ML20077J592
| ML20077J592 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 08/15/1983 |
| From: | Boyer V PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | Eisenhut D Office of Nuclear Reactor Regulation |
| References | |
| RTR-NUREG-0974, RTR-NUREG-974 NUDOCS 8308170021 | |
| Download: ML20077J592 (10) | |
Text
I.
PHILADELPHIA ELECTRIC COMPANY 2301 MARKET STREET P.O. BOX 8699 PHILADELPHIA. PA.19101
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August 15, 1983 Mr. Darrell G. Eisenhut, Director Division of Licensing U. S. Nuclear Regulatory Commission Washington, DC 20555
Subject:
NUREG 0974:
Draft Environmental Statement Related to the Operation of Limerick Generating Station, Units 1 and 2, Docket Nos. 50-352 and 50-353
Dear Mr. Eisenhut:
We have reviewed the subject DES and our comments are enclosed.
Sincerely, d
Encl.
See attached service list CcoR 8308170021 830815 ld}/
PDR ADOCK 05000352 D
PDR b
(L
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I cc: Judge Lawrence Brenner (w/cnclosure)
Judge Richard F. Cole (w/ enclosure)
Judge Peter A. Morris (w/ enclosure)
Troy B. Conner, Jr., Esq.
(w/ enclosure)
' Ann P..Hodgdon, Esq.
(w/ enclosure)
Mr. Frank R. Romano (w/ enclosure)
Mr. Robert L. Anthony (w/ enclosure)
Mr. Marvin I. Lewis (w/ enclosure)
Judith A. Dorsey, Esq.
(w/ enclosure)
Charles W. Elliott, Esq.
(w/ enclosure)
Jacqueline I. Ruttenberg (w/ enclosure)
Thomas Y. Au, Esq.
(w/ enclosure)
Mr. Thomas Gerusky (w/ enclosure)
Director, Pennsylvania Emergency Management Agency (w/ enclosure)
Mr. Steven P. Hershey (w/ enclosure)
Angus Love, Esq.
(w/ enclosure)
Mr. Joseph H. White, III (w/ enclosure)
David Wersan, Esq.:
(w/ enclosure)
Robert J. Sugarman, Esq.
(w/ enclosure)
Martha W. Bush, Esq.
(w/cnclosure)
Spence W. Perry, Esq.
(w/ enclosure)
Atomic Safety and Licensing Appeal 90ard (w/ enclosure)
. Atomic Safety and Licensing Board Panel (w/ enclosure)
Docket and Service Section (w/ enclosure)
._d
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5 COMMENTS ON NUREG-0974 DRAFT ENVIRONMENTAL STATEMENT RELATED TO DE OPERATION UF LIMERICK GENERATING STATION UNITS 1 AND 2 DOCKET NOS. 50-352 AND 50-853 CIIAPTER/SECTION COMMENI
SUMMARY
AND CONCLUSION Page v Item (2),
second paragraph, third sentence, using water from the should read ".
Schuylkill River, Perkionen Creek, and the Delaware River."
Page vili Item (4)(u):
See comments below on pages 5-77, 5-93, and 5-94.
FOREWORD No Comment INTRODUCTION Page 1-1 Section 1,
second paragraph, first sentence:
Suggested rewording, "The generating system consists of two boiling water reactors, two steam turbine generators, heat-dissipation systems, and associated auxiliary facilities and engineering safeguards."
PURPOSE AND NEED FOR ACTION No Comment ALTERNATIVES TO PROPOSED ACTION No Comnent PROJECT DESCRIPTION AND AFFECTED ENVIRONMENT Page 4-4 Table 4.1: We believe that two of the values in this table are in error.
For nakeup from the Delaware /Perkionen during June through October, the range should be 52.1-57.4 and the average should be 55.7 ft*/see based on the values as given in ER0L Table 3.3-1.
Page 4-7 Section 4.2.4, Cooling
- System, first paragraph: The following should be added to the third sentence
.with two units operating and when the downstream river water The tenperature is less than 15'C.
statement should also note that water may be withdrawn from the Schuylkill River regardless of temperature during April, May, and June, provided the river flow is above 1791 ft*/ cec.
Page 4-12
. Main Sten of Perkionen Creek Intake, last sentence of the first paragraph:
This should be corrected to state that the system will be activated manually from a control panel located at the punphouse.
There are no automatic means to activate the systen.
Page 4-14 Section 4.2.6.2, Cooling Water Systens: While the DES indicated a value for average concentration factor for the June-through-expectation October period of about 3.7, our of the range of average concentration factors is 2.0 to 3.4.
Page 4-18 Section 4.2.7, This discussion should be updated to be consistent with Rev. 14 to the ER0L submitted July, 1983.
Therefore, the third paragraph, first sentence, "23kn (14.5 miles)" should be changed to "22kn (13.5 miles)".
