ML20134M925

Submits Review of Util Request for Certification That Specified Features Meet Pollution Control Requirements. Cooling Lake Not Totally in Furtherance of Pollution Control Objectives.Related Info Encl

ML20134M925
Person / Time
Site:	South Texas, 05000000
Issue date:	09/12/1984
From:	Samworth R Office of Nuclear Reactor Regulation
To:	Ballard R Office of Nuclear Reactor Regulation
Shared Package
ML20134M881	List: ML20134M878 ML20134M888 ML20134M920 ML20134M925 ML20134M938
References
FOIA-85-426 NUDOCS 8509040348
Download: ML20134M925 (9)

Text

U

. N, / /fi (i SEP 121934 NOTE T0: Ronald L. Ballard, Chief, EHEB, DE FROM: Robert 8. Samworth, Section Leader, EES, EHEB, DE

SUBJECT:

SOUTH TEXAS POLLUTION CONTROL BONDS At the request of the LPM, Vic Nerses I reviewed the request of Houston Lighting and Power Company (HLP) for NRC to certify that specified features of the South Texas Project are in furtherance of meeting pollution control requirements. Two of the features, the cooling lake and the boron recovery system gave me difficulty.

I had expected the value of the recovered boron to exceed the cost of constructing a recovery system and therefore felt that this system should not qualify as a pollution control investment. However the utility has subsequently advised that the value of the boron is not that great but 1

that they have already reduced the " cost" of this system to reflect the value of the recovered boron. They further indicated they would send the PM a copy of an IRS ruling specific to boron recovery systems. Thus this problem has gone away.

I am not sure that the cooling lake question can be resolved so quickly.

There is not enough fresh water in Texas to operate a large steam-electric power plant with once through cooling. Closed cycle cooling is necessary because water is a scarce commodity. Pollution control is of concern to Texans but that concern alone does not convert a condenser cooling system into a pollution control device.

I asked HLP whether they could breakout any fraction of the cooling lake cost which is clearly pollution control. I also asked that they check the IRS rulings to see whether IRS has already ruled on the condenser cooling system issue. They will get back to us through the PM.

8509040348 85(M323 PDR FOIA BELL 85-426 PDR s

I SEP 121934 Ronald L. Ballard -

My inclination is to say that the cooling lake is not totally in furtherance of pollution control objectives. The circulating water

-flow is around 4,000 cfs while the seven-day-ten-year low flow in the Colorado River is closer to 1 cfs. If you threw out all pollution control laws you couldn't do away with the lake.

I expect this may be elevated in the management chain by HLP and would welcome your help in resolving the issue.

9242 su.. af:. %; . . recoye; Robert B, Samworth, Section Leader Environmental Engineering Section Environmental & Hydrologic Engineering Branch Division of Engineering cc: V. Nerses DISTRIBUTION:

EHEB Rdg EHEB File RBSamworth 9

~

DE:EHEB RB5amworth:ws 9/12/84 t:

,n G.

The Light E f liouston Lighting & Power P.O. Box 1700 liouston, Texas 77001 (713) 228 9 II October 1,1984 ST-HL-AE-1137 File Number: G25 Mr. Harold R. Denton Director, Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Ccmmission Washington, D.C. 20555

Dear Mr. Denton:

South Texas Project Units 1 & 2 Docket Nos. STN 50-498, STN 50-499 Pollution Control Bond In Furtherance Certificate Matagorda County Navigation District Number 1 Pollution Control Revenue Bonds, Series 1984 On August 14, 1984 Houston Lighting & Power Company (HL&P) sent a letter to you requesting that the NRC issue an "In Furtherance" Certificate needed to facilitate the issuance, by HL&P, of pollution control revenue bonds to finance certain facilities at the South Texas Project (STP). The purpose of this letter is to clarify the cost allocation methods used for the Cooling Water Reservoir System and the Boron Recycle Systems described in the August 14, 1984 submittal.

