ML20028D912
| ML20028D912 | |
| Person / Time | |
|---|---|
| Site: | Midland |
| Issue date: | 01/18/1983 |
| From: | Wilcove M NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| To: | SINCLAIR, M.P. |
| References | |
| ISSUANCES-OL, ISSUANCES-OM, NUDOCS 8301200082 | |
| Download: ML20028D912 (13) | |
Text
O January 18, 1983 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
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CONSUMERS POWER COMPANY
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Docket Nos. 50-329'0M & OL
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50-330 OM & OL (MidlandPlant, Units 1and2)
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REMAINDER OF NRC STAFF RESPONSES TO INTERR0GATORIES SUBMITTED BY MARY SINCLAIR ON AUGUST 25, 1982 I.
INTRODUCTION On August 25, 1982, Intervenor Mary Sinclair filed " Discovery Questions to the Nuclear Regulatory Commission on New Contentions Accepted by Board Order, August 14, 1982." By letter dated September 2, 1982, the Staff advised the Board that it would voluntarily respond to those interrogatories. On January 7, 1983, the Staff responded to the first of the interrogatories. This is the Staff's response to the remainder of those interrogatories. Affidavits in support of all responses to the interrogatories contained in Ms. Sinclair's August 25 submittal will be filed shortly.
II.
INTERR0GATORIES Interrogatory II Contention 5 deals with questions about the adequacy of the basis of the data in the Monthly Cooling Pond Performance Tables on the cooling 880120 g OQ (y
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. pond provided in the DES (4-7, 4-8) and the extent of the fogging and icing.
Question 1 of Interrogatory II What was the source of the data relied upon for these Tables in DES (4-7,4-8)? Give the basis of data for each factor in the Table and FES (4-24,4-25).
Response
The data presenteo in Tables 4.1 and 4.2 in both the DES and FES were derived from physical hydraulic and themal model tests conducted by Alden Research Laboratory, and from calculations related to the power plant design and the climatology of the Midland plant area. Detailed descriptions of the cooling pond hydrothermal analysis can be found in the references cited for Tables 4.1 and 4.2.
Question 2 of Interrogatory II Explain in detail the effect on the efficiency and safety of the n-plant's operation when blowdown will have to be withheld when the conditions listed in FES (4-8) (last paragraph of 4.2.6.2) occur.
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a.
What percentage of annual time or days per year will Dow Chemical's plant discharge utilize the entire TDS capacity of the river i
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b.
What percentage of annual time or days per year will ambient river temperatures be equal to or greater than the monthly maximum allowable specified in the NPDES permit?
c.
What percentage of annual time or days per year can makeup not compensate for pond water losses caused by evaporation or seepage?
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Response
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2a. The staff did not specifically determine or confirm the discharge characteristics of the Dow Chemical Company during preparation I
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of the FES, but directed its attention to the operation of the Midland plant. The staff used the results of the model studies discussed in the
' response to Question 1 above.
In the physical model study, the Dow plant discharge was set at 65 cfs with an excess temperature of 5 F and a TDS concentration of 3000 ppm. The modeling results indicated that the Dow effluent would use the whole TDS capacity of the Tittabawassee River 50% of the time; necessitating withholding of Midland plant blowdown during this period.
Information obtained recently from Dow. Chemical Company indicates that the average discharge from the Dow tertiary pond is about 39 cfs and the maximum discharge is about 65 cfs which according to Dow occurs only about 1% of the time.
The average and the maximum TDS concentrations are about 3516 and 4718 ppm, respectively. These concentrations are higher than that assumed in the model study. However, the probability of having these concentrations occur with the maximum discharge would only be about 1%. Moreover, the combination of these concentrations with the average discharge of 39 cfs would result in a smaller amount of dissolved solids than that assumed in the physical model study. Therefore, the applicant's predicted TDS changes in the Tittabawasee River as a result of Dow's tertiary pond discharge appear to be reasonable.
2b. The ambient river temperature will be equal to or greater than the monthly maximum allowable specified fcr the Midland plant discharge in the NPDES permit about 8.3% of the time.
