ML20115J467

First Amended Response to Joint Intervenors Third Set of Interrogatories & Request for Production of Documents. Certificate of Svc Encl.Related Correspondence

ML20115J467
Person / Time
Site:	Vogtle
Issue date:	04/19/1985
From:	Joiner J GEORGIA POWER CO., TROUTMANSANDERS (FORMERLY TROUTMAN, SANDERS, LOCKERMA
To:
Shared Package
ML20115J460	List: ML20115J457 ML20115J467 ML20115J478
References
OL, NUDOCS 8504230557
Download: ML20115J467 (10)

Text

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6 April 19, 1985~

98CKETED USNRC UNITED STATES OF AMERICA .

NUCLEAR REGULATORY COMMISSION '83 H 22 Atll:24 Befcre the Atomic Safety and Licensing Board [l{fhf,f [g{f[,'

ERA!.C4 In the Matter of  :

GEORGIA POWER COMPANY, et al. : Docket Nos. 50-424CL-

50-42544-(Vogtle Electric Generating  :

Plant, Units 1 and 2)  :

APPLICANTS' FIRST AMENDED RESPONSE TO INTERVENORS' THIRD SET OF INTERROGATORIES AND REQUEST FOR PRODUCTION OF DOCUMENTS On January 9, 1985, Joint Intervenors Campaign for a Prosperous Georgia and Georgians Against Nuclear Energy

("Intervenors") served upon Applicants by mail their Third Set of Interrogatories and Requests to Produce. The Appli-cants served their responses to those discovery requests upon the Intervenors on February 13, 1985. The Applicants submit the following amended responses to interrogatories B-8 and B-49 of the Intervenors' Third Set of Interrogatories.

INTERROGATORY B-8 B-8. Applicants state that " drift deposition rates predicted for five similar power plants were used to estimate a range of drift rates that could be expected at 8504230557 850419 PDR ADOCK 05000424 9 pm

Plant Vogtle . . . . Thus, although some of these plants are now operating, the data used was based on design information." (" Applicants' First Response" p. 93).

Please provide empirigal data comparing the actual deposi-tion rates during operations for those plants that are in operation and on whose predictions the Applicants relied in calculating deposition rates for Plant Vogtle. Provide the bases for the response.

INTERROGATORY B-8 AMENDED RESPONSE: When the comparative analysis was performed, Beaver Valley Unit 1 had been operating since December 1976 and Susquehanna Unit 1 since June 1983. Susquehanna Unit 2 began commercial operation in February 1985. Neither of these plants has performed any monitoring of salt drift deposition rates, either by taking source term measurements or by taking field deposition measurements. Grand Gulf Unit 1 started a 70% power load test run in January 1985 and commercial operation is expected by summer 1985. Salt drift deposition monitoring is underway, but the sampling results are not available.

INTERROGATORY B-49 B-49. In response to IQ R-4 and S-3, " Applicants interpret [ chlorine to mean] chlorine gas." In fact, chlorine emissions in general are within the scope of the contention, and Intervenors request that Applicants provide this response for all chlorine.

INTERROGATORY B-49 AMENDED RESPONSE: Chlorine is added to the makeup water and circulating water systems to destroy the organic growths which may foul piping and heat transfer surfaces in the cooling water systems. The procedures call for the addition of sufficient chlorine to produce a residual " free available chlorine" (FAC) in the circulating water. This " free avail-able chlorine" is not chlorine gas, but "the concentration of unreacted hypochlorous acid and hypochlorite ions existing in the chlorinated water." White, Handbook of Chlorination,

p. 190. The magnitude of FAC maintained in the circulating water will be about 0.2 mg/ liter, except during the Corbicula spawning season when a FAC of 1.0 mg/ liter will be maintained.

OL-ER S 3.6.1.1 Amendment 2.

As described in Section 9.3.7 of the FSAR and Section 3.6.1.1 of the OL-ER, chlorine gas is dissolved in water and added to the water systems at two locations. The first addition point is at the river makeup water intake and the second is at the intake of the circulating water pumps in the condenser cooling water system. In both instances the chlorine added is immediately hydrolyzed and begins to react

with those substances in the water which exercise a " chlorine demand" as described below. The chlorine will exist either as HOCl (hypochlorous acid), as OCl- (hypochlorite ion), or as (reacted) hypochlorites or chlorides.