The part of the total cost of these two systr.ms attributable to controlling atmospheric or water pollutants will be detennined in accordance Lwith methods approved by the Internal Revenue Service (IRS) in prior rulings g These allocation methods have previously beer. accepted by the NRC in issuing "In Furtherance" Certificates for other nuclear power plants.

This supplementary information should allow the NRC staff to complete its review of our August 14, 1984 letter and issue the requested certificate.

In order to allow HL&P to issue pollution control revenue bonds as planned, we request that such certificate be issued as soon as possible, but no later than October 8, 1984.  ;

If you have any questions, please contact Mr. Michael E. Powell at (713)993-1328.

Very truly yours, J. H. Goldberg Vice-President Nuclear Engineering & Construction

, W2/NRC1/f -fL's/_f, ' ' _ . ' - - < r J, f

e ,. -

ST-HL-AE- 1137 )

Houston Lighting & Power Company File Number: G25 l Page 2 cc:

Darrell' G. Eisenhut, Director Brian E. Berwick, Esquire Division of Licensing Assistant Attorney General for Office of Nuclear Reactor Regulation the State of Texas U.S. Nuclear-Regulatory Comission P. O. Box 12548, Capitol Station Washington, DC 20555 Austin, TX 78711

. John T. Collins Lanny Sinkin Regicnal Administrator, Region IV Citizens Concerned About Nuclear Power Nuclear Regulatory Commission 114 W. 7th, Suite 220 611 Ryan Plaza Drive, Suite 1000 Austin, TX 78701 Arlington, TX 76012 Robert G. Perlis, Esquire Victor Nerses, 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 20016 Washington, DC 20555 D. P. Tomlinson Charles Bechhoefer, Esquire Resident Inspector / South Texas Project Chaiman, Atomic Safety & Licensing Board c/o U.S.. Nuclear. Regulatory Comission U.S. Nuclear Regulatory Commission P. O. Box 910 Washington, DC 20555 Bay City, TX 77414 Dr. James C. Lamb, III M. D. Schwarz, Jr., Esquire 313 Woodhaven Road Baker & Botts Chapel Hill, NC 27514 One,Shell Plaza Houston, TX 77002 Judge Ernest E. Hill Hill Associates J. R. Newman, Esquire 210 Montego Drive Newman & Holtzinger, P.C. Danville, CA 94526 1615 L Street N.W.

Washington, DC 20036 William S. Jordan, III, Esquire Harmon, Weiss and Jordan Director, Office of Inspection 2001 S Street, N.W.

and Enforcement Suite 430 U.S. Nuclear Regulatory Comission Washington, DC 20009 Washington, DC 20555 .

Citizens for Equitable Utilities, Inc.

'E. R. Brooks /R. L. Range c/o Ms. Peggy Buchorn Central Power & Light Company Route 1, Box 1684 P. 0. Box 2121 Brazoria, Texas 77422

'~

Corpus Christi, TX 78403 H. L. Peterson/G. Pokorny City of Austin

P. O. Box 1088 4 Austin, TX 78767 J. B. Poston/A. vonRosenberg

!- City Public Service Board P.~ 0. Box 1771 San Antonio, TX .78296 Revised 09/10/84 W2/NRC1/j L-

MATE Or cat'"OmNIA af 55f_M_UCuH requy, CALIFORNIA POLLUTION .

CONTROL'Fif%NCING AUTHORITY 915 CAMf0LbALL EDOM 280 i SALRAM(NTO 95814 og,g

""3"

. uy, co. .

" :l.1 October 22, 1984 *;"," 7",_,

Mr. Robert Thomas - Material Reactor Protection & Licensing Section Nuclear Regulatory Commission 1450 Maria Lane, Suite 210 Walnut Creek, California 94596

Dear Mr. Thomas:

Re: SOUTilERN CALIFORNIA EDISON COMPANY - Application No. 421 The California Follution Control Financing Authority is required by !!calth and Sa f e ty Code Sect ion 44533(b) to obtain certificates from various pollution control agencies before it sells Bonds to assist companies with financing their projects.

