ST-HL-AE-1706, Forwards Util Proposed Responses to State of Tx Comments Re Des
| ML20207J403 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 07/18/1986 |
| From: | Wisenburg M HOUSTON LIGHTING & POWER CO. |
| To: | Noonan V Office of Nuclear Reactor Regulation |
| References | |
| CON-#386-092, CON-#386-92 OL, ST-HL-AE-1706, NUDOCS 8607290046 | |
| Download: ML20207J403 (17) | |
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The Light (OE E
Houston Lighting & Power P.O. Box 1700 Houston. Texas 77001 (713) 228-9211 July 18, 1986 ST-HL-AE-1706 File No.. G07.03 Mr. Vincent S. Noonan, Project Director PWR Project Directorate #5 U. S. Nuclear Regulatory Commission Washington, DC 20555 South Texas Project Units 1 and 2 Docket Nos. STN 50-498, STN 50-499 Draft Environmental Statement; Comment Review
Dear Mr. Noonan:
As discussed with N. Prasad Kadambi of your staff, Houston Lighting &
Power (HL&P) has reviewed comments received by your office regarding the South Texas Project Draft Environmental Statement (DES).
In the attachment we are providing information which we believe will be useful during your development of formal responses to the comments received.
HL&P has reviewed coranents from the following State of Texas agencies:
Houston-Galveston Area Council, Texas Department of Health, Public Utility Commission and the Texas Water Commission.
In addition, we have reviewed comments from Region VI of the U. S. Environmental Protection Agency.
If you should have any questions on this matter, please contact Mr. J. S.
Phelps at (713) 993-1367.
Very truly rs,
/&
M.IR Wise burg Manager, Nu lear Licen ng JSP/yd Attaclunent :
DES Comment Review 8
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flouston Lighting & Power Company ST-HL-AE-1706 File No.: G07.03 Page 2 cc:
t Hugh L. Thompson, Jr., Director Brian E. Berwick, Esquire Division of PWR Licensing - A Assistant Attorney Ge_neral for Office of Nuclear Reactor Regulation the State of Texas U.S. Nuclear Pegulatory Commission P.O. Box 12548, capitol Station Washington, DC 20555 Austin, T:t 78711 Robert D. Martin Lanny A. Sinkin Regional Administrator, Region IV Christic Institute Nuclear Regulatory Commission 1324 North Capitol Street 611 Ryan Plaza Drive, Suite 1000 Washington, D.C.
20002 Arlington, TX 76011 Oreste R. Pirfo, Esquire N. Prasad Kadambi, Project Manager Hearing Attorney U.S. Nuclear Regulatory Commission Office of the Executive Legal Director 7920 Norfolk Avenue U.S. Nuclear Regulatory Commission Bethesda, MD 20814 Washington, DC 20555 Claude E. Johnson Charles Bechhoefer, Esquire Senior Resident Inspector /STP Chairman, Atomic Safety &
c/o U.S. Nuclear Regulatory Licensing Board Commission U.S. Nuclear Regulatory Commission P.O. Box 910 Washington, DC 20555 Bay City, TX 77414 Dr. James C. Lush, III M.D. Schwarz, Jr., Esquire 313 Woodhaven Road Baker & Botts
' Chapel Hill, NC 27514 One Shell Plaza x
Houston, TX 77002 Judge Frederick J. Shon Atomic Safety and Licensing Board J.R. Neaman, Esquire U.S. Nuclear Regulatory Commission Newman & Holtzinger, P.C.
Washington, DC 20555 1615 L Street, N.W.
Washington, DC 20036 Citizens for Equitable Utilities, Inc.
c/o Ms. Peggy Buchorn Director, Office of Inspection Route 1, Box 1684 and Enforcement Brazoria, TX 77422 U.S. Nuclear Regulatory Commission Washington, DC 20555 Docketing & Service Section Office of the Secretary T.V. Shockley/R.L. Range U.S. Nuclear Regulatory Commission Central Power & Light Company Washington, DC 20555 P.O. Box 2121 (3 Copies)
Corpus Christi, TX 78403 Advisory Committee;on Reactor Safeguards H.L. Peterson/G. Pokorny U.S. Nuclear Regulatory Commission City of Austin 1717 H Street ~
P.O. Box 1088 Wachington, DC 10555 Austin, TX 78767 J.B. Poston/A. vonRosenberg City Public Service Board P.O. Box 1771 San Antonio, TX 78296 L1/NRC/ad Revised 5/22/86
Houston Lighting & Power Company ST-HL-AE-1706 File No.: G07.03 Page 3 Hershel S. Meriwether, II Associate Deputy Assistant for Programs Office of the Governor State Capitol Austin, TX 78711 l
Jack Steele Executive Director Houston-Galveston Area Council P. O. Box 22777
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Three 555 Timmons Houston, TX 77227 i
David M. Cochran, P.E.
