ML061730180
| ML061730180 | |
| Person / Time | |
|---|---|
| Site: | Vermont Yankee File:NorthStar Vermont Yankee icon.png |
| Issue date: | 02/17/2006 |
| From: | Vermont Yankee |
| To: | Office of Nuclear Reactor Regulation |
| References | |
| %dam200610 | |
| Download: ML061730180 (21) | |
Text
Vermont Yankee Nuclear Power Station License Renewal SEIS Information Needs February 17, 2006 Argonne staff have reviewed Appendix E, Environmental Report, of the Vermont Yankee Nuclear Power Station Operating License Renewal Application and have found that it meets the requirements of 10 CFR 51.45. However, in order to develop the SEIS for license renewal, a number of informational needs have been identified. These are preliminary and are outlined below.
- 1.
Air Quality A. Air Source Registrations for each stationary source (and amendments, as necessary) (R.
Buckley)
Response: See file named I.A.. There is only one air contaminate source registration certificate that covers the two boilers and two waste oil burners. The emergency diesel generators and the PSB heating boiler are not within the scope of this registration since they are classified as insignificant sources based on Vermont Air Regulations.
Operational hours for each generator is <100 hours per year. [Refer to State of Vermont Regulations, Chapter 5, Subchapter X, 5-1002(h)(1)(vi)]. Operational hours for the generators are maintained and reported annually to the Vermont Department of Environmental Conservation in order to maintain insignificant source classification for these sources and to continue maintaining the "opt-out" provision from permitting requirements.
" PSB heating boiler is rated at less than 3.0 million British Thermal Units (BTUs) per hour
[Refer to State of Vermont Regulations, Chapter 5, Subchapter X, 5-1002(h)(1)(i)].
B. Correspondence from Vermont Department of Environmental Conservation relating to air quality compliance (previous three years) (R. Buckley) inspection reports notices of deficiency notices of violation consent decrees, compliance schedules, etc.
Response: There are no records associated with these items. VYNPS has not been subject to any regulatory inspections, violations, consent decrees or compliance schedules over the past years. This is probably due to the fact that VYNPS is considered an insignificant source of air emissions (<10 tons/year) within the State of Vermont and the fact that the site is operating under an "Opt-Out" provision from Vermont's air permitting program [Refer to State of Vermont Regulations, Chapter 5, Subchapter X, 5-1016].
C. Pertinent records for all comfort heat boilers: (L. DeWald) nameplate ratings -
operating logs -
fuel usage logs -
fuel analyses (including Btu content and % sulfur) - See file named I.C, VY Air Emissions recordkeeping logs for 2001-2005. Vendor provides required % sulfur content.
Potential to Emit (PTE) calculations, if available -These are not calculations we perform VYNPS LR Informational Needs - 1
Response: See file named LC Pertinent Records for House Heating Boilers D. Pertinent records for waste oil furnace: (L. DeWald) operating logs, waste oil analyses (including Btu content, heavy metal content, chlorine (total) content).
Response: See file named I.D VY Air Emissions record keeping logs and waste oil analyses.
E. Pertinent records for each generator for which "Emergency Generator" status is claimed: (L.
DeNVald) operating logs, Preventative Maintenance (PM) logs (may be combined with operating logs),
fuel consumption logs (may already be included in PM documentation),
fuel analyses (Btu content, % sulfur),
hours of operation (may already be included in PM documentation)
Response: See file named I.E (a - f) Emergency Diesel Generator Data F. Documentation demonstrating the applicability of the Risk Management Plan requirements of 40 CFR Part 68 (R. Buckley) amounts of each RMP-listed chemical present at the facility (if present in quantities greater than respective threshold planning values of Table I of40CFR68.130 RMP (if such a plan is required to be developed)
Response: VYNPS is not subject to the Risk Management Plan (RMP) requirements described in 40CFR68 since there are only two regulated 40CFR68 chemicals stored on-site and storage quantities are less than the threshold which would trigger the RMP requirements as seen below.
Chemical Regulatory Reference Threshold Maximum Amount Trigger Stored On-Site Hydrogen 40CFR68.130, Table 3 10,000 Pounds
<999 Pounds Nitric Acid 40CFR68.130, Table 1 15,000 Pounds
<99 Pounds VYNPS LR Informational Needs - 2
II.
Hydrology, Water Quality, and Water Supply A. Entergy VY (Entergy Nuclear Vermont Yankee). 2004. Vermont Yankee Nuclear Power Station Procedure RP2616, Sampling, Testing and Treatment of Plant Potable Water System, April 13, 2004. (J. Brochu)
Response: See file named ILA (Station Procedure RP 2616).
B. SVPSB (State of Vermont Public Service Board). 2003. Petition of Entergy Nuclear Vermont Yankee, LLC and Entergy Nuclear Operations, Inc. Pursuant to 30 V.S.A. 248, for a Certificate of Public Good to Modify Certain Generation Facilities, Prefiled Testimony of Sonja A. Schuyler on Behalf of Entergy Nuclear Vermont Yankee, LLC and Entergy Nuclear Operations, inc., February 21, 2003. (J. Brochu)
Response: See file named II.B (SVPSB 2003).
