ML092670523

Request for Additional Information Regarding the Review of the License Renewal Application for the Crystal River, Units 3 Nuclear Generating Plant

ML092670523
Person / Time
Site:	Crystal River
Issue date:	10/06/2009
From:	Keegan E License Renewal Projects Branch 2
To:	Franke J Progress Energy Florida
Keegan E NMSS/SFPO (301) 415-8517
References
TAC ME0278
Download: ML092670523 (19)

Text

October 6, 2009 Mr. Jon Franke, Vice President Crystal River Nuclear Plant (NA1B)

ATTN: Supervisor, Licensing & Regulatory Programs 15760 W. Power Line Street Crystal River, FL 34428-6708

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION REGARDING THE REVIEW OF THE LICENSE RENEWAL APPLICATION FOR THE CRYSTAL RIVER UNIT 3 NUCLEAR GENERATING PLANT (TAC NO. ME0278)

Dear Mr. Franke:

The U.S. Nuclear Regulatory Commission staff (NRC or the staff) has reviewed the Progress Energy Florida license renewal application for Crystal River Unit 3 Nuclear Generating Plant (CR-3). The environmental site audit was conducted at CR-3 during the week of July 20, 2009, by NRC and Argonne National Laboratory staff.

Enclosed is the staffs request for additional information and revised environmental audit needs list that indicates which questions were resolved during the environmental site audit. We request that you provide your responses to these questions no later than 30 days after the issuance of this letter, in order to maintain the environmental review schedule.

If you have any questions, please contact Elaine Keegan by telephone at 301-415-8517 or by e-mail at Elaine.Keegan@nrc.gov.

Sincerely,

/RA/

Elaine M. Keegan, Sr. Project Manager Projects Branch 2 Division of License Renewal Office of Nuclear Reactor Regulation Docket No. 50-302

Enclosure:

As stated cc w/encl: See next page

October 6, 2009 Mr. Jon Franke, Vice President Crystal River Nuclear Plant (NA1B)

ATTN: Supervisor, Licensing & Regulatory Programs 15760 W. Power Line Street Crystal River, FL 34428-6708

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION REGARDING THE REVIEW OF THE LICENSE RENEWAL APPLICATION FOR THE CRYSTAL RIVER UNIT 3 NUCLEAR GENERATING PLANT (TAC NO. ME0278)

Dear Mr. Franke:

The U.S. Nuclear Regulatory Commission staff (NRC or the staff) has reviewed the Progress Energy Florida license renewal application for Crystal River Unit 3 Nuclear Generating Plant (CR-3). The environmental site audit was conducted at CR-3 during the week of July 20, 2009, by NRC and Argonne National Laboratory staff.

Enclosed is the staffs request for additional information and revised environmental audit needs list that indicates which questions were resolved during the environmental site audit. We request that you provide your responses to these questions no later than 30 days after the issuance of this letter, in order to maintain the environmental review schedule.

If you have any questions, please contact Elaine Keegan by telephone at 301-415-8517 or by e-mail at Elaine.Keegan@nrc.gov.

Sincerely,

/RA/

Elaine M. Keegan, Sr. Project Manager Projects Branch 2 Division of License Renewal Office of Nuclear Reactor Regulation Docket No. 50-302

Enclosure:

As stated cc w/encl: See next page DISTRIBUTION:

See next page ADAMS Accession No. ML092670523 OFFICE PM:RPB2:DLR LA:RPOB:DLR BC:RPB2:DLR PM:RPB2:DLR NAME EKeegan SFigueroa DWrona EKeegan DATE 10/1/09 10/1/09 10/6/09 10/6/09 OFFICIAL AGENCY RECORD

Letter to Jon Franke from Elaine M Keegan dated October 6, 2009 DISTRIBUTION:

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION REGARDING THE REVIEW OF THE LICENSE RENEWAL APPLICATION FOR THE CRYSTAL RIVER UNIT 3 NUCLEAR GENERATING PLANT (TAC NO. ME0278)

HARD COPY:

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Crystal River Nuclear Generating Plant, Unit 3 cc:

Mr. R. Alexander Glenn Associate General Counsel (MAC-BT15A)

