ML20091A679
| ML20091A679 | |
| Person / Time | |
|---|---|
| Site: | Braidwood  |
| Issue date: | 05/16/1984 |
| From: | Swartz E COMMONWEALTH EDISON CO. |
| To: | Harold Denton Office of Nuclear Reactor Regulation |
| References | |
| RTR-NUREG-1026 8604N, NUDOCS 8405300056 | |
| Download: ML20091A679 (11) | |
Text
..
,. 't Commonwealth Edison
) on) First Nationil Pla2t. Chic 7go. Hlinois
.l Address R: ply to: Post Offics Box 767
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' Chicago, Illinois 60690
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May 16, 1984 Mr. Harold R. Denton, Director Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, DC 20555
Subject:
Braidwood Station Units 1 and 2 Response to Various Federal, State and Local Comments on the Draft Environmental Statement - NUREG 1026 NRC Docket Nos. 50-456/457 References (a):
B. J. Youngblood letter to D.
I..
Farrar dated January 16, 1984 (b):
C. L. McDonough letter to Director, Division of Licensing dated March 12, 1984
Dear Mr. Denton:
Reference (3) provided the Comm nwealth Edison Company with the Braidwood Station Draf t Environmer.tal Statement (DES) - NUREC 1026.
Reference (b) provided the Commission with our cocmests on this DES in response to th) 45 day comment period that ended March 12, 1984.
Subseauently, Ms. Janice A. Stevens provided Commonwealth Edison with various comments on the DES that were received by the Commission from various Federal, State and Local agencies.
Thn purpose of this letter is ta formally respor.d to certain of those comments.
The enclosed statements were informally provided to Ms.
Janice A. Stevens to facilitate her preparation of the Final Environmental Statement (FES) for our Braidwood Station.
Please address any questions that you or your staff may have concerning this matter to this office.
One (1) signed original and fifteen (15) copies of this letter with Enclosures are provided for your use.
Very truly yours, 8405300056 840516
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PDR ADOCK 05000456 D
PDR E. Douglas Swar Nuclear Licensing Administrator Enclosure cc:
J. G. Keppler - RIII RIII Inspector - Braidwood
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U.S. Environmental Protection Agency Region V Comment 1: Page 1 (attachment), Sixth paragraph.
"The Draft EIS does not address the problem of storing the high level waste. The impact of "away from reactor" and/or "at the reactor" storage needs to be controlling emissions to levels such that when the direct radiation is considered, operations will still be within the EPA Environmental Radiation Standards (40 CFR 190)."
Response
Chapter 12 of the Braidwood FSAR has sufficient information to respond to thts comment.
Comments 2 Page 2 ( Attachment) Water Quality Impacts "During construction of the Braidwood station erosion control programs were developed and implemented by the Commonwealth Edison Company. As part of the scoping process for this Draft EIS, we participated in a site visit to the Braidwood Station.
While on this site visit, we noticed several areas where the measures to control soil erosion had failed and rill and gulleys were the result.
Islands in the cooling pond were also void of vegetation and were erodinE.
Commonwealth Edison needs to better maintain the soil. erosion program. Minimization of suspended solide in the cooling pond should also improve the efficier.cy of the power plant's cooling system."
Response: Tnc erosion control program is an engoing process, steps are taken to correct and repair rills and gulleys when they cccur in areas that would constitute an operational or safety problem.
With regard to the spoil islands in the cooling ponds no action has been taken to this point to revegetate the slopes due to the commitment to the continuation of the fossil hunting program.
Plans are being made to seed areas of the slopes which are less desirable from a fossil hunting standpoint if water quality dictates.
The effect of this would be stabilization of the slopes and reduced leachate.
At this time no cooling system deficiencies due to water quality are anticipated.
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Illinois Department of Nuclear Safety Comment A-3:
"Does the range of annual man-rems anticipated for the occupational radiation exposure include the radiation exposure received for special considerations such as steam generator tube repair and maintenance on the reactor coolant pump seals?"
Response
The data base used to develop the range of exposures extends back to 1974, therefore, such tasks as steam generator tube repair and maintenance of reactor coolant pumps have been undertaken at several pressurized water reactors during that time.
Comment A-4:
Asks if the staff considered the proposed revision of 10 CFR 20.
Response
Since this comment relates to a staff judgement, the staff can best answer this comment.
Comments A-5 Accident, Risk and Impact Assessment (7) Uncertainties (pp 5-69) and B-2:
and Use of Reactor Safety Study (WASH-1400) in risk assessment for Braidwood Station.
Response
The analysis of the consequences of sesere accidents contained in the DE5 is based upon the updated Reactor Safety Study.
CECO. fully agrees with the NRC Staff's conclusions that the level of risk associated with operation of the Braidwood Station is very small and thus acceptable.
However, CECO.
would point out that recent industry efforts to define and quantify accident risks demonstrate that the use of the Reactor Safety Study may well be somewhat overly conservative.
CECO. therefore believes that it would be apropriate for the NRC Staff to recognize that the risks associated with potential accidents at Braidwood Station are likely even smaller than those identified in the DES.
most CECO. comments on DES page 5-52, which were previously submitted, also stated that the Staff's conclusions based on WASH-1400 are conservative.
