NLS8900323, Application for Amend to License DPR-46,changing Expiration Date of License from 080604 to 140118.Basis for Request Encl
| ML20246P644 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 08/31/1989 |
| From: | Kuncl L NEBRASKA PUBLIC POWER DISTRICT |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NLS8900323, NUDOCS 8909110200 | |
| Download: ML20246P644 (31) | |
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if ; GENERAL OFFICE Nebraska Public Power District " '" ""#A"sa"S#E^&M'""
NLS8900323-August 31,.1989 .
3 y^ U.S. Nuclear Regulatory Commission
' Document Control Desk
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- f. LWashington, DC 20555 Gentlemen:
Subject:
Application.for License Amendment Extension of License Expiration Date Cooper Nucicer Station NRC Docket No. 50-298, DPR-46 In accordance with the applicable provisions specified in 10 CFR 50, Nebraska Public Power District requests that the Cooper Nuclear Station Operating License,'DPR-46, be amended to extend the duration of the license
. to forty years from the date of issuance. This extension is consistent with the regulations regarding issuance of operating licenses and with actions taken by the Commission in numerous operating license = applications and amendments since 1982.
Attachment l'to this letter describes the requested change to the Facility
, Operating License. Specifically, it is requested that the expiration date l~ of the' license be changed from June 4, 2008, to January 18, 2014.
The current license for-operation of Cooper Nuclear Station is for forty years, beginning with the issuance of the Construction Permit, CPPR-42, on June 4, 1968. Accounting for the time elapsed during plant construction, the effective term for operation.is approximately 34-1/2 years. However,
.the plant is designed for at least forty years of operation and an operating license term of forty years is permitted by 10 CFR 50.51.
This requested amendment has been reviewed by the necessary Safety Review Committees and the District has determined that the change would not have a significant impact on safety or the environment. Attachments 2 and 3
. provide the basis-for our determination that the requested change does not constitute an unreviewed. safety question per 10 CFR 50.59 or invclve a
, significant hazards consideration per 10 CFR 50.92. Attachment 4 provides our analyses supporting these findings.
In addition to the signed original., 37 copies are also submitted for your use. By copy of this letter and attachments the appropriate State of Nebraska official is being notified in accordance with 10 CFR 50.91(b)(1).
Copies to the NRC Region IV Office and the CNS Resident Inspector are also being sent in accordance with 10 CFR 50.4(b)(2).
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- - l NLS8900323 I August 31, 1989 Page 2 l
Should you have any questions or require additional information, please l contact me. l Sincerely, L. G. Kunci Nuclear Power Group Manager i LCK: RAD Attachments (4) cc: H. R. Borchert Department of Health State of Nebraska NRC Regional Office Region IV Arlington, TX NRC Resident Inspector Office Cooper Nuclear Station
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t NLS8900323 August 31, 1989 Page 3 l
STATE OF NEBRASKA)
)ss PIATTE COUNTY )
L., G. Kuncl, being first duly sworn, deposes and says that he is an authorized representative of the Nebraska Public Power District, a public
-corporation and political subdivision of the State of Nebraska; that he is duly authorized to submit this request on behalf of Nebrauxa Public Power District; and that the statements contained herein are true to the best of his knowledge and belief.
L.#G. Kunc1 Subscribed resence and sw m before me this 3 day of U
JAD = r s, ,
NOTARY PUILIC/ crfttspf 44.m 4 cu m es.a s s. ass:
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,; ... s f : ,l , e ATTACHMENT 1 n
COOPER NUCLEAR STATION UCENSE EXTENSION CHANGE TO FACILITY OPERATING LICENSE DPR-46 i
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- (4) Fire Protection ./069 The licensee.may proceed with'and is required to complete the
/056
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modifications identified in Paragraphs 3.1 through'3.37 of.the ./056; NRC's Fire Protection Safety Evaluation (SE), dated May 23, /056.
1979 for the facility. These modifications will be completed /056 prior to July 1, 1980. /056 In addition, the licenseeshall submit the additional /056 information in Table 3.1 of this SE in accordance with ' the /056 l schedule contained therein. In the event these dates for /056 submittal cannot be met, the licensee shall. submit a report, /056 :
explaining the circumstances, together with a revised schedule. /056 The licensee is required to implement the administrative /056 controls identified in Section 6 of the SE. The administrative /056 controls shall be.in effect by November 1, 1979. /056 D. This license is subject to the a/ditional following conditions for the protection of the environment:
The licensee shall, for operation not later than . April 30, 1975, modify the liquid and gaseous radiological effluent handling systems in accordance with the systems described in Amendment 18 to the Final Safety Analysis Report. If.such systems are not installed by such date, the licensee shall, nonetheless, observe the gaseous activity release limits set
. forth in Paragraph a.4 of Section 2.4.3 of Appendix B attached .
- n. hereto and facility operation shall be restricted accordingly, is necessary.
E.- This license .is effective as of the date of issuance and shall expire at midnight,-E r '. 200". Januorj t g '2.o %
FOR THE ATOMIC ENERGY' COMMISSION ORIGINAL SIGNED BY A. Giambusso, Deputy Director for Reactor Projects Directorate of Licensing Attachments:
l Appendices A&B -
Technical Specifications Dat,e of Issuance: January 18, 1974 9
e 4 of 5 1
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ATTACHMENT 2 COOPER NUCLEAR STATION LICENSE EXTENSION 10 CFR 50.59 SAFETY EVALUATION A' change to the Cooper Nuclear Station Operating License,- DPR-46 is being requestcd to extend the expiration date from June _4,2008, to January 18,2014. This change will extend the duration of the license to forty years from the date of issuance of the Operating License. The present duration is forty years from the date of issuance of the. Construction Permit. The plant is designed for forty years of operation and a license term of forty years is permitted by 10 CFR 50.51.
