ML080840029

Site Audit Needs List for Three Mile Island, Unit 1, Environmental Site Audit

ML080840029
Person / Time
Site:	Three Mile Island
Issue date:	04/01/2008
From:	Sarah Lopas NRC/NRR/ADRO/DLR
To:	Gallagher M AmerGen Energy Co
Lopas, S, DLR/REBA - 415-1147
References
TAC MD7702
Download: ML080840029 (15)

Text

April 1, 2008 Mr. Michael P. Gallagher Vice President License Renewal Projects AmerGen Energy Company, LLC 200 Exelon Way Kennett Square, PA 19348

SUBJECT:

ENVIRONMENTAL SITE AUDIT REGARDING THREE MILE ISLAND NUCLEAR STATION, UNIT 1, LICENSE RENEWAL APPLICATION (TAC NO. MD7702)

Dear Mr. Gallagher:

The U.S. Nuclear Regulatory Commission (NRC) staff has reviewed the Environmental Report submitted by AmerGen Energy Company, LLC (AmerGen), in support of its application for license renewal for the Three Mile Island Nuclear Station, Unit 1 (TMI-1), and plans to conduct its environmental site audit at TMI-1 during the week of April 28, 2008. To develop the Supplemental Environmental Impact Statement for the TMI-1 license renewal, the NRC staff requests that the items described in the enclosed list be made available to the extent possible during the TMI-1 environmental site audit. The NRC staff informally transmitted this list to Nancy Ranek, Exelon License Renewal Environmental Lead, via facsimile on March 19, 2008. If you have any questions, please contact me at 301-415-1147 or at sll2@nrc.gov.

Sincerely,

/RA/

Sarah Lopas, Project Manager Projects Branch 1 Division of License Renewal Office of Nuclear Reactor Regulation Docket No. 50-289

Enclosure:

As stated cc w/encl: See next page

ml080840029 OFFICE LA:DLR PM:DLR:RPB1 BC:DLR:RPB1 OGC NAME SLopas LLund BMizuno DATE 3/ /08 3/27/08 3/28/08 4/1/08 Letter to M. Gallagher from S. Lopas, dated April 1, 2008 DISTRIBUTION:

SUBJECT:

ENVIRONMENTAL SITE AUDIT REGARDING THREE MILE ISLAND NUCLEAR STATION, UNIT 1, LICENSE RENEWAL APPLICATION (TAC NO. MD7702)

HARD COPY:

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Three Mile Island Nuclear Station, Unit 1 cc:

Site Vice President - Three Mile Island Director Nuclear Bureau of Radiation Protection Station, Unit 1 Pennsylvania Department of AmerGen Energy Company, LLC Environmental Protection P. O. Box 480 Rachel Carson State Office Building Middletown, PA 17057 P.O. Box 8469 Harrisburg, PA 17105-8469 Vice President - Operations, Mid-Atlantic AmerGen Energy Company, LLC Plant Manager - Three Mile Island Nuclear 200 Exelon Way, KSA 3-N Station, Unit 1 Kennett Square, PA 19348 AmerGen Energy Company, LLC P. O. Box 480 Vice President - Licensing and Regulatory Middletown, PA 17057 Affairs AmerGen Energy Company, LLC Regulatory Assurance Manager - Three Mile 4300 Winfield Road Island Nuclear Station, Unit 1 Warrenville, IL 60555 AmerGen Energy Company, LLC P.O. Box 480 Regional Administrator Middletown, PA 17057 Region I U.S. Nuclear Regulatory Commission Ronald Bellamy, Region I 475 Allendale Road U.S. Nuclear Regulatory Commission King of Prussia, PA 19406 475 Allendale Road King of Prussia, PA 19406 Chairman Board of County Commissioners Michael A. Schoppman of Dauphin County Framatome ANP Dauphin County Courthouse Suite 705 Harrisburg, PA 17120 1911 North Ft. Myer Drive Rosslyn, VA 22209 Chairman Board of Supervisors Dr. Judith Johnsrud of Londonderry Township National Energy Committee R.D. #1, Geyers Church Road Sierra Club Middletown, PA 17057 433 Orlando Avenue State College, PA 16803 Senior Resident Inspector (TMI-1)

