ML20101Q828

From kanterella
Jump to navigation Jump to search
Forwards Comments on Des,In Response to 841116 Fr Notice
ML20101Q828
Person / Time
Site: Vogtle  Southern Nuclear icon.png
Issue date: 01/04/1985
From: Foster D
GEORGIA POWER CO.
To: Adensam E
Office of Nuclear Reactor Regulation
References
GN-506, NUDOCS 8501080351
Download: ML20101Q828 (22)


Text

Georgia Power Company Route 2. Box 299A

-. Waynesboro, Georgia 30830 Telephone 404 554 9961. Ext 3360 404 724 8114. Ext,3360

- D. O. Foster Georgia Power ne a U * #'*I** 'I' C YSIE*

Vogtle Project January 4,1985 Director of Nuclear Reactor Regulation Attention: Ms. Elinor G. Adensam, Chief Licensing Branch #4 File: X88E03 Division of Licensing Log: GN-506 U. S. Nuclear Regulatory Commission Was,hington, D.C. 20555 j NRC DOCKET NUMBERS 50-424 AND 50-425 i

CONSTRUCTION PERMIT NUMBERS CPPR-108 AND CPPR-109 V0GTLE ELECTRIC GENERATING PLANT - UNITS 1 AND 2 COMENTS ON DRAFT ENVIRO MENTAL IMPACT STATEMENT i

4

Dear Mr. Denton:

Attached are the comments of Georgia Power Company on the Draft

, Environmental Impact Statement related to the operation of Yogtle Electric Generating Plant, Units 1 and 2. These conmients are submitted in response to the Federal Register notice of November 16, 1984. The attached comments are in two parts. The General Commients address monitoring programs proposed in j- the DEIS or ongoing programs. The Specific Counnents address different

!: portions of the DEIS which we feel are in error or need clarification based on i the Operating License Stage Environmental Report and other material submitted i, to the staff.

If you have any questions concerning the attached comments please contact us.

Yours very truly, F

l. D. O. oster DOF/WLB/sro Attachments cc: M. A. Miller R. A. Thomas J. A. Bailey L. T. Gucwa G. F. Trowbridge, Esquire G. Bockhold, Jr.

J. E. Joiner L. Fowler

[ 8 C. A. Stangler )

obo

  • l l

Coments on Draft Environmental Impact Statement related to the operation of Vogtle Electric Generating Plant. Units 1 & 2 i

4 The following are Georgia Power Company's coments on the Draft Environmental Impact Statement (DEIS). The coments are presented in two sections. The first section addresses general comments concerning the staff's findings. The second section addressess specific passages in the DEIS by chapter and section which we feel need correction or clarification for consistency with the Operating License Stage Environmental Report (ER-OL) and l_ other documents submitted to the staff.

General Comments Georgia Power Company agrees with the staff's overall evaluation of impacts attributable to the operation of the VEGP and its associated transmission lines. We do not agree that certain monitoring programs recomended by the staff in the DEIS are necessary. Specifically, we feel that the monitoring and mitigation proposal for transmission line noise is unjustified. We also feel that the proposed program for monitoring of damage attributable to cooling tower drift is unnecessary since our estimates of the i

range of deposition rates fall below rates listed in Regulatory Guide 4.11 as a threshold below which monitoring should not be required. In addition,

monitoring programs for endangered species along transmission lines have been

. completed.

Transmission Line Noise.

l The staff has concluded that noise impacts at one homesite along the transmission line corridor would produce annoyance levels which would be unacceptable based on Composite Noise Rating (CNR) criteria. This conclusion was based on calculations made by the staff assuming a background noise level of 24 dBA. Based on these calculations, the DEIS indicates that the staff i

will require that the appifcant conduct a monitoring program and determine

what mitigation actions, if any, are necessary to reduce impacts to acceptable levels. We do not believe that the inclusion of a monitoring and mitigation program is justified based on the following
1. A monitoring program is unnecessary since sound levels of 55-58 dBA I have been measured under 500 kV transmission Ifnes during rain. This information was provided to the staff in response to the NRC question E 290.14. Further monitoring would only serve to confirm the result of these l measurements which have already beer confirmed by studies conducted by others.

i

2. The staff's conclusions are based on an assumed background noise level of 24 dBA taken at location 4 on May 14,1974. Figures 5.22 and 5.24 of the DEIS show that location 3 is closer to the home of concern. In addition, as noted in section 5.12.1 the staff used the lowest measured ambient noise level i

for each location as the basis for Table 5.18. It would be more appropriate to use an average noise level at the home which should be about 30 dBA in j making calculations.

I h

- , , . ~, -- ._._,___.._m.__,.,,.%.,,..,#_..~,,,,_m-,mm_,m, ym ,,,._w, .-,m,_%y _

.-w ,,c ..,w - r , , m,,.y--

~

m 2

3. During heavy rains, the sound of rain itself raises the ambient sound level and masks the transmission line noise. EPRI has reported that AC corona '

noise is not unlike rain noise itself and may be difficult to distinguish from rain noise. Because of the masking effect of the rain noise, and because people are normally inside during rainy weather, and since the home of concern has a tin (metal) roof, line noise will not be an annoyance during rain.

4. The EPRI Transmission Line Reference Book suggests that transmission line noise levels would remain higher than ambient for 1 to 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> after rain stops as opposed to the "several" hours indicated in the staff assessment. In addition, the duration of higher noise levels will depend on, among other things, the loading on the ifne. A higher loading will result in a shorter duration since the moisture will be evaporated from the line more rapidly.
5. Fog, a foul weather condition which may lead to transmission line noise, occurs infrequently in the site vicinity. Section 2.3.2.1.5 of the FSAR indicates that fog with visibility less than 1/2 mile occurs only 1.21%

of the time. Analysis of the 5 years of data from the Augusta Airport indicates that visibility less than 1/4 mile occurs only 0.4% of the time. In addition, these conditions occur predominantly in the winter and fall months.

Dense fog conditions which could be expected to lead to transmission line noise occur only 30-90 hours during the year with these conditions occurring primarily in the winter and fall months when people are likely to be indoors.

Wet snow, which may also lead to transmission line noise, is even less likely to occur than fog because of climatological conditions.

