ML20086N207
| ML20086N207 | |
| Person / Time | |
|---|---|
| Site: | Grand Gulf  |
| Issue date: | 07/21/1995 |
| From: | Hutchinson C ENTERGY OPERATIONS, INC. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| GNRO:95-00083, GNRO:95-83, NUDOCS 9507250143 | |
| Download: ML20086N207 (19) | |
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Ent:rgy Cperati nt, int P.O Eky 756 ]
l Operations % oesm m 39 s0
'Tel 601 437-2800 L
i July 21,1995 !
t U S. Nuclear Regulatory Commission 1 Mail Station P1-37 !
Washington, D.C. 20555 l
Attention: Document Control Desk .
Subject:
Grand Gulf Nuclear Station !
Docket No. 50-416 l License No. NPF-29 }
Recapture of Low Power Testing Period Proposed Amendment to the ;
Operating License (PCOL-95/01)
GNRO: 95/00083 l l
l Gentlemen: !
Entergy Operations, Inc. is submitting by this letter a proposed amendment to the {
Grand Gulf Nuclear Station (Grand Gulf) Operating License in order to obtain a full 40 year service life for Grand Gulf.
The proposed change requests that the current expiration date for license NPF-29 be changed to reflect the issuance date of the new license granted Grand Gulf on i November 1,1984. This proposed change is not unlike that requested and [
granted to other utilities for the purpose of recovering construction time. The j similarity of this request is further explained in an attachment to this letter.
Attachment 2 provides a detailed description of the proposed change, justification, !
and the no significant hazards considerations. Attachment 3 is a copy of the [
markad-up operating license. Attachment 4 provides a detailed assessment of the l potentialimpact to the environment presented by this request. Attachment 5 i provides additional insights into the potential benefits of this change. [
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ok 9507250143 930721 m\ j PDR ADOCK 05000416 P PDR r
o GNRO-95/00083
. i Page 2 of 2 - l
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l It is Entergy Operations, Inc. desire that this be treated as a cost beneficial licensing :
action and given appropriate priority. This action will save Entergy Operations, Inc.
approximately $120M in purchased power and well in excess of $100,000 in additional _;
construction cost.
~ In accordance with the provisions of 10CFR50.4, the signed original of the requested amendment is enclosed. This amendment has been reviewed and accepted by the plant ,
safety review committee and the safety review committee. Based on the guidelines presented in 10CFR50.92, Entergy Operations has concluded that this proposed amendment involves no significant hazards considerations. i Yours truly,
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CRH/LFD/
Attachment 1. Affirmation per 10CFR50.30 Attachment 2: Detailed Description of the Proposed Change, Justification, and the No Significant Hazards Considerations Attachment 3: Copy of the Marked-Up Operating License ,
Attachment 4: Detailed Assessment of the PotentialImpact to the Environment i Attachment 5: Potential Benefits to Grand Gulf in Recapturing the Low Power Testing Period cc: Mr. J. Tedrow (w/a) [
Mr. H. W. Keiser (w/a) ,
Mr. R. B. McGehee (w/a) [
Mr. N. S. Reynolds (w/a)
Mr. H. L. Thomas (w/o)
{
Mr. Stewart D. Ebneter (w/a)
Regional Administrator !
U.S. Nuclear Regulatory Commission l Region 11 ;
101 Marietta St., N.W., Suite 2900 l Atlanta, Georgia 30323 !
i Mr. P. W. O'Connor, Project Manager (w/2) j Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission .
Mail Stop 13H3 '
Washington, D.C. 20555 ,
, Att: chm:nt 1 to GNRO-95/00083 Page 1 of 1 BEFORE THE UNITED STATES NUCLEAR REGULATORY COMMISSION LICENSE NO. NPF-29 DOCKET NO. 50-416 IN THE MATTER OF MISSISSIPPI POWER & LIGHT COMPANY and SYSTEM ENERGY RESOURCES, INC.
and SOUTH MISSISSIPPI ELECTRIC POWER ASSOCIATION and ENTERGY OPERATIONS, INC.
