ML20236B911

Forwards Addl Info Re Proposed OL Extension for Plant in Response to 870205 Request.Response to Request for Info Re Possible Impact of Extension on Areas of Historical Significance Encl

ML20236B911
Person / Time
Site:	Farley
Issue date:	07/22/1987
From:	Mcdonald R ALABAMA POWER CO.
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
NUDOCS 8707290284
Download: ML20236B911 (23)

Text

Alabama Power Company.

600 North 18th Street

l. Post Office oox 2641 i Birmingham, Atabama 352914400 Telephone 205 250-1835 R. P. Mcoonald m

Senior Vice President Mabailla power Ihv southern electnc system 10CFRSO.90 July 22, 1987 accket Nos. 50-348 50-364 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D. C. 20555 j Gentlemen:

Joseph M. Farley Nuclear Plant - Units 1 and 2 Additional Information Regarding Extension of Operating License Duration NRC letter dated February 5,1987 requested Alabama Power Company provide additional information concerning the proposed operating license extension j for Joseph M. Farley Nuclear Plant Units 1 and 2. The response to this j request is enclosed and addresses items 1 through 8 of the NRC letter. The -

response to item 4 also includes information relative to Table S-4 of 10 j CFR 51.b2. Also included as item 9 is a response to the verbal request of I the NRC Staff for information relating to the possible impact of the j operating license extension on areas of historical significance.

If there are further questions, please advise.

Respectfully trtnqitted, l 1 7

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R. P. Mcdonald RPM / JAR:dsi-D-T.S.2 1

1 Enclosure cc: Mr. L. B. Long Dr. J. N. Grace Mr. E. A. I:eeves Mr. W. H. Bradford

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B7072902B4 B70722 PDR ADOCK 05000348 P PDR \

ENCLOSURE

1) 'NRC Request Population information similar to FES Section 2.2.1 should be updated:

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a. Population data should be current to include the 1980 census data and estimated projections to include at least the periods of the extension requested.

b. Provide a discussion of trends and forecasts within 50 miles of the plant including percentage increase or decrease considering at least the years 1970 and 1980.

c. Within (b) above, include data for the actual populations of at least Dothan, Columbia and Ashford from the 1970 and 1980 centis and'a )

projection through the period of the extensions. You may wish to J provide figures similar to the referenced FSAR Figures 2.1-5 through 1 2.1-8 with the town locations shown thereon. i l

APC Response 1

The Farley Nuclear Plant Final Environmental Statement (FES) and Final i Safety Analysis Report (FSAR) currently include population projections for )

areas within a 50 mile radius of Farley Nuclear Plant through the year {

2015. The Operating License extension requested involves continued plant operation until 2017 for Unit 1 and 2021 for Unit 2. Farley Nuclear Plant FES Table 2.1 is based on data obtained from the 1970 census. A direct comparison of 1980 census data and the data contained in the FSAR and FES is very difficult because census data is available only on a city / county basis. However, a detailed review of the 1980 census data indicates that the growth rate applied to the 1970 census data in developing the FES and l FSAR tables is reasonable. The growth rate used to determine the population within the 50 mile radius for the year 2015 was about 10.5% per  !

decade. A review of population growth for all counties either inside or: )

partially inside the 50 mile radius reveals that Alabama counties l increased their population by an average of 11.5% from 1970 to 1980. '

Counties in Georgia increased in population by only 6.25% during this decade. Florida counties, which cover only approximately one quarter of the area within 50 miles of the plant site, demonstrated an average growth rate of 23.1%. The only Florida county fully encompassed by the 50 mile radius circle is Jackson which exhibited a growth rate of 13.7% from 1970 to 1980. The portions of the remaining counties which are enclosed by the circle are rural areas. It should be noted that the Florida counties which demonstrated the highest growth rates lie on the perimeter of the 50 mile radius circle. Table 1-1 includes a listing of all counties within 50 miles of the plant site, their 1980 population and the percent change i since 1970.1 Dothan is the only city with more than 20 thousand people within a 50 mile l radius of Farley Nuclear Plant. The FES predicted a 1980 population of

