ML20133E687

Affidavit of RB Samworth Re Joint Intervenors Contention 12 Concerning Potential Environ Impact of Salts & Chlorine Gas Emitted from Natural Draft Cooling Towers at Facility. Certificate of Svc Encl

ML20133E687
Person / Time
Site:	Vogtle
Issue date:	08/02/1985
From:	Samworth R Office of Nuclear Reactor Regulation
To:
Shared Package
ML20133E653	List: ML20133E650 ML20133E655 ML20133E668 ML20133E687
References
OL, NUDOCS 8508070789
Download: ML20133E687 (10)

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UNITED STATES OF AMERICA

( NUCLEAR REGULATORY COMMISSION

- BEFORE THE ATOMIC SAFETY AND LICENSING BOARD in the Matter of )

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

-- ) 50-425

) (OL)

(Vogtle Electric Generating Plant, Units 1 and 2)

Affidavit of Robert B. Samworth t

I I Robert B. Samworth, being duly sworn according to law, depose and say as follows:

1. My name is Robert B. Samworth. I am employed by the U.S. Nuclear Regulatory Commission as the Leader of the Environmental Engineering Section in the Office of Nuclear Reactor Regulation. A statement of my professional qualifications is attached.

2. The purpose of this affidavit is to coment on the " Applicants' Motion for Summary Disposition of Joint Intervenors' Contention 12."

Contention 12 concerns the potential environmental impact of salts and chlorine gas emitted from the natural draft cooling towers at the Vogtle Electric Generating Plant.

My comments address three subjects related to applicants' motion:

(1) the effect on cooling tower drift created by the addition of 950800 SDN *l & OS g 4

r chlorine to the plant's cooling water; (2) the likelihood that chlorine gas will be emitted from the cooling water; and (3) the antic.ipated drift rate for the Vogtle natural draft cooling towers.

The Effect on Cooling Tower Drift Created by the Addition of Chlorine to the Cooling Water.

l 3. The chlorine which is to be added to the Vogtle cooling water for the purpose of inhibiting biofouling will be emitted as part of the i cooling tower drift. Most of the chlorine will be chemically reduced

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to the chloride ion within the circulating water system. Since the chloride ion is potentially damaging to vegetation at high loading rates, it is conservatively assumed herein that all of the chlorine is reduced to the chloride ion.

4. There is a linear relationship between drift quality and drift deposition rate. That is, a ten percent increase in the concen-tration of a chemical in the drift will increase the deposition rate for that chemical by ten percent at each point of deposition.

It is appropriate to use average values (as opposed to instantaneous values) for water quality, since average values reflect the potential cumulative effect of long-term deposition. Table 1 attached hereto summarizes data for the quality of the Savannah River makeup water and for the plant's concentrated circulating water. These data are drawn from Table 4.8 of the Staff's Final Environmental Statement for the Vogtle plant (NUREG-1087, March 1985) ("FES-OL"), page 4-56.

The effect on these values created by the addition of chlorine to lrg -

r the cooling water can be shown most simply by using the applicants' estimate of annual average chlorine usage of 390,000 pounds for each snit. (0L-FES, Table 4.2, page 4-46). If the cooling water system is operated at four cycles of concentration all year, the j average blowdown would be 5,000 gpm, and the average increment in chloride concentration in the blowdown (and in the circulating water) due to biofouling control measures would be 13.7 mg/1. As indicated in Table 1, the effect on the cooling tower drift due to this chlorine addition would represent about a six percent increase in total dissolved solids (TDS), and about a fifty percent increase in chloride.

5. Fact 4 of Applicants' Statement of Material Facts states that the maximum drift deposition rate that will occur during operation of VEGP will be 1.7 pounds per acre per year. While this calculation does not reflect the chloride increment resulting from the addition of chlorine to the cooling water, the resulting incremental increase in chloride deposition would have only a small effect on drift deposition rates, amounting to an increase of no more than several percentage points. The applicants have accounted for this added increment to the drift in Facts 18 and 19 of their Statement of Material Facts, and have properly concluded this increment resulting from the addition of chlorine to the cooling water will not add significantly to the cooling tower drift deposition rates. The Staff agrees with the applicants' conclusion.

