ML19343D532

Forwards Review of Facility Impact Evaluation & Study Results for Intake Design.No Significant Effects on Fish of Savannah River Will Result from Impingement.Condition Requirements Satisfied

ML19343D532
Person / Time
Site:	Vogtle
Issue date:	04/29/1981
From:	Tedesco R Office of Nuclear Reactor Regulation
To:	Ehrensperger W GEORGIA POWER CO.
References
NUDOCS 8105050174
Download: ML19343D532 (14)

Text

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6 UNITED STATES

1. D 8i NUCLEAR REGULATORY COMMISSION o

g fI WASHINGTON, D. C. 20555

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APR 2 91981 l-Docket Nos.: 50-424 and 50-425 g

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\\ g /f/p/ '%'B Mr. W. E. Ehrensperger A

Senior Vice President Power Supply

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P. O. Box 4545 4

1 Atlanta, Georgia 30302 i

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Dear Mr. Ehrensperger:

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Subject:

Review of Georgia Power Company's Study Results and Impact i

j Evaluation for the Vogtle Intake Design

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I We have reviewed Georgia Power Company's (GPC) submittal, dated January 28, j

1981, which provides information as required by condition 3.E(7) of the Vogtle Construction Permits (Nos. CPPR-108 and CPPR-109). Based on our datailed q

review (Enclosur,e 1), we conclude that no significant effects on the fishes of the Savannah River will result from impingement. Therefore, we find that the requirements of condition 3.E(7) have been satisfied.

In the Vogtle FES of March 1974, the staff expressed the need for data to allow f

an assessment of the potential impact of fish impingement with the approach channel intake design. This data need was subsequently made a condition of the Vogtle Construction Permits. GPC's submittal responds by providing new

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data on the adult fish community of the Savannah River, supplemented with data i

on the impingement experience at the U.S. Department of Energy's Savannah River Plant, located across the River. A successful demonstration has been made by j

the Savannah River Plant as to the acceptability of their intakes, pursuant to Section 316(b) of the Clean Water Act. We concur in GPC's assertion that 1

impingement losses at Vogtle should be less than at the Savannah River Plant because of lesser water use, shorter approach channel, and lower intake i

velocity. Also, we note that the FES evaluation of March 1974 considered a j

four-unit Vogtle plant, while only a two-unit plant is now proposed. Thus, the potential cooling water impacts are reduced, theoretic 311y, by one-half with the two-unit plant.

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Mr. W. E. Ehr:nsperger GPC is required to perform a Section.316(b) demonstration-for the Vogtle intake via the State "401 Certification" (See Attachment 2 to Enclosure 1). Require-ments of the "401 Certification" also become conditions of the Section 402 National Pollutant Discharge Elimination System (NPDES) permit. Thus, the State of Georgia and/or EPA, through their review and permitting authority, will make the final determination on the acceptability of the Vogtle intake.

We will be relying on the State and EPA on this and other water quality related matters.

In this regard, a copy of this letter and its enclosure is being transmitted to the Georgia Department of Natural Resources, Environmental Protection Division (See Enclosure 2).

This review was conducted by C. Billups of the Aquatic Resources Section of the Environmental. Engineering Branch.

Sincerely, 0;A< <>

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j Robert L. Tedesco Assistant Director for Licensing Division of Licensing

Enclosures:

1.

Staff Review of GPA's Study Results and Impact Evaluation for the Vogtle Inta'ke Design

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2.. Letter, B. J. Youngblood, NRC, to p

L. Ledbetter, Georgia Departnent of Natural Resources

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See~next page J'

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4 Mr. W. E. Ehrensperger Senior Vice President Power Supply Georgia Power Company P. O. Box 4545 Atlanta, Georgia 30302 cc: Mr. L. T. Gucwa Chief Nuclear Engineer Georgia Power Company P. O. Box 4545 Atlanta, Georgia 30302 Mr. Ruble A. Thomas Vice President Southern Services, Inc.

P. O. Box 2625 Birmingham, Alabama 35202 Mr. J. A. Baily Project Licensing Manager Southern Company Services, Inc.

P. O. Box 2625 Birmingham, Alabama 35202 t

George F. Trowbridge, Esq.