! 63,000 ior the city of Dothan. Figures from the 1980 census indicate that s

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the actual population was 48,750, some 14,250 fewer than projected. 1985 statistics from the Department of Commercey Burtau.of Economic Analysis, project the Dothan metropolitan area (includin counties)willhavethefollowingpopulations:gallofDaleandHouston Year Population 1983 125,200 1990 129,600 1995 132,800 2000- 135,200 2005 138,100 2015 145,600 2035 155,800 Based on these predictions, the Dothan metropolitan ~ area can expect to experience an average population growth of less than 5% per decade. The predicted growth rate between 2015 and 2035 is approximately 3.5% per-decade.

Most of the area within 50 miles of Farley Nuclear Plant is rural and can be expected to continue to experience moderate growth. A review of census data for cities with greater than 10,000 people located within 50 miles of Farley Nuclear Plant also indicates moderate growth. Listed below are all Alabama, Georgia or Florida cities within 50 miles of the plant site with 1970 or 1980 populations of greater than 10,000. Also listed are the 1970 and 1980 populations of Columbia and Ashford due to their proximity to the plant.3 City 1970 Population 1980 Population % Change Ashford, AL 1,980 2,165 9.3 l Columbia, AL 891 881 (-1.1)

Dothan, AL 36,733 48,750 - 32.7 Enterprise, AL 15,591- 18,033 15.7 l

Ozark, AL 13.555 13,188 (-2.7)

, Bainbridge, GA 10,880 10,533' (-3.2) l l

Based on our review of the 1980 census data, it can be concluded that there has been no significant change in the population growth rate or pattern since the FES or.FSAR tables were compiled. Considering the number of variables and the inexact nature of population predictions, Alabama Power Company considers the tables currently included in the FES and FSAR to be reasonably accurate. Therefore it can be concluded that the populations in 2017 and 2021 will not vary greatly from that predicted for 2015 and will not alter the conclusions in the FSAR and FES.

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1) (Continued)

References 1.1) U.S. Department of Commerce, Bureau of the Census, " County and City Data Book", 1983.

1.2) U.S. Department of Commerce, .9ureau of Economic Analysis,

" Metropolitan Statistical Area Projections to 2035", 1985.

1.3) U.S. Department of Commerce, Bureau of the Census, "1980 Census of Population", April 1982.

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1 TABLE 1-1 Populations of Counties Within 50 Miles of Farley Nuclear Plant Population (1980)  % Change from 1970 Alabama:

Barbour 24,756 9.8 Coffee 38,533 10.5 Dale 47,821 (-9.8)

Geneva 24,253 10.6 Henry 15,302 15.5 Houston 74,632 31.9 Pike. 28,050 12.0 Georgia:

Baker 3,808 (-1.7)

Calhoun 5,717 (-13.5)

Clay 3,553 (-2.3)

Decatur 25,495 14.3 Dougherty 100,718 12.4 Early 13,158 3.8 Grady 19,845 11.3 Miller 7,038 9.6 Mitchell 21.114 11.4 Quitman 2,357 8.1 Randolph 9,599 9.9 Seminole 9,057 28.3 Stewart 5,896 (-9.4)

Terrell 12,017 5.3 Florida:

Bay 97,740 29.8 Calhoun 9,294 21.9 Gadsden 41,565 6.1 Holmes 14,723 37.3 l Jackson 39,154 13.7 Liberty 4,260 26.1 Washington 14,509 26.7 l

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2) NRC R.equest Provide statements regarding the impact (10 CFR Part 100) on the Exclusion Area Boundary, Low Population Zone and the nearest population. centers using the most current actual populations for 1980 projected through the l period of the extensions.

APC Response The Exclusion Area is owned and controlled by Alabama Power Company.

There is.no one living within this area. As discussed in the FSAR, the I only activity not related to plant operations within the exclusion area is the operation of the visitors' center. Ihis policy is not expected to change during the period of the requested license extensions.