r Associate Commissioner for Environmental
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and Consumer Health Protection i
Texas Department of Health 1100 West 49th Street Austin, TX 78756 1
Richard Galligan Executive Director Public Utility Commission of Texas 7800 Shoal Creek Boulevard a
Suite 400 N Austin, TX 78757 Larry R. Soward Executive Director Texas Water Commission P. O. Box 13087 Capitol Station Austin, TX 78711
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Attachment ST-HL-AE-1706 File No.: G37.03 Page 1 of 14~
South Texas Project Units 1 and 2 Docket Nos. STN 50-498, STN 50-499 DES Comment Review Houston-Galveston Area Council Emergency preparedness plans have not been fully completed. These plans, particularly evacuation measures, should be reviewed and coordinated with affected governmental units. Review must focus on ensuring the adequacy and compatibility of the South Texas Nuclear Plant's emergency preparedness plans and those of surrounding governmental units.
Proposed Response Emergency Planning is a coordinated effort between HL&P, Matagorda County and the State of Texas. As required by 10CFR50.47, emergency plans for governmental units are reviewed and approved by FEMA before a license to operate above five percent power is issued.
The Matagorda County Emergency Plan has recently been completed with substantial input from HL&P. We understand that the plan will be submitted to the Federal Emergency Management Agency by the State of Texas Department of Public Safety in the immediate future.
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Attachm:nt ST-HL-AE-1706 File No.: G07.03 Page 2 of 14
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Texas Department of Health 1.
The facility will employ about 1,334 persons. Other than sanitary waste, the document does not address the collection and disposal of waste generated by employees or disposal of sewage sludge from the wastewater treatment plants. Such waste should not be radioactive and may be handled as regular municipal solid waste, with no special handling requirements.
By technical definition, such waste wif.1 be considered
" industrial" solid waste under the regulatory jurisdiction of the Texas Water Commission, unless collected and disposed with municipal solid 1
waste.
If, in the collection or disposal process, the waste is mixed with municipal solid waste, then the solid waste will be subject to regulation by the TDH.
' Proposed Response Sanitary waste generated at the South Texas Project (STP) will be treated in onsite wastewater treatment plants.
Sewage sludge and any municipal solid 3
waste generated at the STP will be disposed of offsite at a permitted TDH municipal waste disposal facility.
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L II Attachment ST-HL-AE-1706 File No.: G07.03 Page 3 of 14 i
Texas Department of Health (cont'd) 2.
Chemical and sanitary wastes should be treated appropriately and discharged directly to the river. Although the overall impact is probably minimal, the concept of pumping treated waste into the recirculating, cooling reservoir at the STP violates the principle that large-scale dilution is an unacceptable solution to short-term pollution events. Basically, the proposed configuration would reestablish a regulatory precedent which the first Texas water pollution control agency had originally prohibited.
Proposed Response Chemical and sanitary wastes at the STP are treated and monitored prior to discharge to the Main Cooling Reservoir (MCR). The same effluent standards are applied to discharges to the MCR as would be applied to off-site discharges to the Colorado River, therefore, no " dilution" benefit is realized. All wastewaters discharged to the MCR will meet EPA effluent guidelines and limitations as described in NPDES Permit No. TX0064947 (ER-OL Appendix E), as well as TWC requirements in Permit No. 01908.
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Attachment ST-HL-AE-1706 File No.: G07.03 Page 4 of 14 Texas Department of Health (cont'd) 3.
Recirculating power plant cooling reservoirs using river water makeup in Texas provide ideal habitat for Corbicula.
Increasing the size of condenser tubes has alleviated clogging problems of tubes by the asiatic clam in certain instances.
During the biological STP site survey, the native clam Rangia cuneata was not noted, although another native clam Rangianella flexuosa was found.
These two euryhaline species, particularly Rangia cuneata, may find the cooling reservoir to be an ideal habitat and huge populations may result.
Where favorable habitat exists, several hundred individuals of this species have been present on a one square meter area.
