ML20064P059

Forwards Response to Comments on Des,Per NRC 820722 Request. Uncertainties Re March & Corral Codes in Calculating Accident Probabilities Do Not Invalidate Use of Codes

ML20064P059
Person / Time
Site:	Skagit
Issue date:	09/02/1982
From:	Myers R PUGET SOUND POWER & LIGHT CO.
To:	Regan W Office of Nuclear Reactor Regulation
References
PLN-270, NUDOCS 8209130089
Download: ML20064P059 (12)

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September 2, 1982 PLN-270 Mr. William H. Regan, J r. , Ch ief Siting Analysis Branch Division of Engineering Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Washington, D.C. 20555

Subject:

Puget Sound Power & Light Company Skagit/Hanford Nuclear Project, Units 1&2 Docket Nos. 50-522 and 50-523 Draft Environmental Statement Applicant's Response to Comments

Dear Mr. Regan:

In your letter of July 22, 1982, you requested that the Applicant submit by August 11, 1982, any responses it deemed appropriate to the comments received on the Draft Environmental Statement for the Skagit/Hanford Nuclear Project. The Applicant's comments were provided to the NRC Staff, EFSEC Staff and URS by way of a telephone conversation held on July 30, 1982. Attached to this letter is a written summary of those comments.

Ver ruly yours L.8 O

Robert V. Myers Vice President Generation Re o tces Attachment Co o/

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'02LIC12 SK AGIT/II ANFORD NUCLEAR PROJECT Attachment to PLN-270 September 2,198 2 APPLICANT'S RESPONSE TO JOllN F. DOllERTY'S, GULF COAST Page 1 of 11 ENVIRONMENTAL DEFENSE FOUNDATION, COMMENT LETTER DATED JUNE 12, 1982 COMMENT RESPONSE Ash deposition should be considered in the alternative Ash deposition was included as a factor in the Applicant's alternative site analysis (Comment 1). site analysis under the category of geotechnical factors. The impacts of ash deposition on operation of S/IINP was considered by the Applicant in Amendment 26 to the PSAR for S/IINP. As a result of this consideration, it was concluded that ash deposition would not significantly affect operation. Consequently, consideration of ash deposition would not affect the results of the alternative site analysis.

The DES should provide a probability that construction Groundwater will not be used as a source of water for S/IINP. Given or operation would affect buried radioactive waste at the prevailing groundwater elevations at the Plant Site, dewatering Ilanford (Comment 2). will not be required for the Plant excavation, and discharge of treated sanitary waste water will have no measurable effect on groundwater resources. No other discharges to the groundwater are planned.

Consequently, groundwater levels and gradients will not be affected (see p. 4-29 of the DES) and no impact on buried waste at llanford is expected as a result of construction and operation of S/IINP.

The DES should include estimates of the number of The number of non-fatal cancers and birth defects can be calculated fatal birth defects, non-fatal birth defects, and non- using the factors given on page 4-185 of the DES.

fatal cancers induced by Radon-222 for the S/IINP fuel cycle (Comment 3).

The DES should have expressed reservations regarding Uncertainties presently inhere in all methodologies for predicating use of the MARCII and CORRAL computer codes for reactor accident probabilities, including the MARCII and CORRAL cvaluating accident probabilities (Comments 4 and 5). codes. In fact, the DES recognizes there are "substential uncertain-tics" regarding calculation of accident probabilities (DES, p. 4-205).

These uncertainties neither invalidate the use of these codes, nor do they cast doubt upon the general conclusions derived from the codes.

Section 4.2.2.1 of the DES relies upon general The implied premise of the comment is incorrect, the DES not only knowledge of the region of interest in considering relies upon general knowledge but also the information provided by the alternative sites (Comment 7). Applicant, as Section 4. 2. 2.1 of the DES clearly indicates.

Additionally, much of the information on alternative sites was developed in the proceeding for the Skagit Nuclear Power Project since September 1974, as indicated on p. 3-9 of the DES.

