ML070230546
| ML070230546 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek  |
| Issue date: | 02/21/2007 |
| From: | Christian Jacobs NRC/NRR/ADRO/DLR/REBB |
| To: | Garrett T Wolf Creek |
| Jacobs C, PM, REBB, DLR, 415-3874 | |
| References | |
| TAC MD3182 | |
| Download: ML070230546 (11) | |
Text
February 21, 2007 Mr. Terry J. Garrett Vice President Engineering Wolf Creek Nuclear Operating Corporation P.O. Box 411 Burlington, KS 66839
SUBJECT:
ENVIRONMENTAL SITE AUDIT REGARDING WOLF CREEK GENERATING STATION LICENSE RENEWAL APPLICATION (TAC NO. MD 3182)
Dear Mr. Garrett:
The U.S. Nuclear Regulatory Commission (NRC) staff has reviewed the Environmental Report submitted by Wolf Creek Nuclear Operating Corporation, in support of its application for license renewal for the Wolf Creek Generating Station (WCGS), and plans to conduct its environmental site audit at WCGS. To develop the Supplemental Environmental Impact Statement for WCGS license renewal, the NRC staff requests that the items described in the enclosed list be made available to the extent possible during the WCGS environmental site audit. If you have any questions, please contact me at 301-415-3874 or via email at cjj@nrc.gov.
Sincerely,
/RA/
Christian Jacobs, Environmental Project Manager Environmental Branch B Division of License Renewal Office of Nuclear Reactor Regulation Docket No. 50-482
Enclosure:
As stated cc w/encl: See next page
ML070230546 OFFICE LA:DLR GS:DLR:REBB PM:DLR:REBB BC:DLR:REBB NAME IKing AWilliamson CJacobs RFranovich DATE 02/15/07 02/15/07 02/20/07 02/21/07
Letter to T. Garrett from C. Jacobs dated February 21, 2007
SUBJECT:
ENVIRONMENTAL SITE AUDIT REGARDING WOLF CREEK GENERATING STATION LICENSE RENEWAL APPLICATION (TAC NO. MD 3182)
HARD COPY:
DLR R/F E-MAIL:
P.T. Kuo (RidsNrrDlr)
W. Maier R. Franovich (RidsNrrDlrRebb)
E. Benner (RidsNrrDlrReba)
R. Schaaf C. Jacobs A. Williamson Bobbie.Hurley@earthtech.com V. Rodriguez J. Donohew S. Cochrum V. Dricks RidsOGCMailRoom DLR/REBB DLR/REBA
SITE AUDIT NEEDS WOLF CREEK GENERATING STATION Please have copies of all references in the Environmental Report (ER) available for the NRC staff to review during the site audit. Items that will be required for submittal will be identified during or immediately following the audit.
Please have the following documentation available for review or be prepared to discuss during the site audit:
General Aerial photographs of the site dating back to before and during site preparation and plant construction.
Photographs of the site dating to before and during site preparation and plant construction.
Aquatic Ecology Available water or sediment quality data for John Redmond Reservoir (JRR), Coffey County Lake (CCL), and Neosho River.
Available information regarding local, state, or federal management measures for the JRR, CCL, and the Neosho River. This may include fisheries management, watershed management, flow regulation, etc.
Any available documentation regarding minimum flows in the Neosho River.
Available records regarding the operation of the intake screens at either the Neosho River or CCL screen houses as well as information on the ongoing and periodic maintenance that occurs on the screens.
Available information on invasive or nuisance species observed in the facilitys intake, JRR, CCL, or the Neosho River and available information on Wolf Creek Nuclear Operating Corporation (WCNOC) efforts to address this issue.
Documentation regarding the WCNOC or Coffey County Sheriffs office management of the CCL access program.
Examples of the fishery regulations developed by the Kansas Department of Wildlife &
Parks for CCL.
If available, information on any occurrences of the Topeka Shiner in the JRR, CCL, Neosho River, or any water bodies crossed by the facilitys transmission lines.
Section 2.5 of the ER (Wolf Creek Generating Station (WCGS), 1980) states that U.S.
