ML19343D538

Discusses NRC Review of Licensee Proposed Intake Design. Design Will Result in No Significant Impact on Fishes of Savannah River.Design Does Not Follow EPA Guidelines.Nrc Review Encl

ML19343D538
Person / Time
Site:	Vogtle
Issue date:	04/29/1981
From:	Youngblood B Office of Nuclear Reactor Regulation
To:	Ledbetter J GEORGIA, STATE OF
References
NUDOCS 8105050181
Download: ML19343D538 (1)

Text

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jo UNITED STATES

.r,( ' g NUCLEAR REGULATORY COMMISSION 3'

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,; E WASHINGTON, D. C. 20555

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APR 2 91981 e

Docket Nos.:

50-424 a

g and 50-425 d' f[

h f.f7= M R 3{) g k.O J. Leonard Ledbetter, Director i

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Environmental Protection Division Georgia Department of Natural Resources Nd2l48aer

%'f 270 Washington Street, S. W.

Atlanta, Georgia 30334

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Dear Mr. Ledbetter:

g The Nuclear Regulatory Commission (NRC) staff has reviewed information, submitted by Georgia Power Company, concerning the proposed inMke 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 in your review regarding the Clean Water Act Section 316(b) denonstra-tion which is required by condition 3 of the Section 401 Water Quality Certification (SASOP-FP 074 OYN 0o4016).

In our evaluation, we find the proposed intake design will result in no significant effects on the fishes of the Savannah River from impingement; 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 reviews is given in a letter from George L. Harlow to William H. Regan, Jr.,

dated January 24, 1979. ( A copy of the letter is included as an attachment to our 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 Section of our Environmental Engineering Branch discussed the general technical aspects of the anticipated 316(b) demonstration study with Mr. William Jernigan of your Division's Water Protection Branch. Therefore, additional purposes of this letter are to confirm that information provided by Mr. Jernigan is properly reflected in the evaluation and to offer cur thanks for his assistance.

Sincerel,

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ungblood, Chief Licenstng Branch No. 1 Division of Licensing

Enclosure:

Letter, R. Tedesco, NRC, to W. Ehrensperger, GPC, with Enclosure 810 5050181 e

UNITED STATES 8'

D NUCLEAR REGULATORY COMMISSION WASHINGTON, D. C. 20555 O

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APR 2 91991 Docket Nos.:

50-424 and 50-425 Mr. W. E. Ehrensperger Senior Vice Pres.ident l

Power Sbpply.

Georgia. Power Company 1

P. O. Box 4545 Atlanta, Georgia 30302

Dear Mr. Ehrensperger:

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Subject:

Review of Georgia Power Company's Study Results and Impact Evaluation for the Vogtle Intake Design j

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

review (Enclosure 1), we conclude that no significant effects on the fishes 1

of the ' Savannah.. River will result from impingement.

Therefore, we find that I

the requirements of condition 3.E(7) have been satisfied.

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In the Yogtle FES of March 1974, the staff expressed the need for data to allow i

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 data on t'te adult fish community of the Savannah River, supplemented with data on the im)ingement experience at the U.S. Department of Energy's Savannah River Plant, located across the River. A successful demonstration has been riade by 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 impingement losses at Vogtle should be less than at the Savannah River Plant because of lesser water use, shorter approach channel, and lower intake velocity. Also, we note that the FES evaluation of March 1974 considered a four-unit Vogtle plant, while only a two-unit plant is now proposed. Thus, the pote.ntial cooling water impacts are reduced, theoretically, by one-half l

with the two-unit plant.

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Mr. W. E. Ehrensperger.

GPC 1,s requir.pd 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 bf this letter and its enclosure is being transmitted to the Georgia Department-of Natural Resourcesi Environmental Protectipn Division (See Enclosure 2).

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• This review.was conducted by C. Billups of,the Aquatic Resources Section of the Environmental Engiheering Branch.

Sincerely, Rtin

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Robert'L Tedesco Assistant Direct ~or for Licensing Division of Licensing

Enclosures:

1.

