ML20054J754

Final Environmental Statement Related to the Operation of Wolf Creek Generating Station,Unit 1.Docket No. Stn 50-482. (Kansas Gas and Electric Company,Et Al.)

ML20054J754
Person / Time
Site:	Wolf Creek
Issue date:	06/30/1982
From:	Office of Nuclear Reactor Regulation
To:
References
NUREG-0878, NUREG-0878-01, NUREG-878, NUREG-878-1, NUDOCS 8206290526
Download: ML20054J754 (155)

Text

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NUREG-0878 Final Environmental Statement l l related to the operation of I Wolf Creek Generating Station, i Unit No.1 i Docket No. STN 50-482 Kansas Gas and Electric Company, et al.

U.S. Nuclear Regulatory Commission Office of Nuclear Reactor Regulation June 1982 p

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1 NUREG-0878 Final Environmental Statement related to the operation of ,

Wolf Creek Generating Station,  !

Unit No.1 i Docket No. STN 50-482 Kansas Gas and Electric Company, et al.

U.S. Nuclear Regulatory Commission Office of Nuclear Reactor Regulation June 1982

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ABSTRACT

! This final environmental statement contains the second assessment of the enviro 6 mental impact associated with operation of Wolf Creek Generating Station Unit 1 pursuant to the National Environmental Policy Act of 1969 (NEPA) and 10 CFR Part 51, as amended, of the NRC's regulations. This statement examines:

the affected environment, environmental consequences and mitigating actions, and environmental and economic benefits and costs. Land use and terrestrial-and aquatic-ecological impacts will be small. Air quality impacts will also be small. However, steam fog from the station's cooling lake has the potential for reducing visibility over nearby roads and bridges. A fog-monitoring program for roads and bridges near the lake has been recommended. Impacts to historic and prehistoric sites will be negligible. Chemical discharges to the Neosho River are expected to have no appreciable impacts on water quality under normal conditions and will be required to meet conditions of the station's NPDES permit. The effects of routine operations, energy transmission, and periodic maintenance of rights-of-way and transmission line facilities should not jeopardize any populations of endangered or threatened species. No signif-icant impacts are anticipated from normal operational releases of radioactivity.

The risk associated with accidental radiation exposure is very low. The net socioeconomic effects of the project will be beneficial. The action called for is the issuance of an operating license for the Wolf Creek Generating Station Unit 1.

Further information may be obtained from:

Mr. Jon Hopkins, Licensing Project Manager Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, DC 20555 301/492-7144 l

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SUMMARY

AND CONCLUSIONS This Final Environmental Statement was prepared by the U.S. Nuclear Regulatory Commission, Office of Nuclear Reactor Regulation (the staff).

1. This action is administrative.

2. The proposed action is the issuance of an operating license to the Kansas Gas and Electric Company (KG&E) for the startup and operation of the Wolf Creek Generating Station Unit 1 (WCGS), located in Coffey County, about 85 km (53 mi)* south of Topeka, Kansas. KG&E is lead applicant and agent for itself and two co-owners--Kansas City Power and Light Co. (KCPL) and Kansas Electric Power Cooperative, Inc. (KEPCo)--and would operate the station.

The facility will employ one pressurized-water reactor to produce 3425 megawatts thermal (MWt). A steam turbine generator will use this heat to provide a nominal net electrical output of 1150 megawatts (MWe).

The maximum design thermal output is 3579 MWt. The exhaust steam will be cooled by water taken from a cooling lake formed by one main dam across Wo1f Creek and five perimeter saddle dams. The makeup water for the cool-ing lake will be drawn from the Neosho River immediately downstream from the John Redmond Reservoir. Blowdown water from the cooling lake will flow through the lower Wolf Creek stream bed and on to the Neosho River.

3. The information in this statement represents the second assessment of the environmental impact associated with WCGS pursuant to the guidelines of the National Environmental Policy Act of 1969 (NEPA) and 10 CFR Part 51 of the Commission's Regulations. After receiving an application in April 1974 to construct this station, the staff of tre Atomic Energy Commission (now Nuclear Regulatory Commission) carried out a review of impacts that would occur during its construction and operation. That evaluation was issued as a Final Environmental Statement (construction phase) in October 1975. After this environmental review, a safety review, an evaluation by the Advisory Committee on Reactor Safeguards, and public hearings in Kansas City, Missouri, between January 1976 and May 1977, the U.S. NRC issued construction permit No. CPPR-147 in May 1977 for the construction of WCGS Unit 1. As of September 1981, the construction of Unit 1 was about 75% complete. The staff estimates a fuel-loading date of June 1984.

In February 1980 the applicant applied for an operating license for the unit and submitted the required safety and environmental reports in support of the application. .

• Throughout the text of this document most values are presented in both metric and English units. For the most part, measurements and calculafions were originally made in English units and subsequently converted to metric. The number of significant figures given in a metric conversion is not meant to imply greater or lesser accuracy than that implied in the original English value.

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4. The staff has reviewed the activities associated with the proposed opera-tion of the station and the potential impacts, both beneficial and adverse, which are summarized as follows:

a. Commitment of about 2100 ha (5300 acres) of land during the life of the station has been necessary, including 2060 ha (5090 acres) for the station's cooling lake (Sec. 5.2).

b. All of the water used for operating the station will come from the Neosho River and the Wolf Creek drainage basin upstream of the dam.

The average consumptive use (evaporar.~Jn and seepage) will be 1.5 m3 /s (54 cfs) which is about 3% of the average regulated flow in the Neosho River; therefore no significant water-use impacts are expected (Sec. 5.3.1).

c. Thermal and chemical discharges to the Neosho River are expected to meet the limitations in the station's NPDES permit and are also expected to have insignificant impact on the quality of receiving water under normal operating conditions (Sec. 5.3.2).

d. The effect of seepage from the cooling lake and lime sludge pond on groundwater quality is expected to be insignificant (Sec. 5.3.2).

e. Construction of the station will not have significant adverse flood effects either upstream or downstream of the Wolf Creek cooling lake dam. Construction of the station had already begun before the time that Executive Order 11988, Flood Plain Management, was signed in May 1977. Therefore, the consideration of alternatives to the cooling lake is neither required or practicable (Sec. 5.3.3).

f. Operation of the cooling lake will involve occasional formation of grcund fog and icing; however, the impacts are expected to be negli-gible. A fog-monitoring program for roads and bridges near the lake has been recommended. Air quality impacts from plant emissions and dust will be very small (Sec. 5.4).

g. The potential for impacts on the terrestrial ecosystem resulting from operation of the station and electrical transmission lines has been examined and judged to be of minor consequence.

h. The impacts of plant operation on aquatic environments of the John Redmond Reservoir - Neosho River system will be negligible during periods of normal and above-normal hydrologic conditions in the upstream watershed. However, should a severe and prolonged drought occur, the withdrawal of cooling-lake makeup water from the Redmond dam tailwaters area would contribute to a marked drawdown of water in the reservoir and reduced streamflow in the river, thus severely depleting available aquatic habit and adversely affecting resident biota (Sec. 5.5.2.1).

i. Some of the operational effects on aquatic organisms in the cooling lake will be locally severe. For example, periodically high concen-trations of total residual chlorine in the vicinity of the cooling Wolf Creek FES vi

water discharge outlet is expected to cause appreciable mortality among aquatic organisms, especially during periods when temperatures in the area are insufficient to cause fish and other motile species to avoid the area. Cold shock effects on fish due to reactor shut-down could cause significant mortality. Also, impingement and/or entrainment impacts on aquatic biota are expected to be significant since the approach velocity of water flows to the facility are relatively high (Sec. 5.5.2.2).

j. Discharge from the cooling lake (blowdown) to Wolf Creek is expected to influence the composition of aquatic communities immediately downstream from the discharge outlet, but aquatic biota of the Wolf Creek - Neosho River confluence will not be adversely affected by the discharge (Sec. 5.5.2.3).

k. None of the federally listed species of endangered or threatened status are expected to be jeopardized by WCGS operation. State-listed species that would be adversely affected by severe, drought-induced low-flows in the Neosho River include the Neosho madtom, blue sucker, and warty-backed mussel, if present (Sec. 5.6).

1. Operation of the station will not result in any significant impact on historic or archeological sites in the area (Sec. 5.7).

! m. The socioeconomic impacts of the station's operation will be small in adverse effects with the benefits of increased employment being moderate and the increase in tax revenues being large (Sec. 5.8).

, n. No measurable radiological impacts to man or biota are expected to result from routine operation of the station (Sec. 5.9.3).

o. The staff concludes that the risk to nuclear plant workers from station operation is comparable to the risks associated with other occupations (Sec. 5.9.3).

p. The risk associated with radiation exposure due to postulated accidents is very low (Sec. 5.9.4).

5. The draft version of this final environmental statement was made available to the agencies and organizations specified in Section 8 and to the public.

6. On the basis of the analyses and evaluations set forth in this statement, and after weighing the environmental, economic, technical, and other

' benefits against environmental and economic costs, it is concluded by the staff (Sec. 6.1) that the action called for under NEPA and 10 CFR Part 51 is the issuance of an operating license for Wolf Creek Generating Station Unit 1, subject to the following conditions for the protection of the environment:

a. Before engaging in additional construction or operational activities that may result in a significant adverse environmental impact that was not evaluated or that is significantly greater than that evaluated Wolf Creek FES vii

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f in this statement, the applicant shall provide written notification of such activities to the Director of the Office of Nuclear Reactor Regulation and shall receive written approval from that office before j proceeding with such activities.

b. The applicant shall carry out the environmental monitoring programs l' outlined in this statement, as modified and approved by the staff and implemented in the Environmental Protection Plan and the Radiological Effluent Technical-Specifications incorporated in the i operating license for Wolf Creek Generating Station Unit 1.

l c. If adverse environmental effects or evidence of irreversible' environ-j mental damage is detected during the operating life of the station, i

i the applicant shall provide the staff with an analysis of the problem ..

and a proposed course of action to alleviate it.

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j CONTENTS Pagg I iii ABSTRACT . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

SUMMARY

AND CONCLUSIONS ........................ v xii 1 . LIST OF FIGURES ............................ xiii LIST OF TABLES . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

FOREWORD . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . xv i 1 INTRODUCTION ........................... 1-1 1

' l.1 Administrative History . . . . . . . . . . . . . . . . . . . . 1-1 1.2 Permits and Licenses . . . . . . . . . . . . . . . . . . . . . 1-2 l

1' 2 PURPOSE AND NEED FOR.THE ACTION . . . . . . . . . . . . . . . . . . 2-1 i

3 ALTERNATIVES TO THE PP.0 POSED ACTION . . . . . . .......... 3-1 .

4 PROJECT DESCRIPTION AND AFFECTED ENVIRONMENT ........... 4-1 4.1 Resume . . . . . . . . . . . . . . . . . . . . . . . . . . . .

4-1 4.2 Facility Description . .................... 4- 1.

i 4.2.1 External Appearance and Station Layout ........ 4-1 4.2.2 Land Use ....................... 4-2 4.2.3 Water Use . . . . . . . . . . . . . . . . . . . . . . .

4-4 4.2.4 Cooling System .................... 4-4 j 4-5 4.2.5 Radioactive-Waste-Management Systems ......... 4-6 4.2.6 Nonradioactive-Waste-Management System ........

4-10 i 4.2.7 Power-Transmission Systems ..............

4.3 Project-Related Environmental Descriptions . . . . . . . . . . 4-13 l

4.3.1 Hydrology and Water Use . . . . . . . . . . . . . . . . 4-13

! 4-17 4.3.2 Water Quality . . . . . . . . . . . . . . . . . . . . .

4-18 4.3.3 Climatology and Air Quality . . . . . . . . . . . . . .

4-18 4.3.4 Ecology . . . . . . . . . . . . . . . . . . . . . . . .

4-21 4.3.5 Endangered and Threatened Species . . . . . . . . . . . 4-22 4.3.6 Historic and Archeological Sites ...........

4.3.7 Community Characteristics . . . . . . . . . . . . . . . 4-23 j

4-23 References . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

5-1 5 ENVIRONMENTAL CONSEQUENCES AND MITIGATING ACTIONS . . . . . . . . .

5-1 5.1 Resums . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5-2 5.2 Land Use . . . . . . . . . . . . . . . . . . . . . . . . . . .

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CONTENTS (Continued)

Page 5.3 Water ... . . . ........ . . ... . ..... . . 5-2 5.3.1 Use . . ... .................... . 5-2 5.3.2 Quality . .. ............. . .. ... . . 5-4 5.3.3 Floodplain Aspects ......... . . . .. . . . 5-5 5.4 Air Quality . .... ................... . 5-6 5.4.1 Fog and Ice . ....... . .. . ...... .. . . 5-6 5.4.2 Other Emissions . ..... . .. .. . .. . .. . . 5-9 5.4.3 Atmospheric Monitoring . . .. . ... . .... . . . 5-9 5.5 Ecology . .. . .. .................... . 5-9 5.5.1 Terrestrial . . . . . .. .. . . .. . ... .. . . 5-9 5.5.2 Aquatic . . ..... ............... . . 5-11

5. 6 Endangered and Threatened Species . . . . .. . .. . . . . 5-15 5.7 Historic and Archeological Sites . . . . . . . . .. . . . 5-18 1 5.8 Socioeconomics . . . . . . . . . . . . . . . . . . . . . . . . 5-18 i 5.9 Radiological Impacts . ..... . . . . . .. . . .. . . 5-19 )

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-j 5.9.1 Regulatory Requirements . . . . . . . . . . . . . . . . 5-19 1 5.9.2 Operational Overview ............... . . 5-20 1 5.9.3 Radiological Impacts from Routine Operations . .. . . 5-23 l 5.9.4 Environmental Impact of Postulated Accidents . .. . . 5-36 1

5.10 Uranium Fuel Cycle .... ... . . . . .. . . . .. . . . 5-67 's 5.11 Decommissionirig . . . . . . . . . . . . ... ... . . . . . 5-70 5.12 Emergency Planning Impacts ... . . . . .. . .. . .. . .

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References . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5-70 \

6 EVALUATION OF THE PROPOSED ACTION . .... . . . . . . . . . . . 11 6.1 Unavoidable Adverse Environmental Effects .. . . . . . . . . 6- 1 6.2 Irreversible and Irretrievable Commitments of Resources . . . 6 .'

6.3 Relationship Between Local Short-Term Uses of Man's Environment and the Maintenance and Enhancement of Long-Term Productivity . .... . . . . . . . . . . . . . . . 6-1 6.4 Benefit-Cost Summary . . . . . . . . . . . ... .. . . . . 6-4 6.4.1 Benefits . . . ... . . . . . . .. . .. . . . . . 6-4 6.4.2 Costs . . . . . . ..... . . . . . . . .

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6.4.3 Conclusions . . . . . . . . . . . . . . . . . . . . . . 6- 5 y Wolf Creek FES x m__ _ __

CONTENTS (Continued)

Page 7 LIST OF CONTRIBUTORS . . ....... . . . . . . .. . . . . 7-1 8 LIST OF AGENCIES AND ORGANIZATIONS REQUESTED TO COMMENT ON THE DRAFT ENVIRONMENTAL STATEMENT . ...... . ... . .. . . . 8-1 APPENDIX A RESPONSES TO COMMENTS ON THE DRhFT ENVIRONMENTAL STATEMENT - OPERATING LICENSE STAGE, WOLF CREEK GENERATING STATION UNIT 1 . . . . ... . . A-1 APPENDIX B COMMENTS ON THE DRAFT ENVIRONMENTAL STATEMENT - OPERATING LICENSE STAGE, WOLF CREEK GENERATING STATION UNIT 1 . .. . B-1 APPENDIX C EXAMPLES OF SITE-SPECIFIC DOSE-ASSESSMENT CALCULATIONS . . . C-1 APPENDIX D NEPA POPULATION-DOSE ASSESSMENT . . . . . . .. . . . . D-1 APPENDIX E REBASELINING OF THE RSS RESULTS FOR PWRS . . . . . . . E-1

. . . . . . ... . F-1 APPENDIX F CONSEQUENCE MODELING CONSIDERATIONS APPENDIX G IMPACTS OF THE URANIUM FUEL CYCLE .. . . . . . . . . G-1 APPENDIX H LETTER FROM U.S. DEPARTMENT OF THE INTERIOR, FISH AND WILDLIFE SERVICE, CONCERNING THREATENED AND ENDANGERED SPECIES IN THE VICINITY OF THE WOLF CREEK GENERATING STATION . . .. . . . . . . . H-1 APPENDIX I HISTORIC AND ARCHE 0 LOGICAL SITES . . . . .. . . . 1-1 Wolf Creek FES xi

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l LIST OF FIGURES Figure Page 4.1 Plant Site Features 4.2

. .... ... . . .. ... .... . 4-3 Major Existing and Proposed Energy Transmission Facilities Integrated with the Wolf Creek Generating Station . .... . . . 4-11 4.3 Local Right-of-Way Alignments of Transmission Lines Integrated with the Wolf Creek Generating Station ...... .. 4-12 5.1 Floodprone Area before Construction of WCGS and Facilities . . . .

5. 2 5-7 Floodprone Area before and after Construction of WCGS and Facilities . . . . .. ... . ... . .... . ... .. . 5-8

5. 3 Potentially Meaningful Exposure Pathways to Individuals .. . . .

5.4 5-22 Schematic Dutline of Atmospheric Pathway Consequences Model ... 5-53

5. 5 Probability Distributions of Individual Dose Impacts . .

5.6 .... 5-55 Probability Distributions of PopJlation Exposures .. ... . .. 5-56 5.7 Probability Distributions of Cancer Fatalities . . . . .

5.8 ... . 5-57 Probability Distributions of Mitigation Measures Cost .... .. 5-61 F.1 Probability Distribution of Early Fatality for no Evacuation . . . F-5 Wolf Creek FES xii

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LIST OF TABLES Page Table Prime Farmland Crossed by Transmission Lines . . . . . . . . . . . 4-4 4.1 4.2 Concentration of Various Chemicals during Station Operation in John Redmond Reservoir, Cooling Lake, and Circulating Water Discharge under Normal and Drought Conditions .......... 4-8 Estimated Wol f Creek Average Monthly Streamflows . . . . . . . . . 4-13 4.3 Peak Flood Flows of Wolf Creek . . 4-14 4.4 .... . ... . .. .. . .

5.1 Wolf Creek Generating Station Ad Valorem Tax Estimates,

. ..... . ... . 5-16 1985-1989 ................

5.2 Estimated Ad Valorem Taxes to Be Paid to Counties through which WCGS Transmission Lines Pass . . . . . . . . . . . . . . . . 5-17 5-25 5.3 Incidence of Job-Related Fatalities .... . .... . .... .

5.4 (Summary Table S-4) Environmental Impact of Transportation of Fuel and Waste to and from One Light-Water-Cooled

... . .... . 5-28 Nuclear Power Reactor ............

5.5 Preoperational Radiological Environmental Monitoring Program Summary ......................... 5-33 5.6 Activity of Radionuclides in a Wolf Creek Unit 1 Reactor Core

. ... . .. ... .... . 5-39 at 3565 MWt ... .......

5.7 Approximate 2-Hour Radiation Doses from Design Basis Accidents at Exclusion Area Boundary . . . . ..... . . ... . .. . . 5-48 5.8 Summary of Atmospheric Releases in Hypothetical Accident Sequences in a PWR (Rebaselined) . .... ...... . . ... 5-51 Summary of Environmental Impacts and Probabilities . . . . . . 5-58 5.9 5.10 Average Va!ues of Environmental Risks due to Accidents 5-64 per Reactor-Year . . ........ . ...... .... .

5-68 5.11 (Table S.3) Table of Uranium Fuel Cycle Environmental Data . . . .

Benefit-Cost Summary for WCGS . . . . . ......... . 6-2 6.1 .

C.1 Calculated Releases of Radioactive Materials in Gaseous C-3 Effluents from Wolf Creek Unit 1 . . . . . . .... . .... .

C.2 Locations for Maximum Individual Dose Calculations and C-4 Atmospheric Dispersion Parameters .... . ... .. . .... .

C.3 Nearest pathway locations used for maximally exposed individual C-5 dose commitments for the Wolf Creek nuclear station . . ....

C.4 Calculated Release of Radioactive Materials in Liquid Effluents C-7 from Wolf Creek Nuclear Station Unit 1 . . . . . . . . . . .. .

C. 5 Summary of Hydrologic Transport and Dispersion for Liquid C-7 Releases from the Wolf Creek Nuclear Station . . .. . ... . .

C.6 Annual Dose Commitments to a Maximally Exposed Individual near the Wolf Creek Generating Station . . . .. . . .. . . . . . . C-8 Wolf Creek FES xiii

LIST OF TABLES (Continued)

Table Page C. 7 Calculated Appendix I Dose Commitments to a Maximally Exposed Individual and to the Population from Operation of Wolf Creek Nuclear Station . ...... .................. C-9 C.8 Calculated RM-50-2 Dose Commitments to a Maximally Exposed Individual from Operation of the Wolf Creek Generating Station . . C-10 C. 9 Annual Total-Body Population Dose Commitments, Year 2000 . . . . . C-11 E.1 Key to PWR Accident-Sequence Symbols . . . . . . . . . . . . . . . E-4 G.1 Radon Releases from Mining and Milling Operations and Mill Tailings for Each Year of Operation of the Model 1000-MWe LWR . . G-5 G.2 Estimated 100-Year Environmental Dose Commitment for Each Year of Operation of the Model 1000-MWe LWR . . . . . . . . . . . G-6 G.3 Population-Dose Commitments from Unreclaimed Open-Pit Mines for Each_ Year of Operation of the Model 1000-MWe LWR . . . . . . . G-7 G.4 Population-Dose Commitments from Stabilized-Tailings Piles for Each Year of Operation of the Model 1000-MWe LWR . . . . . . . G-7

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FOREWORD This Final Environmental Statement--Operating License Stage was prepared by the U.S. Nuclear Regulatory Commission (NRC), Office of Nuclear Reactor Regula-tion (the staff), in accordance with the Commission's regulation, 10 CFR 51, which implements the requirements of the National Environmental Policy Act of 1969 (NEPA). It reviews the impacts of operation of the Wolf Creek Generating Station, Unit 1. Assessments that are found in this statement augment those described in the Final Environmental Statement - Construction Permit (FES-CP) that was published in October 1975 in support of issuance of a construction permit for Wolf Creek Generating Station, Unit 1.

The information in the various sections of this statement updates the FES-CP in four ways: (1) by evaluating changes in plant design and operation that will result in different environmental effects of operation (including those that would enhance as well as degrade the environment) than those projected during the preconstruction review; (2) by reporting the results of relevant new information that has become available subsequent to issuance of the FES-CP; (3) by factoring into the statement new environmental policies and statutes that have a bearing on the licensing action, and factoring the results of the applicant's preoperational monitoring program into the design of an operational surveillance program and into the development of environmental technical specifications and an environmental protection plan; and (4) by identifying unresolved environmental issues or surveillance needs that are to be resolved by means of license conditions. (No unresolved environmental issues or sur-veillance needs have been identified in this statement for the case of the Wolf Creek Generating Station, Unit 1.)

The staff recognizes the difficulty a reader would encounter in trying to establish the conformance of this review with the requirements of NEPA with only updating information. Therefore, introductory resume in appropriate sections summarize both the extent of updating the FES-CP and the degree to.

which the staff considers the subject to be adequately reviewed.

Copies of this environmental statement are available for inspection at the Commission's Public Document Room, 1717 H Street N.W., Washington, DC, and at the William Allen White Library, Emporia State University, 1200 Commercial St., Emporia, Kansas 66801. Single copies may be obtained by writing to:

Division of Technical Information Document Control Office U.S. Nuclear Regulatory Commission Washington, DC Coad5

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1. INTRODUCTION The proposed action is the issuance of an operating license to the Kansas Gas and Electric Company (KG&E) of Wichita, Kansas, for startup and operation of the Wolf Creek Generating Station (WCGS) Unit 1 in Coffey County, about 85 km (53 mi) south of Topeka, Kansas. KG&E is lead applicant and agent for itself and two co-owners--Kansas City Power and Light Co. (KCPL) and Kansas Llectric Power Cooperative, Inc. (KEPCo)--and would operate the station. KG&E and KCPL each own 47% (540.5 MWe) of WCGS, and KEPCo owns 6% (69 MWe). The sale of 6%

of the station to KEPCo has occurred since issuance of the FES-CP.

.The generating unit consists of one pressurized-water reactor, four steam generators, one steam turbine generator, a heat-dissipation system, and asso-ciated auxiliary facilities and engineered safeguards. Waste heat will be nissipated to a large cooling lake on the site. Makeup water will come from the Neosho River, and blowdown will return to the Neosho River via Wolf Creek, talow the intake for makeup water. The unit is designed to operate at a thermal level of 3425 MWt and to produce a nominal net electrical output of 1150 MWe. The core parameters are expected to support a stretch (design-maximum) thermal level of 3579 MWt and an output of 1185 MWe (ER-OL, Table 3.2-1; FES-CP, Sec. 3.2).*

1.1 ADMINISTRATIVE HISTORY On April 30, 1974, KG&E (the applicant) filed an application with the Atomic Energy Commission, now Nuclear Regulatory Commission (NRC), for a permit to construct the Wolf Creek Generating Station Unit 1. KG&E is lead applicant and sole agent for itself and two co-owners - Kansas City Power and Light Co.

(KCPL) and Kansas Electric Power Cooperative, Inc. (KEPCo. ). Construction permit No. CPPR-147 was issued on May 17, 1977, following reviews by the NRC regulatory staff and its Advisory Committee on Reactor Safeguards, as well as public hearings before an Atomic Safety and Licensing Board in Kansas City, Missouri, between November 11, 1975, and May 11, 1977. The conclusions result-ing from the staff's environmental review were issued as a Final Environmental Statement - Construction Phase (FES-CP) in October 1975.

On February 19, 1980, the applicant submitted an application, including a Final Safety Analysis Repert (FSAR) and Environmental Report (ER-OL), request-ing issuance of an operating license for Unit 1. These documents were docketed

• " Wolf Creek Generating Station Environmental Report, Kansas Gas and Electric Co., Operating License Stage," Vols. I a,d II, (August 19, 1980). Hereinafter this document is cited in the body of the text as the ER-OL, usually followed by a specific section, page, figure, or table number. The applicant's responses to NRC questions are referred to as ER-OL, RQ (Response to Question). The Final Environmental Statement - Construction Phase, published in October 1975, is referred to as FES-CP.

Wolf Creek FES 1-1

on August 7, 1980, and November 25, 1980, respectively. Operational safety and environmental reviews were then initiated. As of September 1, 1981, construction of Unit 1 was about 75% complete. The staff estimates that the unit will be ready for loading of fuel in June 1984.

1. 2. PERMITS AND LICENSES The applicant has provided in Section 12 of the ER-OL a status listing, as of February 6, 1981, of environmentally related permits, approvals, and licenses required from Federal, State, regional, and local agencies in connection with the proposed project. The staff has reviewed the listing and is not aware of any potential non-NRC licensing difficulties that would significantly delay or preclude the proposed operation of WCGS.

A Water Certification under Section 401 of the Clean Water Act was issued to the applicant by the State on September 2, 1975.

Discharges from station operation are not allowed under the present National Pollutant Discharge Elimination System (NPDES) permit, and prior to beginning operation, the applicant, in accordance with applicable regulations governing the implementation of the NPDES permit program, will request the State to modify the existing permit to address the proposed operational phase discharges.

Wolf Creek FES 1-2 i i

2. PURPOSE OF AND NEED FOR ACTION The Commission has amended 10 CFR 51, " Licensing and Regulatory Policy and Procedures for Envirunmental Protection," effective April 26, 1982, to provide that need for power issues will not be considered in ongoing and future operat-ing license proceedings for nuclear power plants unless a showing of "special circumstances" is made under 10 CFR Section 2.758 or the Commission otherwise so requires (47 FR 12940, March 26, 1982). Need for power issues need not be addressed by operating applicants in environmental reports to the NRC, nor by the staff in environmental impact statements prepared in connection with operating license applications. (See 10 CFR 51.21, 51.23(e), and 51.53(c).)

This policy has been determined by the Commission to be justified even in situ-ations where, because of reduced capacity requirements on the applicant's system, the additional capacity to be provided by the nuclear facility is not needed to meet the applicant's load responsibility. The Commission has taken this action because the issue of need for power is correctly considered rt the construction permit stage of the regulatory review where a finding of insuffi-cient need could factor into denial of issuance of a license. At the operating license review stage, the proposed plant is substantially constructed and a finding of insufficient need would not, in itself, result in denial of the operating license.

Substantial information exists which supports the contention that nuclear plants are lower in operating costs than conventional fossil plants. If conservation, or other factors, lowers anticipated demand, utilities remove generating facilities from service accoraina to their costs of operation, with the most expensive facilities removed first. Thus, a completed nuclear plant would serve to substitute for less economical generating capacity (ibid, see also 46 FR 39440, August 3, 1981).

Accordingly, this environmental statement does not consider "need for power."

Section 6 does, however, consider the savings associated with the operation of the nuclear plant.

Wolf Creek FES 2-1

l

3. ALTERNATIVES TO THE PROPOSED ACTION The Commission has amended its regulations in 10 CFR 51 effective April 26, 1982 to provide the issues related to alternative energy sources will not be considered in ongoing and future operatng license proceedings for nuclear power plants unless a showing of special circumstances is made under 10 CFR 2.758 or the Commission otherwise so requires (47 FR 12940, March 26, 1982). In addition, these issues need not be addressed by operating license applicants in environ-mental reports to the NRC, nor by the staff in environmental impact statements prepared in connection with operating license applications. (See 10 CFR 51.21, 51.23(e), and 51.53(c).)

The Commission has concluded that alternative energy source issues are resolved at the construction permit stage and the CP is granted only after a finding that, on balance, no superior alternative to the proposed nuclear facility exists. In addition, this conclusion is unlikely to change even if an alterna-tive is shown to be marginally environmentally superior in comparison to opera-tion of the nuclear facility because of the economic advantage that operation of the nuclear plant would have over available alternative sources (ibid, see also 46 FR 39440, August 3, 1981). By earlier amendment (46 FR 28630, May 28, 1981), the Commission also stated that alternative sites will not be considered at the operating license stage, except under special circumstances per 10 CFR 2.758.

Accordingly, this environmental statement does not consider alternative energy sources or alternative sites.

Wolf Creek FES 3-1

4. PROJECT DESCRIPTION AND AFFECTED ENVIRONMENT 4.1 RESUME Several changes that have been made in plant operating characteristics and design since the FES-CP was issued are described in this section. The station layout and site boundaries have been changed in minor ways (Sec. 4.2.1);

transmission route changes are discussed (Secs. 4.2.2 and 4.2.7); minor changes have been made in the cooling system, resulting in small changes in the temper-ature of discharge water from what was stated in the FES-CP (Secs. 4.2.4 and 4.2.6.3); changes in the station's gaseous, liquid, and solid radioactive wastes are discussed (Sec. 4.2.5); changes in the nonradioactive-waste-management system are discussed (Sec. 4.2.6); there has been a design change concerning the demineralization regime of the plant (Sec. 4.2.6.1); a lime-sludge pond has been added to receive lime-softener and other wastes (Sec. 4.2.6.1);

wastes from an oily wastes separator are discussed (Sec. 4.2.6.4); updated information is given on chemicals in the Neosho River and Wolf Creek Cooling Lake for normal and drought conditions (Sec. 4.2.6.2); emissions from standby generators and auxiliary boiler are described (Sec. 4.2.6.4). The descriptions of the project-related environment (Sec. 4.3) have been updated and revised, in part to reflect information gained since the FES-CP was issued in 1975.

The surface-water hydrological description of the site has been updated and revised (Sec. 4.3.1); estimates of average monthly flows in Wolf Creek have been generated (Sec. 4.3.1.1); the description of groundwater use has been revised (Sec. 4.3.1.2); new information on water quality is presented (Sec. 4.3.2); the air quality of the site is evaluated (Sec. 4.3.3.2);

discussions of terrestrial and aquatic environments (Sec. 4.3.4) and endangered and threatened species (Sec. 4.3.5) have been revised to integrate results derived from biotic monitoring programs and to update information relative to project construction impacts that have occurred subsequent to issuance of the FES-CP; eight additional archeological sites have been identified (Sec. 4.3.6);

and revised population estimates are discussed (Sec. 4.3.7).

4.2 FACILITY DESCRIPTION 4.2.1 External Appearance and Station Layout The design and layout of WCGS have been changed from that described ir. the FES-CP (Sec. 3.1) by the addition of the following buildings and structures in the immediate power block area (ER-OL, RQ 310.1):

1. An auxiliary warehouse (just east of the shop building),

2. A technical support center (between the administration building and shop building),

3. A security building (south of the administration building),

4. Security diesel generator (immediately north of the northwest corner of the security building), and Wolf Creek FES 4-1

l S. A covered walkway connecting the turbine building, administration build-ing, technical support center, shop building, and security building.

These are low-visibility structures and do not appreciably change the skyline of the station. The Emergency Operation Facility (EOF)--Simulator Complex has been located on the site but 4.5 km (2.8 mi) northwest of the power block area (ER-OL, RQ 310.1). The Visitors Center is located 4.5 km (2.8 mi) northwest of the station at the Emergency Operations Facility complex. The center 2

occupies 71 m (760 ft 2) of display space in the E0F/ Simulator / Visitors Center building (ER-0L, RQ 310.3).

A lime sludge pond of about 9 ha (23 acres), not discussed in the FES-CP, is located north of the switch yard and west of the meteorological tower (see Sec. 4.2.6.1).

The configuration of the site boundary has also been changed from what was described in the FES-CP (Sec. 4.1) in a few minor ways (ER-OL, RQ 290.8).

Figure 4.1 is a plan view of the station, showing the plant site features including those discussed above.

4.2.2 Land Use The FES-CP (Sec. 2.2.2) describes land use about the site. Section 2.1.3 of the ER-OL presents revised information about land use. This area is about 89%

farmland, of which cropland, pasture, and range land are the predominant land-use types. Land use within 8 km (5 mi) of the station is similar to that within 80 km (50 mi) and consists of:

Range land 40% Recreation area 3%

( Crop land 40% Water bodies 3%

l Wood land 9% Other 1%

l Built-up area 5%

l There exist ao trends that would significantly change the land-use composition

! of the area.

Modifications made in the configuration of the site boundary (Sec. 4.2.1) have reduced the total area of the site from the 4250 ha (10,500 acres) stated in the FES-CP (Sec. 4.1) to 3973 ha (9818 acres) (ER-OL, RQ 290.8).

Land-use changes resulting from the transmission line corridors are explained in Section 5.1.2 of the FES-CP. The major difference from that description is that the Wolf Creek-Craig transmission line has been replaced by the Wolf Creek-West Gardner line, which is about 23 km (14 mi) shorter (Sec. 4.2.7).

A minor change occurred on the Wolf Creek-Rose Hill line, which was lengthened from 154 km (95.7 mi) to 157 km (97.6 mi). Table 4.1 lists the prime farmland crossed by transmission lines.

Wolf Creek FES 4-2

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Table 4.1. Prime Farmland Crossed by Transmission Linestl Wolf Creek-Rose Hill Wolf Creek-West Gardner Miles Percent Miles Percent Total Prime Prime Total Prime Prime County Miles Farmland Farmland Miles Farmland Farmland Butler 35 15 43 -- -- --

Greenwood 38 12 32 -- -- --

Coffey 25 19 76 11.9 7 59 Anderson -- -- --

7 6 86 Franklintz -- -- --

24 14 58 Miami -- -- --

10 8 80 Johnson -- -- --

3.5 3.3 94 Total 98 46 47 56.4 38.3 68 t1 Source: Kansas Gas & Electric Company & Kansas City Power & Light Company, Environmental Report Operating License, Wolf Creek Unit No. 1.

12 Partially estimated by the applicant.

NOTE: To convert from miles to kilometers, multiply by 1.6093.

4.2.3 Water Use Estimated consumptive water use (evaporation and seepage from the cooling lake) will be about 1.50 m3 /s (52.8 cfs), essentially the same as indicated in the FES-CP (Fig. 3.2).

4.2.4 Cooling System Only minor changes have been made in the cooling-system design from what was described in the FES-CP (Sec. 3.4). The design circulating-water flow rate has been decreased from 33 am /s to 30 m3 /s (1178 cfs to 1114 cfs), and the service-water flow has been increased from 23m /s to 3 3m /s (78 cfs to 90 cfs)

(ER-OL, Sec. 3.3). Other modifications in the cooling system include minor changes in the intake structure and in the circulating-water discharge structure.

Since issuance of the FES-CP, the dam designed to impound the Wolf Creek Cooling Lake has been completed, and as of the end of May 1981, the lake level was at 323.2 m (1060.5 ft) MSL, with a capacity of 3.16 x 107 m 3 (25,600 acre-ft) (ER-OL, RQ 291.16). Theexpectednormaloperatinglevelfor the lake is 331.3 m (1087 ft) MSL, with a capacity of 13.7 x 107 m (111,280 acre-ft). The applicant predicted that the completion of lake filling Wolf Creek FES 4-4

l to the normal operating level would take 14 months with a pumping rate of 3.4 m3 /s (120 cfs) (average year conditions) and 41 months with a pumping rate of 1.2 m3/s (41 cfs) (worst-drought year conditions) (ER-OL, RQ 291.17).

4.2.5 Radioactive-Waste-Management Systems Under requirements set by Part 50.34a of Title 10 of the Code of Federal Regulations, an application for a permit to construct a nuclear power reactor must include a preliminary design for equipment to keep levels of radioactive materials in effluents to unrestricted areas as low as is reasonably achiev-able (ALARA). The term ALARA takes into account the state of technology and the economics of improvements in relation to benefits to the public health and safety and other societal and socioeconomic considerations and in relation to the utilization of atomic energy in the public interest. Appendix I to 10 CFR Part 50 provides numerical guidance on radiation dose design objectives for light-water cooled nuclear power reactors to meet the requirement that radio-active materials in effluents released to unrestricted areas be kept ALARA.

To comply with the requirements of 10 CFR 50.34a, the applicant provided final designs of radwaste systems and effluent control measures for keeping levels of radioactive materials in effluents ALARA within the requirements of Appen-dix I to 10 CFR Part 50. In addition, the applicant provided an estimate of the quantity of each principal radionuclide expected to be released annually to unrestricted areas in liquid and gaseous effluents produced during normal reactor operations, including anticipated operational occurrences.

The NRC staff's detailed evaluation of the radwaste systems and the capability of these systems to meet the requirements of Appendix I will be presented in Chapter 11 of the staff's Safety Evaluation Report, which was issued in April 1982. The quantities of radioactive material that are now calculated by the NRC staff to be released from the plant during normal operations, including anticipated operational occurrences, are presented in Appendix C of this state-ment, along with examples of the calculated doses to individual members of the public and to the general population, resulting from these effluent quantities.

As part of the operating license for this station, the NRC will require Techni-cal Specifications limiting release rates for radioactive material in liquid and gaseous effluents and requiring routine monitoring and measurement of all principal release points to ensure that the station operates in conformance with the radiation-dose-design objectives of Appendix I.

The staff's detailed evaluation of the solid radwaste system and its capability to accommodate the solid wastes expected during normal operations, including anticipated operational occurrences, are presented in Chapter 11 of the SER.

On the basis of its evaluation and on recent data from operating PWRs, the staff estimates that approximately 560 m3(20,000 f ta) of " wet" solid wastes containing approximately 1500 Ci of radioactivity, mainly the long-lived fission and corrosion products, Cs-134, Cs-137, Co-58, Co-60 and Fe-55, and approximately 34J 3m (12,000 f ta) of " dry" solid wastes containing less than 5 Ci of radioactivity will be shipped offsite annually from Wolf Creek to a licensed burial site. The packaging and shipping of all these wastes will be in conformance with the applicable requirements of 10 CFR Parts 20 and 71 and 49 CFR Parts 170-178.

-Wolf Creek FES 4-5

4.2.6 Nonradioactive-Waste-Management System 4.2.6.1 Chemical All the liquid nonradioactive wastes will be discharged with the station ef fluent into the Wolf Creek Cooling Lake. The nonradioactive-waste discharges were partially estimated prior to construction (FES-CP, Secs. 3.6 and 3.7).

Makeup-Water Treatment Wastes Makeup water for the cooling lake as well as for potable water and deminera-lized water systems will be pumped from the Neosho River from a point immedi-ately downstream of the John Redmond Dam. In a design change from the FES-CP (Sec. 3.6.2), all the makeup water flowing into the cooling lake will not be pretreated. Only that portion [1.1 L/s (0.04 cfs)] of the makeup withdrawn for site use as potable water and as demineralized water will be pretreated for lime softening instead of demineralization as proposed in the FES-CP. The water intended for the demineralized water system [0.9 L/s (0.03 cfs)] will then be demineralized prior to use, and the remainder of the softened water

[0.3 L/s (0.012 cfs)] will be'used as potable water and as backwash water for the carbon and sand filters in the treatment system (ER-0L, Sec. 3.3).

Clarifying and Demineralization Treatment Wastes. Water which is influent to the potable and demineralized water systems will be first chlorinated, then softened with lime and cleansed with ferric sulfate, sand, and carbon filters.

The demineralized water will be stored in a condensate storage tank, where it will be added to the condensate feed. Blowdown from the lime softener will be discharged into the lime sludge pond. The average daily discharge will be about 1100 L (300 gal). The blowdown will contain about 3 wt % suspended solids, most of which will consist of calcium carbonate (ER-OL, Sec. 3.6).

Sulfuric acid and sodium hydroxide will be used to regenerate the deminerali-zers. The effluents from this regeneration will be discharged into the lime sludge pond.

Potable water will be treated with 143 kg/yr (315 lb/yr) sodium hypochlorite (ER-OL, RQ 291.14).

Lime Sludge Pond Wastes. The lime sludge pond will have a storage capacity of 2.2 x 105 m3 (180 acre-ft) (ER-OL, RQ 291.1d) and an area of about 13 ha (31 acres) (ER-OL, Sec. 3.7). The unlined pond will be surrounded by a dike with a 3:1 vertical-to-horizontal slope ratio.

The inflow of soluble chemicals into the pond will consist principally of about 47.3 kg/ day (104 lb/ day) of sodium sulfate and 12.8 kg/ day (28.2 lb/ day) of sulfuric acid. The sulfuric acid is expected by the staff to react with the discharged calcium carbonate and lime in the lime-softening-system blow-down or to be neutralized through reaction with naturally occurring minerals in the sides and bottom of the pond. It is expected that negligible amounts of soluble salts will seep into the ground.

Evaporation and precipitation rates (ER-0L, Tables 2.3-7 and 3.3-4) are such that the pond will be nearly dry most of the time. An analysis by the appli-cant shows that even during the three worst recorded wet years the pond would Wolf Creek FES 4-6

be only about half full (ER-OL, RQ 291.lf). Thus, no discharge from the sludge pond into the cooling lake is expected. At the end of 30 years of operation, the depth of sludge contained in the pond is expected to be less than 30 cm (12 in) (ER-OL, RQ 291.lf), which is less than 20% of the pond volume. The staff has evaluated this analysis and concurs with the appli-cant's conclusions.

Scaling and Biocide Treatment Wastes. A continuous flow of 66 Be sulfuric acid

[28,000 kg (61500 lb) per day] will be added to the circulating water to control scaling. The function of the acid is to convert some of the calcium bicarbo-nate, which is responsible for the scaling, into calcium sulfate, carbon dioxide, and water. Three 30 minute doses [187 kg (411 lb) per dose] of chlorine will be added each day to control biofouling. Chlorine also will be added to the service water in three 30-minute doses [15 kg (33 lb) per dose].

The applicant intends to monitor the free residual chlorine content of the circulating water at the condenser outlet in the turbine building. The chlorine dosage will be varied to maintain the free residual chlorine content at between 0.1 and 0.5 mg/L during dose periods. The staff expects the amount of chlorine per dose needed to maintain this residual to be more in the summer than in the winter because increased production of organic materials is expected to cause the chlorine demand of the water to be greater in the summer than in the winter.

The applicant estimates that the total residual chlorine (i.e., free chlorine plus chloroorganics and chloramines) at the discharge outlet to the cooling lake will be between 0.68 mg/L and 1.08 mg/L (ER-OL, RQ 291.5). The total residual chlorine is expected by the staff to decrease to low levels (0.01 mg/L) away from the point of discharge in the cooling lake. This is due to dilution effects and reactions with oxidizable chemicals in the lake water as the discharged circulating water mixes with the lake water.

Corrosion Products Concentrations of iron (Fe), chromium (Cr) and nickel (Ni) in the circulating water as a result of corrosion of the piping are expected by the staff to be 0.3 pg/L Cr, 0.2 pg/L Ni, and 3.9 pg/L Fe after protective oxide coatings are built up. Copper (Cu) releases are expected to be negligible as there is essentially no copper in the piping (ER-OL, Rev. 3). These values are based on a corrosion rate of 0.025 mm/yr (0.001 in/yr) for carbon steel (ER-OL, Rev. 3, RQ 291.6) and 0.005 mm/yr (0.0002 in/yr) for Type 304 stainless steel (Ref. 1). According to the applicant, initial corrosion rates for carbon steel can be as much as a factor of 20 higher than the above values [ER-OL, Rev. 3, RQ 291.6]. Use of this factor of 20 for both steels present results in initial corrosion-rate concentrations of 6 pg/L Cr, 4 pg/L Ni, and 78 pg/L Fe. In the staff's judgment, these represent very conservative (high) estimates of che initial corrosion rate.

Concentrations of Chemicals The concentrations of various chemicals in the John Redmond Reservoir (at the dam), the Wolf Creek Cooling Lake, and the circulating water discharge to the lake during normal station operation are given in Table 4.2 for both normal and drought conditions. The concentrations of chemicals in the John Redmond

_ _e y . . _ . _ , . _ . _ _

Table 4.2. Concentrations of Various Chemicals during Station Operation in the John Redmond Reservoir, Cooling Lake, and Circulating Water Discharge under Normal and Drought Conditionst  !

Concentration (evt) moraal Conditions Orought Conditions Chemical John Redmond John Seasond Cooling takets Circulating Olscharget' Senervoir18 Cooling Lakets Circulating Discharget' Parameter Reservoir 18 172 125 218 218 C a" 89 172 l

43 31 54 54 l Mg" 22 43 46 34 59 59 ha' 24 46 19 <?9 199 45 '45 HCO's 142 490 125 701 711 50; 89 480 54[<57] 40 70 70[<73]

Cl' 28 54 Active chlorine <0.01 free residual 0 (0.01 <0 01[0.1-0.5] O < 0. 0l[0.1-0. 5 ]

0 -

- [0.51] O -

- 10.69)

Other (as NHa Cl)

3. 4 2.4 4.3 4.3 fe (total)t* 1.7 3. 4 0.20 0.08 0.16 0.16 0 11 0.20 fe (soluble)t*

0. 00'f - 0.0C6 0.0c6 Mils .

0.001 CrT* 0.004 0.011 0 Oly 0 006 0.0 Ai 0. 0 3J f C3 0.09 0.17 0.17[0] 0.13 0.23 0.23[0]

NHa, m 0.22 0.22 0 16 0.28 0.28 h0's 0.11 N0'a 4.1 d.0 8.0[84] 57 10.2 10.2[10 6]

400 882 892[895] 560 1156 1166[1169]

105 72 52 91 91 155 31 72 5-day 000 2.1 4.1 4.1[<4.1] 29 5.1 5.1[<5.1] l 19 37 37[<31] 27 47 47[< 41]

C00

< 7. 5 <8 0 7. 3 < T. 3 pH < 8. 0 7. 5 18 from ER-OL, Sec. 3.6 and 2.4. < followed by a neber means the value is less than ttur neber given.

la The Ca, Mg, ha, HCOs, 50., Cl, 105, and pH entries are from the (R-OL, Table 3.6-1. tar fe (total), NH , 3M0s, NOs, 155, 800s, and C00 the normal values are averages of the 1973-1975 values for the John Redmond Reservoir given in Table 2.4-11 of the (R-0L. The le (soluble) values are averages of the 1976-1978 values for the Neosho Elver given in table 2.4 !! of the (R-0L. The Cr value is the average of et0ht measurements taken in 1973 (Tacle 2.54 2 of the (R-CP). The drought values are ! 40 a normal values. The factor 1.40 is obtanned as the retto of drought / normal values for the entries in Table 3.6-4 of the (R-OL. l

, 50,, CI', and pH values are free the (R-OL, Table 3.6-1. The 105 concentration is given as the se of the con-I 13 The Ca, Ng, ha, HCJ 3 centrations of chesiCals in the cooling lake. lhe hH3 , NO3 , NO3 , 155, 800s, and C00 values are obtained by multiplying the values for the reservoir by the average of the cooling lake / reservoir ratios for Ca, Ng, Na, and Cf. the values 1.94 (normal conditions) and 1.74 (drought conditions) of these ratios are independent of the ion species. The total active chlorine concentration is expected te be below 0.01 a0/ t (ER-OL, Sec. 5.3).

l' Values for most species are taken to be equal to those for the Cooling late plus 10 ppa continuous addition of H2 50. plus corrossen products. for those species af fected by chlorine addition, the bracketed values apply during periods of chlorine addition. The unbracketed values refer to periods when no chlorine is added.

1 8 Concentrations of le and Cr in the cooling lake are obtained by calculating concentrations in the same manner as those for NHa, NO 2 ,

etc., and adding concentrations due to corrosion. The latter were calculated anstasing complete sising in the cooling lake and final corrosion rates after protective ontde coatings are built up. The values for Ni are the contributions from corrosion only.

I Reservoir have been assumed by the staff to also apply to the Neosho River above the confluence with Wolf Creek. The values given represent data col-lected over a longer period of time (1949-1964) (ER-OL, RQ 291.3) than do the data given for the Neosho River in the ER-OL (Table 2.4-11). Also, use of these data permits the estimation of concentrations of chemical species in the cooling lake which are not given in Table 3.6-1 of the ER-0L (see Table 4.2,

.! footnotes t 2, 9 3, 94),

The drought conditions mentioned in Table 4.2 refer to the drought that occurred in 1952-1957 and is estimated to occur once every 50 years (ER-OL, Sec. 3.6.1).

The concentrations given for drought conditions are the maximum values that are expected to occur during the drought.

4.2.6.2 Cooling Lake Blowdown 4

The blowdown discharge from the cooling lake will flow down lower Wolf Creek and mix with the Neosho River at a confluence point about 8.8 km (5.5 mi) l south of the cooling lake dam (ER-OL, Secs. 2.4.1 and 3.4). Since the flow of lower Wolf Creek will consist essentially of only the blowdown discharge from l the cooling lake (except possibly during periods of heavy rainfall), the concentrations of chemicals in the creek will be similar to those in the cooling lake (Table 4.2). During periods when evaporation predominates, concentrations of chemicals in the creek would be expected to be slightly.

higher than those in the lake. During periods when precipitation is higher than evaporation, the concentrations of chemicals in the creek would be expected to be slightly lower than those in the lake.

4.2.6.3 Thermal As a result of the design changes in the station cooling system outlined in Section 4.2.4, the circulating and service water temperature rises under maximum operating level (1150 MWe) would be 17.5 C (31.5 F) and 3.6 C (6.4 F) instead of 16.7 C (30 F) and 5.6 C (10 F), and the combined temperature rise at the discharge into the cooling lake would be 16.4 C (29.6 F) (ER-OL, RQ 240.5) instead of 16.0 C (28.8 F) as given in the FES-CP (Secs. 3.4.2 and 5.3.1).

4.2.6.4 Sanitary and Other Wastes Sewage-Treatment System The description of the station sewage-treatment system given in the FES-CP (Sec. 3.7) remains valid. The liquid effluent from the system will be dis-charged into the cooling lake, and the sludges will be hauled away by a con-tractor for of fsite disposal (ER-OL, Sec. 3.7).

Oil-Separator System i Oily wastes generated during station operation will be treated in an oily

wastes separator not described in the FES-CP (ER-OL, RQ 291.13). The sepa-rated water, containing low concentrations of soluble chemicals, will be discharged into the cooling lake at the rate of 54.9 L/ min (14.5 gpm) (ER-OL, Table 3.6-7), and the oil will be reclaimed from the separator.

l Wolf Creek FES 4-9 l

4

Combustion Products As noted in the FES-CP (Sec. 5.5.1.1), there will be two sources of combustion-product emissions during station operation--testing of two diesel powered emergency generators and of an oil-fired auxiliary boiler provided to supply steam in an emergency. The applicant has provided additional information on the use of these pieces of equipment and the emissions expected. Each engine powers a 6190-kW generator (ER-OL, Sec. 3.7.2) and will be tested two hours per month using No. 2 diesel oil as fuel. The applicant estimates that gaseous emissions from the two engines combined during testing will be 194 kg/hr (427 lb/hr) of nitrogen oxides, 36.2 kg/hr (79.6 lb/hr) carbon monoxide, 6.0 kg/hr (15.2 lb/hr) hydrocarbons, 17.4 kg/hr (38.3 lb/hr) of sulfur oxides, and 10.4 kg/hr (22.8 lb/hr) of particulates, (ER-OL, Sec. 3.7).

Estimates of emission rates by the staff give values that are lower by factors ranging from about 1.6 for hydrocarbons to 6 for sulfur oxides.

4.2.7 Power-Transmission System As currently planned, the development of the WCGS energy-transmission system entails several modifications of the transmission facilities described in the FES-CP (Sec. 3.8). The principal modification involves development of the West Gardner substation near Edgerton, Kansas (Fig. 4.2). Upon completion, this substation will interconnect with WCGS, the LaCygne plant, and the Craig substation via three 345-kV transmission lines. This modification will reauce system right-of-way requirements by 23 km (14.5 mi); i.e. , the right-of way for that portion of the originally proposed WCGS-Craig transmission line (FES-CP, Sec. 3.8 and Fig. 3.7) that would have paralleled the existing trans-mission line extending between the Craig substation and the site of the new West Gardner interconnect (Fig. 4.2). Consequently, fewer state and other local transportation routes will be crossed by dual transmission lines, and overall environmental impacts will be correspondingly reduced.

The currently estimated length of the WCGS-Rose Hill transmission line (Fig. 4.2) is 157 km (97.6 mi), about 3.1 km (1.9 mi) longer than reported in the FES-CP Table 3.10. The specified rights-of-way for this and the above-mentioned WCGS-West Gardner transmission line require easement agreements involving total land areas of 718 ha (1775 acres) and 421 ha (1041 acres),

respectively (ER-OL, Sec. 3.9.2). Both transmission lines are scheduled to be completed in 1983 (ER-OL, RQ 290.1).

The alignment of project transmission lines in the vicinity of the WCGS is presented in Figure 4.3. This figure depicts the relocated portien of the previously existing LaCygne-Benton transmission line that was integrated with the WCGS in 1976 (ER-OL, RQ 290.1). The Wolf Creek tap (69 kV) of the Athens-Burlington line and Wolf Creek-Sharpe (69 kV) line (Fig. 4.3) have also been completed (ER-OL, RQ 290.1). The Wolf Creek tap is 6.5 km (4.0 mi) long (ER-OL, Sec. 3.9.2.3), about 4.6 km (2.8 mi) shorter than reported in the FES-CP (Table 3.10). The Wolf Creek-Sharpe line represents an addition to the WCGS transmission system as described in the FES-CP (Sec. 3.8 and Fig. 3.7).

This line is about 5 km (3 mi) long; the specified right-of-way corridor is 30 m (100 ft) wide (ER-OL, Sec. 3.9.2.4).

Design specifications for transmission-line structures, as constructed or currently planned, are essentially the same as those identified in the ER-CP Wolf Creek FES 4-10

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(Sec. 3.9) and summarized in the FES-CP (Sec. 3.8). An exception is that wood structures will be treated with pentachlorophenol in lieu of cellon as pre-viously reported (ER-OL, Sec. 3.9.3). Clearances under all conductors will equal or exceed those adopted in the National Electric Safety Code (ER-CP, Sec. 3.9.2).

4.3 PROJECT-RELATED ENVIRONMENTAL DESCRIPTIONS 4.3.1 Hydrology and Water Use 4.3.1.1 Hydrologic Description Surface Water The surface-water descriptions presented in the FES-CP (Sec. 2.5) are still valid with the addition: and discussions below. In addition, Section 5.3.3 of this report contains a discussion of the hydrologic effects of alterations in the floodplain as required by Executive Order 11988 - Floodplain Management.

Wolf Creek, which is a tributary to the Neosho River, is ungaged and stream-flow records are unavailable. The applicant has estimated average monthly streamflows based on drainage area ratios of Wolf Creek and U.S. Geological Survey gaging stations in adjacent watersheds at Council Grove, Americus, Strawn, Burlington and Iola, Kansas, on the Neosho River, and at Madison, Kansas, on the Verdigris River. The estimated average monthly streamflows are shown in Table 4.3.

Table 4.3. Estimated Wolf Creek Average Monthly Stream-flows (m 3 x 103)

Stream Flow Month 103 m3 Acre-feet January 673 545 February 759 615 March 1,376 1,115 April 1,452 1,180 May 2,074 1,680 June 2,284 1,850 July 3,185 2,580 August 630 510 September 1,216 985 October 1,191 965 November 679 550 December 506 410 Wolf Creek FES 4-13 l

Peak flood flows below the Wolf Creek cooling lake dam with recurrence inter-vals of 2, 10, and 100 years, as well as the standard project flood (SPF) and probable maximum flood (PMF), were estimated by the applicant under natural and modified conditions. Snyder's synthetic unit hydrograph method (Ref. 2) and hydrologic studies of the Neosho River basin by the U.S. Army Corps of Engineers (Ref. 3) were used to derive the runoff hydrograph. Table 4.4 is a summary of the peak flood flows on Wolf Creek below the cooling lake dam under natural and modified conditions. The peak flood flows below the cooling lake dam will be considerably smaller as a result of construction of the dam as shown in the table. This is because of the storage capacity of the cooling lake above the normal operating level of 331.3 m (1087.0 ft) MSL.

i Table 4.4. Peak Flood Flows of Wolf Creek Peak Flow Maximum Re u re Natural With Cooling Cooling Lake a

Condition Lake Water Level (MSL)

(years) ma /s cfs m3 /s cfs Meters Feet 2 106 3,725 8 290 331.86 1,088.78 10 168 5,941 14 497 332.02 1,089.31 100 237 8,363 26 928 332.17 1,089.80 SPF 566 20,000 119 4,188 332.75 1,091.70 PMF 1,157 40,877 647 22,845 333.76 1,095.00 The most severe drought of record in the site region began in November 1951 and continued through March 1957. Wolf Creek did not flow during much of this

! period.

Wolf Creek cooling lake was formed by construction of a rolled earth dam across Wolf Creek and five saddle dams around the perimeter of the lake.

Construction of the cooling lake was completed in late 1980 and filling began on November 13, 1980. As of May 28, 1981, the cooling lake level was 323.26 m (1060.55 ft) M5L, which is about 23% of its normal capacity and 41% of its l low-level operating capacity.

The normal operating elevation of the cooling lake will be 331.3 m (1087 ft)

MSL. At this elevation the lake will have a capacity of 1.37 x 108 m 3

! (111,280 ac-f t) and a surface area of 20.6 km2 (5090 acres). The cooling lake l dam crest elevation [335.3 m (1100 ft) MSL] has been designed to provide

[ sufficient freeboard to prevent significant overtopping during the probable maximum flood and coincident wind-wave activity. The service and auxiliary l

spillways will be able to pass floods of elevations up to and including that l of the probable maximum flood. The maximum cooling lake still-water level ,

calculated for a probable maximum flood that is preceded by a standard project I flood is 333.8 m (1095.0 ft) MSL. l l

l Wolf Creek FES 4-14 l

i l

Total sedimentation in the Wolf Creek cooling lake from Wolf Creek and makeup water from John Redmond Reservoir after 40 years of operation was estimated by the applicant to be 1% of the lake's storage volume at its normal operating level and thus will not affect the functioning of the lake.

Natural runoff from the Wolf Creek watershed and direct precipitation on the cooling-lake surface will not be sufficient to maintain the cooling lake at its normal operating level. Makeup water for the cooling lake will be obtained from the conservation storage of John Redmond Reservoir. The makeup water will be pumped from the Neosho River immediately downstream of the reservoir and discharged into the WCGS cooling lake.