Florida Power Corporation P.O. Box 14042 St. Petersburg, FL 33733-4042 Mr. James W. Holt Plant General Manager Crystal River Nuclear Plant (NA2C) 15760 W. Power Line Street Crystal River, FL 34428-6708 Mr. William A. Passetti, Chief Department of Health Bureau of Radiation Control 2020 Capital Circle, SE, Bin #C21 Tallahassee, FL 32399-1741 Attorney General Department of Legal Affairs The Capitol Tallahassee, FL 32304 Mr. Craig Fugate, Director Division of Emergency Preparedness Department of Community Affairs 2740 Centerview Drive Tallahassee, FL 32399-2100 Chairman Board of County Commissioners Citrus County 110 North Apopka Avenue Inverness, FL 34450-4245 Mr. Stephen J. Cahill Engineering Manager Crystal River Nuclear Plant (NA2C) 15760 W. Power Line Street Crystal River, FL 34428-6708 Mr. Daniel R. Westcott Supervisor, Licensing & Regulatory Programs Crystal River Nuclear Plant 15760 W. Power Line Street Crystal River, FL 34428-6708 Mr. Jon A. Franke Director Site Operations Crystal River Nuclear Plant (NA2C) 15760 W. Power Line Street Crystal River, FL 34428-6708 Senior Resident Inspector Crystal River Unit 3 U.S. Nuclear Regulatory Commission 6745 N. Tallahassee Road Crystal River, FL 34428 Ms. Phyllis Dixon Manager, Nuclear Assessment Crystal River Nuclear Plant (NA2C) 15760 W. Power Line Street Crystal River, FL 34428-6708 Mr. David T. Conley Associate General Counsel II - Legal Dept.

Progress Energy Service Company, LLC Post Office Box 1551 Raleigh, NC 27602-1551 Mr. Daniel L. Roderick Vice President, Nuclear Projects &

Construction Crystal River Nuclear Plant (SA2C) 15760 W. Power Line Street Crystal River, FL 34428-6708 Mr. Mark Rigsby Manager, Support Services - Nuclear Crystal River Nuclear Plant (SA2C) 15760 W. Power Line Street Crystal River, FL 34428-6708

Crystal River Nuclear Generating Plant, Unit 3 cc:

Mr. Robert J. Duncan II Vice President, Nuclear Operations Progress Energy Post Office Box 1551 Raleigh, NC 27602-1551 Mr. Brian C. McCabe Manager, Nuclear Regulatory Affairs Progress Energy Post Office Box 1551 Raleigh, NC 27602-1551 Mr. Brian Moore 5559 Cactus Circle Spring Hill, FL 34606 Ms. Gail Grimm 1007 W. Main Street Inverness, FL 34450 Mr. John H. Ring 220 N. Big Oaks Point Lecanto, FL 34461 Mr. Andrija Vukmir 1498 N. Endicott Point Crystal River, FL 34423 Ms. Dixie Hollins Citrus County Chamber of Commerce P.O. Box 277 Crystal River, FL 34423 Mr. Gary W. Maidhof Department Director Citrus County Government 3600 W. Sovereign Path Suite 109 Lecanto, FL 34461

ENCLOSURE REQUEST FOR ADDITIONAL INFORMATION AND REVISED ENVIRONMENTAL NEEDS LIST FOR THE CRYSTAL RIVER UNIT-3 NUCLEAR GENERATING PLANT Request for Additional Information

1. To assess the cumulative impacts of extended operation, provide a list of all reasonably foreseeable activities and events involving CR-3 or other Progress Energy Florida facilities that will occur during the period covered by the license renewal and that have the likelihood of impacting the environment on or proximate to CR-3; provide a schedule for each; provide an assessment of expected impacts; introduce qualifiers or contingencies as necessary to reflect uncertainty.

2. Provide the Supplemental Environmental Report, Extended Power Uprate, Crystal River Unit 3 Nuclear Power Plant, Progress Energy Florida, Docket No. 50-302, License No. DPR-72, June 2009.

3. Provide the Site Certification Application for Crystal River Unit 3 Uprate Project (two volumes),

prepared by Golder Associates, Tampa, FL (Golder Project 07389531) June 2007 and submitted by Progress Energy Florida, Inc., St. Petersburg, Florida to the Florida Site Certification Board.

4. Provide a copy or description of vegetation management procedures (both mechanical and chemical) for wetland, aquatic, and other sensitive areas and habitats within the facilities area of Crystal River Electric Complex and along the shoreline of the intake and discharge canals, including within the immediate vicinity of the intake and discharge structures.