Section 44533(b) reads:

"No project relating to the improvement of air or water quality or solid waste control shall be eligible for financing under this division unless, prior to the issuance of. bonds or notes, a local, regional, state, or federal environmental authority exercising jurisdiction over the project certifies that the project, as designed, will further compliance with federal, state or local pollution control standards and requirements..."

The Authority has received the enclosed supplemental application for financing. Thus, in accordance with the provisions of the law, we are asking your agency to review the description of the proposed project and to provide us with any comments or reservations you may have. The Authority met on September 19, 1984, and approved the supplement to Jhe Initial Resolution for the project.

Section 44533(c) reads:

"No certification issued pursuant to subdivision (b) shall be admissible in evidenc'c, constitute an admission, or bind any certifying authority in any proceeding in which the compliance of a partici-pating party's facili tics wi th any applicable pollution control, land use, zoning or other similar law is an issue or in any application or proceeding for a permit to locate or construct f acili t ies." ,'

• ) h /} n ,_f 1 i 1

.s I J jjfJ ~I

/-

/ 5

~f ,

fi certificate you signed a~ copy the in l' -have enclosed of connection with our earlier financing for this facility. We require a similar signed certificate prior to approval of a Final Resolution to proceed with additional financing.

Thank you for your attention to these matters.

Sincerely, w A b. N- N DOUGLAS E. C11ANDLER EXECUTIVE SECitETARY Attachment a 0 m.. -=

L_.____m______ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

, 3..

'. o, , UNITED STATES 8 'a * -

' NUCLEAR REGULATORY COMMISSION

.p ,

WASHINGTON, D. C,20555 .

\...../ .

Docket Nos.: STN 50-498/499 Mr. G. W. Oprea, Jr.

Executive vice President Houston Lighting and Power Company P. O. Box 1700 Houston, Texas 77001 In the Matter of Houston Lighting and Power Company (SouthTexasProjectUnits1and2)etal.

Docket Nos. STN 50-498/499

Dear Mr. Oprea:

By letter dated August 14, 1984, your Mr. J. H. Goldberg requested on behalf of the Houston Lighting and Power Company, Central Power and Light Company, the City of Austin, Texas, and the City of San Antonio, Texas .that our office issue a Certification of Pollution Control Facilities for the South Texas Pro-a ject, Units 1 and 2 for certain facilities which are described in Exhibit A to the request.

The staff has reviewed the request. Based on the review, we are satisfied that the portions..of South Texas Project for which;NRC certification was requested are " pollution control facilities." Accordingly, the attached certificate has been executed.

Copies of the request and this response will be available for inspection at the Local Public Document Room (Bay City Library, 1900 5th Street, Bay City. Texas 77414) and at the Comission's Public Document Room at 1717 H Street, N.W.,

Washington, D. C. .

Sincerely, Harold R. Denton, Director Office of Nuclear Reactor Regulation

Enclosure:

As stated cc: See next page l _

&H

/ '

988 ileg)ct 61:31 ggfag gg

,.3 L ,

k l bS h Sd/k .P & S-f' 7$x/ ,v<

I

y. C o A fPreposed W h fo1.etter & c to PyfA v*S leer Regulatory. afp f 44 0 \

Commisst'en) g cost hf WertO. & b g(.a.de f' o. sed fjy)%-NMb-&' 76 'Vmh .

• lj

-87) o,r ee/ , $ An joor/

eu d,&+3f m en^

-ffed WW d, ,<. r cwAWro+k. PE .

