ML20125C486

Discusses Proposed ETS for Plant.Failure to Follow Up on Fes Recommendations Could Make Agency Vulnerable in Hearing Situation Associated W/Ftol Issuance

ML20125C486
Person / Time
Site:	Monticello
Issue date:	07/13/1978
From:	Grimes B Office of Nuclear Reactor Regulation
To:	Moore V Office of Nuclear Reactor Regulation
References
NUDOCS 9212110211
Download: ML20125C486 (8)

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JUI.13 1978 MEMORANDUM FOR: Voss A. Moore, Jr., Assistant Director for Environmental Projects, DSE , x FROM: Brian K. Grimes, Assistant Director for Engineering and Projects, DDR

SUBJECT:

PROPOSED EINIRONMENTAL TECHNICAL SPECIFICATIONS FOR MONTICELLO NUCLEAR GENERATING PLANT PLANT NAME: Monticello Nuclear Generating Plant DOCKET NUMBER: S0-263 RESPONSIBLE BRA.'4CHES: EP-1; ESB; ORD-3 DSE PROJECT MANAGER: S. Bajwa D0R PROJECT MANAGER: R. Bevan TAC NUMBER: 7587 We have reviewed the proposed Monticello non-radiological environmental technical specifications (ETS) and have found that they are inconsistent with the FES findings in several important areas. While it is not neces-sary that the two be consistent, it is necessary that the inconsistencies be evaluated as to envir9nmental impact and the conclusion reached that the findings of the FES are not invalidated by the changes. This evaluation and conclusion should be prepared as an Environmental Impact Appraisal (EIA) supporting the proposed ETS. We cannot make a judgment on the ecceptability of these ETS and, in particular, the inconsistencies without having the EIA.

We rec, rt that an EIA be prepared and circulated for technical review with the 1 ' -

aaft ETS.

In w m 'y and conclusions section of the FES, requirements are recom-men < - "N incorr a ted in the license for t',e protection of the environ-ment. N voposed ETS do not adopt these recommendations. Furthermore, our r % w -

the licensee's annual reports indicated that the licensee's monito W vrograms generally did not address these areas; thus, implementa-tion of appropriate monitoring programs,as suggestc4 in the FES, may be needed before final conclusions can be drawn. Under a contract from NRC, Battelle-Pacific Northwest Laboratory (PHL) reviewed the licensee's annual reports and found many significant problems with their monitoring programs which support.s our finding that it may not be feasible to do an adequate impact appraisal with the information available to justify some of the in-consistencies between the proposed ETS and the FES. Some of these incon m _

sistencies, however, may be justifiable from a generic standpoint as the W[C Conte::t: W. Pasciak, EEB/00R

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l state-of-the-art of impact prediction has greatly improved since the FES ,

was originally written. A thorough review and environmental analysis should '

! be made to determine exactly which areas may require further monitoring, and these monitoring programs shculd be included in the draft ETS. 3 g; Enclosure 1 outlines specific areas of the FES that should be addressed in j the environmental impact appraisal, along with a discussion of problems that are likely to be encountered in doing these appraisals. We will coordinate-

with DSE in this evaluation as necescary. ,.

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In addition to assuring we are discharging our NEPA responsibilities, we are concerned that failure to follow up on FES recorsnendations could make us vulnerable in any hearing situation associated with the FTOL issuance.

