ML19256E033

Responds to 790820 Request for Comments of State of Wi Dept of Natural Resources Re Amends 13 & 14 to Environ Rept for Proposed Facility.Comments Encl

ML19256E033
Person / Time
Site:	05000502, 05000503, 05000504, 05000505, 05000506, 05000507
Issue date:	10/17/1979
From:	Fay C WISCONSIN ELECTRIC POWER CO.
To:	Druckenmiller WISCONSIN, STATE OF
References
NUDOCS 7910250327
Download: ML19256E033 (22)

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Wisconsin Electnc eom couem 231 W. MICHIGAN, P.O. BOX '046. MILWAUKEE, WI 53201 October 17, 1979 Reference 1630 Mr. Howard S. Druckenmiller, Director Bureau of Environmental Impact WISCONSIN DEPARTMENT OF NATURAL RESOURCES P. O. Box 7921 Madison, Wisconsin 53707

Dear Mr. Druckenmiller:

WISCONSIN UTILITIES PROJECT HAVEN NUCLEAR PLANT DEPARTMENT OF NATURAL RESOURCES SPECIFIC COMMENTS ON AMENDMENTS 13 AND 14 TO THE ENVIRONMENTAL REPORT 0

• This is in response to your letter of August 20, 1979, transmitting the Department of Natural Resources review comments of Amendments 13 and 14 to the Environmental Report for the proposed Haven Nuclear Plant. Our responses to your comments are enclosed.

Punderseparatecover. Fifteen (15) additional copies are being transmitted We are also providing three (3) copies of our responses to the Public Service Commission.of Wisconsin and five (5) copies to the U.S. Nuclear Regulatory Commission.

Very truly yours, Y /w y '

C. W. Fay, Director Nuc ear Power Department cc: Public Service Commission of Wisconsin M7.S. Nuclear Regulatory Commission Service List Osk, 12ii JUl 7910'250327

SERVICE LIST Haven Nuclear Plant Mr. Bruce Churchill, Esquire Department of Natural Resources Shaw, Pittman, Potts & Trowbridge Bureau of Legal Services 1800 M Street, N.W. Mr. Richard W. Henneger Washington, D.C. 20036 Pyare Square Bldg., Room 1307 Madison, WI 53702 Mr. David Beckwith, Esquire Mr. Howard Druckenmiller Foley and Lardner Director, Bureau of Environmental Is..uct 777 East Wisconsin Avenue Department of Natural Resources Milwaukee, WI 53202 P.O. Box 7921 Madison, WI 53707 Wisconsin's Environmental Decade, Inc. Mr. Tho-as Lockyear, Esquire Mr. Peter Anderson Assistant Chief Counsel Public Affairs Officer Public Service Commission of Wisconsin 114 East Mifflin Street 432 Hill Farms State Office Bldg.

Madison, WI 53703 Madison, WI 53702 Safe Haven, Ltd. Mr. Harold R. Denton, Director Mrs. Wend Schaefer Office of Nuclear Reactor Regulation 3741 Koehler Drive U.S. NUCLEAR REGULATORY COMMISSION Sheboygan, WI 53081 Washington, D.C. 20555 Attention: Mr. Olan D. Parr, Chief Light Water Reactors Citizens for a Betser Environment Branch No. 3 Mr. David B. Merritt Two West Mifflin Street, Suite 202 Madison, WI 53703 Mr. David Schoengold Project Coordinator Systems Planning., Environmental Review and Consumer Analysis Public Service Commission of Wisconsin 432 Hill Farms State Office Building Madison, WI 53702 1211 302

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DNR Comment (Page 3.6-5, Paragraph 4)

Your plan to discharge non-radioactive floor and equipment drainage to the sewage treatment plant is questionable since the treatment of such wastes need only be in the form of suspended solids or soil and grease removal and not biological treatment. These wastewaters would contribute to hydraulic loading, but not necessarily to the BOD q loading and could be treated / disposed of in a different manner than through the STP.

RESPONSE

The routing of non-radioactive floor and equipment drainage to the sewage treatment plant was based on DNR requirements for Point Beach Nuclear Plant. Applicants agree that elimi-nating biological treatment for these wastes is acceptable and will consider modifying the routing to include only suspended solids and oil and grease removal.\\ DNR Comment (Page 4 1-9, Paragraph 1) Where would the 121'000 terial proposed to be removed from the shor eb d spos  ?

RESPONSE

This material will be placed in the spoils area shown on Figure 4.1-2.