Revised Environmental Site Audit Needs List

1. AIR, METEROLOGY, CLIMATE (E. Lenning, NRC, R. Kolpa, ANL)

A-1 Provide copies of relevant sections of the last five years of the Annual Operating Report submitted to the Florida Department of Environmental Protection (FL DEP) in accordance with Rule 62-210.370. Provide copies of all other permits (e.g.,

Prevention of Significant Deterioration [PSD] permit for the south cooling tower) issued by and correspondence with the FL DEP pertaining to air pollution sources associated with Unit #3 operations.

A-2 Provide details of stationary and mobile sources of criteria pollutants associated with the operation of CR-3 (including on-site spent fuel storage), including, as appropriate, horse power ratings, fuel consumption, pollution control equipment, operating records, and estimates of annual criteria pollutant releases.

The information package prepared for staff review during environmental site audit answered this item. Provide the information package including the items listed in the following Requested Documents list.

A-3 Make available for review, records of preventative maintenance activities for emergency generators, back-up fire water and feedwater pumps, and other back-up or emergency diesel-fueled equipment for the last three years; confirm that all such stationary sources of air pollutant emissions are not regulated sources under the CR-3 Title V permit.

The information package prepared for staff review during environmental site audit answered this item. Provide the information package including the items listed in the following Requested Documents list.

A-4 Provide copies of procedures for meteorological instrument calibrations and for the collection, verification, and application of meteorological data to support operations.

The information package prepared for staff review during environmental site audit answered this item. Provide the information package including the items listed in the following Requested Documents list.

A-5 Provide procedures for maintenance of heating, ventilating, and air-conditioning (HVAC) equipment, including: management/inventory of refrigerants, characterization/management of filters, refrigerants, and pump oils for systems serving areas with potential airborne radioactivity.

The information package prepared for staff review during environmental site audit answered this item. Provide the information package including the items listed in the following Requested Documents list.

A-6 Provide estimates of drift loss from the helper cooling tower for CR-3, as well as details regarding the chemicals used (if any) to treat the water directed to the helper cooling towers; provide the average percentage of time that the helper cooling tower is operating.

The information package prepared for staff review during environmental site audit answered this item. Provide the information package including the items listed in the following Requested Documents list.

A-7 Provide additional details regarding refurbishment activities planned for 74-day period beginning in September 2009 (replacement of steam generators), including: capacity and throughput of temporary on-site concrete batch plant, type, number, and expected operating schedules of supplemental construction vehicles and equipment used to support refurbishment activities, expected vehicle trips (trucks bringing materials and equipment, as well as vehicles of the refurbishment workforce) that will occur as a result of refurbishment, total area of ground surface to be disturbed to support development of temporary laydown yards, material storage yards, and construction of new buildings/structures.

A-8 Provide information on the status of the FL DEP permit for the south cooling tower (PSD-FL-392) and any operating reports submitted to date.

The information package prepared for staff review during environmental site audit answered this item. Provide the information package including the items listed in the following Requested Documents list.

A-9 Provide copies of all applicable Air permits (past 5 years) including open burning or fire permits if such activities take place at CR-3.

A-10 List all emission sources and materials emitted, if air permit does not contain this information.

A-11 How does CR-3 dispose and/or re-use burned diesel oil and lube oil?

A-12 Are there any incinerators onsite?

A-13 Provide the most current and updated description of the meteorological system/tower.

Confirm elevations for new location of the meteorological tower.

A-14 What are the total direct and indirect projected emissions from the CR-3 refurbishment project?

The information package prepared for staff review during environmental site audit answered this item. Provide the information package.

Requested Air, Meterology, Climate Documents: In addition to the information and documents requested above, provide the following documents.