6. Studies have shown that it requires several hours of fog to build up moisture on the lines which could produce an audible noise. Although several hours of fog may occur at any one time, the above data (5). indicate that the frequency of such episodes is quite low.
7. There are no regulations which specify noise level. The Environmental Protection Agency recommends that Ldn less than 55 dBA be achieved in residential areas and farms and other areas where people spend widely varying
amounts of times and where quiet is a basis for use. The adverse weather
condition sound level predicted by the staff is not significantly above the ,

j EPA recomendation. In addition, it has been proposed that Ldn should be computed on an annual basis taking into account those periods of fair weather in which the line does not make noise. With the ambient sound levels (24-34 l

dBA) measured'around the plant Vogtle site and the low operational levels 2redicted by the NRC staff (29-40 dBA) it is concluded that annual Ldn would

)e much lower than 55 dBA.

8. The staff assessment of annoyance using the modified CNR criterion did not account for the fact that line noise will be a problem only a very small i part of the total time in a year. The modified CNR procedure properly l includes a correction for intermittency, the ratio of source "on" time to the reference time period. If the intermittency is accounted for, the modified CNR rating predicts "no reaction" or " sporadic complaints," rather than j " vigorous community action" as cited by the staff.

I s

--et'*r' #* v Mv W epW ge m-dce_ ,, . WWgwe e t-e -m eesyy mwyr mNgey'pwNw gpe egy qg--i=pwm_ ,w++g-aM- g ering- n-e w-t-=wvg-ryqei+NW, i,p*z f-W u+gN Wwg a--

3

9. The EPRI Transmission Line Reference Book also reports that transmission line noise decreases as the conductors age. Over a three year period, aging is likely to produce noise reduction of 4.5 dB to 11 dB, making line noise even less of a problem at the home site.

Based on the foregoing discussion, we feel that the monitoring and mitigation programs are unjustified. Monitoring programs have been conducted which demonstrate the level of sound beneath transmission lines and these studies indicate close agreement with the staff estimates. Additional monitoring will only serve to verify those numbers. The levels of background noise upon which the staff based its calculations and recommendations for a mitigation program are unrealistically low. Finally, mitigation is unnecessary because the weather conditions which could cause transmission line noise occur very infrequently and the noise levels decrease as the conductor ages.

The following references apply to the above discussion:

Transmission Line Reference Book-345 kV and Above(2nd Edition), EPRI, 1982.

D. N. Keast, " Assessing the Impact of Audible Noise from AC Transmission Lines: A Proposed Method." IEEE Transactions on Power Apparatus and Systems, Vol . PAS-99, No. 3, pp.1021-1031, May/ June 1980.

Drift Deposition Section 5.14.1 of the DEIS indicates that "To monitor for possible impacts of drift on vegetation, the applicant will use stereo, false color, infrared aerial photographs of the site. The details of this program will be specified in the Environmental Protection Plan that will be included as

- Appendix B of the operating license." Georgia Power Company has made no such commitment and monitoring as described in section 5.14.1 is unnecessary.

The staff evaluation of the impact on terrestrial resources due to cooling tower operation (Section 5.5.1.1 of the DEIS) does not provide a basis .,

for requiring such a monitoring program. The staff has indicated that applicant's estimates of peak deposition rates are reasonable based on its review of material submitted in the ER-OL and results of other cocling tower modeling studies. These estimates, as noted in material submitted to the staff by D. O. Foster's letter of September 25, 1984, provided a range of drift deposition rates which varied from 0.7 to 17 lb/ acre per year onsite and 11.2 to 14.7 lb/ acre per year offsite. As noted in the September 25, 1984 submission, the upper level of those ranges were reported in the ER-OL. It should be noted that the upper level of those ranges included all solids in the drift and thus the impact is far below the 90 lb/ acre per year of sodium chloride deposition which may reduce' agricultural productivity. In addition the upper levels are below the 18 lb/ acre per year offsite deposition threshold of solids contained in NRC Regulatory Guide 4.11 for requiring monitoring.

i l

~ - - - , , , , , - , - - - - , - -.,,.,-,---.,--.n....-.--,---n- _ - - - - - - . - ~ . , - . -

4  !

\

The staff has estimated in section 5.5.1 that the solids deposition rate at a distance of 0.6 miles from the cooling towers is expected to be below 45 lb/ acre per year. The staff also estimated that if all the drift were deposited within 0.6 miles of the cooling towers it would result in a deposition rate of 42 lb/ acre per year. This estimate is a very conservative deposition rate and would in no way resemble what will happen in the real world considering the effects of dispersion and meterology. The staff provided no basis for the 45 lb/ acre per year at a distance of 0.6 miles from the cooling towers. These estimates do not provide any basis for the monitoring requirement contained in section 5.14.1 of the DEIS.

Georgia Power Company agrees with the staff's conclusion in section

i. 5.5.1.1 that " Salt deposition rates from both types 'of cooling towers at '

Yogtle is expected be far below the levels that can cause reduced productivity

of plant species, and no signf ficant adverse impacts on vegetation or wildlife iare expected." (emphasis added) We also agree with the staff's conclusion that "Because the sodium chloride deposition rates expected at Yogtle are so much less tnan the critical value reported in the Environmental Standard Review Plan (NUREG-055), the staff concludes that the irnpact will be negligible."(emphasis added) Based on these conclusions drawn in section 5.5.1.1, the staff has not provided any basis for the requirements in section 5.14.1 to menf tor for possible impacts of drift on vegetation.

We encourage the staff to reevaluate the material contained in section 5.5.1.1 relative to their expected drift deposition rates in light of the material which has already been submitted in the ER-OL, and D. O. Foster's letter,of September 25, 1984. In addition, the staff should consider the i

racommendations of Regulatory Guide 4.11. These factors will demonstrate that

monitoring is not required.

Endangered Species

~

Section 5.14.1 of the DEIS notes that " Surveys of power line routes with regard to endangered species is continuing in several locations." Section i 4.3.5.1 of the DEIS indicates that "If the remaining ground surveys identify I habitat potentially impacted by the transmission lines, then the applicant .

must comply with the conditions stated in section 6.1 (1) of this statement."