There are no plant. hardware or system modifications required for this lic~ ense amendment. There are also no changes required to any operating, maintenance or surveillance procedures. Plant drawings, documents and computer software remain unchanged as do the USAR and Technical Specifications.
10 CFR 50.51 permits the issuance of an Operating License for a term of forty years and the Commission has granted numerous such licenses and license amendments
- since 1982.
The probability of occurrence or the consequences of an accident or malfunction of equipment important to safety previously evaluated in the Updated Safety Analysis Report has not been increased because this license change does not involve any changes to the physical plant or plant operating procedures. Plant maintenance and surveillance procedures are also not affected 'oy this change and the present
. procedures will continue to ensure the availability of all required equipment.
The possibility of an accident or malfunction of a different type than any evaluated previously in the Updated Safety Analysis Report is not created because no new modes of operation have been introduced.
The margin of safety, as defined in the basis for any Technical Specification has not been reduced because this change does not affect the Technical Specifications.
.For t he reasons stated above the Station Operations Review Committee and the
- Safety Review and Audit Board have determined that the requested license amendment does not constitute an unreviewed safety question as defined in 10 CFR 50.59.
ATTACHMENT 3 COOPER NUCLEAR STATION LICENSE EXTENSION 10 CFR 50.92 SIGNIFICANT HAZARDS EVALUATION A change to the Cooper Nuclear Station Operating License, DPR-46 is being requested to extend the expiration date from June 4,2008, to Januaq 18,2014. This change will extend the duration of the license to forty years from the date ofissuance of the Operating License. The present duration is forty years from the date of issuance of the Construction Permit. The plant is designed for forty years of operation and a license term of forty years is permitted by 10 CFR 50.51.
This proposed change has been evaluated against the criteria of 10 CFR 50.92 as follows:
- 1. The requested amendment will not involve a significant increase in the probability or consequences of an accident previously evaluated because the license change does not involve any changes to the physical plant or plant operating procedures.
The Cooper Nuclear Station was designed and constructed on the basis of a forty year operating life. The accidents analyzed in the Updated Safety Analysis Report and evaluated in the Safety Evaluation Report were postulated on the basis of a forty year operating life. The information and analyses presented in the Environmental Report and evaluated in the Environmental Impact Statement were not dependent on any specific period of operation.
Surveillance, inspection, testing and maintenance programs are in place to sustain the condition of the plant throughout its service life.
In conclusion, the effects of forty years of plant operation have been considered in the existing design, analysis and operation of the plant and, therefore, the probability or consequences of previously evaluated accidents has not been significantly increased.
- 2. The requested amendment will not create the possibility of a new or different kind of accident from any oreviousiv evaluated since the license change does not affect the design or operation of the plant. Programs are in place to maintain the plant throughout its service life. For the same reasons as outlined in item 1 above, the possibility of a new or different kind of accident is not created.
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o L 3. The requested amendment will not involve a significant reduction in a margin of safety since the license change-involves only a change in the expiration date of the license. The measures outlined in items 1 and 2 above, together with continued operation in 'accordance viith the Technical Specifications assure that an adequate margin of safety is preserved'on a continuous basis. An extension of the Operating License term does not result in a significant reduction in a margin of safety.
For the reasons stated above the Station Operations Review Committee and the Safety Review and Audit Board have determined that the requested license amendment does not involve a significant hazards consideration. It consists of a purely administrative change in the. term of the license which is permitted by the regulations of the Commission.
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COOPER NUCLEAR STATION LICENSE EXTENSION SAFETY AND ENVIRONMENTAL ANALYSIS n
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COOPER NUCLEAR STATION LICENSE EXTENSION
. SAFETY AND ENVIRONMENTAL ANALYSIS CONTENTS -l V
1.0 INTRODUCTION
. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 2.0 NEED AND REASONS FOR LICENSE EXTENSION . . . . . . . . . . . . . 2 3.0 - SAFETY ANALYSIS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3 3.1 . Electrical Equipment .................................3 3.2 ' Mechanical Equipment . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3 33 Stru cture s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4 '
3.4 Special Issues . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4 3.5' Summary of Safety Analysis . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4
- 4.0 ENVIRONMENTAL ANALYSIS ...........................6 4.1 Plant Facilities . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6 -
4.2 Land Use . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6 43 Non-Radiological Effects . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6 43.1 Thermal Discharges . . . . . . . . . . . . . -. . . . . . . . . . . . . . . 7 43.2 Chemical Discharges . . . . . . . . . . . . . . . .. . . . . . . . . . . . . 8 433 Solid Waste . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9 43.4 Site Ecology . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9 43.5 Aquatic Environment .......................... 10 43.6 Concurrence . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10 4.4 Radiological Effects . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11 4.4.1 Normal Exposures . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12 4.4.2 Accident Exposures . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13 4.43 Occupational Exposures . . . . . . . . . . . . . . . . .. . . . . . . . 13 4.4.4 . Fuct Cycle . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15 4.4.5 Transportation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16 4.4.6 ALARA Program . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16 4.5 Summary of Environmental Analysis . . . . . . . . . . . . . . . . . . . . 19
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1.0 INTRODUCTION
The Atomic Energy Act of 1954 allows the issuance of facility operating licenses for a period of up to forty years. Additionally,10 CFR 50.51 permits a forty year license term if the plant is so designed. Since 1982, the Commission has issued numerous operating licenses and operating license amendments alic, wing a period of operation of forty years.
