ML20128P506

Testimony of RB Samworth Re Rate of Emission of Drift from Facility Cooling Towers.Related Correspondence

ML20128P506
Person / Time
Site:	Palo Verde
Issue date:	05/30/1985
From:	Office of Nuclear Reactor Regulation
To:
Shared Package
ML20128P501	List: ML20128P496 ML20128P506
References
OL, NUDOCS 8506030550
Download: ML20128P506 (9)

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UNITED STATES.0F AMERICA c O NUCLEAR REGULATORY COMMISSION- ..

.BEFORE THE ATOMIC SAFETY AND LICENSING BOARD 00CHETED l .\)StJRC In the Matter of-15 'MY 31 P5 :54 ARIZONA PUBLIC. SERVICE Docket Nos. STN 50-529' .' .-

COMPANY, E 3 .. ) STN 50-530c77;cg g7 glgC ETAFv

-d- 00CXETlha & SEnvirl'-

-(Palo Verde Nuclear Generating ER AliCH Station, Units 2 and.3)

.NRC STAFF. TESTIMONY OF ROBERT B. SAMWORTH v

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'0N THE RATE OF EMISSION OF DRIFT FROM THE PALO VERDE COOLING TOWERS Q1. Please state your name and-position.

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.A1.- My name is' Robert B. Samworth. I am the Leader of the Environmental

Engineering Section within the Division of Engineering, Office of

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. Nucle'ar Reactor Regulation, USNRC..

-Q2. .Do you.have a Profeseional Qualifications Statement?

s A2. .A copy is attached to this' testimony.

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~ Q3.1What is the purpose of your testimony?

- A3...To consider what the propericooling tower drift rate should be for

the PVNGS cooling. towers. .Specifically, I shall compare'the drift rate utilized in Staff's environmental impact assessment, namely

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0.0044% of the circulating water flow rate, with the results of the Environmental Systems Corporation (ESC) study which have been cited by the Applicant's witnesses in their testimony. The ESC Study measured a drift rate of 0.0002% of the circulating water flow rate

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under one of its sampling methods. -

. Q4. Why did the staff use a drift rate of 0.0044% of circulating water flow to perform the environmental assessment?

I A4. This was the rate, which according to Staff's environmental report

, (ER-OL 3.4-3), was the des'ign value for the system and it is the rate which is specified by the tower manufacturer, the Marley Company.

. QS.- Were you concerned whether the Marley rate of 0.0044% could be met?

AS. No. The value was within the range used for other projects and within the' range of measured values for operating cooling towers.

I believe this.is a reasonable value even though this rate was questioned by the Intervenor's consultant, Dr. Michael W. Golay, in his comments that were supplied in January 1984.

'i Q6. Have you read the testimony of Applicant's witness, Dr. Morton I.

Goldman, which was recently filed in this proceeding regarding the cooling tower drift rate?

A6. Yes.

3-Q7. Are you aware of the drift rate which he has recommended?

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A7. Yes. Dr. Goldman cites the study performed by ESC as determining

that the drift rate of the Palo Verde cooling towers will be 0.0002%.

-Q8. Have you reviewed the ESC study?

A8. Yes, I reviewed it briefly when it first came in to NRC in September 1983.

Q9. What is your opinion of the study?

4 A9. It is a good study. ESC used two different techniques (sensitive paper and isokinetic sampling) to measure drift rate on three cells of one cooling tower at Palo Verde. In my opinion, the results provide reasonable satisfaction that the manufacturer's design

- drift rate will be met. The study also demonstrates the difficulties of measuring drift as evidenced by the fact that the results of the two sampling methods utilized in this study varied significantly.

Q10. Do you think the results of the ESC Study relied upon by Dr. Goldman (i.e. the 0.0002% drift rate) should be used for estimating the impact of drift from the PVNGS cooling towers?

A10. Although the ESC Study oives confidence as to the conservativeness of the manufacturer's design rate, there are some shortcomings to the study itself which indicate to me it is better to rely upon the manufacturer's rate. The Study was conducted unter a limited set of conditions. For example, Table 1, which is attached to my testimony',

summarizes selected. data from the ESC study. The actual collection of the data was done in a four-day period. Although one cell was measured twice, the study design did not allow computation of a

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. confidence' interval for the drift rate. The station was not producing electricity and, as a result, the water temperature was at about 15 C (59 F) during the studies. During actual operation the water teinperature will range as high as 48 C (118.8 F). Similarly air temperature during the study period was in the range of 21 C to 24 C (70 to 75 F) whereas ambient temperature at the site ranges seasonally from 7'C.(19 F) to 47 C (116*F). (See ER-OL 5 2.3).

