ML19320A357

Discusses Encl ETS Changes & Additions Re Fish Impingement Sampling Frequency & Population Density Estimate of Threadfin Shad.Requests That NRC Recommendation 2a & Specs 6.4 & 6.5 Be Deleted

ML19320A357
Person / Time
Site:	Arkansas Nuclear
Issue date:	04/11/1975
From:	Phillips J ARKANSAS POWER & LIGHT CO.
To:	Giambusso A Office of Nuclear Reactor Regulation
Shared Package
ML19320A358	List: ML19320A357 ML19320A361
References
NUDOCS 8005010855
Download: ML19320A357 (5)

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- ARK ANS AS POWER G LIGHT COMPANY DTH G LOutGIANA STREETS . LITTLE AOCK. AAK ANSAS 72203 15018372-4311 April 11, 1975

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Mr. A. Giambusso, Director Y;.

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Division of Reactor Licensing '

U. S. Nuclear Regulatory Commission Y/. ...

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Washington, D. C. 20555

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Subject:

Arkansas Power G Light Company Arkansas Nucicar One-Unit 1 Docket No. 50-313 License No. DPR-51 Environmental Technical S i ecifications

Dear Mr. Giambusso:

Mr. D. R. Muller's letter of January 9,1975, requested the incorporation of several recer.unendations into our Environmental Technical Specifications.

On February 14, 1975, we responded in a letter stating our position on the recommendations. Subsequently two meetings have been held between Arkansas Power G Light Company and the NRC Staff to discuss the fish impingement problems and Mr. liditu O recommendations, one in Bethesda on March 5,1975, and the other in Little Rock on March 26, 1975. Enclosed for your review are several changes to the Arkansas Nuclear One-Unit 1 Environmental Technical Specifications which are related to the above discussions. A discussion of each change and addition is as follows:

Specifications 4.1.2.a(2), 4.1.1.a(3), and Figure 4-3 This change incorporates recommendations 2c, 2d, 2e and partially incor-porates recommendations 2b and 2f of Mr. Muller's letter. Recommendations 2b and 2f included subdividing each day's samples into 6 hour6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> samples. We see no benefits from implementing tFis recommendation since the parameter

• of interest is total impingement. Fluctuations within a day do not affect impact on reservoir fisheries and are only of academic interest. There-fore, we are specifying 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> samples.

Recommendation 2a sets out a sampling frequency of 3 times per week. Data previously taken at the Arkansas Nuclear One intake screens for six days out of each of ten weeks reveals that twice per week sampling provides an average impingement rate (1bs/hr) that only differs by 2% from the l't .?. G' v D' T AX P AY!NG. INVESTOR OWNEO MEMBE A MICOLE SOUTH UTILITIES SYSTEM

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. Mr. A.'Giambusso In addition, our Bubble l results obtained from 3 times per week sampling.iCurtain i Test

- tional data and will provide throughout itsIt duration is felt thst a means of conf rm ng an additional that twice per _ week sampling is sufficient. Therefore i

k day of sampling would not reflect any significant fou days. . bene sampling versus the.previously specified sampling once every By sampling dissolved. oxygen in the discharge embayment i on a fre we have eliminated the basis for the previous 3,000 pounds We have alsoper estab- day report ng limit (impact on D0 and BOD in the discharge canal).

lished sufficient surveillance to allow fish grinding operations to continue within limits without adversely impacting the DO and BOD in the discharge embayment.

Since the 3000 pound per day reporting limit no longer has a a

basis, the reporting requirements have been changed to routine 26, 1975, meet ing monthly

' reports as requested by the NRC Staff during our March in Little Rock.

The location of the dissolved oxygen surveillance is in a relativelyThis preven st,agnant area out of the main discharge flow path. The depth of measurement from being affected by the flow turbulence. h

'1 measurement is 1/2 the total depth at the barge slip as set out in t e state water quality standards.

Specification 6.3 Bubble Curtain Testing l

This completed.

test is already underway, the fall and winter tests hav this test be documented in the Environmental Techni December 1975.

Specification 6.4 Absolute Population Density Estimate of Threadfin Sh This program was requested by recommendation 4 of Mr. Muller's letter.

Our previous answer to recommendation 6 of Mr. Muller's letter in our Jebruary 14, 1975, letter provided qualitctive verification of large Threadfin shad are considered toThey be winter die offs of threadfin shad.

a trash fish by Arkansas residents and a nuisance by nany people.

are not native to Dardanelle Reservoir or to any lake cr reservoir north of Little Rock. TSey were stocked in Dardanelle Reservoir by the l

Arkansas Game and c.sh Cormaission as an effort to provide a forage fish for the game fish to feed on that would not grow above the first year ,

class and as a result would not coqpete with the game fish for food whenBej they become too large-for the game fish to feed on. l kill phenomena of the threadfin shad, they were particul this purpose.

