ML20079N385

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Response to NUMARC Survey Re Socioeconomic,Aquatic Resource & Waste Mgt Questions in Support of NRC License Renewal Rulemaking
ML20079N385
Person / Time
Site: Vogtle  Southern Nuclear icon.png
Issue date: 11/11/1991
From:
GEORGIA POWER CO.
To:
References
RTR-NUREG-1437 AR, S, WM, NUDOCS 9111110193
Download: ML20079N385 (21)


Text

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O INDUSTRY SURVEY IN SUPPORT OF LICENSE RENEWAL RULEMAKING 7

RESPONSE

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V0GTLE ELECTRIC GENERATING PLANT GEORGIA POWER COMPANY

3 nag 3g mm 1437 C PDR

Q 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 permanent workers on-site for the most recent yes? for which data are available.

1989 1262 Positions

2. To understand the importance of the plant to the local region, and how that has changed over time, estimate the average number of permanent workers on site, in five-year increments starting'with the issuance of the plant's Operating License. If possible, provide this information for each unit at a plant site.

Total Positions on sit 9_.(Both Units)

Unit 1 OL 1987- 1520 Positions Unit 2 OL 1989- 1262 Positions

3. To understand the 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 single outage (in terms of the number of werkers involved) that has occurred to date an estimate of additional workers involved (for the entire outage and for each principal task), -length of outage, months and year in which work occurred, and cost. Also, estimate occupational- doses received by permanent and temporar'y workers during each principal.

task.

Vogtle has only had two refueling outages to date.,

Therefore, little historical information with respect to refueling outages is available to provide-a response to cases A,B and C. Tnt following data is:provided for both of the Vogtle outages. No data is available for an ISI outage at this time.-

Additional Radiation Cases Durat on-- Cost Workers Exposure First Refueling Outage 52 days $15.1M 902 134' MAN-REM Unit 1 10/88 - 11/88 Second Refueling Outage 56 days $20M 900 212 MAN-REM Unit 1 2/90 - 4/90

C 4. To understand the plant's fiscal importance to specific jurisdictions, for 1980, 1985, and the latest year for which data are available, estimate the entire plant's taxable assessed value and the amount of taxes paid to the state and to each local taxing jurisdiction.

1103 Assessed Value $687,821,393 Burke County Taxes $ S,3L,,030 State Taxes $ 171,955 Note: Both units were still under construction in 1980 and 1985.

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1 waste "^"^ctat"' oues'to"s O

A. Spent fuel questions:

1. Which of the following current techniques for at-reactor storage are you using and hr#?

A. Re-racking of spent fuel.

Both units' fuel pools have been completely reracked with high density storage racks.

B. Control rod repositioning. '

Deleted via NUMARC.

C. Above ground dry storage.

Not being used.

D. Longer fuel burnup.

Average discharge burnups have been trending upward. This is being done to attain desired cycle energies and to reduce fuel costs, not specifically to extend storage capacity.

E. Other (please identify).

Ntne.

2. Do you plan on continuing the use of these current 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 scme way?

No changes in strategy are anticipated.

3. Which of the fo M wing techniques for at-reactor storage dc you anticipate using until off-site spent fuel storage becomes available and how?

A. Re-racking of spent fuel.

  • No additional reracking anticipated.

B. Control rod repositioning.

Deleted via NUMARC.

C. Above ground dry storage.

None is anticipated at this time.

D. Longer fuel burnup.

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

j E. Other (please identify).

None.

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Will the techniques described above be adequate for cu, Q 4.

at-reactor storage of spent fuel for the operating -

plant, including a 20-year period of license renewa , .

I developing other plans?

Georgia Power Company has entered into an ag,r< . .

r i the U. S. Department of Energy for the perma 4 0 co< '

of the spent fuel generated through the li' ':*

Hatch. Under the agreement, for a fee paic t governm3nt, the DOE is to begin receiving and .eb )

spent fuel from Plant Hatch not later than aanuary n 1998. The required fees have been paid to the t h ...

fuel discharges from the p; ant, and are paia on a c .a r basis for fuel .wcently operating in the plant.

