ML20248D598
| ML20248D598 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 08/02/1989 |
| From: | Conner T CONNER & WETTERHAHN, PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | NRC COMMISSION (OCM) |
| Shared Package | |
| ML20248D483 | List: |
| References | |
| OL-2, NUDOCS 8908110086 | |
| Download: ML20248D598 (38) | |
Text
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l' 89 E -2 P 3 :03 j UNITED STATES OF AMERICA f
NUCLEAR REGULATORY COMMISSION or e 1..
.'i '
pg Before the Commission P4 In the Matter of
)
)
Docket No. 50-353-OL-2 Philadelphia Electric Company
)
)
(Limerick Generating Station
)
(Severe Accident Unit 2)
)
Mitigation Design
)
Alternatives) l RESPONSE BY LICENSEE PHILADELPHIA ELECTRIC COMPANY TO COMMISSION'S REQUEST FOR COMMENTS BY MEMORANDUM AND ORDER DATED JULY 26, 1989 In its Memorandum and Order dated July 26, 1989, the Nuclear Regulatory Commission recited the events leading up to its authorization of the NRC Staff to issue a low power l
operating license for Limerick Generating Station, Unit 2,
1 l
concluding that "the public interest does not dictate that a safe f acility which is ready to operate should stand idle SAMdAs
[ severe accident mitigation while litigation on design alternatives] proceeds if comoliance with NEPA [the National Environmental Policy Act of 1969, 42 U.S.C.
- S4321, e_t_ s ea. ] can otherwise be achieved."1/
In part, the public interest to which the Commission referred included the cost l
1_/
Philadelphia Electric Company (Limerick Generating Station, Units 1 and 2),
" Memorandum and Order" at 5 (July 26, 1989).
89081100866hhbb52 PDR ADOCK O PDR g
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- of delaying operation of Limerick Unit 2, estimated at that time at $47.6 million for each month of delay.2/
In order to determine whether Limerick Unit 2 conld be licensed to operate before completion of.the litigation, the Commission framed the legal issue as "whether the relative environmental impact of letting the plant run without installation of SAMDAs up to the first refueling outage is significant in comparison with the impact of letting the plant remain idle for the same period of time while the b
Licensing Board considers the SAMDA issue."-
The Commission has identified three areas of potential environmental impacts which might result from permitting full power operation before completion of the litigation on SAMDAs:
1.
The incremental increase in occupa-tional exposure resulting from the installation of SAMDAs after one fuel cycle is completed; 2.
An arguably higher level of risk associated. with operating the plant without SAMDAs rather than with SAMDAs, for one fuel cycle; 3.
The environmental effect of gen-erating electricity by burning fossil fuel or using other replacement generat-inq sources should the facility be compelled to stand idle.4/
2/
Id. at 4-5.
3/
Id. at 5.
4/
Id. at 5-6.
'?5 m
_3_
m;
,.[
S As an'Sid to[its' determination, the Commission invited
- each party to address these three' areas.
The'NRC Staff'was also,' directed, _and the: other'; parties were
- invited, to
- m address five specific questions bearing.on these. issues.
As L
Appendix-'AL attached
- hereto, Licensee has provided the requested comments on each of the, five questions..
l Licensee believes that its comments fully cover each of the'three. areas.identifie'd by the Commission.as relevant to its consideration of potential environmental : impacts asso-ciated with full-power operation prior.to. completion.of the pending SAMDA litigation.
'Briefly summarized, the attached 1.
comments show:
1.
The incremental increase in occupational. exposure
. resulting from the installation of SAMDAs after one fuel cycle is completed is expected to be comparable to
- doses received during routine operation and. maintenance activities.
The. highest' occupational doses associated with the potential SAMDAs are substantially less; than doses experienced during major maintenance.
None of the. occupational doses for any particular SAMDA should significantly affect the cost / benefit balance if installation of SAMDAs is postponed until the first' refueling outage.
2.
The incremental level of risk associated with operating the plant without SAMDAs rather than with SAMDAs for the first fuel cycle is practically Ci___=________________________________
r.
,;.g 4'-
i negligible.
.Because the projected 1 risk 'of a' ' severe n..
accident from operation of Limerick Unit 2 ' is. already..
small. (i.e., early f atality, risk of. 5'.7 x 10~4:during the first fuel cycle)',- any risk reduction achieved:
through installation. of a SAMDA will necessarily, be-
~
proportionally small.
Although ~no SAMDA has been ' calculated to. be anywhere n e a r.. ' cost ef fective, th'e most 'nearly, cost effective SAMDA would reduce ~ severe accident ' risk at Limerick Unit 2 for the first_ fuel cycle, expressed as mean individual exposure for population' within 50
-5
-5 miles,. from-2.1 -'
.10 rem to 1.7 x
10 rem.
x Accordingly, postponing the' addition of
- a. potential 1
SAMDA until the first refueling outage creates an
=almost indiscernible environmental impact in terms of-risk.
3.'
If. Limerick Unit 2.is compelled to stand idle for what would be the first fuel
- cycle, significant environmental (health) impacts are expected.
These include coal mine worker fatalities and injuries due to mining and processing accidents and respiratory disorders as well as deaths and injuries among the general population due to increased pulmonary disecses h
and -transportation accidents.
Increased fossil fuel effluents of about 8 to 16 million tons of carbon L
.: _= - _ _ _ _ _ _ _ _ _ _ _ _ -.
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-dioxide and 105 to 145 thousand tons of the sulfur and nitrogen oxides will aggravate " greenhouse" and " acid.
rain" conditions.
PECO and the Pennsylvania-New Jersey-Maryland (PJM) System are counting or Limerick Unit 2 to meet increasing power demands.
