ML17340A990

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Affidavit Re Contentions 7(b)-(c).Small Amounts of Resin Not Removed from Waste Water Prior to Discharge Pose No Environ Threat & No Biological Impact to Organisms in Canal Sys or Surrounding Water Bodies.Prof Qualifications Encl
ML17340A990
Person / Time
Site: Turkey Point  NextEra Energy icon.png
Issue date: 04/13/1981
From: Masnik M
Office of Nuclear Reactor Regulation
To:
Shared Package
ML17340A987 List:
References
ISSUANCES-SP, NUDOCS 8104160369
Download: ML17340A990 (16)


Text

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of FLORIDA POWER 8

LIGHT COMPANY (Turkey,Point Nuclear Generating Units 3 and 4)

Docket Nos.

50-250-SP 50-251-SP (Proposed Amendments to Facility Operating License to Permit Steam Generator Repairs)

AFFIDAVIT OF MICHAEL T. MASNIK ON CONTENTION 7(b)-(c)

I, MICHAEL T. MASNIK, being duly sworn, state as follows:

l.

I am employed by the U.S. Nuclear Regulatory Commission as a Senior Fisheries Biologist in the Division of Engineering, Office of Nuclear Reactor Regulation.

2.

Contention 7 states, in part:

In evaluating the steam generator repair, the following has not been considered:

b.

the effluent release from a full-flowcondensate polishing demineralizing system; or c.

the environmental degradation caused by a full-flowcondensate polishing demineralizing system.

The effluent.releases and the environmental degradation occasioned by utilization of a full.-flow condensate polishing demineralizing system have been considered in Section 4.3.3, entitled "Operational Impacts",of the Final Environmental Statement related to steam generator repair at Turkey Point Plant (NUREG 0743), dated March, 1981.

I have prepared that Section

4i

(copy attached) and it is true and correct to the best of my knowledge.

I hereby adopt that section as my direct testimony on Contention 7(b)-(c).

In sumary, the function of the full-flowcondensate polishing demineralizing system is to purify the condensate water by filtration and demineralization to assure high quality feedwater to the steam generators.

It is anticipated that the removal of suspended solids and ionic species from the condensate water will reduce corrosion related phenomena.

Replacement of spent resins in the full-flow condensate polishing demineralized vessels wi 11 result in the periodic discharge of a waste stream into,the Turkey Point cooling canal system.

This waste stream wi 11 be released at a rate of less than 0.0009 m3/sec (15 gpm) from the discharge structure to the discharge canal that leads into Lake Warren, a receiving

pond, and then into the canal cooling system.

It is anticipated that the small amounts of resins that may fail to be removed from the waste water prior to discharge pose no environmental threat and no.biological impact to organisms inhabi ting or utilizing the canal system or surrounding water bodies.

Michael T. Masnik Subscribed and sworn to before me iio ary Public Illy Comissioo expires:

Il

ES, March, 1981 4.3.3 0 erational Im acts Operation of the full-flowcondensate polishing demineralizers for each unit has also been evaluated.

This system will be installed and become operational consistent with procurement lead times and planned outages.

This is the only nonradiological modification to the plant that will be materially different from those identified in the Turkey Point FES (Ref.

11).

The function of this system is to purify the condensate by filtration and demineralization to assure high-purity feedwater to the steam generator.

It is anticipated that the removal of suspended sol.ids and ionic species from the condensate water will reduce corrosion-related phenomena.

The deminelalizers will use a mixed-bed ion exchange 4-18

41

resin (Powdex, Ref.

27) in a series of vessels.

Condensate water will be cia cu-lati:d into the vessels and through the exchange beds.

Periodic replacement of the resins will occur due to a buildup of suspended solids and exhaustion of the ion exchange resins.

Replacement of spent resins in the full-flowconden-

'ate polishing demineralizer vessels will result in the periodic discharge of a waste stream into the canal system..

Resin vessels will be backflushed to a

backf lush receiver tank and resins replaced periodically depending on the buildup of suspended solids and ion-exchange capacity exhaustion.

Replacement of spent resins in an on-stream vessel will occur about every two to three weeks (Ref. 28).

