ML20215C855

Forwards Addl Info Re Radiological,Environ & Nonradiological Impacts & Alternative Actions Concerning Application to Amend Licenses NPF-4 & NPF-7,extending OLs for 40 Yrs.Info Re PTS Submitted on 861126

ML20215C855
Person / Time
Site:	North Anna
Issue date:	12/05/1986
From:	Stewart W VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.)
To:	Harold Denton, Rubenstein L Office of Nuclear Reactor Regulation
References
REF-GTECI-A-49, REF-GTECI-RV, TASK-A-49, TASK-OR 86-497A, NUDOCS 8612150469
Download: ML20215C855 (17)

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.i VIRGIN 1A ELECTRIC AND PownB COMPANY v.

--RIcnwown, VIRGINIA 20261 December 5, 1986-W.L,StawAnt Vace Pamespunt t

} Nuctuan OrmeAtsome Mr. Harold.R. Denton, Director..

Serial No.-86-497A Office of Nuclear Reactor. Regulation NO/JDH

Attn:'Mr.'Lester S. Rubenstein, Director Docket Nos. 50-338 PWR' Project Directorate No. 2 50-339 Division of-PWR.. Licensing-A License Nos. NPF-4 U.S.-Nuclear: Regulatory Commission NPF -

Washington, D.C.'

20555 Gentlemend VIRGINIA ELECTRIC'AND POWER COMPANY.

NORTH ANNA POWER STATION UNITS 1 AND 2

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ADDITIONAL INFORMATION-REGARDING FORTY YEAR OPERATING LICENSES On November 24, 1986, we met with you and members of your staff to. -discuss our proposed license amendments. extending the operating. licenses for the North Anna. and Surry Power

' Stations to 40 years.

As.a result of that meeting, several areas 1were identified where additional information was necessary to supplement the statements made.in our August 22, 1986 submittal (Serial-No.86-497) for North Anna.

Additional.information regarding pressurized thermal shock (PTS)'was submitted separately on November 26, 1986 (Serial

.No.- 86-781).

This additional-information regarding PTS demonstrated-the acceptability of continued operations for both-units for approximately 60 calendar years.

.The additional information.you requested regarding radiological

impacts, environmental impacts, non-radiological impacts, and alternative i

actions is attached.

'We appreciate your ' support in evaluating this proposed amendment on a' priority basis.

If you have any questions or I

require additional information, please contact us

-immediately.

Very-truly yours,

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J2AW W.

L.

Stewart

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8612150469 861205 PDR ADOCK 05000338 p

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O cc:' Dr. J. Nelson Grace Regional Administrator

_NEC Region II Mr.-Leon B. Engle NRC North Anna Project Manager

,PWR Project Directorate No. 2-Division of PWR Licensing-A Mr. J. L.~Caldwell NRC Senior Resident. Inspector North Anna Power Station Mr. Charles Price Department of Health s

109 Governor Street Richmond,_ Virginia 23219 I

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ADDITIONAL'INFORMATION FOR I

NORTH ANNA POWER STATION REGARDING FORTY YEAR OPERATING LICENSES L Y 4

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1 GENERAL INFORMATION (Review Methodology)

In assessing the acceptability of extending the operating licenses for North Anna Power Station, we conducted thorough reviews of the following principle licensing documents to identify instances where evaluations were based on other than 40 years:

North Anna Updated Final Safety Analysis Report (June 1986, Revision 4)

North Anna Units 1,2,3 and 4 Final Environmental Statement (April 1973) and Addendum 1 (November 1976) and Addendum 2 (August 1980) ggl North Anna Safety Evaluation Report (June 1976) (and supplements)

North Anna License Nos. NPF-4 and NPF-7 (including Technical Specifications)

In general, where evaluations did not cover a 40 year span, they were found to be on an annual or a 30 year basis, or no specific period was stated.

Evaluations conducted on a per year basis were examined to determine whether any adverse cumulative effects result-ed from the period of additional operations (7 years for North Anna 1; 9 1/2 years for North Anna 2).

Evaluations conducted on a 30 year basis were found primarily to be cost or fuel cycle evalua-tions.

When the basis was unclear, a 30 year period was assumed and the concern was evaluated for the additional period.