These clams are larger than Corbicula.
t Should either of the two species find the cooling reservoir to be an ideal habitat, condenser tube clogging problems would probably not occur for several years until populations attained high levels and individuals grew to a size greater than tube diameter, i
Should such a situation occur, it would necessitate facility shut-down for an extended period.
i Studies should be started now on these two clams. Literature research, and if necessary field studies, should be conducted on the ccology - life
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history of the clams. A pilot cooling reservoir having similar depth, salinity, flow velocity, etc., as the plant cooling reservoir, could be constructed and stocked with the two clam species.
This would serve to determine if huge populations are likely to occur in the reservoir and would provide time to develop control methodology, if required.
i Proposed Response As stated in Section 4.3.4.2.4, of the Draft Environmental Statement HL&P l
l responded to NRC Inspection and Enforcement Bulletin 81-03 in July 1981 noting that specimens of Corbicula had been found in the Main Cooling Reservoir.
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that response, HL&P committed to monitor safety-related cooling systems for potential blockage due to clam infestation and to initiate appropriate actions as necessary to eliminate and control clam infestation.
Operational experience at other HL&P power plants indicates no clogging problems due to Rangia cuneata or Rangianella flexuosa.
Based on this previous experience and on cooling system monitoring to be conducted during operation, no significant adverse operational impacts from clam infestation are anticipated.
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Attachment ST-HL-AE-1706 File No.: G07.03 Page 5 of 14 Texas Department of Health (cont'd) 4.
The NRC requires that sixteen sectors around the plant be monitored by thermoluminescent dosimeters (TLD) at various distances from the plant.
The TLD's can be within the plant boundary (restricted area) or outside the boundary. An effort should be made to determine if it is pcssible to monitor the site south of the plant.
Extensive marshes appear to make access and emplacement impossible or extremely difficult.
During emergency response activities, knowledge of ambient doses would be necessary and essential to assess the dose to Matagorda.
Proposed Rasponse The southern sectors are monitored by TLDs located within the site boundary approximately 3.5 to 4 miles from the containment buildings in accordance with NRC Branch Technical Position November 1979.
In addition, a TLD monitoring station is located in the town of Matagorda.
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Attachment ST-HL-AE-1706 File No.: G07.03 Page 6 of 14 Texas Department of Health (cont'd) 5.
In reviewing Appendix H, Consequence Modeling Consideration, several questions have arisen with respect to site-specific evacuation plans:
What contingency plans have been developed for plant shutdown and evacuation of personnel at the Dupont and Celanese plants? Has the time it would take to shut down these plants without endangering operation personnel at these plants been considered?
Evacuation plans should recognize that people having to leave Matagorda and Selkirk Island would pass through a potentially high radiation field. Highway 60 appears to be the only available highway and evacuation using the highway would require movement toward the facility, to within four to five miles of the STP plant.
Proposed Response The Matagorda County Emergency Management Committee was formed to coordinate emergency preparedness activities between governmental and industrial facilities in Matagorda County. As part of this effort, a process for notification and evacuation of the Dupont and Uelanese plants has been developed which provides for shutdown and evacuation without endangering personnel.
Evacuation plans recognize that access to certain areas might be limited by a radioactive plume. In the unlikely event that protective actions were necessary all variables which affect decisions on evacuation and sheltering would be evaluated.
This would include forecasted plume movement and available evacuation routes.
In the case of Matagorda and Selkirk Island, if forecasted plume movement was likely to cut off the evacuation route, a precautionary evacuation would be considered. The option also exists to move the Matagorda and Selkirk population south on Hwy. 60 to a point outside of the 10 mile EPZ.
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Attachment ST-HL-AE-1706 File No.: G07.03 Page 7 of 14 Public Utility Commission 1.
Section 4.2.7 on page 4-5 and accompanying Figure 4.2 on page 4-18 concerning Power Transmission Systems present an incomplete description of transmission lines associated with the project.
Enclosed is a map of the area showing the existing 345 kv transmission lines emanating from the STP. When compared with Figure 4.2 some differences are indicated.
First, as shown on the enclosed map, an existing line between Central Power and Light Company's (CP&L's) Lon Hill and Houston Lighting and Power Company's (HL&P's) W. A. Parrish generating plants jointly owned by the two Companies was looped through the STP. This is not shown on Figure 4.2.
In addition the San Antonio City Public Service Board double circuit transmission line from STP has one circuit terminating at their Hill country substation and the other at their Skyline substation which also is not shown on Figure 4.2.
It should be noted that all major bulk transmission lines associated with the operation of the STP with the exception of CP&L's STP to Blessing line have been constructed and are in service.
