5.0 Environmental Measurements

and Monitoring Programs

1 Tennessee Valley Authority (TVA) has conducted environmental monitoring at Watts Bar

2 Nuclear (WBN) plant since the 1970s (NRC 1995). Currently, TVA conducts thermal,

3 radiological, hydrological, meteorological, ecological, cultural, and chemical monitoring onsite

4 and in the vicinity of WBN plant.

5.1 Thermal Monitoring

5 TVA monitors the temperature of the receiving water (Chickamauga Reservoir) associated with

6 operating WBN Unit 1 to demonstrate that the thermal limits set in the National Pollutant

7 Discharge Elimination System (NPDES) are met by the plant. NPDES permit limits are set to

8 protect aquatic wildlife. TVA also monitors the temperatures of three outfalls where heated

9 water from plant operations is or could potentially be released: Outfall 101, associated with the

10 blowdown discharge from WBN Units 1 and 2 cooling towers and the Yard Holding Pond (YHP);

11 Outfall 102, the emergency overflow for the YHP; and Outfall 113, associated with the

12 Supplemental Condenser Cooling Water (SCCW) system. The NPDES permit has been

13 updated to include discharges associated with the operation of both WBN Units 1 and 2. The

14 revised permit issued by the Tennessee Department of Environment and Conservation (TDEC)

15 contains no changes to the thermal monitoring required for Outfalls 101, 102, and 113 at the

16 WBN site (TDEC 2011).

17 TVA measures the temperature of water to be discharged through Outfall 101 using a

18 continuous monitor in the blowdown pipe. State water-quality requirements and the WBN site's

19 NPDES permit (TDEC 2011) established a daily maximum discharge temperature limit of 35 0C

20 (950F) for Outfall 101.

21 The plant discharges water from Outfall 102 infrequently. During discharge events, TVA

22 monitors water temperature with a daily grab sample and as for Outfall 101, the daily maximum

23 discharge temperature limit is 35 0C (95 0F) (TDEC 2011).

24 TVA monitors Outfall 113 continuously at the stream bottom to ensure the temperature does not

25 exceed the permitted limit of 33.5°C (92.30 F) at this location. TVA also monitors water

26 temperature in the Chickamauga Reservoir on the Tennessee River to demonstrate that

27 discharges do not exceed permit limits and to verify the temperature models used to manage

28 the cooling system. The NPDES permit identifies two mixing zones for Outfall 113: one for

29 conditions when one or more turbines at Watts Bar Dam operate and one for when the dam

30 discharges little or no water.

September 2011 5-1 Draft NUREG-0498, Supplement 2
Environmental Measurements and Monitoring Programs

1 When TVA operates one or more turbines at Watts Bar Dam, water flows past Outfall 113

2 mixing with the heated discharge water and keeping the plume of heated water moving along

3 the shoreline; as a result, the plant has established a monitoring program for an active mixing

4 zone associated with Outfall 113 (the outfall for the SCCW system). TVA continuously monitors

5 water temperature at the downstream edge of the mixing zone, located 610 m (2,000 ft)

6 downriver from the discharge. Here, TVA suspends temperature sensors from floats in the river

7 and measures the water temperature. Telemeters on the floats transmit temperature data every

8 15 minutes to the plant so operators can adjust the cooling system if the water approaches

9 temperature limits. Sensors are located at 1, 1.5, and 2 m (3, 5, and 7 ft) below the water

10 surface. For comparison, sensors are also located upstream of Outfall 113.

11 When turbines at the dam do not operate and minimal flow exists past the outfall, the NPDES

12 permit allows for a passive mixing zone. Under these conditions, the mixing zone extends

13 300 m (1,000 ft) downriver and includes the entire width of the river. Under these conditions,

14 fish can still pass the heat plume because it resides near the top of the water column. Twice a

15 year, TVA performs a temperature survey along a transect across the river through this mixing

16 zone, and uses these data to verify its models that determine when to alter the operation of the

17 SCCW or release additional water at the dam to comply with discharge permits. TVA reports

18 temperature survey results annually, such as in its Winter 2006 Compliance Survey for Watts

19 Bar Nuclear Plant Outfall 113 Passive Mixing Zone (Proctor and Hopping 2007).

5.2 Radiological Monitoring

20 TVA has conducted its radiological environmental monitoring program (REMP) at the WBN site

21 since Unit 1 began operating in 1996, with its preoperational sample collection activities

22 beginning in 1976 (TVA 2003a). The REMP includes monitoring the airborne exposure

23 pathway, direct exposure pathway, water exposure pathways, aquatic exposure pathways from

24 the Chickamauga Reservoir, and the ingestion exposure pathway within an 8-km (5-mi) radius

25 of the station. The program also uses indicator locations near the plant perimeter and control

26 locations at distances greater than 16 km (10 mi) from the plant. TVA conducts an annual

27 survey of the surrounding area to verify the accuracy of the assumptions it uses in the analyses,

28 including the occurrence of milk production. The preoperational REMP sampled various media

29 in the environment to determine a baseline from which to observe the magnitude and fluctuation

30 of radioactivity in the environment once the units began operating. The preoperational program

31 included collecting and analyzing samples of air particulates, precipitation, crops, soil, well

32 water, surface water, fish, and silt as well as measuring ambient gamma radiation. After Unit 1

33 began operating in 1996, the monitoring program continued to assess the radiological impacts

34 on workers, the public, and the environment. TVA summarizes radiological environmental

35 monitoring data and radioactive effluent release data at the WBN site in two annual reports: the

36 Annual Radiological Environmental Operating Report (e.g., TVA 2008a) and Annual Radioactive

37 Effluent Release Report (e.g., TVA 2008b). WBN Offsite Dose Calculation Manual (ODCM)

38 specifies the limits for all radiological releases (TVA 2008a). The REMP is a sitewide program

Draft NUREG-0498, Supplement 2 5-2 September 2011
Environmental Measurements and Monitoring Programs

1 that monitors the radiological impacts from all radiation sources on the site. Accordingly, TVA

2 does not plan to establish an additional monitoring program for WBN Unit 2. To the greatest

3 extent practicable, the REMP would use the procedures and sampling locations TVA uses for

4 WBN Unit 1. U.S. Nuclear Regulatory Commission (NRC) staff reviewed the documentation for

5 the existing REMP and the WBN ODCM, and determined that the current operational monitoring

6 program is adequate to establish the radiological baseline for comparison with the expected

7 impacts on the environment related to operating and maintaining WBN Unit 2.

8 In support of the Nuclear Energy Institute Ground Water Protection Initiative, TVA's developed a

9 Ground Water Protection Program (GWPP) to monitor the onsite plant environment for

10 indication of leaks from plant systems and buried piping carrying radioactive liquids. The annual

11 radioactive effluent release report for 2010 (TVA 2011 a) summarized results of groundwater

12 sampling it performed in various locations around the plant that could be a source of

13 groundwater contamination. Section 2.6 describes the GWPP. The staff reviewed results of

14 tritium monitoring from WBN Unit 1 for a period of 9 years (2003 through 2010). In 2010, the

15 only observations of tritium offsite were trace levels of tritium in six samples collected from two

16 downstream public water sampling locations. The highest downstream water sample was

17 1.8 x 1013 pBq/L (597 pCi/L), which is well below the U.S. Environmental Protection Agency

18 (EPA) drinking standard of 7.4 x 10.14 pBq/L (20,000 pCi/L). Onsite, tritium levels continue to

19 decrease annually following the 2002 leak described in Section 2.2.3.2.

5.3 Hydrological Monitoring

20 Hydrological monitoring consists of surface-water and groundwater monitoring. At the WBN

21 site, TVA monitors the thermal and chemical characteristics of water discharged to surface22 water through WBN outfalls. TVA also monitors temperature in Chickamauga Reservoir.

23 Section 5.1 describes thermal monitoring and Section 5.6 describes chemical monitoring,

24 including chemical monitoring in surface water and groundwater.

25 In addition, TVA uses information about the volume of water flowing past the WBN site to make

26 decisions related to operating the cooling system in compliance with the NPDES permit for

27 discharging water from Units 1 and 2 to Chickamauga Reservoir. TVA gathers this flow

28 information at Watts Bar Dam immediately upstream of the WBN site.

29 Groundwater monitoring at WBN includes collecting groundwater samples for analysis of

30 radionuclides and is described in Section 5.5.2.

5.4 Meteorological Monitoring

31 TVA has collected meteorological data at the WBN site since 1971 (TVA 2009a). It began

32 operating a permanent meteorological data collection system in 1973. The plant has modified

September 2011 5-3 Draft NUREG-0498, Supplement 2
Environmental Measurements and Monitoring Programs

1 system instrumentation since then. Section 2.3 of the WBN Final Safety Analysis Report

2 (FSAR) (TVA 2009a) describes in detail the data collection system as it currently exists. It

3 consists of a 91r-m (300-ft) tower with wind and temperature sensors at 10 m (33 ft), 46 m

4 (150 ft), and 91 m (300 ft), a ground-level rain gauge, a dewpoint sensor on a separate 10-m

5 (33-ft) tower, and associated data processing and recording equipment. The meteorological

6 system provides meteorological data to support operating WBN Unit 1 and would support Unit 2.

7 During the site audit, TVA indicated its intention to upgrade the meteorological instruments to

8 meet the specifications set forth in Revision 1 of Regulatory Guide 1.23 (NRC 2007).

9 The NRC staff reviewed the meteorological system in 1994 in conjunction with preparing its

10 1995 Supplement No. 1 to the Final Environmental Statement related to the operating license

11 (1995 SFES-OL-1) (NRC 1978, 1995). The staff reviewed the system again in preparing for this

12 supplemental final environmental statement (SFES) related to operating WBN Unit 2. The staff

13 found in both reviews that the measurement location was representative of the WBN site, the

14 instrument specifications were consistent with guidance in Regulatory Guide 1.23 (AEC 1972),

15 and system calibration and maintenance procedures were sufficient to ensure reliable data for

16 meteorological characterization of the site for environmental reviews.

5.5 Ecological Monitoring

5.5.1 Terrestrial Ecology

17 In the 1978 Final Environmental Statement related to the operating license for WBN Units 1 and

18 2 (1978 FES-OL), TVA committed to monitoring the effects of cooling-tower drift, bird collisions

19 with the cooling tower, and maintaining the transmission lines (NRC 1978). TVA also committed

20 to monitoring the effects of total dissolved solids deposition on plants and having qualified

21 personnel inspect vegetation for evidence of damage during the growing season. Also, TVA

22 agreed to initiate an aerial remote sensing program to detect terrestrial effects of cooling-tower

23 drift (NRC 1978). TVA developed these two monitoring activities to address the potential for

24 effects related to the WBN plant plume and the Watts Bar Fossil Plant plume merging. Because

25 TVA has never operated these two plants simultaneously, it has not conducted this monitoring

26 (NRC 1995). To determine the existence and extent of serious episodic collision mortality

27 events, the NRC recommended TVA initiate a monitoring program capable of detecting and

28 reporting such events during migratory periods (NRC 1978). After an unspecified amount of

29 monitoring for bird collisions with the cooling towers without any recorded notable episodes,

30 NRC (1995) deemed this monitoring unnecessary. The NRC also required the applicant to

31 provide an annual report regarding chemical control of vegetation along transmission corridors.

32 TVA does not conduct or propose to conduct any other terrestrial monitoring activities specific to

33 the WBN site. However, TVA has committed to surveying transmission corridors for the

34 presence of Federally protected species before conducting maintenance activities (NRC 1995)

35 and continuing to identify ecologically sensitive areas within transmission corridors as part of the

36 sensitive area review process (TVA 2009b).

Draft NUREG-0498, Supplement 2 5-4 September 2011
Environmental Measurements and Monitoring Programs

5.5.2 Aquatic Ecology Monitoring

1 TVA has collected monitoring data since 1970. Table 5-1 lists the monitoring studies that have

2 already been performed in the vicinity of the WBN site on both the Watts Bar Reservoir and the

3 Chickamauga Reservoir.

4 TVA conducted characterization studies of aquatic communities in the vicinity of the WBN site

5 as part of the preoperational monitoring program with the following objectives:

6 * phytoplankton (1973 through 1976) and zooplankton (1973 through 1975) to describe the

7 phytoplankton community at seven stations in different locations upstream and downstream

8 from the site and study the variation between all four seasons

9 o benthic organisms (organisms living on the substrate) (1973 through 1976) to describe the

10 benthic community by analyzing the colonization of artificial substrates by macrobenthos

11 and to identify the species of mussels in the vicinity of the WBN site during July and August

12 1975 and May and August 1976

13 # ichthyoplankton (fish eggs and larvae) (1976 and 1977 spawning seasons) to determine the

14 spatial and temporal concentrations and distributions of ichthyoplankton in the vicinity of the

15 WBN site

16 o fish (cove rotenone data from 1970, 1972, and 1973) for Chickamauga Reservoir at a site

17 downstream (Tennessee River Mile [TRM] 505-509) of the WBN site to identify species and

18 biomass. A sports fishing survey was conducted from 1972 through 1975 in Chickamauga

19 Reservoir and from January 1 to June 30, 1977 in Watts Bar Reservoir to estimate the

20 annual average sport harvest.

21 The NRC reported these data in the 1978 FES-OL (NRC 1978). This SFES does not discuss

22 the data further except to compare them with more recent sampling results. Since the 1978

23 FES-OL was published, TVA has conducted additional studies of the aquatic communities in the

24 Chickamauga and Watts Bar reservoirs in the vicinity of the WBN site. This SFES describes

25 these data to do the following:

26 * Characterize potential differences between aquatic communities above and below the site

27 and measure the impact of Unit 1 operations on aquatic communities.

28 o Characterize changes TVA observed in the environment as a result of operating WBN Unit 1

29 to measure any potential change that might be expected from operating proposed Unit 2.

30 * Provide a more thorough characterization of the aquatic communities of Watts Bar Reservoir

31 forebay in response to the continued use of the SCCW system, which began operating in

32 1999 to support WBN Unit 1 operations (after publication of the 1995 SFES-OL-1). The

33 SCCW has an intake located above Watts Bar Dam (TRM 529.9). TVA will also use this

34 system for WBN Unit 2, as discussed in Section 2.2.1 (Hydrology).

35 A description of additional survey studies performed since publication of the 1978 FES-OL, as

36 well as future monitoring planned by TVA follows.

September 2011 5-5 Draft NUREG-0498, Supplement 2
z

C,

X

CD1

CD

1 Table 5-1. Aquatic Biota Sampling Studies Performed in the Vicinity of the WBN Site

Type of Sampling Year Purpose Sampling Method Schedule Location Reference

Phytoplankton and 1973-1976 Preoperational Phytoplankton - Mid- Quarterly TRM 532.1, TVA (1986)

zooplankton monitoring

1982-1985 Preoperational

monitoring

1973-1977 Preoperational

monitoring

channel with 8-L Van

Dorn bottle at 0.3, 1,

3 and 5 m (1, 3.3, 10

and 16 ft) depths

Zooplankton - 0.5 m

(1.6 ft) diameter

plankton net fitted

with #20 mesh nylon

bolting cloth.

Same as above with

samples collected in

triplicate.

Plexiglass plates

placed in metal or

polyvinyl chloride

support track,

1.5 dm 2 (23 in.2)

exposed area, 0.5 m

(1.6 ft) from water

surface

See above

Artificial substrates,

529.5, 528.0,

527.4,518,

506.6, 496.5

m

0

:3

CD

CD

3

(n

0-

K0

0

(0

3

Cn

Quarterly

Periphyton May/June;

August/September

0)

TRM 532.1,

529.5, 528.0,

527.4, 518,

506.6,496.5

TRMs 506.6,

518.0, 527.4,

528.0, 529.5;

TRM 496.5

(1977 only)

TRMs 496.5,

506.6, 518.0,

527.4, 528.0,

529.5;

496.5, 506.6,

518.0, 527.4,

528.0 and 529.9

TVA (1986)

NRC (1978);

TVA (1986)

1982-1985 Preoperational

monitoring

1973-1976 Preoperational

monitoring

Benthic

macroinvertebrates

Quarterly

Quarterly 1973-

1976; left for 90 days

from 1973-winter

1975. Changed to

30 days 1975-1977.

TVA (1986)

NRC (1978);

TVA (1986)

2

(I,

CD

3

0r

CD

0"
(n

CD -0

CD

CD

0)

Table 5-1. (contd)

Type of Sampling Year Purpose Sampling Method Schedule Location Reference

1983-1985 Preoperational Artificial substrates, Artificial substrates - Artificial TVA (1998a)

monitoring Hess sampler or by

hand for mussels

quarterly 1982-1985.

30-day colonization

period. Hess sampler

began in autumn

1983 and continued

for two seasons.

substrates -

TRM 496.5,

506.6, 518.0,

527.4, 528.0 and

529.5

Hess Sampling -

TRM 521.0,

526.3, 527.4,

528.0, and 528.5

TRM 521.0,

526.3, 527.4,

528.0, and 528.5

TRM 533.3; 527.4

TRM

520.5-528.5;

June 1978 - TRM

514.2 to 528.9

1996-1997 Operational

(Unit 1)

1999-current Operational

(Unit 1)

1975-1976; Preoperational

1978 monitoring

Mussels

cj

CDw

0)

CD

CD

Sept, 1983

Nov, 1983

July 1984

Nov 1984

July 1985

Oct 1985

July 1986

Oct 1986

July 1988

July 1990

1992, 1994

Preoperational

Hess sampler

Ponar sampler and

Peterson sampler

Brailing and random

scuba dives (1975 -

1976); timed scuba

dives (1978)

Timed scuba dives -

1983 to 1985 - two

pair scuba divers

collected for 11

minutes each in four

sampling sites in

each of three mussel

beds.

1985-1994 - two

divers 22 minutes

each from each of

three mussel beds.

Timed scuba dives -

two divers; 22

minutes at each of

four sampling sites in

each of three mussel

beds.

July-September;

October-December

Annually during the

autumn

July 1975-August

1977, June 1978

TVA (1998a)

Simmons and

Baxter (2009)

NRC (1978)

TRM 520-521,

TRM 526-527,

TRM 528-529

TVA (1998a)

m03

CD

(D

0)

CD3

(D

CL0

(00

(a

C,)

1996, 1997 Operational

(Unit 1)
z

CD

D.

CD3

CD

Table 5-1. (contd)

Type of Sampling Year Purpose Sampling Method Schedule Location Reference

1997 Prior to General survey May TRM 529.2 TVA (1 998b)

2010

operation of

SCCW

Operational

(Unit 1);

Preoperational

(Unit 2)

Preoperational

monitoring

Preoperational

monitoring

0( Fish 1970,1972,

1973

1977-1979

Four 100-m long

sampling transects at

each sampling

location; 10-rm2

sampling area;

additional sampling

in boulder sampling

site; quantitative

samples at end of

transect. Total of

120 semi-quantitative

and 40 quantitative

samples.

Cove rotenone

studies

5 electrofishing runs

per month; timed

3 minutes per run

5 electrofishing

runs/month; 100 

m

(330 ft) per run;

included young 

- of

the year 

- individuals

15 electrofishing

runs; 200 m (660 ft)

of shoreline/run; did

not include young of

the year individuals

15 electrofishing

runs; 200 m (660 ft)

of shoreline/run; did

not include young of

the year individuals

September 28 and

30,2010

TRM 505-509

1982-1985 Update of

preoperational

monitoring

1990-1995 TVA Reservoir

Vital Signs

Monitoring

(preoperational)

1996-1997 TVA Reservoir -a Vital Signs "10

(Monitoring

3 o" (operational)

CID

TRM 528-529L;

TRM 526-527R;

TRM 520-521 L;

Boulder field at

approximately

TRM 529.5

TVA (2011b)

m03

CDM

CDw(n

CID 3

CD

Cl)

0)

0. 00

-o"13 3

in

Monthly, March

1977-November

1979

Monthly, March

1982-December

1985

Once each fall

(OctoberNovember);

Once each fall

(OctoberNovember);

TRM 528

TRM 528

TRM 526-529.9

TRM 526-529.9

NRC (1978)

NRC (1978)

and TVA

(1986)

TVA (1998a)

TVA (1998a)

TVA (1998a)
CI)

CD

CD

C)

Table 5-1. (contd)

Type of Sampling Year Purpose Sampling Method Schedule Location Reference

Fish 1999, 2000, Continued

2001,2002,

2003,2004,

2005,2006,

2007,2008

monitoring as

required by

WBN's NPDES

permit

TNO020168.

electrofishing;

15 runs, 300 

m

(980 ft) long,

approximately

10 minutes

each. Upstream

of WBN gill nets - 30.5 m (100.1

ft) mesh sizes

vary between

2.5 and 12.7 cm

(1 and 5 in.).

10 overnight

experimental gill

net sets.

Electrofishing 

-

15 boat runs near the

shoreline - each

300 m (980 ft) long

with a duration of

approximately

10 minutes each.

Nearshore area

sampled is

approximately

4500 m (14,800 ft);

Gill nets - Five 6.1 m

panels for a total

length of 30.5 m

(100.1 ft). Mesh size

varies between

panels; sizes 2.5,

5.1, 7.6, 10.2 and

12.7 cm (1, 2, 3, 4,

5 in.). Set

perpendicular to river

flow extending from

nearshore to main

channel of reservoir.

Ten overnight gill

nets.

Electrofishing -

30 minutes of

continuous

electrofishing per

site.

Once each fall TRM - 527.4 Simmons and

(October -

November)

TRM 533.3;

upstream and

downstream of

WBN

Baxter (2009)

m03

CD

CD

0)

Cn

CD3

Cn

0~0

(0

(n

('10

6)

Co

CD

(D

K)

1995-2008 Spring sportfish

surveys

Annually in the

spring (typically

March and April)

Watts Bar

Reservoir- 12

sites - Watts Bar

Dam, Blue

Springs and

Caney Creek;

Chickamauga

Reservoir - 12

sites - Harrison

Bay, Sale Creek,

and Ware

Branch.

Simmons and

Baxter (2008)
zM

0P,

C,,

CD

CD

Table 5-1. (contd)

Type of Sampling Year Purpose Sampling Method Schedule Location Reference

Impingement 2005-2006 Demonstration

for SCCW intake

1996-1997 Operational

monitoring (Unit

1)

2010-2011 Operational

monitoring (Unit

1);

Preoperational

(Unit 2)

Ichthyoplankton and

Entrainment

1975

C3

Operational

monitoring for

Watts Bar Fossil

Plant (intake in

Watts Bar

Reservoir)

Operational

monitoring for

WBN Unit 

1

(SCCW in Watts

Bar Reservoir)

Weekly screen wash

samples 

- 24 hour

collection

Weekly screen

washing samples 

-

24 hour collection

Weekly screen wash

samples 

- 24 hour

collection

Beam net (0.5 

m

[1.6 ft] square, 1.8 

m

[5.9 ft] long with

505 micron "nitex"

mesh netting) towed

upstream at speed of

1.0 m/s (3.3 ft/s) for

10 minutes.

Approximately

150 m3 (5,300 ft3

) of

water filtered per 10-

minute sample.

Beam net (0.5 

m

[1.6 ft] square, 1.8 

m

[5.9 ft] long with

505 micron "nitex"

mesh netting) towed

upstream at speed of

1.0 m/s (3.3 fi/s) for

10 minutes.

Approximately

150 m3 (5,300 ft

3

) of

water filtered per 10-

minute sample.

August 2005 to 2007;

weekly samples

March 1996 -

February 1997 (36

samples; March

1997- September

1997 (21 samples)

March 26, 2010-

March 17, 2011

10 sampling periods

between March 24,

1975 and July 28,

1975; biweekly

sampling.

Weekly from April to

June 2000

IPS screens

IPS screens

Five transects on

the reservoir.

Pumped samples

from three of the

six intake screen

wells.

Same transects

as the 1975 study

TVA (1998a)

SCCW intake TVA (2008c)

screens

TVA (2011e)

TVA (1976)

0

CD

(D

CD

CD

CL

0)

=30

3D

(a

2000 Baxter et al.

2001)

CD,

CD

-0

CD

N)

0?
C,)

CD

CD

CDM

Table 5-1. (contd)

Type of Sampling Year Purpose Sampling Method Schedule Location Reference

1976-1979 Preoperational

monitoring (IPS

in

Chickamaugua

Reservoir)

1982-1985 Update of

preoperational

monitoring

01

Beam net (0.5 m

[1.6 ft] square, 1.8 

m

[5.9 ft] long with

505 micron "nitex"

mesh netting) towed

upstream at speed of

1.0 m/s (3.3 ft/s) for

10 minutes.

Approximately

150 m3 (5,300 ft3

) of

water filtered per 10-

minute sample.

As described above.

In addition, samples

in intake were

collected (four

4-minute samples

from plant intake

pump building to

mouth of intake

channel.

As described above,

only the Intake

channel samples

were four 1-minute

samples from trash

boom to mouth of

channel.

Approximately

40-50 m'

(1,400-1,500 ft3

) of

water per intake

sample

schedule during

March-August

along a transect

perpendicular to

river flow

upstream of the

intake channel

(TRM 528)

Biweekly on a diel Five stations TVA (1986)

Biweekly on a diel

schedule during

March-August

Biweekly on a diel

schedule during

April-June

Five stations

along a transect

perpendicular to

river flow

upstream of the

intake channel

(TRM 528). In

1984-1985,

towed samples

also collected in

intake channel

samples)

Five stations

along a transect

perpendicular to

river flow

upstream of the

intake channel

(TRM 528); and

in intake channel

(four 4-minute

samples)

TVA (1998a)

0

CD

0)

CD

a)

Cn

(D

CD

Cn

a)

CL0

Co

0)

Cn

z

C: X

G) 6

Co

OD

CJ)

C:

CD

I'3

1996-1997 Operational

monitoring (Unit

1)

TVA (1998a)
z

CD

00

Cn

3

CD

:3

Table 5-1. (contd)

Type of Sampling Year Purpose Sampling Method Schedule Location Reference

2010 Operational Four tow-net May 11-12, 2010; TRM 530.2; TRM WI-VA (2011 c)

monitoring (Unit samples; two each May 19-21, 2010; 529.9 (SCCW

1); during day and night May 25-27, 2010; intake); TRM 528

preoperational August 17-18, 2010; right descending

monitoring (Unit August 25-27, 2010; bank; TRM 528 -

2) August 30-31,2010 40% of reservoir

width from right

descending bank;

TRM 528 - 60%

of reservoir width;

TRM 528 - left

descending bank

TRM 528, bottom

of main channel.

2010 Operational Beam net (0.5 m Weekly samples Reservoir TVA (2011 d)

monitoring (Unit [1.6 ft] square, 1.8 m from April through samples at five

1); [5.9 ft] long with June on a diel stations along

preoperational 505 micron "nitex" schedule transect TRM

monitoring (Unit mesh netting) towed 528.4; four intake

2) upstream at speed of samples within

1.0 m/s (3.3 ft/s) for the IPS canal at

10 minutes. TRM 528

Approximately

150 m3 (5,300 ft3

) of

water filtered per 10-

minute sample..

TRM Tennessee River Mile.

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Environmental Measurements and Monitoring Programs

5.5.2.1 Phytoplankton and Zooplankton

1 As discussed in Section 2.3.2.1, plankton are small plants or animals that float, drift, or weakly

2 swim in the water column of any body of water. There are two main categories of plankton;

3 phytoplankton and zooplankton. Plankton, also known as "microscopic algae," contain

4 chlorophyll and require sunlight to live and grow. Zooplankton, are small microscopic animals,

5 mainly invertebrates (animals that are lacking a true vertebrate or backbone). In a balanced

6 ecosystem phytoplankton and zooplankton form the basis of the food chains and play key

7 ecosystem roles in the distribution, transfer, and recycling of nutrients and minerals.

8 TVA has conducted two studies to characterize the phytoplankton and zooplankton in the

9 vicinity of the WBN site. The first study occurred from 1973 to 1976 at seven locations from

10 TRM 496.5 to TRM 532.1. Between May 1982 through November 1985, TVA conducted

11 phytoplankton and zooplankton sampling quarterly at the same seven stations. The purpose of

12 the sampling was to obtain data to describe the phytoplankton community in the vicinity of the

13 site in terms of community structure, abundance, biomass, and productivity; and the

14 zooplankton community in terms of taxa, taxon dominance, and densities. TVA also

15 investigated the variations in the communities at different locations upstream and downstream

16 of the site, and look at the variation between all four seasons.

17 TVA continues to measure chlorophyll-a using Secchi depth measurements in the Watts Bar

18 forebay as a part of the Vital Signs Monitoring Studies initiated in 1990 (TVA 2008d). A Secchi

19 disk is a black and white disk that is used to determine the clarity of water. The disk is lowered

20 by hand into the water and the depth at which it can no longer be seen is recorded. The farther

21 the Secchi disk can be seen in the water, the clearer the water.

5.5.2.2 Periphyton

22 As described in Section 2.3.2, periphyton are organisms that grow on underwater surfaces.

23 They can include algae, bacteria, fungi, and other organisms. Periphyton plays an important

24 ecological role as a food source for invertebrates, frog larvae (commonly called "tadpoles"), and

25 some types of fish.

26 Periphyton sampling measurements were conducted between 1973 and 1977 during May/June

27 and August/September initially at five stations, although a sixth station at TRM 496.5 was added

28 in 1977. Sampling was discontinued and then resumed quarterly from 1982 through 1985 at the

29 same six stations. The purpose was to describe the benthic community by analyzing what types

30 of periphyton grew (specifically algal growths) and how quickly they grew on artificial substrates

31 (TVA 1986).

September 2011 5-13 Draft NUREG-0498, Supplement 2
Environmental Measurements and Monitoring Programs

5.5.2.3 Benthic Macroinvertebrates

1 As described in Section 2.3.2, benthic macroinvertebrates are animals that live all or part of their

2 lives on or near the bottom of streams or reservoirs. Invertebrates, as defined previously, are

3 animals that do not have a true backbone. Macroinvertebrates are animals that are large

4 enough to see with the human eye. Macroinvertebrates include animals such as flatworms,

5 roundworms, leeches, crustaceans, aquatic insects, snails, clams, and mussels. Benthic

6 macroinvertebrates are an important food source for other aquatic organisms, including fish.

7 Researchers use studies of benthic macroinvertebrate abundance and distribution to detect

8 major environmental changes because these animals do not migrate rapidly and generally do

9 not make major changes in location.

10 TVA conducted four sets of studies. The first was a preoperational study conducted from spring

11 1973 through autumn 1976. Sampling was conducted using artificial substrates that were made

12 of wire barbeque baskets filled with river stones of uniform size. They were placed at each

13 station and left to colonize for 90 days (1973-1975) or 30 days (1975-1977). Six sampling

14 stations were located at TRMs 496.5 to 529.9; however, the upstream station was relocated to

15 529.5 after autumn 1976 because the original site was not consistently exposed to river

16 currents.

17 During the period from 1983 tol 985, TVA conducted a second preoperational study again using

18 artificial substrates between TRMs 496.5 and 529.5. Hess samplers (circular frame with an

19 attached net of 0.5-mm (0.02-in.) mesh that encloses a surface area of approximately 0.09 m2

20 (1 ft2) was used to obtain the samples (TVA 1998a; EPA 2003) were used from 1983 to 1985

21 between TRMs 521 and 528.5.

22 TVA conducted the third set of studies as operational (1996 to 1997) studies using a Hess

23 sampleter during summer (July to September) and fall (October to December) quarters at TRMs

24 521.0, 526.3, 527.4, 528.0, and 528.5 in the upper Chickamauga Reservoir to determine the

25 structure of the community, spatial distribution, and temporal variability (TVA 1986, 1998a).

26 TVA conducted the fourth set of studies each autumn starting in 1999. TVA collects benthic

27 macroinvertebrates in the forebay of the Watts Bar Dam (TRM 533.3) and in the inflow of the

28 Chickamauga Reservoir (TRM 527.4) as part of its annual monitoring program (Simmons and

29 Baxter 2009). TVA staff performs 10 benthic grab samples using a Ponar sampler in most

30 areas and a Peterson sampler when it encounters heavier substrates (Simmons and Baxter

31 2009). The samplers penetrate the substrate and then enclose bottom substrate material with

32 either spring- or gravity-operated mechanisms. The surface area sampled ranges from 0.02 m2

33 (0.21 ft2) for the Ponar to 0.089 m2 (0.96 ft2) for the Peterson sampler (EPA 2003). TVA is

34 continuing to conduct benthic macroinvertebrate sampling as part of the Reservoir Vital Signs

35 Monitoring program (IVA 2008d, e).

Draft NUREG-0498, Supplement 2 5-14 September 2011
Environmental Measurements and Monitoring Programs

5.5.2.4 Freshwater Mussels

1 TVA has conducted two sets of preoperational monitoring and two different operational

2 monitoring studies of the mussels in the three known concentrations of mussels (mussel beds)

3 downstream of the Watts Bar Dam near the WBN site.

4 TVA conducted preoperational monitoring, during five qualitative or quantitative collections from

5 July 1975 through August 1977 between TRMs 520.5 and 528.5 and in June 1978 between

6 TRMs 514.2 and 528.9.

7 TVA also conducted a second set of preoperational monitoring surveys 12 times before the start

8 of operation of WBN Unit 1 starting in 1983 and continuing to 1994, to identify the species of

9 mussels in the vicinity of the site and their abundance. TVA used time scuba dives to sample

10 the mussels in three known monitoring sites located from TRM 520 to 521 on the left

11 descending bank of the river, from TRM 526 to 527 on the right descending bank, and from

12 TRM 528 to 529 on the left descending bank (TVA 1998a). TVA also surveyed the vicinity of

13 the SCCW discharge (TRM 529.2) in 1997.

14 TVA conducted two operational studies at the same sites and using the same techniques as

15 used in the previous sets of preoperational monitoring in 1994 and 1996 after WBN Unit 1

16 began operation.

17 To supplement the previous studies, TVA conducted additional mussel surveys in 2010 to

18 characterize species composition and relative abundance of juveniles and adult freshwater

19 mussel fauna (TVA 2011 b, d). Section 2.3.2.1 reports the results of the surveys from 2010 with

20 provides a comparison with the results of the previous sampling studies. In addition, during

21 2010, TVA conducted a survey of the four experimental plots discussed in Section 2.3.2 that

22 occur within a boulder field approximately 1.6 km (1 mi) downstream from Watts Bar Dam

23 (TRM 528.3 to 528.8) to determine if habitat enhancement has improved the survival of the

24 freshwater mussels. However, only two historic sampling stations were located and few

25 mussels were identified, as discussed in Section 2.3.2.1.

5.5.2.5 Fish

26 TVA has conducted sampling studies to determine the populations of fish and ichthyoplankton

27 (fish eggs and larvae) in the Tennessee River in the vicinity of the WBN site. Sampling of fish

28 populations, especially near the WBN site, has occurred fairly consistently over the past 40

29 years.

30 TVA performed sampling on the fish community in the vicinity of the WBN site prior to the start

31 of operations of WBN Unit 1. The first studies, as reported in the FEIS for Watts Bar Unit 1

32 (NRC 1978), occurred downstream of the plant (TRM 504 to 509) were sampled using rotenone

33 in the early 1970s (1970, 1972, and 1973). Starting in 1977 the sampling was conducted using

September 2011 5-15 Draft NUREG-0498, Supplement 2
Environmental Measurements and Monitoring Programs

1 electrofishing techniques (TVA 2010a, 1998b). TVA conducted a second set of sampling

2 studies from March 1977 through November 1979. The sampling consisted of timed (five 3-

3 minute duration) electrofishing runs performed monthly. From March 1982 to December 1985,

4 TVA conducted a third set of sampling studies on a monthly basis to update the preoperational

5 fish community monitoring data. These sampling studies used five distance-based 100-m (328-

6 ft) electrofishing runs. Beginning in 1990, the sampling schedule changed to once each fall with

7 15 electrofishing runs of 200 m (656 ft). The sampling was continued as a part of the TVA

8 Reservoir Vital Signs Monitoring program (Simmons and Baxter 2009) and continued through

9 1995 as preoperational studies.

10 TVA continued the sampling as part of the Reservoir Vital Signs Monitoring program after the

11 start of WBN Unit 1 operations in 1996. The sampling was similar to that in previous years.

12 Because it takes place after the start of operations of WBN Unit 1, it is operational monitoring

13 (TVA 1998b, 2010).

14 The TVA Reservoir Vital Signs Monitoring program continued from 1999 to the present with

15 additional gill netting in the Watts Bar Reservoir. In addition, as requested by EPA Region IV,

16 TVA conducts additional aquatic community monitoring for facilities, including the WBN plant,

17 that have alternative thermal limits to verify that balanced indigenous populations of aquatic life

18 were being maintained (Simmons and Baxter 2009). Since 1999, TVA researchers have

19 conducted fish sampling downstream of Watts Bar Dam (and largely downstream of the WBN

20 plant discharge) using boat electrofishing and upstream of the Watts Bar Dam using

21 electrofishing and gill netting. Electrofishing samples consist of 15 electrofishing boat runs near

22 the shoreline. Each run covers about 300 m (980 ft) and takes approximately 10 minutes.

23 Researchers use experimental gill nets to collect fish from deeper habitats above the Watts Bar

24 Dam, which are not easily sampled using electrofishing techniques. TVA does not use gill nets

25 downstream of the WBN site because of high water velocities. Figure 5-1 and Figure 5-2 show

26 the locations of electrofishing and gill net sampling (Figures 2 and 3 of Simmons and Baxter

27 2009). Sampling locations on Chickamauga Reservoir occur upstream and downstream of the

28 intake canal, the SCCW system discharge, and the submerged diffuser.

29 TVA also conducts sport fishing surveys annually in March/April on both the Watts Bar and

30 Chickamauga reservoirs using a boat-mounted electrofishing unit. These surveys are

31 conducted to evaluate the sport fish population on the TVA reservoirs. The surveys have been

32 conducted since 1995 and target three species of black bass (largemouth, smallmouth, and

33 spotted bass) and black and white crappie. TVA samples 12 locations on each reservoir at

34 three different sites for 30 minutes per location. Sampling sites are located at Harrison Bay,

35 Ware Branch, and Sale Creek on the Chickamauga Reservoir. Sampling sites on the Watts Bar

36 Reservoir are located at Watts Bar Dam, Blue Springs, and Caney Creek (Baxter and Simmons

37 2008).

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Environmental Measurements and Monitoring Programs

5.5.2.6 Impingement

1 TVA conducted a fish impingement demonstration for the SCCW intake as part of the Clean

2 Water Act Section 316(b) monitoring program from August 2005 to August 2007 (TVA 2008c).

3 TVA conducted weekly impingement monitoring by rotating the intake screens and washing

4 them on prearranged schedules. Every 24 hours, TVA rotated and washed the screens, and

5 collected the fish and debris from the sluice pipe with dip nets. It sorted, identified, separated

6 into length classes, enumerated, and weighed the fish. The majority of fish collected were dead

7 when processed. TVA did not include fish that appeared to have been dead for more than

8 24 hours in the sample. TVA extrapolated impingement data from the weekly 24-hour samples

9 to estimate the total fish impinged by week and fish impingement for the year.

10 TVA began monitoring impingement at the intake pumping station (IPS) shortly before WBN

11 Unit 1 began producing power (TVA 1998a). TVA collected weekly screen-washing samples.

12 After leaving screens stationary for 24 hours to collect samples, TVA rotated and backwashed

13 them to remove impinged fish. Thirty-six samples were collected from March 1996, through

14 February 1997, and 21 samples from March 1997 through September 1997.

15 TVA conducted impingement monitoring at the IPS from March 26, 2010 through March 17,

16 2011 (TVA 201 le). TVA collected weekly screen-washing samples. TVA followed the same

17 procedures used in the 1996 to 1997 study to ensure consistency between the two studies. As

18 discussed in Section 4.3.2.2, the numbers of fish impinged were so low that the TDEC approved

19 a request by TVA to discontinue sampling as a result of the extremely low numbers of fish

20 impinged (TVA 1998a, 2010a).

21 In addition to conducting weekly impingement mortality sampling at the IPS (TRM 528) for a full

22 24-hour period from March 2010 for at least 1 year for prior to operation, TVA has committed to

23 conduct weekly impingement mortality sampling for one year of operational monitoring following

24 the start of WBN Unit 2 (TVA 201 Ob).

5.5.2.7 Entrainment (includes ichthyoplankton studies)

25 Two studies related to entrainment or ichthyoplankton density on the Watts Bar Reservoir exist

26 for the SCCW system. The first (TVA 1976) was conducted in 1975 when the SCCW system

27 was used as the intake for the Watts Bar Fossil Plant. The flow of water into the intake ranged

28 from 0.45 x 106 m3

/d or 5.23 m3

/s (185 ft3/s) to 1.11 x 106 m3/d or 12.8 m3/s (452 ft3/s) (TVA

29 1976), which is almost twice the flow that will be used for both WBN Units 1 and 2. Sampling

30 occurred during 10 sampling periods between March 24, 1975 and July 28, 1975, at 5 transects

31 in the reservoir. WVA obtained pumped samples from three of the six intake screen wells. WVA

32 conducted sampling biweekly.

September 2011 5-19 Draft NUREG-0498, Supplement 2
Environmental Measurements and Monitoring Programs

1 In spring 2000, TVA conducted the second study, a more recent study of ichthyoplankton

2 density to look at the spatio-temporal concentrations of ichthyoplankton near the WBN SCCW

3 intake (Baxter et al. 2001). Sampling was conducted weekly from April through June 2000

4 along the same transect and using equipment similar to that used in the 1975 study.

5 TVA conducted three sets of entrainment or ichthyoplankton density studies in the

6 Chickamauga Reservoir to characterize entrainment from the IPS. In the first set of studies,

7 TVA collected ichthyoplankton samples during preoperational (1976 to 1979, 1984 and 1985)

8 and operational (1996 and 1997) monitoring surveys (TVA 1998a) in the Chickamauga

9 Reservoir adjacent to the WBN site. TVA researchers sampled biweekly on a diel schedule

10 (day and night) at TRM 528.0, just upstream of the IPS intake channel. Sampling occurred from

11 March through August (preoperational) and from April through June (operational). TVA took

12 samples at five stations along a transect perpendicular to river flow using a beam net (0.5 m2

13 [1.6 ft], 1.8 m [5.9 ft] long with a 505-micron "nitex" mesh netting). The samples were collected

14 by towing the beam net upstream for 10 minutes at a speed of 1.0 m/s (3.3 ft/s). This resulted

15 in approximately 150 m3 (5,300 ftG) of water in each 10-minute sample. In 1984 and during

16 operational monitoring, TVA collected additional samples in the cooling-water intake channel. In

17 addition, preoperational samples from 1984 and 1985 also included four, 4-minute samples

18 taken biweekly on a diel schedule from the plant intake pump building to the mouth of the

19 channel. Each intake sample filtered approximately 40 to 50 m3 (1,400 to 1,766 ft3

) of water. In

20 comparison, the operational samples consisted of four, 1-minute samples (combined) from the

21 intake trash boom to the mouth of the intake channel.

22 In the second study, TVA conducted ichthyoplankton sampling during two hydrothermal surveys

23 during May and August 2010 above and below the dam (TVA 2011c). During two of the weeks,

24 sampling was conducted during releases from the dam. During one week, there were no

25 releases. TVA estimated abundance, distribution, and taxonomic composition of the

26 ichthyoplankton. The samples were taken by tow-net, using tows that were approximately

27 10-minutes long. The samples were obtained along a transect at TRM 530.2, in front of the

28 SCCW intake, and downstream of the dam at TRM 528.0 near each shoreline at 40 and 60

29 percent of the distance across the river. In addition, TVA obtained a bottom-drag sample from

30 the middle of the channel.

31 In addition, TVA collected weekly ichthyoplankton samples from April through June 2010 to

32 estimate entrainment mortality in fish as part of the preoperational monitoring for WBN Unit 2

33 (TVA 2011 d). TVA collected samples of the reservoir from five stations along a transect at TRM

34 528.4, using the same procedures used in the 1996 and 1997 sampling program discussed

35 previously. TVA plans to continue monitoring during 2011 (TVA 2011 d). Furthermore, TVA

36 plans to continue sampling for at least 2 years after WBN Unit 2 begins operation (TVA 2010b).

Draft NUREG-0498, Supplement 2 5-20 September 2011
Environmental Measurements and Monitoring Programs

5.6 Chemical Monitoring

5.6.1 Surface-Water Monitoring

1 TVA's chemical monitoring focuses on the three WBN facility outfalls. TVA performs semi2 annual Whole Effluent Toxicity (WET) tests (also called biotoxicity tests) of Outfall 101 and

3 Outfall 113 samples to confirm compliance with State water-quality criteria (IVA 2008e). WET

4 tests measure the wastewater effects on the test organisms' ability to survive, grow, and

5 reproduce. Section 4.3.2.5 describes the tests in more detail.

6 In addition, TVA monitors chlorine or Total Residual Oxidant (TRO) 5 days per week at Outfall

7 101 and Outfall 113 to ensure it meets discharge limits. The daily maximum discharge limit for

8 chlorine is 0.10 ppm and 0.158 Mg/L for TRO. Results of chemical monitoring are reported in

9 monthly discharge monitoring reports (for example TVA 2003b). Annual non-radiological

10 environmental operating reports (for example TVA 201 If) summarize any noncompliance with

11 monitoring requirements.

12 TVA historically monitored discharge from the construction runoff holding pond (see Section 3.2

13 and Figure 3-3) using an automated sampler at Outfall 112. This pond once received sewage14 treatment plant effluent and now receives only stormwater runoff. The NPDES permit for the

15 site (TDEC 2011) no longer requires monitoring this outfall.

5.6.2 Groundwater Monitoring

16 The NRC requires all power reactor licensees to implement a REMP (General Design Criterion

17 64, "Monitoring Radiological Releases", of Appendix A, "General Design Criteria for Nuclear

18 Power Plants" in Title 10 of the Code of Federal Regulations Part 50, "Domestic Licensing of

19 Production and Utilization Facilities"), which provides for groundwater monitoring. At the WBN

20 site, TVA monitors groundwater for radionuclide concentrations at six REMP groundwater

21 monitoring locations. These wells are equipped with automatic samplers. The plant collects

22 samples daily, composites them for 3 months, then analyzes the samples for gross beta,

23 gamma, and tritium. In addition to the six REMP monitoring wells, TVA monitors 19 non-REMP

24 wells to track the onsite groundwater plume to indicate the presence or increase of radioactivity

25 in the groundwater (TVA 2011 a).

5.7 Historic and Cultural Resource Monitoring

26 The National Historic Preservation Act (NHPA) (16 USC 470 et seq.) and the Archaeological

27 Resources Protection Act of 1979 (ARPA) (16 USC 470aa et seq.) address the protection of

28 significant archaeological resources and preservation of historic properties located on Federal

29 lands or Federal undertakings (TVA 2009c). As a result, TVA operates an extensive cultural

September 2011 5-21 Draft NUREG-0498, Supplement 2
Environmental Measurements and Monitoring Programs

1 resources management program and employs several archaeologists, a historian, and a historic

2 architect to identify, monitor, manage, and protect historic and cultural resources on TVA lands

3 or land affected by TVA actions (TVA 2009d).

4 The TVA Watts Bar Reservoir Land Management Plan examines the potential effects of several

5 alternative ways of managing its public lands on the Watts Bar Reservoir and includes the WBN

6 site (TVA 2009b). The TVA Watts Bar Reservoir Land Management Plan describes the a

7 programmatic agreement (PA) that was signed in 2005 between TVA, the Advisory Council on

8 Historic Preservation, and the Tennessee State Historic Preservation Office/Officer (SHPO).

9 The PA guides Section 106 (NHPA) compliance for TVA land considered in the Watts Bar

10 Reservoir Land Management Plan (TVA 2009e).

11 The TVA cultural resources management program reviews undertakings on its plant

12 properties on a project-by-project basis. TVA conducts surveys and completes projects in

13 consultation with the SHPO and Federally recognized Indian Tribes. TVA considers

14 transmission-line maintenance reviews as sensitive area reviews. TVA conducts the reviews for

15 its transmission-line operations and maintenance activities associated with WBN Unit 1 and

16 would use them for WBN Unit 2 (TVA 2009f). TVA coordinates the sensitive area reviews with

17 TVA cultural resources staff to conduct specific Section 106 reviews. In addition, TVA

.18 developed erosion control measures for WBN Unit 1, which it would also use for WBN Unit 2

19 (TVA 2009e).

20 During operation and maintenance of WBN Unit 2, TVA would implement procedures identifying

21 actions it would take if historic or cultural resource materials are encountered. TVA follows the

22 requirements of implementing regulations of the Native American Graves Protection and

23 Repatriation Act (25 USC 3001 et seq.) for the inadvertent discovery of human remains. TVA

24 has identified Federally recognized Indian Tribes with a demonstrated interest in the Tennessee

25 Valley. When human remains are inadvertently discovered on TVA-managed lands, all work

26 ceases, remains secured, and TVA notifies all Tribes within 3 working days of discovery

27 (TVA 2009e).

5.8 References

28 10 CFR Part 50. Code of Federal Regulations, Title 10, Energy, Part 50, "Domestic Licensing of

29 Production and Utilization Facilities."

30 Archaeological Resources Protection Act of 1979 (ARPA). 16 USC 470aa et seq.

31 Baxter, D.S., K.D. Gardner, and G.D. Hickman. 2001. Supplemental Condenser Cooling Water

32 System Fish Monitoring Program. Final Report, January 2001. Tennessee Valley Authority.

33 Accession No. ML073510313.

Draft NUREG-0498, Supplement 2 5-22 September 2011
Environmental Measurements and Monitoring Programs

1 Baxter, D.S. and J.W. Simmons. 2008. Biological Monitoring of the Tennessee River near

2 Watts bar Nuclear Plant Discharge. Tennessee Valley Authority. Accession No. ML073510313.

3 National Historic Preservation Act. 16 USC 470 et seq.

4 Native American Graves and Protection Repatriation Act. 25 USC 3001 et seq.

5 Proctor, W.D. and P.N. Hopping. 2007. Winter 2006 Compliance Survey for Watts Bar Nuclear

6 Plant Outfall 113 Passive Mixing Zone. Tennessee Valley Authority, Knoxville, Tennessee.

7 Accession No. ML073510313.

8 Simmons, J.W. and D.S. Baxter. 2009. Biological Monitoring of the Tennessee River Near

9 Watts Bar Nuclear Plant Discharge, 2008. Tennessee Valley Authority, Aquatic Monitoring and

10 Management, Chattanooga, Tennessee. Accession No. ML073510313.

11 Tennessee Department of Environment and Conservation (TDEC). 2011. State of Tennessee

12 NPDES Permit No. TN0020168. TVA -Watts Bar Nuclear Plant, Spring City, Rhea County,

13 Tennessee. Accession No. ML1 1215A099.

14 Tennessee Valley Authority (TVA). 1976. Estimates of Entrainment of Fish Eggs and Larvae

15 by Watts Bar Steam Plant, 1975, and Assessment of the Impact on the Fisheries Resource of

16 Watts Bar Reservoir. Norris, Tennessee. Accession No. ML073510313.

17 Tennessee Valley Authority (TVA). 1986. Preoperational Assessment of Water Quality and

18 Biological Resources of Chickamauga Reservoir, Watts Bar Nuclear Plant, 1973-1985.

19 TVA/ONRED/WRF-87/la. Knoxville, Tennessee. Accession No. ML073510313.

20 Tennessee Valley Authority (TVA). 1998a. Aquatic Environmental Conditions in the Vicinity of

21 Watts Bar Nuclear Plant During Two Years of Operation, 1996-1997. Norris, Tennessee.

22 Accession No. ML073510313.

23 Tennessee Valley Authority (TVA). 1998b. Watts Bar Nuclear Plant Supplemental Condenser

24 Cooling Water Project, Environmental Assessment, August 1998. Knoxville, Tennessee.

25 Available at http://www.tva.govlenvironment/reports/wattsbar2/relatedlaug_1998. pdf.

26 Tennessee Valley Authority (TVA). 2003a. Watts Bar Nuclear Plant Unit I and 2 - Annual

27 Radiological Environmental Operating Report - 2002. Knoxville, Tennessee. Accession No.

28 ML031400811.

29 Tennessee Valley Authority (TVA). 2003b. Watts Bar Nuclear Plant (WBN) - National Pollutant

30 Discharge Elimination System (NPDES) Permit No. TNO020168 - Discharge Monitoring Report

31 (DMR) for February 2003 and Notice of Upset. Nashville, Tennessee. Accession No.

32 ML030830137.

September 2011 5-23 Draft NUREG-0498, Supplement 2
Environmental Measurements and Monitoring Programs

I Tennessee Valley Authority (TVA). 2008a. Watts Bar Nuclear Plant Unit I - Annual

2 Radiological Environmental Operating Report - 2007. Knoxville, Tennessee. Accession No.

3 ML081430029.

4 Tennessee Valley Authority (TVA). 2008b. Watts Bar Nuclear Plant - Unit I - 2008 Annual

5 Radioactive Effluent Release Report. Tennessee Valley Authority. Accession No.

6 ML091260371.

7 Tennessee Valley Authority (TVA). 2008c. Letter from Masoud Bajestani (Watts Bar Unit 2,

8 Vice President) to U.S. Nuclear Regulatory Commission dated July 2, 2008 in response to NRC

9 letter dated June 3, 2008 and TVA letters February 15, 2008 and June 16, 2008, "Watts Bar

10 Nuclear Plant (WBN) - Unit 2 - Final Supplemental Environmental Impact Statement - Request

11 for Additional Information (TAC MD8203)." Accession No. MLO081850460.

12 Tennessee Valley Authority (TVA). 2008d. Letter from Jack A. Bailey (Nuclear Generation

13 Development, Vice President) to U.S. Nuclear Regulatory Commission dated June 11, 2008 in

14 response to TVA letter dated October 30, 2007, "Nuclear Regulatory Commission (NRC) -

15 Bellefonte Nuclear Plant (BLN) - Response to NRC Information Needs Related to Reservoir

16 Vital Signs Monitoring Reports and Coal Gasification Project Environmental Impact Statement."

17 Accession No. ML081970366.

18 Tennessee Valley Authority (TVA). 2008e. Final Supplemental Environmental Impact

19 Statement; Completion and Operation of Watts Bar Nuclear Plant Unit 2, Rhea County,

20 Tennessee submitted to NRC as the TVA Environmental Report for an Operating License,

21 Knoxville, Tennessee. Accession No. ML080510469.

22 Tennessee Valley Authority (TVA). 2009a. Watts Bar Nuclear Plant (WBN) - Unit 2 - Final

23 Safety Analysis Report (FSAR), Amendment 94. Spring City, Tennessee. Accession No.

24 ML092460757.

25 Tennessee Valley Authority (TVA). 2009b. Watts Bar Nuclear Plant (WBN) Unit 2 - Additional

26 Information Regarding Environmental Review - Cultural Resources. Accession No.

27 ML101180044.

28 Tennessee Valley Authority (TVA). 2009c. Tennessee Valley Authority, Cultural Resources.

29 Accessed December 19, 2009 at

30 http://www.tva.gov/river/landandshore/culturalresources/index. htm.

31 Tennessee Valley Authority (TVA). 2009d. Watts Bar Reservoir Land Management Plan.

32 Knoxville, Tennessee. Available at http://www.tva.gov/environment/reports/wattsbar/index.htm.

33 Tennessee Valley Authority (TVA). 2009e. Letter from Masoud Bajestani (Watts Bar Unit 2,

34 Vice President) to U.S. Nuclear Regulatory Commission dated December 23, 2009 in response

35 to NRC letter dated December 3, 2009 and TVA letters dated February 15, 2008, July 2, 2008,

Draft NUREG-0498, Supplement 2 5-24 September 2011
Environmental Measurements and Monitoring Programs

1 and January 27, 2009, "Watts Bar Nuclear Plant (WBN) Unit 2 - Additional Information

2 Regarding Environmental Review (TAC No. MD8203)." Accession No. MLI100210350.

3 Tennessee Valley Authority (TVA). 2009f. Final Environmental Impact Statement: Watts Barr

4 Reservoir Land Management Plan for Loudon, Meigs, Rea, and Roane Counties, Tennessee.

5 Knoxville, Tennessee.

6 Tennessee Valley Authority (TVA). 2010a. Letter from Masoud Bajestani (Watts Bar Unit 2,

7 Vice President) to U.S. Nuclear Regulatory Commission dated July 2, 2010, "Watts Bar, Unit 2 -

8 Submittal of Additional Information Requested during May 12, 2010, Request for Additional

9 Information (RAI) Clarification Teleconference Regarding Environmental Review." Accession

10 No. ML101930470.

11 Tennessee Valley Authority (TVA). 201 Ob. Letter from Masoud Bajestani (TVA, Watts Bar Unit

12 2 Vice President) to U.S. Nuclear Regulatory Commission dated April 9, 2010, "Watts Bar

13 Nuclear Plant (WBN) Unit 2 - Response to U.S. Nuclear Regulatory Commission (NRC)

14 Request for Additional Information Regarding Environmental Review (TAC No. MD8203)."

15 Accession No. ML101130393.

16 Tennessee Valley Authority (TVA). 201 la. Watts Bar Nuclear Plant - Unit 1 - 2010 Annual

17 Radioactive Effluent Release Report. Knoxville, Tennessee. Accession No. ML1 11126A180.

18 Tennessee Valley Authority (TVA). 201 lb. Letter from Edwin E. Freeman (Watts Bar Unit 2,

19 Engineering) to U.S. Nuclear Regulatory Commission dated January 4, 2011, "Watts Bar

20 Nuclear Plant (WBN) Unit 2 - Additional Information Related to U.S. Nuclear Regulatory

21 Commission (NRC) Request for Additional Information (RAI) Regarding Environmental Review."

22 Accession No. ML1 10060510.

23 Tennessee Valley Authority (TVA). 2011 c. Letter from Marie Gillman (Watts Bar Unit 2 Vice

24 President, Acting) to U.S. Nuclear Regulatory Commission dated February 7, 2011, "Submittal

25 of 'Hydrothermal Effects on the Ichthyoplankton from the Watts Bar Nuclear Plant Supplemental

26 Condenser Cooling Water Outfall in Upper Chickamauga Reservoir' Report." Accession No.

27 ML110400383 (submittal), ML110400384 (enclosure).

28 Tennessee Valley Authority (TVA). 2011 d. Letter from David Stinson (Watts Bar Unit 2, Vice

29 President) to U.S. Nuclear Regulatory Commission dated March 24, 2011, "Watts Bar Nuclear

30 Plant (WBN) Unit 2 - Additional Information Related to U.S. Nuclear Regulatory Commission

31 (NRC) Regarding Environmental Review." Accession No. ML110871475.

32 Tennessee Valley Authority (TVA). 201 le. Letter from Edwin E. Freeman (Watts Bar Unit 2

33 Engineering Manager) to U.S. Nuclear Regulatory Commission dated March 28, 2011, "Watts

September 2011 5-25 Draft NUREG-0498, Supplement 2
Environmental Measurements and Monitoring Programs

1 Bar Nuclear Plant (WBN) Unit 2 - Additional Information Related to U.S. Nuclear Regulatory

2 Commission (NRC) Environmental Review." Accession No. ML110890472.

3 Tennessee Valley Authority (TVA). 201 if. Watts Bar Nuclear Plant Annual Non-Radiological

4 Environmental Operating Report, February 7, 2010, Through February 6, 2011. Accession No.

5 ML11133A364.

6 U.S. Atomic Energy Commission (AEC). 1972. Onsite Meteorological Programs. Safety Guide

7 23 (Regulatory Guide 1.23), Washington, D.C.

8 U.S. Environmental Protection Agency (EPA). 2003. "Appendix G, Aquatic Resources." in EPA

9 and Hardrock Mining: A Source Book for Industry in the Northwest and Alaska. Seattle,

10 Washington. Available at

11 http://yosemite.epa.gov/Rl0WATER.NSF/Sole+Source+Aquifers/hardrockmining.

12 U.S. Nuclear Regulatory Commission (NRC). 1978. Final Environmental Statement Related to

13 Operation of Watts Bar Nuclear Plant Units Nos. I and 2. NUREG-0498, Washington, D.C.

14 Accession No. ML082540803.

15 U.S. Nuclear Regulatory Commission (NRC). 1995. Final Environmental Statement Related to

16 the Operation of Watts Bar Nuclear Plant Unit 1 and 2. NUREG-0498, Supplement No. 1,

17 Washington, D.C. Accession No. ML081430592.

18 U.S. Nuclear Regulatory Commission (NRC). 2007. Regulatory Guide 1.23 - Meteorological

19 Monitoring Programs for Nuclear Power Plants. Rev. 1, Washington, D.C.

Draft NUREG-0498, Supplement 2 5-26 September 2011
1 6.0 Environmental Impacts of Postulated Accidents

2 Involving Radioactive Materials

3 Previous environmental reports and impact statements have evaluated the environmental

4 consequences of postulated accidents related to the construction and operation of Watts Bar

5 Nuclear (WBN) Units 1 and 2. This chapter summarizes those evaluations and presents the

6 results of the U.S. Nuclear Regulatory Commission (NRC) staff's independent review of the

7 consequences of postulated accidents for WBN Unit 2 based on changes occurring since the

8 last NRC assessment.

9 The term "accident," as used in this chapter, refers to any off-normal event not addressed in

10 Section 4.6, Radiological Impacts of Normal Operations, resulting in release of radioactive

11 materials into the environment. The focus of this review is on events that could lead to releases

12 substantially greater than permissible limits for normal operations. Normal release limits are

13 specified in Title 10 of the Code of Federal Regulations (CFR) Part 20, Appendix B, Table 2.

14 Numerous features combine to reduce the risk associated with accidents at nuclear power

15 plants. Safety features in the design, construction, and operation of the plants, which compose

16 the first line of defense, are intended to prevent the release of radioactive materials from nuclear

17 plants. Additional measures are designed to mitigate the consequences of failures in the first

18 line of defense. These measures include the NRC's reactor site criteria in 10 CFR Part 100,

19 which require the site to have certain characteristics reducing the risk to the public and the

20 potential impacts of an accident, and emergency preparedness plans and protective action

21 measures for the site and environs, as set forth in 10 CFR 50.47, 10 CFR Part 50, Appendix E,

22 and NUREG-0654/FEMA-REP-1 (NRC 1980). All of these safety features, measures, and plans

23 make up the defense-in-depth philosophy to protect the health and safety of the public and the

24 environment.

25 Radioactive material exists in a variety of physical and chemical forms. The majority of the

26 material in reactor fuel is in the form of nonvolatile solids. However, a significant amount of

27 material is in the form of volatile solids or gases. The gaseous radioactive materials include the

28 chemically inert noble gases (e.g., krypton and xenon), which have a high potential for release.

29 Radioactive forms of iodine, created in substantial quantities in the fuel by fission, are volatile.

30 Other radioactive materials formed during the operation of a nuclear power plant have lower

31 volatilities and, therefore, have lower tendencies to escape from the fuel than the noble gases

32 and iodines.

33 Radiation exposure to individuals is determined by their proximity to radioactive material, the

34 duration of their exposure, and the extent to which they are shielded from the radiation.

35 Pathways leading to radiation exposure include (1) external radiation from radioactive material

September 2011 6-1 Draft NUREG-0498, Supplement 2
Environmental Impacts of Postulated Accidents Involving Radioactive Materials

1 in the air, on the ground, and in the water; (2) inhalation of radioactive material; and

2 (3) ingestion of food or water containing material initially deposited on the ground and in water.

3 Radiation protection experts assume that any amount of radiation may pose some risk of

4 causing cancer or a severe hereditary effect and that the risk is higher for higher radiation

5 exposures. Therefore, a linear, no-threshold dose response relationship is used to describe the

6 relationship between radiation dose and detriments such as cancer induction. A recent report

7 by the National Research Council (2006), the Biological Effects of Ionizing Radiation VII report,

8 uses the linear, no-threshold dose response model as a basis for estimating the risks from low

9 doses. This approach is accepted by the NRC as a conservative method for estimating health

10 risks from radiation exposure, recognizing the model may overestimate those risks.

11 Physiological effects are clinically detectable if individuals receive radiation exposure resulting in

12 a dose greater than about 0.25 Sv (25 rem) over a short period (hours). Doses of about 2.5 to

13 5 Sv (250 to 500 rem) received over a relatively short period (hours to a few days) can be

14 expected to cause some fatalities.

15 6.1 Design Basis Accidents

16 The postulated environmental consequences of design basis accidents (DBAs) for WBN were

17 initially evaluated in the 1972 Tennessee Valley Authority (TVA) Final Environmental Statement

18 related to the construction permit for WBN Units 1 and 2 (1972 FES-CP) (TVA 1972).

19 Appendix D of the 1972 FES-CP describes the evaluation of a full range of accidents ranging

20 from those which "may reasonably be expected to occur during the lifetime of the plant" to

21 accidents with a probability of occurrence that is "very small." This latter group of accidents is

22 currently referred to as DBAs. The predicted dose at the site boundary for each accident was

23 well within the 0.25-Sv (25-rem) limit set in 10 CFR Part 100 and the 80-km (50-mi) population

24 dose commitment for each accident was less than 1 person-Sv (100 person-rem) (TVA 1972).

25 In commenting on the 1972 TVA draft environmental statement, the Atomic Energy Commission

26 (AEC) provided its own estimates of the site boundary doses. These dose estimates, found on

27 page 7.1-8 and 7.1-9 of the 1972 FES-CP, are slightly lower than the TVA dose estimates.

28 Dose estimates for DBAs in the NRC's 1978 Final Environmental Statement related to the

29 operating license for WBN Units 1 and 2 (1978 FES-OL) (NRC 1978a) are consistent with and

30 slightly lower than the dose estimates in the AEC comments on the 1972 TVA draft

31 environmental statement.

32 In preparation of the NRC 1995 Supplement No. 1 to the Final Environmental Statement related

33 to the operating license (1995 SFES-OL-1) (NRC 1995), the staff reviewed its earlier DBA

34 calculations and noted that the only change in technical bases from the original DBA analyses

35 was in the population projection. The staff then added evaluation of an accident involving the

36 failure of a spent fuel resin storage tank. The projected consequence of this accident was also

37 less than 5 mSv (500 mrem).

Draft NUREG-0498, Supplement 2 6-2 September 2011
Environmental Impacts of Postulated Accidents Involving Radioactive Materials

1 At the time of the early environmental reviews in the 1970s, a proposed Annex to Appendix D of

2 10 CFR Part 50 contained guidance related to the calculation of the consequences of DBAs for

3 environmental reviews. Appendix D of 10 CFR Part 50 has been replaced by 10 CFR Part 51,

4 and the proposed Annex to Appendix D is Appendix I of Regulatory Guide 4.2 (NRC 1976),

5 which is still used. This guidance permits applicants to modify the accident assumptions from

6 those used in the conservative analysis for safety reviews to more realistic assumptions for

7 environmental reviews. This guidance related to evaluation of potential environmental

8 consequences of DBAs indicates the only difference between the conservative DBA dose

9 calculations for the safety review and realistic dose calculations for the environmental review is

10 in the atmospheric dispersion factors (T/Qs) used in the calculations.

11 Table 6-1 lists X/Qs the NRC staff considers pertinent to the environmental review of DBAs for

12 the WBN site. The first column lists the time periods and boundaries for which X/Q and dose

13 estimates are needed. For the exclusion area boundary, the postulated DBA dose and its X/Q

14 are calculated for a short term (i.e., 2 hours), and for the low population zone, they are

15 calculated for the course of the accident (i.e., 30 days 1720 hours]) composed of four time

16 periods. Section 2.8.4 discusses the calculation of the X/Q values.

17 Table 6-1. Atmospheric Dispersion Factors for WBN Site Environmental DBA Calculations

Time Period and Boundary )/Q (s/m 3)

0 to 2 hours, exclusion area boundary 5.78 x 10.5

0 to 8 hours, low population zone 7.15 x 10-6

8 to 24 hours, low population zone 6.16 x 106

1 to 4 days, low population zone 4.46 x 106

4 to 30 days, low population zone 2.81 x 10-6

18 Table 6-2 lists the set of DBAs the NRC staff considered and presents estimates of the

19 environmental consequences of each accident in terms of whole body for external radiation and

20 thyroid dose from inhaled radionuclides. The NRC presented the consequences in terms of

21 whole body and thyroid dose because the WBN Unit 2 application was submitted prior to

22 January 1997. The entries in Table 6-2 are from NRC staff dose calculations based on the X/Qs

23 in Table 6-1 and TVA DBA calculations described in information supplied by TVA in response to

24 NRC Requests for Additional Information (RAIs) (TVA 201 Oa, b). For consistency with the

25 licensing basis, NRC staff based thyroid dose calculations on the thyroid dose factors from

26 International Commission on Radiological Protection Publication 2 listed in Table E-7 of

27 Regulatory Guide 1.109 (NRC 1977). The review criteria used in the staff's safety review of

28 DBA doses are included in Table 6-2 to illustrate the magnitude of the calculated environmental

29 consequences (doses) because there are no environmental criteria related to the potential

30 consequences of DBAs. In all cases, the calculated values are considerably smaller than the

31 doses used as safety review criteria. The staff notes that Supplement 21 of the NRC Watts Bar

September 2011 6-3 Draft NUREG-0498, Supplement 2
Environmental Impacts of Postulated Accidents Involving Radioactive Materials

1 safety evaluation report (NRC 2009a) lists as open items several DBAs that are not discussed in

2 the Final Safety Analysis Report (FSAR). These accidents include Feedwater System Pipe

3 Break, Reactor Coolant Pump Rotor Seizure, Reactor Coolant Pump Shaft Break, and Failure of

4 Small Line Carrying Coolant Outside Containment. Because the NRC staffs independent

5 review of the DBAs determined that the DBA doses were considerably smaller than the safety

6 review criteria, the NRC staff concluded the environmental consequences are SMALL.

7 Table 6-2. Design Basis Accident Doses for WBN Unit 2

Doses in rem(a)

EAB LPZ Review Criterion

SRP Whole Whole Whole

Accident Section(b) Body Thyroid Body Thyroid Body Thyroid

Main Steamline Break

Pre-Existing Iodine 15.1.5 0.0024 0.41 0.0007 0.15 25(c) 300(c)

Spike

Accident Initiated Spike 15.1.5 0.0068 0.49 0.0066 0.059 2.5 30(c)

Loss-of-Coolant Accident 15.6.5 0.19 3.9 0.18 5.1 25(c) 3001c)

Steam Generator Tube Rupture

Pre-Existing Iodine 15.6.3 0.034 2.7 0.0061 0.46 25(c) 300(c)

Spike

Accident Initiated Spike 15.6.3 0.038 1.2 0.0068 0.21 2.5 30(c)

Loss of Alternating <0.0001 <0.0001 <0.0001 <0.0001

Current Power(e)

Waste Gas Decay Tank 0.055 0.0017 0.0091 0.0003

Rupture(e)

Fuel Handling Accident 15.7.4 0.039 5.2 0.0065 0.86 6 (d) 75(d)

Control Rod Ejection

AccidentO•

(a) To convert rem to Sv divide by 100.

(b) NUREG-0800 (NRC 2007).

(c) 10 CFR 100.11 and 10 CFR 50.34(a)(1) Criterion.

(d) Standard Review Plan (SRP) criterion.

(e) The TVA FSAR evaluated these accidents in the FSAR (TVA 2009) but they do not have a corresponding SRP

section. Nevertheless, the doses must meet the 10 CFR 100.11) criteria.

(f) The TVA FSAR discusses the Control Rod Ejection Accident and concludes that the doses from a Control Rod

Ejection Accident are bounded by the doses from a Loss-of-Coolant Accident.

8 6.2 Severe Accidents

9 TVA briefly addresses severe accidents for WBN Unit 2 in Section 3.1.1 of its Environmental

10 Impact Statement (TVA 2008) and more detailed information in a subsequent submittal on

Draft NUREG-0498, Supplement 2 6-4 September 2011
Environmental Impacts of Postulated Accidents Involving Radioactive Materials

1 severe accident mitigation design alternatives (SAMDAs) (TVA 2009b). TVA subsequently

2 submitted an updated SAMDA assessment using the latest dual-unit probabilistic risk

3 assessment (PRA) model for WBN (TVA 201 Oc). Potential impacts are presented for four

4 severe accident release categories - early containment failure, late containment failure,

5 containment bypass, and small pre-existing leak. In response to an NRC staff RAI, TVA states

6 that a fifth release category, intact containment, was not used because it accounts for minimal

7 offsite consequences (TVA 2011 a). The TVA assessment of the potential environmental

8 consequences incorporates the results of the MELCOR Accident Consequence Code System

9 (MACCS2) computer code (Chanin and Young 1998) run using WBN Unit 2 reactor source-term

10 information and WBN site-specific meteorological, population, and land-use data. WinMACCS

11 Version 3.6.0 was used to assess consequence. WinMACCS is an updated version of the

12 MACCS2 code that has an improved user interface.

13 Following initial review of the TVA ER, the staff asked TVA to provide additional information

14 related to severe accidents. TVA responded by providing the requested information under

15 cover letters dated October 22, 2009 (TVA 2009c), December 23, 2009 (TVA 2009d),

16 February 25, 2010 (TVA 2010a), April 9, 2010 (TVA 2010d), and January 31, 2011 (TVA

17 201 la). In addition to evaluating this information, the staff considered the severe accident

18 analysis for WBN Unit 1 contained in its 1995 SFES-OL-1 and the TVA WBN Unit 2 Individual

19 Plant Examination Summary Report dated February 9, 2010 (TVA 2010e).

20 The MACCS2 computer code was developed to evaluate the potential offsite consequences of

21 severe accidents for the sites covered by NUREG-1 150 (NRC 1990). The MACCS2 code

22 evaluates the consequences of atmospheric releases of material after a severe accident. The

23 pathways modeled include exposure to the passing plume, exposure to material deposited on

24 the ground and skin, inhalation of material in the passing plume and resuspended from the

25 ground, and ingestion of contaminated food and surface water.

26 NRC staff assessed two types of severe accident consequences: human health and economic

27 costs. The staff expressed human health effects in terms of the number of cancers that might

28 be expected if a severe accident were to occur. These effects are directly related to the

29 cumulative radiation dose received by the general population. NRC staff based population

30 health-risk estimates on the population distribution within an 80-km (50-mi) radius of the WBN

31 site.

32 Economic costs of a severe accident include the costs associated with short-term relocation of

33 people; decontamination of property and equipment; interdiction of food supplies, land, and

34 equipment use; and condemnation of property.

35 Risk is the product of the frequency and the consequences of an accident. For example, the

36 frequency of a severe accident with early containment failure for WBN Unit 2 is estimated to be

37 1.26 x 10-6/reactor-year (Ryr), and the cumulative population dose associated with a severe

September 2011 6-5 Draft NUREG-0498, Supplement 2
Environmental Impacts of Postulated Accidents Involving Radioactive Materials

1 accident with early containment failure at the site is calculated to be 2.96 x 104 person-Sv (2.96

2 x 106 person-rem). The population dose risk for this class of accidents is the product of

3 1.26 x 10-6/Ryr and 2.96 x 104person-Sv (2.96 x 106 person-rem), or 3.73 x 10.2 person-Sv/Ryr

4 (3.73 person-rem/Ryr). The following sections discuss the estimated risks associated with each

5 pathway.

6 The risks presented in the following tables are risks per year of reactor operation for WBN

7 Unit 2. However, two of the tables also include an estimate of population dose risk for WBN

8 Unit 1. At multi-unit sites such as the WBN site, where there are few shared support systems,

9 the designs minimize the likelihood that a severe accident affecting one unit will adversely affect

10 other units onsite. Consequently, for this evaluation, the severe accident risk at the site is

11 estimated as the sum of the risks for the individual units.

12 6.2.1 Air Pathway

13 The WinMACCS code directly estimates consequences associated with releases to the air

14 pathway. Table 6-3 presents risks based on results of the combination WinMACCS results

15 provided by TVA (TVA 201 1f) and the results of recent PRA insights (TVA 2010d). The core

16 damage frequencies (CDFs) and release frequencies given in these tables are for internally

17 initiated accident sequences while the facility is at power. Internally initiated accident sequences

18 include sequences initiated by human error, equipment failures, loss of offsite power, etc.

19 Table 6-3 Staff Estimates of Mean Environmental Risks from a WBN Unit 2 Reactor Severe

20 Accident

Release Population

Category Population Dose from

Description Release Dose Risk Latent Water Ingestion

(Accident Frequency (person- Fatalities (person- Cost(b)

Class) (per Ryr) rem/Ryr)(a) (per Ryr) rem/Ryr)(a) ($/Ryr)

Small pre- 3.8 - 10-6 1.2 7.4x 10-4 3.8 x 10'3 2,250

existing leak

Early

containment 1.3 x 10.6 3.7 2.2 x 10-3 4.5 x 10-2 8,000

failure

Late containment 1.3 x 10-5 14 8.5 x 10-3 0.12 41,500

failure

Containment 3.5 x 10-7 0.84 5.0 x 10-4 1.4 x 10'2 1,860 bypass Total 1.8 x 10-5 20 1.2 x 10-2 0.18 53,600

Draft NUREG-0498, Supplement 2 6-6 September 2011
Environmental Impacts of Postulated Accidents Involving Radioactive Materials

1

2

3

4

5

6

7

8

Table 6-3 shows the probability-weighted consequences (i.e., risks) of severe accidents for

WBN Unit 2 are small for all risk categories considered. For perspective, Table 6-4 Error!

Reference source not found.compares the health risks from severe accidents for WBN Unit 2

with the risk range reported in license renewal applications for current operating plants.

Table 6-4 Comparison of Environmental Risks from Severe Accidents Initiated by Internal

Events for WBN Unit 2 with Risks Initiated by Internal Events for Current Nuclear

Power Plants That Have Undergone Operating License Renewal Review and WBN

Unit 1

Core Damage

Frequency (per year)

50-mi Population Dose

Risk (person-rem/Ryr)(a)

Current reactor maximum(b) 2.4x 10-4 69

WBN Unit 2 1.8 x 10-5(c) 20

Current reactor mean(b) 2.6 x 10-5 17

Current reactor median () 1.6x 10-5 14

WBN Unit 1 5.8 x 10-5 5.3

Current reactor minimumr(b) 1.9 x 10-6 0.34

(a) To convert person-rem to person-Sv, divide by 100.

(b) Based on MACCS (Chanin et al. 1990) and MACCS2 (Chanin and Young 1998) calculations for 78 current plants

at 46 sites.

(c) Sum of the release frequencies presented in Table 6-3.

9 Table 6-4 compares WBN Unit 2 with statistics summarizing the results of contemporary severe

10 accident analyses performed for 78 reactors at 46 sites and with the CDF and population dose

11 estimate for WBN Unit 1. The results of these analyses are included in the final site-specific

12 Supplements 1 through 42 to the Generic Environmental Impact Statement (GELS) for License

13 Renewal, NUREG-1437 (NRC 1996, 1999), and in the ERs included with license renewal

14 applications for those power stations for which supplements have not been published as yet.

15 The analyses for 74 of the reactors used MACCS2, which was released in 1997. Table 6-4

16 shows the CDF estimated for the WBN Unit 2 reactor is about the same as the mean and

17 median CDFs for currently operating reactors. However, the population doses estimated for

18 WBN Unit 2 are slightly higher than the mean and median values for currently operating

19 reactors that have undergone license renewal. However, the NRC staff does not consider this

20 difference to be significant.

21 6.2.2 Surface-Water Pathway

22 Surface-water dose pathways are an extension of the air pathway and address the effects of

23 radioactive material deposited on open bodies of water. The MACCS2 code provides an

24 evaluation of risks from water ingestion. The water ingestion dose risk calculated for WBN Unit

September 2011 6-7 Draft NUREG-0498, Supplement 2
Environmental Impacts of Postulated Accidents Involving Radioactive Materials

1 2 of about 1.8 x 10-3 person-Sv/Ryr (1.8 x 10-1 person-rem/Ryr) is small compared to the total

2 dose risk of 0.20 person-Sv/Ryr (20 person-rem/Ryr).

3 The surface-water pathways also can include external radiation from (1) submersion in water

4 and activities near the water and (2) ingestion of aquatic food. The GElS (NUREG-1437; NRC

5 1996) relies on the analysis in the Fermi Final Environmental Statement (NUREG-0769; NRC

6 1981) and the Liquid Pathway Generic Study (NUREG-0440; NRC 1978b). These analyses

7 indicate that the aquatic-food pathway dose is about a factor of 20 larger than the water8 ingestion pathway dose, which is slightly larger than the dose from shoreline activities and

9 significantly larger than the dose from swimming. They also indicate interdiction can reduce

10 doses by as much as a factor of 10. The MACCS2 results in Table 6-3 show that the water11 ingestion dose is a small fraction of the air-pathway dose. This indicates the doses from

12 shoreline activity and swimming would also be small. The staff concludes that the risks

13 associated with shoreline activities and swimming would be significantly smaller than the air14 pathway dose risk, particularly if interdiction were considered.

15 The staff notes that Table 5.16 of the GElS contains an estimate of aquatic-food doses and

16 dose risks for generic river sites. The GElS estimates the aquatic food dose risk as about

17 0.005 person-Sv/Ryr (0.5 person-rem/Ryr) without interdiction. On this basis, the staff believes

18 that the aquatic-food pathway risk with interdiction would be significantly smaller than the air19 pathway risk.

20 6.2.3 Groundwater Pathway

21 The groundwater pathway involves a reactor core melt, reactor vessel failure, and penetration of

22 the floor (basemat) below the reactor vessel. Ultimately, core debris reaches the groundwater,

23 which transports soluble radionuclides. In the GELS, the staff assumed the frequency of a

24 severe accident with basemat penetration was 1 x 104/Ryr and concluded that the groundwater

25 pathway risks were small.

26 The frequency of core melt with a basemat melt-through should be no larger than the total CDF

27 estimate for the reactor. Table 6-4 shows the total CDF for WBN Unit 2 as 1.8 x 1 06 /Ryr.

28 NUREG-1 150 indicates the conditional probability of a basemat melt-through ranges from 0.05

29 to 0.25 for currently operating reactors. On this basis, the staff believes a severe accident with

30 basemat melt-through frequency of less than 1 X 10-5 /Ryr is conservative and a reasonable

31 estimate. The groundwater pathway is also more tortuous and affords more time for

32 implementing protective actions than the air pathway and, therefore, results in a lower risk to the

33 public. As a result, the staff concludes that the risks associated with releases to groundwater

34 are sufficiently small that they would not have a significant effect on the overall plant risk.

Draft NUREG-0498, Supplement 2 6-8 September 2011
Environmental Impacts of Postulated Accidents Involving Radioactive Materials

1 6.2.4 Summary of Severe Accident Impacts

2 The NRC staff conducted an independent review of the severe accident analysis presented by

3 TVA in its ER for completion of WBN Unit 2. The results of the staff review of environmental

4 risks of severe accidents associated with the air exposure pathway are presented in Table 6-3

5 and Table 6-4 in Section 6.2.1. The staff qualitatively evaluated the environmental risks of

6 severe accidents associated with the surface-Water and groundwater pathways in Section 6.2.2

7 and 6.2.3 and concludes that the environmental consequences of severe accidents are SMALL.

8 6.3 Severe Accident Mitigation Alternatives

9 Pursuant to the Third Circuit's opinion in Limerick Ecology Action, Inc., v. NRC, 869 F.2d 719,

10 723 (3d Cir. 1989), the NRC must analyze Severe Accident Mitigation Design Alternatives

11 (SAMDAs) as part of its National Environmental Policy Act (NEPA) review. As a result, the NRC

12 considers the alternative of plant operations with the installation of SAMDAs in the NEPA review

13 for all operating license applications to ensure that plant changes (i.e., hardware, procedures,

14 and training) with the potential for improving severe accident safety performance are identified

15 and evaluated. SAMDAs have not been previously considered by the Tennessee Valley

16 Authority (TVA) for the Watts Bar Nuclear Plant Unit 2 (WBN2); therefore, the remainder of

17 Section 6.3 addresses those alternatives.

18 TVA submitted an initial assessment of SAMDAs for WBN2 as part of the Environmental Impact

19 Statement (EIS) (TVA. 2009b), based on the then most recently available WBN Unit 1

20 probabilistic risk assessment (PRA), modified to reflect the expected operation for WBN2.

21 Subsequently TVA submitted an updated SAMDA assessment utilizing the latest Computer

22 Aided Fault Tree Analysis (CAFTA) based dual unit PRA (TVA 2010c). Both submittals were

23 supplemented by a plant-specific offsite consequence analysis performed using the MELCOR

24 Accident Consequence Code System 2 (MACCS2) computer code and insights from the WBN

25 Unit 1 individual plant examination (IPE) (TVA 1992), the WBN Unit 1 individual plant

26 examination of external events (IPEEE) (TVA 1998), and, in the updated assessment, the

27 WBN2 IPE (TVA 2010e). In identifying and evaluating potential SAMDAs, TVA considered

28 SAMDAs that addressed the major contributors to core damage frequency (CDF) and large

29 early release frequency (LERF) at WBN, population dose at WBN, as well as severe accident

30 management alternative (SAMA) candidates for operating plants which have submitted license

31 renewal applications. TVA initially identified 283 potential SAMDAs, followed by an additional

32 24 in the updated submittal, all of which were reduced to 38 by eliminating ones inapplicable to

33 WBN2 due to design differences; already implemented at WBN2; similar in nature so as to be

34 combined with another SAMDA candidate; excessively costly to implement such that the

35 estimated cost would exceed the dollar value associated with completely eliminating all severe

36 accident risk at WBN2; or determined to provide very low benefit. TVA assessed the costs and

37 benefits associated with each of the potential SAMDAs, and concluded in the EIS that several

38 are potentially cost-beneficial.

September 2011 6-9 Draft NUREG-0498, Supplement 2
Environmental Impacts of Postulated Accidents Involving Radioactive Materials

1 Based on its review, the U.S. Nuclear Regulatory Commission (NRC) issued requests for

2 additional information (RAIs) to TVA (NRC 2009b, NRC 2011 a; NRC 2011 b, NRC 2011 c). TVA

3 provided additional information regarding the PRA, information on 30 additional SAMDA

4 candidates, and additional information regarding several specific SAMDAs. The responses also

5 included revised results of the initial SAMDA analysis and updated submittal (TVA 2010f, TVA

6 2010g, TVA 2011a; TVA 2011b, TVA 2011c, TVA 2011d, TVA 2011e, TVA 2011f). TVA's

7 responses addressed the NRC staff's concerns.

8

9 6.3.1 Risk Estimates for Watts Bar Nuclear Plant Unit 2

10 TVA combined two distinct analyses to form the basis for the risk estimates used in the SAMDA

11 analysis: (1) the WBN Level 1 and 2 dual unit PRA model, which is updated from the Unit 2 IPE,

12 and (2) a supplemental analysis of offsite consequences and economic impacts (essentially a

13 Level 3 PRA model) developed specifically for the SAMDA analysis. The updated SAMDA

14 analysis is based on the most recent WBN Level 1 and Level 2 PRA models available at the

15 time of the assessment (TVA 201 Oc), which does not include external events.

