ML101250348

Comments on Draft Generic Environmental Impact, Statement Supplement 41 Regarding License Renewal Application

ML101250348
Person / Time
Site:	Cooper
Issue date:	04/29/2010
From:	O'Grady B Nebraska Public Power District (NPPD)
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
TAC MD9737, TAC MD9763
Download: ML101250348 (63)

Text

N Nebraska Public Power District "Always there when you need us" NLS2010037 April 29, 2010 U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, D.C. 20555-0001

Subject:

Comments on Draft Generic Environmental Impact, Statement Supplement 41 Regarding the Cooper Nuclear Station License Renewal Application Cooper Nuclear Station, Docket No. 50-298, DPR-46

References:

1. Letter from Bo Pham, U.S. Nuclear Regulatory Commission, to Stewart B.

Minahan, Nebraska Public Power District, dated February 18, 2010, "Notice of Availability of the Draft Plant-Specific Supplement 41 to the Generic Environmental Impact Statement for License Renewal of Nuclear Plants Regarding Cooper Nuclear Station, Unit 1 (TAC Nos. MD9763 and MD9737)."

2. Letter from Stewart B. Minahan, Nebraska Public Power District, to U.S.

Nuclear Regulatory Commission, dated September 24, 2008, "License Renewal Application" (NLS2008071).

Dear Sir or Madam:

The purpose of this letter is for the Nebraska Public Power District (NPPD) to provide comments on the draft Generic Environmental Impact Statement (GEIS) Supplement 41 per Reference 1.

This draft GEIS' supplement was prepared in response to NPPDs License Renewal Application (LRA) for Cooper Nuclear Station (Reference 2). The NPPD comments are itemized in . Section 2.1.6 of the draft GEIS supplement had significant number of comments, and so a recommended underline/strikeout revision is provided in Attachment 2. Attachment 3 contains certain changes to the LRA Environmental Report resulting from the review of this draft GEIS supplement.

Should you have any questions regarding this submittal, please contact David Bremer, License Renewal Project Manager, at (402) 825-5673.

COOPER NUCLEAR STATION (P P Box 98 / Brownville, NE 68321-0098 P0.

Telephone: (402) 825-3811 / Fax: (402) 825-5211 vvww.nppd.com

NLS2010037 Page 2 of 2 I declare under penalty of perjury that the foregoing is true and correct.

Executed on (Date)

Sincerely, Brian J. O'G dy Vice President-Nuclear and Chief Nuclear Officer

/wv Attachments cc: Regional Administrator w/ attachments USNRC - Region IV Cooper Project Manager w/ attachments USNRC - NRR Project Directorate IV-I Senior Resident Inspector w/ attachments USNRC - CNS Nebraska Health and Human Services w/ attachments Department of Regulation and Licensure NPG Distribution w/ attachments CNS Records w/ attachments

4 ATTACHMENT 3 LIST OF REGULATORY COMMITMENTS© 4

ATTACHMENT 3 LIST OF REGULATORY COMMITMENTS© Correspondence Number: NLS2010037

-The following table identifies those actions committed to by Nebraska Public Power District (NPPD) in this document. Any other actions discussed in the submittal represent intended or planned actions by NPPD. They are described for information only and are not regulatory commitments. Please notify the Licensing Manager at Cooper Nuclear Station of any questions regarding this document or any associated regulatory commitments.

COMMITMENT COMMITTED DATE COMMITMENT NUMBER OR OUTAGE None 1 4 4-4- 1

+ I 4- I PROCEDURE 0.42 REVISION 24 PAGE 19 OF 26

NLS2010037 Page 1 of 51 Attachment 1 Comments on Draft Generic Environmental Impact Statement Supplement 41 Regarding the Cooper Nuclear Station License Renewal Application Cooper Nuclear Station, Docket No. 50-298, DPR-46

NLS2010037 Page 2 of 51 I GENERAL The draft Supplemental Environmental Impact Statement (DSEIS) uses Change "CNS-1" to "CNS" through draft SEIS.

the acronym "CNS- I" when referring to Cooper Nuclear Station. No other nuclear units have ever been contemplated at the site. Consistent Basis for Change: List of Acronyms in the CNS with other single unit SEISs (e.g., "KPS" (Kewaunee), "WCGS" (Wolf Environmental Report.

Creek), and "JAFNPP" (Fitzpatrick) the acronym "CNS" should be used for Cooper Nuclear Station, without "-1."

2 GENERAL Measurement units are inconsistent. Sometimes metric units are provided in the text and U.S. customary units are provided in parentheses. Sometimes the reverse is presented. Both measurements are not always provided.

Examples:

Page 2-19, lines 19-20: mg/l, but not ppm Page 2-19, line 4:1000 ft., does not have accompanying meters Page 2-20, line 21: 50 miles, but not kilometers 3 GENERAL Punctuation within references in text is inconsistent. Periods, commas, semi-colons, or no punctuation at all are all used for the same purpose/

location within a reference.

Examples:

Page 2-29, lines 45-46: No punctuation within reference Page 2-29, line 18: Same reference, comma used Page 4-15, line 43: Semi-colon within reference 4 GENERAL Inconsistent use of abbreviations/ acronyms, etc.

Example: Page 2-31, lines 29-30: River miles, river mile, and RM are all used within the same sentence. RM has been used previously and should be used from that point forward.

NLS2010037 Page 3 of 51 5 GENERAL Inconsistent application of 'C and 'F. Degree symbol should be immediately after the number. No spaces between number, symbol, or C/F.

Example: Page 2-33, line 15 6 GENERAL Per the Chicago Manual of Style, whenever there are multiple references in a given year from a single author, the series starts with "a." Example, Reference "(NPPD 2008)" should be "(NPPD 2008a)"

on Page 2-82/Line 27; Reference "(NCDC 2009)" should be "(NCDC 2009a)" on Page 2-80/Line 10.

It is recommended that all of the DSEIS Reference Sections be reviewed for this writing style inconsistency and renumbered, with corresponding changes made in the text.

iii/2 Brownville is a village, not a city. Revise to read: "...in the city*illage of Brownville..."

Basis for Change: CNS License Renewal Application Environmental Report (ER) Section 2.1 8 xvii/ 1I References "(May 1996), (NRC 1996)" are not defined. They should either be deleted or a reference section added at the end of the Executive Summary.

9 xix/I0 and 11 It is not clear what the Staff means regarding the absence of "generic Revise to read: "...Category I n'.

ground water issues." water issues."

Basis for Change: A finding on "new and significant information" for ground water use and quality is unrelated to generic ground water issues.

NLS2010037 Attachment I Page 4 of 51 10 xix/30 The statement "...plans to implement others..." regarding impingement Revise to read: "NPPD has implemented some mitigation measures should be clarified with a rejoinder to pending impingement mitigation measures and plans to changes to Section 316(b) of the Clean Water Act. implement others, as necessary for compliance with Section 316(b) of the Clean Water Act."

Basis for Change: Clarification. See Attachment 3, Changes 2, 4, 5, 6, 7, 8, 9, 10, and 11.

11 xx/22 Insert space after "fields." Revise to read: "electromagnetic fields-- acute effects..."

Basis for Change: Typographical correction.

12 xx/38 Incomplete list of Category 2 socioeconomic impacts. Revise to include "public services (education -

refurbishment)."

Basis for Change: NUJREG-1555 Supplement 1 13 xxi/l 8 There should be a space inserted with "...impacts(..." Typographical correction.

14 xxii/24 through 40 The discussion of "Comparison of Alternatives" seems to be missing a summary of the Staff s conclusions regarding the combination alternative. Recommend a summary statement in the Executive Summary as it pertains to the "Comparison of Alternatives."

15 xxii/27 and 28 Insert symbol of mercury and period after mercury. Delete dash. Revise to read: "... and mercury (Hg). The Delete "and" and capitalize "the" to form a new sentence. Otherwise it corresponding..."

is a run-on sentence.

Basis for Change: Grammatical enhancement

NLS2010037 Page 5 of 51 16 xxii/31 The statement "The gas-fired alternative would have slightly lower air Revise to read: "The gas-fired alternative would emissions,..." makes it sound like gas-fired alternative would have have slightly lower air emissions than the coal-lower air emissions than a nuclear plant. fired alternative, .... "

Basis for Change: Verbiage enhancement for clarity 17 xxvi/3 "CWERCLA" should be changed to "CERCLA." Revise to read: "C-WERCLA" Basis for Change: Typographical correction 18 xxix/1 "NDED" is defined as the "Nebraska Department of Education" in the Table of Acronyms. However, "NDED" is defined as the "Nebraska Department of Economic Development" on Page 2-81, Line 17. The Nebraska Department of Education is "NDE," as stated on Page 2-81 Line 26. Recommend the Table of Acronyms be revised and include an "NDE" entry.

19 xxxi/10 Delete "SPDES" and "State Pollutant Discharge Elimination System" since this program is designated as the "NPDES" program in Nebraska.

20 1-1/7 and 8 The sentence reads awkwardly. Revise to read: "The Atomic Energy Act of 1954 (AEA) originally specifiesd that licenses for commercial power reactors be granted for up to 40 years, and permits license renewal."

Basis for Change: Grammatical enhancement 21 1-1/19 After "2014," a reference should be provided to the CNS License Revise to read: "...2014. (NPPD 2008a)"

Renewal Application.

Basis for Change: Referencing enhancement 22 1-2/Figure 1-1 The asterisked statement and block connector lines are difficult to read against the dark background.

NLS2010037 Page 6 of 51 23 1-9 /last row of the The entry:

table first entry "Mr. Ron Asche NPPD 1414 15th Street Columbus, NC 68601" is a duplicate entry from Page 1-8, and is also the wrong address, it is Nebraska, not North Carolina. Recommend deleting this entry.

24 1-10/Table 1-1 General NPDES Permit Expiration Date is incorrect. Revise to clarify that this is the storm water permit and to read: "Expires: 9/17/20-1-2 2002."

(Add footnote that this has been administratively extended by the Nebraska Department of Environmental Quality (NDEQ)).

Basis for Change: NLS2009036 Change 12.

25 1-10/Table 1-1 Hazardous Waste Generator Identification Number is not correct. Revise to read: "NED105507106, 2 NED055071062."

Basis for Change: NLS2009036 Change 12 26 1-10/Table 1-1 Permit Number 0218-26-08-X with the South Carolina Department of Revise to delete the entry for CNS-1 Radioactive Health and Environmental Control is expired and is no longer being Waste Transport Permit.

used.

Basis for Change: NPPD is no longer authorized to ship radwaste under this permit. See Attachment 3, Change 12.

27 1-1 1/Table 1-1 Missing Stormwater NPDES Construction Permit for Independent Revise to include a third line item provided in Spent Fuel Storage Installation construction. NLS2009036, replacement page 9-5.

Basis for Change: NLS2009036 Change 12

NLS2010037 Page 7 of 51 28 1-11/Table 1-1 The Section 404 Permit for dredging at intake s6iucture and discharge of Revise to include a fourth line item provided in dredge material to the Missouri River is missing from the table. NLS2009036, replacement page 9-5.

Basis for Change: NLS2009036 Change 12 29 1-11/Table 1-1 Missing Section 404 Permit for intake structure ice deflectors. Revise to include a fifth line item provided in NLS2009036, replacement page 9-5.

Basis for Change: NLS2009036 Change 12 30 1-11/Table 1-1 Permit Numbers T-NE002-L08 and 0111000042 need to be updated Revise to read:

with latest expiration dates. [T-NE002-L08] "Expires: 12/31/200910"

[0111000042] "Expires: 1/3/200911" Basis for Change: NPPD has received new expiration dates for these permits from the relevant State agencies. See Attachment 3, Changes 13 and 14.

31 Chapter 2 Global The NAS 2002 and National Research Council 2002 are the same document. Change all references to "National Research Council 2002" throughout the chapter to "NAS 2002," and delete National Research Council reference in Section 2.4.

32 2-1/9 Change "including" to "inclusive of the." Grammatical enhancement.

33 2-1/10 This sentence could be read (in light of previous and subsequent Revise to read: [Relocate to the end of Line 12]

sentences) to apply to the Nebraska Public Power District (NPPD) land "Over 99 percent of the total acreage in Nemaha in Nemaha County. County is used for agriculture and farming."

Basis for Change: Clarification

NLS2010037 Page 8 of 51 34 2-1/11-12 These lines mention that 234 acres is leased for agricultural purposes, Revise to read: "A significant portion of NPPD but that is the land that is now subject to the environmental easement property at CNS-1, 234 acres in Missouri and 715 that is mentioned later. For consistency, the text should mention the acres in Nebraska, is currently leased for environmental easement in addition to the use for agricultural purposes. agricultural activities such as farming and raising livestock or conservation purposes."

Basis for Change: Change for consistency 35 2-1/20 The 100m meteorological tower is 328.08 ft, not 328.8 ft. Revise to read: "... and the approximately 328.--

foot tall..."

