

During the next six. months the concrete dome of the Unit 3 reactor i.

building, the. Unit 3 auxiliary building and the remainder of the exterior l,

-of the turbine building will be completed -

Work will continue on the insta11'ation of Units 2 and 3. equipment, piping and cabling.Construc-r tion will also continue onL the 500 Kv switching station.

Efforts will w

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proceed ' to. acquire the remaining portions of the transmission line righ ts-of-way, land clearing and tower erection on all rights-of-way.

On the site, roads and par king areas.will be paved and, as construction-yard area needs ~ diminish,- grass will be planted in this area.

'i The completion of the containments and other principal onsite buildings will have a small, incremental adverse environmental impact when compared with the impact that already has resulted from the present advanced state y

of construction.

Viis; incremental adverse impact will be largely tempo-rary in nature, of the type which usually accompanies activities at large scale cons truction projects. Impact factors will include heavy t' ruck traffic as construction materials are brought to and moved on

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the site, and the noises associated with crane operation, steel erec-tion work and miscellaneous mechanized tools and equipment.

These cons truction noises are unlikely to disturb the surrounding popu-lationT af ace this:is a relatively remote site. Further significant phy~sical changes,to the site are not anticipated during the prospec -

tive review period.

It is expected; that the appearance of ~ the site, as viewed both-from the completed 'onsite visitor's~ center and from beyond the property boundary.

- will become-aes thetically more pleasing during the period of the ongoing 2/'

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2_[. The final appearance' of this Oconee Nuclear Station is depicted on

Paga 5 of Appendix F of the.0conee Supplemental Environmental Report.

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- o No additional adverse.ef fects are anticipated on ground-water, loss of soil by erosion or pollution of water or air, or, disruption of recrea-tion es a result of continuation of construction.

The incremental adverse impact shared by the surrounding ceenunities as a result of the presence of the 2100 member cons truction force, which is expected to remain' at this level during the continuing NEPA review, will be temporary in nature and is not considered to be unduly disruptive con-sidering the continuing favorable impact that the $2,800,000 monthly payroll can be expected to have on these communities.

7he-clearance. of rights-of-way for transmission lines required as a result of the installation of this power station'and the construction of transmission - facilities will continue.

In evaluating the potential for an incremental environmental impact from this continuation of work we considered-the potential for displacement of residents on the rights-of-way, the further disruption of area ecology, and the aesthetics of clearing the remainder of the 'right-of-way and of constructing the transmission facilities themselves.

- Duke Power Company already owns the' land except small' portions of the Tiger and McGuire transmission line rights-of-way.

No displacement of

- persons will result from continued activities on the owned or proposed

. ri gh t-of-way'.. The clearing of.the remaining portion of the right-of-way is not likely to have significant: additional impact' on the overall i

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~ ecology.of the area since movement iof animal life will not be impeded 4

and since flora and fauna in areas n' jacent to the rights-of-way should d

remain substantially unaffected by clearing and construction activities.

Trees; and other vegetation on, the right-of-way would of course' be removed and animal life at least temporarily displaced.

Damage-to 4

nesting sites on the right-of-way would be heavy but these are a very 1

small fraction.of the total forest p,pulation and there is no reason to believe that the existence of any species would be endangered by

~ further right-of-way clearing.

The trees have no particular intrinsic 4

value except as a lum'oer crop.

Mcat of the rights-of-way are through timbered land and most clearings -

will. not be visible from the main highways.

In addition, to minimize l

environmental impact, Duke Power Company has Etated that this clearing.

i woEk will be carried out _under U. S. Department of Interior guidelines.

Redress 'of the impact. of tower construction could be effected by removal of'the' towers. Redress of the right-of-way clearing could eventuall'y ~

be 'obtained by allowing regrowth or replanting. A mark on the terrain i

would remain.for manyfyears, but as discussed above most of the right-of-way-is ~not -exposed to view from main highways.

l 4.0 J t Foreclosure of ' Alternatives During 'the Prospective Review Period.