C. Application for NPDES Permit (No. VT0000264), including maps showing outfalls and other relevant features. (L. DeWald)
Response: See file named IJ.C NPDES Permit renewal application.
D. Current NPDES Permit (the one in Attachment D will expire on March 31, 2006) (L.
DeWald)
Response: See file named II.D (NPDES Permit).
VYNPS LR Informational Needs - 3
E. From the past five years, any release notifications, violation information, remediation documentation associated with surface water discharges, septic or sewer systems, groundwater or soil contamination (including spills, leaks, and other releases of fuel solvents, or other chemicals). (L. DeWald & R. Buckley)
Response: See below.
Year Issue 2001 One small and of short duration, NPDES Permit thermal exceedence.
This occurred on July 5, 2001 when the hourly average change in water temperature measured at the compliance point was 2.120 F when the permitted limit was 2.0*F. No Notice of Violations issued.
2004 One reportable spill to the National Response Center occurred when a mixture of oil/fire fighting foam entered the storm drain into the Connecticut River as a result of overspray from fire fighting activities associated with a transformer fire. There was no observable impact to aquatic organisms and no regulatory penalties or fines were associated with the reportable spill.
No Notice of Violations issued and no remediation activities occurred during 2004.
2004 One small and of short duration potential NPDES Permit thermal exceedence.
This occurred on July 6, 2004 when the hourly average change in water temperature measured at the compliance point was 2.06°F when the permitted limit was 2.0°F. This was reported as a "potential" exceedence but the difference is within measurement error of the temperature monitoring equipment. No Notice of Violations issued.
2005 Discharge flow limit exceeded at Outfall 005 (RPHR Service Water) due to an operational error that occurred when removing silt buildup from the discharge line. No regulatory penalties or fines were associated with this event.
Three Notice of Violations were issued during a waste program compliance inspection: (1) two hazardous waste shipping manifests were not sent to VDEC and one manifest utilized an old EPA identification number; (2) the Hazardous Waste Coordinator spill response information contained in AP 0526, "Oil and Hazardous Materials Spill Prevention and Control" was not updated; (3) universal waste lamps were stored on-site for greater than the one year exceeding the allowable limit. No regulatory penalties or fines were associated with these NOV's.
No remediation activities occurred during 2005.
VYNPS LR Informational Needs - 4
III.
Health Physics, Radiological Human Health, and Safety Issues A. Most recent Offsite Dose Calculation Manual (ODCM).
Response: See file named III.A. Current ODCM B. Annual Radioactive Effluent Release Reports for last 5 years.
Response: See file named III.B. Annual Radioactive Effluent Release Reports (1.21 Reports)
C. Annual Radiological Environmental Operating Reports for last 5 years.
Response: See file named III.C. Annual Radiological Environmental Operating Reports D. Any available State of Vermont Radiological Environmental Monitoring Reports (if produced).
Response: See file named III.D. State of Vermont Radiological Environmental Monitoring Reports.
E. Annual occupational exposure reports for last 5 years.
Response: See file named IH.E. Annual Occupational Exposure Reports 2001 - 2005.
F. Any reports provided to the State of Vermont for offsite waste shipments for last 5 years.
Response: State waste shipment notifications are provided annually in the Annual Radioactive Effluent Release Reports (1.21 Reports) See file named I11.B.
G. Inventory of waste by waste type (and curie content for radioactive waste) and storage location on site at the end of Calendar Year 2005.
Response: See file named III.G. Waste Inventory.
VYNPS LR Informational Needs - 5
IV.
Aquatic Ecology A. More detailed maps of the Connecticut River showing aquatic sampling locations; (L.
DeWald) More detailed drawings and/or photos of the plant site; (R. Buckley)
Response: Copies of aerial photos are available and can be furnished upon request, otherwise, See IV.A NPDES sampling station maps.
B. Description of the intake screen operation, particularly related to the cleaning of the screens and disposal of impinged fishes; (L. DeWald)
Response: See below.
Fixed Screens (VYNPS PIC. Section 3.3)
The Circulating Water Intake Structure (CWIS) has two sets of fixed screens (bar racks), with one set covering the Circulating Water (CW) intake and one set covering the Service (SW) inlet. The fixed screens at the CW intake forebay are installed on the outer-most face of the intake structure. Mechanical agitators are used to prevent surface ice from forming in front of these screens during winter months. These fixed screens prevent the intake from clogging due to the buildup of frazil ice and/or large debris, and they also will exclude large fish from entering the CW forebay. There are no installed systems to remove large debris from these fixed screens. Any debris removal is performed manually by maintenance workers from installed platforms or boats. Opening the recirculation gate allows all or a portion of the CW effluent to return from the discharge structure to the CW intake forebay, allowing a slight head increase in the forebay above normal River level to aid in removing debris from the screens. The design (maximum) water velocity through each CW fixed screen is nominally about 1.0 feet per second (fps) with all three CW pumps operating in open cycle cooling mode. The actual water velocity through each CW fixed screen varies throughout the year from 1.0 fps down to 0.0 fps as the operating mode for the plant is changed from open cycle to closed cycle.