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DNR Crmment (Page 4.1-22, Items 2 and 4 and Paragraph 1) Additional information on the toxicity of arsenic and barium and related potential disposal problems at this site should be provided. This dredged material may be classified as a toxic and hazardous substance according to proposed Federal guide-lines on these substances. This would place severe restric-tions upon disposal of these sediments and further investiga-tions and planning may be required for disposal of the material.

RESPONSE

It is assumed that the proposed federal guidelines referred to in this comment are the proposed regulations issued under 40 CFR Part 250, the Hazardous Waste Guidelines and Regulations pursuant to the Resources Conservation and Rec 0very Act (RCRA). The identification methods proposed at 40 CFR Part 250 Subpart A are currently tha subject of discussion and are likely to be substantially changed. Finalization of these regalations is not likely in the near future and the content of the final regulations is presently not predictable. Therefore, it is premature at this time to address unknown requiremente of disposal regulations. Under the proposed RCRA regulations, 100 percent release of the barium in the sediment with the highest concentration (Station 5) would not result in a toxic (and therefore hazardous) classification. Release of 100 percent of the arsenic from the sediment with the highest concentration would result in the toxicity limit being exceeded; however, under the condition 3 of the extraction test, 100 percent release of arsenic is unlikely, and release of arsenic from sediments with lower concentrations would be correspondingly less. The bases for evaluating the effects of the proposed regulations / guidelines are not available at this time. When the necessary regulations, standards, and test procedures have been developed, information will be provided as appropriate.

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DNR Comment (Page 6.1-2) When would the preoperationa! -tudies be conducted and what would they concist of? Whc. if any, aquatic studies are planned during the period oi J<1ay that has been scheduled for the Haven project? What are the through screen velocities of the circulating pump intakes?

RESPONSE

The Applicants do not believe that any additional studies of the lower trophic groups (e.g., phytoplankton, zooplankton, veriphyton and benthic macroinvertebrates) will be necessary. The reason for this belief stems from experience gained from the 5-year intensive monitoring program which was conducted at Point Beach Nuclear Plant. No discernible trends in popu-lation densities or community composition were detected for the lower trophic groups during the 5-year period. In addition, the comprehensive studies did not identify any ecologically significant adverse impacts of the thermal discharge on the lower trophic groups. While subtle changes may occur in lower trophic level community composition in the Haven area, changes which may alter impact predictions for the operation of the proposed Haven Nuclear Plant cooling system are extremely remote. Thus, there is no reason for repeating costly base line-type studies. With regard to adult fish, given the existing status of the Lake Michigan fishery management plan (e.g. , abundant sources of forage supporting extensive salmonid stocking programs; protection of native chub stocks through commercial harvest limitations), few changes in the relative abundance or existing stocks of forage or adult game fish in the vicinity of the proposed intake area would be expected. Thus, the baseline adult fish data base together with the information collected during the 5-year study at Point Beach and annual stock assess-ment data will continue to provide a sufficient back-ground with which thermal discharge and intake impacts can be assessed.

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With regard to ichthyoplankton, little difference in ichthyo-plankton taxa representation was observed when the base line and interim study data (collected 4 years apart) were compared. While few changes in ichthyoplankton composition were detected over a 4-year span, it is possible that measurable changes in terms of spawning activity may take place over a longer time span. If stock monitoring studies conducted by managing agencies show measurable changes in ma c or stock abundance, an ichthyoplankton sampling program may be initiated prior to plant operation. These studies would be similar to those conducted during the interim sampling program. As stated in the Applicants' 316(b) report (Section 5.2.3), the through screen velocities at the traveling water screens are approximately 1.3 fps. The velocity approaching the face of the offshore intake structures is about 0.5 fps. 1211 007

DNR Comment (Page 14.3-3, Paragraph 2) Where would the debris from the screens and trash racks be disposed of? .

RESPONSE

The debris collected from the traveling water screens and trash racks would be disposed of offsite by a licensed con-tractor. 1211 008

s DNR Comment (Page 14.3-5, Paragraph 3) Please specify the uses of the 550 gpm (max. ) of demineralized water makeup. The section indicates (as does Figure 14.3.3-1) the use for "in plant systems" but a specific break down is noL given.

RESPONSE

Demineralized water is used fo' the following purposes:

1. Makeup to the steam and power conversion system to replace losses from steim generator blowdown, sampling and miscellaneous equipment leakage.

2. Makeup to the reactor cool ~'t system and auxiliary systems to place losses due to sampling, letdown and equipment leakoff connections.

