W3P81-1565, Forwards Formal Comments Re Facility Des

Forwards Formal Comments Re Facility Des

ML20005A683
Person / Time
Site:	Waterford
Issue date:	06/26/1981
From:	Maurin L LOUISIANA POWER & LIGHT CO.
To:	Office of Nuclear Reactor Regulation
References
W3P81-1565, NUDOCS 8106300608
Download: ML20005A683 (17)

Text

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LOUISIANA 242 onanoNoe sraar POWER & LIGHT P O BOX 6008. NEW ORLEANS. LOUISIANA 70174. (504) 366-2345 EPu?$sysE June 26, 1981 W3P81-1565 Q-3-A30 3-A1.01.04 Director, Division of Licensing U. S. Nuclear Regulatory Com ission Washington, D. C.

20555

SUBJECT:

Waterford 3 SES Docket No. 50-382 Draft Environmental Statement

Dear Sle:

Enclosed are the formal comments of the applicant, Louisiana Power & Light Company, on the Waterford 3 Draft Environmental Statement. We appreciate the opportunity to review and comment on the draft statement, and if there are any questions in this matter, please contact Mr. Roy Prados at (504) 363-8773.

We would also appreciate an opportunity to review and respond to any other comments filed in connection with the DES.

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i Table 2.1 Data Showit, Effect on Reserve Margin of MSU System Operations iith and without Waterford 3 and the Load and Capability if LP&L for the Years 1983 through 1986 a.

MSU Reserve Margin With Waterford 3 Without Waterford 3 Load Load Total Responsi-Reserve Total Responsi-Reserve Capability, bility,

Margin, Capability, bility,

Margin, Year MW MW MW MW 1983 15882 10744 48 14778 10744 38 1984 15758 11364 39 14654 11364 29 1985 16118 11841 36 15014 11841 27 1986 15849 12225 30 14745 12225 21 b.

LP&L Load and Capability (with Waterford 3)

Load Total Responsi-Capability, bility, Year MW MW 1983 5324 4553 1984 5280 4652 1985 5280 4824 1986 5280 5042 '

" Current official projections for the MSU syu.em call for average annual rates of increase of 1.9 percent for peak load and 2.8 percent for net energy requirements from 1978 to 1986. Comparable values for LP&L for peak-load demand and net energy requirements are 3.8 percent and 3.1 percent, respectively.

Table 2.1 shows MSU's reserve margins with and without Waterford 3 in operation in the 1983 through 1986 time period. The peak-load responsibility values reported here reflect the official forecasts for system-maximum hourly load, adjusted downward for firm purchases. System capacity reflects capacity owned by the systems (adjusted downward for natural gas curtailments) plus purchases that are not firm.

LP&L and MSU have identified a 25 percent reserve margin as necessary to maintain minimum acceptable reliability. This standard is consistent with the 15 to 25 percent reserve margin recommended by the Federal Energy Regulatory Commission.

This reliability assessment assumes that 2977 MWe of new capacity, other than Waterford 3, will be added to the MSU system in 1980 through 1985 as scheduled. It also assumes that approximately 500 MWe of purchased power will be available in the 1984 through 1986 peak-use seasons. The conclusions of the reliability assessment could be altered by unavoidable slippages in or decisions to delay any of these subsequent additions, or by the uncertainty associated with MSU's reliance on these outside purchases.".

Comment 3:

In Section 2.4.1 - Fuel Uncertainties (page 2-4) it should be specifically mentioned that The Power Plant and Industrial Fuel Use Act of 1978, prohibits the use of natural gas as a primary fuel in utility boilers by 1990. The mentioning of the act clearly illustrates j

that legislation already exists that can prohibit the use of natural gas, whereas the phrase " current curtailment proceedings" in Section 2.4.1 implies that the regulation of natural gas usage as a utility fuel currently is being considered.

Comment 4:

In Table 4.1 (page 4-4) there appears to be a typographical error. The total time after heat addition for the average low water level condition should be 383 seconds instead of 532 seconds.

