ML20077S218
| ML20077S218 | |
| Person / Time | |
|---|---|
| Site: | Nine Mile Point  |
| Issue date: | 01/09/1995 |
| From: | Terry C NIAGARA MOHAWK POWER CORP. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NMP2L-1522, NUDOCS 9501230331 | |
| Download: ML20077S218 (17) | |
Text
<
=-
4-M V NIAGARA RUMOHAWK NINE MILE POINT NUCLEAR STATION /P O BOX 63. LYCOMING, NEW YORK 13093/ TELEPHONE (315) 343-21 to January 9,1995 NMP2L 1522 U. S. Nuclear Regulatory Commission L
Attn: Document Control Desk Washington, DC 20555 RE:
Nine Mile Point Unit 2 Docket No. 50-410 NPF-69
Subject:
Proposed License Amendment - Upmted Opemtion, Response to Requestfor Additional hqfonnation Gentlemen:
In a letter to the Nuclear Regulatory Commission (NRC) dated July 22,1993 (NMP2L 1397), Niagara Mohawk Power Corporation (NMPC) proposed a license amendment to allow Nine Mile Point Unit 2 (NMP2) to operate at an uprated power of 3467 megawatts thermal.
During the course of the Staff's review of this proposed license amendment, the NRC has determined that additional information regarding the potential environmental impacts of the proposed power uprate, as identified in its December 1,1994 letter to NMPC, is required to complete its review of this matter. Attached to this letter are the Staff's questions and the requested additional information.
Niagara Mohawk has provided a copy of this response to the appropriate state representative.
Very truly yours, C. D. Terry Vice President - Nuclear Engineering CDT/KWK/Imc Attachment l
0 l
ogGQUB I
i 9501230331 950109 PDR ADOCK 05000410 p
PDR i
L.
Page 2 -
xc:
Regional Administrator, Region I Mr. B. S. Norris, Senior Resident Inspector Mr. L. B. Marsh, Director, Project Directorate I-1, NRR Mr. D. S. Brinkman, Senior Project Manager, NRR Ms. Donna Ross Division of Policy Analysis and Planning New York State Energy Office Agency Building 2 Empire State Plaza Albany, NY 12223 Rixords Management l
i J
?
8
NINE MEE POINT UNIT 2 DOCKET NO. 50-410 NPF-69 Comments and Ouestions for Nine Mile Point Nuclear Station Unit 2:
Environmental Assessment for Power Uprate To support the finding of no significant impact (FONSI) for the application for license amendment to increase power level, the licensee should provide the basis for the conclusion that the environmental effects for the uprated conditions are within those previously evaluated. The licensee should address relevant environmental parameters associated with the following systcms:
1.
Senice Water and Circulatine Water SYdLnt.
la.
Pmvide the effects of additional withdmwal of service water and an increase in the blowdown mtefmm the natumi drqft cooling towen, for the pmposed upmted power opemtion.
The additional withdrawal of cooling water from Lake Ontario is expected to increase slightly due to the increased heat loads. Emergency system flows are expected to remain generally unchanged. Increased heat loads are expected for non-safety related loads such as the main generator stator coolers, hydrogen coolers and exciter coolers. These systems, as well as other systems noted in j
Section 6 of the Power Uprate Licensing Evaluation are expected to require additional cooling and an increase in flowrate. The increase is expected to be small and within a nominal 5% increase.
In accordance with the Final Environmental Statement for Unit 2 (NUREG-1085) and conservatively assuming a 5% increase in the withdrawal rate, the intake approach flowrate velocity is expected to increase from 0.5 fps to 0.53 fps. The current designed velocity is low and observations by the Licensee has shown fish impingement to be very low and in most cases non-existent. In addition, the intake entrainment rate is also low due to the low velocity and total quantity of water compared to once through cooling systems. The New York State Department of Environmental Conservation (NYSDEC) has evaluated the potential effects of the current intake flowrate and has concluded that no special aquatic studies are required to assess the biological impact. No aquatic studies have been included in the Licensee's new SPDES (NPDES)
Discharge Permit effective December 1,1994. This new Discharge Permit was issued by New York State since the previous permit had expired. All subsequent references to the SPDES Discharge Permit apply to the recently issued permit of December 1,1994.
1
sj-Because the current intake flowrates are low and the aquatic impacts of l
withdrawal are minimal, a conservative 5", increase is not expected to result t
in a significant impact, if any impact at all.