A total of eight vessels will be used for both units, four per unit, three oper-,

ating at a given time, with one per unit in reserve.

Maximum resin loading is approximately 136 kg (300 lb) dry weight per resin vessel per cycle.

Backflushing will occur at an anticipated frequency of one per week per unit or two vessels per week for the plant.

Approximately 24,000 L (6,350 gal) of high-purity water from the condensate storage tank will be used to backflush each demineralizer resin vessel (Ref.

28).

The spent resins will be backflushed to a receiving vessel for resin-water separation.

The spent resin handling subsystem is designed to process the backwashed resin slurry discharged from the resin vessels using a filtration system.

After resin-water separation, the spent resins

[(136 kg/week/unit),

(300 lbs/week/unit)] will be monitored for radioactivity according to Section 3.9 of the Technical Specification for the plant entitled "Radiation Material Release."

If the spent resins are within the limits for unrestricted

disposal, as expected, they will be disposed of as nonradioactive waste.

If onsite disposal is chosen, NRC is to be notified in writing 30 days in advance.

The supernatant liquid [approximately 22,700 L (6,000 gal)j will be discharged to the canal system.

The quality of the waste water prior to discharge is predicted to have a

pH between 8.5 and 8.7, a dissolved oxygen concentration of 0.08 ppm, and a conductivity about 1 pmho/cm (Refs.

28, 29).

The concentration of total suspended solids in the waste stream is expected to be significantly less than low volume waste source limits which are 100 mg/L instantaneous max.,

30 mg/L monthly average, 40 CFR 423).

The waste water will be released at a rate of less than 0.0009 ma/sec (15 gpm) from the discharge structure to the discharge canal that leads into Lake Warren, a receiving pond (Ref. 27),

and then into the cooling canal system.

Under normal operating conditions, full cooling water flow for all four units is approximately 114 m /sec (1.8 X 10 gpm).

The waste stream from the demineral-izer will discharge for about 7 hours8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br /> per week for each unit.

The waste stream will represent about 0.0008K of the total discharge flow into Lake Warren at full four-unit operation.

Even with multiple unit outage and simultaneous discharge of waste stream from both units, the waste would still represent less than 0.01% of the total discharge flow.

Turbulent mixing in the discharge channel leading to the receiving pond is expected.

Mixing is further enhanced by the geometry of the receiving pond.

Because of the high purity of the backflush waste water stream and the anticipated water quality previously described, no measurable effects on aquatic organisms are anticipated (Refs.

30, 31).

The total demineralizer backflush discharge volume for both units over the life of the plant would represent less than 0.5X of the total present volume of water in the canal system.

-No long-term degradation of water quality in the canal system due to concentration of pollutants in the waste stream system over the life of the plant is expected.

The small amount of resins that may fail to be removed from the waste water prior to discharge poses no environmental threat:

4-19

the resins are highly insoluble, resistant to biological degradation, have no effect on biological oxygen demand

([300) or total organic carbon (TOC), and are nontoxic at concentrations.

expected (Ref. 32).

Ho impact to organisms inhabiting or utilizing the canal system or surrounding water bodies, due to the discharge of the backflush waste water, is anticipated as a result of the (1) extremely small volume of water in relation to the discharge flow and the volume of the canal

system, (2) high purity of the waste
stream, (3) anticipated good mixing of the waste stream and the discharge
flow, and (4) nontoxic aspect of the ion exchange resin.

It is concluded that changes in the operational characteristics of the station due to the steam generator repair or the condensate demineralizer wi 11 not have an adverse or detectable impact on species known to inhabit or used the Turkey Point cooling canal system.

~l 4l

)',Ol"..S I '.'~AL <>UALIFl CA'J J Oh

~'ichael T. Masnik NUCLEAR REGULATORY CO."21l SS10:i 4'ashington, D.

C.

1 am currently employed as Senior Fisheries Biologist in the Office of nuclear Rc"~ctor Regulation, Division of Site Safety and Environmental Analysis, in the E>>viro>>me>>tal Specialists

Branch, USNRC.