If Limerick Unit 2 were not available during the summer of 1990, PECO would not meet its capacity obligatica to PJM.
Increased power demand is expected to add 706 MW to PJM's load from 1989 to 1990 requiring 861 MW of new capacity.
PJM will therefore be deficient in needed capacity without Limerick Unit 2.
Accordingly, the benefits achieved by not delaying full-power operation of Limerick Unit 2 (availability of power from the
- unit,
$854.4 million in cor "avings, averting adverse health effects from alternai energy e
sources) greatly outweigh the minor, incremental impacts upon the general public and Unit 2 workers resulting from later installation of any potential SAMDA.
On the basis of the information provided herewith as well as the legal analysis previously submitted, I Licensee respectfully 5/
Licensee hereby refers the Commission to, and incorporates herein by reference, its previously filed (Footnote Continued) i
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.6-L
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. requests the Commission to issue a full-power - operating -
licenseLfor Limerick Unit 2, conditioned upon the outcome of the pending'SAMDA' litigation.
Respectfully submitted, CONNER & WETTERHAHN, P.C.
/2 C L %'R ?, ' :-
/
's Troy B. Conner, Jr.
Mark J. Wetterhahn Counsel for Licensee August 2, 1989 i
~(Footnote Continued)
Motion for Clarification (June 5,
1989);
Reply Memorandum in Support af Motion for Clarification (June 21, 1989); and Answer 5+- Licensee PECO to Motion of LEA to Reconsider / Stay /
pend / Revoke Order Authorizing Issuance of Low-Power ~) cense for Limerick Unit 2 (July 26, 1989).
APPENDIX A Response of Philadelphia Electric Company to Question 1-l 1.
Provide an evaluation of the incremental increase in occupational radiation exposure associated.
with postponing the installation of SAMDAs to the first refueling outage.
The incremental increase in occupational radiation exposure associated with postponing the installation of SAMDAs on Limerick' Unit 2 to the first refueling outage was estimated for each of the SAMDAs identified by the Licensing Board in its July 18, 1989 Memorandum to be given further consideration in the remand proceeding. /
The methodology used to estimate the radiation expo-sures is as follows:
1.
Each SAMDA was analyzed to identify the various plant locations where installation work would result in radiation exposure.
2.
Estimated dose rates for each of the above locations were based on surveys performed at Limerick Unit 1
during the first and second refueling outages and -on experience in dose rate reductions achieved with temporary shielding, decontamination efforts and other generally accepted "as low as reasonably achievable" (ALARA) practices.
3.
Installation manhours spent in each of the above areas were estimated based upon the specific activities to be carried out in the plant l
]
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As noted in Licensee's letter of June 23, 1989 at Table 1
~
l 2-3, the vacuum breaker SAMDA was determined to have no benefit.
Accordingly, its costs were not developed.
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locations where installation work would result in radiation exposure.
4.
Radiation. exposures'were calculated utilizing the installation manhours and dose rates for each location.
5.
All Commission requirements imposing individu-al exposure limits were met.
These are conservative scoping estimates and are expected to bound the actual exposures should a SAMDA be installed..The occupational doses associated with the installation of the SAMDAs examined are for the most part quite modest, i.e.,
comparable to doses received during routine operation and maintenance activities.
The highest occupational doses associated with the SAMDAs are substantially less than those experienced during major maintenance.
For example, the recirculation and Residual Heat Removal (RHR) pipe replacement project at Peach Bottom Atomic Power i
Station, Unit 3 had an associated occupational dose of 1313 person rem.
None of the doses is expected to significantly affect the cost / benefit balance associated with the installation of individual SAMDAs should their instal-lation after the first refueling outage be required.
j The occupational exposures for each SAMDA considered i
are reported in Table 1-1.
i L______--
Response of Philadelphia Electric Company to Question 3 3.
Provide an evaluation of the incremental environmental effect of generating non-nuclear replacement energy equivalent to one fuel cycle's energy production by Limerick Unit 2.
In order to evaluate the incremental environmental effects of generating non-nuclear replacement energy equivalent to one fuel cycle's energy production by Limerick Unit 2, the following methodology was used:
1.
The mix of replacement energy
- sources, including the relative contributions-to the overall mix by the various generating facilities which together would supply it, was determined from unit-by-unit generating data for utilities in the Pennsylvania-Jersey-Maryland (PJM)
System.
j The analysis conservatively assumed that marginal replacement power sources beyond the PJM System would represent the same mix, when in fact they would disproportionately represent coal-fired units.
2.
Generic analyses were performed for two alternative mixes of replacement energy sources,
{
comparing the environmental (health) risks of j
nuclear-and coal-fuel energy.
The resulting data I
were compared to determine the differential (i.e.,
incremental) effects of replacement power.
3.
Using the proportions derived for each re-placement source and the environmental (health)
)
risks developed generically, incremental unit i
risks were calculated for worker and public deaths l
and injuries attributable to each replacement fuel in the overall mix.
i 4.
The data developed in the previous steps were applied to the estimated first-cycle energy output i
from Limerick Unit 2, and hence to be replaced by alternative
- sources, based on the first-cycle experience of Limerick Unit 1.
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Question.3.
Page 2 The analysis is provided in Attachment A hereto.
Based upon this analysis, it was concluded that an additional 1.5 to 2 worker deaths and 80 to 100 worker injuries, and more than 10 projected public fatalities and 24 injuries, would result from the use of replace-ment energy for the first fuel cycle of-Limerick Unit 2.
Projected worker deaths and injuries result mainly from coal mining and processing accidents, while projected public fatalities result from respiratory diseases.
Public injuries are mainly attributable to transportation accidents.