The SW forebay portion of the intake structure is immediately north of the CW forebay, and is separated from the CW forebay flow path by a reinforced concrete wall. A floating stop log is used as a barrier to prevent surface debris from entering the SW forebay. The entrance to each of the two SW pump bays is protected from debris intrusion by an independent fixed screen (bar rack). Mechanical agitators are used to prevent surface ice from forming in front of these SW fixed screens. These SW fixed screens prevent the service water intake from clogging' due to the buildup of frazil ice and/or large debris, and they also will exclude larger fish from entering the SW forebay. There are no installed systems to remove large debris from these fixed screens.
Any debris removal is performed manually by maintenance workers from installed platforms or boats. The design (maximum) water velocity through each SW fixed screen is nominally about 0.1 fps during maximum flow summertime operations with all four SW pumps operating.
Traveling Screens (VYNPS PIC. Section 3.4)
The traveling water screens are vertical, single speed, single entry/exit mechanical devices providing a basic fish and debris handling system at the CWIS. These traveling screens are located at the in-board (west) side of the Circulating Water (CV) intake forebay and are VYNPS LR Informational Needs - 6
recessed from the fixed screens and intake gates by about 55 feet. This enlarged CW forebay provides sufficient room for the recirculation water outlet to enter and mix with the ambient flow of River water passing through the fixed screens and intake gates. Each traveling water screen is installed between the CW forebay and the pump well of each of the three CW pumps (three screens). One traveling screen is installed between the Service Water (SW) forebay and each of the two SW pump bays. Each of the five traveling screens consists of 54 fiberglass basket elements that are chain driven in a continuous loop. Each basket screen is formed from 0.080" diameter stainless steel wire cloth with 3/8" openings.
Each CW traveling screen has a nominal design capacity of 120,000 gallons per minute (gpm) at a low water depth of 30 feet in the intake structure through a clean screen surface at a velocity of 1.96 fps. A single speed motor rotates the screens to provide for backwashing accumulated debris into a collection trough. The concrete collection trough traverses the length of all five traveling screens and empties the backwashed debris and any impinged fish into a collection basket that is located on the north side of the CW and SW intake forebays. The perforated collection basket can be emptied manually as needed; while a 12" carbon intake forebay in between the CW intake and the SW intake structures. The perforated collection basket can be emptied manually as needed; while a 12" carbon steel drain pipe discharges accumulated backwash water back to the River. All fish and debris removed from the collection basket are placed in a dumpster and disposed of in a sanitary landfill off-site.
A portion of the SW pump discharge is diverted to the SW traveling screens through air operated isolation valves to provide backwash spray water for removing debris from the screen baskets. The spray system utilizes non-clogging, wear-resistant deflector type nozzles, designed to project overlapping fan shaped jets of spray water across the width of the screen so that all material picked up on the screen will be jetted off when the panels are ascending.
Debris is jetted in a direction opposite the direction of flow of water in the intake structure.
The design screen wash spray flow rate for each screen is 206 gpm, at a minimum of 80 pounds per square inch (psi) gauge pressure (psig).
The traveling screens are equipped with an automatic differential level control, and can be operated manually or in automatic mode. When in the automatic mode, each traveling screen will independently start and the backwash spray isolation valves will open when the screen wash line pressure is >70 psig, and traveling screen high screen differential level (4 inches H20) is sensed by level detectors across the screens. Once initiated automatically, a timer ensures a minimum of 10 minutes of backwash, which is sufficient to provide one full rotation of all screens, even if differential pressure across the screen has reduced below 4 in.
H20.
C. Any calculations that have been done on total yearly losses due to impingement and entrainment of fishes; (L. DeeWald)
Response: There are no calculations. The NPDES Permit does not contain nor has it ever contained requirements for calculating yearly losses due to impingement or entrainment of fishes. Current and previous biological studies performed in accordance with the NPDES Permit, only involved recording fish species, number of fish, weight and length.
VYNPS LR Informational Needs - 7
D. Any calculations available on fish larvae and egg densities in the river near the plant that would allow entrainment estimates to be made; (L. DeWald)
Response: There are no calculations. The NPDES Permit does not contain nor has it ever contained requirements for calculating fish larvae and egg densities in the river near the plant.
Current and previous biological studies performed in accordance with the NPDES Permit, only involves recording species and total numbers.
E. Any impingement information collected during winter months; Response: There is none. VYNPS conducts annual impingement monitoring as required by the NPDES Permit. This NPDES Permit does not contain nor has it ever contained requirements for monitoring impingement during winter months.
F. Any incidents of cold shock events that may have occurred due to emergency shutdown in winter; Response: There have been no cold shock events observed at the site.
G. Reports or other information on the stocking of Atlantic salmon fry and smolts in the Connecticut River, Response: VYNPS does not have any reports or other information on the stocking of Atlantic salmon fry and smolts in the Connecticut River. However, this information can be obtained from the Vermont Department of Fish and Wildlife by contacting either Ken Cox or Jay McMenemy (802-885-8855) 100 Mineral Street, Suite 302, Springfield, VT 05156 or by email at ken.cox(@state.vt.us; lay.mcmenemy(@,state.vt.us; H. Description of dredging or other actions undertaken to maintain the intake area; (L. DeWald)
Response: See file named IV.H Intake Structure Dredging I.
