ML19326A381
| ML19326A381 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  |
| Issue date: | 10/05/1971 |
| From: | COMMONWEALTH EDISON CO., TOLEDO EDISON CO. |
| To: | |
| References | |
| NUDOCS 8002030185 | |
| Download: ML19326A381 (46) | |
Text
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\@- 31 se fe?on y & 7 m G APPLICANTS' STATDiENT PURSUANT TO SECTION E OF AMENDED APPE'IDIX D TO 10 CFR PART 50 Reguktor" file Cy. .
Rr h:1r,L' !'^f /d' REASONS FOR NON-SUSPENSION OF CONSTRUCTICH PERMIT NO. CPPR-80 AEC DOCKET NO. 50-3h6 , THE TOLEDO EDISON COMPANY THE CLEVELAND ELECTRIC ILLUMINATING COMPANY OCT0t'ER 15,1971 8 0 0 2 0 3 0tgs-- 4490
TABLE OF CONTENTS Section Page I. Annlicability of Section E. 1 II. Continued Construction During Review Period Will Not Give Rise To Significant Adverse Impact On Environment. 2 A. General Descrintion of Site and Facilities. 2 B. Particular Areas and Facilities. 3
- 1. Marshlands 3
- 2. Main Station Area 3
- 3. Main Station Structures 6
, k. Cooling Tower 7
5 Intake Canal, Intake and Discharge Pines g
- 6. Miscellaneous Construction 9 T. Construction During Review Period Will Have No Adverse Effect On Environ =ent 10 III. Continued Construction During Review Period Will Not Foreclose Alternatives Resulting From NEPA Review. 12 A. Radiolocical Effects. 12
- 1. Liauid Radioactive Waste Systems lh
- 2. Gaseous Waste System 15
- 3. Miscellaneous Gaseous Releases 15
- h. Possible Additional Radioactive Waste Treatment Systems 16 5 Environmental Consequences of Accidents 17 B. Water Quality Matters.
17
- 1. Nature of Discharges 17
- 2. Water Quality Certification and State Annrovals 20 C. Atmospheric Effects.
22 D. Intake System. 23 E. Recreation. 23 F. Miscellaneous Effects. 23
- 1. Aesthetics 23
- 2. Aviation -
2h
- 3. Noise 25
- h. Chemical Releases 25 5 Sanitary Releases 25 G. Conclusions. 26 IV. Delay Of Construction Will Adversely Affect The Public Interest. 27 A. Need For Power. 27
- 1. Forecasts of Demand 27
- 2. Elements of Demand and Consumntion 28
- 3. Demand-Canacity Situation, 197h-1975 36 B. Alternate Sources of Power. 41 C. Cost of Delay. h5
- 1. Increase in Cost of the Davis-Besse Project h5
- 2. Delay Costs Associated with Alternate Source of Power h6
--V. Conclusions. k8 i
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_,_ .; , ~ -. 4 * ) Exhibits' A. Site Plan. t B. Site Areas. C. Site Plan - Aerial Photo, May 17, 196h. D. Site Plan - Aerial Photo, July 31, 1971. E. Site Plan - Aerial ihoto, August 3, 1971. F. Environmental Consideration of Liquid Radioactive Wastes from Davis-Besse Nuclear Power Station. Statement by James E. Martin, Ph.D. , Acting Deputy Director, Division of Technology Ascessment, Office of Radiation Programs , Environmental Protection Agency before the Ohio Water Pollution Control Board, Port Clinton, Ohio, July 28, 1971. G. The Thermal Plume in Lake Erie Caused by the Discharge of Heated Effluent from the Davis-Besse Nuclear Power Station - A Statement by Donald W. Fritchard, Ph.D. ,before the Ohio Water Pollution Control Board, Port Clinton, Ohio, July 28, 1971. H. Public Meeting to Consider the Application for Certification of the Davis-Besse Nuclear Power Station for Purposes of Section 21(b), Federal Water Pollution Control Act, July 28, 1971. Statement of George L. Harlov, Director, U.S. Environ-mental Protection Agency, Fairview Park, Ohio. I. Area Served by CAPCO. J. Federal Power Commission Co=ments Relative to the Environ-mental Statement on the Davis-Besse Nuclear Power Station, and Forwarding Letter, Dated November 3,1970, to the Director of Regulation. e ^ l 11 ) l l -u . 1
DAVIS-BESSE NUCLEAR POWER STATION APPLICANTS' STATHENT PURSUANT TO SECTION E OF AMENDED APPEIDIX D TO 10 CFR PART 50 REASONS FOR NON-SUSPENSION OF CCNSTRUCTION PERMIT AEC DOCKET NO. 50-3L6 I. Aeolicability of Section E. A construction permit for the Davis-Besse unit was issued to Applicants on March 2h, 1971, and they are accordingly required to initiate the pro-ceedings provided for in Section B of Appendix D, as amended, to 10 CFR Part 50, effective Septe=ber 9, 1971 (hereafter referred to as Appendix D), and therefore are required to submit this statement pursuant to Section E.3. of Appendix D. Applicants are now engaged in the preparation of a Supplement to the En-vironmental Report as required by Section B of Appendix D and expect to submit the same to the Com=ission prior to November 8, 1971. Applicants submit, on the basis of the information set forth in this State-ment, that there is no reason why Applicants' construction permit should be suspended, in whole or in part, pending completion of the NEPA environmental review specified in Section B of Appendix D. Such review, it has been esti-mated, could require about nine months from the effective date of the new Appendix D. For purposes of this statement, the Review Period is defined as the period ending June 30, 1971.
II. Continued Construction During Review Period Will Not Give Rise To Significant Adverse Impact On Environment. This part of Applicants' statement is directed to the criteria set forth in , Section E.2. (a) of Appendix D and de=onstrates that continued construction activity during the Review Period will not result in significant adverse impact on the environment. A general description of the station site and planned facilities is included, followed by separate statements as to each facility or group of facilities, giving (a) the status as of September 30,1971, (b) the planned construction up to June 30, 1972, and (c) the effect, if any, of such construction on the environ =ent . A. General Description of Site and Facilities. The plant site consists of 95h acres on the shore of Lake Erie in Carroll Township, Ottava County, Ohio, with a lake frontage of 7,250 feet. It is about six miles northeast of Oak Harbor, six miles vest of Port Clinton, and 21 miles east of Toledo. The site includes 524 acres (532.9 deed acres) called the Navarre Tract which was acquired fras the U.S. Bureau of Sport Fisheries and Wildlife pursuant to an exchange agreement wherein a well-developed marsh tract of 489, acres closer to Port Clinton held by the Applicants was exchanged for the Navarre Tract. This exchange agreement also provided for continued maintenance as a National Wildlife Refuge of the major part of the Navarre Tract so acquired. This ex-
' change agreement also provided for addition to the Refuge area of =arshlands acquired from others.
The station structures, except for the cooling tower, are located on a 56-acre area which is approximately in the center of the site and about 3,000 feet from
the shoreline. The location of these structures and other station facilities are shcun on the site arrangement drawing included hereto as Exhibit A. B. Particular Areas and Facilities.
- 1. Marshlands Pursuant to the exchange agreement with the U.S. Bureau of Sport Fisheries and Wildlife, k47 acres of the marshland acquired in the exchange' have been ,
leased to the Bureau to be used as a National Wildlife Refuge for a period of 50 years and 97 acres of prime marshland acquired from others vill be so leased for a' period of 25 years. Additionally, the Bureau vill be given management of another 66 acres of marshland within the site. Thur, over 600 acres of prime marshland and wildlife habitat vill be maintained in essentially the same condition as prior to acquisition. The various areas are shown on a drawing included hereto as Exhibit B. The marsh areas will not be used in connection with the station except for the intake canal and intake and discharge pipes as described subsequently. Aside from this, the work in the =arsh area includes the construction pursuant to the exchange agreement with the Bureau of an earthen dike along the northern site property line in a marsh area which is north of the Navarre Tract. This dike separates the site from adjacent =arsh areas and will permit water level control in this section of the site marsh area for better manage =ent as a wildfowl refuge area 'oy the Bureau. This construction, which is not related to the Davis-Besse Station, was done in late su==er of 1971 to avoid disturbance of nesting vildlife and was completed prior to arrival of the major migratory flights to avoid disturce:ae of large gatherings of vildfevl in the fall of 1971. The only other activity in the =arsh area during the Review Period by Applicants vill be some maintenance and repair of dikes in the area and the installation t -
of water level control pu=ps, all in performance of the exchange agreement, and not otherwise related to the Davis-Besse Station. In advance of the final pu=p installations, the dikes were repaired in the spring of 1971 and te=porary pu=ps used to lower the =arsh water level. This has resulted in a decided im-prove =ent in the marsh vegetation in the su==er of 1971 and has greatly in-creased its value as a vildlife refuge for the year.
- 2. Main Station Area The main station area of about 56 acres is located almost entirely on the original upland portion of the site and has been graded up to a co==on ele-vation which ranges from 6 to 12 feet above the original grades. This graded area has installed within it, a storm drain system which collects all storm water and discharges it to a drainage ditch so that there is no storm run-off from the construction area entering the marsh. The ditch receiving the storm water drainage was formed when previous owners of the Navarre Tract dredged material to construct dikes along the property line and runs approximately 7,000 feet along the site boundary prior to entering the Toussaint River.
The type of soils used for the grading, the =anner in which it was placed, the stcrm drain system and the length of the on-site dited assures that there is no possibility of any silt being discharged to the river or lake from the con-struction area. The fill material for the grading of the station area has been taken from three other upland locations on the site. These three borrov pits total about h6 acres in surface area. Quarry operations and rock crushing are being conducted in a portion of one borrow pit to provide a stockpile of granular backfill ma-terial for construction purposes. These areas are shown on Exhibits A and B. All exposed earth surfaces around these borrow pit areas and the cooling tower location drain into the borrow pits which prevents any silt or rav earth from being csrried into the marsh areas or other waterways with storm water drainage. The purpose of the quarry and rock crushing operation is to provide the granular backfill material now being placed in the excavated areas around the lower portions of the station. structures. This crushed rock granular material is stockpiled adjacent to the quarry. Most of the a=ount required has been pro-cessed and quarry operations vfil be discontinued in the near future. The re-maining quarry operations will all be performed within the present borrow pits and vill involve no further' disturbance of the site area. Stockpiled material is now being used and the major portion vill be placed in the next few months. This quarry area and the other borrow pit areas will fill with water u9on com-pletion of construction de-watering operations. The surrounding land areas will be landscaped which vill result in attractive pond areas compatible with and enhancing the vildlife refuge nature of the marsh areas. The on-site quarry and crushing operation is away from the marsh areas and has had no effect on the wildlife areas. This arrangement has also reduced considerably the truck delivery traffic to the plant site which would have put a burden on area roads and highways. The site is underlain by glaciolecustrine and till deposits which overlie sedimentary bedrock. These soil deposits have a very low per=eability and 6 range in thickness from 15 to 20 feet. These geophysical features have pro-duced an artesian ground water condition in the upper layer of the bedrock which is generally independent of any surface water. Since the main station structures are founded on rock, and, in the case of some- structures , 30 feet below the upper rock surface, the excavation required for these st;ructures results in a water flow through -the rock aquifer into the excavated aiea.
This presently requires constant pumping from the excavated area to maintain a dry condition for construction. To prevent excessive water flov into the excavation and excessive lowering of the rock aquifer level off site, the upper bedrock layer was grouted at the perimeter of the excavation area. This has limited the water flow to a small amount, but the zona of influence on the water table does extend off site for a short distance, but has not in any manner affected the surface water condi-tions. This rock aquifer water is generally not suitable for human consumption or household use and the effect on local area wells has been minimal. With the current construction schedule, all below-grade work in excavated areas will be complete in December 1971 and this pumping vill be per=anently stopped restoring the rock aquifer to a normal level.
- 3. Main Station Structures Construction work on the substructures of the station building began in Septem-ber of 1970 upon receipt from this Commission of an exe=ption permitting certain below-grade work.
After receipt of the construction permit on March 2k, 1971, slip forming of the shield building was commenced and reached full height of 220 feet above station grade on May 19, 1971. Erection of the steel containment vessel within the shield building co=menced after the completion of the shield building and the complete bottom head is nov in place. Erection of the vertical valls will con-tinue within the confines.of the shield building during the Review Period. The auxiliary building below grade is co=plete and certain areas above grade are now in place. The turbine generator foundation is at full height, 39 feet above grade, and all base substructure work is complete in the turbine and office
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building area. Turbine building and office building structural steel is on the site and erection will commence late in 1971 and will be co=pleted about June of 1972. Continued construction of the main station structures during the Review Period involves work wholly within the cleared areas, will involve no significant effluents , and will have no impact on the environment.
- h. Cooling Tower The cooling tower is located northwest of the main station area, as shown on Exhibit A. The tower will be natural draft with a' hyperbolic reinforced concrete shell k93 feet high and h15 feet in diameter at the base. Circulation of water from the condenser through the tower will be at the rate of h80,000 gpm. The water will flow from the condenser to the tower through two underground pipes and will flow back to the pump house located at the turbine building through a single open channel. Blowdown from the cooling tower system will be discharged to the lake through pipes extending from the pump house to the discharge pipe referred to in subdivision 5 below.
Construc: ion work commenced on the cooling tower in June of 1971 and ground prepa'stion for the complete basin and tower foundation area is complete and the ring foundation is poured. Further work in 1971 will include construction of the basin slab at grade level.and lintel support columns and lintel up to an i elevation h0 feet above grade. Construction of the shell is scheduled to com-mence in March of 1972 and =ust be complete by December of 1972 if construction of the station is to be completed on schedule. There vill be no impact on the environment caused by- continued construction of the cooling tower. Installation of the buried circulating water pipes from the condenser area to the cooling tower. is now being done and will be complete prior to December 1971. All of this work is within the confines of the graded construction area; it vill require no further clearing of land and vill have no i= pact on the en-viron=ent. 5 Intake Canal. Intake and Discharge Fires Lake Erie water will be drawn into the station through submerged intake pipes extending about 3,000 feet into the-lake in a northeasterly direction to a depth near the contour line 11 feet below mean lov vater datum level. The-on-site portion of the intake water system will be a narrow intake canal occu-pying a 2h-acre area in an isolated section of the large marsh and extendir4; to the station's intake structure. The canal vill connect at the shoreline to the submerged intake pipes from the lake. Discharge of liquid effluents from the station vill be by means of a buried pipe extending along the intake canal to the shoreline and continuing in an easterly direction into the lake for 1,300 feet. The on-site intake canal was constructed in late 1970. In the spring of 1971, the canal banks and exposed earth were seeded to prevent erosion and to provide cover for vildlife. None of the work involved with the intake pipes or discharge pipes vill be done during the Review Period. A temporary 2,800-foot-long channel vill be dredged from deep water in the lake to the beach front at the open intake canal to permit barge delivery of the reactor vessel. The beach front vill be temporarily opened for this delivery and then restored following delivery of the vessel and construction of the submerged intake pipes. The required permit from the Army Corps of Engineers pursuant to 33 U.S. Code LO3 has been applied for, but this dredging work vill not be done during the Review Period. All dredged material vill be deposited in one of the on-site borrow pits so that there vill be no solids discharged
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W to Lake. Erie. This temperary work vill have no adverse effect on the environ-ment.