1. Design Basis Document for the Meteorological Measurement System, System Code: MM, Tab: 5/6, Issue Date 11/14/83, Revision 4

2. FLDEP permit: Progress Energy Florida, Inc. Project No. 0170004-016-AC, Air Construction Permit PSD-FL-383, Units 4 and 5 Pollution Controls Project, Permit expires November 1, 2011

3. FLDEP permit: Progress Energy Florida, Inc. Project No. 0170004-019-AC, Air Construction Permit PSD-FL-383, Units 4 and 5 Pollution Controls Project Revisions, Permit expires November 1, 2011

4. FLDEP permit: Air Permit No. 0170004-017-AC, Expiration Date 07/01/2014, Crystal River Power Plant BART Project

5. Calculations on Cooling Tower Data: Emissions, Operating Time for Helper cooling towers, modular cooling towers for the years 2004 through 2008, (includes 5b operating data capture) Developed by D. Meyer, Progress Energy

6. Provide the response to Site Audit Needs List A-6 Helper Cooling Towers Graph of Operation for the period 1/1/2007 through 7/19/2009, Prepared by Brandon Barr on 7/20/09

7. Provide the response to Site Audit Needs List A-6, Data regarding operating parameters for the South Cooling Tower (flow and drift rate) (no date)

8. Provide the response to Site Audit Needs List A-2; List of Other Stationary Combustion Sources (Not Covered by CEMS), Reciprocating Internal Combustion Engines (RICE)

(No date)

9. Provide the response to Site Audit Needs List A-3, Maintenance Activities for Emergency Diesel Fueled Equipment (various) prepared by Brandon Barr, 7/18/2009

10. Provide the response to Site Audit Needs List A-3, Maintenance Activities log for Portable Power Independent Pump

11. Provide the response to Site Audit Needs List A-5, Maintenance Activities for Water Chiller CHHE-1A

12. Provide the response to Site Audit Needs List A-5, Air Conditioning Maintenance Log, entries for the period 2/19/2009 through 7/16/2009

13. Provide the response to Site Audit Needs List A-5 HVAC Maintenance Activities, Prepared by Brandon Barr, 7/20/2009

14. Provide the response to Site Audit Needs List A-7, information regarding planned refurbishment of Unit 3, including request to Florida DEP for amendment to Title V permit to accommodate concrete batch plant dated April 7, 2009

15. Provide the response to Site Audit Needs List A-8 regarding permit for south cooling tower; Permit PSD-FL-392

16. Annual Operating Reports for Unit 3 sources for the period 2004-2008, compiled by D. Meyer

17. Reisman, J. and G. Frisbie, Calculating Realistic PM10 Emissions from Cooling Towers, Greystone Environmental Consultants, Paper presented at an unspecified conference, used by Progress Energy to estiamte PM10 emissions for the south cooling tower it the application to amend the Title V permit to accommodate the south cooling tower, submitted to FL DEP on 6/7/07

18. FLDEP permit: Florida Power Corporation dba Progress Energy Floride, Inc. Title V Air Opertion Permit Revision Final permit Number 0170004-015-AV, Effective Date May 29, 2006, Revision Effective Date February 14, 2007, Renewal Application Due Date July 5, 2009

19. South Cooling Tower Permit Application (Golder Associates)

20. FLDEP South Cooling tower Revised Technical Evaluation and Preliminary Determination, Oct 8, 2007

2. AQUATIC ECOLOGY (D. Logan, NRC; W. Vinikour, ANL)

AQ-1 Provide a copy of the responses received from the United States Fish and Wildlife Service (USFWS), National Marine Fisheries Service (NMFS), and Florida Wildlife Conservation (FWC) regarding listed species and sensitive habitats in the area of CR-3 or along the CR-3 associated transmission lines. (ER Section 2.5, page 2-14)

AQ-2 It was mentioned that an environmental evaluation of the extended power uprate would be performed in mid-2009. What is the status of that review and when will documentation of that review be available? (ER Section 2.12.1, page 2-46)

AQ-3 Provide a copy of the following ER Chapter 2 references: FDEP (2002); FNAI (2008a); FNAI (2008c); NMFS (2002); Progress Energy (undated); and SWEC (1985).

AQ-4 How often is dredging conducted in the intake and discharge canals? (ER Section 3.1.2, page 3-3). Please provide a description of the dredging process and the ultimate fate of the dredged materials.

AQ-5 Answered during environmental site audit, no further information is requested.

AQ-6 Provide a copy of any reports that provide information on entrainment and impingement for Unit 1 and Unit 2.

AQ-7 Answered during environmental site audit, no further information is requested.

AQ-8 Describe the method in which the discharge from Units 1 through 3 is used for cooling tower makeup for Units 4 and 5. Also, what is the quantity of makeup required for Units 4 and 5? (ER Section 3.1.2, page 3-4)

AQ-9 Answered during environmental site audit, no further information is requested.

