ML20037A402

Responds to Doi 700928 Comments on Environ Rept Transmitted by AEC

ML20037A402
Person / Time
Site:	Oconee
Issue date:	10/30/1970
From:	Willie Lee DUKE POWER CO.
To:	Morris P US ATOMIC ENERGY COMMISSION (AEC)
References
NUDOCS 8001140777
Download: ML20037A402 (5)

Text

__

~"

DAT2 RECEIVE 3 ~~ ~ ~~ Noi

,r DAT3 CP OOCUMNT:

Buke Power Company 10.p.M u-2-w c

9 ga f

hg,My M1 %

6 T R.

MEMC6 R EPORT; O TH L 4

3. Lee-x Q at...

CC.

OTHER

{

gg 1

I f4CTION NECESSARY O

Co~cuaac~ce O

oarc a~5* Eato:

I l NO C1404 WECESSARY COMMENT O

e <:

POST OF F KE FibE COOL.

-M S4F:

50 4 50-270 5W

'(EnvIno FILE)

U

.E.

N o.

REFL. tED TO DATE RECENED BY DATE 9

CWPTK,N. (Must Be U nctsstatied)

Ltr in response to our 10-12-70 itr n-3@

which tran -itted Dept of Interior's yfg ggm 9-28-70 ltr.... furnishing ecuments on I

Dept of Interior's comments on Duke's nT ww i -rr ium ;

'j-Regulatory File (3)(1 es docket)

{

'""" Oconee Sta. Enviro Rpt.h L aar m m ('al(1 en danirst.)

j Compliance (2)

(

u

.4

.a=

Felton l

hm,(Oct' mm 1 WAl I

Di$ anna I t',.U OT 2 G l ] llc

.v zw i

f.PVM[l'n)=2003:

II j

DeYoung

" ' " ^ *

• v a. ~

, m,.. m N Dube P. Howe (2)

CE'S

=.a 4, /~,

re i

u.s. Arouc cucacy couaission M All CONTROL FORM roau.m*Ec nes j

@ W.I. G Q W E"NuEN T p erM?lN G C F Fi O E-1970 381 148 77 0

D ig t

c B

j i

, ; OJ j j\\_i La Lu v

C 8001140 777

E

-i

~-

DUEr Pownn Goxrm Powen Burtmxo. Box naa. Gn.uttorrn.N. G conot mm m

u.a... mm.

/

.f h jg-9 m! sp

M s/

it' '

M~O

'actobsr 30, 1970 i~(

t*2G

.A f'

21

..-uvQ d

0V D@!

f~.

gey ?.

• ".'1 ;~~1; Gi Q

yOV2

.\\

t..

x.

1970w 9

m g,3,,$lk-huf Dr Peter A Morris, Director Q

gga,Q/

ri

/

i Division of Reactc-Licen=Ing bemrf l

\\dfp0[K,N/

\\g 4

UC Ato.nlu Energy Commission p

Washington, D C 20545

,c, y

j l

R2:

Oconee Nuci - Station j

Docket Nos 50 -269,' 270 and -287 Regulatory File Cy.

j

Dear Dr Morris:

Please refer to your letter of October 12, 1970 transmitting the Department of

[

Interior's letter of Septeraber 28, 1970 commenting on our environmental report for l

the Oco**

Nuclear Station.

I In the introductory and closing paragraphs of its letter, the Department of Interior l

suggests that our environmentai statement be substantially expanded to include additional detail.

In our cover letter to you of' July 10, 1970, transmitting the environmental report, we indicated the report was necessarily brief. At this late stage in consideration of our _ application for operating licenses on a nearly com;:lete proj ect, it was not feasible to include a broad spectrum of details from our voluminous files of environmental studies that were developed during the early stages I

f, or the Keowce-Toxaway Project, of which Oconee is a part.

Beginning in early 1965, the many environmental aspects of this project were reviewed step by step with the applicable local, state and federal agencies with the result that every such egency, including the Department of Interior, has concurred in this project including its

{

cnvironmental aspects. We feel that the statement appropriately summarizes the t

pertinent Information from the:c m:ny procccc'ings.

l I

With respect to the numbered paragraphs in the Department of Interior's Ictter, we l

offer-the following:

1.