Staff Review of GPA's Study Results and Impact-Evaluation for the Vogtle Intake Design 2.

Letter, B. J. Youngblood, NRC, to

.L. Ledbetter, Georgia Department of Natural Resources cc w/ enclosures:

See next page l

I 9

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Mr. W. E. Ehrensperger Senior Vice President Po,fdr Supply Georgia Power Company P. 0. Box 4545 Atlanta, Georgia 30302 1

.cc: Mr. L. T. Gacwa Chief Nuclear Engineer Georgia Power Company P. O. Box 4545 Atlanta, Georgia 30302 Mr.. Ruble A. Thomas Vicd President

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Southern Services, Inc.

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

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P. O. Box 2625 Birmingham, Alabama 35202 George F. Trowbridge. Esq.

7 Shaw, Pittman Potts and Trowbridge z.

1800 M Street, N. W.

Washington, D. C.

20036 Mr. Charles Kaplan Enforcement Division t

U. S. Environmental Protection Agency Region IV 345 Courtland Street Atlanta, Georgia 30308 t

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Docket Nos. 50-424

.... and 50-425 ENCLOSURE I STAFF REVIEW O'F GEORGIA POWER COMPANYS STUDY RESULTS AND IMPACT EVALUATION FOR

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THE V0GTLE INTAKE DESIGN

Background

As originally proposed by Georgia Power Company (GPC) in their Environmental

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I Report (ER), the Vogtle intake was to be located flush.with the Savannah River shoreline.

In evaluating the originally proposed intake, the staff 6

concluded that fish impingement 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 intake pumping I

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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 sufficient data available to detennine whether the modified intake design would

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significantly increase impingement losses; the need for conditioning the Vogtle construction permit (CP) was based on this staff finding (FES, p. 11-6). As contained fn paragraph 3.E(7) of the CP, the condition requires that:

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., frior to construction of the. intake structure, the applicant shall submit the results of the aquatic monitoring programs and an _ evaluation of the environmental impact of the intake c

t 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 anadromods fish in the

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svannah River."

Iff let},ter datel 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 i

Georgia's "Section 401 certification" and the Corps of Engineer's "Section 404 t

dredge and fill pemit" were provided'by GP.C's letter. dated february 9,1981.

Additional information was obtained via telecommunicat' ions with Mr. Charle3,

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McCrary of GPC.

Iefomation provided by phone on February 10, 1981 was documented l

i in GPC's letter of February 13, 1981.

Clarification of certain intake _ design l

features was provided by Mr. McCrary on February 17, 1981.

j In our present review, we consider GPC's new informaticn ia regard to fulfillinent

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of the CP condition. Secondly, we consider the relevancy of the original u l

i condicion to present requirement of the "401 Certification" which calls for i

i a.Section 316(b) demonstration prior to use of the proposed intake.

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Sumary Review of Nes Information'

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~ 'In the su'Eittal of January' 28,1981,' G'PC has provided additional dati on'the'- ~

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fish connunity in the vicinity of the Vogtle site. These new data are compared and supplemented with results of the Savannah River Plant's successfu1 ~

demonstration, pursuant to Section 316(b) of the Clean Water Act, as to the acceptability of their intakes.

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The Ia'vannah River Plant, located across the River from the Vogtle site, l

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

Intake velocity in front of the[ screens.at the Savannah River Plant is 0.38 m/sec (1.25 fps). Maximum.

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sustain'ed_ flows through the three canals are 16.4 m /sec, 20~.5 m /sec and 4.7 -

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m /sec for a total maximum withdrawal rate of 41.6 m /sec (1468 cfs). Withdrawal 3

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rate for typical operation is 11.6 m.sec (409 cfs).*

Impingement at the Savannah River Plant was estimated.at 11.2 fish per day _

(4088fishinoneyear)with35'speciesrepresentedinthecollectio'ns. The i

four most comonly impinged were the year-round resident species: bluespotted sunfish, warmouth, channel catfish and yellow perch. Of the anadromou's species, 18 American shad were reported impinged No-one of the 35 species made up more than 10% of the total impingement sample. Minnows and other small fishes were not impinged in relative proportion to their composition in the fish community i

of the intake canals.