Fish and Wildlife Service (USFWS) and U.S. Geological Survey (USGS) recommended that additional data be obtained on the habitat requirements of the Neosho River madtoms. Please provide any new information related to these habitat requirements.
Section 2.5 of the ER (WCGS, 1980) states that USFWS and USGS recommended that flows below the John Redmond Dam be increased during critical periods for the Neosho River madtoms. Please provide any new information related to this issue.
If available, information on any occurrences of the Neosho river madtom in the JRR, CCL or Neosho river.
If available, information on any occurrences of the Neosho mucket mussel in the JRR, CCL or Neosho river.
Section 3.1.2 of the ER (WCGS, 1980) states that water is released to Wolf Creek infrequently. Please provide available records documenting these releases and/or information regarding the frequency of these releases.
Details on the anti-scalants, dispersants, biocides, and corrosion inhibitors which are released into the circulating water system. Specifically, names of additives used, concentrations used, and frequency of application.
System operating procedures for the circulating water system traveling screens.
Drawings and a detailed description of the circulating water system/service water system/essential service water system.
Discharge Monitoring Reports for the last 12 month period.
Whole effluent toxicity testing documentation or reports conducted at the facility (and as specified in the facilities National Pollutant Discharge Elimination Systems [NPDES]
permit).
Item D.21 of the Facilities NPDES permit states that information required by the 316(b)
Phase II regulations shall be submitted to Kansas Department of Heath & Environment (KDHE) in accordance with the dates indicated in the Phase II regulations. Please describe the steps conducted to date by WCNOC to comply with this permit requirement and provide any data collected to date in support of this submission.
Current and historic flow records for the Neosho River.
A statement is made in the 5th paragraph of Enclosure 2 to WM 06-0046 (November 17, 2006) that the state of Kansas has not required entrainment monitoring and will not require it for the 316(b) determination. Please provide documentation from KDHE regarding this issue.
Larval fish monitoring data as described in Paragraph 6 of Enclosure 2 to WM 06-0046 (November 17, 2006).
If available, information on the location of the spawning areas for the various fish species in CCL.
Bathymetric map of CCL.
Available information regarding the initial stocking of CCL and subsequent stocking efforts.
Available information regarding trends in the Neosho River fish populations.
As discussed in Enclosure 1 to WM 06-0046 (November 17, 2006), please provide any information available regarding WCNOCs stakeholder participation in the Watershed Restoration and Protection Strategy.
Additional details regarding the detailed assessment of impingement currently being prepared by WCNOC staff (as cited in Enclosure 3 to WM 06-0046, November 17, 2006).
Possible cold shock impacts to gizzard shad is mentioned in Section 2.2 of the ER (WCGS, 1990). If there have been any incidents of cold shock to gizzard shad or other fish, please provide supporting data.
Within Section 2.2 of the ER, it is noted that WCNOC develops annual fishery monitoring reports and management plans. Please have available the most recent publication of each of these reports.
Section 2.5 of the ER (WCGS, 1980) describes the Topeka shiner, Neosho madtom, and Neosho mucket mussel. Please have available any records of these species being collected in impingement and entrainment sampling.
Information on the source of water for the Sharpe Generating Station mentioned in Section 2.12 of the ER (WCGS, 1980).
Information on potential riparian/wetland communities in the project area, including along the transmission line.
Information on any microbiological monitoring program, including any recent data.
Section 6.2 of the ER (WCGS, 1980) notes that routine mitigation and monitoring programs are conducted, including effluent chemistry monitoring and water quality and fishery monitoring of CCL. Please provide at a minimum the most recent set of these data.
A description, including volumes, chemical, and radiological characteristics, of all solid, liquid, aqueous, and gaseous waste streams generated by the facility. Include information on whether waste streams are disposed at off-site locations, or released to land, air, or water bodies on-site.
Land Use/Socioeconomics Residential locations, by city and county, of full-time WCGS employees.
Approximate on-site land area used by major structures and facilities, in square feet.
Information on plant noise and what can be heard at the site boundaries.