Comment 5:

There appears to be a typographical error in Table 4.2 (page 4-9) concerning plant discharge velocities. The average spring discharge velocity should be 0.58 m/sec (1.9 ft/see) instead of.0.78 m/sec (2.5 ft/sec).

Comment 6:

Since the subject of Section 4.2.4.5, " Laboratory and Decontamination Solutions" concerns a source of potentially radioactive wastes, it would be more appropriate to include this discussion in Section 4.2.3 " Radioactive Waste Treatment". In addition, the first sentence of the second paragraph in Section 4.2.4.5 (page e-13) would be more correct if modified to the following:

" Drainage from the chemistry and radiation measurement laboratory sinks is collected in a drain tank, treated in the waste management system and then discharged into the circulating water system discharge".

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Comment 7:

Figure 4.8 depicts site areas investigated in the 1977 Cultural Resources survey and it neglects to present those areas surveyed in 1980 which are the subject of a major portion of Section 4.3.6 (Cultural Resources of the Waterford Site). Therefore, in order to clarify this situation, it is suggested to add ER-OL Figure 2.6-3

" Location of Archaeological Remains Associated with the Waterford Plantation" and to replace the title of DES Figure 4.8 with the following:

"Onsite Areas Scheduled to be Disturbed By Waterford 3 Construction Activity at the Time of the 1977 Cultural Resources Survey."

Comment 8:

• It is suggested that the second sentence of the first paragraph (Section 4.3.7.1) on page 4-29 would be more easily understood by the public if it were replaced with the following two sentences:

" Transient population within 16.1 km (10 mi) of the site consists, in general, of industrial. employees, visitors to festivals, attendees at sporting events, and people traveling through the area on transportation arteries. It is very difficult, when accounting for transient populations of these I

types, to distinguish residents from nonresidents."

Comment 9:

The fifth paragraph of Section 4.3.7.2 on page 4-29 l

l states that "... industrial development is projected to take place southeast and northeast of Waterford 3."

However, industrial development in the vicinity of Waterford 3 is taking place both west and northwest of the plant, as well as to the southeast and northeast. Therefore, the first sentence in this paragraph should be modified, as follows, to reflect this fact:

"In general, industrial development is projected to continue to take place along the Mississippi River in the vicinity of Waterford 3."

Comment 10:

Because the first sentence of paragraoh 1 on page 4-31 does not give an indication of the population density requiring the indicated land area, it is suggested that the sentence should be replaced with the following:

" Additional residential growth is expected to take place within 8 km (5 mi) of Waterford 3.

The population in this area is expected to grow by 3,558 persons, or 19.6%, between 1980 and 1990. If one assumes a density of 17.3 persons per ha (7 persons per acre)*, an increase of 206 ha (508 acres) of residential 1sud will result during this time period".

• Source: ER-OL, Section 6.1.4.2 Comment 11:

The hydrothermal analysis performed by the staff and described in 3ection 5.3.2.3 of the DES, does not incorporate several engineering and site specific hydrologic phenomenon. This exclusion renders the staff's analysis overly conservative in the opinion of the applicant. The considerations excluded from the staff's analysis are the following:

(a) the high velocity jet-type discharge resulting in a relatively fast temperature decay in the nearfield; (b) the observed "back eddy" current in the vicinity of the Waterford 1 and 2 discharge which causes an upstream l L l

l excursion of a portion of the Waterford 1 and 2 thermal discharge; and (c) correlation of the hy'drothermal model predictions with actual measured data from the existing units. The applicant therefore believes thtc, based on these exclusions, in the staff's analysis and the applicant's conservative input assumptions, his analysis provides reasonably conservative, yet realistic results. Furthermore, as stated in the final sentence of Section 5.3.2.2 of the DES, the applicant's analysis is considered to be sufficiently conservative since it was based on all plants operating at maximum load for the temperature calculations, the uodels were calibrated against the largest plume observed and the surface heat exchange cffect was neglected Comment 12:

Section 2.6.1 (page 2.6-2) of the ER-OL describes the procedure that LP&L is using to protect identified cultural resources associated with the Waterford Plantation. This section indicates that the applicant is taking appropriate seasures to ensure that the identified cultural resources will be protected. The DES should be modified to include the applicant's commitment. Therefore, the third sentence of the first paragraph of page 5-25 should be replaced with the following, and the additional statement should be inserted as noted below.

