ML20236H783

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Proposed Tech Spec Page 13,changing Expiration Date of License from 121206 to 180717.Safety Evaluation,Environ Assessment,Occupational Exposure Evaluation,Needs Assessment & NSHC Encl
ML20236H783
Person / Time
Site: Arkansas Nuclear 
Issue date: 10/30/1987
From:
ARKANSAS POWER & LIGHT CO.
To:
Shared Package
ML20236H782 List:
References
NUDOCS 8711040346
Download: ML20236H783 (26)


Text

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This license is subject to the following additional condition i

for the protection.of the environment:

Before engaging in additional construction or operational-activities which may result in an environmental impact that was not evaluated by the Commission, the licensee will prepare and record an environmental evaluation or such activity.

When the evaluation indicates that such activity may result in a significant adverse environmental impact that was not evaluated,-

or that is significantly greater than that evaluated, in the Final Environmental Statement (NUREG-0254) or any addendum thereto, the licensee shall provide a written evaluation of such activities and obtain prior approval from the Director, Office of Nuclear Reactor Regulation.

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This license is effective as of the date of issuance and shall

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expire.at midnight, Oc = ic. O, 2010. July q 3 tot 6 i

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FOR THE NUCLEAR REGULATORY COMMISSION Roger S. Boyd, Director Division of Project Management Office of Nuclear Reactor Regulation Attachments:

Preoperational Tests, Startup Tests and Other Items Which Must Be Completed By the Indicated Operational Mode Date of Issuance: SEP 1 1g73 R711040346 871030 PDR ADOCK 05000368 p

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L ATTACHMENT 2 l

EVALUATIONS SUPPORTING APPLICATION FOR LICENSE AMENDMENT IN THE MATTER OF AMENDING LICENSE N0. NPF-6 ARKANSAS POWER & LIGHT COMPANY ARKANSAS NUCLEAR ONE - UNIT 2 DOCKET NO. 50-368 i

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TABLE OF CONTENTS SECTION PAGE 1.

INTRODUCTION 4

i Objective 4

Scope 4

2.

SAFETY EVALUATION 6

f Mechanical Systems and Equipment 6

Electrical Equipment 6

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Reactor Vessel Intagrity 7

Structures 8

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' Conclusion 8

3.

ENVIRONMENTAL ASSESSMENT 9

Population and Offsite Dose Assessment 9

Environmental Monitoring Program 10 Waste Disposal 10 Uranium Fuel Cycle 13 Transportation 13 4.

OCCUPATIONAL EXPOSURE (ALARA) EVALUATION 15 I

Goals Program 15 i

Specific ALARA Measures 16 Occupational Dose Assessment 17 Future ALARA Program Enhancements 20 5.

NEEDS ASSESSMENT 21 Consideration of Alternatives 21

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Economic Benefit 23

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NO SIGNIFICANT HAZARD 5 ANALYSIS 24 Proposed Change 24 Discussion and Background 24 Significant Hazards Consideration 24 2

LIST OF FIGURES j

FIGURE TITLE PAGE 1

Low Level Waste Generation, ANO and PWR 12 Average 2

Collective Occupational Exposure 18 l

3 ANO Exposure Distribution 19

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AP&L Projected Capability and Load 1988-2018 22 5

MSU Projected Capability and Load 1988-2018 22 LIST OF TABLES TABLE TITLE PAGE 1

Population Data 9

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SECTION 1 INTRODUCTION Section 103.c of_the Atomic Energy Act of 1954 provides for a license to be issued for a specified period not exceeding 40 years.

As stated in 10CFR50.51, the U.S. Nuclear Regulation Commission (NRC) will issue an operating license for the term (not exceeding 40 years) requested by the applicant or for the estimated useful life of the facility if the Commission determines that the useful life is less than the term requested.

In April 1985, the NRC issued a memorandum that establishes staff policy for extending the operating life of nuclear power plants licensed prior to 1982.

The policy is to permit recapture of the Construction Permit (CP) term; i.e., commencement of the Operating License (0L) at the date of OL issuance, thus enabling a nuclear power plant to operate for a full 40 years providing that this license correction poses no undue risk to the public health and safety.

Arkansas Nuclear One - Unit 2 (ANO-2) is a pressurized water reactor (PWR) nuclear power plant located in Pope County, Arkansas, approximately six miles northwest of Russellville, Arkansas.

The nuclear steam supply system (NSSS) was supplied by Combustion Engineering Company and has a design power level of 2,815 megawatts thermal (MWt).

The plant's design net electrical output is 912 megawatts electric (MWe).

The CP for ANO-2 was issued on December 6, 1972.

The OL was first issued on July 18, 1978, and expires on December 6, 2012, forty years from the date of the CP.

The term of the current OL is, thus, approximately 34-1/2 years.