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Shaw..Pittman, Potts and Trowbridge 1800 M Street, N. W.

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. Washington,.D._C.

20036 1

Mr. Charles Kaplan i

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I Enforcement Division

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U. S. Environmental Protection Agency Region IV

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345 Courtland Street i

Atlanta, Georgia 30308

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Docket Nos. 50-424 and 50-425 ENCLOSURE I STAFF REVIEW 0F GEORGIA POWER COMPANY'S STUDY RESULTS AND IMPACT EVALUATION FOR THE V0GTLE INTAKE DESIGN

===.

Background===

As originally proposed by Georgia Power Company (GPC).in their Environmental Report (ER), the Vogtle intake was to be located flush with the Savannah River shoreline.

In evaluating the originally proposed intake, the staff concluded that fish impingment would not result in a significant adverse impact on the fish community of the Savannah River.

By ER Amendment No. 2, GPC proposed the relocation of the mtake pumping structure to an inshore position at the end of a 420 ft intake canal from.the River.

In the Vogtle FES of March 1974, the staff concluded that there were not J

sufficient data available to determine whether the modified intake design would

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significantly increase impingement losses; the need for conditioning the Vogtle f

construction pennit (CP) was based on this staff finding (FES, p.11-6). As I

contained in paragraph 3.E(7) of the CP, the condition requires that:

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" Prior to construction of the intake structure, the applicant shall submit the results ci the aquatic monitoring programs and an evaluation of the 4.nvironmental impact of the intake canal and intake structure which will satisfy the staff that impingement will not have a significant adverse effect on the adult population of resident and anadromous fish in the Savannah River."

By letter dated January 28, 1981, GPC submitted their results and evaluation in a report titled " Savannah River Fish Population Study and Impingement Prediction for Plant Vogtle, Burke County, Georgia". Copies of the State of Georgia's "Section 401 certification" and the Corps of Engineer's "Section 404 I

dredge and fill pennit" were provided'by GPC's letter dated February 9,1981.

Additional information was obtained via telecommunications with Mr. Charles McCrary of GPC.

Information provided by phone on February 10, 1981 was documented in GPC's letter of February 13, 1981. Clarification of certain intake design features was phvided by Mr. McCrary on February 17,19Pl.

In our present review, we consider GPC's new information in regard to fulfillment of the CP condition. Secondly, we consider the relevancy of the original CP condition to present requirement of the "401 Certif'ication" which calls for a Section 316(b) demonstration prior to use of the proposed intake.

Summary Review of New Information

.7 In.the submittal of January 28, 1981, GPC has provided additional data on the fish community in the vicinity of the Vogtle site. These :.ew data are compared l

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and supplemented with results of the Savannah River Plant's successful demonstration, pursuant to Section 316(b) of the Clean Water Act, as to the l

aceptability of their intakes.

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.The Savannah River Plant, located across the River from-the Vogtle site,

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has three pumping stations, two at the ends of long canals (500 m and 410 m) t and the thira' within a cove 20 m from the river.

Intake velocity in front r

of the ' screens at.ne Savannah River Plant is 0.38 m/sec (1.25 fps). Maximum j

sustained flows through the three canals are 16.4 m /sec 20.5 m /sec and 4.7 f

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m /sec for a total maximum withdrawal rate of 41.6 m /sec (1468 cfs). Withdrawal rate for typical operation is 11.6 m.sec (409 cfs).*

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t Impingement at the Savannah River Plant was estimated at 11.2 fish per day i

(4088fishinoneyear)with35speciesrepresentedinthecollec,tions. The four most commonly impinged were the year-round resident species: bluespotted l

sunfish, warmouth, channel catfish and yellow perch. Of the anadromous' species, 18 American shad were reported impinged No one of the 35 species made up more j

than 10% of the total impingement sample. Minnows and other small fishes were j

not impinged in relative proportion to their composition in the fish connunity l

._i of the intake canals.

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The proposed Vogtle intake is shown in plan view by Figure 1.

