L-08-125, Reply to Request for Additional Information Regarding Postulated Refurbishment Impacts, for License Renewal

Reply to Request for Additional Information Regarding Postulated Refurbishment Impacts, for License Renewal

ML081200598
Person / Time
Site:	Beaver Valley
Issue date:	04/25/2008
From:	Sena P FirstEnergy Nuclear Operating Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
L-08-125, TAC MD6595, TAC MD6596
Download: ML081200598 (16)

Text

FENOC FirstEnergyNuclear OperatingCompany PeterP. Sena III 724-682-5234 Site Vice President Fax: 724-643-8069 April 25, 2008 L-08-125 10 CFR 54 ATTN: Document Control Desk U. S. Nuclear Regulatory Commission Washington, DC 20555-0001

SUBJECT:

Beaver Valley Power Station, Unit Nos. 1 and ,2 BV-1 Docket No. 50-334, License No. DPR-66 BV-2 Docket No. 50-412, License No. NPF-73 Reply to Request for Additional Information Regarding Postulated Refurbishment Impacts for Beaver Valley Power Station, Units 1 and 2, License Renewal (TAC Nos.

MD6595 and MD6596)

Reference 1 provided the FirstEnergy Nuclear Operating Company (FENOC) License Renewal Application for the Beaver Valley Power Station (BVPS). Reference 2 provided a summary of a conference call between the U.S. Nuclear Regulatory Commission (NRC) and FENOC on the topic of license renewal major refurbishment and the associated environmental impacts. Reference 3 requested additional information regarding refurbishment impacts described in Appendix E, "Environmental Report," of the BVPS License Renewal Application.

The Attachment provides the FENOC reply to the NRC request for additional information.

There are no regulatory commitments contained in this letter. If there are any questions or if additional information is required, please contact Mr. Clifford I. Custer, Fleet License Renewal Project Manager, at 724-682-7139.

I declare under penalty of perjury that the foregoing is true and correct. Executed on April 2f , 2008.

Sinc Peter P. Sena III 7A/()6

Beaver Valley Power Station, Unit Nos. 1 and 2 L-08-125 Page 2

References:

1. FENOC Letter L-07-113, "License Renewal Application," August 27, 2007.

2. NRC Letter, "Summary of Telephone Conference Call Held on March 05, 2008, Between the U.S. Nuclear Regulatory Commission and FirstEnergy Nuclear Operating Company, Concerning the Request for Additional Information Pertaining to the Refurbishment Activities at the Beaver Valley Power Station, Units 1 and 2, License Renewal Application (TAC Nos. MD6595 and MD6596)," April 7, 2008.

3. NRC Letter, "Request for Additional Information Regarding Refurbishment Impacts for Beaver Valley Power Station Units 1 and 2 License Renewal (TAC Nos.

MD6595 and MD6596)," March 13, 2008.

Attachment:

Reply to Request for Additional Information Regarding Refurbishment Impacts for Beaver Valley Power Station, Units 1 and 2, License Renewal cc: Mr. K. L. Howard, NRC DLR Project Manager Mr. E. Sayoc, NRC DLR Project Manager Mr. S. J. Collins, NRC Region I Administrator cc: w/o Attachment Dr. S. S. Lee, NRC DLR Acting Director Mr. D. L. Werkheiser, NRC Senior Resident Inspector Ms. N. S. Morgan, NRC DORL Project Manager Mr. D. J. Allard, PA BRP/DEP Director Mr. L. E. Ryan, PA BRP/DEP

ATTACHMENT L-08-125 Reply to Request for Additional Information Regarding Refurbishment Impacts for Beaver Valley Power Station, Units 1 and 2, License Renewal Page 1 of 14 Question RAI ENV 3.0-1 The U.S. Nuclear Regulatory Commission's (the NRC or staff) regulations [10 CFR 51.53(c)(3)(ii)] for implementing the National Environmental Policy Act states that "The environmental report must contain analyses of the environmental impacts of the proposed action, including the impacts of refurbishment activities, if any, associated with license renewal and the impacts of operation during the renewal term, for those issues identified as Category 2 issues in Appendix B to Subpart A of this part [part 51]."

