ML20041G366

Forwards Comments on Des (NUREG-0878)

ML20041G366
Person / Time
Site:	Wolf Creek
Issue date:	03/15/1982
From:	Koester G KANSAS GAS & ELECTRIC CO.
To:	Harold Denton Office of Nuclear Reactor Regulation
References
RTR-NUREG-0878, RTR-NUREG-878 KMLNRC-82-176, NUDOCS 8203220137
Download: ML20041G366 (9)

Text

_

KANSAS GAS AND ELECTRIC COA 1PANY T.E E L E C T5+C CL*N8 AP4v GL84N L st O E $ 1 E R

.....u.. m ...

Maren 15, 1982 Mr. liarold R. Denton, Director Office of Nuclear Reactor R

' f j' C 3

U.S. Nuclear Regulatory Commission d h Washington, D.C. 20555 ( ,Uliq:3 2 r- i KMLNRC 82-176 tm at I$A DrRg .9 1982 --

~

C Re: Docket Namber STN 50-482 DM5 Subj: Wolf Creek Draft Environmental Statement i fj ,

Comments s

Dear Mr. Denton:

The draft environmental statement on Wolf Creek requested any comments to be filed no later than 45 days after notice of its availability. Transmitted herewith are KG&E's comments on the Draft Environmental Statement (NUREG-0878) related to the op2 ration of Wolf Creek Generating Station, Unit No. 1.

Yours very truly, s,4.,s&'

/) N GLK :bb Attach cc: Mr. J.B. Ilopkins (2)

Division of Project Management Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Mr. Thomas Vandel Resident NRC Inspector Box 311 nurlington, Kansas 66839 C#p 8203220137 820315 eV PDR ADOCK 05000482 D PDR 201 N Afarket - Wrchita. Kansas - Afail Address: PO Box 208 I Wichita, Kansts 67201 - Telephone Area Code (316) 2616451

OAT!! OF AFFIRMATIOfi STATE OF KA!JSAS )

) SS:

COUIJTY OF SEDGWICK )

I, Glenn L. Koester, of lawful age, being duly sworn upon oath, do depose, state and af firm that I am Vice President - riuclear of Kansas Gas and Electric Company, Wichita, Kansas, that I have signed the foregoing letter of transmittal, know the contents the reo f , and that all statements contained therein arc true.

KNISAS GAS A!1D EIICTRIC COMPNiY ATI'EST : / .

By ]f.'.'$ ~

tdl*f, / &

'Glenn L. Koestier b / Vice President - fluclear W. B. Walke r, Secretary STATE OF KNISAS )

) SS:

COU!1TY OF SEDGWICK )

BE IT FEMEMBERED that on this 15th day of _ March, 1982 , before me, Evelyn L. Pry, a riotary, personally appeared Glenn L. Kocster, Vice President - fluclear of Kansan Gas and Electric Company, Wichita, Kansas, who is personally known to me and who ext cuted the foregoing instrument, and he duly acknowledged the execution of the same for and on behalf of and as the act and deed of said corporation.

I!J WITtJESS WilERI:OP, I have hereunto set my hand and affixed my seal the date and year above written.

.Q.IIi

. . ' i :..,,y/

~ %q

• l ... - .

j

,d* ..*

. velyf L. Pry, ? .tary

\  %. A . J G.

• .aN. ..-UD D leg ?l

.t

- _ ply 'f'qdmission expires on August 15, 1984.

Kansas Gas and Electric Company Comments on Wolf Creek Draft Environmental Statement (Operating License Stage)

Section, Table Page or Figure Comment

- ER(OLS) Chap. ER(OLS) pages in Chapters 1, 8, 9 1, 8, 9 & 11 and 11 were revised extensively in January 1982 to reflect a later inservice date for WCGS, revised plant costs and revised plant ownership.

DES sections which refer to ER(OLS) material in these chapters should be updated.

vii, Summary and The DES (OL) states: " State-listed 4-21, Conclusions, species that would be adversely af-5-14, 4.3.5, 5.6 fected by severe, drought induced 5-15 low-flows in the Neosho River in-clude the Neosho madtom, blue sucker, and warty-backed mussel, if present" (page vii); and " Reductions of riffle habitat during low-flow con-ditions would adversely affect pop-ulation of the small Neosho madtom" (page 5-35).