These surveys were relative to the red-cockaded woodpecker. Section 4.3.5.1 ,

also indicates that the VEGP to Thalmann power.line would traverse the l

geographic range of the eastern indigo snake (a threatened species) and that  ;

j no surveys had been conducted for this species along the power line route.  ;

i l

Georgia Power Company has completed its surveys for all of the transmission lines associated with the VEGP project for the red-cockaded

! woodpecker and other endangered species. As noted in D. O. Foster's letter of l

September 14,-1984, several areas around the Piedmont National Wildlife Refuge were to be investigated for possible red-cockaded woodpeckers. This activity a hasabeen completed and no suitable habitat or colonies were identified. In addition, Georgia Power Company biologists have walked the VEGP to Thalmann transmission line. During this survey, no evidence of indigo snakes were observed on the right-of-way.

L. . . .

Ck u _ ... ;._ _ . . , _ , _ . _ , _ _ , _ , _ _ _____,...,___,__,.,..-_._._,_._____.,

i 5

4 Specific Comment _s 1

Sumary and Conclusions, page viii, item (c)

The two endangered species referred to in section 4.3.5 are the red-cockaded woodpecker and the indigo snake. The above comments on endangered species addresses the occurence of the red-cockaded woodpecker. In addition, the indigo snake is threatened.

Summary and Conclusions, page ix, item (j)

. . .Section 5. 5.1. 3. . . " shoul d read ". . . Section 5. 5.1. 2. . . ". ,

Summary and Conclusions, page ix, item (m).

The allowable limits for chlorine in the discharge are contained in the NPDES permit.

Chapter 4 and 5 change "Thalman" to "Thalmann".

Section 4.1, page 4-1, third paragraph .

j Note that the circulating water system will be chlorinated continuously for a period of up to a week / month during Corbicula spawning season. At other times .

the chlorination will be intermittent.

Section 4.2, page 4-2, second sentence.

Should read "... and the addition of an equipment building from ..."

Subsection 4.2.3.1, page 4-3, third paragraph, last sentence.

'~

Chan 3 gpm)ge ..." ".. 5.05 x 10 L/ min (1333 gpm)..." to ".. 3.18 x 103 L/ min (840 -

Note that, ER-OL Subsection 3.3.3 will be ammended to reflect this correction and thus will agree with the ER-OL figure 3.3-1, sheet 2 of 3. .

Subsection 4.2.3.2, page 4-3, first paragraph, first sentence.

Should read " Chlorine will be added to the circulating water system at the station intake structure makeup water pumps and the circulating water system intake structure as a gas..."

- Second sentence.

T Change "... at the natural draft cooling tower blowdown lines." to "... at

- the blowdown sump follouing dechlorination." This sampling point is designated in the NPDES permit.

4 Third sentence.

Should read " Intermittent chlorination at the circulating water system intake structure will be ..."

6 Fifth sentence.

.Should read "During the Corbicula (Asiatic clam) spawning season, chlorination at the river intake structure makeup pumps may be continuous...

After the sixth sentence.

Add "In the winter when chlorine demand is low, a single weekly injection period is required.

Last sentence.

4 ,

Should read "The circulating water system intake structure is equipped with

. three 10,000 lb/ day capacity chlorine evaporators in series, with one being '

used as a backup. (ADD) The river intake structure is equipped with one 12,000 lb/ day chlorine evaporator."

(NOTE): The ER-OL Section 3.6.1.1 will be amended accordingly.

Subsection 4.2.3.2, page 4-3, second paragraph.

Change ". . 1435 lb/ day . . . " to ". . 1425 lb/ day . . . "

Subsection 4.2.4.4, page 4-5, last sentence.

Change ". . 2.4 m (7. 9 feet) . . . " to ". . 1.4 m ( 5 feet) . . . "

Subsection 4.2.6, page 4-6, first paragraph, second sentence.

i The low volume waste streams and sewage plant effluent are treated and combined in the waste water retention basins then discharged to the blowdown sump where they are combined with the cooling tower blowdown.

~~ Subsection 4.2.6, page 4-7, first paragraph, last sentence.

Flush water, which does not involve the addition of chemicals, will be discharged based on oil and grease and turbidity limits as opposed to the NPDES limits for low volume waste.

Subsection 4.2.6, page 4-7, third paragraph, last sentence.

Should read " Previous operating experience has shown (ER-OL Section 3.6.4.1) that these solid wastes ..."

Subsection 4.2.7, page 4-8, first paragraph.

The route for the South Carolina line has been selected and preliminary engineering studies are being conducted. The route will involve approximately 2.5 miles of line on the Georgia side of the Savannah River and approximately 18.3 miles on the Savannah River Plant. The right-of-way for this line will lbe 100 feet wide. The line will occupy approximately 25 acres of wetlands primarily in 1000 to 2000 foot stretches associated with Four Mile, Branch and Steel Creeks. Most of these wetland areas can be spanned by the transmission lines by placing towers outside these areas. South Carolina Electric and Gas

. w

, . _ _ . . . _ . , ___.,__, m.___.,,,,_._,..,_,.._,,,__,__-,..,,,_.m_...-_m.,-,___ _ - . . . _ , . .

7 (SCE&G) will be responsible for constructing the line. SCE&G will be required to obtain an Environmental Compatability and Public Convenience and Necessity Permit from the state of South Carolina. The application for this permit will include biological evaluations as well as cultural resource evaluations. This process has been initiated by SCE&G. A copy of the application will be provided to the staff for your information when it is submitted to the state of South Carolina.

Subsection 4.3.1, page 4-8, second paragraph, second sentence.

Change ". . 18. 5 feet . . . " to ". . 219. 5 feet . . . "

Subsection 4.3.1.1, page 4-8, third paragraph, third sentence.

Change ".. 5000 feet ..." to ".. 5500 feet ..."

Subsection 4.3.1.1, page 4-11, paragraphs three and four.

These paragraphs appear to be out of order and should be moved to Subsection

4. 3.1. 2.

Subsection 4.3.1.1, page 4-11, third paragraph.

Should read "None of the ground water users are located downgradient of the onsite aquifer system flowpath of a release from the powerblock area as shown on figure 4.11, and thus will not be affected by any potential radioactive liquid release at the Vogtle site.