In Section 3.2 of the Beaver Valley Power Station (BVPS) Environmental Report (ER), the applicant states, "The FirstEnergy Nuclear Operating Company (FENOC) aging management review, including the IPA conducted under 10 CFR Part 54, has identified a need for additional inspection at BVPS, including possible Unit 2 steam generator repair or replacement during the license renewal term." The ER states that the steam generator replacement activities will be done during scheduled outages and therefore are bounded by the environmental impacts analyzed in the Final Environmental Statement (FES). However, the Generic Environmental Impact Statement (GELS) Section 2.6.2.6 provides some examples of major refurbishment and replacement activities. The replacement of PWR steam generators is expressly cited in the GElS Section 2.6.2.6 (and in Table 2-7) as a major refurbishment and replacement activity. Furthermore, the GElS indicates that these activities can have environmental impacts requiring analysis that need to be considered in a site-specific supplement to the GELS.

1. Considering the framework established by the GELS, please indicate whether or not the BVPS Unit 2 steam generator replacement is a refurbishment activity associated with license renewal.

2.a If this refurbishment activity is not associated with the license renewal, please provide a basis for that determination.

2.b If the refurbishment activity is associated with license renewal, please provide an analysis of refurbishment-related issues based on the framework provided in Chapter 3 of the GELS. Specifically, address the refurbishment analysis required for the eight (8) Category 2 environmental impacts listed in Table B-1 of 10 CFR Part 51, Subpart A, Appendix B, namely:

1. Terrestrial Resources, Refurbishment Impacts;

Attachment L-08-125 Page 2 of 14

2. Threatened or Endangered Species;

3. Air Quality During Refurbishment (non-attainment and maintenance areas);

4. Socioeconomics, Housing Impacts;

5. Socioeconomics, Public Services, Education (Refurbishment);

6. Socioeconomics, Offsite Land Use (Refurbishment);

7. Socioeconomics, Public Services, Transportation (Refurbishment);

8. Historic and Archaeological Resources;

9. Socioeconomics, Public Utilities;

10. Environmental Justice.

RESPONSE RAI ENV 3.0-1.1

1. Considering the framework established by the GELS, please indicate whether or not the BVPS Unit 2 steam generator replacement is a refurbishment activity associated with license renewal.

A postulated BVPS Unit 2 steam generator (SG) replacement would not be a major refurbishment activity associated with license renewal even though SG replacement is listed in the Generic Environmental Impact Statement (GELS) as an example of this type of activity. The BVPS Environmental Report (ER) states that repair or replacement of the Unit 2 SGS is possible during the license renewal term. However, FENOC will make decisions regarding repair or replacement of the BVPS Unit 2 steam generators SGs based on the assessments of SG performance and condition required by the Beaver Valley Steam Generator Management Program.

Attachment L-08-125 Page 3 of 14 RESPONSE RAI ENV 3.0-1.2.a 2.a If this refurbishment activity is not associated with the license renewal, please provide a basis for that determination.

A potential BVPS Unit 2 SG replacement does not constitute a major refurbishment based on the significant differences between the GElS assumptions associated with this set of SG replacement activities and the direct FENOC experience that resulted from the identical set of SG replacement activities performed at BVPS Unit 1 in 2006.

The GElS states that major refurbishments are accomplished in several successive outages on a schedule of between 6.5 months (GELS, Appendix B, Figure B.1) to 9 months (GELS, Appendix B, Section 3.1.3.5). Appendix B of the GElS also recognizes that some of the then-current (1993) steam generator replacement activities could, in fact, be accomplished within a 3-5 month period; however, the 9-month schedule was retained within the GElS to accommodate additional undefined tasks that licensees may choose to perform concurrently with the steam generator replacements.

Contrary to the assumptions contained in the GELS, FENOC estimates that a SG replacement for BVPS Unit 2 would be accomplished within one slightly-extended refueling outage lasting about 70 days. This anticipated schedule is close to the normal refueling outage duration of 60 days also cited in the GElS (Table B.3, Outage duration summary). The BVPS Unit 1 SG replacement outage was accomplished within 66 days (65 days, 19 hours2.199074e-4 days <br />0.00528 hours <br />3.141534e-5 weeks <br />7.2295e-6 months <br />) in 2006, indicating that a projected 70-day schedule for Unit 2 is valid.

Based on this information, FENOC believes that the conclusion stated in the BVPS ER, Section 3.2, is correct, in that the activities associated with a BVPS Unit 2 SG replacement are effectively bounded by the environmental impacts associated with normal refueling outages (and, therefore, contained in the Final Environmental Statement, (FES)); they simply would not be of the magnitude that the NRC considered as major refurbishment in the GELS.

