ML20133E650
| ML20133E650 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 08/02/1985 |
| From: | Dewey L NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| To: | Atomic Safety and Licensing Board Panel |
| Shared Package | |
| ML20133E653 | List: |
| References | |
| CON-#385-125 OL, NUDOCS 8508070774 | |
| Download: ML20133E650 (5) | |
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August 2,1985 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION C3gEi[0 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
'85 Alj3 -7 A10 $2 GEORGIA POWER COMPANY
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Docket Nos. 50-424 CFFILE Cr SICat f AK g a_1.
-425 00 Cati g ERVO (Vogtle Electric Generating Plant, Units 1 and 2)
NRC STAFF'S RESPONSE TO APPLICANTS' MOTION FOR
SUMMARY
DISPOSITION OF JOINT INTERVEN0RS' CONTENTION 12 (COOLING TOWER DRIFT)
I.
INTRODUCTION By Motion dated July 11, 1985, Applicants have moved for summary disposition of Contention 12 (cooling tower drift), pursuant to 10 C.F.R. 6 2.749. The Staff supports the Applicants' motion on the grounds that they have demonstrated the absence of any genuine issue of material fact with regard to the matters involved in this contention, and they are entitled to a favorable decision as a matter of law.
In support of this response, the Staff relies upon the Affidavits of Robert B. Samworth, Germain LaRoche, and James E. Fairobent, submitted herewith.
II. DISCUSSION Joint Intervenors' Contention 12 was admitted by the Board in its order of September 5,1984. Georgia Power Co. (Vogtle Units 1 & 2),
LBP-84-35,20NRC887,908(1984). Joint Contention 12, as revised, states as follows:
0508070774 850002 PDR ADOCK 05000424 O
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The applicant has not properly assessed the 4
i amount of salt and chlorine gas release from the cooling towers and the extent of consequent adverse agricultural and environmental damage in the area
.of Plant Vogtle.
Discovery on Contention 12 was conducted by Applicants, Joint Intervenors and the Staff. On July 11, 1985, the Applicants filed i
the instant motion supported by the affidavits of Daniel H. Warren, Morton I. Goldman, and Nora A. Blum.
The Staff has previously discussed the legal principles regarding summary disposition in our July 26, 1985 response to Applicants' motion for summary disposition of Joint Intervenors' Contention 10.3.
In order to avoid unnecessary repetition, that discussion is incorporated by reference herein.
A.
The Emission of Salts from the Vogtle Cooling Towers Will Not be Harmful to the Environment I
Applicants' motion for summary disposition on Contention 12 relies, in part, upon a study performed by the NUS Corporation (NUS). The Applicants commissioned this study after Contention 12 had been admitted for litigation and the Board noted its desire for a more definitive assessment of the Vogtle drift deposition rates and for a determination as to whether the amount of drift will result in damage to vegetation.
LBP-84-35, supra, 20 NRC at 910.
Prior to the NUS Study, the Applicants had relied upon less sophis-ticated methods for computing deposition rates for salts emitted from the Vogtle cooling towers. The rates utilized in Applicants' ER-OL were j
obtained by predicting maximum rates based upon models utilized by other
plants having s_imilar cooling towers and meteorological environments.
Applicants' Motion at 17-18. The Applicants have determined that these earlier methods of determining the drift rates are overly conservative and less accurate than the rates tomputed by NUS in its recent study.
Id_. at 13.
The study conducted by NUS was a modeling study of the amount of salts expected to be emitted from the Vog+1e cooling towers.
It util-izes two years of detailed meteorological data collected at the site and a computer modeling program commonly referred to as the F0G model.
Predictions based upon the F0G model have been utilized for other t
plants licensed by the NRC, and this model is believed to produce reasonable episodal estimates of deposition from natural draft cooling towers.
Fairobent Affidavit at it 6-7, 9, 12.
Utilizing the F0G model, the NUS study predicted that the maximum drift deposition rate for Vogtle would be 1.7 pounds per acre per year.
LaRoche Affidavit at 15.1/ As set forth in NUREG-0555, salt deposition in this small amount will not be harmful to vegetation, nor will it result in damage to vegetation in the vicinity of the Vogtle plant.
LaRoche Affidavit at 6; NUREG-0555, " Environmental Standard Review Plan for the Environmental Review of Construction Permit Applications for Nuclear Power Plants" (1979), Section 5.3.3.2.
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This rate is based upon a lower cooling tower drift rate (0.008%)
than the rate originally guaranteed by the manufacturer (0.03%).
Although Staff has not been furnished materials explaining the basis for this lower figure, the Staff is satisfied, based upon (FOOTNOTE CONTINUED ON NEXT PAGE) 4
. a Further, setting aside the results of the NUS study, it should be noted that salt deposition rates as high as 17 lbs./per acre /per year, which the Applicants had earlier estimated in their ER-OL, should not cause environmental damage in the Vogtle vicinity.
In a study of the Chalk Point cooling towers, under conditions very similar to those at Vogtle, salt deposition in this range did not cause environmental damage.
LaRoche Affidavit at 1 7.
Id. at 11 8-9.
In addition, a projected deposition rate of 17 lbs./per acre /per year would impact upon only a relatively small portion of the area surrounding Vogtle, since drift deposition decreases with distance from the cooling towers, and only a t
limited amount of land within a 5 mile radius of the plant is devoted to agricultural use.
Id.
Under these circumstances, it is clear that environmental damage will not result from the emission of salts from the Vogtle cooling towers, and it is appropriate that this portion of the contention be resolved by summary disposition.
B.
Chlorine Gas Will Not Be Emitted From the Vogtle Cooling Towers In addition to the salt deposition issue, Joint Intervenors have postulated potential damage to the environment resulting from the release of chlorine gas from the plant's cooling towers.
There is no (F0OTNOTE CONTINUED FROM PREVIOUS PAGE) current technology and measured drift rates for other cooling towers, that Applicants' use of a 0.008% drift rate is sufficiently conservative. Samworth Affidavit at 1 7.
factual basis for this assertion. While chlorine gas will be added to the circulating water system, it will essentially become totally hydrolyzed long before it reaches the cooling towers. Samworth Affi-davit at 1 6.
Under these circumstances, no damage can possibly result due to the release of chlorine gas from the Vogtle cooling system.
IV. CONCLUSION For the reasons set forth above and in the affidavits attached hereto, the Staff submits that there is no dispute as to any material fact concerning Joint Intervenors' Contention 12, and Applicants' 6
motion for summary disposition of Contention 12 should be granted.
Respectfully submitted.
aA.
C*i/\\i t
Lee Scott Dewey Counsel for NRC Staff Dated at Bethesda, Maryland this 2nd day of August, 1985
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