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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
BEFORE THE ATOMIC SAFETY AND LICENSING BOARD
In the Matter of
CAROLINA POWER AND LIGHT COMPANY AND ) Docket Nos. 50-400-0L NORTH CAROLINA EASTERN MUNICIPAL ) 50-401-0L POWER AGENCY ) ) (Shearon Harris Nuclear Power Plant, ) Units 1 and 2) )
AFFIDAVIT OF CHARLES W. BILLUPS IN SUPPORT OF NRC STAFF M0TinN FOR SUMMARY DISPOSITION OF EDDLEMAN CONTENTION 8F(1)
I, Charles W. Billups, being first duly sworn do depose and state:
1. I, Charles W. Billups, am an employee of the U.S. Nuclear Regulatory Commission. My present position is as an Aquatic Scientist in the Environmental and Hydrologic Engineering Branch, within the Office of Nuclear Reactor Regulation. A copy of my professional qualifications is attached. 2. I give this affidavit in support of Summary Disposition of Eddleman Contention 8F(1) in this proceeding, and I certify that I have | personal knowledge of the matters set forth herein and that the state- ments are true and correct to the best of my knowledge, information and belief.
3. Eddleman Contention 8F(1) in this proceeding states:
< " Health effects of the coal particulates 1,154 MT per year, are not analyzed nor given sufficient | | weight." I 8312300270 831202 PDR ADOCK 05000400 0 PDR
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4. The purpose of this affidavit is to demonstrate (1) that the Table S-3 level of coal particulates released in the uranium fuel cycle is negligible with regard to the operation of the Harris Nuclear Plant, (2) that f.ie impacts including health effects of emitted particulates from coal combustion at the electrical generating stations or grids involved in the uranium fuel cycle have been thoroughly considered in the NEPA reviews for-the individual gaseous diffusion plants, the major source (96%) of emitted coal particulates in the uranium fuel cycle, and (3) that there is reasonable assurance that the 10 C.F.R. Part 51 Table S-3 level of emitted particulates provides a very conservative (over) estimate of such emissions based on current operating characteristics of the generating plants and electri- cal grids supporting the gaseous diffusion plants and based on current standards of performance and limitations on particulate emissions estab- lished by the Clean Air Act.
Table S-3 Level of Particulates Negligible with Regard to Harris Environmental Review
5. Health effects of coal particulates were not analyzed specifically in the Harris DES (NUREG-0972, April 1983) and FES (NUREG-0972, October 1983). Those impacts of the LWR-supporting fuel cycle that reasonably appeared to have significance for individual reactor licensing sufficient to warrant attention for NEPA purposes were specifically addressed in the DES and FES (Section 5.10 and Appendix C). The judgement by the staff that health effects of coal particulates did not need to be addressed in the Harris environmental review was based on technical information sup- porting the Table S-3 rulemaking. 6. The documents supporting the Table S-3 rulemaking provide a basis for the finding that the particulates emitted from an equivalent
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45 MWe fossil-fueled power plant are negligible. Of particular note is the document entitled, " Environmental Survey of the Uranium Fuel Cycle" (AEC,1974, WASH-1248) which includes the consideration of impacts from
power generation in support of the fuel cycle. -
7. The electrical energy required per annual fuel requirement
; of the model LWR (Light Water Reactor) is given in Table S-3 to be 323 x 103 MW-hr. In comparison to the model 1000 MWe LWR which produces 7 x 106 MW-hr in annual operation at a load factor of 80% (ibid., WASH-1248, p. 5-17), the equivalent generating plant supporting the uranium fuel . cycle is about 46 MWe. It should be noted that this value is slightly higher but not significantly different from the 45 MWe given in Table S-3. The Table S-3 value of 45 MWe is based on energy requirements of 317 x 10 3MW-br which were increased subsequent to initial publication in consideration of the "back-end" of the fuel cycle. Since the equivalent power plant indicated in Table S-3 is 45 MWe, I have used that plant size in my analysis. Also, the rewits of my analysis and conclusions would not be altered if the analysis were based on the net output of the Harris plant.
8. The major user of electricity in the fuel cycle is the enrichment process, carried out at the three U.S. government-owned gaseous diffusion plants. As concluded in WASH-1248 "only the generation of electrical energy for the isotope enrichment step was judged to cause significant environmental effects." This step of the fuel cycle is estimated to require 310 x 103 MW-hr of the total 323 x 103 MW-hr of electricity for the annual fuel requirement of the model LWR. This requirement represents over 96" of the total electrical energy required by the fuel cycle. At the time of the development of
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f technical'information which was subsequently presented in WASH-1248 (as ' Table S-3 data), most of the electricity generated in the United States ' was being produced (as now) in power plants that burn fossil fuels. The conservative assumption (i.e., over-estimating the potential environmental effects) was made in WASH-1248 that coal-fired power plants supplied all .of the required. energy; thus _ the energy requirements and associated air -pollutant emissions were assumed to correspond to a typical, existing coal-fired power plant.(i.e., existing in 1972 when the technical review - of.the fuel cycle impacts was first conducted). The Table S-3 estimates -of effluents from the burning of fossil fuel are based on the equivalent 45 MWe coal-fired plant with characteristics of a typical 1000 MWe coal-fired plant given in Table D-6 of WASH-1248. The equivalent plant zis not to be misinterpreted as an actual 45 MWe plant at a specific loca- tion. Rather it is the energy drawn from the power grids of the-large utility complexes supporting the gaseous diffusion plants. Thus,'no single power supply-source is identifiable as producing the total gaseous effluent level set forth in Table S-3. The term gaseous effluent is used in this affidavit, since the particulate emissions are i listed in Table S-3 under the heading " gaseous." Also, to the extent that power in the grids is produced by nuclear or other fuel types, the total
I quantity of the fossil fuel combustion emissions would be reduced pro- | | portionally. Power for the three gaseous diffusion plants in the U.S. is drawn primarily from the grids of three utilities systems: Tennessee Valley Authority, Ohio Valley Electric Corporation, and Electric Energy Inc. Characteristics of these systems supporting the gaseous diffusion plants are |
, described below. The equivalent 45 MWe of power when distributed over i these systems results in insignificant impacts at any particular loca- . tion within 'the applicable grid systems, as addressed below.
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9. - The estimated level of particulates in Table S-3 gaseous efflu- ents-is. based on a particulate emission rate of 22 lb/ metric ton of coal (WASH-1248, Table D-6) or 3.6 metric tons /hr, WASH-1248, Table D-7) for a typical (1972 vintage) 1000 MWe coal-fired plant. For later comparison with current new stationary sources performance standards for electric utility . steam generating units under the Clean Air Act, 42 USC-7401 et sec, the equivalent particulate emission (in units of lbs per 100 Btu) for the Table S-3 " equivalent plant" is .768 lb/106 Btu. This value is obtained by dividing 22 lb/MT by 28.6 x 106 Btu /MT (or 13,000 Btu /lb as given in Table D-6 of
WASH-1248).
NEPA Reviews of Impacts for the Individual Gaseous Diffusion Plants
10. Environmental reviews pursuant to NEPA have been performed for each of the three gaseous diffusion plants. Included in these reviews were considerations of impacts of the electrical generating plants and/or systems providing power to the gaseous diffusion plants. ERDA 1977 " Ports- mouth Gaseous Diffusion Plant Site Piketon, Ohio;" " Environmental Assess- ment of the Oak Ridge Gaseous Diffusion Plant Site;" " Final Environmental Impact Assessment of the Paducah Gaseous Diffusion Plant Site." In each . of the NEPA environmental review documents, coal particulates and other air pollutant emissions are specifically addressed. Therefore, based on my review of these documents. I believe them to be directly applicable to the Staff consideration of summary disposition of contention 8F(1).