Regarding Interior's comment about radionuclides in the Keowee River, the figure of 24 percent of the maximum permissible Ilmit for radioactive

~ liquid waste was obtaineo f rom Table 11-6, p 11-23 of our Final safety Analysis Report. This table presents the results cf calculations of the maximum activity in the station effluent for the three Oconee reactor units, essuming that ecch was operating with one percent defective fuel for e puriod of one year' This one percent defective fuel condition is a design cssumption that was used in specifying and sizing the radioactive waste disposal systems.,The tabic is not intended to represent the ncrmal or MR

I B

i 3r P tcr A Morris l

kg32 let:b;r 30, 1970 cxp:cted operating condition. Actually, the 24 perce number should be a

intcrpreted as a figure of merit!

It demonstrates the ability of the l

rcdioactive liquid waste system to handle an extreme desiga condition which is essumed to exist simultuneously in all three reactor units, wIthout cxeceding a small percentage of the permissible l'imits.

l l

Th3 radioactive liquid wasta system has provisions for hold-up of liquids l

In tanks, for decay of radioactivity, for treatment by ion exchange and j

evaporation to reduce the activity even further and for controlled, monitored release in accordance with AEC regulations (10CFR20). Further, the Technical j

Sp:cifications for tne Oconee Nuclear Station list additional requirements for processing all wastes to reduce the radioactivity to as low a level as ;

practicable within the limits of 10CFR20.

I Therefore, because of the over-sized radioactive waste systems that have bzen provided in the design of the Oconee Nuclear Station and the regulatory l

I l

requirements for processing these wastes to reduce their activity level and the requirements for controlling and measuring these effluents, the releases i

from the three units, during normal operation, should total less than one ocrcent of the maximum permissible limits, both on a short-term and on an annual basis.

The Environmental Radioactivity Monitoring Program samples, from the upper reaches of the Hartwell Reservoir and from the Clemson and the Anderson water supply intakes, will confirm that this degree of codrol has been tchieved during~stction operation.

2. -With respect to thermal effects, Interior asks about possible interactions bmtween Oconee and future stations planned for Lake Keowee. Our studies show that the extra temperature in condet.ser cooling water from each of the futu.e stations will be dissipated without adverse effects among the stations, and the capacity of the future stations will be limited to achieve this result.

However, the current regulatory proceeding is v ith respect to Ocorae and not the future stations.

Dr Velz's 1966 report and Mr Udall's April 7,1966 letter w:re only with respect to a 3000 mwe nuclear station at the Oconee site, which is being developed to 2658 mwe. The terms of our FPC Ilcense for Project #2503 will require additional proceedings before that agency and other agencies before the future thermal sites can be developed. Since 1959, Duke has had a full-tima praup engagad in water resources research with emphasis on thermal effects cnd with the guidance of a' number of consultants. As pointed out in our cnvironmental rep ~ ort, this group will include Oconee in its monitoring program that already covers a number of lakes on our system. These field tests will b3 used to compare results with predicted behavior and to serve as a sound b: sis for future developments. The conceptual design of the Keowee-Toxaway l

Proj ect, including the skimmer wall and condenser cooling water system for Oconee, was br. sed on field analyses of analogous existing developments on our system..

i nenn t

.I O M i

e l

r Peter A Morris age 3 sctobsr 30, 1970 9

Interior suggests that Information be presented on proposed and alternative

.fccilities to prevent damage to fish and other organisms drawn to or passing through the cooling water intakes.

It should be clearly understood that the 88propused" facilities are already built. The alternative to Keowee-Toxaway was thermal stations with cooiing_ towers but without Lake Keowee as a cooling restrvoir. The development of Lake Keowee substantially increases.the-population of fish and other acustic orgenisms which would not have occurred t

hed the alternative been selecud. The intakes at Oconee were designed with conservatively low water velocities that have proven successful at our other installations on similer lakes in preventing damage to fish.

l h.

Intsrior asks for.Information on the proposed and alternative chemical

-treatment for condenser cleaning. The condenser tubes will be cleaned m:chanically at Oconee without the use of chemicals.

.). Duke's water ~ resources research group includes the Keowee-Toxaway Project cnd the upper end of Hartwell ir its continuing water quality monitoring

]

program. Sampling stations have been selected and data collection'will

-j.

start shortly as Lake Keowee continues to fill prior to Oconee operation.

i This, along with continuing post-operation sampiing, will serve-to' appraise tha impact of Oconec's operations on the environment.

Interior's letter emphasized the impact on recreational and water supply use. As explained in our environmental report, the Keowee-Toxawar Project will provide, and in fact is already providing, substantial recreational and water supply

-l brnefits that did not exist before Keowee-Toxaway was built and would not I:

exist if the alternative had been selected.

I

}. 7h3 combined effect of the three units at Oconee was used as a basis ef.-

cstablishing the requirements for waste control fe-ilities. This is further' l'

reflected in our comments under Item I above.