U.S. Nuclear Regulatory Commission Eric Epstein P.O. Box 219 TMI Alert Middletown, PA 17057 4100 Hillsdale Road Harrisburg, PA 17112 Director - Licensing and Regulatory Affairs AmerGen Energy Company, LLC Correspondence Control Desk 200 Exelon Way, KSA 3-E AmerGen Energy Company, LLC Kennett Square, PA 19348 P.O. Box 160 Kennett Square, PA 19348

Three Mile Island Nuclear Station, Unit 1 cc:

Manager Licensing - Three Mile Island Rich Janati Nuclear Station, Unit 1 Chief, Division of Nuclear Safety Exelon Generation Company, LLC Bureau of Radiation Protection 200 Exelon Way, KSA 3-E Pennsylvania Department of Kennett Square, PA 19348 Environmental Protection Rachel Carson State Building Christopher M. Crane P.O. Box 8469 President and Chief Executive Officer Harrisburg, PA 17105-8469 AmerGen Energy Company, LLC 4300 Winfield Road Michael Murphy Warrenville, IL 60555 Bureau of Radiation Protection Pennsylvania Department of Mr. Charles G. Pardee Environmental Protection Chief Nuclear Officer Rachel Carson State Building AmerGen Energy Company, LLC P.O. Box 8469 4300 Winfield Road Harrisburg, PA 17105-8469 Warrenville, IL 60555 Michael G. Brownell Assistant General Counsel Chief, Water Resources Management AmerGen Energy Company, LLC Susquehanna River Basin Commission 200 Exelon Way 1721 N. Front Street Kennett Square, PA 19348 Harrisburg, PA 17102 Associate General Counsel Rachel Diamond Exelon Generation Company, LLC Regional Director, South Central 4300 Winfield Road Regional Office Warrenville, IL 60555 Pennsylvania Department of Environmental Protection Frederick W. Polaski 909 Elmerton Avenue Manager License Renewal Harrisburg, PA 17110 Exelon Nuclear 200 Exelon Way Kennett Square, PA 19348 Albert A. Fulvio License Renewal Senior Project Manager Exelon Nuclear 200 Exelon Way Kennett Square, PA 19348

Three Mile Island Nuclear Station, Unit 1 License Renewal Site Audit Needs List The NRC staff has reviewed Appendix E, Environmental Report (ER), of the Three Mile Island Nuclear Station, Unit 1 (TMI-1) License Renewal Application and have found that it meets the requirements of 10 CFR 51.45. However, in order to develop the Supplemental Environmental Impact Statement for license renewal, a number of informational needs have been identified and are outlined below. Please have the following documentation available for review, or be prepared to discuss, during the April 28-May 2, 2008 site audit:

General

• During specific plant area tours, please provide personnel knowledgeable of the pertinent technical area(s) (i.e. aquatic, terrestrial, radiological, cultural resources, etc.) to guide or accompany the tour, and to field questions that may arise during the tour. In addition to resource specific tours, interview time for NRC staff and licensee/contractor counterparts should also be scheduled.

• Please provide hardcopies of all references cited in the ER, excluding those cited in the SAMA analysis (Section 4.20 and Appendix E).

Aquatic Review

• Please provide licensee or contractor personnel knowledgeable of aquatic issues at TMI-1 and of the Susquehanna River in the vicinity of the TMI-1 site.

Terrestrial Review

• Have any invasive species been seen or documented on the site? Are any invasive species populations being managed, or have any been managed in the past?

• Please provide the in-scope transmission line right-of-way (ROW) maintenance plans and the names of any ROW maintenance contractors.

• Please provide any aerial photos and topographic maps you have of the ROWs.

Specifically, please provide topographic maps of the site and in-scope transmission line segments, that show any significant natural heritage areas, stream crossings, historical sightings of endangered species, and migratory bird rookeries. Additionally, please provide percentages of terrestrial communities on site (e.g. 20% of the site is forest habitat).

• During the transmission line tour, NRC staff would like to see representative examples of ROW land, including stream and wetland crossings.

• What pesticides and/or herbicides are used on site or within the in-scope transmission line ROWs? What protocol do contractors follow when applying chemicals near streams and wetlands?

ENCLOSURE

• Please provide any current management plans for the osprey and peregrine falcon nesting sites on the meteorological tower and the TMI-1 reactor building. Are there any plans for future attempts to create new suitable nesting areas?

