ML20148D971

Responds to Re Coordinating NRC & EPA for Review of Discharge Permit Appl,Amend to Constr Permit & Issuance of Operating Lic

ML20148D971
Person / Time
Site:	Comanche Peak
Issue date:	10/19/1978
From:	Moore V Office of Nuclear Reactor Regulation
To:	Robert Elliott ENVIRONMENTAL PROTECTION AGENCY
References
NUDOCS 7811060056
Download: ML20148D971 (3)

Text

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/g* Riog'o UNITED STATES ~*

N 8 37 T n NUCLEAR REGULATORY COMMISSION i..

g W ASHINGTON. D. C. 20555 $Yk

%*****/ OCT 191978 Docket Nos. 50-445 and 50-446 l

Robert B. Elliott, Chief Permits and Support Branch (6 AEP)

U. S. Environmental Protection Agency Region 6 1201 Elm Street Dallas, Texas 75270

Dear Mr. Elliott:

This letter is in response to your letter of September 20, 1978 regarding coordination of our two agencies in review of applications for a discharge permit (NPDES application No. TX0065854) and amendment of construction permits and issuance of operating licenses for the Comanche Peak Steam Electric Station.

We recognize that the delay of NPDES Permit issuance until the Nuclear Regulatory Commission (NRC) completes its review of the environmental aspects of the operating license may be a problem. Our review may not be completed for as much as about two years from now, since start of our detailed review may be a year away. We normally start our full review pursuant to the National Environmental Policy Act (NEPA) about eighteen months before expected fuel loading of the facility, which is currently estimated to be in the twelve month period ending July 1981.

We expect the applicant to resubmit the Environmental Report in about a month. If it is accepted, we will re-examine fuel load projections about January 1979 and establish an environmental review schedule. We believe, however, that the description of aquatic impacts in our state-ment should reflect EPA's findings and, furthermore, that conclusions in the statement should be consistent with conclusions reflected in the NPDES permit.

We have an ongoing environmental review of this plant regarding an application for an amendment to the constrinction permits, as we have discussed before. This relates to a request that a study required by NRC to minimize use of chlorine in the prevention of biofouling of the plant's cooling system be rescheduled after plant start-up. Approval by NRC of this amendment request is currently a prerequisite to the applicant's resubmittal of the Environmental Report. Our technical review group at Oak Ridge National Laboratory just completed its assessment of this amendment request. Our staff at NRC is reviewing this assessment, and we 7&l1060bN

s .

Robert B. Elliott l l

would appreciate your comments on the ORNL assessment and applicant's submittal as well before we take final action on the amendment request.

The ORNL assessment and background informa+ ion on this amendment request have previously been sent to your office.

The material on the chlorination minimization study is directly pertinent to your proposed NPDES permit, as your proposed permit also requires this study be performed. NRC staff has reached a preliminary conclusion that the applicant's amendment request can be approved, but we wish your comment before final action. Additional specific comments we offer on the proposed HPDES permit (TX0065854) are as follows.

The descriptions of flow and temperature limits for outfall number 002, reservoir overflow, are not clear as to the limits imposed, if any (page 3). This also is the case for the flow limits for outfall numbers 101, low-volume wastewater (page 4), and 301, sewage (page 6).

The chlorine limits for outfall 201, condenser cooling water, would be consistent with our Final Environmental Statement (Construction) issued June 1974 if they were in terms of total residual chlorine and set a maximum limit of 0.1 mg/l (page 5). Our FES is cited in your letter as the basis for your limits, and we advocate the 0.1 mg/l limit as discussed in our FES, subject to a minimization study. We concur in the requirement for a chlorine minimization study as set forth on page 14 and suggest a cross-reference to this requirement as a footnote on page 5.

It is unclear what is meant by the entry "none" on page 7 as to the schedule for compliance with the effluent limitations. Will compliance be required upon start-up?

We note that you have approved the makeup water intake on Lake Granbury and have required a program to monitor impingement and entrainment at the circulating water intake in Squaw Creek Reservoir (page 14). We wish to have your assessments on these aspects of the plant reflected in our EIS for the operating licenses, along with your assessments on the chlorination study and toxic i;apacts of chlorine discharges and other pertinent issues regarding water quality impacts.

We are looking forward to continued joint coordination on our respective .

activities regarding this proposed facility and to benefiting from specific input from you for our EIS in the area of water quality impacts l

l s a y n

Robert B. Elliott and controls. The former project manager on this case, Mr. J. D. Jackson, has just lef t our agency. Mr. Richard S. Cleveland is now the assigned environmental project manager. Please feel free to contact him directly on any points discussed above and on our ongoing coordination on this case. Mr. Cleveland may be reached at (301) 492-8428.

Sincerely, Vl H pe n#- 3 '-

Original si5ned b'l t .

Voss A. Moore, Assistant Director for Environmental Projects Division of Site Safety and Environmental Analysis l

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