The Kansas Water Re, sources Board has purchased 4.31 x 107 m 3 (34,900 ac-ft) of storage from the conservation pool of John Redmond Reservoir. The conserva-tion storage is used to maintain downstream water quality requirements, supply present and future municipal and industrial water needs, and maintain the lost capacity in John Redmond Reservoir resulting from sedimentation. The Kansas Water Office has estimated that the yield capability from the water supply storage through a 2% chance dre c ht would be 1.0 x 105 ma/ day (26.5 mgd) from the water supply portion, 4.3 x 107 m3 (34,900 acre-feet), of the storage after adjusting for 50 years of sedimentation in John Redmond Reservoir (Ref. 4).

The applicant has purchased this 1.0 x 105 m3 / day (26.5 mgd) from the Kansas Water Resources Board (Water Purchase Contract No. 76-2, March 13, 1976) to supply makeup water to the Wolf Creek cooling lake.

Since the major source of makeup water for the Wolf Creek cooling lake is the conservation storage of the John Redmond Reservoir on the Neosho River, a brief discussion of Neosho River hydrology is appropriate. The flood of record on the Neosho River was in July 1951. The river's estimated peak discharge at the point where Wolf Creek joins it, based on interpolation of drainage areas, would have been about 11,460 m 3 /s (404,500 cfs). This flood occurred before John Redmond Reservoir was completed. Since 1963 the Neosho River flow near the WCGS site has been completely regulated by John Redmond Reservoir.

John Redmond Reservoir dam, located at River Mile 343.7, was designed for flood control, water quality control, recreation, fish and wildlife, and future water supply. The maximum allocation for flood control and conserva-tion storage after adjustment for sedimentation is 7.3 x 108 ma (588,100 ac-ft) and 0.8 x 108 ma (62,500 ac-ft) respectively. Regulation of the flows into the 4 Neosho River began when the control gates were closed to begin deliberate impoundment of water on September 1, 1964. The maximum pool elevation was 325.2 m (1066.8 ft) MSL on October 16, 1973. The minimum pool elevation since regulation of storage began was 314.6 m (1032.1 ft) MSL on September 1, 1964, with a volume of 3.8 x 107m3 (30,970 ac-ft).

Groundwater Groundwater investigations in the site region sponsored by the applicant (ER-OL, pp. 2.4-10 through 26) indicate the presence of three groundwater sources: river valley alluvium, shallow soils and weathered bedrock, and con-solidated bedrock.

Wolf Creek FES 4-15

The river valley alluvium is comprised primarily of gray and light brown silty l clays with scattered lenses of sand and gravel. In the Neosho River valley, the width of the alluvial deposits varies from 1.6 to 16 km (1 to 10 mi), with a maximum thickness of probably less than 6 m (10 ft). In the Wolf Creek valley the alluvial deposits have a maximum thickness of probably less than 11 m (36 f t) and a width of less than 0.2 to 0.8 km (0.1 to 0.5 mi). Aside from the water supply well for the City of New Strawn, located upstream of the confluence of Wolf Creek and the Neosho River, there are no irrigation, indus-trial, or municipal wells tapping the alluvial aquifer along the Neosho River as far downstream as Iola, Kansas.

The soil and weathered bedrock zone is comprised of weathered shales, silt-stones, limestones, and soils derived from them. The soil ranges from a silty sand with traces of rock fragments to soft clay with a trace of sand. Soils range from less than 0.3 m (1 ft) in thickness to a maximum of 5 m (16 ft),

and the weathered bedrock may extend to a depth of 12 m (40 ft), but is usually less than 6 m (20 ft). Recharge of the weathered bedrock zone is by local precipitation and discharge is primarily into the alluvial deposits, streams, water-supply wells, and to a much lesser degree into the underlying aquifers.

Wells tapping the weathered bedrock in the region yield up to 38 L/ min (10 gpm) and are limited to livestock and domestic use (Ref. 5).

Limestone and sandstone members below the weathered bedrock zone in the site region yield small quantities of water to wells (Refs. 5,6). Their strati-graphy and lithology are presented in Section 2.5.6.1 of the ER-OL. The yield

of water from wells tapping the deep aquifers ranges from 4 to 38 L/ min (1 -

10 gpm) (Ref. 5), and the water is generally of poor quality. Recharge is primarily from rainfall and runoff, which occurs where the strata are exposed at the surface. Recharge from each overlying aquifer to the one immediately below is estimated to be small because of low vertical permeability of confining shale units.  ;

i The water-table surface, which is a composite of the alluvial and weathered bedrock aquifers, is a muted image of the surface topography. The direction of groundwater flow in the weathered zone is to the southwest from the station site towards the Neosho River. The piezometric surface of the deeper, unweath-  :

ered bedrock aquifers to some extent reflects the regional dip of the parent formations, which is to the northwest, but the predominant direction of ground-water flow in the unweathered zone is also to the southwest. l 4.3.1.2 Water Use  ;

Present groundwater use in the WCGS region is primarily for domestic supplies )

and livestock watering. Figure 2.1-27 of the ER-OL gives the well inventory within 8 km (5 mi) of the WCGS site and Table 2.1-23 of the ER-0L gives perti-nent information on type of wells, capacity, and use. Wells located within

! the Wolf Creek cooling lake have been sealed.

The major municipal groundwater users within 32 km (20 mi) of the site are given in Table 2.1-22 of the ER-OL. The towns of Waverly, Williamsburg, New Strawn, Melvern, and Hartford draw their water supplies from groundwater wells. All but New Strawn and Hartford draw from the Tonganoxie aquifer. The i

l Wolf Creek FES 4-16

l 1

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'L I Tonganoxie Sandstone Member of the Stranger Formation at the site is found as  !

a facies of silty shale with thin interbeds of sandstone with very low perme-1 abilities. The channel-deposited facies of the Tonganoxic Sandstone Member, which is an important aquifer in some areas of eastern Kansas, has not been encountered in any of the borings at the site (ER-OL, Sec. 2.5.6.2). The i towns of New Strawn and Hartfori draw water from the Neosho River alluvium

upstream of the confluence of Wolf Creek and Neosho River.

There will be no groundwater withdrawals for plant consumptive use during

, operation of the WCGS.

1 The principal surface water withdrawal from the Neosho River downstream of the site is for municipal use, followed by industrial, irrigation, and recreational uses. The major water users and discharges on the Neosho River downstream of

, the site are listed in Tables 2.1-19 and 2.1-20 of the ER-OL. The nearest l municipal water user downstream of Wolf Creek is the City of LeRoy (22 km).

The authorized maximum annual quantity of water withdrawal from the Neosho River in Kansas downstream of the site is 3.7 x 107 m 3 (29,989 ac-ft)

(Table 2.1-19, ER-OL).

4.3.2 Water Quality 4.3.2.1 Neosho River Information on water quality in the Neosho River is presented in Section 2.5.3 of the FES-CP. However, the differences in the Neosho River water quality

! between normal and drought years, as well as concentrations of some metals relevant to corrosion within the plant, were not discussed in the FES-CP.

J Ambient concentrations for various chemical species at the dam in the John Redmond Reservoir for normal and drought conditions are given in Table 4.2. Metals that can be released by corrosion during station operation include iron, chromium, and nickel. Ambient data for nickel are not available.

l l

Comparisol of the entries in the table with regulatory limits given in the l

Kansas Wa.er Quality Criteria, Reg. 28.16.28, and 40 CFR Parts 141 and 143 show that the concentrations of most of the chemical species are below the regulatory limits. One exception is the total dissolved solids (TDS) concen-tratior under drought conditions, which exceeds the limit by 60 mg/L. Accord-1 ing to the applicant (ER-OL, Table 2.4-12), the limit for undissociated ammonia (Nil4 0H) was exceeded in the Neosho River at the John Redmond Reservoir twice

' in 1974 and once in 1975 at a location just above the confluence with Wolf Creek.

4.3.2.2 Groundwater Concentrations of chemical species in groundwater samples obtained by the applicant from several wells near the plant show considerable variation in the water quality among the wells (ER-OL, Table 2.4-12). For example, TDS concen-trations ranged from 408 mg/L to 3775 mg/L; C1 and 504 concentrations ranged from 17.5 mg/L to 512 mg/L and from 12 mg/L to 320 mg/L, respectively; and total iron ranged from 0.15 mg/L to 13 mg/L.

1 i Wolf Creek FES 4-17 l t

4.3.3 Climatology and Air Quality 4.3.3.1 Climatology The discussion of the general climatology of the site and vicinity contained in the FES-CP remains unchanged. Since issuance of the FES-CP, information about the frequency of thunderstorms has changed. A recent study by the 1

National Climatic Center (Ref. 7) indicates that about 70 thunderstorms can be expected to occur each year in the vicinity of the Wolf Creek site, being most frequent May through July.

Since issuance of the FES-CP, two additional years of meteorological data have been collected at the station site. For a. composite three year period of record (June 1, 1973 - May 31, 1974 and March 5, 1979 - March 4, 1980), data

. from the 10-m (33-ft) level indicated prevailing winds from the south (about I 18% of the time), with winds from the south-southeast'and south-southwest each

occurring about 10% of the time. The mean annual wind speed at the 10-m level t

is about 4.5 m/s (10 mph), with calm conditions occurring less than 0.1% of i the time.

4.3.3.2 Air Quality The air quality of the site environs was not discussed in the FES-CP; however, monitoring data are now available that the staff has used to evaluate air quality.(ER-OL, Sec. 2.3.10).

1 Comparison of ambient air quality of the site with applicable standards indi--

cates that the site is in attainment of the National Ambient Air Quality

Standards with respect to particulate matter, sulfur dioxide, nitrogen oxides, and carbon monoxide. The area is unclassified with respect to ozone; however, i

there is a nonattainmer. 'rea for ozone about 60 km (40 mi) away in Douglas i County (ER-OL, Sec. 2. 3.10).

.1 4.3.4 Ecology 4.3.4.1 Terrestrial The terrestrial plant communities destroyed or disturbed by project construc-tion activities are essentially those described in the FES-CP (Sec. 4.3.1),

with the following exceptions. A lime-sludge pond has been constructed north

. of the WCGS switchyard. The pond occupies about 13 ha (31 acres), and periph-eral embankments were constructed with material excavated from. interior par-tions of the facility (ER-0L, RQ 291.1). Slopes of the embankments have been l j dressed with topsoil material and revegetated or riprapred. A second notable exception involves the modifications of the WCGS energy-transmission system as l initially proposed by the applicant (FES-CP, Sec. 3.8). 'As' discussed in l Section 4.2.7, the principal modification entails development of the West '

Gardner substation and the WCGS-West Gardner transmission line in lieu of the l l initially proposed WCGS-Craig line, thereby reducing transmission line require- l l ments by 23 km (14.5 mi). On balancing the environmental effects associated I with construction of the new substation with those resulting from a reduction of 23 km of transmission line's, the staff considers the former to be the preferred alternative.

I l

Wolf Creek FES 4-18

i 1

l Land-clearing, earth-moving and otler project construction undoubtedly resulted in appreciable numbers of small mammals, reptiles, amphibians, and other organisms being buried, crushed, c r otherwise adversely af fected. The more mobile animals were generally distl aced from construction sites. This dis-placement may have caused some mortality, particularly among species with similar habitat requirements. Thy small animals that survived land-clearing and constructirn activities withis the cooling-lake site have been and will be subject to yet another hazard. F lling of the lake was initiated in May 1980 (ER-OL, RQ 291.16), thereby inundating immobile species and forcing others to migrate before ;he rising waters. Migration will not occur without appreciable mortality; sone animals will perish in underground burrcws, others will seek refuge on the higher microrelief that will subsequently be isolated and submerged at distances exceeding the swimming capabilities of the affected animals. Given normal tydrologic conditions in the upstream watershed a.id maximum authorized withdrawai (3.43 m /s, or 120 cfs) of water from the ~

Neos~ho River, the applicant estinates that the cooling lake could be filled to the normal operating level in 14 months (ER-OL, RQ 291.16). A severe drought and/or other circumstances may p olong the lake-filling process. However, at the normal operating level of wa.er in the cooling lake, about 2060 ha l (5090 acres) will have been converted from terrestrial to aquatic environment.

The construction of tall structures at the WCGS site and offsiteSince transmission these facilities are potential hazardous obstacles to flying birds.

hazards will persist throughout the operational life of the WCGS, bird impingements are addressed in Section 5.5.1.

The staff has reviewed projected adverse and beneficial effects on wildlife' species resulting from construction-related destruction and alteration of habitats, as presented in the FES-CP (Sec. 4.1.3.6). These projected effects on wildlife populations are considered generally representative of currently prevailing conditions, with exception of conclusions relative to species

" eliminated" from the site. For example, it is unlikely that construction disturbance caused the extirpation of badger (Taxidea taxus) and plains harvest mouse (Reithrodontomys montanus) from the entire 39TO-ba (9820-acre) site.

Appreciable portions of the site were relatively unaffected by construction; further, some affected species undoubtedly frequent previously disturbed areas that have since been reclaimed.

4.3.4.2 Aquatic Summary descriptions of preconstruction aquatic environments and associated biota of the John Redmond Reservoir, Neosho River, and Wolf Creek were pre-sented in the FES-CP (Sec. 2.7.2 and Appendix C). The applicant has provided additional information in the ER-OL (Sec. 2.2.1), 'ntegrating data derived from monitoring programs conducted during the period 1975 through 1978. Thit updated information relative to the various aquatic life forms is summarized below.

Phytoplankton During the six year study period (1973-1978), total sample collections included over 300 taxa, representing over 100 genera within 8 algal divisions. About 50% of the taxa were diatoms; 25% were green algae; and the remaining taxa Wolf Creek FES 4-19

~ consisted of yellow-brown and blue green algae, euglenoids, cryptomonads, chloromonads, and dinoflagellates. Centric diatoms were typically the domi-nir.t phytoplankton group in collections from the Redmond Reservoir-Neosho River system. Species of green algae and cryptomonads were also prominent phytoplankton in reservoir-river collections. In contrast with the foregoing, pennate diatoms and flagellated algae were dominant in collections from Wolf Creek. Since 1974, flows in Wolf Creek have been intermittent, and most phytoplankton samples were collected (1975-1978) from shallow, stagnant pools in the creek bed.

+

Per_iphyton Identifications during monitoring programs have increased the total observed periphytic organisms to include 237 taxa representing 62 genera. Of these, 83 taxa equalled or exceeded 10% of the total sample population during at least one sampling period. Taxa that were frequently dominant only in the Neosho River include the diatoms Navicula tripunctata and Stephanodiscus sp., and two green algae. The diatoms Diploneis sp., Gomphonema sp., Gyrosigma sp.,

Navicula symmetrica, Nitzschia dissipata, and Surirella ovata and a blue green algae were commonly dominant only in Wolf Creek. During the 1975-1978 monitor-ing period, periphyton were generally more abundant in the Neosho River than in Wolf Creek.

Zooplankton The total zooplankton identified during the six year study period included 22 taxa of Copepoda, 35 of Cladocera, and 39 of Rotifera (ER-0L, Table 2.2-23).

About 57% of these taxa are littoral species; the remainder are limnetic organisms. The limnetic taxa of the Redmond Reservoir-Neosho River system and Wolf Creek are similar, but most major limnetic species of the reservoir were less abundant in Wolf Creek. Fifty-three littoral species were collected in

, Wolf Creek, compared with 30 and 41 species collected in the reservoir and Neosho River, respectively. During the 1975-1978 monitoring programs, virtually all samples of Wolf Creek zooplankton were collected from isolated, stagnant pools.

Benthos Benthic data collected during 1974-1975 surveys of the John Redmond Reservoir were similar to those. reported in the ER-CP and summarized in the FES-CP (Sec. 2.7.2.3). The benthic communities of the tailwaters below Redmond dam were surveyed during a 1976-1978 study period. The Chironomidae were the most diverse as well as the most numerous, and the dominant chironomid genera were Cricotopus, Procladius, and Polypedilum. Survey data (1973-1978) for the Neosho River indicate Hydropsychidae (Potamyia, Cheumatopsyche) are the pre- i dominant benthic organisms. Chironomidae were the most diverse and the second most abundant taxa collected in benthic samples. Other prominent taxa include representatives of Perlidae, Tubificidae, Heptageniidae, and Naididae.

The benthic fauna of Wolf Creek exhibit marked variability in density and spatial distribution, and compositions reflect species adaptability to pool  ;

environments during intermittent stream flows. Tubificidae were generally the most abundant t<n4iic group of survey samples. The Chironomidae were the most e diverse and sere.s most abundant group of benthic samples. Other prominent taxa included Naididae, Sphaeriidae, and Simuliidae.

Wolf Cretk FES 4-20 o __ _ . . - - - - - . - - _ - _ - - -

Fish Surveys conducted in the Neosho River and Wolf Creek during the 1975-1978 monitoring period resulted in identification of 16 fish species in addition to The additional 16 species the 30 species reported in the FES-CP (Table C.2).

consisted of four small minnows, three suckers, three freshwater catfish, two darters, and single species of gar, livebearer, silverside, and a small sunfish.

Of the total 46 species identified (ER-OL, Table 2.2-29), only three species (rosyface shiner, yellow bullhead, and bluntnose darter) were collected exclu-sively f rom Wolf Creek; thus 29 of the 32 species taken frcin Wolf Creek were among the total of 43 species collected from the Neosho River. A principal difference between fish populations of the two drainages is that the Redmond Reservoir-Neosho River system supports mature game fishes (e.g., channel catfish, flathead catfish, white bass, and white crappie), while only juveniles of the game species were collected from Wolf Creek. The reduced or inter-mittent flows in Wolf Creek downstream from the WCGS site contributed to substantial fish kills during the winter seasons of 1976-1977 and 1977-1978.

The initial stocking of fish in a filled portion of the Wolf Creek cooling lake occurred in August 1978, with the introduction of fathead minnow and largemouth bass (ER-OL, RQ 291.24). Subsequent stockings have included those species plus redear sunfish, bluegill, blue catfish, channel catfish, black crappie, small mouth and spotted bass, walleye, striped bass, and a bass hybrid (striped bass x white bass).

4.3.5 Endangered and Threatened Species Based on consultation with the U.S. Fish and Wildlife Service (Appendix H),

the species listed and proposed for listing as federally designated endangered and threatened biota that may occur in the WCGS area are limited to the bald eagle (Haliaeetus leucocephalus) and peregrine falcon (Falco peregrinus).

Bald eagles winter in the area, and the species was observed at or near the WCGS site in 1976 and again in 1977 (ER-OL, Sec. 2.2.1.2.5). However, the falcon has not been observed during seasonal surveys conducted over a period exceeding eight years (ER-OL, RQ 290.11).

Aside from federally listed biota, the Kansas Fish and Game Commission has designated additional animals as endangered or threatened species in Kansas.

Among others, the Neosho madtom (Noturus placidus) and warty-backed mussel (Quadrula nodulata) are included in the state listing of endangered species.

Considered of rare occurrence in 1962 (Ref. 8), the warty-backed mussel appears more widely distrubuted than formerly believed. Schwilling (Ref. 9) cites collections of the species from 26 locations in the Cottonwood, South Fork of the Cottonwood, Marais des Cygnes, Verdigris, and Neosho Rivers. This mussel was found in the Neosho River at Burlington in 1971, and a population of the species may still be present in that part of the river. However, its presence in the Neosho River near the WCGS site is not substantiated by moni-toring surveys. The 1975-1979 benthic survey data prepared for the applicant include organisms reported as " unidentified" or " immature" unionids, some of which may have been warty-backed mussels. Thus, the local presence of the species is unresolved. Such is not the case for the Neosho madtom--77 indi-viduals of this species were collected during 1976-1978 surveys in the Neosho River (ER-OL, Table 2.2-32) at locations near the Wolf Creek-Neosho River confluence. The madtom was not collected during concurrent sampling of Wolf Creek and the tailwaters below Redmond dam.

Wolf Creek FES 4-21

State-listed species of threatened status that have been observed during monitoring surveys of the WCGS area include two birds, a fish, and an amphibian.

Monitoring data indicate a single prairie falcon (Falco mexicanus) was observed in 1978; the species was again observed in 1981 (ER-OL, RQ 290.11). Although  ;

I not reported during 1973-1978 surveys conducted near WCGS (ER-OL, Table 2.2-10),

the least tern (Sterna albifrons) was observed at John Redmond Reservoir in 1977 (ER-OL, RQ 290.11). This tern is typically an uncommon transient through-out Kansas, but the species is reported to nest on salt flats and sandbars in large rivers west of the Flint Hills (Ref. 9). Individuals of the threatened blue sucker (Cycleptus elongatus) were consistently taken during 1977 and 4

subsequent fish surveys conducted in the Neosho River near the WCGS site, including the tailwaters below Redmond dam (ER-OL, Table 2.2-33, RQ 290.11).

' This species was not collected during concurrent monitoring of Wolf Creek fish populations. The northern crayfish frog (Rana areolata circulosa) was observed on a single occasion in mudflats within the John Redmond Reservoir, but repeated monitoring efforts have not established the presence of this species on the WCGS site (ER-OL, RQ 290.11).

i There is currently no official listing of endangered or threatened plant species by the State of Kansas. However, McGregor (Ref. 10) has authored a survey of the rare native vascular plants of Kansas, providing species distri- i butions by county. Coffey County (including WCGS) is not among those counties in which the rare plants are reported to occur, with exception of the following species: Asclepias meadii, Platanthera leucophaea, and Eleocharis quadangulata var. crassior. The first two of these species are presently under review for federal listing as endangered or threatened (Ref. 11). The last named species is known only from a single colony in Coffey County (Ref. 10). However, none of the three species is included in tte inventory of all plants encountered in the 1973-1978 vegetation studies condteted at the WCGS site (ER-OL, Table 2.2-1). Further, none of the tt.ree are among those federally listed i species that may be present in the area, as determined by the U.S. Fish and Wildlife Service (Appendix H). The staff concludes that it is unlikely that any of the three species occur at the WCGS site. i 4.3.6 Historic and Archeological Sites Sections 2.3 and 4.1.1 of the FES-CP report on the cultural resources in the area. In these sections, it states that "There are no natural or historic landmarks, sites, or places within five miles of the WCGS area listed in the National Register of Historic Places or the National Registry of Natural Landmarks." None has been added nor identified as being eligible for inclu-sion since then.

1 1

At the time of the FES-CP, 17 archeological sites had been studied, with five l being defined as having the potential for scientific knowledge. Since then, l eight additional sites were discovered during additional surveying. Of these 25 total sites, 20 were selected for testing. The analysis of the tests was I

' that none of the sites were significant enough to warrant nomination to the National Register.

With respect to the transmission line corridors, their selection was partly based upon the avoidance of archeological sensitive areas, and no significant sites have been identified. The closest properties to the trapsmission lines Wolf Creek FES 4-22

4' i

listed or eligible for listing in the " National Register of Historic Places" are the Columbia Bridge in Peoria, Franklin County at 2.1 km (1.3 mi) and the 1

C.N. James Cabin in Augusta, Butler County at 4.3 km (2.7 mi) (ER-OL, RQ 310.8).  !

The construction of the railroad spur to the plant threatened an archeological site. The site has since been excavated (see Appendix I).

+

j I

j 4.3.7 Community Characteristics The FES-CP reports in Section 2.2.1 on the demography, socioeconomics, and community characteristics of the area. The area remains a rural agricultural one with a low population density. A 1980 survey conducted by the applicant j of homes within 8 km (5 mi) of the station showed a population of 3734. This

) is lower than the FES-CP estimated 1980 population of 4727. In general, the [

area around the station is not expected to experience any significant popula- l tion growth during the operating life of the station. No significant changes from the community characteristics reported in the FES-CP are anticipated over l the plant's operating life.

i References for Section 4 j 1. J.P. Polar, "A Guide to Corrosion Resistance," Climax Molybdenum Co.,

New York, p. 259 (undated). ,

, 2. "V.T. Chow, " Handbook of Applied Hydrology," 1964.

l 3. " Hydrology, Strawn Reservoir," U.S. Army Corps of Engineers, Tulsa, 1 Oklahoma District Design Memorandum No. 2, February, 1958.

i

) 4. "The Fifth Annual Report to the Governor and Legislature, Kansas State Water Plan - Water Supply and Storage Program," Kansas Water Resources Board, 1978.

5. C.K. Bayne and J.R. Ward, " General Availability of Ground Water in i

Kansas: Map," Kansas Geol. Survey, Lawrence, 1967.

j 6. D.F. Merriam, "The Geologic History of Kansas," Geol. Survey, Bull. 162,

1963.

7. M.J. Changery, " National Thunderstorm Frequencie. for the Contiguous l

United States," U.S. Nuclear Regulatory Commission, NUREG/CR-2252, I November 1981.

8. H.D. Murray and A.B. Leonard, "Unionid Mussels in Kansas," Museum j

of Natural History, University of Kansas, Lawrence, 1962.

i r

9. M. Schwilling, " Kansas Nongame and Endangered Wildlife," Kansas School-i Naturalist 27(3):3-15, Emporia State University, Emporia, February 1981.

10. R.L. McGregor, " Rare Native Vascular Plants of Kansas," Technical Pub. No. 5, State Biological Survey of Kansas, Lawrence, 1977.

11. " Endangered and Threatened Wildlife and Plants: Review of Plant Taxa for Listing as Endangered and Threatened Species," U.S. Fish and Wildlife i Service, Federal Register 45(242):82480-82569, 1980.

I Wolf Creek FES 4-23

1 i

5. ENVIRONMENTAL CONSEQUENCES AND MITIGATING ACTIONS 5.1 RESUME Because of the availability of additional information, changes in design parameters, or the use of improved assessment methodology, there have been several changes in the staff's evaluation of environmental effects of station operation since issuance of the FES-CP. Water use and hydrological impacts have been reexamined and updated to reflect changes in station design and operation and more recent environmental data (Sec. 5.3.1). The impact of chemical discharges into the Wolf Creek cooling lake and Neosho River, as well as to the groundwater, has been reexamined (Sec. 5.3.2). The impact of corrosion products on water quality is discussed (Sec. 5.3.2.1). Only insig-nificant changes in the impacts of thermal discharges into the cooling lake are expected as a result of design changes in the heat-dissipation system (Sec. 5.3.2.2). The effects of the station operation on the Neosho River floodplain has been evaluated pursuant to Executive Order 11988 (promulgated since issuance of the FES-CP and after the start of construction of the dam on Wolf Creek) (Sec. 5.3.3). Air quality impacts have been addressed, and the discussion includes the impacts of steam fog from the cooling lake, as well as effluents from auxiliary combustion sources (Sec. 5.4). Terrestrial and aquatic ecology impacts have been reviewed and updated (Sec. 5.5). Land-use impacts resulting from changes in the transmission line routing have been reevaluated (Sec. 5.5.1). The potential impact of station operation No on endan-impacts on gered and threatened species has been reassessed (Sec. 5.6).

historical and archeological sites are expected as a result of station operation The (Sec. 5.7). Socioeconomic impacts are reviewed and updated (Sec. 5.8).

information on routine releases of radiological effluents and resulting doses to members of the general public and station workers has been updated (Sec. 5.9.3). The material on plant accidents now contains information that has been revised and updated to include Class 9 accidents (Sec. 5.9.4). The latest information on er'rironmental effects of the uranium fuel cycle and decommissioning has bee.a provided (Secs. 5.10 and 5.11). The environmental impacts of the applicant's emergency planning procedures have not as yet been determined (Sec. 5.12).

Operational monitoring programs are to be conducted in accordance with the Environmental Protection Plan (EPP) to be issued by NRC as part of the operat-ing license. The EPP will require the applicant, as licensee, to (1) notify NRC if changes in plant design or operation occur, or if tests or experiments affecting the environment are performed, provided that such changes, tests, or experiments involve an unreviewed environmental question; (2) maintain specific environmentally related records; (3) report violations of conditions stated in the NPDES permit or state certification pursuant to Section 401 of the Clean Water Act; and (4) report unusual or important environmental events.

Wolf Creek FES 5-1 j

5. 2 LAND USE Land-use impacts of the operation of WCGS are described in Section 5.1 of the FES-CP. No potentially significant impacts of plant operation on land use on and off the site have been noted by the staff since then.

5. 3 WATER 5.3.1 Use 5.3.1.1 Surface Water k Wolf Creek Generating Station water supply will be derived from the Wolf Creek l cooling lake. Makeup water to the cooling lake will be supplied from conser-vation storage of John Redmond Reservoir on the Neosho River. Cooling lake water originates from Wolf Creek watershed runoff, direct precipitation on the cooling lake, and makeup water from John Redmond Reservoir. Makeup water from John Redmond Reservoir is by far the major source of water for the ccoling lake. Operational activities of the WCGS potentially affecting surface water include: diversion of the cooling lake makeup water from John Redmond Reservoir, operation of the cooling lake, and associated cooling lake blowdown.

The applicant has a contract with the Kansas Water Office (Water Purchase Contract No. 76-2, date March 13, 1976) to purchase 1 x 105ma / day (41 cfs) of water f rom the conservation storage of John Redmond Reservoir to supply makeup to the Wolf Creek cooling lake. Water will be withdrawn from the Neosho River at the makeup water discharge structure located just downstream of the John Redmond Dam. Water may be withdrawn from storage at a maximum daily rate of a t 4.0 m /sec (140 cfs) with a the amount of water pumped not to exceed a running I average rate of 1.2 m /sec (41 cfs) to be calculated on a quarterly basis. 1 The maximum pumping rate including natural river flow is 4.8 m3 /sec {

(170 cfs).

)

The Kansas Water Resources Board has previously purchased 4.3 x 107 m 3 (34,900 ac-ft) of John Redmond Reservoir storage from the U.S. Army Corps of Engineers under provisions of the Federal Water Supply Act of 1958 (P.L.85-500 as amended). The 4.3 x 107 m a (34,900 ac-ft) accounts for 55.84%

of the total storage space after adjustment for 50 years of sedimentation.

The Kansas Water Of fice has the right to contract for the withdrawal of water from reservoirs (Kansas Statutes Annotated 82a-1305) up to but not exceeding the reservoir yield capability during a drough having a 2% chance of occurrence in any one year with the reservoir in operation. The Kansas Water Office's right to divert and store water in John Redmond Reservoir was accepted by the Chief Engineer, Division of Water Resources, Kansas Board of Agriculture (Water Reservation Right Number 5, File Number 22, 197-AR-5).

l The basis for the 1.2 m3 /s (41 cfs) limit to the average withdrawal rate when

! water is below the conservation pool is the Kansas Water Office's estimated drought yield for 34,900 acre-feet of reservoir storage in John Redmond Rese 'oir.

Wolf Creek FES 5-2

~_

I 1

Prior water-rights holders downstream of John Redmond Reservoir (Table 2.1-19, ER-OL) have first priority for water flowing by natural means into John Redmond l Reservoir. However, they have rights only to the first water inflow and not ,

to water already in reservoir storage. If the water inflow to the reservoir is less than the water rights, the water available for prior water rights holders is limited to the rate that water is flowing into the reservoir.

Water-storage space retained by the U.S. Army Corps of Engineers in Council Grove, Marion, and John Redmond reservoirs must be made available for release to maintain the Neosho River water quality at Council Grove, Emporia, and Chanute, Kansas.

During the construction permit stage, the staff performed a detailed analysis of Neosho River flow rates immediately downstream of the John Redmond dam with and without the water being diverted to the Wolf Creek cooling lake. The period of record for analysis was from January 1950 through December 1960, which included the drought of record (estimated to have a recurrence interval of about 50 years). The results of the analysis show that there is a reduction of flow during portions of the period-of-record drought, but there would have been no change in the downriver flow during the worst part of the drought because the water surface in John Redmond Reservoir would have been below the conservation level. In this case, water would be released downstream only for the previous water rights and for water quality purposes, which are the same with or without the presence of the WCGS.

Water is lost from the Wolf Creek cooling lake through evaporation, seepage, blowdown, and overflow. The applicant estimated cooling lake drawdown eleva-tions for one unit operation during the 16 year period from 1949 to 1964.

The minimum drawdown elevation during this period, which includes the period-of-record drought, was 330.7 m (1085.0 ft) MSL. The minimum operating level of the circulating water system of the WCGS is 327.7 m (1075 ft), MSL. The estimated cooling lake drawdown elevations were based on a seepage rate of 5.9 m3 / min (3.5 cfs), a range in evaporation rates in the cooling lake of 38 m3 / min (22.30 cfs) in February to 135.3 m3 / min (79.63 cfs) in August (ER-OL, Table 3.4-4), makeup water input of 204 m3/ min (120 cfs) when the John Redmond Reservoir water elevation was greater than the conservation storage elevation and 68 m3 / min (40 cfs) when less, and a cooling lake blowdown 3

rate varying from 5.9 m3 / min (3.5 cfs) during pre-drought conditions to 0 m /s during the drought period, and 68 m3 / min (40 cfs) during the post-drought period.

During drought conditions water will not be released from the Wolf Creek cooling lake. The Wolf Creek flow below the dam will be negligible during drought conditions. However, these periods of no flow will be similar to conditions prior to construction of the cooling lake dam when the flow of Wolf Creek was 0 m 3 /s during drought conditions.

The staf f therefore concludes that the operation of the Wolf Creek Station will not have a significant effect on downstream water use during normal flow or reasonably severe drought conditions.

Wolf Creek FES 5-3

4 5.3.1.2 Groundwater Operation of the WCGS will be sustained by water obtained from the cooling lake. No groundwater will be used for operation of the plant. Operation of the plant will, however, cause an increase in the concentration of total dissolved solids (TDS) and radionuclides in the cooling lake, which could, conceivably, degrade groundwater quality through seepage from the cooling lake. The applicant made an analysis of seepage through the inundated bedrock units and concluded 3

that seepage from the cooling lake will be negligible, less than 71 m / day (13 gpm) even with conservative assumptions as to perme-ability of the bedrock units. Furthermore, the travel time of seepage to the nearest downgradient wells was found to be several thousand years. The staff has evaluated the applicant's analysis and concludes that any degradation of groundwater due to the operation of the WCGS will be negligible.

Water-table rise due to the construction of the cooling lake was evaluated by the staff in the FES-CP and was determined to be negligible.

5.3.2 Quality 5.3.2.1 Chemical Wolf Creek Cooling Lake The water quality impact for the cooling lake presented in the FES-CP (Sec. 5.5.2.3) remains valid with respect to biocide discharge, total dissolved solids (TOS), and discharge from the sewage treatment plant; however, the impact of corrosion products was not discussed in the earlier review.

As indicated in Section 4.2.6.1, the concentrations of iron (3.9 pg/L), chromium (0.3 pg/L), and nickel (0.2 pg/L) in the circulating water that would result from corrosion are quite small. However, these small values could have a large effect on the concentration of these species in the cooling lake. The reason is that due to the long lifetime of any nonvolatile substance in the cooling lake [1300 8days under normal conditions assuming 1.13 m 3 /s (40 cfs) blowdown and 0.1 m /s (3.5 cfs) seepage], concentrations of corrosion products could build up. The cooling-lake data for chromium in Table 4.2 show this effect, i.e., one-half of the total chromium concentration for both normal and drcught conditions would result from corrosion. The fraction for nickel would be expected to be similar, although no ambient data are available. For iron, however, corrosion would contribute only 3% of the total. Thus, corrosion would have a major effect on increasing concentrations of chromium and possibly nickel in the cooling lake; for iron the effect of corrosion would be small.

Neosho River The water quality of the Neosho River at and below the confluence with Wolf I Creek will be affected by station operation becarse the concentrations of chemicals in the blowdown released to the creek (the cooling lake entries in Table 4.2) will be higher than the ambient concentrations in the river.

However, the applicant is required under the Kansas Water Quality Criteria (Reg. 28.16.28) and 40 CFR Part 143 to regulate discharges so that total dissolved solids (TDS), sulfate, and chloride concentrations in the Neosho River after complete mixing are at most 500 mg/L, 250 mg/L, and 250 mg/L, Wolf Creek FES 5-4

J respectively. A zone of passage that is three quarters of the flow of the river and which satisfies these regulatory concentration limits must also be maintained in the mixing zone.

Because of these requirements, no blowdown could be discharged during drought conditions since the TDS concentrations in both the river and the blowdown would be above 500 mg/L (Table 4.2). During normal conditions the design blowdown flow would be 1.13 3m /s (40 cfs) (ER-OL Sec. 3.6, Rev. 3). Based on an average river flow of 37.8 m3 /s (1335 cfs) (ER-OL, Sec. 3.6.2.2), use of

, the data in Table 4.2 to obtain final mixed concentrations in the Neosho River indicates that concentrations would be 2.7% higher than the ambient values for all chemicals except 50 4, HCO3 , and the metals Fe, Cr, and Ni. For 50.5 anu HCOa, the respective final mixed concentrations in the river woulo be 12.8%

higher and 1.3% lower than the ambient values (HCO3 would be removed from the water by station operation). The final mixed 504 concentration (451 mg/L) would be below the regulatory limit of 500 mg/L. For total iron and soluble iron, the final mixed concentrations in the river would be 2.9% higher than ambient; for chromium, the increase would be 7%. No ambient data are available for nickel; however, corrosion during station operation under normal conditions would produce an increase in the nickel concentration of 0.12 pg/L in the mixed Neosho River.

The applicant will monitor TDS and sulfate levels and flow in the Neosho River downstream of its confluence with Wolf Creek in conformance with NPDES permit requirements (see Appendix B). [

Groundwater In the FES-CP (Sec. 5.2.2) it was concluded by the staff that seepage from the cooling lake will not affect groundwater quality for users outside the site boundary. The staff has not changed its conclusion. Seepage from the lime sludge pond, which was not discussed in the FES-CP, is also expected to have a negligible effect on groundwater quality for users outside the site boundary.

This is because the amounts of soluble chemicals available for seepage from the pond will be small and because the pond will be nearly dry much of the time (Sec. 4.2.6.1).

5.3.2.2 Thermal Since the issuance of the FES-CP, the applicant has modified the station water use and the circulating-water discharge structure design as described in Section 4.2.4. The staff has evaluated the impacts of these modifications and concludes that they would result in insignificant changes in the behavior of the thermal plume in Wolf Creek Cooling Lake and that the applicant's and the staff's hydrothermal analyses, as presented in Section 5.3 of the FES-CP, remain valid.

5.3.3 Floodplain Aspects Construction of the Wolf Creek Generating Station, which, with the cooling lake significantly alters the floodplain upstream of the dam, had already begun at the time Executive Order 11988, Floodplain Management, was signed in May 1977. It is therefore the staff's conclusion that consideration of alternatives to the modification of Wolf Creek as caused by the cooling lake dam is neither required nor practicable.

Wolf Creek FES 5-5

8 i

The following paragraphs address the floodplain-related effects of the cooling I lake dam, which include a greatly increased 100 year floodplain on Wolf Creek i upstream of the dam.

1 The 100 year (one percent chance per year) flood peak discharge on Wolf Creek 3

i below the dam site before construction was estimated to be 237 m /s (8363 cfs).

The area above and below the dam site along Wolf Creek inundated by the 100 year i

flood prior to construction of the dam is shown in Figure 5.1 (Ref. 1). The 100 year flood with the dam in place results in a spillway discharge of 26 m3 /s (928 cfs). The water surface elevation in +'a cooling lake would be 332.2 m (1089.80 ft) MSL. The area inundated by the backwater effect of the 100 year flood above the cooling lake dam, along with the applicant's property boundary, is shown in Figure 5.2. As shown, the 100 year floodplain boundary is within the applicant's property boundary. The 100 year flood flows in Wolf Creek below the cooling lake dam will be considerably smaller, compared to the peak

flood flows prior to construction of the cooling lake, because of the available storage capacity of the cooling lake above the normal lake operating level of

, 331.3 m (1087.0 ft) MSL.

1 Structures within the post construction 100 year floodplain include: the circulating water screenhouse and discharge structures, and the aakeup water i

discharge structure in the cooling lake; the makeup water screentouse on the Neosho River below John Redmond Dam; and offsite roads and railroad tracks i crossing Long Creek, Scott Creek, Crooked Creek and Taucket Creek. The exis-4 tence of these structures has an insignificant effect on the 100 year flood I level within the cooling lake, Neosho River, and adjacent streams, and will i

not af fect flood levels outside the property boundary.

1 Portions of the intake and discharge structures have been designed to be

, located below the 100 year flood levels. However, the plant has been designed to withstand the flooding effects of the Probable Maximum Flood (PMF), which reaches an elevation of 333.8 m (1095.0 ft) MSL. Safety related equipment necessary to shut down the station and maintain it in a shutdown condition are flood protected up to a;. elevation of 335.3 m (1100.2 ft) MSL.

The staff therefore concludes that the construction of the plant will not have any significant adverse flood effects either upstream or downstream of the dam.

5.4 AIR QUALITY 5.4.1 Fog and Ice '

The staff's prediction of operational impacts of the cooling lake on air quality remain essentially the same as described in the FES-CP (Sec. 5.6.6).

This includes influence of the cooling lake on average temperature, relative humidity, and frequency of fog.

A preoperational fog-monitoring program (outlined in the ER-OL, RQ 450.1, and Section 5.4.3) will document the frequency of occurrence of natural fog as

, opposed to fogs induced by the operation of the cooling lake. Should it be j shown that steam fog from the operation of the cooling lake heat-dissipation system creates highway-traffic safety problems, the applicant will be required Wolf Creek FES 5-6

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to take mitigative action. These mitigative measures, if needed, should be coordinated with local highway safety agencies.

5.4.2 Other Emissions As stated in the FES-CP (Sec. 5.5.1.1), nonradioactive atmospheric pollutants (e.g., oxides of nitrogen and sulfur dioxide) produced by operation of emergency diesel engines and the auxiliary steam boiler should not have a significant impact on air quality in the vicinity of the plant.

5.4.3 Atmospheric Monitoring The operational phase of the onsite meteorological measurements program will be essentially the same as the preoperational program described in the FES-CP.

Wind speed and wind direction will be measured at the 10-m (33-ft) and 60-m (200-ft) levels; vertical temperature gradie.c will be measured between the 10-m and 60 m levels; and dry-bulb temperature will be measured at the 10-m level. The applicant has stated that a preoperational fog-monitoring program would be initiated in 1982 and that a fog-monitoring program would continue through the first refueling. Fog visiometer measurements will be made in the area of the highest calculated occurrence of fog due to cooling pond operation.

Visiometer measurements will be continuously recorded on strip charts. The proposed program should adequately measure the increased fogging due to plant operation. Results of the fog monitoring program should be reviewed by the applicant and staff to determine the need for mitigative actions.

5.5 ECOLOGY 5.5.1 Terrestrial 5.5.1.1 Station Site Routine operation of the WCGS is not likely to entail significant additional land clearing or similar disturbances. Thus, the expected operational impacts on the existing vegetation will be primarily limited to onsite utility corridors and the land area within the 453-ha (1120-acre) exclusion zone surrounding the WCGS reactor (Fig. 4.1). The composition and structure of vegetation in these areas will be selectively controlled to be compatible with the function and security of station facilities (ER-OL, Sec. 2.8.3.1) and the general landscape of the area (ER-CP, Sec. 3.1.3). The vegetation within a 200-ha (500-acre) buffer zone surrounding the cooling lake will be retained in, or allowed to develop toward a natural state; i.e., naturally occurring biotic communities (ER-OL, Sec. 2.8.3.2). Seepage through peripheral embankments (saddle dams) of the cooling lake is expected to create small wetland habitats in areas exterior to the embankments.

Both terrestrial and aquatic plant communities will become established in peripheral areas within the cooling-lake impoundment; however, boundaries between the two vegetation types will flue.tuate because of natural phenomena and/or manipulated changes in water level within the impoundment. The nature of the affected vegetation and the effects of cooling-lake management under various hydrologic conditions are discussed in the FES-CP (Sec. 5.5.1.2).

During subfreezing conditions, steam emissions from the lake may cause formation of rime ice on vegetation within and adjacent to the impoundtent; however, damage to plants will likely be infrequent and localized.

Wolf Creek FES 5-9

In view of the foregoing, the staff concludes that operation of the WCGS and onsite facilities will not cause appreciable and continuing degradation of local vegetation. It follows that the wildlife-carrying capacity of local terrestrial environments will likewise be relatively unaffected, although the kinds and extent of terrestrial wildlife habitat available within the cooling-lake impoundment will vary due to cyclic manipulation of lake water levels.

Land areas within the property boundaries of the WCGS site that are not required for station operation will be utilized - "to the extent practical" - consistent with use that occurred prior to the applicants purchase of the site (ER-OL, Section 2.4.8.2). Thus it is unlikely that the future wildlife carrying capacities of these areas will appreciably differ from those of the past.

The filling and continued operation of the cooling lake will perpetuate the marked change in wildlife populations that will frequent the WCGS site.

Discussion of waterfowl and other avifaunal use of habitat resources within

the lake impoundment and the potential for depredation on local agricultural crops is presented in the FES-CP (Sec. 5.5.1.2). Also noted, station operation will preclude ice formation on most of the lake during the winter. This condition will tend to defer fall migration of waterfowl and other birds, as well as induce some species to overwinter in the area, thereby increasing competition for local food resources. However, food sources may be inadequate or unavailable during some years when early and/or unseasonably heavy snowfalls occur, thus necessitating forced dispersion of waterfowl from the area by repeated disturbance using aircraft, boats, or other scare tactics. The heated condition of lake waters may also enhance the potential for development of disease pathogens, including those of waterfowl. The potential for occur-rence of epidemic conditions is probably low. Further, in the absence of epidemic outbreaks, the identification of potential etiological agents may be difficult even under laboratory conditions (Refs. 2,3). Accordingly, the staf f has elected not to require monitoring of potential pathogens. However, in the event of a serious disease problem that is attributable to station operation, the applicant is required to initiate actions specified in Sec-tion 6.1. The staff recommends that the applicant consult with representatives of appropriate wildlife agencies to establish a contingency plan for preventing or controlling a waterfowl disease episode.

Tall structures of the WCGS complex, including onsite transmission lines, will continue to present obstacles to flying birds. The staff expects that bird impingements on facilities in the immediate vicinity of the station will be of minor consequence. Potential impingements on transmission lines are discussed below in Section 5.5.1.2. Limited numbers of some wildlife species will also be hit by vehicles associated with project operation. The staff concurs with conclusions presented in the FES-CP (Sec. 5.5.1.1) that nonradiological gaseous '.

emissions and noise levels associated with station operation will not appre-ciably impact local biota.

l 5.5.1.2 Energy-Transmission System Discussion of periodic maintenance of transmission-line corridors presented in  !

the FES-CP (Sec. 5.5.1.2) remains appropriate, although the applicant has l since qualified proposed use of herbicides. Accordingly, herbicides used for l corridor maintenance will be limited to herbicides approved by the U.S. EPA and the State at the time of such maintenance (ER-OL, Sec. 9.3.4).

Wolf Creek FES 5-10 l

l

The staff has reevaluated the potential for bird collisions with project transmission facilities. Meyer and Lee (Ref. 4) report that transmission facilities located in or near water bodies represent a " worst case situation" with respect to bird collisions. Less than 1% of the WCGS transmission system extends over waterways (FES-CP, Table 4.2); however, the proximity of trans-mission lines to the WCGS cooling lake is pertinent (Fig. 4.3), especially since the ice-free condition of the lake is expected to indum delayed fall migrations and overwintering of birds in the area (Sec. 5.5.1.1). Among other relevant studies, Anderson (Ref. 5) has reported surveys of bird collisions with transmission lines at a cooling lake (Lake Sangchris) in central Illinois.

He estimates that during each fall-winter period, as many as 400 waterfowl and an undetermined number of other birds may be impinged on transmission lines that traverse a 32-ha (80-acre) slag pit (settling pond). Numerous site-specific and other variables preclude meaningful extrapolations concerning potential bird collisions at the WCGS cooling lake. However, given that the applicant has committed to monitoring wildlife use of the lake (ER-OL, Sec. 6.2.4.2),

the staff recommends that a general survey program for waterfowl collision events be incorporated into the proposed monitoring program to determine if mitigation is warranted. If necessary, actions specified in Section 6.1 (item c) should be undertaken.

The staff has also reevaluated the potential environmental impacts associated with operation of the WCGS transmission system. The applicant asserts that design specifications of the system equal or exceed safety standards or prac-tices incorporated into the National Electric Safety Code (ER-CP, Sec. 3.9.2).

Such standards serve to safeguard persons and animals beneath operational transmission lines from shock hazards. Also, clearances between energized and grounded components of transmission facilities are such as to essentially preclude electrocution of birds, including large raptors. Other potential sources of impacts associated with energy transmission include corona discharge and the creation of induced electrical currents and electrical fields.

The princ' pal environmental effects resulting from corona discharge that may be biologically significant include audible noise and the production of ozone.

Noise eaissions from most 345-kV transmission lines are barely audible above ambient noise levels even during periods of foul weather (Ref. 6). Testimony presented during New York Public Service Commission hearings indicates general agreement among experts that ozone produced during operation of EHV (765-kV) transmission lines is insufficient to cause significant biological effects (Ref. 6). Accordingly, the staf f concludes that effects of corona discharge will not appreciably jeopardize the biota of WCGS transmission rights-of-way.

The reported biological or health effects resulting from electrical fields associated with energy transmission have been reviewed by the staff (Refs. 7-9).

Mhile experimental investigations of electrical field effects are ongoing, the staff has found no current substantive evidence that operation of the WCGS 345 kv transmission system will result in significant effects to the health of humans or local plants and animals.

5.5.2 Aquatic Discussion of affected aquatic biota presented in the ER-OL (Sec. 2.2.2) and summarized in Section 4.3.4.2 of this statement incorporates supplemental information derived from aquatic monitoring conducted subsequent to issuance Wolf Creek FES 5-11

of the FES-CP in 1975. In view of this information and considerations of changes in design specifications and operational characteristics of project facilities, the staff has reviewed potential impacts on aquatic environments.

5.5.2.1 John Redmond Reservoir and Tailwaters Area

! In general, evaluations of the potential operational impacts on aquatic biota of the John Redmond Reservoir - tailwaters area presented in the FES-CP I

(Sec. 5.5.2.2) remain valid. Accordingly, the principal sources of impact involve withdrawal of WCGS makeup water from the tailwaters area and the entrainment and/or impingement of aquatic biota at the water intake structure.

The makeup water withdrawals required for WCGS operation are estimated by the applicant to be equivalent to an average withdrawal rate of 1.3 m3 /s (46.9 cfs)

(ER-OL, Table 3.3-1). This rate is about 3.4% of the annual average discharge

[37.9 m3/s (1337 cfs)] from John Redmond Reservoir as reported in 1969 (FES-CP, Sec. 5.5.2.2). Further, the estimated withdrawal rate (1.3 m3 /s) is about 2.7% of the average monthly flow rate [48.3 m3 /s (1705 cfs)] during the period 1965 to 1977 at a Neosho River gauging station located about 5.3 river miles (8.5 km) downstream from the John Redmond dam (ER-OL, Sec. 5.1.2.2).

l In view of the foregoing, the staff concludes that water withdrawals for WCGS operation will not cause unacceptable effects on aquatic biota of the Redmond Reservoir-Neosho River system during normal hydrologic conditions. However, during a severe and prolonged drought, the commitment whereby the applicant will be allowed to withdraw water from the system at the rate of 1.16 m3/s (41 cfs) could result in a marked drawdown of water levels within the res-ervoir and reduced flows in the river. Such conditions would stress aquatic communities, including fish populations, as discussed in the FES-CP, Sec-tions 5.5.2.1 and 5.5.2.2.

Fish and drift organisms, including fish larvae and eggs, entrained in flows through pipes within the dam structure, as well as organisms entrained in spillway overflows, are currently and will continue to be displaced from the John Redmond Reservoir. These and similar aquatic life forms resident in the i tailwaters area will be subject to entrainment and/or impingement at the makeup water intake facility. The design approach velocity of water entering t the screenhouse of the intake structure is 0.15 m/s (0.5 ft/s) (ER-OL, Sec. 5.1.3.5.2.2) and should minimize fish impingements on the traveling screens. However, as noted in the FES-CP (Sec. 5.5.2.2), fish subject to i entrainment and displacement from the reservoir may be disoriented or other-l wise incapacitated. Thus, large fish, as well as slower-swimming juveniles, will be subject to impingement. The applicant has committed to a one year monitoring study of impingement at the makeup water screenhouse during the lake-filling process. The study was initiated November 1980 (ER-OL, RQ 291.22),

and the results of the study were forwarded to NRC in March, 1982 (Ref. 54).

The following is a summary and discussion of the reported results.

Based on collections during 33 sampling dates, the calculated estimate of the total impingement for the 12 month study period included 105,465,103 fish.

The corresponding weight of impinged fish was estimated to be 1,403,086 kilograms I

(3,093,243 lbs). A total of 22 taxa were were involved; however, over 99.5%

l of the estimated total number of impinged fish were gizzard shad, predominately young-of-the year. Estimated totals for other more frequently impinged species Wolf Creek FES 5-12

. _ - - . . .= - . = _ -

l 1

were reported as follows: white bass, 244,747; freshwater drum, 239,355; white crappie, 7,318; channel catfish, 5,429; and smallmouth buffalo, 2,098. Of the total impingement for these species, over 98% were classified as immature individuals. The other 16 taxa identified during the study were represented by a combined total of less than 1,000 fish. Most of the impingement occurred in winter months, peaking in February; the total impinged shad for the month was nearly 80 million fish. The staff considers it pertinent to note that the January and February estimates of impingement are based on a single sampling

date, whereas most of the monitoring effort occurred during Nay through July when about 3,000 fish were impinged. In view of the substantial impingement losses reported, it would seem prudent to continue monitoring fish impingements at least during the initial years of WCGS operation. It would also seem prudent to increase the frequency of winter sampling to better document impingement losses and establish whether the high impingement rates that occurred during lake filling are to be expected during WCGS operation.

The plankton biomass entrained in the makeup water system will be totally displaced from the Neosho River. To some extent, this loss will be offset by drift organisms returned to the river in discharges from the cooling lake via Wolf Creek. However, the staff concurs with the conclusion presented in the a FES-CP (Sec. 5.5.2.2) to the effect that net loss of plankton from the Neosho River does not represent a significant impact.

5.5.2.2 Wolf Creek Cooling Lake Aquatic biota of the cooling lake will be subject to a number of operational impacts, including thermal effects resulting from heated effluents discharged from reactor cooling systems. As noted in Section 4.2.4, the design flow rates of the station's circulating-water and service-water systems have been changed since the issuance of the FES-CP (Sec. 3.4). Thus, during a fully operational mode, the combined rise in temperatures of circulating- and service-water discharges to the cooling lake would be 16.4C (29.6F ) above intake temperatures, a slight increase over the comparable temperature rise of 16.0C (28.8F ) previously reported (Sec. 4.2.6.3). However, the staff does not believe that considerations of this small temperature increase would meaningfully alter conclusions presented in the FES-CP (Sec. 5.5.2.3) with respect to thermal characteristics of the cooling lake. Discussions in the FES-CP of thermal effects on aquatic biota also remain appropriate, as do the evaluations of cold-shock effects on fish due to reactor shutdowns.

Discussion of some water quality characteristics that may affect aquatic biota i of the Wolf Creek cooling lake is presented in the FES-CP (Sec. 5.5.2.3).

Conclusions are that concentrations of total dissolved solids and sulfate, the-generation of hydrogen sulfide, and discharges of sanitary wastes are unlikely to significantly impact biota of the cooling lake. The staff concurs with these conclusions. On the other hand, the periodic use of chlorine as a biofouling agent (Sec. 4.2.6.1) will create a hazard for organisms frequenting the cooling-water-discharge area. The applicant has reported that the total residual chlorine at the discharge outlet is expected to range between 0.68 and 1.08 mg/L for three 30-minute periods per day of operation (Sec. 4.2.6.1).

g Although chlorine concentrations will dissipate to levels of 0.01 mg/L in areas removed from the outlet, the expected concentrations in the discharge i areas will be well in excess of the U.S. EPA criterion of 0.01 mg/L necessary l

Wolf Creek FES 5-13

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4 1

i for adequate protection of freshwater biota (Ref. 10). Total residual i

chlorine in excess of 0.1 mg/L is reported unsafe for many freshwater organisms (FES-CP, Sec. 5.5.2.3). Fish and other motile species will tend to avoid the discharge area only during the warmer months of the year (ER-OL, Table 3.4-2).

Thus the staff concludes that appreciable mortality among chlorine-sensitive

species of aquatic biota could occur in the immediate vicinity of the discharge

! outlet to the lake, especially during periods when temperatures of the discharge i plume are relatively low. The applicant has reported that the area in which l aquatic biota could be adversely affected by chlorinated effluents from WCGS

~

has been " conservatively" estimated at 16 ha or 40 acres (ER-OL, Sec. 51.3.2.1.6).

I The staff agrees that the estimate is conservative. The staff would also agree that the potential impacts associated with the proposed chlorination treatments would not meaningfully affect the overall biological productivity of the cooling lake.

Corrosion products from cooling-system components such as pipes and heat exchangers will be discharged to the cooling lake (Sec. 4.2.6.1); these corro-

! sion products include chromium (Cr), iron (Fe), and nickel (Ni). Soluble

! fractions of these metals will increase the ambient concentrations in the cooling lake. Estimated values of some water quality parameters expected to occur in the cooling lake during WCGS operation under both normal and drought hydrologic conditions are included in Table 4.2. The drought conditions represent a worst-case situation with respect to potentials for causing toxic effects to aquatic biota. Thus, the estimated concentrations of soluble Fe (0.20 mg/L) and Cr (0.021 mg/L) shown in Table 4.2 are of interest. As noted in Section 5.3.2.1, ambient Ni concentrations were not reported by the applicant; thus, the value for Ni shown in Table 4.2 represents contributions from corro-sion only. However, based on other information sources (e.g., Refs. 11-13), it

]

appears unlikely that average Ni concentrations (ambient plus the corrosion fraction) in the cooling lake would exceed 0.025 mg/L. The staff has reviewed water quality criteria proposed by the U.S. Environmentai Protection Agency (Refs. 10,14) and concludes that the aforementioned concentrations of soluble 4 Fe, and Ni will not significantly impact aquatic biota of the cooling lake.

The estimated concentration of Cr (0.021 mg/L) in the cooling lake is pertinent

to the following excerpt of the U.S. EPA; i.e., to protect freshwater aquatic l life, the concentration for total recoverable hexavalent CR should not exceed  !

O.021 mg/L at any time. Comparable concentrations for the less toxic trivalent Cr range from 2.2 to 9.9 mg/L depending on water hardness. These criteria "should protect most, but not necessarily all aquatic life" (Ref. 14, Section 5). )

! However it is unlikely that all of the Cr included in the staff's estimate of I O.021 Mg/L would be in a hexavalent form. Accordingly, the staff concludes j that increases in the concentrations of Fe, Ni and Cr in the cooling lake attributable to WCGS operation are not expected to adversely affect aquatic biota, even during periods of prolonged drought when concentrations of these chemicals will be higher than normal.

Design changes in the WCGS cooling system subsequent to issuance of the FES-CP have various implications as concerns entrainment and impingement impacts on aquatic biota of the cooling lake. A principal implication involves the emplacement of a steel plate at the sump inlet to the circulating water screen-house (ER-OL, Sec. 3.4. 3. 2, Fig. 3. 4-9). This steel plate extends from the

! operating floor of the screenhouse at 333 m (1092 ft) MSL downward to elevation l 328 m (1075 ft) MSL. Thus, velocities of intake water downstream of the steel plate are essentially independent of water levels in the cooling lake. Based j l

Wolf Creek FES 5-14 j

on a total (circulating plus service water) design intake of water at 34 m 3/s (1204 cfs), the applicant estimates that the average velocities of water flows approaching the screenhouse and traveling screens will be 0.26 m/s (0.87 ft/s) and 0.32 m/s (1.06 ft/s), respectively. These velocities are about twice those used in FFS-CP analysis (Sec. 5.5.2.3). The reduction in design flow in circulating water (Sec. 4.2.4) is also pertinent, since entrained organisms will be subject to temperature rises of up to 17.5C (3L SF ) during passage through the plant condensers (Sec. 4.2.6.3), and therefore summer temperatures up to 32.7 C (116.5 F) (ER-OL, Table 3.4-2). The comparable summer maximum reported in the FES-CP (Sec. 5.5.2.3) is 31.6 C (114.3 F). In conclusion, the staf f believes that overall entrainment and impingement impacts will be more severe than would be predicted on the basis of thermal data and intake flow rates used in the FES-CP (Sec. 5.5.2.3) analysis.