• Please provide information on any bird deaths (including birds of prey and migratory birds) that have occurred at the reactor building or the meteorological tower.

• Please provide a topographic map of the site and in-scope transmission line segments, which includes any significant natural heritage areas, stream crossings, historical sightings of endangered species, and migratory bird rookeries, if available. Additionally, please provide percentages of terrestrial communities on site (e.g. 20% of the site is forest habitat).

• Please provide delineation information for the locations/boundaries of the floodplain and wetland areas on site.

• Please provide any wildlife management plans that are used on site.

• Please provide any best management procedures followed for ground-disturbing activities.

• Section 4.9 states that animal species in the forested riparian buffer areas in the southern section of the island might be displaced by noise and vibration increases from refurbishment activities, but that this displacement will be temporary and minor. Please provide the basis for the determination that the displacement effects will be temporary and minor, as well as a list of specifically affected animals, if available.

• Section 2.5 mentions that the threatened species American holly is found on TMI-1 property, but Section 4.9 adds that it is not found in the industrial/paved areas of the site.

Please specify where American Holly is found on site.

• Section 4.9 states that the refurbishment activities will not adversely affect the peregrine falcon population that nests on the property because construction will not commence until October 2009 and the peregrine falcon nestlings have historically fledged the nest by late summer and the adult birds have migrated to their wintering ranges. However, the same reference (PADEP 2007) claims that the peregrine falcon nestlings typically do not fledge the nest until September or October. Please identify measures AmerGen plans to take to confirm that these birds have in fact migrated away from the site by the time that construction begins.

Cultural Resources Review NOTE: For cultural resource reports, if NRC is unable to locate a copy at the State Historic Preservation Office (SHPO), the NRC would like to obtain copies from AmerGen.

• The ER mentions a 1967 archaeological survey and excavation that took place prior to construction of TMI-1. Were any other surveys/investigations conducted prior to construction of TMI-1? If so, NRC would like to see all of the reports (including the 1967 report) associated with the surveys/investigations. NRC needs a map of the sites and would like to visit those sites during the audit.

• NRC would like a copy of the 1987 Mangold and Grace paper from the Mid Atlantic Archaeological Conference Annual Meeting in Lancaster, Pennsylvania.

• NRC would like a copy of the 1988 report from the survey of the 19th century burial site conducted on the southern tip of Three Mile Island by the Curator of Archaeology from the State Museum of Pennsylvania? NRC needs a map of the site and would like to tour the original burial site and the subsequent relocation site.

• Is there a report or any literature associated with the 1999 public history symposium by the Pennsylvania Historical and Museum Commission for historical marker SH-441, which commemorates the 20th anniversary of the TMI-2 accident?

• Has TMI-2 been considered eligible for the National Register of Historic Places? Does it have landmark status?

• On page 2-35, the ER states, The 200-acre area occupied by TMI-1 facilities on Three Mile Island consists entirely of land previously disturbed by prior industrial activities.

The 1972 FES mentions leased cabins and farm use from 1957 until the time of construction. What were those prior industrial activities?

• Who owned the land prior to the Metropolitan Edison Company/Jersey Central Power and Light Company/Pennsylvania Electric Company (TMI Applicants)? When was it purchased?

• Provide information associated with the historical land use of Three Mile Island (land use of the site prior to the construction of TMI Units 1 and 2).

• On pages 4-44 and 4-46, the ER states: Several cultural resource investigations have been conducted on the island, including an archaeological survey and excavation by the Pennsylvania Historical and Museum Commission in 1967 (PHMC 1977). Results of those investigations indicate that Three Mile Island has had a long history of occupation and utilization.

• How many cultural resource excavations have been conducted on Three Mile Island (in addition to the 1967 review and those mentioned in chapters 2 and 4)?

• Please provide reports for any additional investigations you identify.

• NRC would like a copy of AmerGens corporate procedures regarding protection of cultural resources provided at the audit (i.e. environmental, digging/trenching, maintenance, etc.).

• Please identify any TMI-specific procedures relating to the protection of cultural resources.

• For such procedures, please state whether they include stop work provisions and, if they do, provide examples of those provisions.

• What training does the Environmental Coordinator have with respect to Section 106 guidelines?