16 The WBN2 CDF is approximately 1.7 x 10-5 /yr for internal events (including internal flooding) as

17 determined from quantification of the Level 1 PRA model. The CDF is based on the risk

18 assessment for internally-initiated events, which includes internal flooding. The breakdown of

19 CDF by initiating event is shown in the table below, which indicates that events initiated by loss

20 of offsite power (LOOP) and internal floods are the dominant contributors to CDF (TVA 201 la).

21

Table 6-5. WBN2 Core Damage Frequency for Internal Events

Event CDF (Per % Contribution

Initiating Year) to CDF1

Loss of Offsite Power (Grid Related) 3.2 x 1 06 19

Loss of Offsite Power (Plant Centered) 2.8 x 10-6 16

Total Loss of Component Cooling Unit 2 1.6 x 10-6 10

Loss of Offsite Power (Weather Induced) 1.1 x 10-6 6

Flood Event Induced by Rupture of Raw

Cooling Water (RCW) Line in room 1.1 x 10.6 6

772 0 - A8

Flood Event Induced by Rupture of RCW 1.1 X 10-6 6

Line in room 772 0 - A9

Total Loss of Emergency RCW (ERCW) 9.6 x 10-7 6

Cooling

Small LOCA Stuck Open Safety Relief 6.5 x 10- 4

Valve

Flood Event Induced by Rupture of high

pressure fire protection (HPFP) in 3.2 x 10-7 2

Common Areas of the Auxiliary

building

Draft NUREG-0498, Supplement 2 6-10 September 2011
Environmental Impacts of Postulated Accidents Involving Radioactive Materials

Table 6-5. WBN2 Core Damage Frequency for Internal Events

Event CDF (Per % Contribution

Initiating Year) to CDF1

Turbine Trip 3.0 x 10' 2

Others (each 1% or less) 4.1 x 10-6 24

Total CDF (internal events) 1.72 x 10"5 100

1

May not total to 100 percent due to round off.

1

2 TVA did not include the contribution from external events in the WBN risk estimates, but rather

3 accounted for their potential risk reduction benefits by multiplying the estimated benefits for

4 internal events by a factor of 2, which was subsequently increased to 2.28 in response to an

5 NRC staff RAI (TVA 2011 a).

6

7 The Level 2 portion of the SAMDA model represents an updated version of the WBN2 IPE Level

8 2 model, which was based on enhancements to NUREG/CR-6595 (NRC 2004a) and included

9 quantification of containment threats resulting from high pressure failure of the reactor vessel

10 and hydrogen deflagrations/detonations as well as additional detail on the treatment of

11 interfacing system loss of coolant accidents (ISLOCAs) and induced steam generator tube

12 rupture (I-SGTR). Two large containment event trees (CETs) were developed; one for SBO and

13 one for non-SBO sequences. The result of the Level 2 model is a set of four release categories

14- with their respective frequency and release characteristics and one category for intact

15 containment, which is considered to have a negligible release. The frequency of each release

16 category was obtained by summing the frequency of the contributing Level 2 sequences.

17

18 The offsite consequences and economic impact analyses use the WinMACCS code, the current

19 version of the MACCS2 code, to determine the offsite risk impacts on the surrounding

20 environment and public. Code inputs include plant-specific values for core radionuclide

21 inventory, source term and release characteristics, site-specific meteorological data, projected

22 population distribution (within an 80-kilometer [50-mile] radius) for the year 2040, emergency

23 response evacuation modeling, and economic data. The magnitude of the onsite impacts (in

24 terms of clean-up and decontamination costs and occupational dose) is based on information

25 provided in NUREG/BR -0184 (NRC 1997a). The release characteristics are based on the

26 SEQSOR emulation spreadsheet methodology. TVA estimated the dose to the population

27 within 80 kilometers (50 miles) of the WBN site to be approximately 0.200 person-sievert (Sv)

28 (20.0 person-rem) per year (TVA 201 le). The breakdown of the total population dose by

29 release category is summarized in the following table (TVA 201 le). Late containment over30 pressure failure is the dominant contributor to population dose risk at WBN2.

31

September 2011 6-11 Draft NUREG-0498, Supplement 2
Environmental Impacts of Postulated Accidents Involving Radioactive Materials

Table 6-6. Breakdown of Population Dose by Containment Release

Category

Population Dose

Containment Release Mode (Person-Rem[ 1 ] Per Percent

Year)Year)Contribution

Early Containment Failure 3.7 19

Containment Bypass 0.8 4

Late Containment Failure 14.1 71

Small Pre-existing Leak 1.2 6

Intact Containment negligible negligible

Total 20.0[1] 100

'One person-rem = 0.01 person-Sv (Sievert) 2

Total is not equal to the sum of the above due to roundoff

1

2 6.3.2 Adequacy of the WBN2 PRA for SAMDA Evaluation

3

4 Since WBN Units 1 and 2 are essentially identical, the history of both units' PRA models is

5 relevant to this evaluation. There have been eight revisions to the WBN PRA model since the

6 1992 WBN1 IPE submittal (TVA 1992), including the 2009 dual unit model which utilized the

7 CAFTA PRA software, whereas earlier versions utilized the RISKMAN PRA software. A

8 description of the most significant changes made to each revision was provided by TVA in the

9 original and updated assessments and in response to NRC staff RAIs (TVA 2009b, TVA 2010c,

10 TVA 201 Of, TVA 2011 a, TVA 2011 b, TVA 2011 c, TVA 2011 d). A comparison of internal events

11 CDF between the 1994 Unit 1 IPE (TVA 1994a) update and the initial Unit 2 PRA model (2009)

12 indicates a decrease of approximately 80 percent (from 8.0 x 1-05/yr to 1.5 x 10-5 /yr), primarily

13 due to the resolution of various 2001 peer review findings. The WBN2 PRA used for the

14 SAMDA model has a similar internal events CDF (1.7 x 10 5 /yr), which includes credit for cross15 tying Unit1 and Unit 2 shutdown boards and recovery of total loss of Emergency Raw Cooling

16 Water (ERCW) by use of a portable diesel driven fire pump (TVA 201 la).

17 Internal Events CDF

18 TVA states that the Unit 2 IPE is based on the Unit 1 design and operation as of April 1, 2008.

19 Since the IPE 2008 freeze date, a significant number (but not all) of mainly procedural changes

20 that were identified in the initial Unit 2 SAMDA assessment have been implemented and

21 incorporated in the current SAMDA PRA (TVA 201 la). The NRC staff concludes that those

22 changes that have not been incorporated will tend to reduce the CDF and thus make the current

23 results conservative. The NRC staff considered the peer reviews performed for the WBN PRA,

24 and the potential impact of the review findings on the SAMDA evaluation. The most relevant

25 review is that performed by the Westinghouse Owners Group (WOG) in November 2009, for

26 which a summary of the results is provided in the Unit 2 IPE submittal along with a listing of the

27 peer review findings (TVA 201 0e). While most of the findings have been resolved as part of the

28 updated SAMDA model, a significant number remain open in two categories: those considered

29 by TVA to be documentation-only issues and those pertaining to internal flooding (See Appendix

Draft NUREG-0498, Supplement 2 6-12 September 2011
Environmental Impacts of Postulated Accidents Involving Radioactive Materials

1 H) (TVA 201 la). TVA also indicated that the changes between the Unit 2 IPE model and the

2 SAMDA model were independently reviewed internally and externally.

3

4 The WBN CAFTA model utilizes a single fault tree constructed with systems and components

5 for each unit and includes common systems. Shared system initiating events fail the supporting

6 function for both units. Model quantification for each unit accurately tracks the dependent failure

7 for each unit (TVA 2011 a). Given that the WBN internal events PRA model has been peer8 reviewed, the peer review findings have been addressed, and TVA has satisfactorily addressed

9 NRC staff questions regarding the PRA, the NRC staff concludes that the internal events Level

10 1 WBN2 SAMDA PRA model is of sufficient quality to support the SAMDA evaluation.

11

12 Fire CDF

13 Since the WBN PRA does not include external events, the SAMDA submittals cite the WBN Unit

14 1 IPEEE, submitted in November 1998 (TVA 1998), in response to Supplement 4 of Generic

15 Letter 88-20 (NRC 1991), for which the only vulnerability found has been corrected. The Unit 2

16 IPEEE was submitted in April 2010 and uses the same methodology and, to a large extent, the

17 same assessment as the Unit 1 IPEEE, subject to validation that the Unit 1 assessments are

18 applicable to the as built Unit 2 (TVA 2010h). This submittal included a summary of the seismic

19 margin analysis (EPRI 1991), the fire induced vulnerability evaluation (FIVE [EPRI 1992]), and

20 the screening analysis for other external events. No fundamental weaknesses or vulnerabilities

21 to severe accident risk were identified in the Unit 1 IPEEE with the exception of one item related

22 to tornado missiles, for which corrective action has been completed. No seismic, fire, high

23 winds, external floods or other external hazard improvements were identified. The NRC staff

24 concluded that the licensee's Unit 1 IPEEE process is capable of identifying the most likely

25 severe accidents and severe accident vulnerabilities, and therefore, that the Watts Bar IPEEE

26 has met the intent of Supplement 4 to Generic Letter 88-20 (NRC 2000).

27 The dominant fire areas, defined as those having a fire CDF > 3 x 10-7 /yr, and their contributions

28 to the fire CDF are listed in the table below. The total fire CDF is not given in the IPEEE

29 submittal, but the total for those subjected to the final stage of screening is stated to be 9.3 x

30 10-6/yr (TVA 201 la).

31

32 The WNB2 IPEEE did not identify any vulnerabilities due to fire events or any improvements to

33 reduce fire risk.

34

Table 6-7. Dominant Fire Areas and Their Contribution to Fire CDF

Fire Area Description CDF (per year)

Main Control Room 9.7 x 10'

Corridor in Auxiliary Building (713.0-Al & A2) 9.3 x 10-7

125V Vital Battery Board Room IV 8.4 x 10-

Refueling Room 7.5 x 10-'

Auxiliary Instrument Room 2 6.8 x 10-7

September 2011 6-13 Draft NUREG-0498, Supplement 2
Environmental Impacts of Postulated Accidents Involving Radioactive Materials

Table 6-7. Dominant Fire Areas and Their Contribution to Fire CDF

Fire Area Description CDF (per year)

Turbine Building 5.9 x 10-

Corridor (737.0-Al B) 5.1 x 107

Corridor (737.0-AlA) 4.2 x 10-7

Auxiliary Building Roof 3.1 x 10-7

Corridor (737.0-Al C) 2.9 x 10-7

Total 9.3 x 10-

1

2 TVA identified both conservatisms and non-conservatisms in the fire analysis (TVA 201 la),

3 among which are conservative fire ignition frequencies, control room severity factors and non4 suppression probabilities; non-conservatively assuming that fires do not propagate between

5 analysis volumes and excluding some spurious actuations as well as the increased probability

6 of the 182 gpm per pump seal LOCA. TVA concludes that the conservatisms outweigh the non7 conservatisms so that the fire contribution to risk is less than that given by the sum of the final

8 screen results. To account for this conservatism, TVA reduced the fire CDF for the dominant

9 fire areas in the IPEEE (9.3 x 10.6 /yr) by a factor of 2.29 to yield a fire CDF of 4.1 x 10-6/yr for

10 the SAMDA evaluation. This factor is the ratio of the internal events CDF of 2.68 x 1 05/yr given

11 by the modified PRA used for the fire analysis with no fire induced failures nor flood failures to

12 the CDF of 1.17 x 10 5

/yr given by the October 2010 SAMDA PRA for internal events only,

13 excluding floods (TVA 2011 a). Based on the conservatisms in the fire analysis, the staff

14 concludes that a fire CDF of 4.1 x 10-6/yr is reasonable for the SAMA analysis.

15

16 Seismic CDF

17 The WBN Unit 1 IPEEE used a focused scope Electric Power Research Institute (EPRI) seismic

18 margins analysis, which is qualitative and does not provide numerical estimates of the CDF

19 (EPRI 1991). The components in the safe shutdown equipment list were screened using an

20 overall high confidence of low probability of failure (HCLPF) capacity of 0.3g, the review level

21 earthquake (RLE) value for the plant, and the screening level that would be used for a focused22 scope plant. No significant seismic concerns were identified, although some maintenance and

23 housekeeping items were noted and corrected (TVA 1998, TVA 2010h). While the Unit 2

24 seismic assessment makes considerable use of the Unit 1 assessment, individual aspects are

25 repeated and/or the Unit 1 results were reviewed to confirm that they are applicable to Unit 2.

26 TVA considered this an acceptable approach since the designs of the uhits are nearly identical

27 and use the same design criteria. The WNB2 IPEEE did not identify any seismic or

28 improvements to reduce seismic risk.

29 To provide insight into the appropriate estimate of the seismic CDF to use for the SAMDA

30 evaluation, the NRC staff noted that, in the attachments to NRC Information Notice 2010-18,

31 Generic Issue (GI) 199 (NRC 2010), the NRC staff estimated a "weakest link model" seismic

a The remaining contribution from all other fire areas is -3 x 10-6.

Draft NUREG-0498, Supplement 2 6-14 September 2011
Environmental Impacts of Postulated Accidents Involving Radioactive Materials

1 CDF for WBN 1 of 3.6 x 10-5/yr using updated seismic hazard curves developed by the U.S.

2 Geological Survey (USGS) in 2008 (USGS 2008) and requested TVA provide an assessment of

3 the impact of the updated USGS seismic hazard curves on the SAMDA evaluation (NRC

4 201 la). The NRC Information Notice referenced the August 2010 NRC document, "Safety/Risk

5 Assessment Results for Generic Issue 199, Implications of Updated Probabilistic Seismic

6 Hazard Estimates in Central and Eastern United States on Existing Plants" (ADAMS Accession

7 No. ML100270582 (package)), that discusses recent updates to estimates of the seismic hazard

8 in the central and eastern United States. Appendix A of that document describes how the

9 seismic CDF estimate can be acceptably derived using various approaches; including a

10 maximum estimate, averaging estimates, and the weakest link estimate. All these approaches

11 use the plant-specific ground motion characterization (i.e., spectral accelerations at various

12 frequencies and/or peak ground accelerations). For WBN 1, the peak ground acceleration

13 estimate is greater than the spectral acceleration estimates derived at 1 Hz, 5 Hz, and 10 Hz.

14 As a result, the peak ground acceleration estimate is equal to the maximum estimate and

15 dominates the weakest link model estimate at 3.6 x 10 5 /yr.

16

17 In response to the staff request, TVA noted that the Watts Bar site was used as the test case for

18 closure of GI-194, "Implications of updated probabilistic seismic hazard estimates" (NRC 2003a)

19 (TVA 201 la). For GI 194, the staff initially estimated the seismic CDF using the updated peak

20 ground acceleration and derived a value similar to the latest updated value. However, the staff

21 noted that the Watts Bar site's updated seismic spectral acceleration values differed significantly

22 from the design safe shutdown earthquake (SSE) spectrum. To account for the effect of this

23 difference in spectrum shape on the estimated seismic CDF, the Watts Bar plant HCLPF

24 capacity of 0.3g was scaled to the spectral acceleration values at 5 hertz (Hz) and 10 Hz, based

25 on the natural frequency range for most structures and equipment in nuclear power plants being

26 below 10 Hz (NRC 2003a) and used an averaging approach to derive the estimate of the

27 seismic CDF. Based on the GI 194 staff analysis, TVA concluded that 1.8 x 10- 5

/yr is an

28 appropriate estimate of the seismic CDF for use in the WBN2 SAMA evaluation.

29

30 The seismic CDF estimated by the NRC staff for Watts Bar 1 using the 2008 USGS seismic

31 hazard curves resulted in seismic CDFs of 1.3 x 10-5/yr and about 2.8 x 1 0' 5

/yr for spectral

32 ground accelerations of 5 Hz and 10 Hz, respectively (NRC 2010). The average of the seismic

33 CDF for these two acceleration values is about 2.0 x 10-5/yr, which is comparable to the GI-1 94

34 result for Watts Bar based on the same methodology. Based on this being essentially the same

35 as the spectral-average seismic CDF of 1.8 x 10-5/yr determined for closure of GI-1 94, the NRC

36 staff agrees that 1.8 x 10-5 /yr is an acceptable estimate of the seismic CDF for use in the WBN2

37 SAMDA evaluation.

38

39 "Other" External Event CDF

40 The IPEEE analysis of "other" external events, which include high winds, external floods,

41 transportation accidents, etc. (HFO events), followed the screening and evaluation approaches

42 described in Supplement 4 of GL 88-20 (NRC 1991) and focused on demonstrating that the

September 2011 6-15 Draft NUREG-0498, Supplement 2
Environmental Impacts of Postulated Accidents Involving Radioactive Materials

1 design and construction of the plant in the HFO areas met the 1975 Standard Review Plan

2 Criteria (NRC 1975). As a result, TVA completed a corrective action to design and install a steel

3 shield to close an opening on the Unit 2 side of the Auxiliary Building that had the potential for

4 allowing tornado missiles to penetrate into the auxiliary building and damage safety related

5 equipment. TVA did not identify any other vulnerabilities or need for improvements. Based on

6 this result, TVA did not consider specific SAMDAs for HFO events. It is noted that the risks from

7 deliberate aircraft impacts were explicitly excluded since this was being considered in other

8 forums along with other sources of sabotage.

9

10 Level 2 and LERF

11 The NRC staff reviewed the general process used by TVA to translate the results of the Level 1

12 PRA into containment releases, as well as the results of the Level 2 analysis, as described in

13 the SAMDA submittal and in response to NRC staff requests for additional information (TVA

14 2011 a, TVA2011 b, TVA 2011 c, TVA 2011 d). Accident progression was modeled using a 32

15 node containment model in MAAP4.0.7. Two large CETs were developed; one for SBO and

16 one for non-SBO sequences (TVA 2010e). The reactor core radionuclide inventory assumes

17 5% enrichment and a burnup of 1000 effective full power days (EFPD) for WBN2 at 3565 MWt

18 as evaluated using the ORIGEN code. TVA states that these conditions bound that expected

19 for the WBN2 fuel.management program for the license period (TVA 2010f). Each Level 1 core

20 damage sequence is assigned to one of eight plant damage state (PDS) bins, based on

21 characteristics such as bypass containment or not, the type of bypass and high or low reactor

22 coolant pressure. Each core damage sequence is linked to one of 11 Level 2 CET end state

23 groups (plus intact containment), which are then binned into four release categories, used in the

24 Level 3 consequence analysis, that represent similar containment failure modes, release

25 magnitudes and timing.

26

27 The frequency of each release category is the sum of the frequencies of the contributing Level 2

28 sequences. Source terms and other release parameters for the Level 3 consequence analysis

29 were determined for eleven scenarios that are representative of the sequences that contribute

30 to the release categories. Based on the NRC staff's review of the Level 2 methodology, the fact

31 that the LERF model was reviewed by the WOG and the review findings have all been

32 addressed in the SAMDA Level 2 model, the updated Level 2 model was reviewed by an

33 external contractor and independently reviewed by the TVA PRA team, and TVA has responded

34 to the RAIs concerning the Level 2 model, the NRC staff concludes that the Level 2 PRA

35 provides an acceptable basis for evaluating the benefits associated with various SAMDAs.

36

37 Level 3 - Population Dose

38 The process used by TVA to extend the containment performance (Level 2) portion of the PRA

39 to an assessment of offsite consequences (essentially a Level 3 PRA) included consideration of

40 the source terms and other parameters used to characterize fission product releases for the

41 applicable representative release scenarios that contribute to the containment release

42 categories and the major input assumptions used in the offsite consequence analyses. The

Draft NUREG-0498, Supplement 2 6-16 September 2011
Environmental Impacts of Postulated Accidents Involving Radioactive Materials

1 WinMACCS code, the current version of the MACCS2 code, was utilized to estimate offsite

2 consequences. Plant-specific input to the code includes the source terms for each release

3 category and the reactor core radionuclide inventory; site-specific meteorological data for the

4 2002 calendar year; projected population distribution within an 80-kilometer (50-mile) radius for

5 the year 2040, based on the U.S. Census Bureau population data for 2000; emergency

6 evacuation modeling, which assumed that 99.5 percent of the population would evacuate,

7 NUREG-1150 (NRC 1990); and economic data from SECPOP2000 (NRC 2003b, TVA 2010c).

8

9 Sensitivity analyses were performed on some of the WinMACCS input parameters, including

10 variation in the year chosen for meteorological data (data from 2001 through 2005 were

11 available) and evacuation speed. TVA noted that previous SAMA analyses typically show little

12 sensitivity to variations in many of the WinMACCS parameters, e.g., release height and plume

13 buoyancy. The NRC staff concluded that the release parameters, methods and assumptions for

14 estimating population, evacuation assumptions, and approach taken for determining the site15 specific economic data are acceptable for the purposes of the SAMDA evaluation. The NRC

16 staff concludes that the methodology used by TVA to estimate the offsite consequences for

17 WBN provides an acceptable basis from which to proceed with an assessment of risk reduction

18 potential for candidate SAMDAs. Accordingly, the NRC staff based its assessment of offsite risk

19 on the CDF and revised offsite doses reported by TVA.

20

21 6.3.3 Potential Plant Improvements

22 TVA's process for identifying potential plant improvements (SAMDAs) consisted of the following

23 elements:

24 0 Review of other industry documentation discussing potential plant improvements as

25 developed in NEI 05-01 (NEI 2005),

26 0 Review of Phase II SAMAs from license renewal applications for five other U.S. nuclear

27 sites,

28 0 Review of potential plant improvements identified in the WBN IPE and IPEEE,

29 0 Review of the most significant basic events and systems from the WBN Unit 2 PRA

30 submitted in support of the original Unit 2 SAMDA assessment (TVA 2009b), and

31 0 Review of the most significant basic events from the WBN Unit 2 IPE based PRA

32 submitted in support of the Updated SAMDA assessment (TVA 2010c).

33

34 Based on this process, an initial set of 307 candidate "Phase I" SAMDAs was identified. TVA

35 performed a qualitative screening of this initial list to eliminate 269 SAMDAs, leaving 38 for

36 further evaluation, using the following criteria:

37 * The SAMDA is not applicable to the WBN design,

38 * The SAMDA or its equivalent has already been implemented at WBN,

39 * The SAMDA is similar in nature and can be combined with another SAMDA,

40 * The SAMDA has estimated costs that would exceed the dollar value associated with

41 completely eliminating all severe accident risk at WBN, or

September 2011 6-17 Draft NUREG-0498, Supplement 2
Environmental Impacts of Postulated Accidents Involving Radioactive Materials

1 * The SAMDA is related to a non-risk significant system known to have negligible impact

2 on risk.

3

4 For these remaining "Phase I1" SAMDAs, TVA performed a detailed evaluation, accounting for

5 the potential impact of external events using a multiplier of 2.28 (TVA 201 la). This was derived

6 as the ratio of the sum of the internal events, fire and seismic CDFs (1.7 x 10' + 4.1 x 10-6 + 1.8

7 x 105 = 3.9 x 105/yr) to the internal events CDF (1.7 x 10-5/yr). The NRC staff agrees that the

8 applicant's use of a multiplier of 2.28 to account for external events is reasonable for the

9 purposes of the SAMDA evaluation.

10

11 Overall, TVA's efforts to identify potential SAMDAs focused primarily on areas associated with

12 internal initiating events based on the systems and basic events considered to be important to

13 internal event CDF and LERF from a risk reduction worth (RRW) perspective at WBN. This

14 included selected SAMDAs from prior SAMA analyses for other plants. Also in response to

15 NRC staff RAIs, TVA identified an additional 31 candidate SAMDAs resulting from: the

16 enhancements identified in the Watts Bar Unit 1 SAMDA analysis (TVA 1994b), review of the

17 WBN2 PRA down to a lower value of RRW and the dominant fire zones as identified in the

18 IPEEE. All were, however, screened from detailed analysis (TVA 2011 a).a

19 The NRC staff reviewed TVA's process for identifying and screening potential SAMDA

20 candidates, as well as the methods for quantifying the benefits associated with potential risk

21 reduction. The NRC staff concludes that the set of SAMDAs evaluated in the EIS, together with

22 those identified in response to NRC staff RAIs, addresses the major contributors to internal

23 events CDF. Based on the licensee's IPEEE and the expected cost associated with further risk

24 analysis and potential plant modifications, the NRC staff further concludes that the opportunity

25 for seismic and fire-related SAMDAs has been adequately explored and that it is unlikely that

26 there are any additional cost-beneficial seismic or fire-related SAMDA candidates.

27 The NRC staff notes that the set of SAMDAs submitted is not all inclusive, since additional,

28 possibly even less expensive, design alternatives can always be postulated. However, the NRC

29 staff concludes that the benefits of any additional modifications are unlikely to exceed the

30 benefits of the modifications evaluated and that the alternative improvements would not likely

31 cost less than the least expensive alternatives evaluated, when the subsidiary costs associated

32 with maintenance, procedures, and training are considered. The NRC staff further concludes

33 that TVA used a systematic and comprehensive process for identifying potential plant

34 improvements for WBN, and that the set of potential plant improvements identified by TVA is

35 reasonably comprehensive and therefore acceptable. While explicit treatment of external

36 events in the SAMDA identification process was limited, it is recognized that the absence of

37 external event vulnerabilities reasonably justifies examining primarily the internal events risk

38 results for this purpose.

a TVA subsequently provided a revised Level 3 consequence analysis. In assessing the impact of the

corrected consequence analysis on the SAMDA identification process, TVA identified one additional

candidate SAMDA, which was screened out (TVA 201 le).

Draft NUREG-0498, Supplement 2 6-18 September 2011
Environmental Impacts of Postulated Accidents Involving Radioactive Materials

1 6.3.3.1 Risk Reduction

2 TVA evaluated the risk-reduction potential of the 38 Phase-Il SAMAs in a bounding fashion by

3 assuming that the SAMDA would completely eliminate the risk associated with the proposed

4 enhancement. Such bounding calculations overestimate the benefit and are conservative. TVA

5 used model re-quantification to estimate the risk reduction for each of the evaluated SAMDAs,

6 the estimated risk reduction in terms of percent reduction in CDF and population dose, and the

7 estimated total benefit (present value) of the averted risk. The estimated benefits combined

8 benefits in both internal and external events through the use of the external events multiplier, as

9 well as incorporating a number of changes to the analysis methodology subsequent to the

10 original submittal.

11

12 The NRC staff has reviewed TVA's bases for calculating the risk reduction for the various plant

13 improvements as described in the SAMDA assessments and in response to NRC staff RAIs and

14 concludes that the rationale and assumptions for estimating risk reduction are reasonable and

15 generally conservative (i.e., the estimated risk reduction is higher than what would actually be

16 realized). Accordingly, the NRC staff based its estimates of averted risk for the various

17 SAMDAs on TVA's risk reduction estimates.

18 6.3.3.2 Cost Impacts

19 TVA estimated the costs of implementing the 38 Phase-lI SAMAs by focusing on labor (craft,

20 engineering, etc.) and component cost related to installing the proposed physical change.

21 Costs do not include lifetime operation; testing or maintenance; procedural development and

22 training associated with the physical changes (except for those SAMDAs which were solely

23 procedural and/or training activities); or contingency for unforeseen obstacles or inflation (TVA

24 2011 a; TVA 201Of). Concerning per-unit cost savings associated with implementing the

25 changes to both WBN units, TVA stated that the cost of procedural or training module

26 development is only marginally increased to apply to a second unit and that, for physical unit

27 design changes, the costs are for the affected unit only (TVA 2011 a). Therefore, TVA opted not

28 to divide the cost of procedural and training SAMDAs in half. The NRC staff concludes that the

29 per-unit cost of physical changes (for the scope of the cost estimate as described above) would

30 be less then that given by TVA. However, since the scope of TVA's cost estimates excludes

31 lifetime costs associated with the procedure and training, these should be conservative, as

32 borne out by comparison with similar costs given in license renewal SAMA submittals.

33 Therefore, with regard to physical changes, the NRC staff concludes that, while there may be

34 some savings with respect to sharing engineering cost between units, other factors such as

35 lifetime costs and procedure and training associated with the change that are not included in

36 TVA's estimate result in a conservative estimate. The NRC staff thereby concludes that the

37 cost estimates provided by TVA are sufficient and appropriate for use in the SAMDA

38 assessments.

39

September 2011 6-19 Draft NUREG-0498, Supplement 2
Environmental Impacts of Postulated Accidents Involving Radioactive Materials

1 6.3.3.4 Cost-Benefit Comparison

2 The methodology used by TVA is based on NEI 05-01, Severe Accident Mitigation Altematives

3 (SAMA) Analysis Guidance Document (NEI 2005), which in turn is based on NRC's guidance for

4 performing cost-benefit analysis, i.e., NUREG/BR-01 84, Regulatory Analysis Technical

5 Evaluation Handbook (NRC 1997b). The guidance involves determining the net value for each

6 SAMA according to the following formula:

7

8 Net Value = (APE + AOC + AOE + AOSC) - COE

9 where:

10 APE = present value of averted public exposure ($)

11 AOC = present value of averted offsite property damage costs ($)

12 AOE = present value of averted occupational exposure costs ($)

13 AOSC = present value of averted onsite costs ($)

14 COE = cost of enhancement ($)

15 If the net value of a SAMDA is negative, the cost of implementing the SAMDA is larger than the

16 benefit associated with the SAMDA and it is not considered cost-beneficial. TVA performed the

17 SAMDA analysis using a 7 percent discount rate and provided a sensitivity analysis using a 3

18 percent discount rate to capture SAMDAs that may be cost-effective based on either (TVA

19 201 la). This analysis is sufficient to satisfy NRC policy in Revision 4 of NUREG/BR-0058 (NRC

20 2004b). Using the above equations, TVA estimated the total present dollar value equivalent

21 associated with completely eliminating severe accidents from internal events at WBN2 to be

22 about $1,930,000. Use of a multiplier of 2.28 to account for external events increases the value

23 to $4,401,000. This represents the dollar value associated with completely eliminating all

24 internal and external event severe accident risk at WBN2, and is also referred to as the Modified

25 Maximum Averted Cost Risk (MMACR).

26 As a result of TVA's baseline analysis, eight SAMDAs (SAMDAs 4, 156, 256, 285, 292, 299,

27 305 and 306) were cost-beneficial. In addition to considering the impact of discount rate, TVA

28 also estimated the effect of incorporating CDF uncertainties and parameter choices on the

29 results of the SAMDA assessment (TVA 201 la). The change in discount rate from 7 percent to

30 3 percent changed the conclusion concerning cost-benefit of two SAMDAs (SAMDAs 215 and

31 300). Moreover, these results indicated that the impact of the 3 percent discount rate was less

32 than that of the CDF uncertainty (discussed below). Hence, the SAMDAs that are cost33 beneficial based on the CDF uncertainty incorporate those that are cost beneficial considering

34 the 3 percent discount rate. TVA's limited sensitivity studies relative to the parameter choices

35 for the consequence analysis showed no impact on the calculated risk. Based on the

Draft NUREG-0498, Supplement 2 6-20 September 2011
Environmental Impacts of Postulated Accidents Involving Radioactive Materials

1 parameters used and the results of previous SAMA consequence analysis sensitivity studies,

2 the NRC staff concludes that the parameter selection for the consequence analysis is

3 acceptable for the purposes of the SAMDA assessment.

4 TVA considered the impact that possible increases in benefits from analysis uncertainties would

5 have on the results of the SAMDA assessment. Since no uncertainty distributions on CDF were

6 available for the CAFTA-based SAMDA model, TVA used the results of the uncertainty analysis

7 of the earlier RISKMAN-based PRA model (TVA 2009b) to establish an uncertainty multiplier

8 based on the ratio of the 95th percentile CDF to the mean CDF, or 2.70. TVA subsequently

9 determined that six additional SAMDAs (SAMDAs 8, 70, 93, 215, 226 and 300) would be cost10 beneficial. The NRC staff notes that the CAFTA results are point estimates, not means, and

11 hence the ratio of the 9 5th percentile CDF to the point estimate CDF, or 2.78, should be used in

12 the CDF uncertainty analysis instead of 2.70. However, this difference is small and potentially

13 impacts the cost-benefit analysis only of SAMDA 70, changing it from just slightly below to just

14 slightly above the threshold to render it cost-beneficial. TVA has committed to provide a new

15 capability to allow the operators from the control room to transfer from normal compressed air

16 supply to the station nitrogen system for control of the level control valves (LCVs). This new

17 capability, identified as SAMDA 339, will have a greater benefit then that associated with

18 SAMDA 70 and thus supersedes it. TVA also re-examined the initial set of SAMDAs to

19 determine if any additional Phase I SAMDAs would be retained for further analysis if the

20 benefits (and Modified Maximum Averted Cost-Risk) were increased by the uncertainty factor of

21 2.70. None were identified (TVA 2011b, TVA 2011c, TVA 2011e). Use of an uncertainty factor

22 of 2.78 would not change this conclusion.

23 The NRC staff concludes that, with the exception of the potentially cost-beneficial SAMDAs that

24 have been identified, the costs of the other SAMDAs evaluated would be higher than the

25 associated benefits, such that no additional SAMDAs would be expected to be cost-beneficial.

26 6.3.4 Cost-Beneficial SAMAs

27 Highlighted in bold italics in the following table are the potentially cost-beneficial SAMAs:

28

29 Table 6-8. SAMDA Cost-Benefit Analysis for WBN2

% Risk Reduction Total Benefit ($) Cost

SAMDA Populatio Baseline (Internal Baseline With

n Dose + External) Uncertainty

4 - Improve DC bus load 1.1 1.2 40K 110K 32K

shedding

8 - Increase training on

response to loss of two

120VAC buses which 0.8 -0 12K 35K 27K

causes inadvertent

actuation signal

September 2011 6-21 Draft NUREG-0498, Supplement 2
Environmental Impacts of Postulated Accidents Involving Radioactive Materials

% Risk Reduction Total Benefit ($) Cost

SAMDA CDF Populatio Baseline (Internal Baseline With

n Dose + External) Uncertainty

26 - Provide an additional

high pressure injection pump 1.4 1.4 65K 180K 3.6M

with independent diesel

32 - Add the ability to

automatically align

emergency core cooling 7.4 12 400K 1.1M 2.1M

system to recirculation mode

upon refueling water storage

tank depletion

45 - Enhance procedural

guidance for use of cross- 0.3 -0 5K 14K 32K

tied component cooling or

service water pumps

46 - Add service water pump 7.0 3.7 150K 410K 1.OM

56 - Install an independent

reactor coolant pump seal 24 29 1.1M 3.2M 8.2M

injection system, without

dedicated diesel

70 - Install accumulators

for turbine-driven auxiliary 2.5 2.2 1OOK 280K 260K

feedwater pump flow

control valves(aO

71 - Install a new

condensate storage tank

(auxiliary feedwater storage -0 -0 -0 -0 1.7M

tank)

87 - Replace service and

instrument air compressors

with more reliable 0.2 -0 2.2K 6.0K 890K

compressors which have self

-contained air cooling by

shaft driven fans

93 - Install an unfiltered

hardened containment vent

to eliminate the containment

overpressure failure(d)

Draft NUREG-0498, Supplement 2 6-22 September 2011
Environmental Impacts of Postulated Accidents Involving Radioactive Materials

% Risk Reduction Total Benefit ($) Cost

SAMDA CDF Populatio Baseline (Internal Baseline With

n Dose + External) Uncertainty

101 - Provide a reactor

exterior cooling system to 0 8.5 210K 580K 2.5M

cool a molten core before

vessel failure

103- Institute simulator

training for severe accident 33 32 1.4M 3.9M 8.OM

scenarios

109 - Install a passive 0 12 300K 840K 3.7M

hydrogen control system

110 - Erect a barrier that

would provide enhanced

protection of the containment

walls (shell) from ejected 0 4.0 100K 290K 1.2M

core debris following a core

melt scenario at high

pressure.

112 - Add redundant and

diverse limit switches to each <0.1 0.0 3.2K 8.9K 690K

containment isolation valve

136 - Install motor generator

set trip breakers in the 0.9 0.0 13K 37K 240K

control room

156 - Eliminate reactor

coolant pump (RCP) thermal

barrier dependence on CCW,

such that loss of CCW does

not result directly in core 13 20 780K 2.2M 32K

damage (Enhance

procedural guidance for use

of ERCW for RCP thermal

barrier cooling)(bc)

176 - Provide a connection

to alternate offsite power 19 17 780K 2.2M 9.1M

source

191 - Provide self-cooled -0(f -~0-0 ~ 0 1.OM

ECCS seals

September 2011 6-23 Draft NUREG-0498, Supplement 2
Environmental Impacts of Postulated Accidents Involving Radioactive Materials

% Risk Reduction Total Benefit ($) Cost

SAMDA CDF Populatio Baseline (Internal Baseline With

n Dose + External) Uncertainty

215 - Provide a means to

ensure RCP seal cooling so 26 31 1.3M 3.7M 1.5M

that RCP seals LOCAs are

precluded for SBO events(d)

226 - Provide permanent

self-powered pump to back 26 31 1.3M 3.7M 2.7M

up normal charging pump(d)

255 - Install a permanent,

dedicated generator for the

normal charging pump, one 18 20 840K 2.3M 3.2M

Motor Driven AFW Pump

and a Battery Charger

256 - Install fire barriers

around cables or reroute

the cables away from fire

sources (Enhance 25 25 1.1M 3.1M 20K

procedure for controlling

temporary alternatives to

reduce fire risk from

temporary cables)(b)

276 - Provide an auto start

signal for the AFW on loss of 0.7 0.6 25K 70K 620K

standby feedwater pump

279 - Provide a permanent

tie-in to the construction air 1.8 1.6 72K 200K 910K

compressor

280 - Add new Unit 2 air

compressor similar to the 1.8 1.6 72K 200K 810K

Unit 1 D compressor

282 - Provide cross-tie to 1.3 -0 21K 58K l0M

Unit 1 RWST

285 - Improve training to

establish feed and bleed

cooling given no CCPs are 6.4 0.3 lOOK 290K 27K

running or a vital

instrument board fails

Draft NUREG-0498, Supplement 2 6-24 September 2011
Environmental Impacts of Postulated Accidents Involving Radioactive Materials

% Risk Reduction Total Benefit ($) Cost

SAMDA CDF Populatio Baseline (Internal Baseline With

n Dose + External) Uncertainty

292 - Improve training to

reduce failure probability

to terminate inadvertent 4.2 13 400K 1.1M 27K

safety injection prior to

water challenge to PORVs

295 - Increase frequency of

containment leak rate testing

299 - Initiate frequent

awareness training for

plant

operators/maintenance/tes

ting staff on key human

actions for plant risk 4.6 6.6 290K 793K 27K

(Initiate frequent

awareness training for

maintenance and testing

staff as on key human

actions for plant risk)(b)

300 - Revise procedure

FR-H. 1 to eliminate and/or

simplify complex decision

logic for establishing feed 3.4 0.2 57K 160K lOOK

and bleed cooling and to

improve operator recovery

from initial mistakes

303 - Move

indicator/operator interface -0 1.7K 4.8K 50K

for starting igniters to front

MCR panel

304 - Add annunciator or

alarm signaling parameters 0 0 1.7K 4.8K 50K

to initiate hydrogen igniters

to front panel on MCR

305 - Revise procedure E-1

to include recovery steps for 0 6.2 150K 420K lOOK

failure to initiate hydrogen

igniters(e)

September 2011 6-25 Draft NUREG-0498, Supplement 2
Environmental Impacts of Postulated Accidents Involving Radioactive Materials

% Risk Reduction Total Benefit ($) Cost

SAMDA CDF Populatio Baseline (Internal Baseline With

n Dose + External) Uncertainty

306 - Improve operator

performance by enhancing 2.4 5.3 170K 470K lOOK

likelihood of recovery from

execution errors(e)

307 - Make provisions for

connecting ERCW to CCP 0.1 0.0 0.6K 1.7K 99K

2B-B

339 - Provide a capability

to allow the operators from

the control room to

transfer from normal N/A N/A

compressed air supply to

the station nitrogen

system for control of the

AFW LCVs.('

340 - Install flood

detection in areas 772.0-A8 N/A N/A N/A N/A N/A

and 772.0-A9.(g)

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

(a)

(b)

(c)

(d)

(e)

(f)

(g)

As discussed in Section 6.3.3, the evaluation of the benefits of this SAMDA is deemed conservative, such that

the potential slight exceedance of the cost-beneficial threshold does not render it cost-beneficial. It is therefore

not highlighted.

SAMDA title given in parentheses is considered a more accurate description of the actual SAMDA.

Due to time constraints, procedure change envisioned for SAMDA 156 is not considered to be effective; hence

the benefit would be essentially negligible. It is therefore not highlighted. Hardware change is considered in

SAMDA 215.

SAMDAs 93, 215, and 226 relate to preventing RCP seal failures. TVA has committed to follow the progress

and experience with an improved RCP seal package design that has been installed at the Farley Nuclear

Power Plant and, if proven reliable during operation, to install it at the earliest refueling outage following startup

during normal seal package replacements (TVA 2011 a). As a result, final decision as to the disposition of

these potentially cost-beneficial SAMDAs is pending, and they are not highlighted.

While potentially cost-beneficial, this SAMDA has already been implemented. It is therefore not highlighted.

TVA has committed to provide a new capability to allow the operators from the control room to transfer from

normal compressed air supply to the station nitrogen system for control of the LCVs. This new capability,

identified as SAMDA 339, will have a greater benefit then that associated with SAMDA 70 and thus

supersedes it (TVA 201 lb).

This SAMDA captures a previous commitment by TVA to install this flood detection equipment.

Draft NUREG-0498, Supplement 2 6-26 September 2011
Environmental Impacts of Postulated Accidents Involving Radioactive Materials

1 As stated in the November 1, 2010 submittal, TVA has indicated that the following potentially

2 cost-beneficial SAMDAs will be implemented: SAMDAs 4, 8, 256, 285, 292, 299 and 300.' For

3 reasons beyond a cost-beneficial analysis, TVA will be implementing SAMDAs 339 and 340 as

4 committed by letters dated May 13 and 25, 2011.

5 6.3.5 Conclusions

6 TVA compiled a list of SAMDAs based on a review of: the most significant basic events from the

7 plant-specific PRA, insights from the plant-specific IPE and IPEEE, Phase I SAMAs from license

8 renewal applications for other plants, and NEI's list of generic SAMAs. An initial screening

9 removed SAMDA candidates that (1) were not applicable to WBN, (2) were already

10 implemented at WBN, (3) were similar to and could be combined with other SAMDAs, (4) had

11 estimated costs that would exceed the dollar value associated with completely eliminating all

12 severe accident risk at WBN, or (5) determined to have negligible impact on risk. Based on this

13 screening, a number of these SAMDAs were eliminated leaving the remaining candidate

14 SAMDAs for Phase II evaluation.

15

16 For the remaining SAMDA candidates, more detailed design and cost estimates were

17 developed. The cost-benefit analyses showed that eight of the SAMDA candidates were cost18 beneficial in the baseline analysis (SAMDAs 4, 156, 256, 285, 292, 299, 305 and 306). TVA

19 performed additional analyses to evaluate the impact of parameter choices and uncertainties on

20 the results of the SAMDA assessment. As a result, six additional SAMDAs (SAMDAs 8, 70, 93,

21 215, 226 and 300) were identified as cost-beneficial. Six of these SAMDAs (SAMDAs 93, 156,

22 215, 226, 305 and 306) have been dispositioned as not needing implementation because (1)

23 one would not be effective due to time constraints on the operators to perform the action; (2)

24 accumulating operating experience with a recently installed, improved RCP seal design at

25 Farley Nuclear Power Plant may result in TVA installing the same design at WBN2; or (3) two

26 have already been implemented at WBN2.b

27

28 The NRC staff reviewed the TVA analysis and concludes that the methods used and the

29 implementation of those methods were sound. The treatment of SAMDA benefits and costs

30 support the general conclusion that the SAMDA evaluations performed by TVA are reasonable

31 and sufficient for the license submittal. Although the treatment of SAMDAs for external events

Since the Third Circuit's opinion in Limerick Ecology Action, Inc., v. NRC, 869 F.2d 719, 723 (3d Cir. 1989) is not

limited by the scope of license renewal, their relationship of these SAMDAs to aging does not affect the decision to

implement.

b SAMDAs 215 and 226 relate to preventing RCP seal failures. TVA has committed to follow the progress and

experience with an improved RCP seal package design that has been installed at the Farley Nuclear Power Plant

and, if proven reliable during operation, to install it at the earliest refueling outage following startup during normal

seal package replacements (TVA 2011a). As a result, final decision as to the disposition of these potentially costbeneficial SAMDAs is pending.

September 2011 6-27 Draft NUREG-0498, Supplement 2
Environmental Impacts of Postulated Accidents Involving Radioactive Materials

1 was somewhat limited, the likelihood of there being cost-beneficial enhancements in this area

2 was minimized by improvements that have been realized as a result of the IPEEE process and

3 inclusion of a multiplier to account for external events. The NRC staff concurs with TVA's

4 identification of areas in which risk can be reduced in a cost-beneficial manner through the

5 implementation of the identified, potentially cost-beneficial SAMDAs. TVA has committed to

6 implement all but five cost-beneficial SAMAs, and provided adequate justification for why those

7 five will not be implemented. Therefore, the NRC staff finds that TVA's analysis meets the

8 requirements of NEPA.

9 6.4 References

10 10 CFR Part 20. Code of Federal Regulations, Title 10, Energy, Part 20, "Standards for

11 Protection Against Radiation."

12 10 CFR Part 50. Code of Federal Regulations, Title 10, Energy, Part 50, "Domestic Licensing of

13 Production and Utilization Facilities."

14 10 CFR Part 51. Code of Federal Regulations, Title 10, Energy, Part 51, "Environmental

15 Protection Regulations for Domestic Licensing and Related Regulatory Functions."

16 10 CFR Part 100. Code of Federal Regulations, Title 10, Energy, Part 100, "Reactor Site

17 Criteria."

18 National Research Council. 2006. Health Risks from Exposure to Low Levels of Ionizing

19 Radiation: BEIR VII - Phase 2. Committee to Assess Health Risks from Exposure to Low Levels

20 of Ionizing Radiation, National Research Council, The National Academies Press, Washington,

21 D.C.

22 Electric Power Research Institute (EPRI). 1991. "A Methodology for Assessment of Nuclear

23 Power Plant Seismic Margin," EPRI NP-6041-SL, Revision 1. Palo Alto, CA. August 1991.

24 Electric Power Research Institute (EPRI). 1992. "Fire-Induced Vulnerability Evaluation (FIVE),"

25 EPRI TR-100370. Palo Alto, CA. April 1992.

26 Nuclear Energy Institute (NEI). 2005. "Severe Accident Mitigation Alternatives (SAMA)

27 Analysis Guidance document." NEI 05-01, Revision A. November 2005

28 Tennessee Valley Authority (TVA). 1972. Final Environmental Statement Watts Bar Nuclear

29 Plant, Units 1, 2, and 3. Chattanooga, Tennessee.

Draft NUREG-0498, Supplement 2 6-28 September 2011
Environmental Impacts of Postulated Accidents Involving Radioactive Materials

I Tennessee Valley Authority (TVA). 1992. Letter from Mark 0. Medford, TVA, to U.S. Nuclear

2 Regulatory Commission. Subject: "Watts Bar Nuclear Plant (WBN) Units 1 and 2 - Generic

3 Letter (GL) 88-20 - Individual Plant Examination (IPE) for Severe Accident Vulnerabilities -

4 Response (TAC M74488)." September 1, 1992. Accessible at ML080070015, ML080070016,

5 ML080070017, ML080070018, ML080070019.

6 Tennessee Valley Authority (TVA). 1994a. Letter from William J. Museler, TVA, to U.S.

7 Nuclear Regulatory Commission. Subject: "Watts Bar Nuclear Plant (WBN) Units 1 and

8 Common - Generic Letter 88-20 - Individual Plant Examination (IPE) - Update of Level 1 and 2

9 Analysis." May 2, 1994. Accessible at ML080070020, ML080070025, ML080070026.

10 Tennessee Valley Authority (TVA). 1994b. Letter from Dwight E. Nunn, TVA, to U.S. Nuclear

11 Regulatory Commission Document Control Desk. Subject: "Watts Bar Nuclear Plant (WBN)

12 Units 1 and 2 - Severe Accident Mitigation Design Alternatives (SAMDAs) Evaluation from

13 Updated Individual Plant Examination (IPE) (TAC Nos. M77222 and M77223)." June 30, 1994.

14 Accessible at ML073230670.

15 Tennessee Valley Authority (TVA). 1998. Letter from P. L. Pace, TVA, to U.S. Nuclear

16 Regulatory Commission document Control Desk. Subject: "Watts Bar Nuclear Plant (WBN) Unit

17 1 - Generic Letter (GL) 88-20, Supplements 4 and 5 - Individual Plant Examination of External

18 Events (IPEEE) for Severe Accident Vulnerabilities (TAC M83693)." February 17, 1998.

19 Accessible at ML073240218.

20 Tennessee Valley Authority (TVA). 2006. "Tennessee Multi-Jurisdictional Radiological

21 Emergency Response Plan for the Watts Bar Nuclear Plant," Annex H.

22 Tennessee Valley Authority (TVA). 2008. Letter from Masoud Bajestani, TVA, to U.S. Nuclear

23 Regulatory Commission Document Control Desk. Subject: "Watts Bar Nuclear Plant (WBN)

24 Unit 2 - Final Supplemental Environmental Impact Statement for the Completion and Operation

25 of Unit 2" February 15, 2008. Accessible at ML080510469.

26 Tennessee Valley Authority (TVA). 2009a. Watts Bar Nuclear Plant (WBN) - Unit 2 - Final

27 Safety Analysis Report (FSAR). Amendment 94, Spring City, Tennessee. Accession

28 No. ML092460757.

29 Tennessee Valley Authority (TVA). 2009b. Letter from Masoud Bajestani, TVA, to U.S. Nuclear

30 Regulatory Commission Document Control Desk. Subject: "Watts Bar Nuclear Plant (WBN)

31 Unit 2 - Final supplemental Environmental Impact Statement - Severe Accident Management

32 Alternatives (TAC MD8203)." January 27, 2009. Accessible at ML090360588 and

33 ML090360589.

September 2011 6-29 Draft NUREG-0498, Supplement 2
Environmental Impacts of Postulated Accidents Involving Radioactive Materials

1 Tennessee Valley Authority (TVA). 2009c. Letter from Masoud Bajestani, TVA, to U.S. Nuclear

2 Regulatory Commission Document Control Desk. Subject: "Watts Bar Nuclear Plant (WBN)

3 Unit 2 - Additional Information in Support of TVA Final Supplemental Environmental Impact

4 Statement (FSEIS) (TAC MD8203)" October 22, 2009. Accessible at ML093510833.

5 Tennessee Valley Authority (TVA). 2009d. Letter from Masoud Bajestani, TVA, to U.S. Nuclear

6 Regulatory Commission Document Control Desk. Subject: "Watts Bar Nuclear Plant (WBN)

7 Unit 2 - Additional Information Regarding Environmental Review (TAC MD8203)"

8 December 23, 2009. Accessible at ML1 00210358.

9 Tennessee Valley Authority (TVA). 2010a. Letter from Masoud Bajestani (Watts Bar Unit 2,

10 Vice President) to U.S. Nuclear Regulatory Commission dated February 25, 2010 in response to

11 NRC letter dated December 3, 2009 and TVA letters dated July 2, 2008, January 27, 2009, and

12 December 23, 2009, 'V\atts Bar Nuclear Plant (WBN) Unit 2 - Additional Information Regarding

13 Environmental Review (TAC No. MD8203)." Accession No. ML100630115.

14 Tennessee Valley Authority (TVA). 2010b. Letter from Masoud Bajestani (Watts Bar Unit 2,

15 Vice President) to U.S. Nuclear Regulatory Commission dated October 14, 2010 in response to

16 NRC letter dated June 3, 2009 and TVA letters dated July 2, 2008, and January 27, 2009,

17 "WNatts Bar Nuclear Plant (WBN) Unit 2 - Severe Accident Management Alternatives Using

18 Latest Computer Aided Fault Tree Analysis Model - Additional Information (TAC MD8203)."

19 Accession No. ML103080030.

20 Tennessee Valley Authority (TVA). 2010c. Letter from Masoud Bajestani, TVA, to U.S. Nuclear

21 Regulatory Commission Document Control Desk. Subject: "Watts Bar Nuclear Plant (WBN)

22 Unit 2 -Severe Accident Management Alternatives Using Latest Computer Aided Fault tree

23 Analysis Model- Additional Information (TAC MD8203)." November 1, 2010. Accessible at

24 ML103080030.

25 Tennessee Valley Authority (TVA). 2010d. Letter from Masoud Bajestani, TVA, to U.S. Nuclear

26 Regulatory Commission Document Control Desk. Subject: "Watts Bar Nuclear Plant (WBN)

27 Unit 2 -Response to U.S. Nuclear Regulatory Commission (NRC) Request for Additional

28 Information Regarding Environmental Review (TAC MD8203)." April 9, 2010. Accessible at

29 ML101130392.

30 Tennessee Valley Authority (TVA). 2010e. Letter from Masoud Bajestani, TVA, to U.S. Nuclear

31 Regulatory Commission Document Control Desk. Subject: "Watts Bar Nuclear Plant (WBN)

32 Unit 2 - Probabilistic Risk Assessment Individual Plant Examination." February 9, 2010.

33 Accessible at ML100491535.

Draft NUREG-0498, Supplement 2 6-30 September 2011
Environmental Impacts of Postulated Accidents Involving Radioactive Materials

1 Tennessee Valley Authority (TVA). 201 Of. Letter from Masoud Bajestani, TVA, to U.S. Nuclear

2 Regulatory Commission Document Control Desk. Subject: "Watts Bar Nuclear Plant (WBN)

3 Unit 2 - Request for Additional Information Regarding Severe Accident Management

4 Alternatives (TAC No. MD8203)." July 23, 2010. Accessible at ML102100588.

5 Tennessee Valley Authority (TVA). 2010g. Letter from Masoud Bajestani, TVA, to U.S. Nuclear

6 Regulatory Commission Document Control Desk. Subject: "Watts Bar Nuclear Plant (WBN)

7 Unit 2 - Response to Request for Additional Information Regarding Severe Accident

8 Management Alternatives SECPOP2000 Errors (TAC MD8203)." September 17, 2010.

9 Accessible at ML102600582.

10 Tennessee Valley Authority (TVA). 2010h. Letter from Masoud Bajestani, TVA, to U.S. Nuclear

11 Regulatory Commission Document Control Desk. Subject: "Watts Bar Nuclear Plant (WBN)

12 Unit 2 - Individual Plant Examination for External Events Design Report." April 30, 2010.

13 Accessible at ML101240992.

14 Tennessee Valley Authority (TVA). 2011 a. Letter from Marie Gillman, TVA, to U.S. Nuclear

15 Regulatory Commission Document Control Desk. Subject: "Watts Bar Nuclear Plant (WBN)

16 Unit 2 - Response to Request for Additional Information Regarding Severe Accident

17 Management Alternative Review (TAC MD8203)." dated January 31, 2011. Accessible at

18 ML110340040.

19 Tennessee Valley Authority (TVA). 2011 b. Letter from David Stinson, TVA, to U.S. Nuclear

20 Regulatory Commission Document Control Desk. Subject: "Watts Bar Nuclear Plant (WBN)

21 Unit 2 - Response to Request for Additional Information Regarding Severe Accident

22 Management Alternative Review (TAC MD8203)." May 13, 2011. Accessible at ML11145A088.

23 Tennessee Valley Authority (TVA). 2011 c. Letter from David Stinson, TVA, to U.S. Nuclear

24 Regulatory Commission Document Control Desk. Subject: "Watts Bar Nuclear Plant (WBN) -

25 Unit 2 - Response to Request for Additional Information Item Numbers 2, 3, 5 and 15

26 Regarding Severe Accident Management Alternative Review (TAC MD8203)." May 25, 2011.

27 Accessible at ML1 1 147A099.

28 Tennessee Valley Authority (WVA). 201 Ild. Letter from David Stinson, WVA, to U.S. Nuclear

29 Regulatory Commission Document Control Desk. Subject: "Watts Bar Nuclear Plant (WBN) -

30 Unit 2 - Response to Request for Additional Information Regarding Severe Accident

31 Management [Design] Alternative Review (SAMDA) (TAC MD8203)." June 17, 2011.

32 Accessible at ML11171A510.

September 2011 6-31 Draft NUREG-0498, Supplement 2
Environmental Impacts of Postulated Accidents Involving Radioactive Materials

1 Tennessee Valley Authority (TVA). 201 le. Letter from David Stinson, TVA, to U.S. Nuclear

2 Regulatory Commission Document Control Desk. Subject: "Watts Bar Nuclear Plant (WBN) -

3 Unit 2 - Revised Severe Accident Management Design Alternative Review (SAMDA) Response

4 (TAC MD8203)." September 16, 2011. Accessible at ML11264A052

5 Tennessee Valley Authority (TVA). 2011 f. Letter from David Stinson, TVA, to U.S. Nuclear

6 Regulatory Commission Document Control Desk. Subject: "Watts Bar Nuclear Plant (WBN)

7 Unit 2 - Chapter 15.5 Fuel Handling Accident (FHA) Dose Analysis." October 17, 2011.

8 Accessible at ML11294A461

9 U. S. Geologic Survey (USGS). 2008. "2008 NSHM Gridded Data, Peak Ground Acceleration."

10 Available online at: http://earthquake.usqs..qov/hazards/products/conterminous/2008/data/.

11 U.S. Nuclear Regulatory Commission (NRC). 1975. Standard Review Plan for the Review of

12 Safety Analysis Report for Nuclear Power Plants. NUREG-0800. Washington, D.C. November

13 1975.

14 U.S. Nuclear Regulatory Commission (NRC). 1976. Preparation of Environmental Reports for

15 Nuclear Power Stations. Washington, D.C.

16 U.S. Nuclear Regulatory Commission (NRC). 1977. Regulatory Guide 1.109 - Calculation of

17 Annual Doses to Man from Routine Releases of Reactor Effluents for the Purpose of Evaluating

18 Compliance with 10 CFR Part 50, Appendix I. Rev. 1, Washington, D.C.

19 U.S. Nuclear Regulatory Commission (NRC). 1978a. Final Environmental Statement Related

20 to Operation of Watts Bar Nuclear Plant Units Nos. I and 2. NUREG-0498, Washington, D.C.

21 Accession No. ML082540803

22 U.S. Nuclear Regulatory Commission (NRC). 1978b. Liquid Pathway Generic Study: Impacts

23 of Accidental Radioactive Releases to the Hydrosphere from Floating and Land-Based Nuclear

24 Power Plants. NUREG-0440, Washington, D.C.

25 U.S. Nuclear Regulatory Commission (NRC). 1980. Criteria for Preparation and Evaluation of

26 Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power

27 Plants (NUREG-0654/FEMA-REP-1). Washington, D.C. Accession No. ML040420012.

28 U.S. Nuclear Regulatory Commission (NRC). 1981. Final Environmental Statement Related to

29 Operation of Fermi, Unit 2. NUREG-0769, Washington, D.C.

30 U.S. Nuclear Regulatory Commission (NRC). 1990. Severe Accident Risks: An Assessment

31 for Five U.S. Nuclear Power Plants. NUREG-1 150. Washington, D.C.

Draft NUREG-0498, Supplement 2 6-32 September 2011
Environmental Impacts of Postulated Accidents Involving Radioactive Materials

1 U.S. Nuclear Regulatory Commission (NRC). 1991. "Individual Plant Examination of External

2 Events (IPEEE) for Severe Accident Vulnerabilities." Generic Letter No. 88-20, Supplement 4.

3 Washington, D.C. June 28, 1991.

4 U.S. Nuclear Regulatory Commission (NRC). 1995. Final Environmental Statement Related to

5 the Operation of Watts Bar Nuclear Plant, Units I and 2. NUREG-0498, Supplement No. 1,

6 Office of Nuclear Reactor Regulation, Docket Nos. 50-390 and 50-391, Washington, D.C.

7 Accession No. ML081430592.

8 U.S. Nuclear Regulatory Commission (NRC). 1996. Generic Environmental Impact Statement

9 for License Renewal of Nuclear Plants. NUREG-1 1437. Washington, D.C. Accession No.

10 ML040690705

11 U.S. Nuclear Regulatory Commission (NRC). 1997a. Regulatory Analysis Technical Evaluation

12 Handbook. NUREG/BR-0184. Washington, D.C.

13 U.S. Nuclear Regulatory Commission (NRC). 1997b. Individual Plant Examination Program:

14 Perspectives on Reactor Safety and Plant Performance. NUREG-1 560. Washington, D.C.

15 U.S. Nuclear Regulatory Commission (NRC). 2000. Letter from Robert T. Martin, U.S. NRC, to

16 J. A. Scalice, TVA. Subject: "Watts Bar Nuclear Plant, Unit 1 - Review of Individual Plant

17 Examination of External Events (IPEEE) Submittal (TAC Nos. M83693)." Washington, D.C.

18 May 19, 2000.

19 U.S. Nuclear Regulatory Commission (NRC). 2003a. Memorandum from Nilesh C. Chokshi,

20 U.S. NRC, to Ashok C. Thadani, U.S. NRC. Subject: "Results of Initial Screening of Generic

21 Issue 194, 'Implications of Updated Probabilistic Seismic Hazard Estimates."' September 12,

22 2003.

23 U.S. Nuclear Regulatory Commission (NRC). 2003b. SECPOP 2000: Sector Population, Land

24 Fraction, and Economic Estimation Program. NUREGICR-6525, Revision 1. Washington, D.C.,

25 August 2003.

26 U.S. Nuclear Regulatory Commission (NRC). 2004a. An Approach for Estimating the

27 Frequencies of Various Containment Failure Modes and Bypass Events. NUREG/CR-6595

28 Revision 1. Washington, D.C. October 2004.

29 U.S. Nuclear Regulatory Commission (NRC). 2004b. Regulatory Analysis Guidelines of the

30 U.S. Nuclear Regulatory Commission. NUREG/BR-0058, Rev. 4. Washington, D.C.

September 2011 6-33 Draft NUREG-0498, Supplement 2
Environmental Impacts of Postulated Accidents Involving Radioactive Materials

1 U.S. Nuclear Regulatory Commission (NRC). 2007. Standard Review Plan for the Review of

2 Safety Analysis Reports for Nuclear Power Plants, LWR Edition. NUREG-0800, Washington,

3 D.C.

4 U.S. Nuclear Regulatory Commission (NRC). 2009a. Safety Evaluation Report, Related to the

5 Operation of Watts Bar Nuclear Plant, Unit 2, Docket No. 50-391. NUREG-0847, Supplement

6 21. Washington, D.C.

7 U.S. Nuclear Regulatory Commission (NRC). 2009b. Letter from Joel S. Wiebe, U.S. NRC, to

8 Ashok S. Bhatnagar, Tennessee Valley Authority Subject: "Watts Bar Nuclear Plant, Unit 2 -

9 Request for Additional Information Regarding Severe Accident Management Alternatives (TAC

10 No. MD8203)." Washington, D.C. November 30, 2009. Accessible at ML092230024.

11 U.S. Nuclear Regulatory Commission (NRC). 2010. NRC Information Notice 2010-18: Generic

12 Issue 199 (GI-199), "Implications of Updated Probabilistic Seismic Hazard Estimates in Central

13 and Eastern United States on Existing Plants." Washington, D.C. September 2, 2010.

14 Accessible at ML101970221.

15 U.S. Nuclear Regulatory Commission (NRC). 2011a. Letter from Justin C. Poole, U.S. NRC, to

16 Ashok S. Bhatnagar, TVA. Subject: "Watts Bar Nuclear Plant, Unit 2 -Request for Additional

17 Information Regarding Severe Accident Management Alternative Review (TAC No. MD8203)."

18 January 11,2011. Accessible at ML103470681.

19 U.S. Nuclear Regulatory Commission (NRC). 2011 b. Letter from Patrick D. Milano, U.S. NRC,

20 to Ashok S. Bhatnagar, TVA. Subject: "Watts Bar Nuclear Plant, Unit 2.- Supplemental

21 Request for Additional Information Regarding Severe Accident Management Design

22 Alternatives Review (TAC No. MD8203)." March 30, 2011. Accessible at ML110820858.

23 U.S. Nuclear Regulatory Commission (NRC). 2011 c. Letter from Justin C. Poole, U.S. NRC, to

24 Ashok S. Bhatnagar, TVA. Subject: "Watts Bar Nuclear Plant, Unit 2 - Supplemental Request

25 for Additional Information Regarding Severe Accident Management Design Alternatives Review

26 (TAC No. MD8203)." June 13, 2011. Accessible at ML111530523.

Draft NUREG-0498, Supplement 2 6-34 September 2011
1 7.0 Environmental Impacts of Alternatives

2 The National Environmental Policy Act (NEPA) requires the consideration of reasonable

3 alternatives to the proposed action in an environmental impact statement (EIS). In this case,

4 the proposed action is whether to issue a 40-year operating license to the Tennessee Valley

5 Authority (TVA) for Watts Bar Nuclear (WBN) Unit 2. However, a license is just one of a number

6 of conditions that a licensee must meet in order to operate its nuclear plant. After the U.S.

7 Nuclear Regulatory Commission (NRC) issues an operating license, state regulatory agencies

8 and the owners of the nuclear power plant ultimately decide whether the plant will operate, and

9 economic and environmental considerations play a primary role in this decision.

10 The NRC is responsible for ensuring the safe operation of commercial nuclear power facilities in

11 the United States and does not formulate energy policy or encourage or deter the development

12 of alternative power generation. The NRC also has no authority or regulatory control over the

13 ultimate selection of alternative power generation and cannot ensure that environmentally

14 preferable energy alternatives are used in the future. While the NRC considers a range of

15 reasonable alternatives to issuing an operating license, the only alternative within NRC's

16 decision-making authority is not to issue it.

17 In this chapter, the NRC has considered the environmental consequences of no-action (i.e., not

18 issuing the license) and various energy alternatives that could replace the generating capacity

19 of WBN Unit 2. The assessment is limited to a description of each energy alternative and its

20 environmental impact. The no-action alternative is discussed in Section 7.1 and alternative

21 power generation in Section 7.2.

22 It may be worth noting that if the NRC issues an operating license, all of the alternatives,

23 including the proposed action, would be available to energy-planning decision-makers.

24 Conversely, if NRC does not issue the operating license (or takes no action at all), then energy25 planning decision makers would have to resort to finding alternative ways of generating

26 electricity-which may or may not be one of the energy alternatives discussed in this section27 to meet their energy needs.

28 In its Final Environmental Statement for the construction of WBN Units 1 and 2 (1972 FES-CP)

29 (TVA 1972), TVA considered a number of alternatives to constructing and operating WBN Units

30 1 and 2. Among those alternatives were construction and operation of coal-fired units,

31 hydroelectric units, gas-fired units, oil-fired units, and the no-action alternative. These

32 alternatives were either deemed not feasible, more costly, and/or more environmentally

33 detrimental than construction and operation of WBN Units 1 and 2. Since that time, TVA

34 evaluated a range of alternatives as part of its integrated resource planning process, which the

35 NRC considered and evaluated in its Supplement No. 1 to the FES related to the operating

September 2011 7-1 Draft NUREG-0498, Supplement 2
Environmental Impacts of Alternatives

1 license (1995 SFES-OL-1) in December 1995 (NRC 1995). In tiering off the original 1972

2 FES-CP, the 1995 SFES-OL-1, and the balance of the environmental record pertinent to WBN,

3 TVA did not identify any new alternatives or resource options beyond those already addressed

4 in previous documents (TVA 1972; NRC 1995). In addition to factors considered in the

5 1972 FES-CP, TVA stated that completing WBN Unit 2 would provide baseload power in the

6 region of interest, help reduce fossil plant emissions, and lower the cost of power in its service

7 area (TVA 2008a, 201 la). Since the 1978 FES-OL, TVA has produced two publicly available

8 long-term (i.e., 20 or more years) integrated resource plans (IRPs), which evaluate an

9 assortment of power supply alternatives to meet the power demand in the TVA service area. In

10 December 1995, TVA completed an IRP identifying and selecting long-range electricity

11 generation strategies intended to meet the electricity needs of its customers with a forecast

12 period extending from 1996 to 2020 (TVA 1995). On March 2, 2011, TVA issued its most recent

13 IRP with a forecast period extending from 2011 to 2029 (TVA 2011a). On April 14, 2011, the

14 TVA Board of Directors accepted the IRP and authorized the Chief Executive Officer to use its

15 recommended planning direction as a guide in energy resource planning and selection. On

16 July 6, 2011, TVA issued its Record of Decision stating that TVA will adopt the preferred

17 alternative in its final EIS for the IRP (76 FR 39470).

18 As discussed in Chapter 1, the purpose for this SFES is to update the prior environmental

19 review and only cover matters that differ from the final EIS or that reflect significant new

20 information concerning matters discussed in the final EIS. Unless determined by the

21 Commission, a supplement will not include a discussion of need for power or of alternative

22 energy sources (10 CFR 51.95(b)). In this case, the Commission has directed NRC staff to take

23 to take a "hard look" at new information related to alternative energy sources and to supplement

24 the FES with a discussion of those alternative energy sources if new and significant relevant

25 information exists (NRC 2010). While TVA evaluated a set of power generation alternatives as

26 part of the FES (TVA 1972), the evaluation was limited to generation technologies, resources,

27 and information available in 1972. The NRC staff found that energy alternatives have changed

28 substantially in terms of performance and viability since TVA submitted its Watts Bar Unit 2

29 Construction Permit EIS in 1972, almost 40 years ago (TVA 1972). The NRC staffs

30 1978 FES'-OL did not address power generation alternatives. As a result, the NRC staff found it

31 appropriate to update, in this SFES, the NRC staffs consideration of energy alternatives and

32 their relative impacts.

33 7.1 No-Action Alternative

34 As previously discussed, under the no-action alternative the NRC would not issue an operating

35 license to TVA, and WBN Unit 2 would not operate. If the NRC does not issue the operating

36 license, there would be no environmental impacts from operation of WBN Unit 2; the

37 environmental impacts of construction of WBN Unit 2 have largely occurred, and so would not

38 be avoided. Under the no-action alternative, an expected 1,160-MW(e) net electrical output

Draft NUREG-0498, Supplement 2 7-2 September 2011
Environmental Impacts of Alternatives

1 from WBN Unit 2 would not be generated, thus the benefits associated with the proposed new

2 power production would not be realized in the TVA service area (i.e., no electricity would be

3 generated).

4 TVA has indicated that if the WBN Unit 2 operating license is not issued, it would not be able to

5 maintain an adequate reserve margin and would fail to meet its public service obligations to

6 provide sufficient power within its service territory. The determination of the need for power in

7 the TVA service area is discussed in Chapter 8 of this FES. TVA would also not be able to

8 meet its obligations to provide capacity to other suppliers of electricity within the Southeastern

9 Electric Reliability Corporation (SERC) region. Therefore, TVA would likely pursue various

10 replacement power options by implementing one or some combination of the following actions

11 (TVA 2008b, 2011a):

12 * Demand-side management (DSM): DSM programs consist of planning, implementing, and

13 monitoring activities that enable and encourage consumers to reduce and/or modify their

14 levels and patterns of electricity usage. By reducing customers' demand for energy through

15 energy efficiency, conservation, and load management, the need for additional generation

16 capacity can be reduced, postponed, or even eliminated. In addition to existing and planned

17 DSM programs, TVA would need to implement more aggressive programs as conditions

18 necessitate. However, even with additional DSM activities, alternative power sources would

19 need to be acquired. TVA refers to its DSM activities as energy efficiency and demand

20 response. Demand response shifts energy use to periods of lower demand, while energy

21 efficiency reduces energy consumption.

22 * Purchase power: TVA could attempt to purchase power from other suppliers of electricity

23 within the SERC region to fill short-term needs.

24 Construct alternative replacement power generation: TVA could pursue the construction

25 and operation of a replacement power plant using alternative energy sources, such as a

26 coal-fired or combined cycle gas-fired power plant.

27 TVA already offers several DSM programs to its customers to reduce peak electricity demands

28 and daily power consumption. The impacts of these programs have been incorporated in TVA's

29 demand forecast and included in its need-for-power analysis, which is discussed in Chapter 8 of

30 this SFES. Current programs provide incentives to install and implement energy-efficient

31 equipment and technologies, weatherization and insulation programs, and programs that

32 provide technical assistance and educational material in an effort to assist customers in

33 conserving energy. TVA anticipates fiscal year 2010 demand reductions from DSM activities to

34 offset approximately 100 MW(e) of power generation capacity. Although these DSM programs

35 play an important role in reducing peak load power, they would not significantly reduce baseload

36 consumption, and would not be a reasonable alternative for the 1,1 60-MW(e) capacity expected

37 from WBN Unit 2 (TVA 201 Ia).

September 2011 7-3 Draft NUREG-0498, Supplement 2
Environmental Impacts of Alternatives

1 To the extent that TVA would rely on new or existing resources from outside the TVA region to

2 offset the power that would otherwise be produced by WBN Unit 2, these resources would likely

3 produce impacts (e.g., air, groundwater, socioeconomics) from construction (for new resources)

4 and operations (for new and existing resources) in areas outside the TVA region.

5 7.2 Energy Alternatives

6 The current rule governing environmental review at the operating license stage (10 CFR 51.95)

7 states that, unless otherwise determined by the Commission, a supplement on the operation of

8 a nuclear power plant will not include a discussion of need for power or a discussion of

9 alternative energy sources. For WBN Unit 2, the Commission authorized the staff to include

10 those topics if, through its requisite "hard look," the staff concludes that new and significant

11 information is available (NRC 2010). The NRC staff found that energy alternatives have

12 changed substantially in terms of performance and viability since TVA submitted its Watts Bar

13 Unit 2 Construction Permit EIS in 1972 (TVA 1972). As a result, the NRC staff found it

14 appropriate to update, in this SFES, the NRC staffs consideration of energy alternatives and

15 their relative impacts.

16 TVA is seeking an operation license for WBN Unit 2 to produce an additional 1,160-MW(e) net

17 electrical baseload power for the TVA service area. This section examines the potential

18 environmental impacts associated with constructing and operating replacement baseload power

19 plants using alternative energy sources. Alternatives considered, but eliminated from detailed

20 study, are described in Section 7.2.1. Section 7.2.2 describes the environmental impacts from

21 the natural-gas-fired power generation alternative. A combination alternative is discussed in

22 Section 7.2.3. A comparison of the environmental impacts from natural-gas-fired power

23 generation and a combination alternative of power generating options at or near the WBN site

24 are presented in Section 7.2.4.

25 The NRC staff's selection of a reasonable set of energy alternatives to the operation of WBN

26 Unit 2 was limited to power-generation technologies that are technically reasonable and

27 commercially viable (NRC 2000). The staffs analysis uses information from the Generic

28 Environmental Impact Statement (GELS), as well as other sources including the U.S.

29 Department of Energy (DOE), the Environmental Protection Agency (EPA), and TVA.

30 For this analysis, a bounding value of 1 ,160-MW(e) electrical output replacement baseload

31 power was used for comparison purposes, because this is the proposed generation capacity of

32 WBN Unit 2. When reasonable, the WBN site would be used as the location for alternative

33 replacement power generation and existing structures would be used to support these

34 alternatives to minimize impacts and for ease of comparison. The WBN site occupies

35 approximately 427 ha (1,055 ac) within the Watts Bar reservation, which is 690 ha (1,700 ac) of

36 land owned by the U.S. Federal Government in the custody of the TVA. The reservation

Draft NUREG-0498, Supplement 2 7-4 September 2011
Environmental Impacts of Alternatives

1 includes the WBN site, the Watts Bar Dam and Hydro-Electric Plant, the Watts Bar Fossil Plant,

2 the TVA Central Maintenance Facility, and the Watts Bar Resort Area (TVA 2008a). Closed3 cycle cooling with natural draft or mechanical cooling towers is assumed for all thermal plants.

4 It is also assumed that the existing 500-kV electric power transmission lines could be used to

5 serve a new baseload power-generation facility at the WBN site.

6 7.2.1 EIA Power Generation Outlook

7 Each year, the Energy Information Administration (EIA), a component of DOE, issues an annual

8 energy outlook. In its Annual Energy Outlook 2011 (DOE/EIA 2010), the EIA reference case

9 projects that coal-fired capacity will account for approximately 43 percent of the total additions of

10 electric generating capacity between 2011 and 2035. The EIA projects that during this period,

11 natural-gas-fired plants, renewable energy sources, and new nuclear plants will account for

12 approximately 25 percent, 14 percent, and 17 percent of new capacity additions, respectively.

13 The EIA projections are based on the assumption that providers of new generating capacity

14 would seek to minimize cost while meeting applicable environmental requirements (DOE/EIA

15 2010).

16 7.2.2 TVA Resource Planning

17 TVA states that the purpose and need of its proposal to operate WBN Unit 2 is to meet the need

18 for additional baseload capacity in the TVA service area (TVA 2008b). TVA's current and

19 planned power generation system uses a range of technologies to produce electricity and meet

20 the needs of the TVA service area. In 2010, coal-fired generation made up approximately 40

21 percent of TVA's capacity electricity generation mix, while nuclear generation made up

22 approximately 19 percent, combustion turbines and combined cycle (primarily fueled with

23 natural gas) generation together made up 24 percent, and hydro power provided 8 percent. The

24 remaining 9 percent of TVA's electricity generation capacity was made up of diesel-fired

25 generation, pumped storage, renewable energy sources, and DSM activities (TVA 201 la).

26 In its most recent IRP, TVA evaluated resource options that it considers to be developed and

27 proven technologies, or that have reasonable prospects of becoming commercially available

28 before 2029. TVA also only considers resource technologies that are available to TVA either

29 within the TVA region or importable through market purchases and that are economical and

30 contribute to the reduction of emissions of air pollutants, including greenhouse gases. As part

31 of its IRP process, TVA evaluated 100 supply-side (i.e., generation) and 60 demand-side (i.e.,

32 DSM) resource options. By 2020, TVA expects DSM activities to offset approximately 3,600 to

33 5,100 MW(e) of capacity and renewable generation additions to provide approximately 1,500 to

34 2,500 MW(e) of generation capacity. TVA also plans to increase its pumped storage capacity,

35 nuclear, and natural-gas-fired generation capacity. TVA idled three coal-fired units in 2010 for

36 environmental and economic reasons and is considering idling an additional 2,400 to 7,000

September 2011 7-5 Draft NUREG-0498, Supplement 2
Environmental Impacts of Alternatives

1 MW(e) of coal-fired capacity over the next 20 years to reduce emissions. TVA's recommended

2 planning direction includes up to 900 MW(e) of new coal-fired capacity, but these coal-fired

3 additions consist solely of integrated gasification combined-cycle (IGCC) units equipped with

4 carbon capture and sequestration technologies. TVA projects that these units would not come

5 online until 2025 and 2029 (TVA 2011 a), well after WBN Unit 2 is needed.

6 7.2.3 Alternatives Considered but Dismissed

7 This section discusses alternatives to licensing WBN Unit 2 that were eliminated from detailed

8 study due to technical, resource availability, or commercial limitations. NRC believes that these

9 limitations would continue to exist when WBN Unit 2 begins operation. Any reasonable

10 alternative to WBN Unit 2 would need to generate an equivalent amount of baseload power.

11 Under each of the following technology headings, the NRC explains why it dismissed each

12 alternative from further consideration. Offsite coal and gas-fired alternatives were not

13 considered because constructing and operating a new power plant at an offsite location would

14 generally cause greater impacts than constructing and making use of existing infrastructure at

15 the WBN site.

16 7.2.3.1 Alternatives Not Requiring the Construction of New Power Generating Capacity

17 Four alternatives to the proposed action that do not require the construction of new power

18 generating capacity are as follows:

19 9 Purchasing power

20 9 Extending the operating life of existing plants

21 9 Reactivating retired plants

22 * Implementing DSM programs.

23 TVA is part of SERC, which is the largest of eight regional reliability councils within the North

24 American Electric Reliability Corporation (NERC). TVA regularly reviews purchased power

25 supply options through its Bulk Power Trading Group, and TVA already has entered into several

26 long-term purchase contracts to meet future capacity estimates. As previously discussed,

27 although some percentage of TVA's forecasted baseload replacement power might be met with

28 purchased power (if available), purchased power is already included in TVA's current and future

29 capacity estimates. Therefore, any power that is purchased to replace WBN Unit 2 power would

30 be dependent on the availability of baseload power and would need to be some amount above

31 and beyond what is already accounted for in current and planned purchase power agreements

32 (TVA 2011 a).

33 Under the purchased power alternative, the environmental impacts of power production would

34 still occur but would be located elsewhere within the region, nation, or in another country. The

Draft NUREG-0498, Supplement 2 7-6 September 2011
Environmental Impacts of Alternatives

1 environmental impacts would depend on the generation technology and location of the

2 generation site. In addition, new transmission line rights-of-way may be required.

3 TVA currently has purchase power agreements with generators producing power fueled by

4 natural gas, coal, diesel, wind, biomass, munipal waste, and hydroelectricity. These facilities

5 are in various locations, including Alabama, Mississippi, Tennessee, Illinois, Kentucky, Iowa,

6 and North Carolina. In addition, TVA has pending power purchase agreements for renewable

7 energy from Iowa, Illinois, Kansas, South Dakota, and North Dakota. TVA notes that the

8 execution of the pending power purchase agreements for renewable energy is dependent on

9 meeting applicable environmental review requirements and securing firm transmission paths for

10 the delivery of the power to the TVA system (TVA 2011 a). The construction of new lines could

11 have environmental consequences. Overall impacts from purchased power would be SMALL

12 when existing transmission line right-of-ways are used and operational impacts are minor (i.e.,

13 impacts are not noticeable or do not affect important attributes of the resources) to LARGE if

14 acquisition and conversion of new right-of-ways is required, or when operational impacts alone

15 destabilize resources or important attributes of the resources.

16 TVA's existing nuclear power facilities were initially licensed by the NRC for a period of 40

17 years. The operating license can be renewed for up to 20 years, and NRC regulations permit

18 additional license renewal. TVA currently operates three nuclear plants with a combined

19 capacity of 6,900 MW(e); this includes three reactors on the Browns Ferry site in Alabama, two

20 at the Sequoyah Nuclear Plant site in Tennessee, and one on the WBN site. The Browns Ferry

21 Plant has received renewed operating licenses from the NRC (extending the licenses for its

22 Unit 1 to 2033, Unit 2 to 2034, and Unit 3 to 2036). The environmental impacts of continued

23 operation of a nuclear power plant are significantly less than construction of a new plant;

24 however, TVA has assumed that these units will continue to operate and has included their

25 continued operation in its forecast, so the NRC staff does not separately consider continued

26 operation of existing nuclear facilities here. The impacts of operating and uprating other nuclear

27 units in the TVA service area either have been examined by the NRC in separate EISs or

28 environmental assessments, or will be so examined if and when TVA applies to NRC for future

29 license renewals or power uprates. The expected generating capacity of all of TVA's nuclear

30 power plants, including the approved uprates at all three nuclear plants, is included in the power

31 supply forecast of the need-for-power assessment included in Chapter 8 of this SFES (TVA

32 2011 a).

33 As previously discussed, three of TVA's coal-fired units were idled in fall 2010, and future idling

34 of units is anticipated in the coming years. TVA decides which plants to idle based on

35 environmental compliance costs, operational and maintenance costs, outage rates, waste

36 disposal costs, operational flexibility, and carbon dioxide and other greenhouse gas emissions.

37 In August 2010, TVA announced that the following nine coal units with a total capacity of about

38 1,000 MW(e) would be idled (TVA 2011 a):

September 2011 7-7 Draft NUREG-0498, Supplement 2
Environmental Impacts of Alternatives

1 e Two units at Widows Creek in 2011

2 * Shawnee Unit 10 in 2011, which will be evaluated for conversion to a dedicated biomass3 fueled unit

4 * The remaining four older units at Widows Creek by 2015

5 9 Units 1 and 2 at John Sevier by 2015.

6 Older fossil-fueled power plants needing extensive and costly refurbishment have difficulty

7 meeting current and more restrictive environmental standards, and thus TVA does not have

8 plans to retrofit the idled coal facilities. Also, TVA plans to phase out all petroleum-based (i.e.,

9 oil and diesel) generation over the next 20 years (TVA 2011 a), although gas-fired generation will

10 retain the capacity to use diesel as a backup fuel (TVA 201 lb). TVA has already included the

11 planned capacity of fossil plants in its-existing fleet that are upgraded with additional

12 environmental controls in its need-for-power assessment in Chapter 8 of this SFES. According

13 to TVA's IRP, natural-gas-fired plants will be the only fossil-fueled generation TVA plants to be

14 added to its generation mix over the next 10 to 15 years (TVA 201 la).

15 TVA has an existing portfolio of DSM programs, which include energy-efficiency and demand16 response programs. Demand-response programs are designed to temporarily reduce a

17 customer's use of electricity, typically during peak periods when demand is highest. Demand18 response programs do not typically reduce overall energy consumption, but may help a utility

19 reduce the need for peaking, and in some cases, intermediate duty-cycle facilities. Energy

20 efficiency programs are designed to reduce overall energy consumption without any decrease in

21 services to the customer.

22 By reducing customers' demand for energy through energy-efficiency, conservation, and load

23 management, the need for additional generation capacity can be reduced, postponed, or even

24 eliminated. The impacts of existing programs are already incorporated in TVA's demand

25 forecast and are included in its need-for-power analysis presented in Chapter 8 of this SFES.

26 Current programs provide incentives to install and implement energy-efficient equipment and

27 technologies, weatherization and insulation programs, and programs that provide technical

28 assistance and educational material in an effort to assist customers in conserving energy. TVA

29 currently has a DSM portfolio that is estimated to reduce peak capacity by approximately

30 770 MW(e) in the 2012 (TVA 2011 b). TVA plans to continue supporting DSM programs;

31 however, although the DSM strategies can play an important role in reducing peak load power,

32 they are not expected to adequately reduce baseload consumption by 2012 to offset WBN Unit

33 2 capacity. As a result, they would not be a reasonable alternative to operating WBN Unit 2.

Draft NUREG-0498, Supplement 2 7-8 September 2011
Environmental Impacts of Alternatives

1 7.2.3.2 Coal-Fired Power Generation

2 Coal-fired power plants are primarily used to provide baseload power. DOE projects that coal3 fired power plants will account for approximately 43 percent of the total additions of electric

4 generating capacity in the United States between 2011 and 2035 (DOE/EIA 2010). In general,

5 a 1,160 MW(e) coal-fired power plant would have noticeable effects on the environment. Some

6 of these effects would include increased sulfur dioxide (SO2), nitrogen oxides (NOx), carbon

7 monoxide (CO), carbon dioxide (CO 2) and particulate matter (PM) emissions, water quality and

8 thermal impacts, loss of terrestrial habitat, and potential impacts to cultural resources at WBN

9 Unit 2. Coal-fired power plants also produce a substantial waste stream of ash and scrubber

10 sludge, which would either be disposed of or recycled. Ash and scrubber sludge disposal for a

11 1,160 MW(e) plant over a 40-year operating life would require approximately 200 ac (81 ha) of

12 land.

13 Currently, approximately half of TVA's electric power generation is coal-fired; however, TVA

14 idled three coal-fired units in 2010 for environmental and economic reasons and is considering

15 idling an additional 2,400 to 7,000 MW(e) of coal-fired capacity over the next 20 years to reduce

16 emissions of S02, NOx, CO, CO 2, PM, and mercury (Hg) in the TVA service area (TVA 201 Ia).