5.5.2.3 Wolf Creek and the Wolf Creek-Neosho River Confluence Evaluations of WCGS operational effects on aquatic biota of Wolf Creek and Wolf Creek-Neosho River confluence presented in the FES-CP (Sec. 5.5.2.1) remain appropriate. In addition, during drought-induced low flows in Wolf Creek with little or no releases from the cooling lake, fish and other aquatic biota frequenting the pools in the creek bed will be subject to low oxygen levels, high chemical concentrations, and severe winter kills due to ice formation. The staff also notes that releases (blowdown) from the cooling lake to the Neosho River via Wolf Creek will be subject to specifications included in the NPDES permit (Appendix B). Adherence to specifications of the permit should adequately protect aquatic biota of the Wolf Creek-Neosho River confluence.

5.6 ENDANGERED AND THREATENED SPECIES Wintering bald eagles may utilize fish of the Wolf Creek cooling lake as a food source, since most of the lake will be ice-free during the winter. This species may also use towers of the WCGS transmission system as hunting perches.

However, the design of the transmission facilities is such as to essentially preclude electrocution of large birds (Sec. 4.2.7). Eagles could be impinged on transmission facilities while in flight; however, Kroodsma (Ref. 15) reports that most of the relatively few reported eagle mortalities associated with transmission lines are due to electrocution rather than impingement. In conclusion, the staff does not expect that operation of the WCGS will jeopardize wintering populations of bald eagles.

The peregrine falcon has been reported to occur in the area (Appendix H), but the species was not observed during extensive surveys by the applicant (Sec. 4.3.5). Likewise, the isolated sightings of prairie falcon, least tern, and northern crayfish frog (Sec. 4.3.5) are not considered sufficient to establish a meaningful presence of these species in the area. Thus the staff foresees no reasonable circumstances whereby operation of the WCGS would significantly affect populations of the aforementioned species.

No Neosho madtoms and only mature blue suckers were collected from the tail-waters area below the John Redmond dam during fish-monitoring studies of 1976-1977 (Ref. 16). Neither the Neosho madTom nor the blue sucker were collected during a 12 month fish impingement study conducted by the applicant during lake-filling operations, as discussed in Section 5.5.2.1. On this Wolf Creek FES 5-15

Table 5.1. Ilolf Creek Generating Station Ad Valorem Tax Estimates, 1985-1989 1985 198t> 1987 1988 1989 4 of TOTE t of ME 4 of ME t of 1OTAL t of 10TAL WGS TAX REVEMES M TAX MVEMES nG S TAX REVtMES lE S TAX REVDAES nGS DX RDDEES TAXDG JURISDICrim ,

593,089 3.61 600,166 3.59 5 606,155 3.57 $ -612,200 3.55 5 618,411 3.53 State of Kamas S 5 6,576,910 89.30 6,642,726 88.82 6,709,070 88.34 6,776,197 87.86 Cof fey Courty 6,499,187 89.61 4turahips 246 41.21 236 41.99 2 38 41.75 241 41.62 243 41.33 Avon 1,400 97.83 1,414 97.32 1,356 99.27 1,373 98.99 1, 386 98.44 Haaph:n 500 41.08 500 40.45 500 43.03 500 42.37 500 41.74 Puttm atomae ' 48.54 201 48.32 204 48.43 Star 194 48.87 197 48.76 199 Unif ami Sduol Dastr acts 33,379 5.36 33,780 5.34 34,081 5.30 No. 243 32,778 5.43 33,079 5.39 5,071,103 95.44 5,121,778 94.92 5,173,035 94.40 5,214,721 93.89 tu. 244 5,011,288 95.78 34,013 5.20 32,139 5.22 32,987 5.28 33,332 5.25 33,672 5.22 tb. 245 us 4

m Cenetar1 Districts 48.84 127 48.47 129 48 x 130 48.15 131 47.64 Altamont 126 604 45.69 586 46.40 592 46.13 598 45.93 tkuman-M<pte 579 46.58 264 52.30 276 53.18 279 52.94 282 52.71 Pleasart Hill 2 72 53.23 3,074 97.64 3,104 97.27 2,980 99.33 3,014 98.95 3,045 98.42 Stnngtan 34 11.22 35 11.36 35 11.22 32 10.88 34 11.41 Wharton wtershuds .03 11 .03 11 .03 11 .04 11 .04 31 No. 24 4.19 688 4.17 694 4.14 635 4.03 675 4.21 6 81

.10 lb. 48

.10 63 .10 64 .10 65 62 .10 63 43.56 No. 90 4,0 27 44.77 4,053 4 4.36 4,078 4 3.95 4,104 No. 93 3,983 4 4.97 Firu Districts 4.92 600 4.89 606 4.87 5 81 4.96 588 4.95 5 94 1,304 No. 5 1,304 11.55 1,304 11.38 11.20 1,334 11.92 1,304 11.73 No. 40 saatteast Kansas Regional 202,119 53.69 204,135 53.40 206,171 53.11 197,668 54.16 200,042 53.97 Labrary

$12,652,600 $12,779,100 $12,906,900

$12,379,000 $12,527,300 Tctal from ER-OL, Rev. 2, Table 3.10.7-1.

i l

Table 5.2.

Estimated Ad Valorem Taxes to Be Paid to Counties through which WCGS Transmission Lines Pass (thousands of dollars)

Caffey Anderson Butler Franklin Year County Greenwood Johnson Lion Miami County County County County County

'Ibtal County County All Counties 1985 12,379 34 66 116 77 17 5 48 12,743 1986 12,527 34 70 118 81 17 12 49 12,909 1987 12,653 35 71 119 82 17 12 50 13,038 1988 12,779 35 72 120 83 18 13 50 13,169 1989 12,907 35 72 121 84 18 13 50 13,300 OlHER ESTIMATED TAXES 1987 m

($000) h Fe&ral Incone S92,945 Kansas, Incone & Franchise 32,600 Missouri, Incme & Gross Receipts 10,021 From ER-OL, Rev. 2, Table 310.7-2.

D

i basis, the staff concludes that it is unlikely that Neosho River populations of these two species will be jeopardized by impingement at the makeup water 4 intake located in the tailwaters area.

The amount of makeup water withdrawn from the tailwaters area is unlikely to significantly affect populations of Neosho madtom and blue sucker in downstream portions of the Neosho River during periods of normal or above-normal hydrologic conditions in the upstream watershed. However, the withdrawal of makeup water  !

at the rate of 1.16 m 3/s (41 cfs) during drought conditions would extend the duration and severity of low-flow conditions in the downstream portions of the l

Neosho River. Reductions of riffle habitat during low-flow conditions would adversely affect populations of the small Neosho madtom (Ref. 17). Decreased current velocity that permits siltation is reported unfavorable for blue sucker populations. All fish would be subject to overcrowding, with attendant advantages for the larger, predacious fish. Overgrazing of aquatic flora that j serves as protective cover for small fish would also favor predacious species.

l Additional discussion presented in the FES-CP (Sec. 5.5.2.1) is also relevant.

As noted in Section 4.3.5, the presence of the warty-back mussel in the Neosho River immediately downstream from the John Redmond dam is not established.

However, if present, this species would also be adversely affected by decreased available habitat and sedimentation during low-flow conditions.

! 5.7 HISTORIC AND ARCHEOLOGICAL SITES i

The staf f concludes that operation of the station will not result in any significant impact on historic and archeological sites in the area as there are none 3resently known. The State Historic Preservation Officer has stated that "No historic sites or buildings will be affected by the construction or ,

operation" of the Wolf Creek Generating Station (see Appendix I).

)

l 5.8 SOCI0 ECONOMICS Socioeconomic impacts of station operation on the community are discussed in

. Sections 5.6 and 10.4 of the FES-CP. The staff notes no significant changes j in these impacts save for the following. The primary socioeconomic effects of the station's operation are employment and tax revenues. The applicant esti-mates that the permanent operating staff will be comprised of 325 workers with 4

an annual payroll of $6.8 million (1980 dollars) (ER-OL, 8.1.2.1). Because of j

the number of operating staff, the impact on the infrastructure of the communities j

in which they reside and on traffic is expected to be minimal. The staff )

estimates that the number of operating and maintenance employees required will be approximately 25% greater than estimated by the applicant. Projections resulting from using this higher staff estimate will be increased at the same ratio.

l Tax revenues from the first five full years of operation of WCGS are shown in i Table 5.1. WCGS will pay revenues to a variety of county jurisdictions including townships, school districts, cemetery districts, watersheds, fire districts, and a regional library. This is in addition to revenues paid to the state's education and institutions building fund and to Coffey County. The amount of revenue to be paid these jurisdictions in 1985 ranges from a low of $11 to a high of $6.5 million. These values are also expressed as a fraction of the taxing jurisdictions' total revenues. Table 5.2 contains estimates of taxes Wolf Creek FES 5-18

paid to counties through which the transmission lines pass. Estimates for 1987 income and franchise taxes are also contained in that table (ER-OL, RQ 310.7). All tax data are presented in current dollars.

It is also estimated that the local purchases will not exceed $25,000 per year (current dollars) during the plant's operation (ER-OL, RQ 310.6) resulting only in a small impact to the area. The areas of visual intrusion, FES-CP Section 3.1 and 5.1, and noise, FES-CP Section 5.6, are not expected to differ significantly from their previous analyses.

5.9 RADIOLOGICAL IMPACTS 5.9.1 Regulatory Requirements Nuclear power reactors in the United States must comply with certain regulatory .

requirements in order to operate. The permissible levels of radiation in i unrestricted areas and of radioactivity in ef fluents to unrestricted areas are recorded in 10 CFR Part 20, Standards for Protection Against Radiation (Ref. 18)

These regulations specify limits on levels of radiation and limits on concen-trations of radionuclides in the station's effluent releases to the air and wato (above natural background), under which the reactor must operate. These regulations state that no member of the general public in unrestricted areas shall receive a radiation dose, due to Station operation, of more than 0.5 rems in one calendar year, or if an individual were continously present in an area, 2 mrems in any one hour or 100 mrems in any seven consecutive days to the total body. These radiation-dose limits are established to be consistent with considerations of the health and safety of the public.

In addition to the Radiation Protection Standards of 10 CFR Part 20, there are recorded in 10 CFR Part 50.36a (Ref. 19) license requirements that are to be imposed on licensees in the form of Technical Specifications on Effluents from Nuclear Power Reactors to keep releases of radioactive materials to unrestricted

! areas during normal operations, including expected operational occurrencet as low as is reasonably achievable (ALARA). App (1 dix I of 10 CFR Part 50 provides numerical guidance on dose-design objectives for LWRs to meet this ALARA i requirement. Applicants for permits to construct and licenses to operate an LWR shall provide reasonable assurance that the following calculated dose-design objectives will be met for all unrestricted areas: 3 mrems/yr to the total body or 10 mrems/yr to any organ from all pathways of exposure from liquid effluents; 10 mrads/yr gamma radiation or 20 mrads/yr beta radiation air dose from gaseous effluents near ground level--and/or 5 mrems/yr to the total body or 15 mrems/yr to the skin from gaseous effluents; and 15 mrems/yr to any organ from all pathways of exposure from airborne effluents that include the radioiodines, carbon-14, tritium, and the particulates.

Enperience with the design, construction and operation of nuclear power reactors indicates that compliance with these design objectives will keep average annual releases of radioactive material in effluents at small percentages of the limits specified in 10 CFR Part 20, and in fact, will result in doses generally below the dose-design objective values of Appendix I.

At the same time, the licensee is permitted the flexibility of operation, compatible with considerations of health and safety, to assure that the public is provided a dependable source of power even under unusual operating conditions which may temporarily result in releases higher than such small percentages, but still well within the limits specified in 10 CFR Part 20.

Molf Creek FES 5-19

i I

f In addition to the impact created by station radioactive effluents as discussed above, within the NRC policy and procedures for environmental protection l described in 10 CFR Part 51 there are generic treatments of environmental effects of all aspects of the Uranium Fuel Cycle. These environmental data have been summarized in Table S-3 and are discussed later in this report in Section 5.10. In the same manner the environmental impact of transportation of fuel and waste to and from an LWR is summarized in Table 5.4 of Section 5.9.3.

Recently an additional operational requirement for Uranium-Fuel-Cycle Facilities including nuclear power plants has been established by the EPA in 40 CFR Part 190 (Ref. 20). This regulation limits annual doses (excluding radon and daughters) for members of the public to 25 mrems total body, 75 mrems thyroid, and 25 mrems other organs from all fuel-cycle facility contributions that may j impact a specific individual in the public.

5.9.2 Operational Overview During normal operations of the Wolf Creek Generating Station, small quantities of radioactivity (fission and activation products) will be released to the environment. As required by NEPA, the staff has determined the dose estimated to members of the public outside of the station boundaries due to the radiation from these radioisotope releases and relative to natural background radiation dose levels.

1 i These station generated environmental dose levels are estimated to be very 4

small due to station design and the development of a program which will be implemented at the station to contain and control all radioactive emissions and effluents. As mentioned in Section 4.2.5, highly efficient radioactive-waste management systems are incorporated into the station design and are

specified in detail in the Technical Specifications for the station. The effectiveness of these systems will be measured by process and effluent radio-logical monitoring systems that permanently record the amounts of radioactive constitutents remaining in the various airborne and waterborne process and effluent streams. The amounts of radioactivity released threugh vents and discharge points to be further dispersed and diluted to points outside the i

station boundaries are to be recorded and published semiannually in the Radio-active Effluent Release Reports of each facility.

The small amounts of airborne effluents that are released will diffuse in the atmosphere in a fashion determined by the meteorological conditions existing at the time of release and are generally much dispersed and diluted by the

, time they reach unrestricted areas that are open to the public. Similarly, i

the small amounts of waterborne effluents released will be diluted with station waste water and then further diluted as they mix with the cooling lake and the Neosho River beyond the station boundaries. l Radioisotopes in the station's ef fluents that enter unrestricted areas will produce doses through their radiations to members of the general public similar j to the doses from background radiations (i.e., cosmic, terrestrial and internal j radiations), which also include radiation from nuclear weapons fallout. These 3 radiation doses can be calculated for the many potential radiological exposure i

pathways specific to the environment around the station, such as direct radi- i ation doses fro' the gaseous plume or liquid effluent stream outside of the I

Wolf Creek FES 5-20 '

station boundaries, or internal radiation dose commitments f rom radioactive contaminants that might have been deposited on vegetation, or in meat and fish products eaten by people, or that might be present in drinking water outside the station, or incorporated into milk f rom cows at nearby f arms.

These doses, calculated for the " maximally exposed" individuai (i.e., the hypothetical individual potentially subject to maximum exposure), form the basis of the NRC staff's evaluation of impacts. Actually, these estimates are for a fictitious person because assumptions are made that tend to overestimate the dt se that would accrue to members of the public mRside the station bound-aries. For example, if this " maximally exposed" india 1 dual were to receive the total body dose calculated at the station boundary due to external exposure to the gaseous plume, he/she is assumed to be physically exposed to gamma radiation at that boundary for 70% of the year, an unlikely occurrence.

Site-specific values for the various parameters involved in each dose pathway are used in the calculations. These include calculated or observed values for the amounts of radioisotopes released in the gaseous and liquid effluents, meteorological information (e.g., wind speed and direction) specific to the site topography and effluent release points, and hydrological information pertaining to dilution of the liquid effluents as they are discharged.

An annual land census will identify changes in the use of unrestricted areas to permit modifications in the programs for evaluating doses to individuals from principal pathways of exposure. This census specification will be incorporated into the Radiological Technical Specifications and satisfies the requirements of Section IV.B.3 of Appendix I to 10 CFR Part 50. As use of the land surrounding the site boundary changes, revised calculations will be made to ensure that the dose estimate for gaseous effluents always represents the highest dose that might possibly occur for any individual member of the public for each applicable foodchain pathway. The estimate considers, for example, where people live, where vegetable gardens are located, and where cows are pastured.

An extensive radiological environmental monitoring program, designed specifically for the environs of Wolf Creek provides measurements of radiation and radioactive contamination levels that exist outside of the facility boundaries both before and after operations begin. In this program, oifslie radiation levels are continuously monitored with thermoluminescent detectors (TLDs). In addition, measurements are made on a number of types of samples from the surrounding area to determine the possible presence of radioactive contaminants which, for example, m'ght be deposited on vegetation, be present in drinking water outside the plant, or be incorporated into cow's milk from nearby farms. The results for all radiological environmental samples measured during a calendar year of operation are recorded and published in the Annual Radiological Environmental Operating Report for the facility. The specifics of the final operational-monitoring program and the requirement for annual publication of the monitoring results will be incorporated into the operating license Radiological Technical Specifications for the Wolf Creek facility.

Wolf Creek FES 5-21

s i

I I

I GASEOUS EFFLUENT (Diluted by Dispersion)

NUCLEAR POWER PLANT 5E O LIQUID EFFLUENT

? Q #' (Diluted ty Mixing

- in Liquus Streams)

}(

e

}3-

o. - -

i t's,,\ \ =

l 1

?

1 Q

7 .,%

• o, D-

,,,ed \~\(\ '_

{ FUEL TRANSPORT

~~

t 4CL'. . ss ,en,, ,

No,'&&<r, to -

.~

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G Q @ @ C'**  %,

",Mtp&dbabG c3 ,%,'e. %og_~

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g, ^,,geuoa f / _- j' 3  % s c,--... 8 $- [

4

=( -

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<e 4 Figure 5.3. Potentially Meaningful Exposure Pathways to Individuals.

5-22

I 5.9.3 Radiological Impacts from Routine Operations 5.9.3.1 Radiation Exposure Pathways: Dose Commitments There are many environmental pathways through which persons may be exposed to radiation originating in a nuclear power reactor. All of the potentially meaningful exposure pathways are shown schematically in Figure 5.3. When an individual is exposed through one of these pathways, his dose is determined in 4

part by the amount of time he is in the vicinity of the source, or the amount of time the radioactivity is retained in his body. The actual effect of the radiation or radioactivity is determined by calculating the dose commitment.

This dose commitment represents the total dose that would be received over a 50 yr period, following the intake of radioactivity for 1 year under the conditions existing 15 years after the station begins operation (i.e., the mid point of station operation). However, with few exceptions, most of the internal dose commitment for each nuclide is given during the first few years af ter exposure due to turnover of the nuclide by physiological processes and

.! radioactive decay.

1 There are a number of possible exposure pathways to man that can be studied to determine whether the routine releases at the Wolf Creek site are likely to have any significant impact on members of the general public living and working outside of the site boundaries, and whether the releases will in fact meet regulatory requirements. A detailed listing of these possibilities would include external radiation exposure from the gaseous effluents, inhalation of

' iodines and particulate contaminants in the air, drinking milk from a cow or

eating meat from an animal that feeds on open pasture near the site on which iodines or particulates may have deposited, eating vegetables from a garden near the site that may be contaminated by similar deposits, and drinking water or eating fish caught near the point of discharge of liquid effluents.

l Other less significant pathways include: external irradiation from radio-nuclides deposited on the ground surface, eating animals and food crops raised near the site using irrigation water that may contain liquid effluents, shore-line, boating and swimming activities near lakes or streams that may be con-taminated by effluents, and direct radiation from within the station itself.

Calculations of the effects for most pathways are limited to a radius of 80 km (50 mi). This limitation is based on several facts. Experience has shown that all significant dose commitments (>0.1 mrem /yr) for radioactive effluents are accounted for within a radius of 80 km from the station. Beyond 80 km the doses to individuals are smaller than 0.1 mrem /yr, which is far below natural-background doses, and the doses are subject to substantial uncertainty because of limitations of predictive mathematical models.

The NRC staff has made a detailed study of all of the above significant pathways and has evaluated the radiation-dose commitments both to the station workers and the general public for these pathways resulting from routine operation of the station. A discussion of these evaluations follows.

~

5.9.3.1.1 Occupational Radiation Exposure for PWRs r Most of the dose to nuclear plant workers results from external exposure to 1

radiation from radioactive materials outside of the body rather than from Wolf Creek FES 5-23

internalexposurefromInhaledoringested[adioactivematerials. , Experience shows that the dose to nuclear plant workers varies from reactor to reactor and from year to year. For environmental-impact pur' poses, it can.be projected by using the experience to date with modern PWRs. Recently Elicensed 1000-MWe PWRs are operated in accordance with the post-1975 regulatory requirements and guidance that place increased emphasis on maintaining occuoational' exposure at, nuclear power plants ALARA. These requirements and guidance are catlineds ,

primarily in 10 CFR Part 20 (Ref. 18) Standard Review Plan Chapter 1R -

(Ref. 21) and Regulatory Guide 8.8 (Ref. 22) ,

The applicant's proposed implementation of these requirements and guidelines-is reviewed by the NRC staff during the licensfr.g process, and the results.of, that review are reported in the staff's Safety Evaluation Reports. The license is granted only after the review indicates that an ALARA program can be implemented. In addition, regular reviews of operating plants are performed to determine whether the ALARA requirements are being met.

Average collective occupational dose information for 239 PWR reactor years of operation is available for those plants operatlng between 1974 and'1980. (The ,

year 1974 was chosen as a starting date because the dose data for years prior to 1?74 are primarily from reactors with average rated capacities of below 500 MWe.) These data indicate that the average reactor annual dose at PWRs has been about 440 person-rems, with some plants experiencing an average plant lifetime annual dose to date as high as 1300 person-rems (Refs. 23,24).

These dose averages are based on widely varying yearly doses at PWRs. For example, for the period mentioned above,- annual collective doses fc.- PWRs have ranged from 18 to 5262 person-rems per reactor. However, the average annual dose per nuclear plant worker of about 0.8 rem (Ref. 23) has not varied signi-ficantly during this period. The worker dose limit, established by 10 CFR Part 20, is 3 rems / quarter (if the average dose over-the worker lifetime is being controlled to 5 rems /yr) or 1.25 rems / quarter if it is not.

The wide range of annual collective doses experienced at U.S. PWRs results from a number of factors, such as the amount of required maintenance, and the amount of reactor operations and in plant surveillance. Because these factors can vary widely and unpredictably, it is impossible to determine in advance a specific year-to year annual occupational radiation dose for a particular plant over its operating lifetime. There may on occasion be a need for relatively high collective occupational doses, even at plants with radiation protection programs designed to ensure that occupational radiation doses will be kept ALARA.

In recognition of the ft ;rs mentioned above, staff occupational dose estimates for environmental impi.t (. wpsses for Wolf Creek are based on the assumption that the station n: w. ience the annual average occupational dose for PWRs to date. Thus tic M s projected that the occupational dose for Wolf Creek will be 440 sersom m s but could average as much as 3 to 4 times this value over the life of the station.

The average annual dose of about 0.8 rem per nuclear plant worker at operating BWRs and PWRs has been well within the limits of 10 CFR Part 20. However, for impact evaluation, the NRC staff has estimated the risk to nuclear power plant workers and compared it in Table 5.3 to risks that are published for other occupations. Based on these comparisons, the staff concludes that the risk to Wolf Creek FES 5-24

Table 5.3. Incidence of Job-Related Fatalities Fatality Incidence Rates Occupational Group (premature deaths per 105 person years)

Underground metal miners" s1300 Uranium miners" 420 a 190 Smelter workers .

b 61 Miniog

' b Agriculture, forestry, and fisheries 35 b 33 Contract construction Transportation and public utilities 24 c 23 Nuclear plant worker Manufacturing b 7 b 6 Wholesale and retail trade Finance, insurance, and real estate 3 b 3 Services b 10 Total private sector a ihe President's Report on Occupational Safety and Health, " Report on Occupa-tional Safety and Health by the U.S. Department of Health, Education, and Welfare," E. L. Richardson, Secretary, May 1972.

bU.S. Bureau of Labor Statistics, " Occupational Injuries and Illness in the United States by Industry, 1975," Bulletin 1981, 1978.

c The nuclear plant workers' risk is equal to the sum of the radiation-related risk and the nonradiation-related risk. The occupational risk associated with the industry-wide average radiation dose of 0.8 rem is about 11 potential premature deaths per 105 person years due to cancer (using the same risk estimators as used in Appendix G, " Impact of the Uranium Fuel Cycle"). The average nonradiation-related risk for seven U.S. electrical utilities over the period 1970-1979 is about 12 actual premature deaths per 105 person years as shown in Figure 5 of the paper by R. Wilson and E. S. Koehl, " Occupational Risks of Ontario Hydro's Atomic Radiation Workers in Perspective," presented at Nuclear Radiation Risks, A Utility-Medical Dialog, sponsored by the Inter-national Institute of Safety and Health in Washington, D.C., September 22-23, 1980. (Note that the estimate of 11 radiation-related premature cancer deaths describes a potential risk rather than an observed statistic.)

Molf Creek FES 5-25

nuclear plant workers from plant operation is comparable to the risks asso-ciated with other occupations.

3' In estimating the health effects resulting from both offsite (see Section 5.9.3.2) and occupational radiation exposures as a result of normal operation of this facility, the NRC staff used somatic (cancer) and genetic risk estimators that are based on widely accepted scientific information. Specifically, the staff's 4

' estimates are based on in'ormation compiled by the National Academy of Science's Advisory Committee on the Biological Effects of Ionizing Radiation (BEIR I).

The estimates of the risks to workers and the general public are based on con-servative assumptions (that is, the estimates are probably higher than the actual number). The following risk estimators were used to estimate health

effects

135 potential deaths from cancer per million person rems and 258 j potential cases of all forms of genetic disorders per million person-rems.

The cancer-mortality risk estimates are based on the " absolute risk" model i

! described in BEIR I. Higher estimates can be developed by use of the

" relative risk" model along with the assumption that risk prevails for the duration of life. Use of the " relative risk" model would produce risk values

' up to about four times greater than those used in this report. The staff regards the use of the " relative risk" model values as a reasonable upper limit of the range of uncertainty. The lower limit of the range would be zero because health effects have not been detected at doses in this dose-rate range.

The number of potential nonfatal cancers would be approximately 1.5 to 2 times i

i the number of potential fatal cancers, according to the 1980 report of the National Academy of Science's Advisory Committee in the Biological Effects of Ionizing Radiation (BEIR III).

Values for genetic risk estimators range from 60 to 1500 potential cases of

all forms of genetic disorders per million person-rems (BEIR I). The value of 258 potential cases of all forms of genetic disorders is equal to the sum of the geometric means of the risk of specific genetic defects and the risk of

defects with complex etiology.

The preceding values for risk estimators are consistent with the recommendations of a number of recognized radiation protection organizations, such as the Inter-national Commission on Radiological Protection (ICRP 1977), the National Council on Radiation Protection and Measurement (NCRP 1975), the National Academy of Sciences (BEIR III), and the United Nations Scientific Committee on the Effects of Atomic Radiation (UNSCEAR 1977).

The risk of potential fatal cancers in the exposed work-force population at the Wolf Creek facility and the risk of potential genetic disorders in all

, future generaticr.s of this work-force population, is estimated as follows:

j multiplying the annual plant-worker population dose (about 440 person-rems) by the risk estimators, the staff estimates that about 0.06 cancer deaths may occur in the total exposed population and about 0.11 genetic disorders may occur in all future generations of the same exposed population. The value of 0.06 cancer deaths means that the probability of one cancer death over the lifetime of the entire work force as a result of 1 year of facility operation

is about 6 chances in 100. The value of 0.11 genetic. disorders means that the probability of 0.11 genetic disorders in all future generations of the entire work force as a result of 1 year of facility operation is about 11 l chances in 100.

i Wolf Creek FES 5-26

5.9.3.1.2 Public Radiation Exposure.

Transportation of Radioactive Materials The transportation of " cold" (unirradiated) nuclear fuel to the reactor, of spent irradiated fuel from the reactor to a fuel reprocessing plant, and of solid radioactive wastes from the reactor to waste burial grounds is considered in 10 CFR Part 51.20 (Ref. 19). The contribution of the environmental effects of such transportatinn to the environmental costs i f licensing the nuclear power reactor is set forth in Summary Table S-4 from 10 CFR Part 51.20, repro-duced herein as Table 5.4. The cumulative dose to the exposed population as summarized in Tcal- S-4 is very small when compared to the annual dose of about 61,000 person-rems to this same population or 26,000,000 person-rems to the U.S. population from background radiation.

Direct Radiation for PWRs Radiation fields are produced around nuclear plants as a result of radioactivity within the reactor and its associated components, as well as a result of radioactive ef fluent releases. Direct radiation from sources within the plant are due primarily to nitrogen-16, a radionuclide produced in the reactor core.

Because the primary coolant of a PWR is contained in a heavily shielded area, dose rates in the vicinity of PWRs are generally undetectable (less than 5 mrems/yr).

Low-level radioactivity storage containers outside the station are estimated to make a dose contribution at the site boundary of less than 1% of that due to the direct radiation from the station.

Radioactive Effluent Releases: Air and Water As pointed out in an earlier section, all effluents from the station will be subject to extensive decontamination, but small controlled quantities of radioactive effluents will be released to the atmosphere and to the hydrosphere during normal operations. Estimates of site-specific radioisotope release values have been developed on the basis of the descriptions of operational and radwaste systems in the applicant's ER-OL and FSAR and by using the calcula-tional model and parameters developed by the NRC staff (Ref. 25). These have been supplemented by extensive use of the applicant's site and environmental data in the ER-OL and in subsequent answers to NRC staff questions, and should be studied to obtain an understanding of airborne and waterborne releases from the station.

These radioactive effluents are then diluted by the air and water into which they are released before they reach areas accessible to the general public.

Radioactive effluents can be divided into several groups. Among the airborne effluents the radioisotopes of the noble gases--krypton, xenon, and argon--do not deposit on the ground nor are they absorbed and accumulated within living organisms; therefore, the noble gas effluents act primarily as a source of direct external radiation eaanating from the effluer.t plume. Dose calculations are performed for the site boundary where the highest external-radiation doses to a member of the general public as a result of gaseous effluents have been estimated to occur; these include the total body and skin doses as well as the annual beta and gamma air doses from the plume at that boundary location.

Wolf Creek FES 5-27

Table 5.4. (Summary Table S-4) Environmental Impact of Transportation of Fuel and Waste to and from One Light-Water-Cooled Nuclear Power Reactorl seomadAL COssostl0NS OF TRAfssPCRT Heat {per frameted fuel Cask m transst)..

Emonmastalnwet 250.000 Stu/hr, w gni(gov.,ned ey rederei or State resinenons).. 73.000 ins. per truc=; i00 tons per cas= per rad car.

Traffe denssty Truc= . Lee. men i per day.

Aad . . . . . . .

Lees then 3 per month.

Esemated Rarge of doses to Cumulaeve dose to Exposed population number of exposed anecduate 8 exposed popuiamon persons (per reactor year) (per reactor year) 8 exposed Transportanon wortiers~

200 0.01 to 300 mdhrern. a marwom.

Generas out>c:

Oniookers . . . . . .

1.100 0 003 to 1.3 mdhrem 3 maswom.

Along Route . 600.000 0 0001 to 0.06 mdirem ACCsoE8sf5 aN TRA8eSPORT Emorvnerstat nsa Aamoiogeas erfects - Sman t Cornmon (nonraeo6ogcal) causes .. . . . . .

1 fatal mtury n 100 reactor years; 1 nonfatal antury n 10 re.

actor years. 5475 property damage per reactor year.

' Data supportmg ttvs ta06e are given a the Commrsason's "Errvronmental Survey of Transportanon of Raeoective Metenais to and from Nuclear Power Plants." WASH-1238. December 1972, and Supp.1. NUREG-75/038 Apne 1975. Both documents are avasacae for mspection and copyng at the Commrosen's Puche Document Room.1717 H St NW., Weehngton. 0.C., and may be obtamed from Nanonal Techncal informaton Sennce Sonngheid. Va. 22161. WASH-1238 ra avadatdo from NTIS at a cost of 55 a5 (mcrofche 52 25) and NUREG.75/038 as avedeces at a cost of 53 25 (mcrohche 52.25).

• The Federal Ramaton Couned has recommended that the raesson doses from ad sources of rametson other than natural eackground and meccal exposures shoued be hmrted to 5.000 mdhrem per year for ineviduaes as a resut of amg= manas expo.

sure and should De hrrvted to 500 mdhrem per year for mewduses a the general populaeon. The dose to enenduals due to average natures background rseatson is about 130 methrem per year.

8Marwom is an expresason for the summaton of who6e body dotes to menduals e a group Thus d each memcor of a a

popu aten group of f.000 peopse were to recesve a dose of 0 001 rem (1 mdhrem) or d 2 peop6e were to receeve a does of 0.5 rem (500 mdhrs n) eacn. the total marwom dose e each case would be 1 merwom.

• Althougn the opvronmental nsk of reso6ogcal effects stemmmg from transportahon accidents rs currentty a-N of Deeng numencady cuantifed, the nsk remams smed regarciess of whether it is Demg apphed to a smgse reactor or a mustreactor sde 5-28 '

Another group of airborne radioactive effluents -the radioiodines, carbon-14, and tritium--are also gaseous but tend to be deposited on the ground and/or absorbed into the body during inhalation. For this class of effluents, esti-mates of direct external-radiation doses from deposits on the ground, and of internal radiation doses to total body, thyroid, bone, and other organs from inhalation and from vegetable, milk, and meat consumption are made. Concen-trations of iodine in the thyroid and of carbon-14 in bone are of particular significance here.

A third group of airborne effluents, consisting of particulates that remain after filtration of airborne effluents in the station prior to release, includes fission products such as cesium and barium and corrosion activition products such as cobalt and chromium. The calculational model determines the direct external radiation dose and the internal radiation doses for these contaminants through the same pathways as described above for the radiciodines, carbon-14, and tritium. Doses from the particulates are combined with those of the radioiodines, carbon-14, and tritium for comparison to one of the design objectives of Appendix I to 10 CFR Part 50.

The waterborne radioactive effluent constituents could include fission products such as nuclides of strontium and iodine; activation products, such as nuclides of sodium and manganese; and tritium as tritiated water. Calculations estimate the internal doses (if any) from fish consumption, from water ingestion (as drinking water), and from eating of meat or vegetables raised near the site on irrigation water, as well as any direct external radiation from recreational use of the water near the point of discharge.

The release values for each group of effluents, along with site-specific meteorological and hydrological data, serve as input to computerized radiation-dose models that estimate the maximum radiation dose that would be received outside the facility via a number of pathways for individual members of the public, and for the general public as a whole. These models and the radiation dose calculations are discussed in Regulatory Guide 1.109 (Ref. 26) and in Appendix D of this statement.

Examples of site-specific dose assessment calculations and discussions of parameters involved are given in Appendix C. Doses from all airborne effluents except the noble gases are calculated for the location (e.g., site boundary, garden, residence, milk cow, meat animal) where the highest radiation dose to a member of the public from all applicable pathways has been established.

Only those pathways associated with airborne ef' Jents that are known to exist at a single location, are combined to calculate .he total maximum exposure to an exposed individual. Pathway doses associated with liquid effluents are combined without regard to any single location, but they are assumed to be associated with maximum exposure of an individual through other than gaseous-effluent pathways.

5.9.3.2 Radiological Impact on Humans Although the doses calculated in Appendix C are based on radioactive-waste treatment system capability, the actual radiological impact associated with the operation of the station will depend, in part, on the manner in which the radioactive waste treatment system is operated. Based on its evaluation of Wolf Creek FES 5-29 1

the potential performance of the ventilation and radwaste treatment systems, the NRC staff has concluded that the systems as now proposed are capable of controlling effluent releases to meet the dose-design objectives of Appendix I to 10 CFR Part 50 (Ref. 19)

The station's operation will be governed by operating license Technical Speci-fications which will be based on the dose-design objectives of Appendix I to 10 CFR Part 50 (Ref. 19). Since these design objective values were chosen to permit flexibility of operation while still ensuring that station operations are ALARA, the actual radiological impact of station operation may result in doses close to the dose-design objectives. Even if this situation exists, the individual doses for the member of the public subject to maximum exposure will still be very small when compared to natural background doses (s100 mrems/yr) or the dose limits specified in 10 CFR Part 20 (500 mrems/yr - total body).

As a result, the staff concluded that there will be no measurable radiological impact on any member of the public from routine operation of the station.

Operating standards of 40 CFR Part 190, the Environmental Protection Agency's Environmental Radiation Protection Standards for Nuclear Power Operations (Ref. 20), specify that the annual dose equivalent must not exceed 25 mrems to the whole body, 75 mrems to the thyroid, and 25 mrems to any other organ of any member of the public as the result of exposures to planned discharges of radioactive materials (radon and its daughters excepted) to the general environment f rom all uranium-fuel cycle operations and radiation from these operations that can be expected to affect a given individual. The NRC staff concluded that under normal operations the Wolf Creek site is capable of operating within these standards.

The radiological doses and dose commitments resulting from a nuclear power plant are well known and documented. Accurate measurements of radiation and radioactive contaminants can be made with very high sensitivity so that much smaller amounts of radioisotopes can be recorded than can be associated with any possible observable ill effects. Furthermore, the effects of radiation on living systems have for decades been subject to intensive investigation and consideration by individual scientists as well as by select committees, occasionally constituted to objectively and independently assess radiation dose effects. Although, as in the case of chemical contaminants, there is debate about the exact extent of the effects of very low levels of radiation that result from nuclear power plant effluents, upper bound limits of deleter-ious effects are well established and amenable to standard methods of risk analysis. Thus the risks to the maximally exposed member of the public outside of the site boundaries or to the total population outside of the boundaries can be readily calculated and recorded. These risk estimates for the Wolf Creek facility are presented below.

The risk to the maximally exposed individual is estimated by multiplying the risk estimators presented in Section 5.9.3.1.1 by the annual dose-design object-ives for total-body radiation in 10 CFR Part 50, Appendix I. This calculation results in a risk of potential premature death from cancer to that individual i

from exposure to radioactive effluents (gaseous or liquid) from 1 year of reac-tor operations of less than one chance in one million." The risk of potential l

• The risk of potential premature death from cancer to the maximally exposed individual from exposure to radiciodines and particulates would be in the same range as the risk from exposure to the other types of effluents.

Wolf Creek FES 5-30

premature death from cancer to the average individual within 80 km (50 mi) of the reactors from exposure to radioactive effluents from the reactors is much less than the risk to the maximally exposed individual. These risks are very small in comparison to natural cancer incidence from causes unrelated to the operation of the Wolf Creek facility.

Multiplying the annual U.S. general public population dose from exposure to radioactive effluents and transportation of fuel and waste from the operation of this facility (that is, 49 person-rems) by the preceding risk estimators, the staff estimates that about 0.007 cancer deaths may occur in the exposed population and about 0.013 genetic disorders may occur in all future generations of the exposed population. The significance of these risk estimates can be determined by comparing them to the natural incidence of cancer death and genetic abnormalities in the U.S. population. Multiplying the estimated U.S.

population for the year 2000 (s260 million persons) by the current incidence of actual cancer fatalities (s20%) and the current incidence of actual genetic diseases (s6%), about 52 million cancer deaths and about 16 million genetic abnormalities are expected (BEIR I; American Cancer Society, 1978). The risks to the general public from exposure to radioactive effluents and transportation of fuel and wastes from the annual operation of the Wolf Creek facility are very small fractions (less than one part in a billion) of the estimated normal incidence of cancer fatalities and genetic abnormalities in the year 2000 population.

On the basis of the preceding comparison (that is, comparing the risk from exposure to radioactive effluents and transportation of fuel and waste from the annual operation of this facility with the risk from the estimated incidence of cancer fatalities and genetic abnormalities in the year-2000 populatien) the staff concludes that the risk to the public health and safety from exposure to radioactive effluents and the transportation of fuel and wastes from normal operation of the Wolf Creek facility will be very small.

5.9.3.3 Radiological Impacts on Biota Other Than Humans Depending on the pathway and radiation source, terrestrial and aquatic biota will receive doses that are approximately the same or somewhat higher than humans receive. Although guidelines have not been established for acceptable limits for radiation exposure to species other than human, it is generally agreed that the limits established for humans are sufficiently protective for other species.

Although the existence ; extremely radiosensitive biota is possible and increased radiosensitivity in organisms may result from environmental inter-actions with other stresses (for example, heat or biocides), no biota have yet been discovered that show a sensitivity (in terms of increased morbidity or mortality) to radiation exposures as low as those expected in the area sur-rounding the station. Furthermore, at all nuclear plants for which radiation exposure to biota other than humans has been analyzed (Ref. 27), there have been no cases of exposure that can be considered significant in terms of harm io the species, or that approach the limits for exposure to members of th(

pubiic that are permitted by 10 CFR Part 20 (Ref. 18). Inasmuch as the 1972 BEIR Report (Ref. 28) concluded that evidence to date indicated no other Wolf Creek FES 5-31

living organisms are very much more radiosensitive than humans, no measurable radiological impact on populations of biota is expected as a result of the routine operation of this station.

5.9.3.4 Radiological Monitoring Radiological environmental monitoring programs are established to provide data on measurable levels of radiation and radioactive materials in the site environs.

Such monitoring programs are conducted to verify the effectiveness of in plant systems used to control the release of radioactive me' eials and to ensure that unanticipated buildups of radioactivity will not ot.ur in the environment.

Secondarily, the monitoring programs could identify the highly unlikely exist-ence of unmonitored releases of radioactivity. An annual surveillance (Land Census) program will be established to identify changes in the use of unrestric-ted areas to provide a basis for modifications of the monitoring programs or of the Technical Specifications conditions that relate to the control of doses to individuals.

These programs are discussed generically in NRC Regulatory Guide 4.1, Rev. 1, " Programs for Monitoring Radioactivity in the Environs of Nuclear Power Plants" (Ref. 29), ano the Radiological Assessment Branch Technical Position, Rev. 1, November 1979, "An Acceptable Radiological Environmental Monitoring Program" (Ref. 30).

5.9.3.4.1 Preoperational The preoperational phase of the monitoring program should provide for the measurement of background levels of radioactivity and radiation and their var-iations along the anticipated important pathways in the areas surrounding the station, the training of personnel and the evaluation of procedures, equipment and techniques. The applicant proposed a radiological environmental-monitoring program to meet these objectives in the ER-CP and it was discussed in the FES-CP. This early program has been updated and expanded; it is presented in Section 6.1.5 of the applicant's ER-OL and is summarized here in Table 5.5.

The applicant states that the preoperational program has been implemented, at least two years prior to initial criticality of Unit 1, to document background levels of direct radiation and concentrations of radionuclides that exist in the environment. The preoperational program will continue up to the initial criticality of Unit 1 at which time the operational radiological monitoring program will commence. l The staff has reviewed the preoperational environmental monitoring plan of the applicant and finds that it is acceptable as presented. l 5.9.3.4.2 Operational l

The operational, offsite radiological-monitoring program is conducted to i measure radiation levels and radioactivity in station environs. It assists and provides backup support to the effluent-monitoring program as recommended in NRC Regulatory Guide 1.21, " Measuring, Evaluating and Reporting Radicactivity in Solid Wastes and Releases of Radioactive Materials in Liquid and Gaseous

Ef fluents from Light-Water Cooled Nuclear Power Plants" (Ref. 31).

Wolf Creek FES 5-32

l l

Table 5.5.

PRE 0PERATIONAL RADIOLOGICAL ENVIRONMENTAL MONITORING PROGRAM

SUMMARY

Number of Samples Exposure Pathway and Sampling and Type and Frequency and/or Sample Sample Locations Collection Frequency of. Analysis

1. AIkBORNE Radiciodine and 8 locations Continuous operation Radioiodine canister.

Particulates of sampler with sample Analyze weekly for collection as required for I-131.

by dust loading but at least weekly. Analyze for gross beta ,

radioactivity at least L, 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> following fil- w ter change. Perform gamma isotopic analysis on each sample when gross beta activity is

> 10 times the yearly mean of control samples.

Perform gamma isotopic analysis on composite (by location) once per quarter.

38 TLD locations within Quarterly at each Gamma dose quarterly.

2. DIRECT RADIATION 5-mile radius of site location.

and two offsite locations; two TLD dosimeters at each location.

Table 5.5. cont.

Number of Samples Exposure Pathway and Sampling and Type and Frequency and/or Sample Sample Locations Collection Frequency of Analysis

3. WATERBORNE

a. Surface One upstream location Monthly composite Monthly gamma isotopic and one downstream analysis. Quarterly location below Wolf tritium analysis of Creek Dau outfall. composite sample.

b. Ground 3 locations at C-10, Quarterly quarterly gamma iso- yi C-49, D-65, 1 control topic and tritium g location at B-12 analysis.

(see Figure 6.1-7, ER-OL. )

e

c. Drinking Municipal water sup- Monthly composite Monthly gross beta and plies at Burlington, gamma isotopic analysis.

Le Roy, New Strawn, Quarterly tritium analy-and a control at sis of composite sample.

Ila rtfo rd

d. Sediment from i sample from cooling Semiannually Semiannual gamma iso-Shoreline lake discharge cove, topic analysic.

1 sample from south end of cooling lake, 1 control location at John Redmond Reservoir Q

Composite samples shall .be collected by collecting an aliquot at intervals not exceeding 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />.

Table 5.5 cont.

I

(

Number of Samples Sampling and Type and Frequency Exposure Pathway and of Analysis Sample Locations Collection Frequency and/or Sample

4. INGESTION Semimonthly when Gamma isotopic and

a. Milk Three locations with animals are on pasture; I-131 analysis of each highest dose poten- sample.

tial; control at monthly at other times, Y'

Hartford Semiannually Gamma isotopic analysis

b. Fish and 1 rough, 1 game fish on edible portions.

Invertebrates sample from Wolf Creek Cooling Reservoir similar samples from John Redmond Reservoir spillway as control Broad leaf vegetation Monthly during harvest. Gamma isotopic analysis

c. Food Producte on edible portions.

samples at site bound-ary in sector with highest D/Q or two locations with highest dose potential; control at Hartford

l The applicant states that the operational program will in essence be a continu-ation of the preoperational program described above, with some periodic adjust-ment of sampling frequencies in expected critical exposure pathways---such as increasing milk sampling frequency and deletion of fruit, vegetable, soil, and gamma radiation survey samples. The proposed operational program will be j reviewed prior to station operation. Modification will be based upon anomalies and/or exposure pathway variations observed during the preoperational program.

The final operational-monitoring program proposed by the applicant will be reviewed in detail by the NRC staff, and the specifics of the required moni-toring program will be incorporated into the Operating License Radiological Technical Specifications.

1 i 5.9.4 Environmental Impact of Postulated Accidents

5. 9. 4.1 Plant Accidents

The staff has considered the potential radiological impacts on the environment l of possible accidents at the Wolf Creek Generating Station Unit No.1 in accordance wth a Statement of Interim Policy published by the Nuclear Regula-tory Commission on June 13, 1980 (Ref. 32). The following discussion reflects j these considerations and conclusions.

Section 5.9.4.2 deals with general characteristics of nuclear power plant

accidents including a brief summary of safety measures to minimize the prob-i i

ability of their occurrence and to mitigate their consequences if they should occur. Also described are the important properties of radioactive materials and the pathways by which they could be transported to become environmental hazards. Potential adverse health effects and impacts on society associated with actions to avoid such health effects are also identified.

l Next, actual experience with nuclear power plant accidents and their observed i

health effects and other societal impacts are described. This is followed by

! a summary review of safety features of the Wolf Creek Unit 1 facility and of

, the site that act to mitigate the consequences of accidents.

The results of calculations of the potential consequences of accidents that have been postulated in the design basis are then given. Also described are the results of calculations for the Wolf Creek Unit 1 site using probabilistic methods to estimate the possible impacts and the risks associated with severe accident sequences of exceedingly low orobability of occurrence.

5.9.4.2 General Characteristics of Accidents The term " accident," as used in this section, refers to any unintentional event not addressed in Section 5.9.3 that results in a release of radioactive materials into the environment. The predominant focus, therefore, is on events that can lead to releases substantially in excess of permissible limits for normal operation. Such limits are specified in the Commission's regula-tions at 10 CFR Part 20, and 10 CFR Part 50, Appendix I.

Wolf Creek FES 5-36

There are several features that combine to reduce the risk associated with accidents at nuclear power plants. Safety features in the design, construc-tion, and operation comprising the first line of defense are to a very large extent devoted to the prevention af the release of these radioactive materials from their normal places of confinement within the plant. There are also a number of additional lir.c of defense that are designed to mitigate the conse-quences of failures in the first line. Descriptions of these features for the Wolf Creek Unit 1 plant may be found in the applicant's Final Safety Analysis Report (Ref. 33), and in the staff's Safety Evaluation Report (Ref. 34). The most important mitigative features are described in Section 5.9.4.4(1) below.

These safety features are designed taking into consideration the specific locations of radioactive materials within the plant, their amounts, their nuclear, physical, and chemical properties, and their relative tendency to be transported iato and for creating biological hazards in the environment.

(1) Fission Product Characteristics By far the largest inventory of radioactive material in a nuclear power plant is produced as a byproduct of the fission process and is located in the uranium oxide fuel pellets in the reactor core in the form of fission products.

During periodic refueling shutdowns, the assemblies containing these fuel pellets are transferred to a spent-fuel storage pool so that the second largest inventory of radioactive material is located in this storage area. Much smaller inventories of radioactive materials are also normally present in the water that circulates in the reactor coolant system and in the systems used to process gaseous and liquid radioactive wastes in the plant.

These radioactive materials exist in a variety of physical and chemical forms.

Their potential for dispersion into the er.vironment depends not only on mechanical forces that might physically transport them, but also upon their inherent properties, particularly their volatility. The majority of these materials exist as nonvolatile solids over a wide range of temperatures.

Some, however, are relatively volatile solids and a few are gaseous in nature.

These characteristics have a significant bearing upon the assessment of the environmental radiological impact of accidents.

The gasous materials include radioactive forms of the chemically inert noble gases krypton and xenon. These have the highest potential for release into the atmosphere. If a reactor accident were to occur involving degradation of the fuel cladding, the release of substantial quantities of these radioactive gases from the fuel is a virtual certainty. Such accidents are very low fre-quency but credible events (see Sec. 5.9.4.3). It is for this reason that the safety analysis of each nuclear power plant incorporates a hypothetical design-basis accident that postulates the release of the entire contained inventory of radioactive noble gases from the fuel into the containment structure. If further released to the environment as a possible result of failure of safety features, the hazard to individuals from these noble gases would arise predomi-nantly through the external gamma radiation from the airborne plume. The reactor containment structure is designed to minimize this type of releate..

Wolf Creek FES 5-37 l l

Radioactive forms of iodine are formed in substantial quantities in the fuel by the fission process and in some chemical forms may be quite volatile. For these reasons, they have traditionally been regarded as having a relatively high potential for release from the fuel. If released to the environment, the principal radiological hazard associated with the radioiodines is ingestion into the human body and subsequent concentration in the thyroid gland. Because of this, its potential for release to the atmosphere is reduced by the use of special systems designed to retain the iodine.

The chemical forms in which the fission product radioiodines are found are

, generally solid materials at room temperatures, however, so that they have a strong tendency to condense (or " plate out") upon cooler surfaces. In addi-tion, most of the iodine compounds are quite soluble in, or chemically reactive with, water. Although these properties do not inhibit the release of radio-iodines from degraded fuel, they do act to mitigate the release from contain-ment structures that have large internal surface areas and that contain large quantities of water as a result of an accident. The same properties affect the behavior of radioiodines that may " escape" into the atmosphere. Thus, if rainfall occurs during a release, or if there is moisture on exposed surfaces, e.g., dew, the radioiodines will show a strong tendency to be absorbed by the moisture.

Other radioactive materials formed during the operation of a nuclear power plant have lower volatilities and therefore, by comparison with the noble

, gases and iodine, a much smaller tendency to escape from degraded fuel unless 1 the temperature of the fuel becomes very high. By the same token, such materials, if they escape by volatilization from the fuel, tend to condense quite rapidly to solid form again when transported to a lower temperature region and/or dissolve in water when present. The former mechanism can have the result of producing some solid particles of sufficiently small size to be carried some distance by a moving stream of gas or air. If such particulate materials are dispersed into the atmosphere as a result of failure of the containment barrier, they will tend to be carried downwind and deposit on surface features by gravitational settling or by precipitation (fallout),

where they will become " contamination" hazards in the environment.

All of these radioactive materials exhibit the property of radioactive decay

, with characteristic half-lives ranging from fractions of a second to many days j or years (see Table 5.6). Many of them decay through a sequence or chain of decay processes and all eventually become stable (nonradioactive) materials.

The radiation emitted during these decay processes is the reason that ?y are hazardous materials.

(2) Exposure Pathways The radiation exposure (hazard) to individuals is determined by their proximity to the radioactive materials, the duration of exposure, and factors that act i

to shield the individual from the radiation. Pathways for the transport of radiation and radioactive materials that lead to radiation exposure hazards to humans are generally the same for accidental as for " normal" releases. These are depicted in Section 5.9.3, Figure 5.3. There are two additional possible pathways that could be significant for accident releases that are not shown in Figure 5.3. One of these is the fallout onto open bodies of water of radio-Wol f Creek FES 5-38

Table 5.6 Activity of Radionuclides in a Wolf Creek Unit 1 Reactor Core at 3565 MWt Radioactive Inventory Group /Radionuclide in Millions of Curies Half-Life (Days)

A. NOBLE GASES Krypton-85 0.62 3,950 Krypton-85m 27 0.183 Krypton-87 52 0.0528 Krypton-88 76 0.117 Xenon-133 190 5.28 Xenon-135 38 0.384 B. 10 DINES Iodine-131 95 8.05 <

lodine-132 130 0.0958 Iodine-133 190 0.875 Iodine-134 210 0.0366 Iodine-135 170 0.280 C. ALKALI METALS Rubidium-86 . 0.029 18.7 Cesium-134 8.4 750 Cesium-136 3.3 13.0 Cesium-137 5.2 11,000 D. TELLURIUM-ANTIMONY Tellurium-127 6.6 0.391 Tellurium-127m 1.2 109 Tellurium-129 35 0.048 Tellurium-129m 5.9 34.0 Tellurium-131m 14 1.25 Tellurium-132 130 3.25 Antimony-127 6.8 3.88 Antimony-129 37 0.179 E. AKALINE EARTHS Strontium-89 100 52.1 Strontium-90 4.1 11,030 Strontium-91 120 0.403 Barium-140 180 12.8 F. COBALT AND NOBLE METALS Cobalt-58 0.87 71.0 Cobalt-60 0.32 1,920 Molybdenum-99 180 2.8 Technetium-99m 160 0.25 Ruthenium-103 120 39.5 Ruthenium-105 80 0.185 Ruthenium-106 28 366 Rhodium-105 55 1.50 Wolf Creek FES 5-39

Table 5.6. Continued Radioactive Inventory Group /Radionuclide in Millions of Curies Half-Life (Days)

G. RARE EARTHS, REFRACTORY OXIDES AND TRANSURANICS Yttrium-90 4.3 2.67 Yttrium-91 130 59.0 Zirconium-95 170 65.2 Zirconium-97 170 0.71 Niobium-95 170 35.0 Lanthanum-140 180 1.67 Cerium-141 170 32.3 Cerium-143 140 1.38 Cerium-144 95 284 Praseodymium-143 140 13.7 Neodymium-147 67 11.1 Neptunium-239 1800 2.35 Plutonium-238 0.063 32,500 Plutonium-239 0.023 8.9 x 108 Plutonium-240 0.023 2.4 x 108 Plutonium-241 3.8 5,350 Americium-241 0.0019 1.5 x 105 Curium-242 0.56 163 Curium-244 0.026 6,630 Note: The above grouping of radionuclides corresponds to that in Table 5.8.

activity initially carried in the air. The second would be unique to an accident that results in temperatures inside the reactor core sufficiently high to cause melting and subsequent penetrat on of the basemat underlying the reactor by the molten core debris. This creates the potential for the release of radioactive material into the hydrosphere through contact with ground water. These pathways may lead to external exposure to radiation, and to internal exposures if radioactive material is inhaled or ingested from contami-nated food or water.

It is characteristic of these pathways that during the transport of radio-active material by wind or by water the material tends to spread and disperse, like a plume of smoke from a smokestack, becoming less concentrated in larger volumes of air or water. The result of these natural processes is to lessen 3 the intensity of exposure to individuals downwind or downstream of the point

, of release, but they also tend to increase the number who may be exposed. For i a release into the atmosphere, the degree to which dispersion reduces the con-  ;

centration in the plume at any downwind point is governed by the turbulence  !

characteristics of the atmosphere which vary considerably with time and from place to place.

I Wolf Creek FES 5-40 1 . _ . .

- . . - ~- . . . . .-

1 This fact, taken in conjunction with the variability of wind direction and the presence or absence of precipitation, means that accident consequences are I very much dependent upon the weather conditions existing at the time, i

(3) Health Effects The cause-and effect relationships between radiation exposure and adverse health effects are quite complex (Refs. 35,36) but they have been more exhaus-tively studied than any other environmental contaminant.

4 Whole-body radiation exposure resulting in a dose greater than about 10 rem i

for a few persons and about 25 rems for nearly all people over a short period of time (hours) is necessary before any physiological effects to an individual are clinically detectable. Doses about 10 to 20 times larger than the latter dose, also received over a relatively short period of time (hours to a few days), can be expected to cause some fatal injuries. At the severe, but extremely low probability end of the accident spectrum, exposures of these magnitudes are theoretically possible for persons in the close proximity of such accidents if measures are not or cannot be taken to provide protection,

e.g., by sheltering or evacuation.

Lower levels of exposures may also constitute a health risk but the ability to define a direct cause-and effect relationship between any given health effect

! and a known exposure to radiation is dif ficult given the backdrop of the many other possible reasons why a particular effect is observed in a specific individual. For this reason, it is necessary to assess such effects on a i statistical basis. Such effects include randomly occurring cancer in the ,

exposed population and genetic changes in future generations after exposure of

a prospective parent. Occurrences of cancer in the exposed population may f begin to develop only after a lapse of 2 to 15 years (latent period) from the i time of exposure and then continue over a period of about 30 years (plateau period). However, in the case of exposure of fetuses (in utero), occurrences of cancer may begin to develop at birth (no latent period)-and end at age 10 (i.e.,

the plateau period is 10 years). The health consequences model currently being used is based on the 1972 BEIR Report of the National Academy of Sciences (Ref. 28).

The occurrence of cancer itself is not necessarily indicative of l fatality.

Most authorities agree that a reasonable, and probably conservative estimate of the randomly occurring number of health effects of Icw levels of radiation exposure to a large number of people is within the range of about 10 to

500 potential cancer deaths (although zero is not excluded by the data) per i million person-rems. The range comes from the latest hAS BEIR III Report (1980) (Ref. 37) which also indicates a probable value of about 150. This value is virtually identical to the value of about 140 used in the current NRC

! health effects models. In addition, approximately 220 genetic changes per million person-rems would be projected by BEIR III over succeeding generations.

That also compares well with the value of about 260 per million person-rems currently used by the NRC staff.

3 (4) Health Effects Avoidance l 1

Radiation hazards in the environment tend to disappear by the natural process of radioactive decay. Where the decay process is a slow one, however, and where the material becomes relatively fixed in its location as an environmental Wolf Creek FES 5-41 i

- _ , __ _ _ . - , _ - . . . _ _ ~ _ . _ _ _ _ - _ . _ __._. ___.

contaminant (e.g., in soil), the hazard can continue to exist for a relatively long period of time--months, years, or even decades. Thus, a possible conse-quential environmental societal impact of severe accidents is the avoidance of the health hazard rather than the health hazard itself, by restrictions on the use of the contaminated property or contaminated foodstuffs, milk, and drinking l water. The potential economic impacts that this can cause are discussed below.

i 5.9.4.3 Accident Experience and Observed Impacts The evidence of accident frequency and impacts in the past is a useful indica-tor of future probabilities and impacts. As of mid-1981, there were 71 commer-I cial nuclear power reactor units licensed for operation in the United States

, at 50 sites with power generating capacities ranging from 50 to 1130 MWe.

(The Wolf Creek Unit 1 plant is designed for 1150 MWe.) The combined experi-

ence with these units represents approximately 500 reactor years of operation

over an elapsed time of about 20 years. Accidents have occurred at several of these facilities (Refs. 38,39). Some of these have resulted in releases of radioactive material to the environment, ranging from very small fractions of

, a curie to a few million curies. None is known to have caused any radiation injury or fatality to any member of the public, nor any significant individual or collective public radiation exposure, nor any significant contamination of the environment. This experience base is not large enough to permit a reliable '

quantitative statistical inference. It does, however, suggest that signifi-cant environmental impacts caused by accidents are very unlikely to occur over l time periods of a few decades.

Melting or severe degradation of reactor fuel has occurred in only one of 4 these units, during the accident at Three Mile Island Unit 2 (TMI-2) on March 28, 1979. In addition to the release of a few million curies of xenon-133, it has been estimated that approximately 15 Ci of radioiodine was also released to the environment at TMI-2 (Ref. 40). This amount represents an extremely minute fraction of the total radioiodine inventory present in the reactor at the time of the accident. No other radioactive fission products i were released in measurable quantity.

i It has been estimated that the maximum cumulative offsite radiation dose to an i individual was less than 100 millirems (Refs. 40,41). The total population expo-i

' sure has been estimated to be in the range from about 1000 to 3000 person-rems.