OBJECTIVE This license amendment application seeks to change the expiration date of the ANO-2 Operating License from December 6, 2012, to July 17, 2018; i.e.,

40 years from the date of issuance.

SCOPE The evaluation presented herein addresses five principal areas of analysis:

o The adequacy of electrical and mechanical equipment and structures relative to the extended service life.

The ability to operate the electrical and mechanical equipment safely, and maintain reactor vessel integrity, throughout the extended term.

(Section 2) o The environmental impact of extending the service life relative to population growth and radiological and non-radiological effects of plant operation.

(Section 3) o The occupational radiation exposure associated with plant operation.

(Section 4) 4

o The need for the generating capacity represented by the plant, the alternatives, and the financial value-of the extended service life of the plant.

(Section 5) o The significant hazards considerations, as specified by 10CFR50.92.

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I SECTION 2 SAFETY EVALUATION This safety evaluation confirms that the public health and safety will not be adversely affected by this amendment to the ANO-2 plant operating license.

Most of this information summarizes material provided to the NRC in the Safety Analysis Report (SAR) or other previous submittals.

MECHANICAL SYSTEMS AND EQUIPMENT The original SAR has evaluated the adequacy of safety-related mechanical systems, equipment, and components for 40 years of plant operation. It is clear that the design of the plant considered a 40 year service life.

Where a specific design lifetime is specified in the Safety Analysis Report, it is at least 40 years (i.e., 32 EFPY at 80% capacity factor).

Examples include:

the Reactor Pressure Vessel (SAR Section 4.2.3.9), Reactor Coolant System Components (SAR Section 5.2.1.5) and Control Element Drive Mechanisms (SAR Section 4.2.3.1.1).

In other cases, performance requirements govern the design and no specific design lifetime is stated.

Although some mechanical equipment and components might wear out or need replacement during the plant operating lifetime, existing surveillance and maintenance programs are sufficient to maintain or determine replacement of safety-related components.

Periodic inservice inspection and testing requirements have been incorporated into procedures to provide the added assurance that any unanticipated degradation in systems or equipment will be identified and corrected in a timely manner.

Therefore, AP&L concludes that safety-related mechanical systems, equipment, and components considered will

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not be impacted by a 40 year operating lifetime.

1 ELECTRICAL EQUIPMENT l

AP&L has evaluated the safety implications of extending the ANO Unit 2 operating license on safety-related electrical systems and equipment.

This evaluation included a review of extended service life impacts on equipment integrated dose qualifications and environmental qualifications in response to 10CFR50.49.

For safety-related electrical equipment within the scope of 10CFR50.49, aging reviews have been conducted so as t'o establish a qualified life for the equipment.

For this equipment, controls are in place to ensure that required surveillance and maintenance are performed.

These are described in the Environmental Qualification Program Manual and ANO procedures.

The current AP&L Equip.nent Qualification (EQ) Program is in compliance with 10CFR50.49.

There are currently no known open EQ issues which are affected by the extension of the operating license.

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l Based on this evaluation, AP&L concludes that electrical systems design, electrical equipment selection and application, and environmental qualification of electrical equipment either considered the offects of a 40 year operational lifetime or will not be affected by a 40 year operational lifetime.

REACTOR VESSEL INTEGRITY The ANO-2 reactor vessel was designed considering the effects of 40 years of operation at a plant capacity factor of 80% (32 EFPY).

The Reactor Vessel Material Surveillance Program for ANO-2 contains six.in-reactor surveillance capsules that are used to monitor cumulative effects of power operation on l

reactor vessel materials.

This program will ensure that the ANO-2 reactor vessel will meet the requirements of 10CFR50 Appendices G and H through 32 EFPY.

All the reactor vessel materials are predicted to have a low susceptibility to neutron radiation damage because of their high unirradiated charpy V-notch upper shelf energy, and their low copper, phosphorous and nickel content.

The results of the first capsule analysis, which are documented in a Battelle Columbus Laboratory Report dated May 1, 1984, support the prediction that cumulative neutron fluence will not be a limiting consideration for reactor vessel operation through full design life.

These results indicate that at a fast neutron fluence of 3.5 X 1018 n/cm2, base metal longitudinal specimens had the largest reduction in upper shell energy.

This reduction was from 155 ft-lb to 142 ft-lb, which is still substantially higher than the 50 ft-lb criteria of 10CFR50 Appendix G.

Additional surveillance capsules are scheduled to be removed and analyzed to further characterize irradiation-induced property changes for the ANO-2 reactor vessel over 32 EFPY.

As required by 10CFR50.61, AP&L has determined projected values of RT for the ANO-2 reactor vessel materials.

