ML20127A101
| ML20127A101 | |
| Person / Time | |
|---|---|
| Site: | Beaver Valley |
| Issue date: | 06/10/1985 |
| From: | Carey J DUQUESNE LIGHT CO. |
| To: | Knighton G Office of Nuclear Reactor Regulation |
| References | |
| 2NRC-5-089, 2NRC-5-89, NUDOCS 8506210015 | |
| Download: ML20127A101 (5) | |
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'Af 2NRC-5-089 (412) 787-5141 (412) 923-1960 Nuclear Construction Division Telecopy (412) 787-2629 Robinson Plaza. Building 2, Suite 210 Pittsburgh, PA 15205 June 10, 1985 United States Nuclear Regulatory Commission Washington, DC 20555 ATTENTION:
Mr. George W. Knighton, Chief Licensing Branch 3 Of fice of Nuclear Reactor Regulation
SUBJECT:
Beaver Valley Power Station - Unit No. 2 Docket No. 50-412 Comments on BVPS-2 DES
REFERENCE:
Letter from G. W. Knighton to J. J. Carey dated April 11, 1985 Gentlemen:
Please find enclosed additional information that may be helpful in responding to the comments on the Draf t Environmental Statement received by the NRC from the various Federal, State, and Local government agencies.
If you have any questions, please contact T. J. Zogimann at (412) 787-5141.
DUQUESNE LIGHT COMPANY
/h By J.UJ." Carey
/"
Vice President TJZ/wjs Enclosure Ms. M. Ley (w/e) cc:
Mr. B. K. Singh, Project Manager (w/e)
Mr. G. Walton, NRC Resident Inspector (w/e) r 00 N li 8506210015 850610 i
PDR ADOCK 05000412 I
D PDR t
r-i D01 THERMAL DISCHARGES The closed cycle cooling system of BVPS-2 requires some small increase in the temperature of the discharge water over ambient river condit ions.
The average monthly temperature differences for Units 1 and 2 combined range from 1.3
- C in August to 15.9 ' C in January.
However, the combined discharges do not exceed State Water Quality Standards for temperature outside of a small mixing zone immediately adjacent to the discharge structures.
The NPDES permit for BVPS previously contained a requirement for a 33 acre mixing zone.
This requirement was deleted when the permit was renewed by the state of Pennsylvania on November 26, 1984.
The alternatives considered to reduce the temperature in the heated discharge were discussed in the FES-CP.
Alternatives need not be discussed at the FES-OL state (10CFR51.21).
D01 SKIPJACK HERRING Section 4.3.5.2 of the Draf t Environmental Statemert (DES) and Table 2.2-17 of the ER-OLS indicates that skipjack herring were collected at the site in the 1970-1972 sampling period. The anlaysis of impacts of operation of BVPS-2 on aquatic resources as presented in the ER-OLS considered the potential of impact to all fish species with likely or probable occurrence at BVPS included all species collected at the site (including skipjack herring) as well as other indigenous species not collected in the BVPS sampling program (see ER-OLS Table 2.2-18).
D01 GROUNDWATER The two on-site wells are located approximately 1400 feet east of the reactor - containment.
In a phone conversation with Ms.
M. Ley, the following information was provided:
- Well #1 is 89'6" deep
- Well #2 is 92'6" deep The drawdown for the wells is as follows:
- #1:
6'10-1/2" at 210 GPM for 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />; static level, 64' down
- #2:
11' at 115 GPM for 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br />; static level, 65'5" down It should be noted that this drawdown was performed under test condi-tions; actual pumpage would be less since these wells only supply water to BVPS support buildings via the water tower located near the Training Building.
The on-site wells are routinely monitored for chemical and biological contaminants.
Station procedures do not require routine radiological monitoring.
In the unlikely event of a radiological spill, the long travel time associated with groundwater novement would allow ample time to effect remedial measures to isolate the contamination near the source.
Such action would be undertaken immediately.
r EPA WATER ISSUES The effluent limits imposed on the discharges from BVPS 1-2 are con-sistent with the standards for new and existing electric powe r plants, i.e., BAT, promulgated on November 19, 1982. The NPDES permit for BVPS 1-2, ef fective November 26, 1984, was reviewed by EPA Region III under $402 of the Clean Water Act (CWA) before it was issued.
The authority in 40CFR 5123.(c)(4) allows the Regional Administrator (RA) to object whenever he believes the state misapplied the CWA regulations or guidelines under the CWA.
Similarly, 1123.75(c)(6) allows the.RA to object whenever the proposed permit "in his judg-ment" contains case-by-case limitations that fail to carry out the CWA or EPA regulations.
During the permit application review process, the PA DER evaluated the impact of the facilities discharges on the designated use of the receiving waters and the water quality criteria based upon the desig-nated uses.
The basis for the determination was data submitted in the permit application, Form 2c.
Subsequent to this evaluation, the PA DER determined no water quality based limits were appropriate.
The reason for the increases in concentrations of criteria pollutants is primarily the result of evaporative losses in the cooling tower.
Any appearance of adverse impact on water quality as discussed on pages 5-3 and 5-9 of the DES is magnified by the use of a "wors t-case" estimate of cooling tower blowdown concentrations (indicated in ER-OLS Table 5.3-4).
This - is the result of the use of a maximum concentration factor for BVPS-2 of 2.4 (i.e., cooling tower cycles of concentration) combined with maximum ambient river concentrations.
Normally the concentration factor will range from a minimum of 1.5 to a maximum of 2.4 with an average of 1.8.
In addition, the mixing zone requirements outlined on the ER-OLS Table 5.3-4a and discussed on page 5-3 of the DES are based on the 7-day, once-in-ten-year low flow in the Ohio River.
It should be noted that the majority of criteria pollutants are merely passed through the facility and that the net increase due to operation of BVPS-2 is considered insignificant.
EPA AIR ISSUES BVPS-2 has or will obtain operating permits for the Auxiliary Boilers and Diesel Generators as required by the Pennsylvania Bureau of Air Quality Control.
The emission estimates for the above equipment are discussed in ER-OL Section 3.7 and listed in ER-OL Table 3.7-1.
EPA RADIATION ISSUES No comment.
EPA-4 and EPA RADIATION ISSUES BVPS-2 adopted Summary Table S-3 of 10CFR51, Section 51.20, in ER-OLS Section 5.9.
Further evaluation of uranium fuel cycle impacts is the NRC's responsibility.
EPA RECOMMISSIONING.
Dose estimates for decommissioning were not addressed by DLC in ER-OLS Section 5.8.
It is NRC responsibility to provide more detailed information.
JFD RADIATION EXPOSURE' BVPS-2 is required to show that it meets the requirements of 10CFR50.
The dose conversion factors for the various pathways are developed by the NRC and the relationship to health impact is evaluated by them.
JFD RADIATION INDUCED BIRTH DEFECTS
' BVPS-2 adopted Summary Table S-3 of 10CFR51, Section 51.20, in ER-OLS Section 5.9.
Further evaluation of uranium fuel cycle Lapacts is NRC.
responsibility.