3. Miscellaneous other uses such as chemistry laboratory supply, flushing of equipment and decontamination operations.

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DNR Comment (Page 14.3-3, Paragraph 3)

a. Please specify what "other plant components" are supplied by the s'rvice water system, other than the reactor plant comporent cooling heat exchangers (also shown in Figure 14.3.6-3, but not in Figure 14.3.3-1). b. What are the through-screen velocities of the service water intakes?

RESPONSE

a. Other plant components supplied with service water are as follows:

1. Control building ventilation system chillers.

2. Diesel generator engine coolers.

3. Engineered Safety Feature area ventilation coolers.

4. Reactor plant component cooling water pump bearing heat exchangers.

5. Service building ventilation system chiller.

6. Reactor plant ventilation system chillers.

7. Auxiliary boiler blowdown vent condenser.

b. The "through-screen" velocity of the service water intakes is provided in Section 14.3.4.2 and is about 0.1 feet per second.

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t DNR Comment (Page 14.3-6, Paragraphs 3 and 4) Why are the turbine plant component cooling and service water systems to be chlorinated, but not the main condenser cooling systems?

RESPONSE

The turbine plant component cooling and the service water systems are chlorinated to control biofouling since it is not expected that scouring of heat exchange surfaces in these systems will be sufficient to preclude fouling. 1211 011

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DNR Comment (Page 14.3-7, Paragraph 4, Items 1 and 2) Please quantify the projected. solids accumulation since the proposal new states that the storage life has been increased to a 10 year period and the water usage has been decreased.

RESPONSE

The projected solids accumulation is stated in Item 1 as 1850 pounds per year. This is half the value given in Section 3.6.5 for .. units. Since the settling basin size remains the same, the storage period is increased from five to ten years. 121i 012 DNR Comment (Page 14.10-2, Paragraph 1) Besides cost, what other factors (such as environmental degrada-tion) were considered when selecting the condenser temperatures for a once-through cooling system?

RESPONSE

During the preparation of the Applicants' 316(a) and (b) demonstra-tions, joint meetings involving representatives of the U.S. Environ-mental Protection Agency, U.S. Nuclear Regulatory Commi ssion, U.S. Corps of Engineers, U.S. Fish & Wildlife Service, and Wisconsin Department of Natural Resources, were held to discuss issues. During one of these meetings, .L was suggested that the Applicants emphasize reduced water use coupled with an offshore diffuser as a means of reducing thermal discharge imr cts and expediting regulatory review of the proposed once-through cooling system. One of the recommendations involved a tradeoff where higher design AT's would be accepted in exchange for lower circulating water requirements. The rationale behind this recommendation was that higher discharge temperatures coupled with an offshore high-velocity diffuser would have less impact that a lower AT con-denser with a higher cir;culating water use since losses of aquatic organisms would be higher with the latter than with the former. For example, if the design AT is reduced from 40 F to 21'F, circulating water flow would be 625,000 gpm, instead of 348,000 gpm, an increase of almost 80 percent. Conceiveably, entrainment losses alone would almost double while plume size would still be very small. Since 5 years of intensive thermal plume impact studies at Point Beach Nuclear Plant have failed to detect adverse impacts on the aquatic environment, clearly a smaller thermal discharge such as that predicted for the proposed Haven Nuclear Plant would likewise have little or no adverse impact. Thus, it is concluded that the proposed design AT (40 F) coupled with the offshore diffuser and reducedcirculatingwaterflowisthemostenvironmenpj{.ya{cpgpable option available.

DNR Comment (Page 14.10-18, Paragraph 3) Please discIss the attraction and entrainment potential during those time periods when the fixed screens have been removed from the main cooling water intakes and warm water is recycled to keep the intake icefree.

RESPONSE

The response to this question is based on the Applicants' extensive operating experiences and study results at the Poinu Beach Nuclear Plant. Five years of intensjve monthly sampling were conducted in the vicinity of Point Beach Nuclear Plant. With few exceptions, two gill net surveys were conducted each month including the months of November through March, a period during which the protective screens were removed from the 30 inch pipes which perforate the Point Beach intake structure. The results of these surveys demonstrate that comparatively few fish frequent the near shore area of western Lake Michigan near the Point Beach facility during the winter. However, on occasion, rainbow and brown tre.ut were detected in the vicinity of the thermal discharge area. Although the thermal plume often encompassed the intake structure, few trout have been drawn in and subsequently killed by the Point Beach circulating water system. The heated water re< irculated to the intakes proposed for the Haven Nuclear Plant is circulated through the hollow bar grates and is discharged inside the structure. Thus, there is no warning of ambient water in the vicinity of the intake and there will be no attraction due to warm water recirculation. With regard to entrainment, based on existing life history information for Lake Michigan fish species, it is highly unlikely that there are any postlarval fishes other than alewife and smelt present in the near shore area of western Lake Michigan during the winter. Although several species of the family Salmonidae spawn in late autumn, the young do not emerge until spring. During the intensive fish egg and larvae 1211 014

study conducted during autumn and winter 1977 and during spring and summer 1978, no salmonid eggs or larvae were found near the site. Thus, no significant effect is expected due to winter operation with the screenc removed.