Basis for change: Clarification 36 2-7/27 A reference should be provided for "40 CFR Part 190" in the Section 2.4 references for consistency with other CFR references provided.

37 2-8/19 "NAC Title 128 was updated in 2004..." This is incorrect, it was Revise to read: "...was updated in 20042007..."

updated August 18, 2007.

Basis for Change: NAC Title 128 was last updated on August 18, 2007.

38 2-8/23 and 24 The sentence "State-level regulators may add wastes to the EPA's list of Revise to read: "States authorized to administer hazardous wastes." should be clarified. the RCRA program may require generators to manage additional wastes, in addition to those hazardous wastes listed by EPA."

Basis for Change: Clarification 39 2-8/24 and 25 The sentence "RCRA provides the standards for the treatment, storage, and disposal of hazardous wastes for hazardous waste generators (regulations are available in 40 CFR Part 262)." is not correct in that 40 CFR 262 only addresses generators, while 40 CFR 264 and 40 CFR 265 address treatment, storage and disposal facilities.

NLS2010037 Page 9 of 51 40 2-8/27 The reference to 40 CFR 260.10 is not correct. It should be "40 CFR Revise to read: "The EPA recognizes three main Part 262." Additionally, add 40 CFR Part 262 to Section 2.4 references. types of the hazardous waste generators (40 CFR 2604710 Part 262) based on the quantity of the hazardous waste produced:..."

Basis for Change: CFR correction 41 2-8/29 Definition of Large Quantity Generators does not match Environmental Revise to read: "... Large Quantity Generators Protection Agency (EPA) definition. (LQGs), that generate more than 2,200 pounds (1,000 kg) per month or-more of hazardous waste...."

Basis for Change: EPA website Glossary of Terms 42 2-8/36 The sentence is missing an initial definite article. Revise to read: Insert "The" before "State..."

Basis for Change: Grammatical correction 43 2-9/36 "(NPPD, 2008)" is an incorrect reference. Revise to read: "(NPPD, 2008 2009c)"

Basis for Change: NLS2009036 Enclosure 5.3 44 2-9/39 The "(EPA, 2009a)" reference appears to be incorrect based on Section Revise to read: "...approaches to pollution 2.4, which shows the EPA 2009c reference addressing waste prevention (EPA,_2009ac)..."

minimization.

Basis for Change: Reference correction 45 2-9/40 and 41 The sentence "The EPA's clearinghouse can be used as a source for Revised to read: "The EPA's clearinghouse can additional opportunities for waste minimization and pollution be used for waste minimization and pollution prevention at CNS-1, as appropriate." makes the implication that NPPD prevention opportunities by RCRA-regulated does not have an effective waste minimization plan. facilities, as appropriate. Note that Cooper already has an effective waste minimization program in place."

Basis for Change: Clarification

NLS2010037 Page 10 of 51 46 2-10/26 Statement that ER notes that four transmission lines are owned and Revise to read: "qThe-NPPD notes in their ER that operated by NPPD is incorrect. four transmission lines, three of which are owned and operated by NPPD, are...

Basis for Change: ER Section 3.2.7.

47 2-10/29 Transmission line "TL301" should be "TL3501." Revise to read: "Two of these numbered lines, NPPD TL3501 and..."

Basis for Change: ER Section 3.2.7 48 2-10/30 The 145 mile transmission corridor length should be 146 miles. Revise to read: "...transmission line corridor extending 14-56 miles (23-,5 km) west-northwest..."

Basis for Change: ER Section 3.2.7, 63.6 + 82.6

= 146.2 49 2-11/1-3 The paragraph as written does not accurately characterize the Omaha Revise to read: "There are several transmission Public Power District lines that connect with the CNS switchyard. lines originating-at that connect with the CNS-1 switchyard that are neither owned nor operated by C-N-4NPPD. These consist of tTwo transmission lines originating at connecting with the CNS-1 switchyard _which are owned by the Omaha Public Power District (OPPD)ý. Another transmission line connecting with one of the OPPD lines, not connected to the CNS switchyard and a thid is owned by Aqu-iaKansas City Power and Light.

Basis for Change: ER Section 3.2.7. Also, Aquila became Kansas City Power and Light on 7/14/2008.

NLS2010037 Page 11 of 51 50 2-11/4 and 5 The discussion regarding the transmission lines that are in the scope of Revise to read: "As these three transmission lines license renewal does not seem to indicate a proper rationale for are not owned or under the control of NPPD and inclusion; i.e., that the lines originally connected the plant to the grid. were not constructed to connect CNS to the Instead, the Staff seems to indicate that the in-scope lines are those transmission system, they are not within the owned or under the control of NPPD. scope of license renewal for CNS- 1 (NPPD, 2008a).

Basis for Change: Refer to ER Page 3-20, Section 3.2.7.

51 2-11/6 and 7 A word search was performed of the ER, and no statement could be Revise to read: "The transmission lines do not found that transmission lines do not cross any Federal, State, or local cross any Federal, State, or local parks NPPP, parks. Only one transmission crosses the United States Fish and 2008). However, the western half of the only one Wildlife Service (USFWS) rainwater basin area. in-scope transmission line corridor traverses counties that..."

Basis for Change: No ER information supports the statement. Clarification on transmission line corrodors.

52 2-11/11 The "(USFWS, 2009h)" reference appears to be inaccurate based on the Section 2.4 references, which shows it being associated with the Salt Creek tiger beetle.

53 2-11/14 There are actually two separate farmers, one on each side of the Revise to read: "On the CNS 1 property, the Missouri River. It is not important to describe the number of farmers. agricultural and is managed by a single farmer under-an agreement with NPPD).

Basis for Change: The statement appears to be irrelevant.

54 2-11/26-27 Misquote of the ER. *Revise to read: "Native grasses and low-lying growing woody plants..."

Basis for Change: "Low-lying woody plants" is not the same as "low growing woody plants."

NLS2010037 Page 12 of 51 55 2-12/1 Incorrect inspection periodicity. Revise to read: "ROW aerial inspections occur bi m.nthl, six times annually, and there is an annual foot patrol inspection."

Basis for Change: Inspections do not occur every two months.

56 2-15/Figure 2.1.6-2 NLS2009036 Change 10 has not been incorporated. Replace: Figure 2.1.6-2 with NLS2009036 Attachment 2, Enclosure Figure 3.2-4.

Basis for Change: NLS2009036 Change 10 57 2-17/34 The "(NPPD, 2008c)" appears to be incorrect based on the Section 2.4 references, since it refers to a 2007 NPPD Annual Report, which does not appear to support this information.

58 2-17/42 "(NHHSS, 2000)" is defined as "Nebraska Department of Health and Human Services" on Line 42. On Page 2-81/Line 39, this reference is defined as "Nebraska Department of Health and Human Services System." Which is correct?

59 2-18/8 For consistency with Page 2-20 (Line 7), change "This water eventually reaches the water table and disperses." to "This water eventually reaches the water table and disperses before likely discharging to the Missouri River."

60 2-18/13-15 The DSEIS states: "Preliminary sampling and analysis results from the Revise to read: "The NRC staff will request that ground water monitoring program for tritium will be submitted and NPPDD submitpPreliminary sampling and summarized in the final SEIS." NPPD has not committed to provide this analysis results from the ground water monitoring information, and believes it is inappropriate to use the DSEIS as the program for tritium will be submiaed and for venue to solicit this action. However, NPPD is willing to provide this summarizedation in the final SEIS."

information following a request from the NRC staff.

Basis for Change: No communication has been received requesting this information.

NLS2010037 Page 13 of 51 61 2-18/29-30 NDEQ Title 117 lists additional beneficial uses for the Missouri River Revise to read: "Beneficial uses of surface water than those provided. identified in the CNS- 1 area are recreational.

aauatic life (Warmwater A) nublic drinkinn water supply, agricultural water supply, industrial water supply, and aesthetics for agricultura and industrial water supply (NDEQ, 2004)."

Basis for Change: Clarification 62 2-18/34 Reference to NPDES Permit NE-000 1244 is not the correct designator. Revise to read: "...Nebraska NPDES permit NE-000l-2-44 NEOOO 1244."

Basis for Change: ER Table 9.2-1 63 2-19/Table 2.1.7-1 Table 2.1.7-1 listed NPDES outfalls from an earlier permit. The present Revise Table 2.1.7-1 to: a) remove Outfalls 002a, NPDES permit for CNS does not have Outfalls 002a, 003, 005, or 006. 003, 005 and 006 from this table since there are Also, the present NPDES permit has pH limits for each of the'remaining no such outfalls listed in the current NPDES outfalls. Limits are Min. 6.5 SU and Max 9.0 SU. Permit, and b) for Outfalls 001, 002b, 002c, 004, 008 and 009, the pH effluent limitation of 6.5 (Minimum) and 9.0 (Maximum) should be added.

Basis for Change: NPPD NPDES Permit No.

NEOOO 1244.

64 2-19/ Table 2.1.7-1 This table should have a reference to NPPD NPDES Permit No.

NEOOO 1244.

65 2-19/Table 2.1.7-1 The "Max. proposed" temperature column should be deleted, as the proposed NPPD NPDES Permit was approved.

66 2-19/6 "Outfall 006" should be "Outfall 001." Revise to read: ",,,through Outfall 0061..."

Basis for Change: NPPD NPDES Permit No.

NEOOO 1244.

NLS2010037 Page 14 of 51 67 2-19/9-17 The outfall description does not match the latest NPPD NPDES Permit Revise to read: Outfalls-002a* 002b is the as issued on June 26, 2007, by the NDEQ. discharge of industrial well ground water bypass, RO reiect, and boiler blowdown.; and Outfall 002c is the discharge of diesel generator, turbine fan heater, boiler room floor drains, and HVAC blowdown discharge water from roof drain sumps outside the poMwe block, fromn clear-well discharge, and H4VAC blowdown, respectively.

Along with the kitake screen backwAash discharged through Outfall 003, utfa -2alls a, h-,

and-e These outfalls discharge to the Missouri River. Outfall 005 discharges batch volumes of sanitary, waste from the sewage lagoon system.

The discharge is sprayed on nearby farm land an1 is not dir-ectly connected to area surface water-bodies.

Basis for Change: NPPD NPDES Permit NE0001244, Expiration Date June 30, 2012 68 2-19/18 Sentence reads awkwardly. Revise to read: "The only NPDES non-compliance reported in the last five years was for total suspended solids..."

Basis for Change: Grammatical enhancement.

69 2-21/1 Referenced Figure should be 2.2.1-1. Revise to read: "...Atchison County, Missouri, see Figure 2.2.1-1."

Basis for Change: Typographical error 70 2-22/9 The cited source for Figure 2.2.1-2 is "(NPPD, 2008a)." This reference is not provided in Section 2.4.

NLS2010037 Page 15 of 51 71 2-23/4-5 Reference "(David J. Wishart, 2004)" is not consistent with citation in Revise to read: ". .. (David j. Wishar, 2004)

Section 2.4. (Wishart 2004)."

Basis for Change: Citation consistency 72 2-23/31-32 Change "@" symbols to "at" (grammatical enhancement).

73 2-24/18-36 Paragraph should be rewritten to state that CNS's potential to emit is Revise to read: "CNS-l has a number of less than the criteria defined in Title V of the United States EPA Clean stationary emission sources, such as three Air Act and in Chapter 5, Title 129 of Nebraska Administrative Code standby emergency power supply diesel for criteria pollutants and hazardous air pollutants (HAPs). The generators, auxiliaries required for safe starting presentation of the emissions in tons should be clarified to more clearly and continuous operation and which are tested identify which pollutant is associated with which value for emissions, periodically to ensure their reliability to perform and the source for the basis of those emissions should be provided as a their intended function, and several petroleum reference. Remove the mention of used oil as it is not relevant to air fuel storage tanks. which do net require the emissions as discussed. facility to sec.ure Title V pe, it. Since CNS's actual annual emissions are less than the criteria defined in Title V of the Clean Air Act and in Chapter 5, Title 129 of Nebraska Administrative Code for criteria pollutants and hazardous air pollutants (HAPs), CNS-1-4s has been granted a low emitter status by the NDEQ Air Quality Section due to the actual quantities of eissions that are r-equi-red to meet eriteria and not to-xced Offesholds for-the emissions of pollutants-defined in Chapter 5, Title 129 of Nebraska Administrative Code: for the emissions of par-ticulate matter PN4 10, car-bon monoxide (GO),

volatile erganie coempounds (VOG), oxides of nitrogen (NOx),, S02 or- S03 or art) comibinato of the two (80x), single H4azar-dous Air-Pollutant (H4AP) or Hazardous Air-Pollutant (H4APs) an Lead. As reported and submitted to NDEQ, aetual total annual emissions from all sources at CNS-l from 2004 to 2008 were 11.52 tons (10.45 MT)

NLS2010037 Page 16 of 51 per--yea, 10.73 tons (9.73 MT) per-yeaf, 13.21 tons (10.73 MT) perye, 11.43 tons (10.37 MT) per-yyar, and 9.85 tons (8.94 MT) pef-year respectively. Highest.emi.sien; Ffrom 2004 to 2008, maximum reported annual emissions occurred were-repeted in 2006 at 13.21 tons (10.73 MT): 0.16 tons (0.15 MT) per--year of PM1O, 2.41 tons (2.19 MT) per-year of CO, 0.22 tons (0.20 MT) per-ye of VOC, 9.0 tons (8.16 MT) per-yea of NOx, 1.41 tons (1.28 MT) per year of Sox, and 0.01 tons (0.009 MT) per-ye of single HAP (NPPD, 2009c). The generaters are tested per-iodically to ensure their- continued abilit)' to perform their-intended ffinction;an there are pr-ocedures in place to ensure-continuous mionitor-ing, sampling, and filtering ot the-oil Used oil is collected for offsite disposal; therefore, no used oil incineration activities occur on the CNS site. Used oil disposal is discussed further- in the w'.aste management section."