- 6. Miscellaneous Construction Work has commenced on a railroad spur track from the Norfolk & Western Railroad
- main line to the station. This spur vill be approximately 7 miles in length and is contiguous to the main transmission corridor leaving the station site for two miles. It then continues contiguous with one of the main transmission line right-of-ways for the remainder of the distance.
This railroad location was chosen to coincide with the transmission routing to eliminate having an additional right-of-way route through the area even though a shorter route was available. All of the property for the railroad and adjacent transmission right-of-way has been acquired except for two small parcels. There were no buildings or structi.res within the property involved and only a limited number of trees on some parcels which have been removed. Grading for the railroad spur is currently being done and completion of this spur is expected by January 1972. Transmission tower bases on adjacent right-of-vay are now being installed concurrent with railroad spur grading so that all earth vork is being accomplished at one time to minimize crop da= age and con-struction inconvenience to property owners in the area. Erection of 13 trans-mission towers on the two-mile corridor leaving the station and 10 on-site towers will be'done in 1971. Construction and grade plans for the railroad spur have been reviewed and ap-proved by the Ottava County Commissioners, Ottava County Engineer, and Township Trustees of Benton and Carroll Townships. Grade and drainage plans were prepared
giving particular care to provide for proper drainage of the property affected ornd to meet the requirements and desires of the property owners, Soil Conserva-tion Service of the U.S. Department of Agriculture, State Department of Natural Resources, and officials approving the plans. A minimu= of one crossing for each property owner affected has also been included. While the railroad and transmission lines, in certain instances, might be a burden on the specific property crossed, they do not have any significant adverse effect on the general environment. One of the three transmission lines leaving the station site vill connect the Davis-Besse switchyard with that of the Bay Shore Station approximately 20 miles to the vest of the Davis-Besse Station. A six-mile section of this line was com-pleted in the su=cer of 1971 from a point about two miles from the station to provide a te=porary connection with an existing 138 KV transmission line in order to supply temporary construction power for the Davis-Besse construction. The continuation of this line to the Bay Shore Station follows adjacent to an existing transmission line and most towers for this portion have been erected with the conductors scheduled for installation in the spring of 1972. All of the work on the railroad spur and transmission line during the Review Period vill be on areas that are already cleared. A major portion of it vill involve additional work on already existing structurec and none of it will have any adverse effect on the environ =ent. T. Construction During Review Period Will Have No Adverse Effect On Environment All of the major construction activity, except for that associated with the cooling tower, is taking place within the confines of the 56-acre graded area approximately in the center of the site. This includes construction varehousing, construction offices, construction parking, and other activities associated with
-the work in progress. The cooling tower location is adjacent to the switchyard area and also adjacent to the access road from the concrete batch plant. All of the work on the site is away from the marsh areas and has no effect on the wild-life areas.
The arrangement of station fccilities and the care taken during the site prepara-tion and development to date has kept the unique wildlife areas of the site free from station facilities and free from construction activities. Water level con-trol of the large marsh area initiated this year in advance of permanent facilities has decidedly improved the quality of the marsh. Balancing these factors against the temporary undesirable, but relatively minimal, environmental factors associ-ated with any construction activity, there is a large balance on the side of enhancing the environment. To illustrate the character of the site in its original condition and the char-acter-of the site with the present construction, Exhibits C, D, and E are in-cluded. Exhibit C is an aerial photograph of the site area taken on May 17, 196h, prior to acquisition, while Exhibit D is an aerial photograph taken on July 31, 1971. Exhibit E is a low level aerial photograph taken on August 3, 1971, showing most of the station site. It follows from the foregoing that construction to date has had no significant adverse effect on the environment and that continued construction during the Review Period can have no significant adverse effect on the environment. The land areas in which the continued construction will take place have already been cleared. There will be no significant discharges to the atmosphere or to any waters, and no impairment, but rather further improvement, of the marsh areas and of underground water conditions. The only other effects will be those minor effects incident to any construction project, such as noise, all of which
' vill decrease as more of the buildings are enclosed.
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III. Continued Construction During Review Period Will Not Foreclose Alternatives Resulting From NEPA Review. The criteria in paragraph (b) of Section E.2. of Appendix D involve two basic questions: (1) whether the NEPA review will indicate that the effect of the operation of the facility on the environment will probably be such as to require the " adoption of alternatives in facility design or operation," and -(2) whether continued construction during the Reviev Period would " foreclose subsequent adoption" of any such alternatives. If the answer to (1) is in the negative, there is no basis for considering (2). If the answer to (1) is in the affirmative, then the answer to (2) becomes im-portant. It will be shown in what follows that with respect to the various environmental factors, there is no reason to believe that alternatives to present design vill be required. However, it vill also be shown that continued construction during the Review Period vill not foreclose subsequent alternatives.
'A. Radiological Effects.
The extensive systems to process normally radioactive systems and collect, pro-cess, and control releases of liquids and gases to the environment which might contain rad,ionuclides have been fully described in the Preliminary Safety Analysis Report (PSAR) and summarized in the Environmental Report submitted in August of 1970 under the then existing requirements of the Co= mission in regards to NEPA. Since the completion of the Commission's review of the PSAR and agency comment on the Environcental Report, there have been additions to these systems and commitments made on the anticipated mode of operation of these systems to provide further assurance that releases of radioactivity to the environment will be kept u within standards and guidelines, and vill be as low as practicable with a minimal - effect on the environ =ent. During a public hearing before the Water Pollution Control Board, State of Ohio, concerning an application before that Board for Certification of the Davis-Besse Station for purposes of Section 21(b), Federal Water Pollution Control Act, a representative of the U.S. Environmental Protection Agency (EPA) in the Office of Radiation Programs made a statement before the Board concerning liquid radioactive disenarges from the Lavis-Besse facility. This statement which is included hereto as Exhibit F stated that after a review of the PSAR and the Environmental Report, a site visit and consultation with the Ohio Department of Health, they were of the opinion that the Davis-Besse Station can be built and operated witn minimal public risk or environmental effects due to liquid discharges from the station. This opinion was subject to proper consideration by Applicants of two recommendations contained in the statement, the first being that a population dose assessment be made to deter-mine the total impact of radioactive discharges on population exposure. An initial population dose assessment is a matter of record as Exhibit No. 7 to the Construction Permit Public Hearing Record and an updated population dose assessment will be included in the Supplement to the Environmental Report which is to be submitted prior to November 8, 1971. The second EPA recommendation concerned operating procedures. The EPA statement stated that the vaste treatment systems were well designed and if utilized to their full. capability, the effect of waste discharges to the envir tment would be minimal. Criteria and operating procedures governing the operation of these systems will be formulated prior to station operation and will be such that the radioactive discharges will be maintained at minimal levels commensurate with the capability of the system design.
- 1. Liquid Radioactive Waste Systems All radioactive liquid vastes, and all liquid vastes suspected of containing radioactivity, will be processed through liquid radioactive vaste treat =ent systems. There vill be two ec=plete and separate systems with one to handle relatively pure water from the reactor pri=ary system (Clean Liquid Radioactive Waste System), and the other to handle vastes from sources that could contain larger a=ounts of non-radioactive i= purities (Miscellaneous Liquid Radioactive Waste System). In each syste=, the vastes are first collected in tanks where they can be monitored for redicactivity and other impurities.
The first vaste system is designed to process water from the primary reactor coolant system that has been removed to provide for expansion or to reduce the boron content. This water is passed through a degassifier to remove dissolved gases, through a boron saturated demineralizer (ion exchanger) to remove dissolved impurities, through an evaporator system to remove the boron, and finally through a polishing demineralizer, The resulting water is extremely pure and is placed in storage for reuse or it is released from the station. l The second liquid radicactive vaste system processes water from the fuel storage I system drairs and laboratory, laundry, and building drains that could be radio-active. Effluents from these areas, after monitoring, are filtered and released I I directly from the station, if satisfactory, or are processed through an evapora- I l tor if treatment is required. After processing and sampling, they are released 1 from the station or are placed in storage for reuse. Further consideration of the design of the Miscellaneous Liquid Radioactive Waste l System since receipt of the Construction Permit has resulted in the increase in l l size of the evaporator from 5 gpm capacity to 15 gpm capacity and the addition of a demineralizer so that the distillate from the evaporator can be passed through a demineralizer.
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Before any liquid is released fro = a vaste tank, a sample is taken and its level of activity is determined. If it does not =eet established limits, it is recycled until it does. A final check is made on the waste as it is dis-charged through an in-line radiation monitor. If its activity exceeds preset values , an alarm is annunciated and isolation valves automatically shut off the discharge.
- 2. Gaseous Waste System Gases removed from the primary system water that is processed through the clean liquid radioactive system and gases from the quench tank, makeup tank, and reactor coolant drain tank are collected in a vasta gas surge tank. From this tank,.they are compressed into one of three decay *.anks. After a holdup time for radioactive decay which, for most periods of operation, will be 60 days, the gases are discharged to the station vent through a EEPA filter.
- 3. Miscellaneous Gaseous Releases Within the containment building and the auxiliary building, any leakage or spills of radioactive liquid are collected and drained to the miscellaneous liquid waste system. Any dissolved radioactive gases in this liquid would be released to these areas and subsequently vented to the atmosphere from the ventilation and purge systems through particulate filters and the station vent.
The emergency ventilation system which is provided to treat any leskage from the containment in the unlikely* event of a loss-of-coolant accident will be provided with connections to these normal ventilation and purge systems so that in the case of leakage of radioactive liquid into the containment or auxiliary building with a resulting release of radioactive gases to these buildings , the ventilation or purge air can be passed through the charcoal filters to remove gaseous iodine radionuclides. L
g % __ 4 -4,.m .,s. -s. 4 M.- .h.1 _ _# __, 4_ - 4_+o+ _ This is not a normal path, but is an alternate path to be used in case of abnormal activity in the air syste=s to mitigate the release of radioactive iodine during an abnormal operating condition. f
- b. Possible Additional Radioactive Waste Treatment Systems
! There are additional radioactive vaste. treatment systems and ccmponents that
- could be added to the station beyend that now planned such as additional evap-orators or demineralizers in the liquid vaste systems. Cryogenic or absorption
, systems for the vaste gas systems are in the process of being developed and al-though they could not be available for initial operation, could be installed for later use. No additional equipment or systems beyond that now planned are required to main-tain the radioactive releases from the Davis-Besse Station below standards, guidelines, and as low as practicable. The anticipated releases from the sta-tion utilizing the present planned equipment and systems vill have, minimal effect
- on the environment. The Supplement to the Environ = ental Report vill, however, outline and discuss the effect of additional equipment and systems and vill in-clude a cost benefit analysis of such additions.
Some of the equipment such as 'the gas decay tanks and liquid receiver tanks are currently being installed and some additional work primarily involving piping systems will be installed during the Review Period. There is, however, no physical foreclosure due to construction work during the Review Period that i vould prevent equipment or systems from being added which might result from the t NEPA review. Whatever .the incremental costs of adding systems later might be, and it'is estimated that the incremental cost may be in the order of several hundred thousand-dollars to install additional facilities later than now, they will be much less than the cost of delay which will automatically occur if
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construction is stopped during the. Review Period. 16 -
l 5 Environmental consecuences of Accidents The Supplement to the Environmental Report vill fully discuss the environmental consequences of postulated accidents . Due to the extreme conservatism of the Commission in their requirements for nuclear facilities and technical review of applications and the extensive facilities planned for the Davis-Eesse Sta-tion, it is fully anticipated that this review will show that there is a negli-gible environmental risk due to postulated accidents and, accordingly, no addi-tional equipment is necessary. B. 'a'ater Quality Matters.
- 1. Nature of Discharges The initial plan called for a once-through condenser cooling system with direct open discharge to Lake Erie of 685,000 gpm at 18 above ambient lake tempera-ture, plus sr. aller amounts of wattr from the service water and other station systems with a total heat discharged to the lake a=ounting to 6.21 x 109 BTU /Hr.
The present plan will utilize a closed cycle, natural draft evaporative type cooling tower to discharge the vaste heat from the condenser to the atmosphere instead of to the lake. The concentration factor of dissolved solids in the cooling tower system has been established at about twice that of =akeup water
-from the lake and this permits the discharge from the service water system to serve as the makeup for the cooling tower since the flow requirements of each are about equal.
This arrangement results in the only discharge to the lake of any significance being that of the cooling tower blevdown. Other discharges are extremely small and consist of neutralized regenerant vaste from makeup demineralizers , effluent from a settling basin receiving filter clarifier backwash and condensate demin-eralizer backwash, effluent from the sewage treatment plant and processed vastes from the nuclear area. I l
The cooling tower blevdown ranging in quantit/ from 7,500 gym to 10,h00 spm is taken from the outlet of the tower in order to obtain the lowest differential between' its te=perature and that of the ambient lake. This differential varies during the year from a value of 5 0lower than the lake temperature to a maximum 0 condition of 30 above lake temperature with an annual average of 13.8 above ambient lake te=perature. Dilution pu= ping is also provided for limiting the nixed te=perature of blevdown and dilution water to a =axi=um of 200 above lake t,e=perature at any time. All discharges from the station vill be from a conmon collection box at the station and then by means of a buried pipe carried 1,300 feet beyond the shore-line to enter the unrestricted lake waters at the six-foot depth belov =ean low water elevation. Discharge into the lake waters vill be through a slot-type i discharge to promote rapid mixing of the effluent with lake water and rapid degrading of the te=perature differences. Under the maximum discharge condi-tions, there vill be a flow of 13,800 gpm, including dilution water, which will
- be 200 above lake temperature and contain 138 x 106 BTU /Hr. excess heat. Under these conditions, there vill be an area in the lake extending out from the dis-charge point of only 2.lk acres which will be 10 at the perimeter with the long-est distance from the discharge orifice to the 1 0isotherm being 658 feet. '
The calculations of the ther=al plumes .in Lake Erie resulting from the discharges were made by Dr. D. W. Pritchard of the Chesapeake Bay Institute and The Johns-Hopkins University and his work is su==arized in testimony presented before the Chio Water Pollution Control Board during the public hearing concerning Certifi-cation of the Davis-Besse Station for purposes of Section 21(b), Federal Water Pollution Control Act. This testimony is included herewith as Exhibit G. Dr. Pritchard also testified as to the biological significance of the thermal dis-
charge and concluded that existing evidence supports the conclusion that ther=al discharges as nov proposed for the Davis-Eesse Station vill have no adverse biological effects on the waters of Lake Erie. The Fish and Wildlife Service of the U.S. Department of Interior by letter, ? dated Septe=ber 18, 1970, to the Co==ission, withdrev previous objections to the Davis-Besse Station after the plans were changed to include a closed cycle cooling tower in the condenser cooling syste=. The nature and character of all liquid discharges will be fully discussed in the Supple =ent to the Environ = ental Report, but these discharges vill contain 1 only dissolved solids that are well within applicable standards and will not contain toxic substances or deleterious =aterial. With a closed cycle cooling tower system included in the station design which results in the minimal discharges into Lake
- Erie described above, there should be no question that these discharges vill have no adverse effect on the environ-ment.