This exposure could produce between none and one additional fatal cancer over the lifetime of the population. The same population receives each year from natural background radiation about 240,000 person-rems and approximately a

, half-million cancers are expected to develop in this group over its lifetime l (Refs. 40,41), primarily from causes other than radiation. Trace quantities j

(barely above the limit of detectability) cf radioiodine were found in a few samples of milk produced in the area. No other food or water supplies were impacted.

Accidents at nuclear power plants have also caused occupational injuries and a few fatalities but none attributed to radiation exposure. Individual worker exposures have ranged up to about 4 rems as a direct consequence of accidents (although there have been higher exposures to individual workers as a result of other unusual occurrences). However, the collective worker exposure levels (person-rems) are a small fraction of the exposures experienced during normal routine operations that average about 440 to 1300 person rems in a PWR and 740 to 1650 person-rems in a BWR per reactor year.

Wolf Creek FES 5-42

j Accidents have also occurred at other nuclear reactor facilities in the United States and-in other countries (Refs. 38,39). Because of inherent differences j in design, construction, operation, and purpose of most of these other facili-i ties, their accident record has only indirect relevance to current nuclear power plants. Melting of reactor fuel occurred in at least seven of these i accidents, including the one in 1966 at the Enrico Fermi Atomic Power Plant

} Unit 1. This was a sodium-cooled fast breeder demonstration reactor designed to generate 61 MWe. The damages were repaired and the reactor reached full

power in four years following the accident. It operated successfully and completed its mission in 1973. This accident did not release any radioactivity to the environment.

A reactor accident in 1957 at Windscale, England, released a significant I

quantity of radioiodine, approximately 20,000 Ci, to the environment. This j reactor, which was not operated to generate electricity, used air rather than water to cool the uranium fuel. During a special operation to heat the large amount of graphite in this reactor, the fuel overheated and radioiodine and 1

noble gases were released directly to the atmosphere from a 405-ft stack.

Milk produced in a 200-mi2 area around the facility was impounded for up to 1 44 days. This kind of accident cannot occur in a water--cooled reactor like i Wolf Creek Unit 1, however.

5.9.4.4 Mitigation of Accident Consequences Pursuant to the Atomic Energy Act of 1954, the Nuclear Regulatory Commission j has conducted a safety evaluation of the application to operate Wolf Creek Generating Station Unit 1. Although this evaluation contains more detailed information on plant design, the principal design features are presented in the following section.

(1) Design Features

The Wolf Creek Generating Station Unit 1 contains features designed to prevent j accidental release of radioactive fission products from the fuel and to lessen the consequences should such a release occur. Many of the design and operating specifications of these features are derived from the analysis of postulated events known as design-basis accidents. These accident preventive and mitiga-tive features are collectively referred to as engineered safety features (ESF). The possibilities or probabilities of failure of these systems is incorporated in the assessments discussed in Section 5.9.4.5(2).

The steel-lined concrete containment building is a passive mitigating system l that is designed to minimize accidental radioactivity releases to the environ-l ment. Safety injection systems are incorporated to provide cooling water to l the reactor core during an accident to prevent or minimize fuel damage. The containment spray system is designed to spray cool water into the containment j

atmosphere. The operation of the spray system af ter a loss-of-coolant accident (LOCA) would prevent containment-system overpressure by quenching the steam generated as a result of reactor coolant flashing into the containment atmo-sphere. The spray water also contains an additive (sodium hydroxide) that j will chemically react with any airborne radioiodine to remove it from the containment atmosphere and prevent its release to the environment.

4 Wolf Creek FES 5-43 4

The mechanical systems mentioned above are supplied with emergency power from onsite diesel generators in the event that normal offsite station powe.r is interrupted.

The fuel-handling area located in the fuel building also has accident mitigat-ing systems. The ventilation system contains both charcoal and high efficiency

particulate filters. This ventilation system is also designed to keep the i area around the spent-fuel pool below the prevailing barometric pressure during fuel-handling oparations so as to prevent exfiltration through building openings. If radioactivity were to be released from the building, it would be drawn through the ventilation system and most of the radioactive iodine and particulate fission products would be removed from the flow stream before exhausting to the environment.

There are features of the plant that are necessary for its power generation i

function that can also play a role in mitigating certain accident consequences.

For example, the main condenser, although not classified as an ESF, can act to i mitigate the consequences of accidents involving leakage from the primary to the secondary side of the steam generators (such as steam generator tube ruptures).

If normal offsite power is maintained, the ability of the plant to send con-taminated steam to the condenser instead of releasing it through the safety i valves or power-operated relief valves can significantly reduce the amount of

radioactivity released to the environment. In this case, the fission product-

removal capability of the normally operating water processing system would come into play.

! Much more extensive discussions of the safety features and characteristics of j the Wolf Creek plant may be found in the applicant's Final Safety Analysis Report (Ref. 33). The staff evaluation of these features is addressed in the Safety Evaluation Report (Ref. 34). In addition, the implementation of the lessons learned from the TMI-2 accident, in the form of improvements in design,

( and procedures and operator training, will significantly reduce the likelihood of a degraded core accident which could result in large releases of fission products to the containment. Specifically, the applicant will be required to meet those TMI-related requirements specified in NUREG-0737 (Ref. 42). As noted in Section 5.9.4.5(7), no credit has been taken for these actions and improvements in discussing the radiological risk of accidents.

'2) Site Features l The NRC's reactor site criteria, 10 CFR Part 100, requires that the site for every oower reactor have certain characteristics that tend to reduce the risk and pote tial impact of accidents. The discussion that follows briefly describes tha Wolf Creek site characteristics and how they meet these require-ments.

! First, the site has an exclusion area, as required by 10 CFR Part 100. The l total site area is about 3,973 ha (9,818 acred of the 4,808 ha (11,882 acres) owned by the applicant. The exclusion area, located d thin the site boundary, is a circular area with a 1,200-m (3937-ft) radius centered on the reactor containment. The applicant owns all surface and mineral rights in the exclu-sion area, and has the authority, required by Part 100, to determine all Wolf Creek FES 5-44

activities in the area. There are no residents within the exclusion area.

The exclusion area is not traversed by any public highway or railroad.

Easements through the exclusion area have been granted to:

1. United Telephone Company for telephone service to the plant.

2. Rural Electric Cooperative - for a 69-kV line out of the switchyard for local electric service.

There are no other activities unrelated to plant operation within the exclu-sion area.

Second, beyond and surrounding the exclusion area is a low population zone (LPZ), also required by 10 CFR Part 100. The LPZ for Wolf Creek is a circular area with a 4.0-km (2.5-mi) radius. Within this zone, the applicant must ensure that there is a reasonable probability that appropriate protective measures could be taken on behalf of the residents in the event of a serious accident. The applicant has estimated the 1980 population within the LPZ to be 130 persons. There are no schools or hospitals located in the LPZ. The transient population within the area is relatively low. In case of a radio-logical emergency, the plant has made ar angements to carry out protective actions, including evacuation of personnel in the vicinity of the nuclear plant. See also the following section on Emergency Preparedness.

Third, 10 CFR Part 100 also requires that the distance from the .eactor to the nearest boundary of a densely populated area containing more than about 25,000 residents be at least one and one-third times the distance from the j reactor to the outer boundary of the LPZ. Since accidents of greater potential l hazards than those commonly postulated as representing an upper limit are conceivable, although highly improbable, it was considered desirable to add the population center distance requirement in Part 100 to provide for protec- l tion against excessive exposure doses to people in large centers. The nearest l population center is the city of Emporia, Kansas, located about 45 km (28 mi) west-northwest of the site. The population of Emporia was 23,327 in 1970'and is estimated to have been 25,019 in 1980.

The population center distance is at least one and one-third times the LPZ outer radius. Current population densities within 16 km (10 mi) of the site is estimated to be 13 people per square mile (1970 census) and projected to reach a peak of 19.5 people per square mile by the year 2000 followed by a slight decline thereafter.

The safety evaluation of the Wolf Creek site has also included a review of potential external hazards, i.e., activities offsite that might adversely affect the operation of the plant and cause an accident. The reviews encom-passed nearby industrial, military and transportation facilities that might create explosive, missile, toxic gas or similar hazard. With the exception of shipments and onsite storage of chlorine, the review of which has not been completed by the staff, the risk to the Wolf Creek facility from such hazards has been found to be negligibly small.

A more detailed discussion of the compliance with the Commission's siting criteria and the consideration of external hazards will be reported in the staff's Safety Evaluation Report.

Wolf Creek FES 5-45

(3) Emergency Preparedness Emergency preparedness plans, including protective action measures for the Wolf Creek Unit 1 facility and environs, are in an advanced, but not yet fully completed stage. In accordance with the provisions of 10 CFR Section 50.47, effective November 3, 1980, no operating license will be issued to the appli-cant unless a finding is made by the NRC that the state of onsite and offsite emergency preparedness provides reasonable assurance that adequate protective measures can and will be taken in the event of a radiological emergency.

Among the standards that must be met by these plans are provisions for two Emergency Planning Zones (EPZ). A plume exposure pathway EPZ of about 16 km (10 mi) in radius and an ingestion exposure pathway EPZ of about 80 km (50 mi) in radius are required. Other standards include appropriate ranges of protec-tive actions for each of these zones, provisions for dissemination to the public of basic emergency planning information, provisions for rapid notifica-tion of the public during a serious reactor emergency, and methods, systems, and equipment for assessing and monitoring actual or potential offsite conse-quences in the EPZs of a radiological emergency condition.

NRC and the Federal Emergency Management Agency (FEMA) have agreed that FEMA will make a finding and determination as to the adequacy of State and local government Emergency Response Plans. NRC will determine the adequacy of the applicant's Emergency Response Plans with respect to the standards listed in j Section 50.47(b) of 10 CFR Part 50, the requirements of Appendix E to 10 CFR Part 50, and the guidance contained in NUREG-0654/ FEMA-REP-1, Revision 1,

" Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants," dated November 1980. After the above determinations by NRC and FEMA, the NRC will make a finding in the licensing process as to the overall and integrated state of preparedness. The NRC staff findings will be reported in its Safety Evalua-tion Report (SER). Although the presence of adequate and test..d emergency plans cannot prevent an accident, it is the staff's judgment that such plans can and will substantially mitigate the consequences te die public if an accident should occur.

5.9.4.5 Accident Risk and Impact Assessment (1) Design-Basis Accidents

- As a means of assuring that certain features of the Wolf Creek Unit 1 plant meet acceptable design and performance criteria, both the applicant and the staff have analyzed the potential consequences of a number of postulated accidents. Some of these could lead to significant releases of radioactive materials to the environment and calculations have been performed to estimate the potential radiological consequences to persons offsite. For each postulated initiating event, the potential radiological consequences cover a considerable range of values depending upon the particular course taken by the accident and the conditions, including wind direction and weather, prevalent during the accident.

In the safety analysis and evaluation of the Wolf Creek Unit 1 plant, three categories of accidents have been considered. These categories are based upon their probability of occurrence and include (a) incidents of moderate I

Wolf Creek FES 5-46

! I

frequency, i.e., events that can reasonably be expected to occur during any year of operation, (b) infrequent accidents, i.e., events that might occur once during the lifetime of the plant, and (c) limiting faults, i.e., accidents not expected to occur but that have the potential for significant releases of radioactivity. The radiological consequences of incidents in the first cate-gory, also called anticipated operational occurrences, are discussed in Sec-tion 5.9.3. Some of the initiating events postulated in the second and third categories for the Wolf Creek Unit 1 plant are shown in Table 5.7. These events are designated design-basis accidents in that specific design and operating features as described above in Section 5.9.4.4(1) are provided to limit their potential radiological consequences. Approximate radiation doses that might be received by a person at the boundary of the plant exclusion area, which is about 1200 m (3937 ft) distant from the reactor, during the first two hours of the accident are also shown in the table. The results shown in the table reflect the expectation that engineered safety and operating features designed to mitigate the consequences of the postulated accidents would function as intended. An important implication of this expectation is that the releases considered are limited to noble gases and radiciodines and that any other radioactive materials, e.g., in particulate form, are not expected to be released. The results are also quasi probabilistic in nature in the sense that the meteorological dispersion conditions are taken to be neither the best nor the worst for the site, but rather at an average value determined by actual site measurements. In order to contrast the results of these calculations with those using more pessimistic, or conservative, assump-tions described below, the doses shown in Table 5.7 are sometimes referred to as " realistic" doses.

Calculated population exposures for these events range from a small fraction l of a person rem to about 6 person-rem for the population within 80 km (50 mi)

I of the Wolf Creek Unit 1 plant. These calculations for both individual and population exposures indicate that the risk of incurring any adverse health effects as a consequence of these events is exceedingly small. By comparison with the estimates of radiological impact for normal operations shown in Section 5.9.3, the staff also concludes that radiation exposures from design-basis accidents are roughly comparable to the exposures to individuals and the population from normal station operations over the expected lifetime of the plant.

The staff has also carried out calculations to estimate the potential upper bounds for individual exposures from the same initiating accidents in Table 5.7 for the purpose of implementing the provisions of 10 CFR Part 100, j " Reactor Site Criteria." For these calculations, much more pessimistic (con-servative or worst-case) assumptions are made as to the course taken by the accident and the prevailing conditions. These assumptions include niuch larger amounts of radioactive material released by the initiating events, additional

, single failures in equipment, operation of ESFs in a degraded mode,* and very l poor meteorological dispersion conditions. The results of these calculations show that for these events the limiting whole-body exposures are not expected to exceed 3 rems and most would not exceed 1 rem to any individual at the site

• The containment structure, however, is assumed to prevent leakage in excess of that which can be demonstrated by testing, as provided in 10 CFR Section 100.11(a).

Wolf Creek FES 5-47

Table 5.7. Approximate 2-Hour Radiation Doses From Design Basis Accidents at Exclusion Area Boundary a

Dose (rem) at 1200 meters Infrequent Accidents Whole Body Waste Gas Tank Failure 0.05 b

Small-Break LOCA 0.03 Steam Ggnerator, Tube Rupture 0.016 Fuel-Handling Accident 0.003 Limiting Faults c

Main Steam Line Break <0.0005 Control Rod Ejection 0.03 Large-Break LOCA 0.29 Plant Exclusion Area Boundary Distance.

b LOCA-Loss of Coolant Accident; the TMI-2 accident was one kind of a small-break LOCA.

c< means "less than."

d See NUREG-0651 (Ref. 39) for descriptions of three steam generator tube rupture accidents that have occurred in the United States, i

l l

Wolf Creek FES 5-48

i boundary (Ref. ).

They also show that radioiodine releases have the potential for offsite .<posures ranging up to about 61 rems to the thyroid. For such an enposure to occur, an individual would have to be located at a point on the site boundary where the radioiodine concentration in the plume has its highest value and inhale at a breathing rate characteristic of a person jogging, for a period of two hours. The health risk to an individual receiving such an enposure to the thyroid is the potential appearance of benign or malignant thyroid nodules in about 2 out of 100 cases, and the development of a fatal thyroid cancer in about 1 out of 1,000 cases.

None of the calculations of the impacts of design-basis accidents described in this section takes into consideration possible reductions in individual or population exposures as a result of taking any protective actions.

(2) Probabilistic Assessment of Severe Accidents In this and the following three sections, there is a discussion of the proba-bilities and consequences of accidents of greater severity than the design-basis accidents discussed in the previous section. As a class, they are considered less likely to occur, but their consequences could be more severe, both for the plant itself and for the environment. These severe accidents, heretofore frequently called Class 9 accidents, can be distinguished from design-basis accidents in two primary respects; they involve substantial physical deterioration of the fuel in the reactor core, including overheating to the point of melting, and they involve deterioration of the capability of the containment structure to perform its intended function of limiting the release of radioactive materials to the environment.

The assessment methodology employed is that described in the Reactor Safety Study (RSS) which was published in 1975 (Ref. 43).* However, the sets of accident sequences that were found in the RSS to be the dominant contributors to the risk in the prototype PWR (Westinghouse designed Surry Unit 1) have recently been updated ("rebaselined") (Ref. 44). The rebaselining has been done largely to incorporate peer group comments (Ref. 45), and better data and analytical techniques resulting from research and development after the publica-tion of the RSS. Entailed in the rebaselining effort was the evaluation of the individual dominant accident sequences--as they are understood to evolve.

The earlier technique of grouping a number of accident sequences into the encompassing " Release Categories" as was done in the RSS has been largely (but not completely) eliminated.

The Wolf Creek Unit 1 is a Westinghouse-designed PWR having many similar design and operating characteristics to the RSS prototype PWR. Therefore, the present assessment for Wolf Creek Unit 1 has used as its starting point the rebaselined accident sequences and release categories referred to above, and more fully described in Appendix E. Characteristics of the sequences (and release cate-gories) used (all of which involve partial to complete melting of the reactor core) are shown in Table 5.8. Sequences initiated by natural phenomena such as tornadoes, floods, or seismic events and those that could be initiated by deliberate acts of sabotage are not included in these event sequences. The radiological consequences of such events would not be different in kind from RBecause the RSS (Ref. 43) has been the subject of considerable controversy, a discussion of the uncertainties surrounding it has been provided in Section 5.9.4.5(7).

Wolf Creek FES 5-49

j those which have been treated. Moreover, there are design requirements in 10 CFR Part 50, Appendix A, relating to the effects of natural phenomena, and safeguards requirements in 10 CFR Part 73, assuring that these potential initiators are in large measure taken into account in the design and operation of the plant. The data base for assessing the probabilities of events more severe than the design bases for natural phenomena or sabotage is small.

Hence, inclusion of accident sequences initiated by natural phenomena and sabotage events is beyond the state-of-the-art of probabilistic risk assessment.

In addition, the staff judges that the additional risk from severe accidents initiated by natural events or sabotage is within the uncertainty of risks for

! the sequences considered here.

I Calculated probability per reactor year associated with each accident sequence (or release category) used is shown in the second column in Table 5.8. As in the RSS there are substantial uncertainties in these probabilities. This is due, in part, to difficulties associated with the quantification of human error and to inadequacies in the data base on failure rates of individual plant components that were used to calculate the probabilities (Ref. 45). The probability of accident sequences from the Surry plant were used to give a perspective of the societal risk at Wolf Creek Unit 1 because, although the probabilities of particular accident sequences may be substantially different and even improved for Wolf Creek Unit 1, the overall effect of all sequences taken together is likely to be within the uncertainties (see Sec. 5.7.4.5(7) for discussion of uncertainties in risk estimates).

The magnitudes (curies) of radioactivity release for each accident sequence or release category are obtained by multiplying the release fractions shown in Table 5.8 by the amounts that would be present in the core at the time of the hypothetical accident. These are shown in Table 5.6 for the Wolf Creek Unit 1 i plant at a core thermal power level of 3565 MWt, the power level used in the Safety Evaluation.

i The potential radiological consequences of these releases have been calculated by the consequence model used in the RSS (Ref. 46) adapted and modified as described below to apply to a specific site. The essential elements are shown in schematic form in Figure 5.4. Environmental parameters specific to the

site of the Wolf Creek Unit 1 facility have been used and include the following:

I

- meteorological data for the site representing a full year of consecutive hourly measurements and seasonal variations;

- projected population for the year 2000 extending throughout regions of 80-km (50-mi) and 563-km (350-mi) radius from the site; i

- the habitable land f raction within the 563-km (350-mi) radius; and

- land-use statistics, on a statewide basis, including farm land values, farm product values including dairy production, and growing season infor-l mation, for the State of Kansas and each surrounding state within the i

563-km (350-mi) region.

For the region beyond 563-km (350-mi), the United States average population was assumed.

Wolf Creek FES 5-50

l Table 5.8 Summary of Atmospheric Releases in Hypothetical Accident l Sequences in a PWR (Rebaselined)

Accident ,

Sequence or Fraction of Core Inventory Released l Sequegce Probability c d Group per reactor yr Xe-Kr I Cs-Rb Te-Sb Ba-Sr Ru La Event V 2.0 x 10 6 1. 0 0.64 0.82 0.41 0.1 0.04 0.006 TMLB' 3.0 x 10 6 1.0 0.31 0.39 0.15 0.044 0.018 0.002 PWR3 3.0 x 10 6 0.8 0.2 0.2 0.3 0.02 0.03 0.003 PWR7 4.0 x 10 5 6 x 10 3 2 x 10 5 1 x 10 5 2 x 10 5 1 x 10 6 1 x 10 6 2 x 10 7 u,

u, ' Background on the isotope groups and release mechanisms is presented in Appendix VII, WASH 1400 (Ref. 43).

~

b See Appendix E for description of the accident sequences and Release Categories.

c Includes Ru, Rh, Co, Mo, Tc.

d Includes Y, La, Zr, Nb, Ce, Pr, Nd, Np, Po, Am, Cm.

Note: Please refer to Section 5.9.4.S(7) for a discussion of uncertainties in risk estimates.

l l

l, l

4 To obtain a probability distribution of consequences, the calculations are performed assuming the occurrence of each accident release sequence at each of .

! 91 dif ferent " start" times throughout a 1 year period. Each calculation i utilizes the site-specific hourly meteoroiogical data and seasonal information j rar the time period following each " start" time. The consequence model also

! contains provisions for incorporating the consequence reduction benefits of evacuation, relocation, and other protective actions. Early evacuation and relocation of people would considerably reduce the exposure from the radio-l active cloud and the contaminated ground in the wake of the cloud-passage.

i The evacuation model used (see Appendix F) has been revised from that used in

the RSS for better site-specific application. The quantitative characteristics

! of the evacuation model used for the Wolf Creek site are estimates made by the

staff and are partly based upon evacuation time estimates prepared by the  !

1 applicant. There normally would be special facilities near a plant, such as -

l schools or hospitals, where special equipment or personnel may be required to

effect evacuation. Several such facilities have been identified near the Wolf i Creek site such as the Coffey County Hospital and the Golden Age Lodge. Further, i there may be people who either do not receive notification to evacuate or who i choose not to evaluate. Therefore, actual evacuation effectiveness could be l greater or less than that characterized but would not be expected to be very

! much less.

l The other protective actions include: (a) either complete denial of use j (interdiction), or permitting use only at a sufficiently later time after

appropriate decontamination of food stuffs such as crops and milk, (b) decon-

] tamination of severely contaminated environm'.nt (land and property) when it is considered to be economically feasible to lower the levels of contamination to protective action guide (PAG) levels, and (c) denial of use (interdiction) of  !

severely contaminated land and property for varying periods of time until the

contamination levels reduce to such values by radioactive decay and weathering j so that land and property can be economically decontaminated as in (b) above.

These actions would reduce the radiological exposure to the people from mme- i diate and/or subsequent use of or living in the contaminated environment.

Early evacuation within and early relocation of people from outside the plume I exposure pathway EPZ (See Appendix F) and other protective actions as mentioned above are considered as essential sequels to serious nuclear reactor accidents

. involving significant release of radioactivity to the atmosphere. Therefore, I the results shown for Wolf Creek Unit I reactor include the benefits of these protective actions.

There are also uncertainties in each facet of the estimates of consequences and

, the error bounds may be as large as they are for the accident probabilities.

l (See Figure 5.4)

The results of the calculations using this consequence model are radiological doses to individuals and to populations, health effects that might result from these exposures, costs of implementing protective actions, and costs asso-ciated with property damage by radioactive contamination.

f (3) Dose and Health Impacts of Atmospheric Releases The results of the calculations of dose and health impacts performed for the Wolf Creek Unit 1 facility and site are presented in the form of probability l

! Wolf Creek FES 5-52 I

1 I

I__.--_---,- ..__u.- m, ,,,.--m.e-_,.,_,_m.m. .,---m_,., - - - - ---,

Weather Data l f Release . Atmospheric

" ~

Categories Dispersion qr + Dosimetry "

Health Effccts Dispersion

, Property 3 y

• Population - Effects Ground _ aL Contamination Evacuation Figure 5.4 Schematic Outline of Atmospheric Pathway Consequences Model 5-53

j distributions in Figures 5.5 through 5.7 and are included in the impact Summary Table 5.9. All of the accident sequences and release categories shown in Table 5.8 contribute to the results, the consequences from each being weighted by its associated probability.

Figure 5.5 shows the probability distribution for the number of persons who might receive whole-body doses equal to or greater than 200 rems and 25 rems,

, and thyroid doses equal to or greater than 300 rems from early exposure,* all on a per-reactor year basis. The 200-rem whole-bedy dose figure corresponds approximately to a threshold value for which hospitalization would be indicated for the treatment of radiation injury. The 25-rem whole-body (which has been identified earlier as the lower limit for a clinically observable physiological effect in nearly all people) and 300-rem thyroid figures correspond to the Commission's guideline values for reactor siting in 10 CFR Part 100.

i The figure shows in the left-hand portion that there are approximately 7 chances in 1,000,000 (i.e., 7 x 10 8) per reactor year that one or more persons may receive doses equal to or greater than any of the doses specified.

The fact that the three curves run almost parallel in horizontal lines initially shows that if one person were to receive such doses, the chances are ,

about the same that ten to hundreds would be so exposed. The chances of larger numbers of persons being exposed at those levels are seen to be consid-erably smaller. For example, the chances are about 1 in 100,000,000 (i.e.,

10 8) that 1,000 or more people might receive doses of 200 rems or greater. A majority of the exposures reflected in this figure would be expected to occur to persons within an 80-km (50-mi) radius of the plant. Virtually all would occur within a 24-km (150-mi) radius.

Figure 5.6 shows the probability distribution for the total population expo-sure in person-rems, i.e., the probability per reactor year that the total population exposure will equal or exceed the values given. Most of the population exposure up to 100 thousand person-rems would occur within 50 miles but the more severe releases (as in the first two accident sequences in Table 5.8) would result in exposure to persons beyond the 50-mile range as shown. I For perspective, population doses shown in Figure 5.6 may be compared with the annual average dose to the population within 50 miles of the Wolf Creek Unit 1 site due to natural background radiation of 21,000 person rems, and to the anticipated annual population dose to the general public (total United States) i from normal station operation of 50 person-rems (excluding plant workers)

(Appendix C, Tables C.6 and C.8.).

l The consequence calculations for this plant predict no early fatalities. For l

the evacuation and relocation models used, which are more fully discussed in i Appendix F, the calculated doses to all individuals are below that which would be expected to result in fatality within one year with supportive medical treatment. Figure F.1 shows the effects of a much more pessimistic emergency response.

• Early exposure to an individual includes external doses from the radioactive cloud and the contaminated ground, and the dose from internally deposited radionuclides from inhalation of contaminated air during the cloud passage.

Other pathways of exposure are excluded.

Wolf Creek FES 5-54

PROBABILITY DISTITIBUTIONS OF lNDIVIDUAL DOSE IMPACTS

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NOTE: Please see Section 5.9.4.5(7) for discussion of uncertainties in risk estimates.

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f FATALITIES l DISJRI l3UTIONS OF CgNCER I I

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% 1d 1d I l X= LATENT CANCER FATALITIES PER YEAR FOR 30 YEARS )

Fig 5.7 Probability Distribution of Cancer Fatalities NOTE: Please see section 5.9. 4.5 ( 7) for discussion of uncertainties in ris

Table 5.9 Summary of Environmental Impacts and Probabilities Population Latent" Probability Persons Persons Exposure Cancers Cost of Offsite of Impact Per Exposed Exposed Millions of person- 50 mi/ Mitigating Actions Reactor-Year over 200 rem over 25 rem rem 50 mi/ Total Total Millions of Dollars 10 4 0 0 0/0 0/0 0 10 s 0 0 0.006/0.01 0/0 1 5 x 10 6 0 500 0.3/7.7 0/400 200 10 6 0 4,900 0.82/21 50/1,100 900 10 7 200 21,000 2/40 220/2,500 2,200 Y'

10 8 1,500 140,000 3.2/60 670/4,800 3,300 8; Related Figure 5. 5 5.5 5.6 5.7 5.8 Includes cancers of all organs. Thirty times the values shown in the Figure 5.7 are shown in this column reflecting the 30 yr period over which cancers might occur. Genetic effects would be approxi-mately twice the number of latent cancers.

Note: Please refer to Section 5.9.4.5(7) for a discussion of uncertainties in risk estimates.

Figure 5.7 represents the statistical relationship between population exposure and the induction of fatal cancers that might appear over a period of many years following exposure. The impacts on the total population and the popula-tion within 81 km (50 mi) are shown separately. Further, the fatal, latent cancers have been subdivided into those attributable to exposures of the thyroid and all other organs.

(4) Economic and Societal Impacts As noted in Section 5.9.4.2, the various measures for avoidance of adverse health ef fects including those due to residual radioactive contamination in the environment are possible consequential impacts of severe accidents.

Calculations of the probabilities and magnitudes of such impacts for the Wolf Creek Unit 1 facility and environs have also been made. Unlike the radiation exposure and health effect impacts discussed above, impacts associated with adverse health effects avoidance are more readily transformed into economic impacts.

The results are shown as the probability distribution for cost of offsite mitigating actions in Figure 5.8 and are included in the Impact Summary Table 5.9. The factors contributing to these estimated costs include the following:

Evacuation costs I

- Value of crops contaminated and condemned Value of milk contaminated and condemned

- Costs of decontamination of property where practical

- Indirect costs due to loss of use of property and incomes derived therefrom.

l The last-named costs would derive from the necessity for interdiction to prevent the use of property until it is either free of contamination or can be

! economically decontaminated.

Figure 5.8 shows that at the extren,e end of the accident spectrum these costs could exceed several billion dollars but that the probability that this would occur is exceedingly small, less than one chance in a hundred million per reactor year.

Additional economic impacts that can be monetized include costs of decontami-nation of the facility itself and the costs of replacement power. Probability distributions for these impacts have not been calculated but they are included in the discussion of risk considerations in Section 5.9.4.5(6) below.

(5) Releases to Groundwater A pathway for public radiation exposure and environmental contamination that could be associated with severe reactor accidents was identified in Sec-tion 5.9.4.2(2) above. Consideration has beenThe given to the potential environ-principal contributors to mental impact of this pathway for Wolf Creek.

Wolf Creek FES 5-59

the risk are the core-melt accidents. The penetrativn of the basemat of the containment building can release molten core debris to the strata beneath the plant.

Soluble radionuclides in this debris can be leached and transported with groundwater to downgradient domestic wells used for drinking or to surface water bodies used for drinking water, aquatic food and recreation. In pressurized i

water reactors, such as that of Wolf Creek, there is an additional opportunity for groundwater contamination due to the release of contaminated sump water to the ground through a breach in the containment.

An analysis of the potential consequences of a liquid pathway release of radioactivity for generic sites was presented in the " Liquid Pathway Generic Study" (LPGS) (Ref. 47). The LPGS compared the risk of accidents involving the liquid pathway (drinking water, irrigation, aquatic food, swimming and shoreline usage) for four conventional, generic land based nuclear plants and a floating nuclear plant, for which the nuclear reactors would be mounted on a barge and moored in a water body. Parameters for the land-based sites were chosen to represent averages for a wide range of real sites and are thus

" typical," but they represented no real site in particular. The study concluded that the individual and population doses for the liquid pathway through ground water contaimination range from small fractions to very small fractions of l those that can arise from the atmospheric pathways.

The discussion in this section is an analysis to determine whether or not the Wolf Creek site liquid pathway consequences from an accident which released radioactive material to the groundwater beneath the reactor would be unique when compared to land-based sites considered in the LPGS. The method consists of a direct scaling of LPGS population doses based on the relative values of key parameters characterizing the LPGS "small river" site and the Wolf Creek site. The parameters which are normally evaluated included amounts of radioactive materials entering the ground, groundwater travel time, sorption on geological media, surface water transport, drinking water usage, aquatic food consumption, and shoreline usage.

Doses to individuals and populations were calculated in the LPGS without consideration of interdiction methods such as isolating the contaminated groundwater or denying use of the water. In the event of contamination, alternative sources of water for drinking, irrigation and industrial uses would be expected to be found, i f necessary. Commerical and sports fishing, as well as many other water-related activities would be restricted.

The consequences logical.

would therefore be largely economic or social, rather than radio-In any event, the individual and population doses for the liquid pathway range from fractions to very small fractions of those that can arise from the airborne pathways.

The Wolfby affected Creek site is located a postulated above several rock formations which could be core meltdown. )

I order: These formations are in descending

1) Heumader Shale Member

2) Plattsmouth Limestone Member

3) Heebner Shale, leavenworth Limestone, and Snyderville Shale Members l

Wolf Creek FES 5-60

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5) Lawrence Shale Member Of these formations, the highest permeability measurement (2 x 10 4 cm/sec) was in the Plattsmouth Limestone, hence this formation is considered to be the most likely pathway for the contaminated groundwater.

The applicant performed analysis of the radiological consequences of a liquid pathway release from a core melt accident through the Plattsmouth Limestone formation.

Pertinent parameters assumed by the applicant for this analysis

{ were (Ref. 4G):

Permeability 2 x 10 4 cm/sec Hydraulic gradient 0.00462 Effective Porosity 0.12 i

Distance to Cooling Lake 2600 ft Retardation Factor for Strontium 9.3 Retardation Factor for Cesium 83

' The NRC staff agrees that the applicant's assumptions are reasonaSle and that all parameters chosen are conservative or are consistent with the ranges of values observed for geologic materials similar to those at the site.

Based on these parameters, the applicant calculated a groundwater travel time of 326 years to the cooling lake. The travel times for Sr-90 and Cs-137, the major long lived radionuclides, were calculated to be 3,031 years and 27,000 years, respectively. The amount of Sr-90 and Cs-137 entering the cooling lake is negligible under these assumptions, as compared to the LPGS analysis, i

i When the transport times for the Wolf Creek site are compared to 5.7 years for Sr-90 and 51 years for Cs-137 in the LPGS land-based river case, the relatively larger travel times for the Wolf Creek site would allow a much smaller portion of the radioactivity to enter the surface water. For an equal source of radioactive material, the quantity of materials entering the river would be reduced by a factor of at least 3 x 1032 for Sr-90, and at least 10100 for Cs-137 as compared to the LPGS case.

Without further analysis it can be concluded that, because of the relatively long travel times, virtually none of the radioactive materials that were shown to be the significant contributors to population dose in the LPGS could enter and contaminate surface water near the site. The Wolf Creek liquid pathway contribution to population dose has therefore been shown to be much smaller than that predicted for the LPGS river site, which represents a " typical" river site. Thus the Wolf Creek site is not unique in its liquid pathway contribution to risk.

Furthermore, there are measures which could be taken to minimize the impact of the liquid pathway. The estimated minimum ground water travel time for the site to the cooling lake would be over 300 years and the holdup of most of the radioactivity would be much greater, which would allow engineering measures such as dewatering the reactor building and the placement of observation wells to further slowdown and monitor the movement of radionuclides.

l Wolf Creek FES 5-62

l (6) Risk Considerations The foregoing discussions have dealt with both the f requency (or likelihood of occurrence) of accidents and their impacts (or consequences). Since the ranges of both factors are quite broad, it is also useful to combine them to obtain average measures of environmental risk. Such averages can be particu-larly instructive as an aid to the comparison of radiological risks associated with accident releases and with normal operational releases.

A common way in which this combination of factors is used to estimate risk is to multiply the probabilities by the consequences. The resultant risk is then expressed as a number of consequences expected per unit of time. Such a quantification of risk does not at all mean that there is universal agreement that peoples' attitudes about risks, or what constitutes an acceptable risk, can or should be governed solely by such a measure. At best, it can be a contributing factor to a risk judgment, but not necessarily a decisive factor.

In Table 5.10 are shown average values of risk associated with population dose, latent fatalities, and costs for evacuation and other protective actions.

These average values are obtained by summing the probabilities multiplied by the consequences over the entire range of the distributions. Since the prob-abilities are on a per-reactor year basis, the averages shown are also on a per-reactor year basis.

The population exposures and latent cancer fatality risks from Table 5.10 may be compared with those for normal operation shown in Appendix C, Table C.8.

The radiological dose to the population due to normal operation of the station may be about 49 person-rem per year. This dose may result in 0.0069 latent cancer death to the exposed population per year. The comparison shows that the accident risks are comparable to those for normal operation.

Within the 16-km (10-mi) radius plume exposure pathway EPZ the calculations show that expected emergency responses can reduce the risk of whole-body or thyroid exposure and risks of early or latent cancer fatality to an individual to near zero. For comparison the following risks of fatality per year to an individual living in the United States may be noted (p. 577 of Ref. 35):

automobile accident 2.2 x 10 4, falls 7.7 x 10 5, drowning 3.1 x 10 5, burning 2.9 x 10 5, and ftrearms 1.2 x 10 5 The economic risk associated with evacuation and other protective actions could be compared with property damage costs associated with alternative energy generation technologies. The use of fossil fuels, coal or oil, for example, would emit substantial quantities of sulfur dioxide and nitrogen oxides into the atmosphere, and, among other things, lead to environmental, and ecological damage through the phenomenon of acid rain (pp. 559-560 of Ref. 35). This ef fect has not, however, been suf ficiently quantified to draw a useful comparison at this time.

There are other economic impacts and risk that can be monetized that are not included in the cost calculations dicussed in Section 5.9.4.5(4) Economic and Societal Impacts. These are accident impacts on the facility itself that result in added costs to the public, i.e., ratepayers, taxpayers and/or share-Wolf Creek FES 5-63

---. - _ . = _ - . .__ _ _ - _ . - _ ---

i 1

i holders. These costs would be for decontamination and repair or replacement of the facility, and replacement power during the time the facility is inopera-tive. Experience with such costs is currently being accumulated as a result of the Three Mile Island accident. If an accident occurs during the first year of Wolf Creek (1984) operation, the economic penalty is estimated at

$1.0 billion for decontamination and $600 million for restoration, including i replacement of the damaged nuclear fuel. Staff considers the estimate as conservative (high) in that the total costs are assumed to occur during the first year of the accident whereas in reality the costs would be spread over several years thereafter. Although insurance would cover $300 million of the

{ $1600 million, the insurance is not credited against the $1600 million because i

the $300 million times the risk probability should theoretically balance the insurance premium. In addition, staff estimates additional fuel costs of

$60 million (in 1984 dollars) for replacement power during each year the plant is being restored. This estimate assumes that the energy that would have been i

forthcoming from Wolf Creek (assuming a 60% capacity factor) will be replaced primarily by coal-fired generation. Assuming inoperation of the nuclear unit for 8 years, the total additional replacement power costs would be approxi-mately $480 million in 1984 dollars.

Table 5.10 Average Values of Environmental Risks due to Accidents per j Reactor-Year

}

Environmental risk Average value Population exposure Person-rems within 50 miles 4.3 Total Person rems 99 i

Early fatalities 0.0 Latent cancer, fatalities

' All organs excluding thyroid 0.0049 Thyroid only 0.00069 Cost of protective actions and decontamination $3,600*

1980 dollars NOTE: Please see Section 5.9.4.5(7) for discussions of uncertainties in risk estimates.

l l

If the probability of sustaining a total loss of the original facility is taken as the sum of the occurrences of a core melt accident (the sum of the probabilities for the categories in Table 5.8) then the probability of a

• disabling accident happening during each year of the units service life is j 4.8 x 10 5 Multiplying the previously estimated cost of $2.08 billion for an l

l l Wolf Creek FES 5-64

. - . _ _ - . .. _ - - - - - - . - - _ = _ ._- - -- _

i accident to Wolf Creek during the initial year of its operation by the above 4.8 x 10 5 probability results in an economic risk of approximately $100,000 (in 1984 dollars) applicable to the Wolf Creek Unit during its first year of operation. This is equivalent to sporoximately $64,000 in 1980 dollars, '

~

assuming a 12% discount rate. This also approximately the economic risk during the second and each subsequent . ear of its operation. Although nuclear units depreciate in value and may oper te at reduced capacity factors such that the economic consequences due to an accident becomes less as the units become older, this is considered to be offset by higher costs of decontamina- ,

tion and restoration of the units in the later years due to inflation.

(7) Uncertainties j

The foregoing probabilistic and risk assessment discussion has been based upon '

the methodology presented in the Reactor Safety Study which was published in 1975. There are substantial uncertainties associated with the numerical estimates of the liklihood, as well as the consequences, of severe reactor accidents that are evaluated using this methodology.

In the consequence calculations, uncertainties arise from an over-simplified i analysis of the magnitude and timing of the fission product release, from uncertainties in calculated energy release, from radionuclide transport from the core to the receptor, from lack of precise dosimetry, and statistical variations of health effects. Recent investigations of accident source terms, for example, have shown that a number of physical phenomena affecting fission product transport through the primary cooling system and the reactor containment have been neglected. Some of these processes have the potential for substantially reducing the quantity of fission products predicted to be released from the containment for some accident sequences. Such a reduction in the source term

' would result in substantially lower estimates of health effects, particularly the estimate of early fatalities.

One area given considerable recent thought with respect to uncertainty is atmospheric dispersion. Although recent developments in the area of atmospheric dispersion modelling used in CRAC (the computer code developed in RSS) indicate '

that an improved meteorological sampling scheme would reduce the uncertainties arising from this source (including the effect of washout by precipitation),

large uncertainties would still remain in the calculations of radionuclide concentrations in the air and the ground from which radiological exposures to i

an individual and the population are calculated. These uncertainties arise from lack of precise knowledge about the particle size distribution of the radionuclides released in particulate forms and about their chemical behavior.

Therefore, the parameters of particulate deposition which exert considerable influence on the calculated results have uncertain values. The vertical rise of the radioactive plume is dependent on the heat and momentum associated with the release categories, and calculations of both factors have considerable uncertainty. The duration of release which determine the cross-wind spread of the plume is another example of considerable uncertainty. Warning time before evacuation also has considerable impact on effectiveness of offsite emergency response; and this parameter is not precisely calculated because of its dependence on other parameters (e.g. time of release) which are not precisely known.

i 1

Wolf Creek FES 5-65 i

e

j The state-of-the-art for quantitative evaluation of the uncertainties in the probabilistic risk analysis of the type presented here is not well developed.

1

' Therefore, although the staff has made a reasonable analysis of the risks presented herein, there are large uncertainties associated with the results shown.

It is the qualitative judgement of the staff that the uncertainty bounds could be well over a factor of 10, but not so large as a factor of 100.

i The accident at Three Mile Island occurred in March 1979 at a time when the

' accumulated experience record was about 400 reactor years. It is of interest

' to note that this was within the range of frequencies estimated by the RSS for an accident of this severity (p. 553 of Ref. 35). It should also be noted that the Three Mile Island accident has resulted in a very comprehensive j evaluation of reactor accidents like that one, by a significant number of investigative groups both within NRC and outside of it. Actions to improve l

the safety of nuclear power plants have come out of these investigations, ,

! including those from the President's Commission on the Accident at Three Mile Island, and NRC staff investigations and task forces. A comprehensive "NRC i Action Plan Developed as a Result of the TMI-2 Accident," NUREG-0660, Vol. I, May 1980 (Ref. 49) collects the various recommendations of these groups and describes them under the subject areas of: Operational Safety; Siting and Design; Emergency Preparedness and Radiation Effects; Practices and Proce-i dures; and NRC Policy, Organization, and Management. The action plan presents a sequence of actions, some already taken, that result in a gradually increasing improvement in safety as individual actions are completed. The Wolf Creek

' Unit 1 plant is receiving and will receive the benefit of these actions on the schedule indicated in NUREG-0660. The improvement in safety from these actions j has not been quantified, however, and the radiological risk of accidents discussed in this chapter does not reflect these improvements, f 5.9.4.6 Conclusions I

The foregoing sections consider the potential environmental impacts from accidents at the Wolf Creek Unit 1 facility. These have covered a broad i

spectrum of possible accidental releases of radioactive materials into the environment by atmospheric and groundwater pathways. Included in the consid-erations are postulated design-basis accidents and more severe accident sequences that lead to a severely damaged reactor core or core-melt.

The environmental impacts that have been considered include potential radia-tion exposures to individuals and to the population as a whole, the risk of near and long-term adverse health effects that such exposures could entail, and the potential economic and societal consequences of accidental contamina-tion of the environment. These impacts could be severe but the likelihood of their occurrence is judged to be small. This conclusion is based on (a) the fact that considerable experience has been gained with the operation of similar facilities without significant degradation of the environment, (b) that, in order to obtain a license to operate the Wolf Creek Unit 1 facility, it must comply with the applicable Commission regulations and requirements, and (c) a probabilistic assessment of the risk based upon the methodology developed in the Reactor Safety Study. The overall assessment of environmental risk of accidents, assuming protective action, shows that it is roughly comparable to l the risk from normal operation although accidents have a potential for early fatalities and economic costs that cannnot arise from normal operations. The Wolf Creek FES 5-66

risks of early fatality from potential accidents at the site are calculated to be negligible, however, in any case the risks are small in comparison with risks of early fatality from other human activities in a comparably-sized population.

We have concluded that there are no special or unique circumstances about the Wolf Creek Unit 1 site and environs that would warrant special mitigation features for the Wolf Creek Unit 1 plant.

5.10 URANIUM FUEL CYCLE The Uranium Fuel Cycle Rule, 10 CFR Part 51.20 (44 FR 45362), reflects the latest information relative to the reprocessing of spent fuel and to radio-active waste management as discussed in NUREG-0116, " Environmental Survey of the Reprocessing and Waste Management Portions of the LWR Fuel Cycle" (Ref. 50),

and NUREG-0216 (Ref. 51), which presents staff responses to comments on NUREG-0116. The rule also considers other environmental factors of the uranium fuel cycle, including aspects of mining and milling, isotopic enrichment, fuel fabrication, and management of low- and high-level wastes. These are described in the AEC report WASH-1248, " Environmental Survey of the Uranium Fuel Cycle" (Ref. 52). The Commission also directed that an explanatory narrative be developed that would convey in understandable terms the significance of releases in the table. The narrative was also to address such important fuel cycle impacts as environmental dose commitments and health effects, socio-economic impacts and cumulative impacts, where these are appropriate for generic treatment. This explanatory narrative was published in the Federal Register on March 4,1981 (46 FR 15154-15175). Appendix G to this statement contains a number of sections that address those impacts of the fuel cycle that reasonably appear to have significance for individual reactor licensing sufficient to warrant attention for NEPA purposes.

Table S-3 of the final rule is reproduced in its entirety herein as Table 5.11.

Specific categories of natural resource use included in the table relate to land use, water consumption and thermal effluents, radioactive releases, burial of transuranic and high- and low-level wastes, and radiation doses from transportation and occupational exposures. The contributions in the table for reprocessing, waste management, and transportation of wastes are maximized for either of the two fuel cycles (uranium only and no recycle); that is, the cycle that results in the greater impact is used.

Appendix G to this statement contains a description of the environmental impact assessment of the uranium fuel cycle as related to the operation of the Wo1f Creek Generating Station. The environmental impacts are based on the values given in Table S-3, and on an analysis of the radiological impact from radon-222 and technetium-99 releases. The NRC staff has determined that the environmental impact of the station on the U.S. population from radioactive gaseous and liquid releases (including radon and technetium) due to the uranium fuel cycle is insignificant when compared with the impact of natural background radiation. In addition, the nonradiological impacts of the uranium fuel cycle have been found to be acceptable.

Wolf Creek FES 5-67 I

5-68 Table 5.11. (Table S.'3). Table of Uranium Fuel Cycle Environmental Datal

[ltormali:ed to model 1.WR annual fuel requirement [ WASH-1248]

or reference reactor year [NUREG-0116))

w e*ect p. arwmas eu.

Erwwonmented conmaaremons Totas roomernent or reeerence reactor year ce moom i.000 uwe LwA NarumAL AESoumCES USE Land 4acrest T. moor , corn, eted i 100 UrusseWted arma 79 CosturDed area 22 Ecurveent to a 110 Mwe coeWired power Permanentfy conwmeted Daent 13 Overturoen moved (meens of MT) 2.8 Ecurveent to 95 Mwe ceaWired power plant.

Wetur (mnons cd gadons):

Oschargea to as 160 =2 percent of moost 1.000 Mwe LWA sain Oscharged to water boosse . coceing tower.

11.090 Oscnarged to ground 127

, Totas .

11.377 < 4 percent of moose 1.000 Mwe Fosen Not LWR wnn ence Ovougn cooting.

E'ectncas energy (thousanos of MW.now) 223 <5 percent of modes 1.000 Mwe LWA outoul Eaunrawn coas (tnousanos of MT) 1te Ecurvesent to the consurnonon of a 45 Mwe Natures gas armdmans of scf) coaWred power plant 135 (0.4 percent of moom 1.000 Mwe energy output.

ErstuamrS.--Cesimcx (MT)

Gases inauong .u +ai.

• SC, 4.400 NO.

• 1.190 Ecurveent to enuamons from 45 Mwe coas.

Hvorecaroops free piant for a year.

14 CO. 29.6 derticuates. 1,154 Otr er gases:

F. _ . . . . . . . .

67 % from UF. producnort --G..,.4.

and recrocesseng. C 4 .u . metriert range of State Standaros==Conow levet that HC1 . . . nas effects on numan neeftfL 314 Lomas-l SO *. 9.9 From u . a. fuse fanncanon, and reen>

! NO . .. . 25.8 cesang Stoos. Comconents that consatute Fluonce .. 12.9 a poterme for adverse n-, .,.aat effect Ca** - . . .

5.4 are present v1 $1ute concentremons and re-C1 - . .. 9.5 conte aooeones oducon by recemng Docnee Na* 12.1 of water to levees beeow permsmote stand.

NH._ . ... .. .. 10.0 se. . . . . .

aros. The consetuents that roomre cducon 4 and the flow of ddubon water are-NH,--600 cts.

No -20 cfs.

Fluonde--70 cfs.

Taegs sosutions Ltnousapos of MT) 240 Frorn muss on#y-no sagrwheant effluents to erwronment

$chos...._.. . . . .

91.000 Pnncipessy from rms6e-no segrvficarvt effluents to m.-w.. .;

5-69 Table 5.11 (Table S.3). Continued.

u mum erf.ci p.r annum fu.e E%,eneneatal corweranons Totas roousevt or reerence reactor year of modes 1.000 Wee LWA ErsprS A* cot.0Gach tct.iemsi Gases oncNding entranmati' P'eeentfy under reconsideraton ey me Com-An.222... . . . . .

trusson.

C2 A n-226. .. ...-...

02 Th-230.

334 Urarwum . .._

t81 fntium (teousandsL. . . . . . . . . .

24 C-14 . . . - . .

400 Kr-45 Itnousandse .

14 P merpany from fuse recrocessang ptants.

Au- 106. ... ... - - - ..

t- t 29 . _... . . . . . . .

13

$3 t-131 . . . . . . . . . .....m

--.~... Presentfy under conssderation by *ne Com-TC49 - -. ~~

m'ss on Essaort products and transuranics.... 203 Leeds. Pencomty frorn rrwiseg-ccsuced ustegs Uraruum and daugnters . . . . .

2.1 hauor and retumed to ground-no of-fluents. meterore, no er'ect on envron-ment.

0034 From UF. producton.

Aa-226.. . . . . . . . . . . . .

Th-230.. . . . .

0015 01 From Neo 'anncaton piants-concentranon Th-234 . . . . . . . . . . .

to percent of 10 CFA 20 for total crocess-og 26 atinual Nel reQurements 'or modge LWA.

Assen and actniaten oroducts.. 53=10

Solds ibured on satel Ctf'er mari negn level (snaalowl .. .- . . . 11.300 9.100 G comes from now seves reactor wastes and 1.500 G comes from reactor oecon.

taminecon and doccmtrwssaanmq-ouped at land ounal 'acirbes 600 Ce comes from mais--ecNded att tastings returned to 7,rourid. Acoroximatory 60 G comes t=orn converson and soont Not storage. No sag-twhcant effluent to the amm c.t.

t.1 x to ' 8tned at Feoeral Aeoostory.

• Au and HLW tdeeos.. ..

E" tents-mermai ibdiens of Ontsn mermes urwtst.. 4.063 < $ percent of modes 1.000 uwe LW A Transoortanon toersorwomt:

Enocsure et worwers and general cuo'ac.. . . . . 2.5 Occuoaconal esposure ipersorwernt .. 22 6 From reorocessang and waste management.

'in some cases wnere r.,, antry accents it rs clear ' rom me bacsgrourus documents mat the matter was aodressed and that.

n effect, me Tanse snound be read as it a sooofie zero entry 9ad Deen maoe. mwever. :nere are otner areas tnat are not aoaressed at all o me Tacle. Tacle S-3 does not ectude reaim effects from r- ettbents descnbed c me Taose, or estirnates at rosesses of AadorW22

• rom me vrernum Nel cycle or estrnates of Tecnnevn-99 reeessed from waste managernent or recrecesang actnaces. *bese issues mov be me suosect of f.hgaten A me edPndual hCensang proceeOngs Cata suooortng trws f acie are gwen m the "Envvonmental Ssvey ct me Uransum Fuse Crcle." WASW1248. Aone 1974: me

'Envvonenentas Survey of me Aecrocessing and Waste Management pomon of tr e LWA Fues Crce.~ NUAEG4116 iSuco.1 to WASH-1248), tne Puoi.c Commems and Yasa Force Aesponses Aegardeg the Envvenmentas Survey ro the Aeorocesseg and Weste vanagernent Portons of me LWA Fuel Crce.* NUAEG4216 (Suco. 2 to WASH-1248k and n ene record of me hnas neerneneg penasung to Urarnum Fuse Crete !rnpacts ' rom Soent Fuse Aeorocessang and Aadoectrre Waste Management.

Cocnet AM-5N The contnoutons from reecm. weste management and 'ransoortanon of westes are maartwred for eiiner of me two fusa evces (urarwum on#y and no recyce). The contneunon from transoortanon escudes 'ransoortaten of cold tes ?o a reactor and of wraosted fue6 and raccactPre westes from a reactor enten we consdered n Taolo S-4 of 15120(gt Tee contneutons from me amor stees of to fuse cyce Me gven e casumns A-E of Taose S-3A of W ASW1248.

8Tne contnounor's to temocrattry comtrutted iand from recrocessang are not prorated over 30 years, sance tne cornesete

'ernoorary vnoact accrues regardless of weetrar me ptant sannces one reactor for one year or 57 reactors for 30 years.

'Esornated of%ents essed uoon cornousnon of eaucraient coal for powes :snersoon.

• 12 percent ' rom nan.ral gas use and proCest

b 5.11 DECOMMISSIONING The purpose of decommissioning is to safely remove nuclear facilities from service and to remove or isolate the associated radioactivity from the environ-ment so that part of the facility site that is not permanently committed can be released for other uses. Alternative methods of accomplishing this purpose and the environmental impacts of each method are discussed in NUREG-0586.

Since 1960, 68 nuclear reactors, including 5 licensed reactors that had been used for the generation of electricity, have been or are in the process of being decommissioned.

Although to date no large commercial reactor has undergone decommissioning, the broad base of experience gained from smaller faciltias is generally relevant to the decommissioning of any type of nuclear facility.

Radiation doses to the public, as a result of decommissioning activities, at the end of a commercial power reactor's useful life, should be small and will come primarily from the transportation of waste to appropriate repositories.

Radiation doses to decommissioning workers should be well within the occupational exposure limits imposed by regulatory requirements.

The NRC is currently conducting a generic rulemaking that will develop a more explicit overall policy for decommissioning commercial nuclear facilities.

Specific licensing requirements are being considered that include the development of decommissioning plans and financial arrangements for decommissioning nuclear facilities.

! Estimates of the economic cost of decommissioning are provided in Section 6 of this statement.

5.12 EMERGENCY PLANNING IMPACTS In connection with the promulgation of the Commission's upgraded emergency planning requirements, the NRC staff (Office of Standards Development) issued NUREG-0658, " Environmental Assessment for Effective Changes to 10 CFR Part 50 and Appendix E to 10 CFR Part 50; Emergency Planning Requirements for Nuclear Power Plants," (August 1980). Construction of the facilities is discussed in Section 4.2.1. The staff believes the only noteworthy potential source of impacts to the public from emergency planning would be associated with the testing of the early notification system. The test requirements and noise levels will be consistent with those used for existing alert systems; therefore, the staff concludes that the noise impacts from the system will be infrequent and insignificant.

References for Section 5

1. " Flood Hazard Boundary Map for Coffey County, Kansas," Federal Insurance Administration, U.S. Department of Housing and Urban Development, August 1977.

2. F. C. Bellrose, " Ducks, Geese and Swans of North America," Stackpole Books, Harrisburg, PA, 1976.

4 Wolf Creek FES 5-70

3. " Final Environmental Statement Related to the Operation of LaSalle County Nuclear Power Station, Unit Nos. I and 2," U.S. Nuclear Regulatory Commis-sion, NUREG-0486, Docket Nos. 50-373 and 50-374, Washington, DC, 1978.

4. J. R. Meyer and J. M. Lee, " Effects of Transmission Lines on Flight Behavior of Waterfowl and Other Birds," In D. Arner and R. E. Tillman (Eds.),

" Environmental Concerns in Rights-of-way Management," Electric Power Research Institute Palo Alto, CA, pp. 62-1 to 62-15, 1981.

5. W. L. Anderson, " Waterfowl Collisions with Power Lines at a Coal-fired Power Plant," Wildlife Society Bulletin 6(2):77-83, 1978.

6. M. W. Miller, "High Voltage Overhead," Environment 20(1):6-36, 1978.

7. " Biological Ef fects of High-voltage Fields: An Update," EA-1123, Res.

Project 857-1, Electric Power Research Institute, Palo Alto, CA,1979.

3. " Project Resumes: Biological Ef fects f rom Electrical Fields Associated with High-voltage Transmission Lines," CONF. 801187 (Abstracts),

U.S. Department of Energy, Washington, DC, 1980.

9. " Biological Effects and Physical Characteristics of Fields, Ions, and Shock," Addendum to "Public Health and Saf ety Ef f ects on High Voltage Over-head Transmission Lines," Dow Associates, Inc. , prepared for Minnesota Environmental Quality Board, St. Paul, MN, 1980.

10. " Quality Criteria f or Water ," U. S. Environmental Protection Agency, Washington, DC, 1976.

11. " Kansas Water Quality Inventory Report, 1976," Kansas Department of Health and Environment, Topeka, 1976.

12. J.D. Hem, " Study and Interpretation of the Chemical Characteristics of Natural Water," Geological Survey Water Supply Paper 1473, U.S. Geological Survey. Washington, DC, 1970.

13. " Water Resources Data f or Oklahoma, Water Year 1977," Water-Data Report OK-77-1, Water Resources Division, U.S. Geological Survey, Oklahoma City, 1978.

14. " Water Quality Criteria Documents; Availabili ty," U. S. Environmental Protection Agency, Federal Register 45(231):79318-79379, 1980.

15. R. L. Kroodsma, " Evaluation of a Proposed Transmission Line's I, pact on Waterfowl and Eagles," In: " Impacts of Transmission Lines on Birds in Flight," Oak Ridge Associated Universities, Oar Ridge, TN, ORAU-12, pp.117-128, 1978.

16. " Final Report of Construction Environmental Monitoring Program, Wolf Creek Generating Station," Report prepared by Nalco Environmental Sciences, Lincoln, NE, for Kansas Gas and Electric Company, Wichita, 1978.

Wolf Creek FES 5-71 y

i 1

17. W. L. Plieger, "The Fishes of Missouri," Missouri Department of Conservation, Jefferson City, 1975.

18. " Standards for Protection Against Radiation," Title 10 Code of Federal Regulations Part 20, January 1981.

19. " Domestic Licensing of Production and Utilization Facilities," Title 10 Code of Federal Regulations Part 50, January 1981.

20. " Environmental Radiation Protection Standards for Nuclear Power Operations."

Title 40 Code of Federal Regulations Part 190, January 1981.

21. " Radiation Protection," In: " Standard Review Plan," Chapter 12, NUREG-0800, U.S. Nuclear Regulatory Commission, July 1981.

22. "Information Relevant to Ensuring that Occupational Radiation Exposures ,

l at Nuclear Power Stations Will Be as Low as Is Reasonably Achievable,"

i Regulatory Guide 8.8, Revision 3, U.S. Nuclear Regulatory Commission, June 1978.

23. 8. G. Brooks, " Occupational Radiation Exposure at Commercial Nuclear Power Reactors, 1979," NUREG-0713, Vol.1, U.S. Nuclear Regulatory Commission, March 1981.

24. Memo from C. S. Hinson to W. E. Kreger,U.S. Nuclear Regulatory Commission,

" Preliminary LWR Exposure Data for 1980," May 28, 1981.