Attachment L-08-125 Page 4 of 14 RESPONSE RAI ENV 3.0-1.2.b 2.b If the refurbishment activity is associated with license renewal, please provide an analysis of refurbishment-related issues based on the framework provided in Chapter 3 of the GELS. Specifically, address the refurbishment analysis required for the eight (8) Category 2 environmental impacts listed in Table B-1 of 10 CFR Part 51, Subpart A, Appendix B, namely:

1. Terrestrial Resources, Refurbishment Impacts;

2. Threatened or Endangered Species;

3. Air Quality During Refurbishment (non-attainment and maintenance areas);

4. Socioeconomics, Housing Impacts;

5. Socioeconomics, Public Services, Education (Refurbishment);

6. Socioeconomics, Offsite Land Use (Refurbishment);

7. Socioeconomics, Public Services, Transportation (Refurbishment);

8. Historic and Archaeological Resources;

9. Socioeconomics, Public Utilities;

10. Environmental Justice.

Regardless of the specific classification of any potential BVPS Unit 2 SG replacement, FENOC is, nevertheless, providing the following environmental impacts analyses as requested by the NRC Staff.

BVPS Steam Generator Replacement Project General Description BVPS Units 1 and 2 are very similar in design as described in the BVPS License Renewal Application, Section 1.2, "Plant Description." The SGs for both units were originally furnished by Westinghouse, and are roughly cylindrical in shape, approximately 70 feet long and 15 feet in diameter, and they weigh approximately 370 tons each. BVPS Unit 1 and 2 each have three steam generators. The BVPS Unit 1 and 2 containment structures and site arrangement are also similar in design.

FENOC performed a BVPS Unit 1 SG replacement during a slightly-extended refueling outage in 2006. The information that follows provides details from the FENOC experience with the BVPS Unit 1 SG replacement; should FENOC consider a BVPS Unit 2 SG replacement in the future, the process should be very similar to that of Unit 1, and likely would have similar impacts to the site and local environment.

BVPS is located on the portion of the Ohio River that is used extensively for commercial navigation. The three new BVPS Unit 1 SGs were constructed in Europe and shipped

Attachment L-08-125 Page 5 of 14 to the United States in one shipment. These three new SGs arrived in Mobile, Alabama (the port of New Orleans was closed following hurricane Katrina), and were transported by one barge to the Ohio River, and to the existing BVPS onsite barge slip. Prior to arrival, FENOC arranged for necessary barge slip maintenance dredging by a vendor, who disposed of the spoils offsite in an Army Corps of Engineers approved spoils disposal area.

Upon arrival at the site, each new Unit 1 SG was loaded onto a heavy-duty transporter and moved to temporary storage facilities for pre-installation conditioning. Temporary storage and pre-installation preparations of the new Unit 1 SGs were performed in a rented industrial tent. The tent for the replacement SGs was approximately 10,500 square feet, and was erected on the pavement northeast of the Unit 2 cooling tower. Chemical and oil storage, as well as spill prevention measures, were established in accordance with site and company environmental protection procedures; there were no reportable spills or other pollution events resulting from the Unit 1 SG replacement project.

The Unit I reactor containment building is composed of reinforced concrete walls more than three feet thick, with an interior steel liner. To perform the SG replacement, a temporary construction opening approximately 20 feet by 18 feet was created in the containment building near the existing equipment hatch. The process of creating the opening included activities such as removing concrete, cutting rebar, and cutting and removing a section of the steel liner. A hydro-demolition (high pressure water) process and other mechanical methods were used to remove the concrete and cut the liner.

The water used in the Unit 1 hydro-demolition process was cleaned up via a portable water treatment clarification system prior to being discharged to the Ohio River. The temporary discharge was pre-approved through the National Pollutant Discharge Elimination System (NPDES) permit system process by the Pennsylvania Department of Environmental Protection. The Unit 1 concrete debris was disposed of as construction and demolition debris in accordance with Pennsylvania Residual Waste regulations. There were no exceedances associated with clean water or notices of violation related to waste regulations for the Unit 1 SG project.

The Unit 1 steel reinforcement and liner were cleaned, re-conditioned, and reused in-place. After SG replacement, the reactor building containment opening was sealed, and the containment building returned to its original configuration and integrity.