Suf ficient pool s+.c.- age capacity is currently an i .al . a permit normal plant operation of Plant Hatch into the yu 2003. Because GPC expects the DOE to meet its contractual obligation to begin accepting spent fuel from Plant Hatch prior to the time that the f el storage pools will be filled, there will be no need for additional storage capability at Plant Hatch. GPC is evaluating the impact and possible options there would be if the DOE fails to meet its contractual obligation.

5. Do you anticipate the need to :cquire additional land of the O storage of spent fuel for the operating lifetime of the plant, including a 20-year period of license 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 activity on-site, or l 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.

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

N/A 1

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(] B. Low-level radioactive waste management questions:

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 generated during the license renewal period be available to your plant (s)? If so, what is the basis for this conclusion?

Plant Hatch is located in the State of Georgia and therefore is in the Southeast Compact. The current disposal facility in South Carolina and the proposed LLRW facility to be located in the State of North Carolina has or will have sufficient burial space to meet the anticipated needs of Plant Hatch.

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 for continued LLRW disposal?

Plant Hatch has approximately 30 months of on-site storage available for Dry Active Waste (DAW). Resins require shielding containers for storage which would necessitate purchasing additional shielding containers if the plant was denied access to.a licensed disposal site for a long period O

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

A. Waste compaction?

85-90 Y. of DAW is compacted.

B. Vaste segregation (through special controls or segregation at

.adiation check points)? '

Waste volume avoidance is practiced by special controls at both the Radiation Control Zone (RCZ) control point, inside the RCZ and the out processing area of the RCZ. Additional 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 decontaminated by various methods.

9 D. Sorting of waste prior to shipment?

80-90 % of the waste from the RCZ.

E. Other (please identify).

Plant Hatch utilizes the services of a contractor for waste minimization such as supercompaction, oil incineration, and metal smelting.

- --- -- 4

).

In a couple of pages, please describe the anticipated plans for.

Q 4.

  • LRW management to be utilized by your plant (s) during the amainder of the operating license and through the license renewal ,

term. What percentage of your anticipated waste (by volume)-will be ,

managed by:

A. Waste compaction?80-901 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. Decontamination of waste?-

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

Essentially the same as item 3.D 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.

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5. Do you antisipate 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) l Thero is no need to acquire any additional land at Plant  ;

Hatch.

6. To provide information on the timing-of future low-Level waste streams, if 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, o_n-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)

No, i

i- 8. If you answered yes to question 7. briefly describe this

construction activity (e.g. storage areas for steamLgenerator j components or other materials exposed to reactor environment).

l No construction is: anticipated.

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L - . . , _- - . - - - -. , . . . . . . . - _ . . . - - - - . _ - - - . . - -_

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() 9. To provide information on-future low-l.evel waste streams which may effect work force levels, ,oesure, and waste compact planning, do you anticipate any major -t nodifications or refurbishment that are likely to generat. O c.lun,as of Low-Level radioactive waste prior to, or de . licensing period for the plant?

If so, please describt - ' as. Also, what types of modifications do you anc o secessary to achieve license renewal operation througF '

s " ar se renewal term?

Plant Hatch is plant;- 4 '

rweiifications for license i

renewal. However, rep ' ' ??.a Unit I recirculation l

system piping is a contin 5 enc'.

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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O ^au^ tic acsouaces outstions

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 pest-licensing modifications or changes in operation to cooling water intake or discharge systems which have altered the effect, as identified in the Final Environmental Statement (FES) and rupporting documents, of Hatch Nuclear Plant on aquatic resources. It should be noted that Hatch Nuclear Plant does not utilize once-through cooling for the main condensers. Main condenser c.ooling 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 Altamaha river and are returned to the river via a common discharge line.

Changes have been made to service water and circulating

]' water chemical treatment 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 5.5.3 of the Hatch Nuclear Plant Environmental Technical Specifications (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 ongoing or were the result of start-up problems that were subsequently resolved).