Gent 3esen: ,

i Vee have requested addittenal faformaties' mier certafa syrtes et the i 94eblo Canyon Reclear Generatfipp Statfee ht are seed fte poYisties control

~

or selfd asste dispose). purpanes. All- of these systass-were identified f n

.seteriais schoitted by the Celtfaiste Mistfon Centret Flanacing Aethority to

' . the imC en Octaher 30, 1984

9 0 3- T** C**l ""**r ***'" eentrols thernet posi ues by es tresin, heat ,

\ that is released tets-the Pectfic Ocean. In the. early stages of plant i b er;t::1 design, e' design fer the unis cfreeleting water syftandras

] p censidered edrich Wutid beve tacreased the temperstare of unter screts h y

condussers by approxtentely MF.durlag meres 1 ope'rettens. To swduce

! M h petsuttel adverse effects esi:the enstreemmt, a larger,wre 1 b awfve asieling water systes has beein befit ht.will recrease the toeperstars of teater across the condensers by only i : A%'y 18"F

. during aerumi operations. The differsece fa cost between a 30*F system and err 18"F erstem is beleg financed as a pe11stian contrei finc(11ty, the cooling water sys6es dostgn uns not base ( M eder requirensets, your "In Furtherence Certificate

• is not requested.in W op wtth the coo 3 fag unter system. ' --

- f  ;

/  ! g,)

a / ,Lis &

$s.'m

/hy n

, PJ,,a r.c, ,3 p,sbb 3" ,,,,,p ,,nJ / ,

m ),14 .,.

(

I eswtrol facility by reducing twiesses of radioactiva ligvids to the aneteensent. Only the boric acid recycle porttens of the chemical i '

and volume control systeet is treeted as a pelletfos destrel facility.

c. Steam eenerator Stendens forstem. Tafs erstuu tecTudes

' dominere16sers and egstyment that. treats'stres paperatar blowdown, l

bly thfs affleast tressment espdjuneet is. treate es a ps11stion teatral feelltty.

. d, Bac3eer Met seeslies system. This systest saeples and verifies proper operettes of tip plant's pellettos centrol thefittiet.

l

• facleding the Ifgetd ra6erte'systm the gaseems radmasta arstem,-

and the torfe acid recycia system. Te the estest the mecisar Plant

-

• Semplise Systuun samples and ver$fies proper operstfen of .these facilities, it is fumettaasily related met se6erdieete to poliation >

~

centrol factitties.

~

i 9

C

, l 4408N

[

l l

r

~

3 '; 1

.,~ -

...i U F,ili:CATE 1

.. SOUTH lEXAS PROJECT ELECTRIC GE!.ERATit1G STATION .d[c e ' '*,

UNITS 1 AND 2 *-

y ,;: r y .:Y. - > ,

AJ POLLUTION CONTROL FACILITIES ge 'ff7./T,

/)/.l I '

. The Nuclear Regulatory Commission (the f1RC) hereby certifies as follows: * (

,. (a) that it has examined Exhibit A attached hereto which is entitled " General Description of the Facilities" and which describes certain facilities which have been constructed, are under construction or.are to be constructed at the South Texas Project Electric Generating Station - Units 1 and 2, a nuclear electric power generating plant located in Matagorda County, Texas, owned by Houston Lighting & Power Company. ,

, Central Power and Light, Company, the City of Austin, Texas and the City of San Antonio, Texas, ac' ting by and through the City Public Service Board of,

,a San Antonio, oy rTexas.

v,s / c,c tvlfCl Oncle r (c> l'o h Jp ar

. . (b) that facilities desc~ribed in Exhibit A, as designed, are in furtheran,ceoOhepurposeofabatingorcontrollingatmosphericpollutantss, resulting from the generation of electricity at the South Texas Project  % ,

Electric Generating Station - Units 1 and 2.

3 N' For the fluclear Regulatory Connission 5 I.

c.