The current natural draft cooling tower blowdown rate is controlled by total copper concentration in the Circulating Water System and the economic use of water treatment chemicals. An increase in the cooling tower blowdown is not expected. However, should the Licensee re-evaluate the blowdown rate, then a new rate would have to carefully consider the copper concentration limit for the Circulating Water System imposed on the system by the SPDES Discharge Permit and the economic use of water treatment chemicals.
~
An increase in blowdown rate, if instituted, is not expected to impact the.
l receiving water body since the current flowrate utilized is less than the designed flowrate. The current blowdown rate is approximately 40% of the designed rate and is restricted, as noted above, by the SPDES Permit copper limitation and economic use of water treatment chemicals. In the event the blowdown rate was increased by 5-10% in order to evaluate cooling tower efficiency and to reduce the cycles of concentration of natural salts in the Circulating Water System, the copper limitation could still be met and the flowrate impact is expected to be less than designed.
In addition, the NYSDEC has evaluated the service water and cooling tower blowdown based on the original design flowrates, as well as the state of the art l
technology of the discharge diffuser used at the lake discharge point. The NYSDEC has concluded that no thermal measurements or thermal plume studies are necessary because of the low flowrates and the design of the discharge structure. No thermal monitoring requirements have been included in the Licensee's SPDES (NPDES) Discharge Permit, i
In summary, because the intake withdrawal rate is currently low and the cooling tower blowdown rate is currentlj below original design, the increase in water withdrawal or an increase in blowdown is not expected to result in any additional environmental impact. Any increase in flowrate is expected to be no more than the original system design.
Ib.
Identify the change in the tempemture of the cooling tower blowdown.
i The Circulating Water System is designed to remove the heat rejected to the condenser and thereby maintain adequate condenser tack pressure as recommended by the turbine vendor. Maintaining adequate condenser back pressure assures the efficient operation of the turbine-generator (GE Topical
(
Report NEDC-31994P Section 6.4.2).
j Uprate operation will increase the heat rejection to the condenser. This rejected heat will result in an increase in circulating water and subsequent
)
cooling tower blowdown temperatures.
)
2
~
g-As described in the Final Environmental Statement (FES) Section 4.2.4, the circulating water flow is 36,590 Usec (580,000 gpm) and blowdown from the cooling tower is discharged to Lake Ontario along wnh discharge from the '
1 Service Water System. The blowdown was designed to average approximately 955 Usec (15,080 gpm). Currently, the blowdown is operated at approximately 6000 gpm.
While there are no direct limits on blowdown temperature, the New York State SPDES Discharge Permit limits the combined service water and cooling tower blowdown discharge to a maximum discharge temperature of 110*F and a l
t maximum difference in temperature between the condenser intake and the station discharge (AT) of 30*F.
The service water discharge temperature results from the heat rejected to the Service Water System via the closed cooling water systems (including cooling i
tower blowdown) and other auxiliary heat loads. The increase in service water heat loads for these sources due to uprated operation is projected to be j
approximately proportional (<5 %) to the uprate itself (GE Topical Report NEDC-31994P, Section 6.4.1.2).
The 9 year maximum discharge temperature and maximum AT recorded at Unit 2 are approximately 86*F and 20*F respectively (AT is the service water discharge bay temperature minus the condenser inlet temperature where the discharge bay temperature includes service water discharge and cooling tower l
blowdown). A 5% increase in both of these temperatures woulC be approximately 4*F and l'F respectively (data obtained from a review of monthly SPDES Discharge Monitoring Reports submitted to the New York i
State Department of Environmental Conservation).
The power uprate will not require any changes to environmental discharge limitations as they apply to current unit operation. None of the present limits for NMP2 discharges, such as service water discharge temperature (including any addition from coo'ing tower blowdown) will need to be increased as a consequence of uprate. In the unlikely situation that plant releases approach
+
(
environmental limits, plant operation will be managed such that the existing l
limits would not be violated. It is not expected, however, that any environmental limits will be approached (GE Topical Report NEDC-31994P, l
Section 11.3).
ic.
Discuss any adverse impacts on the terrestrial environment due to the additional dr$ emissionsfrom the cooling towen on local soils and vegetation.
i The terrestrial impacts of cooling tower drift emission were thoroughly i
l evaluated in the Unit 2 Environmental Report - Operating License (ER-OL),
and the NMP2 Final Environmental Statement (FES) (including Appendix G).
.1 L
3 L
l
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __j
e As stated in Section 5.5.1.1 of the FES: operation of mechanical draft cooling towers can result in impacts on terrestrial resources including the deposition of salt drift on soil and vegetation.