1The ineremental environmental impact of continued construction of the.

facility, f as' discussed above, could be largely redressed by-removal of-v.

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s truetures; and recons titution of the landscape in the event that the full' NEPA review so required.3 / However, reforestation would take decades and removal of structural features added during the remainder

.of;the NEPA review period would be costly. Except for the impact of 1

operation. the major adverse environmental impact has already been

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made. The additional expenditures expected to be made by continuing construction activities during the remainder of the NEPA review period

- would constitute a substantial increase in investment, but the ongoing construction activities themselves will not result in a substantia) increase in this existing environmental impact.

Alternatives that potentially could be affected by continued construc-tion are those related to effluent control measures. These include the: environmental. impact of routine and accidental radiological releases, and the thermal and chemical effects of water releases to Lake Keowee, Keowee Rive'r and the Hartwell Reservoir. We have examined each of i

these areas to determine the alternatives that might be foreclosed as a result of construction during the NEPA review period.

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- 1The need for powerL in the Duke Power Company customer area and alternates

.to the selected site are discussed in Section 5 and Appendix C of our Detailed Stamment on Environmental Considerations issued February 13, jl971.- Appendix.C of this s tatement contains the August 20, 1970,

' Federal Power l Commission comments on this matter.

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Appendix D to'10 CFR Part 50 requires that a cost-benefit analysis of, radiological,. thermal and 'other environmental effects be performed by

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- the AEC during the NEPA' review and that a conclusion be reached on The whether modification or termination of-the license is warranted.

radiological effects involv2 both _ anticipated low-level releases asso-ciated with operation of t'oe plant and with potential releases of from an radioactivity at somewhat higher levels that could result j'

accident.-

Routine gaseous and-liquid effluent releases will be governed by tFa limits set forth in 10 CFR Part 20 and the technical specificacions to be included in the operating licenses' and Duke will be further required to keep radioactive effluents as far below these limits as practicable.

This will include meeting numerical guidelines for routine releases com-

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parable to those contained in Proposed Appendix I to 10 CFR Part. 50.

The liquid 'radwaste, treatment system for the plant is designed to be capab'le of recycling' liquid ' radioactive wastes generated during operation. The stated design objectives of the system for liquid In addi--

' effluents are comparable to-those of Proposed Appendix 1.

tion,' construction during the prospective NEPA review period would not preclude any necessary modifications to piping systems before or after their completion. Modifications requiring additional building space could involvelsubstantial costs but would not be precluded.

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The gaseous radwaste treatment system presently includes the capability L

for 'a 60-day holdup and filtration with 'a 90% removal ef ficiency for

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todine prior to release.-

Modifications of this system, if required, T

could also involve substantial costs but would not.be precluded.

We concidde that modifiercions to the liquid and gaseous radwaste system would notfbe precluded by continued construction. There is reasonable assurance that a plant under construction can be modified to incorporate any radwaste treatment systems found necessary to restrict environmental release of radioactive waste to levels on the

- order of.those specified in Proposed Appendix I.,

including tha addi-tion of[ building space if required.

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- The probability of ~ occurrence of accidents and the spectrum of their consequences to. be considered from an environmental effects standpoint will be analyze'd using best. estimates of probabilities and realistic fission product release and transport assumptions.

For site evalua-

- tion in our safety review extremely conservative assumptions were used

- for the purpose of comparing calculated doses resulting from a hypo-4

' thetical release of fission products from the. fuel, against the 10 CFR '

Part 100 siting' guide _ lines. The computed doses that would be received by the population and environment from actual accidents would be

. significantly Lless than those presented -in our Oconee Safe;y k

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, Evaluat ion.N Although the env".ronmental effects of _ radiological acci-

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dents are, anticipated to be small, if further reduction in postulated accidental releases is required as a result of the full NEPA review, additional engineered safety systems _could be added.