2c. Makeup will be unable to compensate for pond water losses due to evaporation and seepage about 1.6% of the time.
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._ Question 3 of Interrogatory II What will be the effect on the efficiency of plant operation when more than one of the conditions listed above occur?
(As are listed in the last paragraph of 4.2.6.2 of FES) (4-8).
Question 4 of Interrogatory II What will be the effect on plant efficiency when all of these conditions occur at the same time?
Responses to Questions 3 and 4 The Staff did not make such calculations and therefore does not have the requested information. The Staff did, however, review the expected environmental impacts for the full range of expected conditions and it can be seen that the variation in plant operation under these conditions is small.
The cooling pond is designed to have sufficient water reserve to operate the plant for 100 days with no withdrawals from the river (FES-CP, page III-7). An extensive analysis of cooling pond water management was done by the applicant. Based on historic flow conditions, during the worst drought year it would have been necessary to hold up blowdown for as long as nine months (FES-CP, page III-17).
Pond temperaturt.s were computed for the range of conditions.
It is noted from Tables III-4 and III-5 (FES-CP) that pond temperatures during the drought i
year do not differ greatly from pond terrperatures during the average year and that the seasonal range in both years greatly exceeds the year to year difference.
Since (1) effects of curtailing makeup and blowdown on efficiency would be related almost exclusively to the temperature, (2) normal i
seasonal variations in efficiency are not relevant to the Staff's conclusions, and (3) the temperature effects of the Midland water use
4 restrictions are less than the normal seasonal range, the staff concludes that the effects of plant efficiency from constraints on uptake or tlowdown of cooling pond water will be small and that calculating it precisely would not affect conclusions regarding environmental impact.
Question 5 of Interrogatory II What will be the effect on safety of plant operations when more than one of these conditions occur (as are listed in the last paragraph of 4.2.6.2 of FES (4-8)?
Question 6 of Interrogatory II What will be the effect on the safety of the plant when all of these i
ccnditions occur at the same time?
Responses to Questions 5 and 6 No effect on safety of plant operations would be associated with any combination of the conditions listed in the last paragraph of FES Section 4.2.6.2 (p. 4-8).
Question 7 of Interrogatory II James Carson, meteorologist from Argonne National Laboratory, met with the Midland County Road Commissioner and City Planners on September 8,1978, and said the Dresden pond model was more applicable to the Midwest than the Bechtel cooling pond model of 1973 which was based on data from a Southwest cooling pond.
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Was the Dresden pond data used for calculating either the thermal efficiency or the fogging and icing at Midland in the DES and FES?
b.
If it was, provide the base line data and methodology used to reach the conclusions in the DES and FES, c.
If the Dresden pond was not used for either (thermal efficiency or fogging and icing), explain why not.
t Response The staff understands that the applicant used the Bechtel cooling pond fog model to prepare its Environmental Reports ("The Environmental Effects of the Midland Plant. Cooling Pond -- Summary Report, Bechtel Co.,
Job 7220, April 28, 1972; see also Currier et al., " Cooling Pond Steam Fog," J. Air Pollution Control Assoc. 24:860-864,1974). This model for predicting the frequency v. steam fog is said to be based on observations made at two cooling ponds; the Four-Corners Power Plant at Fruitland, NM, and Lake Coffeen at Coffeen, Illinois.
The applicant's thermal performance model (Refs. 4-4 in the FES-OL) is understood to have been used to predict surface water temperature.
That model is dated August 1973.
These are two separate models.
For further discussion, refer below to subparts a-c of this reply.
7a.
Only Dresden fog, and icing data were used in the staff analysis o
of fogging and icing at the Midland plant. As indicated in the response to Question 1 of Contention 5 above, an entirely different information source was used in the Midland hydrothermal analysis. Hence, hydrothermal analyses of the cooling pond did not consider Dresden data.
7b. The data base for the Dresden studies is presented in Section 5.4.1 (and Refs. 1 and 3 through 7) of the FES-OL.
The methodology used to reach staff conclusions is also presented in Section 5.4.1.