Seventh sentence, "or Tubular steel poles" should be added after " Wide flange steel towers".
Page 4-53 Table 4.13, footnote giving source: as stated on page 4-51 the source of this data is the l
staff not the "ER-OL" as shown.
l Page 4-54 Last paragraph, first sentence, "(Table 2.1-A)" should be "(Table 2.1-10)".
h ENVIRONMENTAL CONSEQUENCES AND MITICATING ACTIONS Page 5-9 Third paragraph, first ser.tence; We believe "and" should be inserted after the phrase "do not exceed one unit"and before "would".
Page'5-18
.Section 5.8.8.2, Wedgewire Screen Bypass Velocities at Point Pleasant: The ASLB in its Partial Initial Decision,' dated March 8, 1983, cited Applicant's testimony and exhibits regarding velocities under Findings, items 85 4
and 66.
At flows of 8,000 cfs the river
. velocity is at or in excess of 1 fps.
It is requested that the second sentence be corrected by the deletion of the words "0.77 fps, with the most likely velocity about".
At flows of 2,500 cfs the river velocity is 0.8 fps.
It is requested that the third sentence be corrected by the deletion of the words "at least 0.64 fps, with the most likely value."
Section 5.8.8.8, Sedimentation and Erosion in Perkiomen
- Creek, first paragraph:
The statement that Delaware River water will enter the East Branch Perkiomen Creek through a 48 Anch diameter pipe is incorrect.
As shown on EROL Figure 2.4-7d, this pipe is 42 inches.
Only the first 12,187 feet of the pipeline, as it leaves Bradshaw Reservoir, is 48 inch. The remaining 23,130 feet of the pipeline is 42 inch.
f Page 5-25 Next to last paragraph, first sentences We believe that the word "not" should be inserted between "will" and " adversely".
Page 5-28 and Section 5.5.1.4, Pipeline Corridor Maintenance Page 5-91 and 5.14.1 Terrestrial Monitoring: The DES expresses concern about the erosion potential of. the slope adjacent to State Highway 82 at Point Pleasant once construction of buried pipeline.is complete.
It should be noted that this pipeline was to be installed to serve the public water supply needs of _ Bucks and Montgonery Counties prior to Applicant becoming involved as a water customer of the Neshamany Water Resources Authority and that this pipeline is not owned and.will not be constructed or operated by Applicant.
The NWRA has considered short and long term impacts and is subject to all conditions in the permits it has received related to this work from the DRBC, DER and COE..
, ;o.
Page 5-37 Section 5.8, First paragraph: The salary of the work force given in EROL (8.1-4) is $44 million in 1990 dollars. The DES estimates
$24.8 million in 1982 dollars.
(This would be a compound escalation rate of 7.4%)
Section 5.8, Third paragraph:
The public utility realty tax of $27 million per year in 1990 dollars is given in ER0L (8.3-3).
The DES estimates a value of $9 million per year in 1982 dollars.
(This would be a compound escalation rate of 14.7%)
The use of these two disparate rates is inconsistent.
Page 5-52 Table 5.8, The fourth and fifth columns for the last two entries on this page are incorrect.
For the next to the last entry 1983 (partial) Sample type " Direct Radiation" under " Analysis" column should read " Gamma dose" and under " Frequency of Analysis" should read " monthly".
The last entry Sample type
" Air (particulate and iodine)"
under
" Analysis" should be added "Radiciodine (I-t 131)" and under " Frequency of Analysis" should be added "
" (See EROL Table 6.1-45).
Page 5-5G Tsble 5.0, Seventh entry from top of page:
The Sector for.the Poplar substation, code "31D2" is "NW" not "NNW" as shown.
Page 5-77 Section 5.12.2.1:
The Bradshaw Reservoir design engineer has been directed to implement the ventilating louvre modification recommendation.
Page 5-90 Figure-5.8: The location of residences C and D are inaccurately shown on this figure.
There are no residences between the plant and the river. Refer to ER0L Table 2.1-37.
Pago 5-98 Section 5.14.4.1, Point Pleasant Pumphouse: A conmitment is acknowledged for construction of physical barriers (walls) if necessary.
Page 5-94 Section 5.14.4.2,.
Noise Monitoring, Bradshaw Reservoir:
The Bradshaw-Reservoir design engineer has been directed to laplenent the noise monitoring program.
l, -
l l1 L
1 EVALUATION OF TIIE PROPOSED ACTION Pages 6-2, 6-3, The reduction in generating costs of $34 and 6-4 million unit / year presented in Table 6.1 and discussed in Section 6.4.2 underestinate the operating savings attributable to Limerick.
Our estimate of these seeing. are presented in ER0L Table E320.1-1 (Revision 11, March 1983).