Subsection 4.3.1.2, page 4-11, first paragraph, third sentence.

Should read "The Blue Bluff marl is a clayey marl and is the load bearing

_ hori zon, . . . "

Sixth sentence l Change ". . . l ower Li sbon. . . " to ". . . Li sbon. . . ".

l l Second paragraph, page 4-12, third and fourth sentences.

Should read "Although the Savannah River is in hydraulic contact with the deep aquifers, it is not a p'otential pathway to these deep aquifers. The deep aquifers discharge ...

Third paragraph, last sentence.

Delete "... is shown in FSAR Figure 2.4.12-7 and ..." Add to the end of the L sentence "... and the contours of the water table aquifer are shown in FSAR l Figure 2.4.12-7."

Note: The OL-ER Figure 2.1-10 from which DES Figure 4.11 was reproduced has been updated and is included as Attachment 1 to these comments. Attachment 2 l 1s a figrue showing the flowpath of the water table aquifer at the Vogtle j site. These figures will be added to the next ER-OL amendment.

l

)

i 8

Subsection 4.3.1.3, page 4-13, third paragraph, second sentence.

Change "... demineralizer ..." to "... demineralized ..."

Subsection 4.3.2, page 4-14, second paragraph, third sentence.

Should read "... over the period of 1979 through 1983 ..." Note that levels of manganese referenced here are not listed in Table 4.8. Also, references identified here are not included in the reference list at the end of this section.

Subsection 4.3.3 page 4-14, second pa agraph, first sentence.

Change ". . 1070F. . . " to " . . 1060F. . . "

Second sentence.

Change 56 days to 54 days.

Third paragraph, last sentence.

Change " . . 1979. . . " to ". . 1972. . . "

Table 4.8, page 4-45, last footnote.

Should read "... Question E291.1."

See Attachments 3 through 6 for corrections to Figure 4.3 and Tables 4.1, 4.2, and 4.5.

Subsection 4.3.4.1, page 4-15, fourth paragraph, third sentence.

Change ". . . Tabl e 4. 9. . . " to" . . . Tabl e 4.10. . . "

Subsection 4.3.4.1, page 4-16, third paragraph, first sentence.

Should read "After becoming aware that the Ebenezer Creek Swamp was a National Natural Landmark, the applicant ..."

Page 4.16, footnote.

Note that Dr. Bozeman now works for the Georgia Department of Natural Resources.

Subsecticn 4.3.5.1, page 4-20, fourth paragraph.

Surveys for red-cockaded woodpecker are complete and no sites were found as noted in the General Comments.

Subsection 4.3.5.1, page 4-21, first paragraph The area in southeastern Georgia along the Vogtle to Thalmann transmission line was walked by Georgia Power Company biologists and no sign of the indigo snake, a threatened species, was found along the right-of-way.

9 Subsection 5.2.2, page 5-3, first paragraph.

There will be two towers inside the Landmark boundary. The 195 foot towers located at station 124.00 and station 135.00 are inside the Landmark. The 195 foot tower on the south bluff and the 175 foot tower on the north edge are outside the Landmark. See item A, page 2 of D.O. Foster's letter of October 10, 1984.

Subsection 5.4.2, page 5-10, third sentence.

Change " . . . Section 3. 7. 2. . . " to " . . . Section 3. 7. 3 tha t the s tate o f. . . "

Subsection 5.3.1.1, page 5-5, second paragraph, fourth sentence.

Should read ". . 3 m/s (10 fps) . .. " to ". . 1.5 m/s (5 fps) . . . "

Subsection 5.3.1.2, page 5-5, first paragraph.

Should read "...that draw water from the Cretaceous aquifer system ..."

Subsection 5.3.3, page 5-9, third paragraph, first sentence.

Change " powerhouse" to "powerblock" '

Subsection 5.5.1.1, page 5-11, last paragraph.

The Staff should provide references for the other cooling tower modeling studies reviewed.

Subsection 5.5.1.2, page 5-13, second paragraph, last sentence.

_ This sentence should be deleted because NESC guidelines do not specifically address the level of field strength within a particular right-of-way.

i Third paragraph, next to the last sentence. ~

Change ". . . Section 5. 6.3 . . . " to ". . . Sec tion 5. 5.1 . . . "

Subsection 5.9.1, page 5-21, third paragraph.

Change ". . .Tabl e 5.16 . . . " to ". . . Tabl e 5.17. . . "

Subsection 5.9.3.1 (1), page 5-25, fourth paragraph, second sentence Change ". . 160 . . . " to ". . 77. 3 . . . " (See FSAR Table 12.4.3-1 ).

Subsection 5.9.3.1 (2), page 5-27, second paragraph, last sentence.

It is not clear at what location the dose rates are expecated to be less than 5 mrems per year. ER-OL Section 5.2.4.3 states the dose rate at the site boundary will be 1 millirem per year.

10 Subsection 5.9.4.4 (3), page 5-41, next to the last sentence, should read..."for two emergency planning zones (EPZs)..."

Subsection 5.9.4.5 (2), page 5.51, third paragraph, last sentence, should read

"... plant (see FSAR Figure 2.4.12-7)."

Page 5-53, first equation.

Change ".. 693 ..." to ".. 0.693 ..."

Page 5-54, Items 2 and 3,.

Change "... Pathways ..." to "... Pathway ..."

Subsection 5.9.4.5 (6), page 5-58, first paragraph, first sentence.

Change ". . 16P . . . " to " . . . P/16 . . . "

Page 5-60, fourth paragraph, fourth sentence.

The minimal expected losses ranging from $0 to $44 per reactor year are not found in Table 5.16. The FES should provide an appropriate reference.

Page 5-68, first paragracj , next to the last sentence.

Should read " ...in the ER-OL (Table 2.7-1) ..."

Subsection 5.14.3, page 5-72, first paragraph, fifth sentence.

- Note that this paragraph should be written in past tense. Also, note that according to FSAR Table 2.3.2-2, the system accuracies for analog recording are within the Regulatory Guide 1.23 specification.

Page 5-72, second paragraph, first sentence should read "Four years of meteorological data (December 4,1972 to December 4,1973, April 4,1977 to April 4,1979 and April 1,1980 to March 31,1981 were provided . . . "

Third paragraph, first and second sentences.

