ML20134P067

Staff Exhibit S-11,consisting of NRC Transmitting RR Samworth Testimony Re Rate of Emission of Drift from Cooling Towers.Summary of Cooling Tower Test Results from Environ Sys Corp Study Encl

ML20134P067
Person / Time
Site:	Palo Verde
Issue date:	06/12/1985
From:	Dewey L NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD)
To:	Callihan D, Cole R, Lazo R Atomic Safety and Licensing Board Panel
References
OL-S-011, OL-S-11, NUDOCS 8509060126
Download: ML20134P067 (11)

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UNITED STATES

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NUCLEAR REGULATORY COMMISSION 5< M E WASHINGTON, D. C. 20555

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ML Robert M. Lazo, Esq., Chairman Dr. Richard F. Cole c.;;.y%'['

Administrative Judge Administrative Judge Atomic Safety and Licensing Board Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission. -

Washington, DC 20555 Washington, DC 2055Er Dr. Dixon Callihan James H. Carpenter Administrative Judge Administrative Judge Union Carbide Corporation Atomic Safety and Licensing Board P.O. Box Y U.S. Nuclear Regulatory Commission Oak Ridge, TN 37830 Washington, DC 20555 In the Matter of ARIZONA PUBLIC SERVICE COMPANY, ET AL.

(Palo Verde Nuclear Generating Station, IfniIs 2 and 3)

Docket Nos. STN 50-529 and STN 50-530

Dear Administrative Judges:

Enclosed is the testimony of Dr. Robert B. Samworth which the Board requested be filed by May 30, 1985.

Sincerely, m

W) &f' s Lee Scott Dewey Counsel for NRC Staff

Enclosure:

As stated cc: Arthur C. Gehr, Esq. Charles Bischoff, Esq.

Theodore W. Barudin Ms. Lee Hourihan Atomic Safety and Licensing Atomic Safety and Licensing Board Panel Appeal Board Lynne Bernat,ei, Esq. Kenneth Berlin Docketing and Service Section Ron Rayrer Nacune MsmAMM COMMi$?M Dechet Ns, Othciel Eth. No.

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

ARIZONA PUBLIC SERVICE Docket Nos. STN 50-529 "

COMPANY, ET AL.

) STN 50-530 -

. .) .

(Palo Verde Nuclear Generating )

Station, Units 2 and 3) )

NRC STAFF TESTIMONY OF ROBERT B. SAMWORTH ON 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 l

Engineering Section within the Division of Engineering, Office of Nuclear Reactor Regulation, USNRC.

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Q2. Do you have a Professional Qualifications Statement?

I i A2. A copy is attached to this testimony.

I Q3. What is the purpose of your testimony?

i A3. To consider what the proper cooling 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 1

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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

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by the Applicant's witnesses in their testimony. The ESC Study measured a drift rate of 0.0002% of the circulating water flow rate 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?

A4. This was the rate, which according to Staff's environmental report (ER-0L 3.4-3), was the design 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.

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?

a A6. Yes.

Q7. Are you aware of the drif t rate which he has recomended?

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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%.

08. 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?

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 l l

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?

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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 under a limited set of conditions. For example, Table 1, which is attached to my testimony, l summarizes selected data from the ESC study. The actual co.ection 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 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 temperature 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 Q 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.

1 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 i 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.

A further problem appears to be that the two sampling methods I

< utilized in the study (the isokinetic and the sensitive paper

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technique) are generally believed to be capable of measuring drift

] rate results that are within 15% of the true value. However, the j 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 of drift rate which is six times j 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?

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 l 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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i 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

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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-

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Study and the cooling towers cited by Mr. Wilber), the values reported at these stations are considerably higher than the value for Palo Verde in the ESC report using the sensitive paper method.

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j Q12. Based upon the information presently available, what are your conclusions regarding the drift value which should be used for j 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 I

drift rate of 0.0044%. The ESC Study is useful in demonstrating that 1

the manufacturer's design rate will be met and that any estimate of drif t based on this value will not underestimate impact.

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

May 29, 1985 j

Robert B. Samworth is employed by the U.S. Nuclear Regulatory Commission as j the Leader of the Environmental Engineering Section, Environmental and  !

I Hydrological Engineering Branch, Division of Engineering, Office of Nuclear Regulation. He has held that position since 1976.

t As the Section Leader, major portions of environmental impac't statements are l prepared under his supervision. Included are essentially all sections on j non-radiological impacts to aquatic and terrestrial resources. Specifically among impacts for which his section is responsible is the assessment of the

, effects of cooling tower drift.

i Dr. Samworth is the senior staff expert on environmental engineering

{ questions and is highly qualified f or this responsibility through education i and tr aining. He holds a B.S. degree in Civil Engineering from the i University of Delaware, an M.S. degree in Sanitary Engineering from the

! Johns Hopkins University, and the Ph.D. degree in Civil Engineering from j Cornell University.

Dr. Samworth joined the regulatory staff in October, 1972, as an

, environmental engineer during the period of the NRC's initial NEPA reviews j of nuclear powm plant license applications. He performed reviews related to impacts of power plant operation on water quality and water use and provided j En v i r onn.en t a l Impa:t Statement input for several projects prior to assuming i the responsibilities of Section Leader. He participated in the development

! of revi ew procedures na 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.