The only population center (as described by 10 CFR 100) within 50 miles of Farley Nuclear Plant is Dothan, which is . located approximately 16 miles west of the site. The most recent population data and projected trends are included in the response to item (1).

l The Low Population Zone for Farley Nuclear Plant includes only the area j within 2 miles of the plant site, even though the population is low for distances at least 10 miles away from the site. There have been no j I

significant housing developments within 2 miles of the site since the FSAR I

projections were made. As discussed in the response to item (1),

population for the Dothan area is projected to grow at an average rate of less than 5% per decade through 2035. Therefore, Alabama Power Company ,

considers the projections currently included in the FSAR to be reasonably 1 accurate. Any variation in population for the Low Population Zone between 3 2015 and the period of the requested extensions (2017 and 2021) are not i considered significant and will not alter the conclusions in the FSAR or I FES. )

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3)? NRC Request:

Provide a'quantification of the radiological impacts to the general

-population based on the calculated off-site doses.(Table 3-1 of APCo-letter dated August 11, 1986). Examples of supporting'information for; discussion may be as follows:

a. Discuss" the impact of the estimated dose commitments for 40 years of plant operation.

b. 1 Identify any specific land use changes which may affectLoffsite dose

> calculations, particularly those for ingestion pathways for child thyroid.

c. Provide a general comparison of the radiological impacts on man-as assessed in the FES with those actually experienced.during plant.

operations. Discuss offsite' dose calculations on actual effluent releases and compare to projected releases and Appendix I guidelines..

APC Response:

Appendix I to 10 CFR 50 contains guidelines to assist applicants for, and holders of, licenses for light water cooled nuclear power reactors in determining design objective limits for the amounts of radioactive material in effluents released from these facilities to unrestricted areas. Further,Section I states: " Design objectives and limiting conditions for operation conforming to the guidelines of this appendix shall be deemed a conclusive showing of compliance with the as low as is reasonably achievable (ALARA) requirements of 10 CFR 50.34a and 50.364."

The information presented below shows that the annual' dose resulting from the operation of Farley Nuclear Plant Units 1 and 2 is clearly below the design objective dose specified by Appendix 1. Therefore, the dose consequence to unrestricted areas has.been shown to be ALARA.

.a. NRC estimates for annual releases and doses resulting from the operation of Farley Nuclear Plant Units 1 and 2 are presented in FES section 5.5.1. The FES yearly dose estimates were originally reviewed for the impact of 40 years of operation. Therefore, these estimates will remain uncbanged regardless of whether the lifetime of, the plant is 35 or 40 years for Unit 1, or 31 or 40 years for Unit 2. More importantly, the actual yearly releases from the plant have been far below the upper bounding values specified in 10 CFR 50, Appendix I (as shown in Table 3-1) and should continue to be lower in the future due to Alabama Power Company's commitment to the ALAR) concept. Further the information presented in Table 3-1 sho ss a general downward trend in offsite dose based on actual release data-for Farley Nuclear Plant ' Units 1 and. 2. Finally, it should be noted that the operation of.Farley Nuclear Plant Unit 1 for an additional 5 years and Unit 2 for an additional 9 years would not alter the favorable conclusions reached in the FES because extension of the operating license does not involve any plant modifications or plant procedure changes which could adversely impact the environment.

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3) '(Continued)

. b. . Table 5.4 of.the FES presented NRC calculated dose to!the cumulative population within a 50 mile radius of Farley. Nuclear Plant Units 1 and 2. :No.significant land.use changes affecting offsite dose have; been identified in this' area'since beginning of plant operation;-

c. Table 3-1 of this response; presents the.10 CFR 50,. Appendix I objectives for Farley Units .1' and 2, along with a comparison' of the projected doses 1(11guid and gaseous) calculated forL Farley Nuclear.

Plant:(from FES Tables 5.2 and 5.3 and FSAR Tables 11.3-11 and-11.2-9) and the actual experience data from 1983 through 1986.L A review of this data shows that the projected doses for Farley Nuclear

-Plant.were below Appendix I limits.and.the actual operating releases.

measured were only a fraction of the projections.