AFFIRMATION 1, C. R. Hutchinson, being duly sworn, state that I am Vice President, Operations GGNS of Entergy Operations, Inc.; that on behalf of Entergy Operations, Inc., System Energy Resources, Inc., and South Mississippi Electric Power Association I am authorized by Entergy Operations, Inc. to sign and file with the Nuclear Regulatory Commission, this application for amendment of ,
the Operating License of the Grand Gulf Nuclear Station; that I signed this application as Vice l President, Operations GGNS of Entergy Operations, Inc.; and that the statements made and the matters set forth therein are true and correct to the best of my kno ledge 'nfor at and belief.
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C. R. Hutchinson I STATE OF MISSISSIPPI i COUNTY OF CLAIBORNE l I
SUBSCRIBED AND SWORN TO befor me, a Notary Public, in and for the County and State above named, this _.Mday of I 1995.
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Notary Public !
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. Att: chm:nt 2 to GNRO-95/00083 Page 1 of 7 l
Detailed Description of the Proposed Changehttification. and the No Significant Harmrds j Considerations j\
Discussion !
1 Grand Gulf is fairly unique among licensed cornmercial nuclear facilities in having an extended period of low /no power operation at the beginning of its 40-year licensed period.
By this license amendment request, we propose to recapture approximately 2 % years of ;
low /no power operation by extending the 40-year operating license term from June 16, 2022 to November 1,2024 (i.e.,40 years from issuance of the full power operating license on November 1,1984).
As discussed in more detail below, the historical record of the Code of Federal Regulations and Commission licensing activities suggest that a low power license period was not intended to be part of the licensed 40-year life of a facility. Rather, this period was intended to confirm design adequacy in an operational setting. After confirming design criteria, the 40-year license period was to commence with full power operations / licensing.
To the best of our knowledge, recapture of a low power testing period has not previously ,
been proposed to the NRC. We believe this is because the low power testing period for the vast majority of licensed facilities seldom exceeded several months. Since recapture of the low power period only makes economic sense if it allows an additional fuel cycle of operation (i.e., on the order of 18 months), few facilities would find such an approach to be attractive.
For Grand Gulf, however, the additional license period would allow for at least one additional cycle of operation and perhaps two. As a result, the economic value would be I substantial. ,
l Grand Gulf Operating License History ;
1 Because Grand Gulf was licensed during a time when the NRC was going through a !
transition in how it issued low power / full power licenses, it is helpful to review the plant j licensing in some detail. i l
Grand Gulf was originally licensed under Operating License NPF-13 issued June 16, l 1982. This license authorized Grand Gulf to operate at low power (not to exceed 5 l percent rated or 191 megawatts thermal).
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Subsequently, Grand Gulf experienced various delays in completing the low power testing period. These delays were self-imposed or ordered by the Commission as part of the resolution of problems resulting from use of the low power license.
Following resolution of outstanding concems and completion of required license conditions associated with the low power license, Grand Gulf's low power license (NPF-
- 13) was amended (Amendment 13) to allow full power operation on August 31,1984. As >
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. Attcchm:nt 2 to GNRO-95/00083 l Page 2 of 7 1
noted in Commission Order CLl-84-Ib, dated October 25,1984, the amendment of the low power license to authorize full power operation was challenged in the US Court of l Appeals (DC Circuit). In resolving this challenge, the Commission reviewed the process !
for issuing operating licenses Specifically, the Commission stated that:
" issuing a separate full-power license [for Grand Gulf) would have been consistent with past Commission practice in this area. For the two years following the Three Mile Island accident, the Commission, rather than amending existing low-power licenses, issued separate full-power licenses. However, after several such cases it was decided that there was no need to issue two separate licenses. Accordingly, the Commission for the past few years has simply " amended" the existing license by dropping the low-power limitation and authorizing full-power operation." (CLl-84-19, page 6)
(The idea of issuing separate low power and full power licenses, as discussed below, is similar to the original intent of 10CFR50.57 in allowing a period of low power testing which is not to be included in the 40-year full power license period. During the two year post-TMI period referred to in the Order above, the Commission issued some separate full power licenses without including the low power operation period within the 40-year full power license.)
To resolve the legal challenge to the Grand Gulf full power license amendment, the Commission reverted to its previous practice and issued a separate full power license for Grand Gulf. This separate license (NPF-29) was issued on November 1,1984; however, the license duration of 40 years was based on the issuance date of the low power license.
