ML20245A585
| ML20245A585 | |
| Person / Time | |
|---|---|
| Site: | Summer  |
| Issue date: | 06/15/1989 |
| From: | Bradham O SOUTH CAROLINA ELECTRIC & GAS CO. |
| To: | Hayes J NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 8906220075 | |
| Download: ML20245A585 (40) | |
Text
.
ollie s.Bradham tNi hu le p rktions C Sumn clear
$nSM SC 29065 scuan
{ggrigt June 15, 1989 Document Control Desk U. S. Nuclear Regulatory Commission Washington, DC 20555 Attention: Mr. J. J. Hayes, Jr.
Subject:
Virgil C. Summer Nuclear Station Docket No. 50/395
~ Operating License No. NPF-12 40-Year Operating License Gentlemen:
This will respond to the NRC April 20, 1989, request for additional information to support the proposed extension of the operating license for the Virgil C. Summer Nuclear Station (VCSNS) to a 40-year term beginning with the date of the operating license rather than the construction permit.
The enclosed information addresses each of the items listed in the April 20, 1989, request, es well as additional items that South Carolina Electric & Gas Company (SCE&G) believes would help facilitate the NRC review.
For convenience, we are providing to the NRC Project Manager a set of the various references utilized in tnis submittal.
SCE&G submitted its license amendment application on August 2, 1985, 19 months after the plant began commercial operation. SCE&G believes that the application was adequate for review and acceptance. Because of the short time of plant operation, the application largely rested upon, and in essence incorporated, the safety and environmental analyses oo which licensing of the j
plant was based. Not only was the facility designed for a 40-year operating life, but the Operating License Environmental Report and the Final
]
Environmental Statement (issued in May 1981) evaluated environmental effects assuminga40-yearoperatinglifefortheplant(SeeFES 4.2).
In the thort period of plant operation up to that time, none of the relevant safety
)
and environmental data had changed materially.
]
In submitting its amendment application, SCE&G was also aware that, at about the time VCSNS was 11 censed in 1982, the Commission had changed its practice so that operating licenses would be granted routinely for 40-year terms
}
beginning with the operating license date.
In the period 1982 to 1986, plants licensed with 40-year terms included LaSalle Units 1 and 2, Susquehanna Units 1 and'2, St. Lucie Unit 2, Callaway Unit 1 Waterford Unit 3 and Catawba Unit 1.
SCE&G reasonably believed that VCSNS would te accorded i
the same treatment as other plants of the same vintage, and is not aware of any substantial additional information presented in those licensing proceedings that was not presented in the VCSNS proceeding. Since 1985, license amendments for some 26 units (some much older units than VCSNS) have j
been granted to extend the operating license term to a full 40 years.
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~8906220075 890615
't ADOCK0500g5 l
DR
Qocument Control Desk g
June 15, 1989 Page 2 of 3 4
SCE&G believed that its original application, when viewed as incorporating the safety and environmental reviews from the then recently completed operating license process, presented essentially the same information found acceptable for the other facilities. The NRC published a notice in the Federal Register of the SCE&G application on May 7, 1986, together with a proposed determination that the application presented no "significant hazards considerations." (51 FR 16934.) Thereafter the Staff requested additional environmental information, which SCE&G provided by letter dated March 30, 1988.
l The enclosed response provides substantial information on environmental and technical items and demonstrates that the proposed extension does not present any significant safety or environmental issues.
In SCE&G has been guided by available NRC guidelines l' preparing the response, and the submittals found acceptable for other plants. SCE&G has made every effort to be responsive to the NRC. The extension continues to be an important matter for.SCE&G. The additional nine years of plant operation are of obvious importance to the welfare of this Company and its service area. Effective in July 1989, SCE&G rates to its customers are expected to reflect a 40-year depreciation schedule for VCSNS, which was based on the assumption of a 40-year operating life. SCE&G, therefore, placed high priority on compiling the necessary information to support the extension and working with the Staff on this matter.
Should you have any questions on this matter or find that additional information or references would be useful, please feel free to telephone my staff, which will stand ready to assist the NRC in any way necessary. SCE&G appreciates your attention to this matter and believes that the proposed license amendment is in the public interest and requests that it be granted.
Very truly yours, h_~
- 0. S. Bradham DFS/0SB: led c:
See Page 3 l
.1)
Memorandum from D. M. Crutchfield to G. Lainas and D. C. Rossi, " Form and Content of Nuclear Power' Plant Operating License Extension Safety Evaluations and Environmental Impact Statement," dated February 13, 1987.
Document Control Desk June 15, 1989 Page 3 of 3 D. A. Nauman/0. W. Dixon, Jr./T. C. Nichols, Jr.
c:
E. C. Roberts W. A. Williams, Jr.
S. D. Ebneter J. J. Hayes, Jr.
General Managers C. A. Price /R. M. Campbell, Jr.
R. B. Clary K. E. Nodland J. C. Snelson G. O. Percival R. L. Prevatte J. B. Knotts, Jr.
H. G. Shealy NSRC NPCF RIS (0L 500)
File (814.03-2) 1
1 l
RESPONSE BY SOUTH CAROLINA ELECTRIC AND GAS COMPANY TO NRC REQUEST FOR ADDITIONAL INFORMATION DATED APRIL 20, 1989 INTRODUCTION South Carolina Electric & Gas Company (SCE&G) provides the following response to the NRC's April 20, 1989 request for additional information to support an extension of the operating license for the Virgil C. Summer Nuclear Station (VCSNS) to 40 years from the date of the operating license rather than the construction permit.
The items addressed were identified in the enclosures to the NRC Staff April 20, 1989 letter. SCE&G has also addressed additional items relevant to the proposed extension, such as the impact on radwaste shipments and electrical equipment.
The response is divided into two sections:
(1) environmental impacts, and (2) technical issues. A set of important reference documents has been provided to the NRC Project Manager.
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1 ENVIRONMENTAL IMPACTS 1
I I
As requested by the NRC letter of April 20, 1989, the SCE&G response (1) compares data from actual plant operation with projections in the Final Environmental Statement (FES)_1/and assesses the impact of operation of the l
VCSNS on the environment, (2) considers the impact of the additional period of operation on the conclusions of the FES, and (3) demonstrates that l
operation of the plant has not negated the conclusions of the FES.
In l
addition, where there have been material changes in the facility or environmental conditions, these have also been addressed.
On the basis of the information discussed below, SCE&G concludes that the extension of the operating license will not have a significant impact on the environment. Moreover, by deferring the need for new generating capacity or costly replacement power, the extension is in the public interest and will enhance the economic well-being of the communities within the SCE&G service area.
1.
Impacts on Land Use The FES assessed land use impacts assuming a 40-year operating life for the plant.
(FES 4.2.)
SCE&G is not aware of any material changes that would alter the original conclusions of the FES with respect to impacts on land use. Nevertheless, a brief discussion of land use is provided.
SCE&G owns approximately 11,000 acres in the vicinity of the site.
The areas cleared for the station and transmission corridors will not change as a result of the proposed license extension. Thus the FES (6 4.2) projection that approximately 2 x 107 bd. ft. of pulpwood and lumber will be lost during the 40-year operating life of the plant is unchanged, and remains a highly conservative estimate.
As the FE5 predicted, the use of land for transmission lines has not resulted in permanent loss of farmland, since farming activities have been able to continue during line operation.
Also as predicted in the FES, plant-induced impacts on land use outside the immediate area of the site have not been pronounced nor will they be as a result of the license extension.
As the FES 4
predicted, population growth resulting from the in-migration of workers both for jobs at the plant itself and for service-oriented jobs stimulated by plant operations has been small compared to existing population in the Central Midlands region.
Thus the amount of land converted from agriculture and forestry to residential and l
commercial uses has also been small. This is not expected to change as a result of the license extension.
.Jf NUREG-0717. " Final Environmental Statemeat by the Nuclear Regulatory Commission, Office of Nuclear Reactor Regulation Related to the Operation of Virgil C. Summer Nuclear Station, Unit 1, Proposed by South Carolina Electric & Gas Company, Docket No. 50-395," dated May 1981.
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4 2.
H.ydroloaic Impacts of Operation A.