The staff's analysis of fogging and icing conditions at the Midland plant is not based on the use of a model. The analysis is based on observations made at operating cooling ponds, including the Dresden plant in Illinois which has water temperatures
. comparable to those expected at Midland and is located in a comparable climatic area. These observations indicate that, under extremely cold weather conditions, dense steam fog will occur over and immediately downwind of the water surface. As the plumes move further inland, they will rise from the surface due to buoyancy; they will simultaneously rapidly become less opaque, due to evaporation of the fog droplets as they mix with dry ambient air.
7c. As discussed in the above parts of this response, results from Dresden fog and icing studies were used only in the staff analysis of 4
fogging and icing at the Midland plant. Dresden pond hydraulic thermal efficiency studies would be irrelevant in an analysis of Midland fogging and icing potential.
Use of Dresden pond hydraulic thermal efficiency studies was not a part of the models used in hydrothermal studies for Midland.
Question 8 of Interrogatory II Has this cooling pond model as given in the DES been applied anywhere that is comparable to Midland? If so, where?
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Response
The fog model was used in analyses of the Four Corners, Lake
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Coffeen, and Dresen plants, as well as.at Midland (see FES-OL, Refs.
1-8).
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Question 9 of Interrogatory II If so, provide the data to show that projections in the model are consistent with actual operating experience.
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. Response Because the state-of-the-art of steam fog forecasting is not precise, the staff has not made any numerical predictions of the frequency, density and extent of fogging from the cooling pond at the Midland plant.
Rather, the staff is requiring that the applicant monitor fogging and icing conditions around the cooling pond and take mitigative measures in the event that traffic problems are created by steam fog and icing (FES-OL, Section 5.4.1).
Question 10 of Interrogatory II If it has not been tried, how can you be sure it will be an effective cooling pond for the Midland plants?
Response
See response to Question 9, above.
Question 11 of Interrogatory II What studies have been made to determine the effect of the fogging on the people in the area and the Bullock Creek clementary school?
(Dr. Edward Epstein, the meteorologist from the University of Michigan who was our expert witness on fogging, discussed this at a seminar of the nuclear engineering department in October, 1972, and said, "I don't know how those people are going to live.")
Response
The Bullock Creek Elementary School-is located slightly over one mile west of the plant site (at the southeast corner of Miller and Poseyville Roads:
FES-CP, page II-7). Observation of steam fog at plants with operating cooling ponds indicate that the fog plumes rise from the surface, and their densities decrease rapidly as they move inland (Refs. 1, 2 and 5 of the FES-OL; J. Vogel and F. Huff,
" Atmospheric Effects of Cooling Lakes," Electric Power Research Institute Report EPRI EA-1762, April 1981).
For this reason, the staff expects that the Bullock Creek Elementary School will not be affected by steam fog from the Midland cooling pond.
Interrogatory III Contention 7 deals with the issue of synergism between chemicals and radiation as it affects insulation in nuclear plants.
Question 1 of Interrogatory III Please provide NUREG/CR/2156, June, 1982.
Response
We believe that the document in question NUREG/CR/2156, is dated June 1981, not 1982. This document is being placed in the local public document room in Midland, Michigan and is available in the main public document room in Washington, D.C.
Question 2 of Interrogatory III On what basis wcs the environmental qualification and durability of the insulation of electrical equipment that is now in place, determined for the lifetime of the plant?
Response
CPC's submittal on equipment environmental qualification for Midland 1 & 2 as extensively revised December 13, 1982, is currently under review, in accordance with the guidelines and requirements of NUREG-0588 and IEEE 323-1971.
The results of the Sandia study (NUREG/CR/2156) will be incorporated if it is determined that those results are of significance to the qualification of equipment at Midland Units 1 & 2.
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~ Question 3 of Interrogatory III How are the results of the Sandia study (NUREG/CR/2156) interpreted as to their effect on the performance of the cable insulation during the lifetime of these reactors?
Response
Although the Sandia study showed a decrease in tensile elongation.
for the tested insulation, the study did not demonstrate or indicate that the cable or its insulation could not (as a result of the decrease in the tensile elongation of the insulation) perform its design function. As a result, the staff has not reached a conclusion on the implications of the Sandia study.
i However, licensees are required to show that all safety-related cable is capable of withstanding a design basis event throughout its designated life.-
d Question 4 of Interrogatory III To what extent is the cable insulation that will be affected not subject to inspection at this time?