The Grand Gulf startup test program then continued and commercial operation was achieved on July 1,1985.
10CFR50 and Plant Licensing The historical development of several sections of 10CFR50 are relevant to this change:
. 10CFR50.51 covers the duration of an operating license,
. 10CFR50.56 covers the transition from construction permit to operating license,
. And 10CFR50.57 discusses the mechanics of issuing an operating license following construction for a period allowed by 10CFR50.51.
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. Att: chm:nt 2 to GNRO-95/00083 Page 3 of 7 10CFR50.51 states:
"Each license will be issued for a fixed period of time to be specified in the license but in no case to exceed 40 vears from date of issuance Where the operation of a facility is involved, the Commission will issue the license for the term reauested by the aoolicant or for the estimated useful life of the facility if the Commission determines that the estimated useful life is less than the term requested." (emphasis added)
There are several things worth noting with respect to 10CFR50.51 and the Grand Gulf operating license.
. Although Grand Gulf requested a 40-year license, the duration of NPF-29 was not specified as 40 years *from the date of issuance". Rather, the 40-year period was based upon the date of issuance of the separate low power license (NPF-13).
. There has been no finding by the Commission that the estimated useful life of Grand Gulf is less than 40 years.
. Had the original full power license amendment for NPF-13 been unchallenged, the intent of 10CFR50.51,10CFR50.56 and 10CFR50.57 should still have dictated that the 40-year duration commence with the full power license period.
10CFR50.56 and 10CFR50.57 are historically related. As described in 56 FR 64960 (December 13,1991):
" Prior to 1960, the Commission did not have any section of findings for issuance of operating licenses similar to $50.57. Rather, there was simply a provision that permitted conversion of construction permits to operating licenses (now 10CFR50.56). Section 50.57 was adopted for:
" procedures and criteria for the issuance of provisional operating licenses in order to permit orderly and expeditious transition from a construction permit to an operating license where (a) the evidence will not support a finding of completion of construction in compliance with the terms and conditions of the construction permit, or (b) there are involved features, characteristics, or components of a proposed facility as to which it appears desirable to obtain actual or further operating experience before issuance of an ooeratina license for the full leEn, up to forty years, requested by the applicant." 25 FR 8712 (September 9,1960); c125 FR 1225 (February 11, 1960) (proposed rule). [ emphasis added]
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Attachment 2 to GNRO-95/00083 Page 4 of 7 In other words, the intent of the Commission was to separately allow a period of time for a ;
newly licensed plant to obtain operating / testing experience. Most importantly, the l Commission intended that this " desirable" period of " actual or further operating j experience" be completed "before issuance of an operating license for the full term"- i.e., '
the 40-year license was not intended to include the testing period. The Commission's ;
intent to treat the operating license term independently of the startup testing period was i later reconfirmed. '
"Any operating license issued to the applicant may be provisional {
for an initial period of operation, at the end of which time a review is made to determine conditions for the full term license (not to exceed more than 40 years)." " Licensing of Power Reactors," U.S.
AEC, reprinted in Joint Committee on Atomic Energy ("JCAE"),
Hearings on Licensing and Regulation of Nuclear Reactors,90th Cong.,1st Sess.,1967, p. 293.
Of course, the notion of a provisionallicense followed by an operating license evolved over the years. The idea of a provisional license was replaced by a low power license followed by a separate full power license. And, today, the practice is to issue a low power i license and amend it into a full power license. A portion of this changing practice is referred to in the Commission's order on Grand Gulf quoted above. (Not to confuse the issue, but there also evolved the practice of determining the 40-year license period based upon the issuance date of a plant's construction permit. This practice has ceased and most affected plants have subsequently recaptured the construction period in their operating licenses.)
Along this evolving licensing path, however, the original intent of a 40-year full power period was blurred and inconsistently applied. Records indicate that some plants I
received full power licenses whose 40-year duration started with the full power license.
Other plants did not. Because the low power testing period was short in most cases, the discrepancy made little practical difference to most facilities. This is not the case for the Grand Gulf low power license period.