The FES(CP) states that "...while there is a reduction of flow during some portions of the period-of-record drought, there would have been no change in the down-river flow during the worst part of the drought because the water surface in the John Redmond Reservoir, natur-ally, would have been below the con-servation level. In this case, water is released downstream only i

for the previous water rights and for water quality purposes which are the same with or without the presence of Wolf Creek Generating Station" (pages 5-2 and 5-3, FES-CP).

i The DES (OL) should be modified to be consistent with this conclusion from the FES(CP).

The DES (OL) also states "...the pre-sence of the warty-back mussel in the Neosho River immediately down-I stream from the John Redmond dam

Comments on Wolf Creek Draft (cont'd)

Section, Table Page or Figure Comment is not established. However, if present, this species would also be adversely affected by decreased available habitat and sedimentation during low-flow conditions" (page 5-15); and "The 1975-1979 benthic survey data prepared for the appli-cant include organisms reported as

" unidentified" or " immature" union-ids, some of which may have been warty-backed mussels" (page 4-21).

The Applicants feel it is extremely unlikely that the " unidentified" and

" immature" unionids collected during surveys were warty-backed mussels due to the fact that additional surveys haven't collected any identifiable warty-backed mussels.

The presence of the warty-backed mussel in the Neosho River down-stream (e.g. Neosho Falls) of WCGS has been verified by others. How-ever, the Applicants feel that despite this fact, adverse effects during low-flow conditions from all causes would be minimized by the preference of this species for mud bottoms in pool areas and oxbows (Murray and Leonard, 1962). Due to their relative depth, these habitat types are affected to a lesser degree by low flows than are riffles.

REFERENCE Murray, H. D. and A. B. Leonard.

1962. Handbook of Unionid Mussels in Kansas. Univ. of Kan. Mus.

Natl. Hist. Misc. Publ. No. 28.

pp 184.

1-1 1.1 KEPCo's six percent ownership in 2-4 2.4 WCGS is equal to 69 MW.

)

Comments on Wolf Creek Draft (cont'd)

Section, Table Page or Figure Comment 2-1 2.1 Suggest the second sentence in the last paragraph on this page be changed to read: "Although KEPCo has complied with the financial aspects of owner-ship in WCGS, KEPCo's system relia-bility is largely dependent upon the resources of other utilities due to the integrated nature of the Cooper-ative's load. Therefore, KEPCo will not be analyzed separately."

2-2 2.2 Applicants' estimate for decommission-6-4 6.4.2.1 ing WCGS is $42 million in 1978 dollars [See ER(OLS ) page 5.8-3] .

2-4 2.4 Suggest the second sentence in the first paragraph of this section be changed to read: "KEPCo will not be analyzed separately since KEPCo's system reliability is largely dependent upon the resources of other utilities due to the integrated nature of the Cooperative's load."

4-2 4.2.1 Item 5. The Emergency Operations Facility (EOF) - Simulator Complex has been renamed the Education Center.

4-7 4.2.6.1 The DES states that 100 percent sulfuric acid will be added to the circulating water to control scaling.

The Applicants are planning to use 66*Be H S0 [ER(OLS) Section 3.6.2.1, page 3.0-2,J.

l 4-14 4.3.1.1 As of March 5, 1982, the cooling lake water level was 1080.4 ft. MS L .

5-12 5.5.2.1 The makeup water screenhouse fish impingement study will be submitted to the NRC by March 19, 1982.

I l _ _

CommentsonbolfCreekDraft(cont'd)

Section, Table Page or Figure Comment 5-2 5.3.1.1 The DES (OL) Section 5.3.1.1 alludes to the maximum pumping rate for the makeup water to the cooling lake as 120 cfs (page 5-2). However, the Applicants have obtained water permits from the Department of Agriculture allowing a maximum pumping rate of 170 cfs, which includes water from the natural flow of the river.

Ad'ditionally, the Applicants have obtained water contract 76-2 for water from John Redmond Reservoir storage (Kansas Water Resources Board) which authorizes withdrawal of 120 cfs or as mutus11y agreed. To date, agree-ment between Kansas Water Resources Board and the Applicants has been reached for a maximum withdrawal rate of 140 cfs. This value represents a maxiinum daily rate. However, the amount of water pumped is not to exceed a running average rate of 41 cfs per day. The running average rate is to be calculated on a quarterly basis.

5-13 5.5.2.2 Copper should not be listed as a corrosion product to be discharged to the cooling lake. DES (OL) 4.7 states that copper releases are expected to be negligible.