Prior to removing the old Unit 1 SGs from the containment building, they were drained and detached from existing piping and supports. Coverings installed on the various nozzles (openings) sealed off internal sections. Loose contamination was removed from the exteriors and a coating applied to affix any residual contamination.

Attachment L-08-125 Page 6 of 14 Site planning, facility construction and modification of existing buildings, and other preparation activities occurred at BVPS prior to removal of the old Unit 1 SGs. Several temporary facilities were erected that housed most Unit 1 project activities, including:

offices, fabrication, mock-up, weld testing, warehouse, and laydown areas. A temporary office complex of approximately 26,600 square feet was erected in the Old Administration Building parking lot (north of Unit 2). A temporary containment access facility, consisting of shops, meeting rooms, and an access point into the radiological controlled area (RCA) and containment building was constructed between Units 1 and 2. Its footprint was approximately 5,600 square feet. An additional temporary office building was built near the Generation Distribution Center covering approximately 20,000 square feet. The temporary structures for the Unit 1 project (tents and buildings) were located in and on previously-disturbed areas. All other temporary facilities either used portions of existing structures and facilities, or consisted of trailers located within the developed industrial area of the site.

A permanent storage building was constructed adjacent to the Waste Handling Building for onsite storage of the old Unit 1 SGs. The Waste Handling Building is the large concrete structure located on the far side of the switchyard on the environmental report cover photograph (note, the photograph predates the Unit 1 SG storage building). This area was previously disturbed during station construction and is covered by grasses and other low vegetation. The Unit 1 SG storage building covers approximately 6,800 square feet, and is a reinforced concrete structure constructed on a reinforced concrete mat foundation. The excavated materials were handled in accordance with the waste and clean-fill rules in effect.

Those activities necessary for removal, replacement, and maintenance of the three Unit 1 SGs took place during a 66-day refueling and SG replacement outage. The peak period of activity for the Unit 1 SG replacement project occurred when the actual removal and replacement of the SGs took place.

The Unit 1 SG replacement project activities necessitated augmenting the BVPS workforce. During the Unit 1 project, approximately 900 additional workers were on-site to support the project activities. The Unit 1 SG replacement project installation contractor augmented 118 employees with approximately 250 specialty crafts workers and more than 500 members from 10 local unions. The 900 workers were in addition to the 1,000 workers required for normal operations and the 800 temporary workers on-site to support the refueling outage. Site clearing and construction activities for the long-term storage building for the original SGs required approximately 50 additional workers; however, this activity was complete prior to the peak of 900.

In order to avoid underestimating impact to area resources, FENOC assumed that all direct jobs for the Unit 1 SG project were filled by in-migrating residents. Due to the temporary nature of the Unit 1 SG replacement project, the size of the surrounding population (approximately 3,274,451 residents within a 50-mile radius), and the fact that

Attachment L-08-125 Page 7 of 14 most indirect jobs were considered service-related, FENOC assumed that the majority of indirect workers already resided within the 50-mile radius.

This summary of the Unit I SG replacement project demonstrates that the project activities and the impacts of those activities to the environment were minor in nature, were included in a slightly-extended refueling outage, and were effectively bounded by the environmental impacts associated with the normal refueling outage. Due to the similarities between BVPS Unit 1 and Unit 2, the Unit 1 SG replacement project should bound the activities and impacts of a BVPS Unit 2 SG replacement project, should FENOC decide in the future to replace the Unit 2 SGs.

The following discussions detail projected environmental impacts from a postulated BVPS Unit 2 SG replacement project, based on the experience gained from the Unit 1 SG replacement project.

Terrestrial Resources (Refurbishment Impacts)

It is assumed that a BVPS Unit 2 SG replacement project likely would include the construction of a permanent storage building for the spent Unit 2 SGs on a previously-disturbed area of the site near the Waste Handling Building. This approach would result in the use of existing industrial areas rather than the loss of undisturbed terrestrial resources; thus, any potential impacts are expected to be associated more with urbanized wildlife, if any, that exist in those settings. The areas in question currently have a thin covering of low grasses and weeds. However, regardless of the location selected for a postulated new storage building, the appropriate Local, State and Federal ground-disturbance reviews would be performed and the appropriate permits and approvals would be obtained before breaking ground on a new structure, as required by FENOC procedures and policies.