The intake design is basically a screened pumping structure located at' the end of an approach canal; however, some novel features have been incorporated in the design, l

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two weir structures, one located at the opening to the river and the other about 30.5 m (100 ft) inside the canal, serve to control sediment transport from the river

• Information provided by Georgia Power Company as documented in letter dated February 13, 1981 from W. A. Widner.

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i to the area of the intake pumps. The river weir will defket'the bottom sediment laden lay'er of river water away from the intake canal. The canal i

weir will trap most of the suspended sediment transported in the upper layer of rive,r water. The geometry of the weirs (design and orientation), plus the-guide vanes, were selected to provide uniform flow distribution through the canal. At the downstream end of the river weir, a 3-ft wide opening will provide j

a fish escape route. Flow direction at the fish gap will be outward from the

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canal to the river based on design hydraulics (C. McCrary, personal cormunication).

Also shown in Figure 1 is a floating boom to be placed just outside the river l

weir. This boom will serve to skim off floating debris (e.g. leaves) and is expected to be used only seasonally (C. McCrary personal communication).

The-approach canal is 126.2 m (414 ft) long. The opening to the river, at the river weir, is 36.6 m (120 Ft) wide. The canal proper is 42.7 m (140 ft) wide, narrowing.to 12.2 m (40 ft) at the pumping structure. The canal bottom will be

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i excavated to El. 67.ft ms1; thns, minimum canal water depth will be 4.0 m (13 ft) i at minicum river stage (water surface El. 80 ft ms1). Make-up water.for the Vogtle..

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closed-cycle cooling system will be withdrawn at an average rate of 2.5 m /sec (88.2 cf: l Design velocities through the trash racks and traveling screens arr. less than O!15 m/sec {

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(0.5 fps) and 0:2 m/sec (0.7 fps), respectively.

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Results of GPC's " adult fish study" indicate that the fish community of the J

l Savannah River in the vicinity of the Vogtle site is dominated in numbers by i

minnows (family Cyprinidae), followed by centrachids (sunfishes and largemouth bass) ll and clupeids (shads and herrings). These three families comprised 69%,115, o

and 5%, respectively, of the 1109 fishes collected in seven electrofishing

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. surveys made during the period, September 1977 - December 1978. Species from 12 additional families made up the remaining 15%.

Of the total 39 species collected,17 were identified as game and comercial species,. These include the year-round residents such as sunfishes, crappies, largemouth bass, chain pickerel, catfishes and yellow perch and three anadromous species: American shad, blueback herring and striped bass. These 17 game and comerical species made up 16% of the fish collected both in terms of numbers and weight. Three of the four species comonly impinged at the

' Savannah River.lant were not collected in GPC's electrofishing surveys (i.e.,

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bluespotted sunfish, wamouth and channel catfish).

t The size ranges for specimens of American shad and blueback herring suggests that spawning upstream of Vogtle is occurring. The 30 American shad ranged in length from 33 to 115 m, indicating young-of-the-year (y-o-y). Of the nine

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blueback herring collected, eight were y-o-y ranging between 43 and 70 mm a.1d the other was'an adult (310 m length)taken in April 1978. The one striped bass collected was an adult (700 m length) also taken in the April 1978 survey.

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Discussion GPC's evaluation of the potential impingement impact is based chiefly on a comparison of the Vogtle intake with the Savannah River Plant intakes and the

,,_ -Ofact'Ehat tfie SayanidhIiver Plant'lias~'made a/5uccessful Section1316(b)-demonstration

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showing low impingement losses. We find this approach to be appropriate; impingement experience at the existing intakes on the same water-body provides a better picture of potential impingement at Vogtle than t' a results of the electrofishing surveys. Based-on a combination of lower with-

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'drawal rates, lower intake velocities and shorter approach canal *, impingement j

h at Vogtle should be even less than experienced at Savannah River Plant. However, the unique features of the proposed Vogtle intake design (e.g. the weirs) may result in some differences in impingement from that at the Sahannah River Plant. '

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~ The riher weir is designed to deflect the lower layer of river water away from I

The half-serrated weir design has a crest elehation of 78 ft with i

the canal.

serrations starting at 74 ft on the downstream half and at 75 ft on the upstream hal f.