Surface Water The effect of the operation of VCSNS on surface water is limited to increased evaporation in Monticello Reservoir and the release of effluents to Monticello Reservoir, Broad River,, and small streams which flow to the Broad River. The evaporation from Monticello Reservoir caused by VCSNS operation was estimated in the FES as 13 cfs; the total evaporation from Monticello Reservoir was estimated as 46 cfs.
Rainfall inflow was estimated as 35 cfs. The resulting 11 cfs deficit is easily made up by the 40,000 cfs pumping rate of the Fairfield Pumped Storage Facility (which is licensed for operation until June 2020). Thus there is no discernible effect on Monticello Reservoir level. Since license extension will not change the rate of evaporation, the FES conclusion that evaporation will not be significant compared with the pump rate of the Fairfield Pumped Storage Facility remains true for a 40-year operating life.
B.
Chemical and Sanitary Wastes The release of chemical and sanitary wastes into surface waters is controlled through the facility's NPDES permit (SC0030856) which is administered by the South Carolina Department of Health and Environmental Control (SCDHEC).
(The NPDES permit expires June 30, 1989. A timely request for renewal has been submitted.)
VCSNS routinely meets the effluent limitations imposed by the NPDES permit. One problem area has been the growth of algae in treatment ponds. This algal growth, because of the associated l
rapid rate of photosynthesis, has caused pH limits to be exceeded at times during the summer months.
SCE&G has requested and received approval from SCDHEC for an algae control program which should solve the problem. Even though pH limits have been periodically exceeded during the summer at these particular discharges, the volume of these discharges (typically less than 1 l
MGD) is small related to the Circulating Water flow (769 MGD) into which they discharge. This dilution precludes any significant impacts in Monticello Reservoir.
SCE&G has also received approval from SCDHEC to use boric acid in the secondary side of the plant in order to control corrosion.
Because of low toxicity of boron to aquatic organisms and the low level of boron concentration to be discharged (less than 10 ppm following an initial " soak" of 50 ppm), the environmental impact was determined to be inconsequential.
Boron discharges are currently being monitored. Since effluent limitations will remain in effect throughout the operating life of the plant, the extension of the operating license to 40 years should have no effect on effluents from VCSNS.
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C.
Water Quality
]
Environmental monitoring studies (Dames & Moore, April 1985)
(Reference 1 hereto) have shown that there has been no
)
significant reduction in water quality in Parr Reservoir or the Broad River as a result of VCSNS operation. The water quality in Monticello Reservoir has also remained very good with turbidity l
levels considerably lower than Parr Reservoir. There is no 1
indication from the studies conducted to date to suggest that l
license extension will have any effect on water quality.
D.
Thermal Operational thermal mapping studies (NUS Corp., 1985) (Reference 2 hereto) have shown the area of the thermal plume in Monticello to be well within predicted values. Computer modeling (NUS, 1985 & 1989) (References 3 and 4 hereto) predicts the maximum thermal plume area (1*C excess temperatures and 20 year meteorology) will cover approximately one half of the surface of Monticello Reservoir. Thermal plume area limits imposed by the NPDES permit (6700 acres, essentially the whole reservoir) have ever been exceeded. Based on the studies and modeling to date, extension of the operating license to 40 years is not expected to cause the thermal effects of VCSNS to exceed predicted values.
E.
Groundwater Effects on groundwater from VCSNS operation are limited. See FES S 4.3.7.
Filling of Monticello Reservoir caused groundwater levels to rise in the area around VCSNS.
In an effort to reduce groundwater levels and the resulting groundwater inflow into the plant, groundwater has been pumped from two wells. A minor oil spill during construction has necessitated the installation of groundwater monitoring wells around the Auxiliary Boiler Fuel Oil Tank. Groundwater monitoring wells have also been installed near the wastewater treatment ponds in expectation of tighter regulations.
Extension of the operating license to 40 years will not change the groundwater effects.
In summary, the hydrological impact of the operation of VCSNS has been consistent with the conclusion made in the FES, i.e., the impact on regional hydrology is insignificant.
Information available to date indicates that the impact will remain acceptable during the extension period.
l 3.
Impacts on Biota l
l A.
Terrestrial Environment Terrestrial effects of VCSNS are very limited as predicted in the FES. See FES 4.4.1.
Infrared photography has revealed no loss of plant vigor around VCSNS.
Bird surveys revealed no differences between preoperational and operation 61 data with the exception of changes in composition and numbers of waterfowl and I
Page 3 of 36
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j wading birds due to the creation of Monticello Reservoir (Dames &
Moore, April 1985) (Reference 1 hereto).
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B.
Aquatic Environment
(
I Preoperational and operational surveys were conducted from 1978 through 1984 to determine effects of VCSNS on aquatic biota in MonticelloReservoirandParrReservoir(Dames & Moore, April
)
1985).
Effects of the thermal discharge in Monticello Reservoir 4
appear to be restricted to the southeastern portion of the reservoir, although there may be a~ general trend of earlier fish spawning in Monticello Reservoir.
Benthic organism densities appear lower in the vicinity of the thermal discharge. Hot weather fish kills have occurred in the discharge canal.
SCE&G has considered these kills minor; the numbers of fish involved range from several up to several hundred. Discussions are being pursued with the South Carolina Department of Health and Environmental Control and the South Car 311na Wildlife and Marine Resources Department concerning possibi mitigative actions.
Thermal limits as stated in the NPDES permit (113*F discharge temperature, 90*F plume temperature measured at Fairfield Pumped Storage Facility, and 3*F plume temperature rise) have not been exceeded.
There was no indication of effects from the thermal discharge on ParrCeservoir(thelowerreservoirofthePumpedStorage Facility) or the Broad River.
This would be expected since studies have shown the thermal plume is generally restricted to the southeastern portion of Monticello Reservoir away from the Fairfield Pumped Storage Facility and the discharge into Parr Reservoir and the Broad River (NUS Corporation, 1985) (Reference.
2 hereto). The FES stated that the thermal discharge into Parr Reservoir should not affect striped bass spawning downstream.
The thermal plume study (NUS Corporation, 1985) supports this statement.
The thermal discharge from VCSNS has no apparent effect on dissolved oxygen levels in Monticello Reservoir.
Low dissolved oxygen levels were found in deep, stratified areas of the lake (Dames & Moore, April 1985) (Reference 1 hereto), but this is unrelated to the operation of VCSNS.
i Cooling system impingement and entrainment were evaluated in 1983 and 1984 (Dames & Moore, March 1985) (Reference 5 hereto). This study indicated that although fish were being removed through impingement, the effects on the adult fish population should be minimal. Also entrainment losses were determined to have no apparent ill effects on the fish community of Monticello Reservoir.
j Chemical discharges from VCSNS have been in line with those predicted in the FES. These discharges are controlled through tne facility's NPDES permit or through specific SCDHEC approval in the case of boron, and thus limit the effects on aquatic l
Page 4 of 36
biota. There is no indication that chemical discharges from VCSNS have caused any detrimental effects to the. aquatic biota.
One change to chemical discharges is the proposed use of biocide to control asiatic clams in the. Service Water System. Approval has been requested from both the NRC and SCDHEC for this biocide' application.
In summary, the VCSNS operational impacts on biota are consistent with the FES evaluation. Based on information to date, the extension of the license to 40 years is not expected to change the observed impacts.
4.
Radiological Impacts SCE&G has assessed the radiological impacts of extending the operating license of the VCSNS. SCE&G has reviewed the FES and compared those values against actual operational values and projected' changes'in-these values during the proposed license extension. As demonstrated in the following discussion, actual and projected future doses are near or below those assumed in the FES, far below 10 CFR 50 Appendix I ALARA Design Criteria, and insignificant when compared to natural background radiation in the environment. Moreover, currently available population projections based on the 1980 census show that the population projections contained in the FES were conservatively hign. Therefore, it will be shown that the FES conclusion "no significant environmental impact" will remain valid for the proposed-extension of the VCSNS operating license.
SCE&G has demonstrated its commitment to maintain radiological environmental impacts (dARA (As Low As. Reasonably Achievable) by limiting effluent releases and thus doses to a small fraction of 10CFR 50~ Appendix I, ALARA Design Criteria (implemented during plant' design and construction and maintained through VCSNS. Technical Specifications and Operating Procedures).