9. T51s item suggests that we present information on th*e visual impact of.

[

Oconee and other construction,. and our plans to minimize this Impact.

Through careful project planning as well as architectural treatment, we i

have attempted to enhance the visual impact of the entire project but not to hida it as " minimize" might suggest. Although located in a remote, lightly-traveled area, the attractiveness of this project is evidenced by the fact that 347,000 visitors have come to view the project since v'sitors' facilities were a

completed in July 1969, fifteen months ago. Visitor's comments with respect to the visual impact as noted in the guest book are highly laudatory. 1he.

visitors' center itself has just received the 1970 Honsr Award of the American Institute of Architects.

i i look forward to continued cooperation with the sever (1 agencies of the Department f-Interior. in connection with the environmental aspects of the Keowee-Toxaway Project'.

fnyoftheseaspects not found in the alternative to this project, are in the areas e

of specific interest to the Department of Inter'or:

downstream flow augmentation in 1

. O t" A m -

?!

I Dr Pat;r A M.ris

[

>sna 4 i

Octobcr 30, 1970

[

/

I I

pr.riods of dry weather, extensive recreational opportunities, roll conservation i

Erc;sures, p: cser,ation of vityin timber, recovery of historical informa ion I

nd crtifacts, substantial fisherier resources, wildlife preservation and pro-p g tion, pub 11c water supply, flood control, and oppot wnities for enjoyment af secnic beauty.

I W3 cpprcciate this opportunity to have furnished this information in connection with tha Departme,t of Interior's comments.

Yor,r very truly, O

r L! S Lee L.'S L/ s l

i i

O e

e 9

O

.e O

N

DUKE PowEn GOMPANY PowEm Bun.mwo. Box 2178. GHARLOTTE.N. G. asson wtLLIAM S LEE vsCE peg geDg ueT, Ese$stug getesse October 30, 1970 Dr Peter A Morris, Director Division of Reactor Licensing Atomic Energy Commission Washington, D C 20545 Re: Oconee Nuclear Station Docket Nos 50-269, -270 and -287

Dear Dr Morris:

Please refer to your letter of October 12, 1970 transmitting the Department of interior's letter of September 28, 1970 commenting on our environmental report for the Oconee Nuclear Station.

In the introductory and closing paragraphs of its letter, the Department of Interior suggests that our environmental statement be substantially expanded to include additional detail.

In our cover letter to you of July 10, 1970, transmitting the environmental report, we indicated the report was necessarily brief. At this late stage in consideration of our application for operating licenses on a nearly complete pr oj ect, it was not feasible to include a broad spectrum of details from our voluminous files of environmental studies that were developed during the early stages of the Keowee-Toxaway Project, of which Oconee is a part.

Beginning in early 1965, the many environmental aspects of this project were reviewed step by step with the applicable local, state and federal agencies with the result that every such agency, including the Department of Interior, has concurred in this project including its environmental aspects. We feel that the statement appropriately summarizes the pertinent Information from these many proceedings.

With respect to the numbered paragraphs in the Department of interior's letter, we offer the following:

1.

Regarding. interior's comment about radionuclides in the Keowee River, the figure of 24 percent of the maximum permissible limit for radioactive liquid waste was obtained from Table 11-6, p 11-23 of our Final Safety Analysis Report. This table presents the results of calcuiations of the maximum activity in the station effluent for the three Ocopee reactor units, assuming that each was operating with one percent defective fuel for a period of one year! This one percent defective fuel condition is a design assumption that was used in specifying and sizing the radioactive waste disposal systems. The table is not intended to represent the normal or n e., m -

hhY

Dr Peter A Morris Page 2 October 30, 1970 expected operating conditio..

Actually, the 24 percent number should be interpreted as a figure of merit!

It demonstrates the ability of the radioactive liquid waste system to handle an extreme design condition which is acsumed to exist simultaneously in all three reactor units, without exceeding a small percentage of the permissible limits.

The radioactive liquid waste system has provisions for hold-up of liquids in tanks, for decay of radioactivity, for treatment by lon exchange and evaporation to reduce the activity even further and for controlled, monitored release in accordance with AEC regulations (10CFR20). Further, the Technical Specifications for the Oconee Nuclear Station list additional requirements for processing all wastes to reduce the radioactivity to as low a level as practicable within the Ilmits of 10CFR20.

