ML20079M915

Industry Survey in Support of License Renewal Rulemaking Response Jm Farley Nuclear Plant,Alabama Power Co

ML20079M915
Person / Time
Site:	Farley
Issue date:	11/11/1991
From:	ALABAMA POWER CO.
To:
References
RTR-NUREG-1437 AR, S, WM, NUDOCS 9111110002
Download: ML20079M915 (14)

Text

I INDUSTRY SURVEY IN SUPPORT OF LICENSE RENEWAL RULEMAKING

RESPONSE

JOSEPH M. FARLEY NUCLEAR PLANT ALABAMA POWER COMPANY 1437 C PDR

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AQUATIC RESOURCES QUESTIONS

1. Post-licensing modifications and/or changes in operations of intake and/or discharge systems may have altered the effects of the power plant on aquatic resources, or may have been made specifically to mitigate impacts that were not anticipated in the design of the pl ant. Describe any such modifications and/or operational changes to the condenser cooling water intake and discharge systems since the issuance of the Operating License.

There have been no post-licensing modifications or changes in operation to cooling water intake er discharge systems which have altered the effect, as identified in the Final Environmental Farley Nuclear Plant Statement (FES)ic resources.and on aquat supporting It should be documents, of noted that Farley Nuclear Plant does not utilize once through cooling for the main condensers and does not derive service water and circulating water directly from the Chattahoochee River. Farley Nuc1 car Plant utilizes a service water pond, supplied by water from the Chattahoochee River, as the ultimate heat sink. Main condenser cooling is provided by a circulating water system utilizing mechanical draft cooling towers. Auxiliary cooling systems are once-through systems. Both main condenser and auxiliary cooling systems derive makeup from the service water pond and are returned to the Chattahoochee River via a common discharge line.

Changes have been made to service water and circulating water chemical trestment programs to provide for more efficient control of corrosion and biofouling. These changes were evaluated with regard to environmental impact prior to implementation in accordance with the requirements specified in Section 3.1 of the Farley Nuclear Pitnt Environmental Protection Plan (Appendix B to the Facility Operating License) and determined to have no significant environmental impact.

2. Summarize and describe (or provide documentation of) any known impacts on aquatic resources (e.g., fish kills, violations of discharge permit conditions) or National Pollutant Discharge Elimination System (NPDES) enforcement actions that have occurred since issuance of the Operating License. How have these been resolved or changed over time? (The response to this question should indicate whether impacts are or7oing or were the result of start-up problems that were subsequently resolved).

There have been no events prior to or sinco the issuance of the Farley Nuclear Plant Operating License which have resulted in significant impact to aquatic resourcas. There have been no documented fish kills or other events which could indichte any negative impact on the aquatic environment attributable to the operation of Farley Nuclear Plant.

Although there have been occasional exceedances of NPDES Permit limits, the overall NPDES Permit compliance record for Farley Nuclear Plant is excellent. In no case has an exceedance of NPOES Permit limits resulted in significant impact to aquatic resources. There is reo indication that any appreciable difference exists between impacts associated with start-up and on-going operation. As stated previously there has been no observation of any significant impact to aquatic resources.

There has been one NPDES enforcement action taken against Farley Nuclear Plant since the issuance of the Operating License. The action was taken due to recurring violations of Total Suspended Solids limits at the main sewage treatment plant and oil and grease violations due to dewatering of the turbine building oil sumps. The violations were the result of flow variations in the influent to the sewage treatment plant and design and maintenance problems with the oil water separator for the turbine building oil sumps. The plant was actively pursuing an engineering solution to the problems at the time the enforcement action was taken. The enforcement action was prompted by a citizen suit filed in April 1987 under the provisions of the Clean Water Act by the Atlantic States Legal Foundation, an environmental activist group.

The Alabama Attorney Generals' office intervened in the suit and brought the enforcement action against Farley Nuclear Plant. The matter was resolved in 1988 with a settlement agreement and consent decree in which Farley Nuclear Plant agreed to install additional treatment equipment to remove suspended solids from the sewage plant effluent, purchase and operate a portable oil water separator to remove oil and grease during the turbine _

building oil sump dewatering process and pay fines and court costs in the amount of $18,200. It should be noted that there was no significant impact on the environment due to-the problems associated with the sewage treatment plant and turbine building sump oil / water separator. The enforcement action was primarily an administrative action taken by the regulatory agency in response to the citizen suit. Resolution of the problems was in progress and the issue probably would not have resulted in pursuit of an enforcement action by the regulatory agency had the citizen suit not been filed.