SCE&G has further demonstrated this commitment by a) establishing programs requiring successively higher management approvals for more significant releases, b) establishing a Radioactive Waste Management Committee to evaluate performance and guide improvement, c) continually evaluating advancements in radioactive effluent reduction technology and implementing effective technology such as the recently-installed enhanced demineralization equipment for liquid radioactive waste, enhanced Reactor Coolant purification (reduces sources of radioactivity), and improved recycle evaporator equipment (allows reuse of chemicals and water). As can be seen SCE&G has been and continues.to be committed to maintaining radiological impacts resulting from operation of the VCSNS "As Low As Reasonably Achievable."
A.
Exposure Pa$hways Environmental exposure pathways (that is, routes of radioactive material migration through the environment) presented in 4.5.1 of the FES have not changed and are not expected to change during the proposed extension of the VCSNS operating license, f
Page 5 of 36
8.
Dose Commitment
. Review of the effluent reports for the VCSNS indicate thatLactual quantities of radioactive materials"in gaseous releases to the
. environment have been considerably less than those projected in
. Tables 4.5 of.the FES. 'The actual quantities of radioactive
' material in liquid releases to the environment were.somewhat greater than projected in Table.4.12 of the FES.. However, as can be seen in the remainder of this discussion, the resultant doses continue to be a small fraction of the ALARA Design Criteria established in 10 CFR 50,; Appendix I and RM-50-2.
Table 1 lists the VCSNS effluent history and gives a comparison,to the FES Tables 4.5 and 4.12.
SCE&G maintains a detailed environmental monitoring program to continually assess the presence and effects of radioactivity in the environment due to operation of the VCSNS.
Results published in the annual Radiological Environmental Monitoring Reports show that the effects of.
operation of the VCSNS are less than the variation in natural' background radiation.and many times less than naturally occurring-radioactivity in the environment.
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Table 1 Part i V. C. Summer Nuclear Station Historical Summary of Radioactive Effluent Releases Curies Liquid Releases Averace' 1982 1983 1984 1985 1986 1987 1988 Fission & Activation Products 1.24E-4 1.47 4.54 7.09E 1 3.26E-1 4.88E-1 7.55 E-1 1.38 Tritium 3.19 E-1 227 225 311 375 736 755 438 Dissolved & Entrained Gases 6.22E-6 2.31E 2 3.90E-2 5.70E-3 3.61 E-3 1.35E-2 3.86 6.6E-1 Gross Alpha Activity 0
2.02 E-4 0
0 0
0-0 3.4E-5 Gaseous Releases l
i Fission & Activation Gases 140 388 16.4 140 13.9 634 332 254 lodines 0
2.05E-5 1.88E-6 2.00E-5 '
2.99 E-5 4.49E-4 2.28E-3 4.7 E-4 Particulate 0
2.69E-5 7.12E-6 5.50E-6 0
2.55E-4 4.38E-5 5.6E-5
)
l Tritium 3.41 E-4 3,62 2.24E-1 2.76E 1 1.51 E-3 5.43E-1 1.51 1.0 1
i 1.
Averages do not include 1982 since the station operated only part of that year and I
activities were very low.
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Table 1 Part 11 -
Comparison Between FES Projected Annual Radioactive Effluent Releases j
and the Average VCSNS Annual Releases l
Averaae VCSNS.
Liquid Releases FES Projection (Ci)
' Annual Release (Cil Total Except Tritium '(Excluding Entrained Noble Gas) 0.26 1.38 Annual Releases 360 438 Gaseous Releases Noble Gases 3125 254 lodine 0.132 4.7 E-4 Particulate (Excluding C 14) 4.0E-3 5.6E Tritium 800 1.0 1.
Noble gases entrained in liquid effluent are not a significant contributor to offsite dose and rapidly dissipated to tlie atmosphere after release to the environment.
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Effluent. reports for the VCSNS indicate that calculated doses from actual radioactive effluent' releases have averaged'less than or only slightly more than those projected in Table 4.8 of the FES. As can be seen in. Table 2, the offsite. individual dose has been a small fraction of the ALARA Design Criteria established in.
10 CFR 50, Appendix 1 and RM-50-2. Considering the location for calculation of offsite individual dose (1.0 and 1.2 miles) which correspond to the site exclusion area' boundary and the nearest -
credible location for a garden, no smaller distances (which would serve to increase calculated individua1' dose) are expected for the extenaed operating period of the VCSNS.
Barring any unanticipated climatological changes or significant changes in annual radioactive effluent releases, offsite individual dose is not expected to change significantly from those presently-experienced during the period of license extension.
The population distribution projections (size of population at various distances and directions from the VCSNS) (presented in this report) are the primary factors affecting population dose commitment. As tne population increases, so does the annual-population dose commitment.due.to natural background radiation.
However, population dose commitment due to operation of the VCSNS is more strongly influenced by changes'in population near the station than changes farther away.
Population projections indicate that population growth in general is less than FES projections. As discussed in sf 4.5.2.1 and 4.5.2.2 of the FES, the population doses due to VCSNS operation were projected to be a very small percentage of natural background population dose-(0.002% down to 0.00001%).
See Table'3 for a representation of these doses. The small difference between FES projected effluent.
release activity and actual release activity coupled with a lower population growth rate indicate that the FES conclusion is conservative. Since the new population distribution projections indicate these trends will continue, extended operation.of the VCSNS should have no significant impact on the annual population dose commitment.
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a Table 2 Part i V. C. Summer Nuclear Station Historical Offsite Individual Dose Doses (mrem / year or mrad / year)
Gaseous Effluents Curies 1Average Noble Gases 1982 1983 1984 1985 1986 1987 1988 Gamma air dose 4.07E-4 1.17E-2 3.72 E-3 2.67E-2 8.71 E-4 4.04E-2 3.31 E-2 1.94E-2
~
Beta air Dose 4.57E-2 1.12 E-1 5.23 E-3 7.64 E-2 2.54E-3 1.15 E-1 6.49E-2 6.27E-2 1
lodine & Particulate Organ 1.59 E-7 2.40E-3 1.52 E-4 4.96E-4 5.14 E-4 8.28E-3 3.28E-2 7.44 E-3 Liquid Effluents I
Total Body 3.63E-6 6.88E-3 1.73 E-2 4.21 E-2 4.36E-2 6.30 E-2 2.13 E-1 6.43 E-2 Organ 3.67E-5 4.51 E-2 2.72E-1 1.44E-1 5.60E-2 7.95 E-2 2.77E-1 1.46E-1 l
1.
Average does not include 1982 since the station operated only part of that year and j
activity levels were very low.
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Table 2 i
Part ll i
Comparison Between VCSN5's Average Annual Offsite Individual Doses
{
i and FES Projections,10CFR 50 Appendix i Dose Design Objectives and RM-50-2 Dose Design Objectives Doses (mrem / year or mrad / year)
{
VCSNS FES 10CFR 50 RW50-2 Gaseous Effluents Average Ta6Te 4.8 Appendix 1 Noble Gases Gamma Air Dose 0.019 0.23 10 10 Beta AirDose 0.063 0.57 20 20 lodines & Particulate Organ 0.0074 0.75 15 15 Liquid Effluent Total Body 0.064 0.05 3
5 Organ 0.15 0.06 10 5
Page 11 of 36
4 Table 3 Projected Population Dose Commitment from FES Sections 4.5.2.1 and 4.5.2.2 Population Within 50 Miles of VCSNS Natural Background Radiation Collective Dose 105,000 person-rem / year VCSNS Gaseous Effluents -
Collective Dose 1.8 person-rem / year
% of Background < 0.002 %
VCSNS Liquid Effluents -
Collective Dose 1 person-rem / year
% of Background < 0.001 %
U. 5. Population Natural Background Radiation Collective Dose 27,000,000 person-rem / year VCSNS Gaseous Effluents -
Collective Dose 28 person-rem / year
% of Background 0.0001 %
VCSNS Liquid Effluents -
Collective Dose 1.1 person-rem / year
% of Background
< 0.00001 %
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o 6
C.
Re-examination of Population Distribution Estimates In order to fully assess potential changes to the radiological impacts on the general public as a consequence of the proposed extended period of operation, SCE&G has re-examined the population distribution estimates on which radiological impacts were assessed.