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

The intake design

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is basically a screened pumping structu're located at the e'nd of an approach o

canal; howEver, some novel features have been incorporated in the design, including two serrated weirs, flow guide vanes and a fish escape gap. The l

two weir structures, one loc:.ced at the opening to the river and the other about j

30.5 m (100 ft) inside the canal.. serve to control sediment transport from the river

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

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. i j-to the. area of the intake pumps. Theriver;weirwilldeflect'thebottom sedimenc lade.n, layer of river water away f om the intake canal. The canal 4

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weir will trap most of the suspended sediment transported in the upper layer j

of river water. Thegeometryoftheweirs(designandorientation),plusthe

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l g{iide banes, were selected to provide uniform flow distribution through the l

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. canal. At the downstream end of the rivir weir, a 3-ft wide opening will provide i

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a fish escape route. Flow direction at the fish gap will be outward.from the canal to the river based on design hydraulibs (C. McCrary, personal communication).

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Also shown in Figure 1 is a floating boom to be placed just outside the river weir. This Loom will serve to skim off floating debri's (e.g. leaves) and is expected to be used only seasonally (C. McCrary personal communication).

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The approach canal is 126.2 m (414 ft) long'. The opening to the river, at the j

river weir, is 36.6 m (120 Ft) wide. The canal proper is 42.7 m (140 ft) wide, l

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narrowing to 12.2 m (40 ft) at the pumping structure. The canal bottom will be i

excavated to El. 67 ft msl; thus, minimum canal. water depth will be 4.0 m (13 ft) at minimum eiver stage (water surface El. 80 ft msl). Make-up water.for the Vogtle..

3 closed-cycle cooling system will be withdrawn at an average rate of 2.5 m /sec (88.2 c i

Design velocities through the trash racks and traveling screens are less than 0.15 in/.s. !

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-(0.5 fps) and 0:2 m/s~ec '(0.7 fps), respe~ctivelf.^^

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d Results of GPC's " adult fish study" indicate that the fish community of the Savannah River in the vicinity of the Vogtle site is dominated in numbers by d

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

i and Si, respectively, of the 1109 fishes collected in seven electrofishing i :

5-surveys made during the period, September 1977 - December 1978. Species from

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12 acikitional families made up the remaining 15%.

Of the total species collected,17 were identified as game and comercial species. These include the year-round residents such as. sunfishes, crappies, 1Ergem'o'uthbass,chainpickerel,catfishesandyellowperchandthree anadromous species: American shad, blueback herring and striped bass. These 1

I 17 game and comerical species made up 16% of the fish collected bot _h.in te" rms W

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of numbers and weight. Three of the four species comonly impinged at the Savanrrah River Plant were not collected in GPC's electrofishing surveys (i.e.,

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bluespotted sunfish, warmouth and channel catfish).

t The size ranges for specimens of American shad and blueback herring suggests that

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spawning upstream of Vogtle -is occurring. The 30 American shad ranged'in 9

f length from 33 to 115 m, indicating young-of-the-year (y-o-y). Of the nine blueback herring collected, eight were y-o-y ranging between 43 and' 70 mmi and' 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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.Diseussion GPC's ev'aluation of the potential impingement impact is based chiefly on a i

'comparisok6f the Vogtlelintakeisith ~the~ Savannah River Plant intakes and the f

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... - fact that the Savannah River Plant has made a successful Se'ction 316(b) demonstration

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showing low impingement losses. We find this approach to be appropriate; f

impingement experience at the existing intakes on the same water-body provides a better picture of potential impingement at Vogtle than the' results of the electroff shing surveys. Based on a combination of lower with-

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drawal rates, lower intake velocities and shorter approach canal *, impingement at Vohtie should be even less than experienced at Savannah River Plant. However, ^

the unique feaIures of the proposed Vogtle intake design (e.g. the. weirs) may result in some difft.rences 'in impingement from that at the Sahannah River