17 Reducing fossil fuel emissions in the TVA service area is part of TVA's overarching goal of

18 providing an affordable, clean, and reliable supply of electricity. TVA's Integrated Resource

19 Plan: TVA's Environmental & Energy Future (TVA 201 la) includes five resource planning

20 strategies, and only one strategy includes an expansion of coal-fired generation. In addition, the

21 one strategy that includes coal-fired generation specifies that 900 MW(e) of coal-fired capacity

22 could be added between the years 2025 and 2029 and that this capacity would consist entirely

23 of integrated gasification combined-cycle (IGCC) units equipped with carbon capture and

24 sequestration technologies (TVA 201 la). IGCC generation technology, which combines

25 modern coal gasification technology with both gas turbine and steam turbine power generation,

26 could reduce some environmental impacts associated with conventional coal-fired generation.

27 The IGCC technology is cleaner than conventional, pulverized coal plants because major

28 pollutants can be removed from the gas stream before combustion, and plants produce smaller

29 volumes of wastes. Despite IGCC's environmental advantages when compared to conventional

30 coal facilities, IGCC plants are more expensive than comparable pulverized coal plants, and

31 system reliability and capacity factors of existing IGCC plants (operating without carbon capture

32 and sequestration) have been lower than pulverized coal plants (NETL 2010). In addition, IGCC

33 with carbon capture and sequestration has not yet been implemented anywhere in the United

34 States.

35 TVA currently has three idled coal-fired units in its generation fleet with a combined capacity of

36 226 MW (e) (TVA 201 la). If these plants were to be kept online and other older previously

37 retired coal-fired plants were brought back online, they could potentially serve as alternative

38 baseload generation to proposed WBN Unit 2. This option, however, would likely prevent TVA

September 2011 7-9 Draft NUREG-0498, Supplement 2
Environmental Impacts of Alternatives

1 from achieving its environmental goals to reduce carbon emissions. In addition, any retired

2 coal-fired plant would likely need to be refurbished to extend the plant life and meet current

3 environmental requirements, which would be costly. The integrated resource strategy

4 recommended to the TVA executive board in its EIS for TVA's IRP (TVA 2011 b) includes the

5 idling of 2,400 to 4,700 MW(e) of coal capacity during the next 20 years as part of its goal to

6 reduce carbon dioxide emissions to meet environmental stewardship goals (TVA 2011 a,

7 2011 b). Although the EIS for the IRP recommends a plan that includes a 900-MW(e) expansion

8 of coal-fired capacity, this coal-fired option would not come online until the 2025-2029

9 timeframe (TVA 2011 b). Based on TVA's IRP and recommendations from its EIS for the IRP,

10 as well as the experience to date with IGCC plants, constructing and operating a coal-fired

11 power plant and or repowering existing retired or idled coal-fired plants would not be a

12 reasonable alternative to operating WBN Unit 2 as a baseload power plant by 2012.

13 7.2.3.3 Oil-Fired Power Generation

14 The EIA's reference case projects that oil-fired power plants would not account for any new

15 electric power-generation capacity in the United States through 2035 (DOE/EIA 2010). Oil-fired

16 generation is more expensive than nuclear, natural-gas-fired, or coal-fired power-generation

17 options. In addition, future increases in oil prices are expected to make oil-fired generation

18 increasingly more expensive. The high cost of oil has resulted in a decline in its use for

19 electricity generation and oil-fired generation currently makes up less than two percent of the

20 existing capacity within the SERC region (SERC 2010). Oil-fired plants are designed to start up

21 quickly and are used exclusively during periods of peak power demand. WVA has no additional

22 petroleum-based power generation options proposed for future capacity needs in the TVA

23 service area, and TVA plans to phase out petroleum power purchases by 2029 (TVA 2011 a).

24 For the preceding economic and environmental reasons, constructing and operating an oil-fired

25 power plant at the WBN site would not be a reasonable alternative to operating WBN Unit 2 as a

26 baseload power plant.

27 7.2.3.4 Wind Power

28 Estimates of the wind resource potential in a region are expressed in wind power classes

29 ranging from Class 1 (low) to Class 7 (high), with each class representing a range of mean wind

30 power density or equivalent mean speed at specified heights above the ground. Areas

31 designated Class 4 or greater are suitable for siting advanced wind turbine technology under

32 development today (USACE 2004). The generation capacity is low within the overall TVA

33 region, which has Class 1 or 2 wind power ratings (DOE 2005). TVA is already using potential

34 wind power-generation sites such as the Buffalo Mountain Ridge in Tennessee, which produces

35 29 MW(e) of wind-generated power (TVA 2008b, 2011 a). Outside of the TVA service area, TVA

36 has power purchase agreements with a 300-MW(e) windfarm in Illinois, a 11 5-MW(e) windfarm

37 in Iowa, and a pending power purchase agreement with an additional 1,080 MW(e) of windDraft NUREG-0498, Supplement 2 7-10 September 2011
Environmental Impacts of Alternatives

1 generated power from six windfarms outside the TVA service area (TVA 2011 a). A utility-scale

2 wind-generation plant would generally require about 1 ha (2.5 ac) per MW(e) of installed

3 capacity, although a portion of this land could be used for other purposes (Denholm et al. 2009).

4 Based on regional wind resource studies, it is estimated that approximately 4,200 MW(e) of

5 wind capacity energy is available within the TVA service area; however, some of this acreage

6 may be in protected areas unavailable for development and the average capacity factor for this

7 wind resource would be about 25 percent (TVA 2011 a). Newer wind turbines typically operate

8 at approximately a 36-percent capacity factor (DOE 2008a). In comparison, the average

9 capacity factor for a nuclear power-generation plant in 2009 in the United States was 90.5

10 percent (NEI 2010).

11 Because of the intermittent nature and limited regional availability of wind resources in the TVA

12 region of interest, wind generation would not be a reasonable alternative to the proposed 1,160-

13 MW(e) baseload generation. Because some neighboring regions outside of the TVA service

14 area, such as Illinois, have higher classes of wind resources and are eligible to receive

15 production tax credits for wind generation (TVA is not eligible for such credits), TVA has

16 determined that the least-cost solution to integrating more wind into their generation portfolio is

17 to purchase wind through power purchase agreements (TVA 2011 a, 2011 b).

18 7.2.3.5 Energy Storage

19 Wind turbines and other renewable generation generally can serve as an intermittent baseload

20 power supply and TVA currently generates intermittent wind power in its region of interest.

21 Energy storage, such as battery storage, compressed air energy storage (CAES) facility, or a

22 pumped storage facility can be coupled with wind or other intermittent power sources to

23 simulate baseload generation. A storage facility can capture the power of the wind during low

24 load times and use it during higher load times. Because storage facilities do not directly

25 generate electricity, but instead convert electric energy to potential (pumped storage and CAES)

26 or chemical (batteries) energy, they are not suitable stand-alone alternatives to WBN Unit 2.

27 Furthermore, this conversion process results in some efficiency losses, so storage facilities tend

28 to have net negative effect on generating capacity.

29 TVA has an existing 1,600-MW(e) pumped storage plant at Raccoon Mountain, near

30 Chattanooga, Tennessee. An additional pumped-storage resource option of 850 MW(e) was

31 included in all five of TVA's IRP future strategies going forward and TVA also includes an

32 expanded CAES option as part of its IRP. TVA did not evaluate any electric battery storage

33 options because of operational limitations (TVA 2011 a). With the Raccoon Mountain facility,

34 excess energy from lower cost generating resources is used to pump water from Nickajack

35 Reservoir to the upper reservoir during periods of low power demand. The pumps are

36 reversible and used as turbines to produce power using water from the upper reservoir during

37 periods of high demand. Additional pumped storage sites are available in the TVA region and

September 2011 7-11 Draft NUREG-0498, Supplement 2
Environmental Impacts of Alternatives

1 could be developed to store excess wind energy from off-peak periods and produce power in

2 periods when wind power is not available; however, these facilities would be associated with

3 noticeable environmental impacts. Pumped storage plants require 2,000 to 3,000 ac for the

4 upper pool, the generating plant, and a lower pool if another reservoir is not available. There

5 would be impacts on terrestrial and aquatic resources as well as socioeconomic and cultural

6 resource impacts. Additional operational impacts for pumped storage facilities include

7 environmental impacts of the operation of thermal plants that might be used to supply power to

8 the plant in pumping mode (TVA 2010a).

9 With CAES, the wind turbines provide the power to compress the air into a storage volume,

10 such as an underground salt cavern or aquifer. The compressed air is discharged from the

11 storage volume into a set of gas turbines that are fired with natural gas. The efficiency of the

12 turbines is improved because compression of the inlet air is provided by the CAES facility

13 instead of by the turbine itself. The only operating CAES system in the United States is the 110

14 MW(e) facility in Alabama, the McIntosh Power Plant (TVA 2010a). Although coupling wind with

15 CAES reduces the problem of intermittency, it increases the air quality impacts by combusting

16 natural gas. In addition, CAES technology is still in the demonstration phase and is not

17 technologically mature.

18 Although it is technically feasible to couple wind or other intermittent resources with energy

19 storage to reduce intermittency, doing so increases environmental impacts (particularly for

20 pumped storage facilities), creates a net loss in energy (because some energy is lost in the

21 operation of the energy storage facility), and many storage technologies (e.g., CAES and

22 batteries) are not yet available in the capacities necessary to support an intermittent

23 replacement for WBN Unit 2. As a result, the NRC staff does not consider any intermittent

24 generating options coupled to energy storage technologies as an alternative to WBN Unit 2 in

25 this SFES.

26 7.2.3.6 Solar Power

27 There are currently two practical methods of producing electricity from solar energy:

28 photovoltaics and solar thermal power. Photovoltaics (also referred to as solar cells) convert

29 sunlight directly into electricity using semiconducting materials. Solar thermal technologies use

30 concentrating devices to create temperatures suitable for power production. Concentrating

31 thermal technologies are currently less costly than photovoltaics for bulk power production.

32 They also can be provided with energy storage or auxiliary boilers to allow operation during

33 periods when the sun is not shining (NWPCC 2006).

34 Solar technologies produce more electricity with more intense and direct sunlight. For solar

35 power generation using concentrating solar power, the annual average amount of solar energy

36 reaching the ground needs to be 6 kWh/m 2 per day or higher (NREL 2002). Based on solar

37 radiation maps developed by the National Renewable Energy Laboratory, TVA has an

Draft NUREG-0498, Supplement 2 7-12 September 2011
Environmental Impacts of Alternatives

1 estimated average solar radiation of 4.9 kWh/m 2 per day (TVA 2011 a). Average annual

2 capacity factors for solar power systems in the TVA region are about 24 percent for

3 photovoltaics and 30 to 32 percent for solar thermal power (TVA 2008b). In comparison, the

4 average capacity factor for a nuclear power plant in 2009 in the United States was 90.5 percent

5 (NEI 2010). The lands with the best solar resources are usually arid and semi-arid. In the

6 United States, the largest operational solar thermal plant is the 64 MW(e) Nevada Solar One

7 plant located near Las Vegas, Nevada (DOE/EIA 2009).

8 TVA currently has experience with solar power technologies through its Green Power Switch

9 Generation Partners. As part of this program, TVA owns 15 photovoltaic installations with a

10 combined capacity of about 400 kW (TVA 2011 a) and pays consumers for energy generated by

11 renewable resource technologies, such as solar photovoltaics. In early 2010, 172 facilities with

12 a total generating capacity of about 2 MW(e) were enrolled in the program and generating about

13 34,000 kWh per month (TVA 2011 a).

14 Because of solar power generation's intermittent nature as well as the regional solar radiation

15 characteristics, the acreage requirements, and expense of solar power generation, a solar16 energy facility at the WBN site would not currently be a reasonable alternative to operating WBN

17 Unit 2.

18 7.2.3.7 Hydropower

19 TVA currently operates 110 conventional hydroelectric generating units at 29 dams with a

20 combined capacity of 3,538 MW(e). TVA hydroelectric plants are primarily operated to provide

21 peaking power; during periods of abundant precipitation, they may also be operated to provide

22 intermediate power (TVA 2011 a). In addition, their availability is dependent on the availability of

23 water and the necessity to control water flow to meet broad multi-purpose goals as established

24 in TVA's Reservoir Operations Policy. Approximately 10 percent of TVA's current generation

25 capacity is met with hydropower. TVA currently has an ongoing effort to gain megawatt

26 capacity through modernization of aging hydropower systems, and this additional capacity is

27 included in TVA's forecast as presented in the assessment of the need for power, found in

28 Chapter 8 of this SFES (TVA 2011 a).

29 A 2006 study by the Idaho National Engineering and Environmental Laboratory identified an

30 approximate additional 1,770 MW(e) of undeveloped hydropower resource in the TVA service

31 area (INEEL 2006). However, none of the feasible capacity is categorized as large power

32 sources (greater than 60 MW(e)). Approximately 70 percent of the feasible hydropower

33 capacity was categorized as small hydro and the remaining 30 percent was categorized as low

34 power resources (less than 2 MW(e)) (TVA 201 la).

September 2011 7-13 Draft NUREG-0498, Supplement 2
Environmental Impacts of Alternatives

1 Because of the relatively low amount of undeveloped hydropower resource in the TVA region

2 and the large land-use and related environmental and ecological resource impacts associated

3 with siting hydroelectric facilities large enough to produce 1, 160 MW(e), hydropower is not a

4 feasible alternative to operating WBN Unit 2.

5 7.2.3.8 Geothermal Energy

6 Geothermal energy has an average capacity factor of 90 percent and can be used for baseload

7 power where available. Hydrothermal resources (i.e., steam or hot water), which are the most

8 common geothermal resources, are available primarily in the western states, Alaska, and

9 Hawaii. Other geothermal resources, e.g., hot dry rock and magma, are awaiting further

10 technology development (DOE 2006). Geothermal technology is not widely used for baseload

11 power generation because of the limited geographical availability of the resource and immature

12 status of the technology (NRC 1996). The TVA region of interest does not have high13 temperature geothermal reservoirs available to produce geothermal power (DOE 2006).

14 Because of the lack of regionally available hydrothermal resources and the current status of

15 geothermal technology, a geothermal-energy facility at the WBN site would not be a reasonable

16 alternative to operating WBN Unit 2.

17 7.2.3.9 Wood Waste

18 As part of its generation mix, TVA co-fires wood waste in a boiler at Colbert Fossil Plant and

19 also has power purchase agreement for 70 MW(e) of biomass wood waste power from

20 Columbus, Mississippi and 3.2 MW(e) from Jackson, Mississippi (TVA 2011 a). Approximately

21 11 million tons of wood waste are generated each year in the TVA service area (TVA 2003).

22 In the GElS for license renewal (NRC 1996), the NRC determined that a wood-burning facility

23 can provide baseload power and operate with an average annual capacity factor of around 70 to

24 80 percent and with 20 to 25 percent efficiency. The fuels required are variable and site25 specific. A significant impediment to the use of wood waste to generate electricity is the high

26 cost of fuel delivery and high construction cost per megawatt of generating capacity. The

27 largest wood-waste power plants are only 40 to 50 MW(e) in size. Estimates in the GElS for

28 license renewal suggest that the overall level of construction impacts per megawatt of installed

29 capacity would be approximately the same as that for a coal-fired plant, although facilities using

30 wood waste for fuel would be built at smaller scales (NRC 1996). Similar to coal-fired plants,

31 wood-waste plants require large areas for fuel storage and processing and involve the same

32 type of combustion equipment.

Draft NUREG-0498, Supplement 2 7-14 September 2011
Environmental Impacts of Alternatives

1 Because of uncertainties associated with obtaining sufficient wood and wood waste to fuel a

2 baseload power plant, the ecological impacts of large-scale timber cutting (for example, soil

3 erosion and loss of wildlife habitat), and high inefficiency, wood waste would not be a

4 reasonable alternative to operating WBN Unit 2.

5 7.2.3.10 Municipal Solid Waste

6 Municipal solid-waste combustors incinerate waste and use the resultant heat to produce

7 steam, hot water, or electricity. The combustion process can reduce the volume of waste by up

8 to 90 percent and the weight by up to 75 percent (EPA 2009). Municipal waste combustors use

9 three basic types of technologies: mass burn, modular, and refuse-derived fuel (DOE/EIA

10 2001). Mass-burning technologies are most commonly used in the United States. This group of

11 technologies processes raw municipal solid waste "as is," with little or no sizing, shredding, or

12 separation before combustion. In the GElS for license renewal (NRC 1996), the NRC determined

13 that the initial capital cost for municipal solid-waste plants is greater than for comparable steam14 turbine technology at wood-waste facilities because of the need for specialized waste-separation

15 and waste-handling equipment for municipal solid waste.

16 Municipal solid-waste combustors generate an ash residue that is buried in landfills. The ash

17 residue is composed of bottom ash and fly ash. Bottom ash refers to that portion of the

18 unburned waste that falls to the bottom of the grate or furnace. Fly ash represents the small

19 particles that rise from the furnace during the combustion process. Fly ash is generally

20 removed from flue gases using fabric filters and/or scrubbers (DOE/EIA 2001).

21 In 2010, 86 waste-to-energy plants operated in the United States. These plants generated

22 approximately 2,572 MW(e), or an average of approximately 30 MW(e) per plant (IWSA 2010).

23 TVA does not plan to construct or operate facilities using municipal solid waste in the next 20

24 years; however, it would consider purchasing power from such a facility (TVA 2011 b). Given

25 the small size of existing plants, generating electricity from municipal solid waste would not be a

26 reasonable alternative to operating WBN Unit 2.

27 7.2.3.11 Other Biomass-Derived Fuels

28 In addition to wood and municipal solid-waste fuel, several other biomass-derived fuels are

29 available for fueling electric generators, including burning crops, converting crops to a liquid fuel

30 such as ethanol, and gasifying crops. Biomass power plants can provide baseload power and

31 are one of few renewable power plants with generation that can be scheduled. EIA estimates

32 that hydropower, wind, and biomass will be the three largest sources of renewable electricity

33 generation renewable fuels through 2035 (DOE/EIA 2010). TVA also considers biomass to be

34 one of its largest renewable energy resources in the Tennessee River valley. Crops grown

35 specifically to produce biomass for use as fuels (dedicated energy crops) are a potentially

36 important commodity in the TVA region. Studies project that approximately 10 million tons of

September 2011 7-15 Draft NUREG-0498, Supplement 2
Environmental Impacts of Alternatives

1 switchgrass, a native, high-yielding grass, could be grown annually as an energy crop in the

2 TVA service area. TVA estimates that in combination, these biomass resources (including

3 wood waste, see Section 7.2.1.9) could potentially produce an energy equivalent of

4 approximately 900 MW(e) in the TVA service area. However, the cost of converting some of

5 these biomass resources to electricity is twice the cost of coal on an energy basis (TVA 2003).

6 TVA currently integrates biomass-derived fuels into the generation mix by co-firing methane

7 from a nearby sewage treatment plant at Allen Fossil Plant (TVA 2011 a). TVA currently

8 purchases about 80 MW(e) of biomass-fueled generation and has purchased power

9 agreements for 11 MW(e) of biomass-fired generation from corn milling residue. In

10 addition,TVA plans to evaluate the Shawnee 10 fossil-plant for conversion to a dedicated

11 biomass-fueled unit (TVA 2011 b). In the GElS for license renewal (NRC 1996), the NRC

12 determined that none of these biomass conversion technologies has progressed to the point of

13 being competitive on a large scale or of being reliable enough to replace a large baseload

14 power-generation plant. Nevertheless, TVA included up to 490 MW(e) of biomass generation

15 and landfill gas generation as a potential resource option for evaluation over the next 20 years

16 in its Integrated Resource Plan (TVA 201 la). The NRC staff notes that this is less than half the

17 proposed capacity of WBN Unit 2, and will not be available until long after WBN Unit 2 is

18 proposed for operation.

19 Construction of a biomass-fired plant would have an environmental impact that would be similar

20 to that for a coal-fired plant, although facilities using wood waste and agricultural residues for

21 fuel would be built on smaller scales. Like coal-fired plants, biomass-fired plants require areas

22 for fuel storage, processing, and waste (i.e., ash) disposal. Additionally, operation of biomass23 fired plants has environmental impacts, including potential impacts on the aquatic environment

24 and air; however, biomass feedstocks have lower levels of sulfur and sulfur compounds

25 compared with coal (DOE/EIA 2010). Because of the limited availability and environmental

26 impacts, biomass-derived fuels do not offer a reasonable alternative to operating WBN Unit 2.

27 7.2.3.12 Fuel Cells

28 Fuel cells work without combustion and its associated environmental side effects. Power is

29 produced electrochemically by passing a hydrogen-rich fuel over an anode, air over a cathode,

30 and then separating the two by an electrolyte. The only byproducts are heat, water, and CO2.

31 Hydrogen is typically derived from hydrocarbon-based fuels, such as natural gas, by subjecting

32 them to steam reforming or partial oxidation, through gasification of coal or biomass, or through

33 the electrolysis of water.

34 Phosphoric-acid fuel cells are generally considered first-generation technology. During the past

35 three decades, significant efforts have been made to develop more practical and affordable fuel

36 cell designs for stationary power applications and the first-generation technologies have given

37 way to membrane and solid-oxide-based fuel cells operating consistently at above 50-percent

Draft NUREG-0498, Supplement 2 7-16 September 2011
Environmental Impacts of Alternatives

1 electrical efficiency (DOE 2008b). High-temperature, second-generation fuel cells have

2 achieved increased fuel-to-electricity and thermal efficiencies, giving second-generation fuel-cell

3 systems the ability to generate steam for cogeneration such as in distributed generation type

4 combined heat and power applications.

5 Research in both stationary and transportation-based fuel cells is intended to provide continuing

6 improvements of both materials and components as they relate to system cost and durability.

7 Currently, the cost of fuel-cell power systems must be reduced before they can be competitive

8 with conventional technologies (DOE 2008c). At the present time, fuel cells are not

9 economically or technologically competitive with other alternatives for baseload electricity

10 generation. Because fuel cells have not been developed to the point where they are capable of

11 supplying power equal to 1,160 MW(e), fuel-cell-based electricity generation does not offer a

12 reasonable alternative to operating WBN Unit 2.

13 7.2.4 Natural-Gas-Fired Power Generation

14 For the natural-gas-fired alternative, the NRC assumed construction and operation of a natural15 gas-fired plant with a closed-cycle cooling system and cooling towers located at the WBN site.

16 The natural-gas-fired plant would use combined-cycle combustion turbines and two units would

17 be needed with a net capacity of 580 MW(e) per unit for a total capacity of 1,160 MW(e). The

18 natural-gas-fired alternative would use existing transmission lines and rights-of-way to the WBN

19 site, as discussed in Section 3.2 of this SFES.

20 TVA currently operates 11 natural-gas-fired generating facilities - 9 combustion turbine plants

21 with a total capacity of 5,326 MW(e) and 2 combined cycle plants with a total capacity of

22 1,327 MW(e). TVA is constructing the John Sevier combined cycle plant with a proposed

23 capacity of 880 MW(e) (TVA 201 la, 201 Ob).

24 7.2.4.1 Air Quality

25 Natural gas is a relatively clean-burning fuel. A natural-gas-fired plant releases similar types of

26 emissions as a coal-fired plant, but in lower quantities. A new natural-gas-fired power plant in

27 the WBN region would likely need a Prevention of Significant Deterioration (PSD) and an

28 operating permit under the Clean Air Act. PSD is an EPA program in which state or Federal

29 permits are required to restrict air emissions from new or modified sources in places where air

30 quality currently meets ambient air quality standards.

31 A new natural-gas-fired, combined-cycle plant also would be subject to the new source

32 performance standards specified in Title 40 of the Code of Federal Regulations (CFR) Part 60,

33 Subpart KKKK ("Standards of Performance for Stationary Combustion Turbines"). This subpart

34 establishes standards for SO2 and NO,.

September 2011 7-17 Draft NUREG-0498, Supplement 2
Environmental Impacts of Alternatives

1 The EPA has various regulatory requirements for visibility protection in 40 CFR Part 51,

2 Subpart P ("Protection of Visibility"), including a specific requirement for review of any new

3 major stationary source in areas designated as in attainment or unclassified under the Clean Air

4 Act. Most of the "designated areas" around the WBN site are designated as

5 "Unclassifiable/Attainment" for all criteria pollutants. However, the area around Chattanooga,

6 Tennessee-Georgia (Hamilton County) and the area around Knoxville, Tennessee (Anderson,

7 Blount, Knox, London, and part of Roane counties) are "Nonattainment" for PM2.5 (40 CFR

8 81.343).

9 Section 169A(a)(2) of the Clean Air Act (42 USC 7491) establishes a national goal of preventing

10 future, and remedying existing, impairment of visibility in mandatory Class I Federal areas when

11 impairment occurs because of air pollution resulting from human activities. The Great Smokey

12 Mountains National Park and the Joyce Kilmer Slickrock Wilderness are identified Mandatory

13 Class I Federal Areas and, where visibility is an important value (40 CFR 81.428). The Great

14 Smoky Mountains National Park comprises 514,758 ac overall, of which 273,551 ac are in North

15 Carolina, and 241,207 ac are in Tennessee. Joyce Kilmer Slickrock Wilderness comprises

16 14,033 ac overall, of which 10,201 ac are in North Carolina, and 3,832 ac are in Tennessee.

17 They are located approximately 80 km (50 mi) from the site to the west and northwest,

18 respectively. If a new gas-fired power-generation facility were located near a mandatory Class I

19 area, additional air-pollution control requirements could be imposed.

20 The emissions from the natural-gas-fired alternative at the WBN site, based on EPA emission

21 factors and performance characteristics for this alternative and its emission controls, would be

22 as follows:

23 * SO2 - 91 T/yr (83 MT/yr)

24 9 NO, - 291 T/yr (264 MT/yr)

25 e CO - 61 T/yr (55 MT/yr)

26 9 PM10 - 51 T/yr (44 MT/yr) (all particulates are PM10).

27 A natural-gas-fired power plant also would have unregulated CO 2 emissions that could

28 contribute to global warming. The NRC staff estimates that the natural-gas-fired alternative

29 would emit approximately 3.1 million T/yr (2.8 MT/yr) of CO 2.

30 The combustion turbine portion of the combined-cycle plant would be subject to EPA's National

31 Emission Standards for Hazardous Air Pollutants for Source Categories (40 CFR 63) if the site

32 is a major source of hazardous air pollutants. Major sources have the potential to emit 10 T/yr

33 (9 MT/yr) or more of any single hazardous air pollutant or 25 T/yr (23 MT/yr) or more of any

34 combination of hazardous air pollutants (40 CFR 63.6085(b)).

Draft NUREG-0498, Supplement 2 7-18 September 2011
Environmental Impacts of Alternatives

1 The fugitive dust emissions from construction activities could impact air quality on or near the

2 WBN site; however, these impacts would be temporary and mitigated using best management

3 practices. In addition, exhaust emissions would come from vehicles and other motorized

4 equipment used during the construction of the plant.

5 The impacts of emissions from a natural-gas-fired power plant could be noticeable, but given

6 the variety of air quality regulations with which the plant must comply, the impacts would not

7 destabilize air quality. Overall, air quality impacts resulting from construction and operation of

8 new natural-gas-fired power plant at the WBN site would be SMALL to MODERATE.

9 7.2.4.2 Water Use and Quality

10 The impacts on water use and quality from operating a natural-gas-fired plant at the WBN site

11 would be comparable to the impacts associated with operating a nuclear power plant on the

12 site. Closed-cycle cooling with cooling towers is assumed. The impacts on water quality from

13 sedimentation during construction of a natural-gas-fired plant are characterized in NUREG-1437

14 as SMALL (NRC 1996). NRC also noted in NUREG-1437 that the impacts on water quality from

15 operations are similar to, or less than, the impacts from other generating technologies. Overall,

16 water use and quality impacts would be SMALL.

17 7.2.4.3 Aquatic and Terrestrial Resources

18 Much of the aquatic and terrestrial resource impacts that would occur from constructing and

19 operating and gas-fired plant on the WBN site would occur in areas previously disturbed during

20 the construction of WBN Unit 2. Constructing a new underground gas pipeline to the site would

21 cause temporary ecological impacts. Construction and operation of a natural-gas pipeline

22 would be subject to various state and Federal environmental requirements depending on how

23 and where it would be constructed. Ecological impacts on the plant site and utility easements

24 would not affect threatened and endangered species, although some wildlife habitat loss and

25 fragmentation, reduced productivity, and local reduction in biological diversity would be likely.

26 Withdrawal and discharge of makeup water for the cooling system could affect aquatic

27 resources, and drift of condensation from the cooling towers could affect terrestrial ecology.

28 Overall, the NRC concludes that ecological impacts would be SMALL to MODERATE.

29 7.2.4.4 Human Health

30 In NUREG-1437, the NRC identified cancer and emphysema as potential health risks from

31 natural-gas-fired plants (NRC 1996). The risk may be attributable to NOx emissions that

32 contribute to ozone formation, which in turn contributes to health risk. The Tennessee

33 Department of Environment and Conservation (TDEC) would regulate air emissions from a

34 natural-gas-fired power plant located at the WBN site. The human health effect would be

September 2011 7-19 Draft NUREG-0498, Supplement 2
Environmental Impacts of Alternatives

1 expected to be either undetectable or minor. Overall, the NRC concludes that the impacts on

2 human health from natural-gas-fired power generation would be SMALL.

3 7.2.4.5 Socloeconomics

4 Land Use

5 The GElS generically evaluates the onsite and offsite impacts of nuclear power plant

6 construction and operation on land use. This analysis of land-use impacts focuses on the land

7 area that would be affected by the construction and operation of a natural-gas-fired power plant

8 at the WBN site.

9 Based on GElS estimates, approximately 128 ac (51 ha) of land would be needed to support a

10 natural-gas-fired alternative to replace WBN Unit 2. This amount of land use would include

11 other plant structures and associated infrastructure. Land-use impacts from construction would

12 be SMALL.

13 In addition to onsite land requirements, land would be required offsite for natural-gas wells,

14 collection stations, and gas pipelines. Most of this land requirement would occur on land where

15 gas extraction already occurs. In addition, some natural gas could come from outside the

16 United States and be delivered as liquefied gas.

17 The elimination of uranium fuel for WBN Unit 2 could partially offset offsite land requirements

18 needed for mining and processing uranium during the operating life of the plant. Overall

19 land-use impacts from a gas-fired power plant would be in the range of SMALL to MODERATE.

20 Socioeconomics

21 Socioeconomic impacts are defined in terms of changes to the demographic and economic

22 characteristics and social conditions of a region. For example, the number of jobs created by

23 the construction and operation of a new natural-gas-fired power plant could affect regional

24 employment, income, and expenditures. Two types of jobs would be created by this alternative:

25 (1) construction-related jobs, which are transient, short in duration, and less likely to have a

26 long-term socioeconomic impact; and (2) operation-related jobs in support of power plant

27 operations, which have the greater potential for permanent, long-term socioeconomic impacts.

28 Workforce requirements for the construction and operation of the natural-gas-fired power plant

29 alternative were evaluated in order to measure their possible effects on current socioeconomic

30 conditions.

31 In its application for two combined licenses at the Bellefonte plant site, TVA indicated that

32 construction of a new natural-gas-fired power plant would require approximately 400 workers

33 over a 3-year period (TVA 2008b). The NRC staff finds that these estimates to be similar to

Draft NUREG-0498, Supplement 2 7-20 September 2011
Environmental Impacts of Alternatives

1 other TVA estimates related to construction of the John Sevier gas-fired plant (TVA JS EA) and

2 considers the estimates to be in reasonable for construction of a gas-fired power plant at the

3 WBN Unit 2 site. During construction of a natural-gas-fired plant, the communities surrounding

4 the power plant site would experience increased demand for rental housing and public services.

5 The relative economic effect of construction workers on the local economy and tax base would

6 vary over time.

7 After construction, the loss of construction jobs and associated loss in demand for business

8 services may temporarily affect local communities. Additionally, the rental housing market could

9 experience increased vacancies and decreased prices. Since WBN is located near the

10 relatively populous cities of Knoxville and Chattanooga, these effects would be smaller because

11 workers are likely to commute instead of relocating closer to the construction site. Because of

12 the WBN site's proximity to this large population center, the impact of construction on

13 socioeconomic conditions could range from SMALL to MODERATE.

14 Operating a natural-gas-fired plant would require approximately 50 workers. (TVA 2008b).

15 During plant operations, demand for housing and public services would diminish due to the

16 relatively small workforce required to operate the plant and considering the surrounding

17 population and infrastructure. Overall, the socioeconomic impacts from constructing and

18 operating a gas-fired plant would be noticeably less than impacts associated with the

19 construction and operation of a coal-fired alternative due to the smaller size of the construction

20 and operations workforce. Operational impacts would be SMALL.

21 Transportation

22 Transportation impacts associated with construction and operation of a gas-fired power plant

23 would consist of commuting workers and truck deliveries of construction materials to the WBN

24 site. During periods of peak construction activity, up to 400 workers could be commuting daily

25 to the site. In addition to commuting workers, trucks would be transporting construction

26 materials and equipment to the worksite, thus increasing the amount of traffic on local roads.

27 The increase in vehicular traffic would peak during shift changes, resulting in temporary levels of

28 service impacts and delays at intersections. Pipeline construction and modification to existing

29 natural-gas pipeline systems could also have an impact. Traffic-related transportation impacts

30 during construction would likely be MODERATE.

31 During plant operations, traffic-related transportation impacts would almost disappear.

32 Operating a gas-fired plant would require approximately 50 workers. Since fuel is transported

33 by pipeline, the transportation infrastructure would experience little to no increased use from

34 plant operations. Overall, the gas-fired alternative transportation impacts would be SMALL

35 during plant operations.

September 2011 7-21 Draft NUREG-0498, Supplement 2
Environmental Impacts of Alternatives

1 Aesthetics

2 The aesthetics impact analysis focuses on the degree of contrast between the natural-gas-fired

3 alternative and the surrounding landscape and the visibility of the natural-gas-fired plant.

4 The gas-fired units could be approximately 100 ft (30 m) tall, with four exhaust stacks up to

5 200 ft (61 m) tall. The facility would be visible offsite during daylight hours, and some structures

6 may require aircraft warning lights. The power plant would be smaller and less noticeable than

7 that of WBN Unit 2. Cooling towers would continue to generate condensate plumes and

8 operational noise. Additional noise during power plant operations would be limited to industrial

9 processes and communications. Pipelines delivering natural-gas fuel could be audible offsite

10 near compressors.

11 In general, aesthetic changes would be limited to the immediate vicinity of the WBN site and

12 would be SMALL.

13 Historic and Cultural Resources

14 Cultural resources are the indications of human occupation and use of the landscape as defined

15 and protected by a series of Federal laws, regulations, and guidelines. Prehistoric resources

16 are physical remains of human activities that predate written records; they generally consist of

17 artifacts that may alone or collectively yield information about the past. Historic resources

18 consist of physical remains that postdate the emergence of written records; in the United States,

19 they are architectural structures or districts, archaeological objects, and archaeological features

20 dating from 1492 and later. Ordinarily, sites less than 50 years old are not considered historic,

21 but exceptions can be made for such properties if they are of particular importance, such as

22 structures associated with the development of nuclear power (e.g., Shippingport Atomic power

23 Station) or Cold War themes. American Indian resources are sites, areas, and materials

24 important to American Indians for religious or heritage reasons. Such resources may include

25 geographic features, plants, animals, cemeteries, battlefields, trails, and environmental features.

26 The cultural resource analysis encompassed the power plant site and adjacent areas that could

27 potentially be disturbed by the construction and operation of alternative power plants.

28 The potential for historic and archaeological resources can vary greatly depending on the

29 location of the proposed site. To consider a project's effects on historic and archaeological

30 resources, any affected areas would need to be surveyed to identify and record historic and

31 archaeological resources, identify cultural resources (e.g., traditional cultural properties), and

32 develop possible mitigation measures to address any adverse effects from ground disturbing

33 activities. The cultural resource analysis encompassed the power plant site and adjacent areas

34 that could be disturbed by the construction and operation of a replacement gas-fired plant at the

35 WBN site.

Draft NUREG-0498, Supplement 2 7-22 September 2011
Environmental Impacts of Alternatives

1 A cultural resources survey would be needed for any onsite property not previously surveyed.

2 Additionally, other lands acquired to support the plant would likely need to be surveyed to

3 identify and record historic and archaeological resources. These surveys would be needed for

4 all areas of potential disturbance, both onsite and offsite (e.g., mining and waste-disposal sites).

5 If project activities adversely affect historic and cultural resources, mitigation measures would

6 be taken in consultation with the State Historic Preservation Officer (SHPO). Historic and

7 cultural resource impacts would be SMALL to MODERATE depending on the location of the

8 power plant. However, cultural resource surveys may reveal important cultural resources that

9 could result in greater impacts.

10 Environmental Justice

11 The environmental justice impact analysis evaluates the potential for disproportionately high and

12 adverse human health and environmental effects on minority and low-income populations that

13 could result from the construction and operation of a new natural-gas-fired power plant.

14 Adverse health effects are measured in terms of the risk and rate of fatal or nonfatal adverse

15 impacts on human health. Disproportionately high and adverse human health effects occur

16 when the risk or rate of exposure to an environmental hazard for a minority or low-income

17 population is significant and exceeds the risk or exposure rate for the general population or for

18 another appropriate comparison group. Disproportionately high environmental effects refer to

19 impacts or risk of impacts on the natural or physical environment in a minority or low-income

20 community that are significant and appreciably exceed the environmental impact on the larger

21 community. Such effects may include biological, cultural, economic, or social impacts. Some of

22 these potential effects have been identified in resource areas evaluated in this SFES. For

23 example, increased demand for rental housing during power plant construction could

24 disproportionately affect low-income populations. Minority and low-income populations are

25 subsets of the general public residing in the vicinity of WBN, and all are exposed to the same

26 hazards generated from constructing and operating a new natural-gas-fired power plant.

27 As discussed in Section 2.4.3.1 of this SFES, within the 80-km (50-mi) region of the WBN site,

28 approximately 11 percent of the population identified themselves as a minority. Approximately

29 206 census block groups wholly or partly within the 80-km (50-mi) radius of the WBN site were

30 determined to have a minority population of 11 percent of the total population (see Error!

31 Reference source not found.). Of these 206 block groups, 70 had aggregate minority

32 population percentages that exceed the regional (within 80-km [50-mi] radius of the WBN site)

33 average by 20 percentage points or more, and 54 census block groups had aggregate minority

34 population percentages that exceed 50 percent. These block groups are primarily located near

35 the town centers of Maryville (Blount County), Oak Ridge (Anderson County), Athens (McMinn

36 County), Cleveland (Bradley County), and the City of Chattanooga (Hamilton County). Some

37 more rural concentrations are located in Knox County, Tennessee, and Whitfield County,

September 2011 7-23 Draft NUREG-0498, Supplement 2
Environmental Impacts of Alternatives

1 Georgia. No block groups with high-density minority populations were found in Rhea or Meigs

2 county (USCB 2000).

3 Based on 2000 Census data, 38 block groups exceeded the 80-km (50-mi) average

4 (12 percent) by 20 percent or more, while only 3 block groups had low-income populations of

5 50 percent or more (see Section 2.4.3.2). These block groups are distributed throughout the

6 80-km (50-mi) radius in relatively rural areas of Scott, Morgan, Cumberland, Grundy, Roane,

7 and Knox counties. In addition, some low-income concentrations are found near the town

8 centers of Oak Ridge (Anderson County), Athens (McMinn County), Cleveland (Bradley

9 County), and the City of Chattanooga (Hamilton County). No high-density low-income block

10 groups were found in Rhea and Meigs counties (USCB 2000).Potential impacts on minority and

11 low-income populations from the construction and operation of a new natural-gas-fired power

12 plant at WBN would mostly consist of environmental and socioeconomic effects (e.g., noise,

13 dust, traffic, employment, and housing impacts). Noise and dust impacts from construction

14 would be short-term and primarily limited to onsite activities. Minority and low-income

15 populations residing along site access roads would also be affected by increased commuter

16 vehicle traffic during shift changes and truck traffic. However, these effects would be temporary

17 during certain hours of the day and not likely to be high and adverse. Increased demand for

18 rental housing during construction in the vicinity of the WBN could affect low-income

19 populations. However, given the close proximity to populated areas, most construction workers

20 would likely commute to the site thereby reducing the potential demand for rental housing.

21 Based on this information and the analysis of human health and environmental impacts from a

22 natural-gas-fired alternative presented in this section of the SFES, the construction and

23 operation of a new natural-gas-fired power plant would not have disproportionately high and

24 adverse human health and environmental effects on minority and low-income populations

25 residing in the vicinity of the WBN site.

26 7.2.4.6 Waste Management

27 According to the 1996 GElS (NUREG-1437), waste generation from natural-gas-fired

28 technology would be minimal (NRC 1996). The only significant waste generated at a natural29 gas-fired power plant would be spent Selective Catalytic Reduction (SCR) catalyst, which is

30 used to control NOx emissions. The spent catalyst would be regenerated or disposed of offsite.

31 Other than spent SCR catalyst, waste generation at an operating natural-gas-fired plant would

32 be largely limited to typical operations and maintenance waste. Construction-related debris

33 would be generated during construction activities. Overall, waste impacts from natural-gas-fired

34 power generation would be SMALL.

35 The impacts of natural-gas-fired power generation at the WBN site are summarized in

36 Table 7-1.

Draft NUREG-0498, Supplement 2 7-24 September2011
Environmental Impacts of Alternatives

1 Table 7-1. Summary of Environmental Impacts of the Natural Gas-Fired Alternative

Natural Gas CombinedCycle Generation

Air quality SMALL to MODERATE

Water use and quality SMALL

Aquatic and terrestrial resources SMALL to MODERATE

Human health SMALL

Socioeconomics (including land, cultural SMALL to MODERATE

resources, and environmental justice)

Waste management SMALL

2 7.2.5 Combination of Alternatives

3 Individual alternatives to the operation of an additional nuclear unit at the proposed site might

4 not be sufficient on their own to generate the equivalent of 1,160 MW(e), because of the small

5 size of the resource or lack of cost-effective opportunities. Nevertheless, it is conceivable that a

6 combination of alternatives might be cost-effective. There are many possible combinations of

7 alternatives. Based, in part, on resources identified in TVA's IRP (TVA 201 Ia), the NRC staff

8 has assembled a combination of alternatives that could reasonably serve as a generation option

9 for WBN Unit 2, considering the proposed capacity of WBN Unit 2 (1,160 MW(e) operated as

10 baseload plant), the proposed start date (2012), proposed license period (40 years), and the

11 availability of resources in the TVA service area.

12 Any combination of alternative sources that incorporates renewable sources of energy (e.g.,

13 solar or wind power) also would need to be combined with some form of 100 percent load

14 capacity fossil-fuel-fired power generation to accommodate the intermittent power generation

15 from renewable sources. The natural-gas-fired power generation option, evaluated as part of

16 the baseload alternatives, would be the most likely fossil fuel-generated option in the TVA

17 region of interest. The impacts of natural-gas-fired power generation previously discussed

18 would form the basis of evaluating this portion of the combination of power generating

19 alternatives. When considering the combined environmental impacts (e.g., land-use,

20 aesthetics) from a natural-gas-fired generation unit, solar, wind, biomass sources, or any

21 number of renewable alternatives, the combination of alternatives, would likely have

22 environmental impacts that exceed the environmental impacts of operating WBN Unit 2.

23 Construction and operation of two natural-gas-fired, combined-cycle generating units

24 (generating 580 MW(e) each) at the WBN site using closed-cycle cooling with cooling towers

25 was discussed in Section 7.2.2. For a combined alternatives option, the environmental impacts

26 of two 380-MW(e) natural-gas-fired, combined-cycle power generating units at the WBN site

27 using closed-cycle cooling with cooling towers was considered. In addition, it is assumed that a

28 combination of alternatives could reasonably include 400 MW(e) of wind energy (assuming a 36

September 2011 7-25 Draft NUREG-0498, Supplement 2
Environmental Impacts of Alternatives

1

2

3

4

5

6

percent capacity factor), 100 MW(e) from biomass sources, and 150 MW(e) from energy

efficiency programs. Due to wind availability limitations, it TVA would likely purchase some

portion of the wind energy from neighboring regions. A summary of the environmental impacts

associated with the construction and operation of this combination of alternatives is provided in

Table 7-2.

Table 7-2. Summary of Environmental Impacts of a Combination of Power Sources

Impact Category

Air Quality

Water Use and

Quality

Ecology

Human Health

Socioeconomics

Impact

SMALL to

MODERATE

Comment

Emissions from the natural-gas-fired plant and biomass facilities could

affect air quality.

SMALL Impacts would be comparable to the impacts for a new power plant

located at the WBN site.

SMALL to

MODERATE

Many of the impacts would occur in areas previously disturbed

during the construction of WBN Units 1 and 2; however, biomass

plant would require areas for fuel storage, processing, and waste

(i.e., ash) disposal. Impacts on terrestrial ecology from cooling

tower drift could occur. Land requirements for wind farm could

result in habitat loss and some avian mortality.

SMALL Regulatory controls and oversight would be protective of human

health.

SMALL to Construction and operations workforces would be relatively small.

LARGE However, construction related impacts would be noticeable.

Impacts during operation would be minor because of the small

workforce involved. Wind farm and new transmission lines

associated with generation would create aesthetic impacts.

Land Use

Historic and

Cultural

Resources

Environmental

Justice

Waste

Management

MODERATE A biomass plant and natural-gas-fired plant would require land for

the powerblock, fuel storage/natural-gas pipeline, and waste

disposal. Wind farms and associated transmission lines would

require a large amount of land.

SMALL to Most of the facilities and infrastructure at the site would likely be

LARGE built on previously disturbed ground. Site surveys would have to be

conducted and the effects to cultural resources assessed and

mitigated, if necessary, prior to any ground disturbing activities.

SMALL Depending on their location, construction and operation of these

facilities may affect minority and low-income populations.

SMALL to

MODERATE

Waste would be from spent SCR catalyst used for control of NO,

emissions from natural-gas-fired plant and ash from biomass waste

sources.

Draft NUREG-0498, Supplement 2 7-26 September 2011
Environmental Impacts of Alternatives

1 7.2.5.1 Air Quality

2 As discussed in Section 7.2.2, although natural gas is a relatively clean-burning fossil fuel, any

3 gas-fired generation option would be associated with emissions of SO 2, NO,, CO, CO 2 and PM.

4 Similarly, biomass-powered plants produce emissions in the form of NOx, C02 and a small

5 amount of SO 2. The amounts emitted depend on the type of biomass burned and generator

6 used. Wood waste is relatively abundant in the TVA service area, with approximately 11 million

7 tons of wood waste generated each year (TVA 2003). If wood waste fueled a 1 00-MW(e)

8 biomass plant, the NRC staff calculates that it could produce 124 T (112 MT) of SO2 per year,

9 608 T (552 MT) of NO), 744 T (675 MT) of CO, 370 T of PM10, and 968,000 T (878,000 MT) of

10 C02 per year, based on likely fuel and power plant characteristics. Wind generation and

11 energy efficiency programs would not affect air quality in the TVA region of interest.

12 In addition to operation impacts, the construction of this combination of alternatives would

13 produce temporary fugitive dust emissions from construction activities. The exhaust emissions

14 from vehicles and other motorized equipment used during the construction of the facilities would

15 also have temporary air-quality impacts in the TVA region of interest.

16 The impacts of emissions from a natural-gas-fired power plant and biomass/municipal waste

17 generation would be noticeable, but would not be sufficient to destabilize air resources. Overall,

18 air quality impacts resulting from construction and operation of the combination of alternatives

19 would be MODERATE.

20 7.2.5.2 Water Use and Quality

21 The impacts on water use and quality from operating a natural-gas-fired and biomass plant at

22 the WBN site would be comparable to the impacts discussed in NUREG-1437 associated with

23 the operation of a nuclear power plant. Closed-cycle cooling with cooling towers would be used.

24 The impacts on water quality from sedimentation during construction are characterized in

25 NUREG-1437 as SMALL (NRC 1996). NRC also noted in NUREG-1437 that the impacts on

26 water quality from operations are similar to, or less than, the impacts from other generating

27 technologies.

28 Wind generation and energy efficiency would not have noticeable impacts on water use or

29 quality in the TVA region of interest. Overall, water use and quality impacts would be SMALL.

30 7.2.5.3 Aquatic and Terrestrial Resources

31 Constructing a new underground gas pipeline to the WBN site would cause temporary

32 ecological impacts. Impacts on the plant site and utility easements would not affect threatened

33 and endangered species, although some wildlife habitat loss and fragmentation, reduced

34 productivity, and local reduction in biological diversity would be likely. Like coal-fired plants,

September 2011 7-27 Draft NUREG-0498, Supplement 2
Environmental Impacts of Alternatives

1 biomass-fired plants require areas for fuel storage, processing, and waste (i.e., ash) disposal,

2 which could potentially impact aquatic and terrestrial resources on the site. Most of the aquatic

3 and terrestrial resource impacts of constructing and operating and gas-fired plant and biomass

4 plant on the WBN site would occur in areas previously disturbed during construction of WBN

5 Unit 2. Withdrawal and discharge of makeup water for the cooling system could affect aquatic

6 resources, and drift of condensation from the cooling towers could affect terrestrial ecology.

7 A wind farm would also affect terrestrial resources. The total impact would depend on the

8 location and acreage. Wind generation with a capacity of 400 MW(e) would permanently impact

9 approximately 290 ac (120 ha), and temporarily impact an additional 690 ac (280 ha) during

10 construction (Denholm et al. 2009). The energy efficiency programs would not have any impact

11 on aquatic and terrestrial resources in the region of interest. Overall, the NRC concludes that

12 ecological impacts from the combination of alternatives would be SMALL to MODERATE.

13 7.2.5.4 Human Health

14 In NUREG-1437, the NRC identified cancer and emphysema as potential health risks from

15 natural-gas-fired plants (NRC 1996). Health risks from the gas-fired plant and biomass plant

16 may be attributable to NOx emissions. TDEC would regulate air emissions from the natural-gas17 fired and biomass power plants located at the WBN site. No human health effects are

18 associated with wind generation and energy efficiency components. The human health effect

19 would be expected to be either undetectable or minor. Overall, the NRC concludes that the

20 impacts on human health from the combination of alternatives would be SMALL.

21 7.2.5.5 Socioeconomics

22 Land Use

23 The GElS generically evaluates the onsite and offsite impacts of nuclear power plant

24 construction and operation on land use. This analysis of land-use impacts focuses on the land

25 area that would be affected by the construction and operation of a natural-gas-fired power plant

26 and a biomass power plant at the WBN site, as well as the construction and operation of a wind

27 farm located offsite but within the TVA service area.

28 Based on TVA estimates, approximately 80-100 ac (30-40 ha) of land would be needed to

29 support a natural-gas-fired and biomass plants (TVA 2011 b). In addition, the biomass-fired

30 plant would require areas for fuel storage, processing, and waste (i.e., ash) disposal. In addition

31 to onsite land requirements, land would be required offsite for natural-gas wells, collection

32 stations, and gas pipelines. The construction of wind turbines and associated transmission lines

33 would require a large amount of land spread over several offsite locations. Wind generation

34 with a capacity of 400 MW(e) would permanently affect approximately 290 ac (120 ha), and

35 temporarily affect an additional 690 ac (280 ha) during construction (Denholm et al. 2009). The

Draft NUREG-0498, Supplement 2 7-28 September 2011
Environmental Impacts of Alternatives

1 elimination of uranium fuel for WBN Unit 2 could partially offset offsite land requirements;

2 however the combined land-use impacts from the construction and operation of a gas-fired

3 plant, wind farm, and biomass plant would be noticeable in the region of interest.

4 Energy efficiency programs could have minor land use impacts if they involve the rapid

5 replacement and disposal of old energy inefficient appliances and other equipment that would

6 generate waste material and could increase the size of landfills. However, given the time for

7 program development and implementation, the cost of replacements, and the average life of

8 equipment, the replacement process would probably be gradual. More efficient appliances and

9 equipment would replace older equipment (especially in the case of frequently replaced items,

10 such as light bulbs). In addition, many items (such as home appliances and industrial

11 equipment) have recycling value and would not be disposed of in landfills. Overall land-use

12 impacts from the combination of alternatives would be MODERATE.

13 Socioeconomics

14 As previously discussed, socioeconomic impacts are defined in terms of changes to the

15 demographic and economic characteristics and social conditions of a region. For example, the

16 number of jobs created by the construction and operation of new power plants could affect

17 regional employment, income, and expenditures. Two types of jobs are created by this

18 alternative: (1) construction-related jobs, which are transient, short in duration, and less likely to

19 have a long-term socioeconomic impact; and (2) operation-related jobs, which have greater

20 potential for permanent, long-term socioeconomic impacts.

21 Section 7.2.2.5 states that the socioeconomic impacts from the construction of two gas-fired

22 units at the WBN site would be SMALL to MODERATE. Similarly, the construction of a gas23 fired and biomass plant onsite would require a construction workforce to commute to the site.

24 Additional construction workers would be required offsite for the construction of a wind farm.

25 These workers could cause a short-term increase in the demand for services and temporary

26 (rental) housing in the region around the construction site.

27 After construction, the loss of construction jobs and associated loss in demand for business

28 services may temporarily affect local communities. Additionally, the rental housing market could

29 experience increased vacancies and decreased prices. However, these effects would likely be

30 spread over a large area, as the wind farms may be constructed in more than one location. The

31 combined effects of these construction activities would range from SMALL to MODERATE.

32 Additional estimated operations workforce requirements for this combination alternative would

33 include operations workers for the natural-gas-fired and biomass energy power plants and wind

34 farm. Given the small number of operations workers at these facilities, socioeconomic impacts

35 associated with operation of the natural-gas-fired and biomass power plant at the WBN site, and

36 the wind farm would be SMALL. Socioeconomic effects of energy efficiency programs would be

37 SMALL.

September 2011 7-29 Draft NUREG-0498, Supplement 2
Environmental Impacts of Alternatives

1 Transportation

2 Construction and operation of natural-gas-fired and biomass energy power plants, and a wind

3 farm would increase the number of vehicles on the roads near these facilities. During

4 construction, cars and trucks would deliver workers, materials, and equipment to the worksites.

5 The increase in vehicular traffic would peak during shift changes, resulting in temporary levels of

6 service impacts and delays at intersections. Transporting components of wind turbines could

7 have a noticeable impact, but is likely to be spread over a large area. Pipeline construction and

8 modification to existing natural-gas pipeline systems could also have transportation impacts to

9 the extent that transportation and pipeline networks intersect. Traffic-related transportation

10 impacts during construction could range from SMALL to MODERATE depending on the location

11 of the wind farm site, current road capacities, and average daily traffic volumes.

12 During plant operations, transportation impacts would not be noticeable. Given the small

13 numbers of operations workers at these facilities, the levels of service traffic impacts on local

14 roads from the operation of the gas-fired power plant at the WBN site, biomass energy facility,

15 and at the wind farm would be SMALL. Transportation impacts at the wind farm site or sites

16 would also depend on current road capacities and average daily traffic volumes, but are likely to

17 be small given the low number of workers employed by that component of the alternative. Any

18 transportation effects from the energy efficiency component would be widely distributed across

19 the state and would not be noticeable.

20 Aesthetics

21 The aesthetics impact analysis focuses on the degree of contrast between the surrounding

22 landscape and the visibility of the power plant. In general, aesthetic changes would be limited

23 to the immediate vicinity of the WBN site and the wind farm facilities.

24 Aesthetic impacts from the gas-fired power plant component of the combination alternative

25 would be essentially the same as those described for the gas-fired alternative in Section 7.2.2.5.

26 of this SFES. Power plant infrastructure would be generally smaller and less noticeable than

27 WBN Unit 1 and Unit 2 containment, cooling tower, and turbine buildings. The natural draft

28 cooling towers would continue to generate condensate plumes and operational noise. Noise

29 during power plant operations would be limited to industrial processes and communications. In

30 addition to the power plant structures, construction of natural-gas pipelines would have a short31 term aesthetic impact. Noise from the pipelines could be audible offsite near compressors.

32 However, In general, aesthetic changes would be limited to the immediate vicinity of the WBN

33 site and would be SMALL.

34 The wind farm would have the greatest visual impact. The wind turbines, up to 450 ft (137 m)

35 tall and spread across multiple sites, would dominate the view and likely become the major

Draft NUREG-0498, Supplement 2 7-30 September 2011
Environmental Impacts of Alternatives

1 focus of attention. Depending on its location, the aesthetic impacts from the construction and

2 operation of the wind farm would be MODERATE to LARGE.

3 Impacts from the energy efficiency programs would be SMALL. Some noise impacts could

4 occur in instances of energy conservation and efficiency upgrades to major building systems,

5 but this impact would be intermittent and short lived.

6 Historic and Cultural Resources

7 The same considerations discussed in Section 7.2.2.5 of this SFES for the impact of the

8 construction of two gas-fired plants on historic and cultural resources apply to the construction

9 activities that would occur on the WBN site for a new gas-fired power generating plant. As

10 previously noted, the potential for historic and archaeological resources can vary greatly

11 depending on the location of the power plant. To consider a project's effects on historic and

12 cultural resources, any affected areas would need to be surveyed to identify and record historic

13 and archaeological resources, identify cultural resources (e.g., traditional cultural properties),

14 and develop possible mitigation measures to address any adverse effects from ground15 disturbing activities.

16 As discussed earlier, much of the WBN site has been previously disturbed by the construction of

17 WBN Units 1 and 2. In addition, previous WBN site cultural resource surveys have already

18 resulted in the identification of archaeological sites.

19 Surveys would be needed to identify evaluate and address mitigation of potential impacts prior

20 to the construction of any new power generating facility. Studies would be needed for all areas

21 of potential disturbance (e.g., roads, transmission corridors, or other rights-of-way). Areas with

22 the greatest sensitivity should be avoided. Because TVA would conduct a survey and apply its

23 established protection plan for future resources, the impact of a new gas-fired power plant and

24 biomass plant at the WBN site on historic and cultural resources would be SMALL.

25 Depending on the resource richness of the wind farm site chosen, the impacts could range

26 between SMALL to LARGE. Therefore, the overall impacts on historic and cultural resources

27 from the combination alternative could range from SMALL to LARGE. However, cultural

28 resource surveys may reveal important cultural resources that could result in greater impacts.

29 Impacts to historic and cultural resources from implementing energy efficiency programs would

30 be SMALL and would not likely affect land use or historic or cultural resources elsewhere in the

31 State.

September 2011 7-31 Draft NUREG-0498, Supplement 2
Environmental Impacts of Alternatives

1 Environmental Justice

2 The environmental justice impact analysis evaluates the potential for disproportionately high and

3 adverse human health and environmental effects on minority and low-income populations that

4 could result from the construction and operation of a new natural-gas-fired power plant at the

5 WBN site, biomass energy facility, wind farm, and energy efficiency programs. Adverse health

6 effects are measured in terms of the risk and rate of fatal or nonfatal adverse impacts on human

7 health. Disproportionately high and adverse human health effects occur when the risk or rate of

8 exposure to an environmental hazard for a minority or low-income population is significant and

9 exceeds the risk or exposure rate for the general population or for another appropriate

10 comparison group. Disproportionately high environmental effects refer to impacts or risk of

11 impact on the natural or physical environment in a minority or low-income community that are

12 significant and appreciably exceeds the environmental impact on the larger community. Such

13 effects may include biological, cultural, economic, or social impacts. Some of these potential

14 effects have been identified in resource areas discussed in this SFES. For example, increased

15 demand for rental housing during power plant construction could disproportionately affect low16 income populations. Minority and low-income populations are subsets of the general public

17 residing around a power plant, and all are exposed to the same hazards generated from

18 constructing and operating gas-fired and biomass energy power plants and wind farm.

19 As mentioned previously in this chapter, of the approximately 206 census block groups with the

20 50-mi radius of the WBN site, 70 block groups that have high concentrations of minority

21 populations (see Section 2.4.3.1). These block groups are primarily located near the town

22 centers of Maryville (Blount County), Oak Ridge (Anderson County), Athens (McMinn County),

23 Cleveland (Bradley County), and the City of Chattanooga (Hamilton County). Some more rural

24 concentrations are located in Knox County, Tennessee, and Whitfield County, Georgia. No

25 block groups with high-density minority populations were found in Rhea or Meigs county (USCB

26 2000). There are also 38 block groups that have relatively high concentrations of low-income

27 populations (see Section 2.4.3.2). These block groups are distributed throughout the 80-km

28 (50-mi) radius in relatively rural areas of Scott, Morgan, Cumberland, Grundy, Roane, and Knox

29 counties. In addition, some low-income concentrations are found near the town centers of Oak

30 Ridge (Anderson County), Athens (McMinn County), Cleveland (Bradley County), and the City

31 of Chattanooga (Hamilton County). No high-density low-income block groups were found in

32 Rhea and Meigs counties (USCB 2000).

33 Low-income families could benefit from energy efficiency programs related to residential

34 weatherization and insulation improvements, as lower-income households pay a relatively high

35 proportion of their household income for home energy expenses. Overall impacts to minority

36 and low-income populations from energy conservation and efficiency programs would be

37 nominal, depending on program design and enrollment. Potential impacts to minority and low38 income populations from the construction and operation of a natural-gas-fired and biomass

Draft NUREG-0498, Supplement 2 7-32 September 2011
Environmental Impacts of Alternatives

1 power plant at the WBN site, and a wind farm offsite would mostly consist of environmental and

2 socioeconomic effects (e.g., noise, dust, traffic, employment, and housing impacts). Noise and

3 dust impacts from construction would be short-term and primarily limited to onsite activities.

4 Minority and low-income populations residing along site access roads would also be affected by

5 increased commuter vehicle traffic during shift changes and truck traffic. However, these effects

6 would be temporary during certain hours of the day and not likely to be high and adverse.

7 Increased demand for rental housing during construction in the vicinity of the WBN site, and the

8 wind farm could affect low-income populations. Given the close proximity to relatively populous

9 cities, Knoxville and Chattanooga, most construction workers would likely commute to the site

10 thereby reducing the potential demand for rental housing.

11 Based on this information and the analysis of human health and environmental impacts

12 presented in this SFES, the construction and operation of a natural-gas-fired power plant,

13 biomass energy facility, and the wind farm (depending on its location) would not have a

14 disproportionately high and adverse human health and environmental effects on minority and

15 low-income populations.

16 7.2.5.6 Waste Management

17 According to the NUREG-1437, waste generation from natural-gas-fired technology would be

18 minimal (NRC 1996). The only significant waste generated at a natural-gas-fired power plant

19 would be spent SCR catalyst, which is used to control NO) emissions. The spent catalyst would

20 be regenerated or disposed of offsite. Biomass based power plants produce a fly ash waste

21 stream; however, much of this waste could be recycled. Other waste would be largely limited to

22 typical operations and maintenance waste. The operation of wind generation and energy

23 efficiency activities would not produce waste streams. Construction-related debris would be

24 generated during construction activities. Overall, waste impacts from the combination of

25 alternatives would be SMALL to MODERATE.

26 7.2.6 Summary Comparison of Alternatives

27 Table 7-3 contains a summary of the NRC's environmental impact characterizations for

28 constructing and operating a natural-gas-fired power plant alternative and a combination of

29 power generation alternatives. Both alternatives would have an impact on air quality. There

30 would also be construction impacts to terrestrial resources and socioeconomic impacts. Based

31 on this information, neither of the viable energy alternatives would be preferable to the operation

32 of WBN Unit 2.

September 2011 7-33 Draft NUREG-0498, Supplement 2
Environmental Impacts of Alternatives

1

2

Table 7-3. Summary of Environmental Impacts of Construction and

Fired Generating Units and Combination of Alternatives

Operation of Natural-GasCombination of

Impact Category Natural Gas Alternatives

Air quality SMALL to MODERATE SMALL to MODERATE

Water use and quality SMALL SMALL

Aquatic and terrestrial resources SMALL to MODERATE SMALL to MODERATE

Human health SMALL SMALL

Socioeconomics (including land, cultural SMALL to MODERATE SMALL to LARGE

resources, and environmental justice)

Waste management SMALL SMALL to MODERATE

3 7.3 References

4 10 CFR Part 51. Code of Federal Regulations, Title 10, Energy, Part 51, "Environmental

5 Protection Regulations for Domestic Licensing and Related Regulatory Functions."

6 40 CFR Part 51. Code of Federal Regulations, Title 40, Protection of Environment, Part 51,

7 "Requirements for Preparation, Adoption, and Submittal of Implementation Plans."

8 40 CFR Part 60. Code of Federal Regulations, Title 40, Protection of Environment, Part 60,

9 "Standards of Performance for New Stationary Sources."

10 40 CFR Part 63. Code of Federal Regulations, Title 40, Protection of Environment, Part 63,

11 "National Emission Standards for Hazardous Air Pollutants for Source Categories."

12 40 CFR Part 81. Code of Federal Regulations, Title 40, Protection of Environment, Part 81, "Air

13 Quality Control Regions (AQCRs)."

14 76 FR 39470. July 6, 2011. "Tennessee Valley Authority: Integrated Resource Plan." Federal

15 Register. Tennessee Valley Authority.

16 Clean Air Act. 42 USC 7401 et seq.

17

18

19

20

21

Denholm, P., M. Hand, M. Jackson, and S. Ong. 2009. Land-Use Requirements of Modern

Wind Power Plants in the United States. NREL/TP-6A2-4583. National Renewable Energy

Laboratory, Golden, Colorado.

Idaho National Engineering and Environmental Laboratory (INEEL). 2006. U.S. Hydropower

Resource Assessment for Tennessee. DOE/ID-10430(TN). Idaho Falls, Idaho.

Draft NUREG-0498, Supplement 2 7-34 September 2011
Environmental Impacts of Alternatives

1 Integrated Waste Services Association (IWSA). 2010. The 2010.ERC Directory of Waste-to2 Energy Plants. Accessed January 24, 2011 at

3 http://www.wte.org/userfiles/file/ERC_201ODirectory.pdf

4 National Environmental Policy Act of 1969 (NEPA), as amended. 42 USC 4321, et seq.

5 National Energy Technology Laboratory (NETL). 2010. Cost and Performance Baseline for

6 Fossil Energy Plants. Volume 1: Bituminous Coal and Natural Gas to Electricity, Rev. 2.

7 DOE/NETL-2010/1397. November 2010. Accessed January 9, 2011 at:

8 http:l/www.netl.doe.govlenergy-analyseslpubslBitBaseFinRepRev2.pdf.

9 National Renewable Energy Laboratory (NREL). 2002. Fuel from the Sky: Solar Power's

10 Potential for Western Energy Supply. NREL/SR-55-32160. Golden, Colorado.

11 Northwest Power and Conservation Council (NWPCC). 2006. Biennial Assessment of the Fifth

12 Power Plan: Assessment of Other Generating Technologies. Accessed August 20, 2008 at

13 http://www.nwppc.org/energy/Biennial/BiennialOther%20gen.pdf.

14 Nuclear Energy Institute (NEI). 2010. Resources & Stats. Accessed January 4. 2011 at

15 http://www.nei.org/resourcesandstats/documentlibrary/reIiableandaffordableenergy/graphicsand

16 charts/usnuclearindustrycapacityfactors/.

17 SERC Reliability Corporation (SERC). 2010. Information Summary. SERC Reliability

18 Corporation, Charlotte, North Carolina. Accessed on January 24, 2011 at

19 http://www.sercl .org/documentslSERC/SERC%20Publications/lnformation%2OSummary/201 0

20 %201nformation%20Summary%20Brochure%20%28July%202010%29.pdf.

21 Tennessee Valley Authority (TVA). 1972. Final Environmental Statement Watts Bar Nuclear

22 Plant, Units 1, 2, and 3. TVA-OHES-EIS-72-9, Chattanooga, Tennessee. Accession No.

23 ML073470580.

24 Tennessee Valley Authority (TVA). 1995. Energy Vision 2020: Integrated Resource Plan

25 Environmental Impact Statement. Volume 1. Available online at:

26 http://www.tva.-qov/environment/reports/enermvvision2020/index.htm. Accessed on August 21,

27 2011.

28 Tennessee Valley Authority (TVA). 2003. The Role of Renewable Energy in Reducing

29 Greenhouse Gas Buildup. Accessed September 30, 2008 at

30 http://www.tva.gov/environment/air/ontheair/renewable.htm.

31 Tennessee Valley Authority (TVA). 2008a. Final Supplemental Environmental Impact

32 Statement; Completion and Operation of Watts Bar Nuclear Plant Unit 2, Rhea County,

September 2011 7-35 Draft NUREG-0498, Supplement 2
Environmental Impacts of Alternatives

1 Tennessee. Submitted to NRC as the TVA Environmental Report for an Operating License,

2 Knoxville, Tennessee. Accession No. ML080510469.

3 Tennessee Valley Authority (TVA). 2008b. Bellefonte Nuclear Plant Units 3 & 4 COL

4 Application Part 3 Environmental Report. Revision 1. Accession No. ML083100559.

5 Tennessee Valley Authority (TVA). 2010a. Final Supplemental Environmental Impact

6 Statement, Single Nuclear Unit at the Bellefonte Plant Site. May 2010. Available online at

7 http://www.tva.gov/environment/reports/blnp/index. htm#FEIS.

8 Tennessee Valley Authority (TVA). 201 Ob. John Sevier Fossil Plant Addition of Gas-Fired

9 Combustion Turbine/Combined-Cycle Generating Cap[acity and Associated Gas Pipeline.

10 March 2010. Available online at

11 http://www.tva..qov/environment/reports/iohnsevier ct/index.htm.

12 Tennessee Valley Authority (TVA). 2011 a. Integrated Resource Plan: TVA's Environmental &

13 Energy Future. March 2011. Accessed March 2011 at

14 http:l/www.tva.qovlenvironment/reports/irp/index.htm.

15 Tennessee Valley Authority (TVA). 2011 b. Environmental Impact Statement for TVA's

16 Integrated Resource Plan. Volume I. Accessed September 2011 at

17 http://www.tva.qov/environmentlreports/irp/pdfllRP FEIS V2 ToC.pdf.

18 U.S. Army Corps of Engineers (USACE). 2004. Appendix 3 A: Wind Energy as a Siting Criteria

19 for Potential Wind Parks. ESS, Inc., Hackensack, New Jersey.

20 U.S. Census Bureau (USCB). 2000. "Total Population [1] - Universe: Total Population

21 Dataset. Census 2000 Summary File (SF1) 100-Percent Data."

22 U.S. Department of Energy (DOE). 2005. Wind Energy Resource Potential. Accessed

23 September 30, 2008 at http://wwwl .eere.energy.gov/windandhydro/wind_potential.html.

24 U.S. Department of Energy (DOE). 2006. U.S. Geothermal Resource Map. Accessed

25 September 8, 2008 at http://www.eere.energy.gov/geothermal/geomap.html.

26 U.S. Department of Energy (DOE). 2008a. 20% Wind Energy by 2030. DOE/GO-102008-

27 2567. Accessed January 21, 2009 at http://wwwl.eere.energy.gov/windandhydro/.

28 U.S. Department of Energy (DOE). 2008b. Hydrogen Fuel Cells. DOE Hydrogen Program,

29 Washington, D.C. Accession No. ML100280723.

Draft NUREG-0498, Supplement 2 7-36 September 2011
Environmental Impacts of Alternatives

1 U.S. Department of Energy (DOE). 2008c. Hydrogen, Fuel Cells & Infrastructure Technologies

2 Program - Fuel Cell Technology Challenges. Accessed at January 24, 2011 at

3 http://wwwl.eere.energy.gov/hydrogenandfuelcells/fuelcells/fcchallenges.html. Accession No.

4 100280888.

5 U.S. Department of Energy-Energy Information Administration (DOE/EIA). 2001. Renewable

6 Energy 2000: Issues and Trends. Washington, D.C.

7 U.S. Department of Energy, Energy Information Administration (DOE/EIA). 2009. Solar

8 Thermal and Photovoltaic Collector Manufacturing Activities 2008. Accessed January 22, 2011

9 at http://www.eia.doe.gov/cneaf/solar.renewables/page/solarreportlsolar.html.

10 U.S. Department of Energy, Energy Information Administration (DOE/EIA). 2010. Annual

11 Energy Outlook 2011 with Projections to 2035. DOE/EIA-0383(2010). Available at

12 http://www.eia.gov/oiaf/archive/aeol 0/index. html.

13 U.S. Environmental Protection Agency (EPA). 2009. "Non-Hazardous Waste." Accessed

14 December 27, 2009 at http://www.epa.govlwaste/basic-solid.htm. Accession No.

15 ML100280908.

16 U.S. Nuclear Regulatory Commission (NRC). 1995. Final Environmental Statement Related to

17 the Operation of Watts Bar Nuclear Plant, Units I and 2. NUREG-0498, Supplement No. 1,

18 Washington, D.C. Accession No. ML081430592.

19 U.S. Nuclear Regulatory Commission (NRC). 1996. Generic Environmental Impact Statement

20 for License Renewal of Nuclear Plants. NUREG-1437, Vols. 1 and 2, NRC, Washington, D.C.

21 U.S. Nuclear Regulatory Commission (NRC). 2000. Environmental Standard Review Plan22 Review Plans for Environmental Reviews for Nuclear Power Plants. NUREG-1555,

23 Washington, D.C.

24 U.S. Nuclear Regulatory Commission (NRC). 2010. In the Matter of Tennessee Valley

25 Authority (Watts Bar Nuclear Plant, Unit 2) Docket No. 50-391-OL, CLI-10-29, Memorandum

26 and Order. Washington D.C.

September 2011 7-37 Draft NUREG-0498, Supplement 2

1 8.0 Need for Power

2 The current rule governing environmental review at the operating license stage (10 CFR 51.95)

3 states that, unless otherwise determined by the Commission, a final environmental statement

4 (FES) supplement on the operation of a nuclear power plant will not include a discussion of

5 need for power. For Watts Bar Unit 2, the Commission authorized the staff to include need for

6 power if, through its requisite "hard look," the staff concludes that new and significant

7 information is available (NRC 2010).

8 The Nuclear Regulatory Commission's (NRC's) original 1978 FES Operating License (FES-OL)

9 included a need-for-power assessment for Watts Bar Nuclear (WBN) Units 1 and 2 (NRC 1978).

10 The 1978 assessment was based on electric load estimates from 1978 and included load

11 forecasts out to 1983. Since 1979, the Tennessee Valley Authority (TVA) has updated its

12 analysis of its overall need for power. TVA annually undertakes a long-term capacity expansion

13 planning effort focused on achieving a least-cost portfolio plan that identifies the long- and short14 term actions (TVA 2008a). In addition, since the 1978 FES-OL TVA has produced two

15 publically available long-term (i.e., 20 or more years) Integrated Resource Plans (IRPs). In

16 December, 1995, TVA completed an IRP identifying and selecting long-range electricity

17 generation strategies intended to meet the electricity needs of its customers with a forecast

18 period extending from 1996 to 2020 (TVA 1995). On March 2, 2011, TVA issued its most recent

19 IRP, with a forecast period extending from 2011 to 2029. On April 14, 2011, the TVA Board of

20 Directors accepted the IRP and authorized the Chief Executive Officer to use its recommended

21 planning direction as a guide in energy resource planning and selection. On July 6, 2011, TVA

22 issued its Record of Decision stating that TVA will adopt the preferred alternative in its final

23 environmental impact statement (EIS) for the IRP (76 FR 39470).

24 The purpose of this Supplemental FES (SFES) is to present new and significant information

25 related to the need for power in the TVA service area, including information related to current

26 and projected electricity demand and supply within the timespan proposed for operation of WBN

27 Unit 2. This chapter presents the conclusion of the need-for-power analysis, which is that the

28 TVA service area has a need for baseload power to meet increased demand and to support the

29 displacement of power from older, less economical, and less environmentally favorable

30 generating capacity. The NRC staffs evaluation of alternatives in Chapter 7 of this SFES did

31 not reveal any viable energy generation alternatives that would be clearly environmentally

32 preferable to the operation of WBN Unit 2.

33 The following sections describe TVA's need for electric generating capacity. Section 8.1

34 reviews the current power system, including geographic considerations, and describes the

35 regional characteristics. Section 8.2 provides a review of the demand for power, including an

36 assessment of aspects that can affect the demand for power (e.g., energy efficiency and

September 2011 8-1 Draft NUREG-0498, Supplement 2
Need For Power

1 demand-side management [DSM], and econometric indicators). Section 8.3 discusses power

2 supply, including a review of past, present, and future generating capacity in the TVA service

3 area. Section 8.4 presents some conclusions regarding the need-for-power analysis.

4 8.1 Description of Power System

5 TVA provides service to an 80,000-mi 2 (207,200-km2) region encompassing almost all the State

6 of Tennessee and portions of the States of Kentucky, Mississippi, Alabama, Georgia, North

7 Carolina, and Virginia (Figure 8-1). This is the approximately the same size as TVA's service

8 territory identified in the 1978 FES-OL (NRC 1978). TVA's service area includes the area

9 mandated by the TVA Act, as amended, in 1959 and the area in which TVA has transmission

10 capability, and is the region for which TVA demonstrated a need for power (TVA 2008a). TVA

11 states that the purpose and need of its proposal to operate WBN Unit 2 is to meet the need for

12 additional baseload capacity in the WVA service area and maximize the use of existing assets

13 (TVA 2008b). TVA is proposing to operate a four-loop pressurized-water nuclear reactor

14 (WBN Unit 2) (NRC 1995) that is wholly owned by TVA (TVA 2009). WBN Unit 2 would be

15 operated on the WBN site in Rhea County, Tennessee, and would operate at 3,425 MW(t). The

16 net electrical output would be 1,160 MW(e), and the gross electrical output would be

17 1,218 MW(e) for the rated core power (TVA 2009). Although TVA originally expected to

18 complete Unit 2 by April 2012, it recently announced that completion is delayed until July to

19 September 2012, with a proposed operation of WBN Unit 2 beginning in 2013 (NRC 2011).

20 In 2008, the population of the service territory was estimated to be 9 million (TVA 2010), while in

21 1978, the population was approximately 6.7 million (NRC 1978). TVA currently serves

22 155 municipal and cooperative customers as their sole wholesale supplier of electricity, and

23 58 directly served industries as retail customers. The total number of businesses and

24 residential customers served in 2008 was 4,571,600. TVA supplies almost all electricity needs

25 (99 percent) in Tennessee, 31 percent in Mississippi, 24 percent in Alabama, and 26 percent in

26 Kentucky. TVA contributes 3 percent or less to meeting the electricity needs in the States of

27 Virginia, North Carolina, and Georgia (TVA 2010). The major load centers are the cities of

28 Memphis, Nashville, Chattanooga, and Knoxville, Tennessee, and Huntsville, Alabama

29 (TVA 2008a), while the load centers that were identified by TVA in 1978 included Paducah,

30 Kentucky, and Columbia, Tennessee (NRC 1978).

31 TVA is not subject to the jurisdiction of the Federal Energy Regulatory Commission (FERC)

32 under the Federal Power Act, but it is subject to certain limited aspects of FERC jurisdiction,

33 including the provision of open access transmission service, interconnections, and compliance

34 with FERC-approved reliability standards. In addition, TVA has voluntarily chosen to follow

35 FERC rules and orders to the extent they remain consistent with meeting TVA's obligations

36 under the TVA Act (TVA 2008a).

Draft NUREG-0498, Supplement 2 8-2 September 2011
Need For Power

2 Figure 8-1. Geographical and Political Boundaries of the TVA Power Service Area (TVA 2011)

3 Figure 8-2 illustrates the electrical transfer capabilities between TVA and neighboring utilities.

4 TVA has interconnection agreements with its neighboring systems, and these agreements

5 typically provide for emergency backup power. The TVA service area composes one of five

6 major geographical sub-regions of the Southeastern Electric Reliability Corporation (SERC) that

7 are identified as. Entergy, Gateway, Southern Company, TVA (also referred to as the Central

8 sub-region), and the Virginia-Carolinas Area (see Figure 8-3). SERC, a regional reliability

9 organization within the North American Electric Reliability Corporation (NERC), promotes,

10 coordinates, and ensures the reliability and adequacy of the bulk power supply systems in the

11 service areas of its member systems.

September 2011 8-3 Draft NUREG-0498, Supplement 2
Need For Power

Louisville Gas &

Electric/Kentucky

Utilities (E.ON

U.S.)- 2093 MW Arneren IP - 355 MW

2

2 Figure 8-2. TVA's Electrical Transfer Capabilities (TVA 2008a)

3

4

5

6

7

8

9

10

11

T"I" "t OIs oidld to depWI SERC otegions ejo•NOg the TA •M•o• eam0.

8sord.s 000t$ dxeq0 M00 W•0•a o•"0te.

Figure 8-3. Major Geographical Sub-Regions of the Southeastern Electric Reliability

Corporation (TVA 2008a)

Being a SERC member obligates TVA to exchange information on planning and operating its

systems with other sub-regions to ensure continued reliability of the interconnected systems and

facilitate periodic reviews of reliability-related activities within the SERC Region. SERC's

Reliability Review Subcommittee (RRS) conducts seasonal and annual reliability assessments

of the SERC Region by reviewing the data and studies submitted by SERC member systems

and performing related tasks in the assessment of the reliability of the SERC Region's

Draft NUREG-0498, Supplement 2 8-4 September 2011
Need For Power

1 interconnected bulk power system. The RRS also assesses future reliability and .adequacy of

2 the region based on the region's data co.llection efforts. In addition, the RRS independently

3 assesses the ability of the region and sub-regions to serve their obligations, given the demand

4 growth projections and overall capacity in the system (SERC 2008, TVA 2008a).

5 Although the Federal Power Act requires NERC to conduct annual reliability assessments to

6 perform these analyses, NERC must rely on reports its component regional entities create.

7 References to the "NERC Assessment" in this section should be interpreted as the SERC report

8 within the NERC Assessment. NERC results are used to confirm the applicant's conclusions

9 regarding the need for power in the TVA service area. NERC forecasts are subject to peer

10 review and adhere to academic standards for the analysis and reporting of scientific information

11 (NERC 2010).

12 8.2 Long-Term Capacity Expansion Planning and Power

13 Demand

14 The 1992 National Energy Policy Act (EPACT) directs TVA to use a least-cost energy planning

15 process (also referred to as integrated resource planning) to add new energy resources to its

16 power system, with congressional oversight. The EPACT also requires TVA to provide

17 distributors of its power an opportunity to participate in the planning process. TVA continues to

18 use least-cost energy planning today per EPACT requirements, carried out under congressional

19 oversight. As part of the Federal oversight process, the U.S. General Accounting Office (GAO;

20 now the Government Accountability Office) in 1995 reviewed TVA's financial conditions,

21 including its integrated planning load forecasting methodology. While GAO expressed concern

22 about TVA's financial condition, it concluded that TVA's forecasting methodology was

23 "reasonable and state of the art when compared to other forecasting tools available in the electric

24 utility industry" (GAO 1995). The NRC defers to independent integrated planning efforts

25 implemented or overseen by regional, State, or other public authorities in analyzing the need for

26 power. Although a state or regional utility regulatory commission does not regulate TVA, it is

27 structured and self-regulated in a manner similar to a regulated utility monopoly, with Federally

28 mandated least-cost planning requirements, congressional oversight, and a board of directors.

29 TVA annually undertakes a long-term capacity expansion planning effort focused on achieving a

30 least-cost portfolio plan that identifies the long- and short-term actions (TVA 2008a). TVA

31 anticipates additional baseload generation is necessary to meet the future demand for peak

32 load and overall energy needs (TVA 2008b, 2011). The last NRC staff review of TVA's need for

33 power from the WBN Unit 2 project occurred when NRC developed the FES-OL in 1978. TVA's

34 forecast period ended in 1983. Thus, the last NRC evaluation of the need for power from WBN

35 Unit 2 is more than 30 years old, and the period it included has long passed.

September 2011 8-5 Draft NUREG-0498, Supplement 2
Need For Power

1 Today, the NRC staff finds that TVA systematically prepares near-term and long-term forecasts

2 of demand and energy use applying methods tailored to the available data and customer

3 requirements. TVA uses several quantitative models, including econometric and economic end4 use models, to evaluate the relationship between major causal factors and the corresponding

5 impacts on future electricity consumption. The variety of models used by TVA allows for

6 comprehensive forecasting. TVA executives review and approve all outcomes and

7 assumptions. Various forecasting outcomes also are subject to confirmation by external parties

8 such as SERC's RRS. The load forecast represents a critical element of the process to

9 establish SERC Region capacity obligations. As a result, TVA and the SERC RRS scrutinize

10 the load forecast to ensure it represents a reliable estimate of future peak loads and provides

11 basis upon which to evaluate future capacity requirements (SERC 2008). The NRC staff further

12 addresses TVA's forecast in the section titled "Factors Affecting Demand."

13 Figure 8-4 illustrates the actual and forecasted net system demand requirements for the TVA

14 service area through 2030. Historically, net system requirements grew at an average rate of

15 2.3 percent (1990 through 2008) before the 2009 economic downturn. TVA uses a medium16 load forecast, which shows a 1.3 percent average annual growth from 2010 through 2030, to

17 project future power needs. It also uses high and low forecasts to help make more informed

18 power supply decisions. These high, medium, and low forecasts address the uncertainty

19 associated with a future outside of normal expectations. The NRC staff finds these forecasts to

20 be acceptable for purposes of this need-for-power analysis.

- H g h F o re c .a s t . ., ,

25•l'ttO0 •Medium Famwt•-.s ..

200O

21

22 Figure 8-4. Actual and Forecast Net System Requirements (TVA 2010)

Draft NUREG-0498, Supplement 2 8-6 September 2011
Need For Power

1

2

3

4

5

6

7

8

9

10

11

12

Figure 8-5 compares actual and forecasted net system requirements expressed in total annual

energy in terms of gigwatt-hours (GWh). The annual forecast error for the TVA net system

requirements has remained 1 percent over the 10-year time period from 1999 to 2008

(TVA 2008a, 2011). However, as shown in Figure 8-5, the sharp decline in energy usage in

2009, primarily due to the sudden regional economic downturn, presented an anomaly in energy

trends not well characterized by previous forecasts. TVA expects future growth to be lower than

historical averages for a number of reasons, including impacts of the 2008 to 2009 recession

and subsequent recovery, declining U.S. manufacturing, and projected loss of some TVA

customer load. TVA indicates that increased financial market regulation, tighter credit

conditions, and large Federal budget deficits may all restrain growth to a level lower than

previously predicted. All long-term planning forecasts consider the most current economic

indicators (TVA 2010).

190,000

185,000

INO(,000

175.000

170,.00

165,000

160,000

155.000

I - .Y ; 2009

! 1Y"2008 !

Apr 2006

Jul 2005

-W- Jul 2004

* *- I lan 2(3W

-+- Jul 2000

-w- Norm. Actuai

2000 2001 2002 2003 2004 2005 2006 2007 2008 2009

13

14 Figure 8-5. Comparison of Actual and Forecast Net System Requirements (TVA 2011)

15 Factors Affecting Demand

16 In general, economic and demographic trends, price and rate structure, energy efficiency and

17 substitution, and DSM programs all affect demand. The following paragraphs provide the

18 NRC's review of TVA's demand forecast methodology and the NRC staff's findings based on

19 this review.

