ML13189A033
| ML13189A033 | |
| Person / Time | |
|---|---|
| Site: | Watts Bar, 07007018  |
| Issue date: | 07/01/2013 |
| From: | O'Dell J Tennessee Valley Authority |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| TAC L33242 | |
| Download: ML13189A033 (8) | |
Text
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9-Tennessee Valley Authority, Post Office Box 2000, Spring City, Tennessee 37381-2000 July 1, 2013 10 CFR 70.33 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555-0001 Watts Bar Nuclear Plant, Unit 2 NRC Docket No. 50-391
Subject:
Watts Bar Nuclear Plant (WBN) Unit 2 - Response to Request for Additional Information Regarding 10 CFR Part 70 Special Nuclear Material License Renewal (TAC No. L33242)
Reference:
- 1. NRC Letter to TVA dated May 24, 2013, Request for Additional Information Regarding Watts Bar Nuclear Plant Unit 2 Part 70 License Renewal
- 2. TVA Letter to NRC dated August 23, 2012, Watts Bar Nuclear Plant (WBN) - Unit 2 - Request for renewal of Special Nuclear Material (SNM) License No. SNM-2014 The purpose of this letter is to respond to the NRC Request for Additional Information (RAI) related to renewal of Special Nuclear Material License (SNM) SNM-2014 provided in Reference 1. provides the requested information.
U.S. Nuclear Regulatory Commission Page 2 July 1, 2013 There are no new commitments in this letter. If you have any questions, please contact Gordon Arent at (423) 365-2004.
I declare under penalty of perjury that the foregoing is true and correct. Executed on the 1st day of July, 2013.
Respectfully, James H. O'Dell Compliance Manager Watts Bar Unit 2
Enclosure:
Detailed RAI Response cc (Enclosure):
U. S. Nuclear Regulatory Commission Region II Marquis One Tower 245 Peachtree Center Ave., NE Suite 1200 Atlanta, Georgia 30303-1257 NRC Resident Inspector Unit 2 Watts Bar Nuclear Plant 1260 Nuclear Plant Road Spring City, Tennessee 37381
ENCLOSURE TENNESSEE VALLEY AUTHORITY WATTS BAR NUCLEAR PLANT, UNIT 2 Detailed RAI Response E-1
NRC Request for Additional Information Title 10 of the Code of Federal Regulations (10 CFR) 51.45, "Environmental Report", (b)(3) requires an applicant to submit an environment report discussing the alternatives to the proposed action.
Section 9.1.3, "Analysis of the Effects of Proposed Actions and Alternatives", of the license application for the renewal request states that Tennessee Valley Authority Final Supplemental Environmental Impact Statement (FSEIS) describes the effects and impacts of the proposed action; the FSEIS describes all the alternatives except the option of non-renewal or no action. Consistent with NUREG 1748, "Environmental Review Guidance for Licensing Actions Associated with NMSS Programs", please provide a discussion of the effects of non-renewal of SNM-2014 with respect to the stored Watts Bar Unit 2 (WB2) fresh fuel already present on site. If SNM-2014 is not renewed as requested, describe how 10 CFR 70.38 would be implemented for the fresh fuel already on site and for the new fuel storage vault, where the WB2 fresh fuel has been stored. Would the WB2 fuel already on site be returned to the manufacturer, used in the Watts Bar Unit 1 reactor, or some other disposition?
TVA Response TVA has submitted environmental assessments as required by 10 CFR 51 (Reference 1) as part of the 10 CFR 50 (Reference 2) licensing activities for Watts Bar Nuclear Plant (WBN) Unit 2. Title 10 of the Code of Federal Regulations 51.95(b), "Initial operating license stage," states, in part, that an applicant for a nuclear plant operating license will submit an operating license stage supplement to the construction permit environmental impact statement (EIS). This supplement only covers matters that differ from the final EIS or that reflect significant new information concerning matters discussed in the final EIS. This section also states that no discussion of the need for power, or of alternative energy sources, or of alternative sites for the facility, or of any aspect of the storage of spent fuel for the facility is necessary.