Comment B-1:
"Does Braidwood Station have the capability to handle radioactive chemical decontamination?"
Response
The chemical radwaste system (WZ System) is designed to handle radioactive chemical waste on a small scale but not on the scale of decontamination such as planned for Dresden 1.
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. o Comment B-3:
"Please provide an explanation as to why there are differences in the following tables:"
Release Type Type of Document FES-CLS DES-OLS Liquid Table 3.5 Tcble D-4 Gaseous Table 3.6 Table D-1
Response
The difference between the construction and operating licensing stage data is attributable to design changes and the application of different computer codes.
Comment B-4:
Questions basis for qualitative judgement of staff on uncertainty bounds.
Response
CECO. can not respond to staff's rationale.
Comment B-5:
Requests explanation for reduction of the gaseous release rates.
Response
CECO. can not respond to the Staff's rationale.
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Illinois Department of Conservation
-Comment 1:
"On page 5-2, last paragraph, it is stated, "The water quality standards also require that the discharge structure must be designed to ensure that the mixing zone allows a reasonable zone of passage for aquatic life and must-not encompass more than 25%
of the cross-sectional area or volume of flow, except in those instances where the dilution ratio is less than 3:1 (ER-OL Section 5.1) "
On page 5-13, first paragraph, it is stated, "The thermal plume is projected to extend to 28% of the river width in August, 33%
in September, and 22% in December--."
These two statements appear to be in conflict; therefore, further clarification should be presented in the Final Environmental Statement (FES)."
Response
The projected' thermal plume values on page 5-13 of the DES are in terms of the percent of the surface of the river covered by the plume at its maximum width.
It must be considered that the plume does not extend from the surface to the bottom of the river across its entire width and also that the river's average depth in the center one third is greater than the portion near shore. When the depth of the plume and the river cross sections are considered the 50 T plume cross sectional areas are 18%
in Augutt, 21% in September, and 13% in December. These areas meet the Illinois water quality standards.
Section 5.1.2 of the Braidwood ER-OLS will be amended to show these values.
Comnent 2:
"For these reasons, we suggest the FES assessment of impacts on eggs and larval fish include a discussion of studies Commonwealth Edison has conducted to determine distribution of larval drif t across the cross-section of the river. We are most interested in learning if an analysis by species and percent of drift already dead was conductel so a meaningful comparison can
- be made by species prior to entering the intake and/or heated l
water area and af ter passing through these hazards.
If these studies have not been conducted at this site then the FES should include a definite statement relative to the need for such studies after plant start-up."
Response
The three years of fish egg and larvae studies which were con-ducted in the Kankakee River as part of the construction phase monitoring program indicated that the distribution of larval drif t varies 1) with the flow of water in the river and 2) the size of a sand bar upstream of the intake structure.
Larvae live-dead observations were not made during these studies.
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,- When Unit One begins normal commercial operation, Edison is committed to conduct an entrainment study during the spawning season.
In addition to fish egg and larvae samples at the in-take structure, samples will also be taken in the river.
Samples will be taken over a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> period once a week. These studies will provide further data to evaluate the effects of plant operation on the fish populations in the river. Require-ments for this type of operational program are included as part of the NPDES permit issued by the Illinois Environmental Protection Agency.
i Comment 3:
"For the above reasons, we suggest the FES fully discuss Commonwealth Edison's commitment to conduct 12 month impingement entrainment studies after plant start-up.
We look to this study to provide answers to the aforementioned concerns."
Response
Commonwealth Edison is committed to conducting a 12 month im-pingement study at the intake structure on the Kankakee River.
The study will begin when Braidwood Unit One begins normal com-mercial operation.
It is expected that the study will be con-ducted in the same manner in which the study performed during the filling of the cooling pond was conducted.
Therefore, im-pingement sampics will be collected on three conae.utive twenty-four hour periods each week.
Requirements for this type of operational program are included as part of the NPDES permit issued by the Illiaois Environmental Protection Agency.
Comment 4:
"The FES should address Commonwealth Edison's specific plans for river monitoring and study of this species (the pallid shiner) prior to and following plant start-up."
Response
The pallid shiner is rare in the State of Illinois but it is not on the Illinois list of endangered or threatened species.
Although the species has been proposed for the list, studies still need to be conducted to see if the pallid shiner can be found in other parts of the state. We have recorded this species in Pool 14 of the Mississippi River.
The pallid shiner was collected by seining during the Commonwealth Edicon study. The fish appears to prefer protected areas with slow water movement.
Commonwealth Edison will con-tinue to pay par 6icular attention to this species. The sampling program currently being conducted (fish surveys in August) will be continued until the plant becomes operational at which time the program will be done in conjunction with the impingemen.
study.
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h Northeastern Illinois Planning Commission Comnent 1: Page-1 (attachment) Paragraph 1 "The draft statement which is the object of this review is oriented toward plant operations. Perhaps as a result of this orientation the draft statement does not address the environmental impacts of the pipeline to the Kankakee River, even though the impacts of the plant, cooling pond and intake and discharge facilities on the Kankakee Riverr are discussed in detail."
