ML19303A299

Comments on NUREG-0813,DES for Facility.Final Research Design Has Been Prepared & Forwarded.Fuel Load Date Changed to June 1983.Clarification Needed Re Issuance of Water Quality Certification Being Required Before OL Issuance

ML19303A299
Person / Time
Site:	Callaway
Issue date:	11/20/1981
From:	Schnell D UNION ELECTRIC CO.
To:	Youngblood B Office of Nuclear Reactor Regulation
References
RTR-NUREG-0813, RTR-NUREG-813 ULNRC-529, NUDOCS 8112040607
Download: ML19303A299 (16)

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UNION ELEcmic COMPANY j

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,, Mr. B. J. Youngblogd, Chief Licensing Branch Ng. 1 Division of Licensing

. . U.S. Nuclear Regulatory Commission .

. Washington, D.C. 20555 . ULNRC-529

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Dear Mr. Youngblood-

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• DOCKET NUMBER 50-483 jp y ,~ ,',p{jji d,'

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DRAFT ENVIRONMENTAL- STATEMENT *

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CALLAWAY PLANT - UNIT 1 j . ~' \

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ug.p# 1 We hjl;ve'.reyiewed the Draf t Environmental State e8

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related to the operction of the Callaway Plant, Unit No Q ,

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(NUREG-0813 ) and have the following cc::ments: \ ,'

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41. Summary and Cenclusions, P. tee v, Item 3 - The_7uel load 4 ate for Unit 1 has been changed to June',.;19 C

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and Unit 2 has been cancelled. ~--

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p 2. Su==ary and Conclusions, Pace vii, Item 5f - A

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final researen cesign nap peen preparec anc,  !

f:rwarded to Mr. Youngblood by letter dated November 9, 1981. " -

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p 3. Chapter 1, Section 1.1, Page 1-1 and 1 The fuel  ;

load date for Unit 1 has been changed to June, 1983

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," with ec=mercial operation in early, 1984. Unit 2

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,,has been cancelled. .

4:$. 4 . I Ch apter 1, Section 1.2, Page 1 This section I

states that the issuance of a water quality certification by the state is a necessary prerequisite for obtaining an operating license from NRC, however, the statement is vague'and ,

misleadinc as to whether this cert fication has COO *

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been secured. This statement should be clarified #

to indicate a water quality certificatied has been  ;

gebtained. ~, /l l

. g 5. Pages 4-3, 4-6, 4-11, 5-2, 5-3, 5-8, 5-9 and i Appendix 3 - In April 1980, the Missouri Department of Natural Resources (DNR) published notice of a proposed NPDES permit for Callaway Plant'. The draft

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91120A0607 911120 PDR ADOCK 05000483 .

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j permiti proposed a limitation of 30 mg/l (mont.hly aver, age) and 100 mg/l (daily maximum) of TSS for

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discharge from the water treatment clarifier

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(out(all #003). These TSS limitations were imposed

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.. in the NPDES permit that was issued in fiaal form

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-in Adgust 1980.

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In MQ 1980, Union Electric filed with DNR its 4 . formal request for a variance for outfall #003

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,pff s pursuant to 40 C.F.R. Section 423.12(a). In its variance' request,' Union Electric objected tc these ~

i h limitations, since the suspended solids in the- #003

outfall discharge consist mainly of silt from intake water taken from the Missouri River. The

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. _. . variance request noted -that UE qualifie's for a 3

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• _ varian_ge because the clarified blowdown at callaway

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,.. considered by federal EPA in developing limitations  ;

1 for the steam-electric power generating category.

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Maior differences exist with respect to technical factort (e.g. type of facilities, raw materials),

3 non-water quality environmental impset, costsy- and water quality considerations. On May 23, 19 8_Q:, .-DNR j

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forwarded UE's variance ~ request to EPA-Region ~-21I

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_ without recommendation, for EPA's decision. 2 j Uni 8n 11'ectric has already completed construc* .[

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of 3 of the 16 sludge retention ponds that wontd be i

required over the life of the plant. A favo'rable

. decision to allow the return of clarifier sludg'e to

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the riv.er would most p.robably res' ult in the current and future ponds being unneqessary. _

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It should be noted throughout the report that, as a

_ result of the variance request, clarifier sludge

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disposal ponds at callaway may be used as opposed

, to will be used. _

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-$F 6. ~"Pages 4-3, 4-6, 4-11, 5-2, 5-3, 5-8, 5 'i

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Discussions on these pages should be expanded to .

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include information from the attached revised pages 3.6-1, 3.6-9, 4.1-1, 4.1-2, 4.3-1, 10.4-1,. 10.4.2 and Figures 2.1-3, 4.1-2 and 3.3-1 of the .ER-OL.

These revised pages discuss the . method to be used a

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for disposal of Cooling Tower Basin Sediment for

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Unit-1 only. .