In April,1985, an NRC policy letter was issued establishing staff policy for extending the expiration date of operating licenses issued prior to 1982 so that the term of the license would be forty years from the date of the operating license rather than forty years from the date of the construction permit.
The Cooper Nuclear Station (CNS) is located in Nemaha County, Nebraska, on the west bank of the Missouri River approximately 55 miles south of Omaha, Nebraska. The nuclear steam supply system (NSSS) is a boiling water reactor (BWR) supplied by the General Electric Company. The licensed power level for the reactor is 2381 megawatts thermal (MWt); hcwever, accident consequences were evaluated at a power level of 2486 MWt. The station has a gross electrical output of 801 megawatts electric (MWe) and a net output of 778 MWe. The station was designed and constructed for an operating life of forty years.
The construction permit, CPPR-42, for CNS was issued June 4,1968. The operating license, DPR-46, was issued January 18,1974, and expires on June '
4,2008, forty years from the date of the construction permit. The Nebraska Public Power District (the District) is requesting an amendment to the operating license to extend the expiration date to January 18,2014, forty years from the date of issuance.
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i 2.0 NEED AND REASONS FOR LICENSE EXTENSION Nebraska Public Power District is a public corporation and political subdivision of the State of Nebraska. The District includes 85 of the state's 93 counties and portions of two other counties. In 1988 the District served the total requirements of 54 municipalities and 26 other public power districts and rural cooperatives at wholesale. Also, the partial requirements of 18 municipalities were served at wholesale. In addition, the District served an average of 106,645 customers at retail. Approximately 77 percent of the District's total power sales were to wholesale customers and 23 percent to retail customers.
Total kilowatt-hour sales and peak system demand set records for the District in 1988. Kilowatt-hour sales totaled 10.6 billion, an 8.8 percent increase over 1987, and peak demand was 1,743 megawatts, an increase of 1.3 percent over the previous peak set in 1980. There is no reason to expect a change in this trend.
The Cooper Nuclear Station produced 40 percent of the District's energy needs in 1988 at a cost of 3.3 cents per kilowatt-hour. This is considerably less than the cost of replacement power.
The District's current projected need date for new power capacity is 2008, the current expiration date of the CNS Facility Operating License. At that time, the District will need an additional 292 MWe of additional capacity. This represents the District's 37.5 percent share of the 778 MWe net output of CNS remaining after long term power sales contracts . If the CNS operating license is extended, additional power capacity is not needed until 2011.
The replacement capacity costs for new coal-fired power resources, assuming a 300 MWe size replacement, are approximately $1800 per kilowatt (1989 dollars). 292 MWe of new coal-fired capacity to replace the District's current share of CNS output would cost $526 Million (1989 dollars). Any delay of this capital expenditure would save $44 Million (1989 dollars) in debt service costs alone for each year of delay.
The requested license amendment will allow the operation of CNS for a period of approximately 5-1/2 years beyond the current expiration date of the operating license. This extension will permit the deferral of decommissioning and additional generating plant construction costs at considerable savings to the wholesale and retail customers of the District.
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3.0 SAFETY ANALYSIS The District has evaluated the safety implications of extending the CNS operating license an additional 5-1/2 years. This safety analysis is intended to demonstrate that the public health and safety will not be adversely affected by the requested amendment to the CNS operating license. Most of the information presented here summarizes material previously presented to the ,
NRC in the USAR or other submittals relating to specific topics.
3.1 ELECTRICAL EQUIPMENT The safety-related electrical equipment and systems at CNS were originally designed and constructed for an operating period of forty years. This equipment has been subjected to an extensive review in response to the environmental qualification (EO) requirements of IE Bulletin 79-01B and 10 CFR 50.49. This review and the District's EO Program are documented in a comprehensive report to the NRC dated January 28,1981.
This report and several more recent submittals document the environmental conditions, aging reviews and life expectancy of all safety-related equipment. An NRC Safety Evaluation dated January 30,1985 concludes that the District's EQ Program is in compliance with 10 CFR 50.49. An NRC Inspection Report dated April 17,1989 closed out all open EO items and found no new items needing further resolution.
There are currently no known open issues which are affected by an extension to the operating license. The EQ Program will ensure that all safety-related electrical equipment will remain qualified for a service life of forty years.
The District has concluded that electrical equipment design, selection, application and qualification either considered a forty year life or will not be affected by a forty year life.
3.2 MECHANICAL EQUIPMENT The safety-related mechanical equipment at CNS was designed and constructed for a forty year service life. If a specific service life (e.g.,
forty years, or 32 EFPY at 80% capacity factor) was not specified, performance requirements were specified to ensure the equipment will perform its intended function. In either case, surveillance and maintenance programs are in place at CNS to maintain or determine replacement requirements for safety-related equipment. In addition, periodic inservice inspection and testing programs provide assurance that any unanticipated degradation in systems or equipment will be identified and corrected in a timely manner.
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Details of the primary system (reactor vessel and reactor coolant system components) design are given in the CNS USAR,Section IV. Operating limits and examination and testing requirements for the reactor coolant system are specified in the CNS Technical Specifications, Sections 3.6 and 4.6.
The District has concluded that safety-related mechanical equipment and systems were designed or are tested to assure their operability for at least forty years of plant life.
3.3 STRUCTURES The plant buildings at CNS are constructed of reinforced concrete and 1 steel. Industrial experience has shown that a service life well in excess of forty years can be expected.
The containment systems consist of a primary pressure suppression system and a secondary system to limit ground level radioactive releases.
Details of this system are given in the CNS USAR,Section V.
Surveillance, inspection and testing programs are in place to monitor the condition of all important structures so that any degradation can be identified and corrected. This includes local and integrated leak rate testing of the primary containment as described in the CNS Technical Specifications, Section 4.7.