25. " Calculation of Releases of Radioactive Materials in Gaseous and Liquid Effluents from Pressurized Water Reactors (PWR-GALE Code)," NUREG-0017, U.S. Nuclear Regulatory Commission, April 1976.

26. " Calculation of Annual Doses to Man From Routine Releases of Reactor Effluents for the Purpose of Evaluating Compliance with 10 CFR Part 50, Appendix I," Regulatory Guide 1.109, Revision 1, U.S. Nuclear Regulatory Commission, October 197'i.

l

27. B. G. Blaylock and J. P. Witherspoon, " Radiation Doses and Effects i Estimated for Aquatic Biota Exposed to Radioactive Releases from LWR Fuel-Cycle Facilities," Nuclear Safety, 17:351, 1976.

28. "The Effects on Populations of Exposure to Low Levels of Ionizing Radiation,"

Advisory Committee on the Biological Effects of Ionizing Radiations (BEIR),

National Academy of Sciences / National Research Council, November 1972.

29. " Programs for Monitoring Radioactivity in the Environs of Nuclear Power Plants," Regulatory Guide 4.1, Revision 1, U.S. Nuclear Regulatory Commission, April 1975.

30. "An Acceptable Radiological Environmental Monitoring Program," Radiological Assessment Branch Technical Position, Revision 1, U.S. Nuclear Regulatory Commission, November 1979.

Wolf Creek FES 5-72

l

31. " Measuring, Evaluating, and Reporting Radioactivity in Solid Wastes and Releases of Radioactive Materials in Liquid and Gaseous Effluents from Light-Water-Cooled Nuclear Power Plants," Regulatory Guide 1.21, Revision 1, U.S. Nuclear Regulatory Commission, June 1974.

32. Statement of Interim Policy, " Nuclear Power Plant Accident Considera-tions Under the National Environmental Policy Act of 1979,"

45 FR 40101-40104, June 13, 1980.

! 33. " Final Safety Analysis Report (FSAR) for the Wolf Creek Generating Station, Unit No. 1," Docket No. 50-482, Kansas Gas and Electric Co.

and Kansas City Power and Light Co., tendered February 19, 1980, docketed July 31, 1980, as amended. Standardized Nuclear Unit Power Plant System, Final Safety Analysis Report, Docket No. 50-482, tendered February 19, 1980, docketed July 31, 1980, as amended.

34. " Safety Evaluation Report for the Wolf Creek Generating Station, Unit No. 1," Docket No. 50-482, U.S. Nuclear Regulatory Commission (NUREG-0881).

3

35. " Energy in Transition 1985 - 2010," Final Report of the Committee on

! Nuclear and Alternative Energy Systems (CONAES), National Research Council, I Chapter 9, pp 517-534, 1979.*

36. C. E. Land, Science 209, 1197, September 12, 1980.

i "The Effects on Populations of Exposure to Low Levels of Ionizing 37.

Radiation," National Academy of Sciences / National Research Council, Committee on the Biological Effects of Ionizing Radiations (BEIR),

4 July 1980.

38. H.W. Bertini et al., Nuclear Safety Information Center, Oak Ridge l

National Laboratory, " Descriptions of Selected Accidents That Have Occurred at Nuclear Reactor Facilities," ORNL/NSIC-176, April 1980.

39. L. B. Marsh, " Evaluation of Steam Generator Tube Rupture Accidents,"

U.S. Nuclear Regulatory Commission, NUREG-0651, March 1980.

40. "Three Mile Island - A Report to the Commissioners and the Public," Vol. I, I Mitchell Rogovin, Director, Nuclear Regulatory Commission Special Inqui~ry Group, Summary Section 9, January .'980.

41. " Report of the President's Commission on the Accident at Three Mile Island," Commission Findings B, Health Effects, October 1979.

42. " Clarification of TMI Action Plan Requirements," U.S. Nuclear Regulatory Commission, NUREG-0737, November 1980.

RThis report was also published in 1980 by W.H. Freeman and Company. Pages cited will differ.

Wolf Creek FES 5-73

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

)

43. " Reactor Safety Study--An Assessment," U.S. Nuclear Regulatory Commission, WASH-1400 (NUREG-75/014), October 1975.

44. " Task Force Report on Interim Operations of Indian Point," U.S. Nuclear

, Regulatory Cornmission, NUREG-0715. August 1980.

1

45. H.W. Lewis et al., " Risk Assessment Review Group Report to the U.S. Nuclear Regulatory Commission," NUREG/CR-0400, September 1978.

46. " Overview of the Reactor Safety Study Consequences Model," U.S. Nuclear i Regulatory Commission, NUREG-0340, October 1977.

1 i 47. " Liquid Pathway Generic Study," U.S. Nuclear Regulatory Commission, j NUREG-0440, February 1978.

i 48. Letter from G. L. Koester, KG&E Company, to H. R. Denton, U.S. Nuclear Regulatory Commission, October 9, 1981, containing Final Report, Class 9

{ Accident Liquid Pathway Assessment, Wolf Creek Generating Station.

1 i 49. "NRC Action Plan Developed as a Result of the TMI-2 Accident," Vol. I, U.S. Nuclear Regulatory Commission, NUREG-0660, May 1980.

50. " Environmental Survey of the Reprocessing and Waste Management Portions of the LWR Fuel Cycle," U.S. Nuclear Regulatory Commission, NUREG-0116

(Supplement 1 to WASH-1248), October 1976.

51. "Public Comments and Task Force Responses Regarding the Environmental '

Survey of the Reprocessing and Waste Management Portions of the LWR Fuel Cycle," U.S. Nuclear Regulatory Commission, NUREG-0216 (Supplement 2 to j Wash-1248), March 1977.

)

52. " Environmental Survey of the Uranium Fuel Cycle," U.S. Atomic Energy l Commissiun, WASH-1248, April 1974.

53. " Draft Generic Environmental Impact Statement on Decommissioning of Nuclear Facilities," U.S. Nuclear Regulatory Commission, NUREG-0586, January 1981.

54. Letter from G. L. Koester, K G & E Company, to H. R. Denton, U.S. Nuclear Regulatory Commission, March 19, 1982, with enclosure: " Makeup Screenhouse Impingement Monitoring Report, November, 1980 - October, 1981."

55. " Cancer Facts and Figures 1979," American Cancer Society, 1978.

56. " Sources and Effects of Ionizing Radiation," United Nations Scientific l Committee on the Effects of Atomic Radiation, 1977.

I

. 57. " Review of the Current State of Radiation Protection Philosophy," National Council on Radiation Protection and Measurements, NCRP Report No. 43,

! January 1975.

i Wolf Creek FES 5-74

6. EVALUATION OF THE PROPOSED ACTION 6.1 UNAVOIDABLE ADVERSE ENVIRONMENTAL EFFECTS The staf f has reassessed the physical, social, and economic impacts that can be attributed to operation of WCGS. Such impacts, beneficial or adverse, are summarized in Table 6.1 of this environmental statement. Inasmuch as the station is currently under construction, many of the expected adverse impacts of the construction phase are evident. The applicant is committed to an ongoing program of restoration and redress of the station site that will be completed after the termination of the construction period.

At the present time the staf f foresees no impacts of a magnitude requiring mitigating actions. However:

a. Before engaging in additional construction or operational activities that may result in a significant adverse environmental impact that was not evaluated or that is significantly greater than that evaluated in this statement, the applicant shall provide written notification of such activities to the Director of the Office of Nuclear Reactor Regulation and shall receive written approval from that office before proceeding with such activities.

b. The applicant shall carry out the environmental monitoring programs outlined in Section 5 of this statement as modified and approved by the staf f and implemented in the environmental protection plan that will be incorporated in the operating licenses for WCGS

c. If adverse environmental ef fects or evidence of irreversible environ-mental damage are detected during the operating life of the station, the applicant shall provide the staff with an analysis of the problem and a proposed course of action to alleviate it.

6.2 IRREVERSIBLE AND IRRETRIEVABLE COMMITMENTS OF RESOURCES There has been no change in the staff's assessment of this impact since the earlier review except that the continuing escalation of costs has increased the dollar values of the materials used for constructing and fueling the station.

6.3 RELATIONSHIP BETWEEN LOCAL SHORT-TERM USES OF MAN'S ENVIRONMENT AND THE MAINTENANCE AND ENHANCEMENT OF LONG-TERM PRODUCTIVITY There have been no signficant changes in the staf f's preconstruction evalua-tion of the relationship between environmental ef fects of short-term uses (construction and operation of the station) and long-term productivity (FES-CP, Sec. 10.2). The conclusion that the dedication of resources for a nuclear 6-1

4 l

i Table 6.1. Benefit-Cost Summary for WCGS Magnitude Staff Assessment

. Benefit or Cost (Reference) or Referencett of Benefit or Cost?

BENEFITS Direct Electrical energy 6 billion kWh/yr Moderate Additional generating capacity 1150 MWe Moderate 1

Reduced generating costs About $178 million/yr Large Indirect Local property taxes (Sec. 5.8) *$12 million/yr (1985) Large Employment (Sec. 5.8) 325 employees Moderate Payroll (Sec. 5.8) 6.8 million/yr (1980$) Moderaty

. Local purchases (Sec. 5.8) $25,000/yr small [ l l

l COSTS l Economic l Fuel s8.9 mill /kWh (1984) Small l Operation and maintenance $ 3.8 mill /kWh (1984) Small I Decommissioning $63 million (1984$) Sea 11 Environmental and Socioeconomic Resources committed:

Land (Sec. 4.2.2) 3970 ha Moderate Water (Sec. 4.2.3) 1.5 m8 /s Moderate l

Uranium - U 0s About 5000 t Small 3 (NUREG-0480)

Other materials and supplies (FES-CP, Sec. 10.3.4) j Damages suffered by other water users due to:

Surface water consumption (Sec. 5.3.1) 1.5 m8 /s (saximus) Small l Surface-water contamination Secs. 5.3.2 & 5.9.1 Small

' Groundwater eontamination Sec. 5.3.2.4 Small i 1

! 6-2

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Table 6.1. (Continued)

Magnitude Staff Assessment Benefit or Cost (Reference) or Referencett of Benefit or Costt2 COSTS (Continued)

Environmental and Socioeconomic (Continued)

Camage to aquatic biota due to:

Imoingement and entratnment Sec. 5.5.2 Small Thermal effects Sec. 5.5.2 Small Chemical discharges Sec. 5.5.2 Small "akeuo water withdrawals Sec. 5.5.2, 5.6 Small Damage to terrestrial resources due to:

Fog and ice Sec. 5.4.1 Small Vegetation Management Sec. 5.5.1 Small Effects on animal populations Sec. 5.5.1, 5.6 Small Adverse socioeconomic effects due to:

Loss of historic or archeological resources (Sec. 5.7) None visual intrusion (Sec. 5.8) Small Noise (Sec. 5.8) Small Increased traffic (Sec. 5.8) Small Increased demanos on public facilities and services (Sec. 5.8) Small Increased demands on private facilities and services (Sec. 5.8) Small Adverse nonradiological health effects due to:

Air ouality changes (Sec. 5.4) Small dater quality changes (Sec. 5.3.2) Small Adverse radiological health effects due to:

Reactor operation on:

General populatien (Sec. 5.9.3) Small Workers onsite (Sec. 5.9.3) Small Salance of fuel cycle (Sec. 5.10) Small Accident risns (Sec. 5.9.4) Small H

'where a particular unit of measure for a benefit / cost category has not been specified in the EIS, or where an estimate of the magnitude of the cenefit/ cost under consideration has not been made, the reader is directed to the appropriate EIS section or other source for further information.

d

- Suojective measure of costs and benefits are assigned by reviewers, where quantification is not possible: "Small - impacts that, in the reviewers' judgments, are of such minor nature, based on currently availaDie information, that they do not warrant detailed investigations =or considerations of titigative actions; " Moderate" - impacts that, in the reviewers' judgments, d are likely to be clearly evident (mitigation alternatives are usually considered for moderate l impacts); "Large* - impacts that, in the reviewers' judgments, represent either a severe penalty or a sajor benefit. Acceptance requires that large negative impacts should be more than offset i by other overriding project considerations.

6-3

generating station at the WCGS site is consistent with the balancing of short-and long-term objectives for use of the environment is still valid.

6.4 BENEFIT-COST

SUMMARY

\ .

The benefits and costs of operating WCGS are summarized in Table 6.1, which provides the staff's assessments of degrees of benefit or cost, as well as magnitudes of impact where they are quantifiable. References that contain further information are indicated.

l 6.4.1 Benefits I The primary benefits to be derived from operation of WCGS include an annual production of about 6 billion kWh of baseload electrical energy over the lifetime of the plant, improved reliability of both the KG&E and KCPL systems brought about by the addition of 1150 MWe of generating capacity to the system, savings in 1986 of about $178 million in production costs per year, and an increase in the diversity of the fuel supply of the system as a result of providing baseload generating capacity using a fuel other than coal or gas.

Secondary benefits arising from operation of WCGS include wages paid to 325 operating personnel (projected to be $6.8 million per year in 1980 dollars) and taxes paid to local political subdivisions (Sec. 5.8). The applicant projects property tax payments totaling more than $12 million in 1985, with more than 90% of these revenues going to Coffey County and School District 244 (Sec. 5.8). The applicant estimates that local retail purchases for the station will be no more than $25,000 per year (Sec. 5.8).

6.4.2 Costs 6.4.2.1 Economic The economic costs associated with station operation include fuel costs and 0 & M costs which are expected to average 8.9 and 3.8 mills per kWh respectively (in 1987 dollars) and assuming a 65% capacity factor in 1987.

A major benefit to be derived from the operation of the Wolf Creek Station is the approximately 6 billion kWh of baseload electrical energy which will be produced annually (thus projection assumes that WCGS will operate at an annual average capacity factor of 60%). The addition of the plant will also improve j the applicant's (and KCPL's) ability to reliably supply system load requirements by contributing 1150 MW of generating capacity to the interconnacted bulk power supply for the Southwest Power Pool, and the Missouri-Kansas Interconnect (M0KAN).

Another benefit to be derived is the saving in overall system production costs which will accrue from the operation of the plant. A production cost analysis 1 was submitted by the applicant (ER-OL, Rev. 3, pg.1.3-3) which projected i system costs in 1986, with and without WCGS in service. The average savings l l

projected for the first full year of operation (1986) was $178 million. Applicant 1 i estimates these savings will increase as the cost of replacement energy increases and improvement in the WCGS capacity factor is realized. 1 6-4

, The staf f's estimate of decommissioning costs for WCGS is $63 million in 1984 dollars.

~

6.4.2.2 Environmental and Socioeconomic Changes in station design, operating procedures, and environmental data that were taken into consideration in this operating-license review have not led to significant increases in the environmental or socioeconomic costs over the corresponding costs that were estimated during the construction permit review.

The costs considered include those attributable to the uranium fuel cycle and to plant accidents. Except for the moderate amount of the land resource committed, all costs are considered small.

6.4.3 Conclusions As a result of the analysis and review of potential environmental, technical, economic, and social impacts, the staff has prepared an updated forecast of the ef fects of operation of WCGS. No new information has been obtained that alters the overall balancing of the benefits versus the environmental costs of plant operation. Consequently, the staff has determined that the station will most likely operate with only minimal environmental impact. The staff finds that the primary benefits of minimizing KG&E, KCPL, and KEPCo system produc-tion costs and increasing baseload generating capacity by 1150 MWe greatly outweigh the environmental, social, and economic costs.

6-5

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7. LIST OF CONTRIBUTORS The following personnel of the Office of Nuclear Reactor Regulation, U.S.

Nuclear Regulatory Commission, Washington, DC, and consultants participated in preparation of this draf t environmental statement:

NAME TITLE REVIEW BRANCH Jon B. Hopkins Project Manager Licensing' Gordon Edison Project Manager Licensing Maurice Messier Environmental Review Antitrust & Economic Coordinator Analysis Charles L. Miller Nuclear Chemical Eng. Effluent Treatment i

Systems Lynne A. O'Reilly Health Physicist Radiological Assessment Michael E. Wangler Health Physicist Radiological Assessment David M. Rohrer Emerg. Prep. Analyst Emerg. Prep. Lic.

Ren Wescott Hydraulic Engineer Hydrol. & Geotechnical Richard B. Codell Sr. Hydraulic Engineer Hydrol. & Geotechnical i

, Jocelynn A. Mitchell Nuclear Engineer Accident Evaluation' ,

James Fairobent Meteorologist AccidentEvaluatioE i

Anton A. Sinisgalli Site Analyst Siting Analysis. '

Kenneth C. Dempsey Nuclear Engineer Accident Evaluation .

Sarbeswar Acharya Environ./ Radiation Accident Evaluation -

Physicist Millard L. Wohl Nu; lear Engineer. Accident Evaluation j James Hauxhurst Meteorologist Accident Evaluation Reginald L. Gotchy Sr. Radiobiologist Radiological Assessment Argil L. Toalston Section Leader, Antitrust & Economic Antitrust Analysis ,

j Brian J. Richter Cost-Benefit Sitingj /)nalysis ' ' ' ~

c' Economist  ;[' .

I Pacific Northwest Laboratory .

Richard Ecker Consultant <

Ron Schatla Consultant David Myers Consultant ~

-/ .

Richard Skaggs Consultant j 1

Wolf Creek FES 7-1

/ .#

.a .

The following personnel of the Division of Environmental Impact Studies of Argonne National Laboratory, Argonne, 111. participated in the preparation of this environmental statement.

J.E. Carson Project Leader; Ph.D. (Meteorology) 1960, 38 years experience.

P.A. Benioff Nonradioactive-Waste Discharges, Water Quality; Ph.D. (Chemistry) 1959, 22 years experience.

L.S. Busch Need for Power, Benefit-Cost Analyses; B.S. (Chemical Engineering) 1939, 42 years experience.

J.D. DePue Editor; M.S. (Biology) 1974, 15 years experience.

C.E. Dungey Air Quality, Cooling-Lake Effects; M.S. (Meteorology) 1976, 6 years experience.

D.D. Ness Ecology; Ph.D. (Forestry) 1972; 18 years experience.

S.Y.H. Tsai Thermal Discharge; PH.D (Civil Engineering) 1978, 5 years experience.

1 1

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8. LIST OF AGENCIES AND ORGANIZATIONS REQUESTED TO COMMENT ON THE DRAFT ENVIRONMENTAL STATEMENT Advisory Council on Historic Preservation Department of Agriculture Department of the Army, Corps of Engineers Department of Commerce Department of Energy Department of Health and Human Services Department of Housing and Urban Development Department of the Interior Department of Transportation Environmental Protection Agency Federal Emergency Management Administration Office of the Governor, State of Kansas Division of the Budget, State of Kansas State Attorney General's Office State Historic Liaison Office Kansas State Soil Conservation Service Chairman, Coffey County Commission 8-1

l l

l APPENDIX A RESPONSES TO COMMENTS ON THE DRAFT ENVIRONMENTAL STATEMENT OPERATING LICENSE STAGE WOLF CREEK GENERATING STATION UNIT 1 A.1 RESPONSES TO COMMENTS ON THE DRAFT ENVIRONMENTAL STATEMENT Pursuant to 10 CFR 51, the " Draft Environmental Statement Related to the Operation of Wolf Creek Generating Station, Unit 1" was transmitted, with a request for comments, to the agencies and organizations listed in Section 8 of this report.

In addition, the NRC requested comments on the DES from interested persons by a notice published in the Federal Register on January 29, 1982 (47 FR 4370).

In response to these requests, comments were received from the following:

(1) U.S. Department of Agriculture, Soil Conservation Service (DASCS)

(2) U.S. Department of Agriculture, Economics & Statistics Service (DAESS)

(3) U.S. Department of Health & Human Services (DHHS)

(4) U.S. Department of Housing and Urban Development (DHUD)

(5) U.S. Department of Army, Corps of Engineers (DACE)

(6) U.S. Department of the Interior (DI)

(7) U.S. Environmental Protection Agency (EPA)

(8) State of Kansas, Division of the Budget (SKDB)

(9) City of Lawrence Kansas (CLK)

(10) Douglas County Emergency Preparedness (DCEP)

(11) Margaret W. Bangs (MWB)

(12) Scott H. Jamieson (SHJ)

(13) Kansans for Sensible Energy (KASE)

(14) Kansas Gas and Electric Company (KG&E)

(15) Larry R. Kipp (LRK)

(16) William A. Lochstet (WAL)

(17) Teddi McCullogh (TM)

(18) Anne Moore (AM)

(19) Southwind Planning Service (SPS)

(20) Rebecca Vaughn (RV)

The comment letters are reproduced in this statement in Appendix 8. The comments received from DASCS, DAESS, DHUD, and TM did not require a staff response.

The remaining comment letters did require responses and/cr revisions to the text of the environmental statement. The staff's consideration of these comments and its disposition of the issues involved are reflected in part by revised text in the pertinent sections of this report and in part by the discussion in this section. The comments are categorized by subject and are referenced by the use of the above abbreviations and page number.

Wolf Creek FES A-1

A.2 FOREWORD (SKDB, B-22)

SKDB commented on their understanding of resource management.

The landowners (the Applicants) do not plan to "open the lake for public recreational use" (ER-OL, R 290.4, page 290.2). The landowners also designate that " land outside the exclusion area and above the cooling lake normal pool

. level, but inside the WCGS site property, will be utilized to the extent

) practical as it was prior to its purchase for the WCGS site" (ER-OL, Section 2.8.4.2).

A.3 ALTERNATIVES TO THE PROPOSED ACTION (SKDB, B-17 and B-19; MWB, B-31, B-32, and B-33; KASE, B-40, B-41, B-42, and B-43; and AM, B-69)

Comments have been received regarding the cost of the Wolf Creek plant, alterna-tives to the plant, and the resulting benefit / cost analysis.

The Commission has amended its regulations effective April 26, 1982 to provide that need for power issues and issues related to. alternative energy sources will not be considered in ongoing and future operating license proceedings for nuclear plants unless a showing of "special circumstances" is made under 10 CFR Section 2.758 or the Commission otherwise so requires.

The Commission has determined that the need for power is fully considered at the construction permit (CP) stage of the regulatory review where a finding of insufficient need could factor into denial of issuance of a CP. At the opera-ting license (0L) review stage, the proposed plant is substantially constructed and a finding of insufficient need would not, in itself, result in denial of the operating license. The Commission was further influenced by the substantial information which supports the conclusion that nuclear plants are lower in operating costs than conventional fossil plants. If conservation, or other factors, lowers anticipated demand, utilities remove generating facilities from service according to their costs of operation, with the most expensive facili-ties removed first. Thus, a completed nuclear plant would serve to substitute for less economical generating capacity. (See Section 2.)

The Commission has ' Iso noted that alternative energy source issues are resolved at the CP stage ano the CP is granted only after a finding that, on balance, no obviously superior alternative to the proposed nuclear facility exists. The Commission concluded that this determination is unlikely to change even if an alternative is shown to be marginally environmentally superior in comparison to l

operation of the nuclear facility because of the economic advantage which operation of the nuclear plant would have over available alternative sources.

(See Sections 3 and 6.)

A.4 PROJECT DESCRIPTION AND AFFECTED ENVIRONMENT A.4.a Land Use (SPS, B-70)

SPS makes two comments concerning land use. The first comment claims that the DES statement of no significant land use changes occurring is inaccurate because of nearly 10,000 acres of land being converted from agricultural to industrial use. The statement on land use in the DES-OL, Section 4.2.2, refers Wolf Creek FES A-2

to off-site land use trends. However, the modifications to land use on the site itself, since issuance of the FES-CP, including changes in transmission line corridors are also described in Section 4.2.2. The second comment refers to potential future residential and commercial development around the plant being affected due to public concern over the safety of nuclear power. The staff has been generally sensitive to this issue in its CP and OL reviews.

Several post-licensing studies of operating nuclear power plants have also explored this concern. In no case has it been shown that nuclear power plant operation curtailed demographic and/or economic growth and development in the areas surrounding the plants.

A.4.b Radioactive-Waste-Management Systems (EPA, B-13; LRK, B-59)

The EPA commented on the changes in the liquid and gaseous effluents from the FES-CP.

The minor design changes that evolved in the Wolf Creek radwaste systems design have improved the efficiency of the liquid radioactive waste treatment system, thus lowering the amount of radioactive material in liquids that will be released from the plant. The significantly higher gaseous source term is due to the " continuous containment minipurge system" that has been added to the design. The larger source term is due primarily to the continuous Xe-133 (t 1/2 =5.25d.) release from the containment.

LRK commented on waste storage.

The waste repositories that Dr. Roy is referring to are for the storage of "high level" radioactive wastes. The waste that will be shipped annually from Wolf Creek will be " low level" radioactive wastes and will be orders of magni-tude lower in radioactive materials content. These wastes will be shipped to one of the currently licensed " low level" waste burial sites.

A.4.c Nonradioactive-Waste-Management System (KG&E, B-54)

The text has been changed to reflect the comment. There is no substantive change since 66 8e sulfuric acid is essentially 100% sulfuric acid. [ Table 3.6-2, ER-OL and Handbook of Chemistry and Physics, 57th Edition, CRC Press Inc., P. F-7.]

A.4.d Hydrology and Water Use (DACE, B-7; SK08, B-25) 0 ACE commented on annual runoff, rainfall data, spillway material, and sedimentation.

The streamflow data used to estimate monthly average runoff from Wolf Creek Watershed was not provided by the applicant. However, the inflow calculated for Wolf Creek used in the analyses of the cooling lake drawdown during the 50 year drought was very small in comparison to evaporative losses and make up pumped from the Neosho River. Therefore, any effect of overestimating the Wolf Creek runoff on determining the operational impacts of the Wolf Creek Generating Station is considered to be minimal.

Wolf Creek FES A-3

a-l The applicant has listed " Rainfall Frequency Atlas of the United States," U.S.

Weather Bureau 1961, Technical Report No. 40, as the source of rainfall data for recurrent interval floods; " Standard Project Flood Determinations, U.S.

Army Corps of Engineers, 1952, EM 1110-2-1411, as the source of rainfall data for the Standard Project Flood; and " Seasonal Variation of the Probable Maximum Precipitation East of the 105th Meridian for Areas from 10 to 1,000 Square

Miles and Durations of 6, 12, 24, and 48 Hours," U.S. Weather Bureau, 1956, Hydrometeorological Report No. 33, as the source of rainfall data for the l Probable Maximum Flood.

The service spillway which will function alone for floods up to the 100 year recurrence interval flood is a concrete semicircular ogee-crested spillway.

Water discharges by way of a concrete chute to a stilling basin. The channel l downstream of the stilling basin is protected against erosion with riprap.

i The auxiliary or emergency spillway is a 500 f t open cut spillway with a one foot thick concrete apron on the crest and downstream side. This concrete i apron extends down to solid limestone rock. There is also a sloping concrete apron on the sides of the spillway channel which is continued downstream sufficiently to check erosion during the PMF below the toe of the main dam.

Additional detail regarding design of the spillways is contained in subsection 2.4.8.2.2 of the applicants Final Safety Evaluation Report.

1 The section has been modified to state the conservation storage available after l adjustment for sedimentation.

j SKDB commented on yield capability from the water supply portion, and regulated storage.

In response to the comment on yield capability, the seni.ence has been revised according to the recommendation.

In response to the comment on regulated storage, the paragraph has been revised  !

, according to the recommendations. The reference to September 7, 1963 will be

deleted.

A.4.e Water Quality (DI, B-8, B-9, and B-10; SKDB, B-23)

DI commented on instream flow requirements.

The Final Environmental Statement - Construction Permit Stage (FES-CP) contains a table of monthly average flows in the Neosho River immediately downstream of the John Redmond Dam with and without the Wolf Creek Generating Station (WCGS) l for the period 1951 through 1959 (Table 5.1 FES-CP). The period analyzed in this table contains the drought of record which is estimated to have a recur-rence interval of 50 years. This analysis shows that during design drought

' conditions, flow downstream from the John Redmond Dam will not be affected by pumping for WCGS. This is because the storage allocated in John Redmond j Reservoir for supply to WCGS is separate from that allocated in John Redmond, 4

Council Grove, and Marion Reservoirs for meeting downstream water quality l requirements. Also, present downstream water quality requirements are still the same as those upon which the analysis provided in the FES-CP are based.

Wolf Creek FES A-4 t

- . - ,m- c - - - - . . _ _ _ _ , _,, . . , - - - . . . -. - - _ - - , - - , _ _ . _.

I The staff recognizes that the Kansas Water Office does have the authority to set new instream flow requirements, however, it is the staff's understanding that any increases can probably be met by presently unallocated storage upstream of John Redmond Reservoir.

Also, DI and SKDB commented on blowdown releases.

Information presented in Section 5.3.1.1 indicates that cooling lake water or blowdown will not be released to the Neosho River during drought condition. ,

This provision is necessary to avoid violation of Kansas Water Quality Criteria during low-flow conditions in the river; details are presented in Section 5.3.2.1.

A.4.f Ecology (DI, B-9 and B-11; SKDB, B-22 and B-23)

DI commented on impacts to fish, wildlife, and their respective habitats.

DI failed to note that the development of the cooling lake also resulted in the creation of over 5,000 acres of aquatic environment, thus providing habitat for aquatic biota as well as terrestrial species that utilize aquatic habitats for one or more life requirements. The staff does not consider this conversion from terrestrial to aquatic environment to be an unacceptable tradeoff. Aside from the cooling lake area, the potential effects on other terrestrial wildlife habitats of the WCGS site attributable to construction and operational activi-ties were assessed and evaluated to be of minor consequence, as reported in the FES-CP and this environmental statement. The potential effects on wildlife habitat attributable to construction and operation of offsite transmission lines were likewise considered to be of a minor nature. Most of the habitat in the transmission line right-of-way consists of range and cropland vegetation types that are compatible with transmission line operation, thus no right-of-way clearing is necessary. In view of the foregoing, the staff does not believe that requirements involving the development and implementation of an intensive management plan for maximizing fish and wildlife habitat resources on the WCGS site are justified. It is also pertinent to note that applicant-landowner right-of-way lease agreements provide for the land-owners use of the transmission line corridor, subject to certain safety specifications.

DI and SKDB made comments concerning the NEOSH0 madtom.

The presence of the Neosho madtom at the Neosho River--Wolf Creek confluence, the habitat of the species, and the potential effects on the species are discussed in the subject environmental statement and in the FES-CP.

A.4.g Endangered and Threatened Species (SKDB, B-22; KG&E, 8-52 and 8-53)

Both SKDB and KG&E commented on the presence of the warty-backed mussel.

In regard to the SKDB comment, the basis for the staf f's use of Since the warty-the qualifying phrase "if present" is presented in Section 4.3.5 (p. 4-21).

backed mussel was known from only two localities in Kansas as of 1962, Schwil-ling's citing of Cope (1979) as having collected the species at 26 spearate locations on 6 different rivers creates uncertainties as to actual distribution of the species. That the species has not been documented in Coffey County is Wolf Creek FES A-5

contrary to published information by the State Biological Survey of Kansas

("New Records of the Fauna and Flora of Kansas for 1976," Tech. Pub. No. 4, State Biological Survey of Kansas, May 20, 1977). Accordingly, the species was found in the Neosho River at Burlington in 1972. While the species may have since disappeared, the staff believes it reasonable to expect that the species may currently occur in the Neosho River immediately downstream of the Redmond dam.

The staf f suggests that " river flow monitoring information" is available from the Water Resources Division of the U.S. Geological Survey office in Lawrence, Kansas.

In regard to the KG&E comment, the staff has reviewed the document referred to in the comment; i.e., H. D. Murray and A. B. Leonard, 1962. Statements by these authors relative to suitable habitats for the warty-backed mussel (Quadrula nodulata) are as follows:

" Baker (1928, p. 86) reports that this species is found in large rivers where it usually lives in mud bottoms. Q. nodulata has been obtained from but two localities in Kansas; in both instances the animals were found in rocky stream bottoms having little mud" (p. 59). Also, " Members of the genera" . ., "and Quadrula are to be expected in rocky and gravelly areas as well as in mud bottoms" (p. 29).

The foregoing quotations do not support the conclusions presented in the comment.

Also, KG&E commented on the possiblility of droughts adversely affecting aquatic biota.

The staff acknowledges that a future drought event could be sufficiently intense such that the effects of the drought alone would require water releases down the Neosho River to be limited to volumes necessary for satisfaction of previous water rights and maintenance of water quality. However, given the occurrence of such a drought, water withdrawals from the John Redmond Reservoir for operation of the Wolf Creek Generating Station (WCGS) would hasten the onset of low-flow conditions in the river and depletion of the conservation pool in the reservoir. Continued water withdrawals for WCGS operation during the drought would also delay restoration of the conservation pool in the reservoir, thus prolonging the period when aquatic biota of the river and reservoir would be exposed to adverse conditions. Prolonged exposure would also tend to intensify the severity of some impacts on aquatic biota; i.e. ,

overcrowding of fish, overgrazing of aquatic flora and other effects noted in the DES-OL (page 5-15). Accordingly, the adverse effects on aquatic biota due to a severe drought episode would not be the "same with or without the presence of the Wolf Creek Generating Station."

It is also pertinent to note that the occurrence of adverse effects on aquatic biota would not be limited to periods of prolonned arought. For example, aquatic communities that become established during a series of good water years could subsequently be impacted due to the combined influence of water with-drawals for WCGS and moderate reduction of inflows to the Redmond reservoir.

l l

Wolf Creek FES A-6

i In conclusion, the staff does not perceive a need for modification of state-ments quoted from the DES-OL (see comment)-in order to be consistent with the conclusion referred to in the FES-CP.

A.5 ENVIRONMENTAL' CONSEQUENCES AND MITIGATING ACTIONS 4

A.S.a Water Use (DI, B-10; SKDB, B-22 and B-26; KG&E, 8-55)

I

}

Both DI and SKDB commented on operational activites potentially affecting surface water.

The staff does not understand the significance of " loss of management";

J however, the comment appears to imply that water withdrawals for WCGS operation could adversely affect fish and wildlife populations in the John Redmond Reservoir. The staff agrees and the potential impacts are acknowledged in i Section 5.5.2.1 (paragraph 3). Further, sections of the FES-CP are referenced for additional information.

Also, SKDB commented on water-use impacts.

The text relative to expected water-use impacts has been revised. Given that

! the " water levels in the reservoir have not been allowed to drop below con-servation pool" since 1978, the staff does not perceive why this situation "has

,' resulted in a negative impact on fisheries management efforts...." Any negative environmental effects caused by pumping operations would have been more severe if water levels in the reservoir had been lowered to or below the

upper limit of the conservation pool. While uncertain of the rationale pre-sented in the comment, the staff has assumed that the " negative impact" is in reference to water-use, and therefore-advises that details and conclusions relative to water withdrawals from the reservoir river system are presented in Section 5.3.1.1.

i In response to the SKDB comments on page B-26, the paragraphs will be revised

according to the recommendations.

In response to the KG&E comment concerning maximum pumping rate, the paragraph will be revised to include the additional information.

1 A.S.b Water Quality (SPS, B-70)

SPS made a comment concerning the cooling lake being made inhospitable.

[

Consistent with information presented in the ER-OL (R. 291.6, Rev. 3), the staff has deleted reference to Cu as a principal corrosion product in revised text presented in Section 5.5.2.2. Further, the staff has recalculated the anticipated concentrations of the principal corrosion products (Fe, Ni, and Cr) l i that will occur in the cooling lake during WCGS operation. The recalculated concentrations for both total and soluble Fe remain unchanged from those derived from previous calculations (Table 4.2); the values for Ni and Cr l

concentrations are less than previously estimated. The appropriate revised

estimates are included in revised text of Section 5.5.2.2, as is the staff's conclusion; i.e., the increase in concentrations of Fe, Ni, and Cr in the

' cooling lake attributable to WCGS operation are not expected to adversely i

j Wolf Creek FES A-7 i

affect aquatic biota, even during periods of prolonged drought when concentra-tions of these chemicals will be higher than normal.

The thermal and chlorination effects on biota of the cooling lake that will be attributable to WCGS operation have been addressed in the FES-CP (Section 5.5.2.3) and Section 5.5.2.2 of the subject environmental statement. As noted in these discussions, the area in which extreme temperature changes and chlori-nation will adversely affect aquatic biota will be limited to the vicinity of the ccoling water outfall to the cooling lake. The affected area represents but a small fraction of the 5,000-acre cooling lake and affected organisms are expected to have a negligible effect on the overall biotic productivity of the lake.

In view of the foregoing, the allegation that the 5,000 acres of agricultural land converted to an aquatic environment "would become useless to man and other biota" is not a realistic expectation.

A.S.c Terrestrial Ecology (DI, B-10; SKDB, B-23)

DI commented on the potential for an outbreak of waterfowl diseases such as duck viral enteritis. The staff acknowledges the need for preparedness with respect to potential outbreaks of waterfowl diseases such as duck viral enteritis, and the text in Section 5.5.1.1 has been revised in response to this comment.

1 The significance of a " defacto sanctuary available in the cooling lake" is not l clear. '

The proximity of the cooling lake and the Redmond reservoir provides for several possible events; i.e., that the local waterfowl population may increase significantly or that waterfowl will exhibit a preference for one waterbody over the other. The staff considers it premature to assume that waterfowl predation on croplands adjacent to the lake will be a severe problem. The time of the year when the heated condition of the cooling lake will be attractive to waterfowl will likely occur subsequent to normal crop harvesting. However, in the event that crop predation by waterfowl becomes a severe problem, the applicant is obligated to initiate actions specified in Section 6.1 (item c).

In response to a DI and SKDB comment, the text in Section 5.5.1.1 paragraph 1 has been revised for clarification.

Also, DI commented on lessening bird mortality.

The staff is aware of several techniques employed to mitigate bird impingements. As noted in Section 5.5.1.2 (p. 5-11), bird impingements on structures such as transmission lines are influenced by a number of site specific variables. It is difficult to predict how, where, and under what conditions significant impingement may occur. Accordingly, the staff believes j that the actions specified in the revised text of Section 5.5.1.2 are l appropriate.

l l In response to an SKDB comment, the text in Section 5.5.1.1 paragraph 3 has been modified.

l Wolf Creek FES A-8  !

l

(

A.S.d Aquatic Ecology (DI, B-10; SKDB, B-23; KG&E, B-55 and B-56)

Both DI and SKDB commented on water withdrawals.

The John Redmond Reservoir is a fully regulated impoundment under management of the U.S. Army Corps of Engineers. In accord with other management objectives, water releases from the reservoir are controlled by the Corps in order to accommodate downstream water users.

Since the applicant is and will be one of the downstream water users, water withdrawals for WCGS operation will be coordinated with overall management objectives of reservoir management.

In response to the KG&E comment on copper as a corrosion product and in accordance with the information presented in the ER-OL (Revision 3, RQ 291.6),

reference to copper as a corrosion product has been deleted.

In response to the KG&E comment concerning chlorine effects, the text in Section 5.5.2.2 has been modified to further clarify the staff's evaluation of impacts related to proposed chlorine treatments.

A. 5. e Radiological Impacts f rom Routine Operations (DHHS, B-5; DI, B-11; EPA, B-13; SKDB, B-23; AM, B-67, B-68; SPS, B-70; RV, B-71)

DHHS commented on the airborne radiciodine sampling and analysis program.

Table 5.5 indicates that TLD's will be used at designated sites for detecting airborne gamma radiation and that a radioiodine cartridge will be used at 20%

of these sites for collection of I-131. The use of these separate methods allows for the determination of radiohalogens in the presence of radionoble gases under normal operating conditions. Instrument systems for radiciodine monitoring, as well as other types of environmental monitoring, are evaluated before and during use to ensure that they perform according to Technical Specifications. Licensees are required to participate in an Interlaboratory Comparison Program, which provides independent checks on the precision and accuracy of the measurements of radioactive material in environmental monitoring.

Both DI and SKDB commented concerning monitoring fish flesh from within the cooling lake for potential uptake of radioactive contaiminants.

In Table 5.5 of the DES and the FES under Ingestion the applicant indicates that fish in the Wolf Creek Cooling Reservoir will be monitored for radioactive material uptake.

EPA commented concerning drinking water samples and TLD sampling frequency.

The National Interior Drinking Water Regulations are applied to the treated water product from a municipal water supplier and are thus imposed on the water supplier and not the reactor facility. However, because of the dilution factor of the river water at the LeRoy intake (cf Table C.4), the licensee's final operational monitoring program should assure that the piant releases are within the required standards. This program will be reviewed in detail by the staff according to the Radiological Assessment Branch Technical Position and the Wolf Creek FES A-9

specifics will be incorporated into the Operational License Radiological Technical Specifications.

Regarding the TLD sampling frequency, the Branch Technical Position requires either quarterly or monthly TLD measurements. Both frequencies are acceptable to the staff. The applicant has specified that quarterly measurements will be made.

However, as noted above, the applicant's operational program will be thoroughly reviewed prior to operation of the plant.

AM inquired as to whether emissions from normal plant operations would reach the Wakarusa Valley.

It is possible that emissions from WCGS will reach to 35 miles during normal operation of the plant. However, this situation was considered in the assess-ment of population and maximum exposed individual doses. Table C.5 summarizes the doses to maximum exposed individual and C.8 summarizes total population doses within 50 miles of the plant.

Also, AM commented concerning radioactive wastes.

Section G.6 of Appendix G of the Wolf Creek DES and FES discusses the impacts on Wolf Creek associated with uranium fuel cycle waste material. The impacts from both high-level waste and low-level waste were considered. This section concluded that no significant radiological impact is expected.

In addition, AM inquired as to whether the activities at the Richards-Gebaur Air Base had been included in the review of potential external hazards.

The air traffic activities associated with Richards-Gebaur Air Base have been included in the staff's assessment of aircraft hazards.

The Richards-Gebaur Air Base is located approximately 129 km (80 mi) NE of the WCGS.

When addressing potential external hazards associated with air traffic, the staff considered airports within 16 km (10 mi) of the site and air traffic within 32 km (20 mi) of the site. Of the 10 federal airways that pass within 32 km (20 mi) of the site, one is a high-altitude (18,000 to 24,000 ft) military refueling route (10.5 mi south southeast of the site) and one is a military low-level training route (5.8 mi northeast of the site). In addition to the military airways which have been considered, including the contribution of traf fic from Richards-Gebaue Air Base, the Department of Defense has agreed to establish an exclusion zene around the nuclear plant.

SPS commented concerning radiological impact on the proposed Tallgrass Prairie National Park.

As stated in Section 5.9.3.3 of the DES and the FES, the radiological impacts on biota other than humans is expected to be immeasurable but in any event no greater than the impacts on humans. This conclusion is based on the best available studies. The staff has seen no study to date that would alter this conclusion.

RV commented on the radiological impacts on humans and on biota other than humans.

Wolf Creek FES A-10 l_____

1 In Section 5.9.3.2 of the FES the radiological impacts on humans has been  !

augmented to include estimates of the number of cancer deaths and genetic disorders that are expected to result from routine operation of Wolf Creek.

In Section 5.9.3.3 of the DES and the FES the radiological impacts on biota other than humans are discussed. This section states that limits established for humans are generally conservative for other species because no biota have yet been discovered that show a sensitivity, in terms of harm, to radiation exposure as low as those expected in areas surrounding an operating nuclear station. As a result, the staff has concluded that no measurable radiological impacts on biota is expected.

A. S. f Environmental Impact of Postulated Accidents (DHHS, B-5; EPA, B-13; MWB, B-33 and B-34; SHJ, B-37; KASE, B-43 to B-47; LRK, B-59; AM, B-67)

DHHS commented concerning radioactive fallout onto open bodies of water and the release of radioactive material to the ground water under the plant.

The relative consequences and risks due to contamination of open bodies of water as a result of atmospheric fallott from severe accidents in the Wolf Creek plant would be similar in kind to those determined for contamination of Lake Erie and the other Great Lakes via the severe accident fallout route for a Perry Nuclear Power Plant (Reference 1) reactor, which was in turn based on calculations performed for the Fermi Unit 2 plant (Reference 2). The conclu-sions of these studies were that for interdiction of tne fish pathway (the major contributor to dose) and the drinking water pathway in a manner similar to pathways involving ground deposition, the consequences would be small compared to those from air and ground contamination. Further, the open-water area near Wolf Creek is very small compared to the area near Perry or Fermi and, therefore, this pathway wocid be con espondingly reduced. Including this pathway would not alter the conclusions with respect to other accident risks compared to either normal operations or to other accident risks to which the general population is exposed.

An extensive discussion of the consequences of release of radioactive material to the ground water under the plant is found in Section 5.9.4.5(5).

EPA comment concerning the accident risk and impact of Design Basis Accidents.

The Design Basis Accidents are judged not to be significant contributors to environmental risk. Also, they have not been subjected to the same kind of There-probabilistic analysis as the more severe accidents that are treated.

fore, probabilities and consequences of Design Basis Accidents cannot be provided on the same basis as severe accidents in Tables 5.8 and 5.9.

References:

1 " Draft Environmental Statement Related to the Operation of Perry Nuclear Power Plants, Units 1 & 2," NUREG-0884, March 1982.

2 " Final Environmental Statement Related to the Operation of Enrico Fermi Atomic Power Plant, Unit No. 2," NUREG-0769, Addendum No. 1 March 1982.

I I

Wolf Creek FES A- 11

MWB commented concerning Probabilistic Risk Assessment and the improvements of NUREG-0660.

Probabilistic Risk Assessment, imprecise as it is, represents an advance in the information available for assessing the environmental impact of severe accidents. Further, its use is in conformance with the Statement of Interim Policy cited in Section 5.9.4.1. As discussed in Appendix E, only one grouping has been retained, PWR7. The other three sequences represent individual sequences. PWR7 sequence group contains accidents of very low release magni-tudes and the retention of the group does not significantly alter the results presented, compared to a calculation considering the sequences individually.

The quoted statement clearly did not say that the plant would not have the improvements indicated in NUREG-0660. Indeed, the applicant has committed to a schedule for implementation of the required improvements delineated in NUREG-0737 as "necessary and sufficient." The calculations presented in the accident chapter, however, did not account for any improvement in safety; to the extent that safety is improved, this represents a conservatism in the calculations.

Both SHJ and pressurized KASEshock.

thermal commented on reactor vessel embrittlement as related to Although not addressed in the DES and FES, pressurized thermal shock is addressed as an unresolved safety issue in the Wolf Creek Safety Evaluation Report (NUREG-0881).

Also, KASE commented concerning WASH-1400 and WASH-740.

The old AEC study of severe accidents, WASH-740, was completed without any attempt to assess the likelihood of the consequences it reported but assumed worst case factors at every step. The methodology utilized in the RSS was the first to attempt to quantify the probabilities as well as the consequences and represented, therefore, an advance in the state-of-the-art. The Wolf Creek l 1

Environmental Statement utilizes site specific data as indicated in Section 5.9.4.5(2) while the RSS considered 100 reactors at 6 sites. Therefore, the worst case from the RSS should not be cited as applicable to Wolf Creek. An i expanded discussion of the uncertainties has been added to Section 5.9.4.5(7). '

It should be noted that the American Physical Society's Review Group considered a preliminary draft of the RSS and provided comments prior to completion and final publication of WASH-1400. The final RSS, therefore, had the benefit of consideration of the APS review group's comments and responded to them. See Appendix XI of WASH-1400. The methodology of the RSS indeed does provide less uncertain results when two systems are to be compared, than when absolute information is desired. The staff considers that the error bounds cited in the revised Section 5.9.4.5(7) adequately characterize the uncertainties. Severe accidents involving melted fuel and offsite radioactive material releases in reactors other than light water power reactors have only peripheral appli-cability to the consideration of severe accidents at Wolf Creek for the reason cited in Section 5.9.4.3. In addition to the cited effect of less efficient operation when a facility is old, is the effect of " break-in" operation when a facility is new. Further, the RSS relied on failure data from sources other than reactor systems as well as the limited commercial nuclear power plant l

Wolf Creek FES A-12 l

l -. -- -- - -- -

I data. See Appendix XI of WASH-1400 for an overview discussion and Appendices II and III for detailed discussions.

LRK commented on the Reactor Safety Study (RSS), uncertainties in the proba-bilistic risk assessment studies, tornado effects, and electromagnetic pulse (EMP) effects.

There are no numerical values for revised sequences in NUREG/CR-0400; that document contains peer group comments on the RSS. As mentioned briefly in Section 5.9.4.5(2), and discussed more fully in Appendix E, the sequences used in the Wolf Creek Environmental Statement have been "rebaselined" to incorporate revisions suggested in NUREG/CR-0400.

A significantly expanded discussion of uncertainties in probabilistic risk assessment studies like the one presented in the Environmental Statement has been added in Section 5.9.4.5(7).

The Wolf Creek plant is designed to withstand design basis magnitudes of natural phenomena such as tornadoes, floods, or earthquakes. The magnitudes An expanded have been determined based on historical data for the area.

discussion of the staff's judgement on beyond-design-basis natural phenomena events as initiators of severe reactor accidents has been added to Section 5.9.4.5(2). It should be noted that the design basis tornado for this plant is comparable to any that has been estimated to have occurred.

With regard te EMP, per 10 CFR 50.13, "An applicant...is not required to provide for design features or other measures for the specific purpose of protection against the effects of (a) attacks and destructive acts, including sabotage, directed against the facility by an enemy of the United States...."

AM inquired as to whether there was any way to protect the water shed, which supplies the City of Lawrence, Kansas drinking water, from a severe accident.

For the severe accident sequences in the case of wind blowing in the direction of the watershed of Lawrence, Kansas, the calculations would show some contami-nation of the drinking water. However, the likelihood of this is very small, since the probability of a severe accident is very low. Were contamination of the watershed to occur, health effects in the population can be minimized by such tactics as dilution, filtration, and treatment--up to denial of use of the water.

A.S.g Uranium Fuel Cycle (KASE, B-47 to B-49; WAL, B-60 to B-62)

KASE commented on radon exposure due to mining and milling.

The environmental impacts on the uranium fuel cycle are discussed in Appendix G of the DES and the FES. Since the NRC has an existing Branch Position limiting reclaimed tailings radon emissions to twice background, and since the population doses in Appendix G are based on conservative assumptions, the basic conclusion that the environmental impact due to the uranium fuel cycle is insignificant when compared with the impact from natural background radiation remains unchanged. NUREG-0757, " Radon Releases from Uranium Mining and Milling Wolf Creek FES A-13 l

and their Calculated Health Effects" may be consulted for additional information.

Also, KASE commented concerning the risk of accident during transportation of spent fuel. {

Shipping casks for spent fuel assemblies are designed and constructed to withstand accidents likely to be encountered in transport, and thus protect against significant releases of radioactivity. Considering the low probability of a shipment of spent fuel being involved in an accident, the requirements for package design, and the controls exercised over the shipment during transport, i

the risk of radiation exposure to the environment from spent fuel in transportation accidents is small compared to risk associated with routine i

transportation, which is not considered significant in comparison with the dose from natural background.

J WAL commented concerning the evaluation method of the health consequences of radon-222.

WAL's basic contention is that the health consequences of radon-222 emissions from the uranium fuel cycle are improperly evaluated in the Wolf Creek Draft Environmental Statment (DES, NUREG-0878). The basis.for this contention is that the staff has arbitrarily evaluated the health impacts of radon-222 releases from the wastes generated in the fuel cycle for 1,000 years or less, rather than for the entire toxic life of the wastes. WAL then estimates that radon-222 emissions from the wastes from each annual reactor fuel requirement will cause about 200,000 deaths over a period of more than 1 billion years.

'l The major difference between the staff's estimated number of health effects

' from radon-222 emissions and WAL's estimated values is'the issue of the time period over which dose commitments and health effects from long-lived radio-4 active effluents should be evaluated. WAL has integrated dose commitments and health effects over what amounts to an infinite time interval, whereas the-staff has integrated dose commitments from radon-222 releases over a 100 year j period, a 500 year period, and a 1000 year period.

The staff has not estimated health effects from radon-222 emissions beyond

1000 years for the following reasons. Predictions over time periods greater than 100 years are subject to great uncertainties. These uncertainties result l from, but are not limited to, political and social considerations, population l size, health characterististics, and for time periods on the order of thousands i

of years, geologic and climatologic effects. In contrast to WAL's conclusions, some authors 1 estimate that the long-term (thousands of years) impacts from the uranium used in reactors will be less than the long-term impacts from an equivalent amount of uranium left undisturbed in the ground. Consequently, the -

staff has limited its period of consideration to 1,000 years or less for decision-making and impact-calculational purposes.

l 18. L. Cohen, " Radon: Characteristics, Natural Occurrence, Technological Enhancement, and Health Effects," Vol. 4, Progress in Nuclear Energy, 1979.

l Wolf Creek FES A-14

A. 5. h Decommissioning (EPA, B-14; MWB, B-33; SHJ, B-38; KG&E, B-54; AM, B-68, B-69)

Comments concerning decommissioning have been received from all of the above.

The NRC is currently conducting a generic rulemaking which will develop a more explicit overall policy for decommissioning commercial nuclear facilities.

Specific licensing requirements are being considered that include the develop-ment of decommissioning plans and financial arrangements for decommissioning nuclear facilities.

Although no large commercial reactor has undergone decommissioning to date, the broad base of experience gained from smaller facilities is generally relevant to the decommissioning of any type of nuclear facility. Since 1960, 68 nuclear reactors, including 5 licensed reactors that had been used for the generation of electricity have been or are in the process of being decommissioned.

Estimates of the economic cost of decommissioning are provided in Section 6.4.2.1 of the statement. (See Section 5.11.)

A.S.i Emergency Planning (CLK, B-28; DCEP, B-29; AM, B-67, B-68)

CLK and DCEP commented concerning immediate notification, inclusion in the emergency plan, and opportunity to comment on the plan.

The substance of your comments on the Wolf Creek DES, NUREG-0878, should be transmitted to your appropriate State emergency planning organization. Any emergency preparedness needs of your city could thus be included in the Kansas Disaster Emergency Plan which is now under development.

Upon completion of the State and local emergency response plans, and prior to any formal findings and determination by the Federal Emergency Preparedness Agency (FEMA) as to their adequacy, provisions exist for formal public meetings held by FEMA to explain the State and local plans and solicit public comments.

These public meetings will be held in a timely manner to enable FEMA to con-sider all such public comments during their development of formal findings and determinations.

AM commented concerning adequacy of emergency plans, opportunity for public hearings, timing of plan approval, capability to make initial warning, and resources available for radiological monitoring.

The determination of adequacy of State and local emergency response plans for areas surrounding the WCGS is the responsibility of the Federal Emergency Management Agency (FEMA). FEMA will provide formal findings and determinations on the adequacy of such plans to the NRC for consideration prior to issuance of a license for the WCGS.

As a part of the FEMA review of State and local emergency response plans for the areas surrounding the WCGS, provisions exist by which FEMA will hold public meetings to explain the emergency plans and solicit public comments and suggested improvements to the plans. FEMA will consider any such comments during the development of their formal findings and determinations on the adequacy of the plans before those findings are transmitted to the NRC.

Wolf Creek FES A-15

FEMA will provide the NRC with formal findings and determinations on the adequacy of the State and local plans for those areas surrounding the WCGS, and the NRC will make its findings on the adequacy of the licensee's onsite emergency response plans. Both of these actions will be completed prior to the issuance by the NRC of a license for the WCGS.

The planned method to provide initial warning and information messages to the

public within approximately 10 miles of the WCGS is still under development at this time. However, the licensee has indicated in Revision 9 to the WCGS i

Radiological Emergency Response Plan, that such a warning and notification system may incorporate the use of fixed sirens, mobile sirens and the EBS radio l network. Final determinations on the adequacy of such a system and its i limitations must await the development and installation of the final system and i a formal test of its adequacy by FEMA.

Personnel used for radiological monitoring of areas surrounding the WCGS will i

not be limited to the 14 volunteer firemen, as indicated by your comment, but

will be augmented by various State, local, and Federal emergency response

groups.

A.6 EXAMPLE OF SITE-SPECIFIC DOSE-ASSESSMENT CALCULATIONS (KG&E, B-58)

KG&E commented concerning liquid effluent source terms.

Table C.3 is correct as published. The use of mixed bed resin in the recycle evaporator condensate demineralizer was considered in the analysis that I resulted in the source terms presented. The differences between the staffs I results and the applicants results arise from different values of input j parameters assigned by each.

A.7 REBASELINING OF THE RSS RESULTS FOR PWRS (WAL, B-62 AND B-63) 4 WAL commented concerning rebaselining of the RSS and the population assumed

exposed in the case of a severe accident.

, A reference has been added to Appendix E, in which a more detailed discussion of the process of rebaselining can be found.

l

, A sentence has been added to Section 5.9.4.5(2) clarifying that the U.S.

i average population was used beyond 350 miles from the site. The calculation is i

actually an extended calculation in that the last spatial mesh (beyond 350 miles) is elongated and washout is forced to deplete the plume of any nongaseous material that might still be left.

A.8 CONSEQUENCE MODELING CONSIDERATIONS (MWB, B-35; AM, B-68)

MWB commented concerning cost of food and shelter for one week.

The parameters used by the staff to describe the evacuation near Wolf Creek were somewhat conservatively evaluated to reflect the lack of finality in the 1

i Wolf Creek FES A-16 l

plans. The one-week's cost of sheltering and meals is for group shelters and meals and is based on an EPA study of actual evacuations which took place prior to 1974. The staff estimated about 40% increase due to inflation. However, even if this figure were substantially increased, the conclusions would be unlikely to change. See Appendix VI of WASH-1400 for a fuller discussion.

AM commented concerning the evacuation route.

Appendix F discusses the model used in the calculation. Were a severe accident actually to occur, which required evacuation of the residents, the actual con-ditions would be taken into account to eliminate, or reduce as much as possible, exposure to the radioactive plume. To the extent that road networks would allow cross-wind evacuation, this would be considered. The model used is conservative, since it assumes direct down-wind evacuation, thereby calculating maximum consequences relative to what actually might be achieved.

Wolf Creek FES A-17 l

APPENDIX B. Comments on the Draft Environmental Statement - Operating License Stage Wolf Creek Generating Station Unit 1 8-1

un. tea states Depa tment of sod Box 600 [h*

( Agneuture Conservation servce Salina, has 67L01 February 19, 1982 Mr. 3. J. Icungblood, Chief Licensing Branch No.1 Division of Licensing U. S. Nuclear Regulatory Cc ission Washingten, D. C. 20555

Dear Mr. !cungblood:

We appreciate the opportunity to review the Draft Envircrr. ental S*atecient related to the operatien of the Wolf Creek Generating Station, Unit 1

( .'JRT,-CS78) and have no ccer::ents to offer.

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January 25, 1982 Mr. B. J. Youngblood, Chief Licensing Branch No. 1 Division of Licensing U.S. Nuclear Regulatory Coc::nission Washington, D. C. 20555

Dear Mr. Youngblood:

Thank you for forwardir.g the material for issuance of an operating license to the Kansas Gas and Electric Coc:pany (KG&E) for the startup and operation of the Wolf Creek Generating Station Unit 1 (WCGS), located in Coffey County, Kansas.

We have reviewed Docket No. STN 50-482 and have no cotn=ents.

Sincedely, D

pa W. /3%s TFJLMAR W. DAVIS sociate Director p atural Resource Economics Division I

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'8 A Ca A MCEVQ Mr. Jcn Ecpkins )9; Licensirn Project Manager '*

4 ,,M O 3 i$$2Jan Office of Nuclear Reacter Regulations i. 53rsinme m a U.S. Nuclear Regulatory Ccranission k " 7 4"'?

Washingten, D.C. 20555

• 4 Cear Mr. Ecpkins:

'# W' The Bureau of Radiological Health staff have reviewed the Craft Envircr: mental Statenent (CES) related to the operation of the Wolf Creek Generatino Station, Unit No. 1, NCREI3-0878, dated January 1982.

In reviewing the CES, we ncte that (1) the applicaticn for a construction permit is dated April 1974, (2) the Final Environmental State:ent - Ccnstruction Phase was issued in Cctober 1975, (3) the construction permit was nct issued until May 1977, ard (4) as of September 1981, the constructicn of Unit I was about 75 per-cent ecmplete. We Bureau of Radiclogical Health staff have evaluated the public health and safety impacts associated with the preposed cperation of the plant and have the follcwing ccr: rents to cffer:

1. Se dese design cbjectives of 10 CFR 50, Apperdix I, the Uranium Fuel Cycle Standards of EPA's 40 CFR 190, and the applicant's prcpesed radio-active waste management system provide adecuate assurance that radicactive materials in the effluents will be maintained as low as reasonably achiev-able (AMRA) . It appears that the calculated doses to individuals and to the pcpulation resulting frcm effluent releases are within current radia-tien protection stardards.

