ML19344A310

Forwards AEC Response to Questions Re Transportation Accidents,Phosphorus Removal & Chlorine Releases

ML19344A310
Person / Time
Site:	Midland
Issue date:	07/24/1972
From:	Engelhardt T US ATOMIC ENERGY COMMISSION (AEC)
To:	Goodman C, Hall D, Murphy A Atomic Safety and Licensing Board Panel
References
NUDOCS 8008070683
Download: ML19344A310 (6)

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UNITED STATES -

YD ATOMIC ENERGY COMMISSION l

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I WASHINGTON D.C. 24545

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I July 24,1972 Arthur W. Murphy, Esq., Chairman Dr. David B. Hall Atomic Safety and Licensing Board Los Alamos Scientific c/o Atomic Safety & Licensing Board Panel Laboratory U. S. Atomic Energy Commission P. 0. Box 1663 Washington, D..C.

20545 Los Alamos, New Mexice 87544 Dr. Clark Goodman Professor of Physics University of Houston 3801 Cullen Boulevard Houston, Texas 77004 Re:

In the Matter of Consumers Power Company -

Midland Plant, Units 1 and 2, Docket Nos. 50-329 and 50-330 Gentlemen:

Transmitted herewith are the AEC regulatory staff's written responses to the'various deferred questions on transportation accidents, phosphorus removal and chlorine releases.

Sincerely,

=

Thomas F. Etigelhardt Counsel for AEC Regulatory Staff

'En' closures A/S-CC:; William J. Ginster, Esq.

Irving Like, Esq.

James A. Kendall, Esq.

AS&LBP

-Milton R. Wessel, Esq.

' Hon. William !i. Ward James N. O'Connor, Esq.

Mr. Frank ';!. Karas Myron M. -Cherry, Esq.

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MIDLAND PLANT-11 NITS 1 AND 2.

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' DOCKET NOS.' 50-329 AND '50-330.

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1 TRANSPORTAT?r**

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Juestion: At/Page 7605 of f the-transcript, Dr. Goodman directed the. Staff's -

- attention;to the following EPA statecient:

In its review :of nuclear

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power,' EPA.ha's identified a need - for additional -information on' twoL types ~

H cof accidents which

~2 - result in radiation exposure to.the public:,

.those involvingit' etation 'of fuel. and waste, and -in-plant. accidents.

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l These considerations are common.co all'. nuclear. power plants.c Since.the L

odegree of. risk istgenerallyfsimilarifor all plants, th'ese issues are...

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. amenabl.e -to a general analysis. Although the AEC has been working on these-issues for'a ; number of. years,;we believe that' a 'more - thorough analysis

' of these - two - questions - on ' a - general basis, especially the probabilities' of occurrence and the expected consequences, would result ~in a better -

understanding'of-the potential'long-rance' environmental risks associated with the nuclear electric power industry. EPA has encouraged-the'AEC i

to conduct:such analyses.'

.A number of meetings'have'been held with:the D<

AEC on these matters, and they.have indicated that they are actively.

i working on these: questions., EPA will-be participating 'in these general analyses with the AEC' staff, b

With respect toithe. Midland Plant, we believe. that the facility need -

not be idelay'ed while these-questions are being resolved on a general basis..

We take this view'because we do not expect the results of the investi-

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notions will preclude necessary changes. ' if any; in equipment or operat-inn procedures at - the = individual' facilities -involved. ;If EPA believed thats a public or environmental risk were: associated with these two issues-for the Midland : Plant, we ;would,.~ of course, recommendf against proceeding-with the project.'*" ~~(Emphasis ' dded.)?

a Dr. Goodman requested to knowL the' staf f's feelings 'about this and ' whether the ' EPA really has a. significant point' on how the' staf f ~looks upon this '

j matter with. regard to transportation.

Response

A' general analysis of transportation has been under study

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lin; the - AEC - for L some time'. : 7The,results have progressed to the point that x

'the: staff is of,the' opinion that the resultstoffthe sturly when complete 5

will lnot indicate 7the = need1for changes Jin ' equipment or ' operating ' pro-

- cedures 'at the tindividualifacilities. involved..

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,a EPA,-from its-statement, appears to agree with the Staf t's view..

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_ *SectioniE,.page;37p FINAL ENVIRONMENTAL-STATEMENT.

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- *L Dr. Goodman: asked a question On Page 7611 of the transcript, Question:

_concerning the 'following statement' by the Applicant:

"We believe that.

this rail ~ route is' the.most direct and therefore one which will minimize

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exposure should an incident occur." Dr. Goodman wanted to know if the Staf f agreed with -this statement.

Response: ' The Staff does not -agree that the most. direct route will t

necessarily minimize the exposure' if an incident' occurs. The amount-of exposure would depend not on the length of the. route, but on local conditions, in particular the population density in the immediate vicinity of the incident.