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Plant../

.The river weir i!! de~ signed to deflect the lower layer of river water away from the canal. The half-serrated weir design has a crest elevation' of 7B ft with serrations starting at 74 ft on the downstream half and at 75 ft on the u,pstream half.. Assuming the riher bottb to be at El. 67 ft, the def,lected layer of riher t

-r water would be the lower 7 ft..At minimum riher stage'(water surface atIEi.,80 ft),

the irtake 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 adhesihe, 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,

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'are semi-buoyant; thus, the majority of eggs and early larval stages of these species also would likely be transported past the Vogtle intake in the deflected lower layer. As young of both resident and an,adromous species s. tart feeding actihely in the water column, they would become more susceptable to. passage into the Vogtle canal. Although the fate of these young fishes remains speculatihe in a pre-operational assessment, we would expect that any potential for entrap-l ment, and subsequent impingement, is reduced through a combination of the low intake helocities and prohision for a fish escape route in the weir design.

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• The Vogtle canal is shorter than the two canals at S5Eannah River plant.

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

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7 Relevant to the preser.! Teview is the. fact that the Vogtle plant i.s now proposed fortwounitsratherthanfourunits'sehaluatedintheFESofMarch1974.

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

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plant-ds expected to average 2,.5 m /slec (88.2 cfs) which is about 1.5% of the' minimutn'rtver fl.pw and 0.9% of the av' rage river flow.

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Other Relevant Reviews and Requirements -

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t GPC has receihed a " water quality certification" issued by the State of Georgia j

under Section 401 of the Clean. Water jAct and a " dredge and fill" permit issued

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by the Corps of Engineers under Section 404 of the Cle'an Water Act.. As required

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by the' State certification and reiterated in the dredge and fill permit, GPC 4

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 i

i would allow construction of the propysed Vogtle intake to proceed with a decision l

t on its acceptability to be made upon! completion of construction.

In contrast,

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condition 3.E(7) of the NRC-issued construction permits requires a satisfactory showing, " prior to construction of the intake structure", that impingement j

1 will not result in a significant adverse it;. pact. Thus, the NRC-imposed condition i

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conflicts with the requirement of the State certification', i.e., construction t

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.could not' proc,eed._un.til conditio,n 3.E(7) is. fulfilled...

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7 Since issuance of the Vogtle construction permits in 1974, the staff has,,, =,m.

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i received specific guidance with regard to imposing conditions for protection of the aquatic environment. Decisions

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Appeals Board (ASLAB) hahe held as a matter of law that the NRC did not have i

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• Refer to decisions in the cases of Yellow Creek (ALAB '515), Robinson i

l (ALAB 569) and Peach Bottom (ALAB 532).

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

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responsibility for these matters'with the Environmental Protection Agency.**

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

during environmenta'l reviews and (2) reTiance on the certifications and permits

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issued under the Clean Water Act for protection of water quality and aquatic l

i biota.

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In thd present case, we have' discussed the' technical aspect's of the review with Charles Kaplan, EPA-Region IV, and William Jernigan, Georgia Department of ~

Natural Resources. Guidance from EPA-Region IV is that an intake located at 4

the end of a dead-end canal would not generally be considered best available See for example the letter dated January 24, 1979, technology for a new plant.

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1 from G. 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 pemit would require impingement and entrainment studie.s and would contain language requiring modifications if results indicate 6nacceptable impingement and/or entrainment levels. A similar approach is anticipated in the Vogtle

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case. According to Mr. Jernigan, GPC is expected to submit a study plan which.would include pre-operational and operational monitoring to demostrate 4

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compliancewithSection316(b). The study plan would be subject to approval by the State NPDES pemitting authority.

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

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Georgia as a " permitting state" under provisions of Section 402 of the Clean Water Act.