Response
The effects of installing the make-up and blow-down pipelines, were essentially all confined to the construction phase.
Upon completion and redressins of the right-of-way the original land uses were restored including agricultural and roadways.
Surface and subsurface drainage systems were resumed. The only visible evidence of the presence of the pipelines are the small above ground vent structures.
Comment 2: Page 1 (attachment) Paragraph 1 "There is no discussion of asthetic impacts except for re-vegetation plans for the site and the expected impacts related to noise and air quality. Given that the facility is already constructed the Commission urges that the final icndscaping and ongoing operations be conducted in a asnnet which minimize adverse of f-site asthetic impacts."
Response
As stated in Section 3.1.3 of the Braidwood Environmental Report
- Operating License Stage the station structures, while obviously industrial, are designed to provide a variety of texture and color. Tne main structures are somawhst shielded from the view of the closest homes and the highway by an existing stand of trees, as many as possible of which were left standing when the site was prepared for construction.
Additional trees and shrubs have been added to this stand of trees and to the northerly approach to the station.
The profile of the river screenhouse was kept as low as possible and a screen wall hides the trash rack cleaning machinery from the view of the residents across the river.
In addition, extensive landscaping has been done at the river screenhouse to screen and provide a background for the building.
Comment 3: Page 2 (attachment) Paragraph 1 "The Regional Open Space and Recreational Policy Plan encourages increased availability of open space in northeastern Illinois.
l Since cooling ponds become major aquatic and waterfowl habitat areas, the Commission encourages their safe use for wildlife management and related recreational activities.
The C'emmission encourages Commonwealth Edison's cooperation with the Illinois Department of Conservation on this matter."
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Response
No commitment-has been made with regard to public recreational use of the Braidwood cooling pond but Commonwealth Edison has and will continue to cooperate with the Illinois Department of Conservation (IDOC) on.such matters as an experimental fish stocking program'and to monitor the progress of the program. No hunting or fishing is allowed on the site by agreement with the IDOC and' compliance is enforced by its Conservation Law Enforcement Officers.
Evaluations of the potential for recreational uses will be made after the station is in operation.
Comment 4: Page 2 (attachment) Paragraph.1 "NIPC policies encourage the preservation' of historic resources and, therefore,. the protection of archeological resources on the site which may be found to be eligible for inclusion in the National Reginter. Site development activity, including future activities, should be done with the consultation of the State Historic Preservation Officer, the Illinois Archeological Survey and the Illinois Natural History Survey."
Response
There were no sites on the station property that were either included or were eligible for inclusion in the " National j
Register of Historic Places", the " National Registry of Natural Landmarks", or the other listings of locally significant sites.
i An archeological survey of the site was conducted by the t
Illinois State Museum, a member institution of the Illincis i
Archeological Survey. Evidence of prehistoric occupation was found but the results of subsequent testing showed that there was no further archeological work required. These findings which were approved by the State Historic Preservation Officer, gave approval for utilization of the site without further consultation with regard to prehistoric cultural and historic i
sites.
Comment 5: Page 2 (attachment) Paragraph 1 "The arrangement with the Field Museum regarding fossil collecting seems appropriate. The accessibility provided by j
this arrangement should be continued and fossil resources on.the site protected during operation of,the facility."
Response
The agreement with the Field Museum has remained in effect i
throughout the construction period.
In the future, security.
I requirements at the cime of fuel load and operation may require changes or termination of the program. LThe number of fossils found should decrease over the next few years as the spoil banks stabilize _and are covered'with vegetation.
In any case, the fossil resource will be protected throughout the life of the l
- station.
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'e Comment 6: Page 2 (attachment) Paragraph 2 "The Cocmission urges that all appropriate safeguards be used to ensure safe operation of this facility.
Its failure to operate in such a manner could have serious adverse economic impacts, as well as life threatening impacts on the metropolitan area.
The Commission is concerned for the well-being of the region's small communities, several of which are near the facility, as well as its large population concentrations."
Response
Braidwood Station is located well away from any major population center. The siting in this area with a low population density per square mile is appropriate both for a normal operations and for emergency planning. The station will be operated in a safe manner under the full regulatory authority of the Nuclear Regulatory Commission.
Comment 7: Page 3 (attachment) Paragraph 1 "The Commission notes that it develops the official population, household and employment forecasts for the region, in conjunction with the Illinois Bureau of the Budget.
The Commission recommends that such forecasts be used in the planning and design of regional transportation, water supply, waste water treatment and energy facilities.
If decisions remain concerning operation of the facility as it relates to forecasted growth, the Commission encourages Commonwealth Edison to consult with NIPC and the Illinois Bureau of the Budget regarding the use of their official forecaste."
Response
Commonwealth Edison has in the past and will continue to consult 98 with these agencies and use their forecasts in full when appropriate or as a comparison with its own or other forecasts.
Comment 8: Page 3 (attachment) Paragraph 2 "The future of the region is dependent upon the protection of
- the regions ground and surface water resources. Responsible agencies should evaluate with extreme care the plant's impact on these resources during normal, as well as emergency conditions."