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Brian K. Grimes Assistant Director for Engineering and Projects Division of Operating Reactors

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2 MEMORMIDUM FOR:

Voss A. Moore, Jr., Assistant Directo for Environmental Projects, DSE FROM: Brian K. Grimes. Assistant Direct for Engineering and Pmjects, DOR '-

SUBJECT:

PROPOSED ENVIRONMENTAL TECHNI SPECIFICATIONS FOR MONTICELLO NUCLEAR GENERATIN PLANTt PLANT NAME: Montice lo Nuclear Generating P ant DOCKET NO.: S0-263 RESPONSIBLE BRANCHES:\{P-1; ESB; ORB-3 DSE PROJECT MANAGER: S.\Bajwa DDR PROJECT MANAGER: R.Kevan TAC N0.: 7587 \

. N We have reviewed the proposed hontic llo non-radiological environmental technical specifications (ETS) And fave found that they are inconsistent with the FES findings in severa1\i$portant areas. While it is not neces-sary that the two be consistent, y is necessary that the inconsistencies be evaluated as to environmental imRact and the conclusion reached that the findings of the FES are not inya idalgd by the changes. This evaluation and conclusion should be prepar d as an Environmental Impact Appraisal (EIA) supporting the proposed ETS. t is imphssible to make a judgment c4 the ac-ceptability of these ETS and, in particubr, the inconsistences without hav-ing the EIA to review. We uest that ad EIA be prepared and circulated for technical review with the la est draft ETS.

In the summary and conclus%ns section of the ES, requirements are recom-mendedtobeincorporated/nthelicensefort protection of the environ-ment. The proposed ETS d not adopt these rec ndations. Furthennore, our review of the licens 's annual reports indi ted that the licensee's monitoring programs gen ally did not address thes areas; thus, it may be impossible to do an acc ptable evaluation in these eas without implementing appropriate monitoring programs as suggested in the S. Under a contract from NRC, Battelle-Pa ific Northwest Laboratory (PNL) viewed the licensee's '

annual reports and f nd many significant problems with . heir monitoring pro- ,

grams which supports our finding that it may be impossib? to do an adequate impact appraisal wi the information available to justif some of the incon-sistencies between he proposed ETS and the FES. Some of t ese inconsisten-cies, however, may justifiable from a generic standpoint s the state-of-the-art of impact rediction has greatly improved since the FtS was originally written. A thorough review and environmental analysis should be made to

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determine exactly which eas may require furthe monitoring, and these monitoring programs should' e included in the/draf t ETS.

! Enclosure 1 outlines specific reas of t ES that'should be addressed in -

the environmental impact appraital, alo with a discussion of problems that are likely to be encountered in d ng these appraisals. We will co-l ordinate with DSE in this evaluati n s necessary. .  ; ;, ;j 4 <

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'c f' l Bria~ K. Grimes Assistant Director for ngineering and Projects Divisio of Operating Reactors j'

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j Enclosure 1 i

i Items that should be discussed in an Environmental Impact Appraisal Supporting Issuance of FTOL for Monticello Nuclear Generating Plant In the Sumary and Conclusions section of the FES, p. iii, Item No. 7, it states that "after weighing the environmental, economic, technical and other benefits of the Monticello Nuclear Generating Plant against environmental costs and considering available alternatives, it is concluded that the action i called for is conversion of the provisional operating license to a full term operating license for the facility subject to the following conditions for pro-tection of the environment." These five conditions are listed below along with j comments as to how they should be handled in the environmental impact, appraisal.

7 (a) "The Applicant shall operate the plant in such a manner that the maxi-mum temperature of the river, as a result of plant operation, does not exceed 90*F over more than one-half the surface width of the river at any time." The a

NPDES Permit allows discharges during April through October cf 95 F. The ap-l praisal must either assure that this 95 F discharge limit will not cause the 90*F FES limit to be exceeded, perhaps through a hydrologic evaluation, or must de-

scribe the impact that will occur with the 95 F limit, and show that it is either insignificant or show that it does not change _the cost-benefit analysis. Our brief review of the annual reports indicated that the licensee did not_ perform a study addressing this question. It appeared that most of the monitoring tran-sects were located too far downstream to answer this question. Furthermore, the model they developed is apparently inadequate. Battelle-Pacific Northwest Laboratory reviewed it* (p. 60) and concluded that "in general, the model predic-tions are not representative of the river surface therma} distribution." If an f.

