ML17317A753
| ML17317A753 | |
| Person / Time | |
|---|---|
| Site: | Cook  |
| Issue date: | 11/08/1978 |
| From: | Schwencer A Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML17317A751 | List: |
| References | |
| NUDOCS 7811270021 | |
| Download: ML17317A753 (18) | |
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~ 0 ENVIRONMENTAL IMPACT APPRAISAL AND SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION SUPPORTING AMENDMENT NOS.
26 AND 8 TO FACILITY OPERATING LICENSE NOS.
DPR-58 AND DPR-74 INDIANA AND MICHIGAN ELECTRIC COMPANY il'NDIANA AND MICHIGAN POWER COMPANY DOCKET NOS. 50-315 AND 50-3'16
INTRODUCTION By letter dated March 1, 1978, the Indiana and Michigan Power Company
( IMPC
) requested changes to the Environmental Technical Specifications for D.
C. Cook, Units 1
and 2 (Cook).
The proposed changes include:
l.
A change in the location of the measurements'aken for determining the temperature at which deicing must commence.
(Section 2.1.3.2) 2.
A change in the type and amount of chemicals added to the water of the steam and feedwater systems and the plant heating boiler.'Section 2.2.2) 3.
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5.
An increase in the annual limit of detergent discharged from the
- plant, and a modification of the section so that the limits on chemical discharge covered by this section become reporting requirements.
(Section
- 2. 2.3)
The deletion of Section 3, which deals only with descriptions of the plant that are already covered in other reference sources.
A modification to Section 4.1.1.2 which would increase duration of the four surveillance intervals for conducting thermal plume studies.
6.
7.
A deletion of the requirement to report well depths and g'round-water strata of wells on an annual
- basis, and an addition of a requirement to monitor the groundwater level in each well.
(Section 4.1.1.5)
A reduction in the number of wells that must be monitored.
(Section 4.1.1.5) 8.
9.
10.
A reduction in the frequency of groundwater flow tests.
(Section 4.1.1. 5)
Deletion of the requirement for monitoring terrestrial biota (on the basis that the survey has been carried out).
(Section 4.1.2.2)
Replacement of the radioactive effluent release report requirements described in Section 5.4.1.B with a reference to Regulatory Guide
- 1. 21.
Revision of Section 5.4.2.1 so that this section conforms to Draft Regulatory Guide 4.8 (Reporting Requirements).
Several other sections which deal with reporting requirements have also been modified accordingly.
N-C lt
- 12. Certain requirements for installing equipment and submitting reports which were included in Appendix B are deleted because these requirements have been met.
The sections affected are:
2.1.1.2, 2.1.3.2, 2.4.2.g, 2.4.4.b, 4.1.1.2, 4.2.2.4, 4.1.1.4 and 4.1.2.1.1.5.
- 13. Editorial changes to Sections 2.1.1.2.4, 2.4.3.d and 4.1.2.1.1.5.
14.
The replacement of the waste gas storage tank effluent radiation monitor with the Auxiliary Building ventilation system radiation monitor for the purpose of automatically isolating the waste gas storage tanks.
(Table 2.4-4) 15.
A reduction in the number of milk background stations in the event that less than three such stations become available for use.
(Table 4.2-1)
A proposal was included in the IHPC submittal which would change the allowable chlorine limits (Section 2.2.1.2).
This action remains
- open, and will be handled in a separate action at a later date.
Also we considered certain changes from the IHPC proposal appropriate.
These changes have been discussed with and agreed to by the IMPC's staff.
DISCUSSION AND EVALUATION - ENVIRONMENTAL CHANGES l.
Deicin Tem erature Location Section 2.1.3.2 Because of ice cover and frequent equipment-damaging conditions, a change is proposed for the location of measuring the temperature at, which deicing must terminate.
The -present limit refers to ambient lake temperature whereas the proposed'limit will refer to intake temperature.
During deicing operation, the intake temperature increases more than the ambient lake temperature.
- Thus, we find the proposed change to be more conservative from an environmental impact standpoint and, therefore, acceptable.
2.
Steam and Feedwater Chemistr Section 2.2.2 IMPC has proposed to change the type and amount of chemicals added to the water of the steam and feedwater systems and the plant heating boiler.
The following table depicts the chemicals and concentrations that are currently in use and those proposed.
Chemical Current m.
Pro osed m
Phosphate
.025
.007 Morpholine
.006 r
none Ammonium-OH from Hydrazine
.031
.17 Sulfite none
.036 IMPC is proposing this change as it will improve the efficiency of the water treatment procedure.
The staff has proposed that the subject be moved from this section to a
new Section 4.1.1.6, pp. 4.1-13 and 4.1-14.