There are insufficient data to quantify public health risks from operating oil-fired units, although it is expected that such effects should lie between those of nuclear and coal-fired generation.
- Further, it is estimated that about 8
to 16 million tons of carbon dioxide would be created by use of replacement fuel sources.
This would contribute to the atmospheric " greenhouse" problem.
Also, about 105 to 145 thousand tons of sulfur oxides and nitrogen l
oxides would be created by use of the replacement energy source.
These oxides contribute in part to acid rain.
These incremental, adverse environmental effects can be avoided by use of Limerick Unit 2 for the first 1
fuel cycle.
1
Question.3 P:ge 3
- Finally, PECO and the Pennsylvania-New Jersey-Maryland (PJM) Systtal are counting on' Limerick Unit 2 to meet increasing power demands.
If Limerick l
1 Unit 2 were not available ~during the summer of 1990, l
PECO would not meet its capacity obligation to PJM.
.i Increased power demand is expected to add 706 MW to PJM's load from 1989 to 1990 requiring 861 MW of new capacity.
PJM will therefore be deficient in needed capacity without Limerick Unit 2.
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RESPONSE TO COMMISSION QUESTION 3.
ATTACHMENT A I.
INTRODUCTION This is an evaluation of the incremental environmental effects of replacing energy equivalent to one fuel cycle's energy production by Limerick Unit 2.
II. REPLACEMENT ENERGY MIX The incremental environmental impacts of replacing energy from Limerick Unit 2 with that from other sources will vary with the relative contributions to the overall mix of replacement energy by the various generating facilities which together would' supply it.
Older, less efficient oil-and coal-fired stations which would be called into such service would have significantly greater effects than, for example, energy from hydroelectric facilities.
The particular sources from which any needed replacement energy would be obtained can be assumed, but not-known with certainty until the.need arises and available alternatives assessed.
For purposes of this analysis, two alternatives mixes of replace *-
ment energy sources were examined:
the first is represented by a mix of marginal Pennsylvania-Jersey-Maryland (PJM) System (and beyond) coal-and oil-fired capacity (referred to as the " margin-al mix") which is the best estimate of the actual plants likely to be required to make up the shortfall in capacity.
A r,econd evaluation was made based on the 1988 mix of generation sources (exclusive of purchases) used in 1988 by PJM utilitios (referred to hereafter as the "1988 mix") as representative of the risks of
.the more usual mix of energy sources, including nuclear genera-tion.
The " marginal mix" was determined from an analysis of replacement capacity within PJM and beyond, as presented in summary form in Table 3-1.
Those alternatives were simplified by combining all coal-and all oil-supplied energy, and combining non-utility gen-eration with hydroelectric in one category having the same impact.
Thus, the " marginal mix" replacement energy for Limerick Unit 2 assumed for this analysis was that presented in the following tabulation.
Limerick Unit 2 Replacement Energy,
" Marginal Mix", % Contribution Coal Q11 Hydro l
48.7 50.7 0.6 1
u_____1_________._
i
m ra JTonestablish.the 1988 mix, historic data on'the PJM system were
~
assembled and: analyzed.1 Table 3-2. presents the total megawatt-hours distributed 1bylPJM (also identified as the Mid-Atlantic.
LArea Council, MAAC) utilitles in 1988.by energy source, based on
.information supplied._byothe UDI Utility Data Base.
Of the'elec-trical. energy distributed within the PJM system in that' year, 55.6% was_ derived from fossil fuels (coal, oil and gas), 27.2%
-from nuclear, 2.0% from hydro and 15.0% imported from beyond the PJM system.
'No breakdown within the fossil fuels is available.
from this. data set.
To make that breakdown into the mix of' fuels used for generation within PJM,1and determine their airborne emissions, unit-by-unit generating data for fossil and nuclear steam-electric units-in
.MAAC utilities were compiled by UDI for 1987 (the latest data available).
These data permit the derivation of the individual fuel contributions.to MAAC energy generation as a basis for < mis-sions and risk estimates.
The fossil' fuel use data for each MAAC utility are presented ~1n Table 3-3, together with estimates of emissions of sulfur oxides, nitrogen oxides and carbon dioxide, and are summarized in the.following tabulation:
Percent Generation by Fuel in MAAC, 1987-G.23.1 ELL GA g_
Nuc1 ear 61.,3 3.9 2.1 32.7 q
10f the total fuel-generated electric energy generated'in 1987, fossil. fuels generated about twice as much as did nuclear (67% to 33%),. essentially the same ratio as that in 1988 (55.6% to 27.2%).'
On.this basis, the ratio of generation by oil and gas relative'to coal for 1988 was assumed to be the same in 1988 as in 1987.
Since the'1988 data (Table 3-2) show no gas generation, the relatively minor gas-derived energyLusage identified for 1987 was assumed to be contributed by oil in 1988.
Accordingly, the hypothesized "1988 mix" was assumed.to be distributed as follows within the'85% of the internally-generated PJM-sources:
Hypothesized Limerick Unit 2 Replacement Energy, "1988 Mix", % Contribution Coal QLL Nucleat Hydro 59.9 5.8 31.9 2.3 1
Based on these two energy source distributions, incremental risks p
were determined as the total of the risks per unit energy gener-ated by each' source weighted by its respective contribution to the' total of PJH-generated energy (i.e.,
the total less that purchased), minus the risks of Limerick Unit 2.
Mathematically, this is represented by the relationships described below.
