ML20052E014

Forwards Comments by Oh Dept of Natural Resources Re Des

ML20052E014
Person / Time
Site:	Perry
Issue date:	05/03/1982
From:	Hubbell R OHIO, STATE OF
To:	Stefano J Office of Nuclear Reactor Regulation
References
NUDOCS 8205070390
Download: ML20052E014 (3)

Text

.

\

O7 \ \

GJ Olio Jeoarmen of Na ura hsources OFFICE OF OUTDOOR RECREATION SERVICES Fountain Square Columbus. Oruo 43224 - (614) 265-6395

/p May 3, 1982 @ NECayyg 4 y Mr. John J. Stefano ?e Division of Licensing &

Office of Nuclear Reactor Regulation S U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Re: Draf t Environmental Statement - Operation Licensing Stage Perry Nuclear Power Plant, Units 1 and 2, Ohio (Docket Numbers 50-440 and 50-441)

Dear Mr. Stefano:

The Ohio Department of Natural Resources has completed a review of the above-referenced document. The attached comments were generated by an interdisciplinary review process conducted and coordinated by the Office of Outdoor Recreation Services. Should any question arise, please contact me or John Rupert of the Environmental Review Section of this office.

We appreciate the opportunity to provide these comments.

Si rely, c.-

Ro er D. Hub 11, Chief Office of Outdoor Recreation Services i

RDH/dlw Attachment i

cc: Ohio State Clearinghouse (SAI #36-472-0003)

Goos fJ) . Tok^ Ste&se 8205070390 020503 4* I PDR ADOCK 05000 D

JAMES A HHODES. Governor e ROBERT W TEATER. Duector e ROGER D. HUBBELL, Chief 4

\

O7 \ \

GJ Olio Deoarmerrof \aua hsources fountmn Square Columbus Orno 43224 - (614 e65 6886 May 3. 1982 COMMENTS ON DRAFT ENVIRONMENTAL STATEMENT OPERATING LICENSE STAGE PERRY NUCLEAR POWER PLANT, UNITS 1 AND 2 (Cleveland Electric Illuminating Company, U.S. Nuclear Regulatory Commission, March,1982)

The Perry Nuclear Power Plant (PNPP) Draft Environmental Statement -

Operating License Stage (DES-OL) addresses issues involved with the startup and operation of Units 1 and 2 of the plant. Issues raised earlier, evaluated in the Final Environmental Statement - Construction Permit Stage (FES-CP) are not readdressed in this document.

Many of the concerns of the Department of Natural Resources have been addressed both in FES-CP and through the certification procedure for the plant by the Ohio Power Siting Commission (0PSC, now the Ohio Power Siting Board). The Department, represented on the Commission and its technical staff, provided input into the assessment of the application, which resulted in the " Secretary's Report of Investigation and Recommended Findings" for the Commission. This report provided a basis, along with .

other documents, for the certification of the plant.

The DES-OL adequately addresses most of the impacts associated with the startup and operation of the PNPP. However, certain aspects of concern to this Department, need further comment.

The Department is in complete agreement with-the planned use of the closed-cycle cooling system instead of the once-through system as originally proposed for the PNPP. This system will reduce water consumption, thermal pollution and fish impingement and entrainment. This approach utilizes best available technology and is the preferred choice for such a plant.

The locations of the intake and discharge structures are also greatly important in reducing impacts. Sections 4.2.4.1 and 4.2.4.2 state that the intake and discharge structures will be approximately 777m and 503m offshore, respectively, in 6.4m and 5.8m of water. Section 4.3.3 describes the placement of underwater instrument towers in the vicinity of the intake JAMES A. RHODES Governor

• ROBERT W. TEATER. Derector

and discharge structures at 1070m and 760m offshore. It is unclear as c to whether these towers were not necessarily "in the vicinity" of the structures, or whether the placement of the structures were changed during design, or whether some calculation or typographic error is present. This should be clarified. s

.i Section 4.P. 6 descr.ibes the cleaning of the reactor flow passages, piping and equipment with a number of phosphate' based compounds. It

, is stated that these cleaning products will be " neutralized" with lime and that the supernate will be discharged to Lake Erie. This solution will contain about 50% more~ phosphate than the atobient lake water.

. is made in thE; Although this proposal document regarding the fate seems of thereasonable, lime-phosphatenosmeiition,ludoe. ~It is our ~ s understanding that the sludge will be placed upland in'an on-site sludge lagoon'. The document needs to clarify the final deposition of this material. -

This sludge should not ultimately end up in the lake.

Also in Section 4.2.6, the DES-OL states that 8300kg/ day of 93%

sulfuric acid will be added to the closed-cycle ~ cooling system to prevent formation of scale on the condenser tubes. This appears to be a~1arge amount of acid. It is not stated if all of this amount will be added to the secondary system, or just a, portion of it. The FES-0L should identify the necessity for such quantities of the sulfuric acid as well as to which sub-systems it will be added. Furthemore, the FES-OL should better quantify the pH of the cooling water that will to discharged to Lake Erie. Table 4.2 only specifies the limits of the NPDES permit, expected to be issued for the discharge effluent, and not what is actually expected. This should '

be stated. ,

In summary, we feel that the operation of the PNPP poses no significant dVoidable impacts to resources of concer6 to this Department. We concur

with the Summary and Conclusions as presented in the DES-0P. ~

-^

f g

^

' 5

~- -

k M. 6

%  % ~

K

, s.

. \

- i

~

s j , *% , '* ,

v5 4 % .*

r .

4 h

e '

w.

( I 1r d..