ML20054L779
| ML20054L779 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 07/02/1982 |
| From: | Devincentis J PUBLIC SERVICE CO. OF NEW HAMPSHIRE |
| To: | Office of Nuclear Reactor Regulation |
| References | |
| RTR-NUREG-0895, RTR-NUREG-895 NUDOCS 8207080472 | |
| Download: ML20054L779 (7) | |
Text
PUBLIC SERVICE SEABROOK STATION Engineering Office:
Companyof New Hamph 1671 Worcester Road Framinoham, Massachusetts 01701 (617) - 872 - 8100 July 2, 1982 SBN-287 T.F. B 7.2.3 United States Nuclear Regulatory Commission Washing ton, D. C. 20555 Attention:
Director, Division of Licensing
References:
(a) Construction Permit CPPR-135 and CPPR-136, Docket Nos. 50-443 and 50-444 (b) USNRC Letter, dated May 14, 1982, " Issuance of Draft Environmental Statement - Seabrook Station, Units 1 and 2, F. J. Miraglia to W. C. Tallman
Subject:
Comments on Draft Environmental Statement Related to the Operation of Seabrook Station, Units 1 and 2 (NUREG-0895)
Dear Sir:
Attached are the Applicant's comments on the USNRC's Seabrook Station Draft Environmental Statement (Reference (b)].
Very truly yours, I
J 4+ &
J. DeVincentis Project Manager Attachment MO 8207080472 820702 PDR ADOCK 05000443 D
APPLICANT'S COMPENTS ON USNRC DFAFT ENVIRONMENTAL STATEMENT RELATED TO THE OPERATION OF SEAER00K STATION, UNITS 1 AND 2 NUREG-0895 The Applicant generally considers the Draft Environmental Statement (DES) to be a realistic assessment of the anticipated effects of operation of Seabrook Station, Units 1 and 2.
Based upon our review of the DES, we offer the following comments:
Summary and Conclusions, Jtem 2, Paragraph 2 Correct sentence to read, "The gross electrical output for each unit will be 1198 MWe."
Table of Contents, Appendices, Appendix I, Page xil Correct to read, "40 CFR 423, Appendix A" Sect ion 1.2 Administrative History, Page 1-1, Paragraph 3 As of April 1,1982, Unit 2 was approximately 12% complete.
I Section 4.1, Resume, Page 4-1, Paragraph 2 The statement that continuous low level chlorination has replaced thermal
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backflushing of the cooling system may be misleading. It would be more appropriate to say that thermal backflushing may be used to supplement continuous low level chlorination.
If it is determined that chlorination is not completely ef fective in the control of fouling of the intake tunnel, backflushing will be utilized to provide additional fouling control. Also, even if chlorination is completely ef fective, backflushing would be conducted infrequently for the purpose of operator training and system maintenance.
It is unlikely, however, that thermal backflushing and chlorination will be utilized concurrently.
l Section 4.1, Resume, Page 4-1, Paragrat h 3 l
The historic site mentioned is misspelled; it is the Governor Meshech Weare House. Also, to avoid any misunderstanding concerning the activity i
completed at the "three potential sites," it would be more informative to state that they have been investigated by trained archeologists and some artifacts were recovered. Applicant is concerned that the term
" excavated" might lead one to believe that this was done not by archeologists but by bulldozer and power shovel.
l Section 4.2, Figure 4.1, Site Layout, Page 4-2 The item number 36, meteorological tower is misspelled. This error also appears in Page 5-7, Figure 5.1.
I Section 4.2.2, Water Use, Page 4-3, Las t Paragraph of Section Information source is from response to RAI 291.21.
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' Ta ble 4.1, Plan t Wa t e r Use, Page 4-4 Correct footnote Condition B to read, "one unit full load, one unit startup."
Table 4.2, Intake System Data, Page 4-5 The delta-T should be 39 F and should be further qualified as a daily average, not an f ostantaneous maximum. The delta-T provided in the response to ER-OLS RAI 291.9 should be 390F. This change will be incorporated in the next revision of the ER-OLS.
Correct footnote spelling of multiply.
Figure 4.2, Plant Water Use Diagram, Page 4-6 Eliminate horizontal line between termination of Flow Paths 13A and 15.
Flow Path 15, system flushing during construction, is routed to the settling basin for discharge, not the Gulf of Maine.
Section 4.2.5, Non-Radioactive Waste Treatment System, Page 4-9 With regard to the statement, "all station wastewaters, except treated sanitary wastes and non-radioactive floor drainage and storm water runoff, will be routed to the station discharge tunnels for discharge offshore" - for purpose of clarificatior., it should be pointed out that there are three vaults that collect non-radioactive floor drainage.