AQ-10 The ER states that the 67 modular cooling towers should allow Units 1 and 2 to operate without reducing power. Has this actually been found to be the case?

(ER Section 3.1.2, page 3-4)

AQ-11 Answered during environmental site audit, no further information is requested.

AQ-12 Provide a copy of the following ER Chapter 3 references: Florida Power (2005);

Golder Associates (2006).

AQ-13 Answered during environmental site audit, no further information is requested.

AQ-14 Provide a copy of the Environmental Protection Agency (EPA) report (or letter) that concluded that entrainment and impingement losses (presented in the 316 Demonstration submitted in 1985) were unacceptable and any follow-up letters between Progress Energy and both State and Federal Agencies regarding 316(a) and 316(b) issues. (ER Section 4.2, page 4-7)

AQ-15 What was the cooling water withdrawal rate prior to those established in the September 1988 National Pollutant Discharge Elimination System (NPDES) permit?

(ER Section 4.2, page 4-7)

AQ-16 Why are data not available for the Mariculture Center more recently than 2004?

(ER Section 4.2, page 4-8)

AQ-17 Provide a copy of the Fact Sheet for the current NPDES permit. (ER Section 4.4, page 4-11) Also, if available, provide figures that show the thermal plume at different times of the year for the Units 1 through 3 discharge (e.g., from the point of discharge to ambient Crystal Bay temperatures). As practicable, areas of various Ts (e.g., every 3 to 5 degrees above ambient) should be provided.

AQ-18 Provide a copy of the following ER Chapter 4 references: FWC (undated); Progress Energy (2004); Progress Energy (2005); all other annual reports pertaining to Mariculture Center [e.g., those prior to Progress Energy (2004) and any prepared following Progress Energy (2005)].

AQ-19 Provide a figure that shows the monitoring point sample locations for the NPDES permit.

AQ-20 Provide a copy of Progress Energys Manatee Protection Plan. (ER Appendix F, page F-9)

AQ-21 Provide information of sea turtle strandings on the trash racks for Units 1 and 2.

AQ-22 Provide a copy of Progress Energys Sea Turtle Rescue and Handling Guidance.

(ER Appendix F, page F-10)

AQ-24 Provide a copy of the PSD permit for the proposed South Cooling Tower that would be constructed and used in association with the CR-3 uprate.

AQ-25 Provide an update on the design and location of the South Cooling Tower.

AQ-26 Answered during environmental site audit, no further information is requested.

AQ-27 Answered during environmental site audit, no further information is requested.

AQ-28 Answered during environmental site audit, no further information is requested.

AQ-29 Answered during environmental site audit, no further information is requested.

AQ-30 Answered during environmental site audit, no further information is requested.

AQ-31 What is the intake channel water velocity?

AQ-32 What is the water velocity across the traveling screens?

AQ-33 Answered during environmental site audit, no further information is requested.

Requested Aquatic Documents - Provide the following references which are cited in the Environmental Report (ER).

ER Chapter 2

1. Department of Environmental Protection, DEP Permit Nos. FL0000159 (Units 1, 2, and 3) and FL0036366 (Units 4 and 5), Citrus County. (FDEP 2002)

2. Florida Natural Areas Inventory, Project: Central Florida, April 17, 2008 (FNAI 2008(a))

3. Florida Natural Areas Inventory, Project: Lake Tarpon, April 17, 2008 (FNAI 2008(c))

4. Article: The Red-Cockaded Woodpecker: Notes on Life History and Management. March 1980. (Hooper, et. al. 1980) Request for Information on Groundwater, July 26, 2006 (Johnson 2006)

5. Progress Energy Crystal River Unit 3 Plant Operating Manual, AI-571, Sea Turtle Rescue and Handling Guidance (Progress Energy undated)

6. Final Report Crystal River 316 Studies, January 15, 1985 (SWEC, 1985)

7. Calculation Package for Population Density and Environmental Justice, included in ER Section 2.6 Regional Demograph, August 17, 2006 (TtNUS 2006)

ER Chapter 3

1. Crystal River Energy Complex Proposal for Information Collection, NPDES Permit No.

FL0000159, (Golden Associates 2006)