5-13 5.5.2.2 In DES (OL) Section 5.5.2.2, the staff concludes that there could be significant mortality of aquatic biota in the discharge area due to chlorination of the circulating water. This determination appears to have been based on two factors.

The first factor is the planned treatment schedule of three one-half hour treatments per day which will result in total residual chlorine (TRC) levels during those periods of 0.68 to 1.08 mg/1. The second fac-tor for is conclusion is the reference of 0.01 mg/l TRC which was stated to be unsafe for many aquatic organisms (U.S. EPA., 1976).

Comments on Wolf Creek Draft (cont'd)

Section, "able Page or Figure Comment The Applicant feels the extent of chlorine effects have been over-stated by the staff. This position is supported by the following infor-mation. The value cited, 0.01 mg/l TRC, is based on continuous dosing (no criteria for intermittent exposure are given by the reference). The value is also conservative since it is based on very sensitive species and assumes that the predominant residual in the effluent is free chlorine (Edison Electric Institute, 1977). Baseline monitoring data collected in accord-ance with our preoperational environ-mental program as outlined in ER(OLS)

Table 6.1-3 indicates that makeup /

cooling lake water contains relatively high concentrations of ammonia and other nitrogenous compounds. These compounds readily combine with chlorine to form combined-residual chlorine [ER(CPS )

Section 3.6.3 and ER(OLS) RQ 291.5]

which will be the predominant resi-dual in the circulating water. These forms of chlorine have been shown to be less toxic than free chlorine (Ward-1976, Heath-1977).

Additionally, it has been proven that fish can detect and avoid both sub-lethal and lethal chlorine con-centrations, even at low tempera-tures (Cherry et al, 1979). Finally, the affected area of the cooling lake has been conservatively esti-mated to be forty acres [ER(OLS)

Section 5.1.3.2.1.6, page 5.1-14]

and exclusions of fish from this area, if it occurs, would not constitute a significant impact on resident fish

, populations.

1 REFERENCES Cherry, D. S., S. R. Larrich, J. D.

Giattina, K. C. Dickson and I.

Cairus, Jr. 1979. The avoidance responses of the common shiner to Comments on Wolf Creek Draft (cont'd)

Section, Table Page or Figure Comment total and combined residual chlorine in thermally influenced discharges.

in: Energy and Environmental Stress In Aquatic Systems. Edited by Thorp and Whitfield. Dept. of Energy Conference 771114. 1979.

Edison Electric Institute. 1977.

Analysis of U.S. Environmental Pro-tection Agency chlorine and tempera-ture quality criteria for water.

Volumes I and II.

Heath, A. G. 1977. Toxicity of intermittent chlorination to fresh-water fish: influence of temperature and chlorine forms. in: Indiana and Michigan Power Co Report on Accept-able Levels of Chlorine Discharge.

Quality Criteria for Water. 1976.

U.S. Environmental Protection Agency, Washington, D.C.

Ward, R. W., R. D. Griffin, G. M.

DeGraeve and R. A. Stone. 1976.

Disinfection efficiency in residual toxicity of several wastewater dis-infectants. Vol. 1. Grandville, Michigan USEPA Ecological Research Series. EPA-600/2-76-156.

5-18 5.8 The operating staff is now estimated to be 325 persons including guard

[ER(OLS) Section 8.1.2.1].

5-44 5.9.4.4(2) A KG&E survey conducted in 1980 of the population within the LPZ deter-mined that there were less than 70 persons. Also, the 1980 Census population of Emporia was 25,287.

5-62 5.9.4.5(6) Replacement power for Wolf Creek is estimated to be primarily from coal-fired generation by the NRC. KG&E's replacement fuels are gas and oil

[ER(OLS) page 1.3-3]. KCPL would utilize a fuel mixture which is primarily coal but does also use gas and oil.

Comments on Wolf Creek Draft (cont'd)

Section, Table Page or Figure Comment C-7 Table C-3 The liquid effluent source terms of Table C-3 of the DES (OL) do not closely coincide with the liquid effluent source terms of ER(OLS) Table 5.2-2 (updated in Rev. 3). Table C-3 does not appear to reflect the changes made in the recycle evaporator condensate demineralizer to reduce the cesium activities by using a mixed bed resin versus an anion resin only.

Recognition of these changes would reduce cesium levels by about one half.

i l

l l

I l

l t

I

- --