As indicated by the frequent changes in licensing practice over the years, the NRC has considerable flexibility under the Atomic Energy Act (AEA) in defining the starting point of a 40-year license. For instance, when the practice of dating an operating license from the !
issuance of a construction permit was questioned, the staff found that such practice was not required by the AEA.
"Although it has been standard practice to fix the OL expiration date based on the CP issuance date, we have been unable to locate any ;
document which established the basis for this practice." NRC !
Internal Memorandum from Harold R. Denton to Robert M. Bernero
(" Fixing Expiration Date of Operating Licenses"), dated March 16, 1982.
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Attachment 2 to GNRO-95/00083 Page 5 of 7 Similarly, the AEA contains no cornpelling direction to backdate an operating license to the issuance date of a separate low power license. In fact, the historical development of 10CFR50 suggests the contrary.
As discussed earlier, the Grand Gulf Nuclear Station experienced unique site specific delays in achieving full power operations after receipt of the initial low power license.
These delays were self-imposed or ordered by the Commission. For instance, under a confirmatory action letter, Grand Gulf was prohibited from operating (from October 1982 to November 1983) pending resolution of Technical Specification discrepancies.'
Subsequent to resolution of the identified issues and completion of required license conditions associated with the low power license, Grand Gulf was granted a full power license via amendment 13 to the original Operating License NPF-13. This amendment was issued on August 31,1984. Finally, under Order (CLl-84-19) dated October 25, 1984, the Commission directed the NRC staff to issue Grand Gulf a new license. This Order was satisfied by issuance of NPF-29 on November 1,1984.
The operating history for Grand Gulf during this time frame has been docketed in a series of Monthly Operating Reports. Based on a summation of these reports, Grand Gulf was critical for a total of 2286.4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> from June 16,1982 to November 1,1984. The highest power level documented was 21.3% which occurred after receipt of the full power license for testing purposes. First electrical generation was documented as occurring on October 20,1984.
The net effect of this proposed change would be the addition of approximately two operating cycles for the station. The benefits of this proposed change are significant.
The difference between buying replacement power or operating Grand Gulf for this period amounts to approximately 120 million dollars. This change would also put the license expiration date in a compatible position with current projected refueling outage schedules No Significant Hazards Considerations Entergy Operations, Inc. proposes to change the current Grand Gulf Nuclear Station (Grand Gulf) Operating License to modify the expiration date. The change consists of extending the expiration date to 40 years from the date of issuance of License NPF-29 (November 1,1984 to November 1,2024).
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' One could argue that allowing recapture of the Grand Gulf paned of low power licensing would tend to reward poor performance. For several reasons, such an argument has no merit. In the first place, Grand Gulf currently maintains a high level of safety performance over an extended period of time. Approving this change reflects validation of a strong performer. Secondly, Grand Gulf has already incurred significant poor performance penalties during the 2% years of low power operations which produced no commercial electricity. And, finally, while not minimizing the i early performance problems, it is appropriate to recognize that those problems were associated I with a startup organization in its infancy which bears no resemblance to the organization or site culture today.
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, Attachment 2 to GNRO-95/00083 Page 6 of 7 The Commission has provided standards for determining whether a no significant hazards consideration exists as stated in 10CFR50.92(c). A proposed amendment to an operating license involves a no significant hazards consideration if operation of the facility in accordance with the proposed amendment would not: (1) involve a significant increase in the probability or consequences of an accident previously evaluated; or (2) create the possibility of a new or different kind of accident from any accident previously evaluated; or (3) involve a significant reduction in a margin of safety. Entergy Operations, Inc. has evaluated the no significant hazards considerations in its request for a license amendment. In accordance with 10CFR50.91(a), Entergy Operations, Inc. is providing the analysis of the proposed amendment against the three standards in 10CFR50.92(c). A description of the no significant hazards considerations determination follows:
- a. No significant increase in the probability or consequences of an accident previously evaluated results from this change.
The proposed change does not affect the design or operation of any plant system. The effect of 40 years of full power operations has previously been evaluated and documented in the Updated Final Safety Analysis Report (UFSAR). The design life of structures, systems and components is controlled by existing plant problems and processes that are not affected by this change. The proposed change will simply allow Grand Gulf to achieve its original planned 40 years of service. Equipment associated with initiating event frequencies or accident mitigation must continue to meet all applicable maintenance and operability requirements regardless of license duration.2 Therefore, the probability or consequences of previously analyzed accidents are not significantly increased.