TVA issued TVA-OHES-EIS-72-9, Environmental Statement Watts Bar Nuclear Plant Units 1 and 2, November 9, 1972 (1972 TVA Environmental Statement) (Reference 3) in the process of obtaining a construction permit for WBN. Alternatives were addressed in the EIS including the no-action alternative of not constructing WBN. Consistent with the guidance of 10 CFR 51.53(b) the subsequent NRC review of environmental effects from operation of WBN Units 1 and 2 - as documented in NUREG-0498, Final Environmental Statement Related to the Operation of Watts Bar Nuclear Plant Units Nos. I and 2, dated December 1978 (Reference 4) and NUREG-0498, Supplement 1 published in 1995, (Reference 5), and TVA's 2008 Final Supplemental Environmental Impact Statement Completion and Operation of Watts Bar Nuclear Plant Unit 2 (FSEIS)
(Reference 6) - only discussed changes to previous information, and consistent with 10 CFR Part 51 did not address the no-action alternative. TVA's initial request for a Special Nuclear Material (SNM) License and subsequent request for renewal of SNM-2014 were based on these environmental studies which were incorporated by reference.
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The published environmental reviews established that the environmental effects associated with the operation of WBN, either or both Unit 1 and Unit 2, are small. The 1972 TVA Environmental Statement addressed the shipment and receipt of new fuel for the plant. This review determined that there were "no environmental risks from the radiation associated with the normal shipment of new fuel." The potential effects from a transportation accident involving new fuel were also addressed in the 1972 TVA Environmental Statement, which concluded that, when shipped in accordance with federal regulations, that there would be no release of radioactive materials and no increase in radiation dose rates over those from a normal shipment of new fuel. The presence of unirradiated fuel at the Watts Bar site for the initial operation of Unit 2 is within the scope of consideration of environmental effects from the operation of either Unit 1 or Unit 2. Since the operational environmental effects, including the presence of new and spent fuel and radioactive waste, are small, it can logically be concluded that the environmental impacts as a result of the presence of new (unirradiated) fuel for Unit 2 does not represent a major Federal action significantly affecting the quality of the human environment. TVA agrees that 10 CFR 51.53 specifically addresses spent fuel, but does not explicitly mention new fuel. However, unirradiated (new) power reactor fuel of low U-235 enrichments is bounded by the consideration of the environmental effects of spent fuel. This conclusion is consistent with the guidance provided by the language of 10 CFR 51.20 and 51.60 where the storage of new fuel with a low enrichment is not specifically mentioned.
In May 2013, the NRC published NUREG-0498 Supplement 2, Final Environmental Statement Related to the Operation of Watts Bar Nuclear Plant, Unit 2 Supplement 2 Final Report (SFES) (Reference 7). As stated in Section 1.2 of the SFES, Supplement 2 was developed based on the NRC Environmental Standard Review Plan (Reference 8).
Section 4.10 of the SFES discusses the Uranium Fuel Cycle impacts. It concluded that the environmental impacts are small. It is also of note that the there is no updated discussion of new fuel. It can thus be concluded that information provided in the 1972 TVA Environmental Statement with respect to new fuel remains adequate. As part of the development of the SFES, the NRC considered new information on the environmental impacts of alternatives. In Section 7.0, the SFES states:
The current rule governing environmental review at the operating license stage (10 CFR 51.95) states that, unless otherwise determined by the Commission, a FES supplement on the operation of a nuclear power plant will not include a discussion of alternative energy sources, or of alternative sites. For WBN Unit 2, the Commission stated its expectation that the staff would take the requisite "hard look" at new information on alternative sources of energy (Reference 9) and authorized the NRC staff to supplement the FES if the NRC staff concluded that there was new and significant information on alternative sources of energy (Reference 9). The Commission indicated that new and significant information would be information that would likely tip the cost-benefit balance against issuance of the operating license for WBN Unit 2. While the Commission recognized that technologies might change, the Commission stated that it was unlikely that such changes would "tip the NEPA cost-benefit balance against issuance of the operating license (Reference 9).