It is, however, recognized that there have been alternatives suggested to pro-vide some additional cooling such as through cooling ponds or through a mechan-ical draft cooling tower for the blowdown from the cooling tower for periods when its te=perature is above that of the ambient lake te=perature. These alternatives together with a cost benefit analysis vill be fully discussed in the Supple =ent to the Environmental Report. It is expected that there vill be no vorthwhile benefit to be shown by addition of any such alternative, however, the cost of adding any such alternate vould be no greater if added later as a result of the NEPA review with construction proceeding during the review than if added now. L. :
Continued work on the cooling tower and buried circulating water pipes during the review will not preclude addition of any such alternative.
- 2. Water Quality Certification and State Approvals On December 30, 1969, an application was sub=itted to Depart =ent of Health, State of Ohio, for approval of general plans for water use and discharge for the Davis-Besse Station persuant to Sections 3701.18 and 3701.19 of the Ohio Revised Code. The Report and General Plan submitted with this application covered all aspects of water use and discharge f r the station and proposed an open lake system for condenser cooling water purposes. This report also out-lined a nu=ber of alternate methods of providing for condenser cooling water and supplemental cooling of discharge water that had been considered. INe of an open lake condenser cooling system was preliminarily approved by the Depart-ment of Health on June 16, 1970, with a nu=ber of qualifications. This approval was concurred in by the Water Pollution Control Board, State of Ohio.
After a complete review of all the factors involved with the water quality as-pects of the condenser cooling system, the Applicants decided on July 30, 1970, to provide a closed cycle condenser cooling system utilizing a natural draft cooling tower to reject substantially all of the heat in the condenser cooling water directly to the atmosphere. The decision to use a closed cooling water syste= vas based on a number of factors, including the following:
- 1. Numerous state =ents of representatives of the Federal Water Quality Administration and others connected with the Department of the In-terior opposing large additions of heat to Lake Erie from power plants,
- 2. The publicly expressed concern of conservation and ther organiza-tions as to the effect of an open cycle system on the ecology of Lake Erie, 3 The overriding need of having the station in operation on schedule and,thus avoiding the possibility of delays pending decisions as to applicable water quality standards, and
- h. The avoidance of duplicate costs involved with system partially or wholly built and then required to be replaced by a different system.
On January 25, 1971, Applicants filed an application for certification for the purposes of Section 21(b) of the Federal Water Pollution Control Act with the Water Pollution Control Board, State of Ohio. In support of this application, a Report and Plan for water use and discharges, including the use of a closed cycle cooling tower, was prepared and submitted. No action was taken by the Water Pollution Control Board on this application. On April 6, 1971, the Water Pollution Control Board, State of Chio, adopted procedures pertaining to processing applications for certifiention for the pur-poses of Section 21(b) of the Federal Water Pollution Act and on April 8,1971, an application for certification, together with a supporting Report and Plan, was filed with the Board. On July 19, 1971, an amendment to the Report and Plan was submitted to present a revision of the plan by which the service water discharge will be used as cooling tower makeup water, which reduced substantial:.y the already small amount of heat discharged to Lake Erie and the resulting size of the plumes of heated water. A two-day public hearing concerning the application for certification was held by the Board in Port Clinton, Ohio, on 'uly 23 and 29, 1971. The Director of the Cleveland Office of the U.S. Environ = ental Agency testified at this public hearing and his testimony is included herewith as Exhibit H. He stated that after careful consideration of the most recent design changes proposed by the Applicants and evaluation of expected environ = ental i= pact, the U.S. Environ-mental Protection Agency has no objection to the application for certification for the purposes of Section 21(b) of the Federal Water Pollution Control Act and that there is reasonable assurance that the construction and operation of the Davis-Besse Nuclear Power Station vill be conducted in a manner which will not violate applicable existing water quality standards. No action by the Board has been taken as of October 11, 1971, on this applica-tion.
'C . Atmospheric Effects.
Aside from discharges through the station vent of building ventilation air and processed gases from the vaste gas system, the only discharge to the at-mosphere vill be from the cooling tower. Added to the natural flow of air 6 through the cooling tower which averages 2.757 x 10 lbs./ min. vill be 7,500 to 10,h00 gpm of water in the form of vapor which is evaporated from the water flow through the evaporative cooling process. The environmental effects of this discharge of air and vapor to the atmosphere has been carefully analyzed by a consultant for the Applicants and such effacts have been shown to have no significant effect to the environ =ent. This study will be fully discussed in the Supplement to the Environmental Report ana the formal report will be included as an appendix. The average visible plume is expected to be only 1.5 miles long. The proba-bility of increased occurrence of fog has been calculated to be 0.h2% and only represents the possibility of fog occurring earlier or persisting longer and l l
does not represent discreet cases of fog occurring. The predicted increase in icing conditions from this effect has been estimated to be a maximum of one minute for any 22.50 sector in the vinter season. Turbulent downwash occurrence was calculated, but these conditions have not been verified in actual cooling tower operctions in this country. D. Intake System. With the smal.t amount of water use from Lake Erie required with the cooling tower system, che use of submerged intakes and intake pipes to the open intake canal, the type of intakes being planned, the open canal on site to monitor fish and organisms which might pass through the intake pipes, and the screens in front of the pump intake well provides assurance that there vill be no detrimental loss of fish and aquatic organisms resulting from this water use. These systems will be fully described in the Supplement to the Environmental t Report and since no construction work will be done on the intake or intake pipes during the Review Period, there is nothing to foreclose alternatives being added which might result from the NEPA review. F. Recreation. The extent of recreational use of the wildlife refuge portions of the site vill depend on regulations of the Bureau of Sport Fisheries and Wildlife and not on the existence of the station. Full operation of the station vill have no sig-nificant adverse effect on recreation, nor will continued construction have any adverse effect on recreation. F. Miscellaneous Effects. , 1. Aesthetics The station structures have been carefully designed within their functional requirements to present a clean and pleasing architectural appearance which is l-
i conpatible with the site locality. The cooling tower is in itself an archi-tecturally pleasing structure, but is massive in size and will be a prominent landmark on the horizon, both from the lake and from the land areas. The station switchyard has been designed with a low silhouette using a tapered tubular pole structure to support the necessary high voltage lines to give a good aesthetic appearance. After completion of construction, the upland site area between State Route 2 and the station structures will be landscaped to pre,sent an aesthetically appearance to the site area which is viewed from the public areas. The unique marsh areas will be ms.intained in their natural state as previously discussed as well as the more than 7,200 feet of Lake Erie shoreline encompassed by the site. Construction during the Review Period will add only some height to the turbine
. building and cooling tower and will in no other way change the aesthetic appear-ance or factors of the station and site.
- 2. Aviation i
Notice has been given to the Federal Aviation Administration pursuant to 49 U.S.C.1501andlhCFRlPartTT. FAA has acknowledged the notice and no aircraft hazard lighting will b4 required for the main building structures, however, the FAA has determined that there is such .a requirement for the cooling tower. In addition, the FAA has determined that the tower must also be marked or in lieu ofmarking,'ahigh. int (nsitylightingsysteminstalled. In working with the FAA on this later requirement, it has been agreed that a proper balance for aircraft safety and environmental considerations would be to provide one level of high intensity lighting for day-time operation only and to provide conven-tional red lighting for: night-time operation.
- 2h - ,
3 Noise The very nature of a nuclear station as compared to a fossil station provides for an installation with no noise impact to the environment beyond the immedi-ate areas of the station buildings. The natural draft cooling tower vill have no fan noise associated with a forced draft type installation. Normal station operation vill produce less noise than that encountered from the construction activities which have had no discernible effect on the wildlife in the marsh areas closest to the construction activities.
- h. Chemical Releases As discussed previously In this statement, the only substances in the liquid effluent discharges ra om the station other than heat from cooling tower blow-down are dissolved solids that are higher in concentration than ambient lake water. The major portion of these dissolved solids is from the cooling tower system resulting from the evaporation of water in the system which concen-trates the dissolved solids that are initially in the lake water. Some addi-tional dissolved solids are added from neutralized demineralizer vastes and filter clarifier vastes. The dissolved solids concentration in the discharce is slightly higher than twice that of the lake water and is within State of Ohio Standards. These solids contain no toxic substances, are of no nutrient value, and add no biological oxygen cemand to the lake.
5 Sanitary Releases Construction facilities to date have provided for holding tanks to receive sanitary vastes which are periodically removed from the site for disposal by a commercial-disposal firm. Construction is essentially complete on the sewage treatment system which will serve the completed station and portions of the construction facilities such as the construction warehouse and office. 3
~
This sewage treatment plant provides primary and secondary treatment with a fully. chlorinated effluent and meets all requirements of the State of Chio. Approval of the sewage treatment plant and installation has been received from the Department of Health, State of Ohio, in accordance with regulatory require-ments. G. Conclusions. It is clear from the above discussion that the design of the Davis-Bessa Station and the facilities now planned to be installed are such that operation of the facility will not have a significant adverse effect on the environment and that the NEPA review is not likely to result in alternatives in the design of the station and facilities. It is also clear that continued construction during the Review Period will not physically foreclose subsequent adoption
,of alternatives which could conceivably result from the NEPA environmental re-view.
In some instances, such as the radvaste treatment system, alternatives which might be' required resulting from the NEPA review would be more costly to adopt at a later date if construction continues during the Review Period, however, whatever the added incremental cost might be, they will be much less than the cost of delay which vill automatically occur if construction is stopped during the Review Period. In the case of the cooling tower system, the only f easi' _e alternative would be to have the NEPA review and cost benefit analysis call for an open lake condenser cooling system as originally planned. This would result in a substan-tial added incremental cost if construction continues during the Review Period. This added incremental cost would, however, still be much less than the cost of delay and adoption'of this alternative is not likely even though a rigorous ecst benefit analysis might show it to be a proper alternate. IV. Delay Of Station Construction Will Adversely Affect The Public Interest. This part will deal with matters referred to in Section E.2.(c) of Appendix D. It will be shown that Applicants have realistically forecasted the future de-
=and for power from consumers, that the growth in demand is related to and is necessary for the general economic well-being and standard of living of the consumer, that the on-schedule construction of the Davis-Beaaa Station is critical for the purpose of providing reliable electric service for this con-sumer demand, and that the only feasible alternative to provide the required supply, if the Davis-Besse Station is delayed, has extremely high environmental and economic costs associated with it.
A. Need For Power.
- 1. Forecasts of Demand The extreme length of time required to place a new generating unit into ser-vice from the time of commitment requires extensive long-range planning. To provide a coordinated and economical expansion program requires an even longer period of planning. All of this planning is based on projections of future demands for electricity from the consumer. The validity of these projections determines the electrical energy availability for the consumer and financial status of the electrical utility industry. Under-projecting results in genera-ting capacity shortages for the consumer and over-projecting results in idle capacity with attendant added costs to the utility.
All of the capacity addition plans for the Applicants and CAPC0 are based on individual company projections of future denand with the composite CAPCO de-L . l 'mands determined from these projections. l To illustrate these projections and their validity, Charts 1 and 2 have been prepared. Chart 1 shows the Toledo Edison ten-year peak demand planning pro-jection prepared in 1960 for the period 1960 through 1970. The actual system peak demand for 1960 through 1971 to date is also shown for comparison. The current ten-year projection prepared in 1970 is also shown for the period 1971 through 1980 and which forms the Toledo Edison system component of the CAPCO total demand projectiou chown on Chart 2 for the period 1970 through 1980. The first combined CAPCO projection was made in 1967 for monthly demands during the 20-year period commencing September 1971. The Septe=ber 1971 actual com-bined CAPCO peak demand was 8,7h7 MW which is only 178 MW or 2% below projec-tion. All of this illustrates the increasing consumer demand for electrical energy and the prudent and accurate forecasting of these needs on the part of Appli-cants and CAPCO to properly serve the consumers in their service area.
- 2. Elements of Demand and Consumotion '
The historical demand for electrical energy on the Applicants' systems and forecast future demands can be categorized into three major sectors of con-sumers ; namely, industrial, co=mercial, and residential. Charts 3, h, and 5 have been prepared to show this division in consu=er demand. Chart 3 shows the annual peak de=and, actual 1963 through 1971, and projected 1971 through 1975 Chart h shows the same information based on summer peak which is dominant from 1967 through'1975. Chart 5 is the consu=er division of energy used in megawatt hours. Table I lists these sectors and percentages for the year 1971 peak demand to date and sales to date plus esti=ated sales for the balance of the year. Currently, the. industrial sector of the service area accounts for the largest portion of the peak demand, being 511 MW or h8.5% in 1971. The industrial ac-tiv' ity in Toledo Edison's service area and generally in any area of the country
r is a direct and immediate indicator of the prosperity of the area and the re-sulting general level of the standard of living. A growth in industrial demand results in the economic growth of the area. The residential sector accounts for 230 MW or 21.8% of the 1971 peak demand and is very sensitive to changes in industrial activity. The commercial sector is responsive to the residential sector and its growth generally lags changes in the residential and industrial sectors. The commercial sector accounted for 2h0 MW or 22.8% of the peak demand in 1971 i l TABLE I 1971 Demand Consumption MKW % of Peak MMKWH % of Total Industrial 511 k8.5 2,9h3 52.h Commercial 2h0 22.8 752 13.h l Residential 230 21.8 1,376 24.5 other* T3 6.9 Sh7 9.7 Total 1,05h 100.0 5,618 100.0
- Street lighting, Public Authorities , and Municipal Systems .
