ML20087B512

Forwards Comments Re Des (NUREG-1033) for Consideration in Preparation of Fes

ML20087B512
Person / Time
Site:	Satsop
Issue date:	03/05/1984
From:	Sorensen G WASHINGTON PUBLIC POWER SUPPLY SYSTEM
To:	Knighton G Office of Nuclear Reactor Regulation
References
RTR-NUREG-1033 GO3-84-131, NUDOCS 8403090118
Download: ML20087B512 (5)

Text

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Washington Public Power Supply System Box 1223 Elma, Washington 98541 (206)482-4428 Docket No. 50-508 March 5,1984 G03-84-131 Director of Nuclear Reactor Regulation Attention: Mr. G.W. Knighton, Chief Licensing Branch No. 3 U.S. Nuclear Regulatory Commission Washington, D.C.

20555

Subject:

SUPPLY SYSTEM NUCLEAR PROJECT NO. 3 DRAFT ENVIRONMENTAL STATEMENT (NUREG-1033)

Reference:

Letter, G.W. Knighton, NRC, to D.W. Mazur, Supply System same subject, dated January 13, 1984.

.Thank you for the opportunity to review the subject document.

We offer the attached comments which you may wish to consider in the preparation of a Final Environmental Statement.

Very truly yours,

=&:

G.C. Sorensen, Manager Regulatory Programs JPC/mam

Attachment:

As stated cc:

D. Smithpeter (BPA)

A. Vietti (NRC)

J. Adams (NESCO)

N.S. Reynolds (Bishop, Liberman, Cook, Purcell & Reynolds)

J. Porrovecchio (Ebasco - NYO)

WiiP-3 Files F. Swearingen (BPA)

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B403090118 840305 PDR ADOCK 05000508 D

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-SUPPLY SYSTEM COMMENTS ON WNP-3 DRAFT ENVIRONMENTAL STATEMENT'(NUREG-1033)

' Facility Description (Sections 4.2.1 and 4.7.2)

Figure 4.1 is taken from ER-OL Figure 2.1-1 which will be amended consistent with.the response to Q290.14 and the acreages cited in DES-OL Section 4'.2.2.

FSAR' Figure 2.1-1 has already been amended (December 1983). Also note in

Section.4.2.1 that reduction of the base diameter of the cooling tower by 90

. feet is r.at an exception to conclusions regarding the significance of changes in the arrangement of site structures. Construction laydown area should be

^added to the list at the bottom of p. 4-1.

Nonradioactive Wastes (Secion 4.2.6)

With reference to the second paragraph in Section 4.2.6.2, it is now planned that potassium chromate will be added to the closed component cooling water

~ system for corrosion control. As described in the DES, leakages will be Lprocessed in the SHP' system with residual chromate removal by ion exchange.

Water drained from the component cooling water system during maintenance operations will be captured and reused in the system.

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'In the fifth paragraph of Section-4.2.6.2 (bottom of p. 4-11) it should be noted that sodium hypochlorite will 'be the source of free chlorine residuals.

With reference to the last paragraph of Section 4.2.6.2 (p. 4-12) and the second paragraph of Section 5.3.1 (p.: 5-2), we note that although we expect the chlorine residual in the discharge to be at or below 0.02 mg/1, the. NPDES Permit considers 0.05 mg/l to be the detectable limit (p..G-4).

Sanitary waste disposal. is mentioned in Section 4.2.6.3.

It should be noted that WNP-3 will continue to dispose cf treated wastes in the drain field which was sized for construction phase loading (see ER-OL' Sections 3.7.1 and 5.4).

Hydrology (Section 4.3.1)

Mistorical flow data for the Chehalis River are sumarized in the fourth paragraph of Section 4.3.1.1.1.

The average Chehelis River flow at' the site

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3 is given. (without reference) as 6824 ft /sec while the ER-OL and FSAR suggest about 6630 ft Vsec. The average monthly flows cited for' August and January 3

should be given as 806 and 14,668 ft /sec, respectively (see FSAR p. 2.4-2; i'

ER-OL p. 2.4-1 and T. 2.4-1 to be amended, accordingly).

The minimum 3

historical flow is now estimated to be 454 ft /sec (FSAR p.2.4-51) rather than 3

197'ft /sec as cited in the DES.