ER Chapter 4

1. Crystal River Mariculture Center - Fish and Wildlife Research Institute (FWC undated)

2. Progress Energy Corp. Crystal River Mariculture Center 2003 Annual Report, March 22, 2004 (Progress Energy 2004)

3. Progress Energy Corp. Crystal River Mariculture Center 2004 Annual Report, March 29, 2005 (Progress Energy 2005)

3. ARCHAEOLOGY (J. Davis, NRC; K. Wescott, ANL)

AR-1 Provide a map detailing the level of ground disturbance at the plant, including documentation on how this level of disturbance was determined. Has this understanding of the level of disturbance been coordinated with the Florida State Historic Preservation Officer (FL SHPO)? In other words is the FL SHPO in agreement that these portions of the plant have been disturbed sufficiently as to preclude the possibility of any significant archaeological resources, including burials, existing in these areas?

AR-2 Answered during environmental site audit, no further information is requested.

AR-3 Provide USGS 7.5 minute Quadrangle maps for plant site and transmission lines.

AR-4 Answered during environmental site audit, no further information is requested.

AR-5 Answered during environmental site audit, no further information is requested.

AR-6 Provide a copy of the Environmental Compliance Manual and any other environmental review procedures for land-disturbing activities (e.g., trenching, clearing, digging).

AR-7 Answered during environmental site audit, no further information is requested.

AR-8 Answered during environmental site audit, no further information is requested.

AR-9 Answered during environmental site audit, no further information is requested.

AR-10 Provide the historic and archaeological references presented in the ER, especially survey reports (e.g., Miller 1973).

AR-11 Answered during environmental site audit, no further information is requested.

Requested Archaeology

References:

1. Miller 1973 An Archaeological Survey of the Florida Power Corporation Crystal River Tract, Citrus County, Florida by the Bureau of Historic Sites and Properties, Division of Archives, Historical Records Management, Florida Department of State., June.

2. New South Associates 2006 Cultural Resources Background Research Supporting License Renewal Crystal River Nuclear Plant Citrus and Levy Counties, Florida submitted to Tetra Tech, Aiken, S.C. by New South Associates, St. Augustine, FL, Dec.

3. MacRae 1993 Citrus County Historical Notes by Mary Isabel MacRae, Citrus County Historical Society, Inc, Inverness, FL.

4. ENVIRONMENTAL JUSTICE (J. Rikhoff, NRC; W. Metz, ANL)

EJ -1 In order to address the provisions of Section 4-4, Subsistence Consumption of Fish and Wildlife, in Executive Order 12898, provide the following information:

1. Information about any observed subsistence consumption behavior patternsspecifically fish and wildlife consumptionby minority and low-income populations in the vicinity of CR-3. This subsistence consumption behavior could consist of hunting, fishing, and trapping of game animals and any other general food gathering activities (e.g., collecting nuts, berries, and other plant material) conducted by minority and low-income individuals in the vicinity of CR-3.

2. Information about current or past wildlife sampling and testing of game animals such as deer, squirrel, turkey, pheasant, duck, fish and other game birds and animals that may have been conducted in the vicinity of CR-3. Wildlife sampling and testing may have been conducted before, during, and after plant construction and in the early days of plant operation, but was discontinued after determining that tissue samples consistently showed no significant or measurable radiological impact on the environment from plant operations.

5. HYDROLOGY (D. Beissel, NRC; T. Patton, ANL)

H-1 Provide specific information on groundwater wells (PW-1 through PW-7, and PW-1A/B and any others), including locations, depths, and yields. This information should be detailed in Johnson, R., 2006, Response to Request for Information on Groundwater, email to Jan S. Kozyra (Progress Energy), July 26 (cited in ER Section 2.3).

H-2 Provide permits for all on-site wells (including those that are currently inactive and monitoring wells) and monitoring reports for the past 5 years.

H-3 Provide permits for all surface discharges, including surface impoundments, and monitoring reports for the past 5 years. Include the stormwater management plan, if available.

H-4 Provide the complete NPDES permit (No. FL0000159), including maps showing outfalls, monitoring locations, and other relevant site features. The parts of the permit provided in Appendix B of the ER address some discharge parameter limits, but do not include thermal discharge limits. Latitudes and longitudes of outfall locations are provided, but there are no maps. Theres also no information on intake flow limits.

H-5 Provide discharge monitoring reports submitted to the state as required by the NPDES permit for the past 5 years.