J Prior to joining NRC he was the Chief of the Grants, Research, and l Statistics Branch with the Department of Environmental Services of the Government of the District of Columbia. There he was responsible for ovaluating new technology for achieving department objectives in water i supply, wasterwater collection and treatment, and solid waste collection and disposal. He served as liason between laboratory scientists and design

] engineers in the design of the treatment processrs employed at the District's new wastewater treatment plant.

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- before that he was employed as a Public Pealth Engineer with the Tennessee 1 Valley Authority where he conducted research concerning environmental j problems associated with power generation at steam- and hydro-electric l gener ation facilities.

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. e C:: ling T:.e Test Fes;1ts Frcs the ES: Study.

. aw Sae:!e hee ic.er 4 r Ter;s at;re .. .und Mass Drt.t Rate i ae I-'s ,s! Cell ----------------- ----------------- -----------------

Py Llb Wet i.it Speed Direction 54 It de; C. te; C. s;h degrees g/6 g/5 N. 7 14:0'-1$.05 I-l 22.4 14.1 9 230-360 15:1',- .:'0 . 1-: 22.7 13.7 3 270-290 1.51 S.4 h.5  !!:55-1::4 k-1 0.6 17.9 16 210-200 i 17 '5 ' .;::'. >-1-R 'i.0 14.0 17 210-:05 N,i Ji:U-il:L t- 24.4 13.,7 le 200-160 1.82 11.9 1;:v5-i!:50 >~R 27.9 14.1 24 210-220 2.23 10.6 1:.;;-1E:15 F-1 32.0 14.7 29 2:0-240 N y 10 'E:L-10:37 F-  !.. D.2 C 200 1.10 9.E3 14: e .5::: N-1 30.1 [5.0 35 210

.- g* g Aa ag e f ame 1m1:/.*9.7 : 44 b*6 4C.=7 14 7 4V m Als g) V.9.C 4.c.74 u_

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l TAELE 2. Fomer Flant Cooling Systes Data I

e l Station Unit Capac- Cooling Drift Water NRC Date of ity Systen Rate Source Rgn.Coseercial Mae Type 1 Operation

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l Arkansas 2 859 NatD 0.01 Arkansas R. 4 1980

]' feaver Valley 1 610 NatD 0.05 Ohio River 1 1976

Eeaver Valley 2 652 NatD 0.013 Dhio R ver  ! E1987 t Byron 1 1120 NatD 0.002 Rock R. 3 E1985 Eyron 2 1120 NatD 0.002 Rock R. 3 E1986 Cata=ta 2 1145 CirtMech 0.008 Catamba R. 2 E198o

{ Catada 1 !!45 CirtMech 0.000 Catawba R. 2 E1965 .

Farle r 2 E14 MechD 0.1CytahoccheeR. 2 1981 Farley 1 004 MechD 0.1 Chatahcochee R. 2 1977 r Fersi 2 1093 NatD (0.1 Lane Erie 3 1956 Grand Guli 1 1250 NatD 0.008 Mississippi 2 1987 Grand Gulf 2 1250 NatD 0.006 Mississippi 2 E19??

Harris (Shearon) 915 NatD 0.002 Cape Fear R. 2 E1986 i Hatch 2 771 NatD (0.1 Altaeaha R. 2 1979 Fatch 1 757 NatD (0.1 Altaeaba R. 2 1975 Hc;e Creek 1067 Natl 0.00375 Delaware R. 1 E1986 Limerick 1 1065 NatD 0.03 Schuylkill R. 1 E1986 Lieerick 2 1065 NatD 0.03 Schuylkill R. I  ????

Falisades 635 MethD 0.005 Lake Michigan 3 1971 Falo Verde 3 1304 CircMech 0.00,44 Phoenix Se age 5 E1967 Falo Verde i 1304 CircMech 0.0044 Fhoenix Sesage 5 E1985 Falo Verde 2 1304 CircMech 0.0044 Phoenis Semage 5 E1986

! Feach Esttos 2 1051 MechD (0.2 Susquehanna R. I 1974 Feach Icttos 3 1035 MechD (0.2 Susquehanna R. I 1974 Ferry 2 1205 NatD (0.01 Late Erie 3 E19??

Ferry 1 1205 NatD (0.0! Lake Erie 3 E1986

Fratrie Island 1 503MechD (0.2 Mississippi R. 3 1973 i Frairie Island 7 500 MechD (0.2 Mississippi R. 3 1974 Eancho Seco 673 NatD (0.01 Folson South Canal 5 1975 i Riier Eend 934 Ci-cMech 0.01 Mississippi 4 E1986 Sequcyan 2 !!49 NatD 0.01 Tennessee R. 2 1952 i

Sequoyah 1 1128 NatD 0.01 Tennessee R. 2 1981 Susqueba*.na 1 1052 NatD 0.002 Susquehanna R. 1 E198?

1 Vogtle  !  !!00 NatD 0.000 Savannah R. 2 E1987 Vogtle 2 1100 Nat0 0.005 Savannah R. 2 E19??

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