- b. The change would not create the possibility of a new or different kind of accident from any previously analyzed.
The proposed change will not add any plant equipment or introduce any new modes of plant operation. The change will only amend the operating license to allow 40 years of full power operations. The proposed change does not affect the current maintenance or surveillance practices, which are designed to maintain and monitor the current service life of plant structures, systems and components in accordance with regulatory requirements. Therefore, the proposed change does not create the possibility of new equipment failure modes or a new or different kind of accident from any accident previously evaluated.
It is also interesting to note that the license duration limitation of 40 years, as contained in 10CFR50.51, is not a limitation resulting from concerns over plant aging effects. "In fact, the limit ,
was a compromise between the efforts of the Justice Department and electric cooperatives, who j championed a 20-year limit on the basis of antitrust concerns, and the view of the utility industries that a longer penod was necessary to ensure full amortization of a nuclear power plant."(56 FR 64961, December 13,1991)
Attachm:nt 2 to GNRO-95/00083 Page 7 of 7
- c. This change would not involve a significant reduction in a margin of safety.
The proposed change does not involve a significant reduction in a margin of safety since it only provides for 40 years of full power operations for which the plant is designed. Current Technical Specification surveillance requirements (e.g., associated with 10CFR50 Appendix H) and other regulatory requirements remain in place and will ensure continued compliance with applicable safety margins.
No Significant Environmental Considerations Entergy Operations, Inc. has performed a detailed assessment of the potentialimpacts to the environment presented by this proposed change. This assessment is detailed in Attachment 4 and concluded that there is no significant environmental considerations involved with this change.
Atttchm::nt 3 to GNRO 95/00083 Page 1 of 1 Copy of the Marked-Up Operating License F. E01 shall report any violations of the requirements contained in Section 2. Items C.(1). C.(4) through C.(38) of this license within twenty-four (24) hours. Initial notification shall be made in accordance with the provisions of 10 CFR 50.72 with written follow-up in accordance with the procedures described in 10 CFR 50.73(b). (c). and (e).
G. The licensees shall have and maintain financial protection of - i such type and in such amounts as the Commission shall require-in accordance with Section 170 of the Atomic Energy Act of I. 1954. as amended, to cover public liability claims.
H. This license is effective as of the date of issuance and shall expire at midnight on Jur.c 15. 202? November 1, 2024.
FOR THE NUCLEAR REGULATORY COMMISSION
! Harold R. Denton, Director l Office of Nuclear Reactor Regulation Attachments:
l 1. Attachments 1 and 2 l 2. Appendix A - Technical i Specifications (NUREG-0934)
- 3. Appendix B - Environmental Protection Plan
- 4. Appendix C - Antitrust Conditions Date of Issuance: November 1. 1984 l
17 Amendment No. 65 1
, Attichm:nt 4 to GNRO-95/00083 ;
Page 1 of 7 Detailed ASAAzAment of the Potentialimoact to the Environment ;
This section deals with the effect of the proposed amendment on the environment. The environmental effects are assessed both onsite and offsite.
Offsite Radiation Exposure Offsite radiation exposure from routine power operation and postulated design basis !
accidents were assessed and documented in the Grand Gulf Updated Final Safety Analysis Report (UFSAR), Chapters 11 and 15, respectively.
The following section provides a comparison of commercial operation with the USFAR estimate of routine long term releases.
Normal Operation Exposure USFAR Estimates The anticipated releases as documented in the Grand Gulf UFSAR were based on a source term (radioactive invenbry available for release) sized for the Grand Gulf design.
The near-site public was used to determine the radiological effect of these releases.
The magnitude of this effect depends on several factors, including distance and age group of exposed individuals and exposure routes (submersion, ingestion, inhalation, .
and direct exposure from ground deposition).
Actual Releases Actual release data and resultant radiation doses to members of the public are :
determined from measured release of radioactive materials and the effect on offsite i receptors (nearby residences and exposure routes).