11. Pertinent information from the three environmental reviews are summarized below. The health effects associated with air pollutant
' emissions from two " dedicated" coal-fired plants have been evaluated, in detail, in the Final Environmental Impact Statement for the Portsmouth Gasaous Diffusion Plant site. The Portsmouth plant represents a worst
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case, in terms of particulate emissions from " dedicated plants", for our present consideration. DOE's evaluation of health effects for the coal- fired plant emissions is provided as an attachment to this affidavit '(ExhibitA). 12. Enriched uranium is produced at the three federally owned gaseous diffusion plants (GDP) located near Oak Ridge, Tennessee, Paducah, Kentucky and Piketon, Ohio. Upon completion of planned expansion programs for the three plants, the nation's enrichment capacity will be approximately 27.7 million separative work units (SWU) per year (ERDA,1977), or about 250 times the average annual fuel requirements of the Harris plant. 13. Power supply to the Oak Ridge GDP is from the TVA system. The required capacity is projected to be 2800 MWe (assuming 2080 MWe for maximum operation with 35% reserve) in 1984 when all upgrade programs are expected to be completed. This power requirement represents about 6.6% of the TVA system capacity of 42,618 MWe (projected for 1984). The mix of TVA generating capacity would indicate contributions of 1170 MWe of coal-fired,1067 MWe of nuclear, 298 MWe of hydroelectric,165 MWe of combustion turbine and 100 MWe of pumped storage to make up the required
2800 MWe for the GDP.
14. Power for the Paducah GDP is supplied by two utilities, TVA and Electric Energy, Inc. which operates the Joppa Steam Electric Plant, near Joppa, Illinois. The Joppa Plant consists of 6 units each rated at about 181 MWe for a total of 1050 MWe. Of this total capacity 735 MWe is " dedicated" to the Paducah GDP. The required power for the GDP is projected to be 2600 MWe in 19M and 3000 MWe in 1985. The balance of power, over the Joppa plant portion, would be supplied through the TVA
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system. DOE concluded in the Oak Ridge and Paducah environmental assessments that air quality standards would be met at the fossil-fired
generating facilities (DOE, 1979,. p. 8-1 and DOE, 1982, p. 4-20). 15. The Portsmouth GDP is supplied electrical power by the Ohio Valley Electric Corporation (0VEC) and the Indiana-Kentucky Electric Corporation. The bulk of the energy required is supplied to the system by two coal-fired generating stations, the Kyger Creek plant near Gallipolis, Ohio and the Clifty Creek plant near Madison, Indiana. The two plants are considered " dedicated" to the Portsmouth GDP because they were built to supply the future requirements of the GDP but are backed-up by the grids of OVEC, formed in 1952 and made up of 15 investor-owned electric utility companies. In 1977, the two plants had a combined generating capacity of 2,354 megawatts. Lines from the plants are inter- connected with the major electric power transmission network of the utilities serving the area assuring that the GDP has a continuous and uninterrupted supply of energy. Power is supplied to the network when the GDP is operating at reduced levels. (ERDA, 1977, Section 2.2.4). 16. The total power requirement of the Portsmouth GDP was projected to be 2260 MWe when planned expansion was completed in January 1980. The design capacities of the Clifty Creek and Kyger Creek plants of 1284 and 1070 megawatts, respectively would appear a sufficient power supply;
however, additional power estimated to range from 270 to 350 megawatts is , to be obtained from all of the OVEC utilities companies. No one of the 15 sponsoring companies will be obligated to furnish more than 53.2 MWe of the 350 MWe requirement. Table 1 (Exhibit B) identifies the OVEC sponsoring companies and shows their respective percent participation in supplying
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the additional 350 megawatts of power from nondedicated sources. The Table demonstrates that the power is cupplied from grids in Tennessee, Virginia, West Virginia, Ohio, Indiana, Michigan, Kentucky, Pennsylvania and Maryland. 17. The Clifty Creek Power Plant consists of six coal-fired units rated at 214 MWe each. The boilers are pulverized-coal front firing and each consumes about 89 tons of coal per hour at full load. The heat value of the coal used is 10,500 to 11,000 Btu /lb. At the time the Clifty Creek Plant was constructed, the design included the most advanced pollution control devices (expected to remove 96.1% of the fly ash) plus the world's tallest stacks at 682 feet. Flue gas is treated in combina- tion mechanical and electrostatic precipitators.
18. In 1973, an agreement was reached with the Indiana Air Pollution Control Board to bring the Clifty Creek Plant into compliance with the state particulate emissions standards. Unit 6 was to be uprated to a particulate removal efficiency of 99.6% minimum. New cold-gas precipitators were to be installed on the other five units bringing the particulate removal efficiency to 98.0% minimum, and over
, 99.6% with the coal being burned in 1977. Additionally, the three l existing stacks are being replaced with two 984 ft-high stacks. 19. The Kyger Creek Power Plant consists of five coal-fired units ! similar to those at Clif ty C; eek. Flue gas is treated in combination mechanical and electrostatic precipitators and discharged via three 538 ft-high stacks. The first installed precipitators had a 96.1% rated fly-ash removal efficiency and plans were underway in 1977 to install new precipitators, designed for a minimum particulate removal efficiency
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of'98.0%. 1Like at the Clifty Creek plant, state-of-the art pollution control devices were installed at the time of construction, in the period
1952-56.
-20. The potential environmental impacts of the power generation
~~ facilities are assessed in Section'4.2 of the EIS (ERDA, 1977). The computed maximum air concentrations of fly ash particles in the Clifty Creek plant vicinity are shown in Table 2 (Exhibit C). Even at the 70% removal efficiency assumed in the calculation procedure, the air concen- tration did not exceed the Indiana. primary standard of 75 micrograms /m 3
* on an annual basis. 'The new precipitators are expected to decrease the ' emitted particulates by a minimum factor of 15 times assuming that the old precipitators are operating at about 70% removal efficiency and the new ones. operate at 98% minimum removal efficiency. 21. With regard to the human health impacts, ERDA reviewed the '' literature on qualitative and quantitative ertimates of health effects due to exposure to coal combustion products._ The review conducted by ' ERDA for the Clifty Creek and Kyger Creek Plants is provided in Exhibit-A. Major conclusions reached in the environmental impact statement were that: "There will be no adverse health effects from the continued operation of the power plants under normal meteorological conditions. Calculations show, however, that occasionally there will be episodes, because of unfavorable meteorological conditions. during which S0 concentrations may reach levels that:if continued9 for more than 1 or 2 hr may have detrimental health effects on sensitive members of the local populations. AtClijtyCreekPowerPlant the levels may reach 1100 g/m . AttheKygerCrgek Power Plant the-levels of S0, may reach 3300 g/m . Kyger Creek is higher -largely because of the nearby I General James M. Gavin Power Plant." (ERDA,1977, p. 1-6)
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"The power plants do not conflict with local, state, or Federal plans, policies, or controls. Compliance with Federal air and water control requirements are being met or, where deficient, are being corrected." (Ibid., p. 1-8) "If the Portsmouth Gaseous Diffusion Plant were to shut down, the Staff concludes, the Clifty Creek and Kyger Creek Power Plants would continue to operate at essentially full capacity." (Ibid., p. 1-8) "A reasonable conclusion . . . would be that health effects have been found when annual 1evels of 3 particulates or S09 exceed 100 g/m . This concen- trationisabogttentimestheannualconcentration of 7 to 9 g/m in the Clifty Creek Power Plant area and about four jimes the maximum annual concentra- tion of 24 g/m that occurs north of the Kyger Creek Power Plant." (Ibid., p. 4-147). "All of the evidence the Staff has been able to collect and analyze . . . indicates that although pollution in the area of these plants may at times be annoying, no measurable increase in morbidity and mortality would result under most conditions." (Ibid., p. 4-150) "Since the 350 MWe of power [needed for expansion program] will be generated at widely dispersed locations, concentration of S0, No , and particulateswouldalsobedispersEd. The Ohio Valley is already a region of relatively high levels ( of S0,and other pollutants. The 1.3% increase in ' pollutants will add to this condition. If the worst concentration in the area of the 24-hourKyger Creek average Power P S0,lant is assgmed to be the normal ambientconcentration(48 g/m ) throughout the Ohio Valley, and if all electricity production is within theOhioValley,theambientcgncentrationwould ! increase from 48 to 48.62 g/m ." (Ibid., [ p.4-199).