As shown in this table, during the first complete year of one unit operation (1986),
the savings are estimated to be $188.8 million per unit / year and during the first complete year of two unit operation (1980) to be $258.2 million per unit / year.
These estimates are 70% capacity escalated dollars based on a
~~
factor.
If these dollars are brought back to 1985 costs (at 8%/ year), the savings for 1086 and approximately $175 million and $190 1989 are million, respectively. Even if a 55% capacity factor is
- used, the estimated resultant savings are $143 million per unit / year for 1986 savings and $152 million per unit / year for 1989 savings in 1985 dollars using the sane method of calculation.
The energy savings of $34 million per unit / year presented in Table 6.1 of the DES is based on replacement of Linerick by ".
installed fossil units' on.the applicant's
." (Section 6.4.2).
system.
The calculated cost differential appears to be based on our coal costs.-
This is not realistic.
Any installed coal units on our system will have little, if any, replacement energy available since these units will be operated at, or near, base load even with the Limerick units in service.
Therefore, replacement of the Linerick energy with our installed fossil units will be bounded in cost.by replacement with all oil generation on the high side and our oil generation and some coal interchange on the low wide.
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For the purpose of verifying our calculations, the approximate value of-these savings can be estimated by the following calculation. Using the DES basis of the 10 million MWh/ year and either all oil replacement, or 50% oil and 50%
coal-replacement; the fuel savings are approximatelyt m
10 Million MWh/ Year 100% 011 50% 011 0 $5.30/Mbtu e $5.80/Mbte 50% Coal e $2.00/Mhtu Fossil Fuel Costs *
$55G,500,000
$383,250,000 Limerick Fuel Costs **
5 88,000,000 S 88,000,000 Net Savings
$468,500,000
$205,250,000
- G 10,500 btu /kWh
- O 8.8 mills /kWh Thus, on a one unit basis at 55% capacity factor 15 million MWh per-year) the above calculation shows fuel savings of approximately $148 million/ unit / year to $234 million/ unit / year.
Using the sane method of approximation at a 70% capacity factor, the 10 million MWh/ year would increase to approxinately 12.0 million MWh/ year.
The 50%
oil /50% coal savings would then increase to approximately $100 million/ unit year.
Our more detailed calculations shown in EROL Table E320.1-1 and described earlier are within the bounds of this approximate calculation.
.Page 6-8 Table 6.1 Benefit cost summary for Limerick:
The table indicates that the effect on historic and- " archeological resources of Limerick are moderate.
This classification appears to be inconsistent with the discussion in Section 5.7 and based upon that-discussion Applicant believes ~ that the classification should be 'small' or 'none'.
Additionally to update the discussion ~in Sectica
- 5. 7,'
it should be noted, regarding work by the NWRA at their Point. Pleasant pumping station, the j
Corps of Engineers'did include in their permit a condition that work shallfbe performed in accordance with' the Menorandum of Agreement".
Construction work started in. January 1983 and as required an archeologist is on site.,
N' gp.
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LIST OF CONTRIBUTORS
)
No Comment LIST OF AGENCIES, ORGANIZATIONS, AND PERSONS TO WHOM COPIES OF THIS ENVIRONMENTAL STATEMENT ARE BEING SENT No Comment RESERVED FOR NRC STAFF" RESPONSES TO CO?6fENTS ON THE DRAFT ENVIRONMENTAL STATEMENT No Comment
' APPENDIX A No Comment-APPENDIX B No Comment APPENDIX C No Comment APPENDIX D Page D-2 The dose assessment presented is an extrenely conservative treatnent of the expected effects of gaseous and particulate effluent releases.
While the analysis does serve a purpose in showing that even with the most conservative assumptions the plant meets the criteria of 10 CFR' Part 50, Appendix I, these results should not be used for any purpose in which realistic calculations are required.
This should.be made clear in this Appendix.
The most r,onservative aspect of the assessment is the aesumption that all releases in. those sectorr. downwind of the natural draft cooling ground-level towere should be treated as releases, rather than using the wake split approach of' Regulatory Guide 1.111, Rev.
1.
While it is a well-known fact' that large structures such as cooling towers do produce a wake area of increased turbulence during some meteorological conditions, the staff has treated the effluent as if it were brought entirely to the ground during all meteorological conditions. This assumption is clearly ultra-conservative for the following
-reasons: _-
(.
.1)
Cooling tower wake effects do not exist during low wind speed conditions.
j 2)
Hyperbolic cooling towers'do not produce
~
sharp downdrafts at moderate to high wind speeds causing 100%
ground level releases.
Rather, enhanced turbulence results.
These phenomens have been documented in wind tunnel studies and field tests performed for the Rancho Seco and Paradise plants in 1971.
APPENDIX E No Comment APPENDIX F No Comment APPENDIX G No Comment e
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