ML20107L739
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t EPA fD-A2C-06113-!J Envi cr. ental Pro: ction Agency Ucshingten, D.C.
20460 Septe ber 1973 Enviror.cental I=ps:t Statement Cornents Oyster Creek Iuclear Cenerating Staticn TABLE OF CONTC;TS Page l
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I!TRODUCTIO:i M;D CO: CLUSIC};5 1
l RADIOLOGICAL AS?ZCTS Radioactive Easta Treatment 5
Dose Assessment 5
Transportation 7
Reactor Accidents 8
- 0N-RADIOLOGICAL ASPECTS Thermal Effluent Ccasiderations 10 Biological Effects 12 Chemical Offects 16 ADDITIO.NAL CO? TESTS 18 i
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INT?.Zr0TIO:: W:D CO::CI.USIO::S The Environ = ental Protection Agenc;'- (ITA/ has reviewed ths drtf t ' enviren= ental impact statecent.f or the Cyster Creek Nucicar Generating Station prepared by the'U.S Atomic. Energy Co==ission and issued on July 9, 1973..The following are' l
our najor conclusions.
1 1.
Essed on operating enperience at the Cyster Creek Nuclear Generating Station, the current releases of.
radioactive liquids'and gases from the plant and
" subsequent offsite population doses cannot be considered "as low as practicable." A modified waste treatcent Jsystca is proposed which should reduce the releases-
~ and doses to "as low as. practicable levels." The final statement should discuss those proposed codifications in greatar detail, 2.
The cumulative population dose within 50 ciles cannot be considered "as low as practicable."
f We reco mend that the proposed augmented radioactive gns treatment system be installed expeditiously since cost of the calculated population dose results frc: the radiogas' release from the plant off-gas systen.
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During the joint EPA-AEC studies at Oyster Creek, probicas with the on-site meteorolegical tc.ter were noted.
'?e, therefor =, tallava that the his:cric on-site meteorological data are not useful in evaluating the environmantal impact cf the Oyster Creek Station.
If not already instituted, an appropriate on-site neteorological pro 3 ram, based upon the requirements of the AIC Regulatory Guida 1.23, shculd be initiated as soon as possible so that accurate dose assessments may be cade in the future using the plant's operating data.
4.
The final statecent should (either 'directly or by publicly available referenca) provide information on the nature, c::pected schedule, and level of ef fort of those generic studies which are expected to lead to a l
bcsis for a subsequent assesscent by the AEC concerning the risk ftsm all potential accident classes in the Oyster Creek Station.
5.
The quantity and types of infor:ation contained in the inpact statement do not per=f t the evaluation of the extent of biological damage to Barnegat Bay resulting frca plant operation.
E::panded biological conitoring programs should be instituted which vill
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,,s accurately determine.the extent.of impirrement and
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- cntrair. ent 1osses'and the eff et of;these losses.
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on ct.i r.quatic ecosystc=Lo! Barnegat 3ay.
These
' studies.should be completed.and.the resu1.ts analyzed i
prior to'the issuance of a full-term operating'percit.-
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We' concur with the AEC staff's opinion on tha types
'of.' studies'needed as described-in Section'6.2.3.
'n'h er e
.possible, the results of other studies. relative toJthis.
sito should also be utilized.
i'l 6.' The results'of EPA aerial infrared photography l
indicate that the thermal plume affects.the entire
-.6 vidth of-Barnegat Bay to the catent that the proposed New Jersey ther=al standards are violated. The S tate proposes to allow no greater than a 1.5*F temperature rise in se: er outside of a designated mixing zone.
The results of EPA's study show a 4-5'F rise three l
miles from the plant.
In view of this, the applicant Oh'ould undertake a core detailed study of alternate cooling systems.
Ah, 7.
The statement lacks'a characterizatica of the adjacent waters with respect to physiochc=ical data.
0::ygen concentrations in the near bay area tay bc 1
IcuerLthan acceptabic..Uster quality data concernins s
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dicsolved o::ysen concentrations. in, the bcy and the effect that the haated eff1 dents have on these-concentrations s'wul_ be p avided in the fla21 sta : ament.