In comparing the dose consequences presented-in?FES. Table 5.2 to those actually experienced during plant operations, it is . important to note that differences exist.in the makeup and' type oflinformation shown, therefore a one-to-one cocyarison of this data is not

-possible. This is due primarily to." evolving" criteria being used at the time of calculation. .

Based on a review of the information shown in Table 3-1, it can be-concluded.that the radiological impact of the proposed lifetime extension is negligible.

Table-3-1 Farley Nuclear Plant Actual Average Offsite Dose as Reported in Section B.9 of the Semi-Annual Radioactive Effluent Release Reports for Years 1983 through 1986 Compared to 10 CFR 50, Appendix I Objectives and Projected Values from FES Tables 5.2 and 5.3 and FSAR Tables 11.2-9 and 11.3-11 Unit 1 FES Tables 5.2 & 5.3 FNP 162 Projected Actual 10CFR50 FSAR (Nearest Dose From Semi-Annual Appendix I Projected Residence) Effluent Reports (mrem /yr) (mrem /yr) (mrem /yr) (mrem) 1983 1984 1985 1986'

____ j Liquid-Total Body 3 1.8 0.56 0.04 0.02 0.01 0.05 )

Liquid-Organ 10 2.3 0.38 0.40 0.12 0.04 0.08 Gaseous- Total Body 5 2.2 0.10 0.50 0.21 0.09 0.08 Gaseous-Skin 15 2.4 0.33 0.99 0.40 0.20 0.18 Airborne Iodine and Particulate Organ 15 7.2 0.71 0.58 0.09 0.10 0.04  ;

1 Unit 2 FIS Tables I 5.2 & 5.3 FNP 162 Projected Actual 10CFR50 FSAR (Nearest Dose From Semi-Annual Appendix I Projected Residence) Effluent Reports (mrem /yr) (mrem /yr) (mrem /yr) (mrem)

j. 1983 1984 1985 1986

'tquid-Total Body 3 1.8 0.56 0.01 0.18 0.02 0.01~

Liquid-organ 10 2.3 0.38 0.12 0.25 0.07 0.06 i Gaseous- Total Body 5 2.2 0.10 0.12 0.16 0.04 0.04-Gaseous-Skin 15 2.4 0.33 0.13 0.33 0.10 0.09 Airborne Iodine and Particulate Organ 15 7.2 0.71 0.17 0.07 0.09 0.06

4) NRC Request For the uranium fuel cycle provide a statement regarding the environmental impact of the longer production run for the fuel cycle and any net annual i effects on Table S-3 in 10 CFR 50.51 (sic). Also, state any impacts of q the 18-month fuel cycles versus the 12-month cycles used for the FES and j FSAR. I l

APC Response The requested increase in the duration of the Operating License for Unit 1 is approximately five years and for Unit 2 is approximately nine years. ,

This additional period of operation would involve roughly three core I reloads for Unit 1 and six reloads for Unit 2 based on a refueling j frequency of 18-months. The percentage increase in the uranium fuel j requirements for the lifetime of the two units is.small, particularly when '

l the decreased fuel requirements associated with the implementation of higher enrichment, higher burnup fuel management strategies is considered.

1 Farley Nuclear Plant has not experienced a significant increase in offsite radiation exposure or a significant increase in the amount of effluents released offsite due to the transition from 12 month to 18 month cycles.

Offsite releases are monitored and reported in the Semi-Annual Effluent Release Report.

Farley Nuclear Plant Units 1 and 2 were originally fueled with a core loading containing a maximum enrichment of 3.2 weight percent U-235.  ;

Reload cores were limited to a maximum enrichment of 3.5 weight percent

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U-235. On November 4, 1984 the NRC issued License Amendments No. 52 and  !

No. 43 for Units 1 and 2, respectively, which increased the maximum allowable fuel enrichment for core reloads from A.5 weight percent to l 4.3 weight percent U-235. This increase in the allowable fuel enrichment j facilitated the implementation of 18-month operating cycles rather than i the 12-month cycles previously employed. In issuing these License Amendments which cleared the way for the use of 18-month cycles, the NRC determined that "these amendments involve no significant increase in the amounts, and no significant increase in the types, of any effluents that may be released offsite and that there is no significant increase in individual or cumulative occupational radiation exposure."

