ML20028C078
| ML20028C078 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  |
| Issue date: | 12/21/1982 |
| From: | Stolz J Office of Nuclear Reactor Regulation |
| To: | Crouse R TOLEDO EDISON CO. |
| Shared Package | |
| ML20028C079 | List: |
| References | |
| TAC-42152, NUDOCS 8301060016 | |
| Download: ML20028C078 (8) | |
Text
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IE-Hannon & Jordan ACRS-10 AE0D 110rnstein lir. Richard P. Crouse EBlackwood Vice President, !!uclear Toledo Edison Company Edison Plaza - Stop 712 300 !!adison Avenue Toledo, Ohio 43652
Dear Hr. Crouse:
SUDJECT: APPLICATI0il TO A!EllD APPEliDIX B TECliflICAL SPECIFICATI0ils (TS)
By letter dated June 30,1983 (flo. 619), Toledo Edison Company applied for an anentent to Facility Operating License !!o. flPF-3. The appli-cation requests nodification of Appendix B of the license by deletion of certain specification sections. The decision of the Atonic Safety and Licensing Appeal Board relating to the Yellow Creek facility (ALAB 515, 8 liRC 702 (1978)) is cited as the basis for the requested nodification to Appendix B.
Specifically, it was requested that Section 2.1, 2.2, 2.3, 3.1, 4.0 and 5.4.1 Part A be deleted.
The llRC has taken the position that, as a natter of law, water quality conditions should be renoved fror, ayisting mactor operating licenses where the licensee hold an effective !!ational Pollutant Discharge l
Elinination Systen (!'PDES) permit. This position is consistent with the Yellow Creek decision and subsequent related decisions which established that operating conditions on non-radiological aquatic l
natters and other non-radiological aquatic nonitoring requirements are the exclusive concern of the EPA and pernitting states and are not the responsibilit;y of the llRC. These decisions, however, do not have the effect of limiting the llRC's role in non-radiological non-aquatic environnental matters.
The current liRC practice with respect to nodifications to Appendix B is to incorporate all radiological environnental TS requirerents in Appendix A to the license. With regard to water quality related I
natters, the llRC will rely on the agencies (EPA and/or state l
agencies) responsible for regulating these matters under the Clean llater Act. The remaining non-radiological non-aquatic natters are incorporated into a new Appendix B retitled as an Environrental Pro-tection Plan (EPP). The EPP has been adopted in standard fornat for all new plants and for existing plants on a case-by-case basis. The EPP is designed to promote f;RC awareness of environmental effects of plant operation while recognizing that regulation of non-radiological aqcatic matters is the responsibility of other agencies.
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!!r. Richard P. Crouse The !!RC staff has prepared a recomended EPP for the Davis-Besse facility.
This plan: 1) deletes all water quality requirements,
- 2) retains certain terrestrial monitoring requirenents, 3) upgrades the section on administrative controls and 4) divides Appendix B into two parts - Part I-Radiological Environmental TS (RETS) and Part 2-EPP. Eventually, the RETS will become part of Appendix A.
The recomended EPP retains the ETS Section 4.1 Operational f;oise Surveillance. We have reviewed the results of the monitoring con-ducted to date and have concluded that the objectives of this pro-gram have not been fully satisfied. Our specific comments in this regard are presented in Enclosure 1.
The recorrnended EPP is presented in Enclosure 2.
We request that you review this EPP and consider revising your application of June 13,1983 accordingly.
Please provide your response no later than January 27,.1983.
Sincerely, WWW John F. Stolz, Chief Operating Reactors Branch #4 Division of Licensing
Enclosures:
l.
Specific Coments 2.
Recommended EPP cc w/ enclosures:
See next page M~,-
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Toledo Edison Company ccw/ enclosure (s):
Mr. Donald H. Hauser, Esq.
U.S. Nuclear Regulatory comission The Cleveland Electric Residerit Inspector's Office Illuminating Company 5503 N. State Route 2 P. O. Box 5000 Oak Harbor, Ohio 43449 Cleveland, Ohio 44101 Gerald Charnoff, Esq.
Shaw, Pittman, Potts and Trowbridge 1800 M Street, N.W.
Washington, D. C.
20036 Paul M. Smart, Esq.
Fuller & Henry 30011adisdn Avenue
( *jo #f "
oledo Oh o 43603 q
230 South Dearborn Street Mr. Robert B. Borsum Chicago, Illinois 60604 Babcock & Wilcox Nuclear Power Generation Division
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7910 Woodmont Avenue, Suite 220 Bethesda,11aryland 20814 Ohio Department of Health ATTN: Radiological Health Program Director P. O. Box 118 President, Board of County Columbus, Ohio 43216 Comissioners of Ottawa County Port Clinton, Ohio 43452 Attorney General Department of Attorney General 30 East Broad Street Columbus, Ohio 43215 Harold Kahn, Staff Scientist Power Siting Comission 361 East Broad Street Columbus, Ohio 43216 7'
Mr. James G. Keppler, Regional Administrator U. S. Nuclear Regulatory Comission, Region III e
799 Roosevelt Road Glen Ellyn, Illinois 60137 l
v Mr. Larry D. Young Manager, Nuclear Licensing Toledo Edison Company i
Edison Plaza 300 Madison Avenue Toledo, Ohio 43652 l
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Staff Evaluation of Operational Noise Surveillance at the Davis Besse Nuclear Power Plant Unit No.1
Reference:
1.