Historically, Grand Gulf has utilized significant conservatism in the model used to assess dose to the offsite public. This approach maximized the likelihood that doses would not be substantially underestimated. As actual release data accumulated, it was determined the conservative methodology provided a higher calculated dose than necessary. Recent modifications to the dose calculation methodology have resulted in lower, more accurate dose assessment to the public. The dose model continues to '
maintain adequate levels of conservatism to ensure that doses are not substantially underestimated. The parameters used in calculation of offsite doses are subject to modification required by changes in the distribution of near-site public. An annualland use census is required and results incorporated into the dose calculation methodology if determined more restrictive. Since commercial operation began, changes to the population within the 5 mile radius surveyed in the annual land use census have been insignificant.
Additional assurance that offsite doses will be maintained within the limits of 10CFR20 and 10CFR50 Appendix I is through use of alarms on noble gas effluent radiation
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~ Attachment 4 to GNRO-95/00083 Page 2 of 7 monitors. In addition to the conservatism present in dose calculation methodology, Grand Gulf maintains adequate levels of conservatism in setpoint determination. The setpoint methodology provides early indication of increasing effluent release rates prior to exceeding a limit.
Grand Gulf is required by 10CFR50.36a to periodically report the quantity and type of radioactivity released. These Radioactive Effluent Release Reports were reviewed and compared to the UFSAR projections. This comparison is presented in Table 1. Data from start-up testing and less than full power operation (1985 and 1986) is omitted. The doses are well within the 10CFR50 Appendix I limits.
Table 1 Annual Public Dose from Release of Radioactive Materials, Grand Gulf Unit 1 Gaseous lodine, Particulate, Tritium Noble Gas Liquid Organ Gamma Beta Whole body Organ mrem mrad mrad mrem mrem 10CFR 50 Limits
- 15 10 20 3 10 UFSAR '
4 5 8 Projected 1.61 0.82 1.38 0.84 1.42 Grand Gulf Actual 1987 0.94 0.21 0.15 1 1.41 ;
1988 0.03 0.22 0.06 0.14 0.30 1989 0.27 0.18 0.12 0.08 0.37 l 1990 0.25 0.1 0.07 0.09 0.52 .
1991 0.98 0.02 0.02 0.03 0.46 1992 3.56 0.03 0.04 0.06 0.20 1993 0.24 0.02 0.02 0.16 0.23 1994 0.07 0.01 0.01 0.07 0.2 In some cases, actuals shown are above the UFSAR projected. Explanations for these cases and mitigating actions are listed below.
The level of fission products in reactor coolant, gaseous and liquid effluents increases during periods of power operation and following shutdowns when fuel defects are present. Fuel cycle number and corresponding date of discovery for fuel defects are listed for use in interpreting Table 1; Cycle 2 (May 1987), Cycle 4 (August 1989), Cycle 5 ( November 1991) and Cycle 6 (October 1992). In each case, the fuel defect was off-loaded during the next refueling outage.
' 10CFR50, Appendix 1 Section ll
- UFSAR Table 11.3-12, Sheet 2
- UFSAR Table 11.3-12, Sheet 1
- UFSAR Table 11.2-11
Attachment 4 to GNRO-95/00083 j Page 3 of 7 Liquid effluent doses are typically controlled by the presence of cesium-137. Following detection of Grand Gulf's first fuel failure, the use of ion exchange resin with increased affinity for cesium plus administrative controls on the release of liquid waste containing cesium-137 were effective in reducing doses from liquid effluents.
Fuel defects also affect the release of radioactive materials in gaseous form. Gaseous doses from iodine-131 were elevated due to use of the aforementioned conservative ingestion pathway (grassocowomilk at 0.46 miles). The practice, which utilized an onsite garden as a theoretical receptor location, was modified in 1995 to use more realistic pathways and receptors.
In all cases, effluent doses remained well below the 10CFR50 Appendix I limits. Effluent concentrations have been within the limits of 10CFR20. The impact on radiological effluents from the operating license extension will be negligible.
IDarease in Plant Radioactive inventories The concentration of certain radioactive species in plant sistems can increase due to accumulation as the plant ages or from the accelerated release rate of fission products in the presence of fuel failures. At Grand Gulf, the majority of activated corrosion products and fission products have followed this pattern. An exception is the increase in the amount of tritium present in reactor coolant.