H-6 From the past 5 years, provide any release notifications, violation information (NOVs), or remediation documentation associated with surface water discharges, septic or sewage systems, groundwater or soil contamination (including spills, leaks, and other releases of fuel solvents, or other chemicals).

H-7 Provide any reports on Clean Water Act 316(a) demonstration studies in support of thermal limits set in the NPDES permit (or variances applied for - e.g., has a variance been applied for the increased thermal output associated with the extended power uprate to occur in the fall of 2009?). Please include information (as cited on p.

2-47, line 3, of the ER) regarding how higher discharge temperatures would be mitigated.

H-8 Provide any environmental site assessments conducted onsite since the CR-3 was built.

H-9 Please also provide the following documents cited in the ER:

1. SWEC, 1985, Final Report: Crystal River 316 Studies, prepared for Florida Power Corporation, Jan. 15.

2. Florida Power, 2005, Crystal River Unit 3 Final Safety Analysis Report, Rev. 29, Aug.

Requested Hydrology

References:

Provide the following documents.

1.

Thermal Plan of Study; submitted to the Florida DEP in August 2007.

2.

Tritium Study for CR-3 that describes the tritium monitoring wells (depths, locations etc.).

Also the Groundwater Flow Study (by EnHydrol, LLC 2007) done in support of the Tritium Study.

3.

Stormwater Pollution Prevention Plan (recently revised) and Stormwater Management Plan.

4.

Consumptive Water Use Permit; with Florida SW Water Management District. Also, most recent analytical data on groundwater from the potable wells done for the permit.

5.

Documentation for potable wells (PW1 through PW9) providing completion data (depth, yield, casing depth, etc.) and maps showing location relative to plant; also provide well logs if available (and for process water wells 1A and 1B).

6.

Plans for installation of piezometers near potable wells that will monitor effects to nearby wetlands.

7.

Industrial Wastewater Permit (#FLA016960) for discharges to percolation ponds, filed in 2007. Please also provide completion data and maps for monitoring wells for this program.

8.

Quarterly NPDES, IWW, DWW monitoring reports (for past 5 years) with cover letters to the Florida DEP.

9.

Brief description of the thermal model (and process parameters) used to predict temperatures at the POD station. A simple description is fine (we will not be evaluating the model) - we would like to show how the plant predicts temperatures so it can respond quickly to potential exceedences.

10.

Latest Dredging Permit with Army Corps and letter of permission from the Florida DEP.

11.

Domestic Wastewater Permits for north and south treatment plants. Please also provide completion data and maps for monitoring wells for this program (FLA118753 covers Units 1, 2, and 3; but please also provide the other one).

12.

Any plans related to current outage - in terms of increased water usage and wastewater discharge.

13.

NPDES permit modifications for changes related to the power uprate, new tower discharge and discharge related to the Levy plant (when available); and the application for NPDES renewal to be submitted in Nov. 2009 (when available).

14.

Documentation of the sampling protocols for the NPDES monitoring (would this be in the permit application?) - e.g., descriptions of stratified thermal monitoring.

15.

Incident log sheets reporting spills and other releases for the past 5 years.

16.

Environmental Resource Permits - covering the laydown/staging area for the steam generator construction and other aspects of CR-3 not covered by (i.e., outside of the certified boundary) the Conditions of Site Certification (2008).

6. NON-RADIOLOGICAL WASTE (E. Lenning, NRC)

NRW-1 Provide a description of all non-radioactive (hazardous and non-hazardous) waste streams and applicable procedures at CR-3, including types and quantities.

NRW-2 Provide a description of the CR-3 wastewater streams and onsite sanitary waste treatment facility.

NRW-3 Provide a description of applicable procedures of sludge disposal.

NRW-4 Provide copies of all applicable non-radioactive waste permits.

NRW-5 Provide copies of the Section 312 (TIER II) annual reports to EPA with a list of hazardous and toxic chemicals.

NRW-6 Does CRS-3 produce any low-level mixed wastes?

NRW-7 Provide details of characterization and disposition of used oils generated in relation to the operation of CR-3, including used oil removed from dedicated emergency/back-up engines and oils recovered from HVAC vacuum pumps.

NRW-8 Provide a description of any waste minimization measures used at CR-3. If annual or quarterly recycling reports are available, please provide copies.

NRW-9 Does CR-3 produce any medical wastes? If so, please specify quantity and how the disposal of medical wastes is handled.