' ')

Harold R. Denton, Director i Office of fluclear Reactor Regulation .

s '

\ (c) sy ]lcM:p WM9 M.& A~.ch yk~)0 '

\

&^*'

[

' /,,,/l,%,

8.4 c, j /,' f dsm a$i%

cy

/6e.,+y a s.C*oGAQ ,, . y~s dn~Ue ef A 5

lg;& o. 3,,.4oirG p.4 4 A eHa, & s. ,

/ e fe c icf & A .s.M & >

.,. ,A;,,

g. , s,b p,.-<. .<4j AMhi -aLa 4.. s z .

9,;n,i

\

a

. ,p 't

~

t f

l, ,

. . . j&fWO/777/ ~

hI

, f"%,,,

f. 3, , UNIT E D sT ATEs

( . q','

,p, E

NUCLEAR REGULATORY COMMISSION '

WASHING 1CN, D. C. 20555

5l,' s%

. ",b, LF. . [

c. p CERTIFICATE SOUTH TEXAS PROJECT ELECTRIC GENERATING STATION DNITS 1 AND 2 POLLUTION CONTROL FACILITIES The Nuclear Regulatory Comission (the NRC) hereby certifies as follows:

.(a) that it has examined Exhibit A attached hereto which is entitled " General Description of the Facilities" and which describes .

certair. facilities which have been constructed, are under construction or are to be constructed at the South Texas Project Electric Generating Station - Units 1 and 2, a nuclear electric power generating plant located in Matagorda County, Texas, owned by Houston Lighting & Power Company, Central Power and Light Company, the City of Austin, Texas and the City of San Antonio, Texas, acting by and through the City Public Service Board of San Antonio, Texas ("the Owners").

(b) that except as noted under (c) below, facilities described in Exhibit A, as designed, are in furtherance of the purpose of abating or controlling atmospheric pollutants or contaminants or water pollution resulting from the generation of electricity at the South Texas Project Electric Generating Station - Units 1 and 2.

(c) that with respect to the Cooling Water Reservoir System and the Baron Recycle Systems in Exhibit A, it has been represented to the NRC by the Ownersphat%h e + +# Meenetivs ejsts..o od-the ecenemic'bcaBits

. resp::the.j h v: beca tokca ut; : nrideretMfin establishing the cost to be financ through pollution control revenue bonds.

For the Nuclear Regulatory Comission 4hj r -14 h ( d co d , n % % 4: He e) -b er,L ff. . et/,,w y /n.<'~ . ~

c, . . ar a n a. ,

wwc 4 et'e%.. - ~ J u). o c c,,-ar

! ' ,J-f, me shdt.. in , f: opp >v>d bi (A zd S ~ ~ ~ ^

l Harold R. enton, Director Office of Nuclear Reactor Regulation Dated at Bethesda, Maryland, this day of' October, 1984.

Y

.,y r T

,. i,, , ,[< N '

y [!

,4 ,

.- t _ \

• I

,, t EXHIBIT A .

General Description of the Facilities The facilities consist 'of the following systems at the South- Texas. Project Electric Generating Station -

Units 1 j and 2 (thel " Project") and, in each case, include function * ,

ally'related and subordinate machinery and equipment.

1. . CHEMICAL WASTE SYSTEM. The chemical waste system collects nonradioactive chemical wastes from various areas ofi the plant which are treated 'in an equalization basin and/or neutralization basins. The system includes t collection- piping, sumps, storage tanks for acid and caustic, pumps, . controls and related mechanical and electrical equipment.

2. METAL CLEANING WASTE SYSTEM. The metal cleaning . waste water. system collects nonradioactive waste water from start-up. flushes, chemical cleaning, backwashes and blowdown. The waste -water is retained in organic, inorganic and neutral- '

ization' basins. The' system . includes equipment to feed chemicals and coagulate, precipitate, clarify, thicken, ,

tilter and - dewater the waste and . sludge. The system also includes collection piping, sumps,. storage tanks'for lime, acid and polymer, pumps,: controls and other related mechanical and electrical equipment.