Assuming the riher bottom to be at El. 67 ft, the deflected layer of 1iver At minimum riher stage (water surface atIE1, ',80 ft),

water would be the lower 7 ft.

the intake would selectively withdraw from the upper 6 ft of river water. Thus, biota distributed in the upper layer would be more susceptable to transport (passihe or.actihe) across the weir and into the canal.

Most freshwater fishes produce eggs which are adhesive, demersal, or semi-buoyant (near bottom)'; thus, the majority of eggs and early larval stages of resident species are not expected to be susceptable to the.Vogtle intake. Eggs of the American shad and blueback herring, anadromous species which spawn upstream, are semi-buoyant; thus, the majority of eggs and early larva 1 stages of these species also would likely be transported past the Vogtle intake in the deflected lower;1ayer.. As yoiing of both resident and anadromous species start feeding

.actihely in the water column, they would become more s'usceptable to dassage

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into the Vogtle canal. Although the fate of these young fishes remains speculative in a pre-operational assessment, we would expect that any potential for entrap-ment, and subsequent impingement, is reduced through a combination of the low intake Yelocities and prohision for a fish escape route in the weir design.

• TheVogtlecanalisshorterthanthetwocanalsatS3hannahRiverplant.

The third intake, at the latter plant, is located in a cove.

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Relevant to the present review is the fact that the Vogtle plant i.s now proposed l

fortwounitsratherthanfourunitsaschaluatedintheFESofMarch1974.

Thus, the potential impacts associated with river water withdrawal are reduced by one-half those considered in the FES. The withdrawal rate for the two-unit 3

plant is expected to average 2.5 m /sec (88.2 cfs) which is about 1.5% of the l

minimum riher flow and 0.9% of the aherage riher flow.

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Other Relevant Reviews and Requirements I

GPC has receihed a " water quality certificat'on" issued by the State of Georgia j

under Section,401 of the Clean Water Act and a " dredge and fill" permit issued by the Corps of Engineers under Section 404 of the Clean Water Act. As required i

l by the State certification and reiterated in the dredge and fill permit, GPC must demonstrate, " prior to use," that the intake structure complies with appli-cable-Clean Water Act Section 3.6(b) guidelines. The requirements of attachment 1

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would allow construction of the proposed Vogtle intake to proceed with a decision

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on its acceptability to be made upon completion of construction.

In contrast, i

l-condition 3.E(7) of the NRC-issded construction permits requires a satisf,actory showing, " prior to construction of the intake structure", that impingement I

will not result in a significant adverse impact. Thus, the NRC-imposed condition conflicts with the requirement of the State certification, i.e., construction

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could not proceed until-condition 3.E(7) is fulfilled.

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l Since issuance of the Vogtle construction permits in 1974, the staff has f

receihed specific guidance with regard to imposing conditions for protection of the aquatic enhironment. Decisions

• of the Atomic Safety and Licensing Appeals Board (ASLAB) hahe held as a matter of law that the NRC did not hahe f

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• Refer to decisions in the cases of Yellow Creek (ALAB 515), Robinson (ALAB569)andPeachBottom(ALAB532).

8-the requisit'e responsibilities for including conditions of its own for the protection of the aquatic environment because the Clean Water Act placed full

- responsibility for these matters with the E vironmental Protection Agency.**

l In accordance with the ASLAB's findings, prior. staff practice has been modified to include (1) emphasis on coordination with EPA and state permitting agencies l

1 during enhironmental reYiews and. (2) reliance on the certifications and pemits I

issued under the Clean Water Act for protec' tion of water quality and aquatic i

biota.

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Inthepresentcase,wehavediscussedthetechnicalaspectsofthereYiewwith l'

Charles Kaplan, EPA-Region IV, and William,Jernigan, Georgia Department of s

Natural Resources. Guidance from EPA-Regi n IV is that an intake located at the end of a dead-end canal would not generally be considered best available j

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. technology for a new plant. See for example.the letter dated January 24, 19^,3, fromfG. Harlow to Wm. H. Regan, Jr., regarding the intake for TVA's Bellefonte Nuclear Plant (Attachment 2)..