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Conservatism of Table S-3 Value Based on Current Grid Generating Characteristics and Clean Air Act Considerations 22. -The above conclusions reached by ERDA are based on operation of the two coal-fired plants at their combined design capacity of 2354 MWe. At the time the impact statement was prepared (i.e. 1977), the particulates (as fly ash) being emitted from the two plants were estimated to be about 129,700 metric tons per year (based on values in Tables 4.3-2 and 4.3-4 of the EIS). This total level was expected to be reduced by installation of equipment to provide improved removal efficiencies from 70% to 98%, minimum. At this factor of 15 reduction, the fly ash particulates would be about 8650 metric tons per year. In terms of the 45 MWe equivalent plant of Table S-3, the equivalent emissions are found, using the ratio of 45 MWe to 2354 MWe or about 2%, to be approximately 170 metric tons per year. Thus, the " equivalent plant" operating at an efficiency of 98%, minimally required for the actual dedicated plants, would emit particulates at about an order of magnitude lower level than established in Table S-3. 23. As noted above (see paragraphs 13 and 14), TVA supplies 100% of the power for the Oak Ridge GDP and a major portion of the Paducah GDP.
! l In 1985 the power provided by the TVA and for Paducah is projected to be
[ 76% of the total power requirement. With the current mix of generating capacity only about 51% of TVA's power would be supplied by coal-fired plants. Thus, the equivalent coal-fired plant would be only 23 MWe in the TVA system, with the balance of power generated primarily by nuclear and hydroelectric sources. The coal particulates level would be reduced by 51%, accordingly.
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24. The current New Stationary Source Performance Standard is 0.03 -lb/106 Btu (44 Fed. Reg. 33584, June 11, 1979). To meet this present limitation, the actual level of emitted total suspended particulates is estimated to be about 15 metric tons per year, which is nearly two orders of magnitude below the Table S-3 value. The Table S-3 value of 1154 metric tons / year of particulates therefore provides a very conservative over estimate of the level of-particulate emissions, and thus of the potential impacts on air quality of a coal-fired plant operated under the current Clean Air Act requirements. 25. Periodic review of the national ambient air quality standards (NAAQS) is conducted by EPA as required by section 109 of the 1977 Clean Air Act Amendments, 42 USC-7401 et sec. EPA's recent review of the standerd for particulate matter contained in a report titled, " Review of the National Ambient Air Quality Standards for Particulate Matter: Assessment of Scientific and Technical Information," EPA-450/5-82-001 (January 1982), provides the definitive evaluation and interpretation of current infor- mation on health effects of particulates for purposes of revising the standard. As noted by EPA, the primary standards must be based on health effects criteria and provide an adequate margin of safety to ensure pro- tection of public health and also that the margins of safety are to be provided such that the standards af. ford a reasonable degree of protection agcinst hazards which research has not yet identified (Ibid, pp. 1 & 2). As EPA states: "Further guidance provided in the legislative history of the Act indicates that the standards should be set at 'the maximum permissible ambient air level...which will protect the health of any (sensitive) group of the population.'" (EPA 1982, p. 2).
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26. As currently operated, the coal-fired power plant and/or grid systems supplying' energy to-the gaseous diffusion plants do not violate NAAQS. ~ Any health effects attributable to the coal particulates from the plants would therefore be negligible under the definition of the primary standard.
Summary 27. The following is a summary of the important aspects of the coal particulates issue:
(a) The Table S-3 level of particulates is negligible with respect to the operation of the Harris plant; therefore, sufficient weight has been given to the issue in the Draft and Final Environmental State- ments. The basis for this finding is the technical documents supporting the Table S-3 rulemaking (e.g., WASH-1248).
.. ( b) The Table S-3 leveli of emitted particulates is dispersed over large system grids and are not to be associated with the potential emissions nor impacts at a specific plant / site within the grid.
(c) NEPA assessments have been conducted for the individual fuel cycle i facilities including the supportive fossil-fueled power plants or i grids described in WASH-1248 and Table S-3 and, where analyzed in
; ! detail, health effects have been found acceptable.
(d) In the case of the Portsmouth GDP which has two " dedicated" coal-fired plants the impacts (including health effects) have been
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evaluated on the basis of the total power requirements of 2354 MWe and found to meet the air quality standards for particulates. Also, an additional 350 MWe was considered in the assessment and found to be acceptable because of the dispersed generation of power over the grid. Similarly, the 45 MWe equivalent power plant associated with the uranium fuel cycle for the model LWR is a negligible pollutant
source.
(e) EPA establishes the primary standard to protect human health and periodically reviews the basis for setting or revising the standard. The coal fired plants associated with the uranium fuel cycle elec- trical requirements will have to meet the requirement established by EPA under the Clean Air Act. If the power plants meet the primary standard, then human 11 4 is being protected as defined by the Act.
Conclusion
28. For the reasons set forth above, I conclude that the Table S-3 level of emitted particulates is a' negligible amount and its impact would
not alter the cost-benefit balance contained in the Staff's FES. Also, other NEPA reviews have been conducted for individual fuel cycle facilities which support this conclusion.
a. * Charles W. Billups y Subscribed and sworn to before me this 2nd of December, 1983 WB. SWT ' Notary Public My Commission expires: kah
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References
AEC 1974. " Environmental Survey of the Uranium Fuel Cycle" WASH-1248, Directorate of Licensing, Washington, D.C. DOE, 1979, " Environmental Assessment of the Oak Ridge Gaseous Diffusion Plant Site" DOE /EA-0106, December 1979. , DOE, 1982, " Final Environmental Impact Assessment of the Paducah Gaseous Diffusion Plant Site," D0E/EA-0155, U.S. DOE Technical Information Center, Oak Ridge, Tenn. EPA,1982, " Review of the National Ambient Air Quality Standards for Particulate Matter: Assessment of Scientific and Technical Information." EPA-450/5-82-001, Office of Air Quality Planning and Standards, Research Triangle Park, N.C. ERDA, 1977, " Final Environmental Impact Statement: Portsmouth Gaseous Diffusion Plant Site," ERDA-1555, 2 vols.
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' . :. - . PROFESSIONAL QUALIFICATIONS ~ ~ CHARLES W. BILLUPS, Ph.D.