2. Se enviror:nental pathways identified in Section 5.9.3 and in Figure 5.3 cover all possible enission pathways that could imcact en the populatien in the environs of the facility. Se dose cenputational methodology and ::odels (Appendix C and D) used in the estimation of radiation doses to individuals and to ;cpulatiens within 80 km. of the plant have provided the means to make reascnable estimates of the doses resulting frcra normal cperations and accident situaticns at the facility. Results of the calculatiens are shown in Apperdix C, Tables C.5, C.6, C.7 and C.8. t ese results confirm the deses meet the design cbjectives.

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3. Discussicn in Section 5.9.4 en the environmental ig act of pstulated radiolcgical accidents is considered to be an adequate assessment of the radiaticn exposure pathways depicted in Figure 5.3 and the dese and health impacts of atmospheric releases. However, in Section 5.9.4.2 (2), two additional possible exposure pathways are mentioned. Sese are (1) radio-active fallout ento cpen bodies of water and (2) the " China Syndreme" that creates the potential for release of radioactive materials into the hydro-sphere through contact with ground water. If p ssible, it would be helpful to quantify the environmental arx! health irpacts frcm these exposure path-ways in sufficient detail to permit an understandirn of the consecuences of such events. We will forego ecmments on the energency preparedness section (5.9.4.4(3)) since we realize the process cf granting an cperating license to the facility will include an adecuate review of emergency plants (FEPA-NRC Menorandum of Understanding, Regional RAC's criteria in NCREG-0654) .

We have representation on the RAC's whose evaluatien relative to the Wolf Creek Generating Station will speak for this agency.

It is noted in Section 4.2.1 that an Emergency Operation Facility has been located on-site to coordinate activities needed to mitigate the conse-cuences of accidents. Scre mention of this facility could be included in this section to indicate ene of the positive steps the NRC has taken to

!qrove reactor safety as a result of the TMI-2 accident.

4. "he radiological nenitoring program, as presented in Section 5.9.3.4 and sum:arized in Table 5.5, appears to previde adecuate samling fre-quency in expected critical exposure pathways. Se analyses for specific rafienuclides are considered sufficiently inclusive to (1) measure the extent of emissiens frcm the plant, ard (2) verify that such enissions meet applicable radiatien prctecticn standards.

In view of scrne of the monitoring problems that were identified during the Three Mile Island, Unit-2 accident, we suggest reevaluatien cf the airbcene radioicdine sampling and analysis program. In particular, it should be modified to address the problen of monitoring radiohalogens (especially radiciodine) in the presence of radienchie gases. "his could be accceplished by reference to FD'A-REP-2, a document en instrumentation systs prepared with considerable input frem NRC.

5. Section 5.10 and Appendix G centsin descriptions of the envircnmental impact of the Uranium Fuel Cycle (CFC) . The envircnmental effects presented are a reascnable assessment of the pcpulation dese cceritments and health effects associated with the release of radcn-222 frce the CFC.

Sank you for the cpportunity to review and w..mnt en this Drr.'t Environmental State nent.

Sincerely yours, m

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Subject:

Draft Environmental Impact Statement: Operation of Wolf Creek Generating Station, Unit No.1, Coffey County, Kansas (January 1982)

(STN 50-482) [

The draft Environmental Impact Statement for the referenced project has been I reviewed at the Kansas City Area Office, Department of Housing and Urban Develop-ment (HUD). The document was found to be satisfactory in meeting the spirit ?.nd intent of the National Environmental Policy Act (NEPA) of 1969.

This detemination was made on the basis of the following considerations: 1) HUD's areas of review responsibility in accordance with NEPA; and, 2) HUD's activities that might be affected by the proposed action. In this regard there was found no apparent significant environmental impact on any HUD housing or comunity develop-ment projects within our jurisdiction.

Sincerely, Miguel . Madrigal Director, Office of Regional Comunity Planning and Development 8

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Division of Licensing P.ECGVED US Nuclear Regulatory Commission Washington, DC 20555 M.R 011982* -j '

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Dear Mr. Youngblood:

4 We have reviewed your Draft Environmental Statement related to the operation of Wolf Creek Generating Station, Unit No.1 (NUREC-0878), Docket No. STN 50-482.

Section 4.3.1.1 Hydrologic Description. A curve plot showing annual runoff in acre-feet with Wolf Creek and adjacent watershed plotted would be helpful.

This would provide back-up to the average =onthly streamflow presented in Table 4.3.

P Page 4-14, paragraph 1. It is unclear where your source of data for rainfall was extracted.

Page 4-14 It might be helpful if you would discuss what material has been used in the spillway and if it will resist erosion in event of the probable maximum flood.

Page 4-15, paragraph 5. This paragraph discusses the initial flood control and conservation storage capabilities of John Redmond Lake and does not take into consideration the existing sediment conditions after nearly 19 years of project operation.

We appreciate the opportunity to provide comments on this environmental state-ment.

Sincerely, ROBERT D. 3ROWN Chief, Planning Division 8

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@w Dect Mr. Youngblood:

Thank you for your letter of January 18,1982, transmitting copies of the draft environmental statement (OLS) for Wolf Creek Generating Station, Unit No. I, Coffey County, Kansas. Our comments are presented cecording to the format of the statement or by subject.

Water Guclity In reference to water withdrawols from the toilwater of John Redmond Reservoir, we would recommend that instream flow requirements be determined for the crea immediately downstreom from the impoundment. These requirements are necesscry to ensure the maintenance of the aquatic ecosystem in the Neosho River.

The finct statement should present historic and future downstream flows, including the maximum, minimum, and mean daily flows from John Redmond Reservoir, with and without mcke-up water withdrawof.. In addition, it should be stated if any changes in the current reservoir operationct criteric concerning minimum releases from John Redmond will occur. This information will cid in determining if adequate instreem flows will occur to maintain the fishery resource and recreational activities.

The instream flow requirements; i.e., the amount of water flowing through a natural stream course needed to sustain the instream values at on acceptable level, should include four recognized instreem values: fish and wUdlife population maintenance, outdoor recreation activities, wettend preservation, and conveyonce of water to downstream points of diversion. The instream flow requirements should, therefore, be based on the identified value which has the greatest need during cny specific time period or, citernatively, on the resulting best achievcble balance offer recognized trade-offs have been mode. For example,if water supply is released into the stream cnd withdrawn at some downstream point,it may contribute wholly or partictly in meeting other instream flow needs. Thus, the quantity of water to be relecsed for ecch value would not be added together. This allows for o degree of flexibility not possible with the fixed minimum flow approach frequently cpplied in the post.

The instream flow requirements to sustain the identified stream uses of the Neosho River )

have not at this time been quantified. The U.S. Fish and Wildlife Service has developed a tool which makes it passible to qucntify the impact on fish habitat resulting from incremental modifications in streemflow.vThis instrecm flow methodology also provides o technique for estimating the streamflow required for recreation. If interested in )

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discussing specific aspects regarding the instream flow methodology, contact the Konsos Field Office, U.S. Fish and Wildlife Service, Konses State University, Ackert Hall, /

Manhattan, Kansas 66506. /

It is also important to note that the State of Konses recentiy possed a minimum streamflow bill with m objective of achieving the highest public benefit by recognizing a minimum desirable streamflow requirement. The reservation system adopted by Konsos provides a method by wi ':h an instream flow release from o federally operated reservoir con be protected.

NPOES Permit The analysis of expected final mixed chemical concentrations in the Neosho River below/

the confluence of Wolf Creek is based upon an " overage river flow" of 1335 cubic feet per second (CFS). It might be more realistic to discuss potential chemical concentrations in the Neosho River os they relate to the median flow of the river, rather than the overage flow. Also, a more detailed comparison of projected chemical concentrations with the requirements outlined in the National Pollutant Discharge Elimination System (NPCES) permit would be helpful. The present NPDES permit should be included in the final statement as well as a discussion of any proposed modifications to that pe'rmit to allow for operational phase dischcrges os discussed in Section 1.2. -

Ecology '

We are concerned about existing and future impacts to fish and wildlife and their respective habitots. Construction of the power plant cooling icke inundated over 5,000 acres of land, and thus has adversely offecting wildlife habitat. Therefore, we believe a fish and wildlife management and public use plan for the site and transmission line Qhts-of-way should be prepcred because intensive management of project lands could off-set losses ciready suffered by wildlife and help to partially mitigate these losses.

Such a plan should include the preservation of natural crecs and the restoration of others os well es providing facilities for public use, including crecs for fishing, hunting and related recreational uses to assure maximum public benefit. The plan should also consider monogement of project icnd and water for the benefit of resident and migratory fish and wildlife resources since no specific measures have been presented for wildlife loss mitigation.

In addition, specific comments cre attached to this letter.

We hope these comments will be helpful to you.

Sincerely, F

C& #7V/C ruce Bicnchcrd, Director i

, ' Environmental Project Review Enclosure 6

B-9

Specific Comments Page 5-2, section 5.3.1.1, perograph I and page 5-10, section 5.5.1.1, paragraph 2 -

Operational activities of the Wolf Creek Generating Station potentially offecting surface i water include the loss of management of John Redmond Reservoir for fish and wildlife production, and also fonds of the Flint Hills National Wildlife Refuge (NWR). A discussion of this dro)vdown as it relates to wildlife management should be presented and plans to lessen severity should be formulated.

Flint Hills NWR is managed primarily for migratory waterfowl, and control is exercised over population distribution through the mmipulation of food availability, sanctuary, and public hunting. Abnormal concentrations of waterfowl and increased tenure contribute towcrds the chances of an epidemic of duck viral enteritis (DVE). Although discussed in the DEIS, the Fish md Wildlife Service (FWS) believes there is a more eminent danger of DVE occurring. A contingency plan should be developed to handle this problem. The FWS is currently attempting to redur.e concentrations and tenure of waterfowl on its refuges in order to reduce the potentici for DVE cnd other disecses. It would be very difficult to reduce concentration and tenure of waterfowl at this project because of the wcrm open water at the defoeto sanctuary available in the cooling icke. Also, lower I levels in John Redmond Reservoir would increase the frequency and duration of the reservoir's ice cover and would result in the wcrmer, open water of the cooling icke attracting and holding waterfowl that would ordinarily migrate towards the Southern United States. Waterfowl food crops are produced on ogricultural icnds within the Flint Hills Refuge. This pcrtially controls waterfowl depredation of crops on private Icnds.

No such control would be provided at the cooling icke. A contingency plan should be developed to handle crop depredation problems. Although mentioned in the DEIS, no concrete plan to deel with the problem has been put forth, i Page 5-9, sectim 5.5.f.1, paragrcph 2 - further explanation of the term " natural state" is needed to describe the buffer zone cround the cooling lake. l Pcge 5-10, section 5.5.l.I, porograph 3 cnd pcges 5-10 and 5-11, section 5.5.i.2 - Although

' bird impaction events have been discussed cnd monitoring program is to be established, I one means utilized by power companies to reduce bird mortality is to install spherical I balls (orange in color) on transmission lines near orcos of waterfowl use and/or in the l direct flight path of waterfowl. The proximity of Flint Hills NWR to the plant site should indicate that concentrations of migratory waterfowl will undoubtedly be o major l issue. Installation and/or use of such veer tactics to aid in lessening bird mortality  !

should be discussed in the final EIS.

Page 5-12, section 5.5.2.1, paragraph 3 - Water withdrawals could ccuse less negative l effects if they cre coordinated with water level mencgement needs at John Redmond l Reservoir and Flint Hills NWR. Also, see General Comments section.

l l Pcges 5-14 cnd 5-15, section 5.6 - Blowdown relecses via Wolf Creek should be discouraged during low flow conditions in the Neosho River. Therd ' -sses may occur

! of these times os well cs high chemical ecocentrations which may nu . Jequately diluted by waters in the Neosho River.

B-10

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2 Neosho modtoms have been collected at the confluence of Wolf Creek and the Neosho River. As this species inhabits riffles, the above recommendation is necesscry to ensure its survival and habitat. Spawning by Neosho modtoms probcbly occurs during June and July. If low flows would occur during these times and spawning prohibited, the short life span of the species may cause severe inroads into the population. Floculation of heavy metals may contribute to the " filling in" of riffle arcos and grovel interstices reducing ovcilable habitat for adult modtoms. Releases from blowdown, therefore, should only be made during moderate or heavy flows in the Neosho River to ovoid this problem.

Page 5-29, section 5.9.3.4 - In monitoring the ecosystem for radiological impacts, fish flesh from within the cooling lake should be monitored for potential uptake of radioactive contaminants.

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Chief, Licensing Branch No.1 g U.S. Nuclear Regulatory Commission , 4 Vashington, D.C. 20555 Volf Creek Generating Station, Unit No.1. Coffey County, Kansas Oear Mr. Youngblood Ve have reviewed the Draf t Environmental Statement for the proposed operation of the planned nuclear power plant identified above. The project and draft statement have been rated E3-2 (environmental reservations - insufficient information),

respectively. Our primary environmental reservation with the proposed operation is a lack cf detailed descriptions of the gaseous and liquid waste treatment systems. The failure to provide the of ten referenced Safety Zvalution Report with the Draft Environmental Statement prevented a thorough evaluation of the planned facility.

The following comments are provided for your censideration when preparing the

?inal 2nvironmental State =ent:

Generic Cen=ents In our past reviews of Draft Environmental Impact Statements (EIS) relating to light-water nuclear power facilities, we have included generic con =ents which are applicable to all such facilities. As a result of the Three Mile Island accident, we have decided that we =ust revise our generic comments to consider these events and activities. Ye will provide our revised generic co==ents to the Nuclear Regulatory Com=ission (NRC) as soon as they are completed. Generic issues undergoing review are:

o Population dose ce==it=ents o Reactor accidents j o ?uel cycle and long-te:u dose assessments l

o High-level radioactive waste r.anage ent i o Transportation i= pacts o *'ec os=is sioning Radioactive Yaste Manage =ent Svstems The Draft EIS does not contain detailed descriptions of the radioactive waste treatment systems or the N20 staff's detailed evaluations of these systems. Such

stters are referenced to the Safety Evaluation Report (SER), which has not yet been received by our office for use in this review.

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2-Section 3 5 of the applicant's Environ = ental Esport (E2) states that, "Only =inor design changes have occurred in the evolution of the Wolf Creek radwaste systems design . . . ." Our ce= ents on the Draf t E!S-Construction Per=it (CEIS-0?)

indicated concerns regarding inconsistencies between the DE!S-C? and the ER (Construction Per=it Stage) regarding treatment of containment building ventilation and a lack of consideration of buildup of radionuclides in the cooling lake.

These concerns were resolved in the 7EIS-0? and the ER. It now appears that, if the staff's detailed evaluation of the gaseous and liquid radwaste systems are shown in the SER to =eet the require:ents of Appendiz I to 10 CFR Part 50, the operations will te within EPA's Envirors= ental 3adiation Standards (40172190).

However, an explanation is required for the significantly higher gaseous effluents calculated by 52C for this Draf t EIS versus those calculated for the ?E!S-C? and the calculated liquid of 0.16 curies per year in this document versus 0.6 curies per year in the ?IIS-C?.

Reactor Accidents When discussing accident risk and ispacts of design basis accidents, the Draft E!3 addresses probabilities of occurrence qualitatively. Yet, when discussing the ore severe core seit accidents, the probabilities of occurrence are quantified (Tables 5 8 and 5 9). ?or consistency in the presentation of all environnental risks, the probabilities of ccourrence of infrequent ac:idents and liniting fault design basis accidents should also be provided.

0;erational Envirot= ental Monitoring The applicant's preoperational environmental radiation :enitoring program will be implenented at least two years' before initial criticality. The progra as described in the Draf t E!3 and the E2 are acceptable. The applicant's proposed operational program will be reviewed in detail by the TRO staff and incorporated into the technical specifications for the operating license. t is stated that the Operational program will be essentially a continuation of the preoperational progras. This will be acceptable with the following modifications:

o 3amples of drinking water fro: the tcyn of LeRoy should be collected and inaly:ed according to provisions of the National Interi: Orinking Water 3egulations.

This voald require, in addition to the proposed analyses, quarterly analysis for iodine-1?l, based on a 00=posite of five consecutive daily samples, and annual analysis for strontium-90, based on a cc posite of four consecutive quarterly samples er analysis of f:ur quarterly sa:ples.

o There is an inconsistency be tween the Draf t E!S, Table 5 5, and the ER, Table 6.1-17, regarding the sa:pling frequency for TLD. The E2 states that they vill be collected qcarterly while the 02:S states that they will be collected quarterly and seni-annually. Although quarterly TLD =easurements may ,be acceptable for the preeperational progran, monthly seasure=ents would be : ore suitable f or the operational pragram. Monthly sampling periods provide the only potential for seasuring the airborne 10se fres the plant in ez ess of nornal background dose variations. (See: " Natural Radiation Measurenents for Envir:n= ental 2:rveillance at ."u: lear ?ower Stations " V.L. 3rin k, et. al., in the ?receedings of Ps;ers

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- _ _ _ - - _ .. = ~__ _ __ ___ --____ . - - - - _ _ .

b 3-o Other inconsistencies were noted between the Draf t EIS and the EH regarding i types of samples, number and location of samples or sampling frequency for the following pathways surface water, rooted aquatic plants and shoreline sediments, bottom sediments, algae, fish and invertebrates, livestock feed and fodder, nilk, poultry and eggs, and domestic and non-domestic meat animals. Theev inconsistencies should be resolved in the Final EIS.

4

, Decommissioning l The Draft EIS states that planning for decommissioning can affect health and i safe ty as well as cost. Ve concur in this assessment but were unable to find in the Draf t EIS any arrange =ents for financing decommissioning costs. The applicant's Environmental Report (Section 5 8.4) outlines a number of financing options but does not select a preferred choice. Decom=issioning costs are noted in the range l of $42 million (applicant,1978 dollars) to $83 million (staff,1984 dollars).

These are large sums and will represent a large cost burden when needed if not accumulated out of revenues, during the plant's operating lifetime. Tia ?inal EIS should erplain what specific arrangements have been made, or are planned, to assure that funds will be available for decommissioning when required.

! It is not clear at what point the licensee's financial responsibility is to be te rmina ted. Termination of the nuclear license is required at the end of facility life, and this requires decontamination of the facility such that unrestricted l uses can be allowed. Although the applicant's Environmental Report (Section 5 8) does not specify a decommissioning alternative, one option to achieve such decontanination is SA?STOR, which allows deferral of decontamination for up to 30 years . It is not clear, in such a case, whether license termination would occur prior to, or at the end of such an extended storage period. If. termination occurs at the beginning of the storsge period, financial arrangements evidently will be y necessary to pay for security and the deferred decontamination. The Final EIS should clarify this point.

Economic Risks

! As the Three Xile Island accident demonstrated, the cost of reactor building decontamination and replacement power following an accident can be considerable.

This underscorep the need to develop standard methodologies for estimating the contribution of these costs to econocie risks. Economic risks are addressed in Section 5 9 4.5 of the Drsft EIS and, based on low probability of occurrence, annualized risk is calculated to cost $3,500 in 1980 dollars (Table 510). le note this cost is =uch less than the expense of emergency planning to the affected states. The costs of emergency planning zust be included in the economic analysis.

Because of the potentially severs econonic costs in the case of an accident, however, we cannot agree with the NRC staff assessment of these costs as "small (Table 6.1).

l Ti=ing of Supporting Occu=entation for the EIS l

3 The practice of issuing the Traf t EIS in advance of the SE2 has prevented our perforning a ec=plete review of the environ = ental impacts of the Wolf Ireek plant.

As discussed in our ec==ents on radioactive vaste treat:ent systems, this is believed to be detri= ental to our review of this Draft I S. Also, the Draf t E!S refers to seversl other topics which are still under NRC review. These include:

1 1

)

i

! B-1d 1,

, _ , _ _ ~ _ _ _ _ _ _

1. Facility safe ty features. Reference is ade (5 9 4.4) to the forthcoming SER for the YRC staff evaluation of safety features and characteristics of the facility and description of so=e of the accident sitigation features.

This evaluation should include the consequences of a major steas generator tube rupture (0inna accident).

2. Site features. Reference is ade (5 9 4.4) to a review of potential external hazards that night adversely affect operation of the plant. A more detailed discussion of site features is referenced to the SER.

3 Energency preparedness. E=orgency preparedness plans including protective-action measures for the Wolf Creek facility and environs are reported to be in an advanced, but not yet fully co=pleted stage. We are anable to consent on this topic since a draf t of the State and local emergency preparedness plans for Wolf Creek has not yet been sub=itted to the 7ederal Emergency Management Agency for review. NRC Staff findings of adequacy and implementability for both the on-site and off-site plans have not yet been finalized.

!n view of the above, any conclusion such as that in Section 5 9 4.6 regarding tne plant's environ = ental impact, would see: to be contingent on favorable results frcm some i=portant ongoing staff reviews, and hence premature. The Final EIS should be withheld until the above-mentioned reviews are completed, or should specifically discuss any of the areas which are still undergoing review.

We urge the REO to ensure that, in the future, the Safety Evaluation Report is l available before issuing the Draft IIS unless the Draf t EIS is a complete document not requiring reference to the SER. Material incorporated into an EIS by  ;

reference should be reasonably available for inspection within the time allowed for cc =ent (40 CFR 1502.21). Ve do not believe the citations of missing but forthconing information in the SIR constitutes a " reference" in the ec==on meaning of the word.

Thank you for the opportunity to review and con =ent on the Draf t Environmental Statement. If you have questions regarding the concerns we erpressed in this lecter, please contact our office. The staff se:bers =cs: familiar with this project are Messrs. Willias Brinck and Robert Fenemore. They can be reached at FTS 753-6525 and 758-2921, respectively.

Sincerely yours,

_ ,n _ 7 . # . -

Charles H. Hajinian, 3 ranch Chief Environ = ental Review 3 ranch B-15

5:., 8-/ i }

STATE OF KANSAS

... NEQp g

,Afdpl'Sigg E

A

• D.%

,c-DEPARTMENT OF ADMINISTRATION '

l DIVISION OF THE BUDGET x> ~ canu~. ,sa.e ca - March 12, 1982 s== cea em on~ vucmcas.  %=. xanus omn oneo, or = om., <sim 2

• 243e Mr. Jon Hopkins SAI: K5820127-002 Licensing Project Manager REF: Draft Environmental Office of Nuclear Reactor Regulation Statement U.S. Nuclear Regulatory Commission Wolf Creek Generating Washington, D.C. 20555 Station, Unit #1

Dear Mr. Hopkins:

The above referenced project has been processed by the Division of the Budget under its clearinghouse responsibilities as described in the Federal Office of Management and Budget Circular A-95. ,

l Af ter review by interested state agencies, it has been found  ;

that the proposed project does not adversely af fect state plans. Enclosed are comments concerning this proj ect for your information and referral.

If you need any additional clarification or information regarding the state clearinghouse's action please contact this office.

Sincerely, LYNN MUCHMORE Director of the Budget By:

Alan D. Conroy /.

1. [

A-95 Coordinator LM:ADC:sr Enclosures f0Y 8'!!;

2 8203170191 820312 PDR ADOCK 05000462 D PDR B-16

i.

STATE ACENCY A-95 TRANSMITTAI. FORM Return to Division of the Budget D Capitol Building. TopeEa,epartment Kansas 66612 of Administration, 1st Floor

• 1 tiotitication ot Intent PROJEC* TITLE: ORAFT EilVIR0flMEi1TAL STATEfEllT Prespplication Wnif Creek Generating Station, Unit lio.1 t._J Final Application DATE REVI H PROCESS STARTED DATE RIVIEW PROCESS ENDED SAI !; UMBER j 1-27-82 '2-16-82 KS820127-C02 I

EART1 Initial Project Notification Review (To be completed by Clearinghouse)

i The attached project has been submitted to the State Clearinghouse under the provisions of :he Federal CM3 Circular A-95 revised. P.eturn by 2-16-22 This form provides notification and opportunity for review of Expedite

this project to the agencies checked below. Please fill in Add. Info. Avail.

Part II and Part III below and return to the State Clearinghouse.

REVIEW ACENCIES

~

Aging C Human Resources Agriculture - DWR Kansas Corporation Commission Civil Righ,ts Commission Park and Resources Authority

] Economic Developnient Social and Rehabilits: ion Services Cducation (O State Conservation Commission U Fish and Game Cormission [ Transports:ica

$ Health and Environment I _. Water Office, Kansas 8 Historical Society QA3) Kansas Enercy Office M2:s Oci.:p :;. E n c PART 11 Nature of Agency review comments (To be completed by revieu agency and returned to Ch ,

Check one or more appropriate boxes. Indicate comments below. Attach addi:ional sheet if necessary or use reverse side.

C Request clarification or additional info. [ Suggestions for improving projec: propos; COMMENT l  % e Amro e Aercm screes (E 2-33 APerAt To TM2-6W AA)ST1C - N shew crG th5TDit4 Cth - E'UlOEMCE" d LA"M @EPrCTDP - Ct'rf%<aTM i:#_TD % PRE 5DJTY.-O E4, C. KoMMcFP uJ PcW6- RJnJT GoST EscAATTCTd.

' ART ! * ! Recorciended State Clearinghouse Action (To be ccmpleted by review agency and returned to Clearinghouse)

hed oute box only:

l C Clearance of the projec should be Clearance of the project should not be j granted delayed but :he Applicant sh0uld (in

the final :pplicaticas address ar clarify I !_I clearance of the srojec: snould be cne questions or concerns indt:ated abov:

celaved until :ne issues or cuestiens have acen clarified by One Applicant C Request ene opportaniiy :o re.tew :;na final appli:s:ica prior :s susmission :c 9

the federal fanding agency Reviewer's Name Div./ Agency l

Da:e l

~

y 6[

] M.Y B-17 i

STATE AGENCY A-95 T?E SMITTAI. FCR.'i Return to: Division of the Budget, Department of Ad: sinistra: ion,1st Floor, Capitol Suilding, Topeka, Kansas 66612 Noti:1cacica c: intent PRDJECT TIT:.I: DRAFT EliVIR0!ctEliTAL STATE!!E*iT F Preapplication Wnif Creek Generating Station, Unit flo. 1 P___ Final Applica: ion CATE REVIEW PROCESS STARTED DATE REVIEW PROCESS ENCED SAI SU:13ER 1-27-82 2-16-82 K5820127-002 PART I initial Project Notification Review (To be completed by Clearinghouse):

The attached project has been submitted to the State Clearinghouse ander the provisions of the Federal CM3 Circular A-95 revised. @ Re: urn by 2 16 02 This fora provides notification and opportunity for review of Expedi:e this project to the agencies checked below. Please fill in Add. Info. Avail.

Part II and Part I!! below and return to the State Clearinghouse.

REVIEW ACESCIES pviAging Agricul:ure - DWR C Human Resources Kansas Corpora: ion Commission Civil Rights Co: mission i Park and Resources Authority

{ Ecocomic Development ,

Social and Rehabilitation Services Education u,y Fish and Game Cc::::issicn g State Conservation Ccents:lon Transportation L

DJ Heal:h and Environment U Water Office, Kansas

@ His:orical Society Q Kansas Energy Office

'n ;; c:.:;- :- .,_ r :;

? ART II Nature of Agency review co==ents (To be completed by review agency and returned to CH:

Cneck one or more apprcpriate boxes. Indica:e commen:s below. A::ach additional sheet if necessary or use reverse side.

] Reques: clarification or addi:1onal info. O Susses:icn= for improving projecc propos.

C::etESTS:

This office has no objection to the nrantinn of the onerating license.

PART !!! Rec: tendec S:2:e Claaringnouse Action (To be comoleted by review agency :nd returned :: Clearinghouse):

chc6 one box n n ! ;.

@ Clearance of :he proje:: should be [ Clearance of cne project should not be grante: delayed bu: tne Aoplican: should (in

na final appli:stion) address er clarif y Clearance l_ of :he oro;e:: should be the ques::ans or concerns indi:ste; acove celayed un: 1 :he issues or questions have been clarified av :ne Acolic300 Req ,.e s : :he oppct uni:y :o review tha

ina applica:;on prior :c sub:L.ssica ::

he f ederal f nding agency Reviewer's Name Div./ Agency ,

Da'e j l s- /- C ' /.zp-pz B-18

STATE ACENCY A-95 TRANSMITTA' TOP.w. A IIN12Tm n Return to: Division of the 3udget O c Plc543 2 7 ;902 A M.

capitol Building Topeka,epartment Kansas 66612 of Administration, l' P.M R. c, gou t

(- ) tiott:1 cation oc h '

PROJECT TITLE: DRAFT ENVIRORMENTAL STATEliENT Q Preapplication Wolf Creek Generating Staticn, Unit No. 1 _g Finc1 Application DATE PIVIEW PROCESS ENDED SAI SUP.SER DATE REVIEV PROCESS STARTED l-27-32 2-16-22 KS220127-002 l'AMT I Initial Project Notification Revieu (To be cortpleted by Clearinghouse):

Tha attaches projet: has been submi::ed to the State Clearingnouse under the provisions of the Federal OM3 Circular A-95 revised. C Re: urn by 2 *.6-E2 This forn provides notification and opportuni:y for review of Expedite this project to the agencies checked below. Please fill in Add. Info. Avail.

Part II and Part III belcw and return to :he State Clearinghouse.

REVIEW ACENCIES I Aging R Haman Rescurces 7 Agricul:ure - CWR XT Ka.sas a Corporation Commissian Park and Resources Authori:y I Civil Rights Commission Social and Rehabili:stion Services f Economic Developmen:

Education X/ State Conserva:icn Commission

@ Fish and Came Cac. mission j Transpor:stion Q Health and Environment U Water Office, Kansas y Historical Socta:y 8 Kansas Eneroy Cffice n-s n,s. ~.a a u. .-n ea- 1sj PART 11 Sature of Agency review co=ents (To be comple:ed by review agency and :::urned to CH Check one or more appr:priate boxes. Indicate cc=ments below. Attach addi:ional sheet if necessary or use reverse side.

C Reques: clarifica: ion or addi:icnal info. C Suggestiens for i= proving projec: ;repos.

C M.ESTS:

The KCC has revie.ed :his document and has noted that scue of :he KCE and " CPI. figures used

or tne prasuctica cost savings, grow:n :orecasts and wl:n peas demand capac17 and reserve margins do not match present projections. Ti.is statement cites a majcr benefit being the projected savings novever the capaci:y tactors used te detern.ine these numcera c0 tot raten Nr.C's own capacity numbers for the industry. De KCC hewever hcs limi:ed 'urisdiction over

n;s recality un ui :nere is a request to piace it in tne rate oa x . u.e a ns 3 siecur;u Generating Facili:y Sitin; Ac: K.S.A. 66-1,158 e: seq. (1900) does no: cover :he Wolf Creek

'aculty since :ne plant was a.raacy unoer construc ton. .nu .h is ;n.y 2nw ssea ia ;ae cost *oni:oring of :his plant pursuan: to its own order, docket 11 0,924-U. Therefore, the J. .C..s. J L A r. ;

...i; A::;on

.. ..- lTc( ce completed my review agency and s

m. ....,Q ..g ..c. 3 .. . , . . . . . p : 1 .- .

? AP. ..a sec mmenceo 3:ste m.earingnouse re:urned :o Clearinghouse):

Check one hax only:

O Clearance of :ne aro)e=: should be O C: ear nce cf the :rosect shoule no: be gran:ed delayed but the Applicant shculd (in tha final apolicati:n) address or clarif Q Clearance of :ne projec: should be One quest Ons or Ocncerns indicated accvu delayed un:il th3 issues or qutstions _

have been clarified by :ne App.; an: J Reques; :he oppcetuni:y to review :he

nal applica: an prior :s suomission :s the feceral fand.ng agency Reviewer's Name i Div./ Agency Cate

.... /

[ M' f . Q, . C. 1- 8 I B.19

__-___________a

STATE ACE: ICY A-95 TRANSMI TA1. FOR>i ED JAN 2 7T:32 Return to: Division of the Sudget O of Administration, 1st Floor, Capi:ol Building, Topeka,epar::ent Kansas 66612 O !.oti:ication ot intent PROJECT T !LE: .DPAFT EttV!R0iitiEiiTAL STATE!E;li Wolf Creek Generating Station, Uni: !!o . 1 pJ Preapplication Final Application CATE REVIE'd PROCESS STARTED OATE PIV!E'4 PROCESS ENDED SAI NU".3ER 1-27-82 2-16-32 KSS20127-002 PAa; I initial Project Notification Review (To be ::cpleted by Clearinghouse):

The a:ta:hed proje:: has seen submi::ed to the State Clearingnouse under the provisions of :he Federal CM3 Circular A-95 revised. @ Re: urn by 2-16-EI This form provides notification and opportuni:y for review of this projec: :o the agencies checked below. Please fill in

[ Expedite Part II and Par: III below and return to the State Clearinghouse. L Add. Info. Avail.

REVII'd ACENCIES i~l Aging C Human Resources D Agriculture - O'<!R [l3 Kansas Corporation Commissicn 9 Civil Rights Cc--ission

• Park and Resources Authority b Cconante Developmen: 1 Social and Rehabilita:1cn Servi cs I CJuca: ion f State Conservation Ccenissica m

Fish and Care Co. mission i m

i Transpor:a: ion ig Heal h and Envir:n=en: U Water Office, /.ansas A

Historical Society 8 Kansas Enercy Office 6 i'ee i W j PART II Mature of Agency review c == ants (To be completed by review agency and re:urned Oc CH Che:k one or =cre appropria:e boxes. Indicate comments below. Attach addi:icnal sheet if necessary er use reverse side.

Reques: : arificacion er additional info. C Sugges:icns for improving crojet: propos:

~

C:r.ENTS:

N' % ' C ML7 M ? % -> m ^ L,o y~ .w W

d L%.mdtb, b , y).<-s c-l PA?? ::: Fe::mence: 5:a:e Clearinghouse Acti:n (To se completed oy review agency and re:urned :o Clearinghouse):

Cwe s one hcx only:

l < /

l / ~ Cleara'nce of :he proje:: should be C Clearance of the projec: should not bc l

granted delayed but tite Applicant snou.: (;n the final apolic::1:n) 2adress :: clarif j Charance of :ne project shculd ce :ne cues: ens or :.oncerns indica:e: a:ov:

delaye un:11 tha issues :: ques: ons l nave seen clarified oy tne Appli:an: [ Reques: :ne oppcetunity :o review ene j  :.nal applica:ian prior ro submiss; n ::

ha f ederal :un:'.ng agency Reviewer's Name Div./ Agency 02:e M@ #

.fh 7 (' ? -

4 2- + .y., j,/[,-s, W Q ,->: w :O'c B-20

STATE ACESCY A-95 TRANSMITTAL FCF.M

'R4 *~u r n . c o :

Division of :he Budget,, Depart =en: of Administra ion, 1s: Floor, Capi:al Building, Topexa, Kansas 66612

[:] hoti:icatten o: intent C Preapplication PROJECT TITLE: DRAFT ENV!RChMERTAL STATEMENT Final Application Wolf Creer. Generating Station, Uni: No. 1 O_.

SA; 5'JMEER DATE REVIEW PROCESS STARTED DATE REVIEW ?ROCESS E30ED 1-27-82 2-16-32 KS220127-002 PART I Initial Project Notification Review (To be completed by Clearinghouse):

The atta:nes proje:: has been submitted to the S;a:e Clearinghouse under :5e provisions of :ne Federal CH3 Circular A-35 revised. h] Return by 2-lE-E2 This f e rs. provides notification and opportuni:y for review of ([]Expedi:e

nis projec: :o the agencies checked below. Please fill in U A.= .4 ,,. Ava < .-

t..... .

Part 11 and Par: III below and return to the State Clearinghouse.

REVIEW ACENCIES f eging i numan Rescurces u Kansas Corpocation Commission Agri:ulture - D'a'R

                                                                                  . . Park and Resources Authority fI Civil Rign:s Commission

[e"n. Econcetc Development f) S:cial an: Rehabili:stica Services S

       , i Ljucation                                   '

f . 9. s - DLf State Conservation Co nissicn Trans;or:ation ({}}FishandCameCommissi:n'-" Heal:h and Envir o r.=e n: ] Water Office. Fansas 1,_j a_o u [3 His:orical Society [{] Kansas Enerry Cfrice

                                                                                            ....a..
                                                                                    .~               .     .. , . .

s .: ... .. ...: .

    ? ART ;! Nature of Agency review :o=nents (To be c =oleted by rev:ew agency and returned to CM Cneck one er more appr:pria:e boxes.                      Indi:ste cc==en:s below. Attach additional shec: if necessary or use reverse side.

((] 3eques: clarifica:1on or additienal inf o. ((] Suggestians f:: improv ng project propos. _-,,..r,....: . A :nv cf cur inis 3:eaty nas commented directly to N.R.C. en :ne ':!alf Creek CE*S. c mments are attached. review agency anc PAR ::: Re::mmended Sta:e Clearinghouse A:: ion (To be completed bv re:;rned :: Clear:nghouse, i:N.c one .ax an!

            --                                                                     Clearance cf :ne pro 3e : snculd not be 1-- l Clearance of :ne pr:]ect should be                        i granrec                                                        delayed but the Appiteant should (n

na final appli::tt;n; address er clari; Cle:rance Of :nc etc;e:: should be ne cues:1:ns or 0ncerns indicate: a::ve

            !_ l.

selayed ant . :na :ssues :: ques:::ns nave teen :larified my :ne Aoplican ((] Reques: the :pportuni:y :: reviev .ne

                                                                                    ;;nal applica::en pr:or :: sa:missten ::

ne feders. funatng agency 3 v.,A;ency ;a:e aeviewer's Name ) t j

                              /                    l
                                                     !KansasFishiGameCarmissied'                                   82
         /
                                 /            /

e i i B-21

i K

• REoIOMAL offtCEs:

Norshwest nessenal Offlee sootnwont Neennoot toffete At 2.343 SyPase SOS Mif 4Wey ja G8Me lleys. Kamees 4780f (sostee City. E.ames C7mn# Northeentrol Beatonal Offles Montneentres Netsnaet enffsee nas 449, $ll Cedar nos in s,2M wees math UOX 54A, RURAL ROUTE 2, PRATT, KANSAS 67124 #****"#**#'"** '##*# ^'*'******""'##" Northreat Rotennel Office Sout%eest Reesonet totisse tJ t61 G72 5911 22on s w. :sts streen :2: w .t e u... n .a.n..e Tooeke. Wause 46614 Sense C A Is Chanute. K.anean 4s;729I Fe b rua ry 25, 1982 Attn: Director, Division of Licensing U.S Nuclear Regulatory Commission Washington, D.C. 20555

Dear Sirs:

This letter is in reference to the Draft Environmental S tatement related to the operation of Wolf Creek Cenerating Station, Unit No. 1 (Docket No. STN 30-482). Comments are listed as referenced by page numbers within the report. These comments represent the views of the Kansas Fish and Game Commission as related to this project. Page vi, caracranh C-The staccment is made that "no watcr-use impacts are expected." Currently water-use impacts have occurn d. The water level manipulation program on John Redmond Reservoir has been affected. Since 1973, water levels in the reservoir have not been allowed to drop below conservatinn pool (1039') due to pumping operations for the Wolf Creek Cooling Lake. This has resultrd in a negative impact on fisheries management efforts, waterfowl use and water quality. Pas:e vii, Paragraoh L-The words "if present" are inaccurate. All of these species have been documented in the Neosho main-stream below John Redmond Reservoir. The warty-backed mussel has not been documented in Coffey County. In view of potential l impacts on threatened and endangered species, the Wolf Creek Generating Station should be required to provide the Kansas Fish and Game Commission with river flow monitoring information to enable possible salvage operations if they become necessary. Pace w. eara2raoh 8-We understand chts to mean these will be intense management of terrestrial and aquatic wildlif e resources i 1 and they will be available for recreational and consumptive uses. Pace 4-21. section 4. 3. 4. 2. narag rann 2--Subscauent stockings have includad smallmouth bass. Page 5-2. section 5.3.1.1. caragranh 1--Operational activi:ies of tne Wolf Creek Generating Station potentially affecting surf ace water include the loss oi m.2nagement of John itedmond Reservoir for fisa and wildlif a procuccian. 82O3170194 820312 PDR ACCCK 05000482 D PDR B-22

     . _ _ . - . - .         _ _ . . - .-                             .     . _. . ~                   __ .            --          ..                      _ _

1 I U.S. Nuclear Regulatory Commission Page 2 l Washington, D.C. Februa ry 25, 1982 a

 ;                                           Page 5-9, section 5.5.1.1        saragranh 1--Further explanation of "a natural state" is needed to describe the buffer zone around the cooling lake.

Page 5-10, section 5. 5.1.1, paragranh 3--The ef fect on the i wildlife-carrying capacity of local terrestrial environments will depend upon the land management of the area in the future.

  !                                          oaee 5-12, section 5.5.2.1, paratraoh 3--Water withdrawls could I                                          cause less negative effects if they are coordinated with water level management needs at John Redmond Reservoir.

General Considerations--In reference to water withdrawls from the John Redmond tailwater area we would reconmend that instream flow requirements be determined for the area immediately down-stream f rom the impoundment. These requirements are necessary to ensure the maintenance of the aquatic ecosystem in the Neosho

  !                                         River.

Blowdown releases via Wolf Creek would be discouraged during low flow conditions in the Neosho River. Thermal stresses may oct:ur at these times as well as high chemical concentrations which may not be adequately diluted by waters in the Neosho River. l Jeoshe madec=s have been collected at the confluence of Wolf Creek and the Neogho River. As this species inhabits riffles, the above recommendations are necessary to ensure its survival 1 and habitat. Spawning by Neosho madtoms probably occurs during June and July. If low flows would occur during these times and spawning prohibited, the short life span of the species may cause severe inroads into the population. Floculation of heavy metals may contribute to the " filling in" l of riffle areas and gravel interstices reducing available habitat for adult madtoms. Releases from blowdewn, therefore, should only be made during moderate or heavy flows in the Neosho Riv.:r I to avoid this pecblem. In menitoring the ecosystem for radiological impacta, fish flesh from within the cooling lake should be monitored for potential untake of radioactive contaminents. Sincerely.

                                                                                                   ,- , ,?

Nd W s f*4

                                                                                     ~-               t                   3      7 ,

1 Sill llanzlick, Directo9 5(" Kansas Fish and Came Commissicr. , BH:WCL/ pig xc U.S. Fish & Wildlife Service Leonard Jirak Marvin Schwilling Kansas Energy Office BobCulbertson S.E. Regional Offlec B-23 2 I

                     , -_..m            _ - --- - . ,     - . - -                              ---- -        - - - - - -              ,-r-r--.-

STATE ACENCY A-93 TRNISMZTTAI. FORM 2[C"O JAN 2 7 g Division of the Budget D Return :o: Capitol Building, Topeka,epartment Kansas 66612 of Administration, 1st Floor, -(f['. 96 PROJECT TITLE: DRAFT EliVIRONMEilTAL STATEf1EitT Noti:ication c: intent Preapplication Wolf Creek Generating Station, Unit :lo.1 Final Application DATE REVIEW PROCESS STARTED DATE REVIEW PP.CCESS E.N;ED S AL N'J:2ER 1-27-82 2-16-82 KSS20127-002 PART I Initial Project Notification Review (To be completed by Clearinchouse):

   'ineattached project has been submi::ed to :he Sca:e Clearinghouse under the provisions of the Federal OM3 Circular A-95 revised.                                 [I) Return     byh'iQ This form provides notification and opportunity for review of                                        Expedite this project to the agencies checked below.                        Please fill in Add. Info. Avail.

Part 11 and Par: III below and recuta to the State Clearingnouse. REVIEW AGENCIES Aging []

s. Agricul:ure

((] Hunan Resources

                          - Ok'R                                              '? Kansas Corporation Connisstun Civil Righ:s Cornission Park and Resources Authority i

l~)EeunomicDevelopment{h d Education Fish d{})Sact:1 andTransportation Care S:ste Commission and Conservation Rchabilita: Commission ion S.: [3 Health and Environment tater Office, Kansas 2] Historical Society _ ((] Kansas Enerev Office etWM-Ge'ne'?+ tiH-+J m cy PA3T II Na:ure of Agency review comme.mts (To be completed by review agency and returned to i Check one or more appropriate boxes. necessary or use reverse side. Indicate concents below. Attach additional sheet if [] Reques; clarifica: ton or addi:ional info. ((} Suggestions for 1 proving project prope _ COMMENTS: See .sttached Memorandum. 1 AR* 11? Ir.a?.menJed S:ste Clearinghcuse Action (T' ue comnleccJ ny revicv a4:n y and returned :o Clearinghouse): i:heca ne box onI) [] Clearance of :he project should he [$] Clearance of the projec: should not be grantea Jelaycd bu: the .\oclicant should (if tee final cppiscaticn) ad:ress or clari- [_ I Clearance of :nc penject should be :he cuesttans or uuncerns indicated abo-de'.ayed un: 1 :he issues ar ques:1ons __, havs :een clarified by the Applicant ' _j 3cquest :ne opport':nity to review the fina. 1pp i;ca::vn pr:ct :o submission : the f ederal funding agency

 '.4eviewer's Name                                 Div./Agengy                               Date
                                          ,* -^ ) , u ./ . , , A .L .   . , . .           .

B-24

A THE ST ATE e - OF K ANS AS I W KANSAS WATER OFFICE Suite 30) tos Kansas Avenue Telephune (113 ) 196-115T TOPEKA. KANSAS 6'660) _M _E _M O _R _A _N D _U _M Date: February 17, 1982

                                                                         /

To: Division of Budget j/ s From: Allyn O. Lockner, Director

Subject:

A-95 Review, Wolf Creek Generating Station, Unit No. 1 (KS820127-002) The Kansas Water Office has some editorial remarks to make on this Draft Environmental Statement, Wolf Creek Generating Station, Unit No. 1.

1. page 4-15, page 5-2 and others - The Kansas Water Resources Board has been replaced by the Kansas Water Office and Kansas Water Authority by legislation effective July 1, 1931.

2. page 4-15, paragraph 3 - Sentence should read, "The Kansas Water Of fice has estimated that the yield capability from the water suoply storage through a 2% chance drougnt would be 1.0 x 100 ma/ cay (26.5 mgd from the water supply portion, 4.3 x 10'n (34,900 acre-feet), of the storage after adjusting for 50-years of sedimentation in John Redmond Reservoirwater 4)." John (Ref. supply Redmond has two conserveAion storage purposes: and L water quality. Only the yield (26.5 mgd) from the current water l supply storage portion of the total conservation stcrage (yield 47.13 mgd) was contracted to Wolf Creek Generating Station.

3. page 4-15, paragraph 5 " regulated storage" should be Regulation of the flows into the Neosho River began when definec.

the control gates were closed to begin deliberate impoundment of water on September 1, 1964. The project was used for flood control purposes prior to that time. What is source and significance of the September 7, 1963 date?

4. page 4-16, last paragraph "Tonganoxie" misspelled.

page 4-17, paragraph 2 " withdrawals" misspelled. 3.

d. page 4-19, paragraph 1 - Filling cf the lake was initiated in '!ay

             >      1980.

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Division of Budget Page 2 February 17, 1982 7. Page 5-2, paragraph 5 - Should be changed to read, "The Kansas Water Office has the right to contract for the withdrawal of water from reservoirs (Kansas Statutes Annotated 82a-1305) up to but not exceeding the reservoir yield capability during a drought having a 2". chance of occurrence in any one year with the reservoir in operation. The Kansas Water Office's right to divert and store

                                                                          )(k water in John Redmond Reservoir was accepted by the Chief Engineer.

Division of Water Resources, Kansas Board of Agriculture (Water Reservation Right Number 5, File Number 22,197-AR-5)."

8. Page 5-2, paragraph 6 - This paragraph is confusing as rates (m3/ s) are discussed as if rates were quantities (m3). The Kansas Water Office has contracted with the Corps of Engineers to use 34,900 acre-feet of storage space in John Redmond to store water for water supply purposes, i.e., municipal and industrial use. This-storage is estimated to yield 26.5 mgd in conjunction with other uses of the reservoir water. Actual diversion rates are discussed in paragraph 3 of this page. Wolf Creek Generating Station has contracts through the Kansas Water Office for only the storage of John Redmond allocated to water supply AOL:LGH:dk i

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                 "'*"                                                        March 12,1982 wamCt paasc SCO commiss oNeas DONALO8'NNS GamaLgv CLAAE d                                    g 70u QLgason 8   CEM.p NANCYS=o472 bU w NR 1 ;ja82tm. IO' Director. Division of Licensing Huclear Regulatory Comission                                         h ".a;$""                "rre te::2=[

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Dear Director:

The City Commission of the City of Lawrence, Kansas, has asked me to respond . to your invitation for public coments on the Draft Environmental Statement related to the operation of Wolf Creek Generation Station at Burlington, Kansas. There are several reasons why the City of Lawrence is interested in the operation of Wolf Creek Generating Station:

1. The City of Lawrence, with a copulation of 52,738 persons, is between 55 and 62 miles north / northeast of the Wolf Creek Plant. A portion of the Wakarusa watershed area, which provides water for the City of Lawrence, is within 50 miles radius of the Wolf Creek Plant.

2. The prevailing wind pattern in this part of the state places Lawrence and its watershed directly in the prevailing wind pattern during much of the year. We fear that our location will expose our city to radioactive carticles which could be carried by the wind.

3. A number of our citizens han expressed a real concern to the City of Lawrence that we should be well crepared to meet any emergency that might be predoitated in this exoosure pathway by the operation of the Wolf Creek Generating Station.

(CC) 8

                                                                                                                      /C s:03170:s9 e:osia PCR ACCCA o3Cooaag D                             PDR B-27

Director, Division of Licensing Washington, D. C. 20555 March 12,1982 Page 2 The City of Lawrence has taken previous action to control and monitor the transportation of radioactive materials within cur city. We feel that this ordinance indicates the interest of the Commission and the community. The ordinance adoption shows our willingness to accept our responsibility in j this sensitive problem area.

)

The City Commission has asked me to request that the City of Lawrence be I included in the Emergency Preparedness Plan Provision for " appropriate ! ranges of protective actions, provisions for rapid notification of the public '. in serious reactor energency, and methods, assistance, and ecuipment for assess-ing and monitoring actual or potential off-site consequences in the emergency planning zones of a radiological emergency condition." We believe that it is ouite important and prudent for the City of Lawrence to be a part of the overall Emergency Preparedness Plan and have the benefit of immediate notification of any emergency so that our citi: ens can be warned. We ask that the Nuclear Regulatory Commission make certain that the Emergency Preparedness Plan is completed well in advance of the fuel loading dates so that the City of Lawrence and the public can have time to comment on their perceptions of its workability.

We thank you for giving us the opportunity to comment on the Environmental Statement as we believe that it affects the citi

ens of the City of Lawrence.

;     If I can provide further information, please feel free to contact me.

Sincerely, li$$0 NOf & Marci Francisco Mayor MF/ed a cc: Members of the City Commission Leon Mannell t t i f B-28

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Douglas County Emergency Preparedness 3X3

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Judicial and Law Enforcemect Center g#g# 111 Eas: tit Street Lauence. Kansas c5; 4 m.,g, m,7" cow.ssicsE s 3, , , r nat*1m a :mata .

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Nuclear Pegulatory Comnission V q h;"' Y 2 y p % % '-,'. Washington, D.C. 20555 f.K,r ) ;W [

Dear Directcr:

                                                                               "'h , e,. 4 The Emergency Preparedness Board of Couglas County, Kansas, has asked te to respcnd to your invitation for public cerzents on the Draft Environmental State-ment related to the operation of Wolf Creek Generation Station at Surlincton.

The prevailing wind pattern in this part of the state olaces Couglas County ano its watershed directly in tne prevailing wind cattern during mucn of the year. We fear that our locaticn will expose our county to radicactive particles ahich could be carried by the wind. The Couglas County Emergency Preparedness Scard has asked me to rguest that the county be inclucec in the Emergency Preparedness Plan Provision for "ap;;ropriate ranges of protective actions, provisions for rapid notification of the public in serious reactor emergency, and methods, assistance, and equipment for assessing and monitoring actual or potential off-site consecuences in the emergency planning zones of a raciciogical emergency condition." As pcrtions of the county are within 50 miles of the plant, we believe it is important and prudent for the Ccunty Emergency Preparedness office to be a part of the overall Emergency Preparedness Plan and have the benefit of irredtate r.otification of any emergency so that our citizens can be warned. We ask that the Nuclear Regulatory Commission make certain that the Emergency Preparedness Plan is completed well in advance of the fuel loading dates so that Douglas County and the public can have time to comment on their percections of its workability. We thank you for giving us the opportunity to cornent on the Envircnmental Statement as we believe that it affects the citizens of Douglas County. If I can provice further informaticn, please feel free to contact me.

                                                                                   /

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Coordinifor Cougl ( r unty Emergency Preparedness PL:kb TCRN AOC W ARN!NGs m ucurs~ac1Rs 0 . . . NUCLEAR A TTACK

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TO THE

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UNITED STATE NUCLEAR REGULATORY COB 0iISSION f WASHINGTON, D. C. 20555 'kh . "

                                                                    ,         %7ke ,

ATTENTION: DIRECTOR, DIVISION OF LICENSING 'N, 9 y "** gS

                                                                   ?R$f. 3,'?4r5 E~

Ae45% M rROM MARGARET W. LO;GS, 944 ST. JAMES PLACE, WICHITA, KANSAS 67206 While I am a =em b uf i.he-Wichita League 4f.Wnman Voters, a me=ber of the Consumers Information Board of the Kansas Corporation Co:niss-ion, and the Wichita-Sedgwick County Energy Monitoring Board, these co ents are =y own and do not represent the thinking, necessarily, of the above mentioned Eroup and boards to which I belong. l l l l RE: DOCKET NO. STN 50-482 DRAFT ENVIRONMENTAL STATEMENT FOR WOLF CREEK GENERATING STATION, UNIT NO. 1 March 13, 1982 0 e2022202Ce e20212 PDR ADOCK 05000482

                                                              $' \

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Page One Those who read the first environmental statement relative to the construc-tion license for Wolf Creek Generating Station and followed the Ato ic Safety and Licensing hearings in Kansas City from January to May 1976 must experience a strong sense of deja vu upon reading the second environmental statement rel-ative to an operating license. Despite the cancelling of seven nuclear power plants in 1981, of eight in the first three =cnths of this year, and sixteen more to be cancelled according to NRC staf f estimates, despite the accident at Three Mile Island, despite the egregious errors at Diablo Canyon, despite the accident at Ginnay, despite the e=barrassingly inaccurate 1976 projections of de=and, despite the fact that con-struction of nuclear plants is endangering the financial solvency of utilities, despite the Lewis, the Kereny and the Rogovin reports, despite the problems of embrittlement and corrosien that are widespread, --yes, despite all these, the staf f of the 'Welear Regulatory Coc=ission can unequivocably make a case that the cperating license for Wolf Creek should be granted because the nuclear power generated there would be safe, reliable, necessary and econocie. Such opti=iss is suspect; and one is reminded of Harold Denton's use of the word "=ind-set" to describe the attitudes of the regulators of the nuclear power industry. ENVIRORIENTAL Knowing that huge amounts of high level wastes, transuranic wastes and mill tailings generated by the nuclear fuel cycle re=ain in the environment, unburied after forty years, awaiting an acceptable long range canage=ent policy--even a demonstration facility, it is difficult to reconcile this environmental state-

=ent with the NEPA charge which requires the federal government to " fulfill the responsibilities of each generation as trustee of the environ =ent for succeed-ing generations' and to " attain the widest range of beneficial uses of the envi-ronment without degradation, risk to health or safety, or other undesirable and unintended consequences."

Alternative power scurces, such as conservation, cogeneration and other stall power pose virtually no safety problens compared with the environ = ental hazards of nuclear generation and waste disposal. DD!AND It is stated on page 2-5 that the operation of WCGS will provide auch needed capacity for maintenance o f =inimum rese rve mar gins ; ye t , on average, the nation's B-31

I

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l Page Two i utilities have a 35 percent surplus of electric generating capacity, twice the reco== ended reserve =argin. Moreover, =any energy analysts predict that de=and for electricity will re=ain flat and =ay even shew negative growth by the year 2000. Because of energy efficiency the US econo =y is already using about 13 percent less energy to produce each dollar of product than in 1973; and by the end of the century, these analysts =aintain, we will be using 40 percent less energy for our necessary end uses. This RCC draft state =ent ignores the probability that the six =aj or s te a= consu=ing industries will be heavily into cogeneration in the coming two decades. Vulcan, which now uses almost ten percent of KG&E's generating capacity, has al-ready announced its plan to install cogeneration syste=s. Moreover, greving on-site use of wind =achines and photovoltaic syste=s (probably i= ported fro = Japan) will be producing a significant a=ount of electricity by 1990. The staff also fails to recognize the effects of conservation, which is an energy source in it-self. De=and has proven highly elastic; and ingenious custo=ers will =eet the

,  challenge of higher and higher electric prices with weatherization, passive solar heres and buildings, = ore efficient appliances, landscaping, etc.

The NRC should have learned fro = the first environmental state =ent that de-

  =and forecasting is a highly risky art. This second state =ent with its unreal-                  l
                                                                                                   )

istic de=and projection has been based on outmoded assu=ptions. Nuclear power with its long lead ti=es and its high capital require =ents does not provide the flexibility that is required in today's volatile energy =arket. Ccnservation, co-generation, bio = ass, wind power and photovoltaics do meet these require =ents of flexibility. The financial =arkets have already recogni:ed this reality and are saying "no" to nuclear power plant investment. l ECCNOMICS BENEFITS On page 2-2 appears this extraordinary state =ent under the heading of Pro-duction Costs: "Because most of the substantial capital and enviren= ental costs associated with construction have already been incurred, the only econo =ic fac-tors that are relevant for consideration now are syste= fuel costs and operation and =aintenance costs, because these expenses will be affected by whether or not WCCS operates." Should WCCS go en line, KC&E's customers would wish they might as easily escape the costs per kwh of the huge capital invest =ents. What new sys-te= of accounting allows the disregard of S2 to $3 billion? Nor is it easy to l B-32

Page Three i=agine that bond and stock holders would agree to this f acile elimination of their invest =ents. Since the NRC staf f conclusion that the three utilities par-ticipating in WCCS would receive a $110 million a year benefit rests upon this new unorthadox for= of bookkeeping, the conclusion lacks credibility. On Page 2-2 it is stated that the nor=al capacity factor for WCCS would be 650. Yet Charles Ko=anof f, an independent energy consultant, says that the new larger nuclear plants over 800MW are averaging only 55 capacity. Since the NRC estL= ate of the S110 million cost saving also rests upon operating at 65: nor=al capacity, are the conclusions reliable? It is noted that the staff would e xpect only an $86 =1111on cost benefit the first year, and that the staff esti-

 =ates an average 60: lif eti=a capacity factor--still 5% above Ko=anoff's calcu-lations.