Another limitation of the study was that the quality of the circulating water during the study was not typical of what will exist during station operation.

Moreover, the study was not free of defect. The wind speed during the four days of data collection ranged from a low of about 6 miles per hour during the study of cell I to a high of about 38 miles per hour during the sampling of cell N. Although there are possibly other varying factors, it appears that wind speed may have affected' the amount of drift recorded,since lower drift rates were detected during the periods of higher wind flow.

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A further problem appears to be that the two sampling methods utilized in the study (the isokinetic and the sensitive paper technique) are generally believed to be capable of measuring drift rate results that are within 15% of the true value. However, the values yielded by the two techniques in the study at Palo Verde "

differed by a factor of about 6 (i.e. the isokinetic sampling technique gave an average estimate ot drift rate which is six times the estimate by the sensitive paper technique.) I also note that in his testimony Dr. Goldman did not use the conservative isokinetic value but rather has based his analysis on potential agricultural crop damage on the sensitive paper technique which gave a lower value.

Q11. Is the drift rate indicated by the sensitive paper technique a reasonable rate?

.w All. The Applicant's witness, Mr. Karl R. Wilber, has reported in his testimony (at p. 9 and Exhibit W-8) drift rate measurements at other cooling towers. None of the values for these other towers was as low as the value for Palo Verde. Moreover, as he notes, the 0.0002% value has only been measured in laboratory environments where essentially ideal conditions existed.

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In contrast to the values'in the ESC Study and for the cooling towers cited by Mr. Wilber, Table 2, which is attached to my testimony, shows drift rate values which have been used for assessing impact at nuclear power stations. Although these are

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design values and not measured values (as is the case of the ESC' StudyandthecoolingtowershitedbyMr.Wilber),thevaluesreported at these stations are considerably higher than the value for Palo Verde in the ESC report using the sensitive paper method.

Q12. Based upon the information presently available, what are your conclusions regarding the drift value which should be used for predicting deposition rates at Palo Verde?

A12. I would recommend that the initial assessment of impact for the Palo

. Verde cooling towers be based on the more conservative manufacturer's drift rate of 0.0044%. The ESC Study is useful in demonstrating that the manufacturer's design rate will be met and that any estimate

'of drift based on this value will not underestimate impact.

Personal Qualifications Statement Robert B. Samworth, Ph.D.

May 29, 1985 Robert B. Samworth is employed by the U.S. Nuclear Regulatory Commission as th'a Leader of the Environmental Engineering Section, Environmental and Hydrological Engineering Branch, Division of Engireering, Office of Nuclear Rsgulation. He has held that position since 1976.

As the Section Leader, major portions of environmental impa[t statemen s are prcpared under his supervision. Incl'ubed are essentially all sections on non-radiological impacts to aquatic and terrestrial resources. Specifically caong impacts for which his section is responsible is the assessment of the offects of cooling tower drift.

Dr. Samworth is the senior staff expert on environmental engineering questions and is highly qualified for this responsibility through education cnd training. He holds a B.S. degree in Civil Engineering from the University of Del aware, an M.S. degree in Sanitary Engineering from the Johns Hopkins University, and the Ph.D. degree in Civil Engineering from Cornell Uni ver si ty.

Dr. Samworth joined the regulator'y staff in October, 1972, as an cnvironmental engineer during the period of the NRC's initial NEPA reviews of nuclear power plant license applications. He performed reviews related to impacts of power plant operation on water quality and water use and provided Environn, ental Impact Statement input for several projects prior to assuming th2 responsibilities of Section Leader. He participated in the development of review procedures as set forth in the Environmental Standard Review Plcns, revisions to Regulatory Guide 4.2, and revisions to NRC's regulations for environmental reviews found in 10 CFR Part 51.

Prior to joining NRC he was the Chief of the Grants, Research, and Statistics Branch with the Department of Environmental Services of the Government of the District of Columbia. There he was responsible for Cvaluating new technology f or achieving department objectives in water supply, wasterwater collection and treatment, and solid waste collection and dicposal. He served as liason between laboratory scientists and design cngineers in-the design of the treatment processes employed at the Dietrict's new wastewater treatment plant.

B fore that he was employed as a Public Health Engineer with the Tennessee Valley Authority where he conducted research concerning environmental problems associated with power generation at steam- and hydro-electric g:neration facilities.