Proposed Response The Draft Environmental Etatement describes the environmental impacts of changes to the transmission system from those evaluated during the Construction Permit review. The portion of the W. A. Parish (HL&P) - Lon Hill (CP&L) line which " loops" through the STP is routed within the common corridor which extends from the STP to the Danevang Tie Point and contains the transmission lines to the City of Austin and City Public Service of San Antonio. The environmental impacts of constructing and operating this corridor were assessed during the Construction Permit review. A Public Utility Commission Certificate of Convenience and Necessity was issued in Docket No. 44 in 1977.
The single circuit which extends from the STP-Hill Country Right-of-Way to the Skyline substation is routed along a previously existing Right-of-Way (Skyline to Zorn) which is intersected by the STP-Hill Country line.
This connection to Skyline di? not result in the construction of new Right-of-Way as a result of the STP.
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Attachment ST-HL-AE-1706 File No.: G07.03 Page 8 of 14 Texas Water Commission
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Pages 4-21 and 4-22.
Maps showing sampling stations on the Colorado River and the Little Robbins Slough / Marsh Complex are included. -Types of parameters sampled (physical, chemical, biological) should be indicated.
Proposed Response A description of parameters sampled (physical, chemical, biological) during Colorado River and Little Robbins Slough / Marsh Complex studies is presented in ER-OL Chapter 6.
- Numbered in accordance with TWC original comment number.
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Attachment ST-HL-AE-1706 File No.: G07.03 Page 9 of 14 i
Texas Water Commission (cont'd) l 3
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Page 6.4.
The referenced section (5.3.1.2) on Ground Water Consumption appears in the text in section 5.3.3.2 and the referenced section (5.3.2) on " Ground Water Contamination" discusses surface water and does not mention ground water. A discussion of the ground water monitoring requirements specified in TWC Permit No. 01908 should be documented in the impact statement.
Proposed Response The groundwater quality monitoring program specified in TWC Permit No. 01908 is designed to provide for monitoring of possible seepage of water impounded in the MCR into the upper unit of the local shallow aquifer.
The facilities J
. associated with the program include four 4-inch diameter wells, with one located upgradient of the MCR and three located downgradient.
During the initial year of program implementation (1985), water samples will be collected from the wells and from the MCR on a quarterly basis. Samples will be collected on a semi-annual basis in subsequent years. Analyses to be performed include determination of: Calcium, Magnesium, Sodium, Potassium, Bicarbonate, Carbonate, Sulfate, Chloride, Silica, Total Dissolved Solids, Conductivity, Alkalinity, Hardness, and pH.
After one year of monitoring, a report will be prepared and submitted to the TWC.
- Numbered in accordance with TWC original comment number.
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Attachment ST-HL-AE-1706 File No.: G07.03 Page 10 of 14 l
EPA i
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The Applicant proposes to use direct-reading pocket dosimeters to keep a running total of exposure to external radiation exposures of workers, except for neutron exposures.
For personnel working in neutron exposure areas, exposures will be calculated based on measurements by portable instruments, and known occupancy times (SER, p. 12-11).
Since neutron exposure pocket dosimetets are available from commercial suppliers, the Final EIS should explain why direct-reading neutron dosfraetry is not needed for personnel at the South Texas Project.
Proposed Response The health physics staff at STP is not convinced that direct reading pocket I
dosimeters respond reliably to low energy neutrons. Neutron sensitive direct-reading pocket dosimeters which are sensitive to the degraded fission neutron energy spectrum typical of the containment radiation environment anticipated at STP rely on thermal capture reactions for their response.
These dosimeters are calibrated in a thermal (or at least highly moderated) neutron flux. Their response to the anticipated neutron fields in the STP containment is not likely to be identical to their calibration.
Since limited exposure of plant personnel to neutron fields is anticipatad and use direct-reading pocket dosimeters whose response to STP's neutron fields is unknown might create neutron dosimetry problems, the collective experience of the STP health physics staff suggests that stay time coupled with neutron dose rate information will provide the most reliable control for neutron doses on those occasions when neutron exposures are likely.
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S Attachment ST-HL-AE-1706 File No.: G07.03 Page 11 of 14 i
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4 EPA (cont'd) 2.
RCRA Information i
The Draft EIS did not address the management of solid waste according to the Resource Conservation and Recovery Act (RCRA) of 1976. We might expect that operations of this size would generate sufficient volumes of i
nonradioactive hazardous waste to require a RCRA permit.
The management I
of all solid wastes, both hazardous and non-hazardous, should be addressed in the Final EIS. Applicable State as well as EPA regulations should be addressed as Texas is authorized to operate the RCRA program in lieu of EPA. The type and quantity of both nonradioactive hazardous and solid wastes expected to be generated at this power plant should be I
identified and discussed in the Final EIS.