• Has the SHPO reviewed onsite procedures regarding cultural resources? Would the SHPO be contacted in the case of an inadvertent discovery? Will a cultural resource professional be called in to evaluate inadvertent discoveries?

• NRC would like to see any available photos that show the plant site pre-, during, and post-construction.

• NRC would like to see any available old maps of the site prior to plant construction.

• Please provide a land disturbance map that identifies areas of heavy, moderate, low, and undisturbed areas of plant property.

• Are there any archaeological sites or historic structures on or adjacent to transmission lines?

• NRC would like to review maintenance procedures for transmission lines; specifically, do they take into account the protection of cultural resources?

• NRC would like to have copies of any correspondence with the Pennsylvania Historical and Museum Commission that was not included in the ER.

• Please provide a map that clearly delineates the plant property boundary.

Land Use

• NRC needs additional information about the undeveloped portions of land within AmerGen TMI-1 site boundary and/or property with acreage and percentage by land use category beyond what was discussed in ER Sections 2.1 and 2.4 (pages 2-3 and 2-16).

Onsite land use can be divided into three basic categories consisting of (1) the amount of developable unused open portions of the site including fields and forest uplands and (2) the amount of non-developable wetlands and open water bodies (i.e., streams, ponds, and river). The third category, as indicated in the ER (approximately 200 acres), consists of developed portions of the TMI-1 site including facilities, structures, parking areas, and visitor and recreation areas.

• In addition, how much of the 440-acre site has been disturbed at some time during the construction and operation of TMI-1 and TMI-2? (See table below).

Classification Acres Percentage Unused, undeveloped, and open portions of the site including fields, forest, and uplands Non-developable wetlands, streams, and open water bodies Developed portions of the plant site including facilities, structures, parking areas, and visitor 200 or recreation areas How much of the 440-acre site has been disturbed at some time during construction and operation of TMI-1 and TMI-2?

Environmental Justice

• Please provide information about current and past wildlife sampling and testing of game animals, such as deer, squirrel, turkey, pheasant, duck, and other game birds and animals, conducted in the vicinity of TMI-1 by AmerGen and previous owners/operators of the plant. Specifically, please provide information sufficient to establish the time periods and the results of wildlife sampling and testing. The purpose of this request is to obtain information to determine whether people who consume meat from wildlife in the vicinity of the plant are at risk from nuclear power plant operations.

Related Federal Project Activities and Consultations

• NRC needs a list of all Federal facilities including national parks, forests, and wildlife lands and distances within 50 miles of the TMI-1 site. ER Section 2.12 (page 2-36) identifies military installations and EPA-related facilities within or near the vicinity of TMI-1, but this does not appear to be a complete and comprehensive discussion. The lack of this information impedes an assessment of the need for contacting other Federal agencies about their potential status as cooperating agencies with NRC, and impedes the preparation of the Supplemental Environmental Impact Statement.

• Are there any American Indian lands and/or Bureau of Indian Affairs (BIA) lands held in trust for American Indians and Indian tribes located within 50 miles of TMI-1?

Hydrology

• NRC staff would like to discuss the TMI-1 National Pollutant Discharge Elimination System (NPDES) permit and NPDES-regulated or monitored discharges with a knowledgeable licensee counterpart.

• NRC staff would like to see permitted outfalls in conjunction with the intake and discharge system; this could be combined with the circulating water system tour.

• Please provide a complete copy (including fact sheets and amendments, if applicable) of the current TMI-1 NPDES permit and the accompanying application to the state.

• Please detail or provide documentation of any release notifications, notices of violation, or remediation documentation associated with surface water discharges, septic or sewer systems, or groundwater or soil contamination for the last five years (including spills, leaks, and other releases of tritium, fuels, solvents, or other chemicals).

• Please detail the chemicals and biocides used to control the pH in the coolant, control corrosion, and clean and defoul the condenser. Please detail the wastes produced from these processes (as discharged with the cooling water according to the stations NPDES permit).

• Please provide a copy of the TMI-1 Spill Prevention, Control and Countermeasures and/or Pollution Incident Prevention Plan.

Radiological

• Please provide plant personnel and/or tour guides knowledgeable with respect to radiological issues. Additionally, please don't schedule the radiological tour during shift changes.