!' .I am an' Aquatic Scientis't in'the Environmental and Hydrologic Engineering. Branch, Office of Nuclear Reactor Regulation, U.S. Nuclear Regulatory Commission, ' Washington, D.C. 20555. After receiving the Bachelor of Science Degree.in Physics at Marshall University (1962), I served as an Aerospace Engineer with the NASA's Marshall -Space Flight Center (1963-1969) performing in the areas of space vehicle
, dynamics and control system theory. While with NASA, I continued my professional educational progran at the University of Alabama as a part-time student in the Master's program, concentrating in the biological sciences. As a student of Dr. Lorraine Morin Rosing, a marine parasitologist,-I was introduced to :the estuarine habitats of South Alabama. In pursuit of new career goals, I lef t NASA for full-time graduate studies at Louisiana State University, where in 1974, I received the Doctor of Philosophy in Marine Science. My
, - doctoral dissertation, directed by Professor Bert Wilkins, Jr. , involved the modeling.of. shrimp population dynamics for brown shrimp (Penaeus aztecus) in the estuarine systems of Barataria and Camanada Bays, Louisiana. This work was supported .by the University's Office .of Sea Grant, Program, NOAA. , Results have ' been presented in the University's Special Sea Grant Issue of the Coastal Studies Bulletin and at the 70th National Meeting of the American Institute of Chemical Engineers. [.. I accepted employment with the U.S. Atomic Energy Commission's Directorate - _of-Licensing in 1972 and have served in the same professional capacity through the creation of the U.S. Nuclear Regulatory Commission up to the present. My duties with the Commission include evaluating non-radiological environmental impacts of proposed and operating nuclear power plants on aquatic resources. I have provided assistance to Environmental Project F Branches by preparing text to environmental impact statements, by reviewing preliminary draft statements prepared by the National Laboratories (in-house reviews), by responding to agency comments on Statements, by preparing
. Environmental Technical Specifications (ETS) and by responding to licensee ! requests to revise ETS or other license conditions.
, I have participated in the review of over 30 proposed or operating nuclear . power plants. In addition to the Indian Point case, I have been involved in . the environmental reviews for Brunswick, Calvert Cliffs, Douglas Point, Summit, . Surry, and the Offshore Power System's fabrication plant, all of which are sited in~ east-coast estuaries. I have also provided support in the review
, of the Floating Nuclear Plant concept and have presented a review (unpublished) ' of the-techniques which have been used by the Commission Staff in projecting | the effects of interactions of nuclear power plants with estuarine ecosystems. : I have served on the Interagency Review Panel for Cape Fear Estuary Studies, ' established in 1976 for peer review of Carolina Power & Light Company's monitoring programs and have been an advisory member of EPA's ' Hudson River Interagency Technical Committee. Presently, I am NRC's delegate to the Interagency Task Force on Ocean Pollution Research, Development and Monitoring which serves the interagency committee of the same title in coordinating Federal activities under the National Ocean Pollution Planning Act of 1978.
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. . E%HIBIT k '
sec,hrws 4.g.110 (pp y-svi4w, ERDAuc. , 4-Irif 4. s. n. to (y, s-su4q.m)
Final Environmental Impact Statement
PORTSMOUTH GASEOUS | g'. DIFFUSION PLANT , | SITE - Piketon, Ohio
ResponsMe Official: ,. Energy Research & Development Administration Volume l Of 2
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' . 4-141 E h *' , I * ! 4.2.1.10 . Impacts on human health t
.. , ' i The operation of the Clifty Creek and Kyger Creek Power Plants has, in I * thalpast,likelycontributedtosomeincreasedmorbidityandnortality ' in.their respective localities. Health effects on susceptible individuals can be expected to result from continued operation as well. The precise ' determination of the total number of individuals whose health has been ; or will be 'affected is impossible to ascertain without long-term epi-
demiological studies. However, the staff has reviewed the literature , i ' regarding health effects, and hopefully some extrapolations which will allow the. evaluation of potential health hazards that result from ~ operation of these two plants can be made. . The following discussion is based on ~ several recent publications on health effects of coal utili- ; sation.l~3 ' I, ' ,. Most elements in coal,' exclusive of carbon, come in the form of alumino- i silicates, inorganic sulfides, and organic compounds, and are decomposed to produce SO2 and a number of oxides and other chemical species of r , varying volatility. . The aluminosilicates, on the other hand, have very j +- v high vaporization temperatures, and tend, therefore, to survive more or ' ' (- .V less . intact as fly ash ,.nd slag." :- t * * -Physiological and pathological responses of the population exposed to the airborne insults from coal will reflect the individual's ability to ( ~ e ieIspond and the duration .or hisotry of exposure. There will always be
' individuals who have severe short-term reactions to any increased level , of a contaminant. Subgroups such as young children, the aged and the ; * % ,inf % 'are more sensitive to the impact of increased concentrations of ; ' respiratory irritants and other poisons. Disease and death rarely result * , ' t' rom pollution alone; they are the outcome of many factors, both individ- 'ual and environmental acting together. . | % I .g The short-term adverse effects from coal combustion will be manifest in .these subgroups as an. increased incidence of respiratory disease, asthma, I. aggravntion of preexisting chronic cardiopulmonary disease, and premature ! deatha ' Chronic exposure to coal combustion ef fluents may result in an i * increased incidence of respiratory diseases and cancer in the total .POPulat'on.i " All chemical agents cause some form of biological response. The response | ; ; ' * . _is usually related to the quantity absorbed and the period of time over , - | which st'ch absorption occurs'. One belief is generally accepted: The !- slight deviations in physiological parameters that remain within homeo- ' | |- static limits, but which result from very low level exposures to envi- . ! | ronmental stressors, are not categorically deleterious. This reasoning l' ~ ~ " ' This section has been altered in response to the presiding board's .--statement identifying unresolved issues on the Draft Environmental Impact ; | Statement, Portsmouth G1ceouc Diffusion Plant Site, Piketon, Ohio, ERDA-1555-D. f
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* I . . | I 4-142. I underlies the threshold concept.- The threshold dose, or "zero effect" level, is that . quantity of a specified agent .that an organism is .able' to metabolize, detoxify, or. excrete without harmful biological consequences. In any. population, the threshold for response to airborne contaminants is not the same for all, individuals. Whereas the main concern of an '
_ analysis of population risk is apparently with the average individual, , :it is important to recognize the existence of high-risk groups in which many of the observed responses will occur.- The risk factors of age, preexisting illness, genetic sensitivity, occupation, and personal. - habits (such as' smoking) define the hypersusceptible individuals who are more sensitive |than most to changes.in ambient air quality. These individuals may exhibit severe responses to air contaminants which are .below the threshold level of the majority of 'the population.
,
The difficulties in accurately predicting population responses from g experimental data result from the complicated relation between ambient air _ pollution and related health effects. Estimation of the dose term * > ,from a single point source must consider source emission rate along with , atmospheric transport parameters that further specify the potential - delivered dose :(Sects. 4.2.1.3 and 4.2.2.3). i
+ 5
4.2.1.10.1 Health' effects associated with air pollution from coal use l
Stack emissions from coal-burning facilities. characteristically have . four major types of health impacts: physiological irritation, direct [ toxicity, carcinogenesis, and physical synergism.
