ML20037A758

Summarizes Discussions W/Ceq,Doi & EPA Re Impact of Proposed once-through Cooling Sys on Aquatic Biota

ML20037A758
Person / Time
Site:	Crystal River
Issue date:	04/02/1973
From:	Oleary J US ATOMIC ENERGY COMMISSION (AEC)
To:	Muntzing L US ATOMIC ENERGY COMMISSION (AEC)
Shared Package
ML20037A756	List: ML20037A755 ML20037A758 ML20037A759
References
NUDOCS 8003260801
Download: ML20037A758 (4)

Text

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"\\f d Docket No. 50-302 WG 1-

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l L. M:nning Munt:ing, Director of Regulation

.TH20: John F. O'Lecry, Director of Licensing g,g

..,,.y DISCUSSIONS WITH E?A AND DOI CN CRYSTAL RIVER UNIT 3, DCCKE? NO. 50-302 This memo is to hecp you cbreast of recent discussions with CEQ/ DOI /E?A concerning potential probicas associated trith Crystal River Unit 3, located on the Florida Gulf coast. The site consists of two operating oil-fired baseload units and the nuclear unit uhich is now rcuchly 607. co=plete. Fucl loading of Unit 3 is non scheduled for spring 1974 with commercial operation to begin in late 1974.

Su:stary In the coursa of the environmental review of Crystal River Unit 3, a difference of opinion between the AEC on the one hand and the DOI and EPA on the other hand hcs ccorged relative to the existics impact on aquatic d'.ota fro:s the operation of the oil-fired units cad the pro-jected impact of the nuclear unit. This difference is illustrcted by the comments of these two agencies on the Draft Environ =cntal Statement.

(Copies enclosed)

Although existing envirotracatal data has not, in the opinion of the staff, shown the existence of a severe impact on aquatic biota from Units 1 and 2 or the clocr presence of an unccceptable impact once Unit 3 goes into operation, considerable augmentation of the data vill be required before firm conclusions can be drcun. A progrca to develop the necessary data is necring final definition, with EDI ccd EPA participating with AEC in the progrca development. The objective of this progrcm will be to obtain sufficient dcta on which to decide uhether or not the currently proposed once-through cooling system will result in unacceptable environmentcl i= pacts.

In cnticipation that the once-through cooling system will not be ccceptchle, DOI and EPA cre attempting to force the AEC to impose a requirement on Florida Pouer Corporation to perform a dotciled en3 -

1 neering design of closed-cycle cooling alternatives concurrently uith the acquisition of the additionci data required to make a responsible decision. The staff's ponition on this requircuent is 1. hat such cn expenditure is unwarranted ur.lcss it becoucs evident based on the study program results, that a revised cooling system is necessary.

It is our judgment that the delay associated uith carrying out detailed design would not result in any irreversible impact on the environ =cnt

_ in the vicinity of the Crystal River site.

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To date the etcff hac no doc =cnted evidccce of cithcr a cignificact or ca i=cvercible cdverse is:pect on the equctic bloca in the Cryctcl River aron duo to the operation of Unitc 1 and 2.

The fact that acte impact hcc occurred and thct additional 1:::pect vill occur is clocrly stated in the Al'C's drcft acctc= cat. Tao DOI cnd I?A hec;c tchen a stronger pocition relative to i=pcets even ~.houah it is reedily cdeitted that there is no nora inforuction cvailchla to the D0; rcvicucrc tk.n hcc been cyc11abic to tha /IC and the 1chorctory teca et p2 uhich caciated in writing the DZS.

At c necting with the DOI ct the CEQ office on ychruary 1, it was c:::ccd that the cpplicen:: chould be cched to provido a deccile.1 ctudy picn to occcblich the biot invcatory of the c cc. The objective of cuch a progrce. usuid be to qucntify the inpccts on the biota, chuc clicving c nero cc tcin jud; ment cc to the cdcquacy or neccccity to chenOc the proyecod onec-throudt ecoling cycten. Such a pron =a ecc requested cnd 1::c cubnitted to tho 120 by the cpplicant en Ucrch 5.

Copico of the procrc= have been provided to the C2Q, the DJI, the EPAp the P2, cnd 1:q ctcff percon=ci for rcvica. It is c:pected that all involved covercnent c3cncicc will reconvouc in b'cchin00cn in nid-April to catablich a unified positica uith rc;;crd to thic progrcu in prcperation for a necting t:1th the cpp11ccat et Cryctcl niver, Floride en April 24-26. The finci coc1 of thecc necticac 10 to catchlich a pro;=n that cl1 pcrties cca eccept cc one thr. uill pc nit qucntification of the enviroc=cnt:1 inpact frca the cccc-throu;h cooling cyccca, cnd provida the bacic for c cound decicion with rc;crd to the need for cloced-cycle cooling for Cryctc1 River Unit 3.

If the rceultc of thecc p;cpoccd studic cho that entnin=n is a problen cud vill ccuce en unccceptcbic cdverso inpcet, it is our jud.~nent c thic tica baced on presently cvcilchic detc, th the tinc required to engineer cud inplement c change vill not iced to en incyc=ible inpcc:: on the equatic biotc of the cctucry. The scnc cituation provcilc with rc~.rd to cat =pacnt cad thernci diccharga.

