ML022270455
"Draft Supplement" is not in the list (Request, Draft Request, Supplement, Acceptance Review, Meeting, Withholding Request, Withholding Request Acceptance, RAI, Draft RAI, Draft Response to RAI, ...) of allowed values for the "Project stage" property.
| ML022270455 | |
| Person / Time | |
|---|---|
| Site: | Catawba  |
| Issue date: | 08/09/2002 |
| From: | Tuckman M Duke Energy Corp, Duke Power Co |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| GSI-189, NUREG-1437 | |
| Download: ML022270455 (16) | |
Text
S Duke Duke Power Power.
526 South Church St. EC07H A DkEnryCmCharlotte, NC 28202 A Duke Energy Company P.O. Box 1006 EC07H Charlotte, NC 28201-1006 M. S. Tuckman (704) 382-2200 OFFICE Executive Vice President (704) 382-4360 FAX Nuclear Generation August 9, 2002 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555
Subject:
Comments on draft plant-specific Supplement 9 to NUREG-1437, "Generic Environmental Impact Statement for License Renewal of Nuclear Power Plants" Catawba Nuclear Station, Docket Nos. 50-413 and 50-414 By letter dated June 13, 2001, Duke Energy Corporation (Duke) submitted an Application to Renew the Facility Operating Licenses of McGuire Nuclear Station and Catawba Nuclear Station (Application). The staff has reviewed the information provided in the Environmental Report contained in the Application as well as the information provided in Duke letters dated February 1 and 8, 2002. By letter dated May 14, 2002, the staff forwarded a copy of the draft plant-specific Supplement 9 to NUREG-1437, "Generic Environmental Impact Statement for License Renewal of Nuclear Power Plants" for McGuire and provided Duke the opportunity to submit comments.
Accordingly, please find Duke comments on draft Supplement 9 to NUREG-1437.
In addition to providing comments on the draft Supplement 9, Duke is also in the process of reviewing the conclusions contained in Section 5.2.7 of the draft Supplement 9. In this section, the staff concluded that two of the severe accident mitigation alternatives (SAMAs): one related to hydrogen control in SBO sequences is cost beneficial under certain assumptions, which are being examined in connection with the resolution of GSI-189, "Susceptibility of Ice-Condenser and Mark III Containments to Early Failure from Hydrogen Combustion During a Severe Accident" and a second SAMA related to the installation of flood protection around the 6900/4160 volt transformers. Duke is in the process of reviewing both of these SAMA and has provided its position in a separate letter dated August 8, 2002.
If there are any questions, please contact either Bill Miller at (704) 373-7900 or Bob Gill at (704) 382-3339.
Very truly yours, M. S. Tuckman Attachment
U.S. Nuclear Regulatory Commission Document Control Desk August 9, 2002 Page 2 Affidavit M. S. Tuckman, being duly sworn, states that he is Executive Vice President, Nuclear Generation Department, Duke Energy Corporation; that he is authorized on the part of said Corporation to sign and file with the U. S. Nuclear Regulatory Commission the attached comments on draft plant-specific Supplement 8 to NUREG-1437, "Generic Environmental Impact Statement for License Renewal of Nuclear Power Plants," and that all the statements and matters set forth herein are true and correct to the best of his knowledge and belief. To the extent that these statements are not based on his personal knowledge, they are based on information provided by Duke employees and/or consultants. Such information has been reviewed in accordance with Duke Energy Corporation practice and is believed to be reliable.
M. S. Tuckman, Executive Vice President Duke Energy Corporation Subscribed and sworn to before me this q1.1k day of
- 9 !L*t 2002.
Notary Pub c My Commission Expires:
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U.S. Nuclear Regulatory Commission Document Control Desk August 9, 2002 Page 3 xc: (w/ Attachment)
L. A. Reyes Regional Administrator, Region II U. S. Nuclear Regulatory Commission Atlanta Federal Center 61 Forsyth Street, SW, Suite 23T85 Atlanta, GA 30303 D. B. Matthews Director, Division of Regulatory Improvement Programs Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, DC 20555 Senior NRC Resident Inspector McGuire Nuclear Station Senior NRC Resident Inspector Catawba Nuclear Station C.P. Patel Senior Project Manager Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, DC 20555 P. T. Kuo Program Director, License Renewal and Environmental Impacts Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, DC 20555 R. L. Franovich Senior Project Manager Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, DC 20555 R. E. Martin Senior Project Manager Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, DC 20555
U.S. Nuclear Regulatory Commission Document Control Desk August 9, 2002 Page 4 xc: (w/ Attachment)
Henry J. Porter Assistant Director, Division of Waste Management Bureau of Land & Waste Management S.C. Department of Health and Environmental Control 2600 Bull St.