Therefore, a mathematical model was developed to determine the downwind distribution of salt, water deposition and the concentration of airborne salt resulting from cooling tower operation. A detailed description of this model and results are found in Appendix 2D of the Updated Safety Analysis Report t
(USAR) and the ER-OL, Section 5.3.3.1.1.2.
The maximum salt deposition rate was predicted to be appmximately 0.03 gisq m/yr (0.27 lb/ acre /yr), occurring approximately 2,000 m (6,562 ft) northwest of the tower. Also, the maximum annual water deposition rate was approximately 0.08 mm (0.003 in) of water per year. The latter rate was considered insignificant since the annual precipitation at the site is over 76 cm l
(30 in) per year.
The impacts of the chemical discharge (salt deposition) on vegetation are also discussed in the ER-OL in Section 5.3.3.2.2. Salt deposition can impact vegetation either through soil salinization or through foliar salinization.
From the standpoint of soil salinization, there should be no appreciable impact resulting from the operation of the natural draft cooling tower for vegetation at Unit 2 or for agricultural crops which may be grown offsite. This assessment is based on the following:
1.
The maximum amual deposition rate predicted for vegetated areas (pasture, woods, and agricultural parcels) is approximately 11.08 kg/sq km/yr (approximately 0.099 lb/ acre /yr) in the area of the Energy Center.
i 2.
Na+ and C1' ions (those most toxic to plants) make up approximately l
9% and 19% of the drift, respectively. Thus, the majority (approximately 72%) of the drift constituents of the salt deposited by operation of the cooling tower are the less to:dc ions of calcium sulfate, 1
bicarbonate and others.
t 3.
The potential for salt accumulation in the soil is greatly reduced by the relatively high rate of rainfall and the high soil permeability.
A very conservative (assuming that all salt deposited remain with no leaching) annual increase in dissolved solids from water passing through the soil (in the same location as 1 above) is estimated at approximately 0.012 ppm annually.
The concentration would be less elsewhere onsite and in offsite areas.
Researchers (as identified in the ER-OL) have found that even the most sensitive species are not affected by soil salinization of less than 1,280 ppm.
Thus, given this potential small incremental increase in soil a salinization, it is
)
4
highly unlikely that even salt-sensitive species would be measurably affected by the operation of the Unit 2 cooling tower during power uprate.
Deposition of salts (chlorides'; on leaves of plants may cause damage depending upon the concentration and duration of exposure. It appears that the minimal deposition of salt drift that would cause injury to sensiti"e species of l
native perennials is about 10kg/halmo. (11 lb/ acre /mo.) near the dine Mile Point site, approximately 2,000 m (6562 ft.) northwest of the cooling tower.
Deposition rates over land in vegetative areas will be less. Thus, little -
potential for injury to native perennials (or agricultural crops) from salt drift would occur, since deposition rates are far below those known to cause injury.
r In addition to the low deposition rate of salts to the local vegetation and the soil (which has minimal impact upon the local vegetation), the Licensee has established a water treatment program that has reduced the amount of sulfuric acid used to control system scale growth. A non-toxic polymer scale inhibitor has significantly reduced the formation of sulfate salts in the circulating water as a result of the reduced acid use. The reduction has also reduced the amount of sulfate salts in the cooling tower drift.
Based upon the above review of the effect of cooling tower drift emission on local soil and vegetation, and the existing low levels of deposition, even a conservative estimate of a 5% increase in drift (resulting from the approximate 4.3% power uprate) would still be well below the levels of concern to local soil and vegetation.
id.
Ident((v any changes in the cooling tower water chemistry and intake canal velocity.
Changes in the cooling tower water chemistry are expected to be minor. No special or additional water chemistry control programs are expected to be necessary as a result of power uprate. However, slight changes to the current established programs are expected to be necessary. These changes generally 1
include slight increases in chemical addition or the frequency of intermittent
]
chemical treatments.