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Incremental risk'= Incremental unit risk x units of replacement 4
(
.energyH R
. Incremental unit risk = { Replacement energy unit risk - nuclear energy unit' risk) 1 L
Replacement, energy unit risk =l{ (unit risk'[C] x fraction)...z
+ (unit risk [0] x-fraction).sz
+ (unit risk-[N] x fraction)nuaz...-
)
}
+ (unit risk'IH) x fraction)ny... )
l For the'"1988 mix":
Incremental unit risk
{0.599xc+0.058x0+.319xN+0.023xH) - 1xN
=
0.599C + 0.0580 + 0.023H - 0.681N
=
For the " marginal mix":
Incremental unit risk =
(0.487xc+0.507xOt0.006xH) - 1xN III.
UNIT RISK FACTORS Generic analyses for both the nuclear and non-nuclear alterna-tives were used-to provide a consistent basis for determining the differential or incremental effects.
Most of these analyses were published in the mid-to late-1970s and compared the environmen-
- tal and'healtY risks of nuclear-and coal-fueled energy.
For the most part, these analyses were concerned with comparing the health risk aspects of the environmental impact.
Occupational risks are by far the best known, since they are usually documented for fatalities and injuries from both acci-
. dents and occupational diseases.
Both mine accidents and miner respiratory disorders are well publicized, as are the accidents involving oil platforms and uranium miner lung cancers.
Some public injuries resulting from segments of the various fuel cy-cles are also documented, such as those involving coal train or truck accidents' injuring or killing members of the public.
How-ever, the risks to public health from the pollutants emitted by various energy facilities are much more uncertain.
The pollutants emitted from fossil plants include particulate, sulfur dioxide, nitrogen oxides, carbon monoxide, carcinogenic polycyclic organic matter (POM), and trace metals including ar-senic,Lcadmium and mercury, much more so in the case of coal plants than from those burning oil or gas.
Although no specific 3
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cecca are attributed to particular constituents, except in past
. g.
severe pollution episodes such as those in Donora, pa., and Lon-don, a number of studies have correlated increases in respiratory Land cardiac mortality rates with ambient particulate-sulfate exposures.
It is these studies that form the basis for the esti-Emates of the' disease component of.public health risk.
Oil was usually not-included in_these evaluations and comparisons because of its relative cleanliness compared with-coal, its de-clining role in electricity generation and its non-competitive nature relative ~to uranium or coal as a fuel for large base-load generating stations.
Although several estimates of occupational risks'from oil extraction, processing, transport and use have
- been reported, public health effects have been estimated by only a single author, and would provide a mean public health risk estimate. greater.than that for coal, which is unreasonable.
Accordingly, although no public health risks are assigned to oil-fired generating facilities in this analysis, it is expected that such effects should lie between those of nuclear and coal genera-tion.
Hydropower was also essentially excluded from these comparisons for similar reasons, and with the view that there were no sub-stantial emissions or other environmental impacts other than the flooding of large land and wetland. areas.
Accordingly, no health
-risks are assigned to hydroelectric generation.
However, it should be noted that, based on dam failures in the U.S. between 1928 and 1958,_a major disaster rate of 1.3 x 10-* per dam-year has been estimated, and that 1680 persons were killed by such failures over that period (9).
However, there is no existing correlation of these deaths with hydroelectric generation, and
.those risks are also ignored in this analysis.
A number of generic evaluations were examined to select several which provided more complete comparisons of risks of nuclear generation with other energy sources; an earlier site-specific coal / nuclear evaluation by the author (2) was also included for comparability with other generic values in the literature.
The fuel-specific analyses are tabulated in the Appendix for both occupational and public health risks, together with the refer-ences from which they were obtained.
A summary of these health risk effects for each fuel is presented in Table 3-4.
Despite the ranges of risks in the individual estimates of com-ponents of the overall risk displayed in the supporting tables in the Appendix, as Table 3-4 indicates, there is a very substantial difference in total risk per unit energy between coal and nuclear fuel generation in both worker and public health effects.
Oil generation would appear to lie between coal and nuclear fuel in
)
its unit occupational risk impacts and presumably in its public 1
health risks as well.
For example, if the public health risks from oil were only one-tenth those from coal, they would still substantially exceed those from nuclear power plants - by a fac-tor of almost 5 in public fatalities per GW(e)-yr, and by about a factor of 10 in injuries to the public.
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1
To provide proxies for the combustion product contributions to the " greenhouse" and " acid rain" effects, unit emissions of car-bon dioxide, sulfur dioxide and nitrogen oxides (NO.) were deter-mined for the MAAC system.
The sulfur oxide estimates in Table 3-3 were based on the annual fuel burn, average heat content and sulfur content reported, as well as reductions appropriate for any scrubbers in use.
Nitrogen oxide estimates were made by UDI using the eminsion factors of AP42 for the relevant boiler types.
The generation and emission data in Table 3-3 were combined to produce the unit emission rates by fuel which are presented in Table 3-5.
IV.
INCREMENTAL UNIT RISKS FROM REPLACEMENT ENERGY Using the relationships for incremental unit risk presented in-Section II for each of the alternative replacement fuel " mixes" for Limerick Unit 2, and the health risks presented in Table 3-4 incremental unit risks were calculated for worker and public deaths and injuries and are presented in Table 3-6 for each re-placement fuel mix.
As indicated in that table, 1 GW(e)-yr of "1988 mix" replacement!
energy for Limerick Unit 2 would result in an incremental risk of more thar. 1 worker fatality and about 7 additional public fatali-ties from disease and accidents in excess of those that would be calculated to accrue from the operation of a nuclear power plant to generate the same energy.
Further, increments above nuclear energy of about 61 occupational and 18 public injuries are esti-mated to result, per GW(e)-yr of replacement energy.
Similar values for the " marginal mix" replacement energy indicate occupational risks to be about 30% greater than for the "1988 mix" due to the absence of the low-risk nuclear option ja the former.