September 2011 8-7 Draft NUREG-0498, Supplement 2
Need For Power

1 TVA indicates that economic growth remains the single most important driver of electricity sales.

2 TVA uses Gross Regional Product forecasts to estimate power demand forecasts. Population

3 and demographic factors also represent key variables in forecasting energy demand. TVA

4 develops energy forecasts for each economic sector (e.g., commercial, industrial, and

5 residential) based on factors and trends relevant to each sector. Based, in part, on these

6 forecasts, TVA develops annual near- and long-term forecasts. It bases near-term forecasts

7 primarily on the number of customers, employment, and usage trends, adjusted for seasons and

8 abnormal weather. TVA bases long-term forecasts primarily on the growth in the economy,

9 price of electricity, price of natural gas as a competing fuel, and expected growth or decline in

10 direct served customers (TVA 2008a, 2010). The NRC staff finds that TVA's power demand

11 forecasts are comprehensive because they incorporate key factors such as regional economic

12 and demographic trends, price of electricity, energy efficiency and substitution effects, and

13 weather. The NRC staff finds that TVA's approach to demand forecasting is systematic

14 because it occurs on an annual basis and includes similar classes of information as inputs in

15 each demand forecasting effort.

16 To quantify overall uncertainty in the load forecast, TVA indicates that it evaluates the

17 potentialuncertainty in future values of the input drivers (e.g., demographic variables) to the

18 forecast model. To address the uncertainty inherent in single-point forecasts, TVA evaluates

19 inputs such as inflation rates, electricity prices, and the price of fuel across probable ranges to

20 develop high, medium, and low future scenarios (TVA 2010).

21 TVA notes that electricity use varies inversely with the retail price of electricity. Prices and rate

22 structure play a key role in determining energy demand. TVA uses its published rates (constant

23 wholesale prices) for current prices and then forecasts future prices based on revenue

24 requirements, including targeted net income and debt repayment. The applicant simulated the

25 impact of adding an additional generation unit on overall system demand using an iterative

26 production cost model. TVA also used advanced analytical techniques, such as Monte Carlo

27 simulation of select key random variables (e.g., load, fuel prices, weather) to assess the overall

28 robustness of its long-term plans (TVA 2008a; PNNL 2009).

29 TVA indicates that natural gas competes with electricity for a number of end-uses in the

30 residential, commercial, and manufacturing sectors. TVA incorporates substitution effects that

31 occur when higher gas prices encourage more use of electrically powered equipment, and vice

32 versa, into its energy demand forecasts. TVA uses Henry Hub(a) natural gas price forecasts as

33 input to the energy demand forecast to determine the natural gas and electricity market shares

34 for various end-uses (e.g., heating, cooling, water heating). TVA also factors in trends in

35 household appliance usage and substitution to more efficient systems and appliances for

36 heating, cooling, water heating, and other household uses (TVA 2008a).

(a) Henry Hub is the pricing point for natural gas futures contracts traded on the New York Mercantile

Exchange.

Draft NUREG-0498, Supplement 2 8-8 September 2011
Need For Power

1 DSM programs, which are essentially interventions in the market to promote adopting more

2 efficient end-uses and changing consumer behavior, also can influence electricity demand.

3 Programs that reduce customers' energy usage through energy-efficiency, conservation, and

4 load management can significantly affect demand and demand growth. TVA offers several

5 conservation and DSM programs to its customers to reduce peak electricity demands and daily

6 power consumption. The effects of these DSM programs are included in the forecast for net

7 system requirements and summer peak load (PNNL 2009; TVA 2011).

8 The NRC staff finds that TVA's demand forecasts consider variations in multiple factors that

9 contribute to forecasting uncertainty. TVA presents these forecasts as low-, medium-, and high10 demand cases. As a result, the NRC staff finds that TVA's forecasts are both comprehensive

11 and responsive to forecasting uncertainty.

12 SERC develops a supply forecast for the Central/TVA sub-region in terms of reserve

13 requirements, measured by the margin of generation resources held in reserve for unexpected

14 outages of any kind. SERC does not implement a regional reserve requirement for the SERC

15 Central sub-region, but TVA's desired total reserve margin is 15 percent, which aligns with

16 established reserve margins in the utility industry (TVA 2011). This means that for every

17 100 kW of power needed to meet demand service area demand, TVA must be able to produce

18 at least 115 kW of electricity at any time. This reserve margin allows TVA to address

19 unexpected plant outages, take units offline for maintenance or repair, and to address higher20 than-expected peak loads. SERC's RRS committee conducts seasonal and annual reliability

21 assessments by reviewing the data and studies submitted by SERC member systems, which

22 include TVA (SERC 2008). In addition, the EPACT 1992 directs TVA to use a least-cost energy

23 planning process with congressional oversight, which included a comprehensive review of

24 TVA's methodology by the GAO (GAO 1995). Because TVA systematically submits

25 comprehensive power demand forecasts and supporting data to regulatory authorities including

26 SERC, NERC, GAO and U.S. Congress, the NRC staff finds that TVA's demand forecasts are

27 subject to confirmation.

28 8.3 Power Supply

29 In developing the power supply or capacity forecasts for the TVA service area, TVA factors in its

30 present and planned generating capabilities as well as present and planned purchases and

31 sales of power and planned retirements. As noted in Section 8.2, the last forecast NRC staff

32 reviewed in preparing the FES-OL included forecasts through 1983 (NRC 1978), which could

33 not adequately address present and planned capabilities, purchases, or sales in the TVA

34 system.

35 TVA, as directed by EPACT, uses a least-cost generation planning approach that includes a mix

36 of baseload, intermediate, and peak load resources. Generating capacity comes from a

September 2011 8-9 Draft NUREG-0498, Supplement 2
Need For Power

1 combination of existing TVA-owned resources, budgeted and approved projects (such as new

2 plant additions), and purchased power arrangements (PPAs). TVA includes monetary costs,

3 risk assessments, and environmental impacts as part of its cost minimization assessment.

4 Baseload generators are primarily used to meet TVA service area energy needs during most

5 hours of the year due to their relatively lower operating costs and high availability (TVA 2011).

6 TVA states that the purpose and need of its proposal to operate WBN Unit 2 is to meet the need

7 for additional baseload capacity in the TVA service area (TVA 2008b). TVA's power generation

8 system uses a range of technologies to produce electricity and meet the needs of the TVA

9 service area. In 2010, coal-fired generation (which primarily serves baseload and intermediate

10 duty cycles) made up approximately 40 percent of TVA's capacity electricity generation mix,

11 while nuclear generation made up approximately 19 percent, combustion turbines and

12 combined cycle (primarily fueled with natural gas) generation together made up 24 percent, and

13 hydro power provided 8 percent. The remaining 9 percent of TVA's electricity generation

14 capacity was made up of diesel-fired generation, pumped storage, renewable energy sources,

15 and DSM activities.

16 TVA's current forecasts already account for license renewal and power uprates for all

17 operational TVA nuclear plants (TVA 2011). TVA also included in its capacity estimates

18 potential generation from renewable energy sources (e.g., wind power). In addition, TVA

19 assessed the generation potential of distributed- and self-generation (e.g., solar power). TVA

20 currently operates a demonstration program, Green Power Switch Generation Partners, that

21 pays participating consumers for energy generated by renewable resource technologies

22 (e.g., solar photovoltaics). TVA continues to collect data from this program for its system

23 capacity estimates (TVA 2008a, 2011).

24 TVA's long-term capacity resources decline over time as a result of planned generation plant

25 retirements, including idling approximately 2,400 MW to 4,700 MW of coal-fired electricity

26 generation over the next 5 years. (TVA 2011). TVA's strategic planning goal to reduce carbon

27 generation sources to less than 50 percent of the electricity generation mix by 2020 influences

28 the capacity retirement/expansion decisions (PNNL 2009). As the NRC staff noted in

29 Chapter 7, TVA chooses which coal-fired plants to idle based on environmental compliance

30 costs, economic operational and maintenance costs, outage rates, waste disposal costs,

31 operational flexibility, and potential carbon dioxide emissions costs.

32 Although TVA belongs to a power pool with no standing arrangements for ongoing exchange of

33 power or joint ownership of generating facilities, its current and future capacity forecasts

34 consider purchased power potential (TVA 2010). Any location can generate power for purchase

35 and transmit it to the TVA system. Purchased power can contribute to TVA's regional capacity,

36 provided it is technically and economically viable. TVA regularly reviews purchased supply

37 options through its Bulk Power Trading Group, which currently holds several long-term purchase

38 contracts to obtain firm capacity (TVA 2008a).

Draft NUREG-0498, Supplement 2 8-10 September 2011
Need For Power

1 8.4 Need-for-Power Assessment and Conclusions

2 In the foregoing sections of this chapter, the NRC staff addressed TVA's processes for demand

3 and supply forecasts. Both demand and supply forecasts are crucial to the NRC staffs

4 consideration of need for power from WBN Unit 2.

5 The NRC staff notes that TVA assesses the need for power in its service area systematically

6 and comprehensively on an annual basis, while occasionally documenting its long-term planning

7 processes in an IRP. TVA provides documentation and results of its most recent long-term

8 expansion planning process in its 2011 IRP, Integrated Resource Plan: TVA's Environmental &

9 Energy Future (TVA 2011).

10 The NRC staff, in reviewing TVA's need-for-power assessment, found the following:

11 • TVA has a systematic iterative process for load forecasting that is updated annually. TVA

12 maintains a forecasting department that develops annual load forecasts. TVA's internal

13 review process includes an analysis and explanation of the historical predictive capability of

14 TVA's load forecast for its service area. Figure 8-4 and Figure 8-5 illustrate the accuracy of

15 TVA's energy and demand forecasts (1990-2009) (TVA 2011). GAO has reviewed TVA's

16 process and determined that it uses power industry best practices and methodological

17 approaches to determine its need for power. The NRC staff also finds that, as required by

18 EPACT 1992, TVA continues to use least-cost energy planning with congressional

19 oversight. The NRC staff finds that TVA's need-for-power assessment is systematic.

20 TVA power demand estimates and forecasts, as noted in this Section 8.2 of this chapter,

21 incorporate key factors such as regional economic and demographic trends, price of

22 electricity, energy efficiency and substitution effects, and weather. TVA generates different

23 forecasts for each sector of the economy and develops separate forecasts to determine

24 long-term and near-term demand. Power supply forecasts include a comprehensive

25 evaluation of present and planned generating capabilities in the TVA service area as well as

26 present and planned power purchases and sales. TVA also considers the potential of DSM

27 strategies and distributed generation in the analysis. TVA performed all analyses with

28 forecasting and statistical modeling and methodological approaches appropriate for the

29 utility industry. The NRC staff finds that power demand estimates and forecasts are thus

30 comprehensive.

31 TVA's forecasting department subjects its processes and models to peer review, as well as

32 review and approval by the TVA board of directors. In addition, external parties, including

33 SERC's RRS, confirm various outcomes of TVA's energy forecasts. The RRS conducts

34 seasonal and annual reliability assessments of the SERC Region by reviewing data and

35 studies member systems submit (SERC 2008). The SERC's annual reliability review and

36 NERC's annual long-term reliability assessment confirm TVA's forecast estimates and

37 generation needs. The NRC staff finds that TVA's need-for-power assessment is subject to

38 confirmation.

September 2011 8-11 Draft NUREG-0498, Supplement 2
Need For Power

1 As the NRC staff discussed earlier in this chapter, TVA quantifies uncertainty in the load

2 forecast by evaluating uncertainty in the future values of the input drivers and evaluating

3 uncertainty in relationships among input drivers. TVA evaluates the impact of alternative

4 demand-forecast levels (high, medium, and low) on key variables to determine impacts on

5 future electricity consumption. TVA develops forecasts under a range of scenarios, and

6 analyzes and explains the historical predictive capability of its load forecast for its service

7 area. TVA also uses advanced analytical techniques such as Monte Carlo simulation of

8 select key random variables, including load, fuel prices, and weather to assess the overall

9 robustness of its long-term plans (TVA 2011). The NRC staff finds that TVA's forecasts and

10 estimates are responsive to forecasting uncertainty.

11 In reviewing TVA's need-for-power analysis, the NRC staff found that TVA determines need for

12 power in its service area by comparing forecasted power capacity with forecasted demand. It

13 factors planning and operating power reserve margins into these estimates. TVA's desired total

14 reserve margin is 15 percent. TVA considers need for capacity to be demonstrated when

15 forecasted actual reserve margins are less than desired reserve margins. To determine

16 baseload needs, TVA compares existing and planned resources to the average loads (peak and

17 base) (TVA 2008a).

18 The NRC staff also looked to non-TVA data in examining and confirming the results of TVA's

19 need-for-power analysis. The NERC 2009 Long-Term Reliability Assessment reported a

20 decline in the net winter capacity resource margins in the TVA region from 26 percent in 2010 to

21 17 percent over a 10-year period, considering only existing and planned(a) capacity. The report

22 also showed a decline in net summer capacity resource margins from 25 percent in 2010 to

23 6 percent over a 10-year period, considering only existing and planned capacity. The report

24 considers WBN Unit 2 a "planned" capacity addition and assumes plant operation to begin in

25 2012. Without WBN Unit 2 operation, the report estimates a decline in the winter reserve

26 margin to approximately 18 percent in 2014. Without WBN Unit 2's added capacity, the NERC

27 report projects the summer reserve margin to decline to approximately 12 percent in 2014

28 (NERC 2010, which is less than TVA's reserve margin goal. These numbers are based on

29 demand and planned capacity (including retirements) forecasts in the TVA service area.

30 SERC's evaluation confirms that WBN Unit 2 will address a need for power in the Central sub31 region. Table 8-1 provides a comparison of the supply and demand forecast in the TVA service

32 area based on maintaining the targeted 15 percent reserve margin.

(a) Where "planned capacity" includes both capacity that is under construction and existing units that

are to be retired and deactivated or reactivated during the specified year.

Draft NUREG-0498, Supplement 2 8-12 September 2011
Need For Power

1 Table 8-1. Comparison of the Supply and Demand Forecasts for Service Area (NERC 2010)

SERC Central Sub-Region Projections for 2014 MW

Final Electricity Demand for Service Area (winter) 45,662

Final Electricity Demand for Service Area (summer) 46,314

TVA Service Area Winter Capacity Without WBN Unit 2 (net of 15 percent reserve) 44,769

TVA Service Area Summer Capacity Without WBN Unit 2 (net of 15 percent reserve) 42,762

Expected Excess Winter Supply/Capacity (Demand) Assuming 15 percent Reserve Margin (893)

Maintained

Expected Excess Summer Supply (Demand) Assuming 15 percent Reserve Margin (3,551)

Maintained

Rated Capacity of the Proposed Project (Proposed Operation in 2013) 1,160

Net Excess Winter Supply (Demand) if Proposed Project Goes Online in 2013 and 267

(assuming 15 percent reserve maintained)

Net Excess Summer Supply (Demand) if Proposed Project Goes Online in 2013 and (2,390)

(assuming 15 percent reserve maintained)

2 The results of TVA's need-for-power analysis suggests that additional baseload generation

3 capacity from operating WBN Unit 2 could maintain reserve margins above 15 percent, which

4 would allow TVA to meet the expected growing demand for electricity in its service area. TVA

5 proposes to operate WBN Unit 2 with an expected baseload net electrical rating of 1,160 MW(e)

6 (TVA 2008b). Under the medium load forecast, TVA estimates the total capacity needs by 2012

7 will equal the capacity of WBN Unit 2. Under the low-load forecast, TVA estimates this capacity

8 would not be needed until 2014 (TVA 2011). TVA's current timeline for WBN Unit 2 operation

9 calls for a facility to be in operation by the end of 2012 (NRC 2011).

10 Based on NRC's independent review of the need-for-power analysis presented in TVA's ER

11 (TVA 2008b), TVA's IRP (TVA 2011), the Final Supplemental Environmental Impact Statement

12 for Bellefonte Unit 1 (TVA 2008a), discussions with TVA (PNNL 2009), and the foregoing

13 analysis presented in this chapter, the NRC staff concludes that TVA provided a need-for-power

14 determination with a process that is (1) systematic, (2) comprehensive, (3) subject to

15 confirmation, and (4) responsive to forecasting uncertainty. The need-for-power assessment

16 suggests that a need for baseload power exists in the TVA service area to meet increased

17 demand and to support the displacement of power from older, less economical, and less

18 environmentally favorable generating capacity (TVA 2011). Chapter 7 of this SFES evaluates

19 and discusses viable energy alternatives to the operation of WBN Unit 2. This evaluation of

20 alternatives did not reveal any viable alternatives that would be clearly environmentally

21 preferable to the operation of WBN Unit 2.

22 8.5 References

23 10 CFR Part 51. Code of Federal Regulations, Title 10, Energy, Part 51, "Environmental

24 Protection Regulations for Domestic Licensing and Related Regulatory Functions."

September 2011 8-13 Draft NUREG-0498, Supplement 2
Need For Power

1 76 FR 39470. July 6, 2011. "Tennessee Valley Authority: Integrated Resource Plan." Federal

2 Register. Tennessee Valley Authority.

3 Energy Policy Act of 1992 (EPACT). 42 USCS 13201 et seq.

4 Federal Power Act. 16 USCS 791a et seq. North American Electric Reliability Corporation

5 (NERC). 2010. 2010 Long-Term Reliability Assessment. Accessed December 20, 2010 at

6 http:/lwww.nerc.com/files/2010%20LTRA.pdf.

7 Pacific Northwest National Laboratory. 2009. Letter from J.A. Stegen (Pacific Northwest

8 National Laboratory) to U.S. Nuclear Regulatory Commission dated November 12, 2009, "Final

9 Watts Bar Site Audit Trip Report for JCN J-4261, 'Technical Assistance for Operating License

10 Environmental Review - Watts Bar Unit 2 Reactivation."' Accession No. ML100220022.

11 Southeastern Electric Reliability Corporation (SERC). 2008. SERC Reliability Review

12 Subcommittee (RRS) Procedural Manual. February 28, 2008. Charlotte, North Carolina.

13 Available online at:

14 http://www.serc1 .org/documents/RRS%20%28Reliability%2OReview%2OSubcommittee%29/Pro

15 cedures/SERC%20RRS%20Procedural%2OManualEC%2OApproved%2002-28-08.pdf.

16 Tennessee Valley Authority (TVA). 1995. Energy Vision 2020: Integrated Resource Plan

17 Environmental Impact Statement. Volume 1. Accessed August 21, 2011 at

18 http://www.tva.gov/environment/reports/energyvision202O/index. htm.

19 Tennessee Valley Authority (TVA). 2008a. Bellefonte Nuclear Plant Units 3 & 4 COL

20 Application Part 3 Environmental Report. Revision 1. Accession No. ML083100486

21 Tennessee Valley Authority (TVA). 2008b. Final Supplemental Environmental Impact

22 Statement; Completion and Operation of Watts Bar Nuclear Plant Unit 2, Rhea County,

23 Tennessee, submitted to NRC as the TVA Environmental Report for an Operating License,

24 Knoxville, Tennessee. Accession No. ML080510469.

25 Tennessee Valley Authority (TVA). 2009. Watts Bar Nuclear Plant (WBN) - Unit 2 - Final

26 Safety Analysis Report (FSAR). Amendment 94, Spring City, Tennessee. Accession

27 No. ML092460757.

28 Tennessee Valley Authority (TVA). 2010. Final Supplemental Environmental Impact

29 Statement, Single Nuclear Unit at the Bellefonte Plant Site. May 2010. Available at

30 http://www.tva.gov/environment/reports/blnp/index.htm#FEIS.

Draft NUREG-0498, Supplement 2 8-14 September 2011
Need For Power

1 Tennessee Valley Authority (TVA). 2011. Integrated Resource Plan: TVA's Environmental &

2 Energy Future. March 2011. Available at

3 http://www.tva.gov/environment/reports/irp/index.htm.

4 Tennessee Valley Authority Act of 1933 (TVA Act), as amended. 16 USC 831 et seq.

5 U.S. General Accounting Office (GAO). 1995. Tennessee Valley Authority: Financial Problems

6 Raise Questions about Long-Term Viability. Washington, D.C. Available at

7 http://www.gao.gov/products/AIMDIRCED-95-134.

8 U.S. Nuclear Regulatory Commission (NRC). 1978. Final Environmental Statement Related to

9 Operation of Watts Bar Nuclear Plant Units Nos. 1 and 2. NUREG-0498, Washington, D.C.

10 Accession No. ML082540803.

11 U.S. Nuclear Regulatory Commission (NRC). 1995. Final Environmental Statement Related to

12 the Operation of Watts Bar Nuclear Plant, Units 1 and 2. NUREG-0498 Supplement No. 1,

13 Washington, D.C

14 U.S. Nuclear Regulatory Commission (NRC). 2010. In the Matter of Tennessee Valley

15 Authority (Watts Bar Nuclear Plant, Unit 2) Docket No. 50-391-OL, CL1-10-29, Memorandum

16 and Order. Washington D.C.

17 U.S. Nuclear Regulatory Commission (NRC). 2011. "Forth Report on the Status of

18 Reactivation of Construction and Licensing for Watts Bar Nuclear Plant, Unit 2." Policy Issue,

19 SECY-11-0102. July 28, 2011. Available at http://www.nrc.gov/reading-rm/doc20 collections/commission/secys/2011/2011-0102scy. pdf.

September 2011 8-15 Draft NUREG-0498, Supplement 2

1 9.0 Unavoidable Adverse Environmental Impacts

2 This supplemental final environmental statement (SFES) provides the results of the

3 U.S. Nuclear Regulatory Commission (NRC) staff's preliminary analyses, which consider and

4 weigh the environmental effects of operating one new unit (Unit 2) at the Watts Bar Nuclear

5 (WBN) plant in Rhea County, Tennessee.

6 This chapter summarizes (1) any adverse environmental impacts that cannot be avoided if the

7 proposed action were implemented, (2) the relationship between local short-term uses of the

8 environment and maintaining and enhancing long-term productivity, (3) any irreversible and

9 irretrievable commitments of resources involved if the proposed action were implemented,

10 (4) the environmental impacts of alternatives to the proposed action, (5) the benefits and costs

11 of the proposed action, and (6) the NRC staff's recommendation regarding the proposed action

12 based on its environmental review.

13 9.1 Unavoidable Adverse Environmental Impacts During

14 Operation

15 The NRC's regulations in Title 10 of the Code of Federal Regulations (CFR) Part 51 implement

16 Section 102(2)(C)(ii) of the National Environmental Policy Act of 1969, as amended (NEPA),

17 which requires an environmental impact statement (EIS) include a discussion about any

18 adverse environmental effects that cannot be avoided if the proposed action is implemented.

19 Under NEPA, unavoidable adverse environmental impacts at WBN Unit 2 would be those

20 potential impacts of operation for which no practical means of mitigation are available.

21 Construction of Watts Bar Unit 2 has been proceeding since the 1970s under a construction

22 permit that was issued through a regulatory action that is separate from the currently proposed

23 operating license.

24 In 1972, Section 3.0 of TVA (1972) discussed the following adverse environmental effects that

25 could not be avoided: (1) water pollution, (2) air pollution, (3) impact on land use, (4) damage to

26 life systems, and (5) threats to health. TVA (1972) discussed both construction and operation of

27 Watts Bar and methods to mitigate the impacts. Six years later, when evaluating the operating

28 license request, NRC (1978) did not identify any additional adverse effects that would be

29 caused by operation of Unit 2. During consideration of the operating license in 1995, NRC

30 (1995) once again did not identify any additional adverse environmental effects that would be

31 caused by operation of WBN Unit 2.

September 2011 9-1 Draft NUREG-0498, Supplement 2
Unavoidable Adverse Environmental Impacts

1 In the present review, the NRC staff sought additional information developed on unavoidable

2 adverse environmental effects, and Chapter 4 provides a detailed discussion of the potential

3 impacts from operating WBN Unit 2. In terms of the five unavoidable adverse environmental

4 impacts identified by TVA (1972), the NRC staff makes the following conclusions based on

5 review of additional information.

6 Regarding water pollution, assessments in Chapter 4 indicate that unavoidable adverse

7 environmental impacts due to operation would be small. Consumption of surface water from the

8 Tennessee River would increase due to evaporation, but the rate of consumptive water loss

9 would be small compared to the flow of the Tennessee River. Discharge of chemicals and heat

10 due to operation would continue to meet the requirements of the National Pollutant Discharge

11 Elimination System (NPDES) permit, so that the impact on surface-water quality would be

12 minimal. Potential physical impacts of the discharge would be mitigated by a diffuser system

13 and by a concrete incline at the Supplemental Condenser Cooling Water discharge, and the

14 physical effects of the discharge on surface-water quality would also be small. Changes in

15 groundwater withdrawal and groundwater quality due to operation of WBN Unit 2 would also be

16 small.

17 Air pollution is primarily a consideration during construction, and changes in air quality due to

18 operation would be minimal. Regarding land use, operation of the plant would not change

19 present land use on the site or in transmission corridors from that prior to operation, so

20 operation would not result in additional unavoidable adverse environmental impacts.

21 Chapter 4 speaks to "damage to life systems" in terms of impacts on terrestrial and aquatic

22 natural resources. The unavoidable impacts of operating WBN Unit 2 on terrestrial resources,

23 including Federally and State-listed species, would be small. Some loss of surface water

24 through evaporation is unavoidable, but the the total withdrawal and the consumptive withdrawal

25 would have a very minor impact, if any, on the aquatic biota in Watts Bar Reservoir,

26 Chickamauga Reservoir, and downstream. Although some entrainment and impingement of

27 fish is unavoidable, after an extensive review including new information, NRC staff found that

28 the adverse effects of entrainment and impingement would be small and would not destabilize

29 or noticeably alter the aquatic biota of the Chickamauga Reservoir. Mitigation measures and

30 the requirements of the NPDES permits would minimize the physical and thermal effects of the

31 heated discharge on aquatic resources.

32 Regarding threats to human health, NRC staff concluded in Chapter 4 that the information

33 provided by TVA and the NRC's own independent evaluation indicated no observable health

34 impacts on the public would result from normal operation of Unit 2 and the health impacts would

35 be small. The staff concludes that unavoidable adverse environmental impacts for all resource

36 areas are of SMALL significance.

Draft NUREG-0498, Supplement 2 9-2 September 2011
Unavoidable Adverse Environmental Impacts

1 9.2 Relationship Between Short-Term Uses and Long-Term

2 Productivity of the Human Environment

3 The Commission, in implementing Section 102(2) of NEPA through 10 CFR Part 51, requires an

4 EIS to include a discussion of the relationship between short-term uses of the environment and

5 the maintenance and enhancement of long-term productivity. As called for in the Council on

6 Environmental Quality (CEQ) Guidelines, the NRC staff evaluated the relationship between

7 local, short-term uses of the environment and the maintenance and enhancement of long-term

8 productivity of WBN Unit 2. Most of the short-term uses of the site will result in no significant

9 effect on the long-term productivity of the land, and the operation of Watts Bar Unit 2 will not

10 result in any significant long-term environmental degradation. All effluents discharged to the air,

11 water, and land will be within levels allowed by permits so they are considered acceptable by

12 regulatory agencies for short-term uses of the environment. Environmental monitoring

13 programs discussed in Chapter 5 provide a means for detecting and evaluating concentrations

14 of monitored parameters that, if out of permitted ranges could lead to long-term effects, so that

15 timely corrective action could be taken if required.

16 In the staffs 1978 FES, the staff reevaluated the assessment performed in consideration of the

17 Final Environmental Statement related to the construction permit for WBN Units 1 and 2 (FES18 CP) and concluded that presence of this plant in Rhea County, Tennessee, would continue to

19 influence the future use of other land in its immediate environs as well as the continued removal

20 of county land from agricultural use as the result of any increased industrialization.

21 Subsequently, in 1995, the staff determined there were no changes to this conclusion.

22 The local use of the human environment by the operation of WBN Unit 2 can be summarized in

23 terms of the unavoidable adverse environmental impacts of operation of the unit and the

24 irreversible and irretrievable commitments of resources. With the exception of the consumption

25 of depletable resources as a result of operation, these uses may be classed as short term. The

26 principal short-term benefit of the plant is represented by the production of electrical energy.

27 The site is already used for power generation through the operation of WBN Unit 1. WBN 2

28 structures already occupy the land, effectively precluding the land from other productive uses.

29 Initiating operation of Unit 2 and is a more productive use of the facility than not starting the unit.

30 The maximum long-term impact on productivity would result if the plant is not immediately

31 dismantled at the end of the period of plant operation, and, consequently, the land occupied by

32 the plant structures would not be available for any other use. In addition, most long-term

33 impacts resulting from land-use preemption by plant structures can be eliminated by removing

34 these structures or by converting them to other productive uses. Once the units are shutdown

35 the plant would be decommissioned according to NRC regulations. Once decommissioning is

36 complete and the NRC license is terminated, the land would be available for other uses.

September 2011 9-3 Draft NUREG-0498, Supplement 2
Unavoidable Adverse Environmental Impacts

1 9.3 Irreversible and Irretrievable Commitments of Resources

2 The NRC's rules in 10 CFR Part 51 implementing Section 102(2)(C) of NEPA require an EIS to

3 include a discussion of any irreversible or irretrievable commitments of resources that would be

4 involved in the alternative if it is implemented.

5 In 1972, the FES-CP discussed the extent to which operation of the facility curtails the range of

6 beneficial uses of the environment. The FES-CP presumed that the site on the Watts Bar

7 Reservation will continue to be dedicated to power production for the foreseeable future. The

8 FES-CP noted the construction and operation of the WBN plant would involve the use of a

9 certain amount of air, water, and land. Furthermore, except for the plant site itself, the range of

10 beneficial uses of the environment would not be curtailed. The FES-CP discussed the use of

11 fuel oil, industrial chemicals, and nuclear fuel consumption as examples of irreversible and

12 irretrievable uses of resources. It presumed that land and construction materials were

13 irreversibly and irretrievably committed for the foreseeable future. The FES-CP concluded that

14 the commitments were small when evaluated against the production of electricity from the plant.

15 The NRC staff re-evaluated the commitment of resources in its 1978 Final Environmental

16 Statement related to the operating license for WBN Units 1 and 2 (1978 FES-OL) and

17 concluded no changes have occurred since then, except for the continuing escalation of costs,

18 which have increased the dollar values of materials used for fueling the station (NRC 1978).

19 As discussed in the 1978 FES-OL and the 1995 supplemental FES (NRC 1995), uranium is the

20 principal natural resource irretrievably consumed by operating the WBN facility (NRC 1978).

21 Other materials consumed, for practical purposes, include fuel-cladding materials, reactor

22 control elements, other replaceable reactor core components, chemicals used in water

23 treatment, ion-exchange resins, and minor quantities of materials used in maintenance and

24 operation. The resource commitment for WBN Unit 2 is not particularly large when compared to

25 the consumption of these resources worldwide. Approximately 0.9 m3

/s (32 cfs) of cooling water

26 from the Tennessee River would be lost through consumptive use (i.e., evaporation) through

27 operation of WBN Unit 2. In addition, some aquatic biota would be lost through entrainment or

28 impingement; however, the losses would not destabilize populations.

29 During operations, vehicle exhaust emissions would continue in the vicinity of the plant and the

30 facility would release other air pollutants and chemicals, including very low concentrations of

31 radioactive gases and particulates, into the air and surface water. Because these releases

32 would conform to applicable Federal and State regulations, their impact on the public health and

33 the environment would be limited. The resources associated with WBN Unit 2 and associated

34 plant structures are already committed through the construction of the facilities. The additional

35 resources required to operate the plant are small in comparison.

Draft NUREG-0498, Supplement 2 9-4 September 2011
Unavoidable Adverse Environmental Impacts

1 9.4 Environmental Impacts of Alternatives

2 The NRC staff characterized the environmental impacts of constructing and operating a natural3 gas-fired power plant alternative and a combination of power generation alternatives. Both

4 alternatives would have an impact on air quality. There would also be construction impacts to

5 terrestrial resources and socioeconomic impacts. Based on this information, neither of the

6 viable energy alternatives would be preferable to the operation of WBN Unit 2.

7 9.5 Benefit-Cost Balance

8 NEPA and the CEQ require that all agencies of the Federal government prepare detailed

9 environmental statements on proposed major Federal actions significantly affecting the quality

10 of the human environment. One of NEPA's principal objectives is to require each Federal

11 agency to consider, in its decision-making process, the environmental impacts of each proposed

12 major action. In particular, as stated below, Section 102 of NEPA requires all Federal agencies

13 to the fullest extent possible to

14 "(B) identify and develop methods and procedures, in consultation with the Council

15 on Environmental Quality established by Title II of this Act, which will insure that

16 presently unquantified environmental amenities and values may be given appropriate

17 consideration in decision making along with economic and technical considerations."

18 (42 USC 4321)

19 However, neither NEPA nor CEQ requires the benefits and costs of a proposed action to be

20 quantified in dollars or any other common metric. NUREG-1555 (NRC 2000), Section 10.4.2

21 recommends the staff "...express all internal costs, either provided by the applicant or estimated

22 by the staff, in monetary terms."

23 The intent of this section is not to identify and quantify all potential societal benefits of the

24 proposed action and compare them to potential costs. Rather, it focuses only on those benefits

25 and costs of such magnitude or importance that including them in this analysis can inform the

26 decision-making process. This section compiles and compares the pertinent analytical

27 conclusions reached in earlier chapters of this SFES. It gathers the expected impacts from

28 operations of the proposed Unit 2 and aggregates them into two final categories: (1) the

29 expected costs and (2) the expected benefits derived from approving the proposed action.

30 General issues related to TVA's financial viability are outside of NRC's mission and authority

31 and, thus, this SFES will not consider them. The NRC will address issues related to the

32 applicant's financial qualifications in the staff's safety evaluation report. It is not possible to

33 quantify and assign a value to all benefits and costs associated with the proposed action.

34 However, this analysis attempts to identify, quantify, and provide monetary values for benefits

35 and costs when reasonable estimates are available.

September 2011 9-5 Draft NUREG-0498, Supplement 2
Unavoidable Adverse Environmental Impacts

1

2

3

4

5

6

Section 9.5.1 discusses the benefits associated with the proposed action. Section 9.5.2

discusses the costs associated with the proposed action. Table 9-1 summarizes the benefits

and costs of the proposed action. Internal costs include annual costs of operating and

maintaining WBN Unit 2. Section 9.5.3 summarizes the impact assessments and brings

previous sections together to establish a general impression of the relative magnitude of the

proposed project's costs and benefits.

Table 9-1. Summary of Benefits and Costs of the Proposed Action

Benefit-Cost Impact

Category Description Assessment(a)

Benefits

7

Electricity generated

Generating capacity

Fuel diversity

Progress toward

TVA's

environmental

stewardship goals

Long-term price

stability

Tax revenues

9,145,440 MWh per year for the 40-year life of the plant

(assuming 90% capacity factor)

1,160 MW(e)

WBN Unit 2 would increase TVA's nuclear fleet. TVA's

generation mix is heavily coal-fired.

Avoidance of sulfur dioxide, nitrogen oxide, carbon

monoxide, carbon dioxide, and particulate emissions typical

for other alternative fossil-fuel burning baseload power, as

nuclear generation has neglible air-quality impacts.

Historically, the price of nuclear power generation has been

relatively stable.

Tax-equivalent "impact payment" distributions from TVA to

the counties of Rhea, Meigs, McMinn, Roane, and Monroe

during construction period and 3 years after construction is

complete. Rhea County property tax revenues would also

increase over the 40-year life of the units (see Sections 2.4

and 4.4.2).

Increased jobs would benefit the area economically and

increase economic diversity of region (see Sections 2.4 and

4.4.2).

SMALL to

MODERATE

Local economy SMALL

Costs

Internal Costs(b)

Annual fixed

operating and

maintenance (O&M)

costs

Variable O&M costs

Estimated based on cost of staffing, materials, insurance,

fees, and O&M projects (TVA 2010).

Scheduled maintenance outage costs(c) (TVA 2010).

$49.1 million

per year

$18 million

per year 8

Draft NUREG-0498, Supplement 2 9-6 September 2011
Unavoidable Adverse Environmental Impacts

Table 9-1. (contd)

Benefit-Cost Impact

Category Description Assessment(a)

Fuelexpenses

Spent fuel

management

Decommissioning

Tax payments

Land use

External Costs

Land use

Air-quality

Terrestrial ecology

Aquatic ecology

Hydrology

Socioeconomic

Cultural resources

TVA has allocated $126 million for WBN initial core fueling

(TVA 2010). Recent fuel costs on average (throughout the

United States) are approximately 0.7 cents per kWh (WNA

2010; MIT 2009).

Estimated, on average, throughout U.S. industry as 0.1 cent

per kWh(d)

TVA estimates annual decommissioning expenses (in 2008

dollars) of $5.45 million based on average net megawatts

expected for WBN Unit 2 (TVA 2010).

In-lieu taxes paid by TVA to State of Tennessee based on

power sales and book value of property.

TVA will acquire no additional land as part of this proposal.

Negligible impacts on previously disturbed land (Sections 2.1

and 4.1).

Negligible air-quality impacts (see Sections 2.8 and 4.8).

Terrestrial ecology impacts expected to be small

(see Sections 2.3.1 and 4.3.1).

Aquatic ecology impacts expected to be small (see

Sections 2.3.2 and 4.3.2).

Hydrological impacts expected to be small (Sections 2.2.2 and

4.2).

Potential short-term strains on local schools, but the overall

impact is expected to be small (see Sections 2.4.2 and 4.4)

Negligible impacts on historical and cultural resources

(see Sections 2.5 and 4.5).

0.7 cents

per kWh

0.1 cents per

kWh

$5.45 million

annually

$0

SMALL

SMALL

SMALL

SMALL

SMALL

SMALL

SMALL

(a) Impact assessments are listed, for all impacts evaluated in detail, as part of this SFES. The details on impact

assessments are found, in the indicated sections of this SFES.

(b) Internal costs are costs incurred by TVA to implement proposed construction and operation of the WBN site.

Note that no impact assessments are provided for these private financial impacts.

(c) Scheduled maintenance outages occur approximately every 18 months.

(d) A 0.1-cent/kWh levy funds the United States used fuel program (WNA 2010).

September 2011 9-7 Draft NUREG-0498, Supplement 2
Unavoidable Adverse Environmental Impacts

1 9.5.1 Benefits

2 The most apparent benefit from operating a power plant is generating power that provides

3 electricity to thousands of residential, commercial, and industrial consumers in almost all of

4 Tennessee and portions of Kentucky, Mississippi, Alabama, Georgia, North Carolina, and

5 Virginia. For the electricity to benefit the region, however, the region of interest must have a

6 demonstrated need for baseload power.

7 TVA's load forecast indicates a need for additional baseload power in the region of interest by

8 the years 2012-2013. The proposed WBN Unit 2 would generate approximately 1,160 MW(e)

9 net, which would meet a portion of the baseload needs in the TVA service area. Chapter 8 of

10 this SFES discusses the need for power in the TVA service area. Assuming a capacity factor of

11 90 percent, the plant's average annual electrical energy generation would be more than

12 9,145,440 MWh.

13 9.5.1.1 Societal Benefits

14 From a societal perspective, nuclear power offers three primary benefits relative to most other

15 power generating systems: long-term price stability,fuel diversity, and avoidance of green16 house gas emissions (relative to fossil-based power generation).

17 Nuclear power has relatively low and nonvolatile fuel costs. Historically, the price of nuclear

18 generation has been relatively stable as well. Uranium fuel constitutes only 3 percent to 5

19 percent of the cost of a kilowatt-hour of nuclear-generated electricity (WNA 2010). In 2010,

20 coal-fired generation made up approximately 40 percent of TVA's capacity electricity generation

21 mix, while nuclear generation made up approximately 19 percent, combustion turbines and

22 combined cycle (primarily fueled with natural gas) generation together made up 24 percent, and

23 hydro power provided 8 percent. The remaining 9 percent of TVA's electricity generation

24 capacity was made up of diesel-fired generation, pumped storage, renewable energy sources,

25 and demand-side management activities. The operation of WBN Unit 2 along with the recent

26 idling of 3 coal power plants would modestly increase the percent of nuclear power generation

27 in the fleet while modestly decreasing the coal-fired (TVA 2011). Unlike electricity generated

28 from coal and natural gas, operating a nuclear power plant does not result in emissions of air

29 pollutants associated with global warming and climate change (e.g., nitrogen oxides, sulfur

30 dioxide, carbon dioxide) or methyl mercury.

31 9.5.1.2 Regional Benefits

32 The tax-equivalent payments TVA makes to the State of Tennessee related to existence and

33 operation of WBN Unit on the WBN site are redistributed to contribute property tax revenues to

34 Rhea County and other neighboring counties in the vicinity of WBN Unit 2 (see Section 4.4.2).

35 TVA expects operating WBN Unit 2 would maintain and slightly increase property in-lieu tax

Draft NUREG-0498, Supplement 2 9-8 September 2011
Unavoidable Adverse Environmental Impacts

1 payments distributed to Rhea County. Operations workers' retail expenditures (e.g.,

2 restaurants, hotels, merchant sales) would generate sales, use, and income taxes for the

3 county. Although a small local sales and use tax exists, the State would collect most of this,

4 both from individual workers and corporate entities in the general region of the site. No estimate

5 of day-to-day expenditures in the region during Unit 2 operations currently exists.

6 Operating WBN Unit 2 would require an operational workforce of about 200 people (see

7 Section 4.4.2 of this SFES) and would generate additional income and value for the State of

8 Tennessee and local economies for a period of at least 40 years. The economic multiplier effect

9 of increased spending by the direct and indirect workforce created as a result of one new unit

10 would increase the economic activity in the region, most noticeably in Rhea County. Section

11 4.4.2 provides additional information about the economic impacts of operating WBN Unit 2.

12 Table 9-1 summarizes benefits.

13 9.5.2 Costs

14 Nuclear power plants are expensive to construct relative to other power generation sources, but

15 have lower fuel costs relative to fossil-fired generation. WVA had completed about 80 percent of

16 WBN Unit 2 when construction work halted in 1985. In 2007, TVA resumed construction of

17 WBN Unit 2 with the aim of completing construction by 2012 and operating the plant by 2013

18 (WVA 2008). Although substantial construction costs and environmental impacts are associated

19 with constructing WBN Unit 2, they are sunk costs and are not relevant to the question of

20 whether the plant should operate. The relevant economic decision variables NRC considered

21 for this SFES are costs for operation and maintenance (O&M) fuel, waste disposals, and

22 decommissioning, because these expenses could be potentially avoided if the NRC did not

23 grant TVA an operating license for WBN Unit 2. The costs of construction were addressed in

24 NRC's Final Environmental Statement for the construction of WBN Units 1 and 2 (1978 FES25 CP) (NRC 1978).

26 WVA would incur internal costs and external costs to the surrounding region and environment

27 during operation of WBN Unit 2.

28 9.5.2.1 Internal Costs

29 Internal costs include O&M costs, fuel costs, waste disposal costs, and the cost of

30 decommissioning the facility at the end of its operating life.

31 Operating and Maintenance Costs

32 WVA provided annual fixed and variable O&M costs associated with the operation of WBN

33 Unit 2, which are included in Table 9-1. Fixed O&M costs include the cost of staffing, materials,

34 insurance, fees, and other miscellaneous maintenance and contract services. Variable O&M

September 2011 9-9 Draft NUREG-0498, Supplement 2
Unavoidable Adverse Environmental Impacts

1 costs include the cost of performing scheduled refueling and maintenance outages, which occur

2 approximately every 18 months. Operating costs would also include the cost of nuclear fuel.

3 TVA has estimated a fuel cost of approximately $126 million for the initial core fueling of WBN

4 Unit 2.

5 Studies from 2003 through 2005 have estimated that the levelized cost (i.e., price per kilowatt

6 hour of producing electricity, including the levelized cost of capital) to operate a new-generation

7 nuclear plant would be in the range of $36 to $65 per MWh (3.8 to 6.5 cents per kWh)

8 (University of Chicago 2004; MIT 2003; DOE 2004; OECD/IEA 2005). The Massachusetts

9 Institute of Technology (MIT) updated its results in 2009 (MIT 2009) estimating the levelized

10 cost of electricity at 8.4 cents per kWh (2007$). Factors affecting the range include choices for

11 discount rate, construction duration, plant life span, capacity factor, cost of debt and equity, and

12 split between debt and equity financing, depreciation time, tax rates, and premium for

13 uncertainty. Levelized operation cost estimates include decommissioning costs; however,

14 because of the effect of discounting a cost that would occur as much as 40 years in the future,

15 decommissioning costs have relatively little effect on the levelized cost. Because the

16 construction of WBN Unit 2 has taken places over the past 30 years, TVA has not calculated a

17 levelized cost analogous to those presented in the previously mentioned studies; however, TVA

18 has estimated its annual ongoing cost of capital (financing of debt) for WBN Unit 2 during

19 operation to be $15.3 million (2008 dollars), based on $13 million per 1,000 MW(e) capacity

20 (TVA 2010). Table 9-1 presents O&M costs associated with operating WBN Unit 2.

21 Fuel Costs

22 The calculation of levelized cost includes the cost of fuel. Nuclear fuel costs have increased in

23 recent years, from about 0.48 cents per kWh in 2002 to 0.69 cents per kWh in 2007. The most

24 recent MIT (2009) report on nuclear operation costs indicates that the cost of nuclear fuel in

25 2007 was, on average, 0.69 cents per kWh. The MIT estimate corresponds with World Nuclear

26 Association (WNA) estimates of 0.71 cents per kWh based on January 2010 spot prices for

27 uranium (WNA 2010).

28 Waste Disposal

29 Waste disposal costs of nuclear power contribute a small share of total cost of operating a

30 nuclear plant because of the long lifetime of a nuclear reactor and because provisions for waste31 related costs can be accumulated over that time. Radioactive nuclear waste poses unique

32 disposal challenges for long-term management, however. The WNA and U.S. Department of

33 Energy estimate spent fuel management costs to be 0.1 cents per kWh (WNA 2010).

Draft NUREG-0498, Supplement 2 9-10 September 2011
Unavoidable Adverse Environmental Impacts

1 Decommissioning

2 The NRC requires licensees at CFR 50.75 to provide reasonable assurance that funds would be

3 available for the decommissioning process. Because of the effect of discounting a cost that

4 would occur as much as 40 years in the future, decommissioning costs have relatively little

5 effect on the levelized cost of electricity generated by a nuclear power plant. The WNA

6 estimates decommissioning costs to be about 9 to 15 percent of the initial capital cost of a

7 nuclear power plant. However, when discounted, decommissioning costs contribute only a few

8 percent to the investment cost and even less to the generation cost. In the United States, they

9 account for 0.1 to 0.2 cents per kWh, which is no more than 5 percent of the cost of the

10 electricity produced (WNA 2010). TVA has estimated its annual decommissioning expenses

11 related to the operation of WBN Unit 2 to be approximately $5.5 million (2008 dollars) annually

12 (TVA 2010).

13 9.5.2.2 External Costs

14 External costs are those social and/or environmental effects resulting from operating Unit 2 at

15 the WBN site and could include such things as the loss of regional productivity, environmental

16 degradation, or the loss of habitat for wildlife. This SFES includes the NRC staff s analysis that

17 considers and weighs the environmental impacts of operating WBN Unit 2 and mitigation

18 measures available for reducing or avoiding these adverse impacts.

19 Although available information does not exist to assign monetary values to the impacts of

20 operating WBN Unit 2, Chapter 4 identifies and analyzes these impacts and assigns a

21 significance level of potential adverse impacts (i.e., SMALL, MODERATE, or LARGE).

22 Chapter 4 also addresses the environmental impacts from the (1) uranium fuel cycle and solid

23 waste management, (2) transportation of radioactive material, and (3) decommissioning of WBN

24 Unit 2. Table 9-1 summarizes projected internal and external costs for WBN Unit 2. Unlike

25 electricity generated from coal and natural gas, operating a nuclear power plant does not result

26 in emissions of air pollutants associated with global warming and climate change (e.g., nitrogen

27 oxides, sulfur dioxide, carbon dioxide) or methyl mercury; however, the radioactive nuclear

28 waste associated with nuclear power generation poses a unique disposal challenge for long29 term management. Chapter 7 of this SFES provides a comparison of the environmental

30 impacts of various power generation alternatives.

31 9.5.3 Summary

32 As discussed in Chapter 8, the need-for-power assessment suggests that a need for baseload

33 power exists in the TVA service area to meet increased demand and to support the

34 displacement of power from older, less economical, and less environmentally favorable

35 generating capacity (TVA 2011). WBN Unit 2 would help meet the increasing baseload demand

36 in the region by supplying an average annual electrical-energy generation capacity of about

September 2011 9-11 Draft NUREG-0498, Supplement 2
Unavoidable Adverse Environmental Impacts

1 9,000,000 MWh. Table 9-1 summarizes both internal and external costs of operating WBN Unit

2 2 and the identified benefits. The table references other sections of this SFES when more

3 detailed analyses and impact assessments are available for specific topics.

4 Although the NRC staff cannot reasonably assign any specific monetary values to the identified

5 societal benefits, it would appear that the potential societal benefits of operating WBN Unit 2, in

6 addition the power generated, would include reducing the coal-fired dependence of TVA's

7 power generation fleet and, thus, furthering TVA's environmental stewardship goals to reduce

8 greenhouse gas emissions in its service area (TVA 2011). Local benefits would include the

9 addition of jobs and tax revenues in the region. In comparison, the external socio10 environmental costs imposed on the region are relatively small.

11 9.6 Conclusions and Recommendations

12 This SFES contains the environmental review of the TVA application for an operating license for

13 WBN Unit 2 as required by the 10 CFR Part 51 and NRC regulations that implement the NEPA.

14 This section presents conclusions and recommendations from the environmental review and

15 summarizes environmental impacts from operation of WBN Unit 2 identified during the review.

16 The staffs evaluations are based on (1) the application, including the Environmental Report

17 (TVA 2008), previous EISs, and historical documents submitted by TVA; (2) consultation with

18 Federal, State, Tribal, and local agencies; (3) the staff's independent review; and (4) the staff's

19 consideration of comments related to the environmental review received during the public

20 scoping process. The staff based its conclusions on changes in the environment, plant design,

21 and proposed methods of plant operation since the publication of the 1978 FES-OL.

22 The staff concludes that impacts from operation of WBN Unit 2 associated with water use,

23 aquatic ecology, terrestrial resources, design basis accidents, socioeconomics, the radiological

24 exposure and nonradiological wastes and effluents, decommissioning, air quality, and land use

25 are generally consistent with those reached in the 1978 FES-OL and the 1995 Final

26 Environmental Statement Related to the Operation of Watts Bar Nuclear Plant, Units 1 and 2,

27 Supplement No. 1 (NRC 1995). In some cases, the impacts are less than those identified in the

28 1978 FES-OL.

29 Groundwater quality, public services, noise, transportation infrastructure, historic and cultural

30 resources, environmental justice, greenhouse gas emission, severe accidents, severe accident

31 mitigation alternatives, and cumulative impacts were not addressed in thel 978 FES-OL but are

32 addressed in this SFES. NRC staff concludes impacts associated with operation of WBN Unit 2

33 on groundwater quality, public services, noise, transportation infrastructure, cultural and

34 historical resources, greenhouse gas emission, and severe accidents would be SMALL. In

35 addition, staff concludes that operation of the WBN Unit 2 would not result in a

Draft NUREG-0498, Supplement 2 9-12 September 2011
Unavoidable Adverse Environmental Impacts

1 disproportionately high and adverse human health or environmental effect to any of the minority

2 and low-income communities near the WBN site.

3 Staff also considered cumulative impacts from past, present, and reasonably foreseeable future

4 actions. The staff concludes that although one of the cumulative impacts is LARGE, as the

5 result of other activities that affected the environment, the incremental impact from operation of

6 WBN Unit 2 would be, in all cases, minor and not noticeable in comparison to the other impacts.

7 The NRC staff's preliminary recommendation to the Commission related to the environmental

8 aspects of the proposed action is that the environmental impacts are not significant enough to

9 forego issuing the operating license for WBN Unit 2.

lo 9.7 References

11 10 CFR Part 50. Code of Federal Regulations, Title 10 Energy, Part 50, "Domestic Licensing of

12 Production and Utilization Facilities."

13 10 CFR Part 51. Code of Federal Regulations, Title 10, Energy, Part 51, "Environmental

14 Protection Regulations for Domestic Licensing and Related Regulatory Functions."

15 Massachusetts Institute of Technology (MIT). 2003. The Future of Nuclear Power: An

16 Interdisciplinary MIT Study. Cambridge, Massachusetts. Available at

17 http://web.mit.edu/nuclearpower/.

18 Massachusetts Institute of Technology (MIT). 2009. Update of The Future of Nuclear Power:

19 An Interdisciplinary MIT Study. Accessed July 23, 2009 at

20 http://web.mit.edu/nuclearpower/pdf/nuclearpower-update2009.pdf.

21 National Environmental Policy Act of 1969 (NEPA). 42 USC 4321 et seq.

22 Organization for Economic Co-Operation and Development and International Energy Agency

23 (OECD/IEA). 2005. Projected Costs of Generating Electricity, 2005 Update. International

24 Energy Agency (lEA), Paris, France.

25 Tennessee Valley Authority (TVA). 1972. Final Environmental Statement, Watts Bar Nuclear

26 Plant Units 1, and 2. TVA-OHES-EIS-72-9. Chattanooga, Tennessee. Available at

27 http://www.tva.gov/environment/reports/wattsbar2/related/nov_1972.pdf.

28 Tennessee Valley Authority (TVA). 2008. Final Supplemental Environmental Impact

29 Statement; Completion and Operation of Watts Bar Nuclear Plant Unit 2, Rhea County,

30 Tennessee. Submitted to NRC as the TVA Environmental Report for an Operating License,

31 Knoxville, Tennessee. Accession No. ML080510469.

September 2011 9-13 Draft NUREG-0498, Supplement 2
Unavoidable Adverse Environmental Impacts

1 Tennessee Valley Authority (TVA). 2010. Letter from Masoud Bajestani (Watts Bar Unit 2, Vice

2 President) to U.S. Nuclear Regulatory Commission dated February 25, 2010 in response to

3 NRC letter dated December 3, 2009 and TVA letters dated July 2, 2008, January 27, 2009, and

4 December 23, 2009, 'W\atts Bar Nuclear Plant (WBN) Unit 2 - Additional Information Regarding

5 Environmental Review (TAC No. MD8203)." Accession No. ML100630115.

6 Tennessee Valley Authority (TVA). 2011. Integrated Resource Plan: TVA's Environmental &

7 Energy Future. March 2011. Accessed March 2011 at

8 http://www.tva.gov/environment/reports/irp/index.htm.

9 University of Chicago. 2004. The Economic Future of Nuclear Power. Accessed at

10 http://www.ne.doe.gov/np2010/reports/NucllndustryStudy-Summary. pdf.

11 U.S. Department of Energy (DOE). 2004. Study of Construction Technologies and Schedules,

12 O&M Staffing and Cost, Decommissioning Costs and Funding Requirements for Advanced

13 Reactor Designs. Vol. 1 - MPR-2610, prepared by Dominion Energy, Inc., Bechtel Power

14 Corporation, TLG, Inc., and MPR Associates. Accession No. ML10182632.

15 U.S. Nuclear Regulatory Commission (NRC). 1978. Final Environmental Statement Related to

16 Operation of Watts Bar Nuclear Plant Units Nos. 1 and 2. NUREG-0498, Washington, D.C.

17 Accession No. ML082540803.

18 U.S. Nuclear Regulatory Commission (NRC). 1995. Final Environmental Statement Related to

19 the Operation of Watts Bar Nuclear Plant, Units I and 2. NUREG-0498, Supplement No. 1,

20 Office of Nuclear Reactor Regulation, Docket Nos. 50-390 and 50-391, Washington, D.C.

21 Accession No. ML081430592.

22 U.S. Nuclear Regulatory Commission (NRC). 2000. Environmental Standard Review Plan23 Standard Review Plans for Environmental Reviews for Nuclear Power Plants. NUREG-1555,

24 Vol. 1, Washington, D.C. Accession No. MLs ML003702134, ML003701937, ML003702019.

25 World Nuclear Association (WNA). 2010. The Economics of Nuclear Power. Accessed May

26 14, 2010 at http://www.world-nuclear.org/info/default.aspx?id=410&terms=economics.

27 Accession No. ML100600712.

Draft NUREG-0498, Supplement 2 9-14 September 2011
Appendix A

Contributors to the Supplement

Appendix A

Contributors to the Supplement

1

2

3

4

5

The overall responsibility for the preparation of this supplemental final environmental statement

(SFES) was assigned to the Office of Nuclear Reactor Regulation, U.S. Nuclear Regulatory

Commission (NRC). Members of the Office of Nuclear Reactor Regulation prepared the SFES

with assistance from other NRC organizations and the Pacific Northwest National Laboratory.

Name Affiliation Function or Qualifications

NUCLEAR REGULATORY COMMISSION

Joel Wiebe Nuclear Reactor Regulation Project Manager

Patrick Milano Nuclear Reactor Regulation Project Manager

Justin Poole Nuclear Reactor Regulation Project Manager

Laurel Bauer Nuclear Reactor Regulation Branch Chief

Andrew Imboden Nuclear Reactor Regulation Branch Chief, Air Quality

Dennis Beisselta) Nuclear Reactor Regulation Environmental Team Lead, Hydrology, Nonradiological

Human Health

Dennis Logan Nuclear Reactor Regulation Environmental Team Lead, Ecology

Jeffrey Rikhoff Nuclear Reactor Regulation Socioeconomics, Benefit-cost, Environmental Justice

Kevin Folk Nuclear Reactor Regulation Hydrology

Ray Galluci Nuclear Reactor Regulation Severe Accident Mitigation Alternatives

Andrew Stuyvenberg Nuclear Reactor Regulation Need for Power, Alternatives, Benefit-Cost

Jennifer Davis Federal and State Materials and Cultural Resources

Environmental Management

Allison Travers Nuclear Reactor Regulation Cultural Resources

Stephen Nuclear Reactor Regulation Health Physics, Nonradiological Human Health

Klementowicz

Rebekah Krieg

Amanda Stegen

Tonya Keller

Robert Bryce

Corey Duberstein

Katherine Cort

Tara O'Neil

Eva Eckert Hickey

PACIFIC NORTHWEST NATIONAL LABORATORY(b)

Project Manager, Aquatic Ecology

Task Leader

Deputy Task Leader

Hydrology, Groundwater, Surface Water

Terrestrial Ecology

Land Use, Socioeconomics, Environmental Justice,

Benefit-Cost, Need for Power, Alternatives

Cultural Resources

Health Physics

September 2011 A-1 Draft NUREG-0498, Supplement 2
Appendix A

Name Affiliation Function or Qualifications

Richard Traub Health Physics

James V. Ramsdell, Jr Air Quality, Meteorology, Design Basis Accidents,

Severe Accidents

Steve Short Severe Accidents

Amoret Bunn Nonradiological Human Health

Lara Aston Nonradiological Human Health

Tom Anderson Cumulative Impacts

Georganne O'Connor Program Specialist

Lubov Lavrentiev Assistant

Dave Payson Technical Editing, Document Coordinator

Susan Ennor Technical Editing

Michael Parker Technical Editing, Document Design

Tomiann Parker References

Sharon Johnson References

Kathy Neiderhiser Document Design

Rose Zanders Graphics

Donna Austin-Workman Graphics

(a) Staff member is no longer with the NRC Office of Nuclear Reactor Regulation.

(b) Pacific Northwest National Laboratory is operated by Battelle for the U.S. Department of Energy.

1

2

Draft NUREG-0498, Supplement 2 A-2 September 2011
Appendix B

Organizations Contacted

Appendix B

Organizations Contacted

1 The following Federal, State, Tribal, regional, and local organizations were contacted during the

2 course of the U.S. Nuclear Regulatory Commission staff's independent review of potential

3 environmental impacts from operation of one new nuclear unit at the Watts Bar Nuclear site in

4 Rhea County, Tennessee:

5 Absentee Shawnee Tribe of Oklahoma, Shawnee, Oklahoma

6 Advisory Council on Historic Preservation, Washington, D.C.

7 Alabama-Coushatta Tribe of Texas, Wetumka, Oklahoma

8 Alabama-Quassarte Tribal Town, Wetumka, Oklahoma

9 Cherokee Nation, Tahlequah, Oklahoma

10 Choctaw Nation of Oklahoma, Durant, Oklahoma

11 Dayton City School System, Dayton, Tennessee

12 Department of Interior, Office of Environmental Policy and Compliance, Atlanta, Georgia

13 Eastern Band of Cherokee Indians, Cherokee, North Carolina

14 Eastern Band of the Cherokee Indians, Bryson City, North Carolina

15 Eastern Shawnee Tribe of Oklahoma, Seneca, Missouri

16 Harmon, Curran, Spielberg & Eisenberg, L.L.P., Washington, D.C.

17 Jena Band of Choctaw Indians, Jena, Louisiana

18 Kialegee Tribal Town, Wetumka, Oklahoma

19 Meigs County School System, Decatur, Tennessee

20 Muscogee (Creek) Nation of Oklahoma, Okmulgee, Oklahoma

September 2011 B-1 Draft NUREG-0498, Supplement 2
Appendix B

1 Shawnee Tribe, Miami, Oklahoma

2 Southeast Tennessee Development District, Chattanooga, Tennessee

3 Southern Alliance for Clean Energy, Washington, D.C.

4 Tennessee Department of Agriculture, Nashville, Tennessee

5 Tennessee Department of Economic and Community Development, Nashville, Tennessee

6 Tennessee Department of Environment and Conservation, Chattanooga Field Office,

7 Chattanooga, Tennessee

8 Tennessee Department of Environment and Conservation, Nashville, Tennessee

9 Tennessee Department of Transportation, Nashville, Tennessee

10 Tennessee Historical Commission, Nashville, Tennessee

11 Tennessee Wildlife Resource Agency, Nashville, Tennessee

12 The Chickasaw Nation, Ada, Oklahoma

13 Thlopthlocco Tribal Town, Okemah, Oklahoma

14 United Keetoowah Band Headquarters, Tahlequah, Oklahoma

15 U.S. Army Corps of Engineers, Nashville, Tennessee

16 U.S. Environmental Protection Agency, Atlanta, Georgia

17 U.S. Fish and Wildlife Service, Cookeville, Tennessee

18 Watts Bar Utility District, Kingston, Tennessee

Draft NUREG-0498, Supplement 2 B-2 September 2011
Appendix C

Chronology of NRC Staff Environmental Review

Correspondence Related to Tennessee Valley

Authority Application for an Operating License for

Watts Bar Nuclear Plant Unit 2

1

2

3

4

5

6

7

8

9

10

11

12

13

Appendix C

Chronology of NRC Staff Environmental Review

Correspondence Related to Tennessee Valley

Authority Application for an Operating License for

Watts Bar Nuclear Plant Unit 2

This appendix contains a chronological list of correspondence between the U.S. Nuclear

Regulatory Commission (NRC) and the Tennessee Valley Authority (TVA) and other

correspondence related to the NRC staff's environmental review, under Title 10 of the Code of

Federal Regulations (CFR) Part 51, for TVA's application for an operating license (OL) at the

Watts Bar Nuclear (WBN) plant Unit 2 site in Rhea County, Tennessee.

All documents, with the exception of those containing proprietary information or otherwise

exempt from disclosure, have been placed in the NRC's Public Document Room, at One White

Flint North, 11555 Rockville Pike (first floor), Rockville, Maryland, and are available

electronically from the Public Electronic Reading Room found on the Internet at the following

web address: http://www.nrc.gov/reading-rm.html. The public can use this site to gain access

to the NRC's Agencywide Document Access and Management System (ADAMS), which

provides text and image files of NRC's publicly available documents. The ADAMS accession

numbers for each document are included below.

Author Recipient Date of Letter/lEmail

Tennessee Valley Authority

(M. Bajestani)

U.S. Nuclear Regulatory Commission

(J.F. Williams)

U.S. Nuclear Regulatory Commission

(J.F. Williams)

Tennessee Valley Authority

(M. Bajestani)

Tennessee Valley Authority

(M. Bajestani)

U.S. Nuclear Regulatory Commission

(J. Wiebe)

U.S. Nuclear Regulatory

Commission

Tennessee Valley Authority

(A. Bhatnagar)

Tennessee Valley Authority

(A. Bhatnagar)

U.S. Nuclear Regulatory

Commission

U.S. Nuclear Regulatory

Commission

U.S. Fish and Wildlife Service

(M. Jennings)

February 15, 2008

(ML080510469)

June 3, 2008

(ML081210270)

June 20, 2008

(ML081500030)

July 2, 2008

(ML081850460)

January 27, 2009

(ML090360588)

September 2, 2009

(ML092100088)

September 2011 C-1 Draft NUREG-0498, Supplement 2
Appendix C

Author Recipient Date of Letter/Email

U.S. Nuclear Regulatory Commission

(J. Wiebe)

U.S. Nuclear Regulatory Commission

(J. Wiebe)

U.S. Nuclear Regulatory Commission

(J. Wiebe)

U.S. Nuclear Regulatory Commission

(J. Wiebe)

U.S. Nuclear Regulatory Commission

(J. Wiebe)

U.S. Nuclear Regulatory Commission

(J. Wiebe)

U.S. Nuclear Regulatory Commission

(J. Wiebe)

U.S. Nuclear Regulatory Commission

(J. Wiebe)

U.S. Nuclear Regulatory Commission

(J. Wiebe)

U.S. Nuclear Regulatory Commission

(J. Wiebe)

U.S. Nuclear Regulatory Commission

(J. Wiebe)

U.S. Nuclear Regulatory Commission

(J. Wiebe)

U.S. Nuclear Regulatory Commission

(J. Wiebe)

U.S. Nuclear Regulatory Commission

(J. Wiebe)

U.S. Nuclear Regulatory Commission

(J. Wiebe)

U.S. Nuclear Regulatory Commission

(J. Wiebe)

U.S. Nuclear Regulatory Commission

(J. Wiebe)

U.S. Nuclear Regulatory Commission

(J. Wiebe)

U.S. Nuclear Regulatory Commission

(J. Wiebe)

Southern Alliance for Clean Energy

(D. Curran and M. Fraser)

Advisory Council on Historic

Preservation (D. Klima)

Cherokee Nation

(R. Allen)

Eastern Band of the Cherokee

Indians (T. Howe)

Eastern Band of the Cherokee

Indians (R. Townsend)

United Keetoowah Band

Headquarters (L.Larue-Stopp)

The Chickasaw Nation

(V. (Gingy) Nail)

Choctaw Nation of Oklahoma

(T. Cole)

Choctaw Nation of Oklahoma

(G. Pyle)

Jena Band of Choctaw Indians

(L. Strange)

Muscogee (Creek) Nation of

Oklahoma (J. Bear)

Alabama-Coushatta Tribe of Texas

(B. Battise)

Alabama-Quassarte Tribal Town

(A. Asbury)

Kialegee Tribal Town

(E. Bucktrot and G. Bucktrot)

Thlopthlocco Tribal Town

(C. Coleman)

Absentee Shawnee Tribe of

Oklahoma (K. Kaniatobe)

Eastern Shawnee Tribe of

Oklahoma (R. DuShane)

Eastern Shawnee Tribe of

Oklahoma (G.J. Wallace)

Shawnee Tribe

(R. Sparkman)

September 4, 2009

(ML092440217)

September 10, 2009

(ML092120105)

September 10, 2009

(ML092110475)

September 10, 2009

(ML092110475)

September 10, 2009

(ML092110475)

September 10, 2009

(ML092110475)

September 10, 2009

(ML092110475)

September 10, 2009

(ML092110475)

September 10, 2009

(ML092110475)

September 10, 2009

(ML092110475)

September 10, 2009

(ML092110475)

September 10, 2009

(ML092110475)

September 10, 2009

(ML092110475)

September 10, 2009

(ML092110475)

September 10, 2009

(ML092110475)

September 10, 2009

(ML092110475)

September 10, 2009

(ML092110475)

September 10, 2009

(ML092110475)

September 10, 2009

(ML092110475)

Draft NUREG-0498, Supplement 2 C-2 September 2011
Appendix C

Author

U.S. Nuclear Regulatory Commission

(J. Wiebe)

U.S. Nuclear Regulatory Commission

(J. Wiebe)

U.S. Nuclear Regulatory Commission

(J. Wiebe)

U.S. Nuclear Regulatory Commission

(J. Wiebe)

U.S. Nuclear Regulatory Commission

(J. Wiebe)

U.S. Nuclear Regulatory Commission

(J. Wiebe)

U.S. Nuclear Regulatory Commission

(J. Wiebe)

U.S. Nuclear Regulatory Commission

(J. Wiebe)

U.S. Nuclear Regulatory Commission

(J. Wiebe)

U.S. Nuclear Regulatory Commission

(J. Wiebe)

U.S. Nuclear Regulatory Commission

(J. Wiebe)

U.S. Nuclear Regulatory Commission

(J. Wiebe)

U.S. Nuclear Regulatory Commission

(J. Wiebe)

U.S. Nuclear Regulatory Commission

(J. Wiebe)

U.S. Nuclear Regulatory Commission

(J. Wiebe)

U.S. Nuclear Regulatory Commission

(J. Wiebe)

Recipient

Shawnee Tribe

(B. Pryor)

Tennessee Historical Commission

(J.Y. Garrison)

U.S. Army Corps. of Engineers

(R. Gatlin)

Office of Environment Policy and

Compliance, Department of Interior

(G.L. Hogue)

Sam Nunn Atlanta Federal Center

(A.S. Meiburg and S. Gordon)

Tennessee Department of

Environment and Conservation

(M. Apple)

Tennessee Department of

Environment and Conservation

(S. Baxter)

Tennessee Department of

Environment and Conservation

(B. Bowen)

Tennessee Department of

Economic and Community

Development (M. Atchinson)

Environment and Planning

Environmental Division (E. Cole)

Tennessee Department of

Agriculture (K. Givens)

Tennessee Department of

Environment and Conservation

(P. Davis)

Water Supply

(R. Foster)

Tennessee Department of

Environment and Conservation

(J. Fyke)

Division of Radiological Health

(L.E. Nanney)

Tennessee Department of

Environment and Conservation

(B. Stephens)

Date of Letter/Email

September 10, 2009

(ML092110475)

September 10, 2009

(ML092120097)

September 10, 2009

(ML092110147)

September 10, 2009

(ML092110147)

September 10, 2009

(ML092110147)

September 10, 2009

(ML092110147)

September 10, 2009

(ML092110147)

September 10, 2009

(ML092110147)

September 10, 2009

(ML092110147)

September 10, 2009

(ML092110147)

September 10, 2009

(ML092110147)

September 10, 2009

(ML092110147)

September 10, 2009

(ML092110147)

September 10, 2009

(ML092110147)

September 10, 2009

(ML092110147)

September 10, 2009

(ML092110147)

September 2011 C-3 Draft NUREG-0498, Supplement 2
Appendix C

Author

U.S. Nuclear Regulatory Commission

(J. Wiebe)

U.S. Nuclear Regulatory Commission

(J. Wiebe)

U.S. Nuclear Regulatory Commission

(J. Wiebe)

U.S. Nuclear Regulatory Commission

(J. Wiebe)

U.S. Nuclear Regulatory Commission

(J. Wiebe)

Tennessee Historical Commission

(E.P. McIntyre)

Eastern Band of Cherokee Indians

(T. Howe)

U.S. Fish and Wildlife Services

(M. Jennings)

Tennessee Valley Authority

(M. Bajestani)

U.S. Nuclear Regulatory Commission

(J. Wiebe)

Tennessee Valley Authority

(M. Bajestani)

Tennessee Valley Authority

(M. Bajestani)

Tennessee Historical Commission

(E. Patrick McIntyre, Jr)

Tennessee Valley Authority

(M. Bajestani)

Tennessee Valley Authority

(M. Bajestani)

Tennessee Valley Authority

(M. Bajestani)

Tennessee Valley Authority

(R.M. Krich)

Tennessee Valley Authority

(E.E. Freeman)

Draft NUREG-0498, Supplement 2

Recipient

Tennessee Department of

Environment and Conservation

(M. Tummons)

Groundwater

(A. Schwendimann)

Tennessee Wildlife Resource

Agency (E. Carter)

Resource Management Division

(A. Marshall)

Tennessee Department of

Transportation (Commissioners

Office)

U.S. Nuclear Regulatory

Commission (J. Wiebe)

U.S. Nuclear Regulatory

Commission

U.S. Nuclear Regulatory

Commission (J. Wiebe)

U.S. Nuclear Regulatory

Commission

Tennessee Valley Authority

(A. Bhatnagar)

U.S. Nuclear Regulatory

Commission

U.S. Nuclear Regulatory

Commission

U.S. Nuclear Regulatory

Commission (J. Wiebe)

U.S. Nuclear Regulatory

Commission

U.S. Nuclear Regulatory

Commission

U.S. Nuclear Regulatory

Commission

U.S. Nuclear Regulatory

Commission

U.S. Nuclear Regulatory

Commission

Date of Letter/Email

September 10, 2009

(ML092110147)

September 10, 2009

(ML092110147)

September 10, 2009

(ML092110147)

September 10, 2009

(ML092110147)

September 10, 2009

(ML093080084)

September 22, 2009

(ML093510985)

September 29, 2009

(ML0928605910)

October 9, 2009

(ML0929301820)

October 22, 2009

(ML093510833)

December 3, 2009

(ML093030148/

MIL093290073)

December 23, 2009

(ML100210358)

February 25, 2010

(ML100630116)

March 5, 2010

(ML100770290)

April 9, 2010

(ML101130392)

May 12, 2010

(ML101340589)

July 2, 2010

(ML101930470)

July 6, 2010

(ML101890069)

January 4, 2011

(ML1 10060510)

C-4 September 2011
Appendix C

Author

Tennessee Valley Authority

(M. Gillman)

Tennessee Valley Authority

(E.E. Freeman)

Tennessee Valley Authority

(E.E. Freeman)

Tennessee Valley Authority

(D. Stinson)

Tennessee Valley Authority

(D. Stinson)

Tennessee Valley Authority

(D. Stinson)

Tennessee Valley Authority

(R.M Krich)

Recipient

U.S. Nuclear Regulatory

Commission

U.S. Nuclear Regulatory

Commission

U.S. Nuclear Regulatory

Commission

U.S. Nuclear Regulatory

Commission

U.S. Nuclear Regulatory

Commission

U.S. Nuclear Regulatory

Commission

U.S. Nuclear Regulatory

Commission

Date of Letter/Email

February 7, 2011

(ML110400384)

March 24, 2011

(ML110871475)

March 28, 2011

(ML1 10890472)

May 19, 2011

(ML1 1 143A083)

May 20, 2011

(ML1 11 46A044)

May 26, 2011

(ML11152A160)

July 28, 2011

(ML1 1215A098)

1

September 2011 C-5 Draft NUREG-0498, Supplement 2

Appendix D

Scoping Comments 

and Responses

Appendix D

WATTS BAR NUCLEAR PLANT, UNIT 2 - COMPLETE LIST OF COMMENTS,

SUGGESTIONS, AND STAFF RESPONSES CONDENSED FROM THE OCTOBER 6, 2009,

PUBLIC SCOPING MEETING

On October 6, 2009, a Category 3 public meeting (two sessions) was held between the

U.S. Nuclear Regulatory Commission (NRC) and interested public at the Magnuson Hotel,

1421 Murrays Chapel Road, Sweetwater, Tennessee 37874. The purpose of the meeting was

to present an overview of the environmental review process for Watts Bar Unit 2 operating

license application and to obtain public comments regarding the scope of the environmental

review.

Scoping meeting attendees provided either written statements or oral comments that the NRC

recorded and a certified court reporter transcribed. In addition, during the scoping period, the

NRC received four letters and five emails providing comments on the proposed action. The

staff considered all comments and suggestions received.

The meeting summary was issued on October 21, 2009, and is available electronically from the

Publicly Available Records component of NRC's Agencywide Documents Access and

Management System (ADAMS) under accession number ML092880764. ADAMS documents

can be found at https:/twww.nrc.-gov/reading-rm/adams.html.

The following selection of public comments has been broken down into two categories:

1) Public comments that are covered in the supplemental final environmental statement

(SFES) (equivalent to an environmental impact statement [EIS])

2) Public comments concerning issues that are outside the scope of review

Table A-1 identifies the individuals providing comments in alphabetical order; their affiliation, if

given; the ADAMS accession number that can be used to locate the correspondence; and the

correspondence identification number (ID). Table A-2 identifies individual comments covered in

the SFES and those comments outside the scope of review.

Table A-1. Individuals Providing Comments During the Comment Period

Commenter

Burris, Shane

Cobb, Jim

Curran, Diane

Gottfrled, Yolande

Harris, Ann

Harris, Ann

Howe, Tyler

Jennings, Mary

Jones, Ken

Kurtz, Sandy

Mastin, Mary

Affiliation (if stated)

Monroe County

Tennessee House District 31

Harmon, Curran, Spielberg &

Eisenberg, LLP

Comment Source and ADAMS

Accession #

Meeting Transcript (ML092870331)

Meeting Transcript (ML092870331)

Letter (ML093080581)

Letter (ML093090656)

Meeting Transcript (ML092870331)

Meeting Transcript (ML092870338)

Correspondence ID

0003

0003

0010

0008

0003

0004

0006

0005

0004

0004

0003

Eastem Band of Cherokee Letter (ML092860591)

Indians

U.S. Fish and Wildlife Service Letter (ML092930182)

Meigs County Meeting Transcript (ML092870338)

Meeting Transcript (ML092870338)

Meeting Transcript (ML092870331)

September 2011 D-1 Draft NUREG-0498, Supplement 2
Appendix D

McCluney, Ross

Paddock, Brian

Reynolds, Bill

Reynolds, Bill

Safer, Don

Safer, Don

Smith, Stewart

Yager, Ken

Zeller, Lou

Zeller, Lou

BREDL

Sierra Club, Tennessee

Chapter

Meeting Transcript (ML092870331)

Meeting Transcript (ML092870331)

Meeting Transcript (ML092870331)

Meeting Transcript (ML092870338)

Email (ML09306031 1)

Meeting Transcript (ML092870331)

Meeting Transcript (ML092870338)

Tennessee Senatorial District Letter (ML093090655)

12

Blue Ridge Environmental Letter (ML093080360)

Defense League

Blue Ridge Environmental Meeting Transcript (ML092870331)

Defense League

0003

0003

0003

0004

0013

0003

0004

0007

0015

0003

Draft NUREG-0498, Supplement 2 D-2 September 2011
Cn CD>

CD Table A-2 (D Cr 

"D Category No. 1

X

Public Comments that are Covered in the Supplemental Final Environmental Statement

(SFES) (Equivalent to an EIS)

Comment: The Organizations [Southern Alliance for Clean Energy, the Sierra Club, Blue Ridge Environmental Defense League,

Tennessee Environmental Council, and We the People] respectfully submit that the EIS should consider, at a minimum, the

environmental concerns raised in their hearing request to the NRC, which is now pending before the Atomic Safety and Licensing

Board. (0010 [Curran, Diane])

Response: When preparing the SFES, the NRC staff will consider concerns expressed by commenter's that are within the scope of

the environmental review.

Comment: Given all those concerns and the fact that things have certainly changed since 1978, when the first Environmental

Impact Statement was done and those supplements in 1995, I think NRC should recommend to TVA that they start all over with a

new, from ground zero, Environmental Impact Statement. (0004 [Kurtz, Sandy])

Comment: The National Environmental Policy Act requires that before undertaking a major federal action, an agency must take a

"hard look" at the environmental consequences of the action (Baltimore Gas and Elec. Co. v. Natural Resources Defense Council,

Inc., 462 U.S. 87, 97 (1983)). Where an agency has not yet taken the major federal action, it must consider "new and significant

information" that bears on the environmental impacts of the proposed action [Marsh v. Oregon Natural Resources Council, 490 U.S.

360, 371-72(1989)]. Also, federal regulations require supplementation where the proposed action has not been completed, if: "(1)

there are substantial changes in the proposed action that are relevant to environmental concerns; or (2) there are significant new

circumstances or information relevant to environmental concerns and bearing on the proposed action or its impacts." [10

C.F.R. 51.92(a)] The environmental effects of the two side-by-side Watts Bar facilities raise the issues of segmentation and

Ocumulative impacts. (0015 [Zeller, Lou])

z Response: The commission expects the staff to take the requisite "hard look" at new information on the need for power and

C alternative sources of energy and has authorized the staff to supplement the SFES if there is new and significant information relevant

X M to these matters. The NRC staff will prepare the SFES in accordance with NEPA and 10 CFR Part 51. The analysis will address the

O environmental effects of operating the proposed WBN Unit 2.

Z6

(0

9o Comment: I am really concerned about the water quality in the Tennessee River, and I think that as TVA goes forward with this

(D(93

(D

N)v
0= -c

CD z Environmental Impact Statement, they are going to be required to take a hard look at the new information on water quality, C discharges of heavy metals, and serious long-term consequences from the Kingston coal ash spill. (0003 [Mastin, Mary]) " rn

G) Comment: Please, as you go forward with the environmental work on this, consider the water quality and the new information - 1

6 mean, not only is there - are there sediments on the bottom where the Clinch River comes into TVA, coming down from Oak Ridge,

(there apparently is some other stuff from some old paper mill or lumbering operations; there has been a huge concern about doing -9 that very carefully. (0003 [Mastin, Mary])

C

a Response: Operating a nuclear plant involves discharging some effluents to nearby water bodies. The Clean Water Act designated CD the U.S. Environmental Protection Agency (EPA) as the Federal agency responsible for regulating effluent discharges to the Nation's 3

CD waters. Although the NRC does not regulate effluents, it is responsible under NEPA to assess and disclose the expected impacts of

the proposed action on water quality throughout the plant's life. The staff will assess water quality issues related to operating the

proposed WBN Unit 2. Chapter 4 of the SFES will present the NRC staffs assessment of the nonradiological impacts to water

quality. Chapter 4 will also address any cumulative effects of the proposed action.

Comment: There's a whole lot of assumptions about what's a normal condition in the river and what's a normal year, and I think if

you've noticed, the last decade we've seen increasing changes, perhaps due to climate change, where the definition of what's normal

needs to be re-examined. (0003 [Paddock, Brian])

Comment: Operating Watts Bar I nuclear plant requires 188.2 million gallons per day of water drawn from the river. Each day, of

that amount, 14.3 million gallons is evaporated into the air, not returned to the river. Yet another reactor, a second reactor here,

drawing out so much water causes me to ask how much can we draw out of the river on any given day in the same reservoir. (0004

[Kurtz, Sandy])

Comment: The Tennessee River is already overstressed and does not need additional warm water discharge and water lost from

evaporative cooling. (0008 [Gottfried, Yolande])

Response: Nuclear plants consume water due to the evaporation of some of the water used to cool plant components. The NRC

staff will address the impact of consumptive water losses on the sustainability of local and regional water resources. Although the

NRC does not regulate or manage water resources, it is responsible, under NEPA, to assess and disclose the impacts of the

proposed action on water resources. Chapter 4 of the SFES will assess impacts on water resource sustainability related to operating

the proposed W"N Unit 2

Comment: The second point in the scope of the environmental assessment is that there's an interaction here, because the State of

o(n Tennessee has just released the draft NPDES, National Pollution Discharge Elimination System, permit for the Watts Bar nuclear

CD

3

a.

(D

c1
(nCD, co >

3 (D plant. That seems to be talking just about Unit 1, '(but in fact the way TDEC has written the draft permit, it's not clear if you could turn

a- the switch on Watts Bar 2 if it were ready and use that same permit. And there are a number of defects and concerns specifically with -. that permit. We're going to talking with TDEC about this, and the time for public comment has been extended, so that permit is " probably not going to be coming down the road until early next year, at the best, but here are some of the difficulties: And we're 0

assuming -- and I think TVA asserts this in their comments on the NPDES -- that the phase 2 regulations don't apply here; that the

content of this permit under Section 316 is remitted to TDEC in terms of its best professional judgment. That could change if EPA

puts the phase 2 regulations back into effect following the most recent Supreme Court decision. But right now it's up to TDEC, and

there are limitations in both the Clean Water Act and in the state regulations. One of the main problems is that most of the

environmental information that TVA brought to TDEC for the renewal and extension of the NPDES for the nuclear plant basically was

ten and twelve years old. (0003 [Paddock, Brian])

Response: The NRC staff will discuss current surface water quality in Chapter 2 of the SFES and impacts from operating the

proposed WBN Unit 2 in Chapter 4. TVA has indicated in its application that the discharge from WBN Units I and 2 will meet

discharge limits stated in the current National Pollutant Discharge Elimination System (NPDES) permit. The NRC staff will consider

discharge limits in its evaluation of impacts on the Tennessee River.

Comment: There is, we think right now, a clear failure of TVA with respect to the NPDES, and we think if they were held to this in

the FEIS for the additional thermal impacts from Watts Bar 2, that they simply have not been able to show that they won't violate the

water quality criteria. They don't provide data on the drift community, the spacial or temporal distribution of the plankton in the mixing

zones. The mixing zones, by the way, according to the diagram, as I read it -- and I admittedly am no expert on this - seem to be

substantially larger. And by the way, the initial mixing zone in the renewed permit that's proposed actually goes border to border in

the river. There is no way for aquatic life to go down the river without being in either what essentially is a dead zone immediately next

to the discharges or on the cooler but active side of the river where they would have impacts. (0003 [Paddock, Brian])

Response: The NRC staff will consider water quality impacts from operating the proposed WBN Unit 2 on the Tennessee River,

including the effects of thermal discharge on aquatic life. Chapter 4 of the SFES will present results of this analysis.

2Comment: As was mentioned earlier, you now have operating six nuclear plants plus one thermal plant on the same river system,

and you're now about to add a seventh, and the cumulative impacts of this amount of cooling water, cooling water loss from

c evaporation, thermal -- cumulative thermal effects and so forth, needs to be looked at. TVA has already experienced the situation

m

Xo where, during summer peaks, it had to derate downstream nuclear plants. Building another one toward the top of the river system,

1O when it simply, as a consequence of the thermal discharge, will then have to shut down the plants lower on the river system during 6 the hottest times of the peak loads, is not going to make any sense at all. So TVA may have run out of running room in terms of

(D thermal discharges. Let's identify that now before we go ahead and license this plant. In fact, let's make sure that we do it in such a

Po way that those of us who are ratepayers don't wind up for another white elephant that's never licensed to operate. (0003 [Paddock,

C

3

CD

Z',
-,- V

Z Brian])

C: . Xn Response: Chapter 4 of the SFES will address consumptive use and water quality impacts on the Tennessee River, including the

G thermal impacts of discharge to the Tennessee River, from operating the proposed WVBN Unit 2. Chapter 4 also will present

6 cumulative impacts to the Tennessee River from operating WBN Units 1 and 2 and other facilities.

9o

C', Comment: The Tennessee River is stressed already - the quality of the river. It has fish that are not safe to eat. There is the impact

of the Kingston toxic fly ash spill which must be taken into consideration when assessing water quality, because we all live

(D downstream. (0004 [Kurtz, Sandy]) 3

CD=Response: Chapter 4 of the SFES will address impacts on Tennessee River water quality from operating the proposed WBN Unit

12. Chapter 4 also will present cumulative impacts to the Tennessee River from operating WBN Units 1 and 2 and other facilities.