The District has concluded that plant structures are capable of a service life in excess of forty years.
3,4 SPECIAL ISSUES Since the CNS operating license was issued, several new safety issues have emerged. These issues include security, fire protection, emergency planning, electrical equipment qualification (discussed above and including post accident monitoring equipment), control room design, safety parameter display system, plant specific simulator, and severe accident mitigation. As these issues have emerged, equipment has been modified and programs have been developed to address them. This will be an ongoing process which will result in a continuous improvement in plant safety. The District knows of no open items which would limit the life of the plant.
3.5
SUMMARY
The request for an amendment to extend the CNS operating license is based on the fact that a forty year life was considered during the design, construction and operation of the plant. There will be some degradation of equipment during the life of the plant; however, design features were 4
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! incorporated which allow for inspection and testing to determine when repair or replacement of components is necessary.
Based on the above, the District has concluded that an extension of the license to allow for a forty year service life is consistent with all previous safety analyses and poses no undue risk to the health and safety
- of the public.
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4.0 ENVIRONMENTAL ANALYSIS The District issued the CNS Environmental Report September 17, 1971.
Amendments were issued November 8,1971, June 26,1972, August 4,1972, August 25,1972, October 30,1972, and January 5,1973. The Atomic Energy Commission issued the Final Environmental Statement (FES) in February 1973.
The District has evaluated the environmental impacts associated with an extension of the CNS operating license. This environmental analysis is intended to demonstrate that both the onsite and offsite environmental effects associated with the requested amendment are not dependent on a :pecific operating life. Furthermore, the FES does not generally use or discuss a specific period of plant operation. Therefore, the assessments and conclusions of the FES are still valid.
4.1 PLANT FACILITIES i
In the approximately fifteen years of plant operation a number of modifications have been made to CNS. Generally, these modifications had the effect of improving the reliability and safety of the plant or reducing the environmental impact of plant operation. These modifications were either made with NRC approval and evaluated in a ;
Safety Evaluation Report, or were made in accordance with the provisions of 10 CFR 50.59 and reported to the NRC annually. No modification was determined to effec'. the conclusions of the original Environmental Statement.
. 4.2 LAND USE 1
Additional site buildings such as the Multiple Purpose Facility and Training Center have been constructed. Also, existing buildings such as the Administration Building have been expanded. However, the actual land area occupied by buildings or the CNS site itself has not increased significantly even though the actual land area owned and controlled by NPPD has increased by 261 acres. This additional property extended the south boundary of the site.
Of the 1351 acres presently owned by the District, approximately 70 acres constitute land occupied by plant facilities with the remainder in its natural state or utilized as tillable farmland. The amount of land removed from production for the transmission line corridors was found to be minimal as the farming activity adjacent to and under the towers and lines continues to be unimpeded.
4.3 NON-RADIOLOGICAL EFFECTS The CNS FES assessed the non-radiological impacts of plant operation on the terrestrial and aquatic environments as a function of the effects 6
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of plant location, design features, operation characteristics, habitat degradation, short term uses, long term productivity, and irreversible and irretrievable commitments of resources. No specific period of plant operation was used or discussed in these assessments. Based on the baseline data available at that time, the FES predicted the impacts of CNS operation would be minimal. However, a monitoring program was implemented to verify the predicted effects on the Missouri River.
The District initiated environmental studies to assess the impact on the aqu:stie biota of the Missouri River from CNS chemical and thermal discharges. Pre-operational studies were conducted from 1969 through 1973, and operational studies were initiated in 1974 and continued through 1979. The extensive data collected during these studies indicates that operation of CNS had not adversely impacted the water quality or aquatic ecology of the Missouri River.
In addition, an eleven-agency study group', coordinated by the Nebraska Game and Parks Commission, was formed to evaluate operational effects of both CNS and Fort Calhoun Station on temperature, chemistry, phytoplankton, periphyton, zooplankton, macroinvertebrates, laival fish and adult fish of the Missouri River. The findings of this group were published' in 1982. This study group also found that the operation of CNS has limited overall impact on the river production.
4.3.1 THERMAL DISCHARGE Thermal impacts on the Missouri River resulting from CNS operation were considered in the FES. The general areas considered included prompt effluent mixing with the river, abrupt increase (or decrease) in effluent temperature, and unfavorably high effluent temperature for aquatic organism survival.
In order to minimize the thermal stress to the aquatic ecosystem and reduce other adverse thermal effects downstream of the plant, limits have been placed on several plant parameters.
Specifically, the maximum temperature differential across the condenser, the maximum discharge temperature, the maximum !
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- 1. The eleven-agency study group consisted of a consortium including ;
Nebraska Public Power District, Omaha Public Power District, U.S. Army Corps of Engineers, U.S. Environmental Protection Agency, U.S. Geological Survey, University of Nebraska, Nebraska Department of Environmental Control, Iowa i Conservation Commission, Kansas Forestry, Fish and Game Commission, U.S. Fish and Wildlife Service, and the Nebraska Game and Parks Commission.
- 2. "The Middle Missouri River, A Collection of Papers on the Biology with Special Reference to Power Station Effects", Hesse, et.al. editors,1982 7
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rate of temperature change, and an e31uent mixing zone have been specified.
These limits were originally set forth in the Environmental Technical Specifications (ETS) (Appendix B to the CNS Technical Specifications). As of December 12, 1975, thermal discharge limits were also regulated by the Nebraska Department of Environmental Control (NDEC) through a National Pollutant Discharge Elimination System (NPDES) permit issued by them.
As a result, the Technical Specification limits were eventually removed.