However, the public health risk is substanticily under-stated for the " marginal mix" because of the absence of a unit risk value for oil generation, and the significant fractional contribution of oil-fired generation in that mix.
It would be reasonable to expect that the incremental public health risk for that mix would increase in roughly the same proportion over the "1988 mix" risk as does the occupational value, i.e.,
by about 30%, although no quantitative support can be provided for that estimate.
The unquantified impacts from the emitted gaseous precursors of
" acid-rain" and " greenhouse" are all increments beyond the nuc-lear option (except for the energy for uranium enrichment assumed to come from coal-fired capacity).
These were calculated in the same way as for the health risks above from the data l' a Table 3-5 and are presented below.
5
c.
INCREMENTAL ACID-RAINcAND' GREENHOUSE; GASEOUS PRECURSORS
'~1
. EMISSIONS,.1000 T PER GW(e)-YR OF REPLACEMENT ENERGY EMIL MIX "1988"'
59.3 19.4 6163'
" Marginal" 72.1 30.2 11989 V.
INCREMENTAL RISKS OF REPLACEMENT ENERGY FOR LIMERICK.2
-The final' step in the estimation of.the incremental risks arising
'from the replacement of energy from Limerick Unit 2 for one fuel l
cycle is the determination of the magnitude of the' energy requir -
l:
ed.
The~ estimate of.the first-cycle energy output to be expect-edtfrom Limerick Unit 2, and hence to be replaced by alternative L
sources, is: based on the first cycle experience of Limerick Unit 1..
ThatLunit's net generation during its first cycle was.465 Effective Full Power' Days-(EFPD); at a net capacity of-1055
.MW(e), the energy generated totaled 490,575 MW-days, cn: 1. 34 4
!GW(e)-yr.
Thus,Jthe total incremental risk of the replacement energy for i
Limerick 2 is determined as 1.344 times the fuel-weighted unit' risk values.
These are' summarized in Table-3-7 for the two'al-
.ternative fuel mixes.
As indicated in that table, replacementof the nuclear energy.from Limerick Unit 2 tar either the 1986.MAAC mix of:foss11'and nuclear generation, or the marginal unit mix likely to be required,Eis estimated to result"in an~ additional
'17.5 - 2 worker deaths and 83 - 106 worker injuries, and more than 10 projected public fatalities and 24 injuries from such replace-
. ment energy.
Further, it is estimated that additions of about 8 -'16 million tons of carbon dioxide would be made..to the atmospheric reservoir of this " greenhouse" gas by this replacement energy, as well as about 105 - 145 thousand tons of the sulfur and nitrogen oxides which contribute, in part, to acid rain and which would not be produced by Limerick Unit 2 operation.
6
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. TABLE 3-l' i
- REPLACEMENT ENERGY BY ~ FUEL TYPE -
h-LIMERICK' UNIT 2 -' FUEL CYCLE 1
{
EUf1 M GW-HR PERCENT PEco Coal (Low' Sulfur) 279 2.8
.0ther Coal
- 4656 45.9 86 011 & Gas-(Steam).
4547 44.8 02 011 & Gas (Comb. Turb.)-
601 5.9 Net Hydro.
22 0.2 Non-Utility Generation 43 0.4 TOTAL 10148 100.0.
Note: Analysis also includes replacement of precommercial
. energy.
.0ther toal includes energy' sources inside and out:ide the PJM Interconnection Source: System Planning Division,' PECo, 7/31/89
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TABLE 3-2 1988 TOTAL GIGA,_ATT YEARS BY. ENERGY SOURCE FOR MAAC (PJM) UTILITIES TOTAL NUCLEAR FOSSIL HYDRO /
PURCHASED /
ENERGY STEAM STEAM OTHER INTERCHANGE h
UTILITY DISTRIBUTED GENERATION GEiERATION GENERATION GENERATION ACE 0.922 0.152 0.411 0.106 0.252 BGsE-2.946 1.339 1.516 0.019.
0.071
-DELMARVA PsL 1.235
.0.112 1.100 0.004 0.019 JCP&L 2.096 0.559 0.355 0.115 1.067 MET ED-1.204 0.310 0.559 0.019 0.260 PENN ELEC
.1.628 0.155 1.336 0.118 0.019 PP&L-4.111 1.469 3.515 0.072
-0.945 PECO 3.971 1.412 1.167
-0.042 1.433 l
PEPCO 2.753 2.326 0.021 0.406 PSEsG
.4.513 1.399 1.816 0.065 1.232 TOTALS 25.378 5.908 14.102 0.498 3.813 Source: UDI Utility Data Base, 7/89 l
8
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. TABLE 3-3 1
E.
1987 EEI FUEL DATA.FOR MAAC'(PJM) FOSSIL PLANTS a
C0AL
. 0IL '
GAS UTILITY (1000 Il (1000 RRkl (MMCF)
' ACE' 651 1225-BG&E 2680 2262 2451 DEEPWATER 414 229.
2276
- DELMARVA P&L 2451 2902 6451 DOVER ELEC 390 1433 JCP&L 419 10191 MET ED 1250 39 PENN ELEC 15117 232 PP&L 9706 7114 PECO 1245 4440 368 PEPCO 6130 2349 6834 PSEEG 1955 4121 40631 UGI/LUZERNE 194 2
TOTALS 41793
.25724 70835 GENERATION.
(GW-yr) 13.03 0.82 0.44 S02-EMITTED.