7. RADIATION PROTECTION (S. Klementowicz)

RP-1 Provide a description of the radiological groundwater protection program.

RP-2 Provide information on any abnormal, unusual spills or leaks documented in accordance with 10 CFR 50.75(g) and/or any Nuclear Energy Institute Groundwater Protection Initiative reports to State and/or Local government.

RP-3 Provide information on any on-site disposal (10 CFR 20.2002) of radioactive material.

RP-4 Provide a description of plans for the long-term on-site storage of low-level radioactive waste (i.e. B and C Class waste).

8. SOCIOECONOMICS (J. Rikhoff, NRC; W. Metz, ANL)

S-1 Confirm that data for 2005, 2006 and 2007 in ER Table 2-4 labeled, Citrus County Tax Revenues, (the second column) is actually data for Citrus County PROPERTY tax revenues (i.e., versus total tax revenues).

S-2 If available, provide 2008 data on the total property tax revenues in Citrus County, and total property taxes paid by CR-3 in Citrus County (i.e., an update of ER Table 2-4)

S-3 Provide the distribution of CR-3 local property taxes to the various jurisdictions in Citrus County listed in paragraph 2, pages 2-29.

S-4 If available, provide recent information on the total number of CR-3 permanent (employed for more than one year), on-site employees and the residential distribution of permanent, on-site employees by county.

S-5 In addition to property tax payment information presented in Section 2.7 of the ER, describe any other major annual support payments, one-time payments, and other forms of non-tax compensation (if any) provided to local organizations, communities, and jurisdictions (e.g., county, municipality, townships, villages, incorporated places, and school districts) on behalf of CR-3.

S-6 Provide information about any changes in assessed property value or any other recent or anticipated payment adjustments that could result in notable increases or decreases in tax or other payments.

S-7 Provide information on any studies that have quantified, or considered, the impact of noise from CR-3 facilities at various offsite locations.

S-8 Provide data on the height of stacks, cooling towers, and other plant buildings, and the visibility of plant facilities and cooling tower plumes from various off-site locations.

9. TERRESTRIAL ECOLOGY (R. Bulanevitz, NRC; K. LaGory, ANL)

T-1 Provide a map of the CR-3 site that delineates developed areas, previously disturbed areas, and undeveloped terrestrial, wetland, and aquatic habitats (pages 2-11 of the ER). Provide a table or spreadsheet that presents the area covered by each habitat.

T-2 Answered during environmental site audit, no further information is requested.

T-3 Answered during environmental site audit, no further information is requested.

T-4 Answered during environmental site audit, no further information is requested.

T-5 Answered during environmental site audit, no further information is requested.

T-6 Answered during environmental site audit, no further information is requested.

T-7 If available, provide any survey information for threatened and endangered species conducted on the CR-3 site or along associated transmission lines (pages 2-14 of the ER). This will also provide the answer to T-13 and T-22.

T-8 Answered during environmental site audit, no further information is requested.

T-9 Provide information on Florida scrub jay use of transmission lines including a map of the areas that contain potentially suitable habitat and locations where scrub jays have been seen (pages 2-17 of the ER).

T-10 Provide information on wood stork use of the site including a map of the areas used (pages 2-18 of the ER).

T-11 Answered during environmental site audit, no further information is requested.

T-12 Provide information on gopher tortoise use of transmission lines including a map of the areas that contain potentially suitable habitat and locations where tortoises have been seen (pages 2-21 of ER).

T-14 Provide a description of vegetation management procedures for transmission line corridors including procedures for wetland, aquatic, and other sensitive areas; threatened and endangered species locations and habitats (pages 3-5 and 3-6 of the ER).

T-15 Answered during environmental site audit, no further information is requested.

T-16 Answered during environmental site audit, no further information is requested.

T-17 Provide information on the potential effects of cooling tower drift on terrestrial vegetation of the CR-3 site (page A-4). Has deposition of particulates (salt drift) from cooling tower plumes resulted in any damage to vegetation or increased salinity of soils?

T-18 Answered during environmental site audit, no further information is requested.

T-19 Answered during environmental site audit, no further information is requested.

T-20 Provide copies of all correspondence with the USFWS, NMFS, and the state of Florida regarding threatened and endangered species including responses from those agencies if available (Appendix C of the ER).

T-21 Answered during environmental site audit, no further information is requested.