Description of how the proposed power uprate would affect water intake requirements, thermal discharges, and change (e.g., duration) in the operation of the cooling system in its various modes (once-through, hybrid-cycle, or closed-cycle); (L. DeWald)
Response: See below.
Intake Requirements The power uprate did not involve any configuration change to the intake structure. The pump capacity did not change, so there was increase in the rate of withdrawal of water from the Connecticut River. There may be a slight increase in the amount of Connecticut River water consumed as a result of power uprate under all cooling modes of operation due to increased evaporative losses. During the NPDES summer period (May 16 to October 14), the increased water consumption will be less than 0.1% of the average monthly river flow. During the NPDES winter period (October 15 to May 15), the increased water consumption will be less than 0.2% of the average monthly river flow. Therefore, the increased loss is insignificant relative to the flow in the Connecticut River.
Thermal Discharge Under power uprate, thermal discharges will continue to comply with the NPDES permitted thermal discharge limits. However, in 2002 Vermont Yankee applied for a NPDES Permit amendment to allow a slight increase in the thermal discharge under certain ambient river temperature conditions between May and October. The Station's current NPDES Permit includes that amendment.
VYNPS LR Informational Needs - 8
Cooling Tower Operations Based on current information available, cooling tower usage should not change that significantly during the "summer" months. In addition, VYNPS has reached an agreement with TransCanada to maintain river flows at or above 1500 cfs during the "winter months".
Therefore, current practices for operating the cooling towers during the winter months should also not change that significantly.
J. Description of the water withdrawal rate(s) during hybrid-cycle operation (L. De~Vald)
Response: This number is currently not available since intake flows cannot be directly determined due to design and continually varying operation of the cooling system dictated by the NPDES Permit thermal limits.
In addition, copies of the following reports or correspondences cited in the ER are requested
[listed by the reference number and author (date) or just by author (date) for Attachment F):
K. From Chapter 2 (J. Brochu)
A. 2-4 Downey (1990a),
B. 2-5 Downey (1990b),
C. 2-13 Normandeau Associates, Inc. (1999),
D. 2-14 Normandeau Associates, Inc. (2002),
E. 2-15 Normandeau Associates, Inc. (2004), and F. 2-40 Vermont Yankee Nuclear Power Station (2005)
Response: See file named 1V.K. From Chapter 2 L. From Chapter 4 (J. Brochu)
A. 3-2 Aquatec (1990) and B. Normandeau Associates, Inc. (2003)
Response: See file named W.L. From Chapter 4 M. From Attachment F [Studies of the Connecticut River (2004)] (L. DeWald)
A. Aquatec (1993),
B. Aquatec (1995),
C. Binkered et al. (1978),
D. Downey and Binkered (1990),
E-P-Normandeau Associates, Inc. (1998 thru 2005) - reports on abundance of adult and/or juvenile American shad.
Response: See file named IV.M (a - p). Citations Referenced in Literature Cited in Attachment F of ER.
VYNPS LR Informational Needs - 9
V.
Terrestrial Ecology A. Environmental review procedure(s) (referred to on page 3-13) used for new construction projects at VYNPS. (R. Buckley)
Response: See file named V.A (Environmental Review Procedure). Nuclear Management Manual Fleet Procedure EN-EV-1 15 (Environmental Reviews and Evaluations) prescribes and establishes the non-radiological review and documentation process prior to engaging in additional construction or operational activities that may result in an environmental impact.
B. Documentation showing that environmental review procedures have been followed for past construction projects at VYYNPS (e.g., example compliance reports) (L. DeWald & Rick Buckley)
Response: See file named V.B. Dry Fuel Storage Pad Environmental Review.
C. Vegetation/land cover map of the VYNPS site and surroundings. (L. DeWald & FTN)
Response
See file named V.C, D, E, F. VY land use map, vegetation and cover type, delineated site wetlands, and riparian zone.
D. Area in acres of different vegetation/land cover types mentioned on page 2-8 of the ER (L.
DeWald & FTN)
Response: See table below and file named V.C, D, E, F. VY land use map, vegetation and cover type, delineated site wetlands, and riparian zone.
Land Cover Approximate Approximate Acreage Percentage Developed 35 28%
Mixed Pines/Hardwoods 20 16%
Grasslands/Early Successional 66 53%
Shrubs 3
2%
Wetlands 1
1%
E. Descriptions and locations of wetlands and streams on the VYNPS site (L. DeWald)
Response
See file named V.C, D, E, F. VY land use map, vegetation and cover type, delineated site wetlands, and riparian zone.
F. Description and map of riparian habitat on the VYNPS site bordering the Connecticut River (J. Brochu)
Response: Much of the riparian area along the property consists of rip-rap and in some cases, large boulders through which shrubby growth has occurred. South of the Station's discharge structure and north of the Station's boat launch the riparian zone is comprised of mixed pines and hardwoods and some immediate shoreline areas containing additional rip-rap. See file named V.C, D, E, F. VY land use map, vegetation and cover type, delineated site wetlands, and riparian zone.