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, - 2-j j appropriate analysis cannot be made addressing this question, whether by i means of the hydrologic approach, modeling approach, or some other approach, i

a monitoring program should be included in the ETS to obtain the necessary' i

i information and, as in the handling of Oyster Creek ETS, LCOs should be im-4

! posed in this area.

l l 7(b) "The Applicant shall obtain data to ascertain whether or not corrective i

action need be taken to reduce the possible loss of biota due to the intake j structure." We have reviewed the licensee's results and discussions in the l annual reports. While it appears that there are enough data available on' fish =

impingement, the licensee did not compare these data to information on fish populations and fishing catch results to ascertain whether the impact levels are acceptable. Such a comparison is an important part of answering this

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question and should be part of the environmental impact appraisal. If the I

historical impingement rate is not acceptable from the impact standpoint when

! projected into the future, modifications to the proposed ETS should be made i

l as appropriate. If further monitoring were required as a result of high pre-dicted impact, data from other river-located plants may help in designing a l

monitoring program.

7(c) " Planned plant shutdowns shall b programmed such that the rate-of water

! temperature reduction will not'cause excessive fish kills-in the-discharge-canal." The NPDES-Permit does not have a limit on rate of temperature change of discharge water. In such cases, it is current practice to-impose such a condition as an LCO,-or, by means of the evaluation to show that such a l

limit is not necessary and that this conclusion of the FES is no longer valid, i ll R

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j found that they do not specifically address this question, nor may the data j be available in them to do so. In the Battelle-Pacific Northwest Laboratory i

review of the licensee's data * (p. 121),~they stated that "the river popula-

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i l tion estimates .... are both poor and inappropriate (displaced too far in time) to use as an aid in estimating cold shock effects. Thus, it appears that some i

j further action by NRC is necessary in this area. The available data should be reviewed and this review should be included in the environmental impact l appraisal along with the basis supporting the proposed action. Imposing'LCOs i along with a monitoring program may be the appropriate action in this' area, i

! 7(d) "The Applicant shall define a comprehensive environmental- monitoring i

program for inclusion in the Technical Specifications which are. acceptable to the Staff for determining environmental effects'of plant operation."

Batte11.e-Pacific Northwest Laboratory reviewed this report

• and concluded j that (p. 53), in general, the impacts predicted in the Environmental State-ment have not been verified by the data collected fromfthe monitoring prograins.

4 They also stated that "If more consideration was given Lto a sampling design.

that is statistically oriented. ... then answe'rs to-predicted FES impacts could possibly be attained through'a highly quantitative Environmental Techni-cal Specification." The Battelle study was completed in November 1976 so

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data from the last few. years of monitoring were not reviewed. The basis for

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.their conclusions should. be addressed in the appraisal. .As the licensee's analysis =does not verify the FES findings, an analysis should be provided with the. appraisal which does. or appropriate montioring. programs should be included; in the FES. '

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7(e) "If other harmful effects or evidence of irreversible damage are de-4 tected by the monitoring programs, the Applicant will provide an analysis of the problem and a proposed course of action to alleviate the problem."

The monitoring programs in the proposed ETS should be evaluated to deter-mine whether they are adequate to detect such effects. Our review of them indicates that the proposed programs may be inadequate for this purpose.

, The appraisal should describe the areas for which the monitoring is ade-quate to detect possible irreversible damage caused by plant operation, and areas where the monitoring programs should be improved to provide a minimum level of monitoring in ar'eas where possible irreversible damage may occur in the distant future.

In addition to these conditions described in the summary and conclusions, 1

there are recommendations made throughout the FES. Those which are not being implemented through the proposed ETS program should be discussed in the EIA and bases for their omission should be presented, t

4 Evaluation of Monticello Nuclear Power Plant, Environmental Impact Pre-dictions, Based on Monitoring Progrars. Battelle-Pacific Northwest Laboratories, November 1976. BNWL-2150.

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