The FES for the VCSNS, based on the 1970 census, projected a 14.5% increase in population within 50 miles of the VCSNS from 1970 to 1979, and a 67.3% increase from 1979 to 2010 (See.FES Figure 2.2).
FES Table 2.1 projected the population for the Central Midlands region (by county) for the years 1970 through-2000. SCE&G has compared those projected population increases with current available data. As Table 4 shows, the level of-population projected in the FES for 1980 is extremely close to the 1980 census data.
In addition, as, Table 4 shows, population projections based on 1980 census data for'the years 1990 and 2000 are substantially less than those projections contained.in FES Table 2.1, reflecting an expected downward trend in the population of the region.
For example, FES Table 2.1 projected for the year 2000 a population total of 753,000.
However, based on 1980 census data, as reported by the South Carolina Division of Research and Statistical Services and the DRI, State Economic Service, the projected population totals for the year 2000 are 587,700 and 582,910 respectively. -Similarly FES Table 2.1 projected _a population total of 566,750 for 1990; DRI, State Economic Service, projects, based on 1980 census data, that figure to be 523,220. And, the 0-50 mile total projected for 2010 in FES Figure 2.2 was 996,531 (low) and 1,182,356 (high). The increase in population predicted in the FES was therefore conservatively high. Specifically, the projection for 2020, based on 1980 census data, for the Central Midlands Region is 733,977, a figure lower even than the population projected for the' year 2010 in Figure 2.2 of the'FES.
See Table 4.
SCE&G concludes therefore that new projections of population distribution as related to a nine year extension of the VCSNS operating license are bounded by the previous FES projections.
Page 13 of 36
e Table 4 Population in Councies and Rates of Growth Average Average Annual Annual Richland Growth Growth Lexinaton Growth Growth 1970 233,868 89,012 1980 269,600 15.3%
1.4%
140,353 57.7%
4.7%
1990 296,440 10.0%
1.0%
174,300 24.2%
2.2%
1995 316,360 6.7%
1.3%
183,750 5.4%
1.1%
2000 339,590 7.3%
1.4%
191,480 4.2%
.8%
2010 390,189 14,9%
1.4%
207,373 8.3%
.8%
2020 448,327 14.9%
1.4%
224,585 8.3%
.8%
2022 460,880 2.8%
1.4%
228,192 1.6%
.8%
Average Average Annual Annual Newberry Growth Growth Fairfield Growth Growth 1970 29,273 19,999 1980 31,242 6.7%
.7%
20,700 3.5%
.3%
1990 32,500 4.0%
.4%
20,020
-3.3%
.3%
1995 32,610
.3%
.1%
19,870
.8%
.2%
2000 32,170
-1.4%
.3%
19,670
-1.0%
.2%
2010 31,205
-3.0%
.3%
19,277
-2.0%
.2%
2020 30,269
-3.0%
.3%
18,891
-2.0%
.2%
2022 30,088
.6%
.3%
18,816
.4%
.2%
l Average l
Annual l
State 1970 1980 Growth Growth South Carolina 2,590,516 3,120,730 20.5%
1.9%
Forecast Source: Summer / Fall 1988 DRI Forecast - forec.ast to year l
2000./ Projections beyond 2000 by SCE&G Forecasting Department.
Page 14 of 36
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D.
Occupational Dose
)
The VCSNS FES s 4.5.2.3 assumed the average annual occupational I
dose to workers at 1300 person-rem / year. As can be seen in Table 5, the long-term average and the three year running averages (three year averaging is recommended by INP0 to make dose j
l trending more meaningful by adjusting for variations caused by
)
outage and non-outage years) are less than 30% of the FES assumption since the plant began operation. SCE&G has a long-J term commitment to maintaining occupational exposures ALARA.
This commitment is implemented through the SCE&G Corporate ALARA Plan, the VCSNS ALARA Committee and various proceduralized exposure control and reduction programs as outlined in NRC j
Regulatory Guide 8.8, "Information Relevant to Ensuring that 1
Occupational Radiation Exposure at Nuclear Power Stations will be j
As Low As Reasonably Achievable," and INPO ALARA Guidelines.
Extension of the operating license should not result in any increase above the annual occupational dose normally experienced during operation of the plant. Actual doses experienced since VCSNS began operation (Table 5) shows an increasing trend which is projected to level off at an average of approximately 400 person-rem / year during future years of operation. SCE&G expects these projections to be conservative since methods to reduce occupational doses will continue to be pursued.
Future industry developments such as system decontamination processes, improved chemistry controls, and robotics should significantly contribute to lowering annual occupational doses.
Future exposuru could be affected Fy a major modification such as steam generator replacement.
Ccrrent industry experience i
shows that such a modification sould result in 500 to 1,000 person-rem of radiation exposure.
The impact of such an occupational dose would be minimal when averaged over the operating lifetime of the plant.
Should VCSNS 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 in the industry.
In addition, the impact of such a major modification would be further reduced by I
efforts to minimize occupational dose as discussed in the previous paragraph.
1 1
Extension of the operating license should not have any effect on I
occupational doses incurred as a result of decommissioning the i
VCSNS. Decommissioning is a one time dose commitment and will be
{
incurred with or without the extended license.
Any increase in corrosion product buildup during the short additional period of 1
operation should be compensated for by improved chemistry controls and other ALARA measures.
The inventory of activation products and the resultant radioactivity in the reactor vessel I
I and internals will not increase significantly in the period of i
extended operation (per NUREG/CR-0310 Volume 1, Chapter 7).
Thus, the extended period of operation should have no measurable effect on decommissioning dose consequences.
9 I
l Page 15 of 36
i e*
Table 5 V. C. Summer Nuclear Station Occupational Radiation Dose History Three Year Year Person-Rem Averages 1983 110.86 1984 295.421 l
1985 378.846 261.7 1986 22.937 232.4 1987 561.620 321.1 1988 511.007 365.2 Average 313.4 1
I Occupational Radiation Dose Projections Three Year Year Person-Rem Averages 1989 60 377.5 1990 through 2022 400 l
i Page 16 of 36
a a
E.
Low Level Radioactive Waste Shipments The actual experience data for radwaste ;nipments for VCSNS since start up is given in Table'6. This table also provides the estimates contained in Operating License Environmental Report (0LER) Table 3.5-9 as well as the NRC Staff's estimates included in Section 3.2.5 of the FES.
Table 6 provides the actual industry average experience for PWR's for the years 1985 through
-1988..
For years 1983.through 1988, VCSNS. shipped an average of 278 m3/ year of low level radioactive waste (LtW) with.an average specific activity'of 0.66 Curies /m3 While the actual volume of waste shipped was slightly higher than predicted by the OLER (242.5 m3/ year), it was significantly less than the FES estimate (688m3/ year). Additionally, the annual average volume shipped has remained significantly less than predicted by the OLER and the FES (27% and'21%, respectively).
1 For years 1985 through 1988, VCSNS has been slightly higher than the industry average (278.6 m3/ year _versus 223.9 m3/ year).
However, recent installation of state-of-the-art demineralization system and e ihanced volume reduction efforts for dry waste (supercompatiton) is evidence of SCE&G's commitment to reducing the volume of annual shipments to as-low as: reasonably achievable. Based on this information, the volume of waste shipped in the years of the requested extension should remain significantly lower than the FES predictions and represent a small percentage of the total volume generated over the life of-the plant.
- i Page 17 of 36
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F.
Impact on Man The FES s 4.5.3 states that there will be no measurable radiological impact on man from routine operation of the VCSNS.
This conclusion is based upon operation of the station within Technical Specifications which are derived from the design objective doses of 10 CFR 50, Appendix I.
The previous discussion demonstrates that the VCSNS operates well within Technical Specification limits by consistently maintaining radioactive effluent releases well below 10 CFR 50, Appendix I and RM-50-2 dose design objectives and near or below those values projected in the FES. Therefore, the above conclusion, "no measurable radiological impact on man from routine operation of the VCSNS," should remain valid for extended operation of the VCSNS.
G.
Impact on Biota As the FES states in 4.5.4, "Although guidelines have not been established for acceptable limits for radiation exposure to species other than man, it is generally agreed that the limits established for humans are also conservative for other species."