VYNPS LR Informational Needs - 10
G. Clarification regarding the 'New England transmission line" mentioned on page 2-7 of the ER. What line is being referred to and is that line in scope for the license renewal SEIS? (R.
Buckley)
Response: The New England transmission line referred to here probably should have been described as the New England transmission grid and may be misleading but does include the three 345 kV lines discussed in Section 3.2.7 of the Environmental Report. These lines are as follows: the Coolidge 340 line (substation associated with this line provides 115 kV connections to Vermont, New Hampshire, New York and ties to a 450 kV dc link to Quebec),
the Amherst 380 line (substation associated with this line provides interconnections at 345 kV and 115 kV to generation and transmission facilities in Maine, Massachusetts, New Hampshire and ties to a 450 kV dc link to Quebec via the Scobie substation), and the Northfield 381 line (substation associated with this line provides 345 kV transmission line between VYNPS and Northfield pumped storage plant located 14 miles south of VYNPS at Northfield, Massachusetts, and there are 345 kV interconnections of transmission facilities in New York, Connecticut and Massachusetts).
Section IMI.B of the VY FES states that "The 345 kV New England grid loops from Western Massachusetts north to the Vermont Yankee switchyard, where Vermont Yankee is connected to the grid. and "The two 345-kV grid transmission lines built to the Vermont Yankee switchyard would have been required to supply purchased power to the State of Vermont even if the station had not been located at the Vernon site". Therefore, these lines are not within the scope of license renewal. This same conclusion was reached by VY and the NRC staff during the power uprate approval process.
There were also two 115-kV transmission lines associated with the New England grid at the Vernon area prior to construction of VYNPS. However, after VYNPS was constructed, one of these two 115-kV lines was converted to a 345 kV transmission line. This converted 345 kV line is the Coolidge 340 line.
H. Copies of any threatened, endangered, and rare species surveys conducted on the VYNPS site (L. DeWald Response: No such surveys have been conducted at Vermont Yankee.
I.
Clarification regarding correspondence with New Hampshire and Massachusetts regarding state-listed threatened, endangered, or rare species as recommended by the State of Vermont (J. Brochu)
Response: No correspondence was sent to New Hampshire or Massachusetts regarding this issue, although state lists of species were reviewed. Since no issues were raised during the power uprate project by these states and no issues have been raised by the New Hampshire and Massachusetts fish and wildlife agencies in their role as Environmental Advisory Committee members as it relates to VYNS NPDES Permit issues, no consultations were conducted.
VYNPS LR Informational Needs - 11
J. Location of listed and rare species mentioned by the State of Vermont in their letter to the applicant (Vermont offered to provide this information) (J. Brochu)
Response: Entergy did not request a copy of the 139 page document "element occurrence" location data for each species or community, since there are no plans to alter operations, any maintenance activities necessary to support license renewal would be limited to previously disturbed areas on-site, no expansion of existing facilities is planned, and no additional land disturbance is anticipated in support of license renewal. In addition, the Vermont Nongame and Natural Heritage Program (VNNHP) had already determined that no adverse impacts would occur during the power uprate process.
K. Material provided to the State of Vermont on the effects of nuclear power generation on wildlife as requested in their letter to the applicant (R. Buckley)
Response: There were no materials provided to the State of Vermont regarding the effects of nuclear power generation on wildlife since there are no definable impacts. Category 2 issues related to terrestrial impacts from continued operation of VYNPS are small based on Entergy's assessment contained in the Environmental Report. The remaining Category I issues related to terrestrial impacts are small based on NRC's assessment contained in NUREG-1437 (Generic Environmental Impact Statement).
L. Reference 4-16 (State of Vermont Public Service Board 2003) is provided as the reference for threatened and endangered species information, but the title suggests that the report in not related to that topic. Provide the correct reference report. (J. Brochu)
Response: The reference is correct and information contained in the VYNPS ER that was utilized from this reference can be found in responses to Q69, Q70 and Q73.
M. Site-specific information on locations, conditions, and populations of the three rare plants known to occur on the site as well as information on the four State-listed plants that are known to occur near Vernon Dam (J. Brochu & R. Buckley)
Response: There is no site-specific information relative to any rare plants known to occur on or near the site.
The 1997 Significant Habitat Map (Exhibit EN-SAS-14 of Reference 4-16) shows the location of rare, threatened or endangered species, and significant natural communities in the Vernon Town area. The three elements that are mapped on the VYNPS site correspond to the state-listed "rare" species in the following table.
C-'*CdmmonName.
'.:i:ScientificName.
- StateRank., 7..,.VTUT&E! $
- .;.USAT&E"-
Giant Solomon's Polygonatum biflorum
$1 Not listed Not listed seal var. commutatum Trailing stitchwort Stellaria alsine S1 Not listed Not listed Tapering rush Juncus acuminatus S1 Not listed Not listed State Rank - Information category not establish by VT law. Ranking from I (very rare) to 5 (common & widespread).
VYNPS LR Informational Needs - 12
Reference 4-16 (Exhibits EN-SAS-20 and EN-SAS-21) also lists 12 rare, threatened or endangered species, and significant natural communities that occur near the VYNPS site. These species occur at one of 7 locations mapped immediately above or below Vernon Dam. The 11 plant species and 1 significant natural community include the following.