Vaults #1 and #2 are ultimately routed to the discharge tunnel. However, Vault #3, af ter oil separation, goes into the settling basin and henceforth is discharged into the Brown's River, an NPDES compliance point.
Floor drains from the diesel generator building and the fire j
pumphouse go into Vault #3.
Table 4.3, Chemicals Added to Discharge, Page 4-10 i
Table 4.3 is the same as Table 3.6 in the 1974 Seabrook Station FES-CP.
As a result of the planned use of continuous low level chlorination as the method to control biofouling, values presented in Table 4.3 for chlorine addition should be updated as follows. The yearly discharge of 6
chlorine (C1 ) is increased to about 5.5 x 10 pounds. The two 2
categories of free residual and chlorine reaction products with 0.25 ppm and 1.75 ppm effluent concentrations, respectively, are replaced by the single category of total residual oxidant with a maximum estimated effluent concentration of 0.2 ppm.
Figure 4.6, Proposed Transmission Lines, Page 4-14 Termination of Seabrook - Tewksbury line shown on figure should indicate "to Tewksbury" since the figure portrays only the portion of the line in New Hampshire.
Sectiun 4.2.5, Non-Radioactive Waste Treatment Systems, Page 4-11, Paragraph 1 1
Figure 4.5 does not show water temperatures.
' Section 4.2.5, Non-Radioactive Waste Treatment Systems, Page 4-11, Paragraph 3 The control of slime buildup in station condensers and heat exchangers is anticipated to be a recurring need throughout the year, and may require continuous year-round chlorine application to these systems.
Figure 4.5, Block Diagram of Chlorination of Cooling Water System, Page 4-12 Flow to the service water pumphouse originates from the intake transition structure and not the pumphouse. Figure 291.19-1 from Applicant's response to RAI 191.10 will likewise be modified in the next revision to the Seabrook Station ER-OLS.
Figure 4.7, Physiographic Felationship of Seabrook Site to the Hampton Harbor Estuary, Page 4-18 The highway designation shown as State Highway 86 is incorrect. This is State Highway 286.
Section 4.3.2.1.1, Surface Water, Page 4-19, Paragraph 5 Applicant recommends the following changes to the paragraph beginning with " Water temperatures show...":
Insert the word "also" between the word " data" and "show" in the sixth line; replace the comma af ter the word " day" in the seventh line with a period; delete the remainder of the paragraph and insert "The largest variations occur in the summer months, with smaller changes during the winter months."
Applicant feels this change better describes the coastal temperature regime.
It does not, like the original statement, highlight the Hampton Harbor estuary, which only contributes a portion to the coastal tidal variability.
,Section 4.3.3.1, Terrestrial Resources, Page 4-21 S pa r t i na, the genus name of the local salt marsh grass, is misspelled.
Section 4.3.3.2, Aquatic Resources, Page 4-23, Paragraph 3 Same comment previously given for Section 4.1, Resume, Paragraph 2, Page 4-1.
Table 4.5, Estimated Annual Recreational Harvest of Soft Shell Clams...,
Page 4-25 Footnote 2, information source f rom RAI Table 291.2-2 Section 4.3.5.2, Aquatic, Page 4-29 Piscataqua River has been misspelled.
Section 4.3.6, Historic and Archeological Sites, Page 4-29 Meshech has been misspelled.
i' Section 4.3.7.1, Permanent Population, Page 4-30, Paragraph 1 The staff indicates that they use the "...most recent projections (population) by the State of New Hampshire...." This should be given a specific reference so that others can secure the same information if desired.
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Section 4.3.7.2, Transient Population, Page 4-30, Paragraph 1 The staff updated and revised Applicant's information on transient population in part by the "... adoption of different assumption."
However, they do not state what different assumptions were made.
Applicant suggests a listing of all assumptions made by the NRC in assessing the transient population be included.
l Table 4.12, Largest Industrial Employers..., Page 4-35 l
Change USM, Bailey, Div. to Emhart, Eaily Div.
Same as Page 5-43, Paragraph 2.
Section 4.4, References, Page 4-37 To facilitate 1ccation of a specific reference, they should be organized alphabetically. Also, the Normandeau Associates, Inc. Summary Document should be placed with the other NAI reports. Correct the reference shown as Savage and Goldbert (1976) as follows:
f Savage, N. B. and R. Goldberg.
" Investigation of the practical i
means of distinguishing }ggi arenaria and Hiatella sp. larvae in plankton samples."
i Section 5.1, Resume, Page 5-1, Paragraph 3 In the interest of avoiding unnecessary and duplicative regulatory l
requirements, Applicant infers that the Environmental Protection Plan (EPP) conditions (3) and (4) of this paragraph requires reporting only to the cognizant regulatory authority (e.g., USEPA for NPDES-related l-matters).