4 The chemical composition of the Circulating Water System was evaluated in the Licensee's Environmental Report - Operating License Stage and the Final Environmental Statement (NUREG-1085). The primary chemical components are calcium and sulfate salts and corrosion metal products which primarily include copper, iron and zinc. These chemical components originate from the evaporative process and continuous recirculation 'of the Circulating Water System. The calcium salts originate from the evaporative process utilizing water from lhe Ontario._ The sulfate salts originate from the use of sulfuric acid to control scale buildup. The corrosion products, noted above, basically originate from the metallic components of the Circulating Water System and include the condenser tubes, condenser water boxes, and other system 5
,4 supporting structural steel components. A polymer is_also used in the Circulating Water System as a scale inhibitor and reduces the amount of acid needed to control scale formations. The polymer is non-toxic and is maintained at a designated concentration range. A copper corrosion inhibitor is also added but on an intermittent basis and has shown to be very effective to reduce copper corrosion and concurrently extends condenser life. Since the corrosion inhibitor is added intermittently, the residual from the treatments is of a short duration and is insignificant as a normal chemical component of the Circulating Water System. Sodium hypochlorite is also added on an intermittent basis to control biofouling. Hypochlorite is added on a frequency of less than seven days per week, especially during the cooler winter months, and less than two hours per day. The residual from these treatments is also of l
a short duration and is insignificant as a normal chemical component of the j
The calcium and sulfate salts are expected to increase slightly in concentration I
as a result of the evaporative process. The increase in concentration is i
expected to be less than 5%. The metallic corrosion products (copper, iron and zine) are also expected to increase slightly primarily due to the increase in the circulating water temperature. This increase is also expected to be less than 5%. The scale inhibitor (polymer) concentration may have to be increased slightly in reaction to the increased salt concentration although application restrictions imposed by the NYSDEC will have to be reviewed prior to any increases. The copper corrosion inhibitor, which is used intermittently, will not be impacted directly in regards to the treatment concentration. However, the frequency of treatments may increase slightly since the time interval between treatments may decrease slightly due to the water temperature increase. Based on the performance of the inhibitor and the small increase in circulating water temperature, an increase in the frequency may not be necessary. An increase in the frequency of use is currently within the scope of the approval for chemical use approved by the NYSDEC. The frequency of addition for sodium hypochlorite may also have to be increased as a result of power uprate. This is due to the slightly higher temperature of the Circulating Water System. The daily duration of two hours per day, will not increase since this is a federal and state maximum limitation.
The increase in reactor power is expected to increase the intake canal velocity because of an additional demand for service water. The additional service water demand will result from the increased heat load on the facilities' cooling systems and the increased water usage in the Circulating Water System'(i.e.,
cooling tower) from evaporative cooling. The increase in water usage is expected to be less than the 5% increase in reactor power.
I-The increase in the intake canal velocity is also expected to be less than the 5% increase in reactor power. In addition, the intake canal velocity increase will be less than the percentage increase in the demand for service water and cooling tower makeup water since the intake canal also supplies the fish bypass 6
d system. The fish bypass system is unaffected by power uprate and is driven by a motive pump, which, when combined with the bypus flow, is approximately 15,000 gpm (Final Environmental Statement /NUREG-1085).
This flow is approximately 28% of the total intake flowrate.
The total percentage increase in intake canal velocity considering the actual increase in flowrate is minimal and is not expected to have an adverse impact on the impingement or entrainment of aquatic organisms from Lake Ontario.
The increase in flowrate and velocity is expected to contribute beneficially to the growth of zebra mussels in the intake tunnel and forebays. However, the Licensee successfully treats for the growth of zebra mussels on an annual basis. The intake tunnel and forebays are treated once per year and the Service Water System two to three times per year. The treatments effectively eliminate any sustained beneficial growth.
The current intake structure velocity is low and has minimal impact on aquatic 7
organisms. The need for impingement and entrainment studies was evaluated by the New York State Department of Environmental Conservation (NYSDEC) for inclusion in the facilities' SPDES Discharge Permit. Based on the evaluation, the NYSDEC did not provide for any such studies in the SPDES Discharge Permit. Thus, the current system design has minimalimpact. A small increase in total intake canal velocity is not expected to result in any environmental impact.
le.
Addnst any inenased noise levels attnbuted towants power upmte.
The environmental impact of noise from the NMP2 station was thomughly.
assessed and documented in Section 2.10 of the Environmental Report (ER-OLS). The Final Environmental Statement (NUREG-1085) stated in Section 5.3.2.2 that the conclusion of an evaluation of the impact of noise from NMP2 (included in a 1981 report on the environmental effects from the change in cooling systems) remained valid.
Although the cooling tower is environmentally acceptable in terms of HUD noise guidelines, the tower noise would produce a greater awareness of plant i
operation than the once-through system. However, since the number of people living along lakeview Road or other areas adjacent to the site boundary is limited, the staff (NRC) attached no significance to the noise differentials between the cooling system options.
In summary, the noise levels produced by Unit 2 that were evaluated in the FES were within: (a) the proposed New York State Noise Code, which requires that nighttime sound levels not exceed 45 dBA at a commercial-industrial property line, and (b) threshold differences of 5 dBA above ambient noise levels, which is considered the minimum level at which residents would notice a change.
j 7
i.