• Please provide records of spills and leaks of radioactive liquids for the last five years, as required by 10 CFR 50.75(g).

• Please provide information on the site groundwater protection program; specifically, the evaluation used to establish the program, program procedures, locations of monitoring wells, data, and trends. We would like a tour of several monitoring wells.

• We would like a tour of the steam generator replacement project lay-down areas and storage facility site, including:

• Location of the lay-down areas for the Steam Generator Replacement Project;

• Location of the future Steam Generator Storage Facility; and

• Location of any planned radiation monitoring devices for the future Steam Generator Storage Facility.

• Please provide information on radioactive waste increase during the refurbishment period, including:

• What is the projected increase in liquid waste volume and activity?

• What is the projected increase in gaseous waste volume and activity?

• What is the projected increase in solid waste volume and activity?

• Will there be any changes in the radiological effluent release and/or radiological environmental monitoring program methodology?

• What is the projected radiation dose to workers during the refurbishment period?

• What is the projected radiation dose to the public during the refurbishment period?

• We would like a tour of the liquid and gaseous radioactive effluent monitoring system, covering the flow of radiological waste from start to final release:

• Tour should include several monitoring locations with typical examples of gaseous and liquid radiation monitors and release points, and liquid radiological waste control panel.

• We would like a tour of radioactive waste holding, processing, packaging, and storage areas.

• We would like a tour of the meteorological tower; specifically to explain its use for the radiological effluent monitoring, public dose calculations, and environmental monitoring programs.

• We would like a tour of a few offsite radiological environmental monitoring stations (i.e., air sampling sites, vegetation collection sites, and drinking water collection sites).

Electromagnetic Fields

• NRC staff would like to speak with knowledgeable personnel regarding transmission line acute effects.

Non-Radiological Waste/Pollution Prevention

• Please provide a description of non-radioactive waste systems and applicable procedures at TMI-1. NRC staff would like to meet with plant personnel who are knowledgeable about non-radiological waste management and compliance issues.

• Please detail TMI-1 procedures to collect and manage non-radioactive waste (classified as hazardous, universal, or residual) in accordance with federal (40 CFR) and state (25 PA Code) rules.

• Please identify the types of non-radiological wastes that the TMI-1 site has produced for each of the past five years. Please provide an accounting of waste quantities by year and waste stream.

• Please provide the amounts (by weight) of mixed wastes at the TMI-1 site generated over the past five years.

• Please provide copies of waste generator permits.

• Please provide an analyses of planned refurbishment activities (steam generator replacement), projected increase in non-radioactive waste, and measures that will be implemented in order to handle this increase.

• We would like a tour of non-radioactive waste facilities (trash, industrial waste, sewage treatment facility, and hazardous material handling and storage areas).

Alternatives to License Renewal

• NRC staff would like to speak with the alternatives expert/contractor on the project.

Air Quality and Meteorology

• NRC would like a description of the onsite meteorological system/tower with a discussion of the systems backup capabilities in the event of a sensor failure situation.

• NRC would like a list of all emission sources, emission calculations, and emission inventory reports.

• NRC would like copies of air permits for the last five years.

• NRC would like a description of the regional climatology (annual and seasonal mean temperatures, historically high rain and snow events, tornado activities), and a copy of the Annual Meteorological report for 2007, if available.

• NRC would like a description of the local meteorology for the plant (annual and seasonal predominant wind speed and direction).

• NRC would like to see copies of any related documents that would support the conclusion made in ER section 4.11, pages 4-21 and 4-22, that The amount of pollutants emitted from construction vehicles and equipment and construction worker commute traffic would be small compared to total vehicular emissions in the region, and These emissions would be small compared to regulatory thresholds and a conformity determination for this project pursuant to the Clear Air Act would not be required.

• NRC would like a description of burned diesel oil and lubricating oil disposal and/or re-use, and any incinerators on site.

• We would like air quality and meteorology tours, including:

• Tour of the meteorological tower; specifically to explain its use for any measurements used to monitor air quality (can be done in conjunction with radiation tour);

• Tour of any onsite air quality monitoring stations; and

• Tour of any onsite incinerators or fossil-fueled boilers.

• The staff would like to speak to knowledgeable personnel regarding the plants air quality monitoring program.