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02LIC12 SK AGIT/II ANFORD NUCLEAR PROJECT Attachment to PLN-270 September 2,1982 APPLICANT'S RESPONSE TO Tile WASilINGTON STATE DEPARTMENT OF ECOLOGY'S Page 2 of 11 COMMENT LETTER DATED JUNE 14, 1982 COMMENT RESPONSE The minimum river flows used in the DES may increase Because any change would result in an increase in the minimum river as a result of recommendations by the Northwest Power flow, the minimum river flow used in the DES is conservative for the Council (Comment 1). purpose of considering aquatic impacts from S/IINP.

Construction of the intake / discharge structures should These subjects are discussed in Amendment 6 to the ASC/ER.

be scheduled to minimize aquatic impacts, and an intake /

discharge location downstream of that presently proposed should be evaluated (Comment 6).

Provisions regarding on-site waste disposal, storage and As indicated in Section 4.5 of the ASC/ER, plans for these subjects spill contingency plans, open burning, and fugitive will be developed as part of the Construction impact Control Program emissions should be developed (Page 2). for S/IINP and will be submitted to Washington State EFSEC for its review and approval prior to commencement of site construction activities.

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02LIC12 SK AGIT/II ANFORD NUCLEAR PROJECT Attachment to PLN-270 September 2,1982 APPLICANT'S RESPONSE TO Tile WASillNGTON STATE DEPARTMENT OF Page 3 of 11 TRANSPORTATION'S COMMENT LETTER DATED JUNE 15, 1982 COMMENT R ESPONSE The DES should include specific commitments on high- Consultations are still ongoing regarding the exact nature of the way improvements (Comment 6).

highway improvements to be implemented to accommodate the traffic i related to S/IINP. Pending completion of these consultations, it is not feasible to provide specific commitments regarding highway improvements. The general program being considered by the i Applicant is presented in Sections 8.3.10.2 and 8.5.2 of the ASC/ER.

The DES should quantify increased noise and air j

pollution from increased traffic (Comment 7). This subject is discussed in Amendment 6 to the ASC/ER.

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• 02LIC12 SK AGIT/II ANFOltD NUCLEAR PROJECT Attachment to PLN-270 September 1,1982 APPLICANT'S RESPONSE TO Tile DEPARTMENT OF llEALTil & IIUMAN SERVICES' Page 4 of 11 COMMENT LETTEll DATED JUNE 2,1982 COMMENT R ESPONSE (Comment 1) implies that the radiological dose standards Although the numerical standards in each of the listed regulations in 10 CFR Part 20,10 CFR Part 50 Appendix 1, and 40 are different, the standards are not inconsistent because cach CFR Part 190 are inconsistant, and it states that the addresses a different category of exposures. Appendix I presents DES should be modified "to clearly state that the annual guidelines for design objectives to limit doses in unrestricted areas doses to members of the public will comply with" the from the Project during normal operation. 40 CFR Part 190 presents standards in 40 CFR Part 190. standards for normal operation in order to limit doses to members of the public from all uranium fuel cycle operations. Finally, 10 CFR Part 20 provides standards for inclusion in a license to limit radiation levels in unrestricted areas as a result of a licensee's possession and use of radioactive material and other sources of radiation. S/IINP will comply with each of these regulations. See ASC/ER Section 5.2.

It would be helpful for the DES to quantify the health Both the ASC/ER (Section 7.4.8) and the DES (pp. 4-215 to 4-218) impacts from fallout carried into open bodies of water analyzed radioactive releases to the groundwater as a result of an and release of radioactive material to the groundwater accident and found that the consequences of such releases would be as a result of an accident (Comment 3). "significantly less" than calculated in the Liquid Pathway Generic Study (N UREG-0440) for a large river site and that such releases would present "no uniquely large contribution to risk." In light of these conclusions, further analysis to quantify the consequences of such releases is unnecessary for the purposes of NEPA. Similarly, detailed consideration of health impacts from fallout in water is not warranted, since this pathway does not contribute significantly to predicted doses from accidents.

Airborne radio-iodine sampling and analysis program The radiological monitoring program proposed for S/IINP will be should be examined to make certain that the system is capable of detecting iodine-131 in the atmosphere, including as a adequate for monitoring radio-halogens (especially result of an accident. See ASC/ Ell Section 6.1.5.

radio-iodine) in the presence of radionoble gases in the unlikely event of an accident (Comment 4).