As a defense mechanism, physiological irritation assists the body in 1 rejecting foreign materials. It is characteristically seen as a local , reaction. The challenge from the pollutant has the effect of causing an
inflammatory reaction. i
Direct toxicity results from the agent interfering with the metabolism , of the cell, by either inactivating key enzymes, being metabolized into useless products, or otherwise disrupting normal' cell function. In general, substances with toxic effects will also stimulate inflammation, but the respons'e is not always in proportion to the challenge. Inflam- mation usually occurs at the' site of ' contact, but toxic effects may show up anywhere in the bcdy;after absorption. The pollutant and/or its metabolic by-products may stimulate the develop- ment of tumors after some latent period, which can range from a few years to several decades. This may occur as the result of an acc'umulation of gene mutations ~or chromosome aberrations due to.the biochemical reactions between the genetic material of the cell and;the carcinogen.
-In the respiratory system, in particular, there is a further class of effects. Not'directly harmful-themselves, they are capable of potenti- ating the effects described above.- The mechanisms for clearing noxious
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4-143-
substances from the lungs may be. reduced in effectiveness, thereby increasing,the residence time of effluents in the lungs. This usually ! results either from a reduction in ciliary action in.the bronchial tree ! or'from a~ thickening of the protective layer of mucus which interferes j
, with the ciliary action that moves fureign particles out of the lungs. , % Inflan.mation of the pulmonary tissue and the general debility produced by toxic effects make both the upper and lower respiratory tracts more subject to infection. Thus, the incidence of influenza, pneumonia. colds..and other acute pulmonary diseases tends to be elevated in exposed populations.. Acute asthma attacks can be induced in susceptible persons by respired irritants, and the severity of an attack, whether pollutant-induced or not, can be markedly increased by the synergistic . relationships that have been found between the body's response to -histamines, which are released in the initial phase of an asthma attack, -and prior exposur,e to other irritants.
. Prolonged exposure to irritants and toxins has been shown to lead to irreversible lung tissue damage. Emphysema and chronic bronchitis have been shown to develop in a variety of experimental animals exposed to low levels of the. common pollutants.
4.2.1.10.2 Health effects associated with specific' pollutants Most epidemiological studies show good correlation between particulates and health effects. The correlation between SO2 and health effects is less good, and it has been difficult to show correlation between health effectsL and nitrogen oxides or oxidants. Nitrogen oxides and oxidants, 7 'however, have shown significant biological effects in laboratory studies. Although experiments. exposing animals to SO2 gas have not supported epidemiological findings, sulfate particulates, which are chemical - transformants of S02 in the atmosphere as a result of coal combustion, .have been shown in both animal and epidemiological studies to be a major ' factor in disease. Due to the common use of high-efficiency particulate removal equipment, the main exposure of populations to particulates from coal-fired power plants is due to secondary formation of sulfate partic- ulates from the S02 emission. Thus, particulate air pollution from -large coal-fired power plants is composed primarily of these active sulfate transformants in the ' form of respirable particles. The proportion .of sulfates in particulates in the power-plant plume may be as much as 98%.
Sulfur dioxide (502 ) was one of the earliest suspected toxic agents in air pollution episodes, and has, therefore, been studied extensively. [n-the pure state, it is a colorless gas with a slightly acrid odor. In high concentrations, it is largely absorbed in the upper respiratory tract-(URT) and never reaches the pulmonary region, but at low concen- trations, most of:what is inhaled reaches the terminal bronchioles and a lveo li . Thus, the effective dose received by the most sensitive parts
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of the respiratory system does not decrease linearly with decreasing accospheric concentrations. It has not been shown to produce serious i
direct effects in the pure state in humans in the concentrations that I ' would ordinarily3 be expected in areas of heavy coal utilization (i.e. , 780 to 4000 pg/m ), although levels above 650 pg/m3 ciated with advetse health effects .in epidemiological studiesareusualigasso- .In humans, initial exposure at levels that might be realistically en- ! countered produces a slight temporary vasoconstriction which lasts about | 10 to 20 min in a previously unexposed subject, with measurable reduction j in the elasticity of the lung lasting for somewhat longer periods of time. Subjects exposed over several days show slight changes in lung capacity and pulmonary resistance, levels of various enzymes, and blood chemistry. There appears to be a habituation effect, in that a person with prior exposure to low levels of S02 does not react as severely to a given higher dose as does one who has not. In the worst-case realistic , dose range, the irritant effect is mild and.tends to decrease with habituation. Long-term low-level doses result in the thickening of the ! protective mucus layer over the cilia, which inhibits their ability to } -move the debris; therefore, in the long run, there is an effect similar i to that seen following acute exposure. j j Sulfur dioxide has been found in some studies to interact with other
irritants to both enhance and ameliorate their effects. An experimental , subject habituated to S02 , for example, All not react as strongly to a subsequent dose of nitrogen dioxide as one w..hout such prior exposure. Indications of a synergism have been found in studies involving ozone j 3 (0 ) and histamine wherein prior exposure to S02 will result in more i severe reactions to those irritants. ' A significant portion of coal combustion products is in the form of particulates. Microscopic solid particles and liquid droplets are the - result of processes that take place during and af ter combustion. Al- though the size range given for atmospheric particulates extends from i about 0.005 to 500 pm, the particulates from coal combustion appear in a more limited size range. These products tend.to be found in the 0.01- ; to 10-9 range of equivalent aerodynamic diameters. Because this range neatly brackets the size defined for respirable particles, t.he coal ; combustion particulates pose a significant potential for adverse human ! health effects.6
|. ' . Virtually all the naturally occurring elements can be found as contami- -nants in coal. The emission of these constituents is dependent on their chemical form prior to combustion and on their volatility.7 Many of the elements and compounds which volatilize and adsorb on par- ticulates are known to have adverse effects en human health.8 When i adsorbed on such surfaces, SO 2 is, in many cases, transformed into S0 3 , ~ and sulfate ion far more readily than it is in the gaseous state and in { the presence of high humidity (as in the area of Clifty Creek and Kyger ; Creek power plants) cay fore acrosols of sulfuric acid or other acid sulfates,
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6 The toxic effect produced by respirable particles depends on the chemical ! species,that the contain. Small particles are generally more toxic .thanlargeones.{O The submicron fly-ash particle' presents a double t
< threat.to htman health. Nct only does this. particle reach the pulmonary . region of the lung and remain- there for extended periods of time, but it also has the capability of delivering relatively high concentrations of ! ,some of the effluents as the result of surface absorption. Because they can. adsorb SO2 and other irritant gases and vapors, respirable partic- ulates have the ability to magnify;their effects by holding high concen- trations of these irritants in close proximity to sensitive tissues for j protracted periods of time. The sulfate ion which is often associated with small particles and aerosols appears to be a far more potent irritant than any of the others discussed here. ~This is probably due in pa'rt to the fact that the ion forms a very strong and reactive acid and also to the fact that it is so strongly associated with particulates.5 Cations associated with the sulfates are important mediators of irritant potency.Il Pure sulfuric - acid (H 2S0g) and ferric ammonium sulfate (FENHg[S0g]2) ars the most potent forms. Other ions tend to be weaker in proportion to'their acidity;
Particulates act as carriers of many trace elements and hydrocarbons in the effluent stream. Nickel (in the form of nickel carbonyl), chromium -(especially in the form of chromic trioxide), beryllium, and arsenic have been implicated as carcionogens. In the organic particulates, many contain the known carcinogen, benzo [a]pyrer.e, and its relatives. Lead, tellurium,| mercury, arsenic selenium, cadmium, nickel, chromium, and vanadium are all known to be highly toxic,12 with many exhibiting a special propensity for cellular deposition and retention. These elements are' capable of interfering with and disrupting the function of the L central nervous system and other organ systems of the body unrelated to |- the respiratory system.