In a few cases, the previous evaluations assumed the current operating life of 33 (Unit 1) or 30 1/2 (Unit 2) years.

The impact of the addi-tional 7-9 1/2 years was also considered in these instances.

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In brief, no concerns were identified during our review which would

/'h preclude 40 years of operation.

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? RADIOLOGICAL IMPACTS-Additional:information regarding the-radiological impacts.in the P~21 Exclusion; Area,'~the Emergency Planning' Zone, and the_ nearest popula-

' tion centers is provided below.

Exclusion Area'

~s The Exclusion' Area consists of the Company-own'ed. property.in approx-imately a.5000 ft. radius of the station.

There is currently no

expectation that.the_ Exclusion Area boundary would be affected as a result:of Company initiatives during the' additional. years of, opera-

-tion.

' Emergency Planning Zone-

.Thel Emergency' Planning Zone-(EPZ) consists of the area'within.a' 10

mile-radius of the. station for which there is reasonable probability

.that' appropriate protective measures could be taken'on behalf of the population in the event of.a' serious accident.

Based on 1980 census data the permanent.1980 population.in-the EPZ was 14,610-(47 :per

-square mile).

While this population. density is' low and reflects-primarily rural areas, it is.noted that this actual _ population is i-approximately 57% higher than the NRC's projected 1980 10__ mile population lof 9,310 presented in Table 5-9 of the FES.

However, based on general population trends discussed below, we would_ expect little change in the EPZ population during the additional years of operation.

w Major -Population Centers In the-April 1973. Final Environmental Statement for North Anna Power Station Units 1,2,3 and 4, the NRC reported its conclusion that tro F

areas around North. Anna are essentially rural except for the metro-politan areas of Richmond, Charlottesville and, to a lesser extent, Fredericksburg.

This should remain'true throughout the additional years of operation requested (approximately 2011-2020) based on a l

review of 1980 census data and population projections provided by I

the Commonwealth of Virginia's Department of Planning and Budget-(October 1986).

Certain evaluations in the FES were conducted based on populations within a 50 mile radius of the station.

Rigorous comparisons between the FES evaluations and current data are difficult because

1) some of'the assumptions used in the FES data are not known, and

2) current population data is only available on a city / county basis.

_However, population trends within this area are readily discernable by reviewing the populations of major population centers and coun-ties within the area.

To be comprehensive, cities or counties which wereEonly partially inside the 50 mile radius were also considered.

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In general, from 1970 to 1980, the populations

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3 of these cities and counties increased by.21% (annual rate of less than.2%).

The Commonwealth of Virginia projects this population to increase 3:2.7% by the year 2000 (annual rate of less than 1.5%).

Specifically, the' nearest major population-centers within 50 miles

'of the station are still the cities of Richmond,-Charlottesville and Fredericksburg.

The populations of.these cities in 1970 and

1980, and the projected population in the year 2000 are as follows:-

Historical Projected 1970 1980 2000 Richmond City 249,431 219,214 212,700 Fredericksburg 14,450 17,762 22,800 Charlottesville 38,880 39,916 43,400 Total 302,761 276,892 278,900 From this information, it is clear that the total population in these cities decreased from 1970 to 1980, and is expected to remain fairly stable through the year 2000.

The counties are therefore responsible for the modest growth experienced within the 50 mile radius from 1970 through 1980, and the mcdest growth expected through the year 2000.

Based on these actual and projected increases, we have determined that the conclusions in the North Anna FES concerning the population based evaluations remain valid for the additional years of opera-

. tion.

As an example, Section 5 of the FES states:

"Each of the approximately 1 million people who currently live within 50 miles will receive about 125 millirem / year from natural background radia-tion, which is equivalent to a population dose of 125,000 man-rem / year.

Comparison of these numbers with the staff's estimat-ed population dose of 21 man-rem per year of four-reactor operation shows that the increase in dose over background is very small."

The estimated population dose from our two operating units is a smaller fraction yet compared to the total dose from natural background radiation.

The roughly 2% annual population growth results in a

small fraction of the orders of magnitude change necessary to significantly affect the previously evaluated radiological conse-quences.

We have further determined that the conclusions reached in the NRC's SER, North Anna meets the requirements of 10CFR100, remain unchanged for the additional years of operation.