Response
Braidwood Station does not utilize ground water as an operational water source.
The surface water used is withdrawn from the Kankakee River. The agencies involved in approval of this source of surface water have exercised care in restricting the amount of water to be withdrawn and in approving the quality of the water that is to be returned.
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4828E BBB:pp l
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e Will County Development Department General Comment:
The Development Department's comments dealt entirely with a percieved impact on the proposed Will County Public Water Supply System to be located, according to the letter, downstream of the Braidwood Station.
Response: Commonwealth Edison understands the concern but wishes to point out that the proposed Public Water Supply facility is now planned to be located upstream of the Braidwood Station intake and discharge rather than downstream. The proposed intake is to be built in Section 20 of Wesley Township while the Braidwood Station intake is approximately two miles downstream in Section 13 of Reed-Custer Township (see attached plat map).
Individual Comments:
1.
" Degradation of water quality from cooling water discharge to the river.
Response: The water quality of the discharge from Braidwood Station pond to the river will be within all thermal and chemical standards which are formulated to minimize effects.
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2.
"Long-term human health effects and riska associated with effluents entering the river containing low levels of radioactive discharge."
Response: The levels of radioactive discharg2 entering the Kankakee River will be monitored to ensure that releases are below the standards. These standards are set to minimize effects.
3.
" Inadequate volume of river flow downstream to support the water supply system. Specifically, page 5-2, item 5.3.1 of the statement does not include Will County Public Water Supply System as a potential downstream water user."
Response
If, as stated above, the public water supply intake is to be located upstream, this is not a valid comment.
4.
" Risk of possible contamination of the water supply in the case of power plant malfunction and emergency."
Response: There is no direct link between the reactor moderating medium and the cooling weter system that depends on the water taken from, and returned to the Kankakee River, therefore the possibility of this contamination is very remote. In addition, the plant discharge point is downstream from the proposed intake for the public water supply.
5.
" Increased costs to the proposed water system due_to l
mitigating measures that may be required to address the effects of the Braidwood Station upstream."
l Response: Same as response to 3. above.
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John F. Doherty Comment 1:
This comment deals with the NRC's treatment of the generic fuel cycle impacts.
Response
The staff can best answer this comment.
Comment 2: This comment deals with a staff conclusion.
Response
The staff can best answer this comment.
Comment 3:
"The Statement needs to clarify if in the analysis of environ-mental impacts of postulated accidents any credit was given for Applicant compliance with any of the TMI related requirements of NUREG-737 ' Clarification of TMI Action Plan Requirements. '"
Response
As an added c'onservatism, no credit was taken in our analysis.
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United States -
Economic -
Washington, D.C.
Department of Resean:h 20250 Agncu3ure Semce January 27, 1984 Mr. B. J. Youngblood Chief. Licensing Branch No.1 Division of Licensing U.S. Nuclear Regulatory Commission Washington, D.C.
20555
Dear Mr. Youngblood:
Thank you for forwarding the Draf t Environmental Statement concerning the issuance of an operating license to the Commonwealth Edison Company for the startup and operations of Units 1 and 2 of Braidwood Station located south-southwest of Joliet, Illinois.
We have reviewed Docket Nos. STN 50-456 and STN 50-457 and have no comments.
Sincerely, M,m_Miu,
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VEIMAR W. DAVIS Aciing Director iidtural Resource Economics Division
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r undec S'ates sod Springar F;darcl Building Department et conservation 301 N. Randolph Street
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February 6, 1984 B. J. Youngblood, Chief Licensing Branch No.1 Division of Licensing U.S. Nuclear Regulatory Co=m.
Washington, D.C.
20555
Dear Mr. Youngblood:
Me=bers of cur staff have reviewed the data for the draft environmental impact statement related to the operation of Braidwood Station Units 1 and 2, Docket Nos. STN 50-456 and STN 50-457 in Will County, Illinois, and have no com=ents to add to those cade in an earlier review.
Sincerely,
,n J.
ekes State Conservationist Peter C. Myers, Chief, SCS, USDA, Washington, D.C.
ec:
Roger Rowe, ' AISWCD, Marseilles, IL Steve ' Chard, IDOA, Springfield, IL Don Manecke, Orion, IL B. Smith, AC, A-2 A. May, DC, A-2 e
840213 840206 PDR CK 030004S6 D
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1035 Outer Park Drive Springfield, Illinois 62704 (217)5466100 T
Don Etchison Duector Terry Lash Deputy Director February 22, 1984 Director Division of Licensing U.S. Nuclear Regulatory Com=ission Washington, D.C.
20555 RE: Braidwood Station Units 1 & 2 Docket Nos. STN50-456, STN50-457 Draft Environ = ental Statenent (NUREG-1026) Operating License Stage
Dear Director:
After a review of the Braidwood Environmental Statement, the following questions and concents are directed to your attention:
A.
5.9.4.4. (1) - Environmental Impacts of Postulated Accidents - Design Features 1.
How does the Braidwood Station's radioactive vaste gas decay tank system design differ from the Zion Station design which experienced an unplanned accidental release of noble gases on May 26, 19807 Picase provide information as to how Braidwood Station's vaste gas decay tank design would prevent such an accidental radioactive gas release.