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4-146 - ; i, 4' '2.1.10. 3 - Quantitative estimates t ' The preceding section qualitatively defined the effects on human health , 'that may be expected from exposure to coal combustion products at greater-than-threshold levels. The quantitative effects.of the various
' data.effluent combinations are not easily projecced on the basis of existing Laboratory results for single components, such as SO2 , usually 'show considerably smaller. responses to a given dose than do field epi- -demiological studies of the same effluent, due to the complex nature of the effluent stream. In the field, a number of other unmeasured effluents - are also present and are probably acting additively or synergistically ; with the component being studied. Field studies, therefore, only use ' the defined effluent as an index for the total amount of noxious sub- stance in the air. . Past epidemiological studies have measured an effluent mix which usually derives from poorly controlled sources,.and in these situations there has been a reasonably consistent relationship in the relative amounts of the various components. Acute episodes of high pollution have clearly resulted in mortality and : morbidity. Often the effects of high pollutant concentrations in these ! episodes have been combined with other environmental features such as low temperatures or epidemic diseases (influenza) which may in themselves have serious or fatal consequences. This has sometimes made it difficult , i to-determine to what extent pollution and temperature extremes are ' responsible for the effects. Nevertheless, there JLs no longer any doubt that high levels of pollution sustained for periods of days can kill. Those' aged 45 and over, having chronic diseases, particularly of the lungs or heart, seem to be predominantly affected. In addition to these acute episodes, pollutants can attain daily levels that have been shown ! .to have serious consequences to city dwellers. For many years in London, ' - dailyL deaths and illnesses were clearly related to daily levels of smoke and S02 . Comparable observations have been made in New York City, Philadelphia, and Chicago. In the New York-New Jersey metropolitan ' area, an analysis of daily mortality for the years 1962-1966 showed that deaths were 1.5% below expectation at the lowest S02 concentrations and 3 , 2%.above expectation at concentrations of 500'ug/m and above. A i similar, though weaker, relationship was found in Philadelphia but not in Chicago. This work urgently needs to be pursued, since it calls into i
question the concept of a no-effect level on which present air quality , standards are based. ! ; The implication of daily levels of SO2 and particulates has been studied in particularly vulnerable groups, such as patients with chronic bron- ,chitis and emphysema. Deterioration in their respiratory well-being has resulted from a daily concentration of SO2 of about 500 pg/m3 , which is i not much above the 24-hr primary standard. A few studies have even '
- - suggested that deterioration in particularly vulnerable groups may occur . with daily- concentrations that are below this standard. It is impossible to state a concentration below which such health effects will not occur. in many studies, the proportion of persons affected
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increases from the lowest to highest categories of pollution. Had even lower categories of pollution been used in the analyses, even lower critical levels might have been suggested. Thus, the concept of no-effect level may be a chimera. A reasonable cenclusion from these studies would be that health effects have been found when annual levels of particulates or S02 exceed 100 kg/m3 This :encentratien is about ten times the annual concentratien of 7 to 9 pg/m3 in the Clifty Creek Power Plant area and about four times the maximun annual concentration of 24 pg/m3 that occurs north of the Kyger Creek Power Plant. - The need for more information about the lowest levels of pollution that might produce significant effects was recognized by the Environmental Protection Agency through the Community Health and Environmental Sur- veillance System (CHESS) studies. These studies were also intended to j monitor any changes in health that might occur as a result of any change I, in pollution concentrations. It is probably safe to say that, in j attempting to provide a large amount of information as quickly as | possible, the CHESS studies have as yet been less effective than they might have been had a more deliberate approach been adopted. Present assessment of the CHESS studies is that they do not in themselves justify a change in the standards. The CHESS studies also provide some support for the viewpoint that acid sulfates and sulfuric acid may be more important pollutants than SO 2 in terms of health consequences. There is some evidence that local centrols of SO2 (by higher stacks, etc.) are leading to a wider dissemination of particulate sulfates. All this is resulting in a rather uniform level of sulfates in the eastern United States. Cause-and-effect relationships probably exist at ambient air concentrations of sulfur oxides somewhat above the current standards in the United States today, perhaps at twice the current standards. Some studies suggest these relationships also exist at concentrations in the range of the primary ambient air standards for SO2 and TSP. Tentative exposure-effect relationships are available, but must be treated as suggestive, not definitive.
The clinical, laboratory, and experimental studies at relatively high concentrations of sulfur oxides in the ambient air are consistent with the current epidemiological data. Information is not available to provide the desired level of confidence at concentrations approximating the current standards.
The purpose of many epidemiological studies is to define an exposure-
response relationship. The~ best available tentative exposure-response surve is presented in Fig. 4.2-14.3 Although there is considerable variation in response in different people and in the same person at different times, most people show changes in respiratory flow resistance at SO2 concentrations of 5 ppm (15,000 pg/m3 ) and above. Especially sensitive people react to concentrations in the 1 to 2 ppm range (3000 to 6000 ug/m3 ).13-16 After 120 hr of exposure to 3 ppm (9000 ug/m3 ) SO2 , increased small airway resistance and significant but minimal decrease in the dynamic compliance of the lung was noted in normal human subjects. The effect disappeared within 48 hr after cessation of exposure.17 Four week-long exposures of subjects with demonstrable peripheral airway disease to S0 2 levels of 0.0, 0.3, 1.0, and 3.0 ppm (0, 900, 3000, and 900 ug/m3 ) produced no pattern relating to SO dose.18 The study was difficult to carry out, and the data showed2 wide variance. ,
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ES-3396 47 DAYS 2- 114 gg DAYS DAYS g - * 2o3 > 1s4 DAYS DAYS _F_ 3 212 4 DAYS g o _ E 279 O OAYS 2 130 J 12 0 DAYS 210 4 DAYS DAYS p -| - o 5 232 W DAYS E
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The report of the Rail Conunittee, which was a cooperative study with EPA and HEW to evaluate current SO data, concluded that: 2 standards and the existing scientific
With the implementation and enforcement of the primary Federal air pollution standards, we have reached a stage where pollution is unlikely to cause much adverse effect on health. Further reduction of the standard might protect a few sick people from being'made worse by air pollution, but of this there is considerable doubt [ Table 4.2-10]. Such reduction would be disproportionately costly when related to the likely benefits which could be expected. Such cost should only be accepted on the basis of convincing evidence that standards are now too high. evidence that would justif- The only satisfactory well designed experiments fthisconclusionwouldcomefrom
Table 4.210. Expected health effects of air pollution on selected population
Effect Pollutant pg/m 3_.
Excess mortality and hospital 500 admissions (24 hr mean)
Worsening of patients with 250 pulmonary disease (24 hr mean)
Respiratory symptoms (an- 100 nual arithmetic mean) j , , Visibility and/or annoyance 80 l (annual geometric mean)
World llealth Organization (WilO) data.
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4.2.1.10.4 conclusions .