DECOMMISSIONING NRC staff finds EGiE's esti=ated cost of decc==issiong, S63 million, as reasonable, Page 2-4. However, in R. S. Wcods's " Assuring the Availability of Fund for Deco ==issiong Nuclear Facilities", 1979, page 4, from the NRC, it is esti=ated the cost of deco ==1ssioning a large co==ercial reactor (1000MW) would range fro = 4 percent to ten percent of construction costs. Since WCGS

  =ay easily cost S2.5 to $3 billion before construction is completed, 4 to 10 percent of this cost could be $100 million to $250 million. References for Section 2 regarding costs of generation and decc==issioning, " Coal and Nuclear:

A Comparison of the Cost of Generating Baseload Electricity," and " Technology, Safety and Costs of Deco ==issioning," page 2-7, are both studies published in 1978 and so are co=pletely out of date and not pertinent to todays's costs.Be-cause no large nucl' ear power plants have ever been deco ==issioned, NRC staff's acceptance of the unrealistically low KGLE estimate =ust necessarily be largely guesswork. RISK Repeatedly throughout the environ = ental state =ent such ter=s as " negligible effect," "quite small," " exceedingly small," "not expected to be significant" are used. While the NRC does ad=it to some uncertainties in esti=ates of conse-quences , in risk esticate probabilities, nevertheless , the staf f consistently leans toward the least and not the worst case. The staf f see=s never to have heard the dictu "If so:cching can go wrong, it will." Although the NRC staf f has ad=itted the necessity for rebaselining of the B-33

Page Four Reactor Safety Study, nevertheless, it also states that the technique of grouping as was done in the RSS has not been co=;1etely eli=inated, page 5-48. l The Lewis report would seem to receive only lip service; and assessing risk on a probabilities basis, as the NRC has done in the WCGS statement, is far too i= precise to for= a basis for its decision. Especially alarming is the statement on paga 5-64 that the require =ents of new safety ceasures that grew out of the Three Mile Island 2 accident have not been completely applied to the licensing process for WCGS. "The action plan presents a sequence of actions, some already taken, that result in a gradually increasing i= prove =ent in safety as individual actions are co=pleted. The Wolf Creek Unit 1 plant is receiving and will receive the benefit of these actions on the schedule indicated in NUREG-0660. The i= prove =ent in safety from these actions has not been quantified, however, and the radiological risk of accidents discussed in this chapter dces not reflect these i= prove =ents." Surely, at the time KC&E is applying for an operating license, all these safety measures should have been i=plemented. NRC Chairman Nuncio Palladino has recently stated that when a nuclear plant is l' censed, i it should have eneugh insurance to cover the cost of an accident and the cleanup, and that this coverage should be reviewed every two l to three years so that inflationary factors can be taken into account. Will KG&E and KCP&L be required to carry cuch insurance, and were such insurance costs included in the $110 million benefit analysis conclusion? From reading Appendix F regarding evacuation codels for WCGS, it appears that the now repudiated RSS consequence model has been the NRC staff's guide. Even the require =ents of this model are yet to be put into a final form for WCGS. Especially and absurdly inadequate would seem the assumption that the cost of evacuation and relocation would be $125 (1930 dollar) per person which included cost of food and te=porary sheltering for a period of one week. Both the Kemeny and Rogovin repcrts urged the NRC to =ake reforms in three major areas of regulation: the licensing of new plants, safe operation of exis-ting plants and plans for dealing with accidents and other emergencies at nuclear power facilities. CONCLUSION; This environ = ental statement would appear to have been written with little or no regard for the reforms advocated by the Ke=eny and Rogovin re-ports. The NRC continues to be more concerned with giving out licenses than with i= proving the safety of nuclear power plants. The license should be denied. B-34

Page Four Reactor Safety Study, nevertheless, it also states tha: the technique of grouping as was done in the RSS has not been cc:pletely eliminated, page 5-45. The Lewis report would seen to receive only lip service; and assessing risk on a probabilities basis , as the NRC has done in the WCCS statement, is far too imprecise to for= a basis for its decision. Especially alarming is the statement on page 5-64 thar. the requirements of new safety ceasures tha: grew out of the Three Mile Island 2 accident have not been completely applied to the licensing process for WCCS. "The action plan presents a sequence of actions, sc e already taken, that resul: in a gradually increasing improvement in safety ac individual actions are completed. The Wolf Creek Unit 1 plant is receiving and will receive the benefit of these actions en the schedule indicated in NURIG-0660. The improve =ent in safety frc: .hese actions has not been cuantified, hevever, and the radiological risk of accidents discussed in this chapter dees not reflect these inprovements." Surely, at :he :ine KC&I is applying for an operating license, all these safety measures should have been implemen:ed. SRC Chairman Suncio Palladino has recently stated that when a nuclear plant is licensed, it should have enough insurance to cover the cost of an accident and the cleanup, and that this coverage should be reviewed every two to three years so that inflationary f ac:crs can be taken inte account. Will KGLE and KCP5L be recuired to carry such insurance, and were such insurance costs included in the S110 tillion benefit analysis conclusion? Fro reading Appendix F regarding evacuation models for WCCS, it appears that the new repudiated RSS consequence =cdel has been the NRC staf f's guide. Even the requirements of this model are yet to be put into a final for= for

  %'CCS . Especially and absurdly inadequate would see: the assu ption that the cest of evacuation and relecation would be $125 (1930 dollar) per person which included cost of food and te porary sheltering for a period of one week.

Both the Kereny and Ecgovin reports urged the NRC to make reforts in three rajor areas of regulation: the licensing cf new plants , safe operation of exis-ting plants and plans for dealing with accidents and other emergencies at nuclear power facilities. CONCLUSICS; This environmental statement would appear : have been written with little er no regard for the reforts advocated by the Keneny and Rogevin re-ports. The NRC continues to be =cre concerned with giving out licenses than with 1:preving the safety of nuclear power plants. The license shculd be denied. B-35

1224 Louisiana Lawrence, KS 66044 / q 4 March 10, 1982 /ef\

                                                                             /                  s
                                                                           /        RECSNUD Mr. Jon Hopkins, Licensing Project Manager

• D Office of Nuclear Reactor Regulation d(. gy $ gtr d U.S. Nuclear Regulatory Com=ission Washington, D.C. 20S55  % 33rse Ttrzumus N asuss

                                                                                          .maa 4e

Dear Sir:

6 g The following coe=ents with respect to the recent Draft Environmental Stateme_ for the Wolf Creek Nuclear Generating Station (Unit 1) are submitted for your careful consideration. Reactor vessel cracking or "ther=al shock" has recently become a topic of such discussion among those concerned aeout the safe operation and longevity of nuclear power plants. The following excerpt from " Reactor Safety and the Research Budget" (Science. Vol. 214, 13 November 1981) deli =its the nature of the problem in a reasonably succinct and easily understood manner.

        "At the heart of the problem is the steel vessel which holds the radicactive fuel and the water that cools the fuel. As time goes by it is weakened by neutron radiation from the core. Grad-us11y the steel loses resilience. After a decade, the most heavily irradiated section of the vessel (the midline) becomes quite brittle, even at relatively high te=peratures. Flaws in this section of the vessel may expand into cracks and, under cer-                          ,

tain circu= stances, the cracks may burst, spilling the water needed to cool the fuel core. This could happen, for example, if the het (5500 F), brittle area at the middle of the vessel were I suddenly doused with cold (400F) water at very high pressure l (2200 pounds per square inch). The scenario is not implausible. It is precisely what would happen if there were a break in the main steam line outside the pressure vessel, followed by a delib-erate attempt to cool the reactor while maintaining high pres-sure in the vessel. The heat shock and the pressure would put tremendous stress on the fragile section of steel. A crack might develop, burst, dump highly radicactive water on the floor faster , than the energency cooling system ceuld make up the loss, and ' lead to an accident not unlike the one at Three Mile Island in which a partial melting of the core occurred." Richard Johnson, an NRC licensing official, metallurgist and task manager for the thermal shock progra=, says that he and other NRC staff tried to get the NRC to pay attention to this aspect of safety for at least ten years. Just one year ago in yebruarv ~hc=as Murley, the NRC's chief cf safety technology, examined data frc Ranche Seco 1 in Clay Station, California, and found that durin; an unplanned shutdown all of the recu:.rements for a thermal shock r flebh S20'316 CMS 5~Cli E_ p;R ACOC A C"CCv gt C 1 1

                          - a.

B-36 l

( Mr. Jon Hopkins, NRC i Page 2 f March 10, 1932 j l l scenerio were present--except for a brittle vessel (it was only three years old). l l In an October 1981 report, the Oak Ridge National Laboratory (upon request by the NRC) concluded that " pressurized thermal shock must be regarded as a serious potential threat and =erits a great deal more study using refined techniques." The NRC now considers this proble= to be one of extre=ely high priority. However, the draft environ = ental statement for Wolf Creek fails to directly address this serious issue--an c=ission that can only be adequately dealt with, as I see it, in one of two ways: A) A vessel =ust be designed and tested which shows no significant loss in strength af ter 30-40 years (the expected life span of a nuclear plant) of neutron be= bard =ent.

3) The licensing of the plant will be limited to a maxi =u= of ten years and the strength of the steel vessel regularly tested during that time. Needless to say this would require a reanalysis of the cost / benefit calculations for the plant which were based on an expected life span of three to four ti=es this value.

This "new" probles of reactor vessel e=brittlenent also necessitates a recalcu-lation of the probability for a serious accidest to occur, especially as the l vessel ages. Unfortunately, the analyses of data based en hundreds of hours of reactor operation have provided virtually no relic.ble infor=ation about how

                                    =uch the radiation risks to workers and the likelihood of radiation-releasing accidents increase as a plant gets older.

These probabilities most certainly do not re=ain constant ove- time for a given plant, and neglecting to include current, available infor=stion about the pos-sible effects of something that occurs as frequently as a break in a stea line (which, as has been illustrated, can trigger a melting of the core) in the final draft of the environ = ental state =ent for the licensing of Unit I at Wolf Creek can not be thought of as anything less than a serious o=ission. The Wolf Creek draf t also neglected to contain updated infor=ation pertinent to the adverse environ = ental effects associated with nickel-59 and niobiu=-94 which have half-lives of 80,000 and 20,300 years, respectively. An environ-cental impact statement on reactor deco ==issioning published in 1981 by the NRC indicates that the dose rate fro: niobiu=-94 in reactot components will be about 17,000 re=s per year if the reactor is operated for 30 to 40 years; that fro: nickel-59 vill be abcut 300 re=s per year. The statement admits that these dose levels are substantially above acceptacle residual r1dioactivity levels and concludes that entoebinz a shut-down reactor in concrete would thus be acceotable only if these long-lived 13ctopes were.re=oved or if the inhe;- rity of the ento =bing structure could be =aintained for thcusands cf years. l l 1 B-37

Mr. Jon Hopkins, NRC Page 3 March 10, 1982 The SRC's manager of deco =nissioning programs, Donald Calkins, is acutely aware that these two long-lived isotopes create problems in decom=issioning that are neither st=ple nor insignificant. Yet, page 5-68 of the Wolf Creek draft simply states that "the technology for decoccissioning nuclear facilities is well in hand, and, although technical improvements in decommissioning are to be expected, at the present time deco =nissioning can be performed saf ely and at a reasonable cost." However, the statement that a nuclear facility (in the context of this draf t) can be safely decommissioned is not a statement of fact; it is simply a con-jecture since no large commercial reactor has ever been dismantled, much less decommissioned. We do have experience in taking apart and burying the pieces of two small reactors which were shut down after only a few years of operation-- the Elk River plant in. Minnesota (22 megawatts) and the Sodium Reactor Experi-ment in California (see: "A Long-Term Problem f or the Nuclear Industry." Science. Vol. 215, 22 January 1982) . But it is premature to say that we have the technology to even dismantle something on the scale of the Wolf Creek plant before we get experience with a large reactor that has been in operation for at least a decade (our first opportunity will probably be the Shippingport plant in western Pennsylvania). That a nuclear f acility can be deco =missioned at a reasonable cost is not a catter of conjecture: it is a catter of how you interpret the word " reasonable". The s=all. plants in Minnesota and California cost $6.15 million and $10 million, respectively, to take apart and bury. According to estimates published by the DOE (owner of the Shippingport plant) it will cost more than $40 million (at 1982 prices) to dismantle the plant and remove radioactive debris from the site. The process will take about five years to co=plete, and it will generate some 11,700 cubic meters of radioactive waste. All of this will come from a reactor that is only one-tenth the capacity of the large reactors being built today. Recent astimates (see above reference) indicate that decommissioning a 1200 megawatt reactor will cost between $50 million and $100 million. Although this represents less than ten percent of the cost of building one of these plants, this figure is certainly not insignificant and therefore needs to be included in the cost / benefit calculations for Unit I at Wolf Creek. Furthermore, the sentence on page 5-68 of the draft is overstated and requires rewording for accuracy: " Decommissioning costs for reactors are a small fraction of the present-worth ce=missioning costs." In su ary, the final draft of the Wolf Creek Environmental Statement must include a satisfactory solution to the following proble=s associated with decommissioning: A) Since a worn-out reactor is highly radioactive, hew can we guarantee that the extremely expensive process of safely deco ==issioning this plant will be funded? B-38 i

l l Mr. Jon Hopkins, NRC Page 4 March 10, 1932

3) If the experience we gain from Shippingport does prove that the tech-nology exists for dealing with the dismantling of a large power reactor, how can we be sure that the highly radioactive debris resulting frcm such dismantlings will be adequately guarded for the thousands of years neces-sary for niobium-94 and nickel-59 to decay to insignificance, and that none of the radiation from the remains leaks into the groundwater?

       "A" requires an explicit assurance of ability to pay for the decommissioning, and according to Donald Calkins, two proposals are being considered for this assurance. One sets up a special decoccissioning fund and the other allows for the utility to have sufficient insurance to cover such clean-up costs.

It is imperative that these costs and these assurances, currently missing, are clearly specified in the final draft of the environmental statement .

       "3" initially requires waiting to see whether Shippingport can be safely dis-mantled.       Then it requires, I far as I can see, nothing less than faith that we will be able to guard these wastes for thousands of years, either at some designated burial site or at a federal high-level waste repository which will most certainly not be ready for operation before the year 2000 (see: "Radwaste:

Choosing a 3urial Site. Science News. Vol 121, No.l. 2 January 1982). Finally, it appears that we must rely on faith again to keep these icng-lived, highly radioactive wastes from contaminating our groundwater, since no radioactive container has yet proven to be leak-proof for more than several decades. I wish to thank the persons in the Office of Nuclear Reactor Regulation and the members of the Nuclear Regulatory Co= mission for carefully and completely reading and responding to these co=ments on the Draft of the Environmental S tat ement for Unit 1 of the Wolf Creek Nuclear Generating Station. It is my intention that these ce=ments, through your actions, will help to make the final draf t of this important statement more complete, more up-to-date, and more accurate. Yours very truly, Scott H. Jamiesen B-39

alARCH 10, 1982 IntrccLeticn: danstas (cr annsicle t ne r t;y , <Ast, a re intervencre in the up-eretin; license nsarings f or tne Lolf Creek generating station. As e aroup ee suco:rt ccnservation anc consumerism in the el- ' ectri:a1 energy fielc, and capess tne granting of an operating a licensk. In t-is esspense to ins "Draf t Lavircn.acntal 5 tate-ment" relatec to the operation cf dolf Creek Cenerating 5tation,

                         .e s e .i :., - , -:.,
                                                     .Jnt - b-e,.,    .n. A a. .t Of.,ers sc.ns : servations cocket i
      #ce inc cens10cration of tac AdC, and sone e.a t erial w e thi nx i

s7culc Occcme a part of tne. final draft statement. For tne a sake of crevity, ue snsll confine our comments to three gen- e eral e:ecs:

1. '. c e d for tne electricity provided by GCCS J

~

i

2. Assessment of potential risk of accident

3. 31ciolo;Icel impcet of fuel cycle on environment

1. ..CE3 FGn THE EuCCTA: CITY GRC ii 3t] 'cY hCCs.

In saction 3 of tne craft environmentai statement the staff

!      cencludes that "...tna only logical alternative to operation of tne station is to ceny its Operction."                                         .c agree tnat if tne a

spp. two cillion coll rs cf ecastrs:tico c: sts :'rc disr+ 2 rc.a, , t- c; .: .: 1-:s expe.sivs usy t a c, : n .a : ; c.. . , ,:; t e.n l a nt caount

'      cf sic:tric?1 ener;y.                                However, inis coas not a: dress tne i

i ;uestion Of whetP.e :ne 110: ..ie to :e or:cc:ec ey cCGS is 1 S203220218-820310 hl6

,            PDR-ADOCK 050004E2 D                                 PDR B-40 l

2 actuelly needec. Cn page 2-3, taole 2.1 c c:r.p a r e s t h e op e r a -

r, cos:s of 2C 5 ti:h tne cperation costs of replccement poter. 51cce the acssicility exists that oc replacement power is nec:cd, e third category should be edded listing "Produc-tion ecs:s if no replacement power required". Of ccurse, the ccsts esscciated uitn this alternative will be Zero for each y ea r included in tne t acl e. Another line snculc ae accec, "Sav-in;s ti:n 0:C5 not in op era tion". The figures for this line

cul: :s tne :::el nucl err pr::uctice ::::: f:: se c, y e?. : in-c'w  :- :. .=is.

            .1  - : e inclusion of these lines to tacle 2.1, :ns crimary ;ucstion Ceccmess is tne electrical pteor to se gen-erates of 1:35 necJcJ?          There are many r ea sons t        expect tn0 c e ne n; f: elac:rical energy will level off cr cecline.                  ii. u c ,

.of the grottn in peck cema nd in the '70's is a t t ribotable to all-cle:tric .cmes 2nc electrical heating in residelitial use. Croctn in th ese a rea s ha s virtdally ceased cue to lack of Ce-nen: f c r t il-:-l e: t ri: m a.u s . 4::: :P :nis crop 23 4-c nd as r

-s 1: Of a levaling of resicential electricel ra t es, elim-ine:in; a en:e stracture cesigned to rewarc wa ste anc of f er owners of all-ele: ric h:mes reduce: ra t es. As prices gc up 2n0 conservation continues to make a " surprising" cif f erence tetreen load f oreca st s enc actual increa s e in demand, usage anc cea< cemand will cecline. If the utilities woulc, instecc of encouragin; censunctica, f ast er conserva tion :n rougn the use of icac mana;ccent te:nnalogy, deman: 2 ul fall even n=re.

B-41

Which brings us to page 2-6, taole 2.3. This amtitious table forecasts rate of demand growth for the next eignt years. Since the applicants have overestimated this same rate cach year for the past signt years, this table calls for a closer ex a mi na tion. KASE recommends that the f ollowing taole, table 2.3.0, ce added to the final draf t report: Table 2.3. 3 Peak A nnua l Cacacitv ( n.w e ) Reserve u.arcin ( ') Demand date of Without sitn Witncut with 1CG5 uCCS LCC5 Year (WJe) Growtn(f) CCC5 KGE 1954 1755 - 2111 2552 15.2 45 1995 1812 1.5 2111 2552 15.5 45.4 1935 1839 1,5 2247 2755 22.2 51.5 1567 1.5 2247 2755 22.4 49.4 1957 199E 1895 1.5 2247 2755 15.5 47.2 1959 1922 1.5 2247 2795 15.9 45.0 1990 1951 1.5 2247 2788 15.1 42.5 xC;L 1954 2455 - 2904 3255 12.5 31 1965 2535 2.0 2504 3255 12.5 25.5 2525 2.0 2304 3255 S.5 25.3 1925 1987 2537 2.0 2004 3255 5.3 23.5 19a8 2590 2.3 2SO4 3255 4.2 21.4 1959 2744 2.0 2504 3255 2.2 19.3 2799 2.3 275a 3225 -1.3 15.3 1990 inis alterna te tecle gives tne variatles of t a ;1 e 2. 3 wi t s. a new j rate Of grottn. XA5E feels insse rates Cf q O* 07 are very possi:1y too high, certainly current trents woul: ; cica:e a 1cng perloc cf very small gro;th for the next cecace. . cts, accorcing te the tacle, KCE will still nave e 155 cvergenera:ing cacacity witnout .'C35 in 1993. In the craft statanent, s:cff B-42

recommends ut111 ties k eep "mi ni m um reserve margins at 15.1" (og 2-5). When peak demand was increasing 5%-74 each year, such a reserve was necessary; cut new with a leveling p eak , a reserve of 10%-12j should be sufficient. It is interesting to note on the alternate table, tOa in 1933, although KCPL uould be down to a 4.2j margin, KGE wculd still nave a 15.55 margin without dCGS. Since KCE could sell scme of its excess reserve to KCPL, if needed, both utilities would have en adecuate reserve. If, indeed,we cc see a leveling of f trend in ceman g cwth, NRC will be in a position to delay the c; ating license until 1955. This ecul: allow th e commision to see what cemand growth will turn out to oc for the next five years, anc the acalicants will still nave adecuate reserves. Since :onstruction costs are not included in this stucy, the increased c nstruc-tion costs associatec with dela y s in Orin;',Nn e pla n: On-line cannot be considered. Delaying tne applicant's license will Oe cost-free, will sa v e 0 +a. c sts ft:m 1904 to 1955, will leave th e utilities adequate reserves, and will allow th e commissi n to learn demanc trends f or an accitional five years.

2. ASSESS:.ENT OF PCTE.NTI AL RIS< ;F ACCIDEST Altnough ma ny stucies are cited to se: port the cont entien tnat electrical transmission towers only ra r ely imaele natks an eagles, only one stu:y is cited to determine the prc atility and risk cf a major muclear accicent. In regards :: the effect Of a class nine accide7t we Co have anotner study unien can e cit ec in a ttition t: 355. This is t2 AE; (ncs.,C) 5:: <-

haven re::: , ;asn-740. Th e f act tnat any :s;::ts a s use:

stu:y a relatively small pre:lem, wnile evaila le r e:::t s B-43

5 relating to the most serious possicle prcolem are ignorec is i a major . weakness in the craf t statement, uasn-740 fcund a ! worst case accicent coulc cause 45,200 ceatns, injure 120,000, i and cause 317 billion in property camage (1955 collars). Tn e t first draft of RSS ref uted these cosecuences and found One result of a class 9 accicent to ce much less. After criticism cf i R55 by tne American Physical Society, EPA, and oth ers, R55 reevaluated the potential worst case eff ects at 3,203 early deaths, 45,000 early injuries, and 51 4 billion procerty damage (USNRC Cash-1400 (NUREG 75/014) pg 107). Altnougn R55 is tne 2 cnly study citec, this important conclusion is net cirectly given in the craf t statement and referrec tc cnly incirectly in the graphs of procacility. 7his conclusion snculd ce in :ne na r ra tive cf th e final stat ement. R5S mccel reactor was :tice the size of tne 5 roc 4 haven study =ccel reacter, ye: R55 fcunc a j less camage due to a wcrst case accicent, if R55 is cc ce One ultimate authority on risk assessment, tne final stat emen: 4 J should accress the disparity oetween cash-1403 and wasn-743. R55 probacility estimation tecnnicues nave recsivec even r.cr e criticism than RS5 consecuence estimaticn. Every tecle anc l i 1 graph from p'g 5-50 througn pg 5-53 has a fcctnc;e cirecting One reader to section 5.9.4.5(7 ) f c "discussicns of uncertaintics in risk estimates". accever, enen One reacer ref erres to :na; ' section, he does not fine a critical ciscussion of RS5 estimation I t ecnnicue's shcrtccmings. I ns t ea d , a Lewis report fincing is given: "7h e metnocology , wnicn was an inportant acvance over earlier metnocciogies nat nec ceen appliec :o reacter risk, was sound." A mere tnorough ciscussion of R55 sncrtcomings I B--44

6 Can be f ound in the American Physical Society's Reviews of inocern Physics,vol 47, supplement #1, "Re; ort to the A?5 by the Study Group on L$R Safety". KASE reconmen s tnat this recor;, in totak be included in th e final sta t ement. Reliacility estimation tecnniques use: cy RSS were developed y A54 : comoa re the rellatility of two or more diferent sy st ems in relation to a problem. Th e " odds", or procacility o' :: ur-rence, give a go: measure of one system 5 acvantages in relation to a cifferent system. The odds do not give a good measure of a n individual syst e.T.'s p robacilit y to f ail over a perica of time. The technique was never me3nt te give suon information. In spite cf this, ue fine on page 5-54: "Tn e cecicent at inrce

                               ..lile Isla nd cc urrec in ma rch 1979 at a time when the aCCumu-lated experienes re:::: was accut 400 reactor-years.                       It is cf interes              to not e tnet   nis was ci:nin :he range of fre:;encies estimated oy tna R55 f : an acticen; of this severity."                       In
                                '.970,          C:.r.monwealtn Edison's 3rescen II :lant i n .. o r ri s , Illi noi s was cut o.' control f or tuo .icurs.                A stu:y :y th e Sierra Clu:

and t h e 'J ni e n of Concerned Scientis:s, " ? qlimi na r y Revieu Of tne AEC Rea:::: Safty Study", . 'o v . 1974, use: 555 es:imatin; t e:n-nicues t: find the crc ability of tne 3:escen accicent cc:urring. Th e result was t et the at:i:ent uni:n "a: ?.lreacy ha:;ene ma: 3 prc:::ility p reci: tion cf one in a t i l l i o n-:i-l l i o n . Cn page 5-42 sta f f states: "A :icents have else :::urre a: ner nuc l ea r reactor f acilities in the Unite: 5tates en: in c:.e

unt ri es . . . .,6 el ti n; cf reacter 'uel ::urrcc in 3; l ee s: sesen of tnese ec:icents, inclu:ing tne one in 1955 a; One Enr;:

rermi At mi: ?ouer Plant Unit 1." 7.hl is me; tne only severs B-45

7 accident in the nuclear industry's accumulated experience record. In January, 1951, the SL-1 reactor in Idano Falls went cut of control killing three workers, impaling one on tne ceiling with a control rod. In 1975 the drown's Gerry plent neer Decatur, Alabama suffered a serious fire. Altncugn the fuel rods were not damaged, the fact that tne fire laste seven hours, and th e repair bill wa s over 1150 million cer-tainly qualifies 3rcun's Ferry a s a serious accident. Incusancs of accidents occur each year, ranging in severityfrem relatively minor to the loss of thousands of gdlons of radicactive water, as happened et th e S.ont ic ell o , ..i nn. plant in Wovem er, 197'. 1 All tnese accidents :elie st:ff's : land asserti:n t et im! is en isointe: incicent that neatly fits into RSS prc acility estimation. A second p;culem uith staff's statement is that the 400 years of accumulate: reacter experien:e in: lades an Over-2 undance of ea rly plant Op eration. iu: lea r ::ver pla nt s , as with all cther incustrial ocerations, ocerate more e f fEci s n l y when new than when old. In e accumula t ed corx exp erienc e f' rom 500 years to 1000 years snould provide a more accurate litmus test of reactor reliacility. Another pro:lem is related to tnis one. Ini s is the prcolem of emorit t l em e nt , uni:n is caly neu comino to tne attention of the nuclear intustry, anc which is not adcressed directly in the cra f t statement. Em rittisment is metal fatique caused oy radiction exposure. Recently it has been reported tnet .1R0 has found 3 plants in 7 states witn reactor snells suf f ering witn varicus stages of sm:rittle-ment. It is also Oe:: ming more evident t,at this is a :asi: Orcolem i nn e r e nt tc ne fission crecess zni n will effect all B-46

, 6 I, nuclear power plants af ter a d'>ren or so years of operation. Obviously, emerittlement poses not coly a serious risk of ac-

!             cident, out else a foresnortening of reactor plant' life..

These serious considerations are not accressec in tne draf t s t a t e.n e n t , and their omission is a sericus sncr: coming. Jased 1 on the preceding discussion, KASE concludes thct the 555 cen-4 sequence modeling and estima tion techniques a re anreliaole and overly optimistic. Tne data summarized in ta le 5.9 is, therefore, based on unsupacrted assumptions, nence invalid. I If staff acheres to the use cf th e 635 figur Es, 4%5L rs:L aenes 4 another section be added to seriously ciccuss "un:cr:minties in risk estimates". KA3E recommends this secti:n Oe written

 !            by John Ocfman and/or Arthur Tamolin at apolicant's expense.

4

)

3. RADICLCOICAL I.h?ACT CF IUEL CYCLE CN EaVI5LainL.4T ine radiological impact of the uranium fuel cycle is a large and difficult preolem. Teole 5.11 (3. 3) snous th e guanti:y j of 3n-222 released to the environment as "?resently uncer 1

i reconsideration oy tne Commission". Rad n gas exp sure t: l' miners, people who live near ailling operations, and to pe:ple t who misuse mill tailings in construction of homes is a sericus 4 questich nct sufficiently accressed :y the draft statemen:. Tne expense and cracticality of kee:in; animals cut of ::n ac-l instec arees after n sericus accident or de:cmmissionin; is en-j c her question not resolvec in the s t a t e.n e n t . KASE will confine cur main criticism to the area Of nigh-level an: transurani: i i l uas:ss. Trem the draft s:ctement, appen ix 2, pg  :: " Tn e i 1 i B-47

9 Commission notes tnet hign-level anc transurani: castes are to j i I De buried et a Federal repcsitory, and that no release to tha ) environment is asscciated with such disposal." L:vicusly no: all the material removed from the reacter in the form cf spent fuel rods will be lowered into the as yet unknown Federal re-pository. The process of nuclear decay will mean tha t the material entering the Federal repository will ce less :,nn 100% of the material rencved froa the renctor. Th e r eal ;uestion is how much material unaccounted for (i..U F ) t h e r e wi ll O e . Of course there will be f actors otner tnan nu: lear cecay ::ntri-outing to th e n.UF p rc:lem. Tacle 5.' pg 5-15 ;ives  :..2 ra:- iological ef f ects of accicents in transporta ica as"small". How small will tne risk cf accident ce unen the Feaeral re;cs-I itory finally does come into being anc the overcrowcac tems-orary swimming pacis begin emptying incusancs of tens of spent 1 fuel rods into the traffic patterns cf America? Leaving asi:e the question of whether the Federal reacsitcry will successfully isolate high-level wastes f or the thousancs cf years necessary, the more serious question is how much of these vastes will :e lost on the way to the repository? To judge hoe effectively these wastes will ce manage , we need to review hcw they nave ceen managed in the cast. Plutonium release: curing a fire at the Rocky Flats Nuclear 'i'easons f acility in c.ay 1959 cas later f ounc in soil samoles taken in tne h.etroco'litan Jenver a rea. After having ceen r ep ea t ecly citec fcr allowing zerxers ;c tecone ex assively contaminated, the mest '.' alley,  :..Y. ..F 5 i reprocessing plant was closed in 1971. Hi;n-level wastes i.:.- B-48

10 properly ourie: ,on-sit e, a nd still th ere nou, have ccataminatec nearoy creeks, notecly the Cattarcugus. Tn e n'.a x e y f la t s - a r ea near f.iorehead, Xentucky ha s also contamina te nearcy streams cith high level wastes leached through the soil from ";ermanent" burial spots. It is estimated that the Hanford Storage Facility in Richland, Wash. nas leaked 430,000 gallons of high-level wastes over a perloc of 20 years.- Tne U.S. has seen pro ucing hign-level castes for nearly 40 yea rs. Gith'tne exception of those castes unich have already been " lost", that is rele: sed into the environment,none cf this high level caste is permanently > disposed of. dou mucn of tnis caste will never reacn a par-manent resting place? A 1030 a.U nuclear plant can ce expected to procuce 30-35 tons of spent fuel each year, 400 to 50] pounds of this wasta will be plutonium. If we assume tne most conservative, UCCS coulc p :cuce 33 tens cf zeste of whicn 400 pcunds t'culd be plutonium eac7 y ea r , sver tne Urse of its predicted 30 year lif e span, it_would croduce 900 tens of high-level fission procucts, witn 12,33] pcunas of plu;:niam. If 99) of this materiel actually reached the Tederal reposit:ry, 9 tens of waste, including 123 pcunes cf plutonium eculd me una : unte: for. If 99.9) cere ac:cunte: fc:, tnere coul still

e nearly a ten of caste uitn 12 pounds of':lutonium una : cute:

for. It is the opinicn of <ASE that a .13 1..T will se cificult if not impossicle for the nuclear innstry de main:ain. ' itn 72 =p erating plant s, a .1) ioCT of hign-level fissi0n p ::J::s culd mean nearly 73 tons of missin; material :ver a 33 year period. Fi na l l y , X A5E r ecom.nends tha t a fi na l environmental statement ce delayed until af ter the Teceral recesitory is in , coeration. - UY x.!e .,d.n . ,o B-49

XANSAS GAS AND ELECTRIC COA 1PANY r ee:va.cew m, O L E as as L aog37ga e4 a ** e s.cass t es.c.a a e March 15, 1982

                                                                                                                        '  ' D, Mr. Harold R. Denton, Director                                                  ,,

Office of Nuclear Reactor F- S U.S. Nuclear Regulatory Cc..nission s g. Washington, D.C. 20555 # , ;fi'.g ,g e* QgI'?A,9Y & ~108 ~ I KMLNRC 82-176 /C Re: Docket Nurloer S"'N 50-482 Subj: Wolf Creek Draft Environmental Statement  % ff Comments ,,,, g\

Dear Mr. Denten:

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

                                                                                   /o,s o ro f)      /'Q

a. s GLK :bb Attach cc: Mr. J.B. Hopkins (2)

Division of Project Management Office of Nuclear Reactor Regulatien i U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Mr. Thomas Vandel Resident NRC Inspector Box 311 Burlington, Kansas 66839 tgf i 8203220137 820315 Bh PDR ADOCK 05000482 D PDR 201 N. Market - Mchth. wtas - Mad Ac:ress: PC. Scx 208 ! Wrcetta, Kansas 67201 - Telechone: Area Coce (31612616451 B-50 l

OATH OF AFFIRMATICN STATE OF KANSAS )

                                              ) SS:

COUNTY OF SEDGWICK ) I, Glenn L. Koester, of lawful age, being duly sworn upon oath, do depose, state and affinn that I am Vice President - Nuclear of Kansas Gas and Electric Company, Wichita, Kansas, that I have signed the foregoing letter of transmittal, know the contente thereof, and that all statements contained therein are true. KANSAS GAS AND ELEC"'RIC COMPANY A': TEST : f . By ]f**-'. gda.n ',, (,:

                                                                          'Glenn L. Koester dW )                            Vice President - Nuclear W.E. Walker, Secretary STA'"E OF KANSAS       )

4 ) SS: COUNTY OF SEDGWICK ) BE IT REMEMBEFID that on this 15th day of March, 1982 , before me, Evelyn L. Fry, a Notary, personally appeared Glenn L. Koester, Vice President - Nuclear of Kansas Gas and Electric Company, Wichita, Kansas, who is personally known to me and who executed 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 IN WICIESS WHEFIOF, I have hereunto set my hand and affixed my seal the date and year above written. 1 I, L i

                                    \                                      fjsfx             .

h.

       'A k[f $
                                                                            ~

5 0 c.vely[U. Fry,!/tary

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            .. U         C  '

L.$ll

                             . .r,l Y"? - p _ py pp$nission expires on August                15, 1984.

{ 4 B-51

4 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" l (page vii); and " Reductions of riffle habitat during low-flow con-ditions would adversely affect pop-ulation of the small Neosho madtom" (page 5-15). The FES(CP) s tates 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-l ally, would have been below the con-l servation level. In this case, I

water is released downstream.only 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). 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-stream.from the John Redmond dam B-52

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. B-53

Comments on Wolf Creek Draft (cont'd) Section, Table Page or Ficure 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- i ship in WCGS, KEPCo's system relia- 1 i bility is largely dependent -upon the resources of.other utilities due to the integrated nature of the Cooper- I 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. l The Applicants are planning to use 66*Be H S [ER(OLS ) Section 3.6.2.1, page 3.3 0, 21 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 I impingement study will be submitted to the NRC by March 19, 1982. l l l _3 B-54

Comments on Wolf Creek Draft (cont'd) Section, Table Pace or Ficure 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 cbtained 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. Additior. ally, the Applicants have obtained water contract 76-2 for water from Jonn Redmond Reservoir storage (Kansas. Water Resources Board) which authorizes withdrawal of 120 cfs or as mutually 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 maximum daily rate. However, the amotint of water pumped is not to excaed 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 Cepper 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 this conclusion is the reference of 0.01 mg/l TRC which was stated to be unsafe for many aquatic organisms (U.S. EPA., 1976). B-55

l l 1 Comments on Wolf Creek Draft.(cont'd) f Section, Table Page or Figure Comment 4 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 { j criteria for intermittent exposure are i given by the reference). The value is also conservative since it is based i 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 preo mental program as'perational environ-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 ) t Section 3.6.3 and ER(OLS) RQ 291.5] which will be the predominant resi-4 dual in the circulating water. These-forms of chlorine have been shown to be less toxic than free chlorine i ! (Ward-1976, Heath-1977). 1 Additionally, it has been proven that fish can detect and cvoid-both sub-lethal and lethal chlorine con-i centrations, even at low tempera-4 tures (Cherry et al, 1979). Finally, the affected area of the cooling l lake has been conservatively esti-i 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. j REFERENCES 4 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 i-i i B-56

! - , . _ _ _ , - , . _ _ - _ _ - - _ _ _ - , - _ _ - . _ . . - _ . . . - _ . - _ . _ _ _ _ , , _ _ _ _ _ ~ , . , ,

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 chlorinaticn to fresh-influence of temperature water fish: 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 frcm 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. B-57

4 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 B-58 l l '

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THE P ENNSYLVANI A S TATE U NIVERSITY 104 DAVEY LABORATORY UNIVERSfTY PARK. PENNSYLVANIA 16802 College of Science ^"* C

• 83' Deparmat of hyscs 15 March 1982 5 .g,

                                                             @                       N EE          '

Director, Division of Licensing 6 '

                                                                                       ,g U.S. Nuclear Regulatory Commission                        idARI'91932> ;

Washington, D.C., 20555 "'EIN9?8f")3:s b/ 9

Dear Director:

c') / i 60 t Enclosed are my com:.ents on the Draft Environmental Statement related to operation of tre Wolf Creek Generating Station, Unit 1, I.TREG - 0676. Please note that the opinions and calculations here are my own and not necessarily those of the Pennsylvania State University. I hone that these comments are used in develoning the Final Environmental Statement. Fould you also please send me a copy of that Final EIS when it is available. Sincerely > _, L ng A a. % LAs

                                                          ?.i:1. A. Lochstet,Ph.D.

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8' I oe greWJ PDR D AN EQUAL OPPORTUNITY CNi\ ERSITY B-60

The Long Term Health Consequences and Environmental Impact of Postulated Accidents Wolf Creek No. 1 by William A. Lochstet,Ph.D. The Pennsylvania State University

• March 1982 The Nuclear Regulatory Commission (NRC) has attempted to evaluate the health consecuences of the operation of the

'1olf Creek Generating Station, Unit 1 in the Draft Environ = ental Statement, NUREG-0878 (Ref. 1). The health consecuences of the radon-222 released from the mill tailings and mires are evaluated for the first 1000 years in Appendix G ( Ref. 1). This evaluation states t'at the radon emissions increase with time ( Ref. 1, pace G-6). There is no suggestion that there is any reason to believe that these emissions will stop after 1000 years, or even to decrease. The fact is that these radon emissions are governed by the 80,000 year half life of thorium-230, the L.5 billion " ear half life of uranium-238, and the amount of material covering the tailings. The thorium situation has been adecuately discussed by Pohl ( Ref. 2,)in 1976. The imcace to the uranium-239 as a source of radon was recognized by the NRC in GESMO ( Ref. 3), uhich is one of the refrences of Appendix G of this draft report ( Ref. 1). This issue is also discussed in the Final Environmental Statement for the Suscuehanna plants ( Ref. L, Pages 3-33 to B-38). The result is that for a generic 1C00 I?le 01 ant operating at 8C% cacacity f a:'or as is used in Ref.1, the radon emissions

• The The calculations presented here do not necessarily reeresent the cosition of the Pennsylvania State University.

'y affiliation is 'given here for identification Ourposes only.

B-61 l

1:Tolf Creek - 1 f Marbh 1962 2 4 will result in 200,0C0 deaths. Thus the estimates of health effects in the Draft Statement ( Ref.1, p. G-8) are too low by a l factor of 100,000. This is due to the arbitrary, and eronious crocedure of stopping at the end of the first 1000 years. Rebaselining: The NRC has attempted to evaluate the impact. of " Class 9" j accidents which might occur at Wolf Creek - 1. Unfortunately, { the few pages of this report ( Ref. 1) devoted to this t6pic are l not adecuate to describe the calculation that was modified ! from that presented in the eight volumes of the Reactor Safety Study (RSS) '?ASHalh00 (Ref. 5). It should be noted that for severe accidents the assessment is carried out considering I the entire population vithin radii of 60 km ( 50 miles) and 563 km ( 350 miles) ( Ref. 1., Section 5.9.L.5 ). It is entirely aopropriate to use large radii. A radius ~of 800 km (500 miles) was used in a recent DEIS ( Ref. 6). 1.t larSer distances fron the release point, the exposure per eerson is less, but the number of pecole exposed increases. Thus, it was recogni::ed in the 1975 A S study ( Ref. 7) that the major health impact may be locatdd j at the larger distances from the reactcr site. The cresent study ( Ref.1) seems to be based on the RSS f (Ref. 5) and rebaselining to incorporate improvenents since the l publication of RS3. In its January 1979 state =ent of policy, j the Commission took the following actions: l I The peer Review ?rocess: The Commission agrees that the peer review process followed in publishing 'O.SH-lkCO.was  ; inadecuate a:ti that troper peer review is findamental to 1 making sound, technical decisions. The Commission will take whatever corrective action is necessary to assure that effective reer review is an integral' feature of the NRC's risk assessrent crogram. A .6L. l

t'olf Creek - 1 3 March 1982 Accident 'robabilities: The Commission accents the 3eview Groue Renort's conclusion that absolute values of risks cresented by ' ASH-lhCO should not be used uncritically either in the regulatory process or for nublic policy purposes and has taken and will continue to take steos to assure that any such use in the past will be corrected appropriately. In carticular, in light of the o.evicw Group conclusions on accident erobabilities, the Commission does not rggard as reliable the Reactor Safety Study's numerical estimate of the overall risk of reactor accident. ( Ref. 8, P.3) The second statement would creclude the use of the results from the RSS in this action. The first statement recuires a thorough eeer ' review nrocess for an" such study. It is sug ested here that t' e "rebaselining" Fas undergone less ceer review than theRSS of 1975. T'e nresent wor!: is too inconclete (Ref. 1) for any attempt at reer review. It would accear that the IlaC has at least two choices to realize its January 1979 policy. One choice is to publish a new version of the RSS. Another choice would be to publish an exranded version of the crecent report ( Ref. 1) to be as comerehensive as the RSS. This latter would be an enormous duplica tion . In either case, thorough ceer review would be needed, of the scale t'at the 1975 RSS was exposed to. B-63

Wolf Creek - 1 4 Earch 1982 References 1 Draft Environmental Statement related to the operation of Wolf Creek Generating Station Unit No,1 ; ITUREG - 0878, Draft, ITRC , January 1982. 2 R.O. Pohl, " Health Effects of Raden-222 from Uranium Mining", Search, 7 ( 5), 3L5 - 350 ( August 1976). 3 " Final Generic Environmental Statement on the Use of Recycled Plutonium in Mixed Oxide Fuel in Light "ater Cooled Reactors",

          !!UREG-CCO2, !!RC , ( Aus;ust 1976) 4    " Final Environmental Statement related to the operation of Suscuehanna Steam Electric Station Units 1 and 2", !!UREG - 056L
          !!RC , June 1981 5   " Reactor Safety Study",        WASH-lLOO, (!TUREG-75/014 ) , 1975 6   "Suncleme-          sraft Environmental Statement related to the coeration c: the Suscuehanna Steam Electric Station, Units 1 and 2", NUREG 0564, Staplement 2, NHC , (I: arch 1981) Draft.

7 "Recort to the American ohysical Society by the Study groun on lizht - water reactor safety", H.U. Lewis, et al., Reviews of Vodern Physics, 7ol L7, Suop. I:o.1, Summer 1975 8 "HRC Statement on Risk '.ssessment and the Reactor Safety Stucy Recort (" ASH-lLOO) In light of the Risk Assessment 2eview Group Renort ", NRC, January 18, 1979. s 4 m B-64;

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1007 Alabama Lawrence, KS 66044 March 10,1982 g N v

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                                                                     &          NPj . 07S Director, Division of Licensing                                    f, Nuclear Regulatory Commission                                      r-   a%

gg y % gg g , Washingten D.C. 20555 the

                                                                             %             /

Dear Director,

Division of Licensing, - @ I as writing in response to the Nuclear Regulatory Commission's invitation to interested persons to coc=ent on the Draft Environmental Statement related to the operation of Wolf Creek Generating Station, Unit No.l. After a very limited reading of the State =ent ! make the following observations and questions:

1) Is there any way to protect the water shed which supplies the drinking water for the City of Lawrence, Kansas from the consequences of a radiological emergency? With winds coming our way 3S% of the tire, will emissions from normal operating of the plant reach the Waharusa 7 alley which is 35 miles north of WccS?

2) In order to keep the radioactivity at a minimum in the water leaving the plant, thru trying to prevent denting and corrosion in the steam generating tubes by the quality of the water which enters them, is there provision for continious and frequent reporting on the purity of the water to the TRC?

3) On page 5-44 the safety evaluation of the site includes a review of potential external hazards. Have the activities at the Richards-Gebaur Air 2ase south of Kansas City, Missouri been included in this review?

4) Will not the costs per kilowatt hour be greater than forecast if the life of the plant is actually shorter than the predicted 30 years? 3ased on the experience of other nuclear generating stations it seems imprudent to enpect that any where near full capacity production will continue for 30 years. This would make the cost / benefit ratio quite different than presented in the JES.

5) Are the Emergency Preparedness plans tha- --a a' eady written and the State one which is in process workable? Will there be opportunity for public hearings on these emergency preparedness plans before they are accepted by the NRC? 'lill the plans be approved before the reactor is loaded?

In the case of the Coffey Ccunty plan, how can the sheriff's force of 7 office:s and 6 reserves who are volunteers possibly make the initial warning. within 15 minutes while still maintaining their workload within the County? How can la volunteer viremen be adequately trained to do the necessary monitoring of radioactive e :bstances uith :afety S203170C09 820310 n PCR ADCCR 050C0482 3 PDR pIi B-67

to themselves and still keep performing their necessary duties? It does seem like the costs of these added functions should 'at least be borne by the utility company, rather than by the County which had no choice in the matter. The equipment necessary to meet the NRC's ex-pectation of a prompt (45 minute) alert within the 10 mile ZPZ seems to be lacking when you know of the existing fixed sirens and the use of mobile sirens. This is an example of the gap between what is written in an emergency preparedness plan and what the actualities are. That gap will effect the environment.

6) In Appendix F, pg F-3 there is mention of evacuating people moving under the cloud and moving in the same direction as the cloud is moving.

Would it not make more sense to have the people move away from the path of the cloud in a perpendicular direction so as to escape fallout?

7) As for costs, why are not the costs incurred by rate payers included in the calculations of cost / benefit in the production of electricity?

8) I do not agree that the short-term destruction of"5) the atmosphere and water bodies used for disposal of heat and certain waste effluents to the extent that other beneficial uses are curtailed, and 6) land areas rendered unfit for other uses" (?ES-CP pg 10-8) is going to necessarily create long-term productivity. If one-quarter of our population already is at one time in their lives going to have cancer, increasing that proportion is not going to enchance long-term productivity and well-being.

9) The production of 12,000 cu ft of low-level waste every year at WCOS creates a problem for us for which there is no solution currently.

This is a problem that people hats been trying to solve for over 37 years. Granted this is a new ters nology, it still is not right to continue making more low-level radioactive wastes that rapidly when there is no way to safely contain it. The amount of low-level waste created at NCGS annually will be 30 times more than the whole rest of the State pro duces. Sten low-level radiation is detrimental to people's health. I think that Wolf Creek Generating Station should not go on line before there is a way to safely deal with the waste problem. This means both the low-level radioactive wastes zd the fuel rods after they have fissioned. Por neither is there a good way of managing the radioactivity over the many years that is necessary. (People 2do,000 years from now may not be able to read the signs that indicate the danger of radioactivity even if ve could find containers to hold it for a shorter period of ti=e).

10) The cost of decc==issioning is given in Table 6.1 a: 363 =illion in 1934 dollars. I understand that there is no way to really estimate hou =uch deco ==issioning will cost, and a reugh figure used =ight be 17$ of construction costs. If that is the case, then it would be esti-mat ed at clo ser to $200,000,000. Would the RRC staff assess this as a small cost? For only one paragraph to be .:ritten on deco ==issioning seems not to corresponi with the concept of the limited nu=ber of years that the generating station uill be of use in supplying an alternative c urce of electrielty.

B-68

l 11) " Radiation doses to .he public as a result of decoc=issioning activities should be very small and would primarily ec=e from the transportation of deco ==issioning waste to waste-burial grounds."pg 5-68. Besides that time of exposure of the public thru transportation of radio-active wast, there is also that of the annual transport of low-level wastes and spent fuel rods from the site. Since the health effects of radioactivity are cumulative, exposing the public thru the shipment and accidents while being shipped, is not to be taken lightly since it is a real cost to the individuals affected, and therefore should be included in your cost / benefit su==ary.

12) I'm glad that it is recogni:ed that conservation is making a difference in the rate of increase in the use of electricity. It raises again whether there is a need .for cuch a large nuclear plant.

13) The remaining 20% of construction costs does not see= to be include:i in the overall cost / benefit sun =ary an:1 might influence the decision as to whether or not to consider operating the plant.

As stated in the beginning of this letter, I have not read the DES completely, but I do raise many questions about the conclusion which the staff reaches in 6.4 3, page 6-4. Sincerelyfq;7) C? Anne Moore r B-69

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     ./.r. Jon Hopkins licensing Project Manager
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U.S. Muclear Regulatory Oct ission ' washington, DC ' ')2)/ ,7 ., l* ..* Sear Mr. Hopkins: I would like to comment On the Draft Environmental Statement of the ?lolf Creek Generating Station, Docket No. STN 50 455 published in January 1932. As a planner I am c;..cerned abcut the effects cf the nuclear station upon the the environment. Here are sene of my concerns: Secti:n 4.22 states that "There exist no trends thatvould signifi-cantly change the land-use composition.cf the area". 2his state-ment appears to be inaccurate. Firstly, nearly IC,CCC acres of land would be converted frc: agricultural to industrial land uses. Secondly, future land use of the area within a 5-mile radius of the nuclear station would be affected. Due to public concerns over the safety of nuclear power, very few persons are willing to con-This struct new dwellings or businesses near a nuclear power plant. means that development of new residential and connercial areas will be unlikely--thereby precip it ating a decline in the econcey and population. If anthing, =cre and =cre land will becc=e marginal agricultural land. Despite a statement in Section 5 9 3 3 of the Draft to the contrary, there is a potential for a negative radiological impact upon 5icta other than humans. The proposed Tallgrass Frairie :iaticnal Fark would lie only 30 statute =iles frc: the Wolf Creek Plant--well This national park proposed within the 70-mile evacuation zone. by Congressman 'llinn would protect the last major expanse of Tallgrass Prairie remaining in the United States. Significant releases of radicactive gases could result in considerable genetic and other damage to vegetation and wildlife in the park. 2he risk of losing this naticnal treasure is just too great. The thermal, chemical and possible radiological pollution of the 5000-acre cooling lake would make the lake inh 0 spital to both wildlife and people. The extreme temperature changes of the water and releases of chlorine and corrosive troducts would be very detrimental to aquatic and other life. 'In essence 5000 acres of Cob)- agricultural land would become useless to nan and other 3 Ota. 23

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Clark H. C0an cci een. Robert Dole Rep. larry ,iinn 9203090366 820303 Gov. John Carlin PDR ADOCK 05000482 D PDR B-70

1 1 To:Mr. Jon Hopkins-Profect Director Office of Nuclear Peacter Regulation U.S. Nuclear Eegulatory Cennissien Washingten D.C. 20555 March 14,1982 'l/ To When it may concern: Y As accncerned citizen of the state of Kansas I as fcrced to cctment on the prepcsed acticn of the issurance cf a operating license forthe Wolf Creek nuclear pcwer plant,as the Envircnnental Impact statenent.prpared by the tiaclear Regulatcry Ccenissicn suggests.In viewing the above centicned statenent,I was shocked at the number cf unanswered questions through out the bccklet. Int me clarify:insufficent and mis-leading responses and alot of double talk that lef t ne quite anery .I had expected frank and direct responsen-since this issue is ene cf suen sensitive and "pctentially dangericus" natter.

       'n reviewing the II3,I was mest ccncerned with the lack cf infor ation en the nea.lth effects en humans,as well as animals, aquatic life and envircnnental c en .anin s tien. Tnec e issues were cnly vaguly discussed and non-directive to f acts.2ere are no nedical persens involved with these re;cris no hcw cculd they be sufficient?! cppcse any talk cf issuring a c;erating license for Wolf Creek until qualified .;ersons,kncwledgable en nuclear radiaticn are involved with these rep:rts Mnd around Wolf Creek will te un-usalble for a very lcng tine, thus wr.at ever grews cr whatever eats that which gr ws will be affected-this is unat E
 ;eeple need knew. 2ese are cencerns that are directing cur future and I feel it is wholely worthy of direct intensive research(h'.ich hasnt occured yet),be-fere handing out the O.K for production to large ecmpanies with =eney hurg/

cfficials.Instead of talking =cney constantly I would like to see scme sensitive material up helding pecple first and prcfits last.

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i APPENDIX C. EXAMPLES OF SITE-SPECIFIC DOSE ASSESSMENT CALCULATIONS C-1

( 3 APPENDIX C. EXAMPLES OF SITE-SPECIFIC DOSE ASSESSMENT CALCULATIONS C.1 CALCULATIONAL APPROACH ' As mentioned in the text, the quantities of radioactive material that may be released annually from the Wolf Creek Generating Station are estimated on the basis of the description of the radwaste systems in the applicant's ER-OL and FSAR and by using the calculational model and parameters developed by the NRC staff (Ref. 1). These estimated effluent release values for normal operation, including anticipated operational occurrences along with the applicant's site and environmental data in the ER-OL and in subsequent answers to NRC staff questions are used in the calculation of radiation doses and dose commitments. l The models and considerations for environmental pathways that lead to estimates of radiation doses and dose commitments to individual members of the public j near the station and of cumulative doses and dose commitments to the entire population within an 80-km (50-mi) radius of the station as a result of station operations are discussed in detail in Regulatory Guide 1.109 (Ref. 2). Use of I these models with additional assumptions for environmental pathways that lead < to exposure to the general population outside the 80-km radius are described in Appendix D of this statement. f The calculations performed by the staff for the releases to the atmosphere and

,      hydrosphere provide total integrated dose commitments to the entire population within 80 km of the station based on the projected population distribution in l       the year 2000. The dose commitments represent the total dose that would be received over a 50 year period, following the intake of radioactivity for one year under the conditions existing 15 years after the station begins operation (i.e. , the mid point of station operation). For younger persons, changes in organ mass and metabolic parameters with age after the initial intake of radio-activity are accounted for.

i

2. Dose Commitments from Radioactive Effluent Releases The NRC staff's estimates of the expected gaseous and particulate releases (listed in Table C-1) along with the site meteorological considerations sum-marized in Table C-2) were used to estimate radiation doses and dose commit-ments for airborne effluents. Individual receptor locations and pathway locations considered for the maximally exposed individual in these calcula-tions are listed in Table C-3.

Annual average relative concentration (X/Q and relative deposition (D/Q) values were calculated using the straight-line Gaussian atmospheric disper-sion model described in Regulatory Guide 1.111, modified to reflect spatial and temporal variations in airflow. These modifications (to be included in Revision 9 to the FSAR) were based on a comparison performed by the applicant between the results of the straight-line model-with the results of a variable trajectory model for both mixed mode (i.e. , a mixture of ground-level and ! elevated releases) and ground-level releases for a one year period of record. C-2

l l Table C.1. Calculated Releases of Radioactive Materials in Gaseous Effluents from Wolf Creek Unit 1 (Ci/yr) Unit Stack Turbine Building Radwaste Building (Continuous Vent (Continuous Vent (Intermittent Nuclides Release) Release) Release) Kr-83m 3 a a Kr-85 33 a a Kr-85 5 a 254 Kr-87 8 a a Kr-88 48 a a Kr-89 a a a Xe-131m 13 a 3 Xe-133m 66 a a Xe-133 3500 a 1 Xe-135m a a a Xe-135 131 a a Xe-137 a a a Xe-138 2 a a Total Noble Gases 4100.00 Mn-54 0.02 b 0.00005 Fe-59 0.006 b 0.00002 Co-58 0.06 h 0.00007 Co-60 0.03 b 0.000003 Sr-89 0.001 b 0.0000006 Sr-90 0.0002 b 0.00005 Cs-134 0.02 b 0.00008 Cs-137 0.03 b Tota! Particulates 0.17 I-131 0.08 0.0002 a I-133 0.09 0.0003 a H-3 1000 -- -- C-14 8 -- -- a less than 1.0 Ci/yr per reactor for noble gases and carbon-14; less than 10 4 Ci/yr per reactor for iodine. Less than 1% of total for this nuclide. C-3

_ _ _ _ _ _ _ - - _ _ _ - - _ . - . _ _-. . . . , . . , . _ - - - -- _ - . - - - . - . -. . ~_ . . _- I j i i 1 4 i a Table C.2. Locations For Maximum Individual Dose Calculations and Atmospheric Dispersion Parameters Dispersion Parameters l X/Q (decayed-X/Q X/Q (decayed) depleted) D/Q

Location Source b

(m/s ) 3 3 (m/s ) (m/s3 ) (m 2) C 3.0 x 10 7 3.0 x 10 7 2.7 x 10 7 5.2 x 10 8 I Nearest site A 9.7 x 10 7 9.6 x 10 8 boundary B 1.1 x 10 6 1.1 x 10 6 7 (N, 1.1 miles) C 4.3 x 10 6 4.3 x 10 6 3.8 x 10 8 3.7 x 10 8 ' 2.4 x 10 7 2.4 x 10 7 2.1 x 10 7 3.6 x 10 8 Nearest residence A 6.7 x 10 7 6.3 x 10 8 and garden B 7.8 x 10 7 7.8 x 10 7 2.2 x 10 6 2.2 x 10 8 1.9 x 10 8 1.8 x 10 8 I (N, 1.4 miles) C 7.8 x 10 8 7.8 x 10 8 7.0 x 10 8 1.3 x 10 8 Nearest dairy A 2.0 x 10 8 cow 8 3.3 x 10 7 3.3 x 10 7 2.8 x 10 7 n 1.7 x 10 6 1.7 x 10 6 1.4 x 10 6 1.0 x 10 8 g (SE, 1.4 miles) C 2.5 x 10 7 2.5 x 10 7 2.3 x 10 7 6.5 x 10 8 Nearest meat A 8.7 x 10 7 8.7 x 10 7 7.7 x 10 7 9.3 x 10 8 animal B 2.6 x 10 6 3.2 x 10 8 (NNE, 0.8 mile) C 3.0 x 10 6 3.0 x 10 8 a The values presented in this table are corrected for radioactive decay and cloud depletion from deposi- , tion, where appropriate, in accordance with Regulatory Guide 1111, Rev.1, " Methods for Estimating Atmo-j spheric Transport a.nd Dispersion of Gaseous Effluents in Routine Releases from Light Water Reactors," July 1977. b Source A is the reactor building vent, mixed-mode continuous release; Source B is the turbine building vent, ground-level continuous release; Source C is the radwaste building vent, ground-level intermittent release (15 releases / year for 8 hours each). j c" Nearest" refers to that type of location where the highest radiation dose is expected to occur from all appropriate pathways. i l

   - _ _ _ _ _ - _ _ _ _ _ _ _ _                                         __            _ _ .           . _ _ _ _     . _ _ _      _ _ _ _ _ _         _                            =      -                          . _ _ _ _ _ _ _ _ _

l l Table C-3 Nearest pathway locations used for maximally exposed individual dose commitments for the Wolf Creek nuclear station Location sector Distance (mi) Nearest site boundary

• N 1.1

                                                                                                        )

Residence and garden ** N 1.4 Milk cow SE 1.4 Meat animal NNE 0.8

• Beta and gamma air doses, total body doses, and skin doses from noble gases are determined at the effluent-control boundaries in the sector where the maximum potential value is likely to occur.

  ** Dose pathways including inhalation of atmospheric radioactivity, exposure to deposited radionuclides, and submersion in gaseous radioactivity are evaluated at residences. This particular location includes doses from vegetable, meat, and milk consumption as well.

C-5

Releases through the Unit vent have been considered as mixed-mode using the criteria described in Regulatory Guide 1.111. All other releases, including those from the turbine and radwaste building, have been considered as ground-level with mixing in the turbulent wake of plant structures. Intermittent releases from the radwaste vent have been evaluated using the methodology des-cribed in NUREG-0324. A composit three year period of record (June 1, 1973 - May 31, 1975 and March 5,1979 - March 4,1980) of onsite meteorological data (to be included in Revision 9 to the FSAR) was used for this evaluation. Wind speed and wind direction data were based on measurements at the 10 m level, and atmospheric stability was defined by the vertical temperature gradient measured between the 10 m and 60 m levels. The changes to the X/Q and D/Q values resulting from the revisions to the modifications applied to the straight-line model and revisions to the meteoro-logical data base are small (generally less than 15%). However, because the original information was revised extensively, the atmospheric dispersion modeling has been updated accordingly for the FES. The NRC staff estimates of the expected liquid releases (listed in . Table C-4), along with the site hydrological considerations (summarized in Table C-5), were used to estimate radiation doses and dose commitments from liquid releases. (a) Radiation Dose Commitments to Individual Members of the Public As explained in the text, calculations are made for a hypothetical individual member of the public (that is, the maximally exposed individual) who would be expected to receive the highest radiation dose from all pathways that contribute. This method tends to overestimate the doses because assumptions are made that would be difficult for a real individual to fulfill. The estimated dose commitments to the individual who is subject to maximum exposure at selected offsite locations from airborne releases of radiciodine and particulates, and waterborne releases are listed in Tables C-6, C-7, and C-8. The maximum annual total body and skin dose to a hypothetical indi'tidual and the maximum beta and gamma air dose at the site boundary are presented in Tables C-6, C-7, and C-8. The maximally exposed individual is assumed to consume well above average quantities of the potentially affected foods and to spend more time at poten-

tially affected locations than the average person as indicated in Tables E-4 and E-5 of Revision 1 of Regulatory Guide 1.109.