Columbia, SC 29201 North Carolina Municipal Power Agency Number 1 1427 Meadowwood Boulevard P.O. Box 29513 Raleigh, NC 27626 Piedmont Municipal Power Agency 121 Village Drive Greer, SC 29651 R. M. Fry Director, Division of Radiation Protection North Carolina Department of Environment, Health, and Natural Resources 3825 Barrett Drive Raleigh, NC 27609 North Carolina Electric Membership Corporation P.O. Box 27306 Raleigh, NC 27611 Saluda River Electric Cooperative, Inc.
P. 0. Box 929 Laurens, SC 29360 Comments on Draft Plant-Specific Supplement 9 to NUREG-1437, "Generic Environmental Impact Statement for License Renewal of Nuclear Power Plants" Catawba Nuclear Station, Units 1 and 2 Comments on Draft NUREG-1437, Supplement 9 Catawba Nuclear Station, Units I and 2 Chapter Executive Summary Section Not Applicable Comment Page Line Comment Number 1
xix 12-14 The staff's conclusion statement contained in these lines contradicts the staff conclusion statement contained in Section 5.2.7, page 5-28, lines 20-21.
Chapter 1.0 Introduction Section 1.5 Compliance and Consultations Comment Page Line Comment Number 2
1-9 8
From Table 1-1, under Column reading "Permit Expiration or Consultation Date":
The permit expiration date is listed as "April 30, 2006".
The NPDES permit issue date was April 30, 2001, however the permit was not issued until well into the 5 year cycle. Therefore the expiration date on the permit is not the full 5 years from date of issue.
I Correct the permit expiration date to be "June 30, 2005".
2.0 Description of Nuclear Power Plant and Site and Plant Interaction with the Environment 2.1.2 Reactor Systems, Page 1 Chapter Section
Attachment I Comments on Draft NUREG-1437, Supplement 9 Catawba Nuclear Station, Units I and 2 Chapter 2.0 Description of Nuclear Power Plant and Site and Plant Interaction with the Environment Section 2.1.7 Power Transmission Systems Comment Page Line Comment Number 4
2-14 14 The term "conservation easements" should be replaced with "protection of rare species".
Duke does not currently have conservation easements with SCDNR for transmission ROWs.
Chapter 2.0 Description of Nuclear Power Plant and Site and Plant Interaction with the Environment Section 2.2.1 Land Use Comment Page Line Comment Number 5
2-14 34 "4916 ha (12,139 ac)" should read "4,917 ha (12,149 ac)"
6 2-14 35 The statement "Full pond was achieved in 1904..." is somewhat misleading. Construction of a much smaller dam was completed in 1904. This dam was completely covered by the current and much larger Wylie dam which resulted in a significantly larger reservoir.
Change the statement to read: "The lake was initially impounded in 1904. Present full pond was obtained in 1924 with an increase in the dam height.
7 2-16 1
"Duke owns the land that underlays the lake..." is not entirely correct.
Change the statement to read: "Duke either owns the land under the lake or owns flood rights to the land under the lake".
8 2-16 9
The fenced cemetery referenced as part of the site is not part of Catawba Nuclear site. The site is owned and I
I
_ 1
_ 1operated by the Concord Cemetery Association., Page 2 Comments on Draft NUREG-1437, Supplement 9 Catawba Nuclear Station, Units I and 2 Chapter 2.0 Description of Nuclear Power Plant and Site and Plant Interaction with the Environment Section 2.2.8.1 Housing Comment Page Line Comment Number 9
2-27 24-25 From Table 2-4, under Column reading "Number of Personnel":
Currently reads:
Other - NC 95 Other-SC 96 In order to correctly reflect the number counts as given in Table 2-5, change to:
Other-NC 112 Other - SC 79 Chapter 2.0 Description of Nuclear Power Plant and Site and Plant Interaction with the Environment Section 2.2.8.2 Public Services Comment Page Line Comment Number 10 2-32 24-25 Lines Read:
"There are 24 counties within the 80-km (50 mi) radius of the Catawba site: 13 in South Carolina and 10 in North Carolina. The 23-county area is served by 3 major interstate freeways."