ETS Section 4.1 Operational Noise Surveillance 2.
NUS Corp. Report NUS-TM-319 " Supplemental Noise Survey of the Davis Besse Nuclear Power Station Unit 1", February 1979.
General Comments:
The sound level survey conducted on November 20-21, 1978 indicates an expected maximum sound level of 52 dBA at the site boundary due to plant operation, primarily as a result of the operation of the plant cooling tower.
Because the cooling tower sound level can be considered constant 'and continuous, and i
assuming that this is the predominant sound source at the site, the maximum expected day-night equivalent sound level (LDN) at the site boundary is calculated by the staff as about 58 dBA.
This exceeds the EPA identified level of 55 dBA as requisite to protect human health and welfare in outdoor spaces.
l Although not measured, the licensee predicts that sound levels at nearby l
residences will not be above the EPA identified level, based on the levels measured on-site. The licensee also expects that wave noise (from Lake Erie) will partially or completely mask the plant noise at these residences.
I i
.- The environmental conditions that existed during the survey were not ideal.
That is, the wind speed recorded at the plant site exceeded the recommended allowable maximum for conducting sound level surveys (ref. AflSI S1.13-1971) during 2 of 16 measurements and 7 of 16 measurements at the 35 ft and 250 ft levels of the site meteorological tower, respectively. Wind speeds at ground level at the survey locations were not recorded. The licensee restricted the sound level survey to locations on-site because of the wind conditions during the survey. The resulting restricted survey is not in accordance with the program specification as presented in the ETS.
A possible pure tone in the 125Hz band was indicated in the survey results. The presence of pure tones is important in 'off-site noise impact assessment because of their higher annoyance potential. The data presented in the licensee's report is inconclusive in this regard however.
Specific Coments:
1.
The methodology for the operational noise surveillance described in the Specifications section of ETS 4.1 states that "... noise sensitive 1and use and specific noise sources shall be identified. Measurements shall be obtained near critical locations of noise sensitive land use such as the nearest resident, school, hospital, cemetery, and wildlife refuge which may be affected by noise from unit operation." This portion of the Specification
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, was not followed during the survey of 11/20-21/78.
The reason given was excessive wind speed which would interfere with survey results.
In fact, the information presented in Table IV of the results indicate several measurements of wind speed in excess of 13 mph, the recommended maximum allowable during such surveys (see above).
2.
The Specification section of ETS 4.1 also indicates that statistical alcng with the cumulative percent descriptors L'0' '50' '90, Leq and LDN l
distribution and standard deviation of the data will be used in the impact analysis. The NUS report presents only the octave band analysis and L50 data. Theotherstatisticaldescriptorswould5eusefulincharacterizing the sound levels from the plant.
3.
The licensee used a predictive technique for estimating sc rqd levels at the plant boundary. The specific location of this point on the site boundary and its distance from the cooling tower are not specified.
Similarly, the direction and distance from the cooling tower to the point where the predictive technique indicates the 45 dBA contour will reside is not explained.
==
Conclusions:==
The operational noise surveillance program outlined by the staff in the FES and detailed in-the ETS was clearly intended to be a confirmatory monitoring program that would produce a verification of the predictions presented.. the FES. The data submitted, the locations actually surveyed and the location for which a sound level prediction was made are not in accordance with the ETS Specification.
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. The program submitted by the licensee has only partially satisfied the program objective. That is, for close-in locations on-site, actual measurements have been made.
But for the off-site locations, where the greatest amount of uncertainty and potential for impact lie, tha program has only made additional predictions of sound levels.
Using the data submitted, the licensee infers that the offsite sound levels due to the operation of Davis Besse Unit 't are not likely to be above identified levels of noise associated with annoyance or activity interference.
- However, without further descriptive information frem the licensee, the staff cannot agree with the licensee's conclusions.
Recommendations:
ETS 4.1 Operational Noise Surveillance should remain in the ETS for the facility until the critical elements of the program, as described in the Specification l
section, or the staff's critical statement 5concerning the conduct of the program to date are satisfied.
If the licensee elects to try to satisfy the staff's concerns, the following should be included in the submitted information:
a) The licensee should reconcile the wind problem. That is, the licensee I
must explain why the on-site noise measurements are accurate but those off-site could not be made. Also, the licensee should explain why the I
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