~0n the other hand, choosing the most direct route might' decrease the risk of transportation by reducing the probability of an incident. The Staff is of the view that the reduction in overall risk, if any, that might be achieved by direct routing would not be significant.

In general, th.

Staf f does not believe that special routing is indicated.

Question: On Page 7610 of the transcript, Dr. Goodman asked a question concerning the_following statement bv the Applicant:

"We believe that 4

utilization of the. Interstate Highway System will minimize the risk of.

an incident-during shipment of spent fuel.".. Dr. Goodman wanted testimony as to'whether -the Interstate Highways or the back roads would be the better. routing for_ shipments.

Response: Utilization of Interstate Highways _will reduce the pro.

bability. of accidents. Statistics shuw that the probability of ac idents on divided highways is lower than on non-divided. highways. Howevur, the-velocity of ~ impact.of these ' accidents which do occur may be increased because-of the higher speeds: generally reached on Interstate Highways.

Therefore, although.the consequences of an accident on an Interstate Highway might be greater, the. probability is lower. Assuming the number of. miles required by utilization of _ Interstate Highways: to be not much dif ferent - than for alternate routes, *be risk would be about the same in both cases. Again, we do not believe that special' routing is indicated.

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i Question: On Page 7613 of the transcript, Chairman Murphy asked, "How many instances of (accidents in) transport would you expect over the

-life of the reactor?"

Response: The number of truck miles for all shipments of radioactive materialfmay be calculated from pages III-42 and III of the Final' Environmental Statement. This-indicates'about 930,000 miles of truck transportation including the return fof empty containers; during an as-sumed 30-year life of the-plant. The number of miles involving radio-act1ve _ shipments' would be about 600,000. If the irradiated fuel is shipped by' rail, the' number of shipments and hence the number of miles j

lwould.be' reduced.

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_50-329-

_. _50-330,.

Based on recent accident statistics, -(1) a shipment of fuel or' waste may_ be expected.to be involved. in an accident about~ once in a total of 750;000 shipment-miles. This indicates there would be about one accident

' during the life of the plant which involved a radioactive shipment..

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The staff. has extimated hat only about'l in 10 of tb me accidents which involve Type A packages 2) or 1 in 100 of those involving Type B packages (2) might result in any _ leakage of radioactive material. Such leakage may result in an ' exposure of a _ few hundred mrem as indicated on page VI-6 throught VI-8 of the Final Environmental Statement.

<In. case of an accident, procedures which carriers are required (3) to follms will reduce the consequences of an accident in many cases. The procecures includo. segregation of damaged and leaking packages from

. people and notification of the shipper and the Department of Transporta-tion. Radiological assistance teams are available through an inter-Governmental program to_ provide equipped and trained personnel.- These teams,- dispatched in response to calls for emergency assistance, can -

mitigate ths consequences of an accident.~

(1) Federal. Highway ' Administration,: "1969 Accidents of Large Motor Carriers

- of Property," December 1970; 'and Federal Railroad Administration Acci-

-dent Bulletin-No.: 138, " Summary and Analysis of Accidents on Railroads in-the U.

S.," 1969 (A review of -later data that had not been publish-ed showed consistency with the 1959 data).

(2) Define'd in 49 CFR $ 173.389 (j) and (k),

. (3)49 CFR: $ l171.15,174.566 and 177.861.

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Questioni - At :PAge[7428 ofj the transcript,/ Mr. Smith, Counsel for the) 2

y-1 Applicant,. represented-that Lthe Applicant was willing' to treat phosphates lso. t at th'e total. discharge

including' the11aundry. wast'e :and ~startup:

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waste,; based on;the actualL average,' _would:not exceed 35 pounds / per day -

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exclusive of:the ! pond; reconcentration of-existing phosphate,.levelslin-the river. ;He 'thenlinquired whetherf the Staff,:in light of this repre.

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sentation,'.would. be willingito reconsider ;its proposal that tho' Applicant

prevent. any: discharge which would result (in increasing the phosphorus yconcentration :in _.theiriver abovel0.05 ppm.

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Response

There:appeai's to be no basis on which to determine' the ef-

. fective carrying} capacity of a rivert for_ phosphates.or~ those concchtrations.

which;will cause; detrimental eutrophic >effacts on the. river. system or

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' receiving bodies of water..- Phosphates; are. frequently' one : of ~ the:11mit-

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ing : factors regulating producti_vity in-lakes, _ and studies on the Great-

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U Lakes have demonstrated eutrophic effects -associated with tributary i

-discharges. ;The National Technical Advisory Committee to the~ Secretary I-

- of = the Interior;-reconsnended as a; guideline,that :the concentration -of

' Total' Phosphorus 7should not be increased: to -levels exceeding 0.1 ppm

.in ' flowing: streams.or 0.05 -ppm where streamslenter -lahas 'ori reservoirs.