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4 Postulated Accidents The magnitude of accident releases and doses to individuals would not change ~as a result of an increase in the years of plant opera-tion.

The total integrated dose to the public would change if the total population continued to grow during the period covered by the requested license extension.

However, Table 7.2 of the FES shows that the estimated integrated exposure of the population within 50 mile of the station from each postulated accident would be orders of magnitude smaller than that

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from naturally occurring radioactivity, which corresponds to about 125,000 man-rems / year based on a

natural background of 125 s

mrem / year.

As discussed previously, the population is increasing roughly 2% annually within the 50 mile radius of North Anna.

This growth is a small fraction of the orders of magnitude change neces-sary to significantly affect the previously evaluated radiological consequences.

Accident consequences were considered for a 40 year operating life for 4 units in the North Anna FES.

We have determined that the overall conclusions of the FES concerning radiological consequences following accidents remain valid.

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ENVIRONMENTAL IMPACT (General Public)

LThe; Final Environmental: Statement (FES) for-North Anna. Units. 1,2,3 rand.4 provided NRC estimates for' annual' releases and yearly doses f

.e resulting from the operation of the station ~.-

The' estimated annual releases'for-Units. 1'and 2 remain unchanged regardless of.the

' lifetime of the. facility,--and.as shown below, the actual. releases

~have remained small-fractions of the 10CFR50, AppendixfI require-

-ments.

The. dose estimates provided in the FES.(Section 7 5.5 and 5.6) were

. reviewed for the impact of a 40 year operating life.. The-FES ~does not state the' number.of years of operation assumed in those 'analy-caes..However,~ increasing the. operating life to 40 years lwould increase:the actual yearly dose contributed _ from long lived

. radionuclides ~via ingestion; pathways.

Increases' in the actual z

yearly doses contributed from. long lived radionuclides via.other exposure pathways would be substantially les We conservatively estimate that this increase would be -26% at inost.

The effect of.

-shorter-lived isotopes would be much less.

A 26% or less increase

~1n dose is minor considering (1) doses are well within the guide-lines of 10CFR50-Appendix I,

(2) the cost benefits of continued station operation and'(3) the fact that the FES was originally approved for~four unit operation.

We are not_ aware of any significant land use changes within a 50

' mile radius of North Anna that have affected-offsite dose calcula-tions.

We have also. conducted a general comparison of the radiological impacts on man as assessed in the FES with those actually experi-enced during plant operations.

The following. table gives a summary

.of liquid and gaseous effluent dose information during the period from January ~1,'1985 through December 31, 1985 in comparison with 10 CFR Part-50, Appendix I limits.

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10CFR50,1 App.

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Boundary k71 JGammatAirt.

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. Dose:ToCAny Organ'(mrem).

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Total' max.

offsite wholeL bodyfdoseL(mrem) 1.171 10 7

Liquid Releases

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mum'Offsite Whole Body 0-Dose (mrem) 1.26 6

2.~ : Total Maxi-mum Offsite:

Organ Dose (mrem) 1.76 20 i

- The liquid and gaseous effluent doses reported in 1985 are signifi-

~cantly less than the 10 CFR-50, Appendix I limits. 'Furthermore, the 1985 whole body-doses are consistent with the liquid and gaseous

-effluent; doses projected in Table 5.8 of the FES.-

Both the actual gaseous effluent doses reported in 1985 and the FES estimated doses due to gaseous effluents approximate 1.0 mrem.which is a very small

.value< compared to the 500 mrem annual whole body dose rate limit.

- The?1985 whole body dose due to liquid effluents is approximately

_'the same asLthe FES projected value.

Both these dose values are 2

also a small fraction of the annual whole body dose rate limit.

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7 Based _on the continued operation of North Anns using existing liquid and gaseous radwaste treatment systems coupled with the current radiological monitoring program, we anticipate liquid and gaseous effluent doses during the period covered by.the requested amendment

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will remain.a fraction of 10CFR Part 50; Appendix I limits and will:

not adversely impact upon the environment.

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- ENVIRONMENTAL; IMPACT (Fuel Cycle)

Thefimpact of_..the. uranium fuel' cycle was.consideredLin the. Final 4

Environmental Statement for Units:1,2,3'and 4c(April (1973); Addendum

, 41'toithe FES'(November 1976), and-Addendum 2 to the FES (August L1980).