5.9.3. - Radiological Impacts from Routine Operations 2.
What has been done at 3raidwood Station to preclude un=onitored and/or unplanned radioactive releases, both gaseous and liqvid? An 4xample of such is the past unmonitored liquid tritium riulease at Zion Station.
3.
5.9.3.1.1. - occupational Radiation Exposure for P: essurized Water Reactors Does the ran;,e of annual man-rems anticipated for the occupational radiation exposure ir.clude the radistion exposure received for BA03060313 222 POR ADO S0004S6
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Direct 2r, Divisisn cf Licensing F;bruary 22, 1984 Page 2 s.
3.
special considerations such as steam generator tube repair and maintenance on the reactor coolant pump seals?
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IBID (3)
Did the staff take into account the proposed revision of 10CFR20 in developing this section on occupational radiation exposure?
5.
5.9.4.5 - Accident Risk & Impact Assessement (7) Uncertainties (Page 5-69)
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This section indicates that sequences initiated by natural phenonena, such as seismic events, are not included in the scquences being evaluated. The staff also indicates this, as well as other natural i
phenomena effects, would not contribute significantly to risk. Please provide justification as to why, at least for the seismic event, design analysis was not provide,d for the Braidwood Station.
B.
General Comments 1.
Does Braidwood Station have the capability to handle radioactive chemical decontamination waste?
l' 2.
The staff relied heavily upon the Reactor Safety Study (Wash.1400),
l and the Zion acd Indian Point probabilistic risk assessment studies i
in Section 5.9.4.5, " Accident Risk and Impact Aasessment", in its analyses.
In light of the high degrees of uncertainty associated with the I
probability values in Wash.1400, should not a more realistic study be performed for Braidwood Station in order to be able to place a higher degree of confidence in the risk assessment resuits?
3.
Please provide an explanation as to why there are differences in the following tables:
Type of Document Release Type FES-CLS DES-OLS Liquid Table 3.5 Table D-4 Gaseous Teole 3.6 Table D-1 "It is the qualitative judgement of the staff that the uncertainty bounds 4.
could be well over a f actor of 10, but not as large as a factor of 100".
(Page 5-72).
What is the basis for the staff's qualitative judgement?
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m Dircctor, Divicien of Licaesing Tcbruary 22, 1984 Page 3 T
5.
Some of the isotopic values given in Table D-1 are lovet by a factor of 10-100 than the corresponding release rates per reactor as given in the Table on Page B23 of Regulatory. Guide 1.BB, which are used in the NRC PWR/GAI.E con:puter code to determine the off-site gaseous doses for normal operations.
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Please provide an explanscion for :.he reduction of the gaseous release rates.
Thank you for the opportunitT to review the Braidwood Station's Draft Environmental Statement - operati:g permit stage. Your consideration of the above con:nents is appreciated.
Very truly yours, Don Etchison Director DE:RRM:j t e
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T 2-2-84 NIPC No.84-022
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Subject Draft environmental statement for the operation of the Braidwood Station, Units 1 and 2 in Braidwood. Will cmmt y.
The Co=E.ission has received your project refer-enced above.
We will begin our notification and review process immediately and contact you if an9 proble=s or issues become evident.
We have l
tentatively scheduled your project for consider-ation by our Governmental Services Committee at
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t}ieir 12 noon meeting o#
February 22. 1984
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Please use the NIPC number shown above on any communication with us pertaining to the project.
Questions on Cor.r.ission review activities should be directed to our Project Review Section.
^^03 30037 G40202 Thank you.
PDR ADOCK 05000456 D
PDR NORTHEASTERN. ILI,INOIS PIANNING COQION
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400 West Madison Street Chicago. Illinois 60606 (312)454-0400
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February 22, 1984 57ECUTfWe c0.asseTTit N.
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Ms. Janice A. Stevens Division of Licensing n -se C
U.S. Nuclear Regulatory Commission
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Washington, D.C.
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SUBJECT:
NIPC Project No.84-022 U.S. Nuclear
"" Z."~."i Regulatory Commission / Commonwealth
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Edison Company - Draft environmental
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statement for the operation of the Braidwood Station, Units 1 and 2.
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Dear Ms. Stevens:
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Your application referenced above has been reviewed under
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provisions of the federal Office of Management and Budget e - c - -.- -
Circular No. A-95 (Revised) and the Comission's present I.:.'.*O'.O. " -
areawide clearinghouse and bi-state procedures.
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The application was considered by the Commission at a meeting held today of its Governmental Services Committee.
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The finding of the Commission is detailed under the
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heading "A-95 Summary Recommendations" in the enclosed
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copies of any comments on this project we have received from local agencies, governments, or individuals are also l=,2,:,;;-. aaa c-enclosed.