There have been no problems noted with the sewage plant or turbine building oil sumps since installation of the additional treatment equipment.

3. Changes to the NPDES Permit during operation of the plant could indicate whether water quality parameters were determined to have no significant impacts (and were dropped from monitoring requirements) or were subsequently raised as a water quality issue.

Provide a brief summary of changes (and when they occurred) to the NPDES permit for the plant since issuance of the Operating License.

Due to major changes in NPDES regulations since the licensing of Farley Nuclear Plant, the first renewal of the NPDES permit in 1985 resulted in increased regulation over the initial permit. The increased regulation was primarily attributable to the regulatory changes made as a result of promulgation of the Effluent Guidelines for Steam Electric Generating Faciitties in 1982. The changes were in no way tied to plant NPDES compliance issues but were implemented in accordance with Congressional mandate under the Clean Water Act.

There is one case where NPDES Permit requirements were made more stringent in direct response to permitting agency concern over repeated violations of NPDES permit limits at the Farley Nuclear Plant main sewage treatment plant.

Repeated violations of Total Suspended Solids (TSS) limits occurred over approximately a three year period. In 1988, the permitting agency responded by increasing the sampling frequency for the sewage treatment plant from monthly to weekly (See discussion of NPDES enforcement action in the response to question 2) . The plant was subsequently modified to include additional treatment and the violations have ceased.

4. An examination of trends in the effects on aquatic resources monitoring can indicate whether impacts have increased, decreased, or remained relatively stable during operation. Describe and summarize (or provide documentation of) results of monitoring of water quality and aquatic biota (e.g., related to NPDES permits, Environmental Technical Specifications, site-specific monitoring required by federal or state agencies). What trends are apparent over time?

The Farley Nuclear Plant Final Environmental Statement, supported by the Environmental Report - Operating License Stage, identifies potential impacts to aquatic resources which may occur as a result of operation of the plant. The conclusions stated in the Final Environmental Statement indicate that environmental impacts associated with normal plant operation are not significant. In Section 2.0 of the Farley Nuclear Plant Environmental Protection Plan, the NRC indicates verification that thermal mixing occurs as predicted, chlorine releases are controlled within the discharge values previously evaluated, effects on aquatic biota and water quality due to plant operation are no greater than predicted, and documentation of levels of intake entrainment and impingement is provided by the effluent limitations and monitoring requirements detailed in the NPDES Permit and the Section 316(b) demonstration study. Copies of the Section 316(b) report and a study entitled Environmental Non-Radiological Monitorinq of Aquatic Communities in the Chattahoochee River are included as attachments to this correspondence. Both reports conclude that there is no significant impact on aquatic resources associated with operation of Farley Nuclear i Plant.

There has been no observed trend with regard to Farley Nuclear Plant environmental impact. Required monitoring of water quality and aquatic biota continues to support the original finding of no significant environmental impact as stated in the Final Environmental Statomont and supporting documents.

5. Summarize types and numbers (or provide documentation) of organisms entrained or impinged by the condenser cooling water system since issuance of the Operating License. Describe any seasonal patterns associated with entrainment and impingement. How has entrainment and impingement changed over time?

A stated in the response to question 1, Farley Nuclear _

Plant utilizes a service water pond, supplied by water from the Chattahoochee River, as the ultimate heat sink. Main condenser cooling is provided by a circulating water system utilizing mechanical draft cooling towers.

Impingement studies were conducted on the river water intake, which supplies the service water pond, during the licensing process. Types and numbers of organisms entrained or impinged by the river water intake system are provided in the Section 316(b) report for Farley Nuclear Plant included as Attachment 1 to this correspondence. As expected, seasonal variation in the types of organisms entrained or impinged was noted but was not deemed to be significant (see report). There is no indication that entrainment or impingement nas displayed any change with time.

