ML102870233
| ML102870233 | |
| Person / Time | |
|---|---|
| Site: | Bellefonte  |
| Issue date: | 10/08/2010 |
| From: | Pratt D Tennessee Valley Authority |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| Download: ML102870233 (5) | |
Text
Tennessee Valley Authority, 1101 Market Street, Chattanooga, Tennessee 37402-2801 October 08, 2010 10 CFR 50.55(b)
U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555-0001 In the Matter of
)
Docket No. 50-438 Tennessee Valley Authority )
TENNESSEE VALLEY AUTHORITY (TVA) - BELLEFONTE NUCLEAR PLANT (BLN)
UNIT I - REQUEST FOR EXTENSION OF CONSTRUCTION PERMIT CPPR-122
References:
- 1. Letter from NRC to TVA, "Bellefonte Nuclear Plant, Units 1 and 2 -
Order Granting Reinstatement of Construction Permits Nos. CPPR-122 and CPPR-123," dated March 9, 2009 [ML090610237].
- 2. Letter from NRC to TVA, "Bellefonte Nuclear Plant, Units 1 and 2 -
Extension of Construction Permit Expiration Dates (TAC Nos.
MB2549 & MB2550)," dated March 4, 2003 [ML012290092].
TVA Board of Directors' Decision Funding the Next Project Phase During Fiscal Year 2011," dated August 30, 2010.
- 4. Letter from NRC to TVA, "Bellefonte Nuclear Plants, Units 1 and 2 -
Regarding Key Assumptions for Reactivation," dated August 4, 2010
[ML101880337].
By letter and accompanying Order dated March 9, 2009, the NRC granted TVA's request to reinstate Construction Permits CPPR-122 (BLN Unit 1) and CPPR-123 (BLN Unit 2)
(Reference 1). Under current Construction Permit CPPR-1 22, the latest completion date for BLN Unit 1 is October 1, 2011.1 The purpose of this letter is to request that the NRC further extend Construction Permit CPPR-122 to October 1, 2020. This additional time 1 NRC's letter to TVA, "Bellefonte Nuclear Plant, Units 1 and 2 - Extension of Construction Permit Expiration Dates" dated March 4, 2003, granted TVA's request for extension of CPPR-122 to October 1,2011, and CPPR-123 to October 1, 2014 (Reference 2). As mentioned above, NRC issued a subsequent Order granting reinstatement of CPPR-122 and CPPR-123, restating these expiration dates in accordance with 10 CFR 50.55(b) (Reference 1).
U.S. Nuclear Regulatory Commission Page 2 October 08, 2010 would allow TVA to either complete construction of Unit 1 should TVA decide to move forward with project approval (see Reference 3), or allow TVA to continue to preserve and maintain Unit 1 in a deferred status as a valuable asset pending a longer term determination of generation needs to meet future electrical demand.
Consistent with TVA's stated objective to use its existing facilities to the greatest extent possible to meet future electrical power demands, TVA has determined that it is prudent to consider adding the partially completed BLN units to its mix of base-load generating options. Reinstatement of the BLN Units 1 and 2 Construction Permits has allowed TVA and the NRC to establish key regulatory assumptions for the possible completion of the plant (Reference 4) and for TVA to begin work on a more detailed regulatory framework and plant licensing basis for consideration by.NRC. On August 20, 2010, TVA's Board of Directors approved a budget allocation in support of continued engineering, design, and regulatory-basis development, as well as the procurement of long-lead components such as steam generators for BLN Unit 1 in order to preserve the option of timely completion. This will help ensure that Unit 1 continues to be a viable alternative for meeting base-load power needs in the 2018-2020 timeframe. The TVA Board has reserved its ability to determine whether to proceed with construction and completion of Bellefonte Unit 1, beyond the scope of the above budget allocation, following completion of TVA's Integrated Resource Planning process, which is scheduled for the spring of 2011.
The environment at the Bellefonte site was permanently altered by the construction of the main plant facilities in the 1970s. The environmental impacts of constructing and operating BLN Unit 1 (as well as Unit 2 in the majority of the reviews) have been well documented and addressed. The latest public documentation is contained in the Final Supplemental Environmental Impact Statement (FSEIS), Single Nuclear Unit at the Bellefonte Plant Site, which was released in May 2010. In addition to documenting the status and history of the site, the FSEIS updates TVA's plans for completingBLN Unit 1, and the associated environmental effects of that action based on a detailed scoping, estimating and planning study. The FSEIS informed decision makers and the public about the potential environmental impacts that would result from a decision to complete and operate a single Babcock & Wilcox unit or to construct and operate a new Westinghouse AP1000 unit at the Bellefonte site.2 For your information, we are 2 Construction and operational impacts at BLN have been well studied by TVA over the years.