Comment: I am very afraid that we are killing the aquatic life in the Tennessee River and that the thermal discharges from Watts

Bar 1, Watts Bar 2, then you go down to Nickajack or Sequoyah, and Nickajack, you start up there where Oak Ridge - there are still

sediments with radionuclides - I don't know the technical language on this, but I know that TDEC and EPA and TVA have been very

concerned about the dredging as they are trying to clean up the Kingston coal ash spill and not getting down to the bottom and

stirring up all of this really terrible stuff that's there. (0003 [Mastin, Mary])

Comment: I'm working with scientists who have talked to us about the discharges from selenium; you got arsenic and mercury; you

got heavy metals; you've got fragile fish; you've got mollusks. You have got a whole downstream river system and people who are

dependent on your doing this with a great amount of care. (0003 [Mastin, Mary])

Response: The NRC staff will address the cumulative impact on the aquatic biota in the Tennessee River in Chapter 4 of the

SFES. The staff will consider thermal discharges from facilities, including WBN Unit 1, Sequoyah Nuclear Plant, and Kingston Fossil

Plant, as part of the cumulative impact analysis. The staff also will discuss water quality issues related to radionuclides and heavy

metals that exist in river sediments as a result of past operations at Oak Ridge, and the Kingston coal ash spill and subsequent

cleanup activities.

Comment: There are a lot of questions with respect to the mortality of mussels downstream, even though TVA has spent a good

deal of effort over the years relocating mussels. I'm not sure when we started rebuilding natural populations in different places in

order to allow this kind of project to go forward, but it seems to me that the impact on mussels and the impact of mussel relocation

needs to be documented currently. (0003 [Paddock, Brian]) cn

CD

CD3

CD

C,

o
Cn

_0 -0

(D CD -0"D 3 (

0- Response: The NRC staff will assess the impacts of operating the proposed WBN Unit 2 on the aquatic biota in the Chickamauga

Reservoir including any plans for future relocation of mussels and impacts from relocation. Chapter 4 of the SFES will address x

impacts on aquatic biota from operating the proposed WBN Unit 2. o

Comment: The temperature of the water returned is hotter, not good for aquatic life, and in droughts it can't be cooled enough and

so has to be shut down, just as has happened summer before last, I think it was. (0004 [Kurtz, Sandy])

Response: Chapter 4 of the SFES will address impacts on the aquatic biota in the Chickamauga Reservoir from thermal discharges

from the proposed WBN Unit 2.

Comment: So the point I'd like to make in response to my enormous sympathy to the economic problems of the area, and the

mention of jobs in solid-state and other areas, is that renewable energy is a really labor-intensive operation, so that your intensive

worker group that comes in to build the nuclear power plant, usually from outside the region, most of those leave when the plant is

built, and a moderately small task force remains. Whereas if you instead focused on attracting some of this new technology

development and factories, you could build up this region enormously, building and making environmentally benign technology to

provide what electricity is needed. (0003 [McCluney, Ross])

Comment: Our unemployment rate in Monroe County right now is over 16 percent, so we would like to see jobs from that plant as it is being constructed and then once it's completed. (0003 [Burris, Shane])

Comment: Also, if they run out of money, there are provisions in the technical specifications to shut the plants down and put them in

a safe condition so the public is not threatened. That being said, I really admire Mr. Burris for the comments he made about the

economic impact this will have on our area, but I can tell you that the Nuclear Regulatory Commission does not have compassion at

the level that they're really concerned about jobs. (0003 [Cobb, Jim])

0Comment: So anyway, the green economy is how we're going to get back, and part of that green economy is to learn how to

reintegrate our rural areas, our smaller towns with our urban centers and create the - you know, in Nashville people are nuts about xlocal produce. There's a whole industry of local growers that is growing up all around Nashville, and people are making a living at it. Z It's hard work; it's honest work. You get your fingernails dirty, but it's just an old-fashioned way to do it. And, you know, getting back

to more locally based economies with an eye toward creating jobs in our rural counties is definitely something that we need to do, but

m

r these nuclear plants don't create very many jobs after construction. (0003 [Safer, Don])

"AL 4.O Comment: The project will generate thousands of jobs during construction period and 250 permanent jobs in a region characterized

9D by double digit unemployment. (0007 [Yager, Ken]) I

C

3(D
o= 0>

xv CD z "0M

C Response: Chapter 4 of the SFES will address regional socioeconomic impacts of the proposed action, including impacts to the

m local economy, employment, transportation, aesthetics and recreation, housing, education, community infrastructure, and social 0

O, services.

6

PO Comment: [A]s an economic developer in the state of Tennessee, most economic developers know that the United States and the

state of Tennessee's manufacturing base runs on cheap power. And if your cap and trade bill passes in Congress, the electric bill will -_ go up about 300 percent, and also that will end manufacturing in this country as we know it, and we will only be one mass distribution

C " center. (0003 [Burris, Shane]) 3

CD Comment: Our community is suffering economically, and it's important for future economic development and the future health of our

community that we have reliable -- cheap, reliable power so that we can continue to bring industry in to this community. (0004 [Smith,

Stewart])

Response: The price of electricity is outside the regulatory scope of licensing actions; however, the NRC staff will evaluate the

regional socioeconomic impacts of the proposed action in Chapter 4 of the SFES, including impacts to the local economy,

transportation, aesthetics and recreation, housing, education, community infrastructure, and social services.

Comment: The Tribal Historic Preservation Office of the Eastern Band of Cherokee Indians is in receipt of the notification to act as a

consulting party for the above-referenced project information and would like to thank you for the opportunity to comment on this

proposed Section 106 activity. The EBCI THPO accepts the invitation to act as a consulting party on the above referenced Section

106 undertaking(s) as mandated under 36 C.F.R. 800. (0006 [Howe, Tyler])

Comment: The project's location is within the aboriginal territory of the Cherokee People. Potential cultural resources important to

the Cherokee people may be threatened due to adverse effects expected from the level of ground disturbance required for this

project. (0006 [Howe, Tyler])

Comment: Please send all related archaeological, cultural resource and historical investigatory materials, completed by the

applicant to this office for review so we can make proper comments that pertain to accomplishing our NHPA requirements. (0006

[Howe, Tyler])

Response: As outlined in 36 CFR 800.8, "Coordination with the National Environmental Policy Act of 1969," and Section 106 of the

National Historic Preservation Act of 1966, as amended (NHPA), the NRC will fulfill the requirements of NEPA and NHPA by

consulting with and requesting input from the Eastern Band of Cherokee Indians. Chapters 2 and 4 of the SFES will provide historic

(n and cultural resources information. The NRC will consult with the Eastern Band of Cherokee Indians to identify cultural resources (D

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Comment: Talking about a community, I don't see you taking this up to Farragut and putting the nuclear plant in the middle of

Farragut, where the houses all cost like $750,000 or 2 or 3 million. (0004 [Harris, Ann])

Response: Chapter 4 of the SFES will specifically address potential impacts of the proposed action on low income and minority

populations.

Comment: Nuclear plants do have radioactive leaks into the water, which they say is insignificant, but since radiation is cumulative,

how much is too much for humans and other life to absorb without health impacts? (0004 [Kurtz, Sandy])

Comment: The sources of the contamination include leaks from pipes and vales and other water-bearing components and airborne

discharges from cooling towers. These radioactive discharges are difficult to quantify and may be underestimated. (0015 [Zeller, Lou])

Response: The NRC staff will evaluate the.release of radioactive materials into the environment from WBN Units I and 2. Chapter

4 of the SFES will address the cumulative impacts from releases of radioactive effluents from WBN Units 1 and 2.

Comment: I think as - since this reactor was proposed in the '60s, designed in the - or licensed in the '70s, we had a lot of

opportunity to have all these nuclear plants that have been operating. And I haven't seen any public health studies about the

communities that are downwind, you know, with the windrows of where the wind blows, and if it's true that nobody is getting sick, that

their cancer rates and leukemia rates are not elevated, wonderful; I would love to see it. But I haven't seen it. I've looked for it. It's not

easy to find. I think in this Environmental Impact Statement we need to have a clear study of Watts Bar 1; Sequoyah, the two units,

and -- well, in particular those three, because they're the same design of reactor. (0003 [Safer, Don])

Comment: I read of a study completed in Germany. Since 1991 in fact they have done several studies in Europe regarding the

health of children who live within ten miles of nuclear facilities, primarily in England and Wales. And what they found out was that

5there was a statistically significant increased incident rate - I want to say that right, because these are studies - significant increased

z incident rate for leukemia's among children within the five-kilometer zones around the sites. That is, the closer -- and it seemed that

C: the closer you got to the plant, the more - the higher the incidence. This is of great concern and I think should be looked into before

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Csomehow unaware of that. We have children in Meigs County -- I have a son that grew up in Meigs County, went to high school in

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Go Comment: I was born and raised in Meigs County, but I won't live there anymore. There's more to radiation exposure than cancer,

6 and there's a lot of it. (0004 [Harris, Ann])

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Response: These comments refer to health effects to populations around nuclear power plants. The NRC's primary mission is to

Cn protect the public health and safety and the environment from the effects of radiation from nuclear reactors, materials, and waste

v.- facilities. The NRC's regulatory limits for radiation protection are set to protect workers and the public from the harmful health effects

-D of radiation on humans. The limits are based on the recommendations of standards-setting organizations. Radiation standards

3 reflect extensive scientific study by national and international organizations. The NRC has reviewed a number of studies that looked

CD at the incidence of cancers in the vicinity of nuclear power plants in the United States. The studies did not observe a correlation

between the radiation dose from nuclear power facilities and cancer incidence in the general public. Some studies the NRC

recognized include those conducted by the following organizations: the National Cancer Institute, the University of Pittsburgh, the

Illinois Public Health Department, the Connecticut Academy of Sciences and Engineering, the American Cancer Society, and the

Florida Bureau of Environmental Epidemiology. Chapter 4 of the SFES will evaluate the impacts to human health from radioactive

emissions.

Comment: You don't have - there's no water testing in this river of radionuclides by an outside source. That's according to TDEC's

own mouth. That's not my opinion. They trust WVA. Well, we trusted TVA up at Kingston. There's tritium in the soil and the water,

o above legal limits. It's sitting there, and nobody's doing anything about it; you're just pumping more. And this idea that tritium won't

hurt you -- why do we use it to make bombs go off faster than what they did when just a normal bomb? There's no wastewater

program to stop the radionuctides going into the Chattanooga and others' drinking water. (0003 [Harris, Ann])

Comment: There is also - there is radiation already in the river sediment, and another nuclear reactor will only add more. Nuclear

plants put radionuclides in the water that no one tests for. (0004 [Kurtz, Sandy])

Comment: The NRC - when you go to the website, look up the word tritium, and you go down through there, and you go and see

what all the things are. There's a statement there - it's very short; I think it's got - I'll count them in a minute - like a dozen words in

the statement. The NRC does not believe that there's any safe level of exposure to radiation. (0004 [Harris, Ann])

Comment: We respectfully submit that the EIS should consider the issue of tritium releases into the Tennessee River by the

proposed reactor. (0013 [Safer, Don])

Comment: Nuclear power plants generate tritium in the course of their operation and release it both to the atmosphere and to water

(n bodies. Tritium releases have also occurred as a result of malfunctions. (0013 [Safer, Don]) V

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-, can cross the placenta, posing some risk of birth defects and early pregnancy failures. Ingestion of tritiated water also increases ' Co cancer risk. (0013 [Safer, Don]) 0

Comment: Tritium releases generally constitute the largest routine releases from nuclear power plants and as such have caused

widespread contamination of water bodies at low-levels. (0013 [Safer, Don])

Comment: All of this is particularly relevant to public health issues considering the widespread usage of the water from the

Tennessee River especially as the municipal drinking water supply downstream in Chattanooga. (0013 [Safer, Don])

Comment: The NRC must include in its SEIS the impacts of tritium emissions from both Watts Bar Unit I and Unit 2 upon the

environment and public health. (0015 [Zeller, Lou])

Comment: Tritium releases are the largest routine radioactive emissions from nuclear power plants. The chemical compound H20

with a radioactive H3 (Tritium) is virtually impossible to contain because nuclear plants are thermoelectric units which rely upon the

heating of water to drive steam turbine-powered electric generators. (0013 [Safer, Don])

Comment: Nuclear power plants contaminate the water bodies used for cooling water. Watts Bar Unit 2, like Unit 1, would be cooled

by cooling towers drawing makeup water from Chickamauga Reservoir. The contamination of the area surrounding Watts Bar is as

follows [Annie Makhijani and Arjun Makhijani, Science for Democratic Action Vol. 16, No. 1, August 2009 (Sources by plant from -Annual Radiological Environmental Operating Reports for 2006. Sourcelink at http:/Iwww.nrc.govlreactors/operatinglopsexperience/tdtiumlplant-info.html)]:

Drinking water Surface Water

Picocuries per liter 606 588

These levels of tritium contamination of drinking water and the river are found 24 and 9.9 miles from the Watts Bar reactor,

respectively. They are excessive and harmful to human health. (0015 [Zeller, Lou])

Comment: That tritium emissions are released to the environment is well known and even acknowledged in NRC "lessons learned" z documents. At minimum, the NRC must account for these releases in its EIS. Further, the agency should undertake a top to bottom

C: review of its monitoring and control of tritium emissions. (0015 [Zeller, Lou]) m

9 Response: The NRC staff will review and evaluate the monitoring for radionuclides in the environs around the WBN plant and the

Tennessee River. Chapters 2 and 5 of the SFES will address radiological monitoring of all pathways, including water. Chapter 5 also

90 will discuss tritium monitoring at the WBN site. Chapter 4 will present results from the radiological monitoring and any potential

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G Comment: Tennessee Valley Authority is irradiating Tritium-Producing Burnable Absorber Rods (TPBARs) for the U.S. Department

6 P% of Energy (DOE). The production of radioactive tritium for defense purposes is authorized by License Amendment No. 48 issued

October 8, 2003. However, the tests conducted during the sixth cycle of irradiation revealed disturbingly high levels of tritium to the

reactor coolant system outside of acceptable limits; in fact, the emissions were 9.6 times higher than predicted by iVA's analytical C/) model. (0015 [Zeller, Lou])

Comment: The questions which NRC must address are: (1) How were predictions by TVA and DOE nearly an order of magnitude

3 too low? (2) What was the impact upon the local environment caused by the unexpected excess before it was discovered? (3) What (D

eare the implications for Watts Bar Unit 2? (4) What evidence do we have that TVA's predictive analysis is now reliable? (0015 [Zeller,

rN Lou])

Response: This comment is related to tritium production from WBN Unit 1 and is not within the scope of the environmental review

for the proposed WBN Uni 2. However, the cumulative impacts from the releases (including tritium) from WBN Unit 1 will be

considered and addressed in Chapter 4 of the SFES.

Comment: And the situation, as I understand it, in the environmental assessment that's being done right now is that indefinite on-

,.% site retention of spent fuel is proposed. So I hope you folks locally are prepared to take care of this stuff for at least a quarter of a

Nmillion years, because with respect to spent fuel, it's pretty clear that Yucca Mountain is dead. I'm not sure exactly the state of the

post mortem and rites, but it appears that the federal government is not going to invest more in the development of that site, and no

other site has as yet been suggested even as a possible target. (0003 [Paddock, Brian])

Comment: TVA, of course, has no right, even if Yucca Mountain were to open, to send the waste from Watts Bar 2, as I understand

it, to that repository, even if it were to open, and it simply has, as far as I can see, no real plan other than just keep stacking it up

locally. (0003 [Paddock, Brian])

Comment: I'm going to start by going into the storage casks - the spent-fuel storage casks that are being placed by the river right

now. They're going to be placed there with greater frequency if this second plant goes on line. (0003 [Safer, Don])

Comment: I think it's important to know that inside of those casks the radiation is far worse than what went in. The radionuclides in

there, there's plutonium, which didn't even exist on the face of the earth until we started fooling with the atom 60, 70 years ago, and

that's one of the most awful substances on the face of the earth. It is bomb-making material, but one atom of that that gets into your

lungs, if it gets airborne, will give you lung cancer; it will kill you. It burns on contact with the air, spontaneously. It's sitting in there.

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-•J plutonium to make it work, you've got to create a lot of other waste. But inside of there is just this cauldron of about 500 degrees -- it's

C) too hot at the beginning, for the first five years, to put these fuels rods into these dry casks; they haveto be put into the storage

pools, which are overloaded currently and have had to be modified because of the lack of any real storage solution. And then after

five years they go into these concrete-steel dry cask storage that are not hardened, and they are out - I've seen them at Browns

Ferry; they are just out in the open. (0003 [Safer, Don])

Comment: [I]n those casks, that cauldron of 500-degree Fahrenheit radioactive material that's 1000 or 100,000 times more

radioactive than the original fuel rods is doing who knows what. I mean, I asked - I've forgotten your name, but I asked three

gentlemen from the NRC earlier today, in private, or in a conversation at the open house, What's going on inside of those casks? Has

anybody taken one of those apart after ten years? To my knowledge, nobody has, and what I've heard is that it's all sort of, you

know, just kind of decomposing. Nothing stays the same. You put it in there, and its 500 degrees of boiling radioactive science

experiment. And they were supposed to last for about or 30 years at first; now they're saying, well, they'll go for 50 and probably a

hundred. Well, it's your community here that is the guinea pig on this, as well as the community at every other nuclear reactor site,

because that's what's happening with all of these; there's no plan at all to move them away from your community, and these things,

as Mr. Paddock said, they remain toxic for literally several hundred thousand years. (0003 [Safer, Don])

Comment: [T]hey [nuclear plants] leave these legacy of these storage casks that our grandchildren, our great-grandchildren and

those beyond that will not remember us will curse us for those storage casks.

Comment: [T]here is the storage of radioactive waste and the legacy it leaves for the future; there is no solution now, and we hear

people say, We're going to figure it out. They've been working on it for a long time, and so far we actually seem to be going

backwards. Yucca Mountain is closed and, in fact, if it were open, it would be immediately filled up, as I have heard, because we've

already stored enough to fill it up. Where does our radioactive waste go? (0003 [Safer, Don])

Comment: Somehow somebody's got to start stopping and looking, because you haven't dealt with the waste. (0004 [Harris, Ann])

Comment: There is still no solution to the problem of storing nuclear waste. (0008 [Gottfried, Yolande])

Response: The NRC evaluated the safety and environmental effects of long-term storage of spent fuel and, as set forth in the

z Waste Confidence Rule at 10 CFR 51.23 (available at http:/Awww.nrc.gov/reading-rm/doc-collectionslcfrlpartO5l/partO51-0023.html),

the NRC generically determined that "if necessary, spent fuel generated in any reactor can be stored safely and without significant m

G) environmental impacts for at least 30 years beyond the licensed life for operation (which may include the term of a revised or

6 renewed license) of that reactor at its spent fuel storage basin or at either onsite or offsite independent spent fuel

(0 installations. Further, the Commission believes there is reasonable assurance that at least one mined geologic repository will be

90 available within the first quarter of the twenty-first century and sufficient repository capacity will be available within 30 years beyond C,,

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c reactor and generated up to that time." On October 9, 2008, the NRC published for public comment a proposal to amend its generic Xo determination of no significant environmental impact for the temporary storage of spent fuel after cessation of reactor operation X

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G) codified at 10 CFR 51.23(a) (73 FR 59547) and a related update and proposed revision of its 1990 Waste Confidence Decision (73

o FR 59551). Chapter 4 of the SFES will address the impact of the uranium fuel cycle, including disposal of low level radioactive waste

(o and spent fuel.

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Comment: And some people have said that the electricity you get from the nuclear reactor is not really the primary component or

CD the primary outcome; it's really all this nuclear waste, because the electricity you generate, we use it or we don't, and it's gone. (0003 3 CEi) (Safer, Don])

rResponse: According to 10 CFR 51.95(b), the SFES, which is a supplement to the FES-OL, will only cover matters regarding

radioactive waste material (low-level, high-level, and transuranic wastes) that differ from the FES-OL or provide significant new

information concerning issues discussed in the FES-OL. Chapter 4 of the SFES will discuss issues related to radioactive waste

management.

Comment: [T]he Watts Bar Lake area already is highly polluted, particularly at the junction with the Clinch River and is already a

designated Superfund site. And I have not had a chance to review the documents, but it's not clear to me that the -- what happened -

- if there's any mobilization of those upstream legacy sediments from that Superfund site and moving down into the cooling-water -• intakes for this plant. The same thing is true with respect to the coal ash spill, because we've already seen the coal ash migrate

during high-water events. They now they're going to get it out of there by - worst of it out of there by next year, but they also say

there won't even be the phase 2's plan for getting some of the rest of it cleaned up until next year. To the extent that those heavy

metals are in solution, are in compounds and can travel freely with the flow of the river, you essentially have a different condition in

the river at the point that you hit the cooling-water intakes, and we're not sure that the environmental assessment at this point has

recognized that condition and has looked at the consequences of having heavy metals in solution in larger proportions at the point of

intake and discharge from the cooling water. (0003 [Paddock, Brian])

Comment: These proposed [tritium] releases should be considered as an addition to the existing releases from Watts Bar Unit 1

which have been increased by the production of weapons grade tritium for the DOE. (0013 [Safer, Don])

Comment: The requirements of NEPA may not be avoided by segmentation of a project [River v. Richmond Metropolitan Authority,

481 F.2d 1280 (4th Cir. 1973)]. Segmentation arises when the comprehensive environmental impact of a project is not given full

consideration or that analysis of the impact is done after permitting agency decisions are made and the project is underway [Daniel

R. Mandelker, NEPA Law and Litigation, 9-25 (2nd ed. 2004)]. The principal criteria for the determination segmentation are whether

Dthe parts of a project are interdependent, the original intent and whether the parts may be considered alone. Watts Bar Units 1 and 2

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o- significantly greater impacts when viewed with other actions or which have increasing effect caused by successive additions. Council

of Environmental Quality Regulations Implementing NEPA [Sec. 1508.7 Cumulative impact. "Cumulative impact" is the impact on the X

or° environment which results from the incremental impact of the action when added to other past, present, and reasonably foreseeable 0

future actions regardless of what agency (Federal or non-Federal) or person undertakes such other actions. Cumulative impacts can

result from individually minor but collectively significant actions taking place over a period of time provided that reasonably foreseeable future actions are to be considered in a cumulative impact analysis. The consecutive licensing of Watts Bar Units 1 and

2 in close proximity are actions which are plainly foreseeable. Therefore, NRC must account for the combined impact of Watts Bar

Units 1 and 2 in its EIS. (0015 [Zeller, Lou])

Response: The NRC staff determines cumulative impacts by evaluating results from the proposed action in combination with other

past, present and reasonably foreseeable actions, regardless of who takes the actions. The NRC staff will evaluate cumulative

impacts associated with operating the proposed WBN Unit 2 for each affected resource. Chapter 4 of the SFES will present the

results of cumulative impact analyses.

Comment: So my concern is that there are lots of moves afoot to reduce our needs for electricity in the Tennessee Valley and

around the country that aren't really addressed in TVA's Environmental Impact Statements, that I've been able to find. In particular, I'll

refer to sections relating to alternatives, alternatives to building the plant. And sometimes TVA will put a little bit in about that, in other

cases, so I searched the most recent Environmental Impact Statement prior to this meeting, and what I found was a statement that

referred back to that 1995 - December 1995 earlier Environmental Impact Statement for finding something about alternatives. (0003 (A [McCluney, Ross])

Comment: We don't know -- because I couldn't find that document - whether those alternatives were just alternatives to the design

of the plant, alternatives to mitigate environment impact, or whether it actually included alternative power sources or other options for

reducing the need for the plant in the first place. So I believe TVA is fairly deficient in that area. Even if the 1995 report addresses the

subject, a whole lot has happened since then, in 14 years. There's been an enormous amount of research, development, and

promulgation of energy-efficient technology and renewable energy choices. It doesn't take a particularly astute observer to know

0about a lot of this. If you watch TV, and especially if you go to the science channels - Discovery, National Geographic, and these

channels - if you read the paper, read magazines, you'll see about this, because everybody's excited about these relatively pollution- free or somewhat benign alternatives -- energy alternatives. (0003 [McCluney, Ross]) Z

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:;o Comment: Millions and even billions of private money have been spent to explore, develop and actually commercialize an

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lG) enormous variety of technologies we still don't know too much about unless you really dig in. A good - some good searches on the

61 internet will reveal a lot of this technology, a lot more about it, and yet we see nothing about this in TVA's reports. So the question is, (" Do they fail to include it because they've already decided, years ago, that solar can't work here, or whatever decision they make, and

9o I so because they made that decision -- and if we trace it back, we may have to go back to the original - I fear we have to go back to

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c and there was nothing there. So I fear that the really viable alternatives in renewable energy and energy efficiency have not been

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addressed and therefore the decision could be one based on inadequate information that will endanger the public. (0003 [McCluney,

0 Ross])

6

=co Comment: But even if the demand is lower, that doesn't mean they won't have to build new plants, because hopefully they'll be

90 taking out of operation all those dirty coal plants, and so they'll need to replace some of those, and I admit that. But I'd hate to see it

(n C with nuclear, when abundant natural energy is available from the sun and from other sources, outside this region, with long distance

transport of energy as well as within this region, and yet TVA is silent on this. So what I urge the Nuclear Regulatory Commission to

CD do is insist that, before they give any permit to this Unit 2, that TVA do a truly comprehensive study of these other alternatives:

3 improved energy efficiency and renewable energy development. (0003 [McCluney, Ross]) (D

Comment: They [TVA] can put the solar systems out and lease the rooftops of customers in a whole new mode of power plant production which is called distributed energy. The beauty of distributed energy is they're relatively small; they're distributed over the

region. They're not terror-susceptible, because you want to take out the power in the region? How many rooftops do you have to go

and knock out in order to have an event? So distributed power has an inherently higher security factor to it. And the utility can

participate; in fact, it already is, in very tiny, little minuscule power programs, where the homeowner pays to put the solar power on

their roof, and then the utility pays them a double price for the electricity that's generated. So I think if they could look at that model

more, look at these new technologies, including battery storage - battery storage is amazing; I thought it was the unsolvable

problem, because solar power, we know, is intermittent, and therefore we need a way to store electricity or some other form that can

11 be turned into electricity and then produce it where it's needed. WVA has a facility for that near my home in Chattanooga; it's pump o) storage on the top of a mountain, and then they pull the water down when the need the power at peak periods. So there are options

available, and so I urge NRC to insist that TVA do this truly comprehensive study. If they do that, I suspect that what WVA will

discover is they can withdraw their application for this new plant. (0003 [McCluney, Ross])

Comment: But one of the things I think WVA should be held to respond to in its environmental assessment is how poor its energy efficiency and conservation programs are. And I say that with respect to the staff who I've sat with a number of times and discussed

with them the activities that they're rolling out, including the home energy audits and retrofits and so forth, and with respect to the

State of Tennessee, which is going to I think not only get on board with solar generation but is going to join the national effort to

invigorate the purchase of Energy Star appliances. Unfortunately, WVA, in its approach to energy efficiency and conservation, has

made a number of missteps. If you'll remember the strategic plan, the first thing it did was to fail to have a target even for efficiency

and conservation. After a good deal of public debate and lobbying, it put in, I believe, a 1400-megawatt cumulative demand reduction

target, and as it has carried that out, by limiting its instructions to its consultants, the reports of which have not been released to the

public on energy efficiency and conservation and the limited results that have probably come if you tell them only to look at a very

narrow slice of the issue, is that you now have programs that really go to peak shaving only. There has been no effort really to

engage with reducing baseload demand, and clearly the Watts Bar 2 plant is about baseload demand, not just about peaks. And it g) seems to me that as part of the environmental assessment, TVA should be made to explain why it does not expect the baseload

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objective point of view about nuclear energy and went through to the completion of entirely comprehensive studies and assessments

Cr and found the opposite to that claim to be true. The folks who have done these studies are high experts in the fields of energy -3

production technologies and the economics of operating these technologies. They know what they're talking about, and their studies X

C)• have been thorough. The Institute of Energy and Environmental Research is a primary and star example, and this book that they've produced contains excellent documentation of the massive data and analysis that supports the view that alternative sources to both

coal-burning and nuclear power can meet our future energy needs. The scope of NRC's Environmental Impact Statement for Watts

Bar 2 should therefore include full attention to and genuine consideration of what's in this report, and don't expect it to be an easy

read; it's highly technical and deep; but also in addition to this report, the other comprehensive studies that have been done. (0004

[Reynolds, Bill])

Comment In particular, in looking at these other studies that started out objective and neutral about nuclear energy, they should

look at - in the EIS process, they ought to look first at the real-world potential for renewals and implementation of more efficient enduse energy practices and conservation to displace the need for a Watts Bar 2. That would be component of a responsible and honest

Environmental Impact Statement about the proposed licensing Watts Bar 2. (0004 [Reynolds, Bill])

Comment: Secondly, in particular this EIS should fully assess the comparative financial cost of Watts Bar 2 - capital cost and

operating cost over the life of the plant - in contrast to those same costs from meeting future energy needs while protecting

environmental health and climate stability through applications of renewable resources and proved efficiencies in end-use energy use

and conservation. (0004 [Reynolds, Bill])

0

Comment: The money would be better spent on less dangerous alternative energy technologies and energy conservation. (0008

"4 [Gottfried, Yolande])

Response: The commission expects the staff to take the requisite ahard look" at new information on the need for power and

alternative sources of energy and has authorized the staff to supplement the SFES if there is new and significant information relevant

to these matters. Alternative energy sources, including energy-efficiency programs, conservation, and renewable energy sources, will

be considered and discussed in the SFES.

Comment Information available to the Service does not indicate that wetlands exist in the vicinity of the proposed project. However,

our wetland determination has been made in the absence of a field inspection and does not constitute a wetland delineation for the

z

z purposes of Section 404 of the Clean Water Act. The Corps of Engineers and Tennessee Department of Environment and

Xo Conservation should be contacted if other evidence, particularly that obtained during an on-site inspection, indicates the potential rn presence of wetlands. (0005 [Jennings, Mary]) G3)

D, Response: The applicant is responsible for obtaining a Section 404 permit, and the U. S. Army Corps of Engineers is responsible for

9D ensuring the applicant's compliance with its permit. Although Chapters 2 and 4 of the SFES will describe onsite habitats, including

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rn 0 G Category No. 2

o Public Comments Concerning Issues that are Outside the Scope of Review

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Cf) Comment: They don't want anybody there. I mean, this is quite obvious that the public -- this is another way to shut out the public, a and it's a constant thing that we have going here. I mean, you're talking about computer usage. Does anybody see any big

3 overwhelming public libraries over there in Spring City that people can go and pull up on - the Federal Register? I mean, I get

CD notices because I have hounded you people for years to stay on the mailing list, but not everybody knows to do that, or people

suddenly find out things. (0004 [Harris. Ann])

Comment And this visit by the ACRS in the Federal Register - do you all not all work together? Is this another group of people

that's got their own little fiefdoms hanging around through the agency? (0004 [Harris, Ann])

Response: The NRC's mission is to regulate the safe uses of radioactive materials for civilian purposes to ensure the protection of

public health and safety and the environment. As part of this mission, the NRC is responsible for reviewing and issuing licenses for

nuclear power facilities. The Advisory Committee on Reactor Safeguards (ACRS) is an advisory committee mandated by the Atomic

O, Energy Act of 1954, as amended, under the Federal Advisory Committee Act (FACA). The ACRS is independent of the NRC staff

•O and reports directly to the Commission, which appoints its members. The provisions of the FACA govern ACRS operational

practices. The ACRS comprises recognized technical experts in their fields. It is structured so that experts representing many

technical perspectives can provide independent advice, which can be factored into the Commission's decision-making process. Most

Committee meetings are open to the public, and any member of the public may request an opportunity to make an oral statement

during a Committee meeting.

Comment: We've paid billions of dollars out through DOE at these nuclear facilities to people that are really dying. We have two in

our family that's already died from cancer that worked in Oak Ridge. One of them did not die from - a third one did not die from

cancer; he died from Parkinson's disease, and that was a miserable time to watch. (0004 [Harris, Ann])

Response: The commenter is referring to the National Institute for Occupational Safety and Health's Dose Reconstruction Project

for Department of Energy Sites. The NIOSH program is not related to any NRC-licensed activities. This comment will not be

addressed in the SFES.

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Comment: And the final note is that the decommissioning funds that TVA already has set aside for its existing nuclear operations CL

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(D were badly depleted by the change in the economy and the stock market decline. TVA is already trying to figure out ways to steal

money from within its operating budget and perhaps pass through charges to ratepayers to rebuild that decommissioning fund, along

with the retirement funds for its employee retirees, and the whole Issue of an adequate decommissioning fund and how that's to be

accomplished and whether it's really adequate in an age when you don't have nearly the options for the disposal of high-level

radioactive materials which come when you disassemble a plant - unless they're planning to just, you know, build a mountain over

the thing, which I guess is the other option. (0003 [Paddock, Brian])

Comment: But I would again ask that decommissioning - both its costs and its practicability - be listed as one of.the environmental

concerns that has to be addressed. (0003 [Paddock, Brian])

Comment: And they're in DC now, asking for more funds. That doesn't even address the issue of decommissioning funds, which

they had a major start on back in 1995, but somehow those funds got - nobody could ever tell me what they spent them on. So at

that point they had $257 million. The last time I asked, they had 42 million, so you -- I'll let you adjust your own mind as to where that

money went. (0003 [Harris, Ann])

Response: These comments concern decommissioning. Requirements for providing reasonable assurance that funds will be

available for the decommissioning are provided in 10 CFR 50.75.

Comment: I'm also concerned about the high cost and the delayed return on that investment of a nuclear power plant. Its required

to go through a lot of work like this meeting in preparation, a lot of analysis, and even when you get close to construction, it takes

quite a while to get the plant operating and then tested and presumed safe enough to turn it on and finally start generating revenue.

Well, in this economic time it's rather risky, and I'm sure - I believe not a very good idea to invest so much money in something that

may not be needed. (0003 [McCluney, Ross])

Comment: I see this is quite a problem to accomplish, in other words, a gargantuan challenge, at the very least. And environmental

o protection plan that could be fail-safe for eons to come would obviously run into costs over much time adding up to multi-trillions of

dollars, I would imagine. Part of the gargantuan challenge, then, is creating such a plan that it provides and requires a funding

system that will never fail. It will cost lots of dollars. If the funding system fails, the regulation enforcement will not be done, and it will

z C present an unacceptable risk to the public. The Environmental Impact Statement must contain assessment of how these funds will be

X guaranteed. To me it is obvious those funds will have to come out of the pockets of either the ratepayers who buy the power or the

m taxpayers who bail out when the funds aren't there, or both, which is the kind of situation we have now, those of us who are

o ratepayers, in particular, with - dealing with the cleanup of the toxic ash spill. (0003 [Reynolds, Bill])

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9Oc Comment: Couple of things that I want to address up front that Brian talked about earlier: TVA's debt that they admit to today is at

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other rinky-dink stuff they don't count in; it's called creative bookkeeping. (0003 [Harris, Ann]) ;0 x

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GComment: Now they're asking us to believe -- or at least you to believe; they don't want to ask me - that they can do Unit 2 at Watts

6 Bar for less than $4 billion or thereabouts. Well, they started out telling people that they - that Watts Bar 1 was $7 billion. That is not

(.0 true. When you add in the interest, the amortized part of Unit 1 that you -- or Unit 2 that you already paid for, it comes up to closer to

$12-1/2 billion. So now you're going to ask to be paid for probably another 6 to $8 billion on this one. (0003 [Harris, Ann])

Response: The commission has authorized the staff to supplement the SFES if there is new and significant information relevant to

"Dothese matters. In the SFES, the NRC staff will consider the cost of power produced by the proposed licensing action and the overall

3 benefits and costs of operating the proposed WBN Unit 2. However, general issues related to the applicant's financial viability are

(D outside of the NRC's regulatory scope, and the SFES will not consider them. The NRC has requirements for licensees at 10 CFR 50.75 to provide reasonable assurance that funds will be available for the decommissioning process.

Comment: We fully support licensing Watts Bar Number 2. (0003 [Burris, Shane])

Comment: They [the NRC] are concerned about the health and safety of the public, the environmental impact, the physical security

of the plants, and I firmly stand behind the continued construction and moving forward with Unit 2. (0003 [Cobb, Jim])

Comment: And my recommendation to you folks from NRC is that you give serious consideration to issuing license for Watts Bar

o Unit 2. (0004 [Jones, Ken])

Comment: As a member of this community or a member of the community that this plant serves, I would just like to speak out

favorably for licensing of this plant. (0004 [Smith, Stewart])

Comment: I fully support the decision of the Tennessee Valley Authority to complete construction of Unit 2 at the Watts Bar Nuclear

Reactor site and urge favorable consideration from the NRC. (0007 [Yager, Ken])

Comment: TVA's decision to complete construction of Unit 2 results from detailed studies of not only cost and energy needs, but

environmental impacts as well. These studies satisfy me that the project is feasible and environmentally responsible. (0007 [Yager,

Ken])

Response: These comments provide general information in support of the application. They do not provide any specific information

related to the environmental effects of the proposed action and will not be evaluated in the SFES.

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3 Comment: I think that internationally scientists have, for my mind, proven that carbon emissions do have an effect on the (D

CCD• environment, and I think that "-• nuclear energy should play an important role in providing the energy that this country and this world X

needs, particularly this country: clean energy that does not contribute to global warming. (0004 [Smith, Stewart])

Comment: I know that we have in this country had an incident that was certainly a serious incident. I'm getting on up there, a

middle-age guy, and I can barely remember when that happened, and with the technology and as far as technology has come, I feel

like this - that we need to follow up with nuclear energy. (0004 [Smith, Stewart])

Response: These comments provide general information in support of nuclear power. They do not provide any specific information

related to the environmental effects of the proposed action and will not be evaluated in the SFES.

Comment' I heard concerns about, you know, we need to keep a scorecard that accepts nothing less than 100 percent, and I agree

with that. The fact is that the Nuclear Regulatory Commission and Tennessee Valley Authority have a standard that the average

person's 100 percent is probably the TVA and NRC's 50 percent. So I think that they go above and beyond the call of duty to make

sure that we have safe power. (0003 [Cobb, Jim])

Comment: I have lived with it for 35 years. I believe that TVA has proven to us that they can operate a nuclear plant in a safe,

environmentally friendly manner. (0004 [Jones, Ken])

Comment: I'd just like to say that the history of the Tennessee Valley Authority in operating nuclear plants has been very

successful. (0004 [Smith, Stewart])

Response: These comments express support for the applicant. They do not provide any specific information related to the

environmental effects of the proposed action and will not be evaluated in the SFES.

Comment: I start from the national policy of the Sierra Club, which is that nuclear power plants should not be expanded as a source

@of energy in this country until we've solved the waste-disposal problem. (0003 [Paddock, Brian])

Z Comment: This reactor should not be built. (0003 [Zeller, Lou]) C

m Comment: I have compiled a list of reasons, that I have just put together, as to why there should not be a second Watts Bar reactor.

G) (0004 [Kurtz, Sandy]) 6

(D Comment: I am a concerned citizen living in eastern Tennessee and I wish to register my opposition to building (or continuing to

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9D Comment: In addition to my general concerns about nuclear power - I won't list all the concerns and fears; they're in the media.

Cn They've been examined quite a bit, and there's a lot of controversy about most of it, but I think the dangers are real; the potential

-o environmental impact in the event of accidental releases of materials, either fuels or waste, are severe and consequential. What

CD we're counting on is the probability, hopefully, of that happening being low, but as the number of these power plants and materials

3 being transported across the country increase, the probability may change that something can happen, and if it does, it could spell CD serious consequences. (0003 [McCluney, Ross])

Comment: This spells danger to people in Rhea County, eastern Tennessee, if and when one of these reactors was to be

breached. Combined with the fundamental problems of nuclear power, this presents an unacceptable risk in this case. (0003 [Zeller,

Lou])

Response: These comments provide general information in opposition to nuclear power. They do not provide any specific

information related to the environmental effects of the proposed action and will not be evaluated in the SFES.

Comment: TVA overall has a very mixed and, I think, unbalanced, poor environmental record, and I would invite the Commission to

look at the inspector general's report on Kingston, which found a culture in TVA of dispersed responsibility, lack of accountability, lack

of internal communication -- it was always somebody else's job. (0003 [Paddock, Brian])

Comment: I went to work for TVA at Watts Bar Nuclear Plant in nuclear construction in January 1982. They told me I'd be there nine

months. It was nine years before I got a paycheck that did not have overtime on it. And I left under -- for me it was quite a - I don't

want to way victory, because I didn't really win anything; what I did is I turned some magnificently strong lights into some really dark

areas of TVA's management, their money, their funding, how they spend that money, and how they abuse not only ratepayers, but

they abuse each other, they abuse the public, they abuse their future, and they abuse my children and my grandchildren's future.

(0003 [Harris, Ann])

Comment: Browns Ferry Nuclear Plant is listed by Region 2 as the worst nuclear plant program in America. Now, the same person

that was over Browns Ferry's fiasco is heading up the Unit 2 fiasco at Watts Bar. The amount of money that was spent at Browns

Ferry was two times the original designated amount, and longer term, so if - TVA's habits have not changed in the past 25 years, the

way I - according to what TVA puts out. (0003 [Harris, Ann])

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3 Comment: I mean, there were leaks; there were wet spots. There were studies that $26 million could have saved that whole billion- CD

CD dollar nightmare. One of the ten worst environmental disasters on the planet is what that was called by Newsweek, and it could have

N) been saved with $26 million worth of investment, and TVA would not spend it because of their slavish devotion to the bottom line and

keeping our electric rates low, which I appreciate, but it's given everybody the wrong message. (0003 [Safer, Don])

Comment: There's other security guards at WVA that none of them knew anything about each other until they came to me; one from

Browns Ferry, two from Sequoyah, one from Watts Bar, and then this woman out of corporate. This is the beginning of the same

pattern that TVA went through back in the late '80s and the '90s, and I don't see why that we have to go over that same road and

travel that same absolute harassing, demeaning, humiliating practice again, because the only people that come out on top of this is

the media, and the only way that we can get anything done is through the media.NRC doesn't want to listen; WVA won't listen; the

Inspector General won't listen, and the only people that we've got to go to is to the media and the Congress, and we're there. (0004

[Harris, Ann])

Response: These comments express opposition to the applicant. They do not provide any specific information related to the

environmental effects of the proposed action and will not be evaluated in the SFES.

Comment: I'm told by inside sources that are working with the engineers that we have engineers on site that don't know the

difference between a code plant and a noncode plant. Maybe the NRC can describe to the engineers that are working on Unit 2 at

Watts Bar what the difference is and how they need to - how they can see that what they're doing is not working. Browns Ferry is a

noncode plant. Watts Bar Unit 2 is a code plant. And for those of you that don't know and didn't work at the plant, you'll just have to

look it up and trust me on that one. I find that the evacuation plan -- and this is just kind of silly. I'm appalled that the NRC even lets

this get put in print. But in the evacuation plan, that they're going to take the people that live north of the plant, in Spring City and ten

miles on both sides of the river, and they're going to move them up the valley 20 miles downwind; that means north of -- the

prevailing winds all move north in this valley. You can't - its just common sense -- and if you live here, you would know that and

wouldn't question it. But to take people that would be evacuated from Watts Bar Nuclear Plant or the surrounding community and

move them 20 miles up the valley to put them in storage in a gymnasium at the junior college - I mean, I live there, in the connecting community. This is just beyond the pale. I mean, I just - I don't know if the NRC - if they just really and truly don't care anymore or if

they're just too ignorant to ask anybody besides themselves, who don't trust each other. (0003 [Harris, Ann])

Z Comment: My mother lives in a direct line of eight miles from Watts Bar Nuclear Plant. She's blind. She's 86 years old, and she's in C

X; severe bad health. I take care of her. In fact, somebody's hired today so I could be here with y'all. I know that you're going to enjoy

m what I have to say, but this is the truth. My mother gets a calendar; it's this size (indicating). She didn't know what it was, because

Gshe 6 couldn't read it. And then we put all of the announcements on Knoxville and Chattanooga radios. What's the problem with putting A. it out on the local radios? My mother doesn't listen to Chattanooga and Knoxville; she can't even get them. She listens to Athens; she

_oo ~listens to Dayton; she listens to Crossville. What is it with you guys? My mother cannot read this calendar, and I 0o into it, and I find

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something that is so disgusting y'all all ought to get up and walk out; I think you ought to be fired now, because in this calendar it (D

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C says, Take this calendar and keep it with you wherever you go, so that whenever the accident happens, you'll know which direction

X:; to go in. And part of the direction is to come back toward the area that will be so bad that it'll be blocked off. What is it with you x m 0 o people? Don't y'all read what you write? Don't you ever look at it? I mean, it's just really disgusting. This is what you're doing to my

6 family. Think about -- there's other -- I'm not -- my mother's not the only elderly woman in these communities; she's not the only one.

(0 There's little children. I've got great-grandchildren that will be affected by this, sitting in close proximity to Watts Bar. (0003 [Harris,

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. Response: These comments relate to the adequacy of emergency plans, which is a safety issue that is outside the scope of the

environmental review. As part of its site safety review, the NRC staff will determine, after consultation with the Department of 3 Homeland Security and the Federal Emergency Management Agency, whether the emergency plans submitted by the applicant are

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Comment: I admit that TVA will need electricity, not necessarily because it expects a growth in demand -- I really don't think

because of all this technology is getting out there that the demand will be as high as they think it's going to be; I think the lower

growth in their Environmental Impact Statement, the one that's slightly negative, may be closer to the truth. (0003 (McCluney, Ross])

Comment: You know, the electric power that it will generate is very necessary. There's something that most people in this room

may not know. They're going to build a company, Beikler, in Cleveland, Tennessee, that will build solar panels; they will also make

,0 semiconductors, but mostly solar panels. That build out, that plant will require a quarter to a third of a nuclear power plant to run its

full operation. (0003 [Burris, Shane])

Comment: The second thing is basically the -- and this goes to the question of whether or not a license should be granted at all

under NEPA standards, but also to the environment assessment, is options and alternatives, as Dr. McCluney addressed. Basically

you have a situation where, according to the reports to the Tennessee Valley board of directors, power production and sales have

dropped approximately 9 percent during the current economic downturn, the end of which one can debate if it's begun to happen, let

alone any true date for that. In the past TVA, in its power projection demands, including those I assume that were used when the

board decided to go ahead and restart construction on Watts Bar Unit 2, was that there would be an annual 2 percent increase in

demand. That in fact hasn't happened; the reverse has happened. And if in fact we were to have effective conservation and efficiency

programs, it would never happen. We would go into a flat or declining demand usage, and we would have reduced energy intensity

on a per capita basis in the TVA service area. (0003 [Paddock, Brian])

Comment: [D]emand for electricity is down. (0004 [Kurtz, Sandy])

Comment: [S]outheast Tennessee probably is one of the fastest growing areas from a standpoint of population in this state. In the

cn last five or six years, we have seen a tremendous spurt of growth. And certainly when we experience those things, then we're going

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CD Comment: completion of Unit 2 makes good sense, because it uses an existing asset to meet the growing power needs of the L1

Tennessee Valley. (0007 [Yager, Ken])

Comment: There is no guarantee that the demand for power would justify the cost of this plant by the time it is completed. (0008

[Gottfred, Yolande])

Response: In accordance with 10 CFR 51.95(b), unless otherwise determined by the Commission, this SFES will not include a

discussion of need for power, or of alternative energy sources, or of alternative sites, or of any aspect of the storage of spent fuel for

the nuclear power plant within the scope of the generic determination in § 51.23(a) and in accordance with § 51.23(b), and will only

be prepared in connection with the first licensing action authorizing full-power operation. Therefore, this issue is outside the scope of

the environmental review and will not be analyzed in the SFES.

Comment: One percent slackness on enforcement is a failing grade. Why? - Because of what it can do to human beings and their

lives and their health. People's lives and future genetic transmission, by the way, is on the line with radioactive pollution. Necessary

ramifications, lesson learned, is the assertion that and Environmental Impact Statement that omits responsible, honest accounting for

perpetual vigilance through the eons to come, continuously and consistently, is not worth the paper irs written on. So I'm here

encouraging NRC to make sure they get all that covered, all that protection of human health and life in perpetuity, as long as the

waste will last. (0003 (Reynolds, Bill])

Comment: I went there for an NRC hearing about the unscheduled shutdowns of that unit that they brought back on line, the five of

them in the first five or six months. It caused a big, huge slap on the wrist by the NRC. I will have to support some of what Ann said

about the NRC seems to be the enabler of the nuclear industry and not the watchdog, and that's not any news for people that have

been following this issue for quite a while. (0003 [Safer, Don])

Response: The NRC's mission is to regulate the safe uses of radioactive materials for civilian purposes to ensure the protection of

public health and safety and the environment. The NRC has established an extensive regulatory process to ensure the integrity of

each application review. The NRC can deny an application for an operating license based on the findings of its review. These

comments do not provide specific information related to the environmental review and will not be addressed in the SFES.

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m Comment: This bears saying in a scoping session for the environmental impact assessment of a new nuclear power plant here, G) because the most noble and honorable Union of Concerned Scientists, who are not antinuclear, by the way, but they do totally -h, responsible scientific evaluation and assessment of the nuclear power industry and, upon close scrutiny of the Nuclear Regulatory 9D Commission's track record and their oversight of nuclear power plant operation, concluded as follows: Nuclear power is riskier than it co

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Z should and could be. The United States has strong regulations on the books, but the Nuclear Regulatory Commission does not ¢

C enforce them consistently. I agree with the implication in this statement that emphasizes the consistency. TVA has done a lot of good

X things; we all know that. We appreciate the great service they've done, but - and it's not all their fault, because the regulations were OX

mo) not in place regarding the coal ash spill. Regulations are, according to the UCS, in place for strong management of nuclear power, so

6 consistency is what's needed, unfailing consistency. NRC cannot be given a passing grade on their regulation enforcement for

anything less than a perfect 100. (0003 [Reynolds, Bill]) 0o

Comment: How do you think this makes me feel, to know that I'm paying your salaries, and you're not doing your job. You're just

o0 accepting whatever TVA hands you, and TVA will hand you a bunch of garbage, because they will lie. Got it? I don't even want to

CDo• have to say it anymore: You can't trust WVA. You can't trust TVA. How long do you have to have that said to you? And now you can't

3 trust the NRC, because the NRC, they are so close in bed with TVA, that you're beginning to look a bit foolish, even from other

(D people, not just me. Somehow or another this Environmental Impact Statement has to address these issues that concern and deal

with people's lives on a day-to-day basis, and if these jobs are the best that TVA can provide, somebody else needs to be running TVA besides somebody that's running a bunch of serfdoms. (0003 [Harris, Ann])

Comment: I'm telling you, Region 2, we're asking for Congressional hearings on you and your inability to deal with iVA. This is a

repeat of the 1985 and '86 hearings, and you can look for these to be just as disgusting whenever we uncover that pile of crap. (0003

[Harris, Ann])

Comment: We're not going to back down off of this, because the persecution of this -- she's a little, o1' grandmother; she's a clerk.

She had a 18-year career in personnel, and nobody ever - she never made a mistake. She had wonderful - but the bottom line is

0o that there's two women involved that come through the revolving door from the NRC, and they both lost their jobs and were removed

from TVA, but then they went back to work for the NRC in in-house security. Now, what does that say about you, NRC? I can't trust

you to do what you need to do, because you've still got the mentality that the workers don't know what we're doing, because

management is always right. And what you found out after - what was it? - From 1984 to 1996 - how many years is that? - 12

years? You couldn't get it right, and TVA couldn't get it right, because everybody was talking about somebody; they wasn't talking to

anybody, and nobody -- neither one of you were listening, and then the NRC -- I don't know what it's going to take. (0003 [Harris, Ann])

Response: These comments are outside the scope of this review and do not provide specific information related to the

environmental effects of the proposed action; therefore, they will not be evaluated further.

Comment: I daresay I've learned a lot of valid lessons in my studies and private individual studies through the years, and I think I

just recently, within the past year, less than a year, have learned a most important new lesson that I think a lot of folks, including TVA

itself, probably has learned as a result of the horrible disaster of the Kingston ash spill, not far from here, that you all probably are

very well informed with the great disaster, and I'm not going to go into details about it. I bring this up at this time because I think it's a

(n lesson learned that should be known and paid attention to in the practice of producing nuclear power plants and managing nuclear

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Comment. I want to define a lesson learned that I think we should all apply, particularly to the scoping of building a new nuclear x

r')power plant here. And here's my definition: Regulations, monitoring inspection regimens, and compliance enforcement must

absolutely be maintained and sustained with absolute unwavering consistency in perpetuity, as long as the waste remains. And we - those who are informed about nuclear power waste products, some of those waste products remain lethal to'human life and health

for multiple centuries. There must never be a single occurrence of slacking in maintaining and sustaining protection of our supremely

precious air, land, and water from exposure to the poisons contained in the waste produced by electrical power generation. Nothing

akin to the Kingston coal ash spill should ever happen with nuclear power plants, whose waste is even more toxic than coal ash.

(0003 [Reynolds, Bill])

Comment: And you cannot really think that you're going to have a safe 40- to 60-year operation of a nuclear plant in a culture where

plant operations suffer from those same defects. Now, that was respect to a fossil plant, where, if something goes wrong, ordinarily

you think it's not going to be a big deal. Of course, that was a miscalculation, because when you lose 5 million tons of coal ash, it is a

big deal. In fact, it's probably one of the biggest environmental disasters on the North American continent in our lifetimes. But please

do look at the inspector general's report on the culture in TVA and decide what you have to do in terms of building that into the

evaluation of environmental impacts. (0003 [Paddock, Brian])

Comment: Watts Bar Unit 2, as its sister reactor, Number 1, would utilize an ice-condenser containment structure -- many people

have referred to this as an eggshell-type containment - in order to reduce costs of construction, concrete and steel, in the

construction of the containment vessel, that large domed structure. Ice-condenser units employ baskets of ice. During an event

4 inside of a nuclear reactor, excess heat and pressure are created. Ice-condenser reactors are designed to reduce that heat and

pressure by using baskets of ice. There are relatively few of these reactors in operation, and they are fraught with fundamental

engineering flaws and also real-world difficulties in keeping baskets of ice free, operating over a period of decades, which they are

required to do. The ice-condenser system should not be constructed in the 21st century; it should not have been constructed at all.

(0003 [Zeller, Lou])

Comment: I am told by workers - this is not engineers; this is workers, from the inside -- that the 21 million that you paid Bechtel to

go in and see if Unit 2 could be brought up to speed, they spent their $21 million, walked around, and said, Yeah, we can do it; y'all

have a good time. Then, guess what? Bechtel turned around and said, Okay; we're going to start letting them decide what all needs

;pto be done. Bechtel's still looking at what needs to be done; they're still looking at it, because they're finding such massive amounts

Z of rust and corrosion and equipment that cannot be used, won't be used, and cannot be replaced with what is there, because those

X people left and seen better days somewhere else that got the money, that took it and run. (0003 [Harris, Ann])

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G) Comment: The cost-cutting measures designed to make construction cheaper result in some of the most dangerous reactors on the

P. planet. A Sandia study which is memorialized in Nuclear Regulatory's own guidance documents, NUREG/CR-6427, in April

9, 20__•00, states that ice-condenser plants are at least two orders of magnitude more vulnerable to early containment failure than other

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C Hydrogen buildup during an event inside of a nuclear reactor is one of the reasons for this vulnerability. Measures over the years, X

m which have been added to or retrofitted to existing ice-condenser reactors have addressed part of the problem. Buildup of hydrogen G) is why the pressure gets so high and can cause a rupture in the containment structure. Backfitting of hydrogen igniters over the years

have not addressed the full problem. Ice condenser reactors are still vulnerable to hydrogen ignition during a reactor event which

Pwould otherwise be contained inside a more robust containment structure. (0003 [Zeller, Lou]) CO,

Comment: So that's what going on inside those storage casks, which are going to be more and more along the river. They are not

designed to be flooded. I don't know this particular site; I haven't seen it. I know at Browns Ferry they're not that high off of the river,

(D and if they're flooded, then the cooling that is just a convection cooling with vents gets clogged with debris and what-not, and who

3

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Comment: Getting into that reactor design, that design dates from the 1960s. I was in high school when that thing was first

proposed. I'm retired now. A lot of things have changed. You know, a lot of people in this room are not that much different in age from

me; many are younger. But, my gosh, that design comes from the middle '60s; that was when the Mustang - the first iteration of the

Mustang was the hottest car going. You wouldn't buy the Mustang if it was in the showroom - the 1965 - well, you might buy it as an

antique, but it's not going to perform up to environmental standards or whatever; the point being that this design was put together

was an idea of cost containment and not safety. When it was originally designed and approved, there was -- Chernobyl had not

happened. They thought an event like Chernobyl, an event like Three-Mile Island was not even possible; it was not in the design

o criteria for the original design, so that there - and that's why they've had to go back with this hydrogen, you know, ignition system

K)and how you take care of all that hydrogen. This was the cheapest reactor TVA could build at the time. Its a clear indication of the

(00 same culture that put that ash into the river. TVA was dumping that ash into that pile for 50 years. They had plenty of indications that

the ash pile was suspect. (0003 [Safer, Don])

Comment: Back to that ice-condenser design, who can imagine putting 3 million pounds of ice in a nuclear reactor so that you can

make the containment structure half as thick? My gosh, that's a fabulous idea. I applaud whoever came up with it. It's a wonderful

idea. It's just like Rube Goldberg, though; it's stupid. You know, I mean, you have all that ice, which has problems with subsidence. I

went on line, you know, last few days, and somebody patented an idea of what do you do with the ice that's compacted in there? The

ice, from what I read, it's one-foot wide cylinders that are 50-feet tall, and they're wrapped with these steel containment things that

are sort of straps. And so they can't get in there to replace the ice very easily, and somebody invented some sort of a - I didn't look

at the design, but some sort of a contraption to replace the ice, because they were having problems with the ice just melting away,

which it does naturally, and not having the million pounds they needed to survive an incident, which is really a core meltdown, and to

keep that containment structure, however fragile it is, from melting down. (0003 [Safer, Don])

Comment: For example, the most complete and recent probabilistic risk assessment suggests core melt frequencies in the range of

1 in 1000 per reactor year to 1 in 10,000 per reactor. A typical value is 3 in 10,000. I'm reading from David Lochbaum's monograph

CD which quotes a Nuclear Regulatory Commission statement to US Congress, and that's what I am citing here. This is the NRC to the

CD

3

0r

CD

C) 0~
U)

CD>

M" Congress: Were this the industry average, then in a population of 100 reactors, which we have today, over a period of 20 years, the

3 crude cumulative probability of a severe reactor accident would be 45 percent. That is for all reactors combined, including the more

CDrobust designs. The ice-condenser reactor can withstand half the pressure of the more robust old designs, not talking about the new

AP-1 000 and other designs which have not yet been built under CFR Part 52. (0003 [Zeller, Lou])

Comment: [Tlhis reactor plan relies on an outdated ice condenser plan that brings with it far more risk than is necessary. (0004

[Kurtz, Sandy])

Comment: That's not reliable power if you have to shut down the nuclear plants because of droughts and hot weather, an issue

associated perhaps with climate change. (0004 [Kurtz, Sandy])

Comment: Most nuclear accidents happen due to human error. In the light of the Kingston fly ash spill, do you believe that TVA can

avoid human error? And do you believe that TVA is choosing to use this old nuclear reactor design because it's the best technology

available or because it's cheaper? (0004 [Kurtz, Sandy])

Comment: This reactor would use old technology, the ice condenser reactor, which is considered to have design flaws already. (0008 [Gottfried, Yolande])

Response: The issues raised in these comments are safety issues, and as such, are outside the scope of the environmental review

and will not be addressed in the SFES. TVA provided a safety assessment for the proposed licensing action as part of its

*application. The NRC is developing a Safety Evaluation Report that analyzes all aspects of reactor and operational safety.

CD

Comment: And in this letter it talks about this woman who worked at corporate security for TVA. She was drummed out because

she asked too many questions, and she wanted to go by the rules. And the bottom line is that after a two year period, the young lady

and TVA came to a mutually agreeable settlement, and then the NRC's Region 2 - I don't know who they are; we keep getting all

these different names of who they are, what they represent and what their agenda is. The bottom line is the NRC is going after this

woman because they said that she was unauthorized to use documents when she was protesting her termination as retaliation

against the issues that she had raised. TVA agreed, and they redacted the documents. Nobody was identified outside; no documents

were taken off the jobsite. The bottom line is that the NRC's Office of Investigation, they're still pursuing this woman for criminal

charges under federal - they say federal laws; they can't tell us what they're looking for. I suspect that it's more of a fishing Z expedition than it is anything because somebody needs to keep a job, or they're doing something that they don't know what they're

X doing, or they're just totally incompetent and needed someplace to hide themselves. We went to the NRC's Office of Inspector

m General to try to stop it, and they told us that as long as there was an allegation against this woman by somebody at TVA, that they G) would pursue the issue, and they would not do any kind of investigation. Then, whenever we questioned that, TVA's Inspector .r•. General, they just didn't do anything. Of course, that's not unusual; that's their record of decision-making. And now we've been forced

9D to file legal documents with the Commission over this issue. (0004 [Harris, Ann])

CD3

CD
z

C)

9D

-D

(D

(D

=3

0

Comment: But the other thing is if I can't trust you to keep the security at these nuclear facilities and it's not even up and running,

why should I trust you to do right whenever it's up and running? (0004 [Harris, Ann])

Response: Comments related to security and terrorism are not within the scope of the environmental review. The NRC is devoting

substantial time and attention to terrorism-related matters, including coordination with the Department of Homeland Security. While

these are legitimate matters of concern, they will continue to be addressed through the ongoing regulatory process as a current and

generic regulatory issue that affects all nuclear facilities and many of the activities conducted at nuclear facilities. The Commission

has affirmed that the National Environmental Policy Act (NEPA) does not require the NRC to consider the environmental

consequences of hypothetical terrorist attacks on NRC-licensed facilities.

Comment: I would like to see more development in recycling of our nuclear waste so that we can use that to the best of its ability.

(0004 [Smith, Stewart])

Response: The recycling of nuclear waste is a national policy issue that is outside the scope of the environmental review of WBN

Unit 2.

C,,

(D

CD

C?
Appendix E

Draft Supplemental Final Environmental Statement

Comments and Responses (Reserved)

Appendix E

Draft Supplemental Final Environmental Statement

Comments and Responses (Reserved)

1 Pending

September 2011 .E-1 Draft NUREG-0498, Supplement 2

Appendix F

Key Consultation Correspondence

Regarding the Watts Bar Nuclear Unit 2

Operating License

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

Appendix F

Key Consultation Correspondence

Regarding the Watts Bar Nuclear Unit 2

Operating License

The Endangered Species Act of 1973, as amended, the Magnuson-Stevens Fisheries

Conservation and Management Act of 1996, as amended; and the National Historic

Preservation Act require that Federal agencies consult with applicable State and Federal

agencies and groups prior to taking action that may affect threatened and endangered species,

essential fish habitat, or historic and archaeological resources, respectively. This appendix

contains consultation documentation.

Table F-1 provides a list of the consultation documents sent between the U.S. Nuclear

Regulatory Commission (NRC) and other agencies. The NRC staff is required to consult with

these agencies based on the National Environmental Policy Act of 1969 requirements.

Table F-I. Consultation Correspondences

Author

U.S. Nuclear Regulatory Commission

(J. Wiebe)

U.S. Nuclear Regulatory Commission

(J. Wiebe)

U.S. Nuclear Regulatory Commission

(J. Wiebe)

U.S. Nuclear Regulatory Commission

(J. Wiebe)

U.S. Nuclear Regulatory Commission

(J. Wiebe)

U.S. Nuclear Regulatory Commission

(J. Wiebe)

U.S. Nuclear Regulatory Commission

(J. Wiebe)

Recipient

U.S. Fish and Wildlife Service

(M. Jennings)

Advisory Council on Historic

Preservation (D. Klima)

Cherokee Nation

(R. Allen)

Eastern Band of the Cherokee

Indians (T. Howe)

Eastern Band of the Cherokee

Indians (R. Townsend)

United Keetoowah Band

Headquarters (L. Larue-Stopp)

The Chickasaw Nation

(V. (Gingy) Nail)

Date of Letter/Email

September 2, 2009

(ML092100088)

September 10, 2009

(ML092120105)

September 10, 2009

(ML092110475)

September 10, 2009

(ML092110475)

September 10, 2009

(ML092110475)

September 10, 2009

(ML092110475)

September 10, 2009

(ML092110475)

16

September 2011 F-1 Draft NUREG-0498, Supplement 2
Appendix F

Table F-1. (contd)

Author

U.S. Nuclear Regulatory Commission

(J. Wiebe)

U.S. Nuclear Regulatory Commission

(J. Wiebe)

U.S. Nuclear Regulatory Commission

(J. Wiebe)

U.S. Nuclear Regulatory Commission

(J. Wiebe)

U.S. Nuclear Regulatory Commission

(J. Wiebe)

U.S. Nuclear Regulatory Commission

(J. Wiebe)

U.S. Nuclear Regulatory Commission

(J. Wiebe)

U.S. Nuclear Regulatory Commission

(J. Wiebe)

U.S. Nuclear Regulatory Commission

(J. Wiebe)

U.S. Nuclear Regulatory Commission

(J. Wiebe)

U.S. Nuclear Regulatory Commission

(J. Wiebe)

U.S. Nuclear Regulatory Commission

(J. Wiebe)

U.S. Nuclear Regulatory Commission

(J. Wiebe)

U.S. Nuclear Regulatory Commission

(J. Wiebe)

U.S. Nuclear Regulatory Commission

(J. Wiebe)

U.S. Nuclear Regulatory Commission

(J. Wiebe)

U.S. Nuclear Regulatory Commission

(J. Wiebe)

Recipient

Choctaw Nation of Oklahoma

(T. Cole)

Choctaw Nation of Oklahoma

(G. Pyle)

Jena Band of Choctaw Indians

(L. Strange)

Muscogee (Creek) Nation of

Oklahoma (J. Bear)

Alabama-Coushatta Tribe of Texas

(B. Battise)

Alabama-Quassarte Tribal Town

(A. Asbury)

Kialegee Tribal Town

(E. Bucktrot and G. Bucktrot)

Thlopthlocco Tribal Town

(C. Coleman)

Absentee Shawnee Tribe of

Oklahoma (K. Kaniatobe)

Eastern Shawnee Tribe of

Oklahoma (R. DuShane)

Eastern Shawnee Tribe of

Oklahoma (G.J. Wallace)

Shawnee Tribe

(R. Sparkman)

Shawnee Tribe

(B. Pryor)

Tennessee Historical Commission

(J.Y. Garrison)

U.S. Army Corps of Engineers

(R. Gatlin)

Office of Environment Policy and

Compliance, Department of Interior

(G.L. Hogue)

Sam Nunn Atlanta Federal Center

(A.S. Meiburg and S. Gordon)

Date of Letter/Email

September 10, 2009

(ML092110475)

September 10, 2009

(ML092110475)

September 10, 2009

(ML092110475)

September 10, 2009

(ML092110475)

September 10, 2009

(ML092110475)

September 10, 2009

(ML092110475)

September 10, 2009

(ML092110475)

September 10, 2009

(ML092110475)

September 10, 2009

(ML092110475)

September 10, 2009

(ML092110475)

September 10, 2009

(ML092110475)

September 10, 2009

(ML092110475)

September 10, 2009

(ML092110475)

September 10, 2009

(ML092120097)

September 10, 2009

(ML092110147)

September 10, 2009

(ML092110147)

September 10, 2009

(ML092110147)

Draft NUREG-0498, Supplement 2 F-2 September 2011
Appendix F

Table F-1. (contd)

Author Recipient Date of Letter/Email

U.S. Nuclear Regulatory Commission

(J. Wiebe)

U.S. Nuclear Regulatory Commission

(J. Wiebe)

U.S. Nuclear Regulatory Commission

(J. Wiebe)

U.S. Nuclear Regulatory Commission

(J. Wiebe)

U.S. Nuclear Regulatory Commission

(J. Wiebe)

U.S. Nuclear Regulatory Commission

(J. Wiebe)

U.S. Nuclear Regulatory Commission

(J. Wiebe)

U.S. Nuclear Regulatory Commission

(J. Wiebe)

U.S. Nuclear Regulatory Commission

(J. Wiebe)

U.S. Nuclear Regulatory Commission

(J. Wiebe)

U.S. Nuclear Regulatory Commission

(J. Wiebe)

U.S. Nuclear Regulatory Commission

(J. Wiebe)

U.S. Nuclear Regulatory Commission

(J. Wiebe)

U.S. Nuclear Regulatory Commission

(J. Wiebe)

U.S. Nuclear Regulatory Commission

(J. Wiebe)

Tennessee Department of

Environment and Conservation

(M. Apple)

Tennessee Department of

Environment and Conservation

(S. Baxter)

Tennessee Department of

Environment and Conservation

(B. Bowen)

Tennessee Department of

Economic and Community

Development (M. Atchinson)

Commissioners Office, Tennessee

Department of Transportation

Environment and Planning

Environmental Division (E. Cole)

Tennessee Department of

Agriculture (K. Givens)

Tennessee Department of

Environment and Conservation

(P. Davis)

Water Supply

(R. Foster)

Tennessee Department of

Environment and Conservation

(J. Fyke)

Division of Radiological Health

(L.E. Nanney)

Tennessee Department of

Environment and Conservation

(B. Stephens)

Tennessee Department of

Environment and Conservation

(M. Tummons)

Groundwater

(A. Schwendimann)

Tennessee Wildlife Resource

Agency (E. Carter)

September 10, 2009

(ML092110147)

September 10, 2009

(ML092110147)

September 10, 2009

(ML092110147)

September 10, 2009

(ML092110147)

September 10, 2009

(ML092110147)

September 10, 2009

(ML092110147)

September 10, 2009

(ML092110147)

September 10, 2009

(ML092110147)

September 10, 2009

(ML092110147)

September 10, 2009

(ML092110147)

September 10, 2009

(ML092110147)

September 10, 2009

(ML092110147)

September 10, 2009

(ML092110147)

September 10, 2009

(ML092110147)

September 10, 2009

(ML092110147)

ýeptember 2011 F-3 Draft NUREG-0498, Supplement 2
Appendix F

Table F-1. (contd)

Author

U.S. Nuclear Regulatory Commission

(J. Wiebe)

Tennessee Historical Commission

(E.P. McIntyre)

Eastern Band of Cherokee Indians

(T. Howe)

U.S. Fish and Wildlife Services

(M. Jennings)

Tennessee Historic Commission

(E. Patrick McIntyre, Jr.)

Recipient

Resource Management Division

(A. Marshall)

U.S. Nuclear Regulatory

Commission (J. Wiebe)

U.S. Nuclear Regulatory

Commission

U.S. Nuclear Regulatory

Commission (J. Wiebe)

U.S. Nuclear Regulatory

Commission (J. Wiebe)

Date of Letter/Email

September 10, 2009

(ML092110147)

September 22, 2009

(ML093510985)

September 29, 2009

(ML0928605910)

October 9, 2009

(ML0929301820)

March 5, 2010

(ML100770290)

1

Draft NUREG-0498, Supplement 2 F-4 September 2011
Appendix F.1

Biological Assessment

Appendix F

Biological Assessment

U.S. Fish and Wildlife Service

Watts Bar Unit 2 Nuclear Power Plant

Rhea County, Tennessee

U.S. Nuclear Regulatory Commission Operating License Application

Docket No. 50-391

Gray Bat (Myotis gresescens)

Pink mucket (Lampsilis abrupta)

Eastern fanshell pearlymussel (Cyprogenia stegaria)

Rough pigtoe (Pleurobema plenum)

Dromedary pearlymussel (Dromus dromas)

Orangefoot pimpleback (Plethobasus cooperianus)

Snail darter (Percina tanasi)

September 2011

U.S. Nuclear Regulatory Commission

Rockville, Maryland

September 2011 Draft NUREG-0498, Supplement 2

Appendix F

Acronyms

°C degree(s) Celsius

OF degree(s) Fahrenheit

ac acre(s)

BA Biological Assessment

Btu British thermal units

Btu/hr British thermal unit(s) per hour

CCW condenser circulating water

cfs cubic feet per second

cm centimeter(s)

EIS Environmental Impact Statement

ER Environmental Report

ERCW essential raw cooling water

ESA Endangered Species Act

FES-CP Final Environmental Statement related to the construction permit for WBN Units

1 and 2

FES-OL Final Environmental Statement related to Operation

FSAR Final Safety Analysis Report

ft foot (feet)

FWS U.S. Fish and Wildlife Service

gpm gallon(s) per minute

ha hectare(s)

hr hour

in. inch(es)

IPS intake pumping station

km kilometer(s)

kV kilovolt(s)

L/s liter(s) per second

m meter(s)

m3/s cubic meter(s) per second

mi mile(s)

MW(e) megawatts electric

NPDES National Pollutant Discharge Elimination System

NRC U.S. Nuclear Regulatory Commission

ppm parts per million

PWR pressurized water reactor

RAI request for additional information

RCW raw cooling water

s second(s)

September 2011 F.l1-iii Draft NUREG-0498, Supplement 2
Appendix F

SCCW 

Supplemental Condenser Cooling Water

TRM 

Tennessee River Mile TVA 

Tennessee WBN 

Watts Valley Authority Bar Nuclear

Draft NUREG-0498, Supplement 2

F. 1-iv

September 2011
Appendix F

Contents

A c ro n y m s ................................................................................................................................... iii

1.0 Introduction and Purpose ............................................................................................... 1

2.0 Proposed Action and History ........................................................................................ 5

3.0 W BN Site Description ................................................... I.................................................. 7

3 .1 In ta k e s ..................................................................................................................... 1 0

3.1.1 W ater Consum ption .................................................................................. 12

3.1.2 Intake Pum ping Station ........................................................................... 12

3.1.3 Supplem ental Condenser Cooling W ater Intake ....................................... 12

3.2 Discharge System s ............................................................................................. 13

3.2.1 O utfall 101 - Discharge Diffusers ............................................................ 13

3.2.2 O utfall 113 - SCCW Discharge .............................................................. 15

3.2.3 Outfall 102 - Yard Holding Pond Emergency Overflow ........................... 15

3.2.4 Therm al Effects from Discharges ............................................................ 16

3.2.5 Physical Effects from Scouring at the Discharges .................................... 17

3.2.6 Chem ical Discharges from O utfalls .......................................................... 17

4.0 Assessm ent of Listed Species ............................ : ....................................................... 21

4.1 G ray Bat (M yotis grisescens) .............................................................................. 21

4.1.1 Life History of the G ray Bat ..................................................................... 21

4.1.2 Status of the G ray Bat in the Vicinity of the W BN Site .............................. 21

4.2 Aquatic Biota ........................................................................................................... 21

4.2.1 Life History ............................................................................................... 23

4.2.2 Status of Listed Species .......................................................................... 24

5.0 Environm ental Effects of W BN Unit 2 on Listed Species ............................................. 29

5.1 G ray Bat .................................................................................................................. 29

5.2 Freshwater M ussels and Snail Darters .............................................................. 30

5.2.1 W ater Consum ption ............................................................................... 30

5.2.2 Entrainm ent and Im pingem ent ................................................................ 30

5.2.3 Therm al and Chem ical Effects ................................................................ 32

5.3 Sum m ary ................................................................................................................. 33

6.0 Cum ulative Im pacts ......................................................................................................... 35

September 2011 F. 1-v Draft NUREG-0498, Supplement 2
Appendix F

6.1 Terrestrial Species (G ray Bat) ............................................................................. 35

6 .2 A q uatic S pecies .............................................................................................. . . . 35

7 .0 C o n c lu s io n s ..................................................................................................................... 3 7

8 .0 R e fe re n ce s ...................................................................................................................... 3 9

Figures

1-1 The WBN Site and the 80-km (50-mi) Vicinity .............................................................. 3

3-1 W BN S ite (TV A 2008) ................................................................................................. 8

3-2 Major Components of the Cooling System for WBN Units 1 and 2 (TVA 2008) ............ 9

4-1 Known Caves Occupied by Gray Bats in the Vicinity of the WBN Site ........................ 22

4-2 Mussel Beds and Monitoring Stations (TVA 1998b) ................................................... 25

Tables

1-1 Federally Listed Terrestrial Species Occurring in the Vicinity of the WBN Site ............. 4

3-1 A nticipated W ater U se ............................................................................................... 11

3-2 NPDES Temperature Limits for WBN Outfalls to the Tennessee River from TVA ..... 16

3-3 Raw Water Chemical Additives at WBN ..................................................................... 18

3-4 Potential Chemical Discharge to NPDES Outfalls at the WBN Site ............................. 20

4-1 Results of 15 Native Mussel Surveys from TRM 520 to TRM 528.9 (includes one

survey from T R M 529.2) ............................................................................................. 26

5-1 Percent Composition of Dominant Larval Fish Taxa Collected in the CCW Intake

Channel during 1984 and 1985 and 1996 and 1997 ................................................... 31

5-2 Actual and Estimated Numbers of Fish Impinged at WBN Plant during Sample

Periods from March 1996 through March 1997, March 1997 through October 7, 1997

and during March 2010 through March 2011 ............................................................. 31

Draft NUREG-0498, Supplement 2 F.l1-vi September 2011
Appendix F

1.0 Introduction and Purpose

Under the Endangered Species Act of 1973, as amended, each Federal agency shall, in

consultation with, and with the assistance of the Secretary of the Interior, the Secretary of

Commerce, or the Secretary of Agriculture (as appropriate), ensure that any action authorized

by such agency is not likely to jeopardize the continued existence of any endangered species or

threatened species or result in the destruction or adverse modification of habitat of such

species. Each agency shall use the best scientific and commercial data available. Each

Federal agency requests of the Secretary information about whether any species that is listed or

proposed to be listed may be present in the area of such proposed action. If the Secretary

advises, based on the best scientific and commercial data available, that such species may be

present, such agency shall conduct a biological assessment (BA) for the purpose of identifying

any endangered species or threatened species that is likely to be affected by such action.

The Federal agency uses the the BA to determine whether formal consultation or a conference

is required. If the BA indicates that there are no listed species or critical habitat present that are

likely to be adversely affected by the action and the Director (Fish and Wildlife Service regional

director, or the appropriate authorized representative) concurs, then formal consultation is not

required. If the BA indicates that the action is not likely to jeopardize the continued existence of

proposed species or result in the destruction or adverse modification of proposed critical habitat,

and the Director concurs, then a conference is not required. Note that the Director may use the

results of the BA in (1) determining whether to request the Federal agency to initiate formal

consultation or a conference, (2) formulating a biological opinion, or (3) formulating a preliminary

biological opinion.

The U.S. Nuclear Regulatory Commission (NRC) is currently considering a request by the

Tennessee Valley Authority for an operating license for Watts Bar Nuclear (WBN) Unit 2,

located on the northwest shore of Chickamauga Reservoir (on the Tennessee River) in Rhea

County, Tennessee (see Figure 1-1). The site has two Westinghouse-designed pressurized

water reactors (PWRs). In early 1996, the NRC issued an operating license for WBN Unit 1.

The Tennessee Valley Authority (TVA) operates the WBN site. TVA has not yet completed

WBN Unit 2. On August 3, 2007, TVA informed the NRC of its intention to complete

construction activities at WBN Unit 2 under the existing construction permit (TVA 2007a). On

March 4, 2009, TVA submitted to the NRC a request to reactivate its application for a license to

operate a second light-water nuclear reactor at the WBN site (TVA 2008).

The NRC staff requested in a letter dated September 2, 2009 (NRC 2009) that the U.S. Fish

and Wildlife Service (FWS) provide information on Federally-listed endangered or threatened

species, proposed or candidate species, and designated critical habitats that may occur in the

vicinity of the WBN site. The FWS responded to NRC's request in a letter dated October 9,

2009 (FWS 2009), which provided a list of seven Federally listed threatened and endangered

September 2011 F.1-1 Draft NUREG-0498, Supplement 2
Appendix F

species near the WBN site. This BA examines the potential impacts of the proposed actions on

the seven Federally listed species within FWS's jurisdiction (see Table 1-1). The list included

one mammal, the gray bat (Myotis grisescens); one fish, the snail darter (Percina tanasi); and

five species of mussel. The mussels include the pink mucket (Lampsilis abrupta), the Eastern

fanshell pearly mussel (Cyrpogenia stegaria), the rough pigtoe (Pleurobema plenum), the

dromedary pearlymussel (Dromus dromas), and the orangefoot pimpleback (Plethobasus

cooperianus). No critical habitat areas are designated near the Watts Bar site. FWS indicated

that the staff "should assess potential impacts and determine if the proposed project may affect

these species."

On January 19, 2011, the sheepnose mussel (Plethobasus cyphyus) was proposed for listing

(76 FR 3392). The sheepnose mussel occurs in the Southeast and the Midwest, but has been

eliminated from two-thirds of the streams where it had been known to occur. The sauger is the

only known host for the sheepnose mussel (FWS 2011). The sheepnose mussel is known to

occur in the vicinity of the Watts Bar site. In September 2010, TVA found a specimen, judged to

be approximately 20 years old, during sampling (TVA 2011 a).

Therefore, the NRC prepared this BA to support the draft supplemental final environmental

statement related to the operating license for WBN Unit 2.

Draft NUREG-0498, Supplement 2 F. 1-2 September 2011
Appendix F

V . I 

Cookeville'2

441

Oak Ridge/

/ Redan ;\7 akRig

/ / -- ,.....

*70

/"t

*~~~~ Sceit5yMleBufe WB 

-~~~ StteBondris ~ Hihwys 6 

\ ....~2 af" u

Fiue.-.Th BNSt-adth-0km(0-iicnt

-... ..."J'•7<11•" ,/> ,.• Athens ': .. .. , .

.... "7.4 B an -

tanvla6d

t -ge.E 'as inerd

Vlr BN Site ['-50 Mile Bu"e

HihasJ State Boundaries0 10 2

=-"Interstates i~iiCounty --'l Boundaries --- Miles

Figure 1-1. The WBN Site and the 80-kmn (50-mi) Vicinity

September 2011 F.1-3 Draft NUREG-0498, Supplement 2
Appendix F

Table 1-1. Federally Listed Terrestrial Species Occurring in the Vicinity of the WBN Site

Federal

Scientific Name Status

Terrestrial Species

Mammals

Myotis grisescens

Aquatic Species

Fish

Common Name

gray bat E

Percina tanasi

Freshwater mussels

Lampsilis abrupta

Cyprogenia stegaria

Pleurobema plenum

Dromus dromas

Plethobasus cooperianus

snail darter

pink mucket

Eastern fanshell pearly mussel

rough pigtoe

dromedary pearlymussel

orange pimpleback

T

E

E

E

E

E

Draft NUREG-0498, Supplement 2 F. 1-4 September 2011
Appendix F

2.0 Proposed Action and History

The proposed action is for the NRC to issue an operating license for WBN Unit 2 at the WBN

site.

WBN Units 1 and 2 possess a unique licensing history and regulatory framework. On May 14,

1971, TVA submitted a request for issuance of construction permits for WBN Units 1 and 2.

TVA issued its Final Environmental Statement related to the construction permit for WBN

Units 1 and 2 (FES-CP) in November 1972 (TVA 1972). The FES mentioned the bald eagle

(Haliaeetus leucocephalus) as a relatively common visitor to the WBN area and addressed

potential impacts on freshwater mussel species. On January 23, 1973, the Atomic Energy

Commission issued Construction Permits for WBN Units 1 and 2.

In late 1976, TVA submitted an application requesting operating licenses for Units 1 and 2 (TVA

1976). Subsequently, on December 1, 1978, the NRC issued the 1978 Final Environmental

Statement related to Operation (FES-OL), which evaluated operation of WBN Units 1 and 2

(NRC 1978). The 1978 FES-OL addressed the bald eagle and two endangered freshwater

mussel species (pink mucket and dromedary pearly mussel). NRC concluded that operation of

WBN would not affect these species (TVA 1972).

In 1994 following several construction delays, NRC determined that the units were

nearing completion. In a letter dated April 1, 1995, NRC issued Supplement No. 1 to the 1978

FES-OL re-examining environmental considerations before issuance of an operating license for

WBN Units 1 and 2 (NRC 1995). NRC entered into Section 7 consultation with FWS by

submitting a BA, completed by TVA, to FWS on October 28, 1994. The BA included four

species of freshwater mussel (i.e., pink mucket, dromedary pearly mussel, Eastern fanshell

pearly mussel, and rough pigtoe), the snail darter, the bald eagle, and the gray bat. It also

identified three additional aquatic species that FWS had designated as active candidates. TVA

concluded that the operation of WBN Units 1 and 2 was not likely to affect individuals or

populations of any of the listed species or candidate species or their critical habitats. NRC

agreed with the "no effect" determination but requested a formal consultation. On January 25,

1995, NRC indicated that its staff and TVA had become aware of the existence of a fourth

candidate species in the vicinity of the WBN site. In a biological opinion, FWS indicated that the

action was not likely to jeopardize the continued existence of the listed species. TVA received

the full power-operating license for Unit 1 on February 7, 1996.

As indicated in Section 1.0, TVA submitted an updated application on March 4, 2009 for a

facility-operating license from NRC to possess, use, and operate WBN Unit 2 (TVA 2009a) and

the NRC requested consultation with the FWS in a letter dated September 2, 2009 (NRC 2009).

September 2011 F.1-5 Draft NUREG-0498, Supplement 2

Appendix F

3.0 WBN Site Description

TVA owns the 427 ha (1,055 ac) WBN site, located in southeastern Tennessee. The WBN site

contains structures to support the operation of two nuclear units. WBN Unit 1 is currently

operating and WBN Unit 2 is partially constructed. Figure 3-1 shows the layout of the site. A

rural road, Morrison Lane, and forested land form the western border of the site, while TN-68

(also known as Watts Bar Highway) makes up the northern border. The WBN site is bounded

by Chickamauga Reservoir (an impoundment of the Tennessee River) to the east and south of

the site. The WBN site lies entirely within an unincorporated area of Rhea County, Tennessee,

approximately 13 km (8 mi) southeast of Spring City.

TVA originally designed the WBN site as a two-unit PWR nuclear plant with a total electrical

generating capacity of 2,540 megawatts (MWe). Unit 1 began operating in 1996. In addition to

the reactors, the WBN site consists of two reactor containment buildings, a diesel generator

building, a training facility, a turbine building, a service building, an intake pumping station, a

water treatment plant, two cooling towers, 500-kV and 161-kV switchyards, and associated

parking facilities. Figure 3-2 shows the reactor buildings and associated facility layout (NRC

1995). The United States owns the existing facilities at the WBN site, and TVA is the custodian

(TVA 2008).

TVA terminated construction of Unit 2 in 1985 when the unit was 80 percent complete (TVA

2008). Since then, TVA has used many Unit 2 components to replace portions of Unit 1 and

other TVA facilities. As a result, at the time of the operating license application, Unit 2 was

approximately 60 percent complete. Completing Unit 2 may result in some additional grounddisturbing activities, but these activities would be mostly restricted to the existing disturbed

portion of the property (TVA 2008). Because the facility (including the intakes and discharge

systems used by Unit 1) was essentially completed, the only impacts that will affect aquatic and

terrestrial biota include those from operations.