Basis for Change: Clarification 74 2-24/24-25 "PM 10," "S02," and "SO3" should all have the numbers as subscript

("PM1 0," "SO 2," and "SO 3"). Grammatical enhancement.

75 2-24/32 "Sox" should be "SOx." Grammatical correction.

76 2-24/38-39 Text suggests that the two monitoring sites are more than the 100-m Revise to read: "These fir-st-monitoring sites tower and the 10-m tower. consist of acmm_

_ates a 328-foot (100-m) primary meteorological tower and a 32.8-foot (10-m) back up tower."

Basis for Change: Clarification

NLS2010037 Page 17 of 51 Comment Pagetnumbier/ Comm No. 'Liiie Ntijiber i:iiiiiii 77 2-24/40 NLS2009036 Change 2 has not been incorporated. Revise to read: "The former is located approximately 31,230 feet (95ý375 m) and the latter..."

Basis for Change: NLS2009036 Change 2 L 4-78 2-24/42-44 NLS2009036 Change 3 has not been incorporated. The text suggests, Relocate text to Page 2-25 (new paragraph after incorrectly, that the second monitoring site is the new 100-rn tower Line 8) and revise to read: "The-second-A new erected to support dry cask storage at CNS. See also Comment 76. monitoring site, a 328-foot (100-m) meteorological tower is being planned for 2010, The design details are incomnlete. but the new tower will meet or exceed the nerformance standards of the existing tower and will be fully compliant with NRC requirements with Buispment and monitorLig system that is neary identical to the original 328 foot (100 m) towýer-,

was recently built approeximately 2,000 feet (1 in) northwest of the first site."

Basis for change: NLS2009036 Change 3 79 2-25/11 Change "fresh water" to "freshwater." Grammatical enhancement.

80 2-25/18 The acronym "CRA" is not defined after its use here (although it is Revise to read: "As part of a hydrogeologic listed in the Table of Acronyms). Some discussion of who "CRA" is investigation undertaken by CNS- 1 for the study would be helpful; e.g., some indication of their expertise. of radioisotopes in ground water, Conestoga Rivers Associates (CRA) (a noted industry vendor in such studies) reviewed..."

Basis for Change: Clarification 81 2-25/38 "Main-stem" should be "mainstem."

2-29/16

NLS2010037 Page 18 of 51

$Suggcc Rso ionui 82 2-26/4 The metric flow rate for 31,000 cfs is missing. Revise to read: "... north of CNS-1, is 31,000 cfs (878 m3/s)."

Basis for Change: Correction 83 2-26/4 and 5 The minimum permitted 3,000 cfs sanitary flow is not correct. The Revised to read: "In December through February, value should be 4,320 cfs per the U.S. Army Corps of Engineers Master the minimum flow permitted is 3.04 4,320 cfs Manual. (85 122 m3 /s), primarily for sanitary water u;i,,

pur-peses."

Basis for Change: U.S. Army Corps of Engineers Master Manual. See Attachment 3, Change 1.

84 2-26/35 Change "...we derive.'.." to "...are derived..." Grammatical enhancement.

85 2-27/12 and 13 Sentence does not read correctly. Revise to read: "The authors presented a conceptual model to illustrate the links between these activities and those for recovery and restoration and of Midwestern river fish communities."

Basis for Change: Grammatical correction 86 2-28/Figure 2.2.5-1 It is not clear what this figure is trying to communicate. Recommend clarification or deletion.

87 2-29/22-23 Appears the terms "lentic" and "lotic" are interchanged. The reservoirs Revise to read: "The reservoirs have changed would cause lentic flow, not lotic. lentielotic (i.e., pertaining to flowing or running water) habitat into lotielentic (i.e., pertaining to still or standing water) habitat..."

Basis for Change: Merriam-Webster Dictionary.

88 2-29/23 Insert comma after "i.e." Grammatical correction.

NLS2010037 Page 19 of 51 89 2-29/30 "Draught" should be "drought." Revise to read: "...as fire, da ._gtdrought flooding,....

Basis for Change: Spelling correction 90 2-33/2 The upstream reservoir produces a lentic environment, not a lotic Revise to read: "...be largely determined by environment, upstream reservoirs, where the lotie lentic environment ... "

Basis for Change: Merriam-Webster Dictionary.

91 2-34/23 "Louis" should be "Lewis." Revise to read: "... included the upstream Louis Lewis and Clark..."

Basis for Change: Grammatical correction 92 2-35/12 "USACE 2003" is not listed in the Section 2.4 references. Add reference to "USACE 2003" to Section 2.4.

93 2-35/26 Sentence reads awkwardly. Revise to read: "Within the main channel..."

Basis for Change: Grammatical correction 94 2-36/4 Insert "are" between "fish near." Grammatical correction.

95 2-36/24 The site acreage differs from the number provided on Page 2-1, line 8. Revise to read: "According to the ER, the CNS-I facilities are located within 55 acres (22 ha) of a 1, 12-1-0-acre (454 ha) site in Nemaha County,...."

Basis for Change: Consistency change

NLS2010037 Page 20 of 51 96 2-36/31 The statement "...cropland on north, south, and east sides..." is not Revise to read: "The CNS property in Missouri is correct. adjacent to the eastern bank of the Missouri River and is bordered by cropland on its neFth, so.uth and-east and timberland on its north and south sides (Figure 2.2.1-1 ) (NPPD, 2008)."

Basis for Change: ER Figure 2.2.1-1 97 2-36/32 An incorrect number of acres is devoted to agricultural acres on the Revise to read: "On the Nebraska side of the Nebraska side of CNS site. CNS-1 site, approximately 900715 acres (464 289 ha) are currently used..."

Basis of Change: CNS ER Section 2.1 98 2-36/37 This line states "...a 55-acre (22ha) wetland mitigation site." The site Revise to read: "...and, according to NPPD staff, does not have a 55-acre wetland mitigation site. It has an a 55-acre (22 ha) wetland area, which includes an approximately 1.5-acre wetland mitigation site on a 55-acre parcel of approximately 1.5-acre mitigation site."

ground' Basis for Change: Letter from L. Peterson (USACE) to B. Shanks (NPPD), July 6, 1995.

99 2-37/24 and 25 There is an improper attribution to the License Renewal Application ER for 40-acre agricultural activity use on the Missouri side of NPPD property. Delete/relocate "NPPD, 2008" reference.

100 2-38/3 The greater prairie chicken is not commonly found in the vicinity of CNS. Recommend that "greater prairie chicken" be deleted, as it is not indigenous.

101 2-39/1 "(Bubo virginianus)" should be in italics.

NLS2010037 Page 21 of 51 102 2-39/1 Incorrect number of bird deaths. Revise to read: "...homed owl (Bubo virginianus),three a number of additional birds, and the death..."

Basis of Change: ER Page 2-52 cites more than three bird deaths.

103 2-39/Table 2.2.7-1 Incorrect spelling of Blue sucker scientific name. Revise Blue sucker entry to read: "Cycleptus 2-48/10 elongateus."

Basis of Change: NatureServe- "Blue sucker."

104 2-40/Table 2.2.7-1 The scientific name of the pallid sturgeon is listed as "Scaphirhyncus Revise Table 2.2.7-1 entry to read:

albus." Page 248/5 calls the pallid sturgeon "Scaphirhynchus albus" "Scaphirhynchus albus."

(emphasis added).

Basis for Change: NatureServe- "Pallid sturgeon."

105 2-41/Table 2.2.7-1 Incorrect spelling of "Western ribbonsnake" (needs space between Revise entry to read: "Western ribbon-snake."

"ribbon" and "snake").

Basis of Change: NatureServe- "Western ribbon snake."

106 2-41/Table 2.2.7-1 Incorrect spelling of Whooping crane scientific name. Revise Whooping crane entry to read: "Grus Americana."

Basis of Change: NatureServe- "Whooping crane."

107 2-41/Table 2.2.7-1 Need to include the "Bald Eagle" since it is listed as threatened in Nebraska and endangered in Missouri.

NLS2010037 Page 22 of 51 108 2-43/Table 2.2.7-1 Incorrect spelling of Salt Creek tiger beetle scientific name. Revise Salt Creek tiger beetle entry to read:

"Cincindela nevadica lincolnaina."

Basis of Change: NatureServe- "Salt Creek tiger beetle."

109 2-43/Table 2.2.7-1 Per reference MDC, 2009c, the American burying beetle should be listed as possibly extirpated as other items are also listed as such.

110 2-43/Table 2.2.7-1 Incorrect spelling of Thimbleweed scientific name. Revise Thimbleweed entry to read: "Anemone cylindrical."

Basis of Change: NatureServe- "Thimbleweed."

111 2-43/Table 2.2.7-1 "Harry Woodmint" should be "Harry woodmint." Revise entry to read: "Harry Wwoodmint."

Basis of Change: Typographical correction.

112 2-44/Table 2.2.7-1 For Buffalo grass, there should be a Habitat description beyond "Possibly extirpated" for consistency with other flora and fauna that are statused as possibly extirpated.

113 2-44/Table 2.2.7-1 The State Status for Toothed ticktrefoil, Glades gayfeather, and Twisted 2-45/Table 2.2.7-1 ladies'-tresses are "S I?" or "S2?" It is unclear what the '?" signifies.

2-47/Table 2.2.7-1 114 2-44/Table 2.2.7-1 The State Status for Bush's sedge, Frank's sedge, Plains frostweed, and 2-45/Table 2.2.7-1 Maryland senna are "S 1S2." It is unclear what this classification 2-46/Table 2.2.7-1 signifies.

115 2-45/Table 2.2.7-1 "Gastrophe olivacea" (Great Plains narrowmouth toad) should in the amphibian section rather than the plant section of the table.

116 2-45/Table 2.2.7-1 "Seaside Heliotrope" should have a lower case "h." Revise to read: "Seaside t4heliotrope."

Basis for Change: NatureServe - "Seaside heliotrope."

NLS2010037 Page 23 of 51 117 2-45/Table 2.2.7-1 For hairy creeping lovegrass, it should be noted in the Habitat column that it is possibly extirpated.

118 2-45/Table 2.2.7-1 The common name for "Nothocalais cuspidate" is "Prairie false Revise to read: "Prairie false dandelion."

dandelion."

Basis for Change: NatureServe - "Prairie false dandelion."

119 2-46/Table 2.2.7-1 "Locoweed" is not a single species of plant. "Oxytropis lambertii var. Revise to read: " LbeeweedStemless point lambertii" corresponds to "Stemless point vetch." vetch."

Basis for Change: NatureServe - "Stemless point vetch."

120 2-46/Table 2.2.7-1 "Panax quinquefolium" should be "Panax quinquefolius." Revise to read: "Panax quinquefoliums."

Basis for Change: NatureServe - "American ginseng."

121 2-46/Table 2.2.7-1 "Pediomelum argophyllum" should be "Silvery scurfpea." Revise to read: "Silvery pseralee scurfpea."

Basis for Change: NatureServe - "Silvery scurfpea."

122 2-48/15 "(Iowa Administrative Code, Chapter 77)" is not included in the Section 2.4 references.

123 2-48/46 Regarding the pallid sturgeon, the statement "The populations are Revise to read: "The populations are believed to largely older fish that will die off in the near future" is too definitive, be mostly lafgely-older fish that m willdie off in the foreseeable near-future."

Basis for Change: Clarification 124 2-50/17 Insert comma after "chlordane." "Chlordane" and "DDT" are two different chemicals.

125 2-50/36 Delete "had." Grammatical enhancement.

NLS2010037 Page 24 of 51 126 2-51/8 Change "200b" to "2003b." Referencing correction.

127 2-51/16 Incorrect scientific name for piping plover. Revise to read: "...piping plover (Charadrius melodius), and the ... "

Basis for Change: NatureServe - "Piping plover."

128 2-51/37 Delete "but" following the comma. Grammatical enhancement.