(1000 T) 1225.8 42.7 NOx EMITTED (1000 T)'
383-12 6 15 CO: EMITTED b (1000.T) 114931 12509 2113
- a Data from UDI EEI POWER STATISTICS Data Base except for CO:
NOx estimates assume AP42 emission factors SO: emissions include FGD' systems where applicable 32.7t (6.95 GW-yr) generated by nuclear plants b
CO emissions assume 75 wt% C in coal, 85 wtt C in fuel oil, and'75 wtt C in gas 9
c O
TABLE 3-4
SUMMARY
ALTERNATIVE ELECTRIC GENERATION HEALTH RISK PER GW(e)-YR FUEL ELSE M
NUCLEAR E
Occupational
. Deaths 2.35 0.44 0.64 Injuries 114 13 46 Public Deaths' 13 0.27 a
Injuries 31 0.29 b
a Hean literature value too high b No estimates in literature I
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TABLE 3-5 UNIT EMISSION RATES BY FUEL a
(1000 Tons /GW-yr)
FUEL EMISSION M
E QAJ_
SO 94.1 51.8 0
CO2 8820 15176 4752 NOx 29.4 31.3 33.0 a
Based on Table 3-3 generation and emission estimates 11 i
m,-....
1
,3.;
4 e
q"u TABLE 3-6 Y
~
INCREMENTAL FUEL-WEIGHTED HEALTH RISKS FUEL MIX-
"1988' "MARGINAL RIE.T.IPX tiDL" a till" h.-
Occupational' Deaths 1.15 1.'4 7 -
Injuries 62.10 78.84 Public
..,r.
Deaths 7.60 6.33 e
. Injuries 18.37 15.10 e a Replacement fuel mix is 59.9% coal, 5.8% oil, 31.90 nuclear and 24 hydroelectric.
b' Replacement fuel mix is 48.7V coal, 50.7% oil, and 0.6% hydroelectric c.Public risks and injuries are greatly under-estimated due to the absence of risk assigned to oil; if the.public risk from oil were~ half that from coal, these risks would be 50% greater a
12 n-
3
'i p,
g.
f 1
s
)
e i4(
L TABLE 3-7.
LTOTAL FUEL-WEIGHTED HEALTH RISKS-PROM 1.344 GW(e)-YR REPLACEMENT ENERGV FOR LIMERICK UNIT 2 '
- A FUEL MIX r
"1988
" MARGINAL B.IAE HER tiLX". a ifDL". b.
Occupational
- 1 Deaths 1.54 1.97
- Injuries
'83.46 105.96 Public.
j Deaths-10.22 8.51 e
- Injuries 24.69 20.29 e
.\\
. Atmospheric Emissions 4
-(1000 Tons)
' Acid Rain' Precursors
'S02.
80.5 96.9 NO.
26.1 40.6 Greenhouse Effect Precursor C03 -
'8283 16113
'a. Replacement fuel mix is 59.9% coal, 5.8% oil, l
'31.9% nuclear and 2%-hydroelectric j
b Replacement fuel mix is 48.7% coal, 50.7% oil, and 0.6%; hydroelectric c' Public risks and injuries are greatly under-estimated due to the absence of risk assigned to l
oil; if the public risk from oil were half that from coal, these risks would be 50% greater
.a 13 i
I a---_---__--:-______-
l I
. APPENDIX UNIT HEALTH RISKS TO WORKERS AND PUBLIC
'BY FUEL l
1 1
i
.m
- ye l '![)[
.[
' Table 3-0C OCCUPATIONAL ~ DEATHS AND INJURIES FER GW(e)-YR
' COAL
' DEATHS'(Accidents and Diseases)
(Reference)
. RISK SOURCE (1).
(2)
(3).
(4)'
(7)
AVERAGE.
Fuel Extraction 1.30 a 0.98 b' 1,38 c 1.83 e' 3.245 f Processing 0.06 0.08 0.035 Transportation 0.07 0.03 0.55 d.
0.54 d 1.225 Power Generation 0.05 0.00 0.13 0.15 0.02 TOTAL 1.42
- 1.09 2.12 2.59 4.53 2.35 NON-FATAL CASES
't Fuel Extraction 54 a 98 b 134 c 148 e 75 f Processing-4 4-3 Transportation _
7 3
8d 8d 12 Power Generation 2
3 5
5 1
TOTAL 63 104 149 165
- 91 114 a.IncludesLaccidents only in both mining _and preparation;-
assumes 50% underground /50% surface' extraction b Includes both mining and processing, but-excludes CWP;
. assumes 54.5% underground /45.5% surface extraction c Assumes 175% underground, 25% surface extraction and includes CWP; means of ranges from Table 10 l
l.
.d Assumes 1/3 rail, 1/3 barge and 1/3 truck transport e Assumes 75% underground, 25% surface extraction and includes CWP; means of ranges given f Includes accidents and disease; means of ranges given I
o Page A-1 c.
o 3-3
+f y
h j.? )Yhl p Table 3-ON r
?
.e OCCUPATIONAL DEATHS AND INJURIES PER GW(e)-YR-
'-t.'
NUCLEAR
+
Y:.
DEATHS (Accidents and Diseases)
(Reference) 1 RISK SOURCE' (1)
(2)
(4)
(5)
(7)
AVERAGE 1
. j) r Fuel Extraction 0.13 a 0.18: b 0.51 c 0.30 b 0.15 c Processing.
0.06 0.01 0.01 0.004 0.08 0.06.
0.10 0.27 d Transportation 0.002 Power Generation 0.01 0.08-0.14-0.06 0.06
.TOTALz 0.15 0.40-0.72 0.47 0.49 0.si
-NON-FATAL CASES cFuel. Extractions 6.9 a 6.1 11.4 e 9.4 d 5.9 d
-Processing 6.4' 1.7 1.6 1.1 Transportation 0.1 5.3 0.1 0.1 0.1 Power Generation
'1.7 1.8 l'. 5 3.5 1.3 TOTAL 8.7.