(b) Cumulative Dose Commitments to the General Population Annual radiation dose commitments from airborne and waterborne radioactive releases from the Wolf Creek generating facility are estimated for two popula-tions in the year 2000: (1) all members of the general public within 80 km (50 miles) of the station (Table C-7) and (2) the entire U.S. population (Table C-9). Dose commitments beyond 80 km are based on the assumptions t C-6

l Table C.4. Calculated Release of Radioactive Materials in Liquid Effluents from Wolf Creek Nuclear Station Unit 1 a Nuclide Ci/yr per reactor Nuclide Ci/yr per reactor Corrosion and Activation Products Fission products (cont'd) Cr-51 0.00009 Te-129 0.00004 Mn-54 0.00012 I-130 0.00008 Fe-55 0.00009 Te-131m 0.00002 Fe-59 0.00005 I-131 0.078 Co-58 0.0012 Te-132 0.00049 Co-60 0.00098 I-132 0.0012 Zr-95 0.00014 I-133 0.023 Np-239 0.0002 Cs-134 0.018 I-135 0.004 Fission Products Cs-136 0.0055 Cs-137 0.015 Br-83 0.00002 Ba-137m 0.011 Rb-86 0.00004 Ba-140 0.00001 Sr-89 0.00002 La-140 0.00002 Mo-99 0.0015 Ce-144 0.00052 Tc-99m 0.0014 Ru-103 0.00002 g 110m. [00 Total (except H-3) 0.16 Te-127m 0.00001 H-3 390 Te-127 0.00002 Te-129m 0.00006

   'Nuclides whose release rates are less than 10 5 Ci/yr per reactor are not listed individually but are included in "all others."

Table C.S. Summary of Hydrologic Transport and Dispersign for Liquid Releases from the Wolf Creek Nuclear Station Transit Time Dilution Location (hours) Factor ALARA Calculations Discharge Point in Lake 0.1 1.0 City of Leroy 24.0 68.5 Population Dose Calculations Discharge point in Lake 0.1 1.0 City of Leroy 24.0 68.5

             ^See Regulatory Guide 1.113, " Estimating Aquatic Disper-sion of Ef fluents from Accidental and Routine Reactor Re-leases for the Purpose of Implementing Appendix I," April 1977.

C-7

l

                                                                                                                                                            -1 l

l J l } { Table C.6. Annual Dose Commitments to a Maximally Exposed Individual

;                                                   Near the Wolf Creek Generating Station Location                                    Pathway                                                Doses (mrem /yr per unit) j                                                                                                Noble Gases in Gaseous Effluents

} Total Body Skin Gamma Air Dose Beta Air Dose (mrad /yr per (mrad /yr per j unit) unit) l Nearestsige Direct radiation > boundary from plume 0.015 0.081 0.023 0.11 , (N, 1.1 mile) Iodine and Particulates in Gaseous Effluents D < Total Body Thyroid e Nearest site Ground deposition 0.19 (T) 0.19 (T and C) J boundary Inhalation 0.013 (T) 0.026 (T and C) (N, 1.1 mile) l l Nearest residence Ground deposition '0.12 (C) 0.12 (I) and garden Vegetable consumption 0.11 (C) NA ! (N, 1.4 mile) Meat consumption 0.01 (C) NA J Cow milk consumption 0.05 (C) 2.2 (I) j Inhalation 0.009 (C) 0.02 (I) i Nearest dairy Ground deposition 0.045 (C) 0.045 (I) cow Vegetable consumption 0.037 (C) NA (SE, 1.4 mile) Meat consumption 0.004 (C) NA I Cow milk consumption 0.02 (C) 0.78 (I) Inhalation 0.003 (C) 0.0051 (I) l l j Nearest meat Ground deposition 0.24 (A) 0.24.(C) 1 animal Meat consumption 0.015 (A) 0.03 (C) (NNE, 0.8 mile) Inhalation 0.011 (A) 0.02 (C) l l Liquid Effluents (Adults)b 4 Total Body Liver Discharge point Fish consumption 1. 6 2.2 (Into lake) Shoreline 0.004 0.004 City of Leroy Fish consumption 0.02 0.03 Drinking water 0.02 0.02 j Shoreline 0.00004 0.00004 a" Nearest" refers to that site boundary location where the highest radiation doses as a resul j of gaseous effluents have been estimated to occur. + b 00ses are for the age group and organ that results in the highest cumulative dose for the ! location: T= teen, C= child, I= infant. Calculations were made for these age groups and for the following organs: GI-tract, bone, liver, kidney, thyroid, lung, and skin. c" Nearest" refers to the location where the highest radiation dose to an individual from all applicable pathways has been estimated. l C-8

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Table C.7. Calculated Appendix I Dose Commitments to a Maximally Exposed Individual and to the Population from Operation of Wolf Creek Nuclear Station Annual Dose per Reactor Unit Individual Appendix I Calculated Design Objectives a Doses Liquid effluents Dose to total body from all pathways 3 mrem 1.6 mrem Dose to any organ from all pathways 10 mrem 2.2 mrem Noble gas effluents Gamma dose in air 10 mrad 0.023 mrad Beta dose in air 20 mrad 0.11 mrad Dose to total body of an individual 5 mrem 0.015 mrem Dose to skin of an individual 15 mrem 0.081 mrem c Radiciodines and particulates Dose to any organ from all pathways 15 mrem 2.4 mrem Population Within 80 km Total Body Thyroid d (person-rem) Natural-background radiation' 21,000 - Liquid effluents <0.12 <0.01 Noble gas effluents 0.02 0.02 Radiciodine and particulates 0.19 0.38 Design Objectives from Sections II.A, II.8, II.C, and II.D of Appendix I, 10 CFR Part 50 consider doses to maximally exposed individual and to popula-tion per reactor unit. bNumerical values in this column were obtained by summing appropriate values in Table C-6. Locations resulting in maximum doses are represented here. c Carbon-14 and tritium have been added to this category. Represents the organ that results in the highest cummulative dose to the population.

  "" Natural Radiation Exposure in the United States," U.S. Environmental Protection Agency, ORP-SID-72-1, June 1972; using the average background dose for Kansas of 112 mrem /yr, and year 2000 projected population of 184,400.

C-9

Table C.8. Calculated RM-50-2 Dose Commitments to a Maximally

 ,                   Exposed Individual from Operation of the Wolf Creek Generating Station
                                                            'nnual A      Dose per Site RM-50-2           Calculated Design Objectives b      Doses Liquid effluents Dose to total body or any organ from all pathways                                    5 mrem            2.2 mrem Activity release estimate, excluding tritium (Cl)                                    5                 0.16 Noble gas effluents Gamma dose in air                              10 mrad            0.023 mrad Beta dose in air                               20 mrad            0.11 mrad Dose to total body of an individual             5 mrem            0.02 mrem Dose to skin of an individual                  15 mrem            0.08 mrem Radioiodine and particulates c Dose to any organ from all pathways            15 mrem            2.4     mrem I-131 activity release (Ci)                     1                 0.08 1

a An optional method of demonstrating compliance with the cost-benefit Section (II.D) of Appendix I to 10 CFR Part 50. b Annex to Appendix I to 10 CFR Part 50. c Carbon-14 and tritium have been added to this category. l l l C-10

Table C.9. Annual Total-Body Population Dose Commitments, Year 2000 (per site) U.S. Population Dose Commitment, Category person-rem /yr Natural background radiation a 26,000,000" Wolf Creek Nuclear Station Unit 1 operation Plant workers 440 General public: b Liquid effluents 3 Gaseous effluents 39 Transportation of fuel and waste 7 a using the average U.S. background dose (100 mrem /yr) and year 2000 projected U.S. population from " Population Estimates and Projec-tions," Series II, U.S. Department of Comtr.erce, Bureau of the Census, Series P-25, No. 541, February 1975. b 80-km (50-mile) population dose. C-11

                                                                                                         \

discussed in Appendix 0. For perspective, annual background radiation doses ' , are given in the tables for both populations.

3. References t

U.S. Nuclear Regulatory Commission, " Calculation of Annual Doses to Man From Routine Releases of Reactor Effluents for the Purpose of Evaluating Compliance with 10 CFR Part 50, Appendix I," Regulatory Guide 1.109, Revision 1, October 1977. U.S. Nuclear Regulatory Commission, F.P. Cardile and R. R. Bellamy (editors),

    " Calculation of Radioactive Materials in Gaseous and Liquid Effluents from Boiling Water Reactors," NUREG-0016, Revision 1, January 1979.

U.S. Nuclear Regulatory Commission, " Calculation of Releases of Radioactive Materials in Gaseous and Liquid Effluents from Pressurized Water Reactors (PWR-GALE Code)," NUREG-0017, April 1976. U.S. Nuclear Regulatory Commission, " Methods for Estimating Atmospheric Transport and Dispersion of Gaseous Effluents in Routine Releases from Light-Water Reactors," i Regulatory Guide 1.111, Revision 1, 1977. I I 8 l; i i C-12

l l APPENDIX D. NEPA POPULATION-DOSE ASSESSMENT D-1

APPENDIX 0. NEPA POPULATION-DOSE ASSESSMENT Population-dose commitments are calculated for all individuals living within 80 km (50 mi) of Wolf Creek Generating Station employing the same models used for individual doses [see Regulatory Guide 1.109, Rev.1 (Ref.1)] for the purpose of meeting the "as low as reasonably achievable" (ALARA) requirements of 10 CFR Part 50, Appendix I (Ref. 2). In addition, dose commitments to the population residing beyond the 80-km region, associated with the export of

• food crops produced within the 80-km region and with the atmospheric and hydrospheric transport of the more mobile effluent species, such as noble gases, tritium, and carbon-14, are taken into consideration for the purpose of meeting the requirements of the National Environmental Policy Act of 1969 (NEPA). This appendix describes the methods used to make these NEPA population-dose estimates.

D.1 10 DINES AND PARTICULATES RELEASED TO THE ATMOSPHERE Effluent nuclides in this category deposit onto the ground as the effluent moves downwind; thus, the concentration of these nuclides remaining in the plume is continuously being reduced. Within 80 km (50 mi) of the facility, the deposition model in Regulatory Guide 1.111, Rev.1 (Ref. 3) is used in conjunction with the dose models in Regulatory Guide 1.109, Rev.1 (Ref.1). Site specific data concerning production and consumption of foods within 80 km of the reactor are used. For estimates of population doses beyond 80 km it is assumed that excess food not consumed within the 80-km distance will be consumed by the population beyond 80 km. It is further assumed that none, or very few, of the particulates released from the facility will be transported bayond the 80-km distance; thus, they will make no contribution to the population dose outside 80-km region, except by export of food crops. This assumption was tested and found to be reasonable for the Wolf Creek Generating Station. 0.2 NOBLE GASES, CARBON-14, AND TRITIUM RELEASED TO THE ATMOSPHERE For locations within 80 km (50 mi) of the reactor facility, exposures to these effluents are calculated with a constant mean wind-direction model according to the guidance provided in Regulatory Guide 1.111, Rev.1 (Ref. 3), and the dose models described in Regulatory Guide 1.109, Rev.1 (Ref.1). For estima-ting the dose commitment from these radionuclides to the U.S. population residing beyond the 80-km region, two dispersion regimes are considered. These are referred to as first pass dispersion regime and the world-wide dispersion regime. The model for the first pass-dispersion regime estimates the dose commitment to the population from the radioactive plume as it leaves the facility and drifts across the continental United States toward the north-eastern corner of the United States. The model for the world-wide-dispersion regime estimates the dose commitment to the U.S. population after the released radionuclides mix uniformly in the world's atmosphere or oceans. 0-2

0. 2.1 First-Pass Dispersion For estimating the dose commitment to the U.S. population residing beyond the 80-ka (50-mi) region due to the first pass of radioactive pollutants, it is assumed that the pollutants disperse in the lateral and vertical directions along the plume path. The direction of movement of the plume is assumed to be from the facility toward the northeastern corner of the United States. The extent of vertical dispersion is assumed to be lin.ited by the ground plane and tha stable atmospheric layer aloft, the height of which determines the mixing d:pth. The shape of such a plume geometry can be visualized as a right-cylindrical wedge whose height is equal to the mixing depth. Under the assump-tion of constant population density, the population dose associated with such a plume geometry is independent of the extent of lateral dispersion, and is only dependent upon the mixing depth and other nongeometrical related factors (R:f. 4). The mixing depth is estimated to be 1000 m (3300 f t), and a uniform p:pulation density of 62 people /km2 (24 people /mi2) is assumed along the plume path, with an average plume-transport velocity of 2 m/s (4.5 mph).

Th2 total-body population-dose commitment from the first pass of radioactive effluents is due principally to external exposure from gamma emitting noble gases, and to internal exposure from inhalation of air containing tritium and from ingestion of food containing carbon-14 and tritium. 0.2.2 World-Wide Dispersion . For estimating the dose commitment to the U.S. population af ter the first pass, world wide dispersion is assumed. Nondepositing radionuclides with half-lives greater than one year are considered. Noble gases and carbon-14 are assumed to mix uniformly in the world's atmosphere (3.8 x 1018 ma ), and radioactive decay is taken into consideration. The world-wide-dispersion modal estimates the activity of each nuclide at the end of a 15 year release period (midpoint of reactor life) and estimates the annual population-dose commitment at that time, taking into consideration radioactive decay and physical removal mechanisms (e.g. , C-14 is gradually removed to the world's oceans). The total-body population-dose commitment from the noble gases is due mainly to external exposure from gamma emitting nuclides, whereas from carbon-14 it is due mainly to internal exposure from ingestion of food contain-ing carbon-14. The population-dose commitment due to tritium releases is estimated in a cann:r similar to that for carbon-14, except that af ter the first pass, all tha tritium is assumed to be immediately distributed in the world's circulating etater volume (2.7 x 1016 m3 ), including the top 75 m (250 ft) of the seas and j oceans, as well as the rivers and atmospheric moisture. The concentration of I tritium in the world's circulating water is estimated at the time af ter 15  ! y:ars of releases have occurred, taking into consideration racioactive decay; l th population-dose commitment estimates are based on the incremental concen- i tration at that time. The total-body population-dose commitment from tritium l is due mainly to internal exposure from the consumption of food.

0. 3 LIQUID EFFLUENTS Population-dose commitments due to effluents in the receiving water within 80 km (50 mi) of the facility are calculated as described in Regulatory 0-3

      -   -       .        . - - _            -  __   ..     ._-      .     - - _ _  - .=

Guide 1.109 (Ref. 1). It is assumed that no depletion by sedimentation of the nuclides present in the receiving water occurs within 80 km. It is also assumed that aquatic biota concentrate radioactivity in the same manner as was assumed for the ALARA evaluation for the maximally exposed individual. However, food-consumption values appropriate for the average, rather than the maximum, individual are used. It is further assumed that all the sport and commercial fish and shellfish caught within the 80-km area are eaten by the U.S. population. Beyond 80 km, it is assumed that all the liquid effluent nuclides except tritium have deposited on the sediments so that they make no further contribu-tion to population exposures. The tritium is assumed to mix uniformly in the l world's circulating water volume and to result in an exposure to the U.S. population in the same manner as discussed for tritium in gaseous effluents. 1 1

References for Aopendix 0

!             1.  " Calculation of Annual Doses to Man from Routine Releases of Reactor

! Effluents for the Purpose of Evaluating Compliance with 10 CFR Part 50, Appendix I," Reg. Guide 1.109, Rev. 1, U.S. Nuclear Regulatory Commission,

 ,                October 1977.

i l 2. " Domestic Licensing of Production and Utilization Facilities," Title 10 Code of Federal Regulations, Part 50, January 1981.

3. " Methods for Estimating Atmospheric Transport and Dispersion of Gaseous Effluents in Routine Releases from Light-Water-Reactors," Regulatory Guide 1.111, Rev. 1, U.S. Nuclear Regulatory Commission, July 1977.

4. K.F. Eckerman et al., " Users Guide to GASPAR Code," NUREG-0597, U.S.

Nuclear Regulatory Commission, June 1980. t i l f I-4 l l l

                                                    ~

l D-4 l - . _. - - . _-- -

l i I f f APPENDIX E. REBASELINING OF THE RSS RESULTS FOR PWRS E-1

APPENDIX E. REBASELINING OF THE RSS RESULTS FOR PWRs The results of the Reactor Safety Study (RSS) have been updated. The update was done largely to incorporate results of research and development conducted after the October 1975 publication of the RSS and to provide a baseline against which the risk associated with various LWRs could be consistently compared. Primarily, the rebaselined RSS results (Ref. 1) reflect use of advanced modeling of the processes involved in meltdown accidents, i.e., the MARCH computer code modeling for transient and LOCA initiated sequences and the CORRAL code used for calculating magnitudes of release accompanying various accident sequences. These codes

• have led to a capability to predict the transient and small LOCA initiated sequences that is considerably advanced beyond what existed at the time the Reactor Safety Study was completed. The advanced accident process models (MARCH and CORRAL) produced some changes in our estimates of the release magnitudes from various accident sequences in WASH-1400. These changes pri-marily involved release magnitudes for the iodine, cesium and tellurium families of isotopes. In general, a decrease in the iodines was predicted for many of the dominant accident sequences while some increases in the release magnitudes for the cesium and tellurium isotopes were predicted.

Entailed in this rebaselining effort was the evaluation of individual dominant accident sequences as we understand them to evolve rather than the technique of grouping large numbers of accident sequences into encompassing, but syn-thetic, release categories as was done in WASH-1400. The rebaselining of the RSS also eliminated the " smoothing technique" that was criticized in the report by the Risk Assessment Review Group (sometimes known as the Lewis Report; NUREG/ CR-0400). In both of the RSS designs (PWR and BWR), the likelihood of an accident sequence leading to the occurrence of a steam explosica (a) in the reactor vessel was decreased. This was done to reflect both experimental and calculational indica-tions that such explosions are unlikely to occur in those sequences involving small size LOCAs and transients because of the high pressures and temperatures expected to exist within the reactor coolant system during these scenarios. Furthermore, if such an explosion were to occur, there are indications that it would be unlikely to produce as much energy and the massive missile-caused breach of containment as was postulated in WASH-1400. For rebaselining of the RSS PWR design, the release magnitudes for the risk dominating sequences, e.g., Event V, TMLB' 6, y and S2 C6 (described later) were explicitly calculated and used in the consequence modelling rather than being

*It should be noted that the MARCH code was used on a number of scenarios in connection with the TMI-2 recovery efforts and for post-TMI-2 investigations to explore possible alternative scenarios that TMI-2 could have experienced.

E-2

lumped into release categories as was done in WASH-1400. The rebaselining led to a small decrease in the predicted risk to an individual of early fatality or latent cancer fatality relative to the original RSS-PWR predictions. This result is believed to be largely attributable to the decreased likelihood ~ of occurrence for sequences involving severe steam explosions (a) that breached containment. (In WASH-1400, the sequences involving severe steam explosions (a) were artificially elevated in their risk significance (i.e. , made more likely) by use of the " smoothing technique.") In summary, the rebaselining of the RSS results led to small overall dif-ferences from the predictions in WASH-1400. It should be recognized that these small dif ferences due to the rebaselining efforts are likely to be far out-weighed by the uncertainties associated with such analyses. The accident sequences which are expected to dominate risk from the RSS-PWR design are described below. Accident sequences are designated by strings of identification characters in the same manner as in the RSS (See the table of these symbols, Table E.1). Each of the characters represents a failure in one or more of the important plant systems or features that ultimately would result in melting of the reactor core and a significant release of radioactive mate-rials from containment.* Event V (Interfacing System LOCA) During the Reactor Safety Study a potentially large risk contributor was identi-fied due to the configuration of the multiple check valve barriers used to sepa-rate the high pressure reactor coolant system from the low design pressure par-tions of the ECCS (i.e., the low pressure injection subsystem - LPIS). If these valve barriers were to fail in various modes, such as leak-rupture or rupture-rupture, and suddenly exposed the LPIS to high overpressures and dynamic load-ings, the RSS judged that a high probability of LPIS rupture would exist. Since the LPIS is largely located outside of containment, the Event V scenario would be a LOCA that bypassed containment and those mitigating features (e.g., sprays) within containment. The RSS assumed that if the rupture of LPIS did not entirely fail the LPIS makeup function (which would ultimately be needed to prevent core damage), the LOCA environment (flooding. steam) would. Predic-tions of the release magnitude and consequences associated with Event V have indicated that this scenario represents one of the largest risk contributors from the RSS-PWR design. The NRC has recognized this RSS finding, and has taken steps to reduce the probability of occurrence of Event V scenarios in both existing and future LWR designs by requiring periodic surveillance testing of the interfacing valves to assure that these valves are properly functioning as pressure boundary isolation barriers during plant operations. Accordingly, Event V predictions for the RSS-PWR are likely to be conservative relative to the design and operation of the Wolf Creek Unit 1 PWR. TMLB'-6, y This sequence essentially considers the loss and nonrestoration of all AC power sources available to the plant along with an independent failure of the steam RFo? additional information detail see Reactor Safety Study (WASH-1400), Aipendix V. E-3 l l

Table E.1. KEY TO PWR ACCIDENT SEQUENCE SYMBOLS A - Intermediate to large LOCA. B' - Failure to recover either onsite or offsite electric power within about 1 to 3 hours following an initiating transient which is a loss of offsite AC power. , C - Failure of the containment spray injection system. D - Failure of the emergency core cooling injection system. H - Failure of the emergency core cooling recirculation system. K - Failure of the reactor protection system. L - Failure of the secondary system steam relief valves and the auxiliary feedwater system. M - Failure of the secondary system steam relief valves and the power conversion system. Q - Failure of the primary system safety relief valves to reclose after opening. S - A small LOCA with an equivalent diameter of about 2 to 6 inches. t S2 - A small LOCA with an equivalent diameter of about 1/2 to 2 inches. T - Transient event. V - LPIS check valve failure. A a - Containment rupture due to a reactor vessel steam explosion. y - Containment failure due to hydrogen burning. s 6 - Containment failure due to overpressure. c - Containment vessel melt-through. - turbine driven auxiliary feedwater train which would be required to operate to remove shutdown heat from the reactor core. The transient event is initiated by loss of offsite AC power sources which would result in plant trip (scram) and the loss of the normal way that the plant removes heat from the reactor core (i.e. , via the power conversion system consisting of the turbine, con-denser, the condenser cooling system, and the main feedwater and condensate delivery system that supplies water to the steam generators). This initiating event would then demand operation of the standby onsite emergency AC power E-4 x

supplies (2 diesel generators) and the standby auxiliary feedwater system, 2 trains of which are electrically driven by either onsite or of f site AC power. With failure and nonrestoration of AC and the failure of the steam turbine driven auxiliary feedwater train to remove shutdown heat, the core would ulti-mately uncover and melt. If restoration of AC was not successful during (or following) melt, the containment heat removal and fission product mitigating systems would not be operational to prevent the ultimate overpressure (6, y) failure of containment and a rather large, energetic release of activity from the containment. Next to the Event V sequence, TMuR'6, y is predicted to dominate the overall accident risks in the RSS-PWR design. SeC-6 (PWR 3) In the RSS the 5 C-62 sequence was placed into PWR release Category 3 and it actually dominated all other sequences in Category 3 in terms of probability and release magnitudes. The rebaselining entailed explicit calculations of the consequences from2 5 C-6 and the results indicated that it was next in overall risk importance following Event V and TMLB'6, y. The S C-6 sequence included a rather complex series of dependencies and inter-actions that are believed to be somewhat unique to the containment systems (subatmospheric) employed in the RSS PWR design. In essence, the S2 C-6 sequence included a small loss-of-coolant accident occur-ring in a specific region of the plant (reactor vessel cavity); failure of the recirculating containment heat removal systems (CSRS-F) because of a dependence on water draining to the recirculation sump from the LOCA and a resulting dependence imposed on the quench spray injection system (CSIS-C) to provide water to the sump. The failure of the CSIS(C) resulted in eventual overpressure failure of containment (6) due to the loss of CSRS(F). Given the overpressure failure of containment the RSS assumed that the ECCS functions would be lost due either to the cavitation of ECCS pumps or from the rather severe mechanical loads that could result from the overpressure failure of containment. The core was then asstmed to aelt in a breached containment leading to a significant release of radioactive materials. Approximately 20% of the iodines and 20% of the alkali metals present in the core at the time of release would be released to the atmosphere. Most of the release would occur over a period of about L 5 hours. The release of radio-active material from containment would be caused by the sweeping action of-gases generated by the reaction of the molten fuel with concrete. Since these gases would be initially heated by contact with the melt, the rate of sensible energy release to the atmosphere would be moderately high. PWR 7 This is the same as the PWR release category #7 of the original RSS which was made up of several sequences such as $2 D-c (the dominant contributor to the risk in this category), S tD-c, S2 H-E. St H-c , AD-c , AH-c , TML c , and TKQ-c. All of these sequences involved a ontainment basemat melt-through as the con-tainment failure mode. With exception of TML c and TKQ-c, all involve the potential failure of the emergency core cooling system following occurrence of a LOCA with the containment ESFs cohtinuing to operate as designed until the E-5

basemat was penetrated. Containment sprays would operate to reduce the con-tainment temperature and pressure as well as the amount of airborne radio-activity. The containment barrier would retain its integrity until the molten core proceeded to melt through the concrete containment basemat. The radio-active materials would be released into the ground, with some leakage to the atmosphere occurring upward through the ground. Most of the release would l occur continuously over a period of about 10 hours. The release would include approximate?y 0.002% of the iodines and 0.001% of alkali metals present in the core at the time of release. Because leakage from containment to the atmo- l sphere would be low and gases escaping through the ground would be cooled by contact with the soil, the energy release rate would be very low. Reference 1: " Reactor Safety Study Methodology Applications Program," NUREG/CR 1659, Volume 1, April 1981. 1 ( l l 1 l l l l l l l E-6

1 APPENDIX F. CONSEQUENCE MODELING CONSIDERATIONS F-1

I i APPENDIX F. CONSEQUENCE MODELING CONSIDERATIONS

       " Evacuation," used in the context of offsite emergency response in the event of substantial amount of radioactivity release to the atmosphere in a reactor accident, denotes an early and expeditious movement of people to avoid exposure to the passing radioactive cloud and/or to acute ground contamination in the wake of the cloud passage. It should be distinguished from " relocation" which denotes a post accident response to reduce exposure from long term ground con-tamination. The Reactor Safety Study (RSS) (Ref. 1) consequence model contains provision for incorporating radiological consequence reduction benefits of public evacuation. The benefits of a properly planned and expeditiously carried out public evacuation would be well manifested in a reduction of acute health effects associated with early exposure; namely, in the number of cases of early fatality and acute radiation sickness which would require hospitalization. The evacuation model originally used in the RSS consequence model is described in WASH-1400 (Ref. 1) as well as in NUREG-0340 (Ref. 2). However, the evacuation model which has been used herein is a modified version (Ref. 3) of the RSS model and is, to a certain extent, site emergency planning oriented. The modified version is briefly outlined below:

4 The model utilizes a circular area with a specified radius (such as a 10-mile plume exposure pathway Emergency Planning Zone (EPZ)), with the reactor at the center. It is assumed that people living within portions of this area would-evacuate if an accident should occur involving imminent or actual release of significant quantities of radioactivity to the atmosphere. Significant atmospheric releases of radioactivity would in general be preceded by one or more hours of warning time (postulated as the time interval between the awareness of impending core melt and the beginning of the release of radio-activity from the containment building). For the purpose of calculation of radio-l logical exposure, the model assumes that all people who live in a fan-shaped area (fanning out from the reactor), within the circular zone with the down-wind direc-l tion as its median - i.e., those people who would potentially be under the radio-l active cloud that would develop following the release - would leave their residences

after lapse of a specified amount of delay time

• and then evacuate. The delay time is reckoned from the beginning of the warning time and is recognized as the sum of the time required by the reactor operators to notify the responsible authorities, time required by the authorities to interpret the data, decide to evacuate, and

) direct the people to evacuate, and time required for the people to mobilize and get underway. The model assumes that each evacuee would move radiall'; out in the downwind direc-l tion ** with an average effective speed * (obtained by di~iding the zone radius by t the average time taken to clear the zone af ter the delay time) over a fixed  ; distance

• from the evacuee's starting point. '

i Assumed to be of a constant value which would be the same for all evacuees. In the RSS consequence model, the radioactive cloud is assumed to travel outward only. F-2

This distance is selected to be 15 miles (which is 5 miles more than the 10-mile plume exposure pathway EPZ radius). After reaching the end of the travel distance the evacuee is assumed to receive no further radiation exposure. The model incorporates a finite length of the radioactive cloud in the downwind direction which would be determined by the product of the duration over which the atmospheric release would take place and the average windspeed during the release. It is assumcd that the front and the back of the cloud formed would move with an equal speed which would be the same as the prevailing windspeed; therefore, its length would remain constant at its initial value. At any time after the release, the concentration of radioactivity is assumed to be uniform over the length of the cloud. If the delay time were less than the warning time, then all evacuees would have a head start, i.e., the cloud would be trailing behind the evacuees initially. On the other hand, if the delay time were more than the warning time, then depending on initial locations of the evacuees there are possibilities that (a) an evacuee will still have a head start, or (b) the cloud would be already overhead when an evacuee starts to leave, or (c) an evacuee would be initially trailing behind the cloud. However, this initial picture of cloud people disposition would change as the evacuees travel depending on the relative speed and positions between the cloud and people. The cloud and an evacuee might overtake one another one or more number of times before the evacuee would reach his or her destination. In the model, the radial position of an evacuating person, either stationary or in transit, is compared to the front and the back of the cloud as a function of time to determine a realistic period of exposure to airborne radionuclides. The model calculates the time periods during which people are exposed to radionuclides on the ground while they are stationary and while they are evacuating. Because radionuclides would be deposited continually from the cloud as it passed a given location, a person who is under the cloud would be exposed to ground contamination less concentrated than if the cloud had completely passed. To account for this, at least in part, the revised model assumes that persons are: (a) exposed to the total ground contamination concentration which is calculated to exist after complete. passage of the cloud, af ter they are completely passed by the cloud; (b) exposed to one half the calculated concentration when anywhere under the cloud; and (c) not exposed when they are in front of the cloud. Different values of the shielding protection factors for exposures from airborne radioactivity and ground contamina-tion have been used. Results shown in Section 5.9.4.5 for accidents involving significant release of radioactivity to the atmosphere were based upon the assumption that all people within the 10-mile plume exposure pathway EPZ would evacuate as per the evacuation scenario described above. It is not expected that detailed inclusion of any special facilities near a specific plant site, where not all persons would be quickly evacuated, would significantly alter the conclusions. Sheltering in such cases can provide significant mitigation of consequences in most instances. For the delay time before evacuation, a value of one hour was used. The staff believes that such a value appropriately reflects the Commission's emergency planning requirements. The staff estimated the effective evacuation speed to be 12.5 miles per hour (5.6 meters per second) based upon the applicant's estimate of the time to clear the 10-mile zone. As an additional emergency measure for the Wolf Creek site, it was also assumed that all people beyond the evacuation distance who would be exposed to the contaminated ground would be relocated after passage of the plume. For these people outside of the evacuation zone and within 25 miles, a reasonable relocation time span of 4 hours has been F-3 l 1

assumed, during which each person is assumed to receive additional exposure to the ground contamination. Beyond the 25-mile distance the usual assumption of the RSS consequence model regarding the period of ground exposure was used- which is that if the calculated ground dose to the total marrow over a 7-day period would exceed 200 rem, then this high dose rate would be detected by actual field measurements following the plume passage, and people from those regions would then be relocated immediately. For this situation the model limits the period of ground dose calculation to 24 hours; otherwise, the period of ground exposure is limited to 7 days for calculation of early dose. Figure F.1 shows a oessimistic case for which no early evacuation is assumed and all persons are assumed to be exposed for the first 24 hours following an accident and are then relocated. The model has the same provision for calculation of the economic cost associated with implementation of evacuation as in the orginal RSS model. For this purpose, the model assumes that for atmospheric releases of durations three hours or less, all people living within a circular area of 5-mile radius centered at the reactor plus all people within a 45 angular sector within the plume expo-sure pathway EPZ and centered on the downwind direction will be evacuated and temporarily relocated. However, if the duration of release would exceed three hours, the cost of evacuation is based on the assumption that all people within the entire plume exposure pathway EPZ would be evacuated and temporarily relo-cated. For either of these situations, the cost of evacuation and relocation is assumed to be $125 (1980 dollar) per person which includes cost of food and temporary sheltering for a period of one week. References for Appendix F

1. " Reactor Safety Study," WASH-1400 (NUREG-75/014), October 1975.

2. " Overview of the Reactor Safety Study Consequences Model," NUREG-0340, October 1977.

3. "A Model of Public Evacuation for Atmospheric Radiological Releases," SAND 78-0092, June 1978.

F-4

PROBABILITY DISTRIBllTION OF EARLY FATALITIES id 16 10' 10f 16 t i i e e t i t t t t t t ie t 1 1 t t i t t t t o i n i ii I Q i i n t LEGEND E"

                      $,                                                    o = NO EVAC.--RELOCATION AFTER 1 DAY :                    _

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t i i e i i i o w o i i . . . i i i i si i i e i . > i . . ii i Id i i i i i i 1,6 16 10' 16 X=EARLY FATALITIES Fatality for no Evacuation Fig. F-1 Probability Distribution of Early NOTE: Please see Section 5.9.4.5(7) for oiscussion of uncertainties in risk estimates.

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APPENDIX G. IMPACTS OF THE URANIUM FUEL CYCLE G-1

APPENDIX G. IMPACTS OF THE URANIUM FUEL CYCLE Tne following assessment of the environmental impacts of the fuel cycle as related to the operation of the proposed project is based on the values given in Table S-3 (Sec. 5.10) and the staff's analysis of the radiological impact from radon releases. For the sake of consistency, the analysis of fuel-cycle impacts has been cast in terms of a model 1000-MWe light-water cooled reactor (LWR) operating at an annual capacity factor of 80%. In the following review and evaluation of the environmental impacts of the fuel cycle, the staff's analysis and conclusions would not be altered if the analysis were to be based on the net electrical power output of the Wolf Creek Generating Station. G.1 LAND USE The total annual land requirement for the fuel cycle supporting a model 1000-MWe LWR is about 46 ha (113 acres). About 5.3 ha (13 acres) are permanently committed, and 41 ha (100 acres) are temporarily committed. (A " temporary" land commitment is a commitment for the life of the specific fuel cycle plant; e.g. mill, enrichment plant, or succeeding plants. On abandonment or decom-missioning, such land can be used for any purpose. " Permanent" commitments represent land that may not be released for use after plant shutdown and/or decommissioning.) Of the 41 ha per year of temporarily committed land, 32 ha (79 acres) are undisturbed and 9 ha (22 acres) are disturbed. Considering common classes of land use in the United States," fuel-cycle land-use require-ments to support the model 1000-MWe LWR do not represent a significant impact. G.2 WATER USE The principal water-use requirement for the fuel cycle supporting a model 1000-MWe LWR is that required to remove waste heat from the power stations supplying electrical energy to the enrichment step of this cycle. total annual requirement of 43 x 106 m 3 (11.4 x 109 gal), about 42 x Of the 108 ma (11.1 x 109 gal) are required for this purpose, assuming that these plants use once-through cooling. Other water uses involve the discharge to air (e.g. , evaporation losses in process cooling) of about 0.6 x 106 m3 (160 x 106 gal) per year and water discharged to ground (e.g. , mine drainage) of about 0.5 x 108 m3 (130 x 108 gal) per year. On a thermal effluent basis, annual discharges from the nuclear fuel cycle are about 4% of those from the model 1000-MWe LWR using once-through cooling. The

• A coal-fired power plant of 1000-MWe capacity using strip mined coal requires the disturbance of about 81 ha (200 acres) per year for fuel alone.

G-2

I 3 consumptive water use of 0.6 x 108 m /yr is about 2% of that from the model 1000-MWe LWR using cooling towers. The maximum consumptive water use (assuming that all plants supplying electrical energy to the nuclear fuel cycle used cooling towers) would be about 6% of that of the model 1000-MWe LWR using cooling towers. Under this condition, thermal effluents would be negligible. The staff finds that these combinations of thermal loadings and water consump-tion are acceptable relative to the water use and thermal discharges uf the proposed project. G.3 FOSSIL-FUEL CONSUMPTION Electrical energy and process heat are required during various phases of the fuel-cycle process. The electrical energy is usually produced by the combus-tion of fossil fuel at conventional power plants. Electrical energy asso-ciated with the fuel cycle represents about 5% of the annual electrical power production of the model 1000-MWe LWR. Process heat is generated primarily by the combustion of natural gas. This gas consumption, if used to generate electricity, would be less than 0.3% of the electrical output from the model plant. The staff finds that the direct and indirect consumptions of electrical energy for fuel-cycle operations are small and acceptable relative to the net power production of the proposed project. G.4 CHEMICAL EFFLUENTS The quantities of chemical, gaseous, and particulate effluents associated with fuel-cycle processes are given in Table S-3. The principal species are sulfur oxides, nitrogen oxides, and particulates. Judging from data in a Council on Environmental Quality report (Ref.1), the staff finds that these emissions constitute an extremely small additional atmospheric loading in comparison with these emissions from the stationary fuel-combustion and transportation sectors in the United States; that is, about 0.02% of the annual national releases for each of these species. The staff believes that such small in-creases in releases of these pollutants are acceptable. Liquid chemical effluents produced in fuel-cycle processes are related to fuel-enrichment, -fabrication, and reprocessing operations and may be released to receiving waters. These effluents are usually present in dilute concentra-tions such that only small amounts of dilution water are required to reach levels of concentration that are within established standards. The flow of dilution water required for specific constituents is specified in Table S-3. Additionally, all liquid discharges into the navigable waters of the United States from plants associated with the fuel-cycle operations will be subject to requirements and limitations set forth in the NPDES permit. Tailings solutions and solids are generated during the milling process. Tnese solutions and solids are not released in quantities sufficient to have a significant impact on the environment. G.5 RADI0 ACTIVE EFFLUENTS Radioactive effluents estimated to be released to the environment from repro-cessing and waste-management activities and certain other phases of the fuel-cycle process are listed in Table S-3. Using these data, the staff has G-3

calculated for 1 year of operation of the model 1000-MWe LWR, the 100 year involuntary environmental dose commitment

• to the U.S. population from the LWR-supporting fuel cycle.

' It is estimated from these calculations that the overall involuntary total-body gaseous dose commitment to the U.S. population from the fuel cycle (excluding reactor releases and the dose commitment due to radon-222 and technetium-99) would be about 400 person rems for each year of operation of the model 1000-MWe LWR (reference reactor year, or RRY). Based on Table S-3 values, the addi-tional inveluntary total-body dose commitments to the U.S. population from radioactive liquid effluents (excluding technetium-99) due to all fuel-cycle operations other than reactor operation would be about 100 person-rems per year of operation. Thus, the estimated involuntary 100 year environmental dose commitment to the U.S. population from radioactive gaseous and liquid releases due to these portions of the fuel cycle is about 500 person-rems (whole body) per RRY. i At the present time, the radiological impacts associated with radon-222 and technetium-99 releases are not addressed in Table S-3. Principal radon releases i ' occur during mining and milling operations and as emissions from mill tailings; whereas principal technetium-99 releases occur from gaseous diffusion enrich-ment facilities. The staff has determined that radon-222 releases per RRY from these operations are as given in Table G.1. The staff has calculated population-dose commitments for these sources of radon-222 using the RABGAD computer code described in Volume 3 of NUREG-0002, Appendix A, Chapter IV, Section J (Ref. 2). The results of these calculations for mining and milling activities prior to tailings stabilization are given in Table G.2. Wher, added to the 500 person rems total-body dose commitment for the balance of the fuel cycle, the overall estimated total-body involuntary 100 year l environmental dose commitment to the U.S. population from the fuel cycle for the model 1000-MWe LWR is about 640 person-rems. Over this period of time, this dose is equivalent to 0.00002% of the natural-background total-body dose 1 of about 3 billion person-rems to the U.S. popu ation.** The staff has considered health effects associated with releases of radon-222, including both the short-term effects of mining, milling, and active tailings, and the potential long-term effects from unreclaimed open pit mines and sta-bilized tailings. The staff has assumed that after completion of active mining, underground mines will be sealed, returning releases of radon-222 to background levels. For purposes of providing an upper-bound impact assess-ment, the staff has assumed that open pit mines will be unreclaimed and has calculated that if all ore were produced from open pit mines, releases from them would be 110 Ci per RRY. However, because the distribution of uranium

            *The 100 year environmental dose commitment is the integrated population dose for 100 years; that is, it represents the sum of the annual population doses     i for a total of 100 years.                                                        l
          ** Based on an annual average natural-background individual dose commitment of 100 millirems and a stabilized U.S. population of 300 million.

I G-4

i Table G.I. Radon Releases from Mining and Milling Operations and Mill Tailings for Each Year of Operation of the Model 1000-MWe LWR

• Radon Quantity Source Released Mining a 4060 Ci b

Milling and tailings (during active milling) 780 Ci Inactive tailingsb (prior to stabilization) 350 Ci b Stabilized tailings (several hundred years) 1 to 10 Ci/yr Stabilized tailingsb (after several hundred years) 110 Ci/yr a Testimony of R. Wilde from: "In the Matter of Duke Power Company (Perkins Nuclear Station)," U.S. Nuclear Regulatory Commission, Occket No. 50-488, April 17, 1978. b Testimony of P. Magno from: "In the Matter of Duke Power Company (Perkins Nuclear Station)," U.S. Nuclear Regulatory Commission, Docket No. 50-488, April 17, 1978.

         *After three days of hearings before the Atomic Safety and Licensing Appeal Board (ASLAB) using the Perkins record in a " lead case" approach, the ASLAB issued a decision on May 13, 1981 (ALAB-640) on the radon-222 release source term for the Uranium Fuel Cycle. The decision, among other matters, produced new source term numbers based on the record developed at the hearings. These new numbers did not differ significantly from those in the Perkins record which are the values set forth in this Table.

Any health effects relative to radon-222 are still under consideration before the ASLAB. Since the source term numbers in ALAB-640 do not differ significantly from those in the Perkins record, the staff continues to conclude that "both the dose commitments and health effects of the uranium fuel cycle are insignificant when compared to dose commit-ments and potential health effects to the U. S. population raulting from all natural background sources.' G-5

Table G.2. Estimated 100-Year Environmental ' Dose Commitment for Each Year of Operation of the Model 1000-MWe LWR Dosage (person-rems) Radon-222 Radon Release Lung (bronchial Source (Ci) Total Body Bone epithelium) Mining 4100 110 2800 2300 Milling and active tailings 1100 29 750 620 Total 140 3600 2900 ore reserves available by conventional mining methods is 66% underground and 34% open pit (Ref. 3), the staff has further assumed that uranium to fuel LWRs will be produced by conventional mining methods in these proportions. This means that long-term releases from unreclaimed open pit mines will be 37 Ci/yr (0.332 x 110) per year per RRY. Based on these assumptions, the radon released from unreclaimed open pit mines over 100- and 1000 year periods would be about 3700 Ci and 37,000 Ci per RRY, respectively. The total dose commitments for a 100- to 1000 year period would be as shown in Table G.3. These commitments represent a worst-case situation in that no mitigating circumstances are assumed. However, state and Federal laws currently require reclamation of strip and open pit coal mines, and it is i very probable that similar reclamation will be required for open pit uranium mines. If so, long-term releases from such mines should approach background levels. l For long-term radon releases from stabilized tailings piles, the staff has assumed that the tailings would emit, per RRY,1 Ci/yr for 100 years,10 Ci/yr for the next 400 years, and 100 Ci/yr for periods beyond 500 years. With these assumptions, the cumulative radon-222 release from stabilized-tailings piles per RRY would be 100 Ci in 100 years, 4090 Ci in 500 years, and 53,800 Ci in 1000 years (Ref. 4). The total-body, bone, and bronchial-epithelium dose commitments for these periods are as shown in Table G.4. Using risk estimators of 135, 6.9, and 22 cancer deaths per million person-rems ' for total-body, bone, and lung exposures, respectively, the estimated risk of cancer mortality resulting from mining, milling, and active-tailings emissions of radon-222 is about 0.11 cancer fatality per RRY. When risk from radon-222 emissions from stabilized tailings over a 100 year release period is added, the estimated risk of cancer mortality over a 100 year period is unchanged. Similarly, a risk of about 1.2 cancer fatalities per RRY is estimated over a 1000 year release period. When potential radon releases from reclaimed and l G-6

Table G.3. Population-Dose Commitments from Unreclaimed l Open-Pit Mines for Each Year of Operation of the Model 1000-MWe LWR Population-Dose Commitments (person-rems) Time Radon-222 Period Release Lung (bronchial (yr) (Ci) Total Body Bone epithelium) 100 3,700 96 2,500 2,000 500 19,000 480 13,000 11,000 1,000 37,000 960 25,000 20,000 Table G.4. Population-Oose Commitments from Stabilized-Tailings Piles for Each Year of Operation of the Model 1000-MWe LWR Population-Dose Commitments (person-rems) Time Radon-222 Period Release Lung (bronchial (yr) (Ci) Total Body Bone epithelium) 100 100 2.6 68 56 500 4,090 110 2,800 2,300 1,000 53,800 1,400 37,000 30,000 G-7

unreclaimed open pit mines are included, the overall risks of radon-induced cancer fatalities per RRY range as follows: 0.11-0.19 fatality for a 100 year period, 0.13-0.57 fatality for a 500 year period, and 1.2 -2.0 fatalities for a 1000 year period. To illustrate: A single model 1000-MWe LWR operating at an 80% capacity factor for 30 years would be predicted to induce between 3.3 and 5.7 cancer fatalities in 100 years, 5.7 and 17 in 500 years, and 36 and 60 in 1000 years as a result of releases of radon-222. These doses and predicted health effects have been compared with those that can be expected from natural-background emissions of radon-222. Using data from the National Council on Radiation Protection (NCRP) (Ref. 5), the average radon-222 3 concentration in air in the contiguous United States is about 150 pCi/m , which the NCRP estimates will result in an annual dose to the bronchial epithelium of 450 millirems. For a stabilized future U.S. population of 300 million, this represents a total lung-dose commitment of 135 million person-rems per year. Using the same risk estimator of 22 lung cancer fatali-ties per million person-lung-rems used to predict cancer fatalities for the model 1000-MWe LWR, estimated lung-cancer fatalities alone from background radon-222 in the air can be calculated to be about 3000 per year, or 300,000 to 3,000,000 lung cancer deaths over periods of 100 and 1000 years, respect-ively. The staff is currently in the process of formulating a specific model for analyzing the potential impact and health effects from the release of technetium-99 during the fuel cycle. However, for the interim period until the model is completed, the staff has calculated that the potential 100 year environmental dose commitment to the U.S. population from the release of Tc-99 should not exceed 100 person-rems per RRY. These calculations are based on the gaseous and the hydrological pathway model systems described in Volume 3 , of NUREG-0002, Chapter IV, Section J, Appendix A (Ref. 2). When added to the 4 640 person-rem total-body dose commitment for the balance of the fuel cycle, 1 including radon-222, the overall estimated total-body involuntary 100 year environmental dose commitment to the U.S. population from the fuel cycle for the model 1000-MWe LWR is about 740 person rems. Over this period of time, this dose is equivalent to 0.00002% of the natural-background total-body dose of about 3 billion person-rems to the U.S. population.* l The staff also considered the potential health effects associated with this release of technetium-99. Using the modeling systems described in NUREG-0002, the major risks from Tc-99 are from exposure of the GI tract and kidney, although there is a small risk from total-body exposure. Using organ specific risk estimators, these individual organ risks can be converted to total-body risk equivalent doses. Then, by using the total-body risk estimator of 135 cancer deaths per million person-rems, the estimated risk of cancer mortality due to technetium-99 releases from the nuclear fuel cycle is about 0.01 cancer fatality per RRY over the subsequent 100 to 1000 years.

• Based on an annual average natural-background individual dose commitment of 100 millirems an a stabilized U.S. population of 300 million.

G-8

In addition to the radon- and technetium-related potential health effects from the fuel cycle, other nuclides produced in the cycle, such as carbon-14, will contribute to population exposures. It is estimated that an additional 0.08 to 0.12 cancer death may occur per RRY (assuming that no cure for or preven-tion of cancer is ever developed) over the next 100 to 1000 years, respectively, from exposures to these other nuclides. The latter exposures also can be compared with those from naturally occurring terrestrial and cosmic ray sources. These average about 100 millirems. Therefore, for a stable future population of 300 million persons, the whole-body dose commitment would be about 30 million person-rems per year, or 3 billion person-rems and 30 billion person-rems for periods of 100 and 1000 years, respectively. These natural-background dose commitments could produce about 400,000 and 4,000,000 cancer deaths during the same time periods. From the above analysis, the staff concludes that both the dose commitments and health effects of the uranium fuel cycle are insignificant when compared with dose commitments and potential health effects to the U.S. population resciting from all natural-background sources. G.6 RADI0 ACTIVE WASTES The quantities of buried radioactive waste material (low-level, hign-level, and transuranic wastes) associated with the uranium fuel cycle are specified in Table S-3. For low-level waste disposal at land-ourial facilities, the Commission notes in Table S-3 that there will be no significant radioactive releases to the environment. The Commission notes that high-level and transuranic wastes are to be buried at a Federal repository, and that no release to the environment is associated with such disposal. It is indicated in NUREG-0116 (Ref. 6), in which are provided background and context for the high-level and transuranic Table S-3 values establisned by the Commission, that these high-level and transuranic wastes will be buried and will not be released to the biosphere. No radiological environmental impact is expected from such disposal. G.7 OCCUPATIONAL DOSE The annual occupational dose attributable to all phases of the fuel cycle for the model 1000-MWe LWR is about 200 person rems. The staff concludes that this occupational dose will not have a significant environmental impact. G.8 TRANSPORTATION The transportation dose to workers and the public is specified in Table S-3. This dose is small and is not considered significant in comparison with the natural-background dose. G.9 FUEL CYCLE The staff's analysis of the uranium fuel cycle did not depend on the selected fuel cycle (no recycle or uranium only recycle), because the data provided in Table S-3 include maximum recycle option impact for each element of the fuel cycle. Thus, the staff's conclusions as to acceptability of the environmental impacts of the fuel cycle are not affected by the specific fuel cycle selected. G-9

t i-i 4 j References for Appendix G

1. "The Seventh Annual Report of the Council on Environmental Quality,"

Figures 11-27 and 11-28, pp. 238-239, Council on Environmental Quality, i September 1976. l 2. " Final Generic Environmental Statement on the Use of Recycle Plutonium in Mixed 0xide Fuel in Light-Water-Cooled Reactors," NUREG-0002, U.S. Nuclear [ Regulatory. Commission, August 1976.

3. " Statistical Data of the Uranium Industry," GJ0-100(8-78), U.S. Depart-ment of Energy, January 1, 1978.

l 4. Testimony of R. Gotchy from: "In the Matter of Duke Power Company (Perkins !- Nucl. ear Station)," U.S. Nuclear Regulatory Commission, Docket No._50-488, j filed April 17, 1978. l S. " Natural Background Radiation in the United States," Publication No. 45, j National Council on Radiation Protection and Measurements, November 1975. I

6. " Environmental Survey of the Reprocessing and Waste Management Portions i of the LWR Fuel Cycle," NUREG-0116 (Supplement 1 to WASH-1248), U.S.

Nuclear Regulatory, Commission, October.1976.

l 1 I i i l l . f I 1 i I i f G-10

l APPENDIX H. LETTER FROM THE U.S. DEPARTMENT OF THE INTERIOR, FISH AND WILDLIFE SERVICE, CONCERNING THREATENED AND ENDANGERED SPECIES IN THE VICINITY OF THE WOLF CREEK GENERATING STATION l H-1

H-2

 /b_                United States Department of the Interior FISH AND WII.DI.!FE SERVICE               c 2701 Rocketeek Parkway, smte I06 North Kansas City, Mimours 64116     Y-p l r C, j /g 814U14 3032 w               %t May 29, 1981 m

(4 C 46 p[ d p 9s t- m s .

                                                                          *v                l Mr. Glenn L. Koester
                                                                                     @      i Xansas Gas and Electric Company                                                    s      ;

P.O. Box 208 a t i Wichita, Kansas 67201

Dear Mr. Koester:

In response to a memorandum from the Office of Environmental Project Review, dated May 6.1981, we have reviewed the subject Revision No. I to Environmental Report (OLS) for Wolf Creek Generating Station, Coffey County, Kansas (ER 80/1586) and offer these coments for your consideration. General Coments: We do not have any problems with the revisions and other enanges made in this repo rt. We do call to your attention one item that should be dealt with here. This item, endangered species, is presented below under Specific Coments. I Soecific Coments: Section 7(c) of the Endangered Species Aqt, as amended, requires the Nuclear Regulatory Comission to obtain from the Fish and Wildlife Service infomation concerning any species, listed or proposed to be listed, which may be present in the area of the proposed action. Therefore, to facilitate compliance with Section 7(c) of the Act, we are furTiishing you the following list of species requested by Mr. B. J. Youngblood in his letter of April 30, 1981, which may be present in the concerned area of the Wolf Creek Generating Station, Coffey County, Kansas. Bald eagle (Haliaeetus leucocephalus) Peregrine falcon (Falco peregrinus) l The Nuclear Regulatory Comission has the responsibility to review the project and to evaluate the possible effects of construction on these Federally listed endangered species. The detemination to be made on the project is whether the proposed action "may affect or will not affect" listed threatened or endangered species. If it is detemined the preposal "may affect" an endangered species, either adversely or l beneficially, formal consultation must be initiated. However, if it is determined that the proposal "will not affect" an endangered species, no further action is necessary and the procedure is teminated. The Regional Director, U.S. Fish and Wildlife Service, has the prerogative to request your agency to formally consult on any project if deemed necessary. We would appreciate the opportunity to review the biological assessments you prepare for the two aforementioned Federally endangered species. We request that you contact Mr. Maurice Anderson, Area Endangered Species Coordinator, Pierre Area Office (FTS 782-5226 or Comercial: 605-224-8692) if further assistance is required in making a determination. COO 1 5

                                                                                        /

T'0602010Y A l l l l l

H-3 l 2 We suggest the Kansas Fish and Game Comission be contacted for State threatened or endangered species that may occur in the project area. Your inquiry should be directed to Mr. Marvin Schwilling, 832 East 6th, Emporia, Kansas 66801 or telepnone 316-342-0658. Thank you for your interest and cooperation in conserving endangered species. Feel free to contact Mr. Anderson or tnis office for further assistance if deemed necessary. Sincerely, fg .~ id Richard R. Raines Kansas Field Supervisor Ecological Services cc: Area Manager, Pierre, SD (ENV),(SE),(RW) Kansas Fish and Game Commission Emooria, KS Office of Environmental Project Review Washington, DC pdticlear Regulatory Comission Washington, DC PWS/0EC, Washington, DC Attn: Noreen Clough

l l l l APPENDIX I. HISTORIC AND ARCHE 0 LOGICAL SITES Page Item I-2 Letter from A.H. Rohn, Chairman, Anthropology Depart-ment, Wichita State University, to Tom Witty, State Archaeologist, Kansas State Historical Society, dated September 17, 1975. I-3 Letter from A.H. Rohn, Professor, Wichita State University, to Nyle Miller, State Historic Preserva-tion Officer, Kansas State Historical Society, dated June 11, 1976. 1-4 Letter from Joseph W. Snell, State Historic Preserva-tion Officer, Kansas State Historical Society, to B.J. Youngblood, Chief, Licensing Branch No. 1, U.S. Nuclear Regulatory Commission, dated June 3, 1981. I-l

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This is to '.nfer: ycu *aat we have : mpletec all Of t .e fial: verk on site 1107519 en Lent, freek in Coffey Ocunty, Xansss, a: 'sitiga*ien of adverse effects caused by the pr: posed const:;: ita of an ac:ssa rail-wa7 to the future '4cif Or:ek generating stati:n. *_aterate g ar.alysis is alcest :c= .'eted ar.d the re;crt is new in preparati:n.

            ! see n need t                 nduct any further fie'd               . Crk at this site.

Sincerely, A. M. ?.0MN, ?r:fessor

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June 3,1981 B. J. Youngblood, Chief Licensing Branch Nunter 1 Division of Licensing j U. S. Nuclear Regulatory Comission j l Washington, D. C. 20555 Pe: Wolf Creek Unit Nt.mcer 1 Kansas Cear Mr. Youngblood: I I The c eration of the Wolf Creek nuclear generating plant located in the . vicinity of Burlington, Kansas will not affect Kansas' cultural rescurces. Mitigation of any adverse effects, as defined in 26 C.F.R. 800, to archeological i resour:es at the site and railrcad spur has been ccepleted. ~he transmission , line routes have been plannned to be routed arcund archeolegical sites ' encountered in their c:rriders. No historic sites er buildings will te af'ected by the c rstruction or ::eration. This office has no cbjection to granting the operating license. { I '!ery truly ycurs, , Joseph W. Snell State Historic Preservaticn Cfficer i I i l

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oRu 335 f,R, U S NUCLE AR REGULATOW COMMISSION BIBLIOGRAPHIC DATA SHEET ' ' 4 TI TLE AND SUBTITLE LAdd Volume No, d wproonste1 2- (Leave blek) FI:lAL E:lVIRD:!'!EUTAL STATEMEllT RELATED TO Tl!E OPERATIO!! 0F WOLF CREEK GE!!ERATI:lti STATI0'!, U:!IT *!0.1 3. RECIPIENT'S ACCESSION NO. 7 AUTHOH(Si

5. DATE REPORT COMPLE TED M ON TH l YEAR JU"E 10"2 9 PE RF ORMING ORGANIZA TION NAME AND MAILING ADDRESS (Include les Codel DATE REPORT ISSUED U.S. Nuclear Regulatory Conrnission " "'" l**^"

Office of Nuclear Reactor Regulation l"'"-

                                                                                                                                                '  9 2 Washington, DC 20555                                                                   8  * * "'"*'

8. (Leave N m kl 12 SPONSOHING ORGANIZATION NAME AND MAILING ADDRESS (include ten Codel 10 PROJECT / TASK! WORK UNIT NO SA'1E as 9 above

11. CONTRACT NO 13 TYPE OF REPORT PE RIOD COVE RE D (loclustre dates /

TECH:!ICAL JANUARY 1932 - JUIE 1902 15 SUPPL EMEN T ARY NOTES 14 (Leave orm&f 9(if"'_[T n STt! Gn _ /' g 2

16. ABSTR ACT (200 words or less)

The information in this Final Environmental Statement is the second assessnent of the environmental inpact associated with the construction and operation of the Wolf Creek

    'ienerating Station, Unit Tio.1, located in Coffey County, Kansas. The Draft Environnental Statenent was issued in January 19^>2. The first assessnent was the Final Environmental Statenent related to construction issue 1 in October 1975 prior to issuance of the '.lolf Creek Construction Permit. The present assessment is the result of the :lRC staff's review of the activities associateJ with the proposeJ operation of the plant, and includes the staff response to connents on the Draf t Environnental Statenent.

17 KE Y WORDS AND DOCUMENT ANALYSIS 17a DESCRIPTOR3 17n IDE NTIFIE RS OPE N ENDE D TE RMS 18 AV AILABILITY ST ATE MENT 19 S R ASS / s **oorri 21 NO OF P AGE S U;lLIMITED 20 SE Cu Ri r y Ct ass t r .s o,,, 22 rR.ct U"CLASSIr:rg s N RC F ORM 335 i 7 7 7 6 U.S. UrvElt.9BT TH INil sG OFF r t In 2- h l.29 7. 2205

UZlTED STATES n;sr ctass r. 4,i NUCLEAR CE*ULATORY COMMissgog PO$11GE & sil5 Pia 0 bi41C WASHINGTON, D.C. 20565 #a$M Q C Ps aun =. 3n OFFsciAL sustNEss PENAL 1Y FOR Pasynyg ygg_ g3nn 1 AN 120555078877 US NRC BP y C U ATIONS MGT [ pOR NUREG COPY 20555 DC LA 212 W A.SH I NG T ON l l

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