129 2-51/38-43 These lines should be deleted. The critical habitat for plovers in Nebraska was vacated and remanded for new designation but that has not occurred yet. This discussion is no longer accurate as the USFWS designation of critical habitat has been overturned.

Reference:

Case: 4:03-cv-03059-LES-DLP Document #: 53 Date Filed:

10/13/2005, Case: 4:03-cv-03059-LES-DLP Document #: 54 Date Filed: 10/13/2005 130 2-52/4 and 9 Change "NGPC 2009a" to "NGCP 2009b" to correlate with the Section 2.4 references.

131 2-52/13 and 16 Delete the space between "NYS DEC" to be shown as "NYSDEC" for consistency with Section 2.4 references.

132 2-52/27 Delete the space between "MN DNR" to be shown as "MNDNR."

133 2-52/46 The whooping crane population discussion is no longer accurate, as the Revise to read: "There are currently three-two experimental population of whooping cranes in Idaho is extinct. populations of whooping cranes totaling less than 400 adult and juvenile birds, including one wild population and two one experimental, nonessential populations.

Basis for Change:

http://www.whoopingcrane.com/FLOCKSTATU S.HTM

NLS2010037 Page 25 of 51 134 2-52/35, 38, 41 Change "(NGPC, 2009b)" to "(NGPC, 2009a)" to correlate with the Section 2.4 reference.

135 2-53/7-8 The experimental population of whooping cranes in Idaho is extinct. Revise to read: "One of the two experimental populations breeds in Idahe and overnvinters in L-ah. The second experimental population breeds in Wisconsin and overwinters in Florida and several other southeastern States (NatureServe, 2008a)."

Basis for Change:

http://www.whoopingcrane.com/FLOCKSTATU S.HTM 136 2-53/13 Recommend that the word "significant" be deleted since it implies that there are large populations, which is not the case.

137 2-53/26 The statement that-"... collisions with transmission lines are the main Revise to read: "The USFWS has indicated that 4-42/44-45 cause of whooping crane mortality during their migrations" should be collisions with transmission lines are the main clarified that these are the main known cause of mortality, known cause of whooping crane mortality during their migrations ... "

Basis for Change: It is not known what the main reason is for loss of whooping crane numbers during migratory transit. Therefore, it is appropriate to characterize transmission line collisions as a "known" cause.

138 2-58/1-2 Section 2.4 contains no reference "(NDED and NPPD, 2008a)."

2-59/4 139 2-59/Table 2.2.8.2-1 "City of Nebraska" should be "City of Nebraska City."

140 2-59/10 There is no "(NDE, 2008)" listed in the Section 2.4 references.

NLS2010037 Page 26 of 51 141 2-62/44 There has been no indication that noise levels at CNS have exceeded the Revise to read: "The EPA uses However, noise 2-63/1-2 55 dBA threshold noise level. levels may sometimes exceed the 55 dBA level that the EPA uses as a threshold level to protect against excess noise during outdoor activities (EPA, 1974)."

Basis for Change: There is no data that noise levels at CNS have exceeded the 55 dBA noise level.

142 2-63/Table 2.2.8.5-1 In title "2006" should be "2007."

143 2-63/Table 2.2.8.5-1 Footnote: Reference "(USCB, 2009)" does not exist in Section 2.4.

Reference "University of Nebraska-Lincoln, Nebraska Population Projections (2008)" does not exist in Section 2.4.

144 2-64/Table 2.2.8.5-2 The race percentages do not add up to 100%.

2-65/Table 2.2.8.5-3 145 2-65/Table 2.2.8.5-3 If some other race category has been eliminated from the Census estimate, why is it being included in the table? Consider eliminating the category of "Other Race."

146 2-71/17-18 It is not clear what the nexus is between NPPD's charter to provide Revise to read: "NPPD!s would continue charter electricity to it's customers in Nebraska, and that payments would is to be responsible for provide elecicity to continue regardless of the operation of CNS. customers tfhughout the State, these payments would continue regardless of whether or not the CNS-4--is operating."

Basis for Change: Clarification

NLS2010037 Page 27 of 51 147 2-71/25 The numbers provided for "Nebraska in Lieu of Taxes to Counties With NPPD Retail Electric Sales Attributed to the CNS- 1," "Payments to Retail Communities Attributed to CNS-1," and the Total values do not match what was provided in ER Table 2.7-1. Recommehd revision to conform with ER information.

148 2-71/26 Reference "NPPD, 2008b" is incorrect. Change "NPPD, 2008b" to "NPPD, 2008" to correlate with the reference in Section 2.4.

149 2-73/17 Delete random ")" following "population."

150 2-76/19 and 20 The reference "50 CFR Part 22" is not referenced in the Section 2.0 discussion.

151 2-78/23-28 Hesse, L.W., [et al]. 1982a is not referenced in the Section 2.0 discussion.

152 2-79/15-17 Missouri Conservation Department 2009 is not referenced in the Section 2.0 discussion.

153 2-79/38-41 MDC 2009d" is not referenced in the Section 2.0 discussion.

154 2-80/23-25 NRCS. 2000" is not referenced in the Section 2.0 discussion.

155 2-82/10 Change "2004a" to "2004" to correlate with the reference listing in the Section 2.0 discussion.

156 2-82/12 Change "2005a" to "2005" to correlate with the reference listing in the Section 2.0 discussion.

157 2-82/24-26 NPPD 2007c is not referenced in the Section 2.0 discussion.

158 2-82/35-37 NPPD 2008d is not referenced in the Section 2.0 discussion.

159 2-82/42-43 NPPD 2009b is not referenced in the Section 2.0 discussion.

160 2-83/9 Insert "2009a" after "(NGPC)" to correlate with the reference listing in the Section 2.0 discussion.

• NLS2010037 Attachment 1 Page 28 of 51 161 2-84/27-30 USCB 2009b is not referenced in the Section 2.0 discussion.

162 2-85/34-37 USFWS 2008c is not referenced in the Section 2.0 discussion.

163 2-86/5 and 6 USFWS 2009d is not referenced in the Section 2.0 discussion.

164 2-86/7-11 USFWS 2009e is not referenced in the Section 2.0 discussion.

165 2-86/12-15 USFWS 2009f is not referenced in the Section 2.0 discussion.

166 3-4/3-5 Need to separate 10 CFR 54 as a stand alone reference.

167 3-4/10-12 NRC 1999 is not referenced in the Section 3.0 discussion.

168 4-1/14 For consistency, "10 CFR Part 51" should be listed in the Section 4.12 references.

169 4-2/13 Insert a "period" after "(gpm)."

170 4-5/22 Delete "the" before "Section 316(a). " Grammatical enhancement.

171 4-5/15 and 16 Delete the duplicated phrase "...for minimizing adverse environmental impact."

172 4-5/35 On line 35, the NRC appears to be calculating a fish impingement value for the year 1974, not 1978. Please verify.

173 4-5/39 Recommend the use of the word "reasonable" over "useful."

NLS2010037 Page 29 of 51 174 4-6/9 The Staff indicates that NPPD has committed to change out the fish Revise to read: "CNS- 1 has not yet completed the screens during the 2011 refueling outage, as opposed to the more fish protection system. and plans to install, during general characterization of during the initial operating term. This a 2011 refteling outage, The intention is to install should be clarified to be consistent with the discussion suggested in a fish handling and return system to mitigate fish Attachment 2 for Page 2-13/Lines 26-31. impingement censisting of inside and outside spraysl' tol' wash.. fi-s-,h f theN KTDDTn sern an -

separate fish return trougJh (NPPD, 2008, pgs 4 11). The plant's seraffee water- sstem ,oetuld supply water- for the spray wash. The new screens, fish handling system, and fish r-eturn troufch nrifnar-ilv affect imoinLaement but not entfainment. CNS implementation date and the final design of the fish handling system are dependent upon the content of the final 316(b)

Clean Water Act requirements."

Basis for Change: Clarification. See Attachment 3, Changes 2, 4, 5, 6, 7, 8, 9, 10, and 11.

175 4-6/39 The "(EPA, 2009)" reference should be changed to "(EPA, 2009b)"

based on the Section 4.12 references.

176 4-7/1-6 The NRC states the following:

"The NRC staff examined the question of how the age of the data might affect the conclusions regarding entrainment and impingement at CNS-

1. The NRC staff found that the argument used in the NPPD's ER is inconsistent because it assumed at different points that the aquatic resources are both stable and unstable, although in fact they cannot be both. In describing the aquatic resources, the ER stated that fish communities have long been responding to changes in the river brought on by man's activities."

These statements should be deleted. The CNS ER does not present an argument that aquatic species are stable or unstable. NPPD's evaluation

NLS2010037 Page 30 of 51 of the aquatic resources in the vicinity of CNS did not assume or conclude that the aquatic resources were stable. In fact, the available studies of Missouri River communities indicate little historic information is available related to the aquatic communities in the Missouri River prior to its damming and channelization. There have, however, been numerous studies that conclude alterations of the river flows and channel may have had significant impact on the communities that may have once existed. NPPD's ER made several statements that some species may be in decline while others may be aggressively and invasively increasing (e.g., Asian carp). NPPD's ER discusses at length the anthropogenic factors that have and continue to affect the aquatic resources. These anthropogenic factors, however, are unrelated to the operation of CNS or other power plants on the Missouri River.

177 4-7/30 and 31 The "EPA (2009)" reference should be changed to "EPA (2009b)"

based on the Section 4.12 references.

178 4-7/45 The "(Berry et al.)" reference is not listed in the Section 4.12 references.

179 4-8/15-16 Delete extra closing parentheses in two locations.

180 4-8/38-40 NPPD's plans for installing a fish handling system should indicate that Revise to read: "...and NPPD plans to install a the final design is dependent on the content of the final 316(b) fish handling and return system consisting ef regulations. inside and outside spr.ays to wash fish fr*m*hm screens and a separate fish r-eturn trough to mitigate ad..er.se efects of impingement whose final design is dependent upon the content of the final 316(b) Clean Water Act requirements ... "

Basis for Change: Clarification. See Attachment 3, Changes 2, 4, 5, 6, 7, 8, 9, 10, and 11.

181 4-8/40 Replace "NDEC" with "NDEQ."

NLS2010037 Page 31 of 51 182 4-10/45-46 The design of the fish handling system is contingent on content of the Revise to read: "Whatever the total effects of final 316(b) regulations. CNS- 1 on the fish community were in the past, the installation of the modified dual-flow traveling screens in 2006 and future installation of a fish handling and return svstemlow-pressure screen wash and fish return t.ough (dependent upon the final design and implementation of the final 316(b) Clean Water Act requirements) would mitigate those impacts ....."

Basis for Change: Clarification. See Attachment 3, Changes 2, 4, 5, 6, 7, 8, 9, 10, and 11.

183 4-11 /Table 4-4 Table 4-4 is not in the Table of Contents.

184 4-12/10 and 17 As noted in Section 2.0, the number of acres owned by NPPD on the Missouri side of the river is 239 acres, not 230 acres. This entire parcel was offered for a conservation easement. The acreage values should be revised.

185 4-12/21 and 22 The conservation agreement discussions should be updated. Revise to read: "At the time of writing thisSEIS The deed restriction for conservation has been placed upon the 239 acres that NPPD owns on the Missouri side of the river, and the MOU including conditions regarding the additional payment of $250,000, has been finalized and signed by the parties in-voled-pai4ies...e discussing details of the conser.'ation agreement."'

Basis for Change: Status update 186 4-12/31 The "Hrabik et al. (2007)" reference is not listed in the Section 4.12 references.

187 4-13/3 Change "section" to "Section." Grammatical correction.

NLS2010037 Page 32 of 51 188 4-13/25-33 It is not necessary for the NRC to solicit a commitment for NPPD to Revise to read: "The staff requests that NPPD report the existence of endangered or threatened species via the draft r-'nnrt the ex~istence of any Feder-alk' lis~ted or-4 A A 14- + I SEIS. Reporting is conducted in accordance with State and Federal Qfý 1; +

regulations. within the CNS 1 site Or near the transmission line eiorideo- to NGPC, ND*C, and the USFWS, it any such speries are identified during the license renewal term. in addition, the NPPD is raequi to promptly repoet to the apprfproiate wildlife management agencies and to NRC, any evidence of injury5 to, or-mortality' of-, migratory birds OF treatened or-endangered species obsenred within the tfansmission line corridor, especially iatjud to, or mortalit' of-, Feder-ally listed whooping oranes, interior leasthreatened ing ploaerse along the Platte River- in-ear-thewest-ern limfit Of CNS 1 transmission line NPPD) TL3 502, near-Grandisland, NEAll of NPPD operations, including those necessary for transmission line maintenance and operation, are conducted in accordance with NPPD policies and procedures that require special precautions related to operations involving threatened and endangered species and avian protection [NPPD 2007a:

NPPD 2007b]."