19.6
'14.7 14.6 8.3 13 0
a Includes mining and processing; includ.es accidents only b Includes both accidents and radiogenic cancers
~
c Includes' accidents, radiogenic cancers and other diseases d Based on means of ranges given l
l.
l l
i i
l-Page A-2
Ib)E
- y v ps; w,'
- [;;
b-
-g.
J.
Table 3 H' OCCUPATIONAL DEATHS AND INJURIES f:
.PER GW(e)-YR OIL-t l
. DEATHS (Accidents and Diseases)-
(Reference)
RISK SOURCE (1)
(6)
(7)
' AVERAGE Fuel Extraction 0.15 a
.0.18 b-
-Processing'<
0.67 Transportation-0.04 0.09 Power Generation 0.05 0.03
. TOTAL 0.24 0.97 0.72 c 0.64 NON-FATAL CASES
- Fuel Extract'lon 13.3 a 19.0 Processing 43.3 Transportation' 1.5 6.7 Power Generation 2.0 1.4 TOTAL' 16,7 70.5 51 c 46 a Includes mining'and processing; includes accidents only b Based on means of ranges given c Only totals for effect.given, mean of range listed Page A-3
= __ - _ __
jffh Table 3-PC PUBLIC DEATHS AND' INJURIES.
PER GW(e)-YR COAL DEATHS (Accidents and Diseases)'
~.
1
-(Reference)
' RISK SOURCE'
- (2)
(3)
(4)
(7)
AVERAGE Fuel Extraction-Processing, 5.50 be' Transportation.
- 0. 36" a 0.58 b-1.21'b 0.93
' Power Generation' 7.53 15.60'c 15.00 151.50
. TOTAL' 7.89 16.18 16.21-
'157.93 50 NON-FATAL CASES Fue1~ Extraction d
Processing:.
Transportation
.1 7b 7b Power Generation' -----
77 TOTAL 1
7 84 31 a Rail; transportation assumed b' Assumes 1/3: rail, 1/3 barge and 1/3 truck transport c Represents mean of ranges L
d No non-fatal effects listed Page A-4 I '.
\\
t..
24!
Table 3-PN j
PUBLIC DEATHS-AND INJURIES PER GW(e)-YR NUCLEAR j
DEATHS (Accidents and Diseases).
(Reference) a 1
RISK SOURCE (2)
(4)
(5)
(7)
AVERAGE
' Fuel Extraction 0.001 0.050 0.142 b Processing 0.370 a 0.013 0.204 Transportation
.0.002 0.011
'c Power Generation 0.011
.0.120 0.053 0.085 d TOTAL 0.385 0.194 0.399 0.085 0.266 1
NON-FATAL CASES Fuel Extraction 0.010 0.160 b e
Processing-0.135 0.003 0.280 Transportation 0.350 0.100 c
. Power' Generation 0.001 0.020 0.082 TOTAL-0.486 0.133 0.521 0.000 0.285 a Predominantly from assumed coal-energy used for U enrichment b Represents mean of ranges; only cancer mortality included i
e No transportation mortality risks presented d Public mortality risks only for generation e No non-fatal effects listed.
Page A-5 YL L_:_2_
,r x*;
1
,~
Table 3-PO PUBLIC dei?HS AND INJURIES PER GW(e)-YR OIL
' DEATHS (Accidents and Diseases)'
(Reference)
RISK SOURCE.
(6)
(7)
Fuel' Extraction Processing Transportation J
Power Generation 50.50 a
- TOTAL 50.50 50.50 a l
NON-FATAL CASES Fuel Extraction b
b Processing Transportal 2on-Power Generation TOTAL 0.0 0.0 a Presents a range of 1 - 100 fatalities, based on Reference (8)-
b No non-fatal effects listed i
4 l-l Page A-6 d
I
[4 -
i 1
)
1 1
'I l
HEALTH RISK REFERENC2S (1). " Health Effects of Alternative Means of EP2ctrical Generation",
K.A.' Hub and R.A. Schlenker, in " Population Dose Evaluation and Standards for-Man and His Environment", IAEA-SM-184/18, 1976 l
(2)
" Comparative Health Effects of Generating. Electricity at Erie Nuclear Plant and a coal-Fired Alternative", Testimony of Morton I.
Goldman, July 21, 1978, Ohio Public Service Commission
'l (3)
" Health Risks of Coal Energy Technology", S. C. Morris, in
" Health Risks of Energy Technologies", C.C. Travis and E.E. Etnier, Eds.
1981, AAAS Selected Symposium 82, Westview Press, Boulder, CO i
(4)
" Health and Environmental Risks of Energy Systems",, L.D. Hamilton, in " International Symposium on the Risks and Benefits of Energy l
Systems", IAEA-SH-273, April 1984 (5)
" Health Risks from the Nuclear Fuel Cycle", R.L. Gotchy, in
" Health Risks of Energy Technologies", C.C. Travis and E.E. Etnier, Eds.
1981, AAAS Selected Symposium 82, Westview Press, Boulder, CO (6)
" Health Effects of Energy Production and Conversion", C.L. Comar and L. A.-Sagan, in " Annual Review of Energy", 1976 (7)
" Health Evaluation of Energy-Generating Sources", Report of the Council of Scientific Affairs, American Medical Association,1978 (8)
"The Health and Environmental Effects of Electricity Generation -
A Preliminary Report", L.D. Hamilton, Ed., Brookhaven National Laboratory, 1974
^
(9)
" Energy in Transition, 1985 - 2010",
Final Report of the Commit-tee on Nuclear and Alternative Energy Systems, National Research Council", National Academy of Sciences, pp. 459-460, 1980 i
l l
l Page A-7
l-L Response of Philadelphia Electric Company l
to Question 1
4.