Theresultsofthisanalysis,whb were submitted to the NRC on January 22, 1986, showed that the RT for eachmaterialintheANO-2reactorvesselwasbelowtheNRCscree$Ibg criteria through the current license and through 32 EFPY.

The most limiting material is intermediate shell plate, heat number C8161-3, which will have an RT of 173 F upon expiration of the current license and an RT of 179.6hbat the end of 32 EFPY.

Thesevaluesarewellwithinthe1bR50.61 screening criteria of 270 F for plate materials.

The NRC review of the AP&L 10CFR50.61 submittal found the material properties of reactor vessel beltline materials, the projected fluence at the inner surface of the reactor vessel for the end of life of the plant and the calculated RT for the end of life of the plant to be acceptable.

TheNRCSafetyEvalua$Ibn Report, dated July 20, 1987, also found that the RT value of 179.6 F for the limiting plate material at the end of 32 EFPY, bch is beyond the current expiration date of the license, is acceptable.

As required by the NRC Safety Evaluation Report for the ANO-2 PTS evaluation, AP&L will submit J

a reevaluation of RT and comparison with the predicted value with future i

pressure-temperature $bmittalswhicharerequiredby10CFR50AppendixG.

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STRUCTURES l'

The reactor building, auxiliary building, intake structures and turbine l'

building are constructed of reinforced concrete and steel.

The containment building is a steel-lined, post-tensioned concrete structure.

Industrial experience with such materials establishes that a service life well in excess of forty (40) years can be anticipated.

Surveillance, inspection, and testing programs are in place to monitor-the condition of important structures so that any degradation can be identified and corrected.

In particular the containment integrated leak rate test (ILRT) performed at least three times every 10 years, verifies the leak tightness of the containment throughout its service life.

Surveillance of the containment post-tensioning system are performed to further verify integrity of the structure.

CONCLUSION Based on these programs and the evaluations of the potential impacts associated with this request, Arkansas Power & Light Company has determined that the proposed Operating License amendment does not pose significant safety risks during the additional six years of operation.

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SECTION 3 ENVIRONMENTAL ASSESSMENT The ANO Unit 2 Environmental Report was issued in March 1974.

Amendments were issued in July 1974, December 1974, June 1975, October 1975, December 1975, June 1976'and September 1976.

The Atomic Energy Commission issued a Final Environmental Statement (FES) in June 1977.

AP&L has reviewed these reports and concluded that the overall assessment and conclusions would not be dependent on specific operating life.

There are, however, five areas in which a specific operating life was either assumed or discussed:

o Population and Dose Assessment o

Environmental Monitoring Program o

Waste Disposal o

Uranium Fuel Cycle o

Transportation Each of these issues has been reevaluated as part of this license amendment request.

The results are presented below.

POPULATION AND.0FFSITE DOSE ASSESSMENT Comparison of current population within 50 miles of ANO based upon 1980 census data and original projections of 1980 populations made in the FSAR are given in Table 1.

The original projections are generally comparable to the census results, but underestimated the 1980 population between 0-30 miles from the facility.

TABLE 1 POPULATION DATA 1970-1980 Radial Distance Census FSAR Proj. Census Annual FES Current from ANO (miles) 1970 1980 1980

% Growth Proj. 2016 Proj. 2018 0-5 7,149 8,315 11,689 5.0 14,091 75,728 5-20 37,824 43,411 50,101 2.9 79,860 145,804 20-30 25,629 27,046 33,486 2.7 35,804 92,501 30-40 28,340 28,582 29,851

0. 5 32,822 36,368 40-50 65,746 67,819 67,041 0.2 92,952 72,192 164,688 175,173 192,168 255,529 422,593 Revised population estimates were obtained by determining the Annual Percentage Growth rate for each radial ring in Table 1 from 1970 to 1980.

Although it is unlikely that the large growth rates within 30 miles of the

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site will be sustained, that Annual Percentage Growth rate was applied to the 1980 census data to determine a projected 2018 population.

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The revised estimate (422,593 in 2018) is greater than the end of unit lifetime estimates given in the FES (255,529 in 2016) and FSAR (250,860 in 2016).

The revised population estimate is approximately 60% greater than the original estimates.

The estimated population dose per year of unit operation given in FES (Table 5.5) for the year 1990 is less than one man-rem.

Even considering the increase in population estimates, the l

population dose will remain very small compared to the population dose from natural background, which is estimated at 18,000 man-rem.

The increase in population associated with the proposed license extension will not change the conclusion reached in Section 5.5.1.6 of the FES that no measurable radiological impact on the local population is expected from the normal operation of ANO Unit 2.

ENVIRONMENTAL MONITORING PROGRAM The Environmental Monitoring Program (EMP) for ANO is based on the ANO Unit 1 Environmental Technical Specifications, Section 4.3 and on the Unit 2 Technical Specifications, Section 3/4.12.