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After taking the requisite hard look at new information, the NRC staff concludes that the new information on alternative energy sources is not new and significant because it does not tip the cost-benefit balance against issuance of the WBN Unit 2 operating license. Although energy alternatives have changed in terms of performance and viability since TVA submitted its WBN Unit 2 construction permit EIS in 1972, the NRC staff's hard look at energy alternatives did not identify any new and significant information related to energy alternatives. The NRC staff did not identify a viable alternative that was clearly and substantially environmentally superior to operation of WBN Unit 2 (i.e., an alternative that would tip the cost-benefit balance).
It is TVA's position that with respect to the requirements of 10 CFR 51, the environmental effects from the operation of WBN Unit 2 have been fully addressed.
The following discussion evaluates the options available if the NRC does not renew SNM-2014.
TVA has received 193 fuel assemblies from Westinghouse for use in the first operating cycle of WBN Unit 2. These fuel assemblies are stored in both the Spent Fuel Pool and the New Fuel Storage Area. The New Fuel Storage Area was sized to accommodate the number of fuel assemblies typical for a routine refueling outage as opposed to the total number of fuel assemblies in the reactor core at WBN Unit 1 or Unit 2. One hundred seven new Unit 2 fuel assemblies are located in the New Fuel Area and 86 are located in the Spent Fuel Pool.
TVA has identified three potential alternatives that could be used if SNM-2014 is not renewed. The following information is applicable to each of the alternatives discussed below. In SECY-12-0103 (Reference 10), the Office of Nuclear Reactor Regulation stated that the Final Safety Analysis Report (FSAR) review was 99 percent complete.
Since that assessment, the NRC has issued Supplemental Safety Evaluation Report (SSER) 26 that addresses additional FSAR review items, as well as closing a number of open items from earlier SSERs. The NRC has also issued NUREG-0487, Supplement 2 (Reference 7). Thus, the current state of the NRC review is more complete than when SECY-12-0103 (Reference 10) was issued. TVA is committed to licensing WBN Unit 2 and there is no indication that the NRC will not complete its review and issue an operating license for Unit 2 within the time frame specified in the renewal request for SNM-2014. This response does not address actions or alternatives that would be considered should Unit 2 not be completed or licensed.
Alternative 1 The Unit 2 fuel could be transferred to Unit 1 and used in future operational cycles.
WBN Units 1 and 2 both use Westinghouse RFA-2 fuel. Thus, the fuel is mechanically compatible with Unit 1. However, the Unit 2 fuel for the initial core loading has a low U-235 enrichment when compared to the current new fuel for Unit 1. The Unit 2 fuel enrichments range from approximately 2.1 to 3.1 weight percent U-235. New Unit 1 fuel typically has nominal enrichments between 4.0 and 5.0 weight percent. TVA plans core designs well in advance and works to optimize each fuel cycle. Using the Unit 2 fuel in Unit 1 would have a negative impact on this optimization. TVA has already procured fuel for several future Unit 1 cycles.
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To exercise Alternative 1, WVA would have to immediately purchase additional new fuel for the first cycle of operation at Unit 2. The fuel cost for the initial core loading is approximately $113 million. There would also be additional costs associated with transporting the new fuel to the site. In addition, if SNM-2014 is not renewed, the new fuel purchased could not be shipped until Unit 2 receives an Operating License. This would result in additional costs associated with the delay in the plant being commercially available to supply power to the TVA system and would do nothing to further the purpose of NRC's regulation to protect the health and safety of the public. While this alternative is technically feasible, it is not an economically practical alternative or a practical use of TVA or NRC resources given the current state of progress towards an Operating License for WBN Unit 2. This is the most unfavorable of the options identified.
Alternative 2 The Unit 2 fuel could be transferred to Unit 1. When the Operating License is issued for Unit 2, the fuel could be transferred back to Unit 2. This alternative is technically feasible. This option requires additional regulatory actions on the part of both TVA and NRC and, likewise, does nothing to provide protection to the health and safety of public.