,*::,*SclenitlficiName6 1;St i*..,IS
......~
~
~
~
~
~~~~Z Rank
!U...
- Status*: 1ý.Statuis.ýý-i Giant Solomon's seal Polygonatum biflorum S1 Not listed Not listed var. commutatum Trailing stitchwort Stellaria alsine S1 Not listed Not listed Tapering rush Juncus acuminatus S1 Not listed Not listed Great St. John's-wort Hypericum ascyron S2 Threatened Not listed Pursh's bulrush Scirpus purshianus S2S3 Not listed Not listed Musk flower Mimulus moschatus 52S3 Not listed Not listed Matted spikerush Eleocharis intermedia S2S3 Not listed Not listed Horned pondweed Zannichellia palustris s1 Not listed Not listed Small water-wort Elatine minima S1 Not listed Not listed Pygmyweed Tilaea aquatica S2 Not listed Not listed Frank's love-grass Eragrostis frankii S2S3 Not listed Not listed Silver maple-ostrich fern NA S3 NA NA riverine floodplain forest Only 1 state-listed "threatened or endangered" species, Great St. John's-wort (Hypericum ascyron), is reported to occur near VYNPS. This VT threatened species occurs downstream from VYNPS near the Vernon Dam. The Vermont Department of Fish and Wildlife did not anticipate any adverse impact to Great St. John's-wort or the other rare species listed above from VYNPS.
In 2005, during the preparation of the ER, the VT Department of Fish and Wildlife was also contacted for any information regarding impacts of concern from the continued operation of VYNPS. A copy of Entergy's consultation letter and the Department's response are shown in Appendix A to the ER. The response included a 3-page list of rare, threatened or endangered species, and significant natural communities occurrences with in a 6-mile radius of VYNPS.
Only 2 federally-listed T&E species (dwarf wedge mussel and bald eagle) and 1 state-listed T&E species (Great St. John's-wort) are reported to potentially occur in the area. Potential impacts to these species are addressed in Section _.
N. Bald eagle use of site including winter use and foraging (R. Buckley)
Response: The VYNPS site is not used by bald eagles for winter use or foraging.
VYNPS LR Informational Needs - 13
VI.
Land Use and Visual A. Site land cover/land use percentages -
there are no descriptions or percentages for categories, such as, open area (fields, beach area, marches), forests, facilities and structures, parking areas, water (ponds -
natural or manmade), and visitor or recreation areas. No site maps are provided that would allow for these determinations to be made. (R. Buckley &
FIN~
Response: See response to Item V.D above.
B. Does the fence surround the outer boundary of the property or only "the immediate area around the station?" Further explanation is needed as the site is surrounded by a 0.17-mile radius exclusion area as shown in Figure 2-3. (R. Buckley)
Response: There is a perimeter fence around the site property. The exclusion area (10CFR1OO.3) identified in Figure 2-3 is the area surrounding the reactor, in which VYNPS has the authority to determine all activities including exclusion or removal of personnel and property from the area. This area may be traversed by a highway, railroad, or waterway, provided these are not so close to the facility as to interfere with normal operations of the facility and provided appropriate and effective arrangements are made to control traffic on the highway, railroad, or waterway, in case of emergency, to protect the public health and safety.
Residence within the exclusion area shall normally be prohibited. In any event, residents shall be subject to ready removal in case of necessity. Activities unrelated to operation of the reactor may be permitted in an exclusion area under appropriate limitations, provided that no significant hazards to the public health and safety will result.
C. Is it accurate to assume that the Vermont Yankee site is included in the Municipal Plan? (L.
DeWald)
Response: Vermont Yankee is included in the Town of Vernon's Town Plan, last updated in 2003. See file named VI.C 2003 Vernon Town Plan.
D. Is Vernon Pond used for recreational uses as stated in the FSAR 2.4.4.3? Are recreational users precluded from landing on Station waterfront property, the narrow strip of land on the east boundary of the property, and the pond area in front of the site out to the middle of the Connecticut River? (L. DeWald)
Response: Vernon Pond continues to be used recreationally, as stated in the FSAR.
Recreational users are precluded from landing on Station waterfront property.
E. Need information on the height, color, or visibility of the facilities and structures and from what distances and locations they can be seen. Also need information about the plant cooling tower noise and what can be heard at the site boundaries. (L.DeWald, R. Buckley)
Response: VYNPS is situated in an area where the land is used primarily for agriculture. The site is surrounded with mostly rural countryside, which includes open pasture lands, scattered farmsteads, woodlands, few residents, and little industry within several miles. Population densities around the site are low, with the nearest population center of significance (Brattleboro, VT) approximately 5 miles from the plant. The Connecticut River traverses the area near the site from north to south, along the eastern side of the Vernon area, geographically separating the states of Vermont and New Hampshire at this point.