Basis for Change: ER Page 4-47, Section 4.10.5 189 4-13/4041 The status of the bird diverters should be updated. Revise to read: "The-NPPD is-also has coordinateding with USFWS staff and has to installed bird diverters on transmission line NPPD TL3502 where it traverses the Platte River."

Basis for Change: Status update.

NLS2010037 Page 33 of 51 190 4-15/32 Insert space after "0.0031."

191 4-16/21-22 The verbiage needs to be revised to more accurately reflect the Revise to read: "The effects of thermophilic applicability of the issue since CNS is not a closed-cycle plant. microbiological organisms on human health, listed in Table B-I of Appendix to Subpart A of 10 CFR Part 51, are categorized as a Category 2 issue and require plant-specific evaluation during license renewal process for the plants located on the a small river, that use clesed cycle oeeling."

Basis for Change: 10 CFR 51.53(c)(3)(ii)(G) 192. 4-16/24 "3.15x 1012 ft3/year (9x 1010 m3/year)" should be revised as follows:

"3.15x 1012 ft3/year (9x 1010 m3/year)"

193 4-19/Table 4-7 Recommend that NRC confirm the subject matter of Table 4-7, as it appears to be nearly identical to Table 4.6. Should Table 4-7 cover Category 2 socioeconomic issues?

194 4-20/8 Delete the period following "proximity."

195 4-22/19 Add a space after the comma as follows "...history, (2)..."

196 4-23/8 Extra "(" at end of the line.

197 4-23/15 There is no "pending research" anticipated for historic archeological Revise to read: "All surface structures associated sites in the vicinity of CNS. with the earlier house sites have been demolished; however, remnants of these buildings remain as historic archaeological sites and could be eligible for inclusion to the NRHP under Criteria A and D pending fur.her researchb."

Basis for Change: Clarification 198 4-23/32 The "(Gibbon and Ames, 1998)" reference is not listed in the Section 4.12 references.

NLS2010037 Page 34 of 51 199 4-23/34 The "(NSHS, 1937)" reference is not listed in the Section 4.12 references.

4 .4-200 4-24/22-30 NPPD has procedural administrative controls in place to ensure that Revise to read: "N-PPD could further reduce cultural resource reviews are conducted prior to engaging in potential impacts to histor-ic and arcehaeological construction or operational activities in previously undisturbed areas resources located at the CNS 1 by training NPPD that may result in a potential impact to cultural resources at the site staff in the Section 106 consultation processan

[NPPD, 2007c]. Areas depicted in Phase IA Literature Review and eultural awareness training to ensure tha Archeological Sensitivity Assessment were identified as higher info~med decisions are made prior to any groGund probability archeological site areas on the CNS Owner Controlled Area. disturbing activities. in addition, NPPD could However, NPPD has developed a Cultural Resources Protection Plan in also forwvard its Cultural Resources Protection an effort to meet state and federal expectations and includes measures Plian to the fwsmii and the mvissourt Nrruitor for archeological investigations (Phase IB) and consultations with the r-eview and comment. This will ensure tha Nebraska and Missouri State Historic Preservation Offices (SHPO), and hist~ric and archaeological resoreac the appropriate Native American groups prior to any future ground pr~otected at the CNS !.site. Any revisions to the disturbing activities [CNS, 20081. These measures provide adequate Cultur-al Resources Protection Plan should be protection for potential area cultural resources. developed in consultation with the NRCG, NSHS, and Missouri SHPO. in addition, lands not sur.eyed should be investiated-b a qualified a~rchaeologist prior to an), ground disturbing aetiviby. NPPD should continue to fulfill all site, state, federal, and NEPA requirements regarding future land disturbances on-site."

Basis for Change: It is not necessary for the DSEIS to make recommendations on actions NPPD could take to further reduce the SMALL impacts on historic and archaeological resources at CNS.

201 4-26/16 The "(USCB, 2009)" reference is not listed in the Section 4.12 references.

202 4-26/17 There is a big space at the end of this line that should be filled with text

- check the carriage return.

NLS2010037 Attachment 1 Page 35 of 51 203 4-27/3 The "(USCB, 2008)" reference is not listed in the Section 4.12 I 4-28/3 references.

4-29/7 4-30/3 4-31/3 204 4-29/11 The "(USCB, 2009)" reference is not listed in the Section 4.12 references.

205 4-33/14 Change "Thorium" to "Naturally occurring thorium" to indicate that it's Revise to read: "Naturally occurring Thorium-not plant-related. 228 was measured in one sample."

Basis for Change: Clarification 206 4-33/23 Sentence does not read correctly. Revise to read: "There were 26 broadleaf vegetation samples w-e-collected from June through September.."

Basis for Change: Grammatical correction 207 4-33/37 Change "10 CFR Part 72" to "10 CFR Part 50" since CNS has not yet Revise to read: "The REMP continues to implemented a General License under Part 72. demonstrate that the dose to a member of the public from the operation of CNS4 remains significantly below the Federally required dose limits specified in 10 CFR Part 20, 10 CFR Part 5072, and 40 CFR Part 190."

Basis for Change: CNS has a Part 50 license, but not a General License under Part 72.

NLS2010037 Page 36 of 51 208 4-33/39 "Soils" are not monitored. Revise to read: "Based on recent monitoring results, concentrations of contaminants in native leafy vegetation, soils-and sediments, surface water, and fish in areas surrounding CNS-1 have been quite low (at or near the threshold of detection) and seldom above background levels."

Basis for Change: CNS Offsite Dose Assessment Manual 209 4-34/18 The "(NRC, 2000)" reference is not listed in the Section 4.12 references.

210 4-36/3 The "(USGCRP, 2009)" reference is not listed in the Section 4.12 4-44/21 references.

211 4-36/5 "(14 'C)" should be "(3.3°C)."

"(12 'C)" should be "(5.6°C)."

212 4-37\36-39 This section states:

"The impact of introduction and stocking of native and introduced fish species is also somewhat similar to the impact of CNS-1, because the effect of a power plant that impinges and entrains aquatic organisms is somewhat similar to that of a large predator introduced into an aquatic system."

This appears to be subjective and is not substantiated. Recommend deletion.

213 4-38/1 Recommend clarification as to which states are being referred to.

214 4-38/4 The "Nelson-Stastny (2004)" reference is not listed in the Section 4.12 4-40/Table 4-9 references.

NLS2010037.

Page 37 of 51 215 4-38/22-25 The characterization of the Missouri River aquatic ecosystem being Revise to read: "While the level of impact due to 4-47/Table 4-10 potentially past the point of reparable change is not adequately justified. direct and indirect impacts of CNS- 1 on aquatic communities is SMALL, the cumulative impact when cembined with of all other sources of impact has resulted in the Missouri River aquatic ecosystem being unstable and has resulted in a de. This condition meets NRl's de-fi-nition of a LARGE level of impact."

Basis for Change: Clarification 216 4-40/Table 4-9 Why is this table titled "Stastny 2004?" No other tables have titles from the reference name.

217 4-41/2, 13, and 20 The "(NGPC, 2005)" reference is not listed in the Section 4.12 references.

218 4-41/27-29 The acreages listed do not match the values provided in ER Section 2.1. Revise to read: "Approximately 900 acres (364 hectares) of the 1,120-1-acre (4534 hectare) CNS-1 site is used for agriculture (NPPD, 2008). Much of the 5590-acres (22-36 hectares) of land where the CNS-1 facilities have been constructed was cropland prior to construction of the facility, so disturbance to wildlife habitat had occurred prior to construction of CNS- 1."

Basis for Change: CNS Environmental Report, Section 2.1.

NLS2010037 Page 38 of 51 219 4-41/34 -36 The site does not have a 55-acre mitigation site, it has an approximately Revised to read: "NPPD was recently required by 1.5-acre mitigation site on 55-acre parcel of ground. the USACE to restore approximately 1.5 5-5-acres (Q.62-2 hectares) of disturbed wetlands habitat onsite on a 55-acre (22-hectacre) parcel of ground as mitigation for NPPD filling in other disturbed wetlands for construction of CNS-1 parking facilities.

Basis for Change: Letter from L. Peterson (USACE) to B. Shanks (NPPD), July 6, 1995.

220 4-41/47 The "(NDNR, 2009)" reference is not listed in the Section 4.12 references.

221 4-42/9-13 This discussion should be updated based on the recently reached Revised to read: "Based upon discussions with wetland agreement. NPPD staff during the environmental site audit-,

NPPD is currently coor-dinaing with Federal and State r-esourcee agencies to place this Missour-i land into a consefvation easement, which mnay lead to long term pr-otection of this land from any development as well as removal of the 10 acres of cropland 4fro agr-icultural production. A conservation deed restriction has been placed upon the 239 acres of land located on the Missouri side of the river to provide for long-term protection of this land from any development as well as agricultural production.

Basis for Change: Clarification 222 4-42/18 The "(NCRS), 2007" reference is not listed in the Section 4.12 references.

223 4-42/25 The "(NGPC, 2005)" reference is not listed in the Section 4.12 references.

NLS2010037 Page 39 of 51 224 4-43/3 "(NPPD, 2009)" appears to be an incorrect reference since it does not correlate with the Section 4.12 NPPD references.

225 4-43/30-35 The NRC concluded that the cumulative impacts on terrestrial resources would be MODERATE. However, the information presented in Section 4.11.4 makes it unclear how that conclusion was reached. Additional justification should be provided.

226 4-43/33-35 It is recommended that this section be revised for consistency with the Revise to read: "...however, the cumulative language utilized on Page 4-38 of the DSEIS regarding aquatic impacts. impats on terrest.ial resources resulting from a 34 past, present, and reasonably foreseeable future actions, inlcuding non CNS 1 activities, while the level of impact due to direct and indirect impacts of CNS on terrestrial communities is SMALL, the cumulative impact when combined with all other sources, even if CNS was excluded, cwould be moderate."

Basis for Change: Clarification 227 4-43/35 Moderate should be in all capital letters.

228 4-44/1 Delete "the" before 34. Grammatical enhancement.

229 4-44/21 and 22 "(14 'C)" should be "(3.3TC)"

"(12 °C) should be "(5.6 0C)"

230 4-44/34-38 This sentence appears to be out of place for this air quality discussion:

"As discussed in Nonradioactive Waste Management Section 2.1.3, NPPD is committed to the EPA's Reduce, Reuse, Recycle program at its major and minor facilities, with a growing Green Team, that focuses on pollution prevention, waste minimization, education and training of the personnel, and incorporates EPA recommendations on the national implementation of the climate change energy conservation techniques (EPA, 2009a)."

NLS2010037 Page 40 of 51 231 4-44/4245 In Comment 73, a significant rewording was suggested for Section 4-45/1-10 2.2.2.1. If these changes are accepted by the NRC, conforming changes to-Page 4-44/42-45 and Page 4-45/1-10 are necessary.

232 4-44/45 Insert "(CO)" after carbon monoxide. Grammatical enhancement.

233 4-45/2 A cross-reference is made to Air Quality Impacts in Section 2.2.2.2.

This should be Section 2.2.2.1.

234 4-45/13. Delete the second "The staff concludes." It is repeated.

235 Page 4-45/16-20 It is not clear why a discussion of alternatives is made in this cumulative impacts assessment. The National Environmental Protection Act requires the cumulative impact conclusions be based on known and foreseeable actions, not hypothetical alternatives. Recommend deletion.

236 4-46/13 and 14 NPPD has made no commitments to initiate further consultations with the NRC and SHPO should plans change for future land-disturbing activities. NPPD procedures stipulate when outside agency consultations should be initiated. Accordingly, the statement: "Should plans change, further consultation would be initiated by NPPD with the NRC and SHPO." should be deleted.

237 4-46/19-21 It is unclear if the NRC is describing the potential cumulative impacts of CNS operation alone, or the cumulative impacts of CNS operation combined with other Federal or non-Federal actions (ref. Council on Environmental Quality implementation of 40 CFR 1508.7).

If describing CNS operation alone, the text should be: "...resulting from.

CNS- 1 operation alone during the period of extended operation would be SMALL. to MODERATE" based on the Staffs conclusions in Sections 4.1 through 4.9.

If describing CNS operation with other non-CNS actions, the text should read: "... resulting from CNS-1 operation combined with these other actions during the period of extended operation would be SMALL

NLS2010037 Page 41 of 51 to MODERA-TE LARGE" due to the previous aquatic determination of a LARGE impact in Section 4.11.3.

238 4-47/Table 4-10 It is unclear what NPPD's commitment to "the EPA's Reduce, Reuse, Air Quality Recycle program at its major andminor facilities, with a growing Green Team, that focuses on pollution prevention, waste minimization, education and training of personnel..." relates to air quality.

Recommend deletion.

239 4-48/6 and 7 10 CFR Part 54 is not referenced in the Section 4.0 discussion.

240 4-48/8 and 9 36 CFR Part 60 is not referenced in the Section 4.0 discussion.