"The applicant is taking appropriate measures to p.otect the area during this process. Should any ground disturbance of these areas become necessary in the future, the applicant will consult with the SHP0 and develop an approved mitigation plan.

Operation of Waterford 3..." continue with the remainder of the paragraph. -

Comment 13:

The number of operatoc*.1 work force employees at Waterford 3 presented in section 5.8.1 (page 5-25),

fails to include security and other non-technical workers. The total operational work-force (technical and non-technical) for 1979 is 131 (the year cited in the DES - see reference 34 to Chapter 5 of DES) and for the first year of commercial operation (1983) is 267.

The omission of these nontechnical workers from the total operational work-force results in an under estimation of the benefits derived from these workers income that will be accrued within the region's non-basic (indirect or secondary) employment sectors.

Comment 14:

In September of 1979, the applicant conducted two surveys in response.to NRC Question No. 301.34 and 301.35 and included those responses with Amendent No 1 to the ER-OL (Docket No. 50-382). These 'uestions considered the impact of both immigrant construction and operational workers associated with Waterford 3 upon local public services (e.g. fire, police, water, sewer, schools, etc.) in the area within 0-10 miled of the facility. The results of this analysis projected different impacts upon public services than those cited in DES Section 5.8.1.

The basis for the determination of the effect of immigrant workers and their associated population upon public services is two recent surveys. A

" Construction Worker Survey" was conducted on June 6 and 7, 1979 and an " Operational Worker Survey" was conducted becween May 1 to 15, 1979. The results of these two surveys, with the aid of a fiscal impact model, were used to predict the impact of the

L immigrant population upon public services from 1979 to 1982. At the time of ths

_y, 1982 was the expected operational date for Waterford 3.

Since this, analysis, the commercial operation of Waterford 3 has been delayed until March, 1983. However, even with this delay, the immigrant worker impacts upon public services for 1982 should remain representative for 1983 and therefore the survey results are still considered valid.

All the appropriate public service functions for the portion of St. Charles Parish that is within 10 miles of Waterford 3, exhibit excess capacities and have the ability to absorb the immigrant population's service demands. In the portion of St. John the Baptist Parish that is within 10 miles of Waterford 3, the applicant's cualysis showed that all pubIlc service functions, except for the general control and library service functions, demonstrate excess capacities and have the ability to absorb the immigrant population's service demands during the operational phase. For these two above mentioned affected public service functions, the immigrant population service demand will have a marginal adverse impact. Furthermore, the hospital facilities, medical staff, and the firefighting staff and equipment were found to have suf ficient existing excess capacity to absorb the immigrant service demand for the additional workforce from Waterford 3.

i Therefore, the third sentence of Seccion 5.S.1 (page 5-25) should be replaced with the following sentence:

I "A recent study which included the results of a field survey utilizing the aid of a fiscal impact model indicated that all public service functions within a 10 mile radius of Waterford 3 are adequate to serve the operation phase workers at Waterford 3 with the exception of the general control and library service functions within the adjacent St John the Baptist Parish. These service functions within St John the Baptist Parish will only be insignificant 1y impacted by Waterford 3."

Comment 15:.

The monetary values that are expressed in section 5.8.2.1 (page 5-25) for both annual payroll ($2.8 million) and induced expenditures ($257.7 million) are taken from Chapter 8.0 of the original ER-OL which was submitted to the Nuclear Regulatory Commission in 1978. Since the original submission, these values have been revised in Amendment No. 18 to the FSAR (dated 5/81). These revisions are based upon a 1983

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commercial operation of Waterford 3, as well as a 267 member operations staff. Therefore, the annual income that will be generated by the operations staff is expected to be about $5.5 million (1983 dollars).

Also there is anticipated to be about $1.9 million (1983) generated in the region's non-basic employment sectors, resulting in an total annual income affect of about $7.4 million (1983 dollars).