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l The Likelihood That Chlorine Gas Could Be f Emitted From the Vogtle Cooling Towers 1

6. Chlorine is delivered to the Vogtle site as a gas. However, it is i'

to be added to the circulating water in water solution, and cannot be purged from the cooling towers in measurable amounts as a gas under the expected range of operating conditions. As noted in the FES-OL (Response to JEG-5, at page 9-21), the chemical action of chlorine in water is well documented and leads unequivocally to the expecta-tion that chlorine added for biofouling control essentially will be totally hydrolyzed, and will not be in a volatile form >in the cir-culating water system. Applicants' facts 13-17 of their Statement of Material Facts rely on this same classic chlorine chemistry in their determination that the circulating water will not contain measurable amounts of chlorine gas and, accordingly, that chlorine gas will not be emitted from the cooling towers. The Staff agrees with these conclusions.

l The Reliability of the Drift Emission Rate Utilized by Applicants l

7. The effectiveness of the cooling towers' drift eliminators has a l

significant impact upon the rate of cooling tower drift. Acc0rding to the applicants, the supplier of the Vogtle natural draft cooling towers initially guaranteed that the drift rate would be less than 0.03% of the circulating water flow rate, and subsequently stated that the expected drift rate would be 0.004% or less for natural

draft cooling towers with drift eliminators similar to those at Vogtle. To be conservative, the applicants have used a drift rate of 0.408% in estimating the drift deposition (See Facts 8 and 11 of Ap'plicants' Statement of Material Facts). Although the tests and analyses supporting the cooling tower suppliers' drift rate projections have not been submitted for Staff review, the Staff notes that drift rates of 0.008% and below are attainable with current technology, and measured drift rates significantly lower than this havebeenrepohtedforotherplants. Accordingly, the Staff believes that Applicants' use of a 0.008% drift rate for the Vo tle natural draft cooling towers is sufficiently conservative.

hh. A Robert B. Samworth Subscribed and sworn to before me this 2nd day of August, 1985 h Notary Pubric A O^

My commission expires: 7,/f /F6 1

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1 TABLE 1:

Makeup Water Quality and Drift Quality For the Vogtle Circulating Water System Savannah River Water Quality Cire.

FES-CP Values Data for 1979-83 System Concen- Incre-Quality Parameter Range' Average Range Average tration ment Total Dissolved 41.8-76.3 59.9 31-115 55.7 222.8 13.7 Solids

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Chloride ion 0-17.0 4.8 2.4-10 6.0 24.0 13.7 Notes:

Data are from the FES-OL Table 4.8, page 4-56.

All values are mg/1.

Values in the column labelled " Circ. System Concentration" are the calculated average values for the Circulating Water System based on four cycles of concentration using the average water quality value for the period 1979-83.

. The 13.7 mg/l increment (due to the addition of chlorine to the circulating water system) is in addition to the values shown in the column for " Circ. System Concentration". See Affidavit f 4 above.

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

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

. - As the Section Leader, major portions of environmental impait statemen s are prepared under his supervision. Inc1'Uded are essentially all sections on non-r ad i ol og i c al impacts to aquatic and terrestrial resources. Specifically cmong 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 questi ons and i s highly qual t fled f or this responsibility through education cnd training. He holds a B.S. degree in Civil Engineerind from the University of Delaware, an M.S. degree in Sanitary Engineering from the Johns Hopkins University, and the Ph.D. degree in Civil Engineering from Cornell University.

Dr. Samworth joined the regulatory staf f in October, 1972, as an environmental engineer during the period of the NRC's i ni ti al 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 the responsibilities of Section Leader. He participated in the development of review procedures as set forth in the Environmental Standard Review Plans, 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 ovaluating new technology f or achieving department objectives in water eupply, wasterwater collecti0n and treatment, and solid waste collection and disposal. He served as liason between laboratory scientists and design cngineers in- the design of the treatment processes emp1'ayed at the District's new wastewater treatment plant.