The EMP for ANO would be expected to continue essentially unchanged during the extended operating life.

Measurements to date, as reported in the 1986 Radiological Environmental Report for ANO-1 and ANO-2, show no statistically significant difference in total dose between the average dose for the TLD indicator locations in the ANO EMP and marginal background radiation (control station-Danville, Arkansas).

The Arkansas Department of Health (ADH) conducts an independent environmental monitoring program similar to the AP&L program.

The results of the ADH's program are comparable to the AP&L's program and supports its conclusions.

Extension of the operating life of the unit by six years is not expected to affect previous estimates of annual releases of gaseous and liquid effluents.

No build-up of long life radionuclides in the soil has been detected by the ANO Environmental Monitoring Program, therefore, the six year extension of unit operation will not increase ingestion doses via an airborne-soil-food product pathway.

With respect to non-radiological effects, a general characterization of the fishery in the Dardanelle Reservior is that it is highly variable.

However, there does not appear to be a major shift in species diversity or relative density over the eight year sample period, 1974-1981, and thus no major shifts would be expected in the future.

WASTE DISPOSAL Low-Level Radioactive Waste Generation History Arkansas Power & Light Company has generated an average of 11,477 cubic feet of low-level radioactive waste per unit per year since December 1974.

Waste 10

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I volumes generated for each year of operation are shown in Figure 1.

Note that ANO waste generation af ter 1980 are shown for the average of both units.

Between 1980-1986, the industry PWR average waste generation was 15,452 cubic feet per unit per year.

AP&L generated an average of 14,777 cubic feet per unit per year during the same time period, j

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AP&L has shown a continual decrease in waste generation since 1981 except for 1984.

The higher than-industry-average waste generation in 1981 was due to a backlog of waste accumulated during previous years and that in 1984 was

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due to disposal of greater that 16,000 cubic feet of waste during the Unit 1

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spent fuel rerac'k modification.

AP&L initiated a waste volume reduction (VR) program in 1986.

A senior management directive was issued in January 1986 that addressed the plant's VR program and assigned responsibilities to individuals and management.

This management directive is reviewed annually and updated, if necessary, to reflect changes in the Company's VR program.

During the last 18 months (January 1986 through June 1987), AP&L has made a significant ef fort to reduce waste volumes.

Programs aimed at reducing waste volumes have proven successful, and waste generation rates are the lowest since 1977.

Waste Compact Arkansas joined the Central Interstate Compact (CIC) in 1983. Other member states include Kansas, Louisiana, Nebraska, and Oklahoma.

The CIC was ratified by the U.S. Congress in 1985.

The CIC Commission issued a Phase I Site Exclusionary Screening Study in June 1985 and a Phase II Site Exclusionary Screening Study in August 1987.

These studies identified geographic areas where the Compact's waste management facility could not be located.

The CIC Commission also issued a Management Plan in August 1987.

This plan evaluated the regional waste characteristics, alternative waste disposal technologies, and outlined an irrplementation plan for meeting the milestones in the 1985 Low-Level Radioactive Waste Policy Amendments Act.

In June 1987, the CIC Commission selected U.S. Ecology to develop, construct, and operate the region's waste management' facility.

U.S. Ecology has issued draft host-state selection criteria and a volunteer state incentives program to the CIC Commission, which will choose a host state and l

issue a siting plan by January 1, 1988.

AP&L anticipates that these arrangements will satisfy the low-level waste disposal needs of ANO-2 through the year 2023.

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Figure 1 Low Level Waste Generation, ANO and PWR Average -

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75 76 77 78 79 80 81 82 83 84 85 86 1

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  • - PWR Avg Unit Note: Data for ANO generation 1975-1983 is shipped volume, i

Data for 1984 1986 is final processed volume.

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URANIUM FUEL CYCLE I

The impact of the uranium fuel cycle was considered in the Final Environmental Statement (FES) for ANO Unit 2 (June 1977).

Since that time, the maximum reload enrichment has been increased to 4.1 weight percent U-235, thus allowing longer fuel cycles than those assumed in the original FES.

As a result of higher enrichments and longer fuel cycles, fewer total fuel assemblies will be discharged to the spent fuel pool (i.e.,

j an average of approximately.68 assemblies per 18 month cycle versus 59 assemblies per annual cycle).

In assessing the environmental impact of increasing the operating life from approximately 34 years to 40 years, the original FES has been reviewed along with the environmental analysis of the change in enrichment.

The additional years of reactor operation would almost proportionally increase the total fissile uranium required.

However, the annual environmental effects of the uranium fuel cycle activities remain essentially unchanged; the longer fuel cycles will result in a lower cummulative total of spent fuel assemblies discharged (i.e., with the longer cycles, approximately 1782 assemblies versus approximately 2420 assemblies with annual cycles over the assumed 40 year plant operating 1ifetime.