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udC 7. Chapter 4, Section 4.2.4.1, Page 4 The' list l

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sentence of the second paragraph on this page ntates that for one unit operation, the intake i velocities (for the intake structure) would be {

( about one-half the previously stated values for two '

I unit operation. Since each intake water. pump is l L located in its own pump bcy and operation of the

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4( 7, I pump

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gI velo,is'at cities design capacaty across the screensatwould all times, inta$ke be the same

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• gpgardless of the number of pumps in operation.

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, , . Chapter 4, Section 4.3.4.1, Page 4 The

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. construction monitoring program will continue until

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4 the end of construction and not "up to May, 1981"

, as indicated.

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gg 9. Ichapter 5, Section i .

5.1., Page 5 In the fourth

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paragraph of this Section NRC states that in

• accordance with the Environmental Protection Plan,

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Union . Electric must report violations of conditic as r.tated in the NPDES permit. We feel that

' ~~ violations need -only .be_ reported to the NPDES perni( issuing authority which is the Missouri

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Dep'artfent of Natural Resources.. This duplication j [. ,of,repbrting is an unreasonable regulatory burden.

. gyp .10. " Chapter 5, Section 5.2, Pace 5' The second A .

-sentence tf paragraph 2 stgtes that 2000 acres will

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be unavailable for public use during'the . . _ .

operational lifetime of the plant. This is not the

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intent.of our land management plan. Those lan'd 2

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designated as "Public Uhe Not Authorized" on EEPOL 3 Figure 2.1-34 are so designated only through the __ t l' con h etion period. -During Operation, - these Qnd,s ---

will be added to that already under the management

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of the Missouri Department of Conservation for-low

{intensitypublicuse. >

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q$.11. fChapter5, Secticn 5.5*.1.2, Pace 5 In the paragraph under " Drift Fallout" a comparison of cooling tower drift deposition is made to the 15

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ton /mi per month settleable particulate standard 1 established by the State of Missouri. Missouri has I

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.' ' since deleted this settleable particulate standard Lf rom the state regulations..

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.pr 12. Ichacter 5, Section 5.5.1.6, Page 5 The NRC

evaluated tne potential operational impacts from Callaway Plant - Unit 1 and concluded that "the potential for damage to the surrounding ec'esystem cauced by the water and chemicals in the drift expected from the cooling tower will be small"

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neverthelers the staff recommended that Union

. Electric conduct a limited-term inspection program.

NRC also stated that an acceptable program-is best

, accomplished by means of infrared aerial

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photography with accompanying ground truth and that this progran would be specified in Appendix B of

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the operating license. ,

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- ' While Union Electric does not have a strong objei-tion to some moderate ' form of monitoring for

. terrestrial operational impacts, we question why it

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is necessary to include such a low-key program as

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- is ne[of the operating license and why NRC feels it cessary to specify a methodology. As part of g the operating license there is the possibility that gh - certa,:.n meaningful, scientifically valid modif.j. cations of .the monitoring program could not

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license modificat; ion process including possible

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publig hearings and Federal Register notice. This

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' , process is unnecessary and represents an excessive regulatory burden for both the Commission and the

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Cospany. Therefore, -it- is recommended that this

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monitoring program .not be included as part of Appen@ix B of the operafiii~g license.

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...- *  ; 4 Uni'on Electric is in the process of developing a

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moliitoring program that will adequately measure Tmpac(1.s Unit caused by operation of Callaway Plant .- ~

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- This prograin will include procedures for repo~rQng to NRC any occurrence of important events that-potentially could result in significant environmental impact causally related to plant$~ E- --

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M 13..PChapter 5. Table 5.4. Pace 5-31, 5 All sample  ;

quantit;.es are sub]ec* td change depending upon analysis techniques utilized in the future. .

g 14,i Chapter 5. Section 5.9.4.3. Pace 5 The second

_ paragrapn under site Features states that

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activities within the exclusion area are limited to

, ., agricultural activities. Our, intent is that no 1

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developments attracting uncontrolled public l activity in or encouraging casual.public entry into the exclusion area be permitted. This does not  ;

, limit the use to agricultural activities.

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g 15. Chapter 5. Section 5.9.4.3, Page 5-41, Emergencv Preparedness - The Callaway Plant Radiological

~ Emergency Response Plan is complete and a conclusion has been made by NRC that the plan meets the planning standards of 10 CFR 50.47(b) _and the requirements of 10 CFR Part 50, Appendix E (3UREG-

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0830, Safety Evaluation Report related to the operation of Callaway Plant, Unit No. 1, October, 1981, Appendix F).

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g 16 - Chapter 5, Section 5.9.4.4, Page 5 In the .

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third paragraph, Item 1, Columbia is 30 miles from ,

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._ the s.ite rather than 15 miles as stated.

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- If you have any questions, please do not hesitate to

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contact us. 4 4

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very truly yours,

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