There have been no events prior to or since the issuance of the Hatch Nuclear Plant Operating License which have resulted in significant impact to aquatic resources. There have been no documented fish kills or other events which could indicate any negative impact on the aquatic

(~') environment attributable to the operation of Hatch Nuclear

'v Plant.

Although there have been occasional exceedances of NPDES

_Q v Permit limits, the overall NPDES Permit compliance record for Hatch Nuclear Plant is excellent. In no case has an '!

exceedance of NPDES Permit limits resulted in significant l impact to aquatic resources. There is no indication that I any appreciable difference exists between impacts associated with start-up and on-going operation. As stated I

previously there has been no observation of any significant impact to aquatic resources.

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 p'lant since issuance of the Operating License.

Due to major changes in NPDES regulations since the licensing of Hatch Nucient Plant, the renewal of the NPDES permit in 1988 resulted in increased regulation over the initial permit. The increased regulation was primarily.

attributable to the regulatory chan5es made as a result of promulgation of the Effluent Guidelines for Steam Electric Generating Facilities in 1982. The changes were in no way tied to plant NPDES compliance issues but were implemented O in accordance with Congressional mandate under the Cleon Water Act.

4. An examination of trends in the effects on aouatic resources monitoring can indicate whether impacts have-increased,. decreased, or remained relatively stable durin_g 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 Hatch 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. A Section 316(a) study to verify the thermal plume model used _ in the Environmental Report - Operating License Stage-and a biological survey to fulfill .the Section 316(b) i requirements were required as a condition of the Hatch Nuclear Plant NPDES Permit. Both studies were completed in l

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March 1981 an; ncluded that no significant environmental O impact was n:...,ad. This finding was consistent with the finding published in the Final Environmental Statement.

The studies were submitted to the State of Georgia -

Department of Natural Resources and approved in August 1981. Additional studies were not required. Copies of the studies are included as A'tachment I to this correspondence.

There has been no observed trend with regard to Hatch 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 Statement and supporting documents.

5. Summarize types and numbers (or provide dor.umentation) 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 impinaement. How has entrainment and impingement changed over time?

Types and numbers of organisms entrained or impinged by the river water intake system are provided in the Section p 316(b) report for Hatch Nuclear Plant included as V 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 has displayed any change with time.

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

anadromcus fish runs) during operation may have enhanced the biological communities in the vicinity of the plant.

Alternatively, degradation 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 Hatch Nuclear Plant since the issuance of the Operating License. Impingement, entrainment, larval fish and fisheries studies conducted as a condition of the Hatch Nuclear Plant NPDES Permit indicate no significant impact associated with plant operation to the biological communities in the vicinity of q Hatch Nuclear Plant.

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Plant operations may have had positive, negative, or no impact on Q 7.

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 Hatch 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 HaLh 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 is no 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 resources (e.g.,

p industrial discharges, other power plants, agricultural runoff)

V 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 Altamaha River noted as a result of operation of Hatch 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 Hatch Nuclear Plant.

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?

Copies of tne Section 316(a) Thermal Plume Model Verification Study and the Section 316(b) Biological Survey completed as a condition of the Hatch Nuclear Plant NPDES Permit are included as Attachment 1 to this correspondence.

All studies conducted at Hatch Nuclear Plant under authority of the Clean Water Act resulted in findings of "no p significant environmental impact" and were accepted by the V regulatory agencies as satisfying the conditions specified in the licensing documents.

h WASTE MANAGEMENT QUESTIONS A. Spent fuel questions: ,

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

4 A. Re-racking of spent fuel.

The Vogtle Unit 2 -fuel pool has been completely reracked with high density racks. The two storage racks in the Unit 1-fuel pool are also high density racks.

B. Control rod repositioning.

Deleted via NUMARC.

C. Above ground dry storage.

- Not being usi:d.

D. Longer fuel burnup.

Average discharge burnups have been trending upward. This is being done to attain desired cycle ene qies and to reduce fuel costs, not- specifically to extend storage capability.

E. Other (please identify).

None, P

U 2. Do you plan on continuing the use of these current 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 anticipated.