Since no measurable radiological effects on man are expected from extended operation of the VCSNS, extended operation should not cause any measurable radiological effects on biota.
H.
Risk to Workers. Individuals and Populations As discussed previously, extended operation of the VCSNS does not invalidate conclusions made in the FES as related to dose commitment.
Since dose commitment is the vehicle for assessing radiological risk to workers, individuals and populations, extended operation of the VCSNS should not invalidate the conclusions made in the FES concerning radiological risks to workers, individuals and populations.
I.
Potential Accidents As a means of assuring that certain features of VCSNS meet acceptable design and performance criteria, SCE&G and USNRC Staff analyzed the potential consequences of a number of postulated accidents.
In the safety analysis and evaluation of VCSNS, three categories of accidents were considered. These categories were based upon their probability of occurrence and include (a) incidents of moderate frequency, i.e., events that can reasonably be expected to occur during any year of operation, (b) i infrequent accidents, i.e., events that might occur once during the lifetime of the plant, and (c) limiting faults, i.e.,
accidents not expected to occur but that have the potential for significant releases of radioactivity.
Initiating events postulated in the second and third categories for VCSNS were shown in Table 6.1 of the FES. Also shown in this table were the Page 19 of 36
.?
e' approximate radiation doses that might be received by a person 1
.j mile from the plant.
The original FES' Table 6.1 has been reproduced in Table 7.
Table 7 includes the USNRC Staff estimates (conservative case) presented in 6.1.4.1 of the FES which represent potential upper-bounds for individual exposures from the same initiating accidents for the purpose of. implementing the provisions of 10CFR Part 100, " Reactor Site Criteria." Table 7 also includes results of analyses performed in support of the revision to the VCSNS Technical Specifications which requested refueling and' operating with VANTAGE 5 fuel. These results, which represent VCSNS's current licensing basis, demonstrate'that FSAR off-site doses for realistic and conservative cases remain within the original Staff estimates contained in the FES, 6.1.4.1.
In addition, the USNRC has accepted the Radiological Impact Assessment contained within the VANTAGE 5 Reload Technical Specification change request dated May 20, 1988, by issuance of Amendment No. 75 to Facility Operating License No. NPF-12 dated October 28, 1988.
In summary, the environmental consequences from potential accidents with the use of higher fuel burnup, longer operating cycles, and the proposed increase in duration of the Operating License remain bounded by the original FES Staff estimates and well within 10CFR Part 100 limits.
Page 20 of 36
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5.
Other Impacts A.
Social Impacts of Operatina Labor Force The FES, in 4.6.2, projected that during the operation period of VCSNS, 213 people will be employed at the site (one third in maintenance, one fourth administrative employees, one fifth technical ard one fifth in actual operations). The actual permanent workforce at VCSNS as of June 1989 numbered some 660 e:nployees. The larger than expected workforce is attributable in part to the relocation of management, licensing, engineering and other personnel from corporate headquarters to the site in recent years. As predicted in the FES, however, operation of the VCSNS has not brought sufficient population growth to strain existing public service delivery systems (including telephone service, electricity, sewer facilities) or existing public education resources or residential housing. Nor will the license extension change this situation; as discussed Section 4 of this submittal, curreni. population projections predict a decline in population -
growth in the area of the site.
B.
Economic Impacts The FES, in 4.6.3, concluded that the VCSNS would have little influence on the nature of the regional economic base or the rates of unemployment.
It further predicts that regional income would increase slightly because the wages paid to VCSNS employees are substantially higher than the Central Midlands average.
Current available data support the FES conclusions regarding economic impacts of operation of the VCSNS facility. As can be seen from these data, economic activity in the surrounding areas has improved significantly since the plant began operation.
The extension of the operating license should not affect these conclusions.
Fairfield County's unemployment rate decreased from 9.9% in 1982 to 8.9% in 1986 and continued to decline to 8.0% in 1087.
This was above the 1987 statewide unemployment rate of 5.6%.
Nonagricultural wage and salary employment in the county rose from 6.280 persons in 1982 to 6,460 in 1987.
Manufacturing experienced the largest increase, rising 16% from 1982 to 1987. At the same time, the number of construction, finance, insurance and real estate jobs in the county decreased, while government, transportation and public utilities, services and mining jobs increased. Of total county employment manufacturing accounted for 35.6%, 20.3% government, services and mining 13%, and transportation and public utilities 12.8%
and wholesale and retail trade 11.7%.
Page 22 of 36
4 4
Between 1980 and 1987, average per capita income in Fairfield County increased by 55.7% from $5,749 to $10,809. Retail activity increased 58.4% over the same period.
Retail activity increased less in Fairfield County than any other Central Midlands county.
In Newberry County between 1982 and 1987, the unemployment rate decreased from 10.9% to 6.1%.
Total nonagricultural employment increased from 10,530 in 1982 to 11,580 in 1987.
Every economic section experienced gains in 1987 as compared to 1982.
In both years, manufacturing accounted for over 40%
of all jobs in the county. Wholesale and retail trade provided 17.8% of total in 1987, government contributed 16.5%
and services accounted an additional 10.7% of all jobs.
Per capita income rose 49.3% between 1980 to 1987, from $7,984 to
$11,920. Between 1980 and 1987, retail activity increased 145%.
In Richland County between 1982 and 1987, Richland County's unemployment rate went from 6.8% to 4.3%, just below the state average at 5.6%.
From 1980 to 1988, per capita income in Lexington County rose by 75%, from $8,258 to $14,455. This growth rate is substantially higher than the state average. Betweer.1980 and 1987, sales went from $643,899,038 to $1,744,620,583, an increase of 170.9%.
In summary, the change in unemployment rate from 1982 to 1987 by county looks as follows:
Central Midlands Region Unemployment Rate (by County and State) 1982 1986 1987 Fairfield 9.9 8.9 8.0 Lexington 7.7 3.1 3.2 Newberry 10.9 6.5 6.1 Richland 6.8 4.0 4.3 South Carolina 10.8 6.2 5.6 l
l l
i l
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Page 23 of 36 l
1 1
As noted in FES 6 4.6.3, substantial economic benefits will accrue to the federal goernment and South Carolina as a result of taxes on revenues generated by the plant, and to fairfield County as a result of property taxes paid on the VCSNS. For 1988. SCE&G paid $7,983,400 in property taxes on the VCSNS to Fairfield County. This continues to be a major portion of the County's tax revenues.
Tax payments to the county for VCSNS and the Fairfield Pumped Storage facility for 1988 were as follows:
Fairfield County 1988 Property Tax Exoense Total County City V. C. Summer Station 7,983,400 7.98),400 Fairfield Pumped Storage facility 3,032,000 3,032,000 All Other 470.800 466.500 4.300 Total Fairfield County Property Tax for 1988 11.486.200 _1_1 481.900 4.300 Property taxes for VCSNS are expected to increase in excess of
$2 million, due primarily to the expiration of the manufacturers' S-year exemption.
Lengthening the amortization period as a result of the proposed license extension will have a small impact on the property tax liability to Fairfield County.
It will likely increase that liability in early years.
It is clear that operation of the VCSNS has been and will continue to be an important part of the regional tax base.
C.
Recreational Impacts As discussed in the FES, 4.6.4 recreational opportunities have been provided in conjunction with the VCSNS project by the creation of a 300-acre subimpoundment on the northern end of Monticello Reservoir. This area has been managed by SCE&G as a fishing lake for public access.
However, as the FES predicted, because South Carolina has a large supply of lakes and rivers for water-based recreation, the SCE&G facilities i
have not drawn substantial visitors from outside the immediate area, nor is this expected to change as a result of the license extension.
6.
Imoact on Uranium fuel Cycle VCSNS was originally fueled with a core loading containing maximum enrichment of 3.10 weight percent U-235 which provided the desired twelve month core lifetime and a region average discharge burnup of 33,000 MWD /MTU.
Page 24 of 36
C t
Since initial operation, longer cycle lengths (18 months) and higher fuel enrichments have been implemented.
VCSNS.is currently licensed (Amendaent No. 74 dated November 3, 1988) for fuel enriched to 4.25 weight percent U-235. Region average discharge burnups through the end of the current operating cycle will not exceed 38,000 MWD /MTU.