Tritium is produced from fission of uranium and mixed oxide fuels as well as neutron reactions with several light elements (including boron-10). At Grand Gulf, boron was formerly present in trace amounts in a corrosion inhibitor used in closed loop cooling water systems and is currently present as the neutron absorber in the Standby Liquid Control System solution and control blades.
In Boiling Water Reactors, the boron pathway has been identified as a contributor to increased tritium concentrations in reactor coolant. While some of these plants operate with a control cell core, which results in more rapid control blade burnup (and potential failure), their experiences should not be ignored in evaluating Grand Gulfs increased tritium level.
In late 1994, Grand Gulf initiated use of a boron-free corrosion inhibitor. Initial control blade replacements are scheduled for Refuel Outage 8 (October 1996).
Although the tritium level in reactor coolant is higher than desired, release concentrations and resulting doses remain well within 10CFR20 and 10CFR50 Appendix I limits. The maximum reactor coolant tritium concentration of 1.5E-2 pCi/miis comparable to the Grand Gulf Final Environmental Report (FER) value of 1E-2 Ci/ml7 Grand Gulf's average reactor coolant tritium concentration is less than 1E-2 Ci/ml.
7 Grand Gulf FER Section 3.5.1.4 ,
Attachment 4 to GNRO-95/00083 Page 4 of 7 Radioactive Waste Produntion Gaseous Waste As described in the UFSAR, the gaseous waste treatment systems are designed to assure airborne releases are maintained ALARA during normal plant operation. The Radiological Effluent Technical Specifications (RETS) were relocated to the Offsite Dose ,
Calculation Manual in 1992 in accordance with the guidance provided in Generic Letter l i
89-01. The specifications contain operability requirements for the gaseous waste l treatment system. Periods of inoperabilty are monitored by compensatory measures as required by the specifications. If inoperabilities are not corrected in a timely manner, notification is made via the Annual Radiological Effluent Release Report.
l Liquid Waste As described in the UFSAR, the liquid waste treatment systems are designed to assure I
liquid releases are maintained ALARA during normal plant operation. The RETS were relocated to the Offsite Dose Calculation Manual in 1992 in accordance with the guidance provided in Generic Letter 89-01. The specifications contain operability requirements for the liquid waste treatment system. Periods of inoperability are monitored by compensatory measures as required by the specifications. If i inoperabilities are not corrected in a timely manner, notification is made via the Annual Radiological Effluent Release Report.
Primary contributors to the volume of waste water discharged from the site are ultrasonic cleaning of resin used in the condensate system, resin transfer operations and fan coil unit condensation (affected by seasonal humidity and steam leaks). Actions to reduce discharge volume at Grand Gulf include a design modification allowing increased reclamation (for piant use) of water generated by fan coil condensation. The discharge volume history is presented in Table 2. Data from start-up testing and less than full power operation (1985 and 1986) is omitted. Although the discharge volume is higher than the industry average, liquid effluent doses and release concentrations remain well below applicable limits (10CFR50 Appendix 1,10CFR20).
. l Att chm:nt 4 to GNRO-95/00083 Page 5 of 7 -
'4 Table 2 ,
Annual Liquid Discharge million gallons 16 i 9.2 10.3 10.1 [
79 79 gg g 7.3 7.05 7.35 I ; ;
1987 1988 1989 1990 1991 1992 1993 1994 l j
Non-Radioloalcal lmoac.ta ,
The Final Environmental Statement (FES) concluded the Grand Gulf Nuclear Station could be operated with minimal environmentalimpact.
Environmental monitoring activities were discussed in the Final Safety Analysis Report, .
FES, FER and Environmental Protection Plan (EPP). j l
Environmental monitoring activities deal primarily with terrestrial issues as the FES did not identify any aquatic issues. The Grand Gulf National Pollutant Discharge and '
Elimination System Permit No, MS0029521 (effective October 9,1990 through October 8,1995) contains effluent limitations and monitoring requirements for aquatic matters.
This permit is issued by the Mississippi Department of Environmental Quality.
Specific monitoring activities which were originally required by the EPP and have been discontinued after accumulation of adequate amounts of data showing negligible effect of plant operation are: Transmission Ling Survevs - discontinued 1988 and .Cs9]jng ,
Tower DJift Accumulation - discontinued 1992.