Based on the Unit 1 SG replacement experience gained in 2006, a Unit 2 SG replacement project would have little potential for disturbing or otherwise impacting local flora and fauna. It can be expected that any Unit 2 SGs would be transported from the manufacturer to BVPS in a similar manner as was used with the Unit 1 SGs, and would be moved from the barge slip to the storage area along an on-site service road that was previously upgraded during the Unit 1 SG replacement. Therefore, no natural habitat would be lost or altered. Construction of a storage building likely would occur on a previously-disturbed area on-site; thus no undisturbed habitat is expected to be lost.

The only project effects are expected to be noise and construction impacts on existing wildlife population, possibly disrupting existing behaviors and distribution during the short period of on-site activity. Based on these elements, FENOC concludes that project impacts on terrestrial resources would be SMALL, and no mitigation would be warranted.

Attachment L-08-125 Page 8 of 14 Threatened or Endangered Species ER Section 4.11 addresses endangered, threatened or otherwise sensitive species potentially located at the BVPS site. Based on this information, the only species that may be impacted by a postulated SG replacement at Unit 2 would be mussels that could be located near the barge slip; all other species cited in this section are adequately covered by the normal operating envelope of the plant. The postulated Unit 2 SG replacement project could include maintenance dredging in this area, and it is expected that the dredging permit would prohibit dredging during the spawning season for threatened or endangered aquatic species, generally from February through mid-May. Given that project activities would occur on previously-developed or altered industrial lands on-site, and that maintenance dredging recently occurred for the Unit 1 SG replacement with no apparent impact to endangered mussels, FENOC concludes that project-related impacts to threatened or endangered species would be SMALL, and that further mitigation would not be warranted.

Air Quality During Refurbishment (Nonattainment and Maintenance Areas)

Most Unit 2 SG replacement project activities would likely be performed on equipment inside existing buildings and, therefore, would not generate atmospheric emissions.

However, laydown areas and a SG storage building would be needed to support project activities. FENOC estimates that the disturbed area for building construction and laydown areas would be less than 10 acres. The small amount of disturbed area and implementation of best management practices (e.g., watering, silt fences, covering soil piles, etc.) would minimize the amount of fugitive dust generated during construction.

Also, particulate matter in the form of fugitive dust consists primarily of large particles that settle quickly and thus have minimal adverse public health effects.

During the project, temporary and localized increases in atmospheric concentrations of nitrogen oxides (NOx), carbon monoxide (CO), sulfur dioxide (SO 2 ), volatile organic compounds (VOC), ammonia (NH3 ), and particulate matter (PM) may result from exhaust emissions of motorized equipment and workers' vehicles. All vehicles and motorized equipment would be equipped with standard pollution-control devices to minimize emissions. As discussed in Section 3.3 of the GELS, air quality impacts from these sources would be minor and of short duration.

As discussed in Section 3.4 of the ER, 82 percent of the BVPS site workforce resides in Beaver and Allegheny counties. Therefore, the focus of the air quality analysis is on these two counties. ER Section 2.4 contains a discussion on the U.S. Environmental Protection Agency (EPA) National Ambient Air Quality Standards (NAAQS) that have been established for six common pollutants. All areas of the United States have been classified as having air quality better than (attainment) or worse than (nonattainment) the NAAQS. Beaver County is designated as a nonattainment area for fine particulate matter (PM-2.5) and ground-level ozone. Allegheny County is also designated as a

Attachment L-08-125 Page 9 of 14 nonattainment area for PM-2.5 and ground-level ozone; in addition, it includes maintenance areas for coarse particulate matter (PM-10), SO 2 , and CO.

As noted in GElS Section 3.3, a conformity analysis is required for each pollutant where the total of direct and indirect emissions caused by a proposed federal action would exceed established threshold emission levels in a nonattainment or maintenance area.

Federal conformity rules are defined in 40 CFR Parts 51 and 93. CO, PM-10, and SO 2 emissions are potential sources of concern due to the presence of maintenance areas for these pollutants in Allegheny County. However, the PM-1 0 and S02 violations were caused by industrial stationary sources and motor vehicles were not an important factor.

Consequently, no analysis of transportation related PM-10 and S02 impacts is required (Refs. 1, 2).

Also, EPA approved a limited CO maintenance plan as part of the re-designation of the former Allegheny County nonattainment area. Under limited maintenance plans, EPA policy does not require a CO emission budget test for conformity determinations.