I Contrary to the impression many opponents to nuclear power have expressed, the I residential sector accounts for a small portion of the total demand, being only 21.8% of the system peak on Toledo Edison's system in 1971. l Company studies have ghown conclusively that the dominant determinant of the level of usage of electrical energy in the household is household income. l These studies have also shown that new dwelling units consume significantly l , more electric energy than the older existing dwelling units. l .The annual population growth rate over the past decade in the Toledo Edison l service area,is about 0.9%, however, the growth in residenti .11 customer units ) I t.
i during this period in the residential sector has been about 1.6%. This is considerably less than the 6.h% growth rate in usage of electrical energy. This means that the increasing consu=er demand in the household usage of electrical energy is consistent with a rise in the standard of living in the household. In Lucas County, the county containing over 73% of the Toledo Edison service area population, the Office of Economic Opportunity estimatec that there are over 18,000 families (one in eight) with incomes below $3,000. " Survey of Buying Power " Sales Management estimates show that 25% of families in Lucas County have incomes of $5,000 or less per year with another 20% having incomes between $5,000 and $8,000. Clearly, a large segment of the area population is not sharing in a high stan-dard of living. A shift of this segment into a higher standard of living vill mean an increased usage of electricity since an increased usage is directly coupled with the standard of living. The only meaningful way such a shift can come about is through a higher income from employment which requires a rise in industrial and commercial activity, all of which requires an increase in the demand for and supply of electricity. An inability on the part of the Applicants to provide this energy upon demand, either resulting from delays in installing new capacity or forced rationing, as some critics have called for, vill result in a limitation on the general level of prosperity in the areas served and potentially a lowering of the stand-ard of living of the consu=er in the service area. O C N OD 0 SN 8 I A I) DM 9 1 EE
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- 3. Demand-Capacity Situation. 197h-1975 The Davis-Besse Nuclear Power Station is being built as a jointly-owned facil-ity, 52.5% of its output will be owned by The Toledo Edison Company and h7 5%
will be owned by The Cleveland Electric Illuminating Company. Both companies are members of the Central Area Power Coordinating Group (CAPCO). This Group is an operating and generating pool composed of the Applicants, Duquesne Light Company, and Ohio Edison Company. These four CAPCO companies supply electricity in the northern and central areas of Ohio and in the westarn part of Pennsyl-vania as shown on Exhibit I included hereto. The Davis-Besse Unit will be the fourth generating unit to be installed by CAPC0 and it will be the second nuclear unit (Beaver Valley Unit 1 will be the l first). The Davis-Besse Unit will become a part of the CAPCO pool generating capacity and it is needed to provide generating capability to meet anticipated load demand with adequate reserve generation for this pool, During the initial period of its operation, Ohio Edison will be entitled to 280 MW of its output; Cleveland, 31h MW; and Toledo, 277 MW. Table I shows the December 197h and June 1975 load-generation situation for CAPCO with and without Davis-Besse. The generating capacity- figures shown in Table I include the output from Beaver Valley Unit 1 during both the December 197h and June 1975 peek-load periods, and the June 1975 figures include Mansfield Unit 1, scheduled for April 1975 Prior to completion of Davis-Besse, Toledo is entitled to 175 MW from Beaver Valley Unit 1 and Cleveland,10 MW. Suspension of construction during the Re-view Period will absolutely preclude the availability of power production from the Davis-Besse Nuclear Power Station during the December 197h and June 1975 peak-load periods. Table. II shows similar data for the Toledo Edison system and Table III shows
. data for the Cleveland Electric Illuminating system. The official CAPCO load
and generation forecasts, dated March 18, 1970, were used in Tables I, II, and III. This forecast data takes into account the long-range coordinated maintenance requirements and the allocation of generating capability to each company to provide adequate capacity for load and reserve during these main-tenance periods. Table I data showing December 197h and June 1975 which is the CAPC0 1975 peak-load month is summariced below: CAPCO % Reserve
- December 1974 June 1975 Prior to Maintenance With Davis-Besse 21.9 17.6 Without Davis-Besse 1h.0 10.1 With Maintenance With Davis-Besse lh.3 12.h Without Davis-Besse 6.h 5.0 This clearly illustrates the need for Davis-Besse on the part of CAPCO and that without Davis-Besse, there would not be adequate reserve to provide re-liable service to the consumers of the CAPC0 co=panies. This is substantiated by the FPC comments (Exhibit J, Page 3) which deems a 20% reserve cargin before maintenance considerations as requisite to provide pool reliability.
Tables II and III, which are Applicants' components of Table I, show that the Applicants' systems vould have inadequate reserves without Davis-Besse in De-cember 197h and both are deficient in generating capability to =eet load in June of 1975 This clearly shows that without Davis-Besse, Applicants vill be deficient in generating capability and that CAPCO as a group vill have a serious deficiency in reserves and that generating capability equal to Davis-Besse =ust be found I from other sources. 1 TABLE I ' CAPCO PEAK LOAD WEEK December 197h June 1975 With Without With Without Davis-Besse Davis-Besse Davis-Besse Davis-Besse i Net Demonstrated Capability - MW
~
13,002 12,130 13,942 13,070 Net Concurrent System Capability - MW 12,850 11,976 13.572 12.700 Net Purchase from other Systems - MW 536 536 261 261 Available Capability - MW 13,386 12,514 13,833 12,961 e- . Scheduled Maintenance - MW 834 834 609 609 ta Available Capacity for Load - PDi 12,552 11,680 13,224 12,352 Forecasted Peak Load Including Interruptable Loads - MW 10,980 10,980 11,767 11,767 Reserve Over Load With Scheduled Maintenance
- MW 1,572 700 1,k57 585 1
-% 14.3% 6.k% 12.4% 5 0%
Vith No Maintenance Provision
- MW 2,406 1,534 2,066 1,194
-% 21.9% 14.0% 17.6% 10.1%
TABLE II TOLEDO EDISON PEAK LOAD WEEK CORRESPONDING TO CAPCO December 197h June 1975 With Without With Without Davis-Besse Davis-Besse Davis-Besse Davis-Besse
, Net Demonstrated Capability - MW 1,523 1,065 1,523 1,065 Net Concurrent System Capability - MW 1,497 1,039 1,467 1,010 Net Purchase from Other Systems - MW AEP 100 100 100 100 CAPCO 44 219(1) 31 206(1)
- OVEC 27 27 16 16 ,
u Michigan Pool 200 200 - - CAPCO (Delivery) (290) (110)(2) - - I Available Capability - MW 1,578 1,475 1,614 1,332 Scheduled Maintenance - MW 6 6 lik 114 Available Capacity for Load - MW 1,572 1,469 1,500 1,218 Forecasted Peak Load - MW 1,292 1,292 1,389 1,389 Reserve Over Load With Scheduled Maintenance
- MW 280 177 111 (171)
-% 21 7% 13 7% 8.0% (12.3%)
With No Maintengnce Provision
- MW ' 286 183 225 (57) l
-% 22.1% 14.2% 16.2% (4.1%)
r t (1) Includes 175 MW from Beaver . Valley which is TECo's Entitlement for Period until Davis-Besse is available. This would reduce Duquesne's Reserve Over Load by 7 7% in December 1974 and 7 3% in June 1975 (2) Delivery of 180 MW of Toledo Edison's share of Davis-Besse output to Ohio Edison Company eliminated.
TABLE III CLEVELAND ELECTRIC ILLUMINATING PEAK LOAD WEEK CORRESPONDING TO CAPCO December 197h June 1975 With Without With Without Davis-Besse Davis-Besse Davis-Besse Davis-Besse Net Demonstrated Capability - MW 4,146 3,732 4,203 3,789 Net Concurrent System Capability - MW k,100 3,686 4,118 3,704 Net Purchase from Other Systems - MW AEP - - - - CAPCO 18 28(1) - 10(1) OVEC - - - - 8 Michigan Pool - - - - (( CAPCO (Delivery) (450) (350)(2) (41) (41) Available Capability - MW 3,668 3.364 .k,077 3,673 Scheduled Maintenance - MW 46 h6 124 124 Available Capacity for Load - MW 3,622 3,318 3,953 3,549 , Forecasted Peak Load Including Interruptable Loads - MW 3,380 3,380 3,720 3,720 Reserve Over Load With Scheduled Maintenance
- MW 242 (62) 233 (171)
-% 7.2% (1.8%) 6.3% (4.6%)
With No Maintenance Provision
- MW 288 (16) 357 (47)
-% 8.5% (0.5%) 9.6% (1.3%)
(1) Includes 10 MW from Beaver Valley which is CEI's Entitlement for Period until Davis-Besse is available. This would reduce Duquesne's Reserve Over Load by 0.k%. (2) Delivery of 100 MW of CEI's share of Davis-Besse output to Ohio Edison Company eliminated.
B. Alternate Sources of Power. If the Davis-Besse construction permit was suspended during the Review Period, the commercial operation date would be delayed by the length of the Review Period plus about three months required to restart the construction and re-assemble a trained construction force. It is estimated that this would delay the commercial operating date by 12' months. A delay of this duration would make it necessary for the Applicants and CAPCO to obtain alternate sources of generation, either outside or within CAPCO, to reliably serve their loads. Table IV shows the Winter 197h-75 and Summer 1975 load-generation situation for ECAR. This data was obtained from a report, " Load Projections and Resource Planning," to The Federal Power Commission pursuant to FPC Docket R-362, Order 383-2, Appendix A, Items 1, 2, 3, and h, April 1971. Additional generation data without Davis-Besse in both the Winter 197h-75 and Su=cer 1975 is included in Table IV. The load and capacity forecasts used in the Federal Power Commis-sion Report in connection with the Environ = ental Statement (Exhibit J, Page 2) are based on a September 1970 report to the FPC and are slightly lower than the similar data cubmitted in the April 1971 report and used in Table IV. Also, the capacity and reserves figures in the FPC comments did not consider scheduled maintenance outages. Even with these differences in the FPC's and our analysis, the FPC comments substantiates CAPCO's need for Davis-Besse's capacity and the conclusion that CAPCO should not depend upon ECAR for any power during the . Summer 1975 Particular attention is directed to the FPC statement as to the unreliability of ECAR reserves for CAPC0 purposes on Pages 3 and 6 of Exhibit J. Additionally, the data in Table IV assumes the availability of h,173 MW of ca-pacity from the following nuclear power units, all of which are subject to de-
. lays of availability as a result of application of the new procedures. in Appen-dix D or for other reasons.
- kl -
Cook Unit 1 & 2 Beaver Valley Unit 1 Fermi Unit 2 The data in Table IV also assumes the availability of 1h,201 MW of new capacity from the following fossil and pumped storage units scheduled to be placed in service between January 1973 and Summer 1975, including h,500 MW of capacity scheduled for the first six months of 1975, which could be subject to delay in completion: In Service - 1973: Conesville Unit k Ludington Unit 2, 3, h, 5, & 6 E. W. Stout Unit 7 Culley Unit 3 Michigan City Unit 12 Amos Unit 3 Harrison Unit 2 Monroe Unit h Ghent Unit 1 In Service - 197h: Stuart Unit h Mill Creek Unit 2 Gavin Unit 1 Karn Unit 3 In Service First Six Months - 1975: Gibson Unit 1 Miami Fort Unit 7 Harrison Unit 3 Mansfield Unit 1 Northern Indiana Public Service (Undesignated)
, Gavin Unit 2
- h2 -
TABLE IV ECAR Winter 1974-75 Summer 1975 With All With All Planned Without Planned Without Units Davis-Besse Uni ts Davis-Besse Net Demonstrated Cap. (1) - MW 74,372 73,500 80,243 79,371 Net Seasonal Cap.(1) - MW 74,150 73,278 78,804 77,932 Net Sales (2) - MW 738 738 1,008 1,008 Available Capacity - MW 73 h12 72,540 77,796 76,924 Scheduled Maintenance (3) - MW 3,710 3,710 1,576 1,576 Available Capacity for Load - MW 69,702 68,830 76,220 75,348 7
' Forecasted Load. Including Interruptable Loads - MW 57,h67 57,h67 62,941 62,941 Reserve Over Load With Scheduled Maintenance
- MW 12,235 11,363 13,279 12,407
-% 21.4% 19.8% 21.1% 19.7%
With No Maintenance Provision
- MW 15,945 15,073 14,855 13,983
-% 27.8% 26.2% 23.6% 22.2%
(1) Includes Cardinal #2, owned by Buckeye Power, Inc., and projected additional capacity to be owned by Buckeye Power, Inc. (2) Includes delivery to Buckeye Power, Inc. (3) Scheduled Maintenance figures for ECAR are not available; figures shown are estimated at 5% of Net Seasonal Capacity in Winter and 2% in Summer.
Since it would not be prudent for CAPCO to depend upon any firm capacity from ECAR. in this situation, CAPCO would have to install additional generation within its system. The inevitable result is that the necessary generating capability to make up for delay of Davis-Besse must be supplied from the installation of gas turbines. At this time, it would be impossible to obtain and put into operation fossil fuel ~ steam units. Aside from the very high additional expense involved, as shown below, there are other serious objections to' gas turbines. The CAPCO companies already have 9h MW of diesel and gas turbine peaking units installad and plans call for an additional 300 MW prior to the scheduled date of Davis-Besse operation. This represents the maximum desirable amount of this high operating cost peaking equipment which should be installed in proportion to total capacity of the Group for most efficient and economical service. Present CAPC0 capacity planning is firm through 1979 and no additional gas turbine peaking units are scheduled between 197h and 1979 Normal and prudent planning for a foreseeable period beyond 1979 would not include the addition of any sizeable quantity. Since these gas turbine units have a lower efficiency than existing coal and oil-fired generation, the peaking units vould be used only during peak-load periods. As a result, CAPCO's older coal and oil-fired units would operate at a higher capacity factor during the delay and generate more power during off-peak periods. This increased generation on existing units and the new peaking units would burn approximately 2,h00,000 tons of coal and 102,000,000 gallons of fuel oil per year. This increased coal and oil-fired generation would re-lease the following effluents to the atmosphere: CO 6,300,000 Tons / Year 2 SO 2 124,000 Tons / Year
- hk -
... 1
4 NO 10h,000 Tons / Year Fly Ash
- 8,600 Tons / Year
- Based on an assumed average precipitator efficiency of 97% for the Appli-cants ' older coal-fired units.
Also, it would unnecessarily consume additional quantities of our nation's coal and oil reserves that are presently in short supply. C. Cost of Delay. 1. ^ Increase in Cost of the Davis-Besse Project The cost of construction delay at Davis-Besse resulting from a suspension of the construction permit would include the monthly interest cost of funds in-vested, the monthly escalation on all material and labor expenditures that are delayed, and a one-time cost to shut down the construction and to restart it at a later date. These costs have been estimated assuming that the construction permit would be suspended on October 1,1971. The monthly costs of a con-struction stoppage are as follows: Interest Cost of Funds Invested 7 5%/Yr. on $44,730,000 invested up to 10/1/71 during delay $ 280,000/ Month Escalation on Items Delayed 4%/Yr. on $o3,499,000 for Nuclear , Steam Supply System, nuclear fuel, and turbine-generator $ 278,000/ Month 8.7%/Yr.on$118,538,000 for remaining delayed purchases, field construction labor and overheads $ 858,000/ Month Total Escalation $1,266,000/ Month Maintenance and Security Vendor Warran,y Extensions, Construction Skeleton Staff, and Miscellaneous Monthly Expenses 3 250,000/ Month Total Monthly Cost $1,666,000/ Month h5 -
The escalation costs for the Nuclear Steam Supply System, nuclear fuel, and turbine-generator are based upon the price adjustment provisions for delayed shipments in the purchase agreements with the suppliers of these ite=s. The escalation costs for the remaining delayed purchases, field construction labor and overheads are based on the construction experience of the Applicants and the Bechtel Company, who are the architect-engineers for this project. The one-time cost to shut down the construction and restart it at a later date is estimated at $h,100,000. A nine-month suspension of construction, which would delay the commercial startup of the station by 12 months, would add an esti-mated $24,100,000 to the initial cost of the station. This would increase the fixed charge on the station each year during its life by $h,338,000 (at 18% fixed charge rate) or by 0.68 mills /KWH (using an 80% capacity factor).