Should read "The applicant has upgraded ... The upgrade included ... and includes measurements ..."

Third paragraph, second sentence.

Change "133" to "33"

, . , . - - - - . - - -m , . .y - - . , . . - - - -.,,-, -- ----- e e. .m.,

11 Table 5.3, page 5-106 The maximum deposition on land for Beaver Valley Unit 2 should be 2.4 kg/ha/ year (2.1 lb/ acre / year). This is based on the 9.9 lb/ acre / year maximum value reported for Units 1 and 2 in ER-OL Table E290.8-1 and assuming that the salt deposition attributed to each unit is proportional to its emission rate.

An annotated copy of Table 5.3 provides additional corrections in Attachment 7.

Subsection 6.4.1, page 6-2, first paragraph.

Note that the total annual avoided cost would exceed $500 million (constant 1987 dollars). This projection is based on a capacity factor of 63%-66%. The response to NRC Question E320.1 justifies the use of this capacity factor.

Current studies indicate this capacity will rise to 69% (based on an effective forced outage rate of 18.4% and a maintenance of 8 weeks per year), and is supported by a demonstrated availability of nuclear units on the Southern electric system for 1983 of 69.9%.

Subsection 6.4.2, page 2, first paragraph.

Same comment as above regarding the capacity used.

Table D1, page 4 and 5, Table D6, page 10.

Annetated cortes of these tables are provided as Attachments 8 through 10.

h

. - , , . ._. . , ..c.. ..,..so...__. -.,._.. - , , . . . - , _ , ,.., ,., - . . , , - - ,.e

T. _

h x4Sr ND E

T I

S N

r OS .

e M 0 f

NE 1 iu IT qe)d S 1 Am wo , SY .

nfl NS 2 a nF O is o IR A

eC t(

r f-

- ,- ), ,

TE CF E

R U

, / EI G

" - ., RU I 5 y IQ DA F

  • _ ~

~

~ $ ,L W

(,

~

- ' 3g,. 3mlJ4 ? .

\3 p

o O

L

, s Q 3' F hQ U

Q!si

')'n Na 1 Q.A'}/ .S ' N ii ' T N

f,c l ,

h

/

[c 4'g 1

h^ f ,\ .

- A L

P G

N aN1iX Q$

. I 46 g

/

1h

- T A

RT

! Whr L ._

=M  :

a_

y EU

\ ' =

Q .. o

- / Xga]R g h"

,w ,yGf'/b I I ,

' ,K \- e -

f'

/ -

i -

_)s ly S

. r

['

g c, .

's -

're ' 5~

I.

%~yp-f -

A z _

[f ._ ,

s

-. [I g/. [/ .

f* ,,?

3 .h r l,

4 }\,g'

( 7, - s gy e 4' " i q' (f

! h j'-

/ N Dy ,\ s w I 5_

- 43[,

'l y'

0),

d P

a W=

[ / g ~

' m,-Wn , *1

.G l

Y 3 i

g r

o e

N I' g' ,i

\

G M ,Wmb. -

di _ -

\'

(\-

w a

s

. . . ~

. m a

~

~

9-3 3 _

4

e

! . 85 9 (O$

. 13Ei

  • 3 3 g 3%

I  !$

o>

2 it .- l'  !;8 M i i*

7

!!s#

3 $1I r zi l .

8- 8 c5

~f'5*i r;'e

$ E S;2 $

eegi

}.

h

=

o

! kN

=8<

E e,

hd --["3 E 8

.2 e ,' n.

ji $ $ k c c h a$ 3 z e l ; i ~- 118 rs, .

t;3. o. 3 w

o si=== . .-

Ei b E h !! 5 * / /h g j

~'

N

  • ' Y , /f ,, fg

" - ' jr W30@yg

.. . di

' /,. / 3

./ L er v

)l\'N k -

. x 'e

/ (

4 v' & >i pD3- c1n g \' M,n/4Q e ~

y 94x, ,Qv \ .. .

, y, i V I ~ < 1\ .a l ' W f' ]

r /Q/e),!$yf ' ,)!\ ~yY i' ' -

)f' {

l.A)LO.,,a,y;,/ V-p a

,t/ &n

/ v/W L t

.wyk.tq.;; s c  : n .1n:+ y.

1 . ,~ . 2.l

, / , .  ;;;55 i 7wn\,/ &\(f)ph y L) f m C n w m.sm :

7n,:?)u 9N n l mhtYrY

-' m

&}'rl.%,'N 2 Tbg __; . -.s.%

3m=

kh W \Q $l }(

ll Y c/m  ?'

%$v & J'.%y/,T$m eao V An W.(?/ '\. llllr4 %

0 _}L.,.

% w fifSti s f l m(y-l?ll W^

x- r . x..n %,%+ l.

!'!* ' %. ' O.m%kk\\\

8

_fff

.si f.. H Epg s/

vyg c jg p#,m\ &y3r^.;.pg'%gpj! PQg:

w b.:. y / ) l v~

$ E [, d ,M

, ai . ,

9 .

/j# 'Npi$v',,i 'I; a

a,l

- .',0;

's eO@klu

/~n g ; t e .:, .

sg,a c _s\

k ,["o e

~

( }i,

~

l_ <

n-

///

\

37\) A 4 ; , ! j#

- /,,i, II a C n

i\

\ y .:

/

\

  • h\p ,., k .N

&y' h' * ...',,..Q j:y% ;As i

s9 D ' ' '{j s D'l f/:$:h':+.Q,.o? s. ,. j. .

0

}ff y avi%ik r  : 3& uni _

- y i

, (C.kPme%h q HieJett HAleWas t f f

MeSLEtt ahttstat Maett WP WWa1E 80 /'"%

IHEalMENI b

, }

pg(gg si a g

- n.i uP--., --

.L os. .E.s m n .u,, a,..... . w a s . ..