Emission budgets in limited maintenance plan areas are considered to be not constraining for the length of the initial maintenance period (Ref. 3). Therefore, conformity for CO is demonstrated in the county, and no analysis of impacts is required.

Due to the status of Beaver and Allegheny Counties as ground-level ozone non-attainment areas, the generation of NOx and VOC, which combine in the presence of heat and sunlight to create ozone, is a source of concern (Ref. 4). For the Pittsburgh-Beaver Valley ozone area, which includes both Beaver and Allegheny Counties, VOC and NOx emissions budgets for the year 2011 and beyond are 41,444 kilograms per day (Kg/day) and 69,932 Kg/day, respectively (Ref. 4).

Fine particulates (PM-2.5) can result from both direct and indirect sources. Gasoline and diesel fueled vehicles emit both direct PM-2.5 and gases (NOx, SO 2 , VOC, and NH 3) that react in the air to form PM-2.5. The EPA requires NOx emissions to be considered in PM-2.5 conformity assessments, but consideration of SO 2 , VOC, and NH3 emissions is only required if the EPA or the state air agency determine that one or more of these precursors are significant. No such determination has been made for Beaver and Allegheny Counties. Consequently, direct generation of PM-2.5 and the generation of NOx emissions are sources of concern due to the county's status as a PM-2.5 nonattainment area. Submittal of the State Implementation Plan (SIP) for PM-2.5 to the EPA is due soon. Consequently, emission budgets for PM-2.5 are not yet available.

Prior to approval of the PM-2.5 SIP, the Transportation Conformity Rule allows conformity determinations to be based on demonstration that future emissions would be below 2002 levels (Ref. 4). For the Pittsburgh-Beaver Valley nonattainment area, direct PM-2.5 emissions in 2002 were 851.26 tons per year (tpy) and NOx emissions were 51,607.86 tpy (Ref. 4).

Attachment L-08-125 Page 10 of 14 FENOC performed a screening analysis of ground-level ozone and PM-2.5 impacts from 2,300 vehicles traveling to and from BVPS for a period of 70 days. Based on the conservative assumption that each worker would commute 50 miles each way, the total vehicle miles traveled (VMT) during a 70-day refueling outage period would be 16,100,000 miles, approximately 0.08 percent of the projected annual VMT in the Pittsburgh-Beaver Valley area in the year 2011, approximately 0.36 percent of the projected daily VMT during the 2011 ozone season, and an even smaller percentage of the projected VMT in 2020 (Ref. 4). Based on emissions projections provided in the Air Quality Conformity Determination Pittsburgh Transportation Management Area (Ref. 4),

the incremental increase in VMT in the Pittsburgh-Beaver Valley area attributable to postulated BVPS Unit 2 SG replacement project activities would not cause established threshold emission levels to be exceeded. Air quality impacts during SG replacement would be SMALL, and additional mitigation would not be required.

Socioeconomics, Housing Impacts FENOC estimates that 900 temporary employees would be needed to perform the postulated Unit 2 SG replacement project activities. This temporary workforce could generate demand for 900 housing units for a period of up to 70 days. As discussed in ER Sections 2.5 and 2.9, the BVPS site is in an area ranked in the high population category according to NRC criteria. In addition, Beaver and Allegheny Counties encourage development in areas that can be served by existing infrastructure. Project activities may increase the demand for housing in the area, but the increase would be temporary and the housing market is very large. Based on FENOC experience during the Unit 1 steam generator replacement in 2006, an adequate number of housing units are expected to be available to accommodate the project workforce. Therefore, FENOC expects project related housing impacts to be SMALL and additional mitigation would not be necessary.

Socioeconomics, Public Services, Educatioon (Refurbishment)

Based on FENOC experience from BVPS refueling outages and from the Unit I SG replacement in 2006, it is anticipated that the 900 temporary workers are either already located in the area, or would in-migrate but would not relocate families to the plant site region for a project of this short duration. Therefore, FENOC estimates that few to no children would be relocated to the region, and there would be essentially NO impact to the education system.

Socioeconomics, Offsite Land Use (Refurbishment)

FENOC estimates that up to 900 temporary employees could be needed to perform the project activities associated with a postulated Unit 2 SG replacement effort. The

Attachment L-08-125 Page 11 of 14 estimate also stipulates that additional indirect jobs would be filled by residents, resulting in no additional population growth.