In the third sentence of Section 4.3.1.1.3 it should be noted that the 550-ft3 /sec river flow limitation could be waived by the State based on regional power needs.

Water Quality (Sections 4.3.3 and 5.3.1) 4-The-ambient Chehalis River copper concentrations given in the fourth paragraph of Section 5.3.1 are based on older data. Reference should be made to Table

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-Supply System Comnents - NUREG 1033 Page Two

.The Supply. System bioassay studies are mentioned in the last paragraph of

-Section 5.3.1.

Contrary to as cited therein, the draft report summarizing the results of these studies was provided to the NRC by letter dated October 21, 1983. ' The results suggest' a.long-term, no-effect level of 18 uc/1 for coho salmon-versus the 7 ug/l cited on p. 5-3.

Meterology ~(Section 4.3.3)

It shoul'd be noted in the third paragraph of-Section 4.3.3 that observations

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' of " heavy fog" are from valley stations where fog and stagnant air collects.

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WNP-3.is located on a ridge above the heavy fog.

Aquhtic Resources (Sections 4.'3.4.2 and 5.5.2)

The11ast two. sentences of the second paragraph of Section 4.3.4.2 seem somewhat. confusing and unnecessary in view of discussion provided in Sections 4.2.4'and 5.5.2.

This latter section (p..-5-6) notes that the diffuser was relocated to minimize potential impact to migrating salmonids.

Angler survey data.are provided on p. 4-22 and 4-25.

We have difficulty

relating the numbers to the referenced sources.

Does the range 4 to 17 anglers per day refer to all; anglers or only salmon fishermen? Does the range 10 to 26 per day and maximum of 50 mean 'steelhead fishermen? Our reading of the data suggests that the annual average ranged from 6 to 12 anglers per day

,N for 1978 - 1981. ' Monthly averages-for the survey period ranged from 0.2 to 26.4 anglers per day.

. Terrestrial Resources (Sections 5.2.1 and 5.5.1)

The: DES notes that a wildlife management plan is to be submitted to the Energy

Facility Site Certification Council (EFSEC).- The plan is not specifically

- required, but stems from conditions of the Site Certification Agreement between the Supply System'and the State of Washington.

It is subject to approval by EFSEC; a copy will be provided to the NRC at the time of its submittal..

Connunity Characteristics (Section 4.3.6)

.In response to Q311.05-we noted minor errors in the distribution of near-plant residents.

ER-OL Table -2.1-2 and FSAR Table 2.1-3 will be amended to provice corrections. For instance the 1980 population within one mile of WNP-3 is now

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estimated to be 3 ~versus the 15 noted in DES Table 4.7.

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Radiological Impacts, ' Routine Operation (Section 5.9.3)

The~ estimated doses from routine operation are-provided in DES Appendix D.

We

! only note that the Staff's calculated dispersion factors and resultant doses are roughly-twice the Supply. System estimates in the ER-OL. Tne fish L

consumption liquid pathway dose, although very small, seems to be based on an excessively conservative dilution factor for an anadromous fishery.

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The " maximally exposed" individual is explained in Section 5.9.2 (bottom of p.

L 5-10)..It would be useful.to remind the reader in Section 5.9.3.1.2 (p. 5-20)

Lthat this individual is hypothetical and that the doses from various pathways are calculated and summed very conservatively.

e' Supply System comments - NUREG.1033 Page Three :

The~ peoperational monitoring program is discussed in Section 5.9.3.4.1.

The

. Supply' System plans minor changes to the program described by Table 5.3 to

. assure consistency with Regulatory. Guide 4.8 and its Branch Technical Position. Table 6.1-7 of the ER-OL will be amended to reflect the changes and correct the' typos.

Radiological Impacts, Accidents (Section 5.9.4)

The evacuation model is referenced on~ p. 5-41 and discussed in Appendix F.

The DES (p. F-3) " conservatively" estimates an effective evacuation speed of

~ 2. mph. :Given all the conservatisms of the accident analysis, we find this

' estimate overly conservative'by.compariscr. with evacuation times estimated in

' Table 12-5 of the WNP-3 Emergency Preparedness Plan.