The result of this will be to convert the limits of chemicals controlled by this section to report requirements.
Evaluation:
The D. C.
Cook Final Environmental Statement (FES) did not predict that these chemicals would have an adverse impact on the environment.
Operational data support a conclusion of no signi-ficant adverse impact.
Thus, it is no longer necessary to include-them as limiting conditions for operation; Including them as report requirements wi 11 provide the staff the information to take action if nec'essary.
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The concentrations of phosphate and morpholine used in these systems will be lower than that now used, and as such, will have less potential environmental impact;
- however, the concentrations of ammonium hydroxide and sulfite will'e greater tPan that now used.
We find the change iq the limits (now report requirements) to be acceptable on the following basis:
(1)
Hydrazine reacts to form ammonium hydroxide, which in turn, reacts to form ammonia.
It is the ammonia which can have destructive environmenta]
effects.
The chemical equilibrium between the ammonium hydroxide and the ammonia is such that, at a discharge concentration of ammonium hydroxide of 0.17 ppm, the equilibrium concentration of ammonia would be about 0.002 ppm.
This is 10 percent of the EPA "Red Book" limit for toxicity to aquatic life. Thus, we expect the discharge to have an insignificant environmental impact.
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(2)
Under worst case conditions'. the discharge of sulfite will be less than 0.036 ppm.
Su)fite reacts quickly in the natural environment to form sulfate.
The concentration of sulfate in the lake is around 20 ppm, thus, the natural lake sul'fate concentration and the equilibrium chemical kinetics between sulfate and sulfite will determine.the equilibirum sulfite concentration.
The sulfite released from the plant will be
'ow, consequently we conclude that it will have a negligible effect on the concentration of'sulfate or sulfite.
3.
Deter ent Dischar e Limit (Secti~on 2.2.3 This section deals with chemical discharges other than chlorine and corrosion and deposition inhibitors.
The staff has proposed that the subject be moved from this section to a new Section 4. 1.1.7, pp.
4.1-15 through 4.1-17.
The result of this will be to convert the limits on chemicals controlled by this section to report requirements.
IHPC has also proposed an increase for the annual limit (now report level) of detergent discharged fr'om the plant.
The present limit is 3,000 lbs/year and the proposed report level is 5,000 lbs/year.
IMPC also requested that the specification allowing a one-time discharge of detergent to the cleaning pond be deleted as the cleaning has been completed.
Evaluation:
The FES,d,id not predict that these chemicals would have an adverse impact on 'the environment.
Operational data supports this conclusion of no significant adverse impact.
- Thus, we conclude that it is no longer necessary to include them as limiting conditions for operation.
Including they a's 'report requirements will provide the staff the information to "take action if necessary.
The environmental concern of the change of the limit (now report requirement) of detergent usage is the phosphate content.
The detergent used at this facility contains 0.7 percent phosphate.
Thus, under the proposed level, 35 lbs/year of phosphate would be discharged to the lake.
If the detergent were discharged uniformly and continuously, we calculate that the level will still be well below the natural level of about 40 ppb, and, therefore, that there will be an insignificant environmental impact.
On this basis, we find the change to be acceptable.
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4.
Deletion of Section 3.
IMPC has requested deletion of Section 3 of Appendix B on the basis that it contains only descriptions and specifies no monitoring require-
'ents and no operating limits.
Evaluation:
This section gives background information on the station and its operation.
Since this information has been placed in the NRC docket files under oath or affirpation, we conclude that the section may be deleted without effect on'he environmental impact of the station.
5.
Thermal Plume Studies Surveillance Intervals Section 4.1,1.2 IMPC is required to conduct thermal plume studies during at least four specified periods annually.
The four periods are one month in duration and begin on February 15, April 15, June 15, and November 1.
During each of these periods a minimum of 5 days of data collection, with at least two thermal plume resolutions per day, are required.
IMPC has requested that a 15-day extension be allowed when unit outages pr'event completion of the data'=collection during the specified 1-month period.
Evaluation:
In view of the following facts, we find this change to be acceptable.
(1)
To collect data, weather conditions must not be extreme and the total plant power output must be greater than 75 percent.
Occasionally'oth of these conditions do not exist during a
sampling period.
(2)
The intent here is to get data that represents seasonal averages.
The extra 15-day period will not invalidate the results.
6.
Monitorin and Re ortin Re uirements for Wells Section 4.1.1.5 IMPC is now required to annually report well depths and groundwater strata of wells that'are samples.
IMPC has proposed to delete this reporting on the basis, that this information does not change, and has proposed this information will be submitted on a one-time basis.
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II ~ In addition, a requirement to monitor the groundwater level in each well has been proposed.
Evaluation:
We agree with the above basis for this change
- and, therefore, find it acceptable.