When traveling south on Vermont State Highway Route 142 (Fort Bridgman Road), a portion of the main plant stack (318 feet high) can be seen periodically, although the stack is constructed of concrete and is not painted. As motorists get closer to the plant (approximately VYNPS LR Informational Needs - 14
1/4 mile), the primary metrological tower (-305 feet high), and a portion the switchyards and the Reactor Building (-120 feet high) become visible. The Turbine Building (-90 feet high) is not visible to passing motorists or Vernon residents. The site itself is situated in a lowland area along the Connecticut River, so all plant structures are somewhat aesthetically shielded from passing motorists or residents that live within the Vernon area.
When traveling on State New Hampshire Highway 119 (east side of Connecticut River), the VYNPS site can be periodically visible to motorists. In addition, the site is visible to some Hinsdale, New Hampshire residents, although not many, along with the Hinsdale, New Hampshire High School. As a note, the site may become more visible during seasonal changes when trees begin to lose their foliage.
During periods of operation, the vapor plume from the cooling towers is visible. The Connecticut River is utilized for recreational boating and fishing as well as boat tours originating in Brattleboro, Vermont near the VYNPS area. Therefore, the site and structures are obviously visible from the river. Since VYNPS is situated in a mostly rural countryside with low-density residential being the norm, aesthetic and noise impacts from the site and associated structures are minimal.
F. Federal facilities and lands with a 50-mile proximity to the VYNPS are the U.S. Air Force and U.S. Army facilities in Massachusetts, National Wildlife Refuge in New Hampshire, and the U.S. Army Corps of Engineers facility and Green Mountain National Forest in Vermont (is this list inclusive, it is based on Figure 2.4; what are the distances and full names of the facilities?). (10 CFR 51.10[b][2]) (J. Brochu)
Response: The names and approximate distances of the federal facilities and lands within 50 miles of the VYNPS are:
- Wapack National Wildlife Refuge in New Hampshire: 33 miles
" Green Mountain National Forest in Vermont: 18 miles
- Westover Air Force Base in Massachusetts: 40 miles Fort Devens (closed) in Massachusetts: 42 miles VYNPS LR Informational Needs - 15
VII.
Historical and Archaeological Resources A. Any correspondence with the Vermont Division of Historic Preservation concerning the property. Including that done for the Energy Uprate. (R. Buckley)
Response: The only current correspondence is associated with power uprate. The Vermont Division for Historic Preservation (VDHP) was contacted during the power uprate process.
The VDHP determined that there would be no impact on archeological or historic sites at VYNPS. A copy of this determination is included as Exhibit EN-SAS-19 of the file named II.B (SVPSB 2003).
B. Any information on the archaeological investigations that took place prior to construction of the power station (Reports, letters, maps, etc.). (J. Brochu)
Response: Based on the Section II.D of the VYNPS FES, the Vermont Archaeological Society (VAS) was contacted concerning the possibility of archaeological materials being found in this section of the Connecticut River Valley. VAS was not aware of any significant fossil deposits in the Vernon area, however, surveys of the area are incomplete and no survey was made prior to site preparation. Extensive subsurface exploration followed by excavation was done before construction began at the site. Neither of these activities revealed any fossil deposits or archaeological materials of significance, and since construction was essentially complete, none can be expected in the future.
In the ER they identify the Hunt House as a building on power station property that has been determined historically significant. We require a copy of the Vermont Division of Historic Preservation evaluation form and supporting data used to determine that this building is historically significant. A copy of the state's historic property form for this structure is also requested. (L. DeWald)
Response: This property is not a registered historic property in Vermont. While we do not have the documentation requested, there is a notebook containing information about the Governor Hunt House, its restoration, and informal history. See Binders of Historical documents and photographs labeled "Governor Hunt House" (L. DeWald)
C. Any power station correspondences with Native American groups. (L. DeWald)
Response: There is no station correspondence with Native American groups. In addition, there are no Native American lands within a 50-mile radius of VYNPS.
D. A map or aerial photos showing the portions of the power station's property that are disturbed and those that are undisturbed. (L. DeWald)
Response: Copies of aerial photos are available and can be furnished upon request.
E. I need to see the power station's procedures for determining if an action has the potential to impact cultural resources (e.g. ground disturbance) and how the impact is evaluated and if necessary how it is mitigated. Also, what are their procedures for dealing with an unexpected discovery of archaeological material. (R. Buckley)
Response: See file named VII.G (Environmental Review Procedure). Nuclear Management Manual Fleet Procedure EN-EV-115 (Environmental Reviews and Evaluations) prescribes and establishes the nonradiological review and documentation process prior to engaging in additional construction or operational activities that may result in an environmental impact.
This includes a cultural resource review and actions to be taken if unexpected archaeological material is discovered.
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VIII.
Socioeconomics (R. Buckley)
A. Residential locations, by city and county, of full-time VYNPS plant employees. Latest data available.
Response: See file named VIII.A (Ellen Cota Email 4-5-06). Employee data contained in the Environmental Report was based on October 2004 data and has not changed significantly
(<45 employees) in a manner that would affect the socioeconomic analyses.
B. Electric Generation taxes paid by VYNPS to the State in 2004 and 2005 (the ER only has an estimate for 2004 and a mid-year estimate for 2005).
Response: See file named VIII.B,C,E,F (Kim Riverio Email 4-3-06) and updated information below on Table 2-7 of the VYVPS Environmental Report.