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i Proposed Response
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The South Texas Project (STP) is currently and will. remain classified as a i
generator of hazardous waste under the Resource Conservation and Recovery Act (RCRA). As a generator of hazardous waste, STP is regulated by the j
Environmental Protection Agency (EPA) under the requirements of 40 CFR 262 1
" Environmental Protection Agency Regulations for Hazardous Waste Generators" and the Texas Water Commission (TWC) under 31 TAG 335 Subchapter C " Standards Applicable to Generators of Hazardous Industrial Solid Waste".
As long as the 1
applicable generator rules are met, a hazardous waste permit is not required for the facility. Nonradiological industrial wastes, both hazardous and I
non-hazardous, generated at STP will be similar in type and quantity to those generated at existing gas-fired facilities. At STP, two wastestreams would be classified as hazardous under RCRA: demineralizer regenerant and inorganic metal cleaning wastes. These wastes would be classified as hazardous on the i
basis of corrosivity. However, both thr se wastewaters will be collected and i
treated in concrete wastewater treatment systems and discharged through a j
permitted outfall. Handling these wastes in this matter exempts them from the permitting requirements under RCRA.
In addition, small amounts of hazardous I
wastes will be generated at STP primarily as a result of maintenance activities.
These wastes (i.e., solvents, thinners, paints) will be drummed, l
labeled, place in a designated hazardous waste storage area, and shipped offsite to a permitted hazardous waste disposal facility within 90 days of the date of accumulation. Non-hazardous industrial waste generated at STP will be 4
i handled and disposed of in a manner consistent with TWC Industrial Solid Waste Regulations.
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Attachment ST-HL-AE-1706 File No.: G07.03 Page 12 of 14 EPA (cont'd) 3.
Spills The Draft EIS did not address oil spills in the transformer yard.
Operations of this size usually have a large transformer yard where spills or leaks of the dielectric fluid during the operation of the project may occur.
In any of these spills include PCBs or if there are any PCB transformers on the project site, then applicable EPA procedures should be followed.
This concern should be discussed in the Final EIS.
Proposed Response Transformers purchased for the South Texas Project (STP) are non-PCB mineral oil type. Any oil spills that occur at the STP will be contained within the immediate area and cleaned up in accordance with STP operational procedures and applicable State and Federal rules and regulations.
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Attachment ST-HL-AE-1706 File No.: G07.03 Page 13 of 14 i
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Wastewater Treatment On page 4-4 the EIS states that the sanitary-waste system is adequate for 500 people but 1,334 people are projected to work at the plant.
It further states that a larger system will be necessary to comply with their NPDES permit effluent limitations. The Applicant should therefore supply assurances in the Final EIS that sufficient capacity for wastewater treatment will be available to insure that effluent permit limitations will not be exceeded.
Proposed Response HL&P plans to operate three onsite sewage treatment plants with a combined capacity of 77,500 gpd. Operation of these facilities is authorized under NPDES Permit No. TX0064947. HL&P has committed to revise the ER-OL to reflect this.
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Attachment ST-HL-AE-1706 File No.: G07.03 Page 14 of~14
- 5. Wastewater Treatment According to the SER, the main condenser vacuum pump discharge-is unfiltered, and gases released from liquid radwaste system equipment vents are released without filtration. Since these affluents are treated prior to release at some nuclear power plants, the Final EIS should explain the reason for not treating them at the South Texas Project.
Because the projected annual activity releases are not given for these sources, we could not judge whether the "as low as reasonably achievable" (ALARA) criterion has been met.
We therefore ask that the Final EIS address radioactive effluents from these sources in the context of the ALARA concept.
Proposed Response The projected annual activities released from these two sources are provided in the South Texas Project Final Safety Analysis Report (Table 11.3-1).. The condenser releases are listed in the column labeled TGB releases while the liquid waste processing system (LWPS) activities are in the column labeled Auxiliary Building release.
As stated in 10CFR50, Appendix I; Design objectives and limiting conditions for operation i
conforming to the guidelines of this appendix shall be deemed a conclusive showing of compliance with the "as I
low as is reasonably achievable" requirements of 10CFR50.34a and 50.36a.
Since the dose consequences of operation for STP have been shown to be less than the required values found in 10CFR50, Appendix I (See DES Tables D.7 &
D.8) STP has conclusively shown the ALARA criterion has been met.
These doses include the contribution from the unfiltered condenser vacuum pump and LWPS system activities.
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