Therefore, because of the over-sized radioactive waste systems that have been provided in the design of the Oconee Nuclear Station and the regulatory requirements for processing these wastes to reduce their activity level end the requirements for controlling and measuring these effluents, the releases from the three units, auring normal operation, should total less than one percent of the maximum permissible limits, both on a short-term and on an annual basis.

The Environmental Radioactivity Monitoring Program samples, from the upper reaches of the Hartwell Reservoir and from the Clemson and the Anderson water supply intakes, will confirm that this degree of control has been avhieved during station operation.

2.

With respect to thermal effects, interior asks about possible interactions between Oconee and future stations planned for Lake Keowee. Our studies show that the extra temperature in condenser cooling water from each of the future stations will be dissipated without adverse effects among the stations, and the capacity of the future stations will be limited to achieve this result.

However, the current regulatory proceeding is with respect to Oconee and not the future stations. Dr Velz's 1966 report and Mr Udall's April 7, 1966 letter were only with respect to a 3000 mwe nuclear station at the Oconee site, which is being developed to 2658 mwe. The terms of our FPC license for Project #2503 will require additional proceedings before that agency and other agencies before the future thermal sites can be developed. Since 1959, Duke has had a full-time group engaged in water resources research with emphasis on thermal effects and with the guidance of a number of consultants. As pointed out in our environmental report, this group will include Oconee in its monitoring program that already covers a number of lakes on our system. These field tests will be used to compare results with predicted behavior and to serve as a sound basis for future developments. The conceptual design of t'he Keowee-Toxaway Pr oj ect, including the skimmer wall and condenser cooling water system for Oconee, was based on field analyses of analogous existing developments on our system.

O C ',3" ww v

~

Dr Peter A Morris Page 3 October 30, 1970 3.

interior suggests that information be presented on proposed and alternative facilities to prevent damage to fish and other organisms drawn to or passing through the cooling water intakes.

It should be clearly understood that the

" proposed" facilities are already built. The alternative to Keowee-Toxaway was thermal stations with cooling towers but without Lake Keowee as a cooling reservoir. The development of Lake Keowee substantially increases the population of fish and other aquatic organisms which would not have occurred had the alternative been selected. The intakes at Oconee were designed with conservatively low water velocities that have proven successful at our other installations on similar lakes in preventing damage to fish.

4.

Interior asks for information on the proposed and alternative chemical treatment for condenser cleaning. The condenser tubes will be cleaned mechanically at Oconee without the use of chemicals.

5 Duke's water resources research group includes the Keowee-Toxaway Project and the upper end of Hartwell in its continuing water quality monitoring i

I program. Sampling stations have been selected and data collection will f

start shortly as Lake Keowee continues to fill prior to Oconee operation.

This, along with continuing post-operation sampling, will serve to appraise the impact of Oconee's operations on the environment.

Interior's letter emphasized the impact on recreational and water supply use. As explained in our environmental report, the Keowee-Toxaway Project will provide, and in fact is already providing, substantial recreational and water supply benefits that did not exist before Keowee-Toxaway was built and would not exist if the alternative had been selected.

6.

The combined effect of the three units at Oconee was used as a basis of establishing the requirements for waste control facilities. This is further reflected in our comments under Item 1 above.

7 This item suggests that we pres.nt information on the visual impact of Oconee and other construction,- aad our plans to minimize-this impact.

Through careful project planning as well as architectural treatment, we have attempted to enhance the visual impact of the entire project but not.

to hida it as " minimize" might suggest. Although located in a remote, lightly-traveled area, the attractiveness of this project is evidenced by the fact that 347,000 visitors have come to view the project since visitors' facilities were completed in July 1969, fifteen months ago. Visitor's comments with respect to the visual impact as noted in_the guest book are highly laudatory. The visitors' center itself has just received the 1970 Honor Award of the American Institute of Architects.

We look forward to continued cooperation with the several agencies of ~ the Department of Interior in connection with the environmental aspects of the Keowee-Toxaway Project.

Many of these aspects, not found in the alternative to this oroject, are in the areas of specific Interest to the Department of interior:

downstrean, flow augmentction in arqr dv4

.r Dr Peter A Morris Page 4 October 30, 1970 periods of dry weather, extensive recreational opportunities, soll conservation measures, preservation of virgin timber, recovery of historical information and artifacts, substantial fisheries resources, wildlife preservation and pro-pagation, public water supply, flood control, and opportunities for enjoyment of scenic beauty.

Ve appreciate this opportunity to have furnished this information in connection with the Department of Interior's comments.

Yours very truly,

/

/

W S Lee WSL/s a

d >

,s

, -.. - ~. - -----