The May 2010 FSEIS supplements and updates the original TVA Final Environmental Statement for Bellefonte Nuclear Plant Units 1 and 2 (May 1974); the TVA Final Environmental Impact Statement for the Bellefonte Conversion Project (October 1997); the U.S. Department of Energy's Final Environmental Impact Statement for the Production of Tritium in a Commercial Light Water Reactor (March 1999), which TVA adopted; and the TVA Bellefonte Nuclear Plant Units 3 and 4, Combined License Application Part 3, Environmental Report, Revision 1 (October 2008). The final SEIS also tiers from and incorporates by reference two TVA programmatic reviews, Energy Vision 2020 Integrated Resource Plan Final Programmatic Environmental Impact Statement (December 1995) and Reservoir Operations Study Final Programmatic Environmental Impact Statement (May 2004). In addition, TVA completed an Environmental Assessment, Activities at Bellefonte Nuclear Plant Related to Future Site Use (July 2008), in connection with TVA's request that NRC reinstate the Construction Permits and reinstituted protective measures in place before the permits were terminated. In June 2009, TVA began work on a new Integrated Resource Plan for meeting future demand on the TVA power system over the next 20 years.
U.S. Nuclear Regulatory Commission Page 3 October 08, 2010 providing a copy of TVA's May 2010 FSEIS (Enclosure 1). The FSEIS identifies TVA's preferred alternative as the completion and operation of BLN Unit 1 (CPPR-122). The conclusions of the FSEIS demonstrate that the environmental impacts associated with completion of a single nuclear unit at the Bellefonte site are consistent with the environmental impacts previously considered by the NRC when the BLN Units 1 and 2 Construction Permits were last extended in 2003 (Reference 2), as well as those considered by the NRC to support reinstatement of the Construction Permits in 2009 (Reference 1). No additional change to the existing Construction Permit is requested, and the scope of activities authorized by the Construction Permits would not change.
No decision to build or complete any new generating capacity at the Bellefonte site has been made at this time; however, TVA considers it imperative to maintain CPPR-122 (and CPPR-123, in which the latest construction completion date is October 1, 2014) in order to maintain a flexible range of generating options and alternatives for future base-load power supplies and competitive energy production choices. TVA will continue to comply with the terms and conditions of these Construction Permits as required by NRC regulations, including NRC's Deferred Plant Policy. TVA's history of past actions in conformance with the terms and conditions of these Construction Permits provides the NRC with a high level of assurance that public health and safety will continue to be protected.
If construction resumes, TVA would undertake those activities necessary to complete construction pursuant to a schedule'that supports full power operation by May 2018.
TVA would also conduct all completion activities in a deliberate and careful manner, mindful and taking full account of those measures necessary to ensure that the health and safety of workers and the general public is protected. The requested extension includes a reasonable amount of time to allow for adjustments to the schedule as may become necessary. The requested extension will also allow TVA to continue to preserve and maintain Unit 1 in a deferred status as a valuable asset pending a longer term determination of generation needs to meet future electrical demand.
The only modification proposed by TVA to the existing Construction Permit (CPPR-122) is an extension of the latest completion date. As stated previously, this extension would not allow any work to be performed of a type not previously authorized by the existing construction permit. As TVA is not seeking authorization for activities not previously authorized, this request does not involve a significant increase in the probability or consequences of an accident previously evaluated, create the possibility of a new or different kind of accident from any accident previously evaluated, or involve a significant reduction in a margin of safety.
For the foregoing reasons, TVA submits, in accordance with 10 CFR 50.55(b), that good cause exists for the extension of Construction Permit CPPR-122 and that the extension is for a reasonable period of time.
No regulatory commitments are identified in this letter. If you have any questions concerning this matter, please call Zackary W. Rad at (256) 574-8265.
U.S. Nuclear Regulatory Commission Page 4 October 01, 2010 I declare under penalty of perjury that the foregoing is true and correct.
Executed on this, the 1st day of October, 2010.
Respectfull Daniel Pratt General Manager Bellefonte Project
Enclosure:
- 1. Final Supplemental Environmental Impact Statement - "Single Nuclear Unit at the Bellefonte Plant Site, Jackson County, Alabama," dated May, 2010.
cc: (see page 5)
U.S. Nuclear Regulatory Commission Page 5 October 08, 2010 cc:
Eric Leeds, Director U.S. Nuclear Regulatory Commission One White Flint North, 13H16M 11545 Rockville Pike Rockville, Maryland 20852-2738 Stephen J. Campbell U.S. Nuclear Regulatory Commission One White Flint North, 8H4A 11545 Rockville Pike Rockville, Maryland 20852-2738 Patrick D. Milano U.S. Nuclear Regulatory Commission One White Flint North, 8C2 11545 Rockville Pike Rockville, Maryland 20852-2738 Lakshminarasimh Raghavan U.S. Nuclear Regulatory Commission One White Flint North, 8H4A 11545 Rockville Pike Rockville, Maryland 20852-2738 Mr. Luis A. Reyes, Regional Administrator U.S. Nuclear Regulatory Commission Region II Marquis One Tower 245 Peachtree Center Avenue N.E., Suite 1200 Atlanta, GA 30303 Loren R. Plisco, Deputy Regional Administrator for Construction U.S. Nuclear Regulatory Commission Region II Marquis One Tower 245 Peachtree Center Avenue N.E., Suite 1200 Atlanta, GA 30303