The induced expanditure level of $257.7 million, presented in the DES is based upon the effect of the operational staff's accumulated payroll over the operational life (40 year) of the plant will have upon various sectors of the region's economy (regional product or output). Amendment No. 2 to the ER-OL utilized a somewhat different approach, by examining

the additional income that will be generated in both the region's basic and non-basic sectors from the operation of Waterford 3.

This approach resulted in an additional income figure of $205.8 million (discounted to 1983 dollars) for the entire operational phase.

In Section 5.8.2.2, the level of tax revenue ($1,963 Comment 16:

million) is derived from the original TR-OL.

In Amendment No. 2 to the ER-OL, the revised level of tax revenue f,or local, state and Federal governments generated during the operational phase of Waterford 3 was revised to about $2,296 million (discounted to 1983 dollars). Of this total amount, about 10 percent is expected to go to the state government.

Comment 17 :

Theplantstackandaire[ectorcharcoalfilterhasa 90% iodine removal efficiency. The calculated releases of radioactive materials in gaseous effluents from Waterford 3, as presented in Table 5.6 (page 5-30) should be revised to reflect the 90% removal efficiency. In addition, Table 5.3 contains a typographical error under the waste decay tanke heading. The word "continous" should be changed to

" continuous".

Comment 18:

Based on the applicants most recent' survey, (see ER-OL Section 2.1.3.4) the nearest milk goat is located at 3.1 miles in the east direction, And the nearest milk cow is located 1.1 miles in the northeast direction from Waterford 3.

Therefore, Tables 5.7, 5.8 and 5.9 should be revised to reflect this information..

Comment 19:

In order to evaluate one of the expressed areas of controversy, it is suggested that the following be added at the end of the second paragraph on page 5-46:

"One of the areas of controversy pertaining to the issuance of the operating license for Waterford 3 is the synergistic and cumulative effects of low level radiation and carcinogens. This issue has arisen because of prevalence and retrospective studies which have reported an increase in death rates due to cancer (e.g. lung cancer) in southern

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Louisiana relative to the national average (85)

With such a pre-existing condition, concern has been expressed regarding the need to evaluate possible synergistic effects between existing environmental carcinogens which may be responsible for the elevated cancer incidence, and the low level radiation exposures wh*ch may be associated with the routine operation of the Waterford 3 facility.

In responding to this conce n, consideration must be given to several factors concerning potential synergistic effects. First, consideration should be given to the exposure limits under which the Waterford 3 plant is required to operate as compared to other radiation exposures to which members of the general public are routinely exposed. This comparison is provided in Table 5.16 of the FES, which s? :s that the routine exposures associated with tie operation of the station are required to be a small fraction of existing exposures, and well within the variability of natural background.

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In addition, studies have either failed to find a synergistic effect, er have observed some synergistic effects only at much higher exposures than allowed for the Waterford station. For example, the exposures at whi:h some synergistic effects have been experimentally observed were in excess of 10,000 mrem delivered over a short period of I80 ~ 93) time This is to be compared to the guidelines set forth in Appendix I to 10 CFR 50 of 5 mrem /yr to the whole body and 15 mrem /yr to the thyroid gland. This information provides considerable assurance that any such effects associated with Waterford 3 would be either vanishingly small or non existent.

Furthermore, it is also acted that:

'when considering to what extent chemicals can cause syner,gistic effects even in the dose range relevant for radiological protection, it should be remembered that generally all experiments, investigations and tests for toxicologics1 effects, cancerogenicity and mutagenicity of chemical substances are always carried out in combination with the influence of ionizing radiation, since natural xposure to radiation is present everywhere and at all times.

Thus since each determination of the hazard potential of chear:als is necessarily always carried out under a possible synergistic effect of ionizing radiation, this factor is included.

It is thus cartain that no unforeseen intensification of the effects can be caused by I

additional radiation exposure of the order of l

magnitude of natural 5 adiation exposure.' "(94) l

REFERENCES (FOR COMMEYr 19) 85 Mason, T.J.M. et al.

" Atlas of Cancer Mortality for U.S. Counties: 1950-1969 DEEW Publication No.