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I C E 1. -Sc: ary of Falc Verde Eccling ic>er Test Results Free the ESC Stu:y.

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', Sas;le/ itse Tener t.ir Ter;erature .... kind Mass Drift Rate

.i Eate~ Interval Cell ----------------- - ------ -- ---

- Dry Bulb Wet Balb Speed Direttien SP IK ce; C. deg C. sph degrees g/s g/s

........ ........- ........ ........ ........ ===. ........ ... ... =

May.7 14:05.-1s:05 1-1 22.4 14.1 9 230-360 19:10-21:10 1-2 22.7 13.7 3 270-290 1.51 8.4

'May 8 14:55-16:40 K-1 30.8 17.9 16 210-200 17:35-19:20 K-1-R '29.0 14.0 17 210-205 Maf 9 09:45-11:30 K-2 24.4 13.) 16 200-120 1.82 11.9 12:05-13:M K-2-R 29.9 14.1 24 210-220 2.29 10.6 16:32-16:15 P-1 32.0 14.7 29 230-240 May 10 08:50-10:37 P-2 23.2 13.2 40 200 1.10 9.83 14:00-15:32- N-1 30.1 15.0 35 210 ~

17:35-19:12 h-2 28.9 13.9 40 210 0.425 4.91

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o TAELE 2. Fower Plant Cooling Systes Data ,

a Station Unit Capac- Cooling .

Drift Nater NRC Date of ity'Systee Rate Source Rgn.Coseercial Mme Type 1 Operation Arkansas 2 858 NatD 0.01 Arkansas R. 4 1980 Eeaver Valley 1 810 NatD 0.05 Ohio River 1 1976 ..

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Beaver Valley 2 852 NatD 0.013 Ohio River 1 E1987 Byron -1 '1120 NatD 0.002 Rock R. 3 L1985 Eyron 2 !!20 NatD 0.002 Rock R. 3 C1996 Catawba 2 1145 CircMech 0.008 Catawba R. 2 E1986-

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~Cataeba 1  !!45 CircMech 0.000 Catawba R. 2 E1985 .

Farley 2 814 MechD 0.1 Chitahoochee R. 2 1981 Farley 1 804 MechD 0.1 Chatahcochee R. 2 1977 Fersi 2 1093 NatD (0.1 Lake Erie 3 1986 Grand Gulf 1 .1250 NatD ' O.008 Mississippi 2 198?

Grand Gull 2 1250 NatD 0.000 Mississippi 2 E19??

Harris (Shearon) 915 NatD 0.002 Cape Fear R. 2 E1986 Hatch 2 771 NatD (0.1 Altaeaha R. 2 1979

-Hatth. 1 -757 NatD (0.1 Altamaha R. 2 1975 Hope Creek 1067 NatD 0.00375 Delaware R. 1 E1986 Liwrick 1 1065 NatD 0.03 Schuylkill R. 1 E1986 p Liser.ck 2 1065 NatD 0.03 Schuylkill R. I  ????

Palisades 635 MechD 0.005 Lake Michigan 3 1971 Palo Verde- 3 1304 CirtMech 0.00j4PhoenixSewage 5 E1987 Palo Verde l' 1304 CirtMech- 0.0044 Phoenix Semage 5 E1985 Palo Verde 2 1304 CirtMech 0.0044 Phoenix Semage 5 E1986 Peach Bottos 2 -1051 MechD (0.2 Susquehanna R. I 1974 Peach Bottos 3- 1035 MechD (0.2 Susquehanna R. I 1974

- Pe ry 2 1205 NatD (0.01 Lake Erie 3 E19??

Perry 1 1205 NatD (0.01 Lake Erit 3 E1986 Frairie Island 1 503 MechD (0.2 Mississippi R. 3 1973 Frairie Island 2 500 MechD (0.2 Mississippi R. 3 1974 Rancho Seco 873 NatD -(0.01 Folsoe South Canal 5 1975 River Bend _

934 CircMech 0.01 Mississippi 4 E1986

-Sequoyah 2 !!48 NatD 0.01 Tennessee R. 2 1982 Sequoyah. I  !!28 NatD 0.01 Tennessee R. _ 2 1981 Susquehanna 1 1052 NatD 0.002 Susquehanna R. 1 E198?

Vogtle 1 1100 NatD 0.000 Savannah R. 2- E1987

. Vogtle. 2- 1100 NatD 0.006 Savannah R. 2 E19??

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