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AP&L has concluded that no changes to the FES would be necessary in order to l

permit 40 years of operation.

TRANSPORTATION The environmental effects of transportation accidents were evaluated in the Final Environmental Statement for ANO Unit 2.

That evaluation is not j

affected by extension of the plant's operating term.

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I 10CFR51.52, " Environmental effects of transportation of fuel and waste -

l Table S-4" provides the criteria for acceptable transportation of fuel and waste.

The following information pertains to ANO Unit 2 as required by 10CFR51.52:

1.

The reactor core thermal power is 2,815 megawatts.

2.

The reactor fuel is in the form of sintered urar)ium dioxide pellets having a uranium-235 enrichment not exceeding 4.1% by weight, and the pellets are encapsulated in zircaloy rods.

Although the maximum enrichment of ANO Unit 2 may exceed the criteria (4.0%) stated in 10CFR51.52 (a)(2), the environmental effect is I

negligible since average initial enrichment levels are below the l

10CFR51.52 value.

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The average burnup of ANO-2 discharged fuel a'ssemblies'is less than 33,000 MWD /MTU, with the highest batch average to date to 34,900 l

MWD /MTV.

Current cycle plans will achieve a batch average burnup of 42,000 MWD /MTU,.with peak bundles approaching 45,000 MWD /MTV.. The

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decay period (after fueljis discharged) prior to transportation will be much greater'than the 90 days required by 10CFR51.52(a)(2).

Based on the current progress for the development of'a high level waste

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repository, most: fuel. assemblies will have. decayed for several years.

While the average rate of fuel irradiation may exceed the value (33,000-MWD /MTU) reported in 10CFR51.52(a)(3), the environmental effect is not

.significant due to additional decay time beyond the 90 days specified in tne regulation.-

Furthermore, as stated in a' study prepared for the National Environmental Studies. Project of.'the Atomic Industrial Forum

.-(AIF/NESP-032), "... extending fuel burn-up'even to 60,J00 MWD /MTU resulti in environmental consequences which are either less than or-virtually the same-as those assumed in the current regulations."

4.

.All radioactive-waste shipped from the ANO site is in a solid form.

5.

Unirradiated fuel is shipped to the ANO site by truck.

Current plans are to ship irradiated fuel by truck or rail.

Radioactive waste other than irradiated fuel is shipped by truck.

6.

The transportation of radioactive material is regulated by the Department of Transportation and the Nuclear Regulatory Commission.

The regulations specify that the public and transport workers are to be protected from radiation.

This protection is achieved by a combination of standards and requirements applicable to packaging, limitation on the chemical (material) contents and radiation concentrations in waste packages, and handling procedures to limit the exposure of persons under normal and accident conditions.

i Primary reliance for safety in transport of radioactive material is placed on the packaging.

The packaging must meet-regulatory standards (10CFR71 and 49CFR173.and 178) that apply according to the type and form of material for containment, shielding, nuclear criticality safety, and heat dissipation.

The standards provide that the packaging shall:

prevent the loss or dispersal of the radioactive contents; retain shielding efficiency; assure nuclear criticality safety; and provide adequate heat dissipation under normal conditions of transport and under specified accident damage test conditi.ons.

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packages not designed to withstand accidents are limited, thereby

.j limiting the risk from releases which could occur in an accident.

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I contents of the package also must be limited so that the standards for l-external radiation levels, temperature, pressure, and containment are l

met.

f-Based on the above, AP&L concludes that the environmental impacts j

attributable to transportation of nuclear fuel and radioactive waste to and from the ANO site, with respect to normal conditions of transport and possible accidents in transport, is and will remain in accordance with the

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impacts set forth in Table S-4 of 10CFR51.52 regardless of the term of the operating license.

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SECTION 4 l

OCCUPATIONAL EXPOSURE (ALARA) EVALUATION 1

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AP&L:is committed to operate _ Arkansas Nuclear One in a manner that will not

-jeopardize Arkansas Power and Light personnel or the public health and safety.

Included _in the ANO Operating Licenses, is the obligation to maintain the radiation exposure to occupationally exposed personnel at i

levels which arelas low as is reasonably achievable (ALARA) and which.are in compliance with the USNRC Regulations, Title 10 Code of Federal Regulations, Part'20..To fulfill this obligation, Arkansas Power and Light Company 4

conducts'a Radiation Protection Program that insures compliance with regulatory requirements and the ALARA objective. _ The primary goal of the l

Radiation Protection Program.is to maintain individual and collective f

radiation doses to AP&L and contractor employees at ALARA levels through 1

improved operational practices, procedures, and equipment.