The original cooling system constructed for the WBN units was a closed-cycle system to

transfer heat from the main condenser of each unit to the natural-draft cooling tower basin

associated with that unit. In its 2008 environmental report (ER) (TVA 2008), TVA identified this

system as the condenser circulating water (CCW) system. During normal plant operation, the

CCW system for each unit would dissipate up to 7.8 x 109 Btu/hr of waste heat (TVA 1972, TVA

2009b). The Essential Raw Cooling Water (ERCW) system and the Raw Cooling Water (RCW)

system remove additional heat from the plant components. Water from both of these systems

discharges to the cooling tower basins for the CCW.

September 2011 F. 1-7 Draft NUREG-0498, Supplement 2
Appendix F

(To convert feet [ft] to meters [m], mL uY -W ýSe -.. (V 2 )Ll

Figure 3-1. WBN Site (TIVA 2008)

The WBN cooling water system uses natural-draft cooling towers to dissipate waste heat from

the plant. Two single cooling towers, one for each unit, would serve the WBN site. Each tower

is 108 m (354 ft) in diameter and 146 m (478 ft) high (TVA 1972). Most excess heat in the

cooling water transfers to the atmosphere by evaporative and conductive cooling in the cooling

tower. In addition to evaporative losses, a small percentage of water is lost in the form of

droplets (drift) from the cooling tower. The water that does not evaporate or drift from the tower

routes back to the cooling tower basin.

Draft NUREG-0498, Supplement 2 F.1-8 September 2011
Appendix F

To ontufet[t 102

(To convert feet [ft] to meters [in], multiply by 0.3048 m/ft)

Figure 3-2. Major Components of the Cooling System for WBN Units 1 and 2 (TVA 2008)

September 2011 F. 1-9 Draft NUREG-0498, Supplement 2
Appendix F

Evaporation of cooling water system water from the cooling tower increases the concentration of

dissolved solids in the cooling water system. In most closed-cycle wet-cooling systems, a

portion of the cooling water is removed and replaced with makeup water from the source (for

WBN, the Tennessee River) to limit the concentration of dissolved solids in the cooling system

and in the discharge to the receiving water body.

Because the WBN cooling towers cannot remove the desired amount of heat from the

circulating water during certain times of the year, TVA added the Supplemental Condenser

Cooling Water (SCCW) system to the cooling system for the WBN reactors. The SCCW draws

water from behind Watts Bar Dam and delivers it by gravity flow to the cooling tower basins to

supplement cooling of WBN Unit 1. Unit 1 currently uses the SCCW system. Unit 2 will also

use the SCCW system. The temperature of the water from the SCCW intake is usually lower

than the temperature of the water in the cooling tower basin and, as a result, lowers the

temperature of the water used to cool the steam in the condensers. Approximately the same

volume of water that enters the cooling tower basins through the SCCW intake leaves the

cooling tower basins and flows through the SCCW discharge structure into Chickamauga

Reservoir (TVA 2008). Since the SCCW has been operating, elevated total dissolved solids in

blowdown water have not been a concern because a large volume of water enters and leaves

the cooling tower basins continually (PNNL 2009).

Table 3-1 lists the anticipated water usage parameters associated with current operation of

Unit 1, the anticipated parameters for Unit 2 and the increment from the added operation of

Unit 2.

3.1 Intakes

WBN Unit 1 uses two intakes. The first is the SCCW intake, which withdraws water from Watts

Bar Reservoir. The second is the intake pumping station (IPS) for the CCW, which withdraws

water from Chickamauga Reservoir. Unit 2 would also operate with two intakes.

The intake for the SCCW system, which TVA originally used for its Watts Bar Fossil Plant, is

located above Watts Bar Dam. The intake canal for the IPS, which supplies water to the CCW

system, is located at Tennessee River Mile (TRM) 528.0, which is approximately 3.1 km (1.9 mi)

below the dam.

Draft NUREG-0498, Supplement 2 F.1-10 September 2011
Appendix F

Table 3-1. Anticipated Water Use

WBN Unit I Current Anticipated WBN WBN Unit 2 Added

Item Operations Units 1 and 2 Increment

Circulating Water System

Heat discharged

Waste heat to atmosphere

Waste heat via liquid

discharges to outfall 101

Intake Pumping Station

Normal maximum makeup

water flow rate

Consumptive use

Evaporation rate

Drift rate

Blowdown Flow Rate

Normal

Maximum when discharging

from yard holding pond and

cooling tower basins

Maximum allowable

blowdown temperature

SCCW System

Waste heat via liquid

discharges

Intake flow rate

Discharge flow rate

Temperature of discharge

7.8 x 109 Btu/hr(c)

6.9 x 109 Btu/hr(c)

1.5 x 108 Btu/hr(b)

2.5 m3/s (88 cfs)(c)

0.82 m3/s (29 cfs)(c)

2.8 L/s (45 gpm)(a)

1.5 m3

/s (53 cfs)(c)

3.82 m3/s (135 cfs)(b)

350C (950F)(b)

7.5 x 108 Btu/hr(b)

7.31 m3/s (258 cfs)(c)

7.48 m3

/s (264 cfs)(c)

35 0C (95 0F) also

33.5 0C (92.3 0F) in

receiving stream

bottom) ')

1.5 x 101) Btu/hr(c)

1.4 x 10"' Btu/hr(c)

1.7 x 108 Btu/hr(b)

4.93 m3

/s (174 cfs)(c) 2.4 m3/s (86 cfs)

7.7 x 109 Btu/hr

7.1 x 109 Btu/hr

2 x 107 Btu/hr(b)

1.73 mr3/s (61.1 cfs)(c)

5.7 L/s (90 gpm)(a)

1.8 m3/s (64 cfs)(c)

4.81 m3/s (170 cfs)(b)

35 0C (9 50F)(b)

8.6 x 108 Btu/hr(b)

7.1 m3/s (250 cfs)(c)

8.46 m3/s (299 cfs)(c)

350C (95 0F) also

33.50C (92.3 0F) in

receivingstream

bottom)

0.87 m3

/s (31 cfs)

2.8 L/s (45 gpm)

0.3 m3/s (11 cfs)

0.99 m3/s (35 cfs)

No change

1.1 x 108 Btu/hr(b)

Intake flow rate will

decline because

elevation of water

surface in Unit 2 cooling

tower will be higher

when plant is in

operation.

A portion of the water

entering the system

through the IPS will be

discharged through the

SCCW discharge

No change

(a)

(b)

(c)

1972 FES-CP (TVA 1972)

TVA (2008)

TVA (2010a)

September 2011 F.1-11 Draft NUREG-0498, Supplement 2
Appendix F

3.1.1 Water Consumption

The maximum normal makeup water flow rate through the IPS from Chickamauga Reservoir

would be 4.93 m3/s (174 cfs) (TVA 2010a), which is 0.6 percent of the mean annual flow of the

Tennessee River at Watts Bar Dam (i.e., 778 m3

/s [27,500 cfs]). The average monthly intake

flow rate through the SCCW intake from above Watts Bar Dam in the Watts Bar Reservoir

would be 7.1 m3/s (250 cfs), which is slightly less than that currently withdrawn for WBN Unit 1

and is 0.91 percent of the mean flow of the Tennessee River at the dam (TVA 2010a).

Combined, this total withdrawal is 1.3 percent of the mean flow of the Tennessee River at Watts

Bar Dam. However, much of this water returns to the river in the discharge. The maximum

annual plant consumption rate represents 0.1 percent of the mean annual flow of the

Tennessee River at Watts Bar Dam. The NRC staff considers the total withdrawal and the

consumptive withdrawal to have a slight, if any, affect on the aquatic biota in Watts Bar

Reservoir, Chickamauga Reservoir, and the Tennessee River downstream. Data collected

during the preoperational and operational periods for Unit 1 also indicate that the number of

species in the reservoir and numbers of individuals per species in the reservoir did not change

significantly from the preoperational period to the operational period.

3.1.2 Intake Pumping Station

TVA originally designed the IPS to supply water to both WBN Units 1 and 2; however, since

1996, it has supplied water only to WBN Unit 1. It is located about 3.1 km (1.9 mi) below

Watts Bar Dam at TRM 528.0. The IPS is located at the end of an intake channel approximately

240 m (800 ft) from the shoreline of the reservoir (TVA 2009b). The IPS has two sump areas

with two intake bays each. Each intake bay is 1.58 m (5.17 ft) wide at the traveling screens and

5.3 m (17.5 ft) high, resulting in an opening of 8.40 m2 (90.4 ft2). The open area through the

trash racks at each bay opening in the IPS is approximately 8.8 m2 (95.1 ft2

), for a total of 35.3

m2 (380 ft2) open for the passage of water through the trash racks.

Currently, Unit 1 withdraws approximately 2.5 m3/s (88 cfs) of water from Chickamauga

Reservoir for normal operations (TVA 2010a). TVA estimates normal maximum operations for

WBN Units 1 and 2 would require withdrawal of 4.93 m3

/s (174 cfs) of water from the reservoir

(TVA 2010a). Under these conditions, while drawing water through all four bays in the IPS, the

maximum water velocity through the openings in the traveling screens would be 0.21 m/s

(0.67 ft/s) in the winter and 0.19 m/s (0.62 ft/s) in the summer for the portion of the intake

structure with four RCW pumps operating (TVA 2011 b). The maximum water velocity through

the openings in the traveling screens would be 0.24 m/s (0.8 ft/s) (TVA 2010b).

3.1.3 Supplemental Condenser Cooling Water Intake

The intake facility for the SCCW is located above Watts Bar Dam at TRM 529.9. The SCCW

has six intake bays and uses three for operation of WBN Unit 1. No additional bays are

Draft NUREG-0498, Supplement 2 F.1-12 September 2011
Appendix F

required for operation of both units. Each intake bay is 2.17 m (7.13 ft) wide at the traveling

screens and 9.37 m (30.75 ft) high, resulting in an opening of 20.3 m2 (219.1 ft2). The traveling

screens and their support structures occupy a portion of the opening leaving 9.16 m2 (98.6 ft2)

open to the passage of water in each bay for a total of 27.48 m2 (295.8 ft2) for the passage of

water through the screens into the SCCW intake. The open area through the trash racks at

each bay opening in the SCCW intake structure is approximately 11.5 m2 (124 ft 2), for a total of

34.6 m2 (372 ft2) (TVA 2010a). Figure 3-2 shows the locations of the IPS and SCCW water

intakes.

The SCCW system operates by gravity flow, so the flow through the intake structure fluctuates

as the water-level elevation in Watts Bar Reservoir changes. TVA estimates that the average

monthly SCCW intake flow from Watts Bar Reservoir to Unit 1 is approximately 7.31 m3/s

(258 cfs) (TVA 201 Oa). For the operation of both Units 1 and 2, TVA estimates that the average

monthly flow through the SCCW intake would be 7.1 m3

/s (250 cfs) of water from Watts Bar

Reservoir (TVA 2010a). The lower flow rate for two units in operation is anticipated because

water moves through the system under gravity flow, and the water level in the cooling tower

basin for Unit 2 would be 0.6 m (2 ft) higher when the unit is operating (TVA 2010a). This

reduces the water level elevation difference between Watts Bar Reservoir and the cooling tower

basin, resulting in a reduction of flow rate.

The normal intake flow rates are higher in the summer months when TVA maintains the

elevation of Watts Bar Reservoir at 225.7 m (740.5 ft) above mean sea level. Normal flow rates

during summer months with both units operating would be approximately 7.6 m3/s (270 cfs),

resulting in a water velocity of 0.22 m/s (0.73 ft/s) through the open areas in the trash racks in

the SCCW. The water velocity through the openings in the traveling screens at the SCCW

would be 0.28 m/s (0.91 ft/s) under these conditions (TVA 2010a).

3.2 Discharge Systems

WBN Unit 1 uses three discharge systems and three outfalls for discharge from the cooling

water systems. TVA holds permits through the National Pollutant Discharge Elimination System

(NPDES) permit process for the three outfalls. All three outfalls empty into Chickamauga

Reservoir. The outfalls include Outfall 101, which uses discharge diffusers; Outfall 102, which

uses a shoreline discharge; and Outfall 113, which also uses an emergency overflow weir that

flows into a local stream channel and empties into Chickamauga Reservoir.

3.2.1 Outfall 101 - Discharge Diffusers

TVA plans to discharge cooling water from the main cooling-water system for WBN Units 1 and

2 to Chickamauga Reservoir through a diffuser system located approximately 3.2 km (2 mi)

below Watts Bar Dam at TRM 527.9 (TVA 2008). The National Pollutant Discharge Elimination

September 2011 F. 1-13 Draft NUREG-0498, Supplement 2
Appendix F

System (NPDES) permit for the WBN site identifies the diffuser discharge as Outfall 101 (TDEC

2011). TVA (1997) describes this diffuser system as consisting of two pipes branching from a

central conduit at the right bank of Chickamauga Reservoir and extending perpendicular to the

river flow of the Tennessee River. Each pipe is controlled by a butterfly valve located a short

distance from the junction with the central conduit.

The downstream leg of the diffuser consists of 49 m (160 ft) of unpaved 1.37-m (4.5-ft)-diarmeter

corrugated steel diffuser pipe at the end of approximately 91 m (297 ft) of paved corrugated

steel approach pipe of the same diameter. The diffuser pipe is half buried in the river bottom

and has two 2.54-cm (1-in.)-diameter ports per corrugation. The centroid of the ports is angled

up at 45 degrees from horizontal in a downstream direction (TVA 1997).

The upstream leg of the diffuser system consists of 24 m (80 ft) of unpaved 1.07-m (3.5-

ft)-diameter corrugated steel diffuser pipe at the end of approximately 136 m (447 ft) of

paved corrugated steel approach pipe of the same diameter. The upstream diffuser pipe

section is half buried in the river bottom and extends its entire length beyond the dead

end of the downstream diffuser pipe section. The port diameter, spacing, and orientation

of the upstream leg are the same as those of the downstream leg (TVA 1997). TVA

document Figure 3 (1977) illustrates the diffuser configuration. TVA does not plan to

make any upgrades or changes to the diffuser design in preparation for operating Unit 2

(TVA 2010c).

TVA maintains operational procedures for this system to ensure adequate dilution of the plant

effluent. The 2008 TVA ER explains the process as follows:

To provide adequate dilution of the plant effluent, discharge from the diffusers is

permitted only when the release from Watts Bar Dam is at least 3,500 cubic feet

per second (cfs). To ensure this happens, an interlock is provided between the

dam and WBN that automatically closes the diffusers when the flow from the

hydroturbines at Watts Bar Dam drops below 3,500 cfs. To provide temporary

storage of water during these events, the blowdown discharge conduit also is

connected to a yard holding pond. When the flow from Watts Bar Dam drops

below 3,500 cfs, thereby closing the diffuser valves, the blowdown is

automatically routed to the yard holding pond. When hydro operations resume

with releases of at least 3,500 cfs, the interlock is 'released' and the diffuser

valves can be opened. When this occurs, the discharge from the diffusers would

contain blowdown from the cooling towers and blowdown from the yard holding

pond. To protect the site from the consequences of exceeding the capacity of

the yard holding pond, an emergency overflow weir is provided for the pond,

which delivers the water to a local stream channel that empties into the

Tennessee River at TRM 527.2. The operation of Watts Bar Dam and the WBN

Draft NUREG-0498, Supplement 2 F.1-14 September 2011
Appendix F

blowdown system are very carefully coordinated to avoid unexpected overflows

from the yard holding pond (TVA 2008).

3.2.2 Outfall 113 - SCCW Discharge

The SCCW system discharges water through a discharge structure originally constructed for the

Watts Bar Fossil Plant. The NPDES permit for the WBN site identifies the SCCW discharge as

Outfall 113 (TVA 2008). Water leaving the cooling tower basins flows through a pipe to the

discharge structure approximately 1.8 km (1.1 mi) upstream of the IPS. TVA describes the

discharge structure as an "open discharge canal, an overflow weir drop structure, and a below

water discharge tunnel" (TVA 1998a). TVA describes the discharge tunnel as a "rectangular

culvert 7 feet wide by 10 feet high at the discharge point" (TVA 1998a). The elevation of the

culvert outlet is 205.7 m (675 ft) above mean sea level. To reduce the impact of the discharge

on the river bottom, TVA installed a concrete incline to direct flow toward the river surface as it

leaves the outfall (TVA 1998a, PNNL 2009).

WVA designed and constructed the SCCW system so it could operate the cooling system for

WBN Units 1 and 2 with or without the SCCW. If the temperature of the discharge water

exceeds allowable release limits, TVA can shut down the SCCW system. WVA also included a

crosstie and control valve in the system that allows part of the flow from the SCCW intake to

bypass the cooling tower basins and mix with the effluent in the discharge pipeline. When the

possibility of exceeding the NPDES river temperature limit exists, TVA opens a bypass valve to

allow cooler water in the intake pipeline to mix with water in the discharge line, thus cooling the

effluent before it is discharged to the reservoir (WVA 2008). The bypass is necessary during

winter months when the water temperature in the Tennessee River is cooler, and a possibility

exists of exceeding the instream temperature rate of change limit in the NPDES permit. TVA

opens the crosstie around November 1, and it remains open until the end of April (PNNL 2009).

3.2.3 Outfall 102 - Yard Holding Pond Emergency Overflow

WVA uses the unlined yard holding pond (Figure 3-2), which is approximately 8.9 ha (22 ac) in

area (TVA 2005a), for temporary storage of cooling tower blowdown when the flow from the

hydroturbines at Watts Bar Dam is less than 99 m3

/s (3500 cfs). When dam operations resume

with releases of at least 99 m3

/s (3,500 cfs), diffuser valves allow the yard-holding pond to

discharge into Chickamauga Reservoir through the diffusers (WVA 2008).

The yard-holding pond has an emergency overflow weir at 215.3 m (706. 5 ft) above mean sea

level. This weir design prevents the yard-holding pond from overflowing the capacity of the

pond. In the event that water rises above the height of the weir, it flows into a local stream

channel that empties into Chickamauga Reservoir at TRM 527.2 (WVA 2008). The NPDES

permit for the WBN site identifies this discharge as Outfall 102 (WVA 2008).

September 2011 F.1-15 Draft NUREG-0498, Supplement 2
Appendix F

3.2.4 Thermal Effects from Discharges

WBN Unit 2 would continue to discharge water via three outfalls. Table 3-2 shows the current

NPDES temperature limits for the three outfalls used during operation for Unit 1. The NPDES

permit issued by the State of Tennessee for Unit 1 specifies limits on the amount of thermal

effluent the plant may discharge into the Tennessee River. The permit also establishes an

active mixing zone and defines in-stream monitoring and reporting requirements necessary to

comply with effluent limitations. Table 3-1 provided the increment added for waste heat

discharged to the river for both Outfall 113 (i.e., the SCCW system shoreline discharge) and

Outfall 101 (i.e., the diffuser discharge). The additional increment for flow is approximately

14 percent of the current amount of heat discharged. The mixing zone dimensions for the

outfall to the SCCW (i.e., Outfall 113) are based on a physical hydrothermal model test of the

discharge. TVA has confirmed the model output with actual measurements (TVA 2005b, 2006,

2007b, 2007c). The model and measurements indicate that the plume rises after hitting the

concrete pad located at the end of the discharge. The model results also predict a zone of

passage for fish along the bottom of the river especially in the area of the navigation channel

(IVA 2004). The location of the plume from the SCCW discharge does not prohibit fish from

swimming past the plant, and the plume would likely not reach the river's mussel beds.

Table 3-2. NPDES Temperature Limits for WBN Outfalls to the Tennessee River from TVA

Outfall Effluent Parameter Daily Report Limit

101 Effluent Temperature Daily Avg 35.00C (957F)

102 Effluent Temperature Grab 35.0°C (95°F)

113 Instream Temperature(a) Max Hourly Avg 30.5°C (86.9°F)

Instream Temperature Rise(b) Max Hourly Avg 3.00C (5.4°F)

Instream Temperature Rate-of-Change(a) Max Hourly Avg ±20C/hr (±3.60F/hour)

Instream Temperature Receiving Stream Max Hourly Avg 33.50C (92.3 0F)

Bottom(c)

Source: TVA 2010d

(a) Downstream edge of mixing zone.

(b) Upstream ambient to downstream edge of mixing zone.

(c) Mussel relocation zone at SCCW outlet.

TVA relocated freshwater mussels from an area 46 m by 46 m (150 ft by 150 ft) at Outfall 113.

TVA relocated the mussels to the mussel bed directly across the river in order to prevent

adverse impacts during operation of the SCCW. In addition, TVA placed a ramp on the invert of

the SCCW outfall to deflect the discharge upward, and away from the bottom of the river (TVA

2004). The analysis of instream data collected by TVA for Outfall 113 showed that heat from

the SCCW effluent does not reach the river bottom in significant amounts (TVA 2004).

Discharge from the emergency overflow (i.e., Outfall 102) is infrequent. The current NPDES

permit also specifies a discharge temperature limit of 350C (950F) for Outfall 102 (TVA 2008).

Draft NUREG-0498, Supplement 2 F.1-16 September 2011
Appendix F

3.2.5 Physical Effects from Scouring at the Discharges

No impacts are anticipated to benthic organisms in the vicinity of, or immediately downstream

of, the outfalls from scouring of the bottom of the reservoir by adding WBN Unit 2. TVA

indicates that water flow from the SCCW discharge would not increase, and the concrete

structure at the discharge of the SCCW (i.e., Outfall 113) continues to reduce the affect the

discharge has on the river bottom and directs the flow of water toward the river surface as it

leaves the outfall (TVA 1998a). The use of a diffuser that discharges at an angle of 45 degrees

above horizontal in the downstream direction for Outfall 101 minimizes the amount of scouring

discharge from this outfall. Use of Outfall 102, which discharges emergency outflow from the

yard holding pond, has been infrequent. This outfall discharges into a local stream channel that

empties into the Chickamauga Reservoir. The NRC staff determines that physical changes at

the outfalls as a result of the additional operation of Unit 2 would not affect the aquatic biota of

Watts Bar Reservoir.

3.2.6 Chemical Discharges from Outfalls

Another discharge-related stressor involves chemical treatment of the cooling water. TVA

would control water chemistry for various plant water uses by adding biocides, algaecides,

corrosion inhibitors, pH buffering, scale inhibitors, and dispersants. The NPDES permit requires

that TVA follow the TDEC-approved Biocide/Corrosion Treatment Plan (B/CTP) (TDEC 2011).

WBN's current B/CTP was approved in 2009 (TDEC 2011) based on the list of chemicals

included in the permit modification request submitted by TVA in April 2009 (TVA 2010e).

Table 3-3 lists chemicals and their discharge quantities included in the WBN site's NPDES

permit request submitted for the WBN site on April 2009 (TVA 2009c).

TVA discharges water containing chemical and biocidal additives for the condenser cooling

system and the SCCW system to the Chickamauga Reservoir through Outfalls 101 and 113,

respectively. Chemical and biocidal additives and waste streams from various other watertreatment processes and drains are returned to the Yard Holding Pond (YHP) where they are

subjected to dilution, aeration, vaporization, and chemical reactions. The plant then discharges

the YHP water to Chickamauga Reservoir through Outfall 101 or 102, subject to the limitations

of the WBN site's existing NPDES permit (TDEC 2011).

The NPDES permit (TDEC 2011) provides additional detail about the chemicals that may be in

water discharged through the outfalls. In addition to the chemicals added as biocide and for

corrosion-treatment, other chemical additives are used in a variety of plant processes. These

chemicals may occur in trace quantities at Outfall 101 or Outfall 102. The potential discharge of

these chemicals is through the cooling-tower blowdown line to Outfalls 101 and 102 so Outfall

113 would not receive these discharges. The summary of potential chemicals discharged by

NPDES outfall number is shown in Table 3-4.

September 2011 F. 1-17 Draft NUREG-0498, Supplement 2
Appendix F

Table 3-3. Raw Water Chemical Additives at WBN

Frequency of Active Discharge Concentrationta)

Product Purpose Discharge Ingredients (ppm active ingredients)

Depositrol Dispersant to Continuous copolymer < 0.2

PY5200

(replaces Nalco

7 3 2 0 0)(b)

Inhibitor

AZ8100

(replaces Nalco 1336)(b)

Sprectrus

ED 1500

(replaces Nalco 73551)(')

Towerbrom

60 m (replaces

Towerbrom 960) (b)

Spectrus

OX 1200

(replaces Nalco

901 G)(b)

Spectrus

DT 1404

(replaces Nalco

CA_3S)(b)

Spectrus

CT1300(d)(repla

ces H150M)(b)

or

Spectrus

NXl104

4

(replaces

Spectrus

NX 1 0 4 )(b)

Bentonite clay(b)

Liquid bleach(b)

H 150M(e)

facilitate iron

corrosion

inhibition

Copper corrosion

Inhibition

Surfactant to

facilitate

oxidizing

biocides

Oxidizing biocide

(chlorination)

Oxidizing biocide

(chlorination)

De-chlorination

Periodic

Periodic

sodium tolyltriazole

nonionic surfactant

< 0.25

< 2.0

Periodic

Continuous

Periodic(c)

sodium bromide and

sodium

dichloroisocyanurate

bromo-chloro,

dimethyl hydantoin

sodium bisulfite

0.10 chlorine

(total residual)

0.10 chlorine

(total residual)

<10

Nonoxidizing

biocide (mollusk

control)

Nonoxidizing

biocide (mollusk

control)

Detoxification of

nonoxidizing

biocides

Oxidizing biocide

(chlorination)

Nonoxidizing

biocide

Periodic

Periodic

Periodic(c)

Alkyl dimethyl

benzyl ammonium

chloride

dimethylbenzylammonium chloride and

dodecylguanidine

hydrochloride

sodium silicate

(bentonite clay)

sodium hypochlorite

25 percent dimethyl

benzyl ammonium

chloride and 25 percent

dimethyl ethylbenzyl

ammonium chloride.

< 0.001 active ingredient in

stream after mixing

< 0.05 measured in effluent

< 0.001 total active ingredient

in stream after mixing

< 0.031 quaternary ammonium

compound measured in

effluent

<10

0.10 chlorine (total residual)

< 0.05 ppm

Continuous

Minimum of 4 times

per year

Draft NUREG-0498, Supplement 2 F.1-18 September 2011
Appendix F

Table 3-3. (contd)

Frequency of Active Discharge Concentration

Product Purpose Discharge Ingredients (ppm active ingredients)

Flogard Iron Corrosion Continuous when zinc chloride, < 0.2 total zinc

MS6209 Inhibitor river temperature is orthophosphate < 0.2 total phosphorus

(replaces MSW- above 15.6°C

109, (60-F). 2010)(°

Source: From Table in TVA (2009d)

(a) The maximum discharge concentration is indicated except where noted. Concentrations are achieved through

a combination of dilution and dechlorination with sodium bisulfite or detoxification with bentonite clay.

(b) Denotes chemicals previously approved by the division (Tennessee Department of Environment &

Conservation, Division of Water Pollution Control).

(c) Dechlorination and detoxification chemicals are applied as needed to ensure the discharge limitations identified

in this table are met.

(d) Non-oxidizing biocide treatments are not applied at the same time as oxidizing biocide treatments.

(e) Application information from TVA 2008

(f) SCCW and river flow conditions have a significant impact on these discharge concentrations.

(g) Active ingredient information from TVA 2008.

September 2011 F.1-19 Draft NUREG-0498, Supplement 2
Appendix F

Table 3-4. Potential Chemical Discharge to NPDES Outfalls at the WBN Site

No. Outfall Description Chemical

101 Diffuser Discharge

102

103

YHP Overflow Weir

Low-Volume Waste

Treatment Pond

Lined Pond and

Unlined Pond

SCCW Discharge

ammonium hydroxide, ammonium chloride, alpha cellulose,

asbestos after 5 micron filter, boric'acid, sodium tetraborate,

bromine, chlorine, copolymer dispersant, ethylene oxide, propylene

oxide copolymer, ethylene glycol, hydrazine, laboratory chemical

wastes, lithium, molybdate, monoethanolamine, molluscicide, oil

and grease, phosphates, phosphate cleaning agents, paint

compounds, sodium bisulfite, sodium hypochlorite, sodium

hydroxide, surfactant, tolyltriazole, x-ray film processing rinse water,

zinc chloride orthophosphate, zinc sulfate, phosphino-carboxylic

acid copolymer, diethylenetriaminepenta-methylene phosphonic

acid, sodium salt, sodium chloride, ethylenediamine tetracetic acid.

Alternate discharge path for Outfall 101

ammonium hydroxide, ammonium chloride, boric acid, sodium

tetraborate, bromine, chlorine copolymer dispersant, ethylene

glycol, hydrazine, laboratory chemical wastes, lithium, molybdate,

monoethanolamine, molluscicide, oil and grease, phosphates,

phosphate cleaning agents, paint compounds, sodium hydroxide,

surfactant, tolyltriazole, x-ray film processing rinse water, zinc

sulfate

metals - mainly iron and copper, acids and caustics, ammonium

hydroxide, ammonium chloride, asbestos after 5 micron filter, boric

acid, sodium tetraborate, bromine, chlorine, copolymer dispersant,

hydrazine, laboratory chemical wastes, molybdate, molluscicide, oil

and grease, phosphates, phosphate cleaning agents, sodium,

sodium hydroxide, surfactant, tolyltriazole, zinc sulfate

some contact with chemicals listed for outfall 101, alpha cellulose,

bromine, chlorine, copolymer, molluscicide, zinc chloride

orthophosphate

107

113

Source: TDEC 2011

Draft NUREG-0498, Supplement 2 F. 1-20 September 2011
Appendix F

4.0 Assessment of Listed Species

4.1 Gray Bat (Myotis grisescens)

4.1.1 Life History of the Gray Bat

The gray bat, listed as endangered by FWS (41 FR 17736) and the State of Tennessee, is a

migrant colonial bat. The distribution of gray bats is centered by limestone karst areas within

the southeastern United States (Brady et al. 1982). The gray bat possesses very specific

microclimate requirements and use caves during both winter and summer. Colonies may travel

over 100 km (60 mi) between winter and summer habitats (NatureServe 2010). Summer

colonies occupy traditional home ranges that include a maternal cave and several roost caves

usually within 1 km (0.6 mi) of a river or reservoir (NatureServe 2010).

Adult gray bats feed on insects almost exclusively over water bodies (Brady et al. 1982). They

a have been known to forage more than 19 km (12 mi) from summer roost caves and are known

to forage over and along the Tennessee River. FWS has not designated critical habitat for the

gray bat.

4.1.2 Status of the Gray Bat in the Vicinity of the WBN Site

Gray bats have not been observed on the WBN Site. In 1982, three caves in the State of

Tennessee served as major winter hibernacula for gray bats (Brady et al. 1982). Two caves

(see Figure 4-1) within 16 km (10 mi) from the WBN site serve as summer roosts for gray bats

(NRC 1995). A cave located approximately 4 km (2.5 mi) from of the WBN site contained

385 gray bats in 2002, while another cave almost 13 km (8 mi) from the WBN site contained 340

gray bats during the same year (Harvey and Britzke 2002). Although no direct observations of

gray bats foraging over the Tennessee River immediately adjacent to the WBN site or under

transmission lines that service the site have been recorded, the staff concludes gray bats

routinely forage at these locations based on habitat preferences and proximity to known active

summer roost caves.

4.2 Aquatic Biota

Federally listed aquatic biota that could potentially reside in the vicinity of the WBN site include

freshwater mussels (pink mucket mussel [Lampsilis abrupta], Eastern fanshell pearlymussel

[Cyprogenia stegaria], rough pigtoe [Pleurobema plenum], dromedary pearlymussel [Dromus

dromas] and orangefoot pimpleback [Plethobasus cooperianus]) and the snail darter (Percina

tanasi).

September 2011 F. 1-21 Draft NUREG-0498, Supplement 2
Appendix F

Sensabaugh

Cave

4) . Chickamauga

SReserv~oir..~

Watts Bar

w Dam

/Watts Bar

Nuclear Site

N

Eves 0 0.5 1 2 Miles

0 1 2 4 Kilometers

Figure 4-1. Known Caves Occupied by Gray Bats in the Vicinity of the WBN Site

Draft NUREG-0498, Supplement 2 F. 1 -22 September 2011
Appendix F

4.2.1 Life History

The life histories of the freshwater mussels and the snail darter are discussed separately.

4.2.1.1 Life History of Freshwater Mussels

Mussels spend their entire juvenile and adult lives buried either partially or completely in the

substrate. Although mussels are able to change their position and location, they rarely move

more than a few hundred yards during their lifetime unless dislodged. Native freshwater

mussels have an unusual reproductive cycle. Although some species are hermaphroditic, the

species discussed in this BA have separate sexes. The eggs of female mussels move from the

ovaries to the gills where fertilization occurs. Sperm is released to the water by male mussels

and is carried into the female's body through the incurrent aperture. The gills, or a portion of the

gills, serve as brood pouches, called marsupia. The fertilized eggs develop into small larvae,

called glochidia, which release into the water. At the time of their release from the marsupia,

the glochidia possess only the embryonic stages of a mouth, intestines, a foot, and a heart. If

the glochidia do not encounter a passing fish and attach to its gills, skin, or fins then they fall to

the bottom and die a short time later. The glochidia usually remain on the fish from one to six

weeks (sometimes longer) and then fall off and begin their growth into adulthood. Each mussel

species has specific species of fish that serve as a host fish for the glochidia (Parmalee and

Bogan 1998). The survival of freshwater mussel species depends not only on the

environmental conditions for the mussel, but on the survival and health of the host fish

populations.

Pink mucket mussel - Pink muckets prefer free-flowing reaches of large rivers, typically in siltfree and gravel substrates. Fishes that reportedly serve as hosts for glochidia include the

smallmouth bass (Micropterus dolomieu), spotted bass (M. punctulatus), and largemouth bass

(M. salmoides) as well as freshwater drum (Aplodinotus grunniens), and possibly sauger

(Sander canadensis) (Mirarchi et al. 2004).

Eastern fanshell pearlymussel - Fanshells are usually found on coarse sand and gravel less

than 0.9 m (3 ft) deep (Parmalee and Bogan 1998). The glochidial hosts have been reported to

be banded sculpin (Cyprogenia stegaria), mottled sculpin (Cottus bairdi), greenside darter

(Etheostoma blennioides), Tennessee snubnose darter (E. simoterum), banded darter

(E. zonale), tangerine darter (Percina aurantiaca), blotchside logperch (P. burtoni), logperch

(P. caprodes), and the Roanoke darter (P. roanoka).

Rough pigtoe - The rough pigtoe is found primarily in large rivers inhabiting a mixture of sand

and gravel in areas kept free of silt by moderate to strong currents. A fish host for the glochidia

has not been identified (Mirarchi et al 2004).

September 2011 F.1-23 Draft NUREG-0498, Supplement 2
Appendix F

Dromedary pearlymussel -The dromedary pearly mussel inhabits small-to-medium, lowturbidity, high-to-moderate-gradient streams. In recent studies, FWS has identified the fantail

darter (Etheostoma flabellare) as the host species. Other potential hosts include the banded

darter, tangerine darter (Percina aurantiaca), logperch, gilt darter (P. evides), black sculpin

(Cottus baileyi), greenside darter, Tennessee snubnose darter, blotchside logperch, channel

darter (P. copelandi), and the Roanoke darter (FWS 201 Oa).

Orangefoot pimpleback - The orangefoot pimpleback is primarily a big river species found in

silt-free areas in a mixture of sand and gravel. The species still survives in the tailwaters of

some Tennessee River dams, such as Pickwick Dam. A glochidial host has not been identified

(Mirarchi et al. 2004).

4.2.1.2 Snail Darter

Snail darters inhabit larger creeks where they frequent sand and gravel shoal areas in lowturbidity water. They also inhabit deeper portions of rivers and reservoirs in areas where there

is a current. Snail darters are known to burrow beneath the substrate, possibly for concealment

or to conserve energy. Snail darters spawn early with their spawning season extending from

February to mid-April in shoal areas. Females contain an average of 600 mature eggs and may

mate with several males during the mating season. Eggs hatch in 15 to 20 days depending on

the water temperature. The larvae of snail darters may drift considerable distances to deeper

water areas downstream, although by late summer they have migrated upstream again toward

the spawning habitat. Snail darters prefer small pleurocerid river snails although they may also

feed on caddis fly larvae, midge, and blackfly larvae (Etnier and Starnes 1993).

4.2.2 Status of Listed Species

Federally listed aquatic species include freshwater mussels and the snail darter.

4.2.2.1 Freshwater Mussels

The Tennessee River is home to both introduced and native mussel and clam species.

Approximately 130 of nearly 300 species of freshwater mussels in the United States live or have

lived in waters within Tennessee (Parmalee and Bogan 1998). The numbers of native mussels

in the Tennessee River have been declining since the early 1940s when TVA filled the

Chickamauga and Watts Bar reservoirs. Based on studies of shell midden material and

evaluations conducted before the impoundments were built, ecologists believe a total of

64 freshwater mussel species occurred near the WBN site prior to impoundment of the river

(TVA 1986). Surveys conducted by TVA between 1983 and 1997 identified only 30 native

mussel species (TVA 1998b).

Because of the loss of diversity in mussel species, the State of Tennessee created a freshwater

mussel sanctuary in Chickamauga Reservoir in the vicinity of the WBN site. The freshwater

Draft NUREG-0498, Supplement 2 F. 1-24 September 2011
Appendix F

mussel sanctuary, in which harvesting mussels is illegal, currently extends 16 km (10 river mi

from TRM 520.0 to TRM 529.9) (TVA 1998a). Figure 4-2 shows the extent of the freshwater

mussel sanctuary, as well as the approximate locations of the mussel beds and the locations of

TVA's mussel sampling stations.

530

Watts Bar Dam

TRM 529.9

Watts Bar

Fossil Plant

Watts Bar/

TRM 526.527 TRM526-527B•• R Intake Nuclear Plant'lj.!

\ • ~~Canal".. . ,..-.

~528-529 L

Submerged

Diffuser

525

TRM 520-521 L North

*-Mussel Sampling Station

0 1 2 kmi _____________________ +River Mile Marker

Figure 4-2. Mussel Beds and Monitoring Stations (TVA 1998b)

TVA has monitored three known concentrations of mussels (mussel beds) within this sanctuary

since 1983. The beds are all located on submerged gravel and cobble bars in water 2.7 m to

6.4 mr (9 ft to 21 ft) deep (TVA 2010b). The furthest bed downstream is located at TRM 520 to

TRM 521 on the left descending bank of the river. This bed is 10 km (6 mi) downstream of the

WBN site and on the opposite side of the river. A second bed is roughly from TRM 526 to

TRM 527 on the right descending bank, and the third from TRM 528 to TRM 529 on the left

descending bank (TVA 1998b). The most recent data reported is from surveys from 2010 (TVA

2011a, 2011c).

September 2011 F.1-25 Draft NUREG-0498, Supplement 2
Appendix F

Table 4-1 provides the results of 15 mussel surveys over a period of 14 years (1983-1997)

adjacent to or downstream of the site between TRM 520 and TRM 529.2. The table includes

only those species considered in this BA. TVA sampled the same locations in 2010 but did not

observe any of the listed species (TVA 2011 a), with the exception of a single pink mucket

mussel.

Table 4-1. Results of 15 Native Mussel Surveys from TRM 520 to TRM 528.9 (includes one

survey from TRM 529.2)

1997 at

TRM

529.2

Common 1983 1984 1985 1986 1988 1990 1996 1997 (TVA

Species Name (Sep/Nov) (Jul/Nov) (Jul/Oct) (Jul/Oct) (July) (July) 1992 1994 (July) (July) 1998a)

Lampsilis Pink mucket 3/7 6/2 1/7 6/2 12 4 6 2 4 0 1

abrupta

Cyprogenia Eastern 2/1 0/1 1/0 0/0 0 0 0 0 0 0 0

stegaria fanshell

Dromus Dromedary 1/0 0/0 0/0 0/0 0 0 0 0 0 0 0

dromas pearlymussel

Pleurobema Rough pigtoe 1/1 2/0 1/0 0/0 0 0 0 0 0 0 0

plenum

Plethobasus Orangefoot 0/0 0/0 0/0 0/0 0 0 0 0 0 0 0

cooperianus pimpleback

Source: Adapted from TVA 1998b, and TVA 1998a

Pink mucket mussel - The FWS designated the pink mucket mussel as endangered in 1976

(41 FR 24062) and wrote a recovery plan in 1985 (FWS 1985). Historically, this species

inhabited the entire reach of the Tennessee River across northern Alabama. Currently, it occurs

only in the riverine reaches downstream of Wilson Dam in Tennessee and Guntersville Dam in

Alabama. However, FWS considers the species to be uncommon to rare. Researchers report

specimens younger than 10 years of age as rare in the Wilson and Guntersville dam tailwaters.

TVA found the pink mucket in the vicinity of the WBN site during every mussel survey from 1986

to 1997, although the number of specimens was never more than 10 (1988) in the surveys from

TRM 528.2 to TRM 528.9 (TVA 1998b) as shown in Table 4-1. The occurrence data provided

by TVA (TVA 2010a) indicated that nine specimens were found in the 1990 survey, six

specimens in the 1992 survey as well as two specimens in the vicinity of the SCCW discharge

(TRM 529.2). The most recent sighting was of a single individual located between TRM 526

and 527 during the most recent survey conducted in 2010 (TVA 201 la).

Eastern Fanshell Pearlymussel - The FWS has listed the Eastern fanshell pearlymussel, also

known simply as the fanshell, as endangered since 1990 (55 FR 25591). According to the

Fanshell Recovery Plan (FWS 1991), the species is known from only three reproducing

populations. The closest population to the WBN Site is in the Clinch River in Tennessee,

although it also inhabits the Green and Licking rivers in Kentucky. This species generally is

Draft NUREG-0498, Supplement 2 F. 1 -26 September 2011
Appendix F

distributed in the Tennessee and Cumberland river systems. The fanshell is generally

considered a big river species, though it also may be found inhabiting shallow, unimpounded

upper stretches of the Clinch River, and in unimpounded portions of the Tennessee and

Cumberland rivers. Researchers think fanshells may be reproducing below Pickwick Landing

Dam on the Tennessee River (Parmalee and Bogan 1998). Many factors have caused the

decline of this species, including impoundment, navigation projects, water quality degradation,

and other forms of habitat alternation such as gravel and sand dredging. These habitat

modifications either directly affected the species or reduced or eliminated the fish hosts

(55 FR 25591). TVA last found the fanshell in 1985 in the mussel bed nearest the WBN site

(TRM 528.2 to TRM 528.9) (TVA 1998b). In addition, three specimens were observed in 1983

and a single specimen in 1984. The occurrence data provided by TVA (TVA 201 Oa) indicated

that a single individual was reported from survey years 1983 to 1984 and that two individuals

were confirmed from a survey in 1983.

Dromedary Pearlymussel - The FWS listed the dromedary pearlymussel as endangered in

1976 throughout its entire range in Kentucky, Tennessee, and Virginia (41 FR 24062), and its

recovery plan was published in 1983 (FWS 1983a). This species was historically widespread in

the Cumberland and Tennessee river systems. The dromedary pearlymussel commonly is

found near riffles on sand and gravel substrates with stable rubble. Individuals also have been

found in slower waters and up to a depth of 5.5 m (18 ft). Most historic populations apparently

were lost when the river sections they inhabited were impounded. The more than

50 impoundments on the Tennessee and Cumberland Rivers eliminated the majority of riverine

habitat for this species in its historic range. TVA did not find the dromedary pearlymussel in the

bed closest to the WBN site (TRM 528.2 to TRM 528.9) in surveys conducted between 1983

and 1997, but it did find one specimen in the bed located at TRM 520.0 to TRM 520.8 once in

1983 (TVA 1998a). The occurrence data provided by TVA did not show this siting (TVA 2010a).

Rough Pigtoe - The FWS listed the rough pigtoe as endangered in 1976 (41 FR 24062), and

published a recovery plan in 1984 (FWS 1984a). Researchers have identified extant

populations in the Tennessee River tailwaters of Wilson Dam, where they are very rare, and

possibly in the tailwaters of Guntersville Dam (Mirarchi et al. 2004). During surveys conducted

near the WBN site, TVA found a single rough pigtoe in each of two surveys in 1983 and two in

the early survey of 1984. TVA reported a single individual rough pigtoe as recently as 1985 in

the mussel bed closest to the site (TRM 528.2 to TRM 528.9). The occurrence data from TVA

(TVA 201 Oa) indicated the presence of only one specimen from the surveys conducted between

1983 and 1984 at TRM 528.9.

Orangefoot Pnimpleback - The FWS has listed the orangefoot pimpleback, also known as the

Cumberland pigtoe (Mirarchi et al. 2004), as endangered since 1976 (41 FR 24062), and a

recovery plan was published in 1984 (FWS 1984b). The orangefoot pimpleback is primarily a

big river species found in silt-free areas in a mixture of sand and gravel. The species still

survives in the tailwaters of some Tennessee River dams, such as Pickwick Dam. TVA has not

September 2011 F. 1 -27 Draft NUREG-0498, Supplement 2
Appendix F

found the orangefoot pimpleback near the WBN site during surveys conducted in 1983 or since

that time (TVA 1998b). The occurrence data provided TVA shows that the nearest occurrence

of the orangefoot pimpleback was at TRM 595.0 in Watts Bar Reservoir in 1978 (TVA 201 Oa).

4.2.2.2 Snail Darter

The snail darter was classified as endangered on October 9, 1975 (40 FR 47506) and was

reclassified to threatened on July 5, 1984 (49 FR 27510). The FWS wrote a recovery plan in

1979, and updated it in 1982 (FWS 1983b). FWS believes that snail darters originally inhabited

the main stem of the Tennessee River and possibly ranged from the Holston, French Broad,

Lower Clinch, and Hiwassee Rivers downstream in the Tennessee drainage to northern

Alabama (FWS 1992). Etnier and Starnes (1993) report that it is likely that the snail darter

inhabited the main channel of the upper Tennessee River and the lower reaches of its major

tributaries; however, impoundments fragmented much of the species' range. In 1973, the snail

darter was thought to be restricted to the lower Little Tennessee River, with some additional

individuals dispersed into Watts Bar Reservoir below Loudon Dam. In 1975, TVA biologists

transplanted snail darters into the Nolichucky River until another jeopardized fish species was

found in that vicinity. In 1976, they transplanted snail darters into the lower Hiwassee River

and, during 1979 and 1980, into the lower Holston and Middle Elk Rivers. Subsequently, in

1988 and 1989, snail darters were collected from the lower French Broad and lower Holston

Rivers, respectively. However, the transplant attempts into the lower Holston and Middle Elk

rivers did not appear to be successful (Etnier and Starnes 1993). In 1980, an additional

population was discovered (estimated to number between 200 to 400 individuals) in South

Chickamauga Creek (between Creek Mile 5.6 in Tennessee [Hamilton County] and Creek Mile

19.3 in Georgia [Catoosa County]) (Etnier and Starnes 1993; TVA 2010a). Biologists also found

a few darters in the Tennessee River mainstream just below Chickamauga and Nickajack Dams

(FWS 1992). The upper Watts Bar Reservoir contained a population of snail darters, but the

population did not appear to be reproducing subsequent to the impoundment of the Tellico

Reservoir (Etnier and Starnes 1993). Individuals were found at TRM 591.4 as recently as 1976

and at TRM 597.2 as recently as 1982. They were also found as recently as 1979 in the Little

Tennessee River, which empties into the Watts Bar Reservoir. As recently as 1985, snail

darters inhabited Sewee Creek (Meigs County), which empties into-the Tennessee River just

south of the WBN site (TVA 201 Oa). They were identified as living from Creek Mile 3.2 to

Creek Mile 5.7. TVA has not observed snail darters since 1975 in any sampling they have

conducted in the upper Chickamauga Reservoir (TVA 1998b; Simmons and Baxter 2009).

Draft NUREG-0498, Supplement 2 F. 1-28 September 2011
Appendix F

5.0 Environmental Effects of WBN Unit 2

on Listed Species

Listed species could potentially be affected by the addition of the second nuclear unit as a result

of operational noise, water consumption, entrainment or impingement of fish or fish hosts from

the intake or as a result of chemical or thermal discharges to Guntersville Reservoir. The

potential environmental impact on the gray bat is discussed separately from that of the aquatic

species (freshwater mussels and snail darter).

5.1 Gray Bat

Because gray bats do not occur on the WBN site, the potential affect from WBN Unit 2

operations is minimal. The proximity of caves used by gray bats in summer to the site likely

means gray bats forage over the Tennessee River immediately adjacent to the site. In a

previous biological opinion for the operation of WBN Units 1 and 2, FWS determined that the

discharge of excess heat, chemicals, and radionuclides into the river would likely be the primary

threat to this species from the operation of WBN Units 1 and 2 (Widlak 1995). Discharge of

radioactive materials, chemicals, and other substances could have detrimental effects on larvae

of insect species that make up the gray bats' diet. Standards established within the NPDES

permit issued by the State of Tennessee are designed to prevent water quality degradation that

would result from unregulated discharge of pollutants into the Tennessee River. The NPDES

permit also governs monitoring and testing of discharges to ensure continued compliance with

permit requirements.

Operational noise also may preclude use of habitats near the WBN site by gray bats. Gray bats

forage while flying over open water, and emit sounds to detect flying insects via echolocation.

Bats may avoid noise when foraging (Schaub et al. 2008). Greater mouse-eared bats

(Myotis myotis) foraged most often in experimental chambers where neither broadband noise,

traffic noise, nor noise recorded in a noisy outdoor setting was broadcast. However, unlike gray

bats, mouse-eared bats forage by listening for sounds produced by non-flying prey while using

echolocation for navigation only. Anthropogenic (i.e., traffic) noise may mask sounds made by

ground-dwelling insects, while call frequencies of echolocating bats like the gray bat are above

frequencies produced by traffic (Jones 2008). Sound frequencies of operational noise and the

degree that operational noise may affect foraging gray bats are not known. However, the

portion of the Tennessee River adjacent to the WBN site that might experience operational

noise from Units 1 and 2 has not been identified as an especially important foraging area for

gray bats. Additionally, the displacement of gray bats from using this portion of the Tennessee

River for foraging would not noticeably affect gray bat populations that spend summers in

nearby caves.

September 2011 F. 1-29 Draft NUREG-0498, Supplement 2
Appendix F

Therefore, the staff concludes, as did FWS in 1995, that although the operation of WBN Unit 2,

within the bounds of the NPDES permit, may affect the Tennessee River, it would not jeopardize

the continued existence of the gray bat in the vicinity of the WBN site.

5.2 Freshwater Mussels and Snail Darters

Operations at the WBN Unit 2 site have the potential to affect freshwater mussels and fish in the

vicinity of the site as a result of water consumption, entrainment, impingement, and thermal and

chemical effects.

5.2.1 Water Consumption

As discussed in Section 3, the maximum annual plant consumption rate (amount of water that

will be consumed by WBN Unit 2) represents 0.1 percent of the mean annual flow of the

Tennessee River at Watts Bar Dam. This is small and will not measurably affect the habitat

available for Federally listed species.

5.2.2 Entrainment and Impingement

The SCCW intake pulls water from the reservoir above Watts Bar Dam. As a result, snail

darters or freshwater mussels residing below the dam would not be affected by continued

operation of the SCCW.

Although adult mussels are not susceptible to entrainment or impingement by the IPS, the fish

host on which the glochidia implants could be entrained or impinged. Hosts for the rough pigtoe

and the orange pimpleback have not been identified. The hosts for the pink mucket include

smallmouth, spotted, and largemouth bass, as well as freshwater drum and sauger. Less than

10 percent of the larval fish in the intake canal were drum, sauger, or bass (see Table 5-1).

Other fish present in the vicinity of the intakes, including any snail darters potentially present in

the Watts Bar or Chickamauga Reservoirs, also could be subject to entrainment and

impingement. As shown in Table 5-2, very small numbers of fish are impinged overall by the

IPS, with the exception of shad impinged between January 2011 and the first week of March

(TVA 201 1d). As a result, the NRC staff considers the likelihood that entrainment or

impingement from operation of WBN Unit 2 would affect the host for pink mucket glochidia

would be minimal. A variety of darters and sculpins are hosts for larval Eastern fanshell

pearlymussel and the dromedary pearlymussel. Except for the logperch, which is a host for the

Eastern fanshell, the other host fish for these two mussel species are not present based on

sampling studies as far back as 1975. Snail darters are not known to be present in the vicinity

of the WBN site.

Draft NUREG-0498, Supplement 2 F. 1 -30 September 2011
Appendix F

Table 5-1. Percent Composition of Dominant Larval Fish Taxa Collected in the CCW Intake

Channel during 1984 and 1985 and 1996 and 1997

Taxon

Aplodinotus grunniens

Centrachidae

Clupeidae

Dorosoma sp.

Morone (not saxatilis)

Morone sp.

Source: TVA 1998b

Common name

Freshwater drum

Sunfish

Unidentified shad

Threadfin or gizzard shad

Bass (not striped)

Bass

Percent Composition of

Larval Fish Taxa

Preoperational Operational

1984 1985 1996 1997

0.1 0.2 0.8 0.4

0.9 12.5 7.7 8.2

97.8 86.4 90.5 84.7

0.09 -- 0.8 0.2

0.6 0.5 0.09 0.9

0.5 0.5 0.09 5.6

Table 5-2. Actual and Estimated Numbers of Fish Impinged at WBN Plant during Sample

Periods from March 1996 through March 1997, March 1997 through October 7,

1997 and during March 2010 through March 2011

March 1996 - March 1997 and

March 1997 - October 1997 March 2010 - March 2011

Actual Total Annual

Number Estimated Percent

Impinged Number Composition Total

Sampling Sampling Sampling Actual Annual

Common Period Period Period Number Estimated Percent

Name 1 2 1 2 1 2 Impinged Number Composition

Gizzard 4 0 41 0 25% 0% 1,172 8,204 60.4%

shad

Threadfin

shad

Freshwater

drum

Channel

catfish

Flathead

catfish

Bluegill

Redear

sunfish

White

crappie

2 0 20 0 12.5% 0%

3 3 30 31 18.7% 75%

1 0 10 0 6.3% 6.3%

1 0 10 0 6.3% 0%

766 5,362 39.5%

0

0

0

0

0

0

0

0

0

0

0

0

0%

0%

0%

0%

0%

0%

2

1

0

0

20

10

0

0

12.5%

6.2%

0%

0%

2 0 20 0 12.5% 0%

September 2011 F. 1-31 Draft NUREG-0498, Supplement 2
Appendix F

Table 5-2. (contd)

March 1996 - March 1997 and

March 1997 - October 1997 March 2010 - March 2011

Actual Total Annual

Number Estimated Percent

Impinged Number Composition Total

Sampling Sampling Sampling Actual Annual

Common Period Period Period Number Estimated Percent

Name 1 2 1 2 1 2 Impinged Number Composition

Log perch 0 1 0 10 0% 25% 0 10.2 0%

Inland 0 0 0 0 0% 0% 1 0.1%

silverside

Total 16 4 161 41 100% 100% 1,939 13,573 100%

Source: TVA 1998a; TVA 2011d

5.2.3 Thermal and Chemical Effects

The current NPDES permit issued by the State of Tennessee for Unit 1 specifies limits on the

amount of thermal effluent the plant may discharge into the Tennessee River, establishes an

active mixing zone, and defines in-stream monitoring and reporting requirements necessary to

comply with effluent limitations. The additional increment for flow of the SCCW is approximately

14 percent of the current amount of heat discharged. The measurements and model indicate

that the plume rises after hitting the concrete pad located at the end of the discharge, allowing

room underneath for fish passage and not directly affecting the freshwater mussels.

In an effort to limit the impact to the mussels in the vicinity. of the SCCW discharge, a mussel

relocation zone was established that extended 46 m (150 ft) from the right bank and 23 m (75 ft)

upstream and downstream of the centerline of Outfall 113. The area was surveyed for mussels

in 1997. The only Federally protected mussel identified was a single specimen of the pink

mucket. The freshwater mussels that were in an area of 46 m by 46 m (150 ft by 150 ft) at the

outlet to the SCCW system (23 m [75 ft] upstream and downstream of the centerline of

Outfall 113) were relocated before the startup of the SCCW (TVA 1999). TVA moved these

mussels in an effort to prevent adverse effects from operation of the SCCW system discharge.

In addition, TVA placed a ramp on the invert of the SCCW outfall to deflect the discharge

upward, and away from the bottom of the river (TVA 2004a). The analysis of in-stream data

collected by TVA for Outfall 113 showed that heat from the SCCW effluent does not reach the

bottom in significant amounts (TVA 2004a).

Draft NUREG-0498, Supplement 2 F. 1-32 September 2011
Appendix F

TVA also conducted field studies to confirm the diffuser performance for Outfall 101 (TVA

1998a). To provide adequate dilution of the plant effluent, TVA permits the diffusers to

discharge water only when Watts Bar Dam releases at least 99 m3/s (3,500 cfs). This policy will

remain the same when both units are operating. The location and design of the diffuser

discharge should not impede fish passage up and down the Tennessee River. Fish (including

darters) and other organisms likely would avoid the warmer water, but mussels and benthic

organisms would not be able to avoid the elevated temperatures. However, as indicated, the

diffuser's plume angles upward at 45 degrees above horizontal in the downstream direction, and

as a result, the plume would not have much of an effect on the mussels and other benthic

organisms in the area of or immediately downstream of the diffuser.

TVA conducted hydrothermal surveys (combined with ichthyoplankton surveys) in May 2010 to

coincide with the period of expected peak abundance of ichthyoplankton and in August 2010 to

coincide with the near maximum ambient water temperatures. TVA mapped and tracked the

thermal plume from discharge Outfall 113 at a time when there were no releases from the Watts

Bar Dam, showing that the plume remained near the surface and spread across the river.

During periods of normal release from Watts Bar Dam, the plume remains near the right

descending bank. Based on the ichthyoplankton taxa collected, thermal tolerance data, river

temperatures, and exposure times, TVA concluded, "there is essentially no risk of thermal

damage to ichthyoplankton during no-flow conditions" from the dam (TVA 2011 e)

According to NPDES permit requirements, TVA conducts biotoxicity tests (i.e., 3-brood

Ceriodaphnia dubia survival and reproduction tests and 7-day fathead minnow (Pimephales

promelas) larval survival and growth tests) on samples of final effluent from Outfalls 101, 102,

112, and 113. The NRC staff reviewed 12 years of toxicity testing data provided in the NPDES

permit request (TVA 2009c). The data showed that percentage survival in the highest

concentration tested for 96-hour survival was a mean of 92.8 percent for Outfall 101 and

99 percent survival for Outfall 113. Based on the results of these tests and the lack of changes

from the quantity of chemicals that would be discharged, the NRC staff determined that the

aquatic biota of Chickamauga Reservoir would not be affected by chemical discharges resulting

from the additional operation of WBN Unit 2.

5.3 Summary

Based on the information provided in this section of the BA, the staff determines that there

would be no adverse impact to threatened and endangered species from noise, cooling tower

operation, water consumption, entrainment, impingement, and thermal, and chemical discharge

operations of WBN Unit 2.

September 2011 F. 1-33 Draft NUREG-0498, Supplement 2

Appendix F

6.0 Cumulative Impacts

The NRC staff considered potential past, present, and reasonably foreseeable activities that

could have cumulative effects on Federally protected species in conjunction with operating

another nuclear unit at the WBN site.

6.1 Terrestrial Species (Gray Bat)

For this analysis, the geographic area of interest includes all of Rhea and Meigs Counties and

lands of Hamilton, Bradley, McMinn, Roane, Anderson, Knox, Blount, and Loudon Counties that

occur within 0.8 km (0.5 mi) of the transmission line system that would support WBN Unit 2.

Based on the nature of the potential impacts and attributes of the affected terrestrial resources,

these counties would bound the area expected to be affected by the operation of WBN Unit 2.

WBN Unit 2 is co-located with WBN Unit 1. Operation of Unit 1 produces a visible vapor plume

and operational noise. However, because of the nature of the effects from operating Unit 2, the

synergistic effect of operating both units is not expected to affect the gray bat any more than the

operation of a single unit.

Little is known about a phenomenon known as white-nose syndrome that has caused massive

mortality of many bat species in the northeastern United States. (Cohn 2008). The name comes

from a white Geomyces fungus that grows on affected bats' muzzles. White-nose syndrome

has affected at least six species of bats and has been confirmed in at least eight U.S. states,

including Tennessee, and three Canadian provinces (FWS 2010b). The mortality rate of

affected bats is high, with bat colony reductions in infected caves over 90 percent. White-nose

syndrome afflicts at least six bat species, and it may be affecting gray bats (FWS 2010c).

Because little is known about white-nose syndrome, the extent that it may affect the gray bat

population is still unknown.

6.2 Aquatic Species

Historically, the Tennessee River was free flowing and flooded annually. Before 1936, the few

power dams that obstructed- streams in Tennessee backed up relatively small impoundments.

In 1936, TVA completed Norris Reservoir, its first reservoir on the Tennessee River. Currently,

TVA operates nine dams on the Tennessee River. The dams have fragmented the watershed,

and the isolation and stress dams have imposed on tributaries of the river have caused and will

continue to cause extirpation of fish (such as the snail darter) and freshwater mussels.

September 2011 F. 1-35 Draft NUREG-0498, Supplement 2
Appendix F

Historically, species introduced after building the dams, over fishing of species such as

paddlefish, harvesting of mussels, toxic spills, mining, and agriculture have affected the fish

fauna.

Impacts on aquatic biota from operations at both WBN Unit 1 and Unit 2 are difficult for NRC

staff to separate, because both units share the same intake and discharge systems. The

makeup flow rate through the IPS would be almost twice that for the single unit operation. The

intake flow rate for the SCCW when both units are operating would be less than that for

operating a single unit. The volume of water returned to the river through the SCCW discharge

would be less because of greater amounts of water evaporation. Watts Bar Units 1 and 2

together would consume 1.7 m3/s (61 cfs) of water, which is approximately 0.2 percent of the

mean flow past the WBN site. This would result in an increase of less than 10 percent from the

current consumptive use of WBN Unit 1 (see Table 3.1).

Other facilities also have adverse impacts on the aquatic biota of Watts Bar and Chickamauga

Reservoirs by entrainment, impingement, or thermal, chemical, or physical discharges. These

facilities include Watts Bar Dam (TRM 529.9), which is immediately upstream of the facility

(the SCCW intake is located on the dam); Sequoyah Nuclear Plant, which is located on the

Chickamauga Reservoir (TRM 484.5); the Kingston Fossil Plant, which is located at the junction

of Emory River and Clinch River (approximately 69 river kilometers [42 river miles]); and

Oak Ridge National Laboratory, which is located on the Clinch River (approximately 89 river

kilometers [55 river mile]) upstream of Watts Bar Dam. The facility that has the greatest effect

on the freshwater mussels would be the Watts Bar Dam. Watters (1999) points to

impoundments, dredging, snagging, and channelization as having long-term detrimental effects

on freshwater mussels. The impoundments result in silt accumulation, loss of shallow-water

habitat, stagnation, pollutant accumulation, and nutrient-poor water.

Draft NUREG-0498, Supplement 2 F. 1-36 September 2011
Appendix F

7.0 Conclusions

The potential impacts of the operation of WBN Unit 2 on Federally protected species near the

site have been evaluated. This BA considers the known distributions and records of those

species, and the potential ecological impacts of facility operations on those species. Based on

this review, the NRC staff reached the following conclusions:

Operation of proposed Unit 2 at the WBN site may affect foraging for a small number of gray

bats. However, the portion of the Tennessee River adjacent to the WBN site that may

receive operational noise has not been identified as an especially important foraging area

for gray bats. Gray bat avoidance of this portion of the Tennessee River for foraging would

not noticeably affect populations that spend summers in nearby caves. Therefore, the staff

concludes, as did FWS in 1995, that although the operation of WBN Unit 2 may affect the

Tennessee River, it would not jeopardize the continued existence of the gray bat in the

vicinity of the WBN Site. Therefore, the NRC staff concludes that direct, indirect,or

cumulative impacts from the operation of WNB Unit 2 are not likely to adversely affect the

gray bat.

" Operation of the proposed Unit 2 may affect the pink mucket mussel that is known to

potentially be present in the vicinity of the WBN site. The impact of entrainment or

impingement is not likely to affect the survival of the pink mucket because of the low fraction

of water withdrawn and the low demonstrated rates of entrainment and impingement from

the intake in the Chickamauga Reservoir. Although thermal discharges may affect the pink

mucket, this is unlikely from the discharge of the SCCW as a result of the relocation of

freshwater mussels near the outlet of the SCCW discharge system. It is also unlikely at the

IPS discharge because of mitigative strategies enacted by the applicant, such as the use of

diffusers only when Watts Bar Dam releases at least 99 m3

/s (3,500 cfs) and the orientation

of the diffuser plume (45 degrees above horizontal in the downstream direction). Further,

based on a review of 12 years of toxicity testing data provided in the NPDES permit request

(TVA 2009b) it is unlikely that chemical discharges will affect the pink mucket mussel. Thus,

the NRC staff concludes that operation of the proposed Unit 2, even in addition to the

operation of Unit 1, is not likely to adversely affect the pink mucket.

" Operation of the proposed Unit 2 is not likely to affect the Eastern fanshell mussel because

they are likely no longer present in the vicinity of the WBN site. The last Eastern fanshell

was found in 1985 in the mussel bed nearest the WBN site (TRM 528.2 to TRM 528.9). It

was not seen in any of the following 10 surveys that were conducted in the vicinity or

downstream of the WBN site between 1985 and 1997, or in the survey conducted in 2010.

Therefore, the NRC staff concludes that operation of WNB Unit 2, even in addition to the

operation of Unit 1, will have no effect on the Eastern fanshell mussel.

September 2011 F. 1-37 Draft NUREG-0498, Supplement 2
Appendix F

" Operation of the proposed Unit 2 is not likely to affect the rough pigtoe because the species

probably is no longer present in the vicinity of the WBN site. The last rough pigtoe was

observed in Chickamauga Reservoir near the site in 1985. TVA conducted seven additional

surveys of the mussel beds downstream of the WBN site between 1985 and 1997, and one

in 2010 without observing a live rough pigtoe mussel. Therefore, the NRC staff concludes

that operation of WNB Unit 2 will have no effect on the rough pigtoe mussel.

* Operation of the proposed Unit 2 is not likely to affect the dromedary pearly mussel

because they probably are no longer present in the vicinity of the WBN site. The most

recent observation of a dromedary pearly mussel occurred in 1983. Additional surveys were

conducted annually over the next 14 years, with an additional survey in 2010 and no

specimens of the dromedary pearly mussel were identified. Therefore, the NRC staff

concludes that operation of WNB Unit 2 will have no effect on the dromedary pearly mussel.

* The orangefoot pimpleback mussel has not been reported from the vicinity of the proposed

Unit 2 during any of the surveys conducted since 1983. Therefore, the NRC staff concludes

that operation of WNB Unit 2 will have no effect on the orangefoot pimpleback mussel.

* Operation of the proposed Unit 2 is unlikely to affect the snail darter because they have not

been observed in Chickamauga Reservoir in the vicinity of the WBN site. The population

that was identified as recently as 1985 as living in Sewee Creek from Creek Mile 3.2 to

Creek Mile 5.7 could possibly still be located in the creek since no additional studies were

found to have been conducted since that time. However, operation of the proposed Unit 2

would be unlikely to affect a population located in Sewee Creek. Therefore, the NRC staff

concludes that operation of WNB Unit 2 will have no effect on the snail darter.

Draft NUREG-0498, Supplement 2 F. 1-38 September 2011
Appendix F

8.0 References

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Species". Federal Register. U.S. Department of the Interior.

41 FR 17736. April 28, 1976. "Determination that Two Species of Butterflies are Threatened

Species and Two Species of Mammals are Endangered Species." Federal Register.

U.S. Department of the Interior.

41 FR 24062. June 14, 1976. "Endangered and Threatened Wildlife and Plants; Endangered

Status for 159 Taxa of Animals." Federal Register. U.S. Department of the Interior.

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55 FR 25591. June 21, 1990. "Endangered and Threatened Wildlife and Plants; Designation of

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76 FR 3392. January 19, 2011. "Endangered and Threatened Wildlife and Plants; Endangered

Status for the Sheepnose and Spectaclecase Mussels. Proposed Rule." Federal Register.

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Cohn, J.P. 2008. "White-nose Syndrome Threatens Bats." BioScience 58(11).

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Etnier, D.A. and W.C. Starnes. 1993. The Fishes of Tennessee. University of Tennessee

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Harvey, M.J. and E.R. Britzke. 2002. Distribution and Status of Endangered Bats in

Tennessee. Tennessee Wildlife Resources Agency, Nashville, Tennessee.

Jones, G. 2008. "Sensory Ecology: Noise Annoys Foraging Bats." Current Biology

18(23):R1099.

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Management, Chattanooga, Tennessee. Accession No. ML073510313.

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TVA/ONRED/WRF-87/1a. Knoxville, Tennessee. Accession No. ML073510313.

Tennessee Valley Authority (TVA). 1997. Watts Bar Nuclear Plant Supplemental Condenser

Cooling Water Project, Thermal Plume Modeling. Norris, Tennessee.

Tennessee Valley Authority (TVA). 1998a. Watts Bar Nuclear Plant Supplemental Condenser

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Draft NUREG-0498, Supplement 2 F. 1-40 September 2011
Appendix F

Tennessee Valley Authority (TVA). 1998b. Aquatic Environmental Conditions in the Vicinity of

Watts Bar Nuclear Plant During Two Years of Operation, 1996-1997. Norris, Tennessee.

Accession No. ML073510313.

Tennessee Valley Authority (TVA). 1999. July 1999 Verification Study of Thermal Discharge

for Watts Bar Nuclear Plant Supplemental Condenser Cooling Water System. WR99-2-85-143.

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Existing Facilities - Proposal for Information Collection for Supplemental Condenser Cooling

Water (SCCW) System." Accession No. ML052150033.

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Accession No. ML073510313.

Tennessee Valley Authority (TVA). 2006. Summer 2005 Compliance Survey for Watts Bar

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Accession No. ML073510313.

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Authority, Chief Operating Officer) to U.S. Nuclear Regulatory Agency dated August 3, 2007,

"Watts Bar Nuclear Plant (WBN) - Unit 2 - Reactivation of Construction Activities." Accession

No. ML072190047.

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Tennessee Valley Authority (TVA). 2007c. Winter 2006 Compliance Survey for Watts Bar

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September 2011 F. 1-41 Draft NUREG-0498, Supplement 2
Appendix F

Tennessee, submitted to NRC as the TVA Environmental Report for an Operating License,

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Vice President) to U.S. Nuclear Regulatory Commission dated March 4, 2009, "Watts Bar

Nuclear Plant (WBN) Unit 2 - Operating License Application Update." Accession

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Safety Analysis Report (FSAR). Amendment 94, Spring City, Tennessee.

Tennessee Valley Authority (TVA). 2009c. Letter from Darrin Hutchison (Tennessee Valley

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(WBN) - National Pollutant Discharge Elimination System (NPDES) Permit No. TN0020168 -

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Tennessee Valley Authority) to U.S. Nuclear Regulatory Commission dated July 6, 2010,

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Draft NUREG-0498, Supplement 2 F. 1-42 September 2011
Appendix F

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Commission (NRC) Request for Additional Information (RAI) Regarding Environmental Review."

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Tennessee Valley Authority (TVA). 2011 b. Letter from David Stinson (Watts Bar Unit 2) to

U.S. 11 Nuclear Regulatory Commission dated May 19, 2011, "Watts Bar Nuclear Plant (WBN)

Unit 2 -Intake Pumping Station Water Velocity - Response to Request for Additional

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Tennessee Valley Authority (TVA). 2011 c. Letter from David Stinson (Watts Bar Unit 2, Vice

President) to U.S. Nuclear Regulatory Commission dated March 24, 2011, "Watts Bar Nuclear

Plant (WBN) Unit 2 - Additional Information Related to U.S. Nuclear Regulatory Commission

(NRC) Regarding Environmental Review." Accession No. ML1 10871475.

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Bar Nuclear Plant (WBN) Unit 2 - Additional Information Related to U.S. Nuclear Regulatory

commission (NRC) Environmental Review." Accession No. ML1 10890472

Tennessee Valley Authority (TVA). 201 le. Letter from Marie Gillman (Watts Bar Unit 2, Vice

President, Acting) to U.S. Nuclear Regulatory Commission dated February 7, 2011, "Submittal

of 'Hydrothermal Effects on the Ichthyoplankton from the Watts Bar Nuclear Plant Supplemental

Condenser Cooling Water outfall in Upper Chickamauga Reservoir' Report." Accession Nos.

ML1 10400383, ML1 10400384.

U.S. Fish and Wildlife Service (FWS). 1983a. Dromedary Pearly Mussel Recovery Plan.

Atlanta, Georgia.

U.S. Fish and Wildlife Service (FWS). 1983b. Snail Darter Recovery Plan. Atlanta, Georgia.

U.S. Fish and Wildlife Service (FWS). 1984a. Rough Pigtoe Pearly Mussel Recovery Plan.

Atlanta, Georgia.

U.S. Fish and Wildlife Service (FWS). 1984b. Orange-footed Pearly Mussel Recovery Plan.

Atlanta, Georgia.

U.S. Fish and Wildlife Service (FWS). 1985. Recovery Plan for the Pink Mucket Pearly Mussel,

Lampsilis obiculata (Hildreth, 1828). Atlanta, Georgia.

September 2011 F. 1 -43 Draft NUREG-0498, Supplement 2
Appendix F

U.S. Fish and Wildlife Service (FWS). 1991. Recovery Plan for Fanshell (Cyprogenia stegaria

(= C. irrorata)). Atlanta, Georgia.

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(Imostoma) tanasi)." In Endangered and Threatened Species of the Southeastern United

States: The Red Book. Accessed December 22, 2009 at

http://www.fws.gov/cookeville/docs/endspec/snldtrsa. html.

U.S. Fish and Wildlife Service (FWS). 2009. Letter from Mary E. Jennings (Field Supervisor) to

U.S. Nuclear Regulatory Commission dated October 29, 2009, "FWS #2009-SL-0885. Watts

Bar Nuclear Plant, Unit 2 - Request for list of Protected Species, Rhea County, Tennessee."

Accession No. ML0929301820.

U.S. Fish and Wildlife Service (FWS). 2010a. "Dromedary Pearlymussel - Dromus dromas."

Accessed May 17, 2010 at http://ecos.fws.gov/docs/life-histories/FOOK.html.

U.S. Fish and Wildlife Service (FWS). 2010b. White-Nose Syndrome. Accessed May 26, 2010

at http://www.fws.govANhiteNoseSyndrome/about.html.

U.S. Fish and Wildlife Service (FWS). 2010c. The White-nose Syndrome Mystery-Something is

Killing Our Bats. Available at http://www.fws.gov/WhiteNoseSyndrome/pdfI~hitenosejmystery.pdf.

U.S. Fish and Wildlife Service (FWS). 2011. "Sheepnose (a freshwater mussel) - Plethobasus

cyphyus)." Accessed March 28, 2011 at

http://www.fws.gov/midwestlendangered/clams/sheepnose/SheepnoseFactSheetJan20l 1. html.

U.S. Nuclear Regulatory Commission (NRC). 1978. Final Environmental Statement Related to

Operation of Watts Bar Nuclear Plant Units Nos. I and 2. NUREG-0498, Washington, D.C.

Accession No. ML082540803, ML082560293, ML082560292, ML082560291, ML082560289.

U.S. Nuclear Regulatory Commission (NRC). 1995. Final Environmental Statement Related to

the Operation of Watts Bar Nuclear Plant, Units 1 and 2. NUREG-0498 Supplement No. 1,

Washington, D.C. Accession No. ML081430592.

U.S. Nuclear Regulatory Commission (NRC). 2009. Letter from U.S. Nuclear Regulatory

Commission to M.E. Jennings (Field Supervisor, U.S. Fish and Wildlife Service) dated

September 2, 2009. "Watts Bar Nuclear Plant, Unit 2- Request for List of Protected Species

within the Area under Evaluation for the Operating License Application Environmental Review."

Accession No. ML092100088.

Draft NUREG-0498, Supplement 2 F. 1-44 September 2011
Appendix F

Watters, G.T. 1999. "Freshwater Mussels and Water Quality: A Review of the Effects of

Hydrologic and Instream Habitat Alterations." In Proceedings of the First Freshwater Mollusk

Conservation Society Symposium. Ohio Biological Survey, Columbus, Ohio.

Widlak, J.C. 1995. Biological Opinion for the Proposed Operation of the Watts Bar Nuclear

Plant-Rhea County, Tennessee. U.S. Fish and Wildlife Service. Ecological Services Field

Office, Cookeville, Tennessee.

September 2011 F. 1-45 Draft NUREG-0498, Supplement 2

Appendix G

List of Authorizations, Permits, and Certifications

Appendix G

List of Authorizations, Permits, and Certifications

September 2011 G-1 Draft NUREG-0498, Supplement 2
0

z

C)

CC)

CD

(D

X

G)

1 Table G-1. Federal, State, and Local Authorizations

Agency Authority Phase/Requirement/Status Activity Covered

U.S. Nuclear

Regulatory

Commission

(NRC)

NRC

U.S. Fish and

Wildlife Service

(FWS)

Title 10 of the Code

of Federal

Regulations (CFR)

Part 50

10 CFR Part 50

16 U.S.C. §§ 1531 et

seq.

U.S.

G) Department of

rs, the Interior

(DOI)

Federal

Aviation

Administration

(FAA)

U.S Coast

Guard

Tennessee

Department of

Environment

and C,,

Conservation

(TDEC)

42 U.S.C. § 1996; 25

U.S.C. § 3001 et seq.

14 CFR Part 77

14 U.S.C. §§ 81, 83,

85, 633; 49 U.S.C. §

1655(b).

Water Quality

Control Act, TCA §§

69-3-101 et seq.

Preconstruction. Construction Permit

CPPR-92 EXP: 31 DEC2013.

OL Submittal. Updated license

application filed 04MAR2009.

SFES. Concurrence. 1995

consultation with FWS, cited in SFES

Appendix D, applied to WBN Unit 1

and WBN Unit 2. 2007 SFES also

found no impacts.

SFES. Consultation. Consultation

not required as SFES did not identify

any items of cultural significance to

Native American tribes.

Preconstruction. Notification not

required as no activities affect

structures over 60 m (200 ft).

Preconstruction. Authorization not

required as no activities affect

navigation.

Preoperation. Certification. TVA will

seek any required certification from

TDEC prior to issuance of the OL.

Identification, protection, and repatriation of items of

cultural significance to Native American tribes.

Preconstruction letter of notification to FAA results in a

written response certifying that no hazards exist or

recommending project modification.

Navigation markers authorization to protect river navigation

from hazards connected with temporary construction

activities in a river.

Aquatic resource alteration permit for any alteration of the

properties of State waters. This permit also serves as a

Section 401 water quality certification, which is required

prior to seeking a Federal permit or license, including an

operating license from the NRC.

Permit for construction of a utilization facility.

Operation of a utilization facility for commercial purposes.

Consultation concerning potential impacts to Federal

threatened & endangered species.

3

(D

C, 0

2
CD

CD

(D

N)

C)

Table G-1. (contd)

Agency Authority PhaselRequirement/Status Activity Covered

(D

GI) 0.

0u

U.S. Army

Corps of

Engineers

(USACE)

TDEC Air

Division

TDEC Air

Division

33 U.S.C. § 1344; 33

U.S.C. §§ 1341

Tennessee Air

Quality Act, TCA §§

68-201-101 et seq.

42 U.S.C. §§ 7401 et

seq.

TCA §§ 68-201-101

42 U.S.C. §§ 7401 et

seq. G)

Preconstruction. Permit. USACE

stated, as listed in SFES Appendix D,

that a Section 404 permit is not

required as no work requires

discharge of dredged or fill material.

Preconstruction. Construction permit.

Permit 957606P held by TVA. EXP:

01JAN2007 Renewal pending.

Requested update and consolidation

with operating permit 448529 on

23JAN2007.

Preoperation. Operating permit.

Permit 448529 held by TVA. EXP:

01SEP2010.

Continuing permit requirement.

National Pollutant Discharge

Elimination System Permit

TN0020168 held by TVA. EXP:

31 DEC2011.

Continuing permit requirement.

Industrial Storm Water Multi-Sector

General Permit TNR050000 held by

TVA. EXP: 14MAY2014.

Preconstruction. Permit. Not

required, as no construction activities

planned that would result in storm

water discharge.

Section 404 permit required for discharge of dredged and

fill material. A Section 401 certification that the action does

not violate state water quality standards is required prior to

obtaining a Section 404 permit.

Construction permit for prevention of significant

deterioration of air quality required to construct an air

contaminant source.

This permit covers emissions from the WBN site for both

Unit 1 and Unit 2 equipment. TVA - WBN opted out of

major source - Not a Title V Permit.

Facility permit for point source discharges of wastewater to

surface waters and in-stream monitoring Unit 1 only -

Permit modification request to include Unit 2 was filed in

with TDEC in August 2010.

Permit for discharge of storm water associated with land

disturbance and industrial activity.

Permit for discharge of storm water associated with

construction involving clearing, grading or excavation that

result in an area of disturbance of one or more acres, and

activities that result in the disturbance of less than one

acre if it is part of a larger common plan of development.

TDEC Water 42 U.S.C. § 1342;

Division TCA §§ 69-3-101 et

seq.

z

m

C)

co

CD

3

CD

TDEC Water

Division

TDEC Water

Division

33 U.S.C. §1342;

TCA §§ 69-3-101 et

seq.

33 U.S.C. §1342;

TCA §§ 69-3-101 et

seq.
0

z

6)

00

C,,

CD

CD

Table G-1. (contd) CD

Agency Authority Phase/Requirement/Status Activity Covered G)

TDEC Division

of Solid and

Hazardous

Waste

Management

(SHW)

"3 TDEC Division

Nof SHW

Alabama

Department of

Environmental

o Management

(ADEM)

TDEC Division

UST or Solid

and Hazardous

Waste

Tennessee

Historical

Commission

(THC) (State

Historic

Preservation

Officer)

Tennessee

C,,

CD Public Service

-0, Commission

CD3

CD

Tennessee Solid

Waste Disposal Act,

TCA §§ 68-211-101

et seq.

TCA §§ 68-212

ADEM Admin. Code

R. 335-14

TCA §§ 68-212

16 U.S.C. §§ 470 et

seq. 36 CFR Part

800

Preoperation. Permit. Permit number

DML72-103-0025 held by TVA. EXP:

N/A.

EPA Facility ID TN2640030035

Construction Demolition Landfill

Permit Number DML 721030025 EXP:

N/A.

Ongoing. Permit. Operation Permit

AL2-640-090-005 held by TVA. EXP:

06MAY201 1.

Preconstruction/operation. Permit.

Not required as no underground

storage tanks as defined by TDEC.

Preoperation. Consultation.

Consultation with THC completed and

documented in SFES Appendix D

(TVA ER 2008).

Site Permit for operation of a Class IV disposal facility

(onsite construction & demolition landfill).

Transportation of waste.

Storage of hazardous waste at the hazardous waste

storage facility in Muscle Shoals, AL.

Installation/operation of underground storage tanks that

store regulated substances.

Review and analysis of cultural and historic resources,

including completion of National Historic Preservation Act

of 1966, as amended, Section 106 consultation.

Operation. Certification not required. Certificate of public convenience and necessity.
C,)

CD

-a

CD

3

0r

CD

C)

G)

Table G-1. (contd)

Agency Authority Phase/Requirement/Status Activity Covered

TVA Executive Order SFES. Completed. Protect and enhance the quality of the environment;

11514 (Protection develop procedures to ensure the fullest practicable

and Enhancement of provision of timely public information and understanding of

Environmental Federal plans and programs that may have potential

Quality) 40 CFR environmental impacts that the views of interested parties

Parts 1500-1508 can be obtained.

TVA Executive. Order SFES. Completed. Floodplain impacts to be avoided to the extent practicable.

11988 (Floodplain

Management) WVA

Procedure for

Compliance With

NEPA, Section 5.7

TVA Executive Order SFES. Completed. Requires Federal agencies to avoid any short- and long11990 (Protection of term adverse impacts on wetlands wherever there is a

Wetlands) WVA practicable alternative.

Procedure for

Compliance With

NEPA, Section 5.7

"10

"10

CD

:.

XC°

I

z

G)

Co

co

C,)

C:

(D

3

CD

K)
Vi
Appendix H

Severe Accident Mitigation Design Alternatives

July 2011 H-1 Draft NUREG-0498, Supplement 2
Appendix H

Appendix H

U.S. Nuclear Regulatory Commission Staff Evaluation of

Severe Accident Mitigation Design Alternatives (SAMDAs) for

Watts Bar Nuclear Plant Unit 2 in

Support of Operating License Application Review

H.1 Introduction

Tennessee Valley Authority (TVA) submitted an initial assessment of severe accident mitigation

design alternatives (SAMDAs)1 for the Watts Bar Nuclear Plant Unit 2 (WBN2) as part of the

Final Supplemental Environmental Impact Statement for the Completion and Operation of WBN

Unit 2 (TVA 2009). This assessment was based on the most recent WBN Unit 1 probabilistic

risk assessment (PRA) available at the time of the assessment modified to reflect expected two

unit operation. Subsequently TVA submitted an updated SAMDA assessment utilizing the latest

Computer Aided Fault Tree Analysis (CAFTA) based dual unit PRA (TVA 2010a). In addition to

these plant-specific PRAs, the SAMDA assessments were based on a plant-specific offsite

consequence analysis using the MELCOR Accident Consequence Code System 2 (MACCS2)

computer code, as well as insights from the WBN Unit 1 individual plant examination (IPE) (TVA

1992), the WBN Unit 1 individual plant examination of external events (IPEEE) (TVA 1998), and,

in the updated assessment, the WBN Unit 2 IPE (TVA 2010b). In identifying and evaluating

potential SAMDAs, TVA considered SAMDA candidates that addressed the major contributors

to core damage frequency (CDF) and large early release frequency (LERF) at WBN, as well as

severe accident mitigation alternative (SAMA) candidates for operating plants which have

submitted license renewal applications. TVA identified 283 potential SAMDA candidates in the

original submittal and 24 additional SAMDA candidates in the updated submittal. This

combined list was reduced to 38 unique SAMDAs by eliminating SAMDAs that (1) are not

applicable at WBN because of design differences, (2) have already been implemented at WBN,

(3) are similar in nature and could be combined with another SAMDA candidate, (4) have

estimated costs that would exceed the dollar value associated with completely eliminating all

severe accident risk at WBN or (5) were determined to provide very low benefit. TVA assessed

the costs and benefits associated with each of the potential SAMDAs, and concluded that

several of the candidate SAMDAs evaluated are potentially cost-beneficial.

Based on a review of the SAMDA assessments, the U.S. Nuclear Regulatory Commission

(NRC) issued requests for additional information (RAls) to TVA by letters dated November 30,

1 While the TVA submittals generally refer to potential enhancements at WBN2 as severe accident

mitigation alternatives (SAMAs), which is the phrase used in license renewal applications, this appendix

refers to the potential enhancements as severe accident mitigation design alternatives (SAMDAs). The

term SAMDA is the appropriate phrase for the WBN2 assessment since it is for the operating license

stage.