- 2. Delav Costs Associated with Alternate Source of Power In addition to added capital cost to the Davis-Besse project which would re-sult from a suspension of the construction permit, there are added costs to the Applicants and other CAPC0 members- that would be incurred in providing an alternate source of power for an estimated one-year delay in commercial opera-tion of the Davis-Besse Station. These costs result from added fixed charges, operation and maintenance costs, and fuel costs. Such costs have been estimated for an alternative involving the addition of app roximately 872 MW of gas turbine peaking units for operation in Dece=ber 197h and total $57,507,000. Details of these costs are given on Table V.
h6 -
~
TABLE V DELAY COSTS FOR GAS TURBINES ALTERNATE SOURCE OF P0hTR Basic Data Fixed Charge Ratu - 18% Present Worth Year - 1975 Present Worth Rate - 7.5% Plant Depreciation Life - 25 Years Current Davis-Besse Cost Estimate - $269,918,000 Current Cost Estimate For Gas Turbines - 95,920,000 Fixed Charge Costs Davis-Besse First Year Fixed Charge Saved if Delayed ($h8,585,000) Present Worth of Last Year Fixed Charge 8,h0h,000 Sum of Present Worths of Fixed Charges on Added $2h,100,000 Capital Cost hh,982,000 Added Fixed Charges on Davis-Besse Costs $ h,801,000 Gas Turbines Sum of Present Worths of First Three Years of Fixed Charges * $48,266,000 Sum of Present Worths of Last Three Years of Fixed Charges Eliminated * ( 7,916,000) Sum of Present Worth of Savings of Three Years ' Escalation Costs ($11,980,000) ( 19,3h9,000) Added Fixed Charges for Gas Turbines $21,001,000 Total Added Fixed Charge Costs $25,802,000 Overation and Maintenance Costs Savings in 0 & M at Davis-Besse ($ 2,658,000) Gas Turbines and Increased Coal Generation Gas Turbines $ 2,880,000 Coal Generation 3,860,000 Total Added 0 & M Gas Turbines & Coal $ 6,Th0,000 Total Added 0 & M $ h,082,000 Fuel Costs Davis-Besse Fuel Cost Displaced by Delay ($1h,h37,000) (For 6.397 x 10# KWH) Gas Turbines and Increased Coal Gener*. Lion Gas Turbines (For 0.960 x 109 KWH) $12,960,000 Coal (For 5.h37 x 109 KWH) 29,100,000 Total Added Fossil Fuel Cost $h2,060,000 Total Added Fuel Cost $27,623,000 Total Cost of Delay - $57,507,000
- If gas turbines were installed to provide capability needed due to delay of
-Davis-Besse, the CAPCO units scheduled for 1975 and 1976 would not be delayed due to their advanced stage of procurement and construction and the first unit to be delayed would be the unit scheduled for 1977 This results in capacity added three years in advance of scheduled requirements to provide for a delay of Davis-Besse.
h7 -
V. Conclusions. The Davis-Besse site acquisition; site arrangement; station design in regards to effect of postulated accidents, radiological considerations of routine radia-tion releases and water quality aspects; design of the off-site facilities; and construction activities to date have all been undertaken with a proper consid-eration of the environmental aspects of the project and a proper balancing of all the factors involved. Various aspects of many of these factors have changed in the course of project development. Some very major changes have been incor-porated such as the closed cycle evaporative cooling tower system to provide for condenser cooling where a balancing of the need for timely completion of the project was weighed against environmental concerns of an open lake cooling system and questions of approved water quality standards. The station design as now formulated and which is now in the process of being detailed and built has a proper balance for all considerations of the environment and does not have a significant adverse effect on the environment. The Supplement to the Environmental Report will address all aspects of the pro- - ject which involve a possible impact on the environment and will discuss alter-natives which have been considered in establishing the current design and con-struction progress to date and feasible alternatives available for reducing any adverse effect on the enviror;nent. None of these alternates are expected to be required as a result of the Commission's ongoing NEPA environmental review. Constructica t' date has not had any significant detrimental effect to the en-vironment and continued construction during the Review Period can have no sig-nificant adverse effect. Continued construction during the Reviev Period will not physically foreclose adoption of any feasible alternative and any incremental cost of adding systems later vill be much less than the cost of delay which will automatically occur if construction is stopped during the Review Period. h8 -
~
There is a critical need for power to serve the consumers in Applicants' ser-vice areas and in other CAPCO service areas which can be met by the timely ccmmercial operation of the Davis-Besse Station on the presently scheduled date of December 1974. Prudent planning by the members of CAPCO and the larger system of ECAR has provided for the installation of generating facilities and transmission lines on a schedule to meet this consumer demand with dependable and lowest possible cost service. A delay in the Davis-Besse project during the Review Period and possibly other nuclear projects will seriously disrupt this prudent planning and impose con-siderable and unwarranted costs on the Applicants, other members of CAPCO, and ultimately the consumer.
-There is no justific.. tion, balancing all aspects of the environment, for con-sidering the suspension of the Davis-Besse Station construction permit during the ongoing NEPA Review Period. In contrast, there would be a decided adverse impact if the construction permit were suspended.
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3 I EXHIBIT F
- 1.
- ENVIRONMENTAL CONSIDERt.TIONS OF LIQUID RADIOACTIVE WASTES FROM THE DAVIS - BESSE NUCLEAR POWER STATION i
1 a I-
' Statement by James E. Martin, Ph.D.
' Acting Deputy Director, Divir. ion of Technology Assessment-Office of Radiat. ion Programs Environmental Protection Agency before the Ohio Water Pollution Control Board Port Clinton, Ohio
[ July 28, 1971 9 + F-1
. , . . .- -.~.,,m_.,- . _ .--,-,,m.-wy- y ,y - + < <
.In response to requirements placed on Federal agencies by the National Environmental Policy Act, our group performed a review of the potential environmental effects of the Davis - Besse Nuclear Power -Station in September, 1970 The review was conducted by our staff when we were in the U.S. Department of Health, Education and Welfare; the Boar.d is probably aware that several components of that Department were transferred to the Environmental Protection Agency when it began operation December 2, 1970.
The review of the Davis - Besse Nuc1 car Power Station was based on: 1) the applicant's Preliminary Safety Analysis Report and environmental report; 2) a site visit; and 3) consultations with the Ohio Department of Health. Evaluations were made of site suitability, radioactive waste disposal, potential radiation doses to the public, environmental surveillance, and emergency planning. It is our under-standing that the purpose of this hearing is to explore water quality aspects only; tFucsfore, even though we have reviewed other aspects of the facility, we will limit our remarks to liquid radioactive wastes only. In our evaluation of September,1970, uc made a number of comments that have since been resolved to our satisfaction. I would like to list the more substantive ones:
- 1) We recommended that the applicant and the Ohio Department of Health develop a cooperative pre- and post-operational environmental surveillance program since both have a e
F-2
s 2 responsibility to maintain a qual,ity environment. A program conducted by the applicant would be acceptable if data are provided to the Ohio Department of Health officials who should make population dose estirrates and interpret these in the health interest.
- 2) It was recommended that two important exposure pathways in the aquatic environment be given special consideration in developing the surveillance program for the plant. First, since the Locust Point area is a popular sport fishing location for walleyes, it was recommended that this pathway should receive preoperational study and should be monitored routinely after the facility begins operation. The second potentially significant exposure pathway that was recommended for monitoring was tritium in drinking water from Lake Eric,
- 3) It was also recommended that routine surveillance should include monitoring of drinking water from Lake Erie, fish, milk, external gamma radiation, and commercial food crops.
The applicant has responded to thW recommendations by stating that they "will cooperate closely with the Ohio Department of Health and other interested agencies in the detailed planning of the environ-mental monitoring program";"that the monitoring program will include surveillance of all items mentioned"; and that " monitoring data will be providedhtheDepartmentofHealth." Although some of the details of the
*~
U.S. Atomic Energy Commission, Division of Reactor Licensing, " Detailed Statement on the Environmental Considerations of the Davis-Besse Nuc1 car Power Station," November 20, 1970 ( F-3
t 3 program are incomplete at this stage, we are reasonably assured that an adequate environmental surveillance program for this station will be developed. There are two areas which we commented on that are not resolved to our complete satisfaction at this time. First, we recommended that a population dose assessment be done in order to determine the total impact of the liquid radwaste discharges from the plant on population exposure and to assist in environmental surveillance planning. Lake water users both east and west of the site and reconcentration of radionuclides in aquatic biota must be considered when evaluating population exposure. The detailed statement by the AEC states that, "the a) plicants have indicated, and the regulatory staff agrees, i that a conservative estimate of the maximum dose that a member of the general public could conceivably receive as a result of the discharge of low-level gaseous and liquid radioactive wastes is less than 5 ) millirems per year. The average dose to the general public would be considerably less..." We are able to support this conclusion; however, ! l this estimated dose rate does not constitute a complete population dose 4 estimate in that it neglects the total dose impact. A complete popula-tion dose assessment expressed as man-rem /yr taking into consideration
- environmental and demographic factors should be performed. This is not to suggest that the total radiological impact will be unacceptabic, but - to iterate that such information is most important in assessing the environmental effects of such facilities and it ought to be provided.
l 1 1 l 6 F-h e
4 0 The second point that is not completely resolved, in our view, is the use of the liquid waste treatment systems. The systems are well designed and if utilized to their full capability during all plant operations, liquid radioactive waste discharge.to the environment and resulting effects would be minimal. The impact of the facility I on the aquatic environment will, therefore, be largely a function of waste management practices since designs are adequate. The operator of the plant has available several different routes of treatment through these systems, and, in establishing operating procedures for them, he should routinely use those processing routes which will result in the lowest effluent level. Although the applicant has indicated his , intent to use such systems fully, we are hopeful that in his work with the Ohio Water Pollution Control Board and other regulatory agencies, he will specify criteria for processing liquid wastes through dhe various system components so that environmental effcces will be maintained at minimal levels commensurate with the capability of the design. If the recommendations previously mentioned are given proper consideration, we are of the opinion that the Davis - Besse Nucicar Power Station can be built and operated with minimal public risk or environmental effects due to liquid discharges from the station. These recommended actions appear to be both prudent and reasonabic and would enhance the capability of operating the Davis - Besse Nuc1 car Power Station with a minimal environmental impact. 9 F-5
June 1971 EXHIBIT G The Thermal Plume In Lake Erie Caused By The Discharge of Heated Effluent From the Davis-Besse Nuclear Power Plant A Statement Prepared by Donald W. Pritchard Introduction My name is Donald W. Pritchard. I am Director of the Chesapeake Bay Institute and also Professor of Oceanography, Department of Earth and Planetary Sciences, The Johns Hopkins University. I hold a B.S. degree in Meteorology and M.S. and Ph. D. degrees in Oceanography. For the past 23 years I have conducted and directed research programs concerned with the movement and mixing of waters in lakes, estuaries, and marine coastal aieas, and with the chemistry and biology of these water bodies. Investiga-tions of the heat budget have been a part of my studies of the physical processes in natural water bodies and for the last six years I have concen-
~
trated on studies of the fate of excess heat discharged with the condenser cooling water flow from steam-electric generating plants. I have served as an advisor to federal, state and local government agencies concerning the fate of waste materials discharged into natural water bodies, and as a consultant to industry. In recent years, much of my consulting activities have been carried out as a partner in the firm of Pritchard - Carpenter, Consultants. I have been concerned with the conservation and management of our natural resources for over 22 years. I was a member of the Board of Natural Resources of the State of Maryland for 12 years, and also served as Vice-Chairman of that Board. I am presently serving the State of Maryland as a member of the Board of Review, Department of Natural Resources; as a member of the Air Quality Advisory Board, State Health : Department; and as a member of the Radiation Control Advisory Board. I 1 was a member of the Committee on' Oceanography, National Academy of { G-1 l
2-Sciences for 12 years, serving for some six years as Chairman of the Panel on Radioactivity in the Marine Environment of that Committee. I was also Co-Chairman of the National Academy of Sciences - National Academy of Engineering Joint Workshop on Coastal Waste Management. A curriculum vita is attached to this statement as an appendix. I was asked to present this statement by The Toledo Edison Company of Toledo, Ohio. However, the opinions and conclusions I present here are my own, and have not been dictated in any way by personnel of that company. Likewise, this statement does not necessarily represent the views of my principal employer, The Johns Hopkins University. The Fate of Excess Heat Discharged Into a Natural Water Body In the following discussion I will frequently use the terms " excess heat" and " excess temperature". By the term excess heat I mean the artificially produced heat introduced into a natural waterway from any given activity of man, as, for example, in the production of electric power. The term excess temperature is a measure of the concentration of excess heat in the water-way, and is given by the difference between the temperature at any position and time in the waterway which occurs under conditions of a discharge of
. excess heat, and the temperature at that point and time which would have occurred in the absence of any thermal discharge.
Consider now the processes which affect the fate of excess heat intro-duced into a natural water body, and which control the distribution of the resulting excess temperature. Two categories of processes control the distribution of excess temper-ature in the waters of a lake, an estuary, or off a coastline into which the condenser cooling water from an electrical generating plant is discharged. The ultimate sink for all the excess heat thus discharged is the atmosphere. Thus one of the two categories of processes is the loss of heat from the G-2
water surface to the overlying air. The second category is dilution, which results both from the process of momentum entrainment and the process of natural mixing, of the heated effluent by the cooler receiving waters. Despite the fact that the ultimate fate of all the excess heat discharged is a transfer from the water to the atmosphere by surface cooling, it has been clearly demonstrated that in the case of discharge of heated effluent into a relatively large body of water (that is, a body of water having a surface area large compared to that required for transfer of the excess heat to the atmosphere even at very small surface excess temperatures, or a water body having a natural renewal rate due to inflow of "new" water which is large compared to the volume rate of discharge of heated effluent) then the distribution of excess temperatures in that segment of the thermal plume in which the excess temperatures exceed approximately one-tenth the initial excess temperature is determined primarily by the processes of dilution. Surface cooling plays a dominant role only in areas having relatively small excess temperatures. As distinct from the situation in the definable thermal plume, the mean excess temperature for the surface layers of the entire receiving waterbody, or any significant segment of the waterbody, is usually determined primarily by the process of surface cooling, and secondarily by dilution of the excess heat with the volume rate of flow through the water body. When a heated effluent is discharged horizontally into the surface layers of a natural body of water via an open canal or a closed conduit, the effluent will in general have a different velocity than that of the receiving wate rs. Consequently, the momentum of the introduced flow will be different from that of the natural waterbody. Usually the heated discharge will initially be directed offshore, approximately normal to the shoreline. Since natural motion in the nearshore region is directed approximately parallel to shore, . the effluent will have an excess momentum in the offshore J direction', and a deficiency of momentum parallel to shore. In the absence G-3
4 of any longshore current the excess momentum in the effluent plume is lost by entrainment of receiving water. Since this water is of lower temperature
.than the heated discharge, the excess temperature of the thermal plume will be decreased by dilution, at nearly the same rate as the decrease in excess velocity.