Provide an evaluation of whether operation of Unit 2 for' one fuel cycle would foreclose later installation of SAMDAs.
Operation of Limerick Unit 2 for one fuel cycle would not foreclose later installation of SAMDAs.
The design concepts and estimated costs for each of the SAMDAs addressed by PECO in its June 23, 1989 submit-tal to the NRC Staff were examined as to whether they could be installed after Limerick Unit 2 operation had begun.
There were no matters identified for any of the SAMDAs which would preclude installation due to full-power operation of Limerick Unit 2.
The occupational doses associated with postponing installation of the SAMDAs until after the first refueling outage, as discussed in response to Commis-sion Question 1, would also not preclude installation.
As discussed in that response, the SAMDA closest to l
being cost beneficial (but clearly not) entails a
1 modest occupational dose.
All of the SAMDAs studied i
i have the same or less occupational exposure associated 1
with their installation compared with typical outage j
i maintenance activities.
Even the highest occupational exposures associated with the installation of
.,ome j
-Question.4 Pcge 2 SAMDAs studied are far less than those associated with major outage maintenance.
l l
l l
l i
i f-l___ _ _ __ __
\\
Response of Philadelphia Electric Company to Question 5 5.
Provide an evaluation of the dollar cost resulting from a delay in starting up Limerick Unit 2 for a period of time equivalent to one fuel cycle.
In evaluating the cost of delaying the commercial operation of the plant, three costs must be considered.
They are (1) the additional financing costs asacciated with the delay (AFUDC);
(2) additional direct costs (capitalized operating and maintenance expenses); and (3) lost fuel savings.
Financing Costs In accordance with the Federal Energy Regulatory Commission (FERC) accounting
- rules, the cost of financing a project under construction are capitalized as part of the project cost.
These capitalized financing charges are called AFUDC.
The calculation of the additional AFUDC associated with the delay is done in accordance with FERC accounting rules.
The 9.5%
AFUDC rate is approximately equal to the Company's after tax cost of capital and is calculated in accordance with FERC rules.
The AFUDC is calculated by i
multiplying the AFUDC ra:e by the funds invested in the 1
l project to datc.
l l
L L
Question 5 Page 2 Operation and Maintenance Expense Once a plant starts to generate power, operating personnel are required and maintenance costs are incurred.
The costs associated with operating the plant prior to commercial operation are capitalized as part of the plant
- cost, in accordance with FERC accounting rules.
Also included in this category are expenses associated with retaining the necessary construction and startup personnel at the site.
Lost Fuel Savings Delaying the commercial operation of Limerick 2 delays the benefit of the lower cost of nuclear power generation.
The cost calculation of monthly fuel savings herein was derived from estimated savings for the period April 1990 (projected commercial availability of Unit 2) to March 1991.
The average monthly savings were then applied to the applicable fifteen-month period (eighteen months of the first fuel cycle minus three months refueling).
l Total Costs Total financing costs and operation and maintenance expenses resulting from an 18-month delay l
in commercial operation of Limerick Unit 2 are $675.9 l
million.
Lost fuel savings are $178.5 million.
The total costs of delay are $854.4 nillion.
Details are provided in Table 5-1.
_ _ _ _-l_ _ _ _ _
y -
I.i L
Table 5-1
-CALCULATION OF THE COSTS'OF' DELAYING' LIMERICK UNIT 2 COMMERCIAL OPERATION FOR'FIRST FUEL CYCLE (EIGHTEEN MONTHS)
ASSUMPTIONS:
l'.
Commercial-operation date for Limerick' Unit. 2:
February 1990.
Ir 2.
Cost. for bringing Limerick Unit 2 and 50% common
-areas on line by February.1990:
$3,836 million.
e 3..
Refueling; cycle is 18 months.
- 4..
Thecimpact of.the.:ost recovery cap imposed by the h
Pennsylvania Publ.lc Utility Commission is not reflected in the calculation.a/
FINANCING COSTS:-
Allowance for Funds Used..During Construction:(AFUDC)
$30.4 million per. month
($3,836 x
- 9. 5 % /12) :
~$547.2 million AFUDC is compounded every six months (AFUDC/AFUDC):
.$26.4 million OPERATING AND M?.INTENANCE EXPENSE:
E, Direct expenditures:
$95.4 million ($5.3 million per month x;18)-
AFUDC accrued on capitalized operating and maintenance expense:
$6.9 million
-a_/:
The estimated cost of Limerick Unit.2 (excluding common areas). for on-line commercial operation by February
-1990 is $2,888.7 million.
This is approximately $309 million ; below - the $3,197 million cost cap imposed by the Pennsylvania ?UC.
Any increase in cost above the PUC-imposed cost cap may. prevent Licensee from capitalizing additional costs for Limerick Unit 2,
i.e.,. cost of delay estimated herein at $675.9 million might be disallowed as recoverable cost by the PUC to the extent they. exceed $309 million.
m__m
.__-m.m_
______________._m_._
Table:5-1 Page 2 FUEL: SAVINGS:
$11.9 million per month x 15:
$178.5 millionNI 1
1
SUMMARY
OF COST OF DELAY FOR UNIT 2 OPERATION (Millions $)
{
Total Capitalized Increase In Capital O&M Expenses Plant Cost j
i
- Direct 0.0 95.4 95.4 j
AFUDC 547.2 6.9 534.1 AFUDC/AFUDC 26.4 0.0 26.4 Total 573.6 107.3 675.9 Total Increase in Plant Cost =
675.9 M 178.5 M Lost Fuel' Savings
=
854.4 M Total Cost
=
b/
An 18-month refueling cycle consists of 15 months rup.ning and 3 months refueling.
__.--_______-__.m
_