4 The Nuclear Regulatory Commission Staff has reviewed the environmental impacts of extended irradiation up to 60,000 MWD /MTU and increased enrichment up to 5.0 weight - percent 'U-235 and has.
documented these reviews in the Federal Register (53 FR 6040 dated February 29, 1988 and 53 FR 30355 dated August 11,1988). The staff has concluded that the results of Tables S-3 of-10 CFR 51.51~
and Table S-4 of 10 CFR 51.52 are conservative and bound the corresponding impacts for increased burnup levels and enrichments.
Applicability of the S-3 and S-4 tables to enrichments up to 5.0 weight percent of U-235 and irradiation up to 60,000 MWD /MTU conservatively bounds the anticipated future range of operation for VCSNS.
Under the current license (License Amendment No. 27), the plant.has adequate spent fuel storage with full core discharge capability well into the next century (c.2008). See SCF&G letter to NRC, dated January 23, 1984, transmitting Licensing Report on High Density Spent FuC Storage Racks.
SCE&G currently has an agreement with the U. S. Department of Energy for high-level waste storage.
If DOE is unable to take delivery by the time shipment off site is necessary, SCE&G will have sufficient storage capacity in an NRC licensed facility on site or by an alternative means (e.g.,
monitored retrievable storage). The VCSNS spent fuel pool has capability for rod consolidation, which would provide sufficient storage capacity through 2022 (NRC approval of a license amendment would be necessary).
Therefore, the assessment of Section 4.7, "The Uranium Fuel Cycle,"
of the FES is expected to remain valid through the proposed increased duration of the operating license.
In summary, the use of higher fuel burnup, longer operating cycles and the proposed increases in duration of the Operating License do not alter the conclusions of Table S-3 and Table S-4 or the FES.
7.
Air Quality Impacts Air quality impacts from VCSNS are minimal..See FES E 4.8.
As stated in the FES, the only significant waste gas sources are the Auxiliary Boiler and the emergency Diesel Generators. These sources are controlled through Air Quality operating permits i
administered by SC0 HEC. These impacts will not be affected by the license extension.
Page 25 of 36 l
L-__ ___ _ _ - -
8.
Decommissioning SCE&G_has considered the impact of the preposed extension on decommissioning of.the unit and does not believe there will be a significant impact.
With respect to the financial assurance aspects of decommissioning, SCE&G is currently collecting monies for decommissioning and has established an external decommissioning fund which is designed to accumulate funds until the year 2013 sufficient to pay the total costs to decommission both radioactive and nonradioactive portions of the facility (though a particular-method of decommissioning has not yet been selected). Thus by the time of termination of operations, SCE&G expects to have accumulated sufficient funds to-complete the decommissioning process. Financial assurance arrangements will remain in effect in accordance with the NRC decommissioning rule (53 FR 24018) regardless of the openating license term.
SCE&G anticipates that the extended period of operation will have a negligible cffect on decommissioning activities, including decontamination, dismantling and removal of structures and systems, and therefore will not appreciably affect the cost of decommissioning. A reactor's fission product inventory builds up rapidly, so that af ter,10 years of operation the inventory approximates 90% of the total expected after 40 years of operation.
As a result, most of the cost for decontamination and decommission, as well as occupational exposure, arises early in a reactor's operating life. The extended period of operation thus will not add significantly to the cost and effort to decommission the plant.
It should also be noted that the environmental effects of decommissioning power reactors have been assessed generically by the NRC. See NUREG-0586, " Final Generic Environmental Impact Statement on Decommissioning of Nuclear Facilities (GEIS)," issued August 1988. The GEIS, among other things, assessed the expected radiation doses for decommissioning the reference PWR. See NUREG-0586, Table 4.3-2.
In its final decommissioning rule (53 FR 24039), the NRC described the conclusions as follows:
"The GEIS shows that the difference in impacts among the basic alternatives for decommissioning is small, and the dose' impact of decommissicaing is small, whatever alternative is chosen, in
~
comparison with the impact accepted from 40 years of licensed j
operation. The relative impacts are expected to be similar from-(
plant to plant, so that a site-specific EIS would result in the same conclusions as the GEIS with regard to methods of decommissioning."
SCE&G intends periodically to update the cost estimates for decommissioning, with the next update expected in 1990.
In accordance with the NRC's decommissioning rule, 10CFR50.33(k),
SCE&G will submit to the NRC by July 26, 1990, an initial j
decommissioning report and will submit its proposed decommissioning.
1 l
plan for review at or about five years before'the expected termination of operations (see 10CFR50.75). These measures provide j
Page 26 of 36
additional assurance that the funding and methods for decommissioning the plant will be adequate.
9.
Short-term Uses versus Lono-term Productivity The National Environmental Policy Act (t*PA) required the NRC to consider the long-term consequences to >1ogical production of building and operating the VCSNS and d alternative short-term uses of man's environment.
In this context, according to the FES, f 8.3, short-term is the period of construction and operation, and long-term is the period beyond the service life of the facility.
The FES concluded that there would not be any serious impacts on short-term productivity or long-term productivity of the forested-area, and the staff was assuming an operable life of 40 years-(see-FES E 4.2).
Thus, the effects of operating the Summer station-until 2022 in terms of short-term and long-term production have been considered by the FES.
10.
Irreversible and Irretrievable Commitment of Resources The FES concluded in section 8.4 that no irreversible impacts would occur in terms of terrestrial, and aquatic resources for the life of the station, assumed to be 40 years (FES Section 4.2). The FES also concluded that quantities of materials that could not be decontaminated for unlimited recycling after this operating life of the plant represent a very small fraction of the resources available in kind and in broad use in industry. See FES-ff 8.4.3, 8.4.4.
In f 8.4.5, the FES concluded that sufficient uranium resources exist in the United States to fuel all operating and planned reactors, The FES further concluded in 8.4.6 that the-use in the operation of the VCSNS facility of other consumed resource materials (such as fuel-cladding materials, chemicals, maintenance materials) would be reasonable with respect to needs of-other industries.
Finally, the FES concluded in sections 8.4.6 and 8.4.7 that operation of the VCSNS will have little effect on air resources beyond the minimal impact caused by emissions, and that despite the extended use of the land for power production, at some future time, the land could be restored for other useful purposes.
Because the FES had assumed an operating life of 40 years, the effects of a 40-year operating period in terms of commitments of i
resources have already been evaluated and found acceptable. SCE&G i
is not aware of any information from plant operation that would invalidate that conclusion.
- 11. Historic Preservation The FES, in @ 4.6.5, discussed the documented historic and i
archaeological sites within 15 Km (9.3 miles) of the VCSNS and of the historic sites within 2 Km (1.2 miles) of the associated j
transmission lines.
As of August of 1978, six of the identified j
Page 27 of 36
1 historic and archaeological sites within 15 Km of the VCSNS and one
]
within 2 Km of the transmission line were listed in the National i
Register of Historic Places.
The FES further concluded that the i
VCSNS would not adversely affect their historic character or the j
public's use of the historic facilities. Extension of the operating license will not affect that conclusion. Moreover, no new historic or archaeological sites have been identified since the FES was issued, and SCE&G does not expect that situation to change.
)
- 12. Plant Modifications The plant modification process at the VCSNS ensures that changes to the facility and procedures are reviewed for any environmental impacts. Engineering Services Procedure (ES) 416 governs the process by which changes are made to the facility under 10CFR50.59.
That procedure calls for an evaluation of whether the change will
" increase radiation doses (include installation and environmental doses)" or alter " chemical or thermal releases to the environment."
ES-416 also provides for review by, among others, the Manager, Corporate Health Physics and Environmental Programs as well as the Manager, Chemistry & Health Physics. This ensures that environmental impacts of facility changes are evaluated. Should this review conclude that there are significant environmental considerations, the necessary environmental approvals and permits will be sought from the SC0 HEC before the modification is carried out (see examples below).
In annual updates, the NRC is apprised of changes made to the facility under Section 50.59.
In accordance with the Section 50.59 process, NRC approval will be sought if a proposed facility change presents an "unreviewed safety question" or necessitates a change to the Technical Specifications.
This process ensures that the environmental effects of facility changes or other licensing actions for which NRC review is required are fully evaluated.