As noted in Section 2.10 of the Unit 2 ER-OLS (evaluation of noise _ levels),
- Unit 2 is located on the shore of Lake Ontario, approximately 10 km (6.2 miles) northeast of the City of Oswego, and shares a single contiguous site with two other operating nuclear power plants (i.e., Niagara Mohawk Power Corporation's Nine Mile Point Unit 1 and the New York Power Authority's James A. Fitzpatrick Nuclear Power Plant). In general, the region surrounding the site (up to and beyond the property line boundaries) consists of mostly wooded areas with some open fields and farmland. Most of the i
permanent residences in the area are located along the main roads surrounding i
the site.
As a result of these factors, the land use in the area surrounding the Nine Mile Point site is relatively homogeneous, and the ambient noise levels throughout the area are expected to be quite similar. A study to determine sound levels in the area of the site boundary was conducted during a 5-day period between September 27 and October 1,1979. The results are also documented in Section 2.10 of the ER-OLS and indicate that only during nighttime hours, when the impact of cricket noise (native insects) as well as the general level of activity in the area appeared to be reduced, then the power plant noise (primarily ventilation and transformer noise) was audible or just barely audible at all 9 noise monitoring sites.
Also, in Appendix G of the FES, the Commission concludes that the Unit 2 natural draft cooling tower would not produce noise contours of 45 dBA at the site boundary. The cooling tower would impact the Lake Road corridor from Lake Ontario to the plant's southern boundary with noise levels within the approximate range of 35-40 dBA while other nearby residential areas would be impacted with less than 35 dBA sound levels. Both of these levels were below.
the proposed New York State Noise Code commercial-industrial property line night-time sound limits.
With the exception of the cooling tower, all other significant noise producing equipment associated with the service water and circulating water systems are located inside buildings and/or well below grade where the noise level would have little, if any environmental impact.
Basically the primary and dominant noise source associated with the operation of the cooling tower is the sound of water cascading through the fill material and splashing into the tower basin. The maximum circulating water flow is approximately 36,590 IJsec (580,000 gpm) (ER-OL Section 3.4.1.1.2) and there are no plans to increase this flow rate as part of the proposed power uprate. Therefore, there is no expected increase in cooling tower noise levels associated with the proposed power uprate. In addition, since there are no expected changes to station ventilation systems or transformers associated with the power uprate, there should be no measurable offsite increase in ventilation system or transformer noise. These were the two sources of plant noise that were audible or barely audible in the 1979 ambient noise study noted above.
8 i
m 1
1f.
Discuss any changes to the service water dischargeflow mte, velocity, tempemture or thennalplume, or chemical composition due to the power upmte. Also, address the efects ofpower upmting on the National P6tlutant Discharge Elimination System (NPDES) Pennit.
The service water discharge flow rate and velocity are expected to increase slightly as a result of the increase heat load on various facility systems that are l
affected by the power uprate. Systems such as the main generator stator coolers, hydrogen coolers, exciter coolers, etc., are expected to require more cooling water under extreme conditions. In addition, the cooling tower blowdown rate may also be increased as a result of the heat discharged from the main condensers. However, the blowdown rate is ultimately controlled by the copper concentration in the circulating water since the SPDES Discharge Permit issued by the NYSDEC limits the copper concentration to 250 ppb in -
i the service water discharge bay.
1 The service water discharge flow rate and velocity increase will not affect the overall discharge system since the increase is within design capacity. The cooling tower blowdown rate is operated below design because of the SPDES Discharge Permit copper limitation of 250 ppb total copper. The small increase in service water flow rate and velocity will not have an impact on the aquatic environment in Lake Ontario since the total discharge flow rate and velocity is significantly less than a once through cooling system. In addition, the small increase in flow rate and velocity will also have an insignificant impact because the discharge structure utilizes a two port diffuser to minimize any potential discharge impact.
]
The service water discharge temperature is expected to increase slightly as a result of the additional heat loads placed on systems that will be affected by i
power uprate. These systems include, for the most part, the generator and stator cooling systems as well as the cooling tower blowdown. The slight increase in discharge temperature is not expected to impact the discharge system and associated components. In addition, the increase in discharge temperature will not have an adverse impact on the aquatic environment because of the minimal impact overall due to the use of a natural draft cooling j
{
tower.
The increase in heat load will, as noted above, increase the discharge temperature and the flow rate slightly. Both are expected to be less than 5%.