For example, space is available for the inclusion of supplemental containment air cleanup. sys tems. '-

In any event,' operation of the plant will be required to be such that the environmental impact of postulated accidental releases will be within Conraission guidelines. We conclude that alternatives related to mitigation of accident consequences would not be precluded by the continuation of construction during the prospective review period.

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-1t'is expected that there may be measurable thermal effects of the

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Oconee Station cooling water discharge on the ecology of portions of Lake Keowee, Keowee River and the Hartwell Reservoir. However, from the data currently = available, there is no indication t' at the environ-mental' impact of these ef fects will be unacceptable. The maj or environ-mental. impact on Lake Keowee has already been' J.ncurred by its very.

creation which was specifically authorized by the FPC as a part of

= the Keowee-Toxaway Project. With~ all three Oconee' units operating at

'90%. capacity, the temperature rise in the water released to the O - Safety Evaluation by the Divis' ion of Reactor Licensing, U.!S. Atomic

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Energy Commission in the matter of Duke Power Company Oconee Nuclear.

Station Docket No. 50-269,' December -29,1970, pages 67-70.

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>Hartwell1 Reservoir' is expecte

' be within the water quality criteria set by the State of South Carolina. :In the unlikely. event that a differe'nt cooling me thod

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.were require'd '.as a result' of the NEPA review, a major additional

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_. dollar cost' would be incurred.

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The control-of effluents other than radwaste and cooling water will be

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Effluents from this providad by an onsite sewage treatment facility.

f acility. and from a 5 million gallon settling pond will enter the Keowee River below Lake Keowee and are estimated by Duke Power to include 53 I

1100 gallons of commercial liquid cleaner pounds of-boron.per year, Water in the

. 1 per year and 4760 lbs of powdered detergents per year.

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s'ettling pond will be sampled' and chemic' ally conditioned as required.

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This' sewage treatment system has been _ approved by the South Carolina Alternative chemical agents or further Pollution Control. Authority.

. treatment of waste effluents would not be precluded by the continua-tion of ~ construction..

An alternate routing of transmission line rights-of-way if required by -

the NEPA review wotild -not.be precluded by completion or continuation ~

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'of the' present clearing' and construction activities.

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In summary, no alternatives would be foreclosed by cont.nued construc-tion' from the standpoint of technical feasibility but significant extra dollar cost could be incurred as a result of ongoing' construction acti-l-

vities if major changes in the plant design, such as a dhange in the omethod of ~ cooling, or re-routing of transmission lines were required at the end of the ongoing NEPA review.

5.0 Costs of Delays We have examined the Duke Power Company estimate of costs that might t,

be. incurred through suspension of the Oconee Unit 2 and Unit 3 con-struction permits in whole or in part.5/ If the permits were to be suspended in their entirety pending completion of the NEPA review,-

Duke has. estimated that the increase in costs as a result of a 6-month suspension would be about $48,193,000. The AEC's Division of Construction has reviewed-these delay costs and has concluded that the estimated overall increase in costs associated with such a delay falls in the general range.of what could be expected. These incremental costs include -suspension of physical site activities including the layoff and. rehiring of the construction workers, field construction standby charges, additional engineering work, contingencies and escalations on future work except hardware procurement. They also include taxes,

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Duke. letter of November 141971, to P. A. Morris regarding Oconee

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show cause.

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~ insurance,f owners staf fing,. administration, training and overhead, and

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' interest.- An-increased-fuel cost associated with'the use of less-effi-i cient existing ! generating equipment to insure 886 megawatts of replace-

. ment power aticurrent. rates would range from 14 to 50 million dollars

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- for a six' month fperiod.

We also' examined the costs of -delay _ in construction of the transmission These costs, provided by lines. ' ending completion of the NEPA review.

p under oath 6/ 'and summarized below, do not include Duke Power Company any of the above costs, but are based on the assumption that the halted l

work will be reactivated in such a manner as to permit completion of

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these parts 'along with ' the remainder of the facility with no signifi-can't. overall ' dclay.