The distribution between the hypochlorous acid and hypochlorite ion is a function of temperature and pH and can be calculated as follows:

(HOCl) / [ (HOCl) + (OCl-) ] = 1/ [l+ (Ki/ (H+) ) ]

where (HOCl), (OCl-) , and (H+) are molar concentrations and Ki is the ionization constant which varies with temperature.

White, p. 185. For a pH of 7.5, the fractions of FAC represented by HOCl at temperatures of 89 and 122 degrees Fahrenheit (the cold and hot water temperatures, respectively) are 0.43 and 0.37, respectively.

Chlorine demand is produced by those constituents of the raw and circulating water which combine with or form complexes with chlorine to create a form other than FAC.

These other forms may be " combined residual chlorine" (CRC) or some chlorine-containing compounds which cannot be defined as CRC. Chlorine which has been reduced to chloride by any reductant, or which has been combined with organic compounds by oxidation or substitution is not considered-to be any part of the total residual chlorine (TRC) which is the sum of FAC and CRC.

The breakpoint chlorine demand of the Savannah River water has been measured (GPC, PLANT VOGTLE Makeup Water Study, 1978) and has indicated on average, the requirement for a dosage of about 5.5 mg/ liter to produce a FAC residual of 1 mg/ liter in the river water. That value might be used as one basis for estimating the quantities and the significance of potential discharges from the cooling tower of these chlorination products. To provide a maximum worst case emission and deposition evaluation, this analysis uses the maximum addition of chlorine specified in Section 3.6.1.1 of the OL-ER.

As indicated in Table 9.3.7-1 of the FSAR, the River Water

' Chlorination System has two 6000 lb per day chlorinators and the Circulating Water Chlorination System, three 10,000 lb per day chlorinators. With an average makeup flow rate of 20,000 gallons per minute per unit, the two river water chlorinators can add about 25 mg/ liter of chlorine to the makeup water. However, Section 3.6.1.1 of the OL-ER indicates that chlorination will be continuous up to a level of 10 mg/ liter during the Corbicula spawning season to maintain a FAC residual of 1 mg/ liter; this dosage would be continued for a period of about one week per month. Tne maximum concentration produced in the condenser cooling water flow of 484,600 gallons per minute by a 10,000 lb per day chlorinator is about 1.7 mg/ liter.

To provide for maximum emissions, conservative estimates have been made of the distribution of the chlorine derivatives.

It is assumed that all of the added chlorine except for the FAC

d J

and CRC is present as chloride ion, and adds to the dissolved chlorides already introduced into the system by the makeup river water (about 5 mg/ liter). It is further assumed that the CRC is composed of 0.6 mg/ liter of monochloramine formed by the reaction of the hypochlorous acid with the 0.21 mg/ liter ammonia contained in the makeup water. Table 3.7-1 of the CP-ER.

Of the 1.67 lbs of chlorine added per minute to the makeup water from the river, about 0.083 lbs per minute is assumed to combine with the ammonia to form monochloramine; 1.59 lbs per minute is assumed to become chloride ion. Of the 6.94 lbs per minute added to the circulating water, all but the amount producing the FAC of 1.0 mg/ liter adds to the chlorine-derived chlorides. The FAC and CRC are assumed to follow the behavior of the circulating water passing through the cooling tower; i.e., the fraction carried into the vapor phase will be the same as the fraction of water evaporated.

Assuming operation of the cooling tower at four cycles of concentration, the added " chlorides" would increase the blowdown (and drift) dissolved solids concentration at equilibrium from 240 mg/ liter to about 440 mg/ liter (an unrealistically high value), and increase the drift mineral deposit by the same proportion (440/240). Thus, if the practice were to be continuous on a year-round basis, the previously estimated maximum drift deposition from both

towers of 1.7 pounds per acre-year (See "An Evaluation of Cooling Tower Drift Deposition at the Vogtle Electric Generating Plant") would increase to about 3.1 pounds per acre-year. However since such a high dosage practice would occur for one week per month per unit from April to November

[ Response to NRC Question 291.15], for an equivalent of 2 months per unit year, the maximum deposition value would increase to 1.7 + 1.4/6, or 1.93 lbs per acre-year.

