ML19319D353

Submits Comments on CP Application in Response to Rs Boyd 670817 Ltr.Recommends Performance of Preoperational & post-operational Radiological Surveys,Including Studies of Radionuclide Effects on Selected Organisms

ML19319D353
Person / Time
Site:	Crystal River, 05000303
Issue date:	02/12/1968
From:	Pautzke C INTERIOR, DEPT. OF, FISH & WILDLIFE SERVICE
To:	Price H US ATOMIC ENERGY COMMISSION (AEC)
References
NUDOCS 8003131025
Download: ML19319D353 (6)

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Mr. Harold L. Price Director of Regulations U. S. Atonic Energy Comission Washington, D. C. 205h5

Dear Hr. Price:

This is in reply to Mr. Boyd's letter of August 17, 1967, reonesting our co=cnts on the application of the Florida Po ter Corporation for a con-struction pemit for the proposed Crystal River Nuclear Generating Plant Units Hos. 3 and h, Crystal River, Citrus County, Florida, AE0 Docket Nos. 50-302 and 50-303 The project would be located adjacent to Crystal River Unit No.1 presently in operation and Unit No. 2 uhich is under construction on the Gulf of ::exico Coast, 7.5 niles northwest of Crystal River. Pro pres-surized water reactors, designed for a conbined ultinate output of 5,088 themal negauctts and a net electrical output of cpproximately 1,758 nogawatts, vould be used as a power source. . The heated effluent fron the cooling systen will be discharged into a shallou water area betacen spoil from the condenser water discharge channel and spoil fron the Cross Florida Barge Canal. This 150-acro area is open to the Gulf of Mexico on the west at Denory Mp. The botton of this shallow water area is predoninantly hard sand and rock.

Severcl large bars of " coon" oysters occur within the area and small patches of Cuban shoalweed are found in the vicinity of Denory Gap.

Although connercial net fishing in the area is limited, crabbing along this.section of Gulf of Mexico coastal narsh is extensive. There is a valuable sport fishery for redfish (channel bass) and seatrout in the l estuarine area surrounding the project site during winter months. l l

According to statencnts of XLorida Power Corporation personnel, water in the area of the proposed cooling water intake reaches a secconel high tenperatur! of 8h0to 850 F. during August, and surface temperature reaches 920 F. during calm days. An anticipated 8 to 10o F. gain in temperature uill occur as the cooling w@ passes over the condensers.

The gain in heat will remain nore or less cor.ctant, while the volune of cooling unter required will vary according to en tenperature and

. operational denands. Water requirenents for cooling the conventional coal-powered units vary betueen 285,000 g.p.n. (3,800 c.f.s.) for a single unit to 600,000 g.p.n. (8,000 c.f.s.) for both units. Estinates 488 t

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b of the quantity of unter required for the operation of each nuclear unit ,

vary betroen 663,000 g.p.n. (1,500 c.f.s.) and 1,032,000 3.p.n. 1 (2,~.00 c.f.s.) uith a calculated average of 310,000 g.p.m. (1,C00 c.f.s . ), e The applicant indicates that the release of radioactive unstes vould not enceed naninin pemissible limits prescribed in Title 10, Part 20, of the i Oodo of Federal acculations. Although these linits refer to na:& tun levels of radioactivity that ecn occur in drinking unter for nan, uithout resulting in any knoin hemful effects, operation within these linits may not alunys ;;uarantee that fish and uildlife vill be protected from adverse effects. If concentrations in the receiving uater nere the only con-

, sideration,. nc-dnun pemissible lhits uould be adequate criteria for detemining the safe rato of discharge. Horever, radioisotopes of nany elenents are concentrated and stored by organisns that require those elenants for their nomal notcbolic activities. 3one organisns concen-trate and store radiois'otopes of elenents not nomally required but uhich cre chemically similar to elenents essential for netabolism. In both cases, the radionuclides are transferred fron one organism to another through various levels of the food chain just es are the nonradion ave elenents. Tnese transfers nay result in further concentration of radio-nuclides.and a nide dispersion froci the project area, particulcrly by nigratory fish, cannals, cnd birds.

In vieu of. the above, ne believe that pre-operational and post-operational radiological surveys should be conducted by the applicant and should in-clude studies of the effects of radionuclides on celected orsanisms

' indigenous to- the project area uhich require these vaste elenents or ,.

similcr elenents for their notabolic activities. In addition, the surveys should include studies _to detemine current velocities and patterns and tenperature neasurenents at various depths, including the surface. Tnese survoya'should be planned in cooperation uith she appropriate Federal and State a;encies. If it is detomined fron pre-operational su veys that the release of radiocctive effluents at levels pomitted tmder the Code of Federal Regulations uould result in harnful concei trations of radio-activity in fish and uildlife, plans. should be nau to reduce the discharge of radioactivity to acceptable levels. Bat-operational surveys should be conducted .to evaluate the predictions based on the pre-operational surveys and to serve as. a basis for reduction of radiocctive levels to insure that no. unforeseen dtnage' occurs.

!In view of' the importcnce of the sport and comercial fisheries of this section of the Gulf of 1.'enico, it is imperative that ever/ possible effort be.nade to protect these valuable resources from radiorctiva contanination.