Records of public water usage by WCGS (e.g., water bills from City of Burlington).
Federal lands and Native American lands in the area.
Information regarding the source of the water Public Wholesale District 12 and the City of Burlington distribute as potable water.
Cultural Resources WCNOC policies and procedures concerning the identification and documentation of cultural resources in advance of ground surface disturbing activities.
Examples of the implementation of these policies and procedures during past ground surface disturbing activities.
Water Use/Water Quality Site-specific hydrogeological information, including: groundwater depth(s) at site; aquifer(s) present at site; location, elevation, construction, and historical analyses on current and past monitoring wells (including B-12, C-10, C-49, J-1, J-2, G-2, and F-1);
details of the current monitoring and analytical program; flow direction information (direction, rate, fate); and comprehensive local production information (locations, construction information, history of analysis, pump rates, use).
Documentation of any environment releases, including any evaluations of the incident with respect to the nature, extent, and impact of the release.
Locations, volumes, and existing chemical and radiological analytical data on drinking water intakes for Burlington, Neosho Falls, Iola, and any other intakes on the Neosho River between JRR and Iola.
Correspondence, reports, and any other information related to any past restrictions on water withdrawal, if any have occurred. If none have occurred, a statement that these restrictions have never been implemented.
More detailed data regarding the groundwater quality study performed from 1973-87.
Provide the locations of the wells included in the study, their depths, production rates, and water uses. Discuss any regulatory involvement, including the regulatory program of which the study was a part, which agency(ies) reviewed and approved workplans and conclusions, the chemical and radiological parameters that were measured, the periodicity of the sampling, and the standards to which results were compared. Provide the rationale for ceasing the program only two years into operations, including any regulatory concurrence in this action.
A map showing the locations of all groundwater monitoring or production wells in the local area, including their depths, rates of production, and use of water, if known.
Section 2.9.1 states that 80% of water use in the basin is from surface sources -
describe the source, location, and use of the other 20%.
More detailed meteorological data, including historic rainfall data, to provide additional information for the evaluation of water use conflicts in Section 2.10 of the ER (WCGS, 1980). Include average rainfall, seasonal variations, and information on extreme conditions. Please provide the average peak and low-flow values for the Neosho River.
Also provide information on seasonal variability, if it exists.
Clarification of the relationship between the WCNOC contract with the Kansas Water Resources Board, versus the Certificate of Appropriation discussed in ER Section 4.1.
It appears that the contract has controls based on available supply within the reservoir, while certificate has controls based on the flow rate in the river. Please verify if this is correct. Also identify if a different agency implements the controls in either case, or if this is a single agency.
Historical information on how the water withdrawal controls have been implemented in the past. If there have never been any incidents where low water levels in the reservoir or low flow in the river have resulted in water withdrawal restrictions, then state this. If there have been incidents where the rights of any user (WCGS or any other user) have been restricted, provide information on the cause of the incident, length of duration, restrictions placed on which users, and any other relevant information.
Please provide actual historical data on water withdrawal volumes from the Neosho River.
Groundwater levels were predicted to rise 45.8 feet within 100 feet of the site 50 years after the filling of CCL. The height of the ground water table was predicted to rise 0.4 feet, 2 miles from the site after the lake was filled. Please provide the elevation of the water table before the lake was filled and the current water table elevation.
The groundwater flow direction was noted to be generally SW from WCGS to the Neosho River. Are there any localized groundwater flow directions to Wolf Creek (below CCL)?
Regarding water use conflicts at Wolf Creek, although the ER Section 4.1 indicates no surface water use conflicts, our Generic Environmental Impact Statement (GEIS) for license renewal says (section 4.4.2.1, p. 4-52): Two nuclear power plants, the Braidwood Station and Wolf Creek Generating Station, have already experienced water-use conflicts. Furthermore, the GEIS on p. 4-53 (left column, first full para) uses WCGS as an example of potential water use conflicts. Water use conflicts at Wolf Creek are also cited in section 4.4.3, p. 4-57, left column. Although there seems to be a discrepancy, perhaps all water use conflicts have been solved. If so, Wolf Creek should provide this information.