In GElS Section 3.7.5, NRC stated that, if project-related population growth is less than 5 percent of the study area's total population, off-site land-use changes would be small, especially if the study area has established patterns of residential and commercial development, a population density of at least 60 persons per square mile, and at least one urban areawith a population of 100,000 or more within 50 miles.

ER Section 3.4 indicates that 82 percent of the BVPS workforce resides in Beaver and Allegheny counties. BVPS is located in Beaver County, and Allegheny is the location of Pittsburgh. FENOC assumes that the project workforce would find temporary residences within this area. ER Table 2.5-1 indicates that the 2000 population for Beaver County was 181,412 and for Allegheny County it was 1,281,666, for a total of 1,463,078. Five percent of this value is 73,154. The project-related temporary population growth of 900 is much less than 5 percent of the study area's total population.

Section 2.9 describes land use planning in Beaver and Allegheny counties, including patterns of residential and commercial development. The counties contain a combined total of approximately 761,000 acres, or 1,189 square miles, resulting in a population density of approximately 1,231 persons per square mile. ER Table 2.5-2 indicates that the Pittsburgh 2000 population was 334,563.

In summary, the BVPS area satisfies the GElS criteria for predicting that project-related offsite land use changes would be small. Due to the small number of project workers compared to the area's total population, available residential and commercial development, proximity to a major metropolitan area, the short duration of a postulated Unit 2 SG replacement project, and its direct experience with the Unit 1 SG replacement project, FENOC expects that project-related off-site land use changes would be SMALL, if not undetectable, and would not warrant mitigation.

Socioeconomics, Public Services, Transportation (Refurbishment)

As FENOC notes in ER Section 2.8.2, access to the BVPS site is via State Route (SR) 168, and the major commuting routes used by BVPS site employees are in rural and uncongested areas. Historically, increased traffic during outages has not degraded the capacity of local roads. Additionally, the increased worker population for the Unit 1 outage which included steam generator replacements did not create the need for additional or widening of roads, or traffic control devices. FENOC routinely employs personnel to direct traffic during high volume periods, including morning and afternoon shift changes during normal operation, which ensures efficient traffic flow on SR 168 at the site.

Attachment L-08-125 Page 12 of 14 The Council for the Borough of Shippingport stated in a letter to FENOC that it does not anticipate the need to increase the number of roads or traffic lanes for a potential Unit 2 SG replacement project that would include 900 temporary workers for a period of 70 days. In addition, the Beaver County Planning Department has not identified any of the major commuting routes to BVPS as deficient due to limited capacity or physical condition (see ER Section 2.8.2). Finally, as described in ER Section 2.5.1, BVPS is located in an area of declining population; therefore, traffic volumes are not expected to increase. On the basis of these considerations, and the traffic counts and classifications for SR 168 and commuting routes to the BVPS site as described in ER Section 2.8.2 and Table 2.8-1, FENOC concludes that impacts to transportation from a Unit 2 SG replacement would be SMALL, and would not warrant mitigation.

Historic and Archaeological Resources The only postulated Unit 2 SG replacement project activity involving ground disturbance is expected to be the construction of the storage building for the old Unit 2 SGs. The likely site of this construction would be adjacent to the existing Waste Storage Building and the storage building for the old Unit 1 SGs and reactor head. This area, on the back side of the switchyard opposite the station, was graded and otherwise disturbed during station construction.

The Pennsylvania Historical & Museum Commission, Bureau for Historic Preservation (SHPO), recently approved an Integrated Cultural Resources Management Plan (ICRMP) (see FENOC Letter L-08-107 to NRC dated April 2, 2008) for BVPS. Besides evaluating local potential archeological, cultural, and historic resources, the ICRMP provides the methodology to ensure operation of BVPS adequately considers those resources into the future. For instance, the ICRMP includes a site plan that depicts areas in which further consultation with SHPO is not required before conducting land disturbing activities. The ICRMP also provides additional guidance to ensure protection of cultural resources (e.g., inadvertent discovery of an archeological artifact during excavation) by providing details and steps to revise excavation and environmental evaluation procedures.

All activities associated with a postulated Unit 2 SG replacement, including construction and excavation, would likely occur in previously disturbed and evaluated areas that do not require further consultation with SHPO prior to commencing work. These activities also include the likely delivery of the new SGs to the BVPS barge slip and transportation of the SGs onsite. Based on the Unit 1 SG replacement project experience and the ICRMP, FENOC concludes that a Unit 2 SG replacement would have NO impact on archeological, cultural, or historic resources.