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SK AGIT/II ANFORD NUCLEAR PROJECT Attachment to PLN-270 1 September 2,1982 APPLICANT'S RESPONSE TO NATIONAL OCEANIC AND ATMOSPilERIC Page 5 of 11

} ADMINISTRATION'S COMMENT LETTER DATED JUNE 14, 1982 COMMENT RESPONSE The proposed water inlet openings do not meet NMFS As is discussed in Section 5.1.3.1 of the ASC/ER, no significant

) criteria for the protection of juvenile anadromous fish, impact upon juvenile anadromous fish is expected as a result of l'

operation of the intake for S/IINP. This conclusion is attributable i

to the fact that the intake will be located in the deep water approximately 600 feet offshore where juvenile fish are not expected to frequent and to the fact that the swift river current at the intake i

location will tend to sweep juveniles away from the intake. Testing i of a similar intake for WNP-2 confirms the absence of any significant l adverse effects, in the absence of any significant adverse impacts,

) compliance with the NMFS criteria is unnecessary to provide protec-I tion for juvenile anadromous fish.

[ The DES should discuss the range of actual tempera-j tures which might result from thermal discharge to The temperature of the Columbia River varies from approximately 3 20F to 700F. The temperature of the Project discharge will vary 1

the Columbia River. from less than 600F to 84.50F. For an unrealistic worst case of maximum discharge temperature and flow and minimum river '

temperature and flow, the increase in river temperature at the edge

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i of the dilution zone boundary would only be 0.280F. Thus, it may be seen that the actual river temperature at the edge of the dilution j

zone boundary will be approximately the same as ambient river temperatures under all operating conditions.

l i The thermal plume area should be monitored for Available data indicate that migrating juvenile salmonids primarily

pradation rate under operational conditions during travel in shoreline areas, and they are not expected to frequent the i the downstream migration period in order to document proposed discharge area. Furthermore, it is not expected that the losses, if any, of juvenile salmonids. ,

j Project discharge will have any significant affect upon predation  ;

rates due to the relatively small size of the discharge plume and differential temperatures. Consequently, even if it assumed that a reasonable monitoring program for predation rates could somehow be i

devised, such a program would not be expected to provide much useful information at S/IINP.

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' SK AGIT/II ANFORD NUCLEAR PROJECT Attachment to PLN-270 September 2,1982 APPLICANT'S RESPONSE TO Tile WASilINGTON STATE DEPARTMENT OF GAME'S Page 6 of 11 COMMENT LETTER DATED JUNE 28, 1982 COMMENT RESPONSE Monitoring and mitigation plans should be developed liabitats in those areas which will be utilized for the Plant facilities for habitats which will be impacted by construction. and for such other activities as parking, will be lost during the life i

of the Plant. Thus, it is not possible to mitigate these losses. Since the converted areas are relatively small and do not have any ecological features of significance, the losses are not expected to have any adverse impact on wildlife communities as a whole. With respect to other areas disturbed during construction of the Plant, restoration programs are planned to return those areas not landscaped or utilized or other activities essentially to their natural conditions.

(See Section 4.1, 4.1.1, 4.5.4.3, 4.5.5.4 and 4.5.5.5 of the ASC/ER).

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02LIC'12 SK AGIT/II ANFORD NUCLEAR PROJECT Attachment to PLN-270 September 2,1982 APPLICANT'S RESPONSE TO Tile NRDC, NWF, OEC AND SIERRA CLUB'S Page 7 of 11 COMMENT LETTER DATED JUNE 28, 1982 COMMENT RESPONSE

, The analysis of need-for-power and alternatives Need-for-power and alternative energy sources discussions will be j to S/IINP is inadequate (Sections ill and IV). supplemented by Amendment 7 to the ASC/ER for the S/IINP which i

is scheduled to be filed near the end of September.

The DES does not consider aquatic impacts from This comment is the subject of NWF/OEC Contention 4 to which the increased use of hydro power for peaking purposes. Applicant has previously axpressed its objections and on which the (Section V). Licensing Board has deferred acceptance.

The DES does not adequately assess the uranium fuel This comment is the subject of NWF/OEC Contention 5 which was cycle (Section VI).

rejected by the Licensing Board in its Memoradum and Order dated July 6, 198 2.