As a supplement to the corporate ALARA program, Generation Engineering initiates a peer review and corporate Health Physics _ conducts a review of q

changes ~or modifications to nuclear equipment and facilities for ALARA.

As part of the corporate ALARA efforts, periodic training has been provided for en'gineering and ALARA review personnel.

State-of-the-art ALARA design techniques that emphasize crud volume reductions and minimize dose accrual during plant modifications are introduced at the training sessions.

The corporate Health Physics group reviews the ALARA portion of each Design Change Package (DCP) as part of the approval process.

The corporate and AN0 ALARA programs have been implemented and audited, both j

internally and externally, with favorable results.

A corporate oversight program is in place to review radwaste, volume reduction, ALARA, and dose j

reduction techniques.

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G0ALS PROGRAM A_ Radiation Exposure Goals Program was started in 1987 to achieve personnel exposure reduction through improved performance of radiological work.

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goals are to be established annually, AP&L anticipates the continuation of this program as long as it remains effective or unless a more effective methodology is developed.

The following actions are initially being taken to implement this program, As with any dynamic program, these actions will J

be modified as more experience is gained.

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-(A) _ Radiation exposure goals for 1987 were developed by work groups that received significant radiation exposures.

Work groups which used or were responsible for contractor support were also responsible for developing exposure goals for those contractors.

i Managers select personnel f*om within these work groups to be

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responsible for developing radiation exposure goals and action plans 1

to achieve these goals.

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The ANO ALARA Coordinator works with these assigned individuals to provide data and assistance in the development of goals.

Work group exposure is tracked by the assigned individuals, and deviations from the goals are reported to the ANO ALARA Coordinator.

l These goals and plans of action were developed and reviewed with Departmental Managers to obtain their direction, ownership and approval.

The work group goals were compiled to develop the ANO 1987 Total Radiation Exposure Goal.

AP&L will be assessing the annual exposure goal effort to determine its effectiveness as an ALARA tool.

(B) Supervisory / management involvement in work activities in radiologically controlled areas has been increased.

(C)

Exposure reduction techniques and good radiation work practices are emphasized during radiation worker training.

(D) AP&L has implemented a decontamination and contamination control program for the ANO 1 and 2 Auxiliary Buildings, emphasizing the control of leaks and spills.

(E) ANO management are working to improve communications between Health Physics and other work groups on radiological considerations during work activities, routine operations, and outages.

SPECIFIC ALARA MEASURES Arkansas Power & Light Company has evaluated and implemented numerous ALARA-related changes that have or are expected to reduce occupational exposures.

The following are examples of specific measures that have been or are being taken at ANO:

(A) Equipment mock-ups are frequently used to train personnel prior to actual repair work being done.

(B) ANO subscribes to the NSSS vendor-specified lithium-borate chemical control programs for each unit to minimize activity buildup in the reactor coolant systems.

(C) Periodic cleaning of tanks and sumps has been implemented to evaluate its potential to reduce the quantity of spent resin that must be handled as radwaste, which would reduce the associated worker exposures.

(0) Permanent shielding has been installed for the Unit 2 reactor vessel head storage stand.

(E) The Unit 1 and 2 Auxiliary Buildings are being decontaminated so that most areas will not require anti-c clothing for entry.

Over the long-term, this is expected reduce personnel exposures and the volume of low level radioactive waste.

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l (F) ANO is implementing the use of glove bags to evaluate their effectiveness in helping maintain much of the Auxilary Buildings as uncontaminated areas.

(G) A dedicated decontamination crew has been added to the ANO staff.

(H) A computerized health physics record system has been installed.

The system tracks personnel exposures, produces ALARA reports, and generates radiation work permits.

OCCUPATIONAL DOSE ASSESSMENT The proposed additional years of reactor operation are not expected to increase annual collective occupational exposures to radiation workers.

Arkansas Power & Light Company will continue to comply with NRC guidance and requirements for keeping radiation exposures as low as is reasonably achievable.

Figure 2 presents information on past annual collective exposures at ANO j

compared to the industry average exposure per reactor.

Industry data for the years 1975 through 1982 are from NUREG 0713.

The industry data for 1983 through 1986 are from INPO documents.

ANO data reflects operation of both units after 1980.

ANO exposures have consistently been below the industry average with the exception of 1983 and 1986.

In 1983, approximately 100 man-rem was incurred I

during the installation of extensive modifications and 440 man-rem was due to Unit 1 steam generator tube repair.

An additional 30 man-rem was attributed to one-time evolutions such as fire barrier work and service water piping replacement.

The higher than average exposure in 1986 resulted from refueling outages for both units being extended, which permitted additional jobs to be performed during that year.

Arkansas Power & Light Company has tentatively set a long-term exposure goal for 1990 of less than 250 man-rem / unit based on a three year average.