Response
As stated above in the answer to Question 3, the requirement for cable-is that it must be capable of withstanding a design basis event throughout its designated life. This requirement is independent of the availability of cable for inspection.
In addition, licensees are also required to establish a surveillance and maintenance program that includes a replacement schedule for all safety-related ele:trical equipment (including cable) with designated lives shorter than that of the plant. After review of the submittal on equipment environmental J
> qualification for tiidland, the staff will determine if these requirements are met.
Question 5 of Interrogatory III What percentage of the cable insulation will not be available for inspection once the plants begin operations?
Response
The Staff does not have this information.
Respectfully submitted,
\\N rA h N %
i Michael N. Wilcove Counsel for NRC Staff Dated at Bethesda, Maryland this 18th day of January 1983 1
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of CONSUMERS POWER COMPANY
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50-330 OM & OL (Midland Plant, Units 1 and 2)
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CERTIFICATE OF SERVICE I hereby certify that copies of "REf1AINDER OF NRC STAFF RESPONSES TO INTERROGATORIES SUBMITTED BY P1ARY SINCLAIR ON AUGUST 25,1982" in the above-captioned proceeding have been served on the following by deposit in the United States mail, first class, or, as indicated by an asterisk through deposit in the Nuclear Regulatory Commission's internal mail system, this 18th day of January 1983:
- Charles Bechhoefer, Esq.
Frank J. Kelley Administrative Judge Attorney General of the State Atomic Safety and Licensing Board of Michigan U.S. Nuclear Regulatory Comission Steward H. Freeman
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Washington, D.C.
20555 Assistant Attorney General Environmental Protection Division
- Dr. Jerry Harbour 525 W. Ottawa St., 720 Law Bldg.
Administrative Judge Lansing, Michigan 48913 Atomic Safety and Licensing Board U.S. Nuclear Regulatory Comission Ms. Mary Sinclair Washington, D.C.
20555 5711 Summerset Street i
Midland, Michigan _ 48640 Dr. Frederick P. Cowan l
Administrative Judge 6152 N. Verde Trail Michael I. Miller, Esq.
Apt. B-125 Ronald G. Zamarin, Esq.
Boca Raton, Florida 33433 Alan S. Farnell, Esq.
Isham, Lincoln & Beale James E. Brunner, Esq.
Three First National Plaza Consumers Power Company 52nd Floor 212 West Michigan Avenue Jackson, Michigan 49201 Chicago, Illinois 60602
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Ms. Barbara Stamiris
- Atomic Safety and Licensing Board 5795 N. River U.S. Nuclear Regulatory Commission Freeland, Michigan 48623 Washington, D.C.
20555 James R. Kates
- Atomic Safety and Licensing Appeal 203 S. Washington Avenue Panel Saginaw, Michigan 48605 U.S. Nuclear Regulatory Commissio.n Washington, D.C.
Wendell H. Marshall, President
. 20555 Mapleton Intervenors
- Docketing and Service Section RFD 10 U.S. Nuclear Regulatory Commission Midland, Michigan 48640 Washington, D.C.
20555 Wayne Hearn Steve J. Gadler, P.E.
Bay City Tines 2120 Carter Avenue 311 Fifth Street St. Paul, MN 55108 Bay City, Michigan 48706 Frederick C. Williams Paul C. Rau Isham, Lincoln & Beale i
Midland Daily News 1120 Connecticut Avenue, NW i
124 Mcdonald Street Washington, D.C.
20036 Midland, Michigan 48640 Lee L. Bishop Myron M. Cherry, p.c.
Harmon & Weiss Peter Flynn, p.c.
1725 I Street, N.W.
Cherry & Flynn Suite 506 Three First National Plaza Washington, D.C.
20006 Suite 3700 Chicago, IL 60602 T. J. Creswell Michigan Division Legal Department Dow Chemical Company Midland, Michigan 48640 Michael N. Wilcove Counsel for NRC Staff
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