North 1 Anna'was. originally fueled with 3.2%'enrichmentswith'a' limit-cing;reloadienrichment'of 3.5%. :Since:that time,Jtwo license amend-ments (Amendment Nos.127/8 on April 29, 1981 and Amendment'Nos.

'36/16 on. January:19;r1982) allowed an increase in enrichment for new-and'apentsfuel.from'3.5%.to the limiting enrichments currently

specified in Technical Specification 5.3.1 of 4.1% thus'. allowing longer operating cycles in lieu of.the 12_ month _ cycles. assumed in.

othe FES.

In each case, the environmental. considerations were E.

~ assessed and the NRC staff concluded that the amendments would not iresult'in-any significant impact.

.In assessing the impact on the uranium fuel cycle for the additional'-

7' years operation 1for Unit 1 and 9'1/2 years operation for Unit 2 (approximately 116 1/2 reactor-years additional operation), we have considered the following factors

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The additional years of reactor operation'would almost propor-

-tionally increase the total fissile uranium. required.

This

_ impact is justified in light of the continued benefit received i

c from station' operation.-

F 2.

The units-are expected to consume 11.4 tons of fissile uranium for-Unit 11and 10.9 tons of fissile uranium for-Unit 2 overLthe current' licensed periods.

This is. expected to increase to 14.0 i

tons for Unit 1 and 14.4 tons for Unit 2 consumed over the e

extended 40 year period..Therefore, a two unit total of 22.3 tons for the current licensed period and 28.4 tons for the extended' period are expected to be-consumed.

These values were 1

calculated based on the actual uranium. loadings for past and current cycles and projected loadings for future cycles, and 4-were converted to the amount of uranium loaded which is actual-ly consumed.

The North Anna FES gave a value of 71 tons for the expected j

fissile uranium to be consumed during the lifetime of the four originally planned North Anna reactors.

The total predicted t

value for Units 1 and 2 over the extended license periodc is still bounded by the four unit total uranium consumption value accepted by the NRC in the FES.

i Based on our review of the previous NRC findings regarding two license amendments supporting increases in enrichments, the lack of adverse impact on the fuel cycle due to increased enrichments, and the previous FES assessment for 4 units, we have determined that the FES values for consumed fissile uranium remain bounding for the j

additional operating period.

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LOCCUPATIONAL EXPOSURES

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The average dose exponded over the'recent six year: period' -covering i

1980-1985 has been:524 person-rem per year per unit.- This compares j

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favorably.withithe: industry average of.579 person-rem per year per LunitEfor this period of time.

It is-projected _ North Anna Units 1 1

andl2 will: expend approximately 800. person-rem (400 per unit). in

1986.

Mid-year projections by INPO. puts the PWR industry average

.forJ1986.at 1018_ person-rem for a two unit facility.,

.Mhjor exposure saving' modifications scheduled for' future refuelings

-include installation of permanent reactor head shields, removal _ of non-essential large bore snubbers, and a computer-enhanced photo

" documentation of the entire plant for ALARA-preplanning..

Implemen-tation of.these modifications 1when coupled with tighter primary ichemistry control and an improving ALARA program should lower the

average person-rem per refueling even when factoring in the in-

creased doses associated with an aging plant.

The Company:is committed to equal or bettering the industry's

. performance in_ radiation ~ exposure.

The North Anna exposure goals for 1990 submitted to INPO were set at 269 person-rem per. unit (538 person-rem.for'the site).

Using these goals,.the total occupational

-dose expected over the period of the operating license extension of 7 and 9 1/2 years for. North Anna 1 and 2, respectively, is 4439

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person-rem, and is' based on 12 additional refuelings during this

~ period and no major' unanticipated maintenance.

The Company's aggressive ALARA program, dose-saving plant modifica-

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tions and management commitment should ensure that the occupational dose ~ received during_the additional years of operation is. maintained 1

as low as. reasonably achievable and would be. consistent with indus-t try.

We conclude that the ALAEA measures and dose projections for C

.the additional years of plant operation would remain in accordance with 10 CFR Part 20 and the guidance of Regulatory Guide 8.8, T

"Information Relevant to Ensuring that Occupational Radiation Exposures at Nuclear Power Stations Will Be As Low As Is Reasonably Achievable" (Revision 3).