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i Conclusion The Vogtle construction permits were conditioned such that, prior to construction l

of the intake structure, GPC would prohide information to satisfy the staff that,

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impingement will not have a signifij: ant adverse effect o.n..the adult population (s) of resident and anadromous fish in the Savannah River. GPC's submittal of -

January28, 1981 provides study results and an impact evaluation in accordance with the CP condition. Based on our rehiew of GPC's submittal, we are s tisfied

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that no significant effects on the ' fishes of the SaEannah Riher will result 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 the intake complies with Section 316(b) of the Clean Water Act. Section 401 l

recluires that conditions of certification shall become a condition'of the y

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l Section 402 NPDES permit. Thus, the State of Georgia and/or EPA, through their i

l review and permitting authority, will make the. final determination on th.e l

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

t with regard to this and other water quality related matters.

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l ATTACHMENT 1 03s

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Jcpartment af Natural fcso<urces. m

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t ENVIRONMENTAL PROTECTION OlVISION 270 WASHINGTON STREET. S W.

joe D. TANNER iTLANTA. GEORGlh 30334 cornmiss.oner May IS,1979 J. LEON ARo, LED 8ETTER Division Director

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Mr. T. E. Byerley Manager of Environmentcl Affairs Georgio Power Company P. O. Box 454.5

'-Atle'nto, CA 30302

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~. Re: Water Quality Certification

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SASOP-FP 074 OYN 004016 Intoke Structure & Access Road i

Plant Vogtle Savannah River-Burke County Deor Mr. Byerley:

Pursuont to Section 401 $f the Federal Water P' llution Control Act Amend o

ments of 1972 (33 USC 1251,3141), the State of Georgia issues this certification to Georgio Power Company, on applicant for o Federal permit or license to

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conduct on activity in, on or odjacent to the waters of the State of Georgio.

The State of Georgia certifies that there is no opplicable provision of '

Section 301;, no li'mitations under Section 302; no stonderd under Section 306; j

ond no stonderd under Section 307, for the opplicant's cetivity.

This certification is contingent upon the following conditions:

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1.

All work performed during construction will be done in a menner s

so os not to violate cpplicoble water quality stonderds.

2.

No oils, grease, materials or other pollutants will be discharged i

from the construction activities which reach public waters.

3.

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

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^ federal cgEncE.'.ponsibility'to submit this c~ertifi~cotion to th

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j.~?~~ '~ ' Sincerely,

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f)J. Leonard Ledbe er V Director i

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Mr. Steven Osvold' cc:

Dr. s~ red Marland l

Mr. E. T. Heinen Mr. J. Setser Mr. J. Lohlo 79-04-16-03 AN Arriftt.1ATIVC ACTluNIEoVAL EbPloVP1ENT of'I'OnTuNITY Er.it* LOVER

ATTACHMENT 2 ENVIRONMENTAL PROTECTION AGENCY

'JAN 2 4 s73

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4E-WE Mr: William H. Reg;an, Jr.

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.Environ =entkl Projects 3 ranch 2

• Division of Site Safety and -

Environment Analysis Nuclear Regulatory Co= mission Washington, D. C.

20555 RE: 3ellefonte Nuc*.eir Plant NPDES No. ALOO24635 -

Dear Mr. Regan:

We have reviewed the =aterial enclosed with your letter of Dece=ber 6,1978, to Mr. Paul Frey as well as other information contained in our files re-r lative to the referenced facility.

While va vould not generally consider that'a cooling water intake located at the end of a dead-end canal is best available technology for a new planc, available data and evaluations indicate that i=pinge=ent and ent =f n-e e at this facility should not result in unacceptable environmental damage. Since cc struction of the intake is virtually completed, we vill not require any modifications at this tire. The NPDES per=it, when issued, will require i=pinge=ent and entrainment studies, however. The permit will also contain language which would require modifications if the results of the studies indicata unacceptable levels of impinge =ent and/or entrain-ment are occuring.

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

Sincerely yours,

, [ ![

George. Harlow Chief Water Enforcement 3 ranch Enforcement Division cc:

Dr. Harry ".. Moore Tennessa Valley Authority (Q

Mr. James W. Warr Alaba=s Water I=provement Co=n.

7901290 m P00RBRl3\\N?L

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