In that case, EPA indicated that the NPDES

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.pemit would require impingement and entrainment studies and would contain i

language requiring modifications if results indicate 6nacceptable impingement l

and/or entrainment leYels. A similar approach is anticipated in the Vogtle t

case. According to Mr. Jernigan, GPC is expected to submit a study plan l

l which would include pre-operational and operational monitoring to demostrate j

r compliance with Section 316(b). ThestudyplanwouldbesubjecttoapproYa1 f

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by the State NPDES pemitting authority.

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• • For the Vogtle case, the responsibility is. delegated to the State of i

Georgia as a " permitting state" under provisions of Section 402 of j

the Clean Water Act.

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Conclusion The Vogtle construction permits were conditioned such that, prior to construction of the int $ke structure, GPC would prohide information to satisfy the staff that,

. impingement 'will'not hahe a significant adherse effect on the adult population (s) t of resident and anadromous fish in the Savannah River'. GPC's submittal of January 28, 1981 prohidesstudyresultsandan~impactehaluationinaccordance i

with the CP condition. Basedonour'rehiewofGPC'ssubmittal,wearesatisfied i

that no significant effects on the fishes of the Sahannah Riher will result i

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I from impingement.

Our finding here does not constitute the final approhal of the Vogtle intake.

Rather, it allows construction of the intake to proceed. GPC is required by condition of the State " water quality certification" to demonstrate that i

it the-intake-complies with Section 316(b) of.the_ Clean Water Act. Section 401

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requires that conditions of certification shall become a condition of the i

h ll Section 402 NPDES perniit. Thus, the State of Georgia and/or EPA, through their review and permitting authority, will make the final determination on the i

i acceptability of the Vogtle intake. The staff will rely on the State and EPA

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with regard to this and other water quality related matters.

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V0GTLE ELECTRIC-GENERATTlNG.,

PURPOSE: TO SUPPLY :.!AKElp WATER TO PLANT PLANT-UNITS 1 & 2 DATU:.l:

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STRUCTURE FACILITY ll0

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l. APPRMi'.t.a.TELY 96.500 C Y Or Al.LUVi? L CL AYStii900 CYCF At.L;v:AL sat:DS TO i2 IN i SAVAN.M AH RT,yER Rn.:a.co oY Ei.nTn uAvut:0 Couie To OISPOU.L SITE A3 LOCATED IN INdERT.

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Approxt:nately 13,500 cy of alluvial amt COUNTY CFi3UD!ii..;_

c art clay: ullt lic 'rertoved

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ATTACHMENT 1

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e ENVIRONMENTAL PROTECTION DIVISION 270 WASHINGTON STREET. S W.

joe D. TANNER ATLANTA. GEORGtA 30334 Commiss oner of Up ID J. LEON ARo LED 8ETTER Divise Director Mr. T. E. Byerley Manager of Environmento! Affairs Georgio Power Company P. O. Box 454S Atiento, GA 30302

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Re: Water Quality Certification SASOP-FP 074 OYN 004016 Intake Structure & Access Road i

Plant Vogtle Savannah River-Burke County

Dear Mr. Byerley:

Pursuant to Section 401 of the Federal Water P'ollution Control Act Amend-ments of 1972 (33 USC 1251,3141), the State pf Georgio issues this certification to Georgio Power Company, on opplicant for a Federal permit or license to

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conduct on activity in, on or adjacent to the waters of the State of Georgia.

The State of Georgia certifies that there is no opplicable provision of Section 301; -ho limitations under Section 302; no standard under Sectica 306; and no standard under Section 307, for the cpplicant's activity.

This certification is contingent upon the following conditions:

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All work performed during construction will be done in a manner so os not to violate applicable water quality standards.

N No oils, grease, matericts or other pollutants will be discharged from the construction cetivities which reoch public waters.

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The opplicant will be required to demonstrate that the intoke structure complies with applicable 316-b guidelines prior to use.