Section 5.3.1, Water Quality, Page 5-3, Paragraph 1 It should be clarified that the 88-minute transit time from the intakes to the intake transition structure is based on one unit operating. With two units operating, the transit time to the intake transition structure is reduced to approximately 44 minutes.
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Section 5.3.1, Water Quality, Page 5-3, Paragraph 2 It should be clarified that the 42-minutes travel time from the discharge transition structure to the station diffuser is based on both units operating. With only one unit operating, the transit time from the discharge transition structure to the station diffuser is about twice the value given.
Section 5.3.1, Water Quality, Page 5-4, Paragraph 4 The correct reference to the DES section that discusses the cooling j
system is 4.2.3.
Also, correct spelling of reference to Normandeau Associates, 1977.
Section 5.3.1, Water Quality, Page 5-5 Two references, Mattice and Zittel 1976 and Gibson et. al.1981, appear missing from the Reference section (5.14, Page 5-75).
Gibson et. al. may be listed as NUREG CR-1297, however, no reference to Mattice and Zittel is apparent.
Section 5.5.1.2, Right-of-Way Maintenance, Page 5-11 i
Applicant is concerned about NRC's understanding with regard to our use
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of herbicides in watershed areas. Certainly, Applicant avoids direct
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spraying in wetlands and spraying of watershed areas that drain into l
reservoirs used for public water supplies. However, in a strict sense, all highground is some sort of watershed, the water draining from it goes ultimately into some water course or pond, lake, etc., yet we do use herbicides on dry ground rights-of-way.
Applicant assumes that NRC shares their pragmatic interpretation of this point.
Section 5.9.2, Operational Overview, Page 5-20, Paragraph 3 Applicant wishes to clarify that revised dose calculations will be performed, but that they will be based on the annual land census mentioned earlier in the subject paragraph. Applicant recommends the deletion of the phrase, "As use of the land surrounding the site boundary a
changes," and replace it with, " Eased on this annual land census."
Section 5.9.3.1.2, Direct Radiation for PWRs, Page 5-26, Paragraph 2
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It appears that something has been deleted at the end of the phrase, "make a dose contribution at the site boundary of less than 1"(?).
Table 5.6, Radiological Environmental Monitoring Program, Page 5-33 I
With respect to surface water samples, Applicant intends to collect the initial preoperational samples as grab samples for the purpose of establishing background levels, and will implement the use of a composite sampler prior to commencement of station operation.
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Table 5.6 Indicates the composite ground water samples will be collected from two sample locations likely to be affected by plant operation.
Since the principal direction of ground water is towards the rarsh and estuary, and away from any ground water users, the possibility of plant releases af fecting ground water used for drinking or irrigation is unlikely.
Therefore, as indicated in Section 6.1.5.6 of the ER-OLS submittal, Applicant intends to take grab samples of ground water from two locations in the immediate area of the plant site.
Section 5.9.4.4, Mitigation of Accident consequences, Page 5-44, Paragraph 1 NRC should review the projected population densities provided since 2 versus m12 densities per km appear inconsistent.
Sec tion 5.9.4.5, Acciden t Risk and Impact Assessment, Page 5-62, Paragraph 1 Correct references to FSAR Figures to Figures 2.5-12 and 2.5-14.
Section 5.13, Emergency Planning Impacts, Page 5-75 The first sentence contains an incorrect reference, i.e.,
NUREG-0658 should be NUREG-0654.
Section 6.1, Unavoidable Adverse Impacts, Page 6-1 Applicant interprets the scope of condition (1) to apply only to on-site activities, and tha t the requirement for notification will be based on Applicant's determination of an activities significance.
Table 6.1, Benefi t-Cos t Summary, Page 6-2 An additional indirect benefit that should be included in the B/C Summary is the franchise tax that PSNH must pay to the state.
The esticated state franchise tax for the first full year of operation is $5 million (see ER-OLS Section 8.1.4).
l Quantitative indications of land and water resource commitments and their impacts are not provided in the table.
Section 6.4.3, Economic Costs, Page 6-4, Paragraph 1 It should be noted that the opera:Ing and maintenance (06M) cost of l
8.3 mills per kWh (1987 dollars) does not include capital additions.
If capital additions are included the C6M cost is about 11.05 mills per kWh.
Appendix C, Impacts of the Uranium Fuel Cycle, Page C-1, Paragraph 1 I
Add the word " reactor" af ter the phrase " light-water-cooled".
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