6. Aquatic habitat enhancement or restoration efforts (e.g.,

anadromous fish runs) during operation may have enhanced the _

biological communities in the vicinity of the plant.

Alternatively, degradition of habitat or water quality may have resulted in loss of biological resources near the site. Describe any changes to aquatic habitats (both enhancement and degradation) in the vicinity of the power plant since the issuance of the Operating License including those that may have resulted in different plant impacts than those initially predicted.

There have been no changes to aquatic habitats (enhancement or degradation) in the vicinity of Farley Nuclear Plant since the issuance of the Operating License. Impingement, entrainment, larval fish and fisheries studies conducted in accordance with the Farley Nuclear Plant Environmental Protection Plan indicate no significant impact associated with plant operation to the biological communities in the vicinity of Farley Nuclear Plant.

It should be noted that operational practices implemented to periodically dredge the plant river water intake canal have allowed Farley Nuclear plant to maintain low intake canal velocities and therefore minimize impingement and entrainment effects on local biota.

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7. Plant operations may have had positive, negative, or no impact on the use of aquatic resources by others. Harvest by commercial or recreational fishermen may be constrained by plant operation.

Alternatively, commercial harvesting may be rather large compared with fish losses caused by the plant. Describe (or provide documentation for) other nearby uses of waters affected by cooling water systems (e.g., swimming, boating, annual harvest by commercial and recreational fisheries) and how these impacts have changed since the issuance of the Operating License.

There have been no observed impacts associated with operation of Farley Nuclear Plant on use of aquatic resources by others. Initial evaluation of the impact of plant operation on usage of fisheries resources by commercial and recreational fishermen is documented in the Farley Nuclear Plant Environmental Report - Operating License Stage (ER-OLS). The ER-OLS indicated no significant impact from plant operation on use of aquatic resources was expected. There has been no observed indication that any change, with regard to impact of plant operations on use of aquatic resources, has occurred since the issuance of the Operating License.

8. Describe other sources of impacts on aquatic re' sources (e.g.,

industrial discharges, other power plants, agricultural runoff) that could contribute to cumulative impacts. What are the relative contributions by percent of these sources, including the contributions due to the power plant, to overall water quality degradation and losses of aquatic biota?

There has been no observed degradation in water quality of the Chattahoochee River noted as a result of operation of Farley Nuclear Plant. In addition, there has been no indication of water quality degradation due to impacts resulting from other sources located in close proximity to Farley Nuclear Plant. A decrease in water quality in distant upstream impoundments has been noted due to increased loading from wastewater treatment plants and combined sewer overflows from the Atlanta, Georgia metropolitan area. No effects have been noted in the Farley Nuclear Plant area or immediate upstream reservoirs to date.

9. Provide a copy of the Section 316(a) and (b) Demonstration Report required by the Clean Water Act. What Section 316(a) and (b) determinations have been made by the regulatory authorities?

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A copy of the Farley Nuclear Plant Section 316(b) study for Unit 1 and Unit 2 is included as Attachment 1 to this correspondence. A copy of a supporting study entitled Environmental Non-Radioloaical Mot.itorina of Aqua 11g (qmmunities in the Chattahoochee River _ is also included.

Section 5.3.2 of the Farley Nuclear Plant Final Environmental Statement indicates the initial thermal analysis provided is conservative and adequate to ensure compliance with discharge criteria; therefore, a demonstration study under Section 316(a} was not warranted.

All studies conducted at Farley Nuclear Plant under authority of the Clean Water Act resulted in findings of "no significant environmental impact" and were accepted by the regulatory agencies as satisfying the conditions s?ecified in the Environmental Protection Plan.

g e m s. p m 'Ca, SOCIOECONOMIC QUESTIONS FOR ALL UTILITIES

1. To understand the importance of the plant and the degree of its socioeconomic impacts on the local region, estimate the number of ptrmanent workers on-site for the most recent year for which data are available.

1989 912 Positions

2. To understand the importance of the plant to the local region, and how that has changed over time, estimaLq the average number of permanent workers on site, in five-year increments starting with the issuance of the plar.t's Operating License. If possible, provide this information for each unit at a plant site.