3. Which of the following techniques for at-reactor storage do you anticioate using until off-site spent fuel; storage becomes l

available and how? '

A. Re-racking of spent fuel.

No further reracking should be required. See response to l question-4.

B. Control rod repositioning.

Deleted via NUMARC.

C. Above ground dry storage.

Not expected to be required.. Sufficient pool storage-capacity is currently available to permit normal plant operation of Plant Vogtle into the year. 2011.

D. Longer fuel burnup.

Current fuel cycle planning call for continued increases in discharge burnups.

E. Other (please identify).

None.

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Will the techniques described above be adequate for continued Q 4.

at-reactor storage of spent fuel for the operating lifetime of the plant, including a 10-year period of license renewal, or are you developing other plans?

Georgia 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 Vogtle. Under the agreement, for a fae paid to toe government, the DOE is to begin receiving and take title to spent fuel from Plant Vogtle 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 Vogtle into the year 2011. Since GPC expects the DOE to meet its contractuhl obligation to begin accepting spent fuel from Plant Vogtle prior to the time that the fuel storage pools will be filled, there will be no need for additional storage capability at Plant Vogtle.

5. Do you anticipate the need to acquire additional land of the storage of spent fuel for the operating lifetime of the plant, including a 20-year period of license 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 activity 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 & 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 O

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Low-Level radioactive waste management questions:

O B.

1. Under the current scheme for LLRW disposal (i.e. LLP.W policy Amendments Act of 1985 and regional :ompacts) is there currently or will sufficient capacity for wastes generated during the license renewal period be available to your plant (s)? If so, what is the basis for this conclusion?

Plant Vogtle is located in the' State of Georgia and therefore is in-the Southeast Compact. The current disposal facility in South Carolina and the proposed LLRW facility to be located in the State of North Carolina has or will have sufficient burial space to meet the anticipated needs of Plant Vogtle.

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 for continued LLRW disposal?-

Plant Vogtle has approximately 40 months of on-site storage available for Dry Active Waste (DAW).

3. In a couple of pages, please describe the specific methods of LLRW management currently utilized by your plant. What percentage of O your current'LLRW (volume) is managed by:

A. Waste compaction?

85-90 % of DAW is compacted.

l B. Waste segregation (through special controls or segregation' at radiation check points)? 't Waste- volu::.e avoidance is practiced- by-special- controls at both the Radiation Control Zone (RCZ) control point, inside-the RCZ and the out processing' area of the RCZ. Additional Waste segregation is practiced in the LLRW processing building.. Waste minimization is prt of planning. The percentage of waste saved is an unknown quantity.

, C. Decontamination of wastes?

l When economically feasible and/or practical waste-is

! decontaminated by various methods. '

l D.-Sorting-of waste. prior to shipment?

l 80-90 % of.the waste in the RCZ.

E. Other (please identify).

Plant Vogtle utilizes the services of a contractor for:

waste minimization such as supercompaction, oil incineration, and metal smelting.

.O

O 4. ia a coun'e or ne9es. nieese describe the aaticineted pleas 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 anticipated waste (by volume) will be managed by:

A. Waste compaction?

80-90 Y, Essentially th<s same as item 3. A B. Waste segregation (through sr;ecial controls or segregation at radiation check points?

Essentially the same as item 3.8 C. Decontamination 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 tha only change to item 4.0 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 Q sentences)

There is no need to acquire my additional land at Plant Vogtic.

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

( N/A l

l 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)

No.

8. If you answered yes to question 7, briefly describe this l

construction activity (e.g. storage areas for steam generator l components or other materials exposed to reactor environment).

No construction is anticipated.

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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-licensing 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 Vogtle anticipates 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, O

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O xoutric aESouncES ouES11ons l

1. Post-licensing modifications and/or cnanges 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

! plant. 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 or discharge systems which have altered the effect, as identified in the Final Environmental Statement (FES) and supporting documents, of Vogtle Electric Generating Plant on aquatic resources. It should be noted that Vogtle Electric Generating Plant does not utilize once through cooling for the main condensers.