The Clifty Creek and Kyger Creek power plants emit large quantities of- | 2 I SO , NOx , particulates, and_ smaller quantities of other potential pol- lutants and, therefore, affect human health. ! . Health effects on suscep- ' tible individuals will occur as a result of continued operation because there appears to be_no lower limit at which human health effects do not occur. pollutants.However, planned abatement will reduce concentrations of the
The contribution of Clifty Creek and Kyger Creek power plants to regional pollution concentrations, although significant, are not the sole sources nor even the sources of a majority of the pollutant concentrations (Sects. 4.2.1.3 and 4.2.2.3). The average ambient levels of S0 : 3 2 in the * region of the plants (7 to 9 pg/m ) is below that which appeats to cause ' measurable increases in the mortality rate.19 4
i
Calculations show (Sect. 4.2.1.3) that the yearly average 50 ' 3 2 concentra- tion is at a maximum of 20 to 50 pg'/m about 10 km NE of the Clifty ' ofCreek 80 pg/m3 Power Plant. This value is well below the EPA F02 primary standard (Appendix I). During episodic meteorological conditions, pollutant concentrations in small localized areas can reach levels (possibly 1100 pg/m3 for less than 15 min if normal high-sulfur coal is used) that, if sustained for several hours or days, could result in severe health effects to susceptible individuals. Such incidences are very infrequent and are expected to last only minutes. The Indiana Kentucky Electric Corporation has reserve low-sulfur coal to burn during thsee times [ estimated to be no more than four days per year (see Sect. 3.2.1.3)] when severe episodic meteorological conditions exist. Ill of the evidence the staff has been able to collect and analyse (summarized above) indicates that although pollution in the area of these plants may at times be annoying, no measureable increase in morbidity and mortality would result under most conditions.
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REFEkENCES FOR SECTION 4.2.1.10
1. U.S. Nuclear Regulatory Commission, Health and Ecological Effects Novemberof Coal Utilisation, 1976. draf t study, Argonne National Laboratory, 2. L. D. Hamilton, testimony in the U.S. District Court for the Western District of North Carolina, Charlotte Division, Carolina Environmental Study Group Inc. 3.
D. P. Rall, 'i _ Review of Health Effects of Sulfur Oxides," Environ. Health _Persp. 8: 97-121 (1974). , 4. " Air Quality and Stationary Source Emissions Control," report by Commission on Natural Resources, National Academy of Sciences, National Academy of Engineering, National Research Council, pre- ' Marchpared 1975.for Commission on Public Works, U.S. Senate, Serial No. 94-4,
5. M.' O. Amdur, " Air Pollutants," in J. J. Casarett and J. D. Doull . New(eds.), York, Toxicology: 1975. The Basic Science of Poisons, Macmillan,
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6. F. Fennelly, "The Origin and Influence of Airborne Particulates," Am. Sci. 64: 46-56 (1976). 7. D. N. Klein et al., " Pathways of Thirty-Seven Trace Elements through Coal-Fired Power Plants," Environ. Sci. Technol. 9(10): 973-79 (1975).
8. P. F. S. Natusch and J. R. Wallace, " Toxic Trace Elements: Pref- erential Concentration in Respi able Particles," Science 183: 202-04 (1974). ]. 9. .L. J. Casarett and J. D. Doull (eds.), Toxicology: The Basic |- Science of Poisons, Macmillian, New York (1975). 'I
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~10. P. F. S. Natusch and J. R. Wallace, " Urban Aerosol Toxicology: The Influences of Particle Size," Scisnee 186: 695-99 (1974). 11. M. O. Amdur, " Aerosols Formed by Oxidation of Sulfur Dioxide," Arch.' Environ. Health 23: 459-68 (1971).- 12. J. J. Bulka and.T. H. Risby, "Ultratrace Metals in Some Environ- mental and Biological Systems,"'Analyt. Chem. 48(8): 640A (1976). 13. NAPCA Publication AP-DO, Air Quality Criteria for Sulfur Oxides. U.S. Government Printing Office, Washington, D.C.,'1970.
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14. " Air Quality Criteria and Guides for. Sweden in Regard to Sulfur Dioxide and Suspended Particulates," Nord. Hyg. Tidsk. 54 (Suppl. 5) (1973).
15. M. O. Amdur, " Toxicologic Appraisal of Particulate Matter, Oxides of Sulfur, and Sulfuric Acid," J. Air Pollut. Contr. Assoc.19: (1969). 638
16. I. Andersen et al., " Human Response to Controlled Levels of Sulfur Dioxide," Arch. Environ. Health 28: 31 (1974). 17. F. W. Weir and P. A. Bromberg, Further Investigation of the Effects of Sulfur Dioxide on Human Subjects, American Petroleum Institute Project No. CAWC S-15, June 1972.
18. F. W. Weir and P. A. Bromberg, Effects of Sulfur Dioxide on Human Eubjects Exhibiting Peripheral Airway Impairment, American Petroleum Institute Project No. CAWC S-15, September 1973. 19. Environmental Protection Agency, Sulfate Briefing for Region Administrators, Neu York, Feb. 7,1971, National Envrionmental Research Center, Research Triangle Park, N.C.
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, "- 4.2.2.9 Potential effects of accidents . . . . . ] Hypothetical accidents of environmental consequence, which are con- . * . sidered credible, are presented in Sect. 2.4.4. .2 , .5* x 4.2.2.9.1 tu Terrestrial environmental effects ifjAccidentsat the Kyger Creek Power Plant will be similar in consequence , to those potentially occurring at Clif ty Creek Power Plant (Sect. "C'4.2.1.9).. , d i- s. t #;!4.2.2.9.2 Aquatic environmental effects II ; oI N |to Accidents those potentially at the Kyger occurring Creek atPower Clifty Plant Creek will Power be similar Plant in (Sect. consequence .;;4.2.1.9). $l . **',j f ....4 2 2 9 3 Effects on air quality I a. g j The most likely source of accidental air pollv* ion would be an oil al fire. Concerning Kyger Creek Power Plant, the some comments apply as ( in the case for Clif ty Creek Power Plant (Se :t. 4.2.1.9). 4 ,
4.2.2.10 Impacts on human health
For a general discussion of th,e health effects, see Sect. 4.2.1.10. Calculations show (Sect. 4.2.2.3) that there is, in general, a signifi , cant increase in the areal ground-level SO2 concentration when contribu- tions from the General James M. Gavin Power Plant and the Philip A. Sporn Power Plant are added to the Kyger Creek Power Plant emissions. However, the maximum yearly average concentrations are about the same in the two cases '(%24 pg/m 3), presumably because the maximum exposure points for the plants do not coincide.
The calculated maximum yearly average of N24 pg/m3 is well below the Primary Ambient Air Standard of 80 pg/m3 , and it concluded that there
would be no adverse health effects from the continued operation of the , Kyger Creek Power Plant under normal atmospheric conditions. However, ' episodic concentrations at specific locations around the Kyger Creek Power Plant are much worse than around the Clif ty Creek Power Plant by a-factor of about 3. This is because there could be additive effects from the three plants under the worst meteorological conditions. During these episodes there could be some health effects in susceptible indi-
~ viduals because the episodic S02 concentration could exceed the concen-
tration used as the 24-hr Primary Ambient Air Standard by a factor of ;
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about 9. However, these conditions will last only 15 min or less, and, therefore, the 24-hr standard is not likely to be exceeded. The occurrence of these conditions would be rare (Sect. 4. 2. 2. 3) .