We are of the opinion that subsurface rock and soil layers are not likely to change such that water strata would change.
We find IMPC's proposal to provide new data on new wells or modifications to existing ones acceptable.
- Also, we conclude that groundwater level measurement is necessary information related to potential radioactive spills and should be included in the ETS to assure periodic updating.
7.
Number of Wells to be Monitored (Section 4.1.1.5)
IMPC proposes to eliminate the groundwater sampling from four wells:
2, 3, 6 and 7
on the basis that samples from wells la, 8, ll and 12 will be sufficient for determining'ossible groundwater contamination.
4 Evaluation:
Monitoring wells la, 8, ll and 12 are located South,
- East, North and West, respectively, of the process sanitary waste ponds.
These ponds are the only source of possible chemical contamination to the groundwater.
We examined'he locations, depths and distances of these wells from this potential source and conclude that the proposed remaining four monitoring stations will be adequate to detect significant contamination.
8.
Fre uenc of Groundwater Flow Tests (Section 4.1.1.5)
The present specification requires that groundwater flow tests be made each year.
The proposed specification requires them to be done once every 2 years instead.
Evaluation:
The purpose of these flow (or propagation) tests is to ensure that the interval between well-water sampling tests
{26 weeks) is short enough to detect potential contaminants from the onsi te absorption field at an early stage of propagation from the" point of introduction.
The groundwater velocities are low and have been exhibiting a decreasing trend.
We have considered the low propagation rate that would be associated.
with the low measured values and conclude that future measurements of flow rate at two year intervals will, essentially accomplish the desired purpose of assuring that the well water is sampled at an appropriate frequency.
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Deletion of Terrestrial Biota. Honitorin Section 4.1.2.2 IMPC has requested deletion of the requirement for monitoring terrestrial biota on the basis that the survey has been carried out.
Evaluation:
We have reviewed the annual reports for 1975 and 1976 and conclude that the applicant has met the objectives of ETS 4.1.2.2.
No significant adverse changes were found in the terrestrial flora and fauna and the data indicate that none are likely to occur.
We, therefore, conclude that the requirement has been satisfied and that deletion of ETS 4.1.2.2 is acceptable.
10.
Radioactive Effluent Release Re orts Section 5.4.1.B The radioactive effluent release report requirements are described in detail in this section.
IHPC proposes to delete this description and to replace it with reference to NRC Regulatory Guide 1.21.
- Also, IMPC has proposed an editorial change to delete the monthly fish reporting requirement from this section as it already appears in Section 4.1.2.1.2.
Evaluation:
This change is acceptable because Regulatory Guide 1.21 represents the most up-to-date reporting requirements established by the staff.
We also concur with the licensee's basis for deleting the fish reporting requirement from this section and find it acceptable.
11.
Re ortin Re uirements Section 5.4.2.1 and Related Sections IHPC proposes to revise this section (5.4.2.1) to conform to NRC Draft Regulatory Guide 4.8.
The proposed wording distinguishes between two types of nonroutine reports, a prompt and a 30-day report and proposed the new wording on the basis that the existing wording does not distinguish between the two clearly enough.
To-make this consistent with other parts of the ETS, wording would be added in the different sections of the ETS to" refer to the appropriate type of report.
These sections are Section 2.1.3.2,
- p. 2.1-4; Section 2.2.1.2,
- p. 2.2-1; Section 2.2.2.2.,
- p. 2.2-3; Section 4.1.1.6,
- p. 4.1-13; Section 4.1.2.1.2,
- p. 4.1-31; and Section 4. 1.2.3.7,
- p. 4. 1-37.
Evaluation:
We find that these proposed changes are consistent with the intended purpose of these specifications,
'provide only clarification impact changes and, therefore, are acceptable.
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12.
Deletion of Satisfied E ui ment and Re ort Re uirement IMPC has informed NRC of methodology for making certain measurements, installed certain equipment and has submitted certain reports as required by various sections of the ETS.
Following is a list of, these satisfied requirements:
Re ui rement Deadline for installing thermal discharge alarm instrumentation Method for calculating ambient temperature Deadline for installing equipment for monitoring radioactivity in steam generator blowdown Dead'line for installing equipment for monitoring gaseous release of radioactivity Deadline for submitting methodology for thermal surveys Section 2.1.1.2 2.1.3.2 2.4.2.g 2.4.4. b 4.1.1.2
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2.1-2 2.1-4 2.4-3 2.4-8 4.1-3 Report models that are used to predict thermal plumes Report methodology for measuring wind and lake currents 4.1.1.2 4.1.1.2 4.1-3 4.1-4 Report methodology used in drogue surveys Describe hydraulic models and studies Submit alternative intake designs 4.1.1.2 4.1.1.4 4.1.2.1.1.5 4.1-4 4.1-8 4.1-25 Deadline for installing turbine gland seal condenser Table 2.4-4 2.4-18 Evaluation:
Since it is already a matter of record that these requirements have been satisfied, we conclude that it serves no purpose to retain them in the ETS.