L' Radioactive Waste

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I-North Anna currently makes approximately 55 radioactive waste shipments per year within a range of 40 to 60 shipments in any given year.

Section 5 of the FES estimates the number of yearly shipments at 200 for 4 operating units.

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10 Radioactive waste shipments are expected to decline over the next few years due to radwaste reduction efforts,.such as the construc-tion of a radwaste processing facility, supercompaction, and a

-sorting / segregation program.

Based on the radwaste reduction efforts described above and the Company's commitment. to reduce waste, it is anticipated that radwaste shipments would continue to remain. well belowtthe FES

-estimates during the additional years of plant operation.-

Spent Fuel

. Spent fuel will be stored in the reracked spent fuel pool which has been previc"wly reviewed and approved by the NRC.

Hence, onsite storage of..ent fuel is available_through the year 1999.

Addition-El onsite storage through the use of fuel rod consolidation or der cask storage will be added as necessary and would require NRC revicw.

The radiological and environmental effects of these changes wou13 be evaluated by the NRC at that time.

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.NON-RADIOLOGICAL IMPACTS

'The~ environmental impacts lof station operations are discussed' in.

.Section-5'of the.FES.. Our. review of-the FES~ determined.thatl the non-radiologicalfimpacts were based en plant design features,.

' relative loss:ofLrenewable resources, or: relative' loss:or: degrada -

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tion of;available habitat.

In brief, no significant short-. or

long-term damage:or. loss of. biota of the region.hascoccurred.or..is i

' anticipated during the additional: years of. operation.- Should.;an unanticipated significant detrimental effect.to biotic communities or the environment occur,.the' monitoring. programs that are presently in place are designed to detect such1 anomalies.

Subsequent correc-tive' measures would be taken-as: appropriate.

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0riginal design features;that.are in place to. assure no adverse environmental effects, environmental. studies which have assessed-

. actual impacts of plant operation,~and the review orogram which

< assures that.no changes will be made to the plant that could ad-l versely effect the environment are further discussed below.

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. Original Design Features i

With regard to thermal discharge effects on aquatic organisms, E

the design characteristics of certain structures and the lake itself provide for additional environmental protection.

These-include: ~(1) a submerged discharge structure that discharges the cooling water as a high velocity. jet producing rapid mixing E

of the waste heat-with lower lake waters and maximizing dilu-tion, (2) construction of the Waste Heat Treatment Facility

.(WHTF) formed by diking off a series of threa interconnected i

cooling lagoons from which more than 50% of the station's rejected heat is' dissipated before discharge to Lake Anna.

Because of_this arrangement, the delta-T for the cooling water L

system is a relatively low plus 3 degrees Centigrade, and (3) l j

an induced circulation pattern in the lower lake formed as E

cooling water ~ discharged at Dike 3 of the WHTF is drawn uplake L

by the circulating water pumps.

This circulation pattern results in deepening the epilimnotic layer, alleviating summer stagnation, increasing the volume of oxygenated water and the i'

acreage of benthic substrate, and thus improving the fishery.

Other structures in the lake itself provide additional environ-mental protection for aquatic organisms.

Fish structures comprised of cinderblocks to which small trees and brush are secured have been submerged in Lake Anna to provide cover and L

protection for young fish and serve as spawning and feeding areas for large fish.

Seven such structures are currently in place and twelve more are planned.

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112 These additional environmental devices and conditions will'

- continue to be in place for.the. period.of the proposed: license extension. - Their advantageous' effects onfaquatic organisms will'not be changed.

2; Environmental'Stu' dies-Since-Issuance of;the Operating License A study was - performed :under Section 316(a) of the Clean Water Act and was completed.as a Hybrid Type I-III Demonstration.

Data.were collected on all major' biological. categories or subcommunities-(phytoplankton, periphyton, aquatic macrophytes, zooplankton, macroinvertebrates, fishes and waterfowl) for five years prior to operation (1973-77) and for-the first eight years sincefoperation began (1978-1985).

The_ final report; of

'the demonstration was submitted.tofthe Virginia Water Control.

s Board in June;1986._ The study-demonstrated that a balanced,.