This letter, any coments, and our review i......,
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statement are to be included with your final application
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to the funding agency, along with your statement that you
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You must also incIude comments
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you may receive separately from the Illinois State g;;.,. ;. -
Clearinghouse.
c;"O, Please direct any questions relating to Commission review
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Barbara Mable, Illinois State Clearinghouse f."l T ", ~
Elizabeth Hollander, Chicago DP g::;;-';;, ;,t.-~
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vy... .r... .,:3,. . q. .. ;p. .r; v.. .p,, u. s, ?*. t..' 'u. n. -~ ~ ^ ~ '" ~~ ~ ~ ~ ' ' ~ " WILL COUNTY DEVELOPMENT DEPARTMENT 501 Ella Avenue Joliet. Illinois 60433 (8I5) 727-87S7 T March 2, 1984 U.S. Nuclear Regulatcry Ccemissien Washin ton, D.C. 20555 s Attn: Director, Divisien of Licensing
Dear Sir:
Will County is concerned with the impact the water withdrawal fro =, and discharge of cooling water into the Kankakee River from the Braidwood Station will have, en the proposed Win County Public Water Supply System planned to be located downstream of the Braidwood Station. The Will County Develcpment Department is currently conducting the Win Ccunty Public Water Supply Study. The study considers the Kankakee River a price source fer possible water supply and the costs to construct and operate a system from the river win be identified in the study.
The impacts of most concern on the proposed water supply system discussed in the Dececher 1983 draft Environmental Statement (NUREG-1026) are as
~
fo nows:
1.
Degradation of water: quality from cooling water discharge to the river.
2.
Leng-term human health effects and risks associated with effluents entering the river containing low levels of radioactive discharge.
3.
Inadequate volume of river flow downstream to support the water supply system. Specifically, page 5-2, item 5.3.1 of the statement does not include the Win County Public Water Supply System as a potential downstream water user.
4 Risk of possible contamination of the water supply in the case cf power plant malfunction and emergency.
5.
Increased costs to the proposed water system due to mitigating measures that may be required to address the effects of the Braidwood Station upstream.
Please consider and incorporate where appropriate these comments in prepara-tien of the final Environmental Staternent.
Sincerely
(
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iJohn R.. GalD w,.- m
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OO:DIENTS OF JOHN F. DOEERTY TO 32.iD2100D STATION DES '(DECIMBER Ms. Janice A. Stevens Division of Licensing U. S. Nuclear Regulatory Oomaission.
Washington D. C. 20555 John.F. Doherty, of 318 Sunnit Ave.
Brirhton, Mass. 02135,-
comments as below on the DES (NUREG-1026),for the Braidwood Station. Units 1 & 2. Docket Nos. STN 50-456,457 4
COFOIENT DORERTY 1 In Appendix C, at page C-6, the fo11owin5 statement is made "To illustrate: A sin-le nodel 1000-MWe LhR operatine at at an 3 Dis caoacity facter for 33 years would be predicted to induce between 3.3 and 5 7 cancer fatalities in 100 1
years, 5.7 and 17 in 500 years and 36 and 60 in 1000 years as a result of releases o,f radon-222.*
t My concern is that the DES has not comoletely described the fuel cycle i pact 'in Arpendix C.
The concern is not impact of the operation of the plant to the general oublic.
Scecifically, the DES should contain a statenent of:
a) The ran e of number of non-fatal cancer injuries induced by fuel cycle raion-222 for trovidinr fuel for the Braidwood Station acity factor (80%) Units 1 & 2, for its nrojected cap-and licensing period (40 years).
b) The range of number of non-fatal birth defects induced by fuel cycle' rad'on-222 for providing fuel for the 3reidwood Station) Units 1 & 2, for its projected cap-acity factor (80#
and licensing period (40 years).
i COY &*3NT DCEERTY 2 4
On ?sge :-26 of the Stitement, it says, "The lower limit of the rance would be zero because there may be biolo-ical mechanisms that can repair damare caused by raiiation a: low dose and/or dose rates." (The discussion t
is of risk cf deaths fr:n cancer due to exoosure to Slant radioactive naterials, etc.)
This statement-is
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_CO?OIETTS OF JOEN P. DOHERTY TO 3RAIDWOOD ST knows but'one iten doing this.unsup7orted by reference, or docunentation,.a to include what backs this position.The Statenant should be altered T
COM.'ECT DOHERTY 3 The Stat'enent needs to clarify if in the analysis of environmental inpacts of postulated accidents any credit was riven for Applicant conpliance with any of the TMI-related requirenants of NUREG-737 " Clarification of TMI Action Plan Recuirenents".
Thank you for the opoortunity to comment.
.t John F. Doherty G
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- 524 SOUTH SECOND STREET
- SPRINGFIELD 82706 CHICAGO OFFICE - ROOM 100.160 NO. LASALLE 60601 David Kenney. Director
- James C. Helfrich, Assistant Dire: tor March 8, 1984 2.
- >;ulatory Commission l in. s -
20555 Attn:
Director, Divisien of Licensing D+ar Dir ec tor :
The De c.o r tmen t has reviewed the Draft Envirenmental Statement GE E.' r e l a t e d to the oper ation of Eraidwood Station Units 1 and 2.
Generally, we are pleased to note that major e nv i r onme n t al concerns we had identified during the early 1970s, and appropriate mitigating actions to alleviate these
- concerns, are adequately ref1+cted in this DES.
During our review of the DES, however, we did note the tendency to present general statements relative to impacts without a thorough presentation of data or references to support these r t t t a.e.- t s.