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~5-4 RADIGLOGICAL ASPECTS Radioactive Uaste Treatment Based on operating experience at the Oyster Creek Nuclear Generating Station, the releases of radicactive liquids and g:ses from tha plant 1
and subsequent offsite population doses cannot be considered "as lov as practicabic." We note that both the applicant and the AEC staff raccgniaad that current radioactive releases do noc represant "as icw as practicable" discharges and that the applicant has proposed to codify the liquid and gaseous radwaste systems to insure ceapliance with the AIC's "as low as practicable" guidelines. Although the doses to individuals are low with tha current waste systems, the off-gas system needs to be aug=ented, as planned, to reduce the potentially high population doses, as discussed below.
The draft statement discussed several specific problems with the waste treat:ent system and indicated a few modifications that uill be icplemented.
Neither the preposed codifications nor the applicant's design basis objectives were discussed in the draf t statement or the j
Environmental Report.
In order that an independent analysis of the l
modified waste treatment systens nay be,made, the final statement should discuss the proposed codifications in greater detail, or at least it should provide the design objectives of the modified system, and should indicate the time schedule for ecdifying the systen.
Dose Assessment The calculated ca::icum doses to an individual frca gaseous and i
liquid dis:hargos from the Oyster Creek radwaste treatment systens are within the dose guidelines of the proposed Appendix I to 10 CFR part 50.
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t However, the cu=ulative population dose within 50 niles cannot be considered "as low as practicable," since currently available " state-of-the-art" technology to control the reactor's gasecu a effluents is not s
presently provided.
Thus,.ee reconnend that the proposed augmented radioactive gas treatment system be installed expeditiously, since nost of che calculated population dose results from the radiogas release frca the plcnt eff gas system.
The EPA expects that the results from currant and planned joint EPA-A2C and industry cooperative field studies in the environs of operating nuclear power facilities vill greatly increase knowledge of the processes and cachanisms involved in the exposure of man to radiation produced through the use of nuclear power. We believe that the overall cuculative assumptions utilized to esticate various human doses are conse rvative. As core infor=ation is developed, the models used to estimate human exposures will be modified to reflect the best data and cost realistic situations possible.
During the joint EPA-AEC studies at Oyster Creek, problees with the on-site neteorological tower vere noted.
We, therefore, believe that the historic on-site cateorlogical data are not useful in evaluating the environmental inpact of the Oyster Creek station.
It is also questionable whether the data available from other locations uill be valid f ar this sita since local features, such as B trnegat 3ay, have a significant effect on the_ local meteorology.
Furthe rmore, the data fron Atlantic City, which have bean utili cd, nay not be applicable to the l
conditions at Oyster Creek since the ceteorological tower there is comparatively short and, thus, does not provide in"ormation at the
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Therefore, if not already instituted, an l
i eppropriate on-site meteorological program, based upon the requirements of the AEC Regulatory Guide 1.23, should be initiated as soon as possibic so that accurate dose assessments cay be cade in the future using the plant's operating data.
We agree with the conclusion of the AEC staff that there are a number of deficiancies, as indicated by the AEC, within the appilcant's existing environmental surveillance program.
EPA has recently published a doce ent entitled " Environ = ental Radioactivity Surveillance Guide" which contains detailed information to assist operators of nuclear power plcnts in planning an adequate environmental surveillance program.
The final statement should provide the details of the updated program which 1
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eliminate these deficiencies. Also, a suitable laboratory analysis k
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quality centrol program, for both effluent and environnental samples, should be instituted utilizing cross-check samples with an outside laboratory.
Data from the environmental radiation surveillance program at the plant haee been collected over a number of year 7.
Based on these data, the AEC staff concluded that no radiological environnertal problems have resulted from radionuclide releases from the plant.
The final statement should present a su==ary of this data.
Trs.nsporta:ica E?A, in its earlier reviews of the environmental inpact of transportation of radioactive naterial, agreed with the AEC that many aspects of this pro 51ca could best be treated on a generic basis.
The generic approach has reached the point where on February 5, 1973, the
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AEC. published for co==ent in the Federal Register a rulecaking proposal concerning the Environmental Effects of Transportation of Fuel and Waste frc= Nuc1 car Pever Reactors.
EPA commented on.the proposed rulemaking Jrf n lettar c.; tha A20, dated March 22, 1973, and by an appearance at the public hearing on April 2, 1973.
Until such tice as a generic rule is established, the EPA is ccatinulag to assess the cdequacy of the quantitative esticates of environmental radiation impact resulting from transportation of radiosctive naterials provided in anvironmental statements.
The esticates provided for this station are deened adequate based on currently available information.