The slight increase in temperature and flow rate will increase the temperature and size of the Unit 2 thermal plume in Lake Ontario. This increase is expected to be insignificant because Unit 2 was designed to utilize a natural
)
draft cooling tower which greatly reduces the size and heat content of a receiving water body plume versus a once through cooling system. The extent and increased heat content of the thermal plume is expected to be less than j
5%. In addition, the NYSDEC evaluated the need for any Unit 2 thermal 9
.7 plume studies in accordance m federal 316(a) criteria. No thermal plume monitoring was included in the tacilities' SPDES Discharge Permit.
The service water discharge, which includes the cooling tower blowdown, is expected to have a very slight increase in chemical composition. The increase is expected to originate from the Circulating Water System as a result of the l
increase in heat rejection from the main condensers and the subsequent slight l
increase in the cooling tower cycles of concentration. Both the heat rejection and the cycles of concentration are expected to increase less than SE i
The chemical composition of the Circulating Water System was evaluated in the Licensee's Environmental Report - Operating License Stage and the Final Environmental Statement (NUREG-1085). The primary chemical components are calcium and sulfate salts and corrosion product metals which primarily i
include copper, iron and zinc. These chemical components originate from the evaporative process and continuous recirculation of the Circulating Water System. The calcium salts originate from the evaporative process utilizing water from Lake Ontario. The sulfate salts originate from the use of sulfuric acid to control scale buildup. The corrosion products, noted above, basically originate from the metallic components of the Circulating Water System and include the condenser tubes, condenser water boxes and other system supporting structural steel components. A polymer is also used in the Circulating Water System as a scale inhibitor and reduces the amount of acid needed to control scale formation. The polymer is non-toxic and is maintained at a designated concentration range. A copper corrosion inhibitor is also added but on an intermittent basis and has shown to be very effective to reduce copper corrosion and concurrently extends condenser life. Since the corrosion inhibitor is added intermittently, the residual from the treatments is of short duration and is insignificant as a normal chemical component originating from l
cooling tower blowdown. Sodium hypochlorite is also added on an i
intermittent basis to control biofouling. Hypochlorite is added on a frequency of less than seven days per week and less than two hours per day. The l
residual from these treatments is also of a short duration and is insignificant as a normal chemical component of the Circulating Water System.
The calcium and sulfate salts are expected to increase slightly in concentration
~
as a result of the evaporative process. The increase in concentration is expected to be less than SE The metallic corrosion products (copper, iron and zine) are also expected to increase slightly due primarily to the increase in circulating water temperature. This increase is also expected to be less than SE The scale inhibitor (polymer) concentration may have to be increased slightly in reaction to the increased salt concentration although application restrictions imposed by the NYSDEC will have to be reviewed prior to any increase. The copper corrosion inhibitor, which is used intermittently, will not
-i be impacted directly in regards to the treatment concentration. However, the frequency of treatments may increase slightly since the time interval between treatments may decrease slightly due to the water temperature increase. Based 10 s
+
on the performance of the inhibitor and the small_ increase in circulating water temperature, an increase in the frequency may not occur. An increase in the 3
frequency of use is currently within the scope of the approval from the NYSDEC for the use of the inhibitor. The frequency of addition of sodium hypochlorite may also have to increase as a result of a slightly higher Circulating Water System water temperature. The daily duration of two hours l
per day will not increase.
Other chemical components that were evaluated in the Unit 2 Environmental Report - Operating License Stage included makeup demineralizer wastewater comprised of filter backwashes and resin regeneration wastes. In addition, low l
volume liquid radwaste discharges were also included in the evaluation. These j
wastes have been, for the most part, eliminated or greatly reduced from the Unit 2 service water discharge. Demineralized water is made from vendor portable trailers. Resin regeneration wastes and filter wastes are generated offsite at the vendor's service facility. ~ In addition, radwaste discharges include only low conductivity, high purity demineralized wastewater.. Wastes other than low conductivity wastes generated from radwaste processing are solidified and stored onsite and are not included in wastewater discharges.
The chemical composition of the Unit 2 discharge to Lake Ontario is expected to increase slightly, as notexi above, for those chemical components that originate from the Circulating Water System. These include calcium salts, sulfate salts and metallic corrosion products, notably copper. However, most of these chemical components are currently reduced in the rate at which they are generated when compared to the original Environmental Report evaluation.