It is our opinion much more data relative to aquatic imp-acts has been collected than is presented or referenced in this DES.
Specific comments on the DES follows Section 5.5.2.2 Kankakee River On page 5-2, last parag aph, it is
- stated, "The-water quality standards also require that the d's-5erge structure must be designed to ensure
- r. s t the mixing :ene allows a reasonable zone of passage for aquatic life and must not encompass more than 25%
of the cross-sectional area or volume of flow, except in those instances where the dilution ratio is less than 3:1 (ER-OL Section 5.1))*
On page 5-13, first paragraph, it is stated, "The thermal p l umi-is projected to extend to 28% of the r:ver width in August, 33% in September, and 22%
in December--."
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S. Nuc103r Regulatory Commission March 6, 1984 These two statements appear to be in confjict1 therefore, further clarification should' be presented in the Final Environmental Statement (FES).
According to the DES (page 5-13, first. paragraph),
"the thermal plume should not act as a barrier to up or downstream movement by mobile aquatic biota."
The DES f ur ther states (page 5-13, f our th paragraph)
" Larval fish could be stressed on passage through the thermal plume; however.
---larval mor t ali ty associated with the thermal plume should not be significent."
The DES r e t i cnal i z e s these conclusions on the basis of shor t residence time in the plume and the statement " natural mcrtality of larval fish can reach more than 99%."
(page 5-13, paragrach 4).
It seems appropriate here to point out that because year class strength is determined by the success in survival of eggs and ' larval fish and natural factors alone can account for 99%
mortali.tv, additional stress on the remaining 1%
from removal by en trainment or mor tali ty from a thermal plume shoul d not be so easily dismissed.
- Here, also, the size and shape of the thermal plume may c ome into play.
If egg and/or larval crift is not evenly or randomly distributed throughout the cross section of the
- river, then there is a
possibility that a dispreportionate amount of drift is passing along the shore'of the station and subject to entrainment or thermal stress.
There may be particular species of fish more affe.cte#
than
- others, i.e.
species whose entire drift would be concentrated into the river -
area where it will be entrained or pass through the thermal plume.
For these reasons, we suggest the FES assessment of impacts en eggs and larval fish include a discussion of studies Commonwealth Edison has conducted to determine distribution of larval drift across the cross-section of the river.
We
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are most interested in learning if an analysis by J."'#U species and percent of drift already dead was conducted to a meaningful comparison can be made
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by species prior to entering the intake and/or heated water ar ea. and af ter passing through these he:ards.
If these s tudies have not been conducted at this site then the FES should include a
cefinite statement relative to the need for such~
studies after plant start-up.
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v U..S. Nucioer Regulatory Commiscion March 8,1984 Based on the information presented in table,'5.4 (page 5-16), and contrary to impingement losses at plants on other rivers where numbers of gizzard shad are commonly 50-80% of the loss, sport fish comprised the large share of impinged fish - 17.8%
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of the total. number were rock bass, 11.1% channel catfish, 6.4% bl ue gi l l, 8.2% smal lmou th bass, 6.1%
white
- crappie, 4.2%
black
- crappie, and 2.4%
pumpkinseed for close to 60% of the total number impinged.
Gizzard shad numbers were only
.4%
of the total.
We ar e aware that imr ingement mor tal i ty of large numbers cf forage fish, such as gi::ard shad, are I.
dismissed es:h year without much concern because of their gr e a t r ecr oduc t i oe potentsal; however, predator fish do not have that same potential.
G i:: tr :
sr,+ c f ma l e s a"er age 375.000 eggs per fish as cemeared to an average 5,000 per female rock bass.
Thus a loss of tens of thousands of shac each year from impingement is of much less concern than the loss.cf thousands of preda tor / spor t fish such as rock bass.
The assumption of highetst mortality in winter (page 5-17, first paragraph),
again ignores' d i f f e r e r.c e s-between species or families of fish.
During closed cycle operation of the Quad-Cities Station in
- 1976, 63%
of the shad impinged (shad were 66% of total impingement) were lost in
- December, January, and February.
However, only 14% of the annual loss of crappie occurred in the December-February period.
It seems logical to expect that impingement at Graidwood may actually be much higher outside the winter petiod. since it includes such a
small proportion of shad and large proportions of -
centrarch. ids such as crapples.
For the accue ressens. we suggest the FES fully discuss Commonwealth Edison's commitment to concuct 12 month impingement entrainment studies after plant s t ar t-up.
We look to this studv to provide answers to the aforementioned conceece.
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".T' Section 5.6.2 Aquatic i
The DES (page 5-15) discusses the pallbdI:s'aner.
u The document c or r e c t l y points out that this fish.
is "a rare species in Illinois" (page 5-18).
In fact.
accoroing to Smith in The Fishes of Illinois, it "is one of the rarest and leest known emerican fishes.*
Fcr this reason, the discoveri' of more than 17 indieicuals of this species at one of the Bra s dwood mon a tor e reg s ta t i ons i s notewor thy h
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U. S. Nuclear Rogul atory Ccani s s icn March 6, 1984 and deserves further attention and study.