Theylfurther noted that the; maintenance of these guidelines may or may l

not;preventLthe occurrence of undesirable blooms an_ inuisance growths.

d The criteria for current water management appears ' to be-essentially that of miniminingi the phosphate discharges from any facility, to decrease:

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.loadinglin.the_ river and:the inventory't'o receiving bodies' of' water.

..i-h f Our ca1culations 1indicateL that at' the Applicant's; proposed reduction

- of fphosphate discharges.'_to an' average of -35 pounds per day, the result-

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ing1' concentrations;in the? cooling pond would be _about 0.12 ppm phosphate *

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. and -thelresulting ; increment of phosphates'in the river would be about '

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'0.004 ppm atzthe average river flow of:1450 cfs and about 0.03 ppm at?

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- a1 flow'~of:200 'cfs..The : total l increment of phosphorus _ in the river as

. ' a ' resulti zof plant operation,- e'.g.,_ due.to pond evaporation and the addi-E (tion _ of 35 : pounds per day at pond ' equilibrium, - has been calculated as i

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. being about '0!012 ppm phosphorus during periods when the - river - flow ^would J

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be 200'cfs and'O.0013 at 1450 cfa.

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JThi Staff; considers L the proposed. reduction in phosphate. discharges ac-

'ceptable: 3 ased on the ~ Applicant's commitment,' the Staf f will require.-

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i that the total: discharge off phosphates not exceed an average of 35' pounds

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-a day kexclusiv'efof: pond reconcentration ofJexisting levels in the river.

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[*To< convert :from pnosphate to phosphorus, use a factor of 0.33.

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RESIDUAL CHLORINE:

Question:D A' discussion.of biocide degradation began on Page 7383 ;of tho'

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transcript and ended on Page. 7397.with. Dr. Goodman's statement,. "My.

suggestion is ~ that this' be examined, both by the applicant and by the 4

g Jgroup here, and see' if. you can come up with some strengthening -of the

recommendation of11owering of..that limit."

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2 Response:. The Staff proposes. iu ' item 7(g) of the Summary and-Conclusions of-the Final Environmental Statement. that the Applicant take the follow-4 l

Ling action:. In ' order to assure that the chlorine residual in the river is negligible,,the concentration in the pond blowdown must.be limited to 0.05; ppm.

t Considering -the expected rate of chlorine degradation in the pond, total y

residual chlorine resulting. from the chlorination of the condenser cooling water system. is expected.to, decay to chloride prior to blowdown. - However,

'if chlorine is used as a biocide. on the pond blowdown cooling towef, some residual chlorine could be present during those times at the intaka point -

for che pond blowdown. Therefore,- the Staff has placed the limit.of 0.05 ppm chlorine residual. on the' pond blowdown. This means that when the cooling tower.has:been chlorinated,,the Applicant must recirculate pond.

! water through-the. tower without blowdown until the residual chlorine is O.05. ppm or less. - This may result in an extended recirculation period if chlorinationiis performed at night.

If it is assumed ~that no further degradation occurs during mixing with-the dilution-' stream during blowdown, the concentration would be 0.0017 ppm at an average river flow of 1450 cfs and 0.01 ppm at-a river flow

_ o f. 2.)0 c f s.

The Applicant is restricted (see Page III-8, FINAL ENVIRONMENTAL STATE-1 MENT)nfrom taking makeup water-unless the river flow is greater than -

i350 cfs. : Until the river flow is, greater than'650 cfs, the volume of makeup z(40 cfs)- is essentially for evaporative losses E(18 to 35 cfs) from the pond. Operationally, the Applicant ~ is restricted from. blowing

.down the pond unless there is makeup water available which effectively.

restricts!pondiblowdown'to those times when.the resultant' flow in the-river at the pond' discharge is. equal to or greater than 610 cfs '(650, cfs

'minus 40 cfs).

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Since the above operational conditions require a minimum river flow of v.

1610, cfs :at: the point of plant discharge, the limit of-0.05 ppm residual

chlorine lin. the. pond blowdown;cf fectively' limits the maximum concentration -

j; to <0.004 ppm in a the river for. a pond. blowdown of 50 cfs-and to '0.COS ppm C

- for a pond - blowdown 'of 100 cfs.'

Furthermore, chlorination-is character-istically-an1 intermittent process 'of short duration. :Under these conditions,-

i eno.significant; kills. of aquatic: organisms or measurable adverse effect

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'on-the'aquaticLecology_is expected. Therefore,_the Staff does not believe

,thaniany further restriction on residual: chlorine above the limit of 0.05 ppa residual chlorine in the pond. blowdown should be required.-

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