- a. t ct  ;

VE r.P g

2-UNil Pi ANI I

l l

..sa . a,,, n.., l

. on . . ., I ,

wa%T p I NUCL E AR ,

I g

SE RviCE e COOL ING (g2) l SYSTEM E SaPJ T ARY l ,

I y W AST E I l '

f@ '9--*c'a';,"',tla' O0 l SYSf E M

- l SANI t aR Y I waEI E s R

RIVEN TREAIMEN1 '"""I I O ** I i P1ahl ' " "

S a"5tN' ' l' t

.__ ' 'r { l g ,

[

do' - h- BL(hvuu,wN sou

n I

l T l p 5'g"'# _. ,g . - - _ _ _. _ J r,p

+/

DesCrtation m, p go,,4 Avg flow (gpsi) Gestrip t iuri N . ( 10 A*9 F lows (97) g 12:ys) ( 90a)

  • 2 manEup wfLis it wELL av a tius Pr usE' 2200 ea0 11 C'aculatino CootnG TowEn stowoowse Pf a Towf. . essPO so O -

2 wasCE a= Ecus wantup warEn soa vf GP tat 2 CYCLIll Iar a CvCLE31 b 2000 soo a ma=Eup warf a vo =vC.Esa staviCE Coota=G ro*Enl aio 2,0 12 "' LLaa.Eu tw voiva.E wastes may wasTi 1Pa ii0ae-g

  1. 2 pea ussif weise ottv I PE A umsf GMilaTEo N# MM 350 uNoE A NOaMat ComonTeo455

,PE g iPf a E "

TOWEm. Towtile ING oAa'4 5v17Eu co%DE N5af E a%D P E EowaT E R' PL uS.e k JEM*NERats2Eo waf Em u %a tup 5v5TEMI e guwEe waTEg yanEWP 595f tw fo Cs#CULatihG waTEm 410Go* a0 000 Sv5 FEM ano omurcas tum.rs e a*O 21 sat e LvCLEE4 saf a CTCLEll 33 SamiTany wasil 30 10 S Masf up wATEn fo CmCULafmeG warEA STSTEM i2 60 0o0 a0 0o0 34 $ 8stf any wa5ft TaEAfwENT Pt. ANT otsCmanGE To o gg

  1. ER8ouC CooLeeG 10w1R51" 10 sat 2 CYCLE 51 taf a CTCLESI walrE WATER RETEreTsom easise P G onuTuoss WATER FoA L:outo Sao*a5TE os5CataAGE 31 000 M 0 15 wa5TE wa7En mETEmrtom assavu DistmanGE Pla uant isoo 1ao fuseTS 1 sho 22%

\ [

16 574a707 FLUSMES Aho CMEusCAL CttaN*NG wa5TES fo to 400 SYa4 tup pow 0 # '

7 EwERGENCT W ATER MaaEUP f os buCLE.aA SERVICE CoOlifeG 1000 0 watEn SYSTEM i, ira.ru, Poso o.sC a GI . .e

. E a,o.a r.o., a,o T Loisti ..o. .uctu. .E. .CE .00 ,0,, 04 -

Coot =G warea 5,srEu na ro*En 9 EvapoaafsDas amo o##1 Los5El saoM CaPCULAfwa is vou.o nao vasit rautut=r svsTEw o.sCasasE 70 ,((N t 18 000 15 000 19 BLowoowm tuwP u.sCuaaGE CootmG wa1ER Sv$ REM PER fo*ER* ll 000 90.230 iassuwfo tassuuto Cosestagrl Comstase n 20 PLa8ei o8$CMa8GE To TME mover 55 000 to 2e5 se seuCLEAa 5'nystE CoottmG Towf 4 DLO*oow4 Pim font h MO 70 21 4suf A "W e"# om af tS 1e*wr.H Taa%H SCpf f's$ HO O }

a TMEst flows amt ho? 4ECES$aAELY CONCURRENI. g eNTEausTTENT ftow Ear #E5sto 45 a Gomt. mucus avEmact 1! rws , Low s easEo on a unCrfo P.Eonaano~aL . u oE..o .atCo~o,Tio s eius o.sC a GE. .

l G ones =or d .sia.euP Gut a.. oCCu etus-Es..~o

_ ._ L ..a,~,C E Cat.Ci.a E

b. lo,oot :pl/,ca dMw g w d % Figure 4.3 Plant water use We coo)N teste Mos 40w . Source: ER-OL Figure 3.3-1 g r

Vogtle DES 4 23 s

c. . P hwr gs s. : 4.A 4k nee M or v.% e, ,4*ow s vm d.d eP W 'd h 7 yJ Mkt t04%9hij N at te C.Wh rpt.< (,ond.itiest g opent=< dJtert Q A. }

F F

_ ~.. . .. . . . . .. . . . - . . . . . . . - - . . . . . . . . . - . . . . . . . _ . . . . . _ .

, hYLsLned CL )

Table 4.1 Cooling water system design comparison 1 Parameter CP stage 2 OL Stage 3 Circulating water system M )f*

Heat rejection rates, Btu /h 8.2 x 109 7.95 x 109 Circulating water flowrate 474,800 484,600 System makeup 19,000 20,0004 Evaporation 14,860 Orift 70 15'000 Blowdow dil 4,000 5,0005 Radwaste '

15,000 OS Concentration factor 4 to 8; 5 average 2 to 6 Nuclear service water system System flowrate 20,700 20,700 System makeup 268 270 Evaporation anc drift 203 200 Blowdown 65 70 1All values in gallons per minute per unit unless otherwise specified. To convert to liters per minute multiply values shown by 3.785; to convert Btu /h to J/h, multiply the values shown by 1055.

2As presented in the FES-CP.

3As presented in the ER-OL.