Reactor Accidents EPAhasexamine[theAECanalysesofaccidentsandtheirpotential risis which AEC has developed in the course of its engineering evaluation of reactor safety in the design of nuclear plants.
Since these accidents are co= mon to all nuclear power plants of a given type, EPA concurs with the AEC's approach to evaluate the environmental risk for each accident class on a generic basis. The AEC has in the past and still continues to devote extensive efforts to assure safety through plant design and accident analyses in the licensing process on a case-by-case basis.
EPA, however, favors the additional step now being utdartaken by the A20 cf a taorough analysis on : core quantitative basis of the risk of potential accidents in all ranges. We continue to encourage this effort and urge the AEC to press forward to its ticely completion and publication.
EPA believes this will result in a better understanding of the possible risks to the environ =ent.
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. V Inorderto-provideafullerunderstandi,15gofthedirectionofthese efforts, it is requested that the final statement (either directly or by publi../ available ref erence) provide informa:non on the nature,
.c::pected schedule, p.nd level of effort of those generic studies which are expected *a lead to a basis for a subsequent assessment by the AEC concerning the risk froa all potential accidents classes in the Dyster Creek station.
It is recognized that this subsecuent assess".ent may by either generic or specific in nature depending on the outcome of the Seneric studies.
In addition, the final statement should include an ASC cc=mitment that this assessment will be made publicly available within a reasonable time period following completion of the generic studies.
C1carly, if the above efforts indicate that unwarranted risks are being taken at the Oyster Creek station, we are confident that the AEC will assure appropriate corrective action.' Similar]y, if EPA efforts related to the accident area uncover any environmentally unacceptable conditions i
related to the sefety of the Oyster Creek station, we vill nake our views knovn.
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!!ON-?ASIOLCCICil AS?ECTS Thernal vff1*:en: Considera:icns -
1 The 0;' ster Creek sta: Ice cmploys a enca throu;h coolins system which draws uater from a dredged, scoicircut:r canal having its termini on Bernegat Bay. -The sesam condenser cooling syscem requires AfD,000 gallona per minu:s (3ps).
-Turbine and reactor building component cooling require an cdd!tienal 10,000 and 12,000 gpn respectively. At a power leval of 1930.'.Gt, the temperature rise across the condensers is 23*T.
Three dilution purps, each having a capacity of 260,000 gps, are availabic to aug=ent flow in the discharge canal.
On July 13, 1973, EPA took aerial infrared photographs of the Oyster Creek plant's thermal plume.
The results of
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this study ar2 new available in draft for=, and a copy of the completed report will be transmitted to the AEC in the next few weeks. The study shows that the ther=al influence of l
the plant's discharge extends across the entire width of Barnegat Bay, a distance of approxicately three miles. The foother s shes frequent temperature variations all the way acto.<s, probably due che shallowness of the bay. A temperature u
riso of frca 4 to 5'F in shown near the barrier beach on the i
cast side of the bay.
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JMeu Jersey oroposes to a:end their water quality standards to allow no greater'than a 1.5'F te=perature rise-6 in succer cut. side of a ' designated 7:ixir.3 zone. Cuc study results ihov that co:pliance vith this regulation vould not' he possible even if the'-State were to designate the entire
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i bay as a mixing' cone.
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In accordance with the Federal Water Pollution Control Act Amendments of 1972 (F*lPCA), discharges frem the Oyster Creek :;uclear Generating Station are subj ect to ef fluent limitations reflecting the "best practicable control technology currently available" by. July 1,.1977, or to q
stricter limitations if they are necessary to =eet applicable
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water quality standards.
By July 1, 1983, dischargers must achieve effluent controls reflecting the "best availabic techno1cgy economically achievable." - (For the thernal-l cc ponent of discharges, a reevaluation of the limitations imposed by the Ad=inistrator of EPA is possible under Section 316, F"PCA.)
Definitions of the technology-based ter=s are scheduled for preculgation in.0ctober 1973. As noted above, we anticipate
- that the thereal discharge from the Oyster Creek plant will be ~ in violation of.a revision to New Jersey standards now pending undar the FWPCA. Furthercore, the discharge vould,
,in all probability, f ail to =cet the-ef fluent licitations e
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guidelines, once proculgated. The applicant should, therefore, evaluate alternative heat dissipation systems for this f acility, including clo3rd-eycia sys e: alternatites.
This evalu2cisa should be included in the final statement and the system with tinicca impact en the aquatic environment shculd be identified.