As a requirement of the ETS and the NPDES permit, pre-operational studies were conducted from 1969 to 1973, and operational studies were conducted from 1974 to 1979 to determine the size and configuration of the thermal plume and it's impact on the water quality and biotic components of the Missouri River. Results of the monitoring program satisfactorily demonstrated that the thermal discharges (downstream extent and width of certain isotherms) complied with state and federal water quality standards, and that the effects on the aquatic biota were minimal. The NDEC subsequently issued a wavier for the operation of a once-through cooling system in accordance with ;
section 316(a) of the Clean Water Act.
The temperature and thermal plume study and monitoring requirements contained in the ETS and NPDES permit were subsequently deleted, except for the NPDES requirement to monitor discharge temperature. The District continues to monitor CNS cooling water discharge to assure that continued plant operation is in accordance with the NPDES permit temperature limits and applicable water quality standards.
4.3.2 CHEMICAL DISCHARGE The FES addressed the effects of chemical sludge and sanitary waste discharges from CNS into the Missouri River. The FES indicated this discharge would not significantly alter the quality of the water and would probably result in only a very small increase to the already high sediment and dissolved solid content of the river. It was also stated that plant operations would not significantly affect ground water supplies.
l An operational chemical monitoring program was conducted from 1974 to 1979 to insure that all chemical releases from the plant would not adversely affect the public health, the natural aquatic environment, or the suitability of water for domestic use.
The results of these studies found that the water quality in the l
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Missouri River was not adversely affected by the operation of ,
CNS. The Missouri River Study Group also found that any minor ;
alterations attributable to CNS operation are greatly overshadowed by the wide variation in water chemistry influenced by run off of the basin.
All chemical and sanitary waste discharges to the Missouri River are limited by the NPDES permit. In addition, the District has made a number of modifications to the chemical and sanitary waste systems at CNS which are designed to insure compliance with water quality standards. The modifications include the development of a pH control treatment system for the effluent of the make up water treatment settling basin (to be installed during the summer of 1989), the replacement of the sanitary waste treatment facility with a complete retention lagoon system, and rerouting of waste lines within the station. All applicable State and EPA limitations are being met in accordance with the current NPDES permit.
4.3.3 SOLID WASTE Non-radiological and non-hazardous solid waste generated by CNS is handled in one of two ways. Garbage and refuse is transported by a local hauler to an off-site landfill. Lime sludge, generated by the water treatment facilities and collected in the makeup water treatment settling pond, is removed periodically and applied to agriculturalland in the area of the station for pH adjustment in accordance with NDEC regulations. No adverse environmentalimpact is expected from the disposal of the plant refuse, and the lime sludge is being utilized for beneficial purposes.
CNS is a hazardous waste generator and has an EPA identification number. All wastes which are classified as hazardous are handled and disposed of in accordance with EPA, NDEC and Department of Transportation regulations.
4.3.4 SITE ECOLOGY The FES assessed the environmentalimpacts of CNS construction and operation to the site ecology. The FES concluded that little terrestrial impact will result from the operation of CNS since the habitats of small mammals and residential birds and the natural feeding grounds of migrating water fowl would be unaffected except in the limited area of the plant.
To assist birds, swans, hawks and eagles avoid the transmission lines that span the Missouri River, large orange plastic balls 9
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have been attached to the lines. The operation of CNS has had no effect on state or federally listed endangered or threatened species. 'Ibere are no parks, wildlife refuges, or organized recreational facilities in the immediate locale tilat can be harmed by plant operation.
4.3.5 AQUATIC ENVIRONMENT The FES addressed the potential effects of CNS operation on the Missouri River aquatic biota. These effects were related to the intake structure, entrainment of organisms, the thermal mixing zone and other station discharges. It was concluded that methods existed with the potential to reduce these effects but that they were not warranted. The FES also predicted that the effects of CNS operation would be insignificant, but concluded that an operational monitoring program should be implemented to verify predicted effects. The operational aquatic monitoring program was conducted from 1973 to 1978. In addition, a study plan was approved by the NDEC to obtain a permit for the operation of the intake structure in accordance with the Clean Water Act.
These studies satisfactorily demonstrated that losses of phytoplankton, zooplankton, macroinvertebrates and fish larvae had no significant effects on the Missouri River populations.
Furthermore, the impingement studies documented that the intake structure had no adverse impact on the fish population of the river and a permit was issued by the NDEC for an intake structure in accordance with section 316(b) of the Clean Water Act. The aquatic surveillance studies also demonstrated no significant adverse effects on the aquatic ecology of the Missouri River due to operation of CNS.
The Missouri River Study Group found the effects of entrainment and station operation on the planktonic, benthic and larval organisms of the Missouri River to be negligible. They also found impingement losses of adult fish to be insignificant. As a result of these findings, all associated monitoring requirements of the ETS and NPDES permit were subsequently dropped.
4.3.6 CONCURRENCE Due to the time period that has elapsed since the non-radiological monitoring studies were completed, the District l consulted with the Nebraska Department of Environmental l Control and the Nebraska Game and Parks Commission to determine if they were aware of any conditions that would result in a license extension adversely affecting the terrestrial or aquatic environments near CNS. Both agencies have agreed with the 10 I
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District's assessment that operating CNS an additional 5-1/2 years would not adversely affect these environments. (See letters appended to this report.)
4.4 RADIOLOGICAL EFFECTS The area surrounding CNS is predominantly rural and is not expected to change over the life of the plant. In Nemaha County, in 1982, there were 614 farms with an average size of 390 acres. In 1964 there were 1,178 farms with an average size of 207 acres. In Atchison County, Missouri, there were 669 farms with an average size of 459 acres in 1982 while in 1964 there were 869 farms with an average size of 369 acres.