4For 4 cycles of concentration; at 2 cycles, makeup would be 60,000 gpm. f 5For 4 cycles of concentration; at 2 cycles, blowdown would be 15,000 gpm 4

8The capability exists for providing a 31,000 gpm flow for dilution, if necessary.

l

'It 1

8 a

1 I

i l

l l

l Vogtle DES 4-38 l

l

wC

- - pth w d &

Ta' % 4.2 Summary of biocide and chemical use at Vogtle Trade name or Use (system Use per year .

scientific formula function) per unit Common name Alkaline phosphate Startup chemical 66,000 lb**

Na3PO4 + Na2HPO 4 solution cleaning

  • Hydroxyacetic acid Startup chemical 33,000 lb Organic acid (HOCH2 C00H) cleaning
  • Formic acid (HC0 2H) 15,000 lb Dow A-145 (or Startup chemical 4000 lb Acid inhibitor cleaning
  • equivalent)

HOC (CH (02H) Startup chemical 31,000 lb Citric acid 2 00 2 H)2, cleaning

  • Hydrazine N24H , 35% solution Condensate and steam 10,000 gal generator Auxiliary boiler 2000 gal H250 92,900 gal ***

4 , 66* Baume Circulating water Sulfuric acid 8000 gal Nuclear service cooling water Waste neutralization 72,000 gal Demineralizer 8500 gal regeneration Sodium hydroxide Na0H, 50% commercial Waste neutralization 9000 gal solution Demineralizer 54,000 gal regeneration Fire protection 2,500 gal corrosion protection NH3 , 29% commercial Condensate and steam 13,300 gal Ammonia solution generator Auxiliary boiler 4600 gal Chlorine Cl 2 River intake 90,000 lb Circulating water 300,000 lb Nuclear service 9000 lb

\c/ cooling water Potable water 147 lb Main circulating 27,800 lb Disperant Nako 7319 or equivalent water Nuclear service 4300 lb cooling water

  • Chemicals may be used for subsequent maintenance cleaning.
    • 1 lb = 0.45 kg.
      • At 70.7% plant availability, 105,120 gal /yr at 80% 3 plant availability (approximate); 1 gal /yr = 3.785 L/yr or 0.003785 m /yr.

Source: ER-OL Table 3.6-1 Vogtle DES 4-39

~

~

/4 hw-~.J (h)

Table 4.5 Liquid effluent water quality summary Main cooling water system NSCW tower Low volume Combined blowdown blowdown waste effluent Avg at Max at Avg at Max at Characteristic

  • 4 cycles 6 cycles 4 cycles 8 cycles Avg Max Avg Flow (gom) 5000 2070 65 30 140 1600 10,280 TOS (mg/L) 240 360 435 870 640 2100 250 TSS (mg/L) 50 100 <50 <100 30 100 30 Calcium (mg/L) 30 40 <60 <120 17 18 30 Sodium (mg/L) 30 44 50 100 40 890 30 Magnesium (mg/L) 14 21 32 64 4 8 14 Iron (mg/L) 1 2 1 2 1 2 1.0 Potassium (mg/L) 8 11 11 22 13 16 8 mg/L) <0.1 <0.1 <0.1 <0.1 <1.0 < 1. 0 <1.0 Lead (mg/L) <0.1 <0.1 <0.1 < 0.1 <1.0 < 1. 0 < 1. 0 Zinc (mg/L) 0.1 0.2 <0.3 <0.6 < 1. 0 <1.0 <1.0 Mercury (mg/L) <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 i Chloride (mg/L) 20 30 10 20 33 50 20 Fluoride (mg/L) 0.3 0.5 < 0.1 <0.2 < 1. 0 < 1. 0 < 1. 0 Total phosphorus 1.0 3.0 2 3 <1.0 < 1. 0 1.0 (mg/L)

Chromium (mg/L) <0.1 <0.2 <0.1 <0.1 < 0.1 <0.2 <0.1 011 and grease Nil Nil Nil Nil <15 <20 <15 5-day BOD (mg/L) NA NA NA NA <30 <45 <30 I Nitrate (ag/L) 1.0 2. 0 6.0 13.0 10 110 1.0 t pH 7.0- 7.0- 7.0- 7.0- 6.0 6.0 6.0- '

8.0 8.0 8.0 8.0 9.5 9.5 9.0 Alkalinity 95 140 140 290 100 250 100

  • Describes the characteristics of the combined liquid wastes after treatment; i.e., the plant effluent discharged to the Savannah River.

Note: Maximum flow is not necessarily concurrent with maximum water quality L concentration.

Source: ER-OL Table 3.6-2 Vogtle DES 4-42

y. . ._

i --

.-L ~~T n _. .: . --- r .u m = tc==t ~1= .:2 .=-=-!=-=- ,-=2.= .- ; -

s.- -- _

g &m.- tf

c Table 5.3 Natural draft cooling tower data for Vogtle compared with four other o

nuclear plants, per cooling tower I

g Beaver Valley m Parameter Vogtle Susquehanna Unit 2 Shearon Harris Grand Gulf Location Burke Berwick, Shippingport, Bonsal, NC Port Gibson, County, GA PA PA MS Drift rate, %

Guaranteed O.03 0.02 0.013 0.05 Expected 0.008 0.008 0.002 NA* 0.002 M MA Circulating water flow 30,569 30,152 32,007 30,404 36,082 rate, L/s (gpm) (484,600) (478,000) (507,400) (482,000) (572,000)

Dissolved solids In makeup, mg/L 60 @ 203 70 376 In blowdown, mg/L 240 1640 365 539 1880 Concentration factor 4 3.8 1.8 7. 7 5. 0 TDS emission rate,**

kg/yr 14,800 24,900 -

8,300 136,900 Frequency of dominant wind, % 12 15 11 g 11 9 Maximum solids <9.5 kg/ 1.7 kg/ 1.7 kg/ha/yr 4.5 kg/ha/yr deposition on land ** ha/yr 2.8 kg/ha/yr ha/y r '

i.' lb/ (4 lb/ (2.5/1b/

(<8.5 lb/ (1.5 lb/ acre /yr) acre /yr) acre /yr) acre /yr) acre /yr) g

  • NA = not available.

, ** Expected drift rate used in calculations.