241 4-49/5-7 AEC 1972 is not referenced in the Section 4.0 discussion.

242 4-50/12-15 EPA 2009b is not referenced in the Section 4.0 discussion.

243 4-50/4246 MDC 2009a is not referenced in the Section 4.0 discussion.

244 4-51/9-11 NEIHS 1999 is not referenced in the Section 4.0 discussion.

245 4-51/12 and 13 Change "2009a" to "2009" so that the reference will correlate with how it's listed in the Section 4.0 discussion.

246 4-51/17-19 NDEQ 2008 is not referenced in the Section 4.0 discussion.

247 4-51/20 and 21 NDEQ 2009 is not referenced in the Section 4.0 discussion.

248 4-51/22-24 NIEHS 1999 is not referenced in the Section 4.0 discussion.

249 4-52/6-9 NPPD 2008a is not referenced in the Section 4.0 discussion.

250 4-52/10 and 11 NPPD 2008b is not referenced in the Section 4.0 discussion.

251 4-52/12-14 NPPD 2008c is not referenced in the Section 4.0 discussion.

252 4-53/16-20 NRC 1999 is not referenced in the Section 4.0 discussion.

NLS2010037 Page 42 of 51 253 4-54/8-10 USAEC 1973 is not referenced in the Section 4.0 discussion.

254 4-54/24-27 Delete the "USFWS 2009a" reference since it is already listed on Lines 20-23.

255 4-54/42-44 WHO 2007a is not referenced in the Section 4.0 discussion.

256 5-3/2 Replace verb "requires" with "require" to agree with subject, "Regulations."

257 5-3/9 Incomplete sentence and misspelled word. Revise to read: "of severe accident mitigation alternatives..."

Basis for Change: Grammatical correction 258 5-3/11-12 Incorrect corporate name. Revise to read: "... conducted by the Nebraska Public Power DistrictNPPD Energy -C*..n.,

LG (NPPD)..."

Basis for Change: Correction 259 5-3/27-33 Section states, "NPPD identified 33 potential SAMAs for CNS-1. Revise to read: "NPPD identified 3 244 NPPD performed an initial screening to determine if any SAMAs could potential SAMAs for CNS- 1. NPPD performed be eliminated because they are not applicable to CNS-1 due to design an initial screening to determine if any SAMAs differences, or have estimated implementation costs that would exceed could be eliminated because they are not the dollar-value associated with completely eliminating all severe applicable to CNS-1 due to design differences, of accident risk at CNS- 1. No SAMAs were eliminated based on this because they have estimated implementation screening, leaving all 33 for further evaluation." oosts that would exceed the dollar value assocsiated with coompletely eliminating all sever-e This is not consistent with the information provided in Section E.2 of aeeident risk already been implemented at CNS-the ER, with the summary in DSEIS Section 5.3.3 (page 5-5), or with 1, or because they are addressed by another DSEIS Appendix F (Section F.3.1, page F-13). In fact, 244 potential SAMA candidate. No 164 SAMAs were Severe Accident Mitigation Alternatives (SAMA) were identified for eliminated based on this screening, leaving all 3 CNS. The dollar-value of completely eliminating severe accident risk 80 for further evaluation."

was not used in the screening phase, and 80 SAMAs were left for further evaluation. Basis for Change: Clarification

NLS2010037 Page 43 of 51 260 5-5/8-10 Section states, "Accordingly, the staff based its assessment of offsite Revise to read: "Accordingly, the staff based its risk on the CDFs and offsite doses reported by NPPD in their December assessment of offsite risk on the CDFs and offsite 2009 letter (NPPD, 2009b)." doses reported by NPPD in their December 2009 kette LRA Environmental Report (NPPD, It appears that the Staff actually based its assessment of the offsite risk 20089b)."

on the Core Damage Frequencies and offsite doses reported by NPPD in the ER (NPPD, 2008). The December 2009 letter merely indicates that Basis for Change: Clarification the ER results are conservative compared to the results that would have been obtained using corrected meteorological data.

261 5-7/25-28 Section states, "NRC staff reviewed NPPD's re-analysis as submitted by NPPD and agrees that the error was conservative relative to the average population dose and offsite economic cost and that no SAMAs were inappropriately excluded from consideration in the LRA as a result of the error."

This paragraph is not clear as a stand-alone paragraph. Suggest moving this paragraph to Section 5.3.2, page 5-4, following lines 11-17.

262 5-8/4 Insert an open parenthesis "(" at the beginning of the line, prior to "e.g."

Also, recommend changing "e.g." to "i.e." since this statement appears to be paraphrasing for clarity of meaning rather than providing an example of managing the effects of aging.

263 5-8/14 and 15 10 CFR Part 100 is not referenced in the Section 5.0 discussion.

264 5-8/16-22 The NPPD 1993 (ML073600192 and M1L073600193) references were not found in ADAMS search.

265 5-8/30 NPPD 2009 reference should be ML091880319 (delete trailing 3).

266 5-8/40 and 41 Add, "September 2004" at the end of the reference for consistency with same reference on page F-39 (line 25).

NLS2010037 Page 44 of 51 267 6-3/1 Change "lifecycle" to "life cycle."

6-4/2, 15, 16, 19, 26 and 28 6-5/9 and 15 268 6-3/24 "(Keepin, 1988; Hagen et al., 2001; and MIT, 2003)" are not listed in the Section 6.3 references.

269 6-5/Table 6-2. The POST (2006) line of data contains an arrow after coal. There is nothing like it elsewhere so it appears it should be deleted.

270 6-5/Table 6-2 "POST (2006)" is not listed in the Section 6.3 references.

6-6/Table 6-3 6-7/Table 6-4 271 6-9/8 and 9 10 CFR Part 63 is not referenced in the Section 6.0 discussion.

272 6-9/10-12 40 CFR Part 191 is not referenced in the Section 6.0 discussion.

273 7-2/24-26 NPPD 2008 is not referenced in the Section 7.0 discussion.

274 8-2/Box The "EIA 2009a" reference appears to be inaccurate based on the Section 8.7 references. Based on Section 8.7, it appears that it should be "EIA 2009."

275 8-4/8 There is no "(NPPD, 2008)" in the Section 8.7 references.

8-6/22 and 23 8-10/12 and 25 8-17/21 8-18/8, 38 and 39 8-19/8 8-23/18 and 21 8-24/39 8-31/5 and 27 8-35/4

NLS2010037 Page 45 of 51 276 8-4/20 and 21 Since the DSEIS had not previously discussed coal ash and scrubber Revise to read: "As noted above, much of tThe sludge being recycled, the following sentence is incorrect: "As noted coal ash and scrubber sludge (about 38,300 tons above, much of the coal ash and scrubber sludge (about 38,300 tons (34,800 MT)) could be recycled."

(34,800 MT)) could be recycled."

Basis for Change: Correction 277 8-4/40 Change "(EPA, 2008a)" to "(EPA, 2008)" to correlate with the Section 8.7 reference.

278 8-5/19-24 The Table of Acronyms identify "MT" as "metric tonnes." This section spells it "metric tones." Recommend replacing with "MT."

Grammatical correction.

279 8-5/22-23 The numbers after PM should be subscript in two locations.

8-6/28 280 8-6/15 The citation "40 CFR 60.44Da(l)" should be "40 CFR 60.44Da(a)(1)."

281 8-6/24 Insert space after "SO 2."

282 8-13/17 Change "driveshaft" to "drive shaft."

283 8-15/3 PM10 should be PM 10.

284 8-15/17 and 18 The statement that "there is no required reporting of GHG emissions in Nebraska" is inaccurate. EPA finalized the mandatory reporting of greenhouse gases rule which was effective January 1, 2010. This sentence should be deleted.

285 8-16/16 Delete extra parentheses after "2 m3/s.",

286 8-20/13 Large space at the end of line needs to be corrected.

NLS2010037 Page 46 of 51 287 Page 8-21/10-17 It does not appear to be reasonable to conclude that 250 MWe of CNS baseload generation can be replaced by conservation. The Staff claims that this is supported by the state's energy efficiency goals, but this does not seem realistic. Request NRC verify and provide reference of the source of the Nebraska energy efficiency goals.

288 8-21/14 Change "is" to "would be." Grammatical enhancement.

289 8-21/22 Change "will" to "would." Grammatical enhancement.

290 8-22/2 Delete the "s" after "require."

291 8-22/28 Insert ")" after Congress.

292. 8-31/7 There is no "(Nucleonics Week, 2008)" in the Section 8.7 references.

293 8-32/4 There is no "(NREL, 2008)" in the Section 8.7 references.

294 8-32/23 There is no "(ORNL, 2007)" in the Section 8.7 references.

295 8-33/24 There is no "(Integrated Waste Services Association, 2007)" in the Section 8.7 references.

296 840/4-6 ACAA, 2007 is not referenced in the Section 8.0 discussion.

297 8-40/34 Change "2000a" to "2000" to correlate with the reference listing in the Section 8.0 discussion.

298 840/37 Change "2008a" to "2008" to correlate with the reference listing in the Section 8.0 discussion.

299 8-40/39 and 40 EPA 2009a is not referenced in the Section 8.0 discussion.

300 9-1/3 Incorrect corporate name for NPPD. Revise to read: "...Nebraska Public Power District (NPPD) Energy Company, LLC's..."

Basis for Change: Correction

NLS2010037 Page 47 of 51 301 9-1/25-30 The discussion states that the NRC staff has identified a variety of measures to mitigate potential acute electromagnetic field (EMF) impacts. The discussion of EMF impacts, however, does not indicate the consideration of any such mitigation alternatives in this case.

Recommend deletion.

302 9-1/31-37 The discussion states that the NRC staff has identified a variety of measures to mitigate potential impacts of thermophilic microbiological organisms resulting from continued operation of CNS. These measures are not enumerated in section 4.8.2 of the document, so it is unclear where the NRC staff identified mitigation measures. Recommend deletion.

303 11-1/33-37 It is unclear how regulatory agencies in Pennsylvania are related to license renewal at CNS. Recommend deletion.

304 11-2/3 Unclear how the Susquehanna River Basin Commission is related to license renewal at CNS. Recommend deletion.

305 F-115 Change "In December 7, 2009" to "On December 7, 2009."

Grammatical correction.

306 F-1/19 There is no "(NRC, 1998a)" in the Section F.8 references.

307 F-1/22 Change "... who addressed..." to "...that addressed..."

308 F-5/3 The "(8.9 x 10-5 per year)" value does not agree with the CDF value Revise to read: "...(8.90 x 10-5 per year)..."

reported in Section E.1.4 of the ER and in DSEIS Table F-3.

Basis for Change: Correction 309 F-7/23-27 Recommend providing a reference to "(NPPD 2009a)."

310 F- 10/44 through F- Recommend providing a reference to "(NPPD 2009a)."

11/2

NLS2010037 Page 48 of 51 311 F-I 1/11-13 Recommend providing a reference to Measurement Uncertainty Recapture power uprate approved by the NRC in 2008 (NPPD License Amendment 231 ADAMS Accession Number ML081540280).

312 F- 11/46 through F- Section states, "Year 2004 tourist information was used to estimate the Revise to read: "Year 2005 tourist information 12/2 transient population for year 2005 (Global Insight, 2006; IDED, 2006; was used to estimate the transient population in Kaylen, 2006; NDED, 2006)." Iowa, Missouri, and Nebraska (IDED, 2006; Kaylen, 2006; NDED, 2006). Year 2004 tourist These references were used for the tourist information. Although this information was used to estimate the transient information was not provided in the ER or the responses to Requests for population in Kansas for year 2005 (Global Additional Information, it was included in the supporting Engineering Insight, 2006; IDED, 2006; Kayl, 2006; Report (CNS-RPT-07-PRA3). This report indicates that year 2004 NDEDr 2006)."

tourist information was used for Kansas since 2005 data was not available. However, 2005 data was used for the other states (Iowa, Basis for Change: Clarification Missouri, and Nebraska).

Thus, the statement in the DSEIS is not accurate.

313 F-12/10 and 11 Add reference to the time estimate studies (listed on Page F-38/Lines 1-

4) for the following sentence: "The evacuation speed and time were based on the average values identified in the Missouri and Nebraska time estimate studies."

314 F-12/2-14 Section states, "NPPD performed sensitivity analyses in which the Revise to read: "NPPD performed sensitivity evacuation delay time was increased to 4.0 hours0 days <br />0 hours <br />0 weeks <br />0 months <br />, and the evacuation analyses in which the evacuation delay time was speed was decreased to 1.0 m/s. These sensitivity cases resulted in less increased to 4.0 hours0 days <br />0 hours <br />0 weeks <br />0 months <br />, and the evacuation speed than 1 percent and 2 percent increases in the total population dose, was decreased to 1.0 m/s. Each of tThese respectively." sensitivity cases resulted in less than a l percent and 2 pereent increases in the total population Table E. 1-15 of the ER provides the results of the sensitivity cases. dose,.-"espeeti*e*y."