't 4.2.3" CUP hwer producing facilities ' t \ ' A maximum of 350 MRe of additional power will be requ . red for operation of the uprated cascades at Portsmouth Gaseous Diffusion ' 'lant . This power (demandwill- be supplied by the 15 sponsoring companie listed in Sect. | 2.4.3. There will be environmental impacts associaiec .with the generation ; of additions.llpower even though the sponsoring compan: es will not be re- ' quired to bidld additional generating units or transmd ssion facilities as a direct result of this power demand. The extra power will probably be provided by operating plants at a slightly higher capa city. The 15 spon- i soring comp < tnies have divided their respective generating responsibilities {accordingto their present installed capacity. Each c ampany will deliver appro'ximate .y 1.3% of its current generation. A total of approximately * 26,300 MWe Ls currently generated by all of these comp anies. No single l deliver more than 60 HRe for the CUP (see Table 4.2-21). c[~[.companywilThe impacts of this added power will be spread over a large geographie - area (see S act. 3.2.3) and, therefore, will impercept131y increase impacts Tjtoaspecif le area. Nevertheless, the staff concluded 'that a worst-case 1 assessment :an be accomplished by assuming that the cunulative impact b) would be si'nilar to operating a single 350-MWe coal-fired! power-generating g, facility, o $[.4.2.3.1 Impacts on land use a C. ,, Major impacjts on land use of the generation of 350 MWu involve forefeiting e present (ar.d future) land use and potential modificat .cx1 of local and * regional 1: nd use plans. The total commitment of lan i resources for the 2 production |of 350 MRe will be approximately 330 acres for coal processing 3 and plant operation, including ash ponds. Gaseous effluents may also affect g local and t!egional land use. Assumingthatcoolingfowers are used to
ydissipateheat, icing and fogging, are likely to be increased by a small - amount. ~5a 0 3 4.2.3.2 I npacts on water quality and use ' il .: Two impact s from operation of a coal-fired power plaqt on water use involve F- alterar. ion. of water quality and consumptive use of wa, :er. Assuming closed- I cycle cooyng, a maximum of 20 cfs would be required formakeupwater,and i 12 cfs would be consumed. If once-through cooling me I : hods are used, over ald be withdrawn, and, similarly, a6out 10 :fs would be consumed. |600cfswoSome chemical and thermal effluent would result. ~~ .. _ ,
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Tavemooc souacc : Wind Ewv'.m%b1 Iq.w'r Ahmed ?cchoad C.o.scou.s Di44usim Nwk site., pike ron,chio,sa01}-6ff"f ' Table 2.4-1. Companies sponsoring OVEC and supplying power to Portsmouth Gaseous Diffusion Plant from nondedicated sources
wer p t c ation Company s an (MWe) ,
Appalachian Power Company * 15.2 53 The Cincinnati Gas and Electric Company 9.0 32 Columbus and Southern Ohio Electric Company 4.3 15 The Dayton Power and Light Company 4.9 17 - Indiana and Michig:n Electric Company * 7.6 27 Kentucky Utilities Company 2.5 9 Louisville Gas and Electric Company 7.0 25 6 Monongahela Power Company 3.5 12 Chio Edison Company 14.5 51 Ohio Power Company * 15.0 53 i Pennsylvania Power Company # 2.0 7 i 6 The Potomac Edison Company 2.0 7 Southern Indiana Gas and Electric Company 1.5 5 The Toledo Edison Company 4.0 14 West Penn Power Company * 7.0 25
* Subsidiary of American Electric Power Company, Inc. ~ 6Subsidiary of Allegheny Power System,Inc. ' Subsidiary of Ohio Edison Company.
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Inmawmo sevus: p i.a g so;,w,gM L,wt St.
Table 424. Maximum air concentration of fly ash particles near Clifty Creek Power Plant (NE direction, JJA season, Covington air data)
Stack height Particie size Precipitator Air concentration 3 (m) (ym) Efficiency (%) (pg/m )
8 76 10 99.75 and 98.0 0.16 6 0.9 76 10 96.1 ' 76 10 70.0* 7.0 8 76 20 99.75 and 98.0 1.6 76 20 96.1 9.3 76 20 70.0 71.8 8 168 10 99.75 and 98.0 0.1 168 10 96.1 0.6 4.4 | 168 10 70.0 ' 168 20 99.75 0.3
' Design efficiency of proposed new precipitators. Unit 6,99.75%; Units 1-5, 98%. 6 Design efficiency of current precipitators. ' Estimated current operating efficiency. -
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. *,
UNITED STATES OF AMERICA NUCLEAR REGULATORY C0tHISSION
BEFORE THE ATOMIC SAFETY AND LICENSING BOARD
In the Matter of
CAROLINA POWER AND LIGHT COMPANY AND Docket Nos. 50-400-OL NORTH CAROLINA EASTERN MUNICIPAL 50-401-OL POWER AGENCY
(Shearon Harris Nuclear Power Plant ) Units 1 and 2) )
CERTIFICATE OF SERVICE
I hereby certify that copies of "NRC STAFF'S MOTION FOR SUMMARY DISPOSITION OF WELLS EDDLEMAN'S CONTENTION 8F(1)", "NRC STAFF'S STATEMENT OF MATERIAL FACTS AS TO WHICH THERE IS N0 GENUINE ISSUE TO BE HEARD" AND, " AFFIDAVIT OF CHARLES W. BILLUPS IN SUPPORT OF NRC STAFF MOTION FOR SUMMARY DISPOSITION OF EDDLEMAN CONTENTION 8F(1)" in the above-captioned proceeding have been served ' on the following by deposit in the United States mail, first class, or, as
indicated by an asterisk, through. deposit in the Nuclear Regulatory Comission's internal mail system, this 2nd day of December,1983.
James L. Kelley, Chairman * Richard D. Wilson, M.D. Administrative Judge 729 Hunter Street Atomic Safety and Licensing Board Apex, NC 27502 U.S. Nuclear Regulatory Comission Washington, DC 20555 Travis Payne, Esq. 723 W. Johnson Street Mr. Glenn 0. Bright * P.O. Box 12643 Administrative Judge Raleigh, NC 27605 Atomic Safety and Licensing Board , i U.S. Nuclear Regulatory Comission Dr. Linda Little Washington, DC 20555 Governor's Waste Management Building ' 513 Albermarle Building | Dr. James H. Carpenter * 325 North Salisbury Street | Administrative Judge Raleigh, NC 27611 . I Atomic Safety and Licensing Board
; U.S. Nuclear Regulatory Comission ' Washington, DC 20555 Daniel F. Read CHANGE /ELP
, 5707 Waycross Street ' - Raleigh, NC 27605
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John Runkle, Executive Coordinator Richard E. Jones, Esq. Conservation Counsel of North Carolina Associate General Counsel 307 Granville Rd. Carolina Power & Light Company Chapel Hill, NC 27514 P.O. Box 1551 Raleigh, NC 27602
Dr. Phyllis Lotchin Docketing and Service Section* 108 Bridle Run Office of the Secretary Chapel Hill, NC 27514 U.S. Nuclear Regulatory Commission Washington, DC 20555 Atomic Safety and Licensing Appeal Ruthanne G. Miller, Esq. Board Panel * Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, DC 20555 Washington, DC 20555* Bradley W. Jones, Esq. Robert P. Gruber Regional Counsel Executive Director USNRC, Region II Public Staff - NCUC 101 Marietta St., N.W. P.O. Box 991 Suite 2900 Raleigh, NC 27602 Atlanta, GA 30303
Wells Eddleman . George Trowbridge, Esq. 718-A Iredell Street Thomas A. Baxter, Esq. Durham, NC 27701 John H. O'Neill, Jr. , Esq. Shaw, Pittman, Potts & Trowbridge 1800 M Street, N.W. Washington, DC 20036 Atomic Safety ar.d Licensing Board Panel * U.S. Nuclear Regulatory Commission Washington, DC 20555
e ir LLGLR.. NNuap_q_ * Janice E. Moore Counsel for NRC Staff
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