In the presence of a longshore current, the thermal plume will be bent in a down-current direction, ultimately becoming parallel to the shoreline. If the discharge is made from the shoreline, or via an open canal formed by jetties extending out from the shore, the bending of the plume can result in a reduction to the rate of momentum entrainment, and hence to the rate of dilution of the excess temperature, as a result of cutting off of the supply of dilution water on the inshore side of the jet. The degree to which such a reduction in rate of dilution occurs depends inversely on the ratio of the speed of the heated effluent at the discharge orifice to the speed of the longshore current. The larger the initial speed of the thermal discharge with respect to the speed of the longshore current, the less will be the reduction in the rate of dilution, as compared to the case of zero longshore current. If the heated effluent is discharged from an offshore discharge structure, connected to the shore via a pipeline or closed conduit buried beneath the bottom, then the natural longshore flow is free to pass on the inshore side of the thermal plume. If the discharge structure is far enough offshore, the dilution rate in the bent plume will be essentially the same as in the case of zero longshore current. Studies of the horizontal discharge of a heated effluent into a water body of large depth have shown that momentum entrainment of cooler dilution water into the thermal plume occurs both horizontally through the sides of the plume and vertically through the bottom of the plume. As a result of this three-dimensional entrainment, the excess temperature along the axis of the plume resulting from the horizontal discharge of a heated effluent through a circular or rectangular-shaped orifice varies as the inverse first power l i G-h
of distance from the orifice. In a natural water body the depth is finite and in many cases will limit vertical entrainment. Usually, at least in the warmer period of the year, the water body will have a natural, stable vertical density gradient. The combination of this natural vertical stability with the added buoyant stability at the bottom face of the thermal plume will also significantly limit vertical entrainment. When the initial vertical thickness of the heated jet discharge is equal to some critical depth of mixing peculiar to the natural processes in the waterway, then a relatively simple model involving only horizontal entrainme.nt is adequate in defining the rat'e of dilution in the thermal plume. For such a two-dimensional entrainment process, the decrease in temperature with distance along the plume axis is proportional to the inverse one-half power of distance from the discharge orifice. If the initial thickness of the thermal plume is less than the characteristic mixing depth, then the plume will thicken to that depth by vertical entrainment, unless limited by the bottom. Observations of thermal plumes in natural water bodies similar to Lake Erie suggest that a conservative estimate of the vertical thickness of the surface water layer within which the most of the excess heat will be distributed by vertical entrainment and mixing is about 10 to 15 feet. For a heated discharge of given volume rate of flow and given initial excess temperature, the rate of dilution of the thermal plume by cooler receiving water increases with increasing speed of flow at the discharge orifice, and hence with decreasing size of the discharge orifice. For a fixed, speed of discharge, and hence fixed cross-sectional area of the discharge orifice, the shape of the discharge orifice affects the rate of dilution to some degree. Recent evidence from flume model studies reveals that for an off-shore discharge an elongated slot of small vertical dimension provides a more rapid rate of decrease of excess temperature with distance along the thermal plume than does an orifice of rectangular or circular cross-section. 3-5 l
9 At a point along the thermal plume where mcmentum jet entrainment has produced a dilution of the heated effluent of between 5:1 and 10:1, natural processes of turbulent diffusion become the dominant mechanism for further dilution. The rate of decrease in excess temperature along the axis of the plume within this region of the plume dominated by natural mixing processes is proportional to the inverse first power of distance. Loss of excess heat from the water surface to the atmosphere by surface cooling occurs from all areas of the thermal plume. The rate of heat loss per unit area is greater from water having a high excess temperature than from water having a low excess temperature. However, processes of dilution by momentum entrainment and natural turbulent mixing result in such small surface areas within the thermal plume having high excess temperatures, that most of the excess heat is lost to the atmosphere from the very rnuch larger areas of very low excess temperature. Numerical Model of the Thermal Plume A number of semi-theoretical, semi-empirical computational models of the distribution of excess temperature in a thermal plume resulting from the discharge of excess heat into a natural water body have been developed in recent years. The particular model used in obtaining the computed distributions of excess temperatures to be discussed later in this statement represents the joint effort of H. H. Carter, a research scientist at the Chesapeake Bay Institute, and D. W. Pritchard, the author of this statement. It is a model which is being updated on an almost day-to-day basis to include new information being developed in laboratory experiments, hydraulic model studies and field surveys. A detailed description of the computational model used here is given in a paper entitled " Design and Siting Criteria for Once-Through Cooling Systems", which I presented at the 68th National Meeting, American Institute of Chemical Engineers, held in Houston, Texas, 2 ' March, 1971, a copy of
-6 i l
\
l
which is attached to the official copy of this statement. Copies will be provided to interested parties on request. In this statement I will briefly outline the stepwise procedure involved in the computational model employed in preparing the predictions of exc.ess temperature resulting from the proposed heated discharge from the Davis-Besse Nuclear Power Plant. Some evidence supporting the validity of the predicting model will also be given. The heated effluent from the Davis-Besse Nuclear Power Plant re s ult s from the necessity of discharging the blow down water from the natural draft, evaporative cooling tower. The volume rate of discharge and the excess heat contained in this discharge are small fractions of the flows and heat rejection rates associated with once-through cooling systems. The heated effluent is to be discharged through a buried pipeline from a submerged off-shore discharge structure, at a point some 1000 feet offshore. The initial direction of the heated jet discharge is about 45' offshore. The discharge orifice is to be sized such that the discharge velocity will be 6. 7 ft - see for a volume rate of discharge of 20,000 GPM. The cross-sectional area
- of the discharge orifice will then be about 6. 7 ft . The preliminary design calls for a slot-shaped orifice having a vertical dimension of 1. 5 ft. and a lateral dimension of slightly under 4. 5 feet.
The depth of water at the point of discharge is 6 feet, and the depth increases in the direction of the flow in the thermal plume. The mean depth of water over the area of the thermal plume will be about 8 feet. As described above, the thermal plume will thicken by vertical entrainment to occupy a layer of some 10 feet deep if not inhibited by the bottom. In this case, the thermal plume will thicken by vertical entrainment from its initial vertical dimension of 1. 5 ft. to occupy the full depth interval of 8 feet. Sub s equent dilution will result entirely from processes of horizontal entrainment and horizontal turbulent diffusion. Under these conditions the step-wise procedure involved in use of the computational model is as follows: 9
(1) The distribution of excess temperature in the thermal plume which would result from hotizontal entrainment and horizontal turbulent mixing only is computed. The pertinent input parameters for this calcula-tion are the width of the discharge orifice and the initial excess temperature. (2) This distribution is corrected to take into account the vertical entrainment in the portion of the thermal plume near the discharge orifice, as the vertical dimensions of the plume increase from the initial value of
- 1. 5 feet to a final thickness of 8 feet.
(3) The distribution of excess temperature thus obtained as a result of considerations of the processes of both vertical and horizontal dilution is finally corrected to take into account the effects of surface cooling.
. The adequacy of the computational model used here has been verified by actual comparison with the results of field measurements of the
- temperature distribution in waterways adjacent to existing power plants using once-through cooling systems, and with hydraulic model studies. Five examples of such comparisons will be briefly described here. The first two i
verification cases will be discussed in somewhat more detail than the others, since these two have many features in common with the situation at the Besse-Davis Plant. In April of 1968 a field survey carried out by Dr. Lawrence P. Beer of Bio-Test, Inc. and Dr. Wesley O. Pipes of Northwestern University provided data on the distribution of temperature in the thermal plume from l the Waukegan Power Station on the western shore of Lake Michigan. Quite i independently I undertook to predict the distribution of temperature in this plume under the conditions of plant discharge, meteorological parameters, i ambient lake temperatures, and lake currents which prevailed at the time of the field survey. Figure 1 shows the comparison between the computed ; and observed temperatures along the axis of the thermal plume. The comparison is very good.except near the mouth of the discharge canal, where the computational model gave higher temperatures than were observed. This l 1 G-8 ) i I
60 - Figure 1 59 - Wadkegan l' owe r Station. Predier "el tempe ra-tures along axis of thermal plume as function _ of distance from point of clischarge into Lake Michigan, for ambient lake temperature dec reas-57 -
- ing linearly with distance offshore from shore, from 48"F at shore to 43*F at a distance of 6000 56 -
e feet from shore. Closeri circles are maximum
<listances from discharge at which specified integer values of the temperature were observed 55 -
by 13eer and l'ipes (15), in April 1968 _ 54 - u. t, 53 - s 52 - e o - e l O v:) - S Si - E e F SO - 49 - e 48 - e 47 - I l l I I I i l 1 l l 500 i000 1500 2000 2500 3000 3500 4000 4500 5000 5500 Distance f rom Point of Discharge ( Feet)
departure is not surprising, due to the difficulty in locating the field measure-
~
ments exactly at the center of the relatively narrow, meandering thermal plume near the point of discharge. Measurements made off the axis of the plume'would have lower temperatures than those expected on the axis. Figure 2 shows the observed and computed horizontal distribution of temperature in the plume. The verification shown by this figure is also adequate. At Waukegan, the discharge orifice has a depth of 5 feet. Shortly offshore from the discharge, the depth to the bottom increases on about a 1% grade. The thermal plume begins to thicken by vertical entrainment as soon as the water depths allow such entraintnent, and this entrainment continues until the plume attains a thickness of about 10 to 12 feet. Thereafter only horizontal entrain-ment appeared to contribute to dilution of the thermal plume. Hence this verification involved the combination of vertical entrainment over a portion of the plume length, horizontal entrainment, horizontal turbulent diffusion, and surface cooling, all factors present in the computations made for the Davis-Besse Plant. The cornputational model used here was also employed to predict the probable distribution of excess ternperature in the thermal plume from the proposed Zion Nuclear Power Station on Lake Michigan. Each unit of this plant will have a submerged offshore discharge structure, with an elongated i discharge orifice three feet in vertical thickness and some 75 feet wide, located on the bottom in some 10 to 12 feet of water depth. Since the compu- l tations for the Zion Plant represented the first time the computational model ) had been used for a discharge orifice of this shape (i. e. , having a vertical l dimension small compared to the expected ultimate vertical thickness of the ! thermal plume), a large scale hydraulic model of the discharge structure l and of a segment of Lake Michigan adjacent to the plant site was constructe.d at the Alden Hydraulic Laboratories, Worcester, Mas sachus etts. The size I and physical characteristics of this model allowed a comparison to be made ' between the computed and observed distributions of excess temperature G-10
4. 4. 4.
^48 48
** N '51 o 49 52 3
~54
.o
- p. . .
.. .1 ., .
- 4. 48 4g
- 4. .. 4.
j: 48 Figure 2 6 9 6 ) Waukegan Power Station. Predicted distribution of temperature in the thermal plume (contours), and D observed temperatures during survey of 30 April 1968 (small numerals). GD C i i i t i I i i I I i i I i i i i i A , M O 200 400 600 800 1000 1200 1400 1600 1800 2000 2200 2400 2600 2800 3000 3200 3400 3G00 353 - a
along the axis of the thermal plume out to dilutions of about 3:1 (i. e. , to the point in the thermal plume where the excess temperature had decreased from its initial value of 20*F to a value of 7'F). This is just the region of the plume where vertical entrainment auguments the effects of horizontal entrainment. Figure 3 shows a comparison between the observed and com-puted excess temperature distribution along the plume axis. This comparison
, indicates that any error in the numerical model is a conservative one - that is, the numerical model predicts somewhat higher temperatures than were observed in the hydraulic model.
Prior to the construction of the Ginna Nuclear Power Plant on the south shore of Lake Ontario, the computational model used here was employed in predicting the distribution of excess temperature in the thermal plume from that plant. Since the plant has gone into operation, over fifty field sur eys of the temperature distribution in the thermal plume in Lake Ontario off this plant have been made. These observations confirm the adequacy of the predicting model. The computational model which I have used to predict the probable distribution of excess temperature in the thermal plume from the Davis-Besse Plant was also employed in thermal predictions for the Surry Nuclear Power Plant on the James River estuary, and for the Calvert Cliffs Nuclear Power Plant on the Chesapeake Bay. These plants are still under construction, but hydraulic model tests were conducted for both cases. The computed distributions of excess temperature and the distributions as observed in the hydraulic models were in close agreement in both cases. l Computed Distribution of Excess Temperature The computational model described above has been used to predict the distribution of excess temperature in the thermal plume for the Davis-Besse Plant for two situations. The first computation is for the case of the maximum G-12
14.0 - \
\ Figure 3 k Results of Ilydraulic hiodel Tests
\ Compared to Results of Numerical 13.0 -
\ Prediction hiodel, for the length,
\ . f, of the area contained within umerlCal thf,given isotherm of excess p Predict,oni tempe ratu re , 9, as a function of e.
12.0 - Model Results g
\
B Hyd raulic Mod eI~ \
*F I I'O \
- Tests. Results g
( B est Fit Curve, Tests 004,005, \
- o 006 and 007) \ 7
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\
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\
\
9.0 - 8.O - 4 7. 0- .- 1 l l ! I I I I 200 300 400 500 600 700 800
! Lg,ft
monthly mean discharge of excess heat. This situation will occur in April, when some 88 x 10 BTU . hr of excess heat will be discharged in an average volume rate of flow of 9,220 GPM (20. 55 ft 5 ), having a temper-ature of 19.1 'F above ambient lake temperature. Table 1 gives the results of this computation. The second case for which computations were made is for the maximum daily discharge of excess heat. This situation involves a discharge of 6 138 x 10 BTU hr of excess heat in a volume rate of flow of 13,800 GPM
~
(30. 8 ft 5 ), having a temperature of 20 'F above ambient lake tempera-ttire. Table 2 gives the results of this computation. Note tint the areas contained within the thermal plume as defined by excess temperatures of 1 'F and greater are quite small, as shown by Table 1 and Table 2. For the case of the maximum monthly discharge of excess heat the area having excess ternperatures of greater than 1 'F is less than 2 acres, and the corresponding area for the case of the maximum daily discharge of excess temperature is only slightly greater than 2 acres. Most of the time. the thermal plume will be even smaller than for these two cases. Further comments on the size of the thermal plume will be made later. The small size of the thermal plume reeults primarily from dilution due to momentum entrainment and turbulent diffusion. Most of the excess heat will be lost from areas having very small excess temperatures and lying outside the thermal plume as defined by the 1 *F excess temperature isotherm. It is necessary to show that the segment of the lake supplying the dilution water, in this case the Western Basin of Lake Erie, will have neglegibly small mean excess temperatures resulting from the discharge of excess heat from the Davis-Besse Plant. This can be shown as follows: The rate of Icss of excess heat, d -- f rom the surface area, 9 Ak g of a segment of the Lake having a mean excess temperature, I, is given by 8 =[ 5 G-lh
15 - Table 1 l 4 The length, 2 , the maximum width, b g, the vertical thickness, 9 h, g and the area, A g, defined by specified isotherms of excess temperature, 9, in the thermal plume from the Davis-Besse Nuclear Power Plant, for the case of the maximum monthly dis-charge of excess heat (88 x 10 BTU
- hr" ) . The initial excess temperature is 19.l'F, in a volume rate of ficw of 9,220 GPM.