Attachment L-08-125 Page 13 of 14 Socioeconomics, Public Utilities: Public Water Supply Availability FENOC estimates that 900 temporary employees would be needed to perform the postulated Unit 2 SG replacement project activities for a period of up to 70 days. The estimate also stipulates that additional indirect jobs would be filled by residents, resulting in no additional population growth. ER Section 3.4 indicates that 82 percent of the BVPS workforce resides in Beaver and Allegheny counties. FENOC assumes that the project workforce would find temporary residences within this area and the workers would not relocate their families.

In GElS Section 3.7.4.5, NRC stated that, impacts on public utility services are considered small if little or no change occurs in the ability to respond to the level of demand. ER Section 2.8.1 describes the public water supply systems in Allegheny and Beaver Counties. BVPS acquires potable water from the Midland Water Authority, which has excess capacity of 2.1 million gallons per day. The combined water systems in both counties have a total excess capacity of approximately 93.1 million gallons per day.

The maximum *impact to the local water supply systems from the project workforce was determined by calculating the amount of water that would be required by the temporary workforce for the postulated Unit 2 SG replacement project. The average American uses between 50 and 80 gallons per day for personal use. Conservatively assuming that each temporary employee used 80 gallons per day while at the BVPS site, the additional maximum usage at BVPS would be 72,000 gallons per day. Therefore, FENOC concludes that impacts resulting from the temporary work force at BVPS would be SMALL and would not require mitigation.

Also conservatively assuming that each temporary employee also used 80 gallons per day while in their temporary residences, the additional maximum usage in the two-county region of interest would be 72,000 gallons per day. Therefore, FENOC concludes that impacts resulting from the temporary work force in their counties of residence would be SMALL and would not require mitigation.

Environmental Justice The NRC provides guidance for conducting environmental justice reviews in Appendix D of NRR Office Instruction LIC-203, Revision 1, "Procedural Guidance for Preparing Environmental Assessments and Considering Environmental Issues." The NRC guidance makes clear that if no potentially significant impacts are anticipated from the proposed action, then "...these results should be documented and the environmental justice review is complete."

For each issue analyzed above, FENOC has concluded that the environmental impacts of the postulated Unit 2 S/G replacement project would result in no significant impacts

Attachment L-08-125 Page 14 of 14 and would be SMALL. Therefore, FENOC concludes that there would be NO disproportionately high and adverse impacts on any member of the public, including minority and low-income populations, and mitigation would not be warranted.

REFERENCES

1. U. S. Environmental Protection Agency; Region 3 Plan Summary Allegheny County, Pennsylvania PM-10 Maintenance Plan. Available online at http://yosemite.epa.gov/r3/r3sips.nsf/e0bfe0e1al 6a9de685256d250052d65e/7df92 ddfcb7e3l e285256dab006ce7a7/$FILE/plan_summaryalleghenycountypapm 10_maintenanceplan.pdf. Accessed March 2008

2. U. S. Environmental Protection Agency; Region 3 Plan Summary Allegheny County, Pennsylvania Sulfur Dioxide (SO 2 ) Maintenance Plan. Available online at http://yosemite.epa.gov/r3/r3sips.nsf/e0bfe0e1 al 6a9de685256d250052d65e/3e32 bec0af5ca08385256ed9006b7639/$F ILE/plan_su mmaryalleghenycountypa_S 02_maintenanceplan.pdf. Accessed March 2008

3. U. S. Environmental Protection Agency; Region 3 Plan Summary Allegheny County, Pennsylvania Carbon Monoxide Maintenance Area. Available online at http://yosemite.epa.gov/r3/r3sips.nsf/e0bfe0e1 al 6a9de685256d250052d65e/da62 a241 54e3979e85256dab006e07d 3/$ FI LE/plan_su mmaryalleg henycou ntypa_c o_maintenance plan.pdf. Accessed March 2008

4. Southwestern Pennsylvania Commission. Air Quality Conformity Determination Pittsburgh Transportation Management Area for the 8-Hour Ozone Standard and PM-2.5 Air Quality Standards, Final Report. June 2007. Available online at http://www.spcregion.org/pubair.shtml. Accessed March 2008