Main condenser cooling is provided by a circulating water system utilizing natural draft cooling. towers; makeup is obtained from the Savannah River. Service water and most auxiliary cooling systems are supplied by groundwater sources; some auxiliary cooling systems are once-through systems. Once-through cooling water and cooling tower blowdown are discharged to the Savannah River via a common discharge line.

Q Changes have been made to service water and circulating water chtmical treatment 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 Vogtle Electric Generating Plant 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 (eg. fish kills,' violations of discharge permit conditions) or National Pollutant Discharge

, Elimination System.(NPDES) enforcement actions that have occurred since issuance of the_0perating License. How have these been resolved or changed over time? (The response to this question

, should indicate whether impacts are ongoing or were the result of start-up problems that were subsequently resolved).

There have been no events prior to or since the issuince of the Vogtle Electric Generating Plant Operating License

< which have resulted in significant impact to aquatic resources. There have been no_ documented fish kills or

Q other events which could indicate any negative impact on the aquatic environment attributable to the operation of 4

Vogtle Electric Generating Plant.

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

As stated previously there has been no obsarvation of any significant impact to aquatic resources.

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.

There were changes made to the NPDES Permit during the permit renewal process which took place in 1989. 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. The changes primarily involved the lowering of total residual chlorine (TRC) discharge limits to conform to EPA Water p Quality criteria based limits under the NPDES Permit V Program. Since Vogtle Electric Generating Plant utilizes a dechlorinator to remove chlorine residuals prior to discharge, this change did not significantly impact the chemical treatment program for the circulating water system.

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 (eg. related to NPDES permits, Environmental Technical Specifications, site-specific monitoring required by federal or state agencies). What trends are apparent over time?

The Vogtie Electric Generating Plant Final Environmental Statenent, 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 Vogtle Electric Generating Plant O Environmental Protection Plan, Appendix B to the Operating V Licenso, the NRC indicates no specific impacts to aquatic resources were identified in the Final Environmental Statement which merited further evaluation or demonstration studies.

There has been no-observed trend with regard to Vogtle O Electric Generating 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 Statement and supporttng documents.

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

Types und numbers of organisms entrained or impinged by the river water intake system are provided in the Environmental Report - Operating License Stage for Vogtle Electric Generating Plant. -No additional-studies were required as a condition of the Environmental Protection Plan, therefore, a Section 316(b) demonstration study subsequent to issuance of the Operating License was not required. As expected, seasonal-variation in the types of organisms entrainod or impinged was noted in the Environmental Report - Operating License Stage but was not decned to be significant. There is no indication that entrainment or impingement has displayed any change with time.

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6. Aquatic habitat enhancement or restoration efforts (eg.-anadromous fish runs) during operation may have enhanced the biological communities in the vicinity of the plant. Alternatively, degradation 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 l of the power plant- since the issuance of the Operating License l 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 Vogtle Electric Generating Plant since the issuance of the Operating License. There is no-indication that any changes to aquatic resources have occurred nor has there been_any observation of unpredicted impacts since the issuance of the Operating License.

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O 7. Plant operations may have had positive, negative, or no impact on the use of aquatic resources by others. Harvest by cc,mmercial 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 (eg., 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 operatio1 of Vogtle Electric Generating 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 ?s documented in the Vogtle Electric Generating 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 is no 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 resources (eg.,

gA 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 l

degradation and losses of aquatic biota?

I There has been no observed degradation in water quality of the Savannah River noted as a result of operation of Vogtle Electric Generating Plant. In addition, there has been no indication of water quality degradation due to impacts l resulting from other sources located in close proximity to Vogtle Electric Generating Plant. The pretence of the Savannah River Plant upstream of Plant Vogtle represents a potential source of discharge which could effect water quality of the Savannah River. There has been no observed I

effect on water quality attributable to the Savannah River Plant or other sources 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?

The Vogtle Electric Generating Plant Environmental Protection Plan states in Se:tior 2.0 that no aquatic issues which required study or ':c mse conditions to (V) resolve concerns and assure adequate protection of the environment were identified. Demonstration studies under the authority of the Clean Water Act Sections 316(a) and (b) were not required.