The FAC and CRC in the circulating water are assumed to be lost'to the atmosphere with that fraction (15,000 gpm) that evaporates; at a concentration of 1 mg/ liter of FAC and 0.6 mg/ liter of CRC, the evaporate would transfer 15,000 gpm X 8.345 lb/ gal X 1.5 lb (FAC+ CRC)/1,000,000 lb water = 0.19 lb/ minute of FAC and CRC. As vapors these materials would be dispersed as gases and not deposit on the ground as promptly, or at as high a deposition density as the drift droplets. However to be conservative, it is assumed that the FAC and CRC deposited would follow the deposition patterns of minerals originating in the liquid drift droplets. Since the emission rate of those minerals leading to the maximum drift deposition estimate of 1.7 lb/ acre-year is 0.155

- lb/ min, it can be estimated that the upper limit of FAC and CRC deposited would be at a rate of (.19/.155) X 1.7 = 2.1 lb/ acre-year per unit. Again since this maximum chlorina-tion practice occurs for an equivalent of 2 months per year per unit, the maximum increment would be about 0.69 lb/ acre- ,

L

4 year with the highly conservative deposition assumption.

Adding these " chlorination" contributions at the maxi-mum location (0.23 lb/, acre-year from added " chlorides" plus

, 0.69 lb/ acre-year from the FAC and CRC) to the (approximately) 8% of the drift mineral comprised of the chloride ion from the river makeup water (0.14 lb/ acre-year) yields a ma.-3 um estimated " chloride" deposition of about 1.06 pounds per acre per year. This value is well below any level of significance to vegetation. See Final Environmental Statement S 5.5.1.1.

Respectfully submitted, Jh es E. Joinck) P.C.

C rles W. Whipey K vin C. Greene Hugh M. Davenport TROUTMAN, SANDERS, LOCKERMAN

& ASHMORE George F. Trowbridge, P.C.

Bruce W. Churchill, P.C.

David R. Lewis SHAW, PITTMAN, POTTS &

TROWBRIDGE Counsel for Applicants DATED: April 19, 1985

EDCCfM UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 00LKETED Before the Atomic Safety and Licensing Board USHRC 15 APR 22 21:24 In the Matter of  :

GEORGIA POWER COMPANY, et al. Docket Nos. 50-424 I NG SERVlb f

50-425[0C BRANCH (Vogtle Electric Generating  :

Plant, Units 1 and 2)  :

CERTIFICATE OF SERVICE I hereby certify that copies of Applicants' First Amended Response to Intervenors' Third Set of Interroga-tories and Request for Production of Documents, dated April 19, 1985, were served upon those persons on the attached Service List by deposit in the United States mail, postage prepaid, or where indicated by an asterisk (*) by hand delivery, this 19th of April, 1985.

Jah E. Joiner,T .C.

Counsel for Applicants DATED: April 19, 1985.

UNITED STATES OF AMERICA

'< . NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board In the Matter of )

. }

GEORG1A POWER COMPANY, et al. ) Docket Nos. 50-424

) 50-425 (Vogtle Electric Generating Plant, )

Units 1 and 2) )

SERVICE LIST Morton B. Margulies, Chairman

• Douglas C. Teper Atomic Safety and Licensing Board 1253 Lenox Circle U. S. Nuclear Regulatory Commission Atlanta, Georgia 30306 Washington, D. C. 20555

• Laurie Fowler & Vicki Breman Mr. Gustave A. Linenberger Legal Environmental Assistance Atomic Safety and Licensing Board Foundation U. S. Nuclear Regulatory Commission 1102 Healey Building Washington, D. C. 20555 Atlanta, Georgia 30303 Dr. Oscar H. Paris

• Tim Johnson Atomic Safety and Licensing Board Campaign for a Prosperous Georgia U. S. Nuclear Regulatory Commission 175 Trinity Avenue, S. W.

Washington, D. C. 20555 Atlanta, Georgia 30303 Bernard M. Bordenick, Esquire Docketing and Service Section Office of Executive Legal Director Office of the Secretary U. S. Nuclear Regulatory Commission U. S. Nuclear Regulatory Washington, D. C. 20555 Commission Washington, D. C. 20555 Atomic Safety and Licensing Board Panel Bradley Jones, Esquire U. S. Nuclear Regulatory Commission Regional Counsel Washington, D. C. 20555 U. S. Nuclear Regulatory Commission Atomic Safety and Licensing Suite 3100 Appeal Board Panel 101 Marietta Street U. S. Nuclear Regulatory Commission Atlanta, Georgia 30303 Washington, D. C. 20555 4

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