Comparison of the sums of the third and fourth columns with the sum of the second column shows that both sensitivity cases resulted in less than Basis for Change: Correction 1% increase in the total population dose.

Thus, the statement in the DSEIS is not accurate.

NLS2010037 Page 49 of 51 315 F-12/19-21 Section states, "In response, NPPD performed a sensitivity analysis that Revise to read: "In response, NPPD performed a showed only a slight increase in population dose (less than 1 percent for sensitivity analysis that showed only a slight the late release) would result (NPPD, 2009a)." increase in population dose (less than 1 percent total for the late release) would result (NPPD, The RAI response letter (NPPD, 2009a) states, "If only 95 percent of 2009a)."

the population had been assumed to evacuate the EPZ, then the offsite exposure risk would have been 2.15 person-rem/yr for the baseline Basis for Change: Correction severe accident consequences."

This represents an increase of less than 1% for the total population dose.

Since the increase in total population dose, rather than "late release" population dose was reported, suggest deleting "for the late release."

316 F-21 through F- For consistency with the rest of the table, remove horizontal lines prior 30/Table F-5 to SAMAs 12, 26, 31, and 66.

317 F-24 and F-30/Table Details in modeling assumption for SAMA 78 are beyond the level of Revise to read: "Reduce failure of operator F-5 detail provided for other SAMAs. Suggest deleting, "to 5.OE-02 for actions to provide alternate injection via the fire events FPS-XHE-FODFPAL and FPS-XHE-FO-RPVIN and to 9.5E-03 water system by a factor of two to 5.OE 02 for for event FPS-XHE-FODISEL.(c)" and note (c). events FPS XHE FO RPVPI and to 9.5E 03 for event FPS XH4E FO DISEL.(c)"

Also, delete note (c).

Basis for Change: Level of detail consistency 318 F-28/Table F-5 Typo in modeling assumptions for SAMA 70; "drywall" should be "drywell."

NLS2010037 Page 50 of 51 319 F-30/Note (a) Note (a) indicates that SAMAs in bold are potentially cost-beneficial, but no SAMAs are bold. The following SAMAs are potentially cost-beneficial, based on the CNS SAMA analysis:

SAMAs 14 and 25 on page F-23 SAMAs 78 and 33 on page F-24 SAMAs 30 and 68 on page F-25 SAMAs 40 and 45 on page F-26 SAMLA 64 on page F-29 SAMAs 75 and 79 on page F-30 320 F-31/33-34 For each of the averted cost calculations, the text states, "For the Revise to read: "For the purposes of initial F-32/8-9 and 25-26 F- purposes of initial screening, which assumes elimination of all severe scr.eening, which assumes elimination of al 33/8-9 accidents caused by internal events, NPPD calculated..." However, sever.e accidents caused by internal events, NPPD NPPD did not use the value of eliminating all severe accidents in the calculated..."

initial screening task.

Basis for Change: Correction 321 F-32/31 and 32 Section states, "Repair and refurbishment costs are considered for Revise to read: "Repair and refurbishment costs recoverable accidents only and not for severe accidents." Wording are considered for-rec.ver.able acidents ony, not incorrectly suggests that repair and refurbishment costs are considered considered for severe accidents."

in the analysis.

Basis for Change: Clarification 322 F-33/28 and 29 Section states, "...also referred to as the Modified Maximum Averted Revise to read: "...external event severe accident Cost Risk (MMACR)." This qualifying statement is not necessary since risk at CNS-1, also referred to as the Modified the ER and DSEIS do not use the term MMACR. Recommend deletion. Maximum Averted Cost Risk (MMACR)."

Basis for Change: Clarification

NLS2010037' Page 51 of 51 323 F-35/36 and 37 Section states that the NRC "requested that NPPD reassess whether or not SAMA 13 would be cost-beneficial if it were to use the same portable generator as for SAMA 14, which was determined to be cost beneficial (NRC, 2009). In response, NPPD stated that since the SAMA submittal, SAMA 13 has been implemented at CNS-1 (NPPD, 2009a)."

As stated, it sounds like NPPD did not address the question. However, in the RAI response, NPPD also stated that the available skid mounted portable power supply considered in the cost estimate for SAMA 14 was not sufficient to supply the battery chargers as proposed in SAMA

13. No DSEIS change needed.

324 F-38/1 and 2 Missouri State Emergency Management Agency (1991) is not referenced in the Section F discussion. It appears to be related to Page F-12/Lines 10 and 11.

325 F-38/3 and 4 Nebraska Civil Defense Agency (1993) is not referenced in the Section F discussion.

326 F-38/21 Add "ADAMS Accession No. ML091880319" for consistency with same reference on page 5-8 (line 30).

327 F-39/21-23 NRC 2002 is not referenced in the Section F discussion.

NLS2010037 Page 1 of 4 Attachment 2 Proposed Revision to Section 2.1.6 of the Draft Generic Environmental Impact Statement Supplement 41 During the course of reviewing draft Supplement 41 to the Generic Environmental Impact Statement, the Nebraska Public Power District identified an extensive number of comments for Section 2.1.6, "Cooling and Auxiliary Water Systems." These comments included: a) the need to incorporate Environmental Report changes from NLS2009036, b) the need to clarify the U.S.

Army Corps of Engineers Missouri River flow regulation, and c) to reorganize the paragraphs in a more topical manner. As this section describes one of the key environmental interfaces of Cooper Nuclear Station, an underline/strikeout version of this section has been generated for the Nuclear Regulatory Commission's consideration.

2.1.6 Cooling and Auxiliary Water Systems CNS4 lies on the western shore of the Missouri River, withdraws river water for its once through cooling system, and discharges heated water back to the river. Unless otherwise cited, NRC staff drew information about CNS-'s cooling and auxiliary water systems from NPPD(2006c) and the applicant's ER. Under the present flow regulation, a minimum Nebraska City flow of 31,000 cfs (878 m 3/sec) is maintained for navigational purposes beginning in March and extending through November. In the vicinity oyf the plant, the M...oU.. RiVeF has a regulated minimum flew of 31,000 cubic feet perF econd (,f.)(878 cubic Mete.S per Second

(,m3/*ee)) to the.uth S, east. During the winter months, the winter flow in recent years has routinely been maintained at approximately 6,000 cfs (170 m 3/sec) or greater. Since the establishment of present flow regulation, the lowest flow at Nebraska City to date (16 year record) was 4,320 cfs (122 m 3/sec) in January 1957, which is also the minimum regulated flow by the U.S. Army Corps of Engineers. [see Attachment 3, Change 1] Should a prolonged drought occur such that water is not available to maintain the above required flows, the navigational season will be shortened so that the minimum sanitary flows can always be maintained, if needed. The annual mean river flow is 38,251 cfs (1,083 m 3/sec)(1930-2001) at the United States Geological Survey (USGS) gauging station at Nebraska City, Nebraska, which is located approximately 30 river miles north of CNS (NPPD 2008a).

The circulating water intake structure is located on the western shore of the river behind a guide wall and submerged weir meant to reduce the amount of suspended sediment in the cooling water. The weir attaches to shoreline structures north of the intake and then runs parallel to the face of the intake at a distance of 14.25 feet (4.3 m). The wall continues past the intake and ends approximately 40 feet (12 m) downstream of the downstream corner of the intake structure. 'I a line r"..rWard of the weir wall and emtending d*.W..t.eam of it, 23 sheet

NLS2010037 Page 2 of 4 pile vanes (10 ft wide by 6 ft high, 3 Fn wide by 2 mn high) orintcAd At;a 2 dcgrcc angle to the rediirect sand-Vwci9P-.r

-;nd- gravel outwardi fro1m1 the weir1 the ntaket land-generally south along the weir and vaervrwater mAust reverse course and turn nrethwest to Move between the weir and shore andP reach th.e in,tke ba.... An array of 20 submerged flow turning vanes has been installed east of the guide wall in the river channel. Each vane is constructed of steel sheet piling and driven into the river bed to a top elevation below barge navigation depth. The vane array functions to induce scouring of the river bed adiacent to the guide wall to prevent sediment accumulation. The prevention of sediment accumulations increases the effectiveness of the guide wall. River water flows over the weir wall leaving heavier sediment on the river side of the wall. Water velocity between the weir wall and the cooling water intake structure is approximately abeut-4 ft/sec (1.2 m/sec).

In winter, abot55 toa 30 percentof mainR condensrI; diSc-harge water recirculates through an ie contRo iRe tu a the front of th h i nkep s*tr*ut ureand discharges in frontplf the trash racr-lk to1 prevent eicng. Water flow.....

I -benea÷t-h -ac .u..all A a-bu*,nt 1.1 ft/sec (0.3 m/-sec). Water enters the five intake bays, fou--r of w0hic-h provide circulating water and are 22 feet (6.7 FR) wide and onRe o-f wihprovides Service water and is 22.5 feet (.6.8 M) wiode. The inoigwater then flows through trash racks, 3/8 inch (1.0 cm) vertical bars. sepaated 3 inches (7.6 cm) on center, at up to 0.7 f/sec (20em cm*/ec*). Water for the facility is drawn through five intake bays. Four of these bays provide circulating water to the generating unit while the other is used for service water. Each circulating water intake bay splits into two screen bays, while the service water intake bay narrows to a smaller screen bay. These bays are 9.7 feet (3 m) in length by 5.6 feet (1.7 m) wide, providing space for 4.2 feet (1.3 m) wide dual flow screens. Each bay is fitted with modified dual flow traveling screens designed with fish collection baskets. The modified dual flow screens operate at 90 degrees to the water flow. Four circulating water pumps provide the circulating water for the facility. Each pump can draw 159,000 gpm (10 m 3/sec). The pump design water level is at El. 875.0 ft, with a minimum submergence level at El. 865.0 ft. There are four service water pumps providing a combined flow of 32,000 gpm (2 m 3/sec). Velocities in the intake structure are 1.1 ft/sec (0.3 m/sec) under the curtain wall, 0.7 ft/sec (20 cm/sec) at the trash racks, and approximately 2.0 ft/sec (0.6 m/sec) at the traveling water screens. These velocities were calculated at low water levels (El. 874.5 ft) and maximum circulating water pump flow (159,000 gpm (10 m 3/sec) per pump). Fish and debris are currently collected on both the ascending and descending sides of the dual-flow screen, which allows only filtered water to pass downstream to the pumps. Fish and debris are removed by a high pressure screen wash system and conveyed back to the river. Modified dual-flow traveling screens were installed in 2006 to address debris carry-over problems encountered with the original flow-through traveling screens. (NPPD 2008a)

The water intake bays each separate into two screen bays and the srvpice water

.irc.ulating intake bay narrows before w.ate~r encouinters the traveling screenS, which -areoriented at right

NLS2010037 Page 3 of 4 angles to the flow. Water filterS twice through nine 1/8 by,14 in. (.3 em by 1.3 em) Smooeth top mnesh mod-ifie-d dafo traveling Screens (eight for czirculating water and one for seric water). The UP ~ard pas is in the fFE)Rt- ;d t-he donWaru paIS

• b-ehid- the Seees tnat rotate continuously at 8.2 4ft/mm (2.5 rn/mmo). The inta-;ke;water velocity at the scr=eens is about 2 ft/sec (0.6 m/sec).

Each circulating water screen has 1/8 by 1/2 in. (0.3 cm by 1.3 cm) smooth top mesh. The service water screen has 0.2-in. (5 mm) perforated plastic mesh. Each screen has a high and low speed, but is normally rotated continuously at the slow 8.2 ft/min (2.5m/min) speed to prevent excess debris build up. A high pressure screen backwash system providing 3,000 gpm (0.19 m 3/sec) at 30-60 psig (207-414 kPa) is used to remove fish and debris from the screens. Water for the screenwash is drawn from the service water pumps. Fish and debris flushed from the screens are returned to the river via an 18 in. (0.46 m) steel pipe. This steel pipe discharges downstream from the intake. The existing screen wash system does not have the capacity to provide the required flow to support both a low pressure fish protection spray system and the high pressure debris removal system nor is there a separate fish return trough and conveyance system to return fish back to the river. (NPPD 2008a) Figure 2.1.6-1, Figure 2.1.6-2, and Figure 2.1.6-3 show the CNS intake structures. After the 1.2 f (1.28 );w.id, e traveling scr.een pan rotate over the upper cog and begin moving down, a high preSSUre (30-60 psig, 200-00,.Pa)

SCreen wash of 3000 gallons per minute (gpm) (0.9 m3/sec) supplied by the service water PUMPS remo-ves fi-sh and debriS, which return) together to the-river t-hrough an 18 in (0.16 mn) diameter steel pipe that discharges do9wnStrea~m fro~m the inae.Athough the screens are fitteed with fis bas,;kets, the syste.m h4 nthe..-...e a loW pressure spray system to morFe gently remove fis-h fro-m t-he Screens nor a fish rePturnF- trough to convey fish and other aquai organisms back to+n the river separately from, potentially damaging debFi..*,Debris loads are approximately a;-i*t-10 cubic yards per month (8 m 3/month).