                                                     '[)i DNR Comment (Page 14.10-13)

Cooling System Selection Section - Department comments on this section will primarily be presented to WEPCo in our review of the 316(a) and 316{b) reports. A p aliminary review of these documents is presently ongoing.

RESPONSE

WE will provide responses to the Department's comments.

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DNR Comment (Table 14.10.2-1) Please evaluate alternatives the annualized investment costs for the intake listed. Also indicate costs of combined systems that were proposed (conventional traveling screens with removable fixed mesh screens, etc.).

RESPONSE

The differential annualized investment cost for alternatives shown on Table 14.10.2-1 are listed below: Differential Annualized Onshore Alternatives Costs 2 $/ Year Conventional Traveling Screens Base (17,235,990) Modified Conventional Traveling Screens with Fish Handling and Return 382,200 Angled Traveling Screens 2,894,600 Centerflow Screens 559,650 Offshore Alternatives Conventional Velocity Cap Base Velocity Cap with Water Jet Barrier 2,111,500 Removable Fixed-Mesh Screens 311,600 Wedge-Wire Screen 5,535,000 The total evaluated cost (in 1987 capitalized dollars) of the base cooling system which employs the conventional velocity cap and conventional traveling screens is $84,078,000. Combined system costs may be calculated by adding the appropriate differ-12i1 017 ential cost to the base costs. This applies to combinatior s within alternatives (an offshore alternative can not be combined with an onshore alternative). 1 Annualizec Costs = Capitalized costs x fixed charge rate. Fixed Charge Rate = 20.5 percent (Table 10.1-8)

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DNR Comment (Page S.3.9-1) Transmission Facilities Section - The Department's wetland policy (NR 1.95, Wis. Admin. Code) is presently being revised. If more restrictive wording of the Code is adopted, this could affect any proposed plans that would impact wetlands.

RESPONSE

The proposed transmission network additions will be constructed in compliance with all applicable policies, rules, and regulations in effect at the time the CPCN and specific permits required are issued. The Wisconsin Legislature is also considering a proposed Wetlands Bill which could also affect the Departuent's proposed policy revisions. 9

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DNR Comment (Page S.3.9-6) More detailed descriptions of substation construction activities and the r_isting environment are necessary before potential environmental impacts can be assessed.

RESPONSE

Substation construction involves the following activities:

1. Grading of the site and access road.

2. Installai sn of a chain link fence around perimeter of the site.

3. Excavation and installation of foundations for each piece of equipment (e.g. transformers, buses, line breakers, control house, etc.).

4. Installation of grounding rods.

5. Installation of station equipment.

6. Application of crushed stone to the substation area and access road. Application of crushed stone to the access road is generally done immediately following grading to facilitate access and egress during construction.

Land use for the various substation sites described in ER Section S.3.9.2 is as follows: New Acreage Proposed Substation Requirements Land Use Construction Power Substation 1 acre Agriculture Haven Nuclear Plant 9 acres Agriculture Erdman Substation NA Cedarsauk Substation-Saukville Switching Station 0.5 acres Agriculture 1211 120

Range Line Substation 4.0 acres Industrial St. Lawrence Substation 5.0 acres Agriculture Forest Junction Switching Substation 5.0 acres Agriculture Alternate Substation South Fond du Lac Substation NA u i the same as existing land use at all ub to t NA - not applicable. 121i U2s1

o-. DNR Comment (Table S.11.1-1A, Item 4.8) Any change in amount of structural fill necessary and trans-portation of this material should be quantified.

RESPONSE

Changes in the amount of structural fill material necessary for the single unit have not been quantified. Since the area disturbed at the borrow site will not change, the impact remains the same as for two units. Even though the total quantity of structural fill material may be reduced, this will not necessarily decrease tS-number of truckloads per day required to deliver the material. Thus, the impacts due to transport of the material (described in Section 4.1.1.8) will not change in magnitude, although the duration may be less. 1211 122

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