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02LIC'12 SK AGIT/II ANFORD NUCLEAR PROJECT Attachment to PLN-270 September 2,1982 APPLICANT'S RESPONSE TO Tile U.S. DEPARTMENT OF Tile INTERIOR'S Page 8 of 11 COMMENT LETTER DATED JULY 8,1982 COMMENT RESPONSE Downstream transport of fine sediments could adversely The nearest known spawning areas are located more than seven miles affect salmon spawning gravels. downstream from the proposed locaticn for the intake / discharge structures. Significant transport of fine sediments is not expected to occur over such a great distance. Studies conducted during construction of the intake and discharge from WNP-2 indicated that increased levels of suspended solid concentrations were only infrequently observed 500 f t. downstream of the excavation.

The intake / discharge should be relocated. This subject is discussed in Section 10.10 of Amendment 6 to the ASC/ER.

Fish will be attracted to the Project discharge and thus Anadromous fish are not expected to be attracted to the warm water will be continously exposed to elevated mercury concen- of the Project discharge. Although warm water species may be so trations. attracted, they are not expected to remain for significant periods of time in the discharge plume because of the significant expenditures of energy required to maintain position in the swift current of the Columbia River. (See Section 5.1.3. 2.4.1 of the ASC/ER). These considerations, together with the slight increase in concentrations, indicate that no significant impact upon fish is expected as a result of discharge of mercury.

Sodium hypochlorite should not be used as an anti- The DES does not reflect the Applicant's decision to reduce concen-fouling agent in order to prevent serious biological trations of total residual chlorine in the blowdown of 0.14 mg/l.

consequences. Amendment 6 to the ASC/ER, Section 5.3.1.2 and Appendix L, will provide a revised and expanded discussion of potential impacts from the discharge of chlorine and will demonstrate that no significant impacts are expected.

Revegetation should be used as a means of controlli..g This subject is encompassed with the Construction Impact Control wind erosion of soil. Program which will be submitted to Washington State EFSEC for its review and approval prior to commencement of construction.

02LI'C 12 SK AGIT/il ANFORD NUCLEAR PROJECT Attachment to PLN-270 September 2,1982 APPLICANT'S RESPONSE TO Tile U.S. ENVIRONMENTAL PROTECTION AGENCY'S Page 9 of 11 UNDATED COMMENT LETTER COMMENT RESPONSE Ilealth impacts associated with electric field No adverse health impacts from electric field intensities are expected intensities from transmission lines should be discussed. due to the remote location of the transmission lines (See Section 3.9.2 of Amendment 6 to the ASC/ER).

The DES should discuss any adverse impacts upon agri- T*iis subject is discussed in Section 5.1.3.2 of the ASC/ER. Addition-culture from salt deposition during operation of the ally, it should be noted that no agricultural activities are conducted cooling towers. within five miles of the Plant Site.

Discuss alternative locations for the intake / discharge This subject is discussed in Section 10.10 of Amendment 6 to the structures. ASC/ER.

02LIG12 SK AGIT/II ANFORD NUCLEAR PROJECT Attachment to PLN-270 -

September 2,1982 APPLICANT'S RESPONSE TO Tile COLUMBIA RIVER INTER-TRIBAL FISil COMMISSION'S Page 10 of 11 COMMENT LETI'ER DATED JULY 16, 1982 COMMENT RESPONSE Each of the comments corresponds to proposed The Applicant's objections to these proposed contentions are set forth contentions submitted by CRITFC. in Applicant's Response in Opposition to Columbia River Inter-Tribal Fish Commission's Motion for Admission of Second Supplement to Petition to Intervene dated July 30, 1982. In some cases, the subject matter of the proposed contentions are encompassed within Amendment 6 to the ASC/ER.

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02LIC'12 SK AGIT/II ANFORD NUCLEAR PROJECT Attachment to PLN-270 September 2,1982 APPLICANT'S RESPONSE TO Tile U.S. DEPARTMENT OF ENERGY'S Page 11 of 11 COMMENT LETTER DATED JUNE 30, 1982 COMMENT RESPONSE  !

The DES should include a discussion of the 1982 These will be discussed in Amendment 7 to the ASC/ER which is Northwest Regional Forecast by PNUCC and the BPA scheduled to be filed near the end of September.

forecast on electricity consumption.