In comparing 1982 statistics with 1964, there has been a trend toward fewer farms of increasing size with continuing specialization toward livestock (cattle and hogs) and grain (corn, sorghum, soybeans, and wheat) production. In 1964 there were 1,530 milk cows in Nemaha County; however, by 1982 that number had declined to 694. In Atchison County there were only 69 milk cows in 1982.
There have been some moderate population gains from 1970 to 1980 in specific areas around CNS. However, since 1940 the population within the 50 mile radius of CNS has been declining. From 1960 to 1980 the population declined 11.6 percent within the 50 mile radius.
The ten mile Emergency Planning Zone (EPZ) is made up of portions of Nemaha and Richardson Counties in Nebraska, and Atchison County in Missouri. Of the EPZ about 48 percent is in Nemaha County,9 percent in Richardson County, and 43 percent in Atchison County.
Except for a 0.3 percent population increase for Atchison County from 1960 to 1970, the above counties have shown a population decline every ,
ten years since 1940. From 1970 to 1980 the total population in these three counties declined by 2,206 persons.
By actual count there are only eight persons residing within a one mile radius of CNS (0.9 mile from the elevated release point in the NW sector). According to the 1980 census, there are an estimated 33 persons residing within the 1-2 mile radius,909 within 5 miles,5,703 within 10 miles, and 159,887 within 50 miles.
After evaluating the population history within the ten mile EPZ, the District has concluded the population will remain stable or show a very slight increase through the life of the plant.
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4.4.1 NORMAL EXPOSURES l
On March 3,1977, the District notified the NRC of the
~ installation of the Augmented Off-Gas Treatment System. This system was designed to further delay the radioactive gases in the off-gas stream, reducing the activity level, prior to venting to the atmosphere. The system was added for compliance with the "as low as practical" requirement of 10 CFR 50. It was designed for continuous operation with a service life of forty years. The system provides for a 44.5 hour5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> delay of Krypton isotopes and a 37 day delay for Xenon isotopes. The specified delays were designed to reduce the effluent activity to less than 100 uCi/sec.
On December 24,1984, the NRC issued Amendment 89 to the CNS operating license. This amendment revised the CNS Technical Specifications to incorporate the CNS Radiological '
Effluent Technical Specifications (RETS). The NRC further determined that these RETS would assure compliance with the ALARA requirements of 10 CFR 50, Appendix I. The offsite effects of continued operation of CNS will be minimized by the plant's compliance with the RETS.
The annual integrated population doses resulting from the operation of CNS continue to be low. The integrated population doses for the gaseous pathway (0-50 miles), for the time period of 1974 through 1988, range from 4.12 E-02 to 7.92 E+00 Man-Rem per year. The same doses for the liquid pathway range from 1.10 E-02 to 4.15 E+00.
The maximum annual gamma and beta air doses for the most exposed resident and at the site boundary are typically just a fraction of the Technical Specification limits of 10 mrad / year for gamma and 20 mrad / year for beta. The maximum annual organ doses due to I-131, I-133, and particulate with half lives greater than 8 days, for the most exposed resident and at the site boundary are also typically just a fraction of the Technical Specification limits. For example, in 1988 the maximum organ dose rate to a theoretical infant, due to I-131, I-133, and particulate with half-lives greater than 8 days, was 1.39 E+00 mrem / quarter which was less that 20 percent of the Technical Specification limit of 7.5 mrem / quarter to any organ. The total dose for 1988 was 2.14 E+00 mrem / year which is less than 15 percent of the Technical Specification limit of 15 mrem / year to any organ.
All radioactive liquid effluents are diluted prior to discharge to the river to concentrations below the concentrations specified in 10 CFR 20.106 for radionuclides other than dissolved and 12
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entrained noble gases. For example in 1988 the maximum concentration for fission and activation products was 1.35 E-07 uCi/ml and for Tritium 1.81 E-07 uCi/ml. During 1988 dissolved and entrained noble gas concentrations were diluted below 2.00 E-04 uCi/ml total activity.
Typically the maximum whole body doses and maximum organ doses, due to liquid effluents, are a small fraction of the Technical Specification limits of 3 mrem / year to the total body and 10 mrem / year to any organ. For example in 1988 the maximum whole body dose was 1.17 E-01 mrem / year which is less than 4 percent of the limit and the maximum organ dose was 1.56 E-01 mrem / year which is less than 2 percent of the limit.
After evaluation of the above data, the Radiological Monitoring Program, and the Annual Radiological Environmental Operating Reports from 1974 through 1988, the District concludes that the CNS has had, and will continue to have, no detectable radiological impact on the environment in the vicinity of the station.
4.4.2 ACCIDENT EXPOSURES The requested amendment extending the CNS operating license will have no effect on the potential for the release of radioactivity in an accident. Recent data have indicated that the source ter c.s used for the CNS accident analyses were quite conservative. In addition, the population history of the area discussed in Section 4.4 above shows a decrease in the population around the plant and no projected significant increase.
The District has concluded that the offsite doses presented in the USAR accident analyses are conservative and bounding for an extended plant life.
4.4.3 OCCUPATIONAL EXPOSURES The District is committed to operate CNS in a manner that will not jeopardize District personnel or the pu' lic health and safety.
Incorporated into the CNS Facility Operating License, is the obligation to maintain the radiation exposure to occupationally exposed personnel at levels which are as low as is reasonably achievable (ALARA) and which are in compliance with 10 CFR
- 20. To fulfill this obligation, the District maintains a Radiation Protection Program that ensures compliance with these regulatory requirements. The primary objectives of the Radiation Protection Program are to 1) provide monitoring of radiological conditions to ensure the safety of all District, vendor and contractor 1
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. l personnel and 2) provide radiation control guidelines and recommendations, as well as to define limits and specify ;
instructions, to assist all on-site personnel in carrying out their '
assigned responsibilities.