, no concern over our shad impingements and stated that, should the shad disappear one winter (as has happened in-other lakes), they would sin a be- restocked. The Game and Fish Commission staff is awa -

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1' April 11, 1975 Mr. A. Giambusso '

d sees no benefit from it other thandpossibly this request for this program :It is our understanding that the state agency expres academic. - staff during their Little Rock visit.

same view to tha d from this We agree with their evaluation of the benefit $156,000. to be Ifderive we are (in our opinion) program which, if conducted, will hcost approxima pense, pmgram we wish to go on recordd/or that the program subjective j with the present state of the economy. d by submits that the costs greatly outweigh any possibic anF benefits. .

the NRC Staff. t re and_

Specification 6.5 Laboratory Study of Effects of Tempera u lemperature Change on the Swim-Speed ' 1ctter. We and Morta This study was requested by recommendation 5 of Mr. Muller sted b can see no practical use of the data that would be generaffects on thread other than further verification of the temperature e Inletter '

documented addition, shad which our reply to recommendation 6 of Mr. Muller h study swe qualitatively and to a limited extent, quantitatively.

have serious doubts about whether it is evenf the extremely possible to do t e because of problems involved with catching and handling oThis Again, if we are delicate threadfin shad.none of which may be recoverable. d that the study 1

cost of $100,000, fit analysis cannet required to perform this study we wish to go b on recor as being done only under duress since a valid cost-i stene implementa-f corrective justify the expense, and in our opi,nion would dictate aga n tion. Furthermore, the results will not determine a course oA action in our opinion.

, as requested by the NRC staff. dditions can be imple-f With regard to schuule, all the above changes i and aof Specification 4.1 mented immediately on approval with the except onSpecification its approval. 4.1.1.a(3) will During and parts of Specification 4.1.2.a(2). i i dng by Specification

a short period of administrative adjustment follow til certain changes periods of high impingement, the 24-hour samples requ re 4.1.2.a(2) will be difficult and at times impossible i uncollection finitive for samp  !

1 are made to our' intake structure to facilitate

-ing. Preliminary esti-eas erTh schedule for completion does not yet exist.f the summer of 1975.

the change completed by the end o $50,000 to $75,000.

mates indicate a cost for this change of about have not yet been Three of the. recommendations in Mr. Muller's duct inletterRecommendation the receiving mentioned in:this letter. i sion has Lgrinding up impinged fish and discharging i the pro. The Arkan "waters" statedhe discontinued.

, .ery strongly their position that all imp nge

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~ April 11, 1975 Mr. A. Giambusso The ' fish grinding system was installed originally returned to the lake. As a result of this state at the Game and Fish Commission's request.

agency's position, we have developed a program to allow con This program is covered by oxygen values in the discharge empayment. The NRC staff has Specifications 4.1.2.a(2), 4.1.1.c(3) and Figure 4-3. expressed

6. In our March 5,1975, meeting in Bethesda, certain data were presented to supplement the data in our February 14, 1975, letter The NRCandstaff to support our has express-position that recommendation 3 is not necessary.

ed a guarded concurrence with this position, but have requested more data before making a commitment.

The following is a further discussion of our position on recommendation 3 and a presentation of additional data.

The lata presented in the March 5 meeting in Bethesda is now documented in the enclosed Table 1. We have a limited amount of drta from our thermal plume mapping study (Specification 6.1)Ilowever,and therefore any statements th'e results using to date appear this data are of necessity preliminary.

Table 1 includes a comparison between to 4.ndicate no recirculation.

our condenser water box temperature and the thermal mapping data that is now available. Detailed temperature measurements throughout the reservoir for the last 6 months of 1974 were provided in our semiannual operating report for Arkansas Nuclear One-Unit 1, which was submitted in March of 1975.

As requested by the NRC staff in the March 5,1975, meeting in Bethesda, we have reevaluated the Environmental Technical Specification changes requested in our January 17, 1975, letter in light of our high fish impinge-ment. We have determined that our impingements do not affect the reason-ing behind any of those requested changes and continue to request them as submitted.

Arkansas Power G Light Company again respectfully submits that recommenda-tion 2a and specification 6.4 and 6.5 as required by the NRC be deleted.

Further, Arkansas Power G Light Company submits that the changes recom-mended by it will provide adequate data and protection of the Environment.

Further, they will avoid unnecessary expenditures of funds which can be put to better and more productive uses.

Your early comments or responses will be appreciated.

Very truly yours,

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J. D. Phillips l Senior Vice President ,

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. Atte.chments

STATE OF ARKANSAS )

) SS COUNTY OF PULASKI )

J. D. Phillips, being duly sworn, states that he is a Senior Vice President of Arkansas Power G Light Company; that he is authorized on the part of said Company to sign and file with the Nuclear Regulatory Commission this Supplementary Information; that he has read all of the statements made and matters set forth therein are true and correct to the best of his knowledge, information and belief.

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u J. D. Phillips /

SUBSCRIBED AND SWORN 'ID-before me, a Notary Public in and for the County and State above named'this ll b day of , 197S.

5- D = . h T:_- a Notary Public My Commission Expires:

March 1, 1978 l

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