As a member of the Aquatic Resources Section of this branch, I have responsibility for the revie~ of applicants'>>viroimenta1 Reports at both Construction (CP) and Operating License (OL) stages for completeness and environmental acceptabili:ty of proposed projects they may affect natural ecological resources, commercial and sports fisheries resources, and other impacts on the aquatic environment.

It is also mv responsibility to provide written evaluation of aquatic resources for inclusion during preparation of both Final Fnvironmental Statement (FES)

CP's and FES OL's.

I a1so act in the capacity of a consultant to other NRC components and provide analyses of aquatic problems through technical assistance requests.

Review of the applicant's environmental technical specifications at the operating 1icense stage and subsequent appraisals of changes to such specifications are a1so part of my responsibilities.

Hy work also involves the preparation of sta>>d'ard review plans, regulatory guides, and staff position papers dealing with aquatic resources.

I provide written input to research proposals under consi,d< ration by the Commission dea1ing with aquatic problems and have served as a Ciimmission representative during the formulation of the Second Hemorandu.

of Undi rstanding between EPA and NRC and have provided written input to both the EPA 316A and 316B guidance manuals.

In the past several years, as a member of the Aquatic Resources Section, I have written the aquatic resources related sections for the Edwin I. Hatch Nuclear Station Unit 2

(FES-OL) and the Perryman Early Site Review; reviewed and provided written input for the aquatic sections of FES-CP stages for the follow-ing plants:

Marble Hill Nuclear Generating Station Units 1 and 2; Phipps Bend Nuclear Station; and the Yellow Creek Nuclear Plant Units l,and 2; provided draft input to a NRC generic study on environmental impacts of the LMFBR program; reviewed and provided written comments on the second draft of the EPA 316B demonstration guidance manual; prepared a biological assessment for sub-mission to the NMFS on the impact of construction and operation of the Salem and Hope Nuclear Stations on the endangered shortnose sturgeon in the Delaware River; provided and was questioned on testimony dealing with the impact of the operation of the Oyster Creek Nuclear Plant Unit 1 on the biota of the receiving waters and the Pilgrim Station Alternate Site Study; represented the USNRC in the area of ecological resources in the CEQ Interagency Working Group for Environmental Data and Monitoring; chaired a section of the Fourth National Workshop on Entrainment and Impingement as well as reviewed and provided comments on numerous solicited and unsolicited grant proposals submitted to the NRC for original research dealing with aquatic resources.

I have a Bachelor of Science in Conservation from Cornell University (1969),

a Master of Science in Zoology from Virginia Polytechnic Institute and State University (1971),

and a Doctor of Philosophy in Zoology from Virginia Polytechnic Institute and State University (1975).

4i

l~'hi.l't Virginia Polytechnic Institute and State University, I undertook research in a variety of areas, specializing in zoogeography and distribution of freshwater fishes.

Other areas of research which resulted in published papers include thermal studies on fishes, recovery of damaged aquatic ecosystems, and develop-s>

sn-...p3ing me'hndology for fishes and macroinvertebrates.

Hy formal

('duo...cu1 program has encompassed and emphas ized studies in Zoology, Ecology, Ichthyology, Evolutionary Biology, and computer techniques for data handling and analysis.

I was a member of the scientific staff of the 1970 Duke University Caribbean Cruise involved in oceanographic investigations and have served as a consultant, through Virginia Polytechnic Institute and State University, for American Electric Power

Company, Koppers Company, Inc., U.S.

Army Corps of Engineers, and Tennessee Valley Authority.

During the summers of 1970 and 1971 I was employed as a field biologist by Ichthyological Associates, an ecological consulting firm under contract with Philadelphia Electric Company and Public Service Electric and Gas

Company, to perform routine sampling on the Delaware estuary.

My duties included routine fish sampling, plankton and benthos

sampling, and inplant monitoring of impingement,.

I am currently a member of the American Fisheries

Society, American Association for the Advancement of Science and the Association of Southeastern Biologists, Societ.y of Sigma Xi, and the Virginia Academy of Science.

1 have authored or co-authored some 19 publications.