This is due to the use of water treatment chemicals, such as the scale inhibitor i
and copper corrosion inhibitor. Therefore, although the power uprate is expected to increase some of the chemical components from the Circulating Water System by no more than 5%, the overall Unit 2 discharge to Lake Ontario is not expected to have any increased aquatic impact. This is i
primarily due to the fact that the current chemical composition is of a smaller magnitude than was originally evaluated for commercial operation of Unit 2.
In addition, the Unit 2 Environmental Report - Operating License Stage, provides design information on the Unit 2 lake discharge structure. The structure is a two port, elevated jet diffuser that provides a high velocity effluent which is rapidly mixed with the ambient lake water. Overall, considering discharge structure design, the small discharge rate for the closed loop cooling system and the reduced chemical composition of the discharge effluent, the impact of power uprate is not significant relative to chemical impacts on the receiving water and the aquatic biota.
Unit 2 discharges are regulated by the NYSDEC since New Y6rk State is an Agreement State with the USEPA. As such, Unit 2 discharges are controlled under the federal NPDES permitting program by a SPDES Discharge Permit.
As noted previously by the Licensee, the Unit 2 power uprate will not cause 11
3
- 4 any of the SPDES Discharge Permit limitations or conditions to be exceeded.
i Should any unlikely situations occur that may cause the permit to be exceeded, then the Licensee will take steps to ensure that the permit is not exceeded in the short term and revise the permit (if possible) in the long term. A review of the current permit limitations and conditions shows that if any of the permit parameters that could be affected by the power uprate are inemased by 5%,.
then the permit limits 4nd conditions will still not be exceeded. It is expected, therefore, that power uprate will have no impact on the SPDES Discharge Permit that would result in an exceedance of limitations or conditions.
2.
Plant Ekel Management System.
2a.
The increase in spentfuelpool heat load is due to the pmposed inenase in power level and the use of high density spentfuel stomge meks. Address -
any envimamentalimpactsfmm the releases of the mdioactive materials.-
i The operational heat load to the spent fuel pool will increase by about 5% due to power uprate. (NMP2 is not changing the existing fuel racks). However, the fuel pool cooling (SFC) system is designed using a conservative heat load I
which envelopes the heat load from either 18 month or 24 month power uprate fuel cycles. Thus, the SFC system is capable of removing the maximum normal pool heat load, and, with supplemental cooling provided by the Residual Heat Removal (RHS) system, as per the original design basis, is capable of removing the maximum emergency full core offload heat load.
Therefore, pre-uprate SFC system design flow and heat rejection requirements as well as normal spent fuel pool temperature (125'F) and design temperature (150*F) remain unchanged. Thus, fuel leakage is not expected to increase.
2b.
Discuss any changes in the liquid mdwaste quantities or activity levels due to the pmposed power upmte.
Liquid radwaste quantities and activity levels are not expected to change significantly due to power uprate. The two principal sources of liquid radwaste are the Condensate Demineralizer (CND) system and the Reactor Water Cleanup (RWCU) system.
.i Ultrasonic cleaning of condensate demineralizer resins is a significant 1
contributor to liquid radwaste collection (regeneration of resins is no longer used at NMP2). With a projected increase of approximately 4.6% in the flow through the demineralizer vessels, there will be a corresponding increase in liquid radwaste volumes associated with ultrasonic cleaning of resins. In addition, it can be expected that resin replacement and disposal will increase by a similar amount (i.e.,4.6%). This increase does not have a significant environmental impact.
l The RWCU system will see minimal changes under power uprate. The flow will remain unchanged while the temperature of RWCU water leaving and l
12 i
i entering the vessel will increase by less than 1*F. Activity levels in the RWCU system are primarily dapaviaat on water chemistry, water temperatures, and flow velocities in the feedwater train and reactor vessel and associated components. Under power uprate there will be minimal changes to operating temperatures (from 2*F in the reactor steam dome to approximately
)
4*F for main feedwater). In addition, flow velocities are expected to increase by up to 5% at various points along the power train equipment string. This i
may result in a slight increase in activity levels in the RWCU blowdown.
However, wtivity levels are strongly depaviant on plant water chemistry, and improved water chemistry practices at NMP2, particularly zinc injection, will j
result in RWCU activity levels under power uprate which are lower than pre-uprate levels prior to injection. Thus, RWCU activity levels are not expected j
to be significantly affected by power uprate.
1 Additionally, there is not expected to be any significant increase in liquid radwaste volumes or activity levels from the equipment drain or floor drain systems.
J 3.
Other Systems.
3a.
INscuss any sign (Scant inenase due to the pmposed power upmte in the makeup requirwmentsfor the nactor coolant system, component cooling i
water system, condensate andfeedwater system, turbine plant cooling water system, auxiliary steam system, water treatment plant, and thepas pmtection system.