The'FES shoule address Commonwealth Edison's spej i f i c plans for river monitoring and s tu dy of this species prior to and following plant start-up.
The Department appreciates the opportunity to comment on the DES.
Sincerely,
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David Kenney DK:RuJL: ale cc Commonwealth Edison Co.
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<p g ENVZONMENTAL PR3TECTION..GENCY nEcios v 230 south DEARBORN ST CHICAGO, fLUNO45 80604 4 meOi REPLY TO ATTENTION OF; NEPA-DE-NRC-F06018-IL
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MAR 121984 (84005)
Mr. B. J. Youngblood, Chief Licensing Branch No.1 Division of Licensing United States Nuclear Regulatory Commission Washington, D.C 20555
Dear Mr. Youngblood:
We have completed our review of the Draft Environmental Impact Statement related to the Operation of Braidwood Station Units I and 2 in Will County, Illinois.
This nuclear power plant will employ two pressurized water reactors to produce up to 6850 megawatts of thermal energy. Two steam turbine-generators will use this heat to provide 2240 megawatts of electrical power. Exhaust steam will be condensed by cooling water circulated from a cooling pond. Makeup and blowdown will be taken from a discharged to the Kankakee River.
Based upon our review of 'the Draft EIS and reference documents, we do not have any major objections to the operation of the Braidwood Station however, addi-tional information should be provided in the Final EIS regarding the radioactive.
waste treatment systems and maintenance of the soil erosion control programs implemented at the time of construction. We have rated our detailed coments on the Draft EIS, which are attached, as LO-2. Specifically this means that we have no objections to the proposed operation of the nuclear power station and that additional information is necessary regarding the topics cited above.
We appreciate your.providing us the opportunity to review this Draft EIS.
If you have any questions regarding our coments please contact Mr. B11.1 Franz at 886-7500 (FTS) or 312-886-7500 (Comeretal).
Sincere you rs, 6
__ O s larry G. R
, Deputy Director Planning Management Division Enclosure sDo ' 54 t/S7 g,t
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U.S. Environmental Protection Agency Coments on the Draft Environmental ImpRegion V's act Statement Related to the Operation of the Braidwood Station Units 1 and 2 The preposed action is the issuance of an operating license to the Comonwealth Edison Company (Ceco) for the startup and operation of Units 1 and 2 of Braid-wood Station, located near the Kankakee River in Reed Township Will County, Illinois, 2.3 km (1.4 mi) south of Braidwood and 32 km ' south-southwest of Joliet.
The plant will employ two pressurized water reactors to produce up to 6850 mega-watts of thermal energy (MWt).
Two steam turbine-generators will use this heat to provide 2240 MW (net) of electrical power capacity. The maximum design ther-mal output of the units is 7130 MWt, with a corresponding maximum calculated electrical output of 2330 MWe, The exhaust steam will be condensed by cooling water circulated from a cooling pond.
Makeup and blowdown water (i.e., water to replace that lost by evaporation and water to control the buildup of dissolved solids, respectively) will be taken from, and discharged to, the Kankakee River.
Radiological Impacts The Draft Environmental Impact Statement (EIS) description of the radioactive waste treatment system and the Nuclear Regulatory Comission staff's evaluation was insufficient for a detailed analysis.
i Evaluation Report (SER) which has not been cogleted.The Draft EIS referenced the We recomend that the Safety Evaluation Report be completed prior to the issuance of the Final EIS in order to permit thorough evaluation of the radioactive waste treatment system.
In view of the concern for development of nuclear waste disposal sites for solid waste. the section of the report on " Radioactive Waste Management" in the SER needs to be completed. The Draft EIS refers to Section 11 of the SER for the presentation of the staff's detailed evaluation of the solid radioactive waste systen and its capability to accomodate the solid wastes expected during normal operations As well as emergency situations.
However, SectioD 11 of the SER has not been completed.
Based upon our review of the available information it appears that the radio-active waste treatmnent systems are capable of controlling emissions to levels such that, when the direct radiation is considered, operations will still be within the EPA Environmental Radiation Standards, 40 CFR 190 The Draft EIS does not address the problem of storing the high level waste.
The impact of "away from reactor" and/or "at the reactor" storage needs to be controlling emissions to levels such that when the direct radiation is consid-ered, operations will still be within the EPA Environmental Radiation Standards (40 CFR 190).
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f In view of the concern for development of nuclear waste disposal sites for solid waste, the section of the report on " Radioactive Waste Management" in the SER needs to be completed.
The presentation of the staff's detailed evaluation expected during normal operations, including anticipated operational occurances needs to be made.
Water Quality Impacts During construction of the Braidwood station erosion control programs were developed and implemented by the Commonwealth Edison Company.
As part of the scoping process for this Draft EIS, we participated in a site visit to the Braidwood Station.
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While on this site visit, we noticed several areas where the measures to control soil erosion had failed and rill and gulleys were the result.
Islands in the cooling pond were also void of vegetation and were eroding. Convenwealth Edison needs to better maintain the soil erosion program.
Minimization of suspended solids in the cooling pond should also improve the ef ficiency of the power plant's cooling system.
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