"Biolo;ical Effects The cuantity and types of infor=ation contained in the inpact statement do not permit an evaluation of the extent of biological damage to Barnegat Day frc: plant operation.
Data are lacking in a number of critical areas, namely:
a) the extent of biological damage to fish and other organis:s by impingement and entrainment, b) the configuration of the thercal plune with different tidal stages, c) physioche ical characterization of the intake and discharge water.
A tajor cause of biological damage is 1:pingement of crabs and fish on tha plant's intake screens. The impact statement presents the results of a single inpingement s:udy carried out betwcen April l'1 and July 1, 1971, for a total of thirty sampling hours. Thirty hours represent 0.1% of the approximately 30,000 hours0 days <br />0 hours <br />0 weeks <br />0 months <br /> that tha plant has been operating. The results t
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of this' ptudy: cannot be said adequately to characterize losses -
of this type, for reasons contained'in:the following discussion.-
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.The'3tudh inilca:.3d an increasing rate of ir pinienent
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- of blue crabs fron' April.12 to July 1.
This could be expected since the caxicus number of blue crabs cccurs late in the suncer.'in late July, August, and.carly Septecher. The max 1=um figure cited in the impingement rate study represents only'the beginning of the period of canicus abundance and activity of blue crabs in the area.
The applicant arrives at the total number of crabs killed /
year by_ the following method:
(average impingement rate over period of. study) X e
i (hours in 6 nonths) X (i= mediate screen nortality) =
- killed / year, or, 147 crabs /hr X 4380 hr X 0.05 =
32,000 crabs / year.
We f eel that the average impingement rate f actor is cuch too low as it does not consider ti=e of maximum abundanca.
Using the attached figure prepared by EPA's Region II, which
- is an extrapolation of the applicant's data, and projecting the impingement rates for the six months of taximum abundance, we arrive-at an inpinge=ent rate for the period April-October, of 466 crabs / hour.
For the last factor in the equation, the applicant is usin; the.ittediate screen tortality rate (.05).
The assurption is 1
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beyond.
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l'Oct) e 10 -
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900 -
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800 -
Average for 6 month period p-700 -
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beginning /pril 1-usino curve s
12 25 Feriod Rate /hr 600 -
E P-NY 23' Y
P I"
Flay-June 70 EE June-July 225 500 -
July-Aug 525 ey Aug-Sept 825 Sept-Oct 1125 U
400 -
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Periods extend to first of month i~
300 -
Average isrpingement rate over tne months of iriterest (six-mon th period of maximum 200 -
abundance) = 466 crabs / hour S// e 100 -
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APRll 1 VAY l JUNE 1 JULY l AUG 1 SEPT 1 OCT 1 l
Figure 1 TIE OF YEAR
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.i-t that the icpinge=ent-experience will cause.no further harm.to-
. live crabs du= ped.with.oth'er' screen.vashings into tha: discharge.
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prepose a. figure core on the order of 0.50 for c tot'al certality
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rate. This figure' considers such factors as techanical shock and du=paga-inco a canal in which. temperatures have been measured.at'1C4*F.
Having re-esticated the applicant's factors, and calculating, 3
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- (4.66 x 10 crabs /hr) X (4.'38 x 10 hr) X (0.50) = 1.02 X 10 1
crabs lost.
The resulting figure is significant in itself.
It does not, however, consider losses'due to entrainment of larvae
-end young. EPA believes that losses on thi. order of l
tagnitude have the potential of affecting the population in 1
the area and possibly in the bay as a whole,
.This.same line of inquiry can also be pursued with respect to finfish.- For exa:ple, young =enhaden would be expected to peak on the intake screens in fall.
The study, however, did not consider this time of year.
The study neglected March and early ' April, months when vinter flounder are abundant. Also,
" snapper"-bluefish would'be expected to peak during high su= er'and early fall.
This period was not included in the i
j istudy.
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i The icpact. statement contains'only a two-pasc-discussion-of.entrainmentlosses.~Modata-Aerepresentedconcerningfish cnd~ crab larvae and young..The data presented cn'phytoplankton.
' cell. counts, chlorophyll and. productivity. vere. collected during.
the poried of cinican productivity--June through October.
'In-general, tha' actual data for entraincent losses.are not
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sufficient to determine. adequately the extent of these losses.