Therefore, we find their removal to be acceptable.
No environmental evaluation is necessary for this action.
With the above requirement to Section 2.1.3.2 satisfied, we find that reference to this section in definition 1.3 on page 1.1-1 is no longer appropriate and should be deleted.
13.
Editorial Chan es Section 2.1.1.2.4 2.4.3d and 4.1.2.1.1.5 IMPC has proposed minor editorial changes to Section 2.1.1.2.4 and Section 2.4.3d.
As these changes simply correct grammatical
- errors, we find these changes to be acceptable, and no environmental evaluation is necessary.
On pages 4.1-27 through 4.1-29 of Section 4.1.2.1.1.5, IMPC has proposed the replacement of labels I, J and M with the labels g, R and W, respectively, which designate fish sampling stations.
The reason is to eliminate a discrepancy that exists between the identification of these three sampling stations in the field sampling program and in the Environmental Technical Specifications.
Recognizing the necessity for consistency, we concur with this editorial change.
No environmental evaluation is necessary.
DISCUSSION AND EVALUATION - SAFETY-RELATED CHANGES 14.
Selection of Another Radiation Monitor to Isolate the Waste Gas Stora e Tanks Table 2.4-4 IMPC proposes to substitute the auxiliary building ventilation system radiation monitor for the waste gas storage tank effluent radiation monitor to automatically isolate the waste gas storage tanks.
This automatic isolation is to terminate releases of radioactivity from these tanks should they exceed Technical Specification limits.
IMPC has experienced difficulties operating the waste gas storage tanks with the waste gas storage'tank effluent radiation monitor.
The monitor is located in a high background radiation area which has caused frequent spurious isolation of the tanks when the radio-activity of the gas being released is actually below the limits in the Technical Specifications.
IMPC has proposed to rectify this problem through the use of the auxiliary building ventilation system monitor to automatically isolate these tanks.
This monitor is not in a high background radiation area and thus will not be subject to these spurious isolation actions.
- 10 We have reviewed and evaluated the data given in the D.
C.
Cook 1
and 2 FSAR on the auxiliary building ventilation system monitor.
Effluents leaving the waste gas storage tank must travel through the auxiliary building ventilation system.
This means that the monitor located in the auxiliary building ventilation system will register the radioactivity of the gas discharged from the waste gas storage tanks.
We conclude that the auxiliary bulding ventilation system monitor is capable of being calibrated and set to automatically terminate releases from the waste gas storage tanks should they exceed Technical Specification limits.
In addition, this change is consistent with the requirements set forth in Standard Review Plan 11.5, which governs the monitoring requirements for radioactive effluents.
Therefore, we conclude that this proposed change to Table 2.4-4 is acceptable.
15.
Milk Back round Stations (Table 4.2-1)
IMPC proposes to add a footnote to Technical Specifications Table 4.2-1 to allow fewer than thr ee control stations within 20 miles of the plant for collecting milk samples when fewer than three such stations are available.
These stations provide milk samples for establishing background radioactivity in milk for comparison with the indicator samples.
The current NRC guidance on radiological environmental monitoring is given in a Radiological Assessment Branch "Position on Radiological Environmental Monitoring".
This technical position is an update draft of Regulatory Guide 4;8 and states the staff guidance on radiological environmental monitoring programs necessary to* implement the requirements of Appendix I to 10 CFR Part 50.
This technical position recommends at least one station to collect control milk samples if available.
Therefore, we conclude that the proposed change to Table 4.2-1 is acceptable provided it calls for the use of at least one control station within 50 miles of the plant to collect milk samples,.if available.
IMPC has agreed to addition of this provision.
ENVIRONMENTAL CONCLUSION AND BASIS FOR NEGATIVE OECLARATION On the basis of the foregoing evaluations, it is concluded that there would be no significant environmental impact attributable to the proposed action.
Having made this conclusion, the Commission has further concluded that no environmental impact statement for the proposed action need be prepared and that a negative declaration'o this effect is appropriate.
CONCLUSION We have also concluded, based on 'the considerations discussed
- above, that:
(1) because the amendments do not involve a significant, increase in the probability or consequences of accidents previously considered and do not involve a significant hazards consideration, (2) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed
- manner, and (3) such activities will be conducted in compliance with the Commission's regulations and the issuance of these amendments will not be inimical to the common defense and security or to the health and safety of the public.
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