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The DES finds that the WNP-3 liquid pathway (p. 5-50 to 5-53) yields doses substantially greater than the LPGS doses and still poses much less risk than e

the. gaseous pathway.. We note that the DES estimates are-also much greater than Supply System estimates (RQ240.14). Both the DES analysis and that of Lthe-Supply System begin with the very conservative assumption that 100 percent of'the-core inventory of cesium, the major contributor to dose, reaches the

. river immediately, whereas 10 percent would be more realistic. Given the conservative source tem, the large population dose for WNP-3, relative to the LPGS, is derived from conservative assumptions regarding shoreline usage,' fish catch / consumption, and river dilution.

?The fish consumption pathway provides the most significant contribution for comparison with the LPGS.

Besides using an overly conservative catch of one million pounds (see DES Table 4.3 and RQ240.14), the analysis must assume (as did the LPGS) that all fish caught are fully exposed and consumed. - If the

- containment were breached such that the Chehalis River was severly L

contaminated, as postulated in the DES, among the immediate impacts would be

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-the-loss of-recreational opportunities and disruption of the fishery markets.

The NRC would be more realistic if it assessed the liquid pathway in terms of L

economics rather than fictitious health effects.

.The' DES analysis (p. 5-52) uses the hannonic mean flow which is about one-fourth of the annual mean flow ~ of the Chehalis River. We assume it conservatively neglects the contribution of tributaries downstream.

Because a large fraction ~of the one million pounds of fish are caught in Grays Harbor, with its associated flushing and dilution, yet another conservatism is inherent in the analysis. -The analysis also neglects any sediment partiticning which would reduce concentrations.

In the second and fourth paragraphs on p. 5-51 (the third seems out of place),

it should be noted that the plant underdrains discharge to a Workman Creek tributary which is referred to as Stein Creek (see Figure 5.1). Workman Creek is not an ephemeral stream. Also, we note that the third paragraph on p. 5-56 i

-seems misplaced and perhaps belongs to the discussion of uncertainties on

.p. 5-63..

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f-In:sunnary of our comments on accidents, we suggest that neither the Staff nor l

the Supply System has "shown" WNP-3 to have " considerably worse" consequences than the LPGS. Given the conservatisms of the analysis, a more qualified judgement seems appropriate for tre last paragraph of Section 5.9.4.5(5).

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Supply System Comments - NUREG 1033 Page Four-Benefit-Cost Summary (Table 6.1)

In Table 6.1 groundwater consumption impact is listed as "none."

Consistent with Sections 4.2.4 and 4.3.1.1.2 this should probably be "small." Section 5.5.2, rather than 5.3.2, should be given as a reference for thermal effects.

" Cooling lake drawdown" is incorrectly listed as an impact in Table 6.1.

Based on the information given in Section 5.7 concerning the effect of plant operation on historic / archeological resources, "none" seems more appropriate than "small. "

Minor Editorial Comments On p. 4-1 (Section 4.2.2) the question number is 290.14, not 29.14.

On the same page, the exclusion area boundary is at 1310 meters, not 13,611 meters.

On p. 4-6 the correct reference for withdrawal limitations is Section

4. 3.1.1. 3, not 4.3.2.

On p. 4-11 in the third paragraph of Section 4.2.6.2, the second reference to ER-CP should be ER-OL Table 3.6.2.

The last three sentences of this paragraph seem excessively wordy.

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On p. 4-13 units of flow are m /sec, not m /sec.

On p. 4-24 "... Emergency... " should be "... Energy... "

On p. 5-2 ".. 61.3 ug/1..." is repeated.

In the same paragraph reference to Section 4.3.2 should be to 4.2.6.3.

3 On p. 5-3 units of flow are m /sec,.not ug/sec.

On p. 5-5 and 5-71, it seems the FES, rather than DES, should be referenced.

' Also on p. 5-5 (Sectica 5.5.1) the correct ER-OL figure reference is 5.1-4 (not 5.1.4) and the DES section reference is 5.14.2 (not 5.11.2).

On p. 5-53, at the bottom, Figure 5.9 should be Figure 5.11.

On p. 5-43 incorrect figure references are given in Table 5.7.

In the second paragraph on this page the background radiation dose should be 82,000 person-rems consistent with p. D-9.

Also, at the bottom of the page "28-m" should be "28-km."

On p. 5-61 and 5-70, the date given for the Nieves reference should be November 1983.

On p. 5-68, FSAR Section 10.3 should be WNP-3 Emergency Preparedness Plan Section 10.3.

On p. F-2, at the bottom, "0.89 km" should be "3.2 km."

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