3. OILY WASTE SYSTEM. 'The oily waste system collects for

+; processing - and offsite disposal, . nonradioactive waste oil from n'onradioactive areass where oil- may be present. -

The system includes drains, sumps, collection piping, oil / water j separators, storage- tanks,- chemical feed- equipment and related mechanical and electrical-' equipment.

l

j. .

4. . COOLING WATER RESERVOIR SYSTEM. The cooling water reservoir . includes a 7,000 - acre closed cycle reservoir to

' dissipate waste heat to-the atmosphere. The system includes '

a river make-up ' water facility, . pipelines to the reservoir, the reservoir, blowdown pipeline to the river :and a spillway

. blowdown structure. The system also includes related

' mechanical and electrical equipment.

i ,

5. GASEOUS WASTE ~ PROCESSING SYSTEMS. The gaseous waste

' processing

~

. systems provide. . collection, . processing- and-control ~ of the L release of potentially radioactive gases

' . generated withinL each unit so . that offsite exposure uis kept

.as lowf as . reasonably : achievable (ALARA). ,High activity igases1containing primarily krypton l and -xenon 1 are contained

~

Lin' hydrogen,y nitrogen and; hydrogen / nitrogen. vent' gas'es'from

.various sources. The gases .are1 cooled and passed through a

, moisture separator, charco441 delay tank ;and a particulate.-

i. - air' filtier before being . reldased. The systems alsoKinclude related monitoring, ' mechanic'al and electrical equipment. :

I

f. l

, - , _ - . - . L. . . - _ _ _ - , _ , , - , _ _ - - ,

,O t

6. REACTOR !!EAD DEGASSING SYSTEMS. The reactor head degas-sirrg ' systems remove radioactive gases, r'eleased into each reactor ecolant system free space from the primary coolant, prior to reactor head removal during refueling operations.

The purged gases pass through a moisture separator prior to being compressed and stored for six months to allow for decay of short-lived isotopes. The stored gases may then be passed through the gaseous waste processing system. The reactor head degassing systems include separators, compres-sors, monitors, piping and related mechanical, electrical equipment and instrumentation.

7. LIOUID RADWASTE PROCESSING SYSTEMS. The liquid rad-waste processing systems of each unit will collect low 1cvel radioactive liquid waste from various floor and equipment drains, liquid discharged from the boron recycle system and radioactive liquid wastes from the regeneration of conden-sate polishing demineralizer resins. The liquid waste is passed through filters, demineralizers and evaporators before being transferred to other systems for further processing. The systems include feed and monitor tanks, sampling and monitoring equipment, collection piping and related mechanical and electrical equipment.

8. BORON RECYCLE SYSTEMS. The boron recycle system of each unit treats radioactive boron from the reactor coolant systems. The processed liquid is then either returned to the reactor make-up water. storage tanks or processed further in the liquid radwaste processing system for disposal. Each units' boron recycle system contains pumps, tanks, filters, demineralizers, evaporators, drains, piping and related mechanical and electrical equipment.

9. SOLID- WASTE PROCESSING SYSTEMS . - The solid waste processing system or each unit provides for the solid-ification and pack. aging of radioactive waste generated by many sources including spent _ demineralizer resins, evaporator concentrates, exhaunted liquid and air filter elements, miscellaneous dry wastes and ,various sludges and slurries. The waste is mixed with cement and fed into steel containers or drums. The systems include collection, treat-ment, storage, mixing, transfer and container filling equip-ment'as well as equipment for the mechanical handling of the filled containers. The, system will also include related controls, instruments and mechanical and electrical equipment.

10. SANITARY WACTE SYSTEM. The sanitary waste . system provides for the collection and treatment of sanitary waste.

, The sewage waste water undergoes extended aeration, clari-fication, and chlorination. The sanitary waste system consists of collection piping, pump, sumps, activated sludge sewage treatment unit and related mechanical and electrical equipment.

i i