' indigenous community of shellfish,-fish and wildlife exists in and on Lake Anna and the North Anna River, that.the balance

.among predators, plankton feeders and ~ bottom feeders appears normal.and similar to'other reservoirs 'and that thermal. dis-

. charges from the station are not adversely affecting aquatic

. life in Lake' Anna or'the lower-North Anna River.

In 1985, the results of another study completed under Section 316(b) of the Clean Water Act were also, submitted to the Virginia Water Control Board.

This study evaluated the envi-ronmental influence of the intake structures on aquatic life in Lake Anna.

The results demonstrated that the. biological impact of impingement and-entrainment.of aquatic organisms has a

minimal impact.on the ecosystem of the lake.

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Data were. collected continuously from early:1978 through 1983 on-the numbers of fish impinged at the intake structures.

It was found that~less than 3.1% of: standing crop numbers -were impinged _. annually.

.The results.of this study demonstrated that the biological impact of impingement on the' ecosystem of-Lake-1 Anna is: minimal.

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' Design Change Review:

A number'of plantLmodifications,have been madelsince the Final Environmental Statement was issued.

These modifications tend to improve: plant reliability.and it-has been shown that _the environmental. impact has been minimal.

The plant l modifications are described-in-the Updated Fina1JSafety Analysis. Report,

.which.is revised._ annually. _ Components associated with-the

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_ modifications that are expected to wear out during: plant life are subjected to a surveillance and maintenance program so.that component degradation will be identified and corrected.

Extending the operating life as proposed-will have no detect-able environmental impact'resulting from plant modifications.

' Jus required under our NRC license and station _ administrative procedures, all1 design changes with the potential for impacting the aquatic: environment are reviewed by the Company.

Discharg-es to Lake Anna are regulated by the Virginia Water Control Board-under authority of the National Pollutant Discharge Elimination System (NPDES) and governed by the NPDES permit issued to. North-Anna Power Station.- The Board issued NPDES Permit No. VA0052451 covering the, North Anna Nuclear Power Station, Units 1 and 2.

Any design change 'which may alter a discharge to the lake is reviewed and evaluated by the Board at

the request of the Company during the Board's periodic review of operating conditions or at-the time of reapp11 cation and reissuance (every 5 years).

Such review in conjunction with the NPDES permit limitations ensure that the consequences of any potential environmental impact should be maintained within accepted standards.

Amendments Nos. 23 and 3 issued December 30, 1980 deleted the water quality monitoring requirements from the Technical Specifications since these requirements would be administered by the Virginia State Water Control Board.

The existing permit expires on March 19, 1990.

The requested extension of the operating licenses would require at least one additional reissuance of the NPDES permit.

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~\\LTERNATIVES TO THE PROPOSED ACTION

-The' principle alternative 'to issuance.of the proposed license

. extensions would be to deny-the application.

In this case, North.

Anna Unitsil:and 2 would shut down upon expiration of the present

operating licenses.

In Chapter 11.0 of the[FES,EaLcost benefit analysis is presented for

' North Anna.

The analysis is based upon 30 years of operation and

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' includes a comparison with various other options for producing-an

' equivalent electrical power capacity.

Even considering significant L

changes in economics of alternatives, the continued operation of

' North Anna Units 1 and 2 for~another 7 and 9 1/2 years, respective-ly,. remains the most. economical alternative.

Nuclear generated electricity is the least expensive power generated m

and sold by the Company.

The annualized cost of the facility' will decrease with additional years of operation since the large initial B'

' capital, outlay would be averaged over a larger period of time.

Continued plant operation would require little capital expenditures compared.to'the construction of new units.

We currently projoct-a new 750 MW fossil unit to cost about $1300/KW.

In comparison, the cost of North Anna 1 was about $827/KW.

A replacement nuclear unit i

~ would not be considered at this time because of extremely large and uncertain costs as well as an uncertain regulatory climate.

Purchased replacement power costs are also higher than the costs associated with : continued operation of the existing units for an C-additional 7-9 1/2 years.

-Approval of this extension would defer (1) the need to install replacement base load ' capacity and (2) the associated capital

. expenditures.

The continued operation of North Anna beyond its current operating license 1 period would also be a benefit to the tax base'and'.the economy of the surrounding areas.

In summary, the cost benefit of North Anna, compared with other alternatives, improves with extended plant life.

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