The impact on 10 CFR 51.51 Table S-3 and 10 CFR 51.52 Table S-4 associated with higher fuel burn-up and correspondingly longer operating cycles has been extensively addressed by the Atomic Industrial Forum (AIF). In a study prepared for the National Environmental Studies Project (NESP) of the AIF it was concluded that "the current values in Tables S-3 and S-4, and the generic analyses of environmental dose commitments performed by i

the NRC staff, are applicable to fuel burnups up to 60,000 megawatt days l

per metric ton (MWD /MT)l." This conservatively envelopes the anticipated operational range of future average core burnups for Farley Nuclear Plant Units 1 and 2.

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Additional margin to the values contained in Tables S-3 and S-4 lies in the fact that these tables were developed based on the anticipated fuel requirements of a 1,000 MWe reactor. Since each of the reactors at Farley Nuclear Plant are. rated at 829 MWe net, the corresponding fuel requirements are lower and, thus, the environmental impact of the uranium fuel cycle is more modest.

Based on previous environmental analyses associated with the increased fuel enrichment License Amendments and the preceding discussion it can be concluded that the use of higher fuel burnup, longer operating cycles and the proposed increased duration of the Operating Licenses do not alter the conclusions of 10 CFR 51.51 Table S-3, 10 CFR 51.52 Table S-4, the FES'or the FSAR.

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4) (Continued)

References 4.1) Atomic Industrial Forum, Inc., "The Environmental Consequences of Higher Fuel Burn-up," AIF/NESP-032, June 1985.

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5) NRC Request (

i Provide a projection of the occupational radiation exposure expected for  !

the periods of the extensions. Provide an estimate of the expected dose j savings from the ALARA program during the extension. Identify examples of )

any major design changes or modifications which would impact the radiation i exposures, i.e. , steam generator replacement, if projected. j i

APC Response: l The Farley Nuclear Plant FES projected the total yearly personnel exposure due to operation of the two unit plant to be 900 man-rem. Actual radiation exposures received for both Units 1 and 2 during the previous four years'are shown in Table 5-1 below. The highest total yearly exposure received over_ this recent four year period from 1983 to 1986 was 935 man-rem total for both Units 1 and 2. This exposure was recorded i during 1983, a per$ od of operation during which Unit 1 experienced fuel leakage problems due to baffle jetting. The average exposure expended during this same four years was 874 man-rem total for both units or an average of 437 man-rem per unit. Comparisons to the data in Table 4.3 of the Occupational Radiation Exposure at Commercial Nuclear Power Reactors and Other Facilities (NUREG-0713, published October 1986) show Farley Nuclear Plant to be substantially below the industry average of 708  ;

man-rem per unit for 1984. 1 Future exposures could be affected by a major modification such as a steam J generator replacement. A review of experience data for radiation exposures received from the work associated with steam generator replacement projects performed at other plants provided the following <

information: {

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Replacement Additional l Activity Exposure  !

Plant Dates (man-rem)

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Surrey 1 September 1980 1759  ;

j through June 1981 Turkey Point 4 October 1982 1305 l

through.

May 1983 Point Beach October 1983 580 through February 1984

5) (Continued)

In reviewing this information it appears that with each successive replacement the associated exposure.has decreased. Alabama Power Company expects that a project of this nature would be performed in the future only if deemed. absolutely necessary and would have to be determined clearly justifiable on both a financial and radiological (man-rem) cost basis. Should Farley Nuclear Plant perform a task equal to the magnitude of a steam generator replacement, it would be done only after careful ALARA pre-planning and review of " lessons learned" experience information obtained from the previous replacements at the plants mentioned above.