An assessment of the impact of population increases attributable to the proposed project on the public water supply, as per 10 CFR 51.53(c)(3)(ii)(I).
Terrestrial Ecology Clarify discussions regarding site boundaries, land ownership, and land use within Section 2.4 and Figure 2-3 of the ER (WCGS, 1980). Clarify the difference between Site Boundary and the Plant Site on the map, with respect to whether these are a land ownership distinction, a physical fencing distinction, or some other regulatory or access distinction. Please claarify whether or not the referenced agricultural production areas are within the Site Boundary as shown on Figure 2-3. Identify any areas fenced to restrict human access and any areas fenced that may restrict wildlife access.
Additional data on the avian collision studies that were ceased in 1986. Section 2.4 of the ER (WCGS, 1980) states that sufficient data had been collected by 1986. Provide any documentation of regulatory involvement and concurrence in this determination of sufficiency.
Details on the power transmission system, including information on the design of the towers, the number and configuration of the lines on the towers within each right-of-way (ROW).
Details regarding the maintenance procedures used in the transmission line ROWs, including mechanical, chemical, and biological control methods for vegetation management.
More detailed maps/aerial photos of the transmission line ROWs showing topographic features, major habitats/vegetation communities, land uses, wetlands, and floodplains, and the location of the Sharpe Generating Station.
Please provide information on the locations of transmission line ROWs crossings with parks, wildlife refuges, or wildlife management areas, or any major lakes (in addition to CCL), ponds, or streams? If so, please provide information on these crossings and their locations.
Any available studies or other information about the issues raised in the letter from the U.S. Fish and Wildlife Service (November 14, 2005) regarding terrestrial threatened and endangered species.
For example:
-- Any assessments of the transmission lines for conformity with Suggested Practices for Raptor Protection on Power Lines (Raptor Research Foundation 1996)? Please provide any such assessments and details of transmission line construction relevant to raptor protection. Also provide a copy of Suggested Practices, if available.
-- Any special ROW maintenance procedures used to reduce the potential for impacts to Meads milkweed or animals with federal or state listing status.
Any available maps and aerial photographs of the WCGS plant site and the area within and adjoining the larger site boundary (which encompasses CCL) showing topographic features, major habitats/vegetation communities, land uses, wetlands, and floodplains.
Any available information identifying natural communities and dominant species of plants and animals that utilize terrestrial habitats of the site and the transmission line ROWs, as well as semiaquatic species such as waterfowl that use Lime Sludge Pond and CCL.
Alternatives Would additional transmission infrastructure be necessary if purchased power replaced Wolf Creeks capacity, i.e., do existing transmission lines have sufficient capacity to support purchased or imported power? Would any new utility ROW be necessary?
Would existing ROW need to be expanded or otherwise modified? Would existing ROW be retired and return to other uses? What are the impacts of these actions?
Can construction begin on a new facility at the Wolf Creek site while WCGS is in operation? Can a new plant be constructed that would use Wolf Creeks cooling system prior to the retirement of WCGS? Can a new plant be constructed on previously-disturbed areas of the site prior to retirement of WCGS? If not, what are the impacts of building a new, alternative plant on a Greenfield site or of constructing and operating a new cooling system?
What is the current attainment status (Clean Air Act) of the region within which WCGS is situated?
PM2.5 is a Clean Air Act criteria pollutant. Please provide any available information on how much PM2.5 would be emitted using the coal, oil or gas alternatives to license renewal.
What is the heat rate for Wolf Creek? How would the differential levels of heat rejection from the sited appropriate alternative energy sources affect the heating of CCL? Would you be aware of any significant effects to water quality or ecology should the thermal output to the lake change in conjunction with alternative energy sources?
Provide the annual average capacity factor for WCGS for the ten year period ending in 2006. Please indicate those years during which refueling outages occurred.
Provide the gross and net electrical output of WCGS based on summer and winter conditions.
What does WCNOC view to be a realistic schedule for implementing the alternatives evaluated in detail in the ER (gas, coal, nuclear)? Please provide a simplified permitting, design and construction schedule for each such alternative.