Table 2-7 (Updated)
Entergy Estimated Tax Distribution, 2003 - 2005 Tax 2003 2004 2005 State Electric Generation 2,577,328 2,600,000 2,600,000 State Electric Generation Education 1,874,419 1,887,209 1,900,000 State Income, Franchise, Sales, Use &
1,575,764 1,799,894 630,116 Excise (Combined)
Vernon Township Property Tax 1,094,520 1,155,960 1,191,452 Brattleboro Township Real Estate &
190,152 165,486 151,228 Personal Property Tax Total 7,312,183 7,608,549 6,472,796
State Electric Generation: April 3, 2006 email from Kim Rivero (Entergy Tax Department).
State Electric Generation Education: April 3, 2006 email from Kim Rivero (Entergy Tax Department).
State Income, Sales, Use & Excise (Combined) -
" Income: ($250) April 3, 2006 email from Steve Goerner (Entergy Tax Department).
" Franchise: ($0) April 7, 2006 email from Steve Goerner (Entergy Tax Department).
Sales: ($0) April 10, 2006 email from Roy Austin (Entergy Tax Department).
" Use: ($581,896) April 7, 2006 email from Roy Austin (Entergy Tax Department).
Excise ($47,970) April 10, 2006 email from Roy Austin (Entergy tax Department).
Vernon Property Tax: April 3, 2006 email from Kim Rivero (Entergy Tax Department).
Brattleboro Real Estate and Personal Property: April 3, 2006 email from Kim Rivero (Entergy Tax Department).
VYNPS LR Informational Needs - 17
C. Electric Generation taxes paid by VYNPS to the State for Education in 2005 (the ER only has mid-year estimates).
Response: See file named VIII.B,C,E,F (Kim Riverio Email 4-3-06) and updated information above on Table 2-7 of the VYVPS Environmental Report.
D. Income, Franchise, Sales and Use taxes paid by VYNPS to the State in 2005 (the ER'only has mid-year estimates).
Response: See files named VIII.D (Steve Goerner Email 4-3-06), VIII.D (Roy Austin Email 4-7-06), VHI.D (Steve Goemer Email 4-7-06) and updated information above on Table 2-7 of the VYVPS Environmental Report.
E. Property taxes paid by VYNPS to Vernon Township in 2005.
Response: See file named VIII.B,C,EF (Kim Riverio Email 4-3-06) and updated information above on Table 2-7 of the VYVPS Environmental Report.
F. Real Estate and Personal Property Tax paid to Brattleboro Township for 2005.
Response: See file named VIII.B,C,E,F (Kim Riverio Email 4-3-06) and updated information above on Table 2-7 of the VYVPS Environmental Report.
VYNPS LR Informational Needs - 18
IX.
Alternatives A. A detailed map or aerial photograph of the VYNPS site that shows the extent of previous ground disturbance and specifically differentiates between industrial/construction disturbances and agricultural disturbances (L. DeWald)
Response: Copies of aerial photos are available and can be furnished upon request.
B. General description of where within the VYNPS area the alternative coal-fired and gas-fired plants would reasonably be located (J. Brochu)
Response: for the alternative coal-fired plant, coal delivered by barge is not feasible due to the dams associated with the Connecticut River. Therefore, the coal-fired plant would need to be located in an area that has a railroad line for delivery of coal. Keene, New Hampshire would be the nearest area to VYNPS with access to a railroad line.
Since the nearest available gas pipeline (Tennessee Gas Pipeline) tie-in is located near Renfrew, Massachusetts (- 40 miles from VYNPS), the alternative gas-fired plant would need to be located within the vicinity of this pipeline to minimize environmental impacts.
VYNPS LR Informational Needs - 19
X.
Transmission Lines A. See related items described under Terrestrial Ecology above. (R. Buckley)
Response: Transmission lines are not within the scope of this license renewal review since they already existed prior to plant construction. In addition, Entergy does not own or operate these lines.
VYNPS LR Informational Needs - 20
XI.
Previous NEPA Documents (J. Brochu)
A. Copies of any site-specific NEPA documents (EIS, EA, FONSI) prepared to support plant additions or modifications (e.g., for ISFSL construction, power Uprates, etc.), including:
U.S. Atomic Energy Commission. 1972, Final Environmental Statement"Related to the Operation of Vermont Yankee Nuclear Power Corporation, Docket No. 50-271, United States Atomic Energy Commission, Directorate of Licensing, July1972.
Response: See file named XI.A (VYNPS FES).
U.S. Nuclear Regulatory Commission. 2005. United States Nuclear Regulatory Commission, Entergy Nuclear Vermont Yankee, LLC and Entergy Nuclear Operations, Inc., Docket 50-271, Vermont Yankee Nuclear Power Station Draft Environmental Assessment and Finding of No Significant Impact Related to the Proposed License Amendment to Increase the Maximum Reactor Power Level, November 3, 2005.
Response: See file named XI.A (NRC FONSI).
ECP (Environmental Compliance Services, Inc.). 2001. Phase I & II Environmental Site Assessment, Vermont Yankee Nuclear Power Corporation, June 4, 2001.
Response: See file named XI.A (ECP Phase I & II).
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