The Ground Water Monitorina program was modified in 1993 and continues with a >
reporting requirement based on a revised design ground water level (DGWL). ;
Air Pollution Control Permit No. 0420-00023, expiration date March 1,2000, provides allowable emission amounts of non-radioactive pollutants from the site. The permit ;
contains details regarding inspections and reporting requirements.
The FES stated that the non-radioactive air pollutants created by the operation of the plant should not have a significant impact on air quality in the station area. A permanent meteorological monitoring program is required at the station, primarily for assessment of radiological releases. i l
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Attachm:nt 4 to GNRO-95/00083 Page 6 of 7 The EPP contains routine and non-routine reporting requirements for environmental matters. The EPP permits changes in Grand Gulf design or operation and performance of tests or experiments that affect the environment provided they do not involve a change in the EPP or unreviewed safety question. An environmental evaluation is not required in cases where:
e all measurable environmental effects are confined to onsite areas previously disturbed during site preparation and plant construction, or e activities are those required to compiy with other federal, state or local requirements.
Summarv of Environmental Effects The proposed license extension effectively moves the end of the operational period forward but does not significantly lengthen the overall period and, as such, is not expected to have an effect on environmental issues.
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I Attachment 4 to GNRO-95/00083 1 Page 7 of 7 I Area Pooulation Distributions j l
The Grand Gulf Updated Final Safety Analysis Report (UFSAR) contains information
~ regarding the population distribution in the general vicinity of Grand Gulf. An update of that distribution compared to the UFSAR estimate is shown below. The general trend in the near site population (< 10 mile) has been a reduction.
radial distances from plant (miles) '
0-1 0-2 0-3 0-4 0-5 0-10 ;
census data 1970 51 190 302 443 2086 7245 ,
predicted 1980 51 189 301 442 2070 7209 predicted 1990 51 194 310 456 2165 7577 predicted 2000 51 206 329 483 2274 7970 radial distances from plant (miles)'
0-1 0-2 0-3 0-4 0-5 0-10 1986 39 94 171 324 890 4959 Grand Gulf UFSAR Table 2.1-5 includes 1970 population data for Mississippi communities and population centers within 50 miles of the site. A comparison using updated census data is shown below, g g 10 g11 Brookhaven 10,594 10,800 10,243 Bude 1,140 1,092 <1,000 Clinton 11,434 14,660 21,847 Crystal Springs 4,422 4,902 5,643 Edwards 1,246 1,515 1,279
- Fayette 1,760 2,033 1,853 l Hazelhurst 4,564 4,437 4,221 Natchez 20,576 22,015 19,460 '
Port Gibscn 2,656 2,371 1,810 Raymond 1,592 1,967 2,275 Utica 1,030 <1,000 1,033 Vicksburg 25,478 25,434 20,908 Wesson 1,240 1,313 1,510 t
a Grand Gulf UFSAR Table 2.1-1, Sheet 3 of 3, (city of Port Gibson population divided between 0- ,
5 and 0-10 mile distances)
' Grand Gulf Emergency Plan, Revision 28, Table 2-2,1986 Evacuation Time Estimate Study, (city of Port Gibson population included in 0-10 mile distance)
' Mississippi Statistical Summary of Population 1800 - 1980, Economic Research Department, Mississippi Power and Light Company "1990 Census of Population,1990 CP-1-26 l
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Attachmsnt 5 to GNRO-95/00083 !
Page 1 of 1 Potential Benefits to Grand Gulf in Recanturing the Low Power Testing Period The net effect of this proposed change wou'd be the addition of approximately two {
operating cycles to the licensed duration 'or Grand Gulf. The associated benefits are i significant. !
Tne difference between buying replacement power or operating Grand Gulf for this ,
period would allow Entergy to save on the order of $120 million using current estimates. !
i Other presently unquantified benefits include:
e Additional flexibility in the long-range planning efforts of Entergy and Entergy l Operations,
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. Deferral of additional system construction, i
. Later entry into the license renewal process after the process has matured and been streamlined, and e Good compatibility with projected refueling outage schedules. ,
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