l 9 (' F) Jg (ft.) bg(ft.) hg(ft.) Ag(Acres) 8' 82 21 2.0 0.03 6' 119 30 2.3 0.07 5' 144 36 2.5 0.10 4' 191 48 2. 8 0.18 3* 249 62 3.2 0.31 2' 355 89 4.0 0.62 l' 623 156 5.9 1.92 l l l l l 1 6
. . l l
G-15
Table 2 The length, 1 , the maximum vidth, b g, the vertical thickness, 9 h, and the area, A, defined by specified isotheres Of excess g g temperature, G, in the thermal plume from the Davis-Besse Nuclear Pcuer Plant, for the case of the maximum daily dis-6 ~ charge of excess heat (138 x 10 BTU.hr ). The initial excess tempe rature is 20* F, in a volume rate of flow of 13,800 GPM. 9 (' F) Jg (ft.) bg(ft.) hg(ft.) A 9(Acres) 8' 87 22 2.1 0.04 6' 125 31 ~ 2.4 0.08 5' 152 38 2.6 0.11 4* 199 50 2.9 0.20 3' 264 66 3.3 0.34 2' 377 94 4.1 0.70 l' 658 165 6.1 2.14 1 9 c-16
where A is the surface cooling coeficient. If the volume rate of flow through the segment is designated Ov , then the rate of loss of excess heat in the flow-through is given by q h, v =YcpQv5 where fc is the product of the density times the specific heat of water. For fresh water f c varies from 62. 6 BTU ft" - (
- F) at 40 *F to 62.1 BTU ft" (
- F) at 80
- F. The sum of these two loss terms must equal the rate of addition of excess heat, Q. Hence the mean excess temperature of the segment is given by:
- Qu
. e ~p sA; + f cyQ consider the month of maximum discharge of excess heat from the Davis-Besse Plant, that is, the month of April. For April the value of g is 6 -1 estimated at 88 x 10 BTU hr . The ambient Lake temperature for April is about 45'F. For this ambient temperature, and a wind speed of say, 10 mph, the surface cooling coefficient, g has a value of about
~
- 3. 65 BTU ft" (*F) hr . For the Western Basin of Lake Erie, the surface 10 2 area, AAg , is 3. 25 x 10 ft , and the volume rate of flow through the 8 3 -1 basin is 200,660 cfs or 7. 23 x 10 ft hr . The resulting mean excess temperature of the Western Basin is then, using these figures in the above equation:
4 = 0.0005 *F. This value is sufficiently near zero to be neglected in the thermal plume calculations. It has already been noted that the surface area of the Western 0 2 Basin is 3. 25 x 10 ft , or 7. 69 x 10 acres. The volume of the Basin is
- 7. 82 x 10 ft , and it has a mean depth of 24 ft. Some indication can be obtained concerning the significance of the dimensions of the thermal plume G-17
as computed above, say, for the month of maximum discharge of excess heat, by comparing these dimensions to,the size of the Western Basin. In the following tabulation the re.tios of the area affected by excess temperatures equal to or greater than the given values. (9), to the area of the Western Basin; and also the ratios of the volume affected by excess temperatures equal to or greater than the given values, (9), to the volume of the Western Basin, are given. Area Area Affected Ve rtical Volume Affected 0 *F (Acres) Area Western Basin Thickne s s Volume Western Basin 6* 0,07 1/11 million 2. 3 1/115 million 5' O.10 1/7. 7 million 2. 5 1/74 million 4* 0. 18 1/4. 3 million 2. 8 1/37 million 3' O.31 1/2. 5 million 3. 2 1/19 million 2* 0.62 1/1. 2 million 4. 0 1/7.4 million l' 1.92 1/0. 4 million 5. 9 1/1.6 million Another indication of the relatively small size of the thermal discharge from the Davis-Besse Nuclear Power Plant is to consider the magnitude of the natural source terms to the heat budget of Lake Erie. On an annual average, the sum of the input of solar radiation to the Lake surface and of the input of long wave radiation from the atmosphere to the Lake surface is about 50 trillion
~
BTU hr . This is nearly a million times greater than the annual average input of excess heat from the Davis-Besse Plant. Of more significance, however, is the time variations in the natural source terms to the heat budget of the Lake. In addition to the regular diurnal and seasonal variations there are relatively large non-periodic variations having time scales ranging from a fraction of a day to many years. This variation is best revealed by examining the time fluctuations in the natural surface temperature of the Lake. Figure 4 shows the natural temperature , variation of the Lake waters in two ways. The lower graph in this figure shows G-18
YEARLY WATER TELtPERATURE CURVE, PUT-IN-BAY, OHIO AND AIR TER.!PERATURE AT TOLEDO, OHIO
#N i FEB i MAR , APR g MAY i JUN i JUL ,AUG i SEP i OCT i NOV i OEC i 4 o. v 'N,
/ s Av Water Temp.
/ /y s
/ .. . g Water Temp. Rangen . - Oy-A g \
s _/ \ 1918 -19 65 T/ ,
\ %., \
/ '
/ \
f g
/ u. %
/ i \.Q. \
Av. Air Temp.% ,e \" ., e s.s. \ss j f /.-
/
f e w w a: 's' . N
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- _e 'Q..
..............*,.- 30 .
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l 54 I\ F l\ I\ h \ u t\ m m ss -
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H , E n-Boy I 51 - g k ( V \ > 50 -
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y
. I loE n.e i i i 49 i i 1920 1930 1940 1950 1960 ANNUAL AVERAGE Y!ATER TEMPERATURES AT PUT-I N - B AY, OHIO AND ERIE, PENNSYLVANIA 1919 -19 65 (FROM OHIO DIV. OF WILDLIFE AND U. S. BUR. COMM. FISH. DATA)
Figure 4 i
-p )
_J
that the annual mean temperature varies from year to year over a range of some 6
- F. The upper graph indicates that sim. tr year-to-year variations apply to the mean monthly temperatures, and certainly to the year-to-year variations in average temperatures taken over periods shorter than a month.
This tnSe of time variation in temperature is typical of natural waterways at mid-latitudes. In addition to time variations in lake temperature, sorne studies in Lake Erie itself, coupled with extensive studies in other similar water bodies show that natural spacial variations on the order of 2 to 3 *F over distances of 5 to 10 miles often occur. These spacial fluctuations are in addition to any regular trend in the temperature field, and the duration over which these temperature anomalies last is also highly variable. Thus the biota in a body of water such as Lake Erie are naturally exposed to irregular temporal and spacial variations in temperature of the same magnitude as those associated with the thermal plume. Biological Significance of the Thermal Discharge Sorrie ecologists have claimed various detrimantal effects of heated discharges on the biota of natural water bodies. Most of the evidence for such claims comes from experiments carried out in the laboratory which are I not actually applicable to the real environment. Some of the apparent l evidence supporting claims of biological damage due to thermal discharges ' into large water bodies results from failure to distinguish thermal effects from other factors such as the use of antifouling biocides and mechanical 1 damage due to inadequate intake design. l One of the difficulties in conducting laboratory experiments which 1 are applicable to the thermal discharge problem in the real environment is the fact that the actual thermal plume is a dynamic rather than a static. phenomenon. The dynamic character of the thermal plume is accentuated in the case of a high discharge velocity for the heated'ef'luent. Water and any l G-20
contained organisms move through the plume in a relatively short time. Organisms entrained into the plume are exposed to elevated temperatures for such a short time period that little or no damage occurs. Ce rtainly, the time of exposure of entrained organisms to temperature elevations having any possible biological significance is, for most thermal discharges made into large water bodies, too small to result in any change in speciation, such as an increase in blue-green algae as has been suggested as a possible consequence of thermal discharges. The computational model used to predict the excess temperature distributions in the thermal plume can also be used to compute the maximum time of exposure of any organism carried into the thermal plume with the entrained dilution waters. I have made such a computation for the case of the maximum daily discharge of excess heat - that is, the worst condition that can be expected to occur for the Davis-Besse thermal discharge. The results of this cornputation are contained in Table 3, which shows that the time of exposure of organism entrained into the plume to excess temperatures of, say, 3 'F or greater will be less than 4 minutes. The biological conse-quence of the type of time-temperature history indicated by Table 3, must be quite different from those associated with the typical laboratory exposures to temperature increments for periods ranging from several hours to several days. Recent experiments using larval forms of certain important estuarine species suggest that exposures to time-temperature histories similar to that given in Table 3 do not result in any measurable biological consequence.
~
It has also been stated that any artificial in:rease in temperature acts synergistically to increase the toxicity or other determimental effects of chemical pollutants present in the waterway. In particular, it has been claimed that increased temperatures associated with thermal discharges will ir crease the eutrophication process in natural water bodies. While it is quite true that the toxicity of certain chemical pollutants does increase with temperature, the differences in toxicity at a given concentration of pollutant over the range of temperatures found inside and l l 1 G-21
.. *p Table 3 Ma::imum time of e::posure to excess temperatures equal tc or exceeding the given values, for crganisms entrained into the thermal plume from the Davis-Besse Nuclear Power Plant, for the case of the maximum daily discharge of excess heat.
Excess Temp. Time of Exposure 9, 'F 8* 30 seconds 6* 54 seconds 5* 1.3 minutes 4* 2.0 minutes 3* 3.4 minutes 2* 6.8 minutes l' 21.9 minutes O G-22
outside of a typical thermal plume are too small to be of any practical consequence. The only cost effective way of reducing the potential environ-mental damage from a toxic chemical pollutant is to treat the source waste stream to remove or drastically reduce the discharge of the subject chemical. Elimination of thermal discharges will in no practical way change the timing or the degree of treatment required. The undesirable consequences of eutrophication are the production of large standing crops of planktonic and attached algae, and also changes in speciation of the algae as well as of some components of the second stage of the food chain such that forms less desirable to organisms of importance to man dominate the population. The size of the standing crop depends on the amount of nutrients available in the water and not on temperature. An examination of the data showing a change in the size of the standing crop and in the speciation of algae in Lake Erie with time clearly shows that these undesirable changes were concurrent with increases in the rate input and in i the concentration of the rnajor nutrients. The ce is no evidence of any response in the progress of eutrophication to the temperature fluctuations which have occurred over this same time interval. The prohibition of thermal discharges to the Lake will not change the fact that the only way to reverse the process of eutrophication is to reduce the rate of introduction of the chemical nutrients. In summary, I firmly believe that existing evidence supports the conclusion that the thermal discharge as now proposed for the Davis-Besse Nuclear Power Plant will have no adverse biological effects on the waters of Lake Erie. G-23
September 1970 DONALD WILLIAM PRITCHARD Biographical Data Born: Santa Ana, California October 20, 1922 Education: B. A. Degree in Meteorology, University of California at Los Angeles, 1943 M. A. (1943) and Ph. D. (1951) degrees in Oce.anography, Scripps Institution of Oceanography, University of California, La Jolla, California Present Employment: Director, Chesapeake Bay Institute, The Johns Hopkins University (since 1951); also Professor of Oceanography, Department of Earth and Planetary Sciences, The Johns Hopkins University Past Professional Employment: Served as Weather Officer in World War II, forecasting sea and swell for amphibious ?.anding operations in Normandy and in Pacific. Head, Current Analysis Section, Scripps Institution of Oceanography, 1946 Oceanographer, U. S. Navy Electronics Laboratory, San Diego, California, 1947-48 Associate Director, Chesapeake Bay Institute, The Johns Hopkins University, 1949-1951 Chairman, Department of Oceanography, The Johns Hopkins Unive rsity, 1950-1968 Professional Activities: National Boards and Committees Member, Committee on Oceanography, National Academy of Sciences (NASCO) Chairman, Panel on Oceanographic Data (NASCO) Member, Panel on Radioactivity in the Marine Environment (NASCO) Member, Advisory Committee on Isotopes and Radiation Development, U. S. Atomic Energy Commission Member, Marine Resources Advisor.y Committee, Department of the Interior G-2h
D. W. Pritchard - Biographical Data Professional Activities: (continued) State Boards and Committees Member, Board of Review, De pa rtme nt of Natural Resources, State of Maryland Member, Air Quality Control Advisory Council, State of Maryland Member, Radiation Control Advisory Board, State of Maryland Member, Commission on Submerged Lands, State of Maryland Member, Study Commission to Investigate Problems of Water Pollution in Maryland Consultant to Special Commission on Pollution, State of Maryland Professional Societies, Editorial Boards, and Honors Fellow, American Geophysical Union; Past President, Past
, Vice President and Past Secretary, Section of Oceanography Life Fellow, The International Oceanographic Foundation Member, American Society of Limnology and Oceanography; Past Vice-President Member, Society of Sigma Xi; Past President and Past Vice-President, JHU Chapter Member, America- ;ssociation for the Advancement of Science Member, Atlantic Estuarine Research Society Board of Editors, The Johns Hopkins Oceanographic L dies Board of Editors, Journal of Marine Research Phi Beta Kappa Society Past Professional Activities :
National Academy of Sciences Representative on the Advisory Board to the National Oceanographic Data Center, 1960-1968 Consultant to Special Advisory Committee to Department of Commerce, The National Academy of Sciences, 1959 Consultant, Sub-Committee on Oceanography and Fisheries. Committee on the Biological Effects of Atomic Radiation, National Academy of Sciences Chairman, Panel on Waste Disposal from Nuclear Powered Ships, Committee on the Biological Effects of Atomic Radiation, National Academy of Sciences Panel member - Radioactive Waste Disposal into the Sea, International Atomic Energy Agency, Vienna, Austria Member, Ad Hoc Expert Committee on Radioactive Materials in Food and Agriculture, Food and Agricultural Organization of the United Nations, Rome, Italy G-25
D. W. Pritchard - Biographical Data Consulting Experience: Consultant to Virginia Electric and Power Company, 1954 to present; on projects related to limnology of impoundments for hydroelectric projects; water quality of hydroelectric plant discharge; distribution of excess temperature from conventional and nuclear powered thermal-electric plant discharges in lakes, rivers and estuaries; distribution of radioactive waste products discharged from nuclear power plants. Consultant to Rochester Gas and Electric Company relative to distribution of excess heat and rad-waste products in Lake Ontario from the Brookwood Nuclear Power Station. (1966) Consultant to Florida Power and Light relative distribution of excess heat and rad-waste products in Biscayne Bay from the Turkey Point combined conventional-Nuclear Power Station. (current)
. Consultant to Duke Power Company relative to limnology of hydro-electric impoundments and water quality of discharge from such impoundments.(1959)
Consultant to Pacific Northwest Power Company relative to stratification in and almon migration through the proposed Nez Perse - High Mountain Sheep hydroelectric project.(1962) Consultant to Bechtel Corporation relative to distribution of excess heat and rad-waste products from the Pilgrim Station Nuclear Power Plant, Boston Edison Company. (current) Consultant to Philadelphia Electric Company relative to distribution of excess heat and rad-waste products in Conowingo Reservoir from Peachbottom Nuclear Power Station, Unit #1 (1960) and Units #2 and 3 (current) Publications: Author of some 50 scientific papers published in scientific journals, in symposia proceedings, in encyclopedia, and as chapters in text books, on such subjects as the physical oceanography of the Arctic and Antarctic; the physical limnology of lakes; the kinematics
' nd dynamics of estuarine circulation and on the distribution of a
constituents in estuaries; the processes of diffusion in estuaries, coastal waters and in the ocean; the fate of radioactive materials in the marine environment; and the eutrophication of estuaries. G-26
m/ - EXHIBIT H PuallC MEETING TO CONSICER THE APPLICATION FOR CERTIFICATION OF THE DAVIS-BESSE NUCLEAR POWER STATION FOR PURPOSES . OF SECTION 21(b) FEDERAL WATER POLLUTION CONTROL ACT July 28, 1971 Statement by George L. Harlow, Director U. S. Environmental Protection Agency Fairview Park, Ohio Early in 1968, the Toledo Edison Company and the Cleveland Electric illuminating Company announced a joint venture to build the Davis-Besse Nuclear Powe'r Station on the south shore of Lake Erie near Port Clinton, Ohio. Since that time, the Environmental Protection Agency has been in i
! close contact with the applicants and the State of Ohio to evaluate the'
', environmental impact of'the proposed waste dischargas. Recognizing that 1
l western Lake Erie is at a danger point with respect to temperature and I i is in a more critical stage of eutrophication than any other part of any of the Great Lakes, we were deeply concerned about the possible impact e of the waste discharges as originally proposed. Thermal discharges and their subsequent impact on western Lake Erie
. were of foremost concern. We are very encouraged by the applicants announcement in August 1970, to build a closed cycle condenser cooling system utilizing a natural draf t cooling tower to ~ reject s'ubstantially all of the heat in the c'ondenser cooling water directly to the atmos-phere. This action affected a reduction of warmed water discharge to the lake to approximately 4 percent of that involved with an open lake l ..