In winter, some of the main condenser discharge (about 25 to 30 percent) recirculates through an ice control tunnel at the front of the intake structure and discharges in front of the trash rack to prevent icing.

-N-S NPPD plans to install "dual flow conversion screen a fish handling and return systems to mitigate the effects of impingement. "durngt, urent operational tern. This system will have loW pressure (5 to 10 psi, 35 70 kPa) fiSh waShing Spray 9Aoboth the"ascending and descending Screens and- a fish r-tuRn trugh that is separate f-ro the debris trough. recov'ery basket wil collet* fish and othePr. aquatic organisms w..ashed from the screens, and the fish trough will return them to the river. The final design and implementation of the fish handling system are dependent upon the requirements of the final Phase II 316(b) Clean Water Act amended regulations. Figure 2.1.6 1, Figure 2.1.6 2, anid Figure 2. 1.6 3:show.. the rNS -Iintkpe struc-tures.

[See Attachment 3, Changes 2, 4, 5, 6, 7, 8, 9, 10, and 11]

NLS2010037 Page 4 of 4

^.Aftcr w.t......

passes through the travcling Screens, the two Screen bays fceach intake bay rejoin bhehind_ the ScreenRS. The four c-irc.ulating water PUMPS, one per bay, draw wte fromF the bays and pro.ide up to 159,000 gpmn (10 m3/se) each. The four. servie water pumps in the fifh bay pro.ide a combined flow of 32,000 gpm (2 m3/se,). Water from the circulating water pumps travels to and circulates through the condenser, where it cools steam from the turbines.

Because of the scouring from the suspended sediment, CNS 1 ty-pically des is not Peed requiredto chlorinate the circulating water to control biological film fouling, although it has the capacity to chlorinate or brominate if needed. .%PPD is Studying the effectiveness of these epten., '[See Attachment 3, Change 3] Water temperature increases approximately abe+it 17.87F (10°C) as it passes through the condenser tubes. Fre.m. the cornden.cr, c;irculating coolig*

w~ater flow;S through conreete tunnels5 tos a seal w.eall struc-ture andd theen to the disczharge canal, w.here ih....- a*bout 1,000 feet (300.. ) to discharge to the ri.er at a light angle. Water velocity at thedicharge is about 1 ft/sec (0.3 ,1/sec) at average river flow and ao 5.6 ft/sec (1.7mloc)t durtne lo lw. h rve iefrmteinaesrutr othe dcabout i.6about 20 minutes at high rive:r fiow" and 10 to 12 minu.tes-at lo'..l floew. From the seal well and gate control structure, the water is directed into a discharge canal that is approximately 1,000 ft (305 m) long; it then enters the river at a slight angle. The -velocity of discharge is about 1 fps (0.03 m 3/sec) during average water levels of 879.4 ft and 35,000 cfs (991 m 3/sec ) river flow, and increases to about 2.5 fps as the river water surface elevation is reduced to 874.5 ft and flows near 11,000 cfs (311 m 3/sec) which is the nominal control low maintained by the USACE below the confluence of the Platte River. Travel times in the pump house-condenser-canal system will be approximately 20 minutes at high flow and 10 to 12 minutes at lower river flows.

Stone rip-rap is used to prevent scours in the vicinity of the discharge structure.

Cooling water flow demand varies with eleeretrieal Iea4 plant power and ambient river water temperature. At full load during summer, the expected circulating water system flow is highest:

about 636,000 gpm (40 m3/sec). Lower cGirculating water flow is lewef required under et-he lower river temperature conditions. in comparison, the lowest river flow; at C.NS 1 is about 3,000 cf4. Under the, wors codiios the circulating water system flow wouldud be about

- 47 percent of Misso-uri River flow. StonRe riprap at the discharge structure prevents the discharge fromF. ero..d.ing

• rv* the e bottom. The annual mean river flow is 38,251 cfs (1,083 m 3/sec) (1930-2001) atthe United States Geological Survey (USGS) gauging station at Nebraska City, Nebraska, approximately 30 river miles north of CNS (NPPD 2008a). The CNS maximum circulating water withdrawal represents less than 4 percent of the average annual Missouri River flow. While the percentage of river flow withdrawn by CNS may be higher during winter, the withdrawal is significantly less than in summer, and occurs at a time when impacts due to entrainment of fish eRgs and larval fish are non-existent or minimal.

NLS2010037 Page 1 of 5 Attachment 3 Changes to the License Renewal Application Environmental Report As a result of reviewing the draft Supplement 41 to the Generic Environmental Impact Statement, the Nebraska Public Power District identified certain corrections/enhancements to the License Renewal Application Environmental Report. They are presented in underline/ strikeout format.

1) Page 2-10, 1 St paragraph is revised to read:

"During the winter months, a minimum regulated flow of 3-,000 4,320 cfs is maintained required at Nebraska City for,.anitar .purposes; however, the actual winter flow in recent years has been maintained at 6,000 cfs or more."

Reference:

Correction based on USACE Master Manual.

2) Page 3-4, second paragraph is revised to read:

"However, CNS is planning to augment its existing intake structure design with a d+Ma flow onver-sion screen fish handling and return systems during the current operational tefm e the effects of fish impingement. The system cur*ently being considered is the Br*cAkef Green USA, Inc. Fish Handling Sr.een with the Advanced S.I.M.P.L.. .

Pro.ess. This possible m.dification to the intake sthucture would involve the installatien of inside and outside fish sprays which operate between 5 10 psi and a separate fish retrn rouh. As raw water- would pass through the existing fish baskets, floating and-retained on the upstr-eamfi side of the mesh and juvenile mar-ine life would be captur-ed in the hydr-aulically stabilized fish r-ecover-y basket. The recover-ed fish would then be dischar-ged on the descending side with aid from the inside and outside fish spr-ays intoa fish troeugh located above the debris troeugh. [Bract] The CNS implementation date and the final design of the fish handling system are dependent upon the content of the final 316(b) Clean Water Act requirements."

Reference:

Clarification. It is expected that the final design will be at least as robust as currently described.

3) Page 3-4, last paragraph, Page 3-5, 1 st paragraph is revised to read:

"Chlorination is typically not required because of the inherent scouring action of the sandy river water. However, a connection is provided for such a system in the event

NLS2010037 Page 2 of 5 should it's be found necessary potentially needed in the future. The chlorination system connection is located on the common inlet to Screen Wash Pump A and B from the service water system. [NPPD 2008, Section XI-6.3]. Bacteria that occur naturally in the Missouri River may contribute to the growth of biological film fouling of the main condenser tubes. The station is proceeding with a study, to dete.mine if routine chemi.al injection (chlorine, br-omine, etc.) will be eff-eetive in eliminating the microebiological filmf on the interior-walls of the condenser tubes."

Reference:

NPPD has completed the chlorination study and has determined that application of up to twice per year can be effective in optimizing thermal performance.

4) Page 4-10, 1st paragraph is revised to read:

"However as discussed in Section 3.2.2, CNS has already installed dual flow conversion screens that are equipped with fish baskets and is planning on installing a fish handling and return system to mitigate the effects of fish impingement" on. of inside and outside fish sprays and a separate fish return tr-ough prior to the end of the currenit operational term. The CNS implementation date and the final design of the fish handling system are dependent upon the content of the final 316(b) Clean Water Act requirements."

Reference:

Clarification. It is expected that the final design will be at least as robust as currently described.

5) Page 4-11, 4 th paragraph is revised to read:

"However, as discussed in Section 3.2.2, CNS is planning to install a fish handling and return system to mitigate the effects of fish impingementeonsisting of inside and outside fish sprays and separate fish return tromugh pior to the end of the cu.rent operational te The CNS implementation date and the final design of the fish handling system are dependent upon the content of the final 316(b) Clean Water Act requirements."

Reference:

Clarification. It is expected that the final design will be at least as robust as currently described.

6) Page 4-21, 1st paragraph is revised to read:

"However as discussed in Section 3.2.2, CNS is planning to install a fish handling and return system to mitigate the effects of fish impingementeonsisting of inside and outside fish spr-ays and a separate fish fetern trough prior to the end of the current operationa terfm. The CNS implementation date and the final design of the fish handling system are dependent upon the content of the final 316(b) Clean Water Act requirements."

NLS2010037 Page 3 of 5

Reference:

Clarification. It is expected that the final design will be at least as robust as currently described.

7) Page 4-23, 1st paragraph is revised to read:

"However as discussed in Section 3.2.2, CNS is planning to install a fish handling and return system consisting of inside and outside fish sprays and a separate fish r.etu.n tro.ugh prior-to the end of the current operational tem. This change to the CWIS design would most likely be considered Best Technology Available for minimizing impingement impacts. The CNS implementation date and the final design of the fish handling system are dependent upon the content of the final 316(b) Clean Water Act requirements."

Reference:

Clarification. It is expected that the final design will be at least as robust as currently described.

8) Page 4-28, 4 th paragraph is revised to read:

"Although NDEQ had already determined that the cooling water intake impacts were probably minimal at CNS, NPPD is planning to install a fish handling and return system eonsisting of inside and outside fish spr-ays and a separate fish return trough during the cur.ent operational term. This change to the existing design of the CWIS (Ristroph screens) would most likely be considered Best Technology Available for minimizing impingement impacts. The CNS implementation date and the final design of the fish handling system are dependent upon the content of the final 316(b) Clean Water Act requirements."

Reference:

Clarification. It is expected that the final design will be at least as robust as currently described.

9) Page 4-28, last paragraph, and 4-29, 1 st paragraph is revised to read:

"NPPD is planning to install a fish handling and return system at CNS, ..eensting -

inside and outside fish sprays and a separate fish return trough to the existinig design Of the CWIS (Ristr"ph sreens). This change to the CWIS would most likely be considered Best Technology Available as it relates to minimizing impingement impacts. The CNS implementation date and the final design of the fish handling system are dependent upon the content of the final 316(b) Clean Water Act requirements. In addition, even though current impingement impacts are minimal, impacts during the license renewal period would be even smaller due to this CWIS design change. -ThefefreInsummary, NPPD concludes the impact due to impingement of fish and shellfish in the Missouri River is SMALL and mitigation measures are not warranted."

NLS2010037 Page 4 of 5

Reference:

Clarification: It is expected that the final design will be at least as robust as currently described.

10) Page 4-4-93, 3 rd paragraph is revised to read:

NPPD is planning to install a fish handling and retum system c ;nsisting of inside and (Ri;tfeph sefeen,,. This change to the CWIS would most likely be considered Best Technology Available as it relates to minimizing impingement impacts. The CNS implementation date and the final design of the fish handling system are dependent upon the content of the final 316(b) Clean Water Act requirements. -herefereln summary, NPPD concludes the cumulative impact due to impingement of fish and shellfish in the Missouri River is SMALL and mitigation measures are not warranted.

Reference:

Clarification. It is expected that the final design will be at least as robust as currently described.

11) Page 6-2, "Impinge of fish and shellfish [10 CFR 51.53(c)(3)(ii)(B)]" is revised to read:

SMALL. Missouri River studies and previous agency determinations identify factors (i.e., river and tributary dams, channelization and other habitat management, invasive aquatic species) other than impingement as being the primary cause of direct and cumulative impacts to the fish populations. CNS is also planning to install a fish handling and return system ........... s an a separate fish .

÷ ... h to th existing÷ e GWIS design ph sefeef)

....... which would most likely be considered Best Technology Available. The CNS implementation date and the final design of the fish handling system are dependent upon the content of the final 316(b)

Clean Water Act requirements. Therefereln summary, NPPD concludes the impact from plant operations due to impingement of fish and shellfish in the Missouri River is SMALL. Further consideration of mitigation measures is not warranted.

Reference:

Clarification. It is expected that the final design will be at least as robust as currently described.

12) Page 9-4, Table 9.2-1, delete entry 7, "CNS Radioactive Waste Transport Permit No.

0218-26-08-X."

Reference:

NPPD is no longer authorized to ship radwaste under this permit.

13) Page 9-5, Table 9.2-1, revise entry 1, "CNS Radioactive Waste License for Delivery No.

T-NE002-L08 expiration date from "December 31, 2008" to "January 3, 2011 ."

NLS2010037 Page 5 of 5

Reference:

Letter from M. Singleton (Tennessee Department of Environment and Conservation) to J. Kuttler (NPPD), dated November 24, 2009, "Radioactive Waste License-for-Delivery."

14) Page 9-5, Table 9.2-1, revise entry 2, "Generator Site Access Permit No. 0111000042 expiration date from "January 3, 2009" to "January 3, 2011 ."

Reference:

Letter from D. Finerfrock (Utah Department of Environmental Quality) to J.

Kuttler (NPPD), dated November 24, 2009, "Generator Site Access Permit Number 0111000042."