Overall, makeup requirements are not expected to increase significantly. More specifically:
Remetor Coolant System Operating pressures for the Reactor Recirculation System pump suction will remain constant at 1037 psia, while pump discharge pressure will increase approximately from 1318 psia to 1325 psia due to power uprate. This small percentage change in operating pressures will have an
)
insignificant effect on leakage rates, and consequently, makeup rates.
Component cooling Water System Operating pressures are unchanged due to power uprate. Therefore, system leakage, and therefore, system makeup, will be unaffected by power uprate.
Condenwe and Feedwater System Condensate (CNM) system and the portion j
of the Feedwater (FWS) system upstream of the feedwater control valves operating pressures will not increase due to power uprate. Thus, system leakage and consequently, system makeup will be unaffected. For the portion of FWS downstream of the control valves, operating presse will increase less than 20 psi. This increase in pressure will have insigniscant effect on leakage rates, and, consequently, makeup rates.
i 13
t Turbine Plant Cooling Water SystCm System flowrates are unchanged due to power uprate. Thus, system operating pressures, and therefore, system l
leakage, and consequently, system makeup, will be unaffected by power
{
uprate.
j I
Auxiliary Steam System Uprated operation willincrease steam supply J
pressures upstream of control valves in the Auxiliary Steam (ASS) system piping that interfaces with Main Steam (MSS) and Extraction Steam (ESS) systems. The maximum operating pressure increase is at the main steam interface. This increase (from approximately 965 psia to 1003 psia) will result in an insignificant increase of leakage and makeup requirements.
Water Treatment Plant As described above for the systems which have makeup requirements from the water treatment plant, demands placed on this system will not increase significantly due to power uprate. Makeup water is currently supplied by vendor portable demineralizer trailers.
i Fire Protection S stems The Fire Protection Water (FPW) system is l
y unaffected by the proposed power uprate changes in NSSS and BOP process l
parameters since the FPW design is based on delivering a given density of l
water to the various fire zones. The modifications proposed for power uprate will not affect the density requirements. FPW operating and design pressures are unaffected by power uprate. Therefore, system leakage, and consequently, system makeup requirements are unaffected by power uprate.
3b.
IdentVy ythere are aAy changes needed to the environmentalpivtection plan.
The Environmental Protection Plan (EPP) is Appendix B to the Unit 2 Facility
(
License. The plan includes a description and purpose of the plan, as well as j
any monitoring and reporting requirements. The plan also includes a section i
that basically defers any non-radiological sampling and analysis to the New l
York State Department of Environmental Conservation (NYSDEC) since New f
York State is an Agreement State with the U.S. Environmental Protection Agency. In addition, the plan provide, requirements that ensure any changes in station design or operation, or the performance of any tests or experiments are evaluated for any unreviewed environmental questions and changes to the EPP.
The non-radiological environmental aspects of the Unit 2 power uprate do not involve any unreviewed environn ental questions. The power uprate actions that will be taken will not result in any significant adverse environmental impacts previously evaluated in the Environmental Report - Operating License Page, environmental impact appraisals, or any decisions of the Atomic Safety and Licensing Board. In addition, the power uprate will not involve a significant change in effluents (non-radiological) or involve a matter not previously reviewed that may have a significant adverse environmental impact.
14
l
. A review of any monitoring requirements in the EPP has shown that no modification to the EPP is necessary. The EPP states that any aquatic monitoring of the environment is within the jurisdiction of the NYSDEC. The License has had discussions with the NYSDEC and no additional monitoring i
was required because no changes were necessary to the SPDES Discharge l
Permit. The Licensee also followed up with written notification that requested
}
the NYSDEC contact the station if additional information or action was necessary.' No additional information or action was needed.
The EPP contains two sections for terrestrial and noise monitoring. These sections provide no monitoring requirements for these two areas. There are no 4
other sections that provide monitoring requirements that are applicable to the Unit 2 power uprate.
P Based on the fact that any of the environmental impacts resulting from the Unit 2 power uprate are of a minimal nature or involve no impact at all, there is no change that needs to be initiated to the EPP. In addition, no changes are I
necessary to any of the reporti-a, requirements contained in the EPP as a result of the Unit 2 power uprate. Also, the objectives of the EPP, as provided in-l' Section 1.0, are not compromised as a result of the Unit 2 power uprate.
I v
h
?
t i
P i
i i
i i
l 15
')
' I.
l