J The crun of the current dicanrec::ent betrcen ACC on enc Iv.nd, and

!OA and DOI on the other head, tentern cro=0 uhe::hcr or not the cppliccnt chould bc required to cenpleto en cur;Inceri.:n deci a of a closed-cycle cyctca for the Cryctal niver cita prior to cc. plati:.e. of che ctudy pro;rca. 7.tc J2A cud LGI contced ::hct the likclihuad of requiring such cn cite =ctive is cufficiently high thct the accign c:ccreicc is juctified. The objceti.c of t te decign c::crciseic to

h" c the design sud coaccruction time once the decicion is nado, oT$o GoP e dq pug e~

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l cnd thus minimise enviro:sacntal impact. Conduct of such en effort

1) requires that c spiscific closed-cycic systcm be identified as the most viable citernatire, 2) requires that significent ccounts of money be cnpended to completo such an encincering desica (estincted ct 1/4 to 1/3 the capita,1 cost of the citernative), cnd 3) presuppocos that the operation of Unit 3 will hcve an impcet of the aquatic biota that is potentially inreversibic and more severe than any similcr impact on the te:; restrict biota associated with a closed-cycic system.

The 1:ork donc by the ntaff to date indicates that thsrc crc c number of viabic cooling sysg:m citernatives availchic if the proposed once-through system ia found unacceptabic.. Further, cny of these alternc-tives can be impicmenpsd in a timely fashion citer identification of an caverse impac.

Additional paralici effort to further refine tSa casessment of thecc alternatives is possible. Such cn effort by the appliccat should Iced to a judg:ent cs to tha one or two best alternatives frcm en im7act/

i benefit / cost point of victs. Sech cn effort vould, however, stop short l

of the detailed design being

'vocated by DOI cnd E21..

Scac work along those lines has been ca..

id out and it is the intention of the staff to further pursup this line of attack cnd vork with DOI and 22A in determining the proferred alternative /citernatives should a chan;c in the condenser coolip; system be required.

Based on discussion uf,th EPA representatives on I'crch 16, 1973, it also appears stat qucations concerning the coolin; system vill be raiscd by E?A as a remit of the MOCA /.:acndments of 1972.

If this is the caso cnd a different cooling citernative is required beccuse of the ROCA, then it i.c.hc staff's opinion that E?A should cdvisc the A2C that the proposed system, roccrdless of the acceptability with regard to enviror=cate,l impcet, must be modified. To date E2A has not been willing t9 tche mch a position beccuse of a lach of sufficient information to judge the system's impcet cnd whether or not' cn exemption michy be warranted.

Based on the f :cgoin!,, we plan to 1) continue to resist the pressure 9

of DOI cud EPA to reqqro dctciled engineering design of a closed-cycle alternativo pricr to completion of the envirc:=cntal studies which are to be perfo:ccd by the applicant, 2) complete the evaluations p weo..e

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which cro required to actchlich the prcforred cooling syst.a citernc-l tiva from cn enviror.nontal cnd cost benefit perspective :tould the reference cystem prove unacceptchle, and 3) revicu the results of the envirorr.antal studies and decide at that timo whether or not a closed-cycle cooling syntam is warranted.

I am available to discuss this with you further if you desire.

OrQinalsigned by A. Giambusso A. Cicmbusso, Deputy Director for Reactor Projects Directorate of Liccasing Enclosurcs:

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Docket File (ENVIRON)

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Docket No. 50-302 L. Manning Muntzing, Director of Regulation THRU: John F. O' Leary, Director of Licensing #

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DEPARTMENT OF INTERIOR CONCERNS RELATIVE TO CP.YSTAL RIVER UNIT 3 DOCKET NO. 50-302 This memo is to apprise you of the most recent development in our dealings with DOI relative to the Crystal River Unit 3.

In my memo of April 2 (copy enclosed) on this subject, I discussed the environ-mental study program that was under review which would be requi:ed before a firm conclusion could be drawn relative to the need.or closed cycle cooling at this plant. Further, I noted that we are carrying out studies which would defire the best closed cycle cooling alternative from a cost / benefit standpoint if the environ-mental studies reveal a problem that would require such measures.

We expect to have the preferable alternative defined prior to the completion of the environmental study program, which is expected to take one year to complete. In the Indian Point and Peach Bottom cases, the staff concluded that sufficient evidence of aquatic impact was available to warrant a decision to recommend closed cycle cooling with no need for additional studies. In contrast, the staff

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has concluded, based on the information that is currently available on the nature of the biota in the area and the impact from Units 1 and 2, that the once-through system at Crystal River, with some possible minor modifications, will not result in a severe aquatic impact. Nevertheless, we do not disagree that further studies would be useful to corroborate our position and thus support the DOI in its desire to obtain such studies.

We have learned through discussions with the applicant, Florida Power Corporation, that Mr. Nat Reid, Asst. Secretary of the Interior, has requested that they attend a meeting in his office on April 11 to decide "What to do about Crystal River Unit 3."

The applicant stated that CEQ and EPA representatives were invited to attend. Late Friday afternoon (April 6, 1973) D. R. Muller received a call from Mr. Coorge Gardner's office inviting him and other representatives of the AEC who could make policy decisions.

Mr. 'luller inquired as to the nature of the meeting and policy decisions but the secretary who was relaying the message from Mr. Gardner could not be specific. She stated that Mrs Cardner would call Mr. Muller on April 9, 1973 with further clarffication.

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Apg i o $73 According to the appliccat, in discussion uith Gcedner, it tras stated that Mr. ncid plcas to decida ct this ccctin; whether Florida Pcuer trill bo requit-cd to start dctciled engincerin; design i

of a closod cyclo cooling system ic=sdictely. It t:ss further stated that Mr. Reid is prepared to cpproach the acccaplisl. cut of this requirement through the Secretary Morton - Chair = n nay route, if tlacessary.

I will be pleased to discuss this situation with you at your ConveniGnCG.

Original Signed Dy A, ninmhano,

A. Gicobusco, Deputy bucctor for Recctor 7:ojects Directorate of Liccusing

Enclosure:

As stated DISTRIBUTION Docket File (ENVIRON)

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