Inherent to the Radiation Protection Program is the District's ALARA Program. The ALARA Program's primary objective is to effectively control the radiation exposure of all District, vendor and contractor personnel at CNS. This control is administered through Station Procedures, the Radiation Protection Program, engineering controls and design considerations, equipment and instrumentation selection, operation and outage plans, system processing techniques, maintenance programs and the overall operating philosophy at CNS.
The Radiation Protection Program and the ALARA program have been implemented and audited, both internally and externally with favorable results. Due to the District's strict adherence to the requirements of these programs, combined with their demonstrated effectiveness, the District currently has a SALP rating of one in the arca of Radiation Protection.
The District's commitment to its ALARA and Radiation Protection Programs is evidenced by the historical CNS radiation exposure data presented in Figure 1. The data clearly shows that CNS maintains an average annual collective radiation exposure well below that of the industry average per BWR unit. Industry data for the years 1975 through 1985 is from NUREG 0713. The data for 1986 through 1988 was obtained from INPO documents on BWR radiation exposure.
Figure 1 includes two years (1983 and 1985) when major outages required unusually high dose commitments to repair or replace reactor plant piping systems. Approximately 1100 Man-Rem was incurred in 1983 to repair 49 Intergrannular Stress Corrosion Crack (IGSCC) indications in reactor recirculation piping welds.
The higher than average exposure in 1985 was the result of an extensive and complex reactor recirculation pipe replacement of IGSCC affected pipe and associated components. Approximately 1050 Man-Rem can be attributed to the IGSCC pipe replacement work concluded in 1985.
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ANNUAL OCCUPATIONAL EXPOSURE
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Figure 1 The District will continue with its commitment to maintain effective ALARA and Radiation Protection Programs throughout the duration of the CNS Facility Operating License.' As a result, lthe proposed additional years of reactor operation are not ,
expected to increase annual collective occupational exposures to radiation workers.
4.4.4 FUEL CYCLE The .CNS FES evaluation 'concerning uranium fuel assumed -
annual refuelings, each with'a discharge of approximately 1/4 of the 548 fuel assembly core. Since that time, the District has .
decided to revise the fuel management scheme and increase the fuel enrichment allowing for an eighteen month fuel cycle. This lengthened fuel cycle will begin with the refueling scheduled for the spring of 1990. As a result, it is anticipated that fewer total fuel assemblies will be discharged to the spent fuel pool even with an extended plant life.
The FES also assumed transportation of spent fuel to Morris, Illinois for reprocessing. The Morris facility never began operation; however, it is being utilized as a storage facility and the District has shipped 1056 fuel assemblies there for that purpose. Additional transportation of fuel assemblies offsite for storage is not anticipated.
The fuel storage facility at CNS has been expanded from an original 740 locations to the present configuration of 2366 15
.A locations. There are presently 288 fuel assemblies in storage and based on current projections the ability to discharge one full core into the pool will end approximately in the year 20CM.
The District has a contract with the Department of Energy for the removal from the plant site and disposal of spent fuel. This service is presently scheduled to begin prior to the full utilization of current onsite storage capacity. In the event that fuel removal becomes delayed and additional storage is required, this storage could be provided by onsite storage in casks. One dry storage cask design has been licensed by the NRC for such use and other licensed casks are expected to be available in the late 1990's if required.
The District has concluded that the requested extension to the CNS operating license will proportionally increase the requirements for total fissile uranium. However, the annual environmental effects of the fuel cycle, including storage, remain essentially unchanged. In fact, the longer fuel cycle may lessen the total impact from fuel storage and disposal activities.
4.4.5 TRANSPORTATION The FES assumed that operation of CNS would result in the shipment of 68 truckloads of low-level radioactive waste per year for disposal. Re number of required shipments has been held well below this figure and only 32 truckloads were shipped in 1988. This is partially due to the successful implementation of a volume reduction program.
Operation of CNS beyond the current license expiration date will necessitate the shipment of additionallow-level radioactive waste; however, the annual rate of production is not expected to change as a function of the age of the plant and should remain below that assumed in the FES.
Nebraska is a member of the Central Interstate Compact (CIC).
The CIC was ratified by the U.S. Congress in 1985 and Nebraska has been selected as the host state. A disposal site is now being selected and the District anticipates that these arrangements will satisfy the low-level radioactive waste needs of CNS throughout it's operating life.
4.4.6 ALARA PROGRAM The CNS comprehensive ALARA Program is designed to effectively control the radiation exposure of all District, vendor and contractor personnel at CNS by ensuring that radiation 16
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exposures are kept to the lowest levels commensurate with sound economics and operating practices. As with_ the Radiation Protection Program, the District believes that'a successful and effective ALARA Program requires a unified and committed effort from all levels of station manaBement. The District is also -
of the opinion that certain key elements are essential to an effective ALARA Program.- These elements provide the framework for the CNS ALARA Program and are formally
, identified in the CNS ALARA Procedures. The elements are:
- 2. The identification of the ALARA Program objectives and the management system by which these objectives will be met.
- 3. The identification of the ALARA organization and associated organizational responsibilities and authorities.
- 4. An effective and comprehensive ALARA Training Program.
- 5. The identification of methods for incorporating ALARA .
-considerations into the initial design and modification of Station facilities, processes and equipment.
- 6. The identification of methods for factoring ALARA into Station Procedure development and review.
- 7. The identification of provisions for prejob planning prior to actual work performance.
- 8. The identification of methods for analyzing exposure trends, setting exposure goals, measuring goal accomplishments and analyzing performance.