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Studies at other plants have shown significant effects with regard to'entrainment'of fish larvae. 'For examp1.e. an EPA study showed 165 'n1111on cenhaden larvae killed at the 4
. 3rayton Point plant of-New England Electric in one day.
Despite such indications of significant. potential effect, and despi:e the fact that the Oyster Creek plant has operated I
for three and one-half years, the draft statement presents no data for this plant on actual entrainment losses.
Using other data, the AEC projects a tocal larval kill by entrain =ent of 100 tillion per year at Oyster creek. To show that this cay be a serious underestimate, the EPA study quoted above showed a higher actual kill for one day of one species than AIC'a estimate for all species for a who3a year.at Oyster Creek.
There is no characterication of the bay _.uaters in the area of thi plant uith regard to physiochemical data.
No information 1
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.r s-cencerning dissolved oxygen.and biochemical o::ygen de=and (EOD) provided. This may be critical since :cnparatures of up to
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'Cl.'T hsve 562n re:ordad in tha di.schar3e c;.nal.
Tha solubility 4
of oxygen at 17,500 mg/l salinity and 104*F is only about 5.20 mg/1.
It seems very likely that thermal enhanceaant of ECD could very well drive exygen concentracions in the near bay to unacceptably lov levels, possibly in violation of Federal-1 Stata water quali:y standards.
Chenical Effecto According to the draft statement, continuous discharge of a chlorine residual in the range of 0.1 to 0.2 mg/l can be expected frca this plant.
Chile the maximum reconnended i
concentrations of chlorine to be applied continuously for slice control in brackish water ecoling.tystems have not yet been determined by EPA, chlorine concentrations used at this plant do exceed the concentrations of 0.002 ag/l continuous discharge with c 0.1 ng/l 30 cinute peak which are considered satisfactory for tha protection of freshwater biota. For this reason, efforts should be cade to reduce the chlorine residual level as cuch as is practicable.
Monitoring for both short and long-term chlorina effects on. representative aquatic biota should be conducted at appropriate locations in the cooling-water canal ud outfall e=O
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' Such inf ormation (at least for short-term effects) areas.
cay aircady be available through,the c'te:ical-dischar;e
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te, tin;; 7 cpas institut:d 111971 as nen;1cned on page 1-2 of this draft statement. The chlorine and o:her appropriate chemical test results should be discussed in the final statement.
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AD3ITIC'IAI. CC:CCITS During the review ue noted in certain instances that the draft state ent did not present sufficient informatica to substantiate the conclusiens prasented.
"2 recognize that nech of :his information in not of najor icportance in-evaluating the environmental impact of Oyster Creek station.
The curulativa effects, ho'iever, could be significant.
I: veuld, therefore, be helpful in determining the inpact of the station if the following topics were addressed in the final statement.
1.
The final atataaent should include an esti ate of the F-32 released with the liquid raduaste from the station as vall as the potential total body and bone doses due to ingestion of this radionuclide.
2.
EPA has conducted surveys of direct radiation exposure along Route 9 in front of the Oyster Creek statica.
These surveys indicate that there is some source of direct radiation over a short portion of this highway, thich causes an increased radiation exposure above anbient background.
A thorough survey of this area should be performed by the applicant to o ruine the source of the direct radiation end to esticate the individual and population dose received by persons using the highway.
3.
A large portion of the turbine building ventilation air passes to the nrnosphere through the turbine building roof vents.
The draft state:ent did not indicate that this release pathway would be conitored for radioactitity.
Previsions should be made to conitor this effluent pathway according to the guidance presented.in the AEC Regulatory Guide 1.21.
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The final statccent should include dcse esticates based on the Oyster Creek release ~ history with the data normalized to a 30," laad factor. These esticates uculd provide a possibly core realistic dose assessnent of the environmental effects of this plant and would provide a conparison with the effects based on the standard AEC codel. As available, details should be presented of the isotopic inventories of the effluents discharged.
5.
The following inforcation regarding chemical effects was not included in the draft state:ent and should be addressed in the final statement:
A.
Concentrations of chemicals in' cleaning and laboratory effluent solutions, B.
Results of chemical analysis of the plant's intake and discharge waters as reported in applicant's Environmental neport, Table 5.3-1, 6.
Pertinent aspects, if available, of the ongoing Earnegat Bay ecological studies by the New Jersey Department of Environmental Protection, the U.S. Depart =ent of Con =erce, and Ichthyological Associates (as centioned en page 6-6 of the draf t state:ent) should be included in the final statement.