Correct the sentences to read:
"There are 24 counties within the 80-km (50 mi) radius of the Catawba site: 11 in South Carolina and 13 in North Carolina. The 24-county area is served by 3 major interstate freeways.", Page 3
Attachment I Comments on Draft NUREG-1437, Supplement 9 Catawba Nuclear Station, Units I and 2 Chapter 2.0 Description of Nuclear Power Plant and Site and Plant Interaction with the Environment Section 2.2.8.4 Visual Aesthetics and Noise Comment Page Line Comment Number 11 2-36 5
"4912 ha (12,139 ac)" should read "4,917 ha (12,149 ac)"
Chapter 2.0 Description of Nuclear Power Plant and Site and Plant Interaction with the Environment Section 2.2.8.5 Demography Comment Page Line Comment Number 12 2-38 31 "4912 ha (12,139 ac)" should read "4,917 ha (12,149 ac)"
13 2-38 34 Duke owns eight (not nine) public recreational access locations on Lake Wylie and one additional access location immediately downstream of the lake. Of these nine access areas, only two (not 3) are leased to other operators.
Chapter 2.0 Description of Nuclear Power Plant and Site and Plant Interaction with the Environment Section 2.2.9.2 Historic and Archaeological Resources at Catawba Comment Page Line Comment Number 14 2-48 25 The Concord Cemetery is not located within the Catawba site, but adjacent to it. The cemetery is owned and operated by the Concord Cemetery Association.
15 2-48 37 The Concord Cemetery is not located within the Catawba site, but adjacent to it. The cemetery is owned and 1 operated by the Concord Cemetery Association., Page 4 Comments on Draft NUREG-1437, Supplement 9 Catawba Nuclear Station, Units I and 2 Chapter 2.0 Description of Nuclear Power Plant and Site and Plant Interaction with the Environment Section 2.2.10 Related Federal Project Activities and Consultations Comment Page Line Comment Number 16 2-49 22 Line Reads:
"This lake was formed by impounding the water of the Catawba River, and full pond was achieved in 1904."
Correct the sentence to read:
"This lake was formed by impounding the water of the Catawba River in 1904."
17 2-49 24 "4912 ha (12,139 ac)" should read "4,917 ha (12,149 ac)"
Chapter 4.0 Environmental Impacts of Operation Section 4.1.2 Microbiological Organisms (Public Health)
Comment Page Line Comment Number 18 4-14 40-41 Statement reads: Based on Catawba-specific experience, a review of available technical literature on thermophilic organisms, and the fact that there is little heated This sentence is incomplete., Page 5 Comments on Draft NUREG-1437, Supplement 9 Catawba Nuclear Station, Units I and 2 Chapter 5.0 Environmental Impacts of Postulated Accidents Section 5.2.2.1 Duke's Risk Estimates Comment Page Line Comment Number 19 5-6 20 5.8E-05/ry should be 5.8E-05/yr Duke's reported risk estimates are base on a calendar year basis, not a reactor year basis. The capacity factor used in the PRA is 0.9.
20 5-6 25 "per reactor-year" should be "per year" 2 cases 21 5-7 17 Table 5 Heading "Frequency (per reactor-year)"
should be Frequency (per year) 22 5-8 23 "reactor-year" should be "year" 23 5-8 26 "per reactor-year" should be "per year" 24 5-9 2
"per reactor-year" should be "per year" 25 5-9 3
"per reactor-year" should be "per year" Chapter 5.0 Environmental Impacts of Postulated Accidents Section 5.2.2.2 Review of Duke's Risk Estimates Comment Page Line Comment Number 26 5-11 10 "per reactor-year" should be "per year", Page 6 Comments on Draft NUREG-1437, Supplement 9 Catawba Nuclear Station, Units I and 2 Chapter 5.0 Environmental Impacts of Postulated Accidents Section 5.2.3.1 Process for Identifying Potential Design Improvements Comment Page Line Comment Number 27 5-12 25 "per reactor-year" should be "per year" 28 5-12 29 "per reactor-year" should be "per year" 29 5-14 Table 5-5 Footnote (a) "per reactor-year" should be "per year" 30 5-14 Table 5-5 Footnote (b) "per reactor-year" should be "per year" 31 5-15 10 Table 5 The cost of enhancement provided by Duke for the back-up power to the igniters ($540,000) is a per unit cost and should not be divided by 2.
One of the major cost categories for the candidate modification is in the installation labor, primarily pulling cables. It was judged that finding a location for the diesel that would allow it to serve either unit would dramatically increase the cable pulling cost component.
As such, it was judged that having a diesel for each unit would be less expensive (given the low cost of the hardware) than pulling cables to both units from a single location.