See 10CFR51.21 et seg.
SCE&G has reviewed past modifications made under Section 50.59.
t The following modifications may be of interest from an environmental standpoint:
In 1984, a modification was made to change the water supply to
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the non-safety-related circulating water pump motor bearing coolers from raw water to filtered water.
This change was made to prevent water flow blockage by asiatic clams. See j
SCE&G Second Annual 10CFR50.59 Report, dated April 18, 1985, at 4.
A modification was completed in 1986 to add a 5000 gallon l
3 collection tank for collection ar'd holding of water from the I
RWST sump. This water is sampled and, if acceptable, discharged to the yard drainage system. This was a change to the non-safety, non-nuclear drain system. The review of this modification concluded that there would be no additional radiological releases or exposures from the sampling. See i
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~3 SCE&G fourth Annual 10CFR50.59 Report, dated May 7, 1987, at 3; MRF-20179..
A modification was completed in 1987 to add two buildings inside the protected area: the Auxiliary Service Building and Radiological Maintenance Building.
These buildings were needed for computer office space and maintenance activities respectively. See SCE&G Fifth Annual 10CFR50.59 Report, dated May 27, 1988, at 3.
To enhance environmental protection, a modification was-f completed in 1988 to provide a monitoring system for underground storage tanks that detects water accumulation inside the tanks, as well as leakage. The system monitors the two diesel fuel oil tanks and the turbine lube oil tank. See SCE&G Sixth Annual 10CFR50.59 Report, dated May 10, 1989, at 4.
Future modifications that SCE&G is currently evaluating and which may, if implemented, have environmental impacts include.the following:
The installation of a Betz CT-1 biocide injection system to treat the Service Water intake system in order to prevent asiatic clam growth. An NPOES permit change is required and SC0 HEC approval will be obtained before implementation.
NRC approval has also been sought. See MRF 20629.
The removal of the RTD manifold system, with installation of wall-mounted RTO's. This change is designed to reduce significantly the occupational dose rates for maintenance activities. See MRF 21315.
The possible installation of an oil incinerator to burn waste-oil. SCE&G is currently evaluating the feasibility of an oil incinerator for on-site waste oil as part of an effort to handle VCSNS waste at the site. Approval by the NRC (pursuant to 10 CFR 20.305) and SC0 HEC will be necessary before implementation.
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SCE&G is also in the preliminary stages of considering options J
for maintaining the steam generators or replacement should j
that be found necessary.
Environmental considerations of this action are discussed in s 4.D above.
In summary, the existing controls at VCSNS ensure that plant modifications are reviewed for their environmental impacts and any necessary regulatory approvals are obtained before the modifications are made. SCE&G does not believe that any plant modifications since the time of licensing, nor any currently planned, invalidate conclusions in the FES. Nor has SCE&G identified any significant plant modifications that will be necessary as a result of the proposed extension of the license term.
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II. TECHNICAL ITEMS As requested in Enclosure 2 to the NRC April 20, 1989, letter, SCE&G has considered the impact of the proposed extension on the reactor vessel, mechanical equipment and plant structures. SCE&G has also considered the impact on electrical equipment.
As with other Westinghouse PWR's, the VCSNS was designed for a 40-year operating life. The reactor vessel, which is generally regarded as the limiting item for purposes of plant operating life, was designed and fabricated for a full 40-year operating term.
Programs are in place to monitor radiation-induced changes to vessel materials and vulnerability to pressurized thermal shock.
Safety-related electrical equipment was also designed for 40 years of operation or are replaced on conservative schedules under the VCSNS 10 CFR 50.49 equipment qualification program.
Other equipment and structures are known to be less susceptible to degradation with age, but nevertheless were designed for 40 years of operation and are subject to comprehensive surveillance and maintenance programs to assess aging (including ISI and IST programs) and ensure that repairs and replacements are made when necessary.
SCE&G thus concludes that plant systems, structures and components are fully adequate to support an extension of the operating license to 40 years.
1.
Reactor Pressure Vessel The VCSNS reactor pressure vessel has been designed and fabricated to meet the requirements of 10 CFR 50.55a and Section III of the ASME Code (1971 edition).
In addition, the vessel meets the requirements of 10 CFR Part 50, Appendices G and H.
See NRC SER dated February 1981 (NUREG-0717), and Supplement 1 thereto dated April 1981.
This provides assurance that the vessel will retain its structural integrity throughout its design life with adequate margin.
With respect to design life, t' Summer vessel was procured to have a design life of 40 years full o.cr operation with specified design cycles or transients.
See Westinghouse Equipment Specification 676413, Rev. 3, } 3.1.7.
A cycle monitoring program is in place to determine when design limits are approached.
In addition, the VCSNS surveillance program prescribed in Technical Specification Q 4.4.9.1.2 monitors the radiation-induced changes in the properties of the vessel materials.
Surveillance tests on capsules conducted to date, as required by 10 CFR Part 50, Appendix H have shown that Appendix G criteria will be met with adequate margin for the life of the plant. See, for example, SCE&G 1etter to NRC dated September 16, 1988, enclosing WCAP 11726 (Reference 6 hereto).
This program provides additional assurance that the effects of power operation are monitored throughout facility life, including the proposed extension period.
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As required by 10 CFR 50.61, the VCSNS vessel has been evaluated for vulnerability to pressurized thermal shock. See SCE&G letter to NRC dated January 23, 1986, enclosing WCAP-10998, Rev. 1 (Reference 7 hereto).
As shown in Table 4-2 of WCAP-10998, Rev. 1, the PTS analysis shows that at the end of a 40-year life, the value of RT/NDT i
at the vessel beltline will approximate 162 degrees F.
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1 V. C. SUMMER REACTOR VESSEL BELTLINE RTPTS AND FLUENCE VALUE RTPTS (decrees F)
Expiration Expiration Current -
of Present of Proposed End of Cycle 2 Operating License Operating License (Oct. 5,1985)
(March 21,2013)
(Oct. 22, 2022)
Beactor Vessel Beltline Material intermediate Shell Plate A9154-1 118 155 162 Intermediate 5 hell Plate A9153-2 62 94 99
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Lower Shell Plate C9923-1 86 113 118 l
Lower Shell Plate C9923-2 86 113 118 Intermediate Shell Longitudinal Welds 23 42 46 Intermediate to Lower Shell Circumferential Weld 31 56 60 Lower Shell Longitudinal Welds 23 42 46 This value is about 110 degrees F lower than the screening criterion of 5 50.61. The analysis clearly demonstrates that PTS will not be a limiting factor in the design life of the VCSNS vessel.
As noted above, the reactor vessel was qualified to the ASME Code,Section III, 1971 Edition. The detailed design and analysis was performed by Chicago Bridge and Iron Company and was approved by Westinghouse. The reactor vessel analysis was performed in three parts: thermal evaluation, stress calculations and fatigue evaluation. A thermal transient evaluation was performed to calculate the thermal gradients through various critical sections of the vessel due to each transient evaluated.
Stresses were then calculated using results from the thermal evaluation in addition to pressure loads, mechanical loads, seismic and LOCA loads.
The resulting stresses were compared and qualified to the code allowables. The 40-year design life was verified in the fatigue evaluation.
The fatigue evaluation combines data from the thermal transients and stress intensities to calculate a total fatigue usage factor. All areas analyzed were qualified to the code allowable.
Based on tt:e above, SCE&G concludes that the VCSNS reactor pressure vessel is fully qualified for 40 years of full power operation.
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2.
Electrical Eauipment The VCSNS has in place a program for the environmental qualification of safety-related electrical equipment (EQ program) in compliance with 10 CFR 50.49 and NUREG-0588.
See SSER No. 4, dated August 1982 at 3-3 to 3-11. This program was audited by the NRC at the time of licensing and found acceptable. SSER 4 at 3-5.
More recently, the NRC has audited the VCSNS EQ Program and found it to be implemented in accordance with Section 50.49 and applicable NRC guidance, though some deficiencies have been identified and are being corrected. See NRC Inspection Report No. 50-395/88-01, dated May 2, 1988. SCE&G is in-the process of implementing an Equipment Qualification Enhancement Program.
(See SCE&G Response to Inspection Report 88-01, dated May 25,1988.)
