ML20133E668

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Affidavit of G Laroche Re Joint Intervenors Contention 12 Concerning Potential Adverse Effects from Salt & Chlorine Gas That May Be Emitted as Part of Drift from Natural Draft Cooling Towers at Facility
ML20133E668
Person / Time
Site: Vogtle  Southern Nuclear icon.png
Issue date: 08/01/1985
From: Laroche G
Office of Nuclear Reactor Regulation
To:
Shared Package
ML20133E653 List:
References
OL, NUDOCS 8508070782
Download: ML20133E668 (6)


Text

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9 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of

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GEORGIA POWER COMPANY, Docket Nos. 50-424 et al.

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50-425

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(OL)

(Vogtle Electric Generating Plant, )

Units 1 and 2)

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Affidavit of Germain LaRoche I, Germain LaRoche, being duly sworn according to law,> depose and state as follows:

1.

My name is Germain LaRoche.

I am employed by the U.S. Nuclear Regulatory Commission as a Land Use Analyst, Environmental and hydrological Engineering Branch, Division of Engineering, Office of Nuclear Reactor Regulation. My professional qualifications are attached hereto.

2.

The purpose of this affidavit is to address the Applicant's Motion for Summary Disposition of Joint Intervenors' Contention 12 con-cerning potential adverse effects from salt and chlorine gas which may be emitted from the natural draft cooling towers at the Vogtle Electric Generating Plant ("VEGP") as part of the drift from these towers.

In this affidavit, I shall evaluate the effect of the l

l drift from the VEGP cooling towers on the terrestrial environment.

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I have personal knowledge of the matters set forth herein and believe them to be true and correct.

3.

As noted in the Affidavit of Robert Samworth, submitted herewith, chlorine gas will net be emitted from the VEGP cooling towers.

Insofar as salt deposition from the cooling towers is concerned, at the CP stage the applicants estimated a deposition of 342 kg/ha/yr (305 lb/ acre /yr) for a two-unit operation based on a conservative drift rate of 0.015% of the circulating water flow rate, a high dissolved solids concentration, and the assumption that all depo-sition would occur within 1.6 km (1 mile) of the site. The NRC Staff's prediction at the CP stage was 2.6 kg/ha/yr (2.3 lb/ acre /yr) using the average expected value of 0.008% for the drift rate, and 300 mg/L for the TDS, and assuming all deposition occurs within 4.8 km (3 miles) of the site. See FES-CP at 5-15 and FES-OL at 5-11.

4.

In the ER-OL, the applicants obtained the results of modeling studies from four other power plants with similar cooling towers to place the potential drift rate from the Vogtle cooling towers in perspective. See FES-OL at 5-11.

Based on the data for the four plants and on meteorological data for the Vogtle site, the applicants predicted that maximum annual dissolved solids deposi-tion rates for the two cooling towers will be 19 kg/ha/yr (17 lb/ acre /yr) on the site and 17 kg/ha/yr (15 lb/ acre /yr) adjacent to the site. About one-seventh of this drift is the potentially damaging constituent sodium chloride.

1 5.

In a recent study conducted by the NUS Corporation, the drift rate for VEGP was calculated to be 1.7 lb/ acre /yr. This stuc'y utilized NUS's. computer modeling program know as the F0G model. The relia-bility of this modeling program is addressed in the Affidavit of James E. Fairobent, submitted herewith.

6.

The potential injury to vegetation from a salt deposition rate of 1.7 lbs/ acre /yr (as computed in the NUS Study) is neglible. The Environmental Standard Review Plans for the Environmental Review of Construction Permit Applications for Nuclear Power Plants, hJREG-0555, Section 5.3.3.2(1979), states that:

" Deposition of salt drift (Nacl) at rates of 1 to 2 kg/ha/mo L10.7 to 21.4 lbs/-

acre /yr] is generally not damaging to plants. Rates approaching orexceeding10kg/ha/mo[107.2lb/ acre /yr]inanymonthduring the growing season could cause leaf damage in many species."

1 7.

Even using the conservative drift rate estimate at tFe Vogtle plant of 17 lb/ acre /yr based upon the estimates in the ER-OL rather than the drift rate calculated by the F0G model of 1.7 lb/ acre /yr, adverse effects caused by salt drift from the Vogtle cooling towers on the terrestrial ecology in the vicinity of the site is extremely unlikely. As noted in the Applicant's affidavit of Nora A. Blum, none of the studies performed for the Chalk Point cooling towers in Maryland found any harm to vegetation from this range of salt drift l

deposition rates. Blum Affidavit at i 15. As Ms. Blum also notes, comparisons between Chalk Point and VEGP are appropriate since the 7

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same major type of soil is found at the two sites (loamy sand) and the types of vegetation studied at Chalk Point (corn, soybeans, dogwood, and grains) are also present in the area around VEGP.

Id., at 9 13, and ER-OL 6 2.1 and 2.2.

I am in agreement with these conclusions.

8.

In assessing potential damage using the 17 lb/ acre /yr deposition rate, it should also be stressed that drift deposition decreases with the distance from the cooling towers.

In the case of agri-

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cultural crops, the distance to the nearest vegetable garden from t

VEGP is approximately 1.4 miles west-southwest of Plant Vogtle (ER-OLTable5.2-1 sheet 2)andmaximumdriftdepositionwill occur in the opposite direction to the east at the site boundary (Goldmanaffidavitati27). Thus, the actual deposition rate in areas impacted by the VEGP cooling tower drift should be less than the postulated 17 lb/ acre /yr deposition rate.

9.

Damage to agriculture would also be lessened since little land is utilized for agriculture within a five mile radius of VEGP; rather, as indicated in ER-OL page 2.1-8 and based on personal observations made while flying over the area, the greatest single land use j

isdevotedtosilviculture(forestry). Also, the South Carolina portion of the area within a five mile radius of VEGP is entirely withintheSavannahRiverPlantsite(EROLp2.1-8)whichlies east of Plant Vogtle and is not used for agriculture.

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10. Based upon my review of these matters, I have determined that VEGP l

cooling tower drift will have a negligible impact upon agriculture in the areas surrounding the facility.

WN Germain LaRoche i

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I' Sworn to and subscribed before me i

this/# day of August 1985

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Dr. Germain LaRoche Professional Qualifications I am employed as Land Use Analyst in the Environmental and Hydrologic Engineering Branch of the Division of Engineering, Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission.

In this post-tion, I am responsible for evaluating the the potential environmental impact on terrestrial ecosystems and the land use of nuclear power plants and their transmission, facilities.

a Prior to being employed by the NRC, I was director of terrestrial ecology for a private consulting firm.

In this capacity, I directed baseline studies of proposed nuclear and fossil fuel power plants, and large urban and recreational developments.

For ten years ! taught at colleges, attaining the rank of Associate Professor of Biology. These colleges were:

Empire State College, Albany, N.Y.

State University College at New Paltz, N.Y.; Manhattan College and Bronx Community College, Bronx, N.Y.

and Holyoke Community College, Holyoke, Mass.

I have also con-ducted forest and range management research with the U.S. Forest Service.

I received the Ph.D. degree in Botany Plant Ecology from the University of Massachusetts in Amherst, Mass.

an M.S. degree in the same areas, from the Catholic University of America in Washington, D.C.; and a B.A.

degree in Biology from the Catholic University of knerica.

I am a member of Sigma X1, the Ecological Society of America, and the Society of knerican Foresters.

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