If there were no suspension, approximately 14-1/2 million dollars would be expended in the next six months on the transmission lines for land l

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If transmission line acquisition,~ clearing and line construction.

wo'rk were.'to be suspended.for six months an increase in costs of

. approximately.13-3/4 million' dollars would be incurred, of which

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approximately seven' million would be required to accelerate construc-l tion _ to. prevent an ;cverall project delay.

t-l b-Duke letter of November 18,1971, toLP.'A. Morris regarding.Oconee show cause.

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. 6.0 Determination and Balancing of Factors Pursuant to Section E of Appendix D to 10 CFR Part 50, we have taken into consideration and balanced the following factors in making a determination whether to suspend the construction permits for Oconee Station Unit 2 and Unit 3 pending completion of the NEPA environmental review:

6.1 It is not likely that the construction activities to be conducted g

during the period that the NEPA review is being completed will give rise to an incremental inpact on the environment that is substantial and unduly adverse. As discussed in Section 3.0 above, the environ-mental effects are those associated with construction rather than operation of these units. Because of the advanced state of completion of the Oconee Station, the environmental costs of construction, those associated with the change of the site from its former undeveloped state, already have been incurred. Redress of such environmental impact as might result from further construction could be achieved by removal of above-grade structures and reconstitution of the landscape.

i 6.2 Continued construction during the prospective NEPA review period would not foreclose subsequent adoption of alternatives to existing design features from the standpoint of technical feasibility, although sub-stantial additional dollar costs might be incurred as a result of

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.Longoing construction: activities if. major structural modificat ons As discussed in Sec-were required 'at. the end of.the.NEPA review.

tion 4.0 above,' flexibility inLsystem-performance specifications has

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b'een preserved in' the area' of treatment of radioactive wastes and installation:of' additional accident mitigating features should improve-ments in these areas prove necessary z as a result of the NEPA review.

Additional reduction in temperature of the. discharge of heated water from the station would not be precluded nor would an additional treat-

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ment of liquid wastes be precluded. - A change in the type of cooling l

4 f acilities would be technically feasible if proven necessary; however it would be quite dif ficult, involving substantial costs, and a major delay, since the existing cooling facilities have already been con-structed.'.- We regard the eventuality of a. change in cooling facilities 1

as unlikely in view of the apparent minimal environmental impact and are supported in this judgement by the favorable comments from other a

Federal and State-agencies.

I 6.3 The effects of: suspension t of the construction permits-would be

- substantial.< Increased construction and interest cost would result-f rom stoppage and.later < resumption' of; construction. As discussed in

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Section '5.0 above,; the cost.of construction stoppage due to six monthsj suspension for completion of th's NEPA review has been esti-

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will be invested It has been estimated that an additional $77,087,000 including

. (investment as of September 30,1971, was $313,299,000 not fuel) in the next 6 months in the normal course of construction.

Parts of this expenditure conceivably could influence a later decision However, as dis-whether to require major modification to the plant'.

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. cussed previously, major modifications are not likely to be require,

For example, it appears highly unlikely based on present information.

that the site would have to be abandoned as a result of the NEPA re We conclude that the large certain cost of delay (at least $48,000,000) outweighs the unlikely possibility that expenditures during the period of' continued construction will affect substantially a subsequent deci-sioc regarding modification of the f acility to reduce environmental impact.-

Af ter. balancing the f actors described above as to environmental impact of continued-construction and the potential for foreclosure of alter-natives as a result of further construction against the ef fect of delay costs, we cenclude that the construction permits for the Oconee Nuclear

'l Station Units 2 and 3 should not be suspended pending completion of the ongoing NEPA review.

Pending completion of the full NEPA review, Duke Power Company, the

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holder of Construction' Permit Nos. ' CPPR-34 and CPPR-35, proceeds with

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k ycons truction 'at its own risk - The discussion and findings herein do

.not< preclude the AEC as a. result of its ongoing NEPA environmental i.

. review. from continuing, modifying, or. terminating the construction i

permits or-their appropriate conditioning to protect environmental 4

- values.

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