The EQ program assigns a " qualified life" to each item of electrical equipment within its scope. This qualified-life is established using available test data and engineering analysis.
In many cases, this qualified life is at least forty years.
Equipment that is required to operate post accident was designed for a qualified life sufficient to ensure continued operability in the event an accident occurred on the last day of its design qualified life. Where the qualified life is less than forty years, the EQ program and Technical Specification surveillance requirements (see, e.g., Technical Specification 3/4.8.2 on electrical power systems including batteries) ensure equipment replacement or maintenance prior to expiration of the qualified life.
Class IE electrical systems at the VCSNS were designed for a full 40-year operating life. The EQ program fully supports extension of the operating license to a 40-year term.
3.
Mechanical Eauipment At the time of licensing the NRC concluded that the design of safety-related components, component supports, reactor internals, and non-Code items conformed to 3.9.1 of the Standard Review Plan and satisfied General Design Criteria 14 and 15 for conditions and events expected over the lifetime of the plant. See SER 3.9.1 and SRP @
3.9.1.
As support for the proposed license amendment, SCE&G-has considered the effect of the OL extension on mechanical equipment and concludes that there will be no significant impact.
Mechanical equipment for VCSNS was either specified to'have a design life of 40 years of operation or is subject to surveillance, testing and maintenance requirements to detect degradation and ensure corrective action.
For example, NSSS mechanical equipment was I
designed and procured for 40-year design life.
See, e.g.,
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Westinghouse Design Specification 952373, Rev. 4, 4.1.1.14 (40-year i
design life for pressurizer).
The Project Design Criteria for balance-of-plant equipment also specified a design life of 40 years.
(Project Design Criteria at page 1-7.
OSP-589 [40-year design life for a number of safety-related valvesJ.) Thus the original design and Page 33 of 36
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4 operational considerations for mechanical equipment encompassed the proposed extension of operation.
It is understood that some items of equipment and subcomponents are not expected to last 40 years. Surveillance, maintenance and testing requirements for mechanical equipment are in place to verify operability of the equipment or detect degradation and ensure that equipment that does degrade is replaced or other corrective action taken.
In addition, subcomponents such as nonmetallic (gaskets, 0-rings) are inspected and replaced, as necessary, as part of routine maintenance in order to ensure the design life of the equipment.
Surveillance, inspection and testing requirements include the following:
ASME Code Section XI.
Equipment that is ASME Code Class 1, 2 or 3 is subject to the Inservice Testing and Inservice Inspection requirements of ASME Code Section XI and 10 CFR s 50.55a. This includes hydrostatic and leakage testing of the reactor coolant pressure boundary, weld inspections, inservice performance testing of pumps and valves and inservice testing of supports.
These requirements apply throughout the operating life of a facility and ensure that mechanical equipment will be properly maintained regardless of the operating license period.
Technical Specifications.
Equipment covered by Technical Specifications is subject to the surveillance 6nd testing requirements of the applicable Technical Specification, with specified testing and surveillance intervals. These surveillance requirements include calibration and inspection of systems and components to ensure that operation of the plant will remain in accordance with Limiting Conditions for Operation, as well as requirements for maintaining the structural integrity of reactor coolant system components (see Technical Specification 3/4.4.10).
Examples include valve leakage testing (see Technical Specifications 4.4.6.2.2 and 3/4.4.6), pressure testing of the Reactor Building air lock (see Technical Specification 4.6.1.2),
and stroke time testing of Main Steam Line Isolation Valves (see Technical Specification 4.7.1.5).
10CFR50. Appendix J.
Equipment and components associated with containment penetrations, including containment isolation valves, are subject to leak rate testing under 10 CFR Part 50, Appendix J.
This includes local leak rate testing (Type B and C) of penetrations as well as Integrated Leak Rate Tests (Type A)-to verify overall containment integrity.
See, e.g., Technical Specifications 4.6.1.1.c and 4.6.1.2.
Performance Testina. Although there are no NRC equipment qualification requirements per se for mechanical equipment, such equipment is subject to performance testing by SCE&G.
In addition to these programs, SCE&G has initiated and will continue to initiate programs to address any identified concerns with items of mechanical equipment.
For example, SCE&G was proactive in Page 34 of 36
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4 establishing a program to address erosion / corrosion concerns in carbon-steel piping.
(See General Test Procedure (GTP) 308). This program is a long-term erosion / corrosion monitoring program,4 maintain the structural integrity of piping systems and win oe incorporated into an engineering procedure. Similarly, SCE&G has developed a program to address boric acid corrosion concerns identified in NRC Generic Letter 88-05. See SCE&G response to NRC dated June 3, 1988.
The above-described activities assist in providing reasonable-assurance that mechanical equipment will be properly maintained throughout the operating life of the plant regardless of the license term.
4.
Structures All Seismic Category I structures for the VCSNS, including the containment, the concrete and structural steel internal structures, and foundations, were reviewed and found acceptable by the NRC at the time of licensing. See SER 3.8.
The structures.were designed to resist various combinations of dead loads, live loads, environmental loads including those due to external phenomena such_as wind, tornadoes, and earthquakes, as_well as loads generated by design basis accidents including pressure, temperature and pipe rupture effects.
The prestressed concrete containment was designed in accordance with ASME Code Section III and American Concrete Institute Standards ACI 318 and ACI 349. The NRC found the design, materials, construction methods and quality assurance utilized for the containment to be-acceptable for satisfying relevant requiren nts of GDC 2, 4, 16 and
- 50. See SER 3.8.1.
The containment was subjected to a preoperational acceptance test in accordance with Regulatory Guide 1.18 utilizin of 1.15 times the containment design pressure.g an internal pressure In addition, a preoperational Integrated Leak Rate Test (ILRT) was performed in
'2 accordance with 10 CFR Part 50, Appendix J.
The reinforced concrete containment is generally known not to be susceptible to significant degradation with time.
Nevertheless, measures are in place to ensure that any deterioration is detected and repaired. Throughout the service life of the unit the containment
)
structure is subject to the inspection and testing program of Appendix J.
The Appendix J program requires three Type A ILRTs during every ten-year cycle.
This program includes visual examination of both interior and exterior surfaces of the containment for any indications l
of degradation affecting structural integrity.
The Appendix J 1eak rate testing program is well documented and provides reasonable assurance that containment structural integrity remains adequate throughout the service life of the facility, including the proposed extension period.
It should be noted that a Technical Specification amendment request has been filed by SCE&G to revise the tendon force limits for Page 35 of 36 4
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containment tendons. See 51 FR 4028 (November 5, 1986). This request was based on calculations snowing that present Technical Specification limits for minimum average tendon forces are very conservative. That request is currently pending.
Similarly, the plant's concrete and structural steel internal structures, including walls, compartments and floors, its other Seismic Category I structures (slabs, walls, beams and columns), and its foundations were found adequate to meet GDC 2 and 4.
See SER S
3.8.2, 3.8.3 and 3.8.4.
Again, these structures were designed to resist various combinations of loadings. These structures are generally known not to be susceptible to significant age-related degradation.
Nevertheless, surveillance and maintenance requirements set forth in Technical Specifications provide assurance of structural integrity and ensure that any degradation will be detected and repaired.
At the time of licensing the service water intake structure and pumphouse were identified as being potentially subject to degradation due to their settlement relative to the west embankment of the service water pond. A condition to the operating license (Liv nse Condition 2.c(5)) requires a program to monitor the condition of the intake structure and embankment.
In addition, SCE&G is committed to a program to monitor the pumphouse and intake structure for settlement twice a year (unless a lesser frequency is acceptable) for the life of the plant.
See FSAR 2.5.4.10.6.2.
Thus far the monitoring reports under License Condition 2.c(5) indicate that the intake structure, pumphouse and embankment remain within design limits. The monitoring programs ensure that the settlement, cracks and other changes in the intake structure, pumphouse and embankment are detected and corrected as necessary.
These programs will remain in effect during the service life of the plant (unless changed after NRC review and approval) and will ensure the structural integrity of the intake structure, pumphouse and embankment during the full term of the license, including the proposed extension.
j On the basis of the above considerations, SCE&G concludes that the plant structures will not be adversely affected by the proposed extension of the operating license.
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