H-2
Appendix H

2009 (NRC 2009),January 11, 2011 (NRC 201 1a), March 30, 2011 (NRC 201 1b) and June 13,

2011 (NRC 2011 c). Key questions concerned: major plant and modeling changes incorporated

within each evolution of the PRA model; justification for the multiplier used for external events;

binning and structure of the Level 2 and Level 3 analyses; resolution of peer review findings;

basis for the source term used for the release categories; incorporation of computer code

corrections into the Level 3 analysis; process for identifying plant-specific SAMDAs to address

internal event risk; identification of SAMDAs to mitigate fire risk; and further information on

several specific candidate SAMDAs and low cost alternatives. TVA submitted additional

information by letters dated July 23, 2010 (TVA 201 Oc), September 17, 2010 (TVA 201 Od),

January 31, 2011 (TVA 2011a), May 13, 2001 (TVA 2011b), May 25, 2011 (TVA 2011c), June

17, 2011 (TVA 2011d), June 17, 2011 (TVA 2011e), September 16, 2011 (TVA 2011f), and

October 17, 2011 (TVA 201 lg). In response to the RAIs, TVA provided: additional information

regarding the PRA model development and resultant changes to dominant risk contributors to

CDF; additional justification for the treatment of external events; a more detailed description of

the Level 2 and Level 3 analyses; justification for the release categories and associated

consequence development; information on resolution of peer review findings; information on 31

additional SAMDA candidates; additional information regarding several specific SAMDAs; and

the impact of uncertainty on the Phase I screening of SAMDAs. The responses also included

revised results of the SAMDA analysis (incorporating updated computer codes, revised release

category characterization, a revised external events multiplier and a revised Level 3

consequence analysis) based on several corrections/changes to the SAMDA analysis contained

in the original and updated submittal (TVA 2011a, TVA 201 1f, TVA 2011g). TVA's responses

and the revised SAMDA analysis addressed the NRC staff's concerns.

An assessment of the SAMDAs for WBN2 is presented below.

H.2 Estimate of Risk for WBN Unit 2

TVA's estimates of offsite risk at WBN Unit 2 are summarized in Section H.2. 1. The summary is

followed by the NRC staff's review of TVA's risk estimates in Section H.2.2.

H.2.1 TVA's Risk Estimates

Two distinct analyses are combined to form the basis for the risk estimates used in the SAMDA

analysis: (1) the WBN Level 1 and 2 dual unit PRA model, which is updated from the Unit 2 IPE,

and (2) a supplemental analysis of offsite consequences and economic impacts (essentially a

Level 3 PRA model) developed specifically for the SAMDA analysis. The updated SAMDA

analysis is based on the most recent WBN Level 1 and Level 2 PRA models available at the

time of the assessment, referred to as the WBN Ul U2 FLOODSAMA model (TVA 2010a).

This model is referred to as the SAMDA model throughout this appendix. The scope of the

WBN PRA does not include external events.

The WBN2 CDF is approximately 1.7 x 10-5 per year for internal events as determined from

quantification of the Level 1 PRA model. The CDF is based on the risk assessment for

internally-initiated events, which includes internal flooding. TVA did not include the contribution

from external events in the WBN risk estimates; however, it did account for the potential risk

H-3
Appendix H

reduction benefits associated with external events by multiplying the estimated benefits for

internal events by a factor of 2. This factor was subsequently increased to 2.28 in response to

an NRC staff RAI (TVA 2011 a). This is discussed further in Sections H.2.2 and H.6.2.

The breakdown of CDF by initiating event is provided in Table H-I. As shown in this table,

events initiated by loss of offsite power (LOOP) and internal floods are the dominant

contributors to CDF. Station blackout (SBO) sequences, a subset of sequences initiated by

LOOP, make up 27 percent (4.7 x 10.6 per year) of the CDF while anticipated transient without

scram (ATVVS) sequences make up approximately 4 percent (6.2 x 10-7 per year) of the CDF

(TVA 2011 a).

Table H-1. WBN2 Core Damage Frequency for Internal Events 2

Event CDF % Contribution to

Initiating (Per Year) CDF1

Loss of Offsite Power (Grid Related) 3.2 x 10-6 19

Loss of Offsite Power (Plant Centered) 2.8 x 10.6 16

Total Loss of Component Cooling Unit 2 16 x 10.6 10

Loss of Offsite Power (Weather Induced) 1.1x 10.6 6

Flood Event Induced by Rupture of Raw 1.1 x 10.6 6

Cooling Water (RCW) Line in room 772 0 - A8

Flood Event Induced by Rupture of RCW Line 1.1 x 10-6 6

in room 772 0 - A9

Total Loss of Emergency RCW (ERCW) 9.6 x 10-7 6

Cooling

Smail Loss of Coolant Accident (LOCA) Stuck 6.5 x 10.7 4

Open Safety Relief Valve

Flood Event Induced by Rupture of high 3.2 x 10-7 2

pressure fire protection (HPFP) in Common

Areas of the Auxiliary building

Turbine Trip 3.0 x 10-7 2

Others (each 1% or less) 4.1 x 10.6 24

Total CDF (internal events) 1.72 x 105 100

'May not total to 100 percent due to round off.

2 Information provided in response to NRC staff RAIs (TVA 2010a, 201 1a).

H-4
Appendix H

The Level 2 portion of the SAMDA model represents an updated version of the WBN2 IPE Level

2 model. The IPE model was based on enhancements to NUREG/CR-6595 (NRC 2004a) and

included quantification of containment threats resulting from high pressure failure of the reactor

vessel and hydrogen deflagrations/detonations as well as additional detail on the treatment of

interfacing system loss of coolant accidents (ISLOCAs) and induced steam generator tube

rupture (I-SGTR). Two large containment event trees (CETs) were developed: one for SBO and

one for non-SBO sequences.

The result of the Level 2 model is a set of four release categories [I - Early Containment Failure

(LERF), II - Containment Bypass (BYPASS), III - Late Containment Failure (LATE) and IV -

Small Pre-existing Leak (ISERF)] with their respective frequency and one category for intact

containment, which is considered to have a negligible release. The frequency of each release

category was obtained by summing the frequency of the individual Level 2 sequences assigned

to each release category. The results of this analysis for WBN2 are provided in Table 2.a.iv-1 of

the January 31, 2011 RAI responses (TVA 2011 a). The four release categories were

characterized by a total of eleven representative scenarioswith their associated release

parameters (source terms, release heights, release times and release energies). The source

terms for the representative scenarios were based on a SEQSOR emulation spreadsheet

methodology. The release parameters for the eleven representative sequences are provided in

Table 2.a.iv-4 of the September 16, 2011 submittal (TVA 201 1f) and Table 2.a.iv-5 of the June

17, 2011 RAI responses (TVA 2011 d).

The offsite consequences and economic impact analyses use the WinMACCS code, the current

version of the MACCS2 code, to determine the offsite risk impacts on the surrounding

environment and public. Inputs for these analyses include plant-specific and site-specific input

values for core radionuclide inventory, source term and release characteristics, site

meteorological data, projected population distribution (within an 80-kilometer [50-mile] radius)

for the year 2040, emergency response evacuation modeling, and economic data. The

magnitude of the onsite impacts (in terms of clean-up and decontamination costs and

occupational dose) is based on information provided in NUREG/BR -0184 (NRC 1997a).

The consequence analysis was performed for each of the eleven representative scenarios and

the results in terms of person-rem and off-site economic consequence weighted by the

contribution each representative scenario makes to the release category to obtain the

consequences for the four release categories. This average consequence for the release

category times the frequency of the release category yields the annual population dose and

offsite economic consequence for each release category.

TVA estimated the dose to the population within 80 kilometers (50 miles) of the WBN site to be

approximately 0..20 person-sievert (Sv) (20.0 person-rem) per year (TVA 201 if). The

breakdown of the total population dose by release category is summarized in Table H-2. Late

containment over-pressure failure is the dominant contributor to population dose risk at WBN2.

H-5
Appendix H

Table H-2. Breakdown of Population Dose by Containment Release Category

Population Dose

Containment Release Category (Person-Rem' Per Year) Percent Contribution

I - Early Containment Failure (LERF) 3.7 19

II - Containment Bypass (BYPASS) 0.8 4

III - Late Containment Failure (LATE) 14.1 71

IV - Small Pre-existing Leak (ISERF) 1.2 6

V - Intact Containment (Intact) negligible negligible

Total 20.02 100

'One Person-Rem = 0.01 person-Sv 2Total is not equal to the sum of the above due to round off

H.2.2 Review of TVA's Risk Estimates

TVA's determination of offsite risk at WBN Unit 2 is based on the following major elements of

analysis:

* the Level 1 and 2 risk models that form the bases for the WBN Unit 2 IPE submittal (TVA

2010b), the external event analyses of the WBN Unit 2 IPEEE submittal (TVA 2010e),

and the modifications to the IPE model that have been incorporated into the latest WBN

Unit 2 model, WBNU1_U2_FLOOD_SAMA, and

" the WinMACCS analyses performed to translate fission product source terms and

release frequencies from the Level 2 PRA model into offsite consequence measures

(essentially this equates to a Level 3 PRA).

Each of these analyses was reviewed to determine the acceptability of TVA's risk estimates for

the SAMDA analysis, as summarized below.

The NRC staffs review of the WBN2 IPE is described in an NRC report dated August 12, 2011

(NRC 201 ld). Based on a review of the IPE submittal and responses to RAIs, the NRC staff

found that TVA's definition of vulnerability and its conclusion that no severe accident

vulnerabilities exist at WBN2 to be reasonable.Consequently the staff found the WBN2 IPE to

be consistent with the intent of Generic Letter (GL) 88-20 "Initiation of the Individual Plant

Examination for Severe Accident Vulnerabilities - 10 CFR [Title 10, Code of Federal

Regulations] 50.54(f)," (NRC 1988), subject to the completion of the applicable commitments

and TVA's plan to confirm that, prior to Unit 2 start up, the Unit 2 PRA model matches the asH-6
Appendix H

built, as-operated plant. Although no severe accident vulnerabilities were identified in the WBN2

IPE, the IPE did cite cost beneficial SAMDAs identified in the original Final Supplemental

Environmental Impact Statement submittal (TVA 2009). Each of these improvements is

addressed by a SAMDA in the current evaluation and is discussed further in Section H.3.2.

The CDF value from the WBN2 IPE submittal (3.3 x 10-5 per year) is near the average of the

CDF values reported in the IPEs for other Westinghouse 4-loop plants. Figure 11.6 of NUREG1560 shows that the IPE-based total internal events CDF for these plants ranges from 3 x 10-6

to 2 x 10-4 per year, with an average CDF for the group of 6 x 10-5 per year (NRC 1997b). It is

recognized that other plants have updated the values for CDF subsequent to the IPE submittals

to reflect modeling and hardware changes. The current internal event CDF result for WBN2 (1.7

x 10-5 per year, including internal flooding) is comparable to that for other plants of similar

vintage and characteristics.

Since WBN Units 1 and 2 are essentially identical, the history of both units' PRA models is

relevant to this evaluation. There have been eight revisions to the WBN PRA model since the

1992 WBN1 IPE submittal, including the 2009 dual unit model which utilized the CAFTA PRA

software, whereas earlier versions utilized the RISKMAN PRA software. A description of the

most significant changes made to each revision was provided by TVA in the original and

updated assessments and in response to NRC staff RAIs (TVA 2009, TVA 2010a, TVA 2010c,

TVA 201 Ia and TVA 2011b), and is summarized in Table H-3.

A comparison of internal events CDF between the 1994 Unit 1 IPE update and the initial Unit 2

PRA model (WBN4SAMA) indicates a decrease of approximately 80 percent (from 8.0 x 10.5 per

year to 1.5 x 10-5 per year). This reduction is attributed to the resolution of various 2001 peer

review F&Os. The approximate factor of two increase for the Unit 2 IPE (from 1.5 x 10,5 per

year to 3.3 x 10.5 per year)is attributed primarily to the removal of credit for LOOP recovery

factors from switchyard cross-ties which are no longer feasible. The factor of two reduction in

CDF from the Unit 2 IPE (3.3 x 10.5 per year) to the SAMDA model (1.7 x 10-9 per year) is

attributed to taking credit for cross-tying Unit1 and Unit 2 shutdown boards and recovery of total

loss of ERCW by use of a portable diesel driven fire pump (TVA 2011 a). A comparison of the

contributors to the total CDF between theWBN4SAMA model and the current SAMDA model

indicates that some have increased while others have decreased. A summary listing of those

changes that resulted in the greatest impact on the internal events CDF and, in particular, the

changed risk profile was provided in response to an NRC staff RAI and is included in Table H-3

(TVA 2011a, TVA 2011b).

H-7
Appendix H

Table H-3. WBN PRA Historical Summary

CDF PRA Version Summary of Changes from Prior Model (per year)

Unit 1 IPE Unit 1 IPE Submittal 3.3 x 10-4

(1992)

Unit 1 IPE Revised success criteria for the component cooling water 8.0 x 10-5

Revision 1 system to one of two pumps being successful

(1994) Provided for the use of nitrogen bottles for steam generator power-operated relief valves (PORVs) and auxiliary feedwater

(AFW) flow control valves under SBO conditions

Revised human reliability analysis (HRA) to reflect updated

procedures and training

Unit 1 Enhanced recovery from loss of offsite power through use of 4.4 x 10-5

Revision 2 Unit 2 equipment and changing certain emergency diesel

generator (EDG) cooling valves from normally closed to

(1997) locked open

- Credited improved operator actions resulting from changes in

emergency operating procedures (EOPs) associated with high

pressure recirculation

- Revised component cooling water system (CCS) model to

credit Unit 2 pump and reduced loss of CCS initiating event

frequency

Unit 1 - Integrated Level 1 and 2 models to allow calculation of LERF 4.5 x 10-5

Revision 3 - Revised seal LOCA model to reflect new high temperature

(2001) seals

- Incorporated plant specific data

Unit 1 - Updated initiating event data 1.3 x 10-'

Revision 4 - Incorporated latest maintenance rule data

- Incorporated comments by WBN system engineers

Unit 2 WBN4SAMA - Revised core damage arrest model in Level 2 to be consistent 1.5 x 10.5

(2008) with Level 1 model

Revised bleed and feed success criteria to indicate two

PORVs required with one safety injection (SI) pump

- Added loss of plant compressed air initiating event

- Revised ventilation system recovery modeling

- Accounted for dual unit operation by removing credit for Unit 2

component cooling water pumps from Unit 1 model and

changing ERCW success criteria.

H-8
Appendix H

Table H-3. WBN PRA Historical Summary

CDF

PRA Version Summary of Changes from Prior Model

(per year)

Dual Unit - Updated PRA model to be dual unit and to use CAFTA 2.9 x 10.5

WBN_UI_U2_ software package

FLOOD - Developed from WBN4SAMA event trees and fault trees

- Removed LOOP recovery factors from switchyard cross-ties

no longer feasible

- Replaced previous CETs with updated models

Unit 2 IPE - Resolved selected findings from Westinghouse Owner's 3.3 x 10-5

WBNU1_U2_ Group (WOG) 2009 review

FLOOD - Updated LOOP model so that all batteries were not failed at

(Feb. 2010) time zero

- Corrected basic event coding for turbine-driven auxiliary

feedwater (TD AFW) pump failure to start

- Revised the linking of steam generator condition after core

damage to the correct plant damage state

Dual Unit - Prepared for the updated Unit 2 SAMDA analysis 1.7 x 105

WBNU1_U2_ - Added cross-tie of Unit1 and Unit 2 shutdown boards

FLOODSAMA - Credited recovery of total loss of ERCW by use of portable

(Oct. 2010) diesel driven fire pump

The Unit 2 IPE is stated to be based on the Unit 1 design and operation as of April 1, 2008. In

response to an NRC staff RAI, TVA discussed the design and procedural changes since the IPE

2008 freeze date with potential PRA significance (TVA 2011 a). A significant number of mainly

procedural changes that were identified in the initial Unit 2 SAMDA assessment have been

implemented and incorporated in the current SAMDA PRA. The NRC staff concludes that those

changes that are assumed to have not been incorporated into the PRA will tend to reduce the

CDF and thus make the current results conservative.

The NRC staff considered the peer reviews performed for the WBN PRA, and the potential

impact of the review findings on the SAMDA evaluation. The most relevant review is that

performed by the WOG in November 2009. A summary of the results of this peer review is

provided in the Unit 2 IPE submittal along with a listing of the peer review findings(TVA 2010b).

Of the 326 supporting requirements of the ASME PRA standard, nine were judged to not be

applicable, 272 were judged to meet Capability Category (CC) 1/11 or greater, 19 met CC I, and

26 were judged as not met. In response to a NRC Staff RAI, TVA discussed the status of the

peer review findings relative to the SAMDA model (TVA 2011 a). While most of the findings

have been resolved as part of the updated SAMDA model, a significant number of findings

H-9
Appendix H

remain open. These are in two categories: those considered by TVA to be documentation-only

issues and those pertaining to internal flooding.

In response to an NRC staff RAI, TVA discussed three specific findings considered by TVA to

be documentation related. With regard to the finding concerning the diesel generator load

sequencer modeling, additional information from the finding was presented including the

reviewer's conclusion that the missing failure modes would be expected to have minimal impact

on the PRA results. Also, the peer review indicated that Capability Category II was met. With

regard to the finding concerning the lack of simulator observations to support the human

reliability analysis, TVA pointed out that the PRA standard required either simulator

observations or talk-throughs with the operators. The talk-throughs with several members of the

operations staff conducted for the WBN PRA model are considered by TVA to meet the PRA

standards requirements. With regard to the finding concerning optimistic mission times used for

room heatup calculations, TVA identified those systems or functions for which a mission time of

less than 24 hours was assumed. These include Emergency Boration, electric power

equipment related to 4-hour battery coping time, Residual Heat Removal, Reactor Protection

System (RPS) and Emergency Safety Features Actuation System (ESFAS). The NRC staff

considers the mission time used for each of these systems acceptable for determining the need

for room cooling.2 TVA stated that, except for two cases, for those areas where the heatup

analysis showed that the temperatures for affected components/functions exceeded the

equipment qualification (EQ) temperature prior to the desired mission time, cooling was

considered necessary and included in the model. For Room 757-01, Auxiliary Control Room,

the room temperature reaches the EQ temperature of 104 °F at just over 21 hours into the event

and peaks at 105.8 OF. Room 757-24, 6.9 kV Shutdown Board Room B reaches 104 *F at 23

hours and exceed this by less than one degree. TVA concludes that these small differences will

not lead to failure of the associated equipment in the 24 hour mission time (TVA 201 1c, TVA

2011 d). The NRC staff agrees with this conclusion.

With regard to the findings concerning the internal flooding analysis, TVA provided, in response

to an NRC staff RAI, a general discussion of the open findings including identifying those that

could be resolved by additional documentation or supporting analysis and those that represent

conservatisms in the flooding CDF (TVA 201 la). Based on the exclusion of recovery actions for

many of the important flooding contributors, TVA concludes that the flooding analysis is

conservatively bounding for the present application. The NRC staff review of the available

information indicates that it is not clear if the overall impact of the resolution of the findings will

increase or decrease the flooding CDF. Several findings indicate the results are clearly

conservative, while for others the impact of the finding resolution is not clear. Further, additional

credit for recovery actions would reduce the flood CDF for those scenarios where recovery can

be credited. As discussed below, TVA has addressed the two important flood induced

sequences by committing to add flood detection equipment in the rooms where floods are

2 In TVA's June 17 submittal (TVA 201 1d) it is stated that the mission time for the RPS, ESFAS and

instrumentation is 12 hours. Subsequently TVA clarified that this reference to instrumentation was meant

to refer to instruments associated with a reactor trip but are not specifically classified as RPS or ESFAS.

They further stated that instrumentation necessary and sufficient to monitor safe shutdown is considered

to have a mission time of 24 hours (TVA 201 le).

H-10
Appendix H

important contributors (Rooms 772.0-A8 and 772.0-A9). In addition, as discussed below for

SAMDAs 70 and 339, TVA has committed to provide the capability to transfer normal

compressed air supply to the station nitrogen system. This addresses flooding sequences that

cause loss of the station air system. Further, SAMDA identification has considered and

adequately disposed of other less important flooding risk contributors. Based on this, the NRC

staff concludes that updating the internal flooding analysis to resolve the remaining peer review

findings is unlikely to result in any additional cost beneficial SAMDAs.

TVA also indicated that the changes between the Unit 2 IPE model and the SAMDA model were

independently reviewed internally by the contractor making the changes, by an independent

contractor, and by TVA.

In response to NRC staff RAIs, TVA identified the systems shared between Units 1 and 2, and

described the modeling of these systems and how Unit 1 outages potentially impacting these

systems are accounted for in the Unit 2 model. WBN Units 1 and 2 share the electric power,

ERCW, CCS, plant and control air, and heating, ventilation and air conditioning (HVAC) systems

(TVA 2010c). The WBN CAFTA model is described as a single fault tree constructed with

systems and components for each unit and common systems modeled. The impact of the

unavailability of Unit 1 components/systems with respect to mitigation and to initiating events

(unit-specific and dual-unit) is incorporated in the model for Unit 2. Model quantification for each

unit accurately tracks the dependent failure for each unit (TVA 2011 a). The test and

maintenance unavailability of Unit 1 components impacting the Unit 2 CDF includes the

unavailability of these components when Unit 1 is operating as well as when it is shutdown.

Testing and maintenance (T&M) unavailability is based on Unit 1 experience data. Since it is

TVA's practice to perform T&M with the unit on line, the unavailability data include routine

testing as well as infrequent but more extensive maintenance activities (TVA 2011 b, TVA

2011 c, and TVA 2011 d).

Given that the WBN internal events PRA model has been peer-reviewed and the peer review

findings were all addressed, and that TVA has satisfactorily addressed NRC staff questions

regarding the PRA, the NRC staff concludes that the internal events Level 1 PRA model,

WBNU1_U2_ FLOOD_SAMA, is of sufficient quality to support the SAMDA evaluation.

As indicated above, the WBN PRA does not include external events. The SAMDA submittals

cite the WBN Unit 1 IPEEE which indicates that the only vulnerability found has been corrected

and no longer impacts either unit. The WBN Unit 1 IPEEE was submitted in November 1998

(TVA 1998), in response to Supplement 4 of GL 88-20 (NRC 1991). The Unit 2 IPEEE was

submitted in April 2010 (TVA 2010e).

The Unit 2 IPEEE uses the same methodology and to a large extent the same assessment as

the Unit 1 IPEEE, subject to validation that the Unit 1 assessments are applicable to the as built

Unit 2. This submittal included a summary of the seismic margin analysis, the fire induced

vulnerability evaluation (FIVE), and the screening analysis for other external events, all subject

to validation for Unit 2 when construction is complete. No fundamental weaknesses or

vulnerabilities to severe accident risk in regard to external events were identified in the Unit 1

IPEEE with the exception of one item related to tornado missiles discussed below. No seismic,

H-11
Appendix H

fire, high winds, external floods or other external hazard improvements were identified. In a

letter dated May 19, 2000, the NRC staff concluded that the licensee's Unit 1 IPEEE process is

capable of identifying the most likely severe accidents and severe accident vulnerabilities, and

therefore, that the Watts Bar IPEEE has met the intent of Supplement 4 to GL 88-20 (NRC

2000). The NRC staffs review of the WBN2 IPEEE is described in an NRC letter dated

September 20, 2011 (NRC 2011 e). Based on a review of the IPEEE submittal and responses to

RAls, the NRC staff found that TVA's definition of vulnerability and its conclusion that no severe

accident vulnerabilities exist at WBN2 to be reasonable. Consequently the staff found the

WBN2 IPEEE to be consistent with the intent of GL 88-20 (NRC 1988), subject to the

completion of validation activities to confirm that the assumptions concerning the Unit 2 design

are valid for the as-built, as-operated plant.

The WBN Unit I IPEEE used a focused scope Electric Power Research Institute (EPRI) seismic

margins analysis (EPRI 1991). This method is qualitative and does not provide numerical

estimates of the CDF contributions from seismic initiators. For this assessment, the seismic

walkdown took advantage of the extensive walkdowns performed prior to the issuance of the

WBN Unit 1 low power operating license including: the Corrective Action Program in which the

plant structures were reevaluated against more recent seismic criteria, the Hanger and Analysis

Update Program, the Integrated Interaction 'Program, and the Equipment Seismic Qualification

program. The components in the safe shutdown equipment list were screened using an overall

high confidence of low probability of failure (HCLPF) capacity of 0.3g, the review level

earthquake (RLE) value for the plant, and the screening level that would be used for a focusedscope plant. No significant seismic concerns were identified. A small number of maintenance

and housekeeping items were noted and corrected (TVA 1998, TVA 2010e).

While the Unit 2 seismic assessment makes considerable use of the Unit 1 assessment,

individual aspects are repeated and/or the Unit 1 results were reviewed to confirm that they are

applicable to Unit 2. TVA considered this an acceptable approach since the designs of the units

are nearly identical and use the same design criteria.

The WNB2 IPEEE did not identify any vulnerabilities due to seismic events or any

improvements to reduce seismic risk.

To provide insight into the appropriate estimate of the seismic CDF to use for the SAMDA

evaluation, the NRC staff noted that, in the attachments to NRC Information Notice 2010-18,

Generic Issue (GI) 199 (NRC 2010), the NRC staff estimated a "weakest link model" seismic

CDF for WBN 1 of 3.6 x 10-5 per year using updated seismic hazard curves developed by the

U.S. Geological Survey (USGS) in 2008 (USGS 2008) and requested TVA to provide an

assessment of the impact of the updated USGS seismic hazard curves on the SAMDA

evaluation (NRC 201 Ia). The NRC Information Notice referenced the August 2010 NRC

document, "Safety/Risk Assessment Results for Generic Issue 199, Implications of Updated

Probabilistic Seismic Hazard Estimates in Central and Eastern United States on Existing Plants"

(ADAMS Accession No. ML100270582 (package)), that discusses recent updates to estimates

of the seismic hazard in the central and eastern United States. Appendix A of that document

describes how the seismic CDF estimate can be acceptably derived using various approaches;

including a maximum estimate, averaging estimates, and the weakest link estimate. All these

H-12
Appendix H

approaches use the plant-specific ground motion characterization (i.e., spectral accelerations at

various frequencies and/or peak ground accelerations). For WBN1, the peak ground

acceleration estimate is greater than the spectral acceleration estimates derived at 1 Hz, 5 Hz,

and 10 Hz. As a result, the peak ground acceleration estimate is equal to the maximum

estimate and dominates the weakest link model estimate at 3.6 x 10s per year.

In response to the staff request, TVA noted that the Watts Bar site was used as the test case for

closure of GI-194, "Implications of Updated Probabilistic Seismic Hazard Estimates" (NRC

2003a) (TVA 201 la). In the staff evaluation supporting the closure of GI-194, the NRC staff

used new seismic hazard curves for the East Tennessee Seismic Zone (ETSZ), which includes

the Watts Bar site, to develop the updated seismic CDF estimate for the Watts Bar site. Initially,

the staff estimated the seismic CDF using the updated peak ground acceleration and derived a

value similar to the latest updated value. However, the staff noted that the Watts Bar site's

updated seismic spectral acceleration values differed significantly from the design safe

shutdown earthquake (SSE) uniform hazard spectrum. In order to account for the difference in

the uniform hazard spectrum shape of the new hazard curves, the Watts Bar plant HCLPF

capacity of 0.3g was scaled to the spectral acceleration values at 5 hertz (Hz) and 10 Hz, based

on the natural frequency range for most structures and equipment in nuclear power plants being

below 10 Hz (NRC 2003a). The average of the seismic CDF for these two seismic acceleration

values resulted in the seismic CDF of 1.8 x 10-5 per reactor-year for the Watts Bar site. Based

on the GI-194 staff analysis, TVA concluded that 1.8 x 10-' per year is an appropriate estimate

of the seismic CDF for use in the WBN2 SAMDA evaluation.

The seismic CDF estimated by the NRC staff for Watts Bar 1 for soil (vs. bedrock - NRC GI-1 99

estimates CDF for both), using the 2008 USGS seismic hazard curves, for spectral acceleration

values of 5 and 10 Hz is 1.3 x 10-5 per year and 2.8 x 10- 5 per year, respectively (NRC 2010).

The average of the seismic CDF for these two acceleration values is 2 x 10-5 per year. Based

on the spectral-averaged seismic CDF of 2 x 10-5 per year using the 2008 USGS data being

essentially the same as the spectral-average seismic CDF of 1.8 x 10-6 per year determined for

closure of GI-1 94, the NRC staff agrees that 1.8 x 10- 5 per year is an acceptable estimate of the

seismic CDF for use in the WBN2 SAMDA evaluation.

For the analysis of plant vulnerability to fire, the WBN Unit 2 IPEEE used the Fire-Induced

Vulnerability Evaluation (FIVE) (EPRI 1992) methodology and modified versions of the WBN

Unit 2 IPE. The methodology consists of a series of progressive screens. In the first phase of

screening, fire areas are screened based on area fire boundary integrity, the absence of safe

shutdown components, and the lack of plant trip initiators. The second phase of screening

consists of an initial, bounding quantitative analysis followed by a more detailed quantitative

evaluation for those areas not screened out based on a fire CDF of 1 x 10-6 per year. The initial

quantification consisted of generating an area specific fire ignition frequency and a conditional

core damage probability from the IPE model assuming all components in the fire area were

damaged. In the detailed quantification further evaluation was performed which included

consideration of fire severity, zones of fire influence, and fire suppression probability. The NRC

staff review of the WBN2 IPEEE fire analysis notes that while the approach was somewhat

unique and deviated from the traditional FIVE methodology in some respects, the methods used

H-13
Appendix H

and the implementation of those methods are adequate to meet the IPEEE objectives. The staff

also concluded that the fire analysis incorporated a degree of conservatism (NRC 201 le). The

WNB2 IPEEE did not identify any vulnerabilities due to fire events or any improvements to

reduce fire risk.

In response to an NRC Staff RAI, TVA provided more information concerning the modified PRA

used in the fire evaluation (TVA 201 la). These modifications consisted mainly of changes to

conform to the FIVE analysis screening assumptions. The changes were unique to the fire

analysis or of little importance to non-fire scenarios. It is noted that the changes made to the

Unit 2 model to create the SAMDA model were not incorporated in the modification used in the

fire analysis. This results in a degree of conservatism in the FIVE results. This is discussed

more below.

The dominant fire areas, defined as those having a fire CDF greater than 3 x 10- per year, and

their contributions to the fire CDF are listed in Table H-3. The total fire CDF is not given in the

IPEEE submittal, but the total for those subjected to the final stage of screening is stated to be

9.3 x 10-6 per year (TVA 2011 a).

Table H-3. Dominant Fire Areas and Their Contribution to Fire CDF 1

Fire Area Description CDF

(per year).

Main Control Room 9.7 x 10-7

Corridor in Auxiliary Building (713.0-Al & A2) 9.3 x 10-7

125V Vital Battery Board Room IV 8.4 x 10-'

Refueling Room 7.5 x 10-7

Auxiliary Instrument Room 2 6.8 x 10.'

Turbine Building 5.9 x 10.'

Corridor (737.0-Al B) 5.1 x 10-7

Corridor (737.0-AlA) 4.2 x 10-7

Auxiliary Building Roof 3.1 x 10-7

1Information provided in responses to NRC staff RAIs (TVA 2010e and TVA 201 la).

In response to an NRC staff RAI, TVA identified 15 conservatisms and 8 non-conservatisms in

the WBN fire analysis (TVA 201 la). The conservative items included: most fire ignition

frequencies, triple counting fires in one area, conservative fire severity factors in the control

room, conservative fire suppression failure probabilities, conservative treatment of core damage

given control room evacuation, the assignment of fire impacts to the individual fire scenarios,

and not incorporating model changes credited in the SAMDA model, principally recovery actions

H-14
Appendix H

for station blackout and loss of ERCW. Non-conservatisms included: not modeling fire

propagation between analysis volumes, not modeling some spurious equipment actuations,

assumption that reactor coolant pump (RCP) seal return valves would not transfer closed as a

result of fires, and not including the increased probability of the 182 gallons per minute (gpm)

per pump seal LOCA on loss of seal cooling. TVA concludes that the conservatisms outweigh

the non-conservatisms so that the fire contribution to risk is less than that given by the sum of

the final fire screen results.

TVA used a fire CDF of 4.1 x 10-6 per year for the SAMDA evaluation. This value is based on

the sum of the detailed CDF quantification of the previously unscreened fire areas as given in

the IPEEE and updated in response to an NRC staff RAI, or 9.3 x 10-6 per year as discussed

previously (TVA 2010e, TVA 201 la), which is reduced by a factor of 2.29 to account for the

conservatisms in the fire analysis. This factor only accounts for the conservatisms in the PRA

model used to evaluate the conditional core damage probabilities compared to the SAMDA

model and does not account for conservatisms in the FIVE methodology or those conservatisms

discussed above. This factor is the ratio of the internal events CDF of 2.68 x 10. per year

given by the modified PRA used for the fire analysis with no fire induced failures nor flood

failures to the CDF of 1.17 x 105 per year given by the October 2010 SAMDA PRA for internal

events only, excluding floods (TVA 2011 a). Based on the conservatisms in the fire analysis, the

staff concludes that a fire CDF of 4.1 x 10-6 per year is reasonable for the SAMDA analysis. 3

The IPEEE analysis of high winds, floods, and other (HFO) external events followed the

screening and evaluation approaches described in Supplement 4 of GL 88-20 (NRC 1991) and

focused on demonstrating that the design and construction of the plant in the HFO areas met

the 1975 Standard Review Plan Criteria (NRC 1975). During the HFO walkdown it was noted

that there was an opening on the Unit 2 side of the Auxiliary Building that had the potential for

allowing tornado missiles to penetrate into the auxiliary building and damage safety related

equipment. A corrective action to design and install a steel shield to eliminate this concern for

both Units 1 and 2 was completed. TVA did not identify any other vulnerabilities and did not

identify any improvements. Based on this result, TVA did not consider specific SAMDAs for

these events.

3

An alternative method of assessing the potential conservatism in the TVA fire CDF due to the PRA

model used for the SAMDA analysis is to ratio the total internal events CDF of the PRA that was the basis

for the WBN2 fire analysis to the internal event CDF of the PRA used for the SAMDA analysis. Using the

IPE CDF of 3.3E-05 per year (TVA 201 Ob) as the internal events CDF on Which the fire CDF was based

and the WBNU1U2_FLOOD_SAMA CDF of 1.7E-05 per year results in a fire CDF reduction factor

of 3.3E-05/1.7E-05 = 1.94. This yields an adjusted WBN2 fire CDF of 9.3E-06/1.94 = 4.8E-06 per year

versus TVA's value of 4.1 E-06 per year. While higher than TVA's value, the difference is well within the

approximate nature of the adjustment methodology. Use of the higher value of fire CDF would increase

the external events multiplier (and, therefore, the potential benefit), but would not change the ultimate

disposition of the various SAMDAs. The staff considers TVA's result, but not necessarily the approach,

as acceptable for use in the SAMDA evaluations.

H-15
Appendix H

In the original and updated SAMDA submittals, TVA assumed that the estimated benefits from

external events was equivalent to the estimated benefits from internal events. This was based

on the SAMA submittals for license renewal applications for several other four loop

Westinghouse plants. Accordingly, TVA applied an external events multiplier of 2 to the internal

events results to account for the additional benefits from fire, seismic and other external

events.In an RAI, the NRC staff questioned the basis for this multiplier and asked TVA to use a

higher multiplier that is supported by WBN specific information relative to the seismic and fire

contributors to CDF (NRC 201 la). In response to the RAI, TVA developed a new external

events multiplier of 2.28 based on the aforementioned results (based on a seismic CDF of 1.8 x

10-5 per year, a fire CDF of 4.1 x 10.6 per year, and an internal events CDF of 1.7 x 10-5 per

year) (TVA 2011 a). In a revised SAMDA analysis submitted in response to the RAI, TVA

multiplied the benefit that was derived from the internal events model by a factor of 2.28 to

account for the combined contribution from internal and external events. The NRC staff agrees

with the applicant's overall conclusion concerning the impact of external events and concludes

that the applicant's use of a multiplier of 2.28 to account for external events is reasonable for the

purposes of the SAMDA evaluation.

The NRC staff reviewed the general process used by TVA to translate the results of the Level 1

PRA into containment releases, as well as the results of the Level 2 analysis, as described in

the SAMDA submittal and in response to NRC staff requests for additional information (TVA

2011 a, TVA2011 b, TVA201 1c, TVA 2011 d). As indicated above, the Level 2 portion of the

SAMDA model represents an updated version of the WBN2 IPE Level 2 model. The IPE model

was based on enhancements to NUREG/CR-6595 (NRC 2004a) and included quantification of

containment threats resulting from high pressure failure of the reactor vessel and hydrogen

deflagrations/detonations as well as additional detail on the treatment of ISLOCA and Induced

Steam Generator Tube Rupture (I-SGTR). The accident progression was modeled using a 32

node containment model in MAAP4.0.7. Two large CETs were developed; one for SBO and

one for non-SBO sequences (TVA 201 Ob).

In response to NRC staff RAIs, TVA provided additional information on the linking of the Level 1

and Level 2 models, the binning of CET end states and their assignment to release categories,

the dominant sequences for each release category, and the determination of the release

characteristics for each release category. Each of the Level 1 core damage sequences is

assigned to one of eight plant damage state (PDS) bins, based on characteristics such as

bypass containment or not, the type of bypass and high or low reactor coolant pressure. Each

core damage sequence is linked to the Level 2 CET in accord with the PDS bin. The CETs

consisted of 18 questions (or events or nodes), the first 5 of which link each PDS to the

appropriate portion of the CET. The remainder of the questions determine the appropriate

containment failure type, the CET end states and release category. This results in 11 CET end

state groups (plus the INTACT end state) which are then assigned to the release categories

used in the Level 3 consequence analysis. It is noted that some changes/corrections were

made to the IPE PDS bin assignments for the SAMDA model. The CET end states are binned

into release categories that represent similar containment failure modes and release timing. The

frequency of each release category was obtained by summing the frequency of the individual

Level 2 sequences assigned to each release category.

H-16
Appendix H

The NRC staff noted that the sum of the frequencies of release categories I through IV of 1.85 x

10.5 per year is greater than the CDF of 1.72 x 10-5 per year even without the inclusion of

release category V for containment intact sequences. In response to an NRC staff RAI to

explain this greater value and to provide the frequency for release category V, TVA explained

the reason for the sum of release category I through IV frequencies being greater than the CDF

as due to not excluding release category IV (a small preexisting containment leak) from the

other branches of the containment event tree that are subsequently assigned to the other

release categories. While the NRC staff agrees that this leads to double counting of release

category IV frequency, the degree of conservatism in risk is not clear since the presence of a

small preexisting containment leak would not necessarily preclude the other containment failure

modes, particularly those early failures due to high pressure reactor vessel failures. TVA further

indicated that the CAFTA based Level 2 model did not calculate the intact containment

frequency correctly. A proportion of the late containment failure sequences (release category

III) was inadvertently included in the intact category and thus a correct value for the intact

containment frequency is not available. This does not impact the risk results since the

containment intact category has negligible impact on the results.

TVA stated that the large early release frequency (LERF) for the latest SAMDA model is 1.70 x

10-6 per year (TVA 201 la). In an NRC staff RAI, the staff noted that this is different from the

sum of the frequencies of release categories I and II of 1.61 x 10-6 per year (NRC 2011 b). In

response, TVA indicated that the correct value for LERF is the sum of the frequencies of release

categories I and II or 1.61 x 10.6 per year (TVA 2011b).

Source terms for use in the Level 3 consequence analysis are based on representative accident

scenarios that reflect the post core damage behavior for the dominant sequence or sequences

within a PDS that contribute to each release category. The release fractions were determined

for each representative scenario using a spreadsheet version of the SEQSOR computer code.

SEQSOR was used to calculate the release fractions for the NUREG-1 150 analysis of the

Sequoyah plant (NRC 1990b). The SEQSOR methodology determines release fractions using

a parametric approach with probabilistic data blocks based on supporting first principle analyses

as well as expert panel judgments. SEQSOR determines the mean release fractions for each

representative sequence that makes up each release category using input release

characteristics describing the representative scenario and parametric data included in the code.

The release characteristics used for the WBN.2 analysis are reported in Table 2.a.iv-3, which

was provided in response to an NRC staff RAI (TVA 201 la). Since the SEQSOR data blocks

were developed for the Sequoyah plant, a sister plant to WBN2, the use of SEQSOR was

considered appropriate by TVA for the WBN2 SAMDA analysis. TVA indicated that the same

data blocks and data were used in the SEQSOR emulator used for the WBN2 analysis as in the

NUREG-1 150 SEQSOR code except where process or equipment that needed to be considered

in the WBN2 analysis were not included in the NUREG-1 150 analysis. TVA states that the

SEQSOR emulator was independently reviewed prior to its use in the SAMDA analysis (TVA

2011c, TVA 2011d).

Based on the NRC staff's review of the Level 2 methodology and the fact that (1) the LERF

model was reviewed by the WOG and the review findings have all been addressed in the

H-1 7
Appendix H

SAMDA Level 2 model, (2) the updated Level 2 model was reviewed by an external contractor

and independently reviewed by the TVA PRA team, and (3) TVA has adequately addressed

NRC staff RAIs concerning the Level 2 model, the NRC staff concludes that the Level 2 PRA

provides an acceptable basis for evaluating the benefits associated with various SAMDAs.

The reactor core radionuclide inventory used in the consequence analysis contained in the EIS

is for 5 percent enrichment and a burnup of 1000 effective full power days (EFPD) for WBN2 at

3565 megawatt thermal (MWt) as evaluated using the ORIGEN code. TVA states that these

conditions bound that expected for the WBN2 fuel management program for the license period

(TVA 201 Oc).

The NRC staff reviewed the process used by TVA to extend the containment performance

(Level 2) portion of the PRA to an assessment of offsite consequences (essentially a Level 3

PRA). This included consideration of the source terms used to characterize fission product

releases for the applicable containment release categories and the major input assumptions

used in the offsite consequence analyses. The WinMACCS code, the current version of the

MACCS2 code, was utilized to estimate offsite consequences. Plant-specific input to the code

includes the source terms for each release category and the reactor core radionuclide inventory

(both discussed above), site-specific meteorological data, projected population distribution

within an 80-kilometer (50-mile) radius for the year 2040, emergency evacuation modeling, and

economic data. This information is provided in Section 4.6 of the SAMDA submittal (TVA

201 Oa).

TVA used site-specific meteorological data for the 2002 calendar year as input to the

WinMACCS code. The data were collected from the onsite meteorological tower. Data from

2001 through 2005 were also considered, but the 2002 data were chosen because they were

found to give the largest risk based on sampling the population dose consequences for each

year with a reference set of fission product releases. Missing data were obtained by linear

interpolation from the recorded data. The NRC staff notes that previous SAMA analyses results

have shown little sensitivity to year-to-year differences in meteorological data and concludes

that the use of the 2002 meteorological data in the SAMDA analysis is reasonable. In response

to an NRC staff RAI, TVA stated that the WinMACCS evaluation for WBN2 applied a large

rainfall boundary condition that results in conservative deposition of radionuclides in the last

spatial interval (40 to 50 miles) (TVA 2010c). The NRC staff notes that previous SAMA

analyses have indicated that this assumption results in a relatively substantial increase in offsite

consequences.

All releases were modeled as occurring at a height of 10 meters, and buoyant plume rise

appropriate to the release category was modeled. TVA did not perform a sensitivity analysis on

these assumptions, instead citing previous SAMA analyses as indicating relatively small

changes in overall risk. Of the two SAMA analyses cited (i.e., Vogtle and Wolf Creek), one

shows an increase in population dose risk of up to 10 percent while the other shows a decrease

of 17 percent in population dose risk with an increase in release elevation from ground level to

the top of the containment building and/or heat release rates of 1 to 10 megawatts (MW) (SNC

2007, WCNOC 2006). The NRC staff notes that previous SAMA analyses have shown only

H-1 8
Appendix H

minor sensitivities to release height and buoyancy. The staff concludes that the release

parameters utilized are acceptable for the purposes of the SAMDA evaluation.

The population distribution the licensee used as input to the WinMACCS analysis was estimated

for the year 2040, based on the U.S. Census Bureau population data for 2000. A map was

prepared displaying county and census tract boundaries partly or entirely within the 50-mile

boundary. A grid of concentric circles and radii were overlaid on this map to display the 160

zones or sectors needed. County population data for 2000 were allocated to the appropriate

sectors, using census tracts to the extent feasible. Block groups were used where census tracts

crossed the sector boundaries. For sectors near the plant, aerial photographs and local

knowledge were used. Projected county growth rates to the year 2030 were then used and

extended using linear trend lines to the years 2040, 2050, and 2060 and the results applied to

each sector. Transient population was included based on peak recreation visitation estimates at

the various sites around the Tennessee River system. The numbers were estimated from TVA

recreational facility information and extrapolated to the year 2040 using population projections

for an eleven county region around the site. The NRC staff considers the methods and

assumptions for estimating population reasonable and acceptable for purposes of the SAMDA

evaluation.

The emergency evacuation model was modeled as a single sheltering and evacuation zone

extending out 16 kilometers (10 miles) from the plant. It was assumed that 99.5 percent of the

population would evacuate. This assumption is consistent with the NUREG-1 150 study (NRC

1990b). The NRC staff notes that previous SAMA analyses have shown only minor sensitivities

to the percent of population evacuated within the range of 95 and 100 percent. The evacuation

speed used in the SAMDA analysis of 2.2 miles per hour (mph) (1.0 meters per second) was

selected considering average evacuation speeds under adverse weather conditions using

evacuation data from the multi-jurisdictional emergency response plan for WBN (TVA 2006).

The evacuation was assumed to start after a sheltering and evacuation delay time of 45 minutes

and 2.5 hours respectively. These values were obtained from the multi-jurisdictional emergency

response plan and the NUREG-1 150 model.

A sensitivity analysis was performed in which the evacuation speed was decreased from 2.2

mph to 1.6 mph and then increased to 3.4 mph. The result was a small change in the

population dose risk (a maximum of approximately an 8% increase when the speed is reduced

to 1.6 mph) and no change in the offsite economic cost risk for each release category for the

baseline consequence analysis (TVA 201 lf).The NRC staff estimates that this increases the

MACR by approximately 0.5 percent. The NRC staff notes that the TVA analysis did not

account for the reduced evacuation speed that would result from population growth from the

time the evacuation time estimates were made to 2040. While this may decrease the speed

below that considered in the sensitivity study, the staff concludes that the impact on the risk

results will be small in light of the above result and since other studies have shown that

population dose is not very sensitive to evacuation speed and population dose risk contributes

only a relatively small part of the total maximum benefit. The NRC staff concludes that the

evacuation assumptions and analysis are reasonable and acceptable for the purposes of the

SAMDA evaluation.

H-19
Appendix H

The site-specific economic data input to WinMACCS2 code used for the SAMDA analysis was

provided from SECPOP2000 (NRC 2003b) by specifying the data for each of the counties

surrounding the plant to a distance of 50 miles. The original SAMDA submittal utilized

SECPOP2000 version 3.12 which was found to have several problems that could lead to

erroneous data being used. In response to an NRC staff RAI, TVA corrected the earlier

analysis using the results from SECPOP2000 version 3.13.1 which corrects the previous

version's errors (TVA 2010d). TVA utilized the corrected version in the updated and

subsequent SAMDA analysis. SECPOP2000 version 3.13.1 utilizes data from the 2000 census

and the 2002 Census of Agriculture to determine the population, land fractions and region index,

and associated economic data for each sector around the plant for use in WinMACCS. The

dollar values were increased by a factor of 1.15 to account for inflation from 2002 to 2007. This

was determined from the United States Bureau of Labor Statistics CPI (consumer price index)

Inflation Calculator (BLS 2010). The sector population from SECPOP2000 was replaced with

the TVA generated values discussed above. The NRC staff concludes that the approach taken

for determining the site-specific economic data is appropriate for the SAMDA analysis.

Since SECPOP2000 provides only generic values for the number of watersheds, the watershed

index, the watershed definition and the crop seasons and share, definitions and values more

appropriate for the WBN site were utilized. TVA described these changes and their basis (TVA

201 Oa) and the NRC staff concludes that their use is appropriate for the SAMDA analysis.

The MACCS2 analysis described above was performed for each of the representative scenarios

that contribute to each of the four release categories. The consequences in terms of personrem and offsite economic costs were then combined using the relative contribution each

representative scenario makes to its release category, as provided in Table 2.a.iv-3 of the

January 31, 2011 TVA submittal (TVA 2011 a). There are 11 representative scenarios: four for

release category I, one for release category II, four for release category III and two for release

category IV. The combined consequences for each release category were then used to assess

the risk associated with each SAMDA. In response to an NRC staff RAI, TVA provided the

source terms, other release parameters and the person-rem and off-site economic results for

each of the 11 representative scenarios. The revised consequences given in Table 2.a.iv-6 of

the September 16, 2011 submittal (TVA 201 lf) for the 11 representative scenarios were

averaged using the relative contributions cited above to yield the consequences for the four

release categories that were used in the cost benefit analysis of each SAMDA.

The NRC staff noted that this approach, while valid for the base case, may not be valid for the

determination of the risk reduction for a given SAMDA. The methodology assumes that the

relative contribution of the representative scenarios for a SAMDA remains the same as for the

base case. If a given SAMDA decreases the relative importance of a high consequence

scenario while not impacting other lower consequence scenarios, then the benefit of the

SAMDA would be underestimated. To assess the impact of this assumption on' the

determination of a SAMDA cost-benefit TVA performed a sensitivity study which applied the

worst accident scenario consequences of the representative scenarios making up a release

category to the entire release category to the evaluation of each SAMDA (TVA 201 ic). The

impact of this sensitivity study is discussed in Section H.6.2.

H-20
Appendix H

Subsequent to TVA's responses to all NRC staff RAIs, TVA determined that all the prior

consequence analysis were based on a misinterpretation of the consequence model (MACCS2)

output for the total person-rem for each of the several release categories (and representative

scenarios) and on two less significant source term errors (TVA 201 if). This misinterpretation

lead to an underestimate of the total person-rem for the base case and all SAMDAs. Revised

consequence and cost benefit results and a summary the impact of these changes on the

SAMDA evaluations and the responses to the prior RAI responses are provided in TVA's

September 16, 2011 (TVA 201 If) and October 17, 2011 (TVA 201 lg) submittals. The revised

consequence analysis are cited in the above discussions.

The NRC staff concludes that the corrected methodology used by TVA to estimate the offsite

consequences for WBN provides an acceptable basis from which to proceed with an

assessment of risk reduction potential for candidate SAMDAs. Accordingly, the NRC staff

based its assessment of offsite risk on the CDF and revised offsite doses reported by TVA.

H.3 Potential Plant Improvements

The process for identifying potential plant improvements, an evaluation of that process, and the

improvements evaluated in detail by WVA are discussed in this section.

H.3.1 Process for Identifying Potential Plant Improvements

TVA's process for identifying potential plant improvements (SAMDAs) consisted of the following

elements:

" Review of other industry documentation discussing potential plant improvements as

developed in NEI 05-01 (NEI 2005),

* Review of Phase II SAMAs from license renewal applications for five other U.S. nuclear

sites,

" Review of potential plant improvements identified in the WBN IPE and IPEEE,

" Review of the most significant basic events and systems from the WBN Unit 2 PRA

submitted in support of the original Unit 2 SAMDA assessment (TVA 2009a), and

* In response to NRC staff RAIs, review of the most significant basic events from the WBN

Unit 2 IPE based PRA submitted in support of the Updated SAMDA assessment (TVA

201 Oa).

Based on this process, an initial set of 307 candidate SAMDAs, referred to as Phase I SAMDAs,

was identified. In Phase I of the evaluation, TVA performed a qualitative screening of the initial

list of SAMDAs and eliminated SAMDAs from further consideration using the following criteria:

0 The SAMDA is not applicable to the WBN design,

H-21
Appendix H

" The SAMDA or its equivalent has already been implemented at WBN,

" The SAMDA is similar in nature and can be combined with another SAMDA,

" The SAMDA has estimated costs that would exceed the dollar value associated with

completely eliminating all severe accident risk at WBN, or

" The SAMDA is related to a non-risk significant system known to have negligible impact

on risk

Based on this screening, 269 SAMDAs were eliminated leaving 38 for further evaluation. The

remaining SAMDAs, referred to as Phase II SAMDAs, are discussed in Section 8 and listed in

Table 16 of the updated SAMDA submittal (TVA 2010a). In Phase II, a detailed evaluation was

performed for each of the 38 remaining SAMDA candidates, as discussed in Sections H.4 and

H.6 below. To account for the potential impact of external events, the estimated benefits based

on internal events were initially multiplied by a factor of 2. As discussed above, in response to

an NRC staff RAI, an external events multiplier of 2.28 was used in a subsequent reassessment

(TVA 2011 a).

In response to NRC staff RAIs, TVA addressed the potential for SAMDAs resulting from: the

enhancements identified in the Watts Bar Unit 1 SAMDA analysis (TVA 1994b), the review of

the WBN2 PRA down to a lower value of Risk Reduction Worth (RRW), and the dominant fire

zones as identified in the IPEEE. In this process 31 additional candidate SAMDAs were

identified. All were, however, screened from detailed analysis (TVA 2011 a). In assessing the

impact of the corrected consequence analysis on the SAMDA identification process TVA

identified one additional candidate SAMDA4. This SAMDA was screened out (TVA 201 if).

These additional SANDA candidates are discussed further below.

H.3.2 Review of TVA's Process

TVA's efforts to identify potential SAMDAs focused primarily on areas associated with internal

initiating events, but also, in response to an RAI, included explicit consideration of potential

SAMDAs for fire events. The initial list of SAMDAs generally addressed the systems and basic

events considered to be important to CDF and LERF from a risk reduction worth (RRW)

perspective at WBN, and included selected SAMDAs from prior SAMA analyses for other plants.

TVA provided a tabular listing of PRA basic events sorted according to their CDF RRW (TVA

2011a, TVA 2011f. SAMDAs impacting these basic events would have the greatest potential

for reducing risk. TVA reviewed the list down to a RRW cutoff of 1.006 (after accounting for the

impact of revised consequence on the MACR) for potential SAMDAs that could reduce operator

error such as enhanced procedures, training, etc. A RRW of 1.006, which corresponds to about

4 The September 16, 2011 submittal (TVA 201 1f) designated this new SAMDA candidate as SAMDA 340.

In the May 25, 2011 RAI responses (TVA 201 1c) a different SAMDA candidate was designated as

SAMDA 340. The May 25, 2011 SAMDA candidate, to install flood detection in areas 772.0-A8 and

772.0-A9, is refered to in this report as SAMDA 340. The new September 16, 2011 candidate SAMDA is

not referred to by a number in this review to avoid confusion.

H-22
Appendix H

a 0.6 percent change in CDF given 100-percent reliability of the SAMDA in eliminating the risk

due to the basic event, was selected as the threshold because it is approximately equivalent to

a benefit of $27,000 (the minimum cost for the types of enhancements mentioned above),

utilizing the revised MACR and an external event multiplier of 2.28. TVA reviewed the RRW list

down to 1.0227 (a 2.27% change in CDF) for hardware based modifications. This corresponds

to a $100,000 maximum benefit (TVA 2011 a, TVA 201 1f).

TVA also provided and reviewed the large early release frequency (LERF)-based RRW basic

events down to a RRW of 1.029. This was determined using the definition of LERF as the sum

of release categories I and II and corresponds to a benefit of $27,000 assuming that all changes

in frequency occurred in release category II since this release category has the greatest

consequences (TVA 2011 b). It is noted that with the revised consequence analysis this

screening value increases to 1.044 due to changes in offsite economic costs since the original

assessment (TVA 201 if).

Based on the review of these basic events and the important basic events in the WBN2 IPE

(TVA 2010b), TVA identified 49 new WBN2 specific SAMDAs. This number does not include

the SAMDAs previously identified from the generic SAMAs, from the review of other SAMA

assessments or from the WBN IPE or IPEEE insights and enhancements which also addressed

the WBN2 important basic events. In response to a NRC staff RAI, TVA correlated the Phase I

SAMDAs with the basic events having the highest risk importance in the Level 1 and 2 PRA.

With a few exceptions, all of the significant basic events (excluding the basic events which

represent "tag events" - not actual equipment or operator failure events - or physical

parameters) are addressed by one or more SAMDAs. Of the basic events of high risk

importance that are not addressed by SAMDAs, each is closely tied to other basic events that

had been addressed by one or more SAMDAs. The staff noted that no SAMDAs were identified

that directly address two emergency diesel generator sequencer failures which contribute a total

of about 2.3% to the CDF. In response to the RAI, TVA discusses the failure modes and

modeling of the sequencers and states that no credit is taken for emergency diesel generator

recovery in the WBN PRA. TVA also discusses the existence of plant procedures and training

that address some of the sequencer failure modes (TVA 2011 b). Considering that the modeling

is conservative and procedures not credited in the PRA address sequencer failure, the NRC

staff concludes that no additional SAMDA to address sequencer failures is likely to be cost

beneficial.

The WBN Unit 2 IPE did not result in the identification of any vulnerability. The IPE submittal

did cite three SAMDAs from the original WBN2 SAMDA assessment as providing a risk

reduction for internal events (TVA 2010b). The NRC staff noted that the WBN2 IPE submittal

cited two sets of sensitivity studies concerning internal flooding, including one which was

intended to evaluate alternative design/procedural changes that would significantly impact the

flood related CDF. In response to an RAI, TVA described these sensitivity studies which

supported the decision that, in addition to replacing carbon steel piping on the raw cooling water

piping in certain plant areas with stainless steel piping, TVA planned to install leak detection

instrumentation in these areas (TVA 2011 c). See the discussion concerning SAMDAs 293 and

294 below.

H-23
Appendix H

The review of the generic list of SAMAs as developed in NEI 05-01 (NEI 2005) led to 153

Phase I SAMDAs for WBN2. The review of Phase I SAMAs contained in the license renewal

applications for Cook, Catawaba, McGuire, Wolf Creek, and Vogtle led to the identification of

105 additional Phase I SAMDAs for WBN2.

Although no vulnerabilities were identified in the Unit 1 IPE, twelve procedural and hardware

enhancements and additional insights and recommendations were identified (TVA 1992).

These twelve were included in the SAMDA Phase I list. The Unit 1 IPE update identified

thirteen additional insights and recommendations (TVA 1994). In response to an NRC staff RAI,

TVA discusses each of these by indicating the Phase I SAMDA which addresses the item or

stating that it had been implemented at WBN (TVA 201 Oc).

In 1994, TVA performed a SAMDA analysis for WBN Unit 1 (TVA 1994b). A number of potential

enhancements were identified in this analysis and in the NRC's review of the analysis (NRC

1995). TVA, in response to an NRC staff RAI indicated that all of these enhancements have

been either implemented at WBN or included in the current Phase I SAMDA list (TVA 201 Oc).

Based on this information, the NRC staff concludes that the set of SAMDAs evaluated in the

EIS, together with those identified in response to NRC staff RAIs, addresses the major

contributors to internal event CDF.

Although several Phase I SAMDAs were identified based on the generic and other plant SAMA

reviews, the WBN2 SAMDA assessments did not include any WBN specific SAMDAs that

addressed external events. As discussed above, the WBN Unit 1 IPEEE did not identify any

vulnerability to external events (except one tornado missile issue which has been addressed).

The WBN Unit 2 IPEEE also did not identify any vulnerabilities, although validation and

finalization of this assessment will not be completed until plant construction is finished. The

NRC staff concludes that the availability of information and status of construction for WBN2 is

sufficient for the purposes of the SAMDA assessment to indicate that no vulnerabilities will be

identified. If any vulnerabilities are identified, these will be addressed under the IPE/IPEEE

program.

NRC requested that TVA consider potential SAMDAs for the dominant fire areas and scenarios

as identified in the WBN2 IPEEE. In response to this RAI, TVA provided a listing of the 18 fire

scenarios that contribute to more than 90 percent of the screening fire CDF in the dominant fire

areas (see Table H-3 above). From the review of this list TVA identified 20 additional Phase I

SAMDAs (TVA 2011 a).

As indicated above the WBN2 IPEEE includes a seismic margins assessment performed in

accordance with the requirements of Supplement 4 to GL 88-20 (NRC 2000). The lowest value

of HCLPF (0.36g) is greater than the review level earthquake of 0.3 g. TVA defined a seismic

vulnerability as any component on the Safe Shutdown Equipment List for which the HCLPF

capacity is less than 0.3g. There is thus some margin to this definition of a vulnerability. The

NRC staff's review of the Unit 2 IPEEE analysis concluded that TVA's definition of vulnerability

and its conclusion that no severe accident vulnerabilities exist at WBN2 are reasonable (NRC

201 le).

H-24
Appendix H

Based on the licensee's IPEEE and the expected cost associated with further risk analysis and

potential plant modifications, the NRC staff concludes that the opportunity for seismic and firerelated SAMDAs has been adequately explored and that it is unlikely that there are any

additional cost-beneficial seismic or fire-related SAMDA candidates.

The NRC staff questioned TVA about other lower cost alternatives to some of the SAMDAs

evaluated (NRC 2009), including:

* Purchasing or manufacturing a "gagging device" that could be used to close a stuckopen steam generator safety valve for a SGTR event prior to core damage.

* Utilizing the spare 5th diesel generator mentioned in the disposition of SAMDA 261

without going through the expense of complete refurbishing and licensing.

" Providing procedures and cabling to enable the use of the trailer-mounted 2 MW diesel

generator provided in response to GSI-189 to be used to power selected equipment

such as battery chargers and/or individual pumps.

* Purchasing and installing a permanent diesel-generator to supply power to the normal

charging pump.

In response to the RAI, TVA addressed the suggested lower cost alternatives and determined

that they are not feasible or had been implemented at WBN (TVA 2009b, TVA 201 la). This is

discussed further in Section H.6.2.

In response to NRC staff RAIs concerning the screening of Phase I SAMDAs, TVA provided

additional information on a number of SAMDAs to support the screening disposition. For those

WBN2 specific SAMDAs identified through the original RRW review that were screened as

"Already Implemented," TVA described the status of implementation at the plant and of

incorporation into the WBN PRA used in the review. A group of SAMDAs were screened on the

basis of design changes that were in progress or other actions to be taken in the future. TVA

discussed each, providing information on the status and schedule for the change or action. For

several SAMDAs screened out on the basis of "low benefit," TVA provided additional information

supporting this conclusion.

SAMDA 29, which is to provide capability for alternate injection via diesel-driven fire pump, was

identified from the list of generic SAMAs provided in NEI 05-01 rather than from WBN plant

specific PRA results. In response to NRC staff RAIs, TVA provided a discussion of the

sequences in which this SAMDA would potentially be a benefit, the existing procedures and

guidelines that would address these conditions, and the feasibility of implementing this SAMDA

(TVA 2011 b). The sequences potentially benefitted by this SAMDA all involve failure of the

RCP seal cooling with some involving loss of steam generator cooling. Existing procedures,

some of which involve use of the diesel-driven fire pump to prevent seal failure or loss of steam

H-25
Appendix H

generator cooling address these sequences. Further, the conditions under which RCS

depressurization to a pressure low enough to allow fire pump injection would be called for occur

only after core damage has already occurred. TVA also points out that other SAMDAs address

the sequences of concern here and TVA has committed to following the installation of a new

seal design that addresses the RCP seal failure and, if favorable, to install these new seals.

Based on this discussion, the NRC staff agrees that further pursuit of SAMDA 29 is not likely to

result in a cost-beneficial SAMDA.

SAMDA 58, which is to install improved reactor coolant pump seals, was initially screened as

not being applicable based on the cost for a new design by Westinghouse not being available

and, hence, since this SAMDA is not under TVA control, the inability to perform a cost benefit

analysis. Subsequently, TVA indicated that a cost estimate is available and that, while not cost

beneficial in the baseline analysis, it would be cost beneficial if the benefit analysis used the 9 5 th

percentile CDF. While TVA states that this SAMDA would not be considered further for

implementation, WVA does commit to following the initial experience with the new seal design

and, if proven reliable during operation, it would be installed at the earliest refueling outage

following startup during normal seal replacements (TVA 201 la).

SAMDA 80, which is to provide a redundant train or means of ventilation, was originally

screened on the basis of having a very low benefit. In response to NRC staff RAI concerning

the use of temporary fans and ducting to mitigate room cooling failures in the CCP area, the TD

AFW pump room, and the EDG switchgear rooms, TVA indicated that, since such equipment

was relatively inexpensive and easy to use, additional equipment will be made available and

procedures will be written for the use of such equipment in these areas (TVA 2011 b).

SAMDA 183, which is to implement internal flood prevention and mitigation enhancements, was

screened as being of very low benefit. Subsequently, two flood related SAMDAs, SAMDAs 293

and 294, associated with raw cooling water failures were added based on the review of the

RRW values for the October 2010 SAMDA PRA. These two SAMDAs were screened as having

already been identified as implementation commitments to the NRC. In response to an NRC

staff RAI, TVA indicated that they had committed to replacing the existing piping with stainless

steel piping. While credit was taken for the lower pipe leak frequencies in the SAMDA PRA,

floods from this piping in specific plant areas still contributed significantly to the CDF. Since

rerouting the raw cooling water piping was considered impractical, TVA committed to installing

flood detection instrumentation in these rooms (-VA201 la). This was supported by sensitivity

studies cited in the IPE and described in TVA's response to an RAI (TVA 2011c). This was

designated by TVA as SAMDA 340 (TVA 201 lc).

SAMDA 242, which is to provide a permanent dedicated generator for the normal charging

pump with local operation of the TD AFW pump after 125V battery depletion, was screened out

as having excessive implementation cost. In an NRC staff RAI it was noted that this SAMDA

was similar to SAMDA 255 (provide a permanent dedicated generator for the normal charging

pump, one motor driven AFW pump, and a battery charger), except that SAMDA 242 had a

smaller scope and therefore would be expected to have a smaller cost. WVA provided additional

information on the cost a benefit for SAMDA 242 that supported the screening.

H-26
Appendix H

SAMDA 314, which is to enhance training for local control of AFW given station blackout, loss of

control air, or fires affecting AFW level control valves (LCVs), identified from the review of the

fire FIVE assessment, was screened out as already implemented; citing SAMDAs 285 and 299.

The staff noted that while these SAMDAs cite enhancements to training in a general sense,

neither appears to specifically address the training enhancement needed for SAMDA 314. In

response to an NRC staff RAIto provide a specific citation which incorporates the requirements

of SAMDA 314, TVA provided a discussion of the existing training and cited the procedures that

deal with failures due to the fires in the key fire areas and specifically the local manual operation

of the AFW LCVs. In addition, TVA, as part of its response to questions on the Appendix R

analysis, has committed to provide a new capability to allow the operators, from the control

room, to transfer from normal compressed air supply to the station nitrogen system for control of

the LCVs. This would be expected to have a greater benefit for these fire scenarios then the

enhanced training of SAMDA 314 (TVA 2011 b). The NRC staff concludes that the existing

training and the new commitment for use of the nitrogen supply adequately addresses the

mitigation of fire scenarios originally addressed by SAMDA 314.

The NRC staff notes that one SAMDA (SAMDA 273, which is to provide a redundant path for

emergency core cooling system (ECCS) suction from the refueling water storage tank (RWST)

around check valve 62-504), originally identified and included as a Phase II SAMDA in the

January 2009 submittal (TVA 2009) was subsequently screened in the updated submittal (TVA

2010a). Check valve 62-504 appeared in the original list of important components but did not

have a RRW of 1.007 or greater in the revised analysis. Based on the NRC staff review, the

NRC staff considers this screening to be appropriate.

The NRC staff notes that the set of SAMDAs submitted is not all inclusive, since additional,

possibly even less expensive, design alternatives can always be postulated. However, the NRC

staff concludes that the benefits of any additional modifications are unlikely to exceed the

benefits of the modifications evaluated and that the alternative improvements would not likely

cost less than the least expensive alternatives evaluated, when the subsidiary costs associated

with maintenance, procedures, and training are considered.

The NRC staff concludes that TVA used a systematic and comprehensive process for

identifying potential plant improvements for WBN, and that the set of potential plant

improvements identified by TVA is reasonably comprehensive and therefore acceptable. This

search included reviewing insights from the plant-specific risk studies, and reviewing plant

improvements considered in previous SAMDA analyses. While explicit treatment of external

events in the SAMDA identification process was limited, it is recognized that the absence of

external event vulnerabilities reasonably justifies examining primarily the internal events risk

results for this purpose.

H.4 Risk Reduction Potential of Plant Improvements

TVA evaluated the risk-reduction potential of the 38 remaining SAMDAs that were applicable to

WBN. The majority of the SAMDA evaluations were performed in a bounding fashion in that the

H-27
Appendix H

SAMDA was assumed to completely eliminate the risk associated with the proposed

enhancement. Such bounding calculations overestimate the benefit and are conservative.

TVA used model re-quantification to determine the potential benefits. The CDF and population

dose reductions were estimated using the WBN2 PRA (version WBNUlU2_FLOOD_SAMA)

model and the Level 3 consequence analysis. The changes made to the model to quantify the

impact of SAMDAs are detailed in Section 8 of the updated SAMDA assessment (TVA 2010a).

Table H-4 lists the assumptions considered to estimate the risk reduction for each of the

evaluated SAMDAs, the estimated risk reduction in terms of percent reduction in CDF and

population dose, and the estimated total benefit (present value) of the averted risk. The

estimated benefits reported in Table H-4 reflect the combined benefit in both internal and

external events, as well as a number of changes to the analysis methodology subsequent to the

above referenced submission. The determination of the benefits for the various SAMDAs is

further discussed in Section H.6.

The NRC staff questioned the assumptions used in evaluating the benefits or risk reduction

estimates of certain SAMDAs provided in the SAMDA assessment (TVA 201 la).

For SAMDA 45, which is to enhance procedural guidance for the use of cross-tied component

cooling or service water pumps, TVA clarified that the model requantification assumed that the

cross-tie provided backup cooling not only to the charging pumps but to the component cooling

system and all of its loads.

For SAMDA 70, which is to install accumulators for turbine-driven auxiliary feedwater pump flow

control valves, the risk benefit is stated to be bounded by eliminating the cognitive portion of

human error to restore AFW control following loss of instrument air. TVA supported the

assumption on the basis that the feasible accumulator size would only provide enough air for a

few cycles of the flow control valves, hence operator action would ultimately be required. The

additional time for operator response provided by the accumulators is assumed to eliminate the

cognitive portion of the human error but not the action portion. In response to an RAI TVA

confirmed that the assessment eliminated the relevant cognitive portion of the human error in

both the independent and dependent human error contributors. Subsequently, as discussed

above, TVA has committed to provide a new capability to allow the operators from the control

room to transfer from normal compressed air supply to the station nitrogen system for control of

the LCVs. This new capability, identified by TVA as SAMDA 339, will have a greater benefit

than that associated with SAMDA 70 and thus supersedes it (TVA 2011 b). The NRC staff

agrees that this commitment adequately dispositions SAMDA 70.

For SAMDA 93, which is to install an unfiltered hardened containment vent to eliminate the

containment overpressure failure, TVA provided additional information on the adjustments made

to the LATE release category to evaluate the benefit of this SAMDA. The early portion of the

category for the releases from the reactor coolant system remained unchanged, while the later

portion for the releases for the core-concrete interaction phase were taken to be half of those

from the SEQSOR methodology for late rupture. The NRC staff noted that TVA's assessment

indicated there is no reduction in CDF for SAMDA 93. The usual purpose of containment

venting is to prevent core damage for loss of containment heat removal sequences where the

H-28
Appendix H

functioning core injection systems would fail upon containment overpressure failure. In

response to an RAI to discuss the reason why there is no CDF reduction for this SAMDA, TVA

provided a discussion of core damage modeling in the Sequoyah NUREG-1150 analysis (NRC

1990c) and the specific sequences at WBN that might lead to a CDF reduction for containment

venting (TVA 2011 b). The WBN CAFTA model adopts a similar approach as that found in

NUREG-1 150 modeling of Sequoyah. This approach evaluates the frequency of core damage

as independent of containment heat removal and thus venting (which is equivalent in impact to

containment heat removal) would not affect the CDF. TVA provides a discussion and bounding

analysis of the WBN sequences for which containment venting might reduce the CDF. The

result indicates a maximum potential CDF reduction of approximately 6 x 10.9 per year, which is

equivalent to an added cost benefit of $1,400. This is very small contribution to the estimated

benefit due to release category changes alone of $1,100,000. While the above cost benefit

values increase slightly (10 - 15 percent) as a result of the revised consequence analysis, the

conclusion remains valid. The NRC staff agrees that TVA's updated assessment of the benefit

of SAMDA 93 is acceptable for the SAMDA analysis.

For SAMDA 110, which is to erect a barrier that would provide enhanced protection of the

containment walls (shell) from ejected core debris following a core melt scenario at high

pressure, the NRC staff questioned the basis for the benefit which was originally estimated by

removing the rocket mode and ex-vessel steam explosion failure modes from the containment

event tree. TVA revised the assessment to only eliminate the rocket mode from the model since

core debris would only be expected to reach the containment wall for high pressure reactor

pressure vessel failures such as those that lead to the rocket mode but not ex-vessel steam

explosions. The rocket mode was utilized since the Level 2 risk model did not explicitly include

the debris impingement failure mode due to the assumption that the seal table would prevent

this impingement. In addition, debris impingement would only be possible for station blackout

sequences since, with AC power available, containment spray injection would be expected to

flood the reactor cavity. The probability of rocket mode failure of 0.05 was set to zero for a

number of containment event tree split fractions. Estimation of the risk reduction using this

value is considered adequate by TVA to represent the debris impingement mode based on

information from NUREG-1 150 (NRC 1990a). TVA reported the results of two sensitivity studies

making different assumptions concerning the Level 2 model. Both resulted in smaller risk

benefits than elimination of the rocket mode of failure (TVA 2011 a, TVA 2011 b). Based on

these results and the fact that this SAMDA potentially reduces the risk of only a small portion of

the core damage frequency, the staff concludes that SAMDA 110 would not be cost beneficial.

For SAMDA 215, which is to provide a means to ensure reactor coolant pump (RCP) seal

cooling so that RCP seal LOCAs are precluded for SBO events, the benefit was assessed by

modifying RCP seal LOCA probabilities. The NRC staff questioned limiting the benefit to only

SBO scenarios. TVA confirmed that the modified seal LOCA probabilities were made for all

sequences including SBO, loss of ERCW, or loss of component cooling system.

For SAMDA 299, which is to initiate frequent awareness training for plant

operators/maintenance/testing staff on key human actions for plant risk, the NRC staff

questioned the calculated reduction in CDF compared to the similar but apparently more limited

H-29
Appendix H

SAMDA 300. TVA indicated that the title of SAMDA 299 is slightly misleading in that the training

for operators had already been implemented and this SAMDA should have been described as

additional training for maintenance and testing staff as appropriate to address key actions they

perform.

For SAMDA 300, which is to revise procedure FR-H.1 to eliminate and/or simplify complex

decision logic for establishing feed and bleed cooling and to improve operator recovery from

initial mistakes both of which involve reducing human errors associated with CDF and release

categories, TVA revised the benefit analysis to be based on eliminating only the action portion

of the human error.

For SAMDAs 303 and 305, both of which involve actions to reduce operator error to initiate

hydrogen igniters, the risk benefit for both was stated to be determined by setting the human

action to place igniters in service as success. The NRC staff questioned the assessment since

the net benefit of the two SAMDAs is significantly different. TVA corrected the assessment of

SAMDA 303 by indicating that the SAMDA would only reduce the cognitive portion of the human

error and thus the benefit was based on eliminating this portion of the human action. For

SAMDA 305, TVA indicated that the procedure change would have a greater impact on the

human error than SAMDA 303 and the benefit would be bounded by the elimination of all

human error to initiate the igniters.

The NRC staff has reviewed TVA's bases for calculating the risk reduction for the various plant

improvements as described in the SAMDA assessments and in response to NRC staff RAIs and

concludes that the rationale and assumptions for estimating risk reduction are reasonable and

generally conservative (i.e., the estimated risk reduction is higher than what would actually be

realized). Accordingly, the NRC staff based its estimates of averted risk for the various

SAMDAs on TVA's risk reduction estimates.

H-30
Appendix H

Table H-4. SAMDA Cost/Benefit Screening Analysis for WBN(a)

% Risk Reduction Total Benefit ($)

SAMDA Assumptions Baseline Baseline with Cost ($)

CDF(b) Population (Internal + Uncertainty(d)

Dose(b) External(C))

4 - Improve DC bus load shedding AC power always recovered prior to 1.1 1.2 40K 110K 32K

battery failure.

8 - Increase training on response to Eliminate the contributions of the 0.8 -0 12K 350K 27K

loss of two 120V AC buses which loss of 120V bus initiators

causes inadvertent actuation signal

26 - Provide an additional high Added a new basic event in parallel with 11.4 1.4 65K 180K 3.6M

pressure injection pump with existing HPI pump without any power

independent diesel dependency

32 - Add the ability to automatically Swapover to high pressure recirculation 7.4 12 400K 1.1M 2.1 M

align emergency core cooling system to is always successful

recirculation mode upon refueling water

storage tank depletion

45 - Enhance procedural guidance for Cross-tying ERCW headers is always

use of cross-tied component cooling or successful. 0.3 -0 5K 14K 32K

service water pumps

46 -Add service water pump ERCW pump 1A-A is always successful 7.0 3.7 150K 410K 1.0M

56 - Install an independent reactor RCP seal injection is always successful 24 29 1.1M 3.2M 8.2M

coolant pump seal injection system, when AC power available

without dedicated diesel

H-31
Appendix H

% Risk Reduction Total Benefit ($)

SAMDA Assumptions Baseline Baseline with Cost ($)

CDF(b) Population (internal + Uncertainty(d) Dose(b) External(c))

70 - Install accumulators for turbine- Operator cognitive error to manually 2.5 2.2 100K 280K(e) 260K

driven auxiliary feedwater pump flow operate the valves to control level set

control valves [Superseded by to zero

SAMDA 339](e)

71 - Install a new condensate storage New tank would require same operator -0(f) ~0M -0 -0 1.7M

tank (auxiliary feedwater storage tank) actions as current design

87 - Replace service and instrument air Normal plant air system is always 0.2 -0 2.2K 6.0K 890K

compressors with more reliable successful.

compressors which have self -contained

air cooling by shaft driven fans

93 - Install an unfiltered hardened LATE release category revised to be 0 38 1.2M 3.5M 3.1M

containment vent to eliminate the half the release for a late

containment overpressure failure containment rupture from the

SEQSOR release methodology.

101 - Provide a reactor exterior cooling Removed the rocket mode and ex- 0 8.5 210K 580K 2.5M

system to cool a molten core before vessel steam explosion failure modes

vessel failure from the containment failure probability

103 - Institute simulator training for Eliminated human action failure to 33 32 1.4M 3.9M 8.OM

severe accident scenarios arrest the severe accidents

109- Install a passive hydrogen control Assumed hydrogen igniters always 0 12 300K 840K 3.7M

system successful

H-32
Appendix H

% Risk Reduction Total Benefit ($)

SAMDA Assumptions Baseline Baseline with Cost ($)

CDF(b) Population (Internal + Uncertainty(d)

Dose(b) External(c))

110 - Erect a barrier that would provide Set rocket mode early containment 0 4.0 100K 290K 1.2M

enhanced protection of the containment failure probability (0.05) to zero for high

walls (shell) from ejected core debris pressure vessel breach sequences

following a core melt scenario at high

pressure.

112 - Add redundant and diverse limit Completely eliminate all ISLOCA <0.1 -0 3.2K 8.9 690K

switches to each containment isolation events.

valve

136 - Install motor generator set trip Operator action to trip reactor is always 0.9 -0 13K 37K 240K

breakers in the control room successful

156 - Eliminate RCP thermal barrier RCP seal injection is always 13 20 7 8 0K(h) 2.2M" 32K

dependence on CCW, such that loss successful when AC power is

of CCW does not result directly in available.

core damage (Enhance procedural

guidance for use of ERCW for RCP

thermal barrier cooling)()

176 - Provide a connection to alternate Remove grid related failures from 19 17 780K 2.2M 9.1M

offsite power source frequency of loss of offsite power

191 - Provide self-cooled ECCS seals Eliminate seal cooling failures -00) -0 -0 -0 10M

215 - Provide a means to ensure Assume for SBO that 21 GPM seal 26 31 1.3M 3.7M 1.5M

RCP seal cooling so that RCP seals event always occurs and other seal

LOCAs are precluded for SBO events LOCAs never occur

H-33
Appendix H

% Risk Reduction Total Benefit ($)

SAMDA Assumptions Baseline Baseline with Cost ($)

CDFo) CD~) Population(d Dosep(b) (Internal + Uncertainty(dl

External(c))

226 - Provide permanent self- Assume guaranteed success of seal 26 31 1.3M 3.7M 2.7M

powered pump to back up normal injection system

charging pump

255 - Install a permanent, dedicated Added an additional diesel generator to 18 20 840K 2.3M 3.2M

generator for the normal charging the power inputs of one charging pump,

pump, one Motor Driven AFW Pump one AFW pump and one battery charger

and a Battery Charger

256 - Install fire barriers around Reduce CDF and consequences of all 25 25 1.1M 3.1M 20K

cables or reroute the cables away release categories except SGTR by

from fire sources (Enhance 25%

procedure for controlling temporary

alterations to reduce fire risk from

temporary cables)(g)

276 - Provide an auto start signal for Beneficial only for startup accidents 0.7 0.6 25K 70K 620K

the AFW on loss of standby feedwater which are assumed to have

pump approximately same risk as at-power

accidents. Reduce risk for all initiators

except SGTR by 1/365 assuming that

standby feedwater pump in use for a

total time of one day per year

279 - Provide a permanent tie-in to the Assume air compressor D is always 1.8 1.6 72K 200K 910K

construction air compressor successful given success of power

supply and no flood events.

H-34
Appendix H

% Risk Reduction Total Benefit ($)

SAMDA Assumptions Baseline Baseline with Cost ($)

CDF(b) Population (Internal + Uncertainty(d)

Dose(b) Externallc))

280 - Add new Unit 2 air compressor Assume air compressor D is always 1.8 1.6 72K 200K 810K

similar to the Unit 1 D compressor successful given success of power

supply and no flood events.

282 - Provide cross-tie to Unit 1 RWST Assume operator actions involving 1-.3 -0 21K 58K 10M

makeup to RWST set to success and

cognitive error to sump swapover

eliminated

285 - Improve training to establish Set human action to initiate bleed 6.4 0.3 140K 144K 27K

feed and bleed cooling given no and feed cooling and associated

CCPs are running or a vital dependent events to guaranteed

instrument board fails success

292 - Improve training to reduce Set human action to terminate safety 4.2 13 400K 1.1M 27K

failure probability to terminate injection to prevent PORV water

inadvertent safety injection prior to challenge to guaranteed success

water challenge to PORVs

295 - Increase frequency of Set containment small and preexisting 0 6.1 144K 400K 2.5M

containment leak rate testing leak frequency to zero

H-35
Appendix H

% Risk Reduction Total Benefit ($)

SAMDA Assumptions Baseline Baseline with Cost ($)

CDF(b) Population (Internal + Uncertainty(d)

Dose(b) External(c))

299 - Initiate frequent awareness Reduced key human actions for CDF 4.6 6.6 290K 793K 27K

training for plant and release category

operators/maintenance/testing staff

on key human actions for plant

risk(Initiate frequent awareness

training for maintenance and testing

staff as on key human actions for

plant risk)(g)

300 - Revise procedure FR-H.1 to Reduce human error rate of operator 3.4 0.2 57K 160K 100K

eliminate and/or simplify complex action to initiate bleed and feed

decision logic for establishing feed cooling to just the cognitive part

and bleed cooling and to improve

operator recovery from initial

mistakes

303 - Move indicator/operator interface Set the cognitive portion of human 0 -0 1.7K 4.8K 50K

for starting igniters to front MCR panel action to place igniters in service as

success

304 - Add annunciator or alarm Set the cognitive portion of human 0 -0 1.7K 4.8K 50K

signaling parameters to initiate action to place igniters in service as

hydrogen igniters to front panel on MCR success

305 - Revise procedure E-1 to Set human action to place igniters in 0 6.2 150K 420K 100K

include recovery steps for failure to service as success

initiate hydrogen igniters

H-36
Appendix H

% Risk Reduction Total Benefit ($)

SAMDA Assumptions Baseline Baseline with Cost ($)

CDF(b) Population (Internal + Uncertainty(d)

Dose(b) External(c))

306 - Improve operator performance Reduce joint probability of 2.4 5.3 170K 470K 100K

by enhancing likelihood of recovery dependent action involved in

from execution errors important recovery action

307 - Make provisions for connecting Added potential for using ERCW for 0.1 0.0 0.6K 1.7K 99K

ERCW to CCP 28-B CCP 28-B similar to that for CCP 2A-A

339 - Provide a capability to allow the Not explicitly evaluated.(e) NA(e) NA(e) NA(e) NA(e) NA(e)

operators from the control room to

transfer from normal compressed air

supply to the station nitrogen system

for control of the AFW LCVs.

340 - Install flood detection in areas Not explicitly evaluated.(') NA(') NA(') NA(') NA(') NA')

772.0-A8 and 772.0-A9

NA - Not available

(a) SAMDAs in bold are potentially cost-beneficial, and have either been committed to be further considered for implementation by TVA and/or have

already been implemented. See the discussion in Section H.6.2

(b) Determined by NRC staff from values given by TVA (TVA 201 Oa, TVA 201 la, TVA 201 1f, TVA 201 1g)

(c) Using an external events multiplier of 2.28

(d) Determined from baseline benefit times a 95th percentile to point estimate ratio of 2.78. Note that this is different from the 2.70 value used by TVA. See

the discussion in Section H.6.2 below.

(e) While SAMDA 70 is slightly cost beneficial at the 9 5 th percentile CDF uncertainty, it has been superseded by SAMDA 339 to which TVA has committed

and should have a greater benefit. See the discussion below.

(f) TVA states that the risk benefit of the SAMDA is zero. While the NRC staff believes the risk benefit may not be zero it does conclude that it is negligible

compared to the estimated cost.

(g) SAMDA title given in parentheses is considered a more accurate description of the actual SAMDA.

(h) Due to time constraints, procedure change envisioned for SAMDA 156 is now considered not to be effective; hence benefit would be essentially

negligible. Hardware change considered in SAMDA 215.

(i) This SAMDA captures the previous commitment by TVA to install this flood detection equipment (TVA 2011 c).

H-37
Appendix H

H.5 Cost Impacts of Candidate Plant Improvements

The costs of implementing the 38 candidate SAMDAs was estimated by TVA and focused on

labor (craft, engineering, etc.) and component cost related to installing the proposed physical

change. Costs do not include lifetime operation, testing or maintenance costs or contingency

for unforeseen obstacles or inflation(TVA 2010c). Procedure development and training

associated with the physical changes were also not included, except for those SAMDAs which

were solely procedural and/or training activities (TVA 201 la).