-Therefore,'it is recommended that the Florida Pouer Corporation be required

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1. Cooperate uith the Fish cnd 'lildlife Service, the Federal Mater ?cllution Control /.dninistratton, the Florida State Pollution Control Com.ission, and $ts nenber a encies, which include the State 2 card of Conserntien, the Florida Gene cnd ."'resh ~~ater Fish Ocmission, cnd the Stato Board of Health, and other interested State a;encies in de-velopin; plans for radiological surveys.

2. Conduct or arren;e for the conduct of pro-operational radiolo;ical survaya, including studies of selected cr-

cnians indicenous to the area that concentrate and storo radioactive isotopes, and of the environnent including

. rater and sed $nent sanples; and studies to detemine current velocitics and patterns and tenperature at various depths. These curveys should be conducted by scinntists hnculed; cable in the fish and uildlife field.

3 Prepare a report of the pre-operationel rediological curvey, end provide five copies to the Secretar; of the Interior for evaluation prior to project operation.

h. '..a':c nodifications in project structurea and operations to r3Cuco the dischar30 of radios.ctive unstes to ccept:ble level :.f it is do erninea in the pre-operational or the pos t,-operabio:n1 surveys that the release of radioactive effluent per.;itted und:r Titic Iv, Part 2J, Oode of Federal Re;;ulations, vould result in harnful concentrations of radioactivity in fish and uildlife.

3 Conduct post-radiolo;ical surveys, similar 1o those specified in reconnendation 2 above, nalyze the data, and propare and submit reports every six nonths thereafter or until it has been conclusive 1f denonstrated that no cig-nificant rdverse conditions e::ist. Subnit five copies of these reports to the 2ecretcry of the Interior for dis-tribution to the appropriate 5tcte and Federal ec;encics 2,;r evcluation.

'*e understand it is the Corniscion'c cHnion nhat its re ;ulatory authority over nuclear pouer plants involves only those hazards associtted uith rvdioactive natorials. Houever, ne recornend end urge that before the per .'it is issued, the:ncl pollution and an:/ other detrimental effects to fish and JildliJe Jhich nty result fro.: pir.at construction and opers._ a be celled to the cp?licant's attention. 'o recomend : cMicr that the applicant he requested to Cccucc thic nat:cr uica ap,roprirte State cenacrvation .officiais and the Jich cnd ~ildlife fervice rnd to devci.op

.cacurcs to ninini;c those htrards.

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7e are unable to determine the acreage of receiving vaters which vill realise c rise in tenperature. Although no danage frca the heated efflur.t fron Unit !!o.1 is evident ct this tine, the increased voltr.e of heated ucter as other units are built and placed into operation nay give rise to excessive tenperatures in the area betreen the spoil fron the condensor unter discharge cha:ulel and that of the Cross Florida 3ar;e Canal, particularly in the 350-acre crea adjacent to the heated effluent. This latter aren varies in depth fren 2 to h feet ana, thereforo, contains approninately 1,0$0 acre-feet of water. Conplete displacement of the uater in this area could occur every 20 hours2.314815e-4 days <br />0.00556 hours <br />3.306878e-5 weeks <br />7.61e-6 months <br /> uith the operation of the conventional coal-po'rered stean generator presently in use, or every 3 5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> with the tro proposed nuclear stcan ;enerators.

Little is knoun cs to effects of thornal pollution in subtropical vaters.

Shri tp taken fron unters exceeding 900 F. cre usually flaccid cnd highly sensitive to stress induced by handling. Large volumes of hected uater dischar;;ed into an aquatic envirorrient nay not only be detrimental to fish life directly,but may also affect these resources indirectly through changes in the ecological connunity, particularly the food or-ganisns on which fish depend. To neasure biolo;ical chen:cs in ncrine or;cnians and long-tcrn chcnges in the envircracnt, ecolo;ical surveys should be carried out prior to cnd follouing plant oper . tion so vhat conparative data will be available for analysis.

Sycical, chemical, and biological aspects of the affected area vill need study to achieve an understanding of the inpact of the project on fish and vildlife resourecs and their utili::ation. Floa studies to deternine current and temperature patterns during each secson vill be needed. The effect of higher unter tenperatures on the crysen content vill be of concern, particularly during the period fron June throuch Septenber. Detemination of chenges in the invertebrate fauna uill require frequent canplinc, probably on a nonthly basis for i :/ car before the plant is in operation and the first year during operation. Sub-coquent aanplin; could be lesc frequent, as cequired by acological conditions.

In view of the Adninistration's policy to naintain, protect, and inpro7e the quality of our environnent, cnd nost particularly the unter and air nedia, ne request that the Co:2ission urse the Florida 'cuer

! Corporation to:

1. Coopertte uith the Fish cnd'ildlife Service, the Federal 7ater Pollution Control Adninistrc. tion, the Florida State Pollution Control Coatissien,and its nenber r;cncies which include the State 3oard of Conservation, the Florida h

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Gane and Fresh *.fator Fish Corr.ission, cnd the State Board of Health, and other interested State agencies in developin; ecological surveys, initiate these studies at least 2 years before reactor operction, and continue then on a recular basis or until it has been con-clusively denonstrated that no significant adverse conditions exist.

2. ::cet uith the above-mentioned Federcl and State a;encies at frequent intervals to discuss neu plans and to evaluate results of enisting surve/s.

3 Ihke such nodifications in project structures and operation, including but not limited to facilities for cooling discharge waters, as nay be determined necessary by the pre-operational or post-operational surveys to protect the fish and vildlife resources of the aren.

This opportu.ity to present our viens on the project is appreciated.

Sincerely yours, es L

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