(NJH)75-780.

86 Moroson, H and M QuinL.11ani (Eds.). (1970).

Radiation Protection and Sensitization.

Proceedings of the Second International Symposium on Radiosensitizing and Radiopror.ective Drugs.

Taylor and Francis, Ltd, London; barnes and Noble, Inc, New York.

87 Streffer, C.

Interaction Measurements of Radioactive, Chemical and Thernal Releases from the Nuclear Industry: Methodology for Considering Cooperative Effects. In " Combined Effects of Radioactive, Chemical and Thermal Releases to the Environment." IAEA, 1975 (STI.' UB/404).

88 Leenousts, H P cud K H Chadwick (1978).

Interaction of Chemical Mutagens and Radiation in the Induction of Malignancy. In: Late Biological Ef f ects of Ioni=ing Radiation." IAEA, 1978 (STI/ PUB /489) 89 Lindell, B (Chairman) (1975). Panel Discussion on the Significance of Synergistic and Combination EFfocts in the Future Development of Nuclear Power Programmers, and the Need for Future Studies.

In:

IAEA, 1975 (STI/ PUB /404) l l

90 Michei, C and H Fritz-Niggli (1978).

Radiation-Induced Developmental Anomalies in Mammalian Embryos by Low Doses and Interaction with Drugs, Stress and Genetic Factors. In:

IAEA (1978); SIT / PUB /489.

91 Lurie, A G and R M Rippey (1978). Low Level Radiation-Induced Alterations of Function'al Haemodynamics in Normal and DMBA-Trented, Tumour-Bearing Hamster Check Pouch Epithelium.

In:

IAEA (1978); STI/ PUB /489.

92 Myers, D K et al (1978). DNA Repair and the Assessment af the Biological Hazards of Tonizing Radiation. In:

IAEA (1978); STI/ PUB /489.

93 Streffer, C et al (1978). In Vitro Culture of Pre-Implanted Mouse Embroys. A model system for studying combined effects.

In:

IAEA (1978)

STI/ PUB /489.

94 Synergism and Radiological Protection Comments of the Radiological Protection Commission September, 1977. Transla'ted as of August 1978. Printed by Gesellschaft Fur Reaktorsicherheit (GRS) mbH Glockergasse 2.5000 Koln 1.

Comment 20:

It is suggested that the last sencence of the third paragraph of Section 6.2.1 (page 6-1) would be clearer if reworded as follows:

"However, a sluiceway is available to remove impinged fish and macroinvertebrates from the traveling screena and return them to the river (Section 5.11), which can be expected to lower the impingement mortality rate to less than that which would otherwise be aniticipated."

Comment 21:

In Section 6.2.4.1, on page 6-3 in the third complete paragraph it is noted that the preooerational program proposed by the applicant is summarized in Table 6.1.

Since the preoperational program has been in effect since 197f and is no Icnger proposed, the following sentence should be substituted for the first sentence:

"The preoperational radiological environmental monitoring program being followed by the applicant is..."

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Comment 22:

Section 6.2.4.2, on page 6-3, second paragraph, it is stated that the applicant plans to essentially continue the proposed preoperational monitoring program during the operational period. Since the preoperational program has begun, the word " proposed" should be deleted. In addition, thia sentence references Table 5.3 which presents thermal impact inf ormation. The correct reference is Table 6.1.

Finally, the third sentence of this paragraph should be modified to include references to NUk2G 0472.

Therefore, this paragraph should road as follows:

"The applicant plans essentially to continue the preoperational program during the operational period (see Table 6.1). However, the TLD locations will be updated to reflect the 1979 Branch Technical Position, Revision 1.

Other refinements may be made in the program to reflect changes in land use, preoperational monitoring experience and revisions to NUREG 0472, " Radiological Effluent Technical Specifications for PWR's"."

Comment 23:

In Section 6.6.2 - Benefits (page 6-6), the inclusion of data pertaining to the customer class percentage use of electrical energy is not pertinent to the discussion of benefits derived fro a Waterford 3.

Therefore, it is suggested to delete this tabular data from the FES. i Nu