Total Posit. ions on sitn (both units 1 Unit 1 OL Aug 1977 317 Positions Unit 2 OL Mar 1981 773 Positions 1986 882 Positions

3. To understand 1he potential impact of the continued operation for an additional 20 years beyond the original licensing term, please provide for the following three cases:

A) a typical planned outage; B) an ISI outage; and C) the largest singic outage (in terms of the number of workers involved) that has occurred to date

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an estimate of additional workers involved (for the entire cutage and for each principal task), length of outage, months and year in which work occurred, and cost. Alsc, utimate occupational doses received by permanent and temporary workers during each principal task.

Additional Radiation Cases Duratiorl Golt Workers hposure A Typical Planned Outage 51 days $20M 530 382 MAN-REM Unit 1 - Sixth Refueling 4/6/85 - 5/27/85 An ISI Outage and 56 days $21.25M 777 431 MAN-REM Unit 1 Eighth Refueling 3/26/88 - 5/21/88 Largest Single Cutage 242 days Not 3300 530 MAN-REM Unit 1 First Refueling Available 3/8/79 - 11/5/79 l

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4. To understand the plant's fiscal irnportance to specific jurisdictions, for 1980, 1985, and the litest year for which data are ava N ble, atinalg the entire plant's taxable asscssed value and the artount of taxes paid to the state and to each local taxing jurisdiction.

IMO

• 19f.L_ 19M Assessed Value $168,963,445 $247,351,020 5266,708,680 Ad Valorem Tax $ 4,899,939 $ 6,431.127 $ 6,934,426

• It 2 w s still under construction.

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WASTE MANAGEMENT QUES 110NS [

A. Spent fuel questions:

1. Which of the following current techniques for at-reactor storage l are you uting and how?

A. Re-racking of spent fuel, f Both fuel pools have been completely rer :ked with high density racks.

B. Control _ rod repositioning. -

Deleted via NUMARC.

C. Above ground dry storage.

Not being used. -

D. Longer fuel burnup. __

Sverage discharge burnups have been trending upward. This is besng done to attain desired cycle energies and to  ;

- reduce fuel costs, not specifically to extend storage  ;

capacity.

E. Other (please identify).

None.

2.- Do you plan on continuing the use of these arrent techniques for at-reactor storage of spent fuel during the remaining time of your operating license or do you expect to change or modify them in some way?

No changes in current strategy are planned. l 3 Which of the following techniques for at-reactor storage do you i anticioate using until off-site spent fuel storage becomes available and-how?

A. Re-racking of spant fuel.

No. No further reracking is possible.

D. Control rod repositioning.

. Deleted via NUMARC.

C. Above ground dry storag';.

Not expecced to be required. Sufficient pool storage capacity is currently available to permit normal plant-operation of Plant farley Unit 1 into the year 2010 and Unit 2 in+- '.he year 2013.

D. Lont,ar fuel burnup. i

- Current fuel cycle planning calls for continuing increases in discharge-burnups.

E. Other-(please idereify).

None.

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4. Will the techniques described above be adequate for continued at-reactor storage of spent fuel for the operating Ilfetime of the plant, including a 20-year period of Itcense renewal, or are you developing other plans?

Alabama Power Company has entered into an agreement with the U. S. Department of Energy for the permanent disposal of the spent fuel generated through the life of Plant Farley. Under the agreement, for a fee paid to the government, the DOE is to begin receiving and take titic to spent fuel from Plant farley not later than January 31, 1998. The required fees have been paid to the DOE on all fuel discharges from the plant, and are paid on a quarterly basis for fuel currently operating in the plant.

Sufficient pool storage capacity is currently available to permit normal plant operation of Plant Farley Unit 1 into the year 7010 and Unit 2 into the year 2013. Because APC 9xpects the DOE to meet its contractual obligation to begin accepting spent fuel fiom Plant Farley pr ior to the time that the fuel storage pools will be filled, there will be no need for additional storaga capability at Plant Farley.

5. Do you anticipate the need to acquire additional land of the storage of spent fuel fcr the operating lifetime of the plant, including a 20-year period of Itcense renewal? If so, how much land? When would this acquisition occur? Where? (if answer is "yes", 3-4 sentences)

No. See response to question 4,

6. Do you anticipate any additional construction ectivity on-site, or immediately adjacent to the power plant site, associated with the continued at-reactor storage of spent fuel for the operating lifetime of the plant, including a 20-year period of license renewal? (yes/no)

No.