Arkansas Power & Light Company will continue to comply with the established ALARA program and will incorporate on going improvements into that program as appropriate throughout the duration of the operating license.

The ALARA program is constantly evolving as techniques are perfected, technology is improved, and the work force becomes increasingly proficient in radiation protection practices.

Arkansas Power & Light Company does not expect any increase in the annual collective occupational exposure for the years 2012 - 2018 for Unit 2.

In fact, meeting the aggressive long-term exposure goals will result in annual exposure reductions.

1 AP&L does not anticipate that the relative distribution of exposures among work groups will change significantly.

Figure 3 provides an overview of man rem exposure by job functions, listed by major work group.

Data is for the entire site and reflects two-units operation af ter 1980.

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c Figure 2 Collective Occupational Exposure 700 --

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Figure 3 ' ANO Occupational Exposure Distribution 10.20 %

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__-___ _ _ m

FUTURE ALARA PROGRAM ENHANCEMENTS i

Arkansas Power & Light Company is committed to evaluating and implementing l

(as appropriate) new ALARA measures as they are developed.

The company is staying abreast of emerging ALARA concepts through its membership in such organizations as INPO, EPRI, NUMARC, and others.

Management attention has l

been focused.on ALARA by the AN0 ALARA Committee and the Generation, i

Transmission, and Engineering corporate ALARA program, which focuses on i

l increased maragement attention on ALARA.

Technological developments in I

fields such ar, the use of remotely operated tools and surveillance 1

equipment, enhanced training of radiation workers, new shielding techniques, I

advanced computer software programs for waste management applications, and others are being monitored to evaluate their applicability for improvement j

l of the AP&L ALARA Program.

J l

I i

l 20

____-______a

i l

j SECTION 5 j

NEEDS ASSESSMENT l

AP&L is a part of the Middle South Utilities (MSU) System, which operates as a single entity, with a highly integrated system consisting of hydro, fossil-fired, and nuclear fueled generating plants.

AP&L serves approximately 500,000 retail customers in 65 of Arkansas' 75 counties and 13 of Missouri's 114 counties with a current net generating capability of 5,694 MW.

Middle South Utilities System serves more than 1.7 million customers in a 92,000 square mile area of Arkansas, Louisiana, Mississippi, and Southeast Missouri with a current net generating capability of q

15,461 MW.

During the period 1976-1986, AP&L's peak load grew from 3,000 MW l

to 3,804 MW, an average annual increase of 2.4% per year.

MSU's peak load grew during the same period from 9,345 MW to 12,351 MW, an average annual j

increase of 2.8%.

l l

The projected peak load generating capability and margin during the period 1988 to 2018 for AP&L and Middle South Utilities System are shown in Figures 4 and 5.

These figures reflect current plant retirement dates and assumed load growth rates of about 1.5% per year for AP&L and up to 2.0% per year for MSU System.

However, they do not include the current planning criteria, which require a 20% capacity margin.

Evaluation of the current projections shows that capacity margin is expected to drop below the planning criteria for margin in 2000 for AP&L and in 1996 for the MSU System.

By the current ANO-1 license expiration year, 2008, projected load exceeds projected capability by 48 MW for AP&L and by 3689 MW for the MSU System.

The capacity deficit (capability deficit plus planned margin) totals 1272 MW for AP&L and 7519 MW for the MSU System in the year 2008.

The projections for 2012, the current ANO-2 license expiration year, are even more critical.

Projected load exceeds projected capability by 2107 MW for AP&L and by 8747 for the MSU System.

The capacity deficit totals 3406 MW for AP&L and 12,886 MW for the MSU system in the year 2012.

The capacity deficits are significant and will need to be made up through an appropriate combination of load management, cogeneration purchases, conservation, life extension, power purchases, or capacity additions.

It is clear, in any case, that the loss of the generating capability represented by ANO-2 in 2012 would place additional strain on an already burdened system.

AP&L considers the requested extension of the license term necessary in order to meet future electrical energy demand and to defer the l

need to construct replacement baseload capacity and the attendant

{

environmental impacts.

L CONSIDERATION OF ALTERNATIVES l

The alternatives to extension of the operating term of ANO-2 consist of load j

management, cogeneration purchases, conservation, power purchases, or capacity additions.