32 5-15 22 Table 5 Delete Footnote (c)
Chapter 5.0 Environmental Impacts of Postulated Accidents Section 5.2.4 Risk Reduction Potential of Design Improvements Comment Page Line Comment Number 33 5-17 28 "per reactor-year" should be "per year" 34 5-17 29 "per reactor-year" should be "per year" 35 5-17 35 "per reactor-year" should be "per year", Page 7
Attachment I Comments on Draft NUREG-1437, Supplement 9 Catawba Nuclear Station, Units I and 2 Chapter 5.0 Environmental Impacts of Postulated Accidents Section 5.2.5 Cost Impacts of Candidate Design Improvements Comment Page Line Comment Number 36 5-19 17
"$205,000 per site" should be "$205,000 per unit" see comment 28 37 5-19 24
"$540,000 per site" should be "$540,000 per unit see comment 28 38 5-19 27-29 The sentence, "In order to provide..." should be deleted as it is not appropriate to divide these costs by 2.
39 5-19 36-38 The sentence, "Duke further noted that..." should be modified. The discussion that Duke provided relative to powering the air-return fans was in the context of powering the igniters. The mixing afforded by the fans may or may not be significant to the effectiveness of PARs, but in any case Duke provided no position on the need for fans when using PARs.
Chapter 5.0 Environmental Impacts of Postulated Accidents Section 5.2.6.1 Duke Evaluation Comment Page Line Comment Number 40 5-22 34 3.81E+08 should be 3.1E+08 see page 12 of Attachment H, Page 8 Comments on Draft NUREG-1437, Supplement 9 Catawba Nuclear Station, Units I and 2 Chapter 5.0 Environmental Impacts of Postulated Accidents Section 5.2.6.2 Staff Evaluation Comment Page Line Comment Number 41 5-25 14 "30 percent" should be "24 percent" See Table 5-3 of the SEIS 42 5-25 29 "per reactor-year" should be "per year" 43 5-25 30 "per reactor year" should be "per year" 44 5-26 3-5 The discussion concerning NUREG/CR-6427 should more accurately characterize the insights from the NUREG. This NUREG provided a simplified level 2 analysis for the purpose of investigating the importance of DCH. The conservative assumptions applied in this analysis with regard to hydrogen generation and the probability of ignition make it useful for understanding the uncertainties associated with early containment failure probabilities. The NUREG should not be interpreted as the latest information with respect to a realistic or best-estimate evaluation of the potential for early containment failure as a result of hydrogen combustion during station blackouts.
45 5-26 3
"per reactor-year" should be "per year" 46 5-26 20 "per reactor-year" should be "per year" 2 cases 47 5-27 5 & 9 Table 5 $270,000 should be $540,000 and $102,5000 should be $205,000 The cost provided by Duke are per unit costs and should not be divided by 2 48 5-27 11-13 Table 5 Delete Footnote (a), Page 9
Attachment I Comments on Draft NUREG-1437, Supplement 9 Catawba Nuclear Station, Units I and 2 Chapter 6.0 Environmental Impacts of the Uranium Fuel Cycle and Solid Waste Management Section 6.1 The Uranium Fuel Cycle Comment Page Line Comment Number 49 6-6 25 This page presents a brief chronology of events that have occurred in the area of high level waste disposal subsequent to the GEIS being published in 1996. The chronology ends at the President's recommendation in February 2002.
While it may seem a bit odd for this type of information to be contained in an environmental document, Duke believes that the chronology should remain in the SEIS and should be updated to reflect significant events that have taken place since then. For example:
"On April 8, 2002, Governor Guinn of Nevada issued a "Notice of Disapproval" regarding the recommendation of the President. As required by the Nuclear Waste Policy Act, the matter was then referred to the Congress.
Subsequently, [insert final decision of Congress and date]."
Chapter Chapter 8.0 Environmental Impacts of Alternatives to Operating License Renewal Section Section 8.2.2.1 Oil and Natural-Gas-Fired (Combined Cycle) Closed-Cycle Cooling System Comment Page Line Comment Number 50 8-32 23 Reference to SCDNR should be replaced with SCDHEC, Page 10 Comments on Draft NUREG-1437, Supplement 9 Catawba Nuclear Station, Units 1 and 2 Chapter Chapter 8.0 Environmental Impacts of Alternatives to Operating License Renewal Section Section 8.2.3.1 Nuclear Power Generation - Closed-Cycle Cooling System Comment Page Line Comment Number 51 8-41 18 Reference to SCDENR should be replaced with SCDHEC Chapter Appendix E Section Table E-1, Page 11