Source: ER-OL Table E290.8-1 e

. kh&m^f Table 0-1 (continued)

~

Radwaste Radwaste solidification solidification Nuclide building vent Nuclide building vent H-3 2. 3IO2Ia- Te-127 8.1E-06 Cr-51 4.3E-05 Te-129 2.1E-05 Mn-54 7.5E-06 Te-129m 3.2E-05 Fe-59 3.9E-05 Te-131 3.3E-06 Fe-58 2.3E-05 Te-131m 1.8E-05 Co-58 3.8E-04 Te-132 3.8E-04 Co-60 4.9E-05 I-130 1.3E-03 Br-83 9.0E-07 I-131 2.6E-01 Rb-86 7.2E-06 I-132 2.0E-02 Sr-89 8.3E-06 I-133 9.7E-02 Sr-90 3.0E-07 I-134 1.5E-05 Y-90 1.0E-07 I-135 1.2E-02 Y-91 1.6E-06 Cs-134 2.4E-03 Y-91m 9.0E-07 Cs-136 1.0E-03 Zr-95 1.4E-06 Cs-137 1.8E-03 Nb-95 1.2E-06 Ba-137m 1.6E-03 Mo-99 1.1E-03 Ba-140 4.6E-06 Tc-99m 1.0E-03 La-140 4.4E-06 Ru-103 1.1E-06 Ce-141 1.6E-06 Ru-106 3.0E-07 Ce-143 3.0E-07 Rh-103m 1.1E-06 Ce-144 8.0E-07 Rh-106 3.0E-07 Pr-143 1.1E-06 Te-125 7.0E-07 Pr-144 8.0E-07 Te-127m 6.7E-06 Np-239 1.4E-05 Total Kr and Xe, 4200Ci Total Iodine and particulates (excluding H-3 and C-14), 0.53 C.i

  • All releases should be considered continuous.
    • Plant vent.
      • Exponential notation: 3.0E+00 = 3x100 tFor the C-14 dose releases, 7 Ci/yr/ reactor is attributed to an annual release duration of 700 hours0.0081 days <br />0.194 hours <br />0.00116 weeks <br />2.6635e-4 months <br />, and 1 Ci/yr/ reactor is attributed to continuous releases.

Vogtle DES 5 Appendix D

^

E

- hhsecAMd ( ,

l Table D-1 Calculated releases of radioactive materials in gaseous effluents from Vogtle 1 and 2 (Ci/yr per reactor)*

Waste Building ventilation Air gas ejector Nuclide system ** Reactor ** Auxil ia ry** Turbine exhaust Total **

Kr-83m 0 3.0E+00*** 0 0 0 3.0E+00 Kr-85m 0 s t00k 3.1E+01 2.0E+00 0 1.0E+00 3.3E+01 Kr-85 2.5E+4re'- 5.0E+00 0 0 0 Kr-87 0 2.6E+02 7.0E+00 1.0E+00 0 0 8.0E+00 Kr-88 0 4.4E+01 4.0E+00 0 3.0E+00 4.8E+01 Kr-89 0 0 0 0 0 0 Xe-131m 3.0E+00 1.3E+01 0 0 0 1.6E+01 Xe-133m 0 6.4E+01 2.0E+00 0 1.0E+00 6.6E+01

~Xe-133- 1.0E+00 3.4E+03 1.1E+02 0 7.0E+01 3.5E+03 Xe-135m 0 0 0 0 0 0 Xe-135 0 1.3E+02 7.0E+00 0 4.0E+00 1.4E+02 Xe-137 0 0 0 0 0 0 Xe-138 0 1.0E+00 1.0E+00 0 0 2.0E+00 I-131 0 1.8E-02 4.5E-03 1.3E-03 I-133 2.8E-02 2.3E-02 0 2.1E-02 6.4E-03 1.4E-03 4.0E-02 2.7E-02 H-3 C-14 8.2E+02 Ar-41 8.0E+00 -

Mn-54 2.5E+01 4.5E-05 2.2E-04 1.8E-04 4.5E-04 Fe-59 1.5E-05 7.4E-05 6.0E-05 1.5E-04 Co-58 1.5E-04 7. 4 E-04 6.0E-04 Co-60 1.5E-03 7.0E-05 3.4E-04 2.7E-04 6.8E-04 Sr-89 3.3E-06 1.7E-05 1.3E-05 S r-90 3.3E-05 6.0E-07 3.0E-06 2.4E-06 6.0E-06 Cs-134 4.5E-05 2.2E-04 1.8E-04 4.5E-04 Cs-137 7.5E-05 3.8E-04 3.0E-04 7.6E-04

  • See footnotes at the end of the table. 'l  ;

Vogtle DES 4 Appendix D

'T S

h khn }-

Table D-6 Annual dose commitments to a maximally exposed individual near the Vogtle 1 and 2 nuclear station Location Pathway Doses (mrems/yr per unit, except as noted)-

Noble gases in gaseous effluents E Total Gamma air dose Beta air dose ;a body Skin (mrad /yr/ unit) (mrad /yr/ unit) 1 Nearest

  • site Direct radiation 0.1 0.2 0.1 0.3 E boundary (1.98 km E) from plume  ?

Iodine and particulates in gaseous effluents **  :

9

.. 3 Total body Organ . g; Nearest *** site Ground deposition a a <

S boundary (1.98 km E) Inhalation 0.1 0.5 (C) (thyroid) )h Nearest residence Ground deposition a a h (1.93 km WSW) Inhalation a 0.5 (C) (thyroid)  ?

Nearest milk cow Ground deposition a a (7.4 km SE) Inhalation a a ,

Vegetable consumption a 0.1 (C) (thyroid) 7 Cow milk consumption a 0.8 (I) (thyroid) ,,

0.3 (C) (thyroid) 1 Nearest garden Ground deposition a a ;c (2.25 km WSW) Inhalation a 0.4 (C) (thyroid) J Vegetable consumption a 0.8 (C) (thyroid) E i

Nearest meat animal Meat consumption a a (5.0 km SW) 7 Liquid effluents ** A

2 Total body Organ

[

Drinking water at Water ingestion 0.9 (I) (thyroid) k 0.1(()C plant discharge area E e

Nearest fish at Fish consumption 0.5 (A) 0.6 (T) (liver)  %

plant discharge area .

I k

i .

1 Nearest shore access Shoreline recreation a a T near plant discharge 'k area y

?

a = Less than 0.1 mrem / year. y

  • " Nearest" refers to that site boundary location Ehere the highest radiation doses as .

result of gaseous effluents have been estimated to occur. l

    • Doses are for the age group and organ that results in the highest cumulative dose fer the location: A= adult, T= teen, C= child, I= infant. Calculations were made for those age groups and these organs: gastrointestinal tract, bone, liver, kidney, thyroid, lung, and skin.
      • " Nearest" refers to the location where the highest radiation dose to an individual from all applicable pathways has been estimated.

Vogtle DES 10 Appendix D

  • \,