However, considering the magnitude of the projected capacity deficit, even with extension of operation of ANO-2, and the capacity of ANO-2, itself, the only realistic, long-term alternative to 21 E_---___________

j

e e

Figure 4 AP&L Projected Capability and Load 1988 2018 6000 I-e.,*e-e-e-e e=e-e-e g.,***"8*e*erere Cao=O*O=0.Oe9"O=O=O=0 5000 O MN j

0 0-0 0-OsO=0.Onp=O=O-O 4000

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(

AN 1 un t Ucense Expiration 2000 e-e,e=e.e-e ANO-2 Current Ucense Expiration 1000 0

l 1988 1990 1992 1994 1990 1998 2000 2002 2004 2006 2008 2010 2012 2014 2018 2018 Year e= Capability

.O. Load Figure 5 MSU Projected Capability and Lead 1988 2018 I

20000 18000

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1988 1990 1992 1994 1998 1998 2000 2002 2004 2006 2008 2010 2012 20 t 4 2018 2018 Year I

.e= Capability O-Load 22

l c

l' I

l continued operation of ANO-2 would be the construction of replacement capacity.

l Extension of'the operating term of ANO-2 is the more appropriate ano l

desirable alternative because; (1).ANO-2 is a valuable generating asset with I

a safe, useful lifetime of at least 40 years, (2) extension of ANO-2 will postpone the financial and environmental impacts associated with any new construction project, and (3) continued use of this nuclear-fueled power plant will reduce the consumption of valuable imported or domestic fossil fuels, and thus minimize the environmental impacts that result from burning those fuels.

ECONOMIC BENEFIT Arkansas Power & Light Company and its customers will experience substantial cost savings due to the license extension of ANO-2.

Savings result from extending the depreciation and decommissioning costs of the plant.

Also, customers benefit from the lower revenue requirements for the investment in the existing plant as opposed to the cost of constructing and licensing a new plant during the extension period.

Extending the license of ANO-2 by approximately six years will result in an estimated net present worth savings in total revenue requirement of over

$175 million.

This estimate is based on a comparison of the revenue requirements of the extended ANO-2 plant to the revenue requirements of a new base load. plant during the extension period.

The cost of the new plant is based on an estimated current cost of $1300 per kW installed capacity.

Fuel and operating costs are based on the projected costs at Arkansas Power

& Light Company's coal-fired plants.

c i

l SECTION 6 SIGNIFICANT HAZARDS ANALYSIS PROPOSED CHANGE This license amendment application seeks to change the expiration date of Facility Operating License No. NPF-6, for ANO-2 from December 6, 2012 to j

July 17, 2018, i.e., 40 years from the date of issuance.

l DISCUSSION AND BACKGROUND Section 103.c of the Atomic Energy Act of 1954 provides for a license to be issued for a specified period not exceeding 40 years.

10CFR50.51 states that the Commission will issue an operating license for the term (not exceeding 40 years) requested by the applicant or for the estimated useful life of the facility if the Commission determines that the useful life is less than the term requested.

The Construction Permit for ANO-2 was issued on December 6, 1972.

The Operating License was first issued on July 18, 1978, and expires on December 6, 2012, forty years from the date of the Construction Permit.

The term of the current Operating License is, thus, approximately 34-1/2 years.

The proposed change would allow operation of ANO-2 for 40 years from the date of the Operating License.

Granting of a 40 year license term is j

permitted by regulations, specifically 10CFR50.51, and consistent with Commission action on other applications of this nature.

SIGNIFICANT HAZARDS CONSIDERATIONS This proposed change has been evaluated against the criteria of 10CFR50.92 and has been determined to involve no significant hazards considerations.

The following evaluation is presented in support of this conclusion.

Criterion 1 - Operating of the facility in accordance with the proposed amendment would not involve a significant increase in the probability or consequences of an accident previously evaluated.

The proposed change does not involve any changes in plant design, physical changes to plant systems, equipment or structures, or modifications to Technical Specifications or plant procedures.

The original plant design provides for 40 years of operation and postulated accidents have been evaluated accordingly.

Surveillance, inspection, testing, and maintenance programs are in place to sustain the condition of the plant throughout its service life.

In conclusion, the potential effects of 40 years of operation have been considered in the existing design, analyses, and operation of the plant and, therefore, the probability or consequences of previously evaluated accidents has not been significantly increased.

24

i. -

4l ' A ~'4, Criterion'2 -' Operation of the facility in accordance with the. proposed.

amendment would not create the. possibility of a new or different type of 1

accident from any accident previously evaluated.

Since the proposed change does not affect the design or operation of the_

plant and programs are.in place to maintain the' plant throughout its service life, the change does not increase the possibility of a new or different accident from those previously evaluated.

Criterion 3 - Operation of the facility in accordance with the proposed' amendment would not involve a significant reduction in a margin of safety.

The proposed change does not involve any changes in plant design, physical changes to plant systems, equipment or structures,.or modifications to Technical Specifications or plant procedures. ' Existing surveillance,

. inspection,' testing, and maintenance programs sustain the condition of the

. plant throughout.its service life.

These measures, together with continued operation in accordance with the Technical Specifications assure that an adequate margin of safety is. preserved on a continuous basis.

Therefore, 1

the extension of the operating license term does not result in a significant reduction in a marnin 'of safety.

a 1

)

25

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