It is your responsibility to submit this certification to the oppropriate Federal agency.

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. c t Sincerely, i G " C ;.~. Q k3 8.'- R E ? ? f. R -j % M ~ [>[/= y- % -:} f

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J. Leonard Ledberter Director I

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Mr. Steven Osvald' cc:

l Dr. Fred Morland Mr. E. T. Heinen Mr. J. Setser Mr.J.Lohla 79-04-16-03 AN AFrint.iATIVE ACT!oNIEcuAL EMPLoVMLNT oN*oGTuNITY CMPLoVER

ATTACHMENT 2_

ENVIRONMENTAL PROTECTION AGENCY JAN 2 41979 4E-WE r

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i Fr. William H. Regan, Jr.

Chief

- Environ = ental Projects Branch 2 Division of Site Safety and Environment Analysis Nuclear Regulatory Comission Washington, D. C.

20555

. l RE: Bellefonte Nuclear Plant

!i NPDES No. AL0024635 l

Dear Mr. Regan:

We have reviewed the material enclosed with your letter of December 6,1978, to Mr. Paul Frey as well as other information contained in our files re-1 lative to the referenced facility.

While we would not generally consider that'a cooling water intake located at the end of a dead-end canal is best available technology for a new plant, available data and evaluations indicate that i=pingement and j

entrain *-ent at this facility should not result in unacceptable environmental damage. Since construction of the intaka is virtually completed, we will I

not require any modifications at this time. The NPDES permit, when-issued, will require impinge =ent and entrainment studies, however. The permit will also contain language which would require modifications if the results of the studies indicate unacceptable levels of impingement and/or entrain-ment are occuring.

Should you have any additional questions or cor:ments, do not hesitate to contact us.

Sincerely yours,

-,e George. Harlow

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Water Enforcement Branch

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Enforcement Divisicu I

cc:

Dr. Harry G. Moore j

Tennessee Valley Authority o7 i

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Mr. James W. Warr Alabama Water I=provement Com.

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9k UNITED STATES

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NUCLEAR REGULATORY COMMISSION g

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E WASHINGTON, D. C. 20555 g

APR 2 91981 T

Docket Nos.:

50-424 and 50-425 i

J. Leonard Ledbetter, Director i

i Environmental Protection Division j

Georgia Department of Natural Resourc,es 270 Washington Street, S. W.

Atlanta,- Georgia" 30334 3

Dear' Mr' tedbetter:

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The Nuclear Regulatory Commf>ssion (NRC) staff has reviewed information, ll submitted by Georgia Power Company, concerning the proposed intake design for the Vogtle Nuclear Plant. By this letter, I am providing a copy of our detailed evaluation for your information; you may find the evaluation useful jn your review regarBing'the Clean Water Act Section 316(b) demonstra-l tion which is required by condition 3 of the Section 401 Water Quality i

Certification (SASOP-FP 074 0YN oo4016).

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In our evaluation, we find the proposed intake design will result in no l

significant effects on the fishes of the Savannah River from impingement; l

however, we note that the design does not appear to follow EPA's guidance related to best available technology for minimizing environmental impact.

An example of the guidance which we have received from EPA in previous :

l reviews is given in a letter from George L. Harlow to William H. Regan, Jr.,

l 1L dated J.anuary 24, 1979.

(A ccpy of the letter is included as an attachment l

A to odr evaluation.) We trust that this matter has been addressed by'your office in its preparation of the Section 401 certification.

In the course of our review, Dr. Charles Billups of the Aquatic Resources l

Section of our Environmental Engineering Branch discussed the general technical aspects of the anticipated 316(b) demonstration study with i

Mr. William Jernigan of your Division's Water Protection Branch. Therefore, additional purposes of this letter are to confirm that information provided i

i by Mr. Jernigan is properly reflected in the evaluation and to offer our thanks for his assistance.

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Sincerel,

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B. i,Y ungblood, Chief"

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Lic'ensing Branch No.1 l

Division of Licensing i

Enclosure:

Letter, R. Tedesco, NRC, to W. Ehrensperger, GPC, with i

Enclosure

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