Provide the range of WCNOC employee salaries. Also, provide the range of salaries for permanent contract employees at WCGS.
Is there a gas transmission line in the immediate WCGS vicinity to support a gas-fired alternative? What is the distance that a new gas line would need to be run to support gas fired operations at the WCGS site and what would be the diameter of the line?
Also, is there adequate capacity in the nearest gas transmission lines to support gas-fired operations at the WCGS site?
Please update the information presented in Section 7.2 of the ER to show both Generating Capacity and Generation by fuel type for the years 2000 through 2006 inclusive.
WCNOC has limited its analysis of coal fired alternatives to pulverized coal systems (ER Section 7.2.1). However, the WCGS operating license does not expire until 2025 which is 18 years off. At this point in time integrated gasification combined cycle systems are well under development and its likely that these and other advanced coal utilization systems will be operational by the time the WCGS license expires. Please provide updated information including a brief assessment of the state of advanced coal utilization technologies, whether such technologies could be employed at the WCGS site and the potential benefits of the new technologies. In particular, the possible environmental advantages of advanced coal systems should be mentioned including reduced air emission in comparison to pulverized coals burners. The purpose of addressing advanced coal technologies would not be to consider those technologies as formal "alternatives" to license renewal but rather to generally update the information presented in the alternatives analysis.
Most license renewal Environmental Impact Statements contain an analysis of a combination of alternatives to replace the output of a generating station should the operating license not be renewed. Please provide an analysis of at least one combination alternative that WCNOC considers feasible.
With regard to Section 7.2.1.4, please identify the range of conservation, efficiency and load management programs being conducted in Kansas. This should list each program, identify its sponsor and goals, and provide information relative to the success of the effort.
ER Section 7.2.1.3 addresses purchased power. Please provide a chart showing Kansas power imports for the last ten years. Also, identify transmission line constraints, if any, to importing power into the state.
Wolf Creek Generating Station Environmental Service List cc:
Jay Silberg, Esq.
Pillsbury Winthrop Shaw Pittman, LLP 2300 N Street, NW Washington, DC 20037 Regional Administrator, Region IV U.S. Nuclear Regulatory Commission 611 Ryan Plaza Drive, Suite 400 Arlington, TX 76011-7005 Senior Resident Inspector U.S. Nuclear Regulatory Commission P.O. Box 311 Burlington, KS 66839 Chief Engineer, Utilities Division Kansas Corporation Commission 1500 SW Arrowhead Road Topeka, KS 66604-4027 Office of the Governor State of Kansas Topeka, KS 66612 Attorney General 120 S.W. 10th Avenue, 2nd Floor Topeka, KS 66612-1597 County Clerk Coffey County Courthouse 110 South 6th Street Burlington, KS 66839 Thomas A. Conley, Section Chief Radiation and Asbestos Control Kansas Department of Health and Environment Bureau of Air and Radiation 1000 SW Jackson, Suite 310 Topeka, KS 66612-1366 Vice President Operations/Plant Manager Wolf Creek Nuclear Operating Corporation P.O. Box 411 Burlington, KS 66839 Supervisor Licensing Wolf Creek Nuclear Operating Corporation P.O. Box 411 Burlington, KS 66839 U.S. Nuclear Regulatory Commission Resident Inspectors Office/Callaway Plant 8201 NRC Road Steedman, MO 65077-1032 Mr. Terry J. Garrett Vice President Engineering Wolf Creek Nuclear Operating Corporation P.O. Box 411 Burlington, KS 66839 Kevin J. Moles, Manager Regulatory Affairs Wolf Creek Nuclear Operating Corporation P.O. Box 411 Burlington, KS 66839 Lorrie I. Bell, Project Manager Wolf Creek Nuclear Operating Corporation P.O. Box 411 Burlington, KS 66839 Mr. James Ross Nuclear Energy Institute 1776 I Street, NW, Suite 400 Washington, DC 20006-3708 Ms. Valerie Williams, Branch Director Coffey County Library Burlington Branch 410 Juniatta St.
Burlington, KS 66839