7. If you answered yes to question 6, briefly describe this construction activity (e.g., expansion of fuel storage pool, building above group dry storage facilities)

N/A-

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i B. Low-level radioactive waste management-questions: j

1. Under the current scheme for LLRW disposal (i.e. LLRW Policy .

Amendments Act of 1985 and regional compacts) is there currently or will sufficient capacity for wastes nenerated during the license renewal period be available to your plant (s)? If so, what is the basis for this conclusion? j Plant Farley is located in the State of Alabama and  !

therefore is in the Southeast Compact. The current i disposal facility in South Carolina and the proposed LLRW  ;

facility to be located in the State of North Carolina has i or will have sufficient burial space to meet the anticipated needs of Plant Farley.

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2. If for any reason your plant (s) is/are denied access to a licensed disposal site for a short period of time, what plans do you have i for continued LLRW disposal? l Plant Farley has approximately 40 months of on-site storage-available for Dry. Active Waste (DAW). l

3. In a couple of pages, please describe the specifi: methods of LtRW management currently utilized by your plant. What percantage of 3 your current LLRW (volume) is managed by: ,

A. Waste compaction?

85-90 % of DAW is compacted or incinerated by contractor. ,

B. Waste segregation (through special controls or segregation at radiat.an check points)7 Waste volume avoidance is practiced by special controls at both the Radiation Control Area (RCA) control-point inside  ;

the RCA and-the out processing area of the RCA. Addltional Waste segregation is practiced in the LLRW processing building. Waste minimization is part of planning. The percentage of waste saved is an unknown quantity.  ;

C. Decontamination of wastes?

When economically feasible and/or practical waste is f decontaminated by various methods.

D. Sorting of waste prior to shipment?

80-90 % of total waste from the RCA.

E. Other (please identify) .

4 Plant Farley utilizes the services of a contractor fer waste minimization such as supercompaction, oil and waste incineration, metal smelting and offsite decontamination.

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4. In a couple of pagas, please describe the anticipated plans for LLRW management to be utilized by your plant (s) during the remainder of the operating license and through the license renewal term. What percentage of your Anticipittd waste (by volume) will be managed by:

A. Waste compaction?

80-90 % Essentially the same as item 3.A B. Waste segregation (through special controls or segregation at radiation check points ?

Essentially the same as item 3.B C. Decontaminition of waste?

Essentially the same as item 3.C D. Sorting of waste prior to shipment?

Essentially the same as item 3.0 E. Other (please identify)?

The utilization of new technology as it becomes available is the only change to item 4.D that would be different from 3.E.

5. Do you anticipate the need to acquire additional land for the storage of LLRW for the operating lifetime of the plant, including the 20-year period of license renewal ? If so, how much land ? When would this acquisition occur ? Where ? (if answer is "yes", 3-4 sentences)

There is no need to acquire any additional land at Plant Farley.

6. To provide information on the timing of future low-level waste streams, it you answered yes to questions #5 (#9, via NUMARC), over what periods of time are these activities contemplated?

N/A

7. Do you anticipate any additional construction activity, on-site, or immediately adjacent to the power plant site, associated with temporary LLRW storage for the operating lifetime of the plant, including a 20 year period of license renewal? (yes\no)

Yes

8. If you answered yes to question 7, briefly describe this construction activity (e.g. storage areas for steam generator components or other materials exposed to reactor environment),

Consideration is being given to constructing mat .,leums to contain the steam generators should replacement :e necessary.

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9. To provide information on future low-level waste streams which may effect work force levels, exposure, and waste compact planning, do you anticipate any major plant modifications or refurbishment that are likely to generate unusual volumes of Low-Level radioactive waste prior to, or during, the re-Itcensing period for the plant?

If so, please describe these activities. Also, what types of modifications do you anticipate _to be necessary to achieve license renewal operation through a 20-year license renewal term?

Plant Farley anticipatos no major modifications for license renewal.

C. Mixed Low-level radioactive waste question:

1. If your plant-generates mixed LLRW, how is it currently being stored and what plans do you have for managing this waste during the license renewal period?

Deleted via NUMARC.

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