Bef ore 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 generation facilities.

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 00tKETEP USNRC

- BEFORE THE ATOMIC SAFETY AND LICENSING BOARD

'85 AUG -7 A10 :52 In the Matter of )

GEORGIA POWER C0. ) Docket Nos. 50-424 [0ChTbG YE Vlb

--et al. ) 50-425 BRANCH

. ) (0L)

(Vogtle Electric Generating Plant, )

Units 1 and 2) )

NOTICE OF APPEARANCE Notice is hereby given that the undersigned attorney herewith enters an appearance in the above-captioned matter. In accordance>with 6 2.713, 10 C.F.R. Part 2, the following information is provided:

Name: - Lee S. Dewey Address: - Office of the Executive Legal Director U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Telephone: - (301) 492-7510 Admission: - Supreme Court of Tennessee U.S. District Court for the District of Columbia U.S. Supreme Court Name of Party: - NRC Staff U.S. Nuclear Regulatory Comission Washington, D.C. 20555 Respectfully submitted,

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u-Q' Lee Scott Dewey Counsel for NRC Staff Dated at Bethesda, Maryland this 2nd day of August, 1985

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 00CKETED USNRC

- BEFORE THE ATOMIC SAFETY AND LICENSING BOARD

'85 AUG -7 N0 :52 In the Matter of )

F GEORGIA POWER C0. ) Docket Nos. 50-424 [0C T h ER b!

--et al. ) 50-425 BRANCH

) (0L)

(Vogtle Electric Generating Plant, )

Units 1 and 2) )

. CERTIFICATE OF SERVICE -

I hereby certify that copies of "NRC STAFF RESPONSE TO APPLICANTS' MOTION FOR

SUMMARY

DISPOSITION OF JOINT INTERVEN0RS' CONTENTION 12 (C0OLING TOWER DRIFT" and " NOTICE OF APPEARANCE" in the above-captioned proceeding have been served on the following by deposit in the United States mail, tirst class or, as indicated by an asterisk, through deposit in the Nuclear Regulatory Commission's internal mail system, this 2nd day of August, 1985.

Morton B. Margulies, Esq., Chairman

• Mr. Gustave A. Linenberger, Jr.*

Administrative Judge Administrative Judge Atomic Safety and Licensing Board Atomic Safety and Licensing Board Panel Panel U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Washington, D.C. 20555 Dr. Oscar H. Paris

• Bradley Jones, Esq.

Administrative Judge Region 1 Counsel Atomic Safety and Licensing Board U.S. haclear Regulatory Commission Panel Suite 3100 U.S. Nuclear Regulatory Commission 101 Marietta Street Washington, D.C. 20555 Atlanta, GA 30303 Bruce W. Churchill, Esq. Douglas C. Teper David R. Lewis, Esq. 1253 Lenox Circle Shaw, Pittman, Potts & Trowbridge Atlanta, GA 30306 1000 M Street, N.W.

Washington, D.C. 20036

Atomic Safety and Licensing Laurie Fowler, Esq.

Board Panel

• 218 Flora Ave. NE U.S. Nuclear Regulatory Commission Atlanta, GA 30307 Washington, D.C. 20555 Docketing and Service Section* Atomic Safety and Licensing Office of the Secretary Appeal Board Panel

• U.S. Nuclear Regulartory Commission U.S. Nuclear Regulatory Connission Washington, D.C. 20555 Washington, D.C. 20555 James E. Joiner, Esq. Ruble A. Thomas Troutman, Sanders, Lockerman, Southern Company Services, Inc.

& Ashmore P.O. Box 2625 127 Peachtree Street, N.E. Birmingham, AL 35202 Candler Building, Suite 1400 Atlanta, GA' 30043 Tim Johnson .

Executive Director Campaign for a Prosperous Georgia -

175 Trinity Avenue, S.W.

Atlanta, GA 30303 A k L'ee Scott Dewey Counsel for NRC Staff

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