cooling system. The applicants propose to f urther reduce the heat dis-charge to Lake Erie by using the service water ef fluent as cooling tower makeup water and to use lake water as dilution water mixed with the l j 9
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3 . . , blowdown water to ensure that the discharge water temperature at the outfall does not exceed 20 F 0 above lake temperature. We recommend that both proposed actions be adopted. Since there are no federally-approved temperature standards for Lake Erie, it is premature to conclude that plant thermal discharges will be in compliance with Federal Water Quality Standards. However, i f the , temperature standards .recently proposed by the Lake Michigan Enforcement Conference can be used as a guide, the thermal discharges defined by the applicants are well within those standards. The recommended Lake Michigan standards recognize the need for a mix!ng zone with a maximum temperature limit and, in this case, it is 30F above ambient for a distance'of 1,000 feet from the point of discharge. The Davis-Besse plant using the cooling tower and the two proposed modifications, considering the extreme condition .sould give a temperature of about 1.20 F above ambient at a distance of 1,000 feet from the point of discharge according to the applicants. Free a dif ferent point of view, the heat input to Lake Erlo was reduced f rom 6.2 billion BTU /hr. (with open lake cooling) to 88 milllor BTU /hr. (with
- a ' cooling tower and the two proposed modi fications). The heat load from the Davis-Besse plant will be comparable to that expected f rom the Enrico Fermi 2 nuclear power plant (maximum 100 million BTU /hr. by State of Michigan permit),
but less than that from existing fossil fueled plants on Lake Erie, such as
. the Cleveland Municipal Light Plant (920 million BTU /hr.), the J. R. Whiting plant (1.5 billion BTU /hr.), and the four Cleveland Electric 1.lluminating Compary plants (6 billion BTU /hr.).
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Another major concern pertained to the disposal of radiological wastes. Separate testimony will be given on this aspect. . Waste discharges from the sewage treatment plant, filter backwash and domineralizer wastes to the Toussaint River were another concern. These discharges, although treated. would have placed an unnecessary - burden on the Toussaint River. The river is a noted spawning are,a for . catfish and bass. As it is now proposed, these wastes will be com-bined with other plant waste streams and discharged to Lake Erie. Dis-charges to the Toussaint River will consist principally of storm water runoff. After careful consideration of the most recent design changes proposed by the applicants and evaluation of expected environmental impact, the U. S. Environmental Protection Agency has no objection to the application for certification for the purposes of Section 21(b) of the Federal Water Pollution Control Act and that there is reasonable assurance that the construction and operation of the Davis-Besse Nuclear , Power Station will be conducted in a manner which will not violate ap-plicable existing water quality standards. The Environmental Protection Agency will continue to maintain close contact with the applicants and the State of Ohio on this matter. The on-going environmental monitoring program will be instrumental in assess-Ing the impact of the plant waste discharge). Should any violation of water quality standards be identified, the Environmental Protection Agency will not hesitate to take appropelate enforcement action.
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I - j WASmNCToN. O c. Io$n gj NOV 5 19M Docket No. 50-346 EXHIBIT J The Toledo Edison Company ATTN: 11r. Glenn J. Sampson Vice President, Power 420 Madison Avenue Toledo, Ohio 43601 Gentlemen: This supplements ny recent letters to you transmitting coaments furnished by various Federal agencies on your environmental report for the Davis-Besse Nuclear Power Station. A copy of the comments submitted by the Federal Power Commission is enclosed for your information. Sincerely yours,
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%~'I&,st<wa..g 7 *' Peter A. Morris, Director 7 T Division of Reactor Licensing
Enclosure:
FPC ltr dtd 11/3/70 w/cocznents cc w/ enclosure: Leslie Henry, Esquire Fuller, Seney, Henry & Hodge Donald H. Hauser, Esquire The Cleveland Electric Illuminating Co.
. George F. Trowbridge, Esquire Shaw, Pittman, Potts, Troubridge & Madden J-l ~
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Dear ).r. P. ice :
This is in reply :o ycur lo:ter of Au;us: IS, 1970, requestic.3 consan:s cf the Fadcrcl Pctier Cc :issic:. on che envirot.nental i= pact c2 the Dcvis-Bascc nuc'.cc: pe:iar plen:. Al;hou;h :he Federci ?c:.or Concissica dccs no: 2enersily have
'.icac.si..; ,'crisdiccion over :hortel pct.'_: p'cn:s construe:cd by .
eloc:ric utili:ics, the Cct ission does have a real and continuing in:er:a: in :he ticaly ccnstrue:ica of generating and transcission faci'.i:ies to cac: grctiing clee ric 'oads and the i= pac: of the . facilities .pon the envirencent in catters relating to air pollution, wcter qua"ity, and c:her fcetors. Cur concen:s on par:inen: fce: ors reiz:ed t- tha proposed environnan:ci statemen; on the Dcvis .,asse nuclear power plant are enclosed. Sincerely,
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Federal Power Commission Comments Relative to the Environment Statement on the Davis-Besse Nuclear Power Station ' to be Jointly Owned by the Toledo Edison Company and the Cleveland Electric
. Illuminating Company General The comments herewith are directed: to the relationship of the electrical capacity of this unit to the prospective power supply' and demand situation of the system and region involved; to the fuel supply situation related to the type of plant and its environmental effects; and to comment on alternative means of meeting the power supply need for which this unit is proposed. It is understood that other agencies will review and comment upon those aspects of the project which involve its effects on air and water quality and other environmental factors.
The Need for Power The Davis-Besse nuclear power station is bei:.g planned as a jointly owned facility 52.5 percent of whose output will be owned by ~~__ the Toledo Edison Company and 47.5 percent by the Cleveland Electric Illuminating Company. Both companies are members of the Central Area Power Coordinating Group (CAPCO). This group is an operating pool composed of the applicants, Duquesne Light Company and the Ohio Edison Company, and is one of 11 operating pools which are participating in the East Central Area Reliability Coordination Agreement (ECAR). The 26 companies of ECAR operate utility systems whose combined service areas cover 192,000 square miles and extend from the southern border of Kentucky to the Northern Peninsula of Michigan and from western Maryland to the eastern border of Illinois. In order to judge the need for the Davis-Besse nuclear station, it is necessary to examine the load-supply situation as it is expected to exist during the summer of 1975, which will be the first critical peaking period following the scheduled in-service date of the station, which is December 1974. e e o e e . es e n s ee J-3
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. 'The following table summarizes the anticipated summer-1975 load-supply situations of the systems of each of the applicants, the immediate operating pool of which ehe applicants are members, and the regional consortium of systems wh ch the applicants are committed to support:
Cleveland Toledo Electric Edison Illuminating Company Company , CAPCO ECAT Dependable Capacity, MW With Davis-Besse 1,492 4,049 13,640 77,573 Without Davis-Besse 1,034 3,635 12,769 76,701 Peak Load, MW, Summer 1975 1,449 3,502 11,502 62,347 Reserve Margin, MW With Davis-Besse 'O 547 2,139 15,226 Without Davis-Besse 0 133 1,267 14,354 , i
! Reserve Margin, Percent With Davis-Besse . 0 15.6 18.6 24.4 Without Davis-Besse 0 3.8 11.0 23.0 i
In evaluating the reserve margin situation on the systems of the Toledo Edison Company and the Cleveland Electric Illuminating Company, it should be noted that these systems are members of the CAPC0 operating
, pool and that their operations and energy requirements are to be 3
coordinated under the pool agreement. Normally each member of an operating pool is . responsible for a proportional share of the pool's total reserve requirement. When the dependable capacity of any pool member is insufficient to meet its share of this requirement, the situation is corrected by the purchase of firm capacity from other systems. Thus,
, the unsatisfactory reserve margins shown in the table for both the Toledo Edison Company and the Cleveland Electric Illuminating Company have economic but no reliability significance for the systems involved during the summer of 1975. .
The Davis-Besse nuclear power station is being planned as a facility whose output will contribute to the general resources of the operating pool. It is significant, therefore, that during the summer peaking season of 1975 the reserva margin of CAPCO, excluding the capacity of the Davis-Besse station is expected to be 1,267 megawatts or only 11 percent of an anticipated pool peak load of 11,502 megawatts. If it is assumed that the in-service date of the plant is met, the reserve margin of the pool will increase to 2,139 megawatts, which is equal to 18.6-percent of the anticipated peak load. i Jh
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In general, we feel that for an operating pool of the size of
.CAPCO the reserve margin should be about 20 percent. There is no question, therefore, that on the basis of anticipated pool require-ments, the capacity of the Davis-Besse nuclear power station will be needed by the summer of 1975.
As a matter of interest, we have included data pertaining to the anticipated summer-1975 load-supply situation of ECAR. The margins, with and without the Davis-Besse planc, are expected to be at an acceptable level, but this level is not rega'rded as sufficiently high to obviate the need of the proposed plant. Several considerations support this judgment. The most important of these is the operating philosophy, widely accepted in the utility industry, which holds that primary responsibility for serving electric loads belongs to the utility or operating pool in whose service area the loads occur. The primary function of regional intercies, internal and external, according to that philosophy is assigned to the accommodation of im- - balances between supply and la.1ds, which are an unavoidable charac-l teristic of utility system operations. Furthermore, the reserve margin determination for ECAR as shown in the table obscures the location of these reserves with respect to the service areas of CAPCO. While this reserve margin may appear to be satisfactory on an area-wide basis and while the ECAR area is served by a highly advanced network of transmission lines, there remains a serious question whether enough of this reserve capacity could be made available in the CAPCO service area on a firm and continuing basis to warrant a delay in the construction of the Davis-Besse nuclear power station. Two other factors mitigate against such a delay. These are the current trends to construction of larger and larger units in the interest of economies of scale and the poor record of availability of such units during the first few years of initial operation. Under these circumstances, we feel it would be imprudent for the managements of the Toledo Edison Company and the Clevelands Electric Illuminating Company to rely on distant and widely scattered generating capacity, even if these were available to them, _____ to supply the critical power needs of their service areas during the summer of 1975. \ The Fuels Situation but isThe ECAR service area is deficient in both oil and natural gas abundantly endowed with bituminous coal resources. Practically all the electric power generated in the ECAR area is coal based. Most of the major plants are capable of burning some oil, but in recent _ years, oil has not been able to compete economically with the area's most available fuel.
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The supply and demand of power generation fuelswere greatly affected by the need to meet more restrictive air quality standards through use of fuels of lower sulfur content. In Cleveland, Ohio, as
- of October 15, 1969, the sulfur content of fuels burned in new plants was limited to one percent for coal and two percent for oil. On December 31, 1971, fuels burned in existing plants will be restricted to 2.0 percent for both coal and oil. In Toledo, Ohio, a sulfur limitation will become effective on January 1,1971. This will restrict the sulfur content of coal burned to an average of 2.7 porcont in any one month, and a fira 1.0 percent for oil, with the one exceptio,n that oil produced and consumed on the premises can have a sulfur content as high as 1.5 percent.
"Throughout the entire ECAR service area,,even where local public concern has not yet been translated into effective restrictive regulation en sulfur content of utility fuels, Federal legislation such as the Air Quality Act of 1967 and the National Environmental Policy Act of 1969, has set the stage for possible future restrictions. Since the service life of a major electric generation station is,in the range of 30 to 35 years, these prospective changes in future fuel use of of a proposed station must be factored in at the planning stage as one of the critical design criteria.
In addition to the environmental complications, the ECAR companies are being seriously af fected-by the immediate situation which is t developing in the utility coal markets. This situation appears to result from increasing exports of coal to Japan, a shortage of rail-road coal cars, recent strict mine safety legislation, and a general reluctance on the part of the coal industry to invest in new mines prior to long-term committment of the output to specific customers. These factors are not only affecting the short term supply of coal but also appear to contribute to upward longer term pressures on the price of coal at the mine, thus affecting the competitive position of these fuels in favor of nuclear generation. To meet existing and future sulfur oxides regulations, the Cleveland Electric Illuninating Company on May 13, 1970, submitted a request to the Oil Import Appeal Board for a permit to import one million barrels of . low-sulfur residual fuel oil during the period April 1, 1971 to March 11,1972 and 2.5 million barrels annually thereafter. Action on the request is still pending. The prospect for substituting natural gas for nuclear power generation is not encouraging. Of the one billion Mef of natural gas used annually in the State of Ohio, less than 18 million Mcf in 1969 was used for the generation of electric power by electric e t 4 emy a en me, , ,w, ,[ J-6 .
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1 a. l These estimates were reported to the Federal Power Commission on September 1, 1970, by the Northeast Power Coordinating Council, l the Mid-Atlantic Area Coordination Group, the Southeastern Electric i Reliability Council and the Mid-America Interpool Network Organization
. in accordance with FPC Order No. 383-2 which calls for annual reporting of detailed system, planning information for a period extending 10 years into the future. -
During the summer peaking season of 1975, the reserve margin of the New England's systems and that of the New York Pool are expegted to be substantially higher than the roughly 20 percent reserve which the Federal Power Commission normally considers as satisfactory. These___ reserves, however, are far too distant from the CAPCO service area to offer,a sound alternative for any electric generating capacity, fossil or nuclear, sited within the service area of CAPCO. The reasont dis-cussed in the section for the need for power which argue againsc the reliance of CAPCO's systems on the reserves of ECAR's systems, speak out even more cogently against any consideration of firm power imports from outside the ECAR service area. While the Federal Power Commission is in favor of interconnections and the coordination of systems in adjacent regions as a sound practice in gaining the advantages of economies of scale and providing the inter-system means for emergency support, it does not overlook the penalty in terms of reliabili,ty of supply which is imposed on utility l operations when sites of generation are selected at long distances from major service areas. In general, the Commission feels that the CAPCO's systems stand to gain an important advantage by planning the Davis-Besse nuclear power plant within the pool's service area rather than seeking to rely either on ECAR resources or those beyond. i Hydro Power Alternative A hydroelectric installation as a substitute for the Davis-Besse nuclear power station does not appear to be feasible because of the
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lack of sites within economic transmission distance of the CAPCO service area which have a hydroelectric capacity potential comparable to the capacity of the proposed plant. Some pumped storage hydro-electric sites are available, but a pumped storage installation is useful only for peaking capacity. Pumped storage plants cannot serve as substitutes for base-load plants. The Davis-Besse nuclear plant is intended to serve a bese-load function.
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