- 9. The identification of methods for evaluating the effectiveness of the ALARA program in order to correct deficiencies, incorporate more effective methodologies, or incorporate state-of-the-art technologies previously not available to the industry.
l Formalidentification of these ALARA Program elements in the l CNS Procedures is essential to assure that all facets of the ALARA Program are understood and implemented and that responsibihties, goals, and methodology for implementation are clearly specified and understood by all levels of the District's Nuclear Power Group organization.
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The District has evaluated and implemented numerous ALARA related measures which have significantly reduced occupational exposures. The following examples demonstrate the effectiveness of the ALARA Program at CNS.
- 1. Strict reactor water chemistry controls, to limit the buildup of activated corrosion products and minimize the resultant plant radiation levels, have been in place for the entire duration of the Facility Operating License. General area radiation levels in the CNS drywell are well below that of BWRs of the same vintage and type.
- 2. Prior to the 1984-1985 recirculation pipe replacement outage the recirculation system and associated piping was chemically decontaminated. . With an average decontamination factor of 40 it is estimated that 350 Man-Rem of exposure was avoided during the recirculation pipe replacerrent outage.
- 3. The reactor recirculation IGSCC affected pipe was replaced with passivated 316NG stainless steel pipe during the 1984-1985 cutage. The passivation consisted of first electropolishing the pipe to remove manufacturing oxides and to smooth the pipe in order to reduce the true surface available for corrosion product uptake. Electropolishing was then followed by exposure to hot, moist air which covered the pipe with a thin oxide film which protected the pipe surface from corrosion and the uptake of corrosion products from the reactor water, when placed into service. Corrosion layer buildup factors based on recirculation pipe gamma scanning conducted during the period 1986-1989 indicate that the passivation process used by CNS is the most effective method curremly available for reducing activated corrosion layer buildup.
- 4. Buildup of general area radiation levels as a result of plant operations and maintenance is frequently reduced in magnitude through periodic hydrolazing of plant drain lines and highly contaminated work areas.
- 5. Underwater desludging of the CNS suppression pool significantly reduced general area radiation levels in the areas surrounding the suppression pool.
- 6. Temporary shielding is effectively utilized to reduce localized high radiation levels within the CNS drywell structure.
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In summary, the CNS ALARA Program is effectively controlling radiation exposure to all on-site personnel. The ALARA related measures implemented at CNS will have a significant long term effect on reducing occupational exposures at CNS in addition to l the short term effects already observed. Therefore, it may be i I. concluded that the proposed additional years of reactor operation L will not involve on-site radiation exposures in excess of those currently encountered at CNS.
4.5
SUMMARY
OF ENVIRONMENTAL ANALYSIS-l A conclusion in Section VIII of the CNS Final Environmental Statement i is, "...the impacts from station operation are short-term (normally coincident with operational lifetime) except for the addition to the inventory of long-term radionuclides and a possible commitment of a small amount of land." In addition, the environmental analysis above demonstrates that an extension to the term of the CNS operating license l will not have any significant impact on radiological or non-radiological i effects either onsite or offsite.
The District has concluded that the impacts associated with an extension to the CNS operating license are all short term and coincident with l operation of the plant. The District has also concluded that there are no new or additional irreversible impacts associated with the requested ,
amendment. Since the issuance of the proposed amendment will have l no significant impact on the quality of the environment, the District has .
concluded that an Environmental Impact Statement should not be prepared for this action. l I
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! f STATE OF NEBRKSKA
[ DEPARTMENT OF ENVIRONMENTAL CONTROL KAY A. ORR DENNIS GRAMS w COVERNOR DIRECTOR m
b June 6, 1989 Brian L. Barels Environmental Manager Nebraska Public Power District P.O. Box 499 Columbus. NE 66601-0499
Dear Mr. Barels:
I have received your letter of May 26, 1989 regarding the possible extension of Cooper Nuclear Station's Operating License to January 18, 2014. I asked my staff to consider any potential impacts to the aquatic resources and water quality of the Missouri River resulting from this action.
By itself, the additional 5 1/2 years of operation should have no significant adverse effect on the aquatic resources and water quality of the Missouri River. This conclusion is based on the continuation of a status quo situation. The only concern raised is if the extension would '
coincide with the operation of any new power stations in the vicinity of Cooper Nuclear Station. Should this happen, the uncertainty of conditions affecting the aquatic environment would negate the no significant adverse effect conclusion.
Sincerely.
AJ S$
U. Gale Hutton, Chief W%
Water Quality Division JB/1f JUN I3 isse P.O. BOX 98922, LINCOLN, NEBRASKA 68509 8922, PHONE (402)4712186 AN EQUAL OPPORTUNITY / AFFIRMATIVE ACTION EMPLOYER j
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a Nebraska Game and Parks Commission l 2200 North 33rd Street / P.O. Box 30370 / Lincoln. Nebraska 68503 June 23, 1989 Mr. Brian Barels '
Environmental Manager Ecology and Engineering PO Box 499 Columbus NE 69601-0499
Dear Mr.Barels:
The following is provided for your consideration in developing your Cistrict's request for a five and or.e-half ye:rs extension of the Cooper Nuclear Station operating license.
We concur with a finding that it would be difficult to show significant adverse impacts on the aquatic resources to result from operation of this single power plant. Hcwever, we recommend that the environmental assessment also address the cumulative effects of larval fish drif t losses as a resul t of intrainment. This is not the only plant operating ,
nor.is power generation the only factor adversely affecting natural !
recruitment to the Missouri River fishery.
Sincerely, Gerald R. Chaff Water Resources Planner GRC/dj 1
I JUN 2 6 was '
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