Using this information and taking into account future improvements in handling components, the additional exp osure to Farley Nuclear Plant personnel from a steam generator replacement would be expected to be slightly lower than the exposures experienced at the plants mentioned above.

l A radwaste solidification / dewatering facility is being constructed at Farley Nuclear Plant which should further reduce the total yearly exposure. Because the facility will contain substantial radiation shielding, the operator exposure during processing and storage will be less than that experienced using the previous process configuration. . In addition, the increase from 12 month to 18 month operating cycles will reduce the total exposure over the life of the plant since the number of refueling outages will be reduced and previous experience Las shown that a substantial percentage of the total annual exposure occurs during outages. Implementation of these modifications in conjunction with a successful ALARA program should continue to reduce exposures throughout the life of the plant and offset any expected increase in dose associated with an aging plant.

As new radiation exposure reducing technologies develop in the future,

'tabama Power Company will continue to investigate the feasibility of incorporating them at Farley Nuclear Plant. Considering the successful ALARA program of Farley Nuclear Plant combined with the recent exposure reducing modifications in the waste handling techniques used and a continuing management commitment'to reducing the overall radiation exposure, the incremental dose received during the additional years of operation will be maintained as low as reasonably achievable in accordance with 10 CFR 20 and Regulatory Guide 8.8, and would continue to be consistent with industry averages, or below, as is now the case.

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Table.5-1 Farley Nuclear Plant Units 1 and 2 Total Radiation Exposure to. Personnel as Reported in the Annual Report i of Radiation Dose' Distribution I (1983-1986) i l

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Total Annual Radiation Exposure to Personnel for Units 1 and 2 J l (man-rem) 1 1

1983 1984 1985' 1986 l 935 905 799 858 i

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6) NRC Request: j Provide a comparison of actual radwaste shipments for rccent operating )

years to that shown in FES Table 11.4 and the estimated incremental change 1 for the extension periods. j APC Response:

FES Table 11.4 addresses the anticipated volume of solid waste generated (not necessarily the volume being shipped). Farley Nuclear Plant utilizes an interim radwaste storage facility and for this reason the volume of wastes generated may not equal the volume shipped for any particular year.

The actual experience data for radwaste generation and shipments from {

Farley Nuclear Plant Units 1 and 2 for recent operating years are shown in l Table 6-1 of this response. In addition the original NRC projections l shown in the Farley Nuclear Plant FES, along with currently available PWR Industry yearly averages for several operating years,are included for comparison'. The PWR Industry data shown was taken from the Institute of j Nuclear Power Operations - 1986 Annual Report. A graph of this j information is provided as Figure 6-1 of this response. In order to make 1 meaningful comparisons of the years of two unit operation, only the data l from 1982 to the present is considered, since Unit 2 did not receive a full power license until March 31, 1981.

An analysis of this data shows Farley Nuclear Plant to be well below the industry waste generation averages for most of the years shown. While the '

volume of waste generated is higher than the NRC FES projections, the volume is well below the prediction included in NUREG-0116.(1) The i annual volume predicted by NUREG-0116 is indicated in Table 6.1 and is shown on Figure 6-1. In addition, an examination of Table 6-1 demonstrates a downward trend in volume generated from 1984 through 1986.

The presence of this downward trend combined with the enhancements incorporated in the nearly completed radwaste solidification / dewatering facility is evidence of Alabama Power Company't, continuing efforts to reduce the activity and volume of the annual shipments to as low as reasonably achievable. Based on this information, the volume of waste generated and shipped in the years of the requested extension can be expected to be a small percentage of the total volume generated over the plant lifetime.

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6) (Continued) l Reference j 6.1) Environmental Survey of the Reprocessing and Waste Management '

Portions of the LWR Fuel Cycle, NUREG-0116, October 1976.

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Table 6-1 Farley Nuclear Plant Units 1 and 2*

Actual Annual Generation and Shipments of Radwaste Compared to NPC FES Radwaste Generation Projection and PWR Industry Data FES Table 11.4 Projected Waste Generated 108 m3/ year NUREG-0116 Table 3.1 Projected Waste Generated 620 m3/ year Operational Years 1982 1983 1984 1985 1986 FNP-Waste Volume Generated * (m3/ unit) 175 238 252 243 220 All PWRs-Waste Volume Generated (m 3 / unit) 481 459 407 334 211 FNP-Waste Volume Shipped" (m3/ unit) 188 231 255 248 123

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• FNP data is per unit operational year. Double value for total waste volume.