In addition, this option produces an undesirable financial result as the Unit 2 fuel was a capital purchase while Unit 1 fuel is categorized as an operation and maintenance expense. It is TVA's position that this is not as practical as the requested action of renewing the SNM-2014 license. It is the best option identified if SNM-2014 is not renewed.
Alternative 3 The WBN Unit 2 fuel could be returned to Westinghouse until Unit 2 receives an operating license. This is a technically feasible option and, as in the case of the other alternatives, does nothing to further the NRC's regulatory purpose to protect the health and safety of the public. Moreover, any Unit 2 fuel that had been stored in the Spent Fuel Pool would have to be considered contaminated. This would require additional protections to prevent the spread of contamination and manage personnel protection in accordance with As Low as Reasonably Achievable (ALARA) principals. It is not ALARA compared to the requested license renewal request or the other alternatives given the progress towards receiving an operating license for Unit 2. WVA has not determined whether Westinghouse would be willing to or could accommodate the storage of the Unit 2 fuel until the issuance of an operating license. Maintaining the Unit 2 fuel on site is clearly preferable.
Actions Required by 10 CFR 70.38 The Spent Fuel Pool and the New Fuel Area at WBN are shared by the two units. These plant features are part of the Unit 1 Operating License. Assuming that SNM-2014 is not renewed, TVA would have to obtain NRC approval for implementing one of the options described above so that no 10 CFR Part 70 material allowed by SNM-2014 would be present on site and associated with Unit 2. Absent that, no additional actions are required under 10 CFR 70.38.
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References
- 1. 10 CFR Part 51. Code of Federal Regulations, Title 10, Energy, Part 51, Environmental Protection Regulations for Domestic Licensing and Related Regulatory Functions.
- 2. 10 CFR Part 50. Code of Federal Regulations, Title 10 Energy, Part 50, Domestic Licensing of Production and Utilization Facilities.
- 3. Tennessee Valley Authority. 1972. Final Environmental Statement, Watts Bar Nuclear Plant Units 1, and 2. TVA-OHES-EIS-72-9. Chattanooga, Tennessee. Accession No. ML073470580.
- 4. U.S. Nuclear Regulatory Commission. 1978. Final Environmental Statement Related to Operation of Watts Bar Nuclear Plant Units Nos. 1 and 2. NUREG-0498, Washington, D.C. Accession No. ML082540803.
- 5. U.S. Nuclear Regulatory Commission. 1995. Final Environmental Statement Related to the Operation of Watts Bar Nuclear Plant, Units 1 and 2. NUREG-0498, Supplement No.
1, Office of Nuclear Reactor Regulation, Docket Nos. 50-390 and 50-391, Washington, D.C. Accession No. ML081430592.
- 6. Tennessee Valley Authority. 2008. Final Supplemental Environmental Impact Statement; Completion and Operation of Watts Bar Nuclear Plant Unit 2, Rhea County, Tennessee.
Submitted to NRC as the TVA Environmental Report for an Operating License, Knoxville, Tennessee. Accession No. ML080510469.
- 7. U.S. Nuclear Regulatory Commission. 2013. Final Environmental Statement Related to the Operation of Watts Bar Nuclear Plant, Unit 2. NUREG-0498, Supplement No. 2, Office of Nuclear Reactor Regulation, Docket Nos. 50-390 and 50-391, Washington, D.C. Accession No. ML13144A092, ML13144A093.
- 8. U.S. Nuclear Regulatory Commission. 2000. Environmental Standard Review Plan-Standard Review Plans for Environmental Reviews for Nuclear Power Plants. NUREG-1555, Vol. 1, Washington, D.C. Accession Nos. ML003702134, ML003701937, ML003702019.
- 9. U.S. Nuclear Regulatory Commission. 2010. In the Matter of Tennessee Valley Authority (Watts Bar Nuclear Plant, Unit 2) Docket No. 50-391-OL, CLI-10-29, Memorandum and Order. Washington D.C. Accession No. ML103340280
- 10. NRC Memorandum SCEY-1 2-0103 dated July 24, 2012, Sixth Report on the Status of Reactivation of Construction and Licensing for Watts Bar Nuclear Plant, Unit 2 E-6