The NRC staff reviewed the bases for the applicant's cost estimates as described above. In

response to an NRC staff RAI concerning per unit cost savings associated with implementing

the changes to both WBN units, TVA stated that the cost of procedural or training module

development is only marginally increased to apply to a second unit and that for physical unit

design changes the costs are for the affected unit only (TVA 201 la). While TVA states that

dividing the cost of procedure and training SAMDAs by a factor of two would not be appropriate,

the NRC staff concludes that the per unit cost of physical changes (for the scope of the cost

estimate as described above) would be less then that given by TVA. The scope of TVAs cost

estimate, however, does not include lifetime costs associated with the procedure and training

and hence is conservative. This is borne out by comparison with similar costs given in license

renewal SAMA submittals. With regard to physical changes, the NRC staff concludes that while

there may be some savings with respect to sharing engineering costs between units to the

extent that these cost are included in the cost estimate, other factors such as lifetime costsand

procedure and training associated with the change that are not included in TVA's estimate result

in a conservative estimate for use in the SAMDA assessments. Further, in response to a

specific RAI concerning SAMDA 70, TVA stated that engineering and design cost were not

considered (TVA 2011 b). This is the only SAMDA where such cost savings would impact the

cost-benefit conclusions.

For a number of the Phase II SAMDAs evaluated by TVA, the information provided did not

sufficiently describe the associated modifications and what is included in the cost estimate. In

response to an NRC staff RAI, TVA provided a more detailed description of both the

modification and the cost estimate for these SAMDAs (TVA 2010c). This information resolved

the NRC staff concerns. In addition, conflicting information was provided for the costs

associated with several SAMDAs. In response to an NRC staff RAI, TVA discussed the reasons

for these differences and indicated the correct value to be used in the cost benefit analysis (TVA

2010c).

The NRC staff concludes that the cost estimates provided by TVA are sufficient and appropriate

for use in the SAMDA evaluation.

H-38
Appendix H

H.6 Cost-Benefit Comparison

TVA's cost-benefit analysis and the NRC staff's review are described in the following sections.

H.6.1 TVA's Evaluation

The methodology used by TVA was based on NEI 05-01, Severe Accident Mitigation

Alternatives (SAMA) Analysis Guidance Document (NEI 2005),which in turn is based on NRC's

guidance for performing cost-benefit analysis, i.e., NUREG/BR-0184, Regulatory Analysis

Technical Evaluation Handbook (NRC 1997b). NEI 05-01 was endorsed for use in license

renewal application by the NRC (NRC 2007). The guidance involves determining the net value

for each SAMA (or SAMDA) according to the following formula:

Net Value = (APE + AOC + AOE + AOSC) - COE where,

APE = present value of averted public exposure ($)

AOC = present value of averted offsite property damage costs ($)

AOE = present value of averted occupational exposure costs ($)

AOSC = present value of averted onsite costs ($)

COE = cost of enhancement ($).

If the net value of a SAMDA is negative, the cost of implementing the SAMDA is larger than the

benefit associated with the SAMDA and it is not considered cost-beneficial. TVA's derivation of

each of the associated costs is summarized below.

NUREG/BR-0058 has recently been revised to reflect the agency's policy on discount rates.

Revision 4 of NUREG/BR-0058 states that two sets of estimates should be developed-one at

3 percent and one at 7 percent (NRC 2004b). TVA performed the SAMDA analysis using

7 percent and provided a sensitivity analysis using the 3 percent discount rate in order to

capture SAMDAs that may be cost-effective using the lower discount rate, as well as the higher,

baseline rate (TVA 201 la). This analysis is sufficient to satisfy NRC policy in Revision 4 of

NUREG/BR-0058.

Averted Public Exposure (APE) Costs

The APE costs were calculated using the following formula:

APE = Annual reduction in public exposure (A person-rem per year)

x monetary equivalent of unit dose ($2000 per person-rem)

x present value conversion factor (13.42 based on a 40-year period with a

7-percent discount rate).

As stated in NUREG/BR-0184 (NRC 1997a), it is important to note that the monetary value of

the public health risk after discounting does not represent the expected reduction in public

health risk due to a single accident. Rather, it is the present value of a stream of potential

H-39
Appendix H

losses extending over the remaining lifetime (in this case, the operating license period) of the

facility. Thus, it reflects the expected annual loss due to a single accident, the possibility that

such an accident could occur at any time over the time period, and the effect of discounting

these potential future losses to present value. For the purposes of initial screening, which

assumes elimination of all severe accidents due to internal events, TVA calculated an APE of

approximately $536,000 for the 40-year license period (TVA 201 if).

Averted Offsite Property Damaqe Costs (AOC)

The AOCs were calculated using the following formula:

AOC = Annual CDF reduction

x offsite economic costs associated with a severe accident (on a per-event basis)

x present value conversion factor.

For the purposes of initial screening, which assumes all severe accidents due to internal events

are eliminated, TVA calculated an annual offsite economic risk of about $53,700 based on the

Level 3 risk analysis. This results in a discounted value of approximately $720,000 for the 40-

year license period (TVA 201 if).

Averted Occupational Exposure (AOE) Costs

The AOE costs were calculated using the following formula:

AOE = Annual CDF reduction

x occupational exposure per core damage event

x monetary equivalent of unit dose

x present value conversion factor.

TVA derived the values for averted occupational exposure from information provided in Section

5.7.3 of the regulatory analysis handbook (NRC 1997a). Best estimate values provided for

immediate occupational dose (3300 person-rem) and long-term occupational dose (20,000

person-rem over a 10-year cleanup period) were used. The present value of these doses was

calculated using the equations provided in the handbook in conjunction with a monetary

equivalent of unit dose of $2000 per person-rem, a real discount rate of 7 percent, and a time

period of 40 years to represent the license period. For the purposes of initial screening, which

assumes all severe accidents due to internal events are eliminated, TVA calculated an AOE of

approximately $8,150 for the 40-year license period.

Averted Onsite Costs

Averted onsite costs (AOSC) include averted cleanup and decontamination costs and averted

power replacement costs. Repair and refurbishment costs are considered for recoverable

accidents only and not for severe accidents. TVA derived the values for AOSC based on

H-40
Appendix H

information provided in Section 5.7.6 of NUREG/BR-0184, the regulatory analysis handbook

(NRC 1997a).

AOSC = [(present value of cleanup costs per core damage event x present value conversion

factor)

+ (present value of replacement power for a single event x factor to account for

remaining service years for which replacement power is required x reactor power

scaling factor)] x annual CDF reduction

The total cost of cleanup and decontamination subsequent to a severe accident is estimated in

the regulatory analysis handbook to be $1.5 x 109 (undiscounted). This value was converted to

present costs over a 10-year cleanup period and integrated over the 40 year license period to

give 1.45 x 1010 S-years.

TVA based its calculations on the value of 1160 megawatt electric (MWe). Therefore, TVA

applied a power scaling factor of 1160/910 to determine the replacement power costs. Using

the methodology of NUREG/BR-0184 for a 7 percent discount rate the resulting net present

value of replacement power integrated over the 40 year license period is 2.43 x 1010 $-years.

For the purposes of initial screening, which assumes all severe accidents due to internal events

are eliminated, TVA calculated an AOSC of approximately $666,000 for the 40-year license

period.

Using the above equations, TVA estimated the total present dollar value equivalent associated

with completely eliminating severe accidents from internal events at WBN to be about

$1,930,000. Use of a multiplier of 2.28 to account for external events increases the value to

$4,401,000 and represents the dollar value associated with completely eliminating all internal

and external event severe accident risk at WBN Unit 2, also referred to as the Modified

Maximum Averted Cost Risk (MMACR) (TVA 201 if).

TVA's Results

If the implementation costs for a candidate SAMDA exceeded the calculated benefit,*the

SAMDA was considered not to be cost-beneficial. In TVA's SAMDA submittal, this is

expressed, not as a negative net value (SAMDA benefit less than cost), but as a benefit to cost

ratio for the SAMDA that is less than 1.0. The benefit, cost, and benefit to cost ratio for the

Phase II SAMDAs are given in the revised Table 2.a.iv-8 of TVA's September 16, 2011

submittal (TVA 201 if). This table incorporates revised analysis taking into account the

responses to NRC staff RAIs on the prior results as well as the results of the corrected

consequence analysis.

In the baseline analysis contained in the January 31, 2011, submittal (using a 7 percent

discount rate and an external events multiplier of 2.28), TVA identified eight potentially costbeneficial SAMDAs. The potentially cost-beneficial SAMDAs are:

H-41
Appendix H

" SAMDA 4 - Improve DC bus Load shedding

* SAMDA 156- Eliminate RCP thermal barrier dependence on CCW, such that loss of

CCW does not result directly in core damage (Enhance procedural guidance for use of

ERCW for RCP thermal barrier cooling)*

" SAMDA 256- Install fire barriers around cables or reroute the cables away from fire

sources (Enhance procedure for controlling temporary alterations to reduce fire risk from

temporary cables)*

" SAMDA 285 - Improve training to establish feed and bleed cooling given no CCPs are

running or a vital instrument board fails

" SAMDA 292 - Improve training to reduce failure probability to terminate inadvertent

safety injection prior to water challenge to PORVs

" SAMDA 299 - Initiate frequent awareness training for plant

operators/maintenance/testing staff on key human actions for plant risk (Initiate frequent

awareness training for maintenance and testing staff as on key human actions for plant

risk) *

• SAMDA 305 - Revise procedure E-1 to include recovery steps for failure to initiate

hydrogen igniters

* SAMDA 306 - Improve operator performance by enhancing likelihood of recovery from

execution errors

* SAMDA title given in parentheses is as given in Section 10, Conclusions, of the

submittals and is a more accurate description of the actual SAMDA.

It was subsequently determined that, due to time constraints, the procedural enhancements of

SAMDA 156 would not be effective and hence this SAMDA would not have the benefit originally

estimated. Also, it was determined that, relative to SAMDAs 305 and 306, the human reliability

analysis in the PRA had not credited recovery steps in an existing procedure (SAG-6

"Containment Control Conditions") and hence these SAMDAs have already been implemented.

TVA performed additional analyses to evaluate the impact of discount rate, CDF uncertainties

and parameter choices on the results of the SAMDA assessment (TVA 201 1f). If the benefits

are calculated for a 3 percent discount rate or increased by a factor of 2.7 to account for

uncertainties, six additional SAMDA candidates were determined to be potentially costbeneficial:

* SAMDA 8 - Increase training on response to loss of two 120V AC buses which causes

.inadvertent actuation signal

H-42
Appendix H

* SAMDA 70 - Install accumulators for turbine-driven auxiliary feedwater pump flow

control valves

" SAMDA 93 - Install an unfiltered hardened containment vent to eliminate the

containment overpressure failure

" SAMDA 215 - Provide a means to ensure RCP seal cooling so that RCP seals LOCAs

are precluded for SBO events

" SAMDA 226 - Provide permanent self-powered pump to back up normal charging pump

* SAMDA 300 - Revise procedure FR-H.1 to eliminate of simplify complex (and/or)

decision logic for establishing feed and bleed cooling and to improve operator recovery

from initial mistakes

SAMDA 215, which is to provide a means to ensure RCP seal cooling so that RCP seals

LOCAs are precluded for SBO events, is considered by TVA to'be essentially the replacement

of the RCP seals with a new design which eliminates the high leakage seal failure mode. This

is the same as SAMDA 58 and is discussed further in Sections H.6.2 and H.7 below.

H.6.2 Review of TVA's Cost-Benefit Evaluation

The cost-benefit analysis performed by TVA was based primarily on NUREG/BR-0184 (NRC

1997a) and was executed consistent with this guidance.

To account for external events, TVA initially multiplied the internal event benefits by a factor of 2

for each SAMDA. As discussed above in Section H.2.2, in response to an NRC staff RAI, TVA

increased this to 2.28, and this value was used for the results discussed above and included in

the results in Table H-4. As a result of TVA's baseline analysis, eight SAMDAs (SAMDAs 4,

156, 256, 285, 292, 299, 305 and 306, as described above) were identified as potentially costbeneficial.

As indicated above, TVA considered the impact of discount rate, CDF uncertainties and

parameter choices on the results of the SAMDA assessment (TVA 201 if). The results of the

discount rate assessment are provided in the updated Table 2.a.iv-9 of the September, 16, 2011

submittal (TVA 201 1f). The change in discount rate from 7 percent used in the baseline case to

3 percent used in the sensitivity analysis increases the assessed benefit of all SAMDAs but only

changed the conclusion concerning the cost-benefit of SAMDAs 215 and 300. The disposition

of these SAMDAs is discussed below in Section H.7. Moreover, these results indicated that the

impact of the 3 percent discount rate was less than that of the CDF uncertainty. Hence, the

SAMDAs that are cost-beneficial based on the CDF uncertainty incorporate those that are cost

beneficial considering the 3 percent discount rate.

H-43
Appendix H

TVA provided the results of an additional sensitivity analysis of evacuation speed, a WinMACCS

input parameter. This analysis did not identify any additional potentially cost-beneficial

SAMDAs. This is as expected since evacuation speed has only a small impact on offsite

exposure and no impact on offsite economic consequence and offsite exposure makes up only

a small portion of the total maximum benefit.

TVA considered the impact that possible increases in benefits from analysis uncertainties would

have on the results of the SAMDA assessment. Since no uncertainty distributions on CDF were

available for the CAFTA based SAMDA model, TVA used the results of the uncertainty analysis

of the RISKMAN WBN4SAMDA PRA model (TVA 2009a) to establish the uncertainty multiplier

to be used. From this information TVA chose the ratio of the 95 th percentile CDF to the mean

CDF or 2.70. The results of the analysis uncertainty assessment are provided in the updated

Table 2.a.iv-10 of the September, 16, 2011 submittal (TVA 201 1f). Based on this uncertainty

consideration, TVA determined that six additional SAMDAs (SAMDAs 8, 70, 93, 215, 226 and

300, as described above) were potentially cost-beneficial:

The NRC staff notes that the CAFTA results are point estimates, not mean values, and hence

the ratio of the 9 5 th percentile CDF to the point estimate CDF of 2.78 should be used in the CDF

uncertainty analysis instead of 2.7. This difference is small and in the revised analysis of

September 16, 2011 (TVA201 lf) did not impact the cost-benefit analysis of any SAMDAs.

SAMDA 70, which is to install accumulators for turbine-driven auxiliary feedwater pump flow

control valves, was originally assessed by TVA to have a benefit to cost ratio of 0.99 (TVA

201 Oa), but was determined to have a ratio just slightly above 1.0 using 2.78 in the corrected

consequence analysis. In response to an NRC staff RAI and as discussed above, TVA, as part

of its response to questions on the Appendix R analysis, has committed to provide a new

capability to allow the operators from the control room to transfer from normal compressed air

supply to the station nitrogen system for control of the LCVs. This new capability, identified as

SAMDA 339, will have a greater benefit then that associated with SAMDA 70 and thus

supersedes it (TVA 2011 b).

As discussed above, the methodology TVA used to determine the benefit of each SAMDA could

lead to an underestimate of the benefit. In response to an NRC staff RAI, TVA performed a

sensitivity study reevaluating the benefit of each Phase II SAMDA basing the consequences for

each release category on the maximum consequence for the scenarios that make up each

release category rather than the average consequence. TVA indicated that, for the uncorrected

consequence analysis (TVA 2011 c), with one exception, the sensitivity study indicated that no

additional SAMDAs would be cost beneficial using the 95 percentile uncertainty factor of 2.78.

The one exception is SAMDA 93, which is to install an unfiltered hardened containment vent to

eliminate the containment overpressure failure. While use of the maximum consequences

increases the benefit to cost ratio from slightly less than 1.0 to slightly more than 1.0, TVA

argues that use of the average LATE release category (release category Ill) is appropriate for

this SAMDA. In addition, TVA points out that 40 percent of the LATE release category is due to

RCP seal LOCAs while 10 percent is due to scenarios involving the loss of control air and

operators failing to control AFW manually. Both of these situations are addressed by other

H-44
Appendix H

SAMDAs, SAMDA 58 for RCP seal failure and SAMDA 339 (replacing SAMDA 70) for loss of

control air. TVA further commits to reevaluating SAMDA 93 if the new RCP seal package

proves to not be reliable (TVA 2011 c).

The revised cost benefit analysis resulting from the correction to the consequence analysis

(TVA 201 1f) indicates that SAMDA 93 is cost beneficial without considering the conservative

source terms, and in the submittal, again cites the commitment to reevaluate SAMDA 93 if the

new RCP seal package proves to not be reliable.

The September 16, 2011 submittal does not specifically state that the use of the conservative

source terms with the revised consequence analysis will not result in any additional cost

beneficial SAMDAs. TVA does point out that the next largest benefit-cost ratio is 0.70 for

SAMADA 255, using the 2.70 uncertainty multiplier, and that this would not be cost beneficial

even if the 2.78 multiplier is used. The staff considers that this SAMDA (and all others which

have lower benefit-cost ratios) is sufficiently removed from being cost beneficial that utilization

of the updated conservative source terms and consequence analysis would not result in it being

cost beneficial.

In response to an NRC staff RAI, TVA reexamined the initial set of SAMDAs to determine if any

additional Phase I SAMDAs would be retained for further analysis if the benefits (and Modified

Maximum Averted Cost-Risk) were based on using the 9 5 th percentile CDF. This reexamination

utilized a number of SAMDA maximum benefit cases that represented the possible change in

the maximum averted cost-risk for a range of assumptions concerning the nature of the impact

of the SAMDA on the risk; for example, entire risk changed linearly with the change in CDF, the

CDF remained fixed and only individual release categories changed, or combinations of both

situations. Using these maximum benefit cases and estimates of the maximum potential

reduction in CDF or risk, TVA provided the results of rescreening of all the Phase I SAMDAs

originally screened out on the basis of excessive implementation cost or very low benefit. All

Phase I SAMDAs screened out remained screened out based on a 95th percentile uncertainty

factor of 2.7 (TVA 2011 c, TVA 2011f). It is noted, however, while SAMDAs 50, 55 and 242, all

impacting RCP seal failure sequences, are screened, WVA has committed to further consider

these SAMDAs if the new RCP seal package proves not to be reliable (TVA 201 lc, TVA

2011 d). The NRC staff has reviewed the information provided and agrees with the conclusion

that the Phase I SAMDAs originally screened will remain screened considering the CDF

uncertainty. While, as indicated above, the more correct uncertainty factor is believed to be

2.78, the staff concludes use of this higher factor will not change the conclusions.

The NRC staff questioned TVA about other lower cost alternatives to some of the SAMDAs

evaluated, as summarized below:

Purchasing or manufacturing a "gagging device" that could be used to close a stuckopen steam generator safety valve for a SGTR event prior to core damage. In response

to the RAI, TVA indicated that utilizing such a device would require access to the stuck

open safety valve. Since the WBN steam generator safety valves do not have tailpipes,

H-45
Appendix H

the discharge is at the throat of the valve making such access infeasible due to local

hazards (TVA 2011 a).

* Utilizing the spare 5 th diesel generator mentioned in the disposition of SAMDA 261

without going through the expense of complete refurbishing and licensing. In response

to the RAI, TVA indicated that the diesel generator has been cannibalized to the point

where essentially an entire new unit would be required. In addition, adding to the cost

would be the requirement for class IE interfaces to the shutdown boards (TVA 2010c).

" Providing procedures and cabling to enable the use of the trailer-mounted 2 MW diesel

generator provided in response to GSI-1 89 to be used to power selected equipment

such as battery chargers, and/or individual pumps. In response to this RAI TVA

indicated that this has been implemented at WBN (TVA 201 Oc).

* Purchasing and installing a permanent diesel generator to supply power to the normal

charging pump. In response to this RAI, TVA indicated that such a SAMDA would need

to consider power supply arrangements and interfaces with existing power supplies as

well as the physical location of the diesel generator. There would be significant cable

routing required as well as the procedures and training involved (TVA 2010c).

The NRC staff concludes that, with the exception of the potentially cost-beneficial SAMDAs

discussed above, the costs of the other SAMDAs evaluated would be higher than the

associated benefits.

H.7 Conclusions

TVA compiled a list of SAMDAs based on a review of: the most significant basic events from the

plant-specific PRA, insights from the plant-specific IPE and IPEEE, Phase I SAMAs from license

renewal applications for other plants, and NEI's list of generic SAMAs. An initial screening

removed SAMDA candidates that (1) were not applicable to WBN, (2) were already

implemented at WBN, (3) were similar to and could be combined with other SAMDAs, (4) had

estimated costs that would exceed the dollar value associated with completely eliminating all

severe accident risk at WBN, or (5) determined to have negligible impact on risk. Based on this

screening, a number of these SAMDAs were eliminated leaving the remaining candidate

SAMDAs for Phase II evaluation.

For the remaining SAMDA candidates, more detailed design and cost estimates were

developed as shown in Table H-4. The cost-benefit analyses showed that eight of the SAMDA

candidates were potentially cost-beneficial in the baseline analysis (SAMDAs 4, 156, 256, 285,

292, 299, 305 and 306). WVA performed additional analyses to evaluate the impact of

parameter choices and uncertainties on the results of the SAMDA assessment. As a result, six

additional SAMDAs (SAMDAs 8, 70, 93, 215, 226 and 300) were identified as potentially costbeneficial.

H-46
Appendix H

Of these potentially cost-beneficial SAMDAs, SAMDA 156 was found by TVA to not be effective

due to time constraints on the operators to perform the action. SAMDAs 305 and 306 are

considered by TVA to have been previously implemented in an existing procedure that was not

credited in the PRA's human reliability analysis.

SAMDAs 93, 215, and 226 both relate to preventing RCP seal failures as does SAMDA 58.

SAMDA 58 was originally screened due to the unavailability of an approved seal design and

associated cost. Subsequently, it was learned that such a seal had been installed at the Farley

Nuclear Power Plant. TVA has committed to follow the progress and experience with this seal

package design and, if proven reliable during operation, to install it at the earliest refueling

outage following startup during normal seal package replacements (TVA 201 la). TVA further

committed that if the seal package is not proven reliable, TVA will use the latest PRA model at

the time to re-evaluate SAMDAs 93, 215, and 226 as well as 10 CFR 50.55 and 10 CFR 59.56

to determine if an alternate SAMDA is cost beneficial for implementation and implement the

SAMDA accordingly (TVA 2011 b). WVA has further committed to similarly re-evaluate other

SAMDAs that may be cost beneficial and/or related to or impacting RCP seal failure sequences

including SAMDAs 50, 55, 56 and 242 (TVA201 lc).

SAMDAs 293 and 294, both related to flooding due to raw cooling water pipe failures, were both

screened as already having been implemented. TVA has committed to the installation of flood

detection instrumentation in the affected areas, 772.0-A8 and 772.0-A9. As discussed above,

the originally installed carbon steel piping had been replaced with stainless steel piping. When

the lower leak frequency for this piping did not lower the risk from these floods sufficiently, flood

detection was committed to so that operators could take steps to isolate the affected piping.

This has been designated by TVA to be SAMDA 340 (TVA 201 1c).

SAMDA 70, which was found to be cost beneficial considering uncertainty in CDF, was

superseded by SAMDA 339, a new SAMDA to provide in the control room the capability to

connect to the station nitrogen system (TVA 2011 b).

SAMDA 80 was originally screened on the basis of having a very low benefit. In response to an

NRC staff RAI, TVA indicated that this SAMDA will be implemented in the CCP area, the TD

AFW pump room, and the EDG switchgear rooms (TVA 2011 b).

As stated in the November 1, 2010 submittal, TVA has indicated that the following potentially

cost-beneficial SAMDAs will be implemented: SAMDAs 4, 8, 256, 285, 292, 299 and 300.Q For

reasons beyond a cost-beneficial analysis, TVA will be implementing SAMDAs 339 and 340 as

committed by letters dated May 13 and 25, 2011.

5 Since the Third Circuit's opinion in Limerick Ecology Action, Inc., v. NRC, 869 F.2d 719, 723 (3d Cir.

1989) is not limited by the scope of license renewal, their relationship of these SAMDAs to aging does

not affect the decision to implement.

H-47
Appendix H

In its September 16, 2011 submittal (TVA 201 1f) TVA reaffirms the commitments made in prior

SAMDA submittals (TVA 2011 a through TVA 2011 e).

The NRC staff reviewed the TVA analysis and concludes that the methods used and the

implementation of those methods were sound. The treatment of SAMDA benefits and costs

support the general conclusion that the SAMDA evaluations performed by TVA are reasonable

and sufficient for the license submittal. Although the treatment of SAMDAs for external events

was somewhat limited, the likelihood of there being cost-beneficial enhancements in this area

was minimized by improvements that have been realized as a result of the IPEEE process, and

inclusion of a multiplier to account for external events.

The NRC staff concurs with TVA's identification of areas in which risk can be reduced in a costbeneficial manner through the implementation of the identified, potentially cost-beneficial

SAMDAs. Given the potential for cost-beneficial risk reduction, the NRC staff agrees, subject to

the above described dispositions, that implementation of these SAMDAs as committed to by

TVA is warranted. Therefore, the NRC staff finds that TVA's analysis meets the requirements of

NEPA.

H.8 References

Electric Power Research Institute (EPRI). 1991. "A Methodology for Assessment of Nuclear

PQwer Plant Seismic Margin," EPRI NP-6041-SL, Revision 1. Palo Alto, CA. August 1991.

Electric Power Research Institute (EPRI). 1992. "Fire-Induced Vulnerability Evaluation (FIVE),"

EPRI TR-100370. Palo Alto, CA. April 1992.

Nuclear Energy Institute (NEI). 2005. "Severe Accident Mitigation Alternatives (SAMA) Analysis

Guidance document." NEI 05-01, Revision A. November 2005.

Southern Nuclear Operating Company (SNC). 2007. Applicant's Environmental ReportOperating License Renewal Stage for Vogtle Electric Generating Plant Units 1 and 2, Appendix

E - Environmental Report, Southern Nuclear Operating Company, Birmingham, Alabama. June

2007.

Tennessee Valley Authority (TVA). 1992. Letter from Mark 0. Medford, TVA, to U.S. Nuclear

Regulatory Commission. Subject: "Watts Bar Nuclear Plant (WBN) Units 1 and 2 - Generic

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ML080070017, ML080070018, ML080070019.

Tennessee Valley Authority (TVA). 1994a. Letter from William J. Museler, TVA, to U.S.

Nuclear Regulatory Commission. Subject: "Watts Bar Nuclear Plant (WBN) Units 1 and

Common - Generic Letter 88-20 - Individual Plant Examination (IPE) - Update of Level 1 and 2

Analysis." May 2, 1994. Accessible at ML080070020, ML080070025, ML080070026.

H-48
Appendix H

Tennessee Valley Authority (TVA). 1994b. Letter from Dwight E. Nunn, TVA, to U.S. Nuclear

Regulatory Commission Document Control Desk. Subject: "Watts Bar Nuclear Plant (WBN)

Units 1 and 2 - Severe Accident Mitigation Design Alternatives (SAMDAs) Evaluation from

Updated Individual Plant Examination (IPE) (TAC Nos. M77222 and M77223)." June 30, 1994.

Accessible at ML073230670.

Tennessee Valley Authority (TVA). 1998. Letter from P. L. Pace, TVA, to U.S. Nuclear

Regulatory Commission document Control Desk. Subject: "Watts Bar Nuclear Plant (WBN) Unit

1 - Generic Letter (GL) 88-20, Supplements 4 and 5 - Individual Plant Examination of External

Events (IPEEE) for Severe Accident Vulnerabilities (TAC M83693)." February 17, 1998.

Accessible at ML073240218.

Tennessee Valley Authority (TVA). 2006. "Tennessee Multi-Jurisdictional Radiological

Emergency Response Plan for the Watts Bar Nuclear Plant," Annex H.

Tennessee Valley Authority (TVA). 2009. Letter from Masoud Bajestani, TVA, to U.S. Nuclear

Regulatory Commission Document Control Desk. Subject: "Watts Bar Nuclear Plant (WBN)

Unit 2 - Final Supplemental Environmental Impact Statement - Severe Accident Management

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ML090360589.

Tennessee Valley Authority (TVA). 2010a. Letter from Masoud Bajestani, TVA, to U.S. Nuclear

Regulatory Commission Document Control Desk. Subject: "Watts Bar Nuclear Plant (WBN)

Unit 2 -Severe Accident Management Alternatives Using Latest Computer Aided Fault tree

Analysis Model -Additional Information (TAC MD8203)." November 1, 2010. Accessible at

ML1 03080030.

Tennessee Valley Authority (TVA). 2010b. Letter from Masoud Bajestani, TVA, to U.S. Nuclear

Regulatory Commission Document Control Desk. Subject: "Watts Bar Nuclear Plant (WBN)

Unit 2 - Probabilistic Risk Assessment Individual Plant Examination." February 9, 2010.

Accessible at ML100491535.

Tennessee Valley Authority (TVA). 2010c. Letter from Masoud Bajestani, TVA, to U.S. Nuclear

Regulatory Commission Document Control Desk. Subject: "Watts Bar Nuclear Plant (WBN)

Unit 2 - Request for Additional Information Regarding Severe Accident Management

Alternatives (TAC No. MD8203)." July 23, 2010. Accessible at ML1 02100588.

Tennessee Valley Authority (TVA). 201 Od. Letter from Masoud Bajestani, TVA, to U.S. Nuclear

Regulatory Commission Document Control Desk. Subject: "Watts Bar Nuclear Plant (WBN)

Unit 2 - Response to Request for Additional Information Regarding Severe Accident

Management Alternatives SECPOP2000 Errors (TAC MD8203)." September 17, 2010.

Accessible atML102600582.

H-49
Appendix H

Tennessee Valley Authority (TVA). 2010e. Letter from Masoud Bajestani, TVA, to U.S. Nuclear

Regulatory Commission Document Control Desk. Subject: "Watts Bar Nuclear Plant (WBN)

Unit 2 - Individual Plant Examination for External Events Design Report." April 30, 2010.

Accessible at ML101240992.

Tennessee Valley Authority (TVA). 2011a. Letter from Marie Gillman, TVA, to U.S. Nuclear

Regulatory Commission Document Control Desk. Subject: "Watts Bar Nuclear Plant (WBN)

Unit 2 - Response to Request for Additional Information Regarding Severe Accident

Management Alternative Review (TAC MD8203)." January 31, 2011. Accessible at

ML1 10340040.

Tennessee Valley Authority (TVA). 2011 b. Letter from David Stinson, TVA, to U.S. Nuclear

Regulatory Commission Document Control Desk. Subject: "Watts Bar Nuclear Plant (WBN)

Unit 2 - Response to Request for Additional Information Regarding Severe Accident

Management Alternative Review (TAC MD8203)." May 13, 2011. Accessible at ML1 1145A088.

Tennessee Valley Authority (TVA). 2011 c. Letter from David Stinson, TVA, to U.S. Nuclear

Regulatory Commission Document Control Desk. Subject: "Watts Bar Nuclear Plant (WBN) -

Unit 2 - Response to Request for Additional Information Item Numbers 2, 3, 5 and 15

Regarding Severe Accident Management Alternative Review (TAC MD8203)." May 25,

2011 .Accessible at ML1 1147A099.

Tennessee Valley Authority (TVA). 201 Id. Letter from David Stinson, TVA, to U.S. Nuclear

Regulatory Commission Document Control Desk. Subject: "Watts Bar Nuclear Plant (WBN) -

Unit 2 - Response to Request for Additional Information Regarding Severe Accident

Management Alternative Review (SAMDA) (TAC MD8203)." June 17, 2011. Accessible at

ML1 1171A510.

Tennessee Valley Authority (TVA). 2011e. Letter from David Stinson, TVA, to U.S. Nuclear

Regulatory Commission Document Control Desk. Subject: "Watts Bar Nuclear Plant (WBN) -

Unit 2 - Response to Request for Additional Information Regarding Severe Accident

Management Alternative Review (SAMDA) (TAC MD8203)." June 27, 2011. Accessible at

ML11I180A008.

Tennessee Valley Authority (TVA). 201 1f. Letter from David Stinson, TVA, to U.S. Nuclear

Regulatory Commission Document Control Desk. Subject: "Watts Bar Nuclear Plant (WBN) -

Unit 2 - Revised Severe Accident Management Design Alternative Review (SAMDA) Response

(TAC MD8203)." September 16, 2011. Accessible at ML11264A052

Tennessee Valley Authority (TVA). 2011g. Letter from David Stinson, TVA, to U.S. Nuclear

Regulatory Commission Document Control Desk. Subject: "Watts Bar Nuclear Plant (WBN)

Unit 2 - Chapter 15.5 Fuel Handling Accident (FHA) Dose Analysis." October 17, 2011.

Accessible at MI1 1294A461

H-50
Appendix H

U.S. Department of Labor Statistics (BLS). 2010. "Bureau of Labor Statistics (BLS) 2010,

Inflation Calculator." Available online at www.bls.qov.

U. S. Geologic Survey (USGS). 2008. "2008 NSHM Gridded Data, Peak Ground Acceleration."

Available online at: http://earthquake.usqs..qov/hazards/products/conterminous/2008/data/.

U.S. Nuclear Regulatory Commission (NRC). 1975. Standard Review Plan for the Review of

Safety Analysis Reports for Nuclear Power Plants. NUREG-0800, Revision 0. Washington,

D.C. November 1975.

U.S. Nuclear Regulatory Commission (NRC). 1988. "Individual Plant Examination for Severe

Accident Vulnerabilities - 10CFR 50.54(f)." Generic Letter 88-20. Washington, D.C. November

23, 1988.

U.S. Nuclear Regulatory Commission (NRC). 1990a. Severe Accident Risks: An Assessment

for Five U.S. Nuclear Power Plants. NUREG-1150. Washington, D.C.

U.S. Nuclear Regulatory Commission (NRC). 1990b. Evaluation of Severe Accident Risks:

Sequoyah Unit 1. NUREG/CR-4551, SAND86-1390, Vol. 5, Rev. 1, Part 2. Washington, D.C.

December 1990.

U.S. Nuclear Regulatory Commission (NRC). 1990c. Analysis of Core Damage Frequency:

Sequoyah Unit 1. NUREG/CR-4550, SAND86-2084, Vol. 5, Rev. 1. Washington, D.C. April

1990.

U.S. Nuclear Regulatory Commission (NRC). 1991. "Individual Plant Examination of External

Events (IPEEE) for Severe Accident Vulnerabilities - 10CFR 50.54(f)." Generic Letter No. 88-

20, Supplement 4. Washington, D.C. June 28, 1991.

U.S. Nuclear Regulatory Commission (NRC). 1994. Letter from Peter S. Tam, U.S.NRC, to

Oliver D. Kingsley, TVA. Subject: "Watts Bar Nuclear Plant - Completion of Individual Plant

Examination Review (TAC No. M74488)." Washington, D.C. October 5,1994. Accessible at

ML073230696, ML082320705, ML082320706, ML082320707.

U.S. Nuclear Regulatory Commission (NRC). 1995. Final Environmental Statement related to

the Operation of Watts Bar Nuclear Plant, Units I and 2. NUREG-0498, Supplement No. 1.

Washington, D.C. April 1995.

U.S. Nuclear Regulatory Commission (NRC). 1997a. Regulatory Analysis Technical Evaluation

Handbook. NUREG/BR-0184. Washington, D.C.

U.S. Nuclear Regulatory Commission (NRC). 1997b. Individual Plant Examination Program:

Perspectives on Reactor Safety and Plant Performance. NUREG-1560. Washington, D.C.

H-51
Appendix H

U.S. Nuclear Regulatory Commission (NRC). 2000. Letter from Robert T. Martin, U.S. NRC, to

J. A. Scalice, TVA. Subject: "Watts Bar Nuclear Plant, Unit 1 - Review of Individual Plant

Examination of External Events (IPEEE) Submittal (TAC Nos. M83693)." Washington, D.C.

May 19, 2000.

U.S. Nuclear Regulatory Commission (NRC). 2003a. Memorandum from Nilesh C. Chokshi,

U.S. NRC, to Ashok C. Thadani, U.S. NRC. Subject: "Results of Initial Screening of Generic

Issue 194, 'Implications of Updated Probabilistic Seismic Hazard Estimates."' September 12,

2003.

U.S. Nuclear Regulatory Commission (NRC). 2003b. SECPOP 2000: Sector Population, Land

Fraction, and Economic Estimation Program. NUREG/CR-6525, Revision 1. Washington, D.C.,

August 2003.

U.S. Nuclear Regulatory Commission (NRC). 2004a.An Approach for Estimating the

Frequencies of Various Containment Failure Modes and Bypass Events. NUREG/CR-6595

Revision 1. Washington, D.C. October 2004.

U.S. Nuclear Regulatory Commission (NRC). 2004b.Regulatory Analysis Guidelines of the U.S.

Nuclear Regulatory Commission. NUREG/BR-0058, Rev. 4.Washington, D.C.

U.S. Nuclear Regulatory Commission (NRC). 2009. Letter from Joel S. Wiebe, U.S. NRC, to

Ashok S. Bhatnagar, Tennessee Valley Authority. Subject: "Watts Bar Nuclear Plant, Unit 2 -

Request for Additional Information Regarding Severe Accident Management Alternatives (TAC

No. MD8203)." Washington, D.C. November 30, 2009. Accessible at ML092230024.

U.S. Nuclear Regulatory Commission (NRC). 2010. NRC Information Notice 2010-18: Generic

Issue 199 (GI-199), "Implications of Updated Probabilistic Seismic Hazard Estimates in Central

and Eastern United States on Existing Plants." Washington, D.C. September 2, 2010.

Accessible at ML101970221.

U.S. Nuclear Regulatory Commission (NRC). 2011a. Letter from Justin C. Poole, U.S. NRC, to

Ashok S. Bhatnagar, TVA. Subject: "Watts Bar Nuclear Plant, Unit 2 -Request for Additional

Information Regarding Severe Accident Management Alternative Review (TAC No. MD8203)."

January 11,2011. Accessible at ML103470681.

U.S. Nuclear Regulatory Commission (NRC). 2011b. Letter from Patrick D. Milano, U.S. NRC,

to Ashok S. Bhatnagar, TVA. Subject: "Watts Bar Nuclear Plant, Unit 2 - Supplemental

Request for Additional Information Regarding Severe Accident Management Design

Alternatives Review (TAC No. MD8203)." March 30, 2011. Accessible at ML1 10820858.

U.S. Nuclear Regulatory Commission (NRC). 2011c. Letter from Justin C. Poole, U.S. NRC, to

Ashok S. Bhatnagar, TVA. Subject: "Watts Bar Nuclear Plant, Unit 2 - Request for Additional

Information Regarding Severe Accident Management Design Alternatives Review - June 2011

(TAC No. MD8203)." June 13, 2011. Accessible at ML1 11530523.

H-52
Appendix H

U.S. Nuclear Regulatory Commission (NRC). 201 1d. Letter from Stephen J. Campbell, U.S.

NRC, to Ashok S. Bhatnagar, TVA. Subject. "Watts Bar Nuclear Plant, Unit 2 - Review of

Individual Plant Examination Submittal - Internal Events and Internal Flood (TAC NO.

ME3334)." August 12, 2011. Accessible at ML111960228.

U.S. Nuclear Regulatory Commission (NRC). 201 le. Letter from Stephen J. Campbell, U.S.

NRC, to Ashok S. Bhatnagar, TVA. Subject: "Watts Bar Nuclear Plant, Unit 2 - Review of

Individual Plant Examination of External Events Design Report (TAC NO. ME4482)."

September 20, 2011. Accessible at ML1 11960300.

Wolf Creek Nuclear Operating Corporation (WCNOC). 2006. Letter from Terry J. Garrett,

WCNOC to U.S. Nuclear Regulatory Commission Document Control Desk. Subject: Docket No.

50-482: Application for Renewed Operating License, September 27, 2006.

H-53

Appendix I

Supporting Documentation for

Radiological Dose Assessment

This appendix contains supporting documentation for the U.S. Nuclear Regulatory Commission

(NRC) staff's determinations described in this supplemental final environmental statement

(SFES) for the radiological dose assessment.

The staff reviewed and performed an independent dose assessment of the radiological impacts

from normal operations of the new nuclear Unit 2 at the Watts Bar Nuclear (WBN) plant in Rhea

County, Tennessee. This appendix contains four sections: (1) dose estimates to the public

from liquid effluents; (2) dose estimates to the public from gaseous effluents; (3) cumulative

dose estimates, and (4) dose estimates to biota from gaseous and liquid effluents.

1.1 Dose Estimate from Liquid Effluents

The NRC staff used the dose assessment approach specified in Regulatory Guide 1.109

(NRC 1977) and the NRC developed LADTAP II computer code (Strenge et al. 1986) to

estimate doses to the maximally exposed individual (MEI) and the population from the liquid

effluent pathway of WBN Unit 2. As described in Regulatory Guide 1.109 (NRC 1977), the MEI

is characterized as an individual with the "maximum" food consumption, occupancy, and other

usages in the vicinity of the plant site and is therefore representative of a member of the public

that would receive the maximum dose from all radiological pathways from the site. The NRC

staff used the projected radioactive effluents release values from Tennessee Valley Authority's

(TVA's) final supplemental environmental impact statement (submitted to NRC as the TVA

Environmental Report for an Operating License) (TVA 2008a) and responses to Requests for

Additional Information (RAIs) submitted by TVA (TVA 2011 a, b).

1.1.1 Scope

Doses from proposed WBN Unit 2 to the MEI were calculated and compared to the regulatory

criteria for the following:

• Total Body - Dose was the total for the ingestion of aquatic organisms as food and cow

meat and external exposure to contaminated sediments deposited along the shoreline

(shoreline exposure). Water downstream from the WBN site is not used for irrigation. Refer

to Figure 4-2 in Section 4.6.1 for visual representation of the exposure pathway to humans.

September 2011 1-1 Draft NUREG-0498, Supplement 2
Appendix I

* Organ - Dose was the total for each organ for ingestion of aquatic food and cow meat and

shoreline exposure with the highest value for adult, teen, child, or infant.

The NRC staff performed calculations for exposure pathways using input parameters and

values found in TVA documentation. When site- or design-specific input parameters were not

available, staff used default values from Regulatory Guide 1.109 (NRC 1997).

1.1.2 Resources Used

To calculate doses to the public from liquid effluents the NRC staff used a personal computer

version of the LADTAP II code titled NRCDOSE, version 2.3.12 (Chesapeake Nuclear Services,

Inc. 2006) obtained through the Oak Ridge Radiation Safety Information Computational Center.

LADTAP II calculates the radiation exposure to man from potable water, aquatic foods,

shoreline deposits, swimming, boating, and irrigated foods, and also the dose to biota. Doses

are calculated for both the maximum individual and for the population and are summarized for

each pathway by age group and organ. LADTAP II implements the radiological exposure

models described in NRC Regulatory Guide 1.109, Rev. 1 (Appendix A) for radioactivity

releases in liquid effluent. The usage factors contained in Regulatory Guide 1.109 have been

included as standard assumptions but may easily be replaced with site-specific data.

1.1.3 Input Parameters

The population distribution assumed for all NRC staff calculations was obtained from the TVA

RAI response letter dated May 26, 2011 and is shown in Table I-1 (TVA 2011 b). Table 1-2 lists

the major parameters used in calculating dose to the public from liquid effluent releases during

normal operation. It should be noted that the 80-km (50-mi) population was assumed to be for

the year 2040. Section 5.4.1 of the Environmental Standard Review Plan (ESRP) guidance

suggests that populations be projected only 5 years out from the date of the licensing action under

consideration (NRC 2000). The staff considers that using the population for the year 2040, rather

than the recommended 5 years from licensing, is acceptable because it assesses the population

dose for a time period that approximates the operating life of WBN Unit 2.

1.1.4 Results of Calculations

Table 1-3 shows the results of the calculations of dose to the public from liquid effluent releases.

The data in this table indicate fairly good agreement between NRC staff calculations and TVA

calculations (WVA 2008b) and therefore the staff can use the WVA calculations for conclusions in

Section 4.6 of this SFES-OL.

Table 1-5 lists the NRC staff's calculated doses to the population in various locations away from

the plan from drinking water and shoreline recreational use such as boating and swimming.

Draft NUREG-0498, Supplement 2 1-2 September 2011
Appendix J

Table 1-6 compares the doses to the MEI from liquid effluents as calculated by NRC staff to the

same doses calculated by the applicant (TVA 2008b). This table indicates fairly good

agreement between the two sets of calculations, despite the fact that the applicant used a sitespecific model, approved by NRC, which used some parameter values that were different from

the mixture of site-specific and default parameter values used by the NRC staff.

Table 1-4 lists the NRC staff's calculated doses to the MEI from liquid effluent releases from WBN

Unit 2, which would include such things as eating the fish, drinking the water, and swimming and

other recreational uses of the water.

September 2011 1-3 Draft NUREG-0498, Supplement 2
z

m,0

Table I-1. Projected Population by Sector and Radial Distance Around the WBN Site for the Year 2040. (D

CL

0.

.01

CO

CO

RadiilDistances (mi)

Sectors Year 0-1 1-2 2-3 3-4 4-5 5-10 0-10 10-20 20-30 30-40 40-50 0-50

North 2040 0 18 0 0 135 2,465 2,619 1,885 2,778 4,798 6,172 18,222

North-Northeast 2040 0 0 18 411 185 1,536 2,150 11,762 18,766 14,502 2,547 49,727

Northeast 2040 0 0 18 308 287 827 1,441 3,783 16,734 29,838 78,334 130,130

East-Northeast 2040 0 0 18 308 287 497 1,110 3,553 29,539 63,798 253,831 351,832

East 2040 0 8 431 308 616 552 1,915 11,352 18,647 30,063 44,013 105,990

East-Southeast 2040 0 0 0 27 41 68 135 6,230 20,120 5,068 3,280 34,833

Southeast 2040 8 0 0 29 39 135 203 19,852 15,185 3,950 7,822 44,012

South-Southeast 2040 21 0 0 246 413 103 783 8,951 12,907 2,918 48,593 74,151

South 2040 16 0 0 0 1,983 3,824 5,823 4,586 42,883 56,430 17,985 127,707

South-Southwest 2040 0 0 21 0 0 546 567 5,725 42,517 46,281 106,392 201,482

Southwest 2040 0 0 0 0 0 1,051 1,051 12,978 14,499 62,307 111,795 202,630

West-Southwest 2040 0 6 36 59 126 711 938 12,791 2,837 2,840 3,372 22,778

West 2040 0 14 22 101 90 710 937 3,406 5,555 2,944 5,474 18,316

West-Northwest 2040 0 0 22 126 79 490 717 2,091 .4,372 5,654 20,511 33,345

Northwest 2040 0 108 332 376 526 2,655 3,998 2,889 18,634 10,462 15,956 51,940

North-Northwest 2040 0 0 0 173 123 3,116 3,413 1,536 33,843 11,609 5,890 56,290

Total 45 155 919 2,471 4,930 19,287 27,799 113,368 299,818 353,432 728,968 1,523,385

Source: TVA 2011b

CD

CD

aCD

C?
Appendix I

Table 1-2. Parameters Used in Calculating Dose to the Public from Liquid Effluent Releases

(WBN Unit 2 only)

Parameter

New unit liquid effluent source term

(Ci/yr)(a)(b)

Br-84

1-131

1-132

1-133

1-134

1-135

Rb-88

Cs-134

Cs-136

Cs-1 37

Na-24

Cr-51

Mn-54

Fe-55

Fe-59

Co-58

Co-60

Zn-65

Sr-89

Sr-90

Sr-91

Y-91 m

Y-91

Y-93

Zr-95

Nb-95

Mo-99

Tc-99M

Ru-103

Ru-106

Te-129IV

Te-129

Te-131fV

Te-131

Te-132

Ba-140

La-140

Ce-141

Ce-143

Ce-144

Np-239

H-3

Staff Value

6.88 x 10"

1.16

1.21 x 10-'

9.10 x 10-1

3.28 x 10-2

4.70 x 10-1

7.68 x10-3

1.98 x 10-1

1.98 x 10.2

2.61 x 10-1

1.86 x 10-2

9.98 x 10-2

5.59 x 10-2

8.09 x 10-3

1.15 x 10.2

1.66 x 10-1

3.16 x 10.2

3.82 x10.4

4.52x 10-3

4.10 x 10"4

2.47 x 10-3

1.68 x 10.4

3.90 x 10-4

1.27 x 10-3

1.34 x 10"2

1.11 x 102

1.04 x 101

3.35 x 10"3

5.88 x10-3

7.63 x 10-2

A 1.41 x 10.4

7.30 x 10-4

A 8 .05 x 104

2.03 x 10 4

3.05 X 10-2

3.58 x 101

5.14 x 10'

3.41 x 10-4

1.53 x 10-3

1.33 x 101

1.37 x 10-3

1.25 x 103

Comments

Table 3-16, p. 80 of the TVA ER

(TVA 2008a, 2011 b Enclosure 1;p.EI-23

.September 2011 1-5 Draft NUREG-0498, Supplement 2
Appendix I

Table 1-2. (contd)

Parameter Staff Value Comments

Freshwater site Selected

Discharge flow rate (ft3/s)

Source-term multiplier

Reconcentration model

Effluent discharge rate from

impoundment system to receiving

water body (ft3/s)

Impoundment total volume (ft3

)

Shore-width factor

Dilution factors for aquatic food and

boating, shoreline and swimming,

and drinking water

Transit time (hr)

Consumption and usage factors for

adults, teens, children, and infants

44.56

1

No impoundment

44.56

0

0.2

78

0

Shoreline usage (hr/yr)

500 (adult)

500 (teen)

500 (child)

500 (infant)

Water usage (L/yr)

730 (adult)

510 (teen)

510 (child)

330 (infant)

Fish consumption (kg/yr)

21 (adult)

16 (teen)

6.9 (child)

0 (infant)

1,523,385

317,370

Discharge is to the freshwater Tennessee

River

Site-specific value. Cooling tower

blowdown rate used for dilution from

Figure 3-7 of TVA ER (TVA 2008a).

For one unit.

Site-specific value.

Matches discharge flow rate for "no

impoundment" model (Strenge et al. 1986).

Set to zero for "no impoundment" model

(Strenge et al. 1986).

Suggested value for river shoreline (NRC

1977; Strenge et al. 1986)

Site-specific value. The quotient of the

minimum Tennessee River flow rate to

allow release of liquid effluent divided by

the cooling tower blowdown used for

dilution prior to release into the river.

Site-specific value from RAI TVA letter

dated May 26, 2011, p. E1-12 (TVA 201 b)

Shoreline Usage: Site-specific value from

Offsite Dose Calculation Manual (ODCM;

TVA 2008b)

Water Usage: LADTAP II code default

values (NRC 1977; Strenge et al. 1986).

Note: for fish consumption, NRC staff

used default values rather than site values

because site values were for average

consumption and these values are for

calculating the dose to the MEL.

Total 50-mi population

50-mi drinking water population

Site-specific value from RAI TVA letter

dated May 26, 2011, p. El-11. The

population was estimated for the year 2040

(TVA 2011 b).

Site-specific value from April 9, 2010 RAI

response (TVA 2010). Note: the

population datum provided for this RAI was

1,066,580. In the May 26, 2011 letter, TVA

updated the population by 500,000 but did

not update the 50-mi drinking water

population (TVA 201 lb).

Draft NUREG-0498, Supplement 2 1-6 September 2011
Appendix I

Table 1-2. (contd)

Parameter

Total 50-mi sport fishing (kg/yr)

Total 50-mi shoreline usage

(person-hr/yr)

Total 50-mi swimming usage

(person-hr/yr)

Total 50-mi boating usage

(person-hr/yr)

Fraction of crops irrigated

Fraction of population using

contaminated water for drinking and

food production

Fraction of agricultural products

within 50-mi radius

Irrigation rate for food products

(LUm 2Imo)

Fraction of contaminated water not

used for feed or drinking water

Total production of vegetables

within 50-mi radius (kg/yr)

Staff Value

65,987

4.56 x 10'

4.56 x 10'

4.56 x 107

0

Staff Value

Comments

Site-specific value from WBN FSAR (TVA

2009) and Table 3-15, p. 79, of the WVA

ER (TVA 2008a). Note: the population

datum provided for this RAI was

1,066,580. In the May 26, 2011 letter, TVA

updated the population by 500,000 but

WVA did not update the 50-mi sport fishing

population (TVA 201 lb).

Site-specific value from Table 3-15 of the

TVA ER (TVA 2009) and ODCM Eq. 6-18,

p. E1-144 (5 hours per visit) (TVA 2008b).

Note: the population datum provided for

this RAI was 1,066,580. In the May 26,

2011 letter, TVA updated the population by

500,000 but TVA did not update the 50-mi

shoreline usage population (TVA 2011 b).

NRC staff assumes that swimming could

equal shoreline use. Site-specific value

from Table 3-15 of the WVA ER (TVA 2009)

and ODCM Eq. 6-18, p. E1-144 (5 hours

per visit) (TVA 2008b). Note: the

population datum provided for this RAI was

1,066,580. In the May 26, 2011 letter,

TVA updated the population by 500,000

but TVA did not update the 50-mi

swimming usage population (WVA 2011 b).

NRC staff assumes that boating could

equal shoreline use. Note: the population

datum provided for this RAI was

1,066,580. In the May 26, 2011 letter, TVA

updated the population by 500,000 but

TVA did not update the 50-mi boating

usage population (TVA 2011 b).

Site-specific value from ODCM, p. 71

(TVA 2008b).

Site-specific value from ODCM, p. 71

(TVA 2008b).

Site-specific value from ODCM, p. 71

(TVA 2008b).

Site-specific value from ODCM, p. 71

(TVA 2008b).

Site-specific value from ODCM, p. 71

(TVA 2008b).

Site-specific value from WBN FSAR

p. 11.3-9 (vegetable production in each

sector annulus = vegetable consumption in

that sector annulus) (TVA 2009).

0

0

0

0

8.07 x 108

September 2011 1-7 Draft NUREG-0498, Supplement 2
Appendix I

Table 1-2. (contd)

Parameter •

Production rate for irrigated

vegetables (kg/yr)

Total production of leafy vegetables

within 50-mi radius (kg/yr)

Production rate for irrigated leafy

vegetables (kg/yr)

Total production of milk within 50-mi

radius (L/yr)

Production rate for irrigated milk

(L/yr)

Total production of meat within

50-mi radius (kg/yr)

Production rate for irrigated meat

(kg/yr)

(a) To convert Ci/yr to Bq/yr, multi

(b) 10 CFR 50; Appendix I. Radic

Staff Value

0

1.37 x 10"

0

4.99 x 108

0

1.37 x 108

0

Comments

Site-specific value from ODCM, p. 71 (TVA

2008b).

Site-specific value from WBN FSAR

p. 11.3-9 (leafy vegetable production in

each sector annulus. = leafy vegetable

consumption in that sector annulus) (TVA

2009).

Site-specific value from ODCM p. 71

(TVA 2008b).

Site-specific value from WBN FSAR

p. 11.3-9 (milk production in each sector

annulus = milk consumption in that sector

annulus) (TVA 2009).

Site-specific value from ODCM p. 71

(TVA 2008b).

Site-specific value from WBN FSAR

p. 11.3-9 (meat production in each sector

annulus = meat consumption in that sector

annulus) (TVA 2009).

Site-specific value from ODCM p. 71

(TVA 2008b).

ply the value by 3.7 x 1010

nuclides included in Regulatory Guide 1.109 are considered (NRC 1977):

Table 1-3. Comparison of Doses to the Public from Liquid Effluent Releases for WBN Unit 2

Type of Dose TVA ER (2009b)(a) Staff Calculation

Total body (mrem/yr) 0.72 (adult) 0.64 (adult)

Organ dose (mrem/yr) 0.13 (adult GI tract) 0.14 (adult GI tract)

Thyroid (mrem/yr) 0.92 (child) 1.91 (infant)

Population dose from liquid 1.6 6.6

pathway (person-rem/yr)

(a) TVA 2008a

(b) 100 x (Staff value - TVA value)/(Staff value)

Table 1-5 lists the NRC staffs calculated doses to the population in various locations away from

the plan from drinking water and shoreline recreational use such as boating and swimming.

Table 1-6 compares the doses to the MEI from liquid effluents as calculated by NRC staff to the

same doses calculated by the applicant (TVA 2008b). This table indicates fairly good

agreement between the two sets of calculations, despite the fact that the applicant used a sitespecific model, approved by NRC, which used some parameter values that were different from

the mixture of site-specific and default parameter values used by the NRC staff.

Draft NUREG-0498, Supplement 2 1-8 September 2011
Appendix I

Table 1-4. Staff Calculation of Annual Doses to the Maximally Exposed Individual for Liquid

Effluent Releases from Unit 2

Pathway

Fish and Other Organisms

Drinking Water

Direct Radiation (Shoreline)

Age

Group

Adult

Teen

Child

Infant

Adult

Teen

Child

Infant

Adult

Teen

Child

Infant

Total Body

(mremlyr)

5.82 x 10"1

3.31 x 10-1

1.29 x 10.1

0

2.90 x 10-2

1.89 x 10.2

3.14 x 10-2

2.96 x 10.2

2.41 x 10-2

2.41 x 10.2

2.41 x 10.2

2.41 x 10.2

Maximum Organ

(mremlyr) ('j

7.89 x 10-1 (liver)

8.11 x 10-1 (liver)

7.08 x 10-1 (liver)

0

4.17 x 10-2 (GI-LLI)

3.00 x 10-2 (liver)

5.43 x 10.2 (liver)

6.23 x 10-2 (liver)

2.82 x 10.2

2.82 x 10.2

2.82 x 10-2

2.82 x 10-2

Thyroid

(mremlyr)

2.00 x 10"'

1.88 x 10-1

1.95 x 10-1

0

5.81 x 10-1

4.98 x 10-1

1.21

1.89

2.41 x 10-2

2.41 x 10-2

2.41 x 10-2

2.41 x 10-2

GI-LLI = gastrointestinal tract - lower large intestine

Other than thyroid

To convert mrem/yr to mSv/yr divide by 100

September 2011 1-9 Draft NUREG-0498, Supplement 2
z

C

m

C)

(0

90

CO

C

CD

"3

M

Table 1-5. Staff Calculation of Population Doses Due to Liquid Effluent Releases from WBN Unit 2

Dose to Population (person-remlyr)

Whole

Body Skin Bone Liver Thyroid Kidney Lung GI-LLI

Drinking Water

Dayton, TN 0.268 (a) 0.146 0.346 4.980 0.254 0.192 0.325

Soddy-Daisy/Falling 0.158 (a) 0.083 0.203 2.230 0.147 0.115 0.176

Water Utility District

East Side Utility, TN 0.681 (a) 0.348 0.875 7.490 0.624 0.497 0.735

Chattanooga, TN 3.240 (a) 1.630 4.150 31.400 2.950 2.370 3.460

Shoreline Use

Chickamauga 0.029 0.034 (C) (C) 0.029 (C) (c) MC)

Reservoir

(from WBN(b) to 100

percent mixing point)

Chickamauga 0.313 0.366 MC) (c) 0.313 (c) (C) (C)

Reservoir

(from 100 percent

mixing point to SQN)

Chickamauga 1.790 2.090 (c) MC) 1.790 (C) (C) (M)

Reservoir

(from SQN(d) to

Chickamauga Dam)

Nickajack Reservoir 0.069 0.080 (C) (C) 0.069 (c) (C) (c)

(from Chickamauga

Dam to WBN 50-mi

radius)

(a) Skin Dose is not appropriate for drinking water pathway

(b) WBN = Watts Bar Nuclear

(c) Not available for Shoreline Use Pathway

(d) SQN = Sequoyah Nuclear

a.

CD

3

0r

MD

9
(D

-0

CD

3

Table 1-6. Comparison of TVA and NRC Staff Calculations for the Dose to the Maximally Exposed Individual and

the Projected 2040 Population from Liquid Effluents Released From WBN Unit 2

Dose to the Maximally Exposed Individual (MEl) from Liquid Effluents (mrem/yr) Population (2040)

Adult Teen Child Infant Person-remlyr

TVA NRC TVA NRC TVA NRC TVA NRC TVA NRC

Skin 0.031 0.028 0.031 0.028 0.031 0.028 0.031 0.028 0.315 2.57

Bone 0.56 0.487 0.6 0.511 0.76 0.647 0.036 0.061 1.761 2.22

Liver 0.96 0.847 1 0.862 0.88 0.786 0.036 0.087 2.13 5.60

Thyroid 0.88 0.832 0.8 0.735 0.92 1.460 0.264 1.910 15.336 48.31

Kidney 0.352 0.316 0.356 0.315 0.312 0.292 0.034 0.064 1.392 3.99

Lung 0.136 0.130 0.152 0.141 0.128 0.132 0.032 0.051 1.037 3.19

GI-LLI 0.132 0.144 0.104 0.111 0.06 0.086 0.033 0.059 1.420 4.71

Total Body 0.72 0.635 0.44 0.374 0.188 0.185 0.032 0.055 1.619 6.57

Source: TVA 2007

0

-D

CL

0.

I

z

6)

90

(O

CD

3

CD

CD

Pi
Appendix I

1.2 Dose Estimates to the Public from Gaseous Effluents

The NRC staff used the dose assessment approach specified in Regulatory Guide 1.109

(NRC 1977) and the GASPAR II computer code (Strenge et al. 1987) to estimate doses to the

MEI and to the public within 80 km (50 mi) of the WBN Unit 2 site from the gaseous effluent

pathway for the proposed units. GASPAR II calculates radiation exposure to humans from

routine air releases from nuclear reactor effluents.

1.2.1 Scope

The NRC staff calculated the MEI dose at 3.8 km (2.38 mi) northeast of WBN Unit 2. Pathways

included were plume, ground, inhalation, and ingestion of locally produced milk, meat, and

vegetables. Refer to Figures 4-2 in Section 4.6.1 for visual representation of the exposure

pathway to humans.

The site parameters listed in Table 1-7 were the basis for the doses calculated by the NRC staff.

Joint frequency distribution data of wind speed and wind direction by atmospheric stability class

for the WBN site provided in the Offsite Dose Calculation Manual (ODCM) (TVA 201 OVIp. 1371)

were used as input to the XOQDOQ code (Sagendorf et al. 1982) to calculate the average %/Q

and D/Q values for routine releases. A summary of XOQDOQ provided by Sagendorf (2010)

states, "XOQDOQ was designed for meteorological evaluation of continuous and anticipated

intermittent releases from commercial nuclear power reactors. It calculates annual relative

effluent concentrations and average relative deposition values at locations specified by the user

and at various standard radial distances and segments for downwind sectors. It also calculates

these values at the specified locations for anticipated intermittent (e.g., containment or purge)

releases, which occur during routine operation. The program computes an effective plume

height that accounts for physical release height, aerodynamic downwash, plume rise, and

terrain features. The user may optionally select additional plume dispersion due to building

wakes, plume depletion via dry deposition, and plume radioactive decay, or specify adjustments

to represent non-straight line trajectories (recirculation or stagnation)."

The NRC staff performed a comparative review of x/Q and D/Q values calculated by TVA

against the values calculated by the NRC staff. The X/Q and D/Q values calculated by the NRC

staff, using joint frequency data from the applicant's ODCM based on meteorological data from

January 2004 through December 2006, are slightly lower (e.g., provides more atmospheric

dispersion) than X/Q and D/Q values calculated by TVA (TVA 2011 b), using joint frequency

tables based on meteorological data from January 1986 through December 2005. However, the

differences in X/Q and D/Q values are not significant. Furthermore, because the NRC x/Q and

D/Q values are lower than the TVA values, the NRC staff's projected dose to members of the

public from the of operation of WBN Unit 2 are slightly lower than the doses calculated by TVA.

The differences do not affect the NRC staffs conclusions regarding the radiological evaluation

for the operation of WBN Unit 2 contained in Chapter 4 of this draft SFES.

Draft NUREG-0498, Supplement 2 1-12 September 2011
Appendix I

Population doses were calculated for all types of releases (i.e., noble gases, particulates, iodines

H-3 and C-14) using the GASPAR II code for the following: plume immersion, direct radiation

from radionuclides deposited on the ground, inhalation, ingestion of vegetables, milk, and meat.

1.2.2 Resources Used

To calculate doses to the public from gaseous effluents, the NRC staff used a personal

computer version of the XOQDOQ and GASPAR 11 computer codes entitled NRCDOSE version

2.3.12 (Chesapeake Nuclear Services, Inc. 2006) obtained through the Oak Ridge Radiation

Safety Information Computational Center.

Table 1-7. Parameters Used in Calculating Dose to Public from Gaseous Effluent Releases

Parameter

Single new unit gaseous effluent

source term (Ci/yr)

H-3

Br-84

1-131

1-132

1-133

1-134

1-135

Cr-51

Mn-54

Co-57

Co-58

Co-60

Fe-59

Sr-89

Sr-90

Zr-95

Nb-95

Ru-103

Ru-106

Sb-125

Cs-134

Cs-136

Cs-137

Ba-140

Ce-141

C-14

Kr-85m

Kr-85

Kr-87

Kr-88

Xe-131r

Xe-133r

Xe-133

Xe-135r

Xe-1 35

Xe-137

Xe-138

Ar-41

Staff Value

1.39 x 10"'

5.07 x 10-2

1.53 x 101

6.73 x 101

4.57 x 10-1

1.07

8.42 x 10-1

5.92 x 10.4

4.31 x 10.4

8.20 x 10.6

2.32 x 10.2

8.74 x 10.3

7.70 x 10-5

2.98 x 10. 3

1.14 x 10.3

1.00 x 10-3

2.45 x 10-3

7.70 x 10.5

7.50 x 10-5

6.09 x 10`5

2.27 x 10'

8.01 x 10-'

3.48 x 10'3

4.00 x 10e4

3.95 x 10-5

7.30

9.48

6.78 x 102

5.81

1.32

m 1.09 x 103

m 4.31 x 10'

2.90 x 103

m 4.68

8.88 x 103

1.23

4.34

3.40 X 101

Comments

TVA ER (TVA 2008a) Table 3-20 p. 87;

TVA letter dated May 20, 2011; Enclosure 2,

Attachment 4; Proposed Markups for FSEIS,

Chapter 3, p. 87 (TVA 2011a).

September 2011 1-13 Draft NUREG-0498, Supplement 2
Appendix I

Table 1-7. (contd)

Parameter Staff Value Comments

Population distribution

Wind speed and direction

Joint frequency distribution of wind

speed and direction by stability class

Atmospheric dispersion factors

(sec/m3)

Ground deposition factors

Vegetable production rate within

50 mi of WBN site

Meat production rate within 50 mi of

WBN site

Milk production rate within 50 mi of

WBN site

Pathway receptor locations (direction

and distance), nearest site boundary,

MEI location

Consumption factors for milk, meat,

leafy vegetables, and vegetables

Updated population data

was provided by TVA in

letter dated May 26, 2011

p. E1-11(TVA 2011 b)

Site-specific data

Site-specific data

Calculated using

XOQDOQ

Calculated using

XOQDOQ

8.07 x 108 kg/yr

1.37 x 106kg/yr

4.99 x 10 L/yr

Table 3-19 of the ER

(TVA 2008a)

Population distribution used by the staff was for

year 2040.

Site-specific data for Jan 04 through Dec. 06

(hourly data obtained from file wb0408)

Site-specific data for Jan 04 through Dec. 06

(hourly data obtained from file wb0408)

Site-specific data for Jan 04 through Dec. 06

Site-specific data for Jan 04 through Dec. 06

Site-specific value from WBN FSAR, p. 11.3-9

(TVA 2009) (leafy vegetable production in each

sector annulus equals leafy vegetable

consumption in that sector annulus).

Site-specific value from WBN FSAR, p. 11.3-9

(TVA 2009) (meat production in each sector

annulus equals the consumption in that sector

annulus).

Site-specific value from WBN FSAR, p. 11.3-9

(TVA 2009) (milk production in each sector

annulus equals milk consumption in that sector

annulus).

Milk ((yr)

310

400

330

330

Meat (kg/yr)

Default value of GASPAR II code

(adult) (Strenge et al. 1987).

(teen)

(child)

(infant)

110 (adult)

65 (teen)

41 (child)

0 (infant)

Leafy Vegetable (kg/yr)

64 (adult)

42 (teen)

26 (child)

0 (infant)

Vegetable (kg/yr)

520 (adult)

630 (teen)

520 (child)

0 (infant)

Draft NUREG-0498, Supplement 2 1-14 September 2011
Appendix I

Table 1-7. (contd)

Parameter

Fraction of leafy vegetables grown

Fraction of year that milk cows are on

pasture

Fraction of MEI vegetable intake from

own garden

Fraction of year beef cattle are on

pasture

Fraction of year beef cattle intake is

from pasture while on pasture

Staff Value

1

0.65

1

1

Comments

Site-specific value from WBN FSAR, p. 11.3-9

(TVA 2009) (leafy vegetable production in each

sector annulus equals leafy vegetable

consumption in that sector annulus).

TVA RAI response letter dated May 20, 2011,

p. E1-1 (TVA 2011 a).

Site-specific value from WBN FSAR, p. 11.3-9

(TVA 2009) (vegetable production in each

sector annulus equals vegetable consumption in

that sector annulus).

Default value of GASPAR II code

(Strenge et al. 1987).

Default value of GASPAR II code

(Strenge et al. 1987).

1.2.3 Input Parameters

Table 1-7 lists the major parameters used by NRC staff to calculate the doses to the public from

gaseous effluents during normal operation. It should be noted that the 80 km (50-mi) population

was assumed to be for the year 2040. Section 5.4.1 of the ESRP guidance suggests that

populations be projected only 5 years out from the date of the licensing action under

consideration (NRC 2000). The staff considers that using the population for the year 2040, rather

than the recommended 5 years from licensing is acceptable because it assesses the population

dose for a time period that approximates the operating life of WBN Unit 2.

1.2.4 Results

Table 1-8 lists the doses to the public at the exclusion area boundary from gaseous effluent

releases from WBN Unit 2. Table 1-9 lists the doses to the MEI, a child, 3.8 km (2.38 mi)

northeast of Unit 2.

September 2011 1-15 Draft NUREG-0498, Supplement 2
Appendix I

Table 1-8. Comparison of Doses to the Public from Noble Gas Releases from WBN Unit 2

WBN Calculations

Type of Dose€a) (TVA ER 2 0 0 8 )(b) Staff Calculation

Gamma air dose at exclusion area 0.801 0.829

boundary(c) - noble gases only (mrad/yr)

Beta air dose at exclusion area 2.71 2.53

boundary(c) - noble gases only (mrad/yr)

Total bodyl dose at exclusion area 0.571 0.499

boundary c) - noble gases only (mrem/yr)

Skin dose at exclusion area boundary(c) - 1.54 1.78

noble gases only (mrem/yr)

(a) To convert from mrad/yr or mrem/yr to mGy/yr or mSv/yr divide by 100

(b) Taken from Table 3-21 of the TVA ER; data is for MEI or maximum residence (TVA 2011 a) (c) At the exclusion area boundary, 1.3 km (0.8 mi) east

Table 1-9. Staff Calculation for Annual Doses to the Maximally Exposed Individual from

Gaseous Effluent Releases from WBN Unit 2 (a)

Pathway Age Total Body Max. Organ Skin Dose Thyroid Dose

(Location) Group (mremlyr) (mremlyr) (mremlyr) (mremlyr)

Plume All 0.269 0.282 (lung) 0.958 0.388

(0.85 mi SE)

Ground All 0.079 0.079 0.093 0.079

(0.85 mi SE)

Inhalation Adult 0.025 0.031 (kidney) (a) 0.720

(0.85 mi SE) Teen 0.026 0.033 (kidney) (a) 0.91

Child 0.034 0.044 (kidney) (a) 1.61

Infant 0.014 0.018 (kidney) (a) 0.983

Vegetable Adult 0.159 0.783 (bone) (a) 0.969

(2.08 mi NE) Teen 0.257 1.3 (bone) (a) 1.4

Child 0.601 3.12 (bone) (a) 2.83

Infant (b) (b) (a) (b)

Cow Milk Adult 0.033 0.138 (bone) (a) 0.751

(1.42 mi SSW) Teen 0.056 0.25 (bone) (a) 1.2

Child 0.128 0.616 (bone) (a) 2.39

Infant 0.26 1.1.9 (bone) (a) 5.77

Meat Adult 0.026 0.120 (bone) (a) 0.081

(1.42 mi SSW) Teen 0.021 0.101 (bone) (a) 0.061

Child 0.039 0.189 (bone) (a) 0.1

Infant (b) (b) (a) (b)

(a) Skin dose is not applicable for these exposure pathways

(b) Infant dose is not applicable for this pathway

To convert person-rem to person Sv, divide by 100

To convert miles (mi) to kilometers (km), multiply by 1.6

Draft NUREG-0498, Supplement 2 1-16 September 2011
Appendix I

1.3 Cumulative Dose Estimates

Based on parameters shown for the liquid pathway and the gaseous pathway, Table 1-2 and

Table 1-7, respectively, NRC staff calculated doses from the WBN Unit 2 using LADTAP II and

GASPAR II to the MEI and the population within 80 km (50 mi) of the WBN Unit 2 site. It should

be noted that the 80-km (50-mi) population was assumed to be for the year 2040. Section 5.4.1

of the ESRP guidance suggests that populations be projected only 5 years out from the date of

the licensing action under consideration (NRC 2000). The staff considers that using the

population for the year 2040, rather than the recommended 5 years from licensing is acceptable

because it assesses the population dose for a time period that approximates the operating life of

WBN Unit 2.

As stated in Section 4.6, there are no regulatory requirements for population doses, but the

comparison to population dose and dose from natural background demonstrates that the annual

estimated population doses from WBN Unit 2 are not significant when compared to the

population dose from natural background (0.236 person-Sv/yr [23.6 person-rem/yr] and 4,738

person-Sv/yr [473,800 person-rem/yr], respectively) Table 1-10 lists the staffs calculation of

cumulative dose rates to the population for the year 2040 from WBN Unit 2.

Table I-11 compares the NRC staff's results for cumulative dose estimates to the MEI with

Title 40 of the Federal Code of Regulations (CFR) Part 190 criteria. All dose estimates are

within the 40 CFR Part 190 criteria.

Table 1-10. Population Total Body Doses (person-rem) for the Year 2040

Pathway Gaseous Effluent Liquid Effluent Total

Noble Gases 1.06 1.06

lodines and particulates 0.30 5.55 4.15

Tritium and C-14 4.73 2.89 7.62

Total 6.09 8.44 14.5

To convert person-rem to person Sv, divide by 100

September 2011 1-17 Draft NUREG-0498, Supplement 2
Appendix I

Table 1-11. Comparison of Maximally Exposed Individual Annual Dose Estimates with 40 CFR

Part 190(a) Criteria (Staff Calculations)

Annual Dose Estimate (mremlyr)

Total Body GI-LLI Bone Liver Kidney Thyroid Lung Skin

Gaseous Effluent

Adult 0.59 0.6 1.4 0.6 0.59 2.87 0.61 1.05

Teen 0.71 0.71 2.01 0.72 0.72 3.92 0.73 1.05

Child 1.15 1.14 4.29 1.18 1.17 7.28 1.17 1.05

Infant 0.62 0.61 1.55 0.66 0.64 7.1 0.64 1.05

Liquid Effluent

Adult 0.63 0.13 0.49 0.85 0.31 0.69 0.13 0.03

Teen 0.37 0.10 0.51 0.86 0.31 0.60 0.14 0.03

Child 0.18 0.08 0.64 0.78 0.29 1.16 0.13 0.03

Infant 0.05 0.06 0.06 0.08 0.06 1.49 0.05 0.03

Total (may not sum due to rounding)

Adult 1.23 0.73 1.88 1.44 0.91 3.55 0.74 1.08

Teen 1.208 0.81 2.52 1.59 1.03 4.52 0.87 1.08

Child 1.33 1.22 4.94 1.97 1.46 8.44 1.3 1.08

Infant 0.67 0.67 1.6 0.75 0.7 8.59 0.69 1.08

40 CFR Part 190(a) Criteria

25 25 25 25 25 75 25 25

To convert person-rem to person Sv, divide by 100

1.4 Biota Doses

To calculate doses to the biota from liquid effluents, the NRC staff used personal computer

versions of the NRC-developed LADTAP II and GASPAR II that are integrated into NRCDOSE

Version 2.3.12 (Chesapeake Nuclear Services, Inc. 2006). NRC staff obtained NRCDOSE

through the Oak Ridge Radiation Safety Information Computational Center.

The LADTAP II input parameters are specified in Section 1.2.2, above, to include the source

term, the discharge flow rate to the receiving freshwater system, the shore-width factor, and

fractions of radionuclides in the liquid effluent reaching offsite bodies of water. The transit time

from the effluent release location to the exposure location was zero hours.

NRC staff assessed dose to terrestrial biota from the gaseous effluent pathway using

GASPAR II by assuming doses for raccoons and ducks were equivalent to adult human doses

for inhalation, vegetation ingestion, plume and twice the ground pathways at a location 1.09 km

(0.68 mi) east. The doubling of doses from ground deposition reflects the closer proximity of

these organisms to the ground. Muskrats and herons do not consume terrestrial vegetation, so

that pathway was not included for those organisms.

Draft NUREG-0498, Supplement 2 1-18 September 2011
Appendix I

As stated in Section 4.6, the NRC does not have a regulatory framework for the protection of

biota from radioactive discharges from nuclear power reactors. The focus of NRC regulatory

framework is for the protection of human beings (NRC 2009). The ICRP (ICRP 1977, 1991,

2007) states that if humans are adequately protected, other living things are also likely to be

sufficiently protected. Table 1-12 lists the results of the NRC staff's biota dose calculations. The

results are within the International Atomic Energy Agency/National Council on Radiation

Protection and Measurements guidelines for protection of biota (IAEA 1992; NCRP 1991)

Table 1-12. Doses to Biota (mrem/yr) Due to Liquid and Gaseous Releases from WBN Unit 2

Biota Liquid Releases Gaseous Releases Total

Fish 4.3 4.30

Invertebrate 11.4 11.4

Algae 19.2 19.2

Muskrat 10.8 0.81 11.61

Raccoon 4.83 1.57 6.4

Heron 55.5 0.81 56.31

Duck 10.3 1.57 11.87

To convert person-rem to person Sv, divide by 100

1.5 References

10 CFR Part 50. Code of Federal Regulations, Title 10, Energy, Part 50, "Domestic Licensing of

Production and Utilization Facilities."

40 CFR 190. Code of Federal Regulations. Title 40, Protection of Environment, Part 190,

"Environmental Radiation Protection Standards for Nuclear Power Operations."

Chesapeake Nuclear Services, Inc. 2006. NRCDOSE for Windows. Radiation Safety

Information Computational Center, Oak Ridge, Tennessee.

International Atomic Energy Agency (IAEA). 1992. Effects of Ionizing Radiation on Plants and

Animals at Levels Implied by Current Radiation Protection Standards. Technical Report Series

No. 332, Vienna, Austria.

International Commission on Radiological Protection (ICRP). 2007. The 2007

Recommendations of the International Commission on Radiological Protection. ICRP

Publication No. 103. Annals of the ICRP 37(2-4). Accession No. ML080790301 National

Council on Radiation Protection and Measurements (NCRP). 1991. Effects of Ionizing

Radiation on Aquatic Organisms. NCRP Report No. 109, Bethesda, Maryland.

Sagendorf, J.F., J.T. Goll, and W.F. Sandusky. 1982. XOQDOQ: Computer Program for the

Meteorological Evaluation of Routine Effluent Releases at Nuclear Power Stations.

NUREG/CR-2919, Pacific Northwest National Laboratory, Richland, Washington.

September 2011 1-19 Draft NUREG-0498, Supplement 2
Appendix I

Sagendorf, J.F., J.T. Goll, W.F. Sandusky, and L.R. Eyberger. 2010. XOQDOQ -

Meteorological Evaluation of Atmospheric Nuclear Power Plant Effluents. Version 2.0.

Accessed at http://www.oecd-nea.org/tools/abstractldetail/nesc0964.

Strenge, D.L., R.A. Peloquin, and G. Whelan. 1986. LADTAP - Technical Reference and

User Guide. NUREG/CR-4013, Pacific Northwest Laboratory, Richland, Washington.

Strenge, D.L., T.J. Bander, and J.K. Soldat. 1987. GASPAR II- Technical Reference and User

Guide. NUREG/CR-4653, Pacific Northwest Laboratory, Richland, Washington.

Tennessee Valley Authority (TVA). 2008a. Final Supplemental Environmental Impact

Statement; Completion and Operation of Watts Bar Nuclear Plant Unit 2, Rhea County,

Tennessee. Submitted to NRC as the TVA Environmental Report for an Operating License,

Knoxville, Tennessee.

Tennessee Valley Authority (TVA). 2008b. "Offsite Dose Calculation Manual." Attachment 3 in

Watts Bar Nuclear Plant Effluent and Waste Disposal Annual Report. Knoxville, Tennessee.

Tennessee Valley Authority (TVA). 2009. Watts Bar Nuclear Plant (WBN) - Unit 2 - Final

Safety Analysis Report (FSAR), Amendment 94. Spring City, Tennessee.

Tennessee Valley Authority (TVA). 2010. Letter from Masoud Bajestani (TVA, Watts Bar Unit 2

Vice President) to U.S. Nuclear Regulatory Commission dated April 9, 2010, in response to

NRC letter dated December 3, 2009 and TVA letters dated February 15, 2008, July 2, 2008,

January 27, 2009, December 23, 2009, and February 25, 2010, "Watts Bar Nuclear Plant

(WBN) Unit 2 - Response to U.S. Nuclear Regulatory Commission (NRC) Request for

Additional Information Regarding Environmental Review; Enclosure 1 (TAC No. MD8203)."

Accession No. ML101130393.

Tennessee Valley Authority (TVA). 201 la. Letter from Dave Stinson (TVA, Watts Bar Unit 2

Vice President) to U.S. Nuclear Regulatory Commission dated May 20, 2011, in response to

NRC letter dated April 13, 2011, TVA letters dated February 15, 2008, December 17, 2010,

February 25, 2011, and an e-mail from Justin C. Poole to William D. Crouch dated March 4,

2011, "Watts Bar Nuclear Plant (WBN) Unit 2 - Response to Final Safety Analysis Report

(FSAR), Chapter 11 and Final Supplemental Environmental Impact Statement (FEIS) Request

for Additional Information." Accession No. MLI 11146A044.

Tennessee Valley Authority (TVA). 2011 b. Letter from Dave Stinson (TVA, Watts Bar Unit 2

Vice President) to U.S. Nuclear Regulatory Commission dated May 26, 2011, in response to an

e-mail from Justin C. Poole to William D. Crouch dated March 4, 2011 and TVA letter dated May

20, 2011, "Watts Bar Nuclear Plant (WBN) Unit 2 - Response to Request for Additional

Information from Public Meeting on May 11, 2011." Accession No. MLI 1 152A160.

Draft NUREG-0498, Supplement 2 1-20 September 2011
Appendix I

U.S. Nuclear Regulatory Commission (NRC). 1977. Calculation of Annual Doses to Man from

Routine Releases of Reactor Effluents for the Purpose of Evaluating Compliance with

10 CFR Part 50, Appendix I. Regulatory Guide 1.109, Washington, D.C. Accession

No. ML003740384.

U.S. Nuclear Regulatory Commission (NRC). 2000. Environmental Standard Review Plan -

Standard Review Plans for Environmental Reviews for Nuclear Power Plants. NUREG-1555,

Vol. 1, Washington, D.C. Includes 2007 updates.

U.S Nuclear Regulatory Commission (NRC). 2009. Memorandum To: R.W. Borchardt From:

Annette L.Vietti-Cook. Subject: "Staff Requirements - SECY-08-0197 - Options to Revise

Radiation Protection Regulations and Guidance with Respect to the 2007 Recommendations of

the International Commission on Radiological Protection. Accession No. ML090920103.

September.2011 1-21 Draft NUREG-0498, Supplement 2

NRC FORM 335 U.S. NUCLEAR REGULATORY COMMISSION 1. REPORT NUMBER

(12-2010) (Assigned by NRC, Add Vol., Supp., Rev.,

NRCMD 3.7 and Addendum Numbers, if any.)

BIBLIOGRAPHIC DATA SHEET

(See instructions on the reverse) Supplement No. 2

2. TITLE AND SUBTITLE 3. DATE REPORT PUBLISHED

Draft Final Environmental Statement, MONTH YEAR

Supplement 2

Related to the Operation of October 2011

Watts Bar Nuclear Plant, Unit 2 4. FIN OR GRANT NUMBER

5. AUTHOR(S) 6. TYPE OF REPORT

J. Poole, et al. Technical

7. PERIOD COVERED (Inclusive Dates)

8. PERFORMING ORGANIZATION - NAME AND ADDRESS (If NRC, provide Division, Office or Region, U.S. Nuclear Regulatory Commission, and mailing address; if contractor,

provide name and mailing address.)

U.S. Nuclear Regulatory Commission

Office of Nuclear Reactor Regulation

Division of Operating Reactor Licensing

Washington, DC 20555-001

9. SPONSORING ORGANIZATION - NAME AND ADDRESS (If NRC, type 'Same as above",; if contractor, provide NRC Division, Office or Region, U.S. Nuclear Regulatory Commission,

and mailing address.)

Same as above

10. SUPPLEMENTARY NOTES

Docket No. 50-391

11. ABSTRACT (200 words or less)

The U.S. Nuclear Regulatory Commission (NRC) prepared this draft supplemental final environmental statement related to the

operating license in response to its review of the Tennessee Valley Authority's (TVA's) application for a facility operating license

submitted on March 4, 2009. The proposed action requested is for the NRC to is sue an operating license for a second

light-water nuclear reactor at the Watts Bar Nuclear (WBN) Plant in Rhea County , TN.

The NRC's regulations in Title 10 of the Code of Federal Regulations (10 CFR) 5 1.92, "Supplement to the Final Environmental

Impact Statement," require the NRC staff to prepare a supplement to the final e nvironmental statement if there are substantial

changes in the proposed action relevant to environmental concerns or if there a re significant new circumstances or information

relevant to environmental concerns and bearing on the proposed action or its im pacts. The same regulation permits the staff to

prepare a supplement when, in its opinion, preparation of a supplement will further the interests of the National Environmental

Policy Act of 1969.

The staff evaluated a full scope of environmental topics, including land and wa ter use, air quality and meteorology, terrestrial

and aquatic ecology, radiological and nonradiological impacts on humans and the environment, historic and cultural resources,

socioeconomics, and environmental justice. The staffs evaluations are based o n (1) the application submitted by TVA,

including the environmental report and previous environmental impact statements and historical documents, (2) consultation

with other Federal, State, Tribal, and local agencies, (3) the staffs independ ent review, and (4) the staffs consideration of

comments related to the environmental review received durinq the public scopinq process.

12. KEY WORDS/DESCRIPTORS (List words or phrases that will assist researchers in locating the report.) 13. AVAILABILITY STATEMENT

Draft Final Environmental Statement unlimited

Watts Bar Nuclear Plant 14. SECURITY CLASSIFICATION

Docket No. 50-391 (This Page)

unclassified

(This Report)

unclassified

15. NUMBER OF PAGES

16. PRICE

NRC FORM 335 (12-2010)