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7) NRC Request ,

s Provide a statement indicating the current National Pollutant Discharge '

Elimination System (NPDES) permit number and date of issuance as well as termination date if one exists. l APC Response The Farley Nuclear Plant NPDES permit number is AL0024619. This permit was issued by the Alabama Department of Environmental Management on March 29,1985 and became effective on May 1, 1985. The permit expires at midnight on May 1, 1990. The State of Alabama issues NPDES permits for five-year intervals. i l

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8) NRC Request Provide a statement identifying any FES or FSAR section wherein time of operation of less than 40 years was assumed. ,

1 APC Response l The-only identified FSAR text which discusses time of operation of less than 40 years is section 2.3. This section addresses population projection through 2015.  !

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Listed below are FES sections which reference time of operation of less than 40 years.

(a) FES Section 2.2.1, page 2-4 This is the section on population projection and is addressed in item (1).

l (b) FES Section 7., page 7-3 This section addresses the environmental aspects of postulated accidents and is based on 40 years of plant operation. However, the man-rem estimates are based on population in 2015. As discussed in item (1), population in 2017 and 2021 is not expected to vary greatly l from that projected for 2015. Therefore the conclusions of the FES remain valid, t I

(c) FES Section 8.4, page 8-3 1

This segment of the FES addresses decommissioning and incorrectly states that the plant was designed to operate for 30 years and the end of its useful life would be about 2010. The operation of Farley Nuclear Plant for 40 years to 2017 and 2021 for Units 1 and 2, respectively, will not significantly increase the cost of decommissioning. Therefore, the discussion contained in FES Section 8.4 remains valid.

(d) FES Section 10.1, page 10-1 This section of the FES discusses the cost / benefit associated with plant operation and assumes 30 years of plant operation. As discussed in 4.1 of Attachment 3 to the August 1,1986 submittal, the extension of the operating license produces significant additional benefit for the customers of Alabama Power Company, while deferring the cost of replacement power. Therefore, the FES conclusion that the environmental impact of plant operation will be greatly outweighed by the availability of electrical power produced by the plant remains valid for the period of the requested operating license extension.

8) (Continued)

(e) FES, September 1980 Addendum, page A.5-8 This addendum to the FES addresses the environmental effects of station' operation. As an input to this analysis a model 1000 MWe reactor is considered to operate for 30 years. The fuel cycle requirements are then annualized. Therefore, the difference in assuming 30 years of operation rather than 40 years is not significant and the conclusions of the FES remain valid.

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9) NRC Request )

Provide a statement on the potential impact of prolonged plant operation l on sites or properties of historical, architectural or archeological I importance (verbal request from NRC Staff).

APC Response As discussed in the Farley Nuclear Plant Environmental Report-Construction Permit Stage submitted in September 1970 and the NRC's Final Environmental Statement-Construction Permit Stage issued in June 1972, no areas of historical, architectural or archeological significance were identified as being on, or in the vicinity of, the Farley Nuclear Plant j site and, accordingly, construction of the plant and related transmission '

l facilities had no ' adverse impact. In the Final Environmental Statement-0perating License Stage issued in December 1974 and supplement dated September 1980, the NRC Staff did not identify any adverse impact posed by the continued construction of transmission lines and subsequent operation of Farley Nuclear Plant. Alabama Power Company is unaware of any areas of historical, architectural or archeological significance on, I or in the vicinity of, the Farley Nuclear Plant site which have been identified since issuance of the Final Environmental Statement-Operating License Stage. The extension of the plant operating license does not involve any modifications of the plant and related transmission facilities or changes to plant and transmission facilities' procedures. Therefore, continued operation of Farley Nuclear Plant and related facilities in accordance with the operating license extension request will not result in l any adverse impact to areas of historical, architectural or archeological significance .

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