ML11193A093

Reply to RAI for the Review of the Davis-Besse Nuclear Power Station, Unit 1, License Renewal Application Environmental Report and Enclosure a - Environmental Audit Needs List

ML11193A093
Person / Time
Site:	Davis Besse
Issue date:	05/27/2011
From:	Allen B S FirstEnergy Nuclear Operating Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
L-11-165, TAC ME4613
Download: ML11193A093 (42)

Text

FENOC 5501 North State Route 2 FirstEnergy Nuclear Operating Company Oak Harbor, Ohio 43449 Batty S. Allen 419-321-7676 Vice President

-Nuclear Fax: 419-321-7582 May 27, 2011 L-11-165 10 CFR 54 ATTN: Document Control Desk U. S. Nuclear Regulatory Commission Washington, DC 20555-0001

SUBJECT:

Davis-Besse Nuclear Power Station, Unit No. 1 Docket No. 50-346, License Number NPF-3 Reply to Requests for Additional Information for the Review of the Davis-Besse Nuclear Power Station, Uniit' No. 1, License Re66Wal Application (TAC No. ME4613)Environmental Report By letter dated August 27, 2010, (Agencywide0',dcentsý'Access and Management System (ADAMS) Accession No. ML1 02450565)-,'firstEnergy Nuclear Operating Company (FENOC) submitted an application pursuant to Title 10 of the Code of Federal Regulations, Part 54 for renewal of Operating License NPF-3 for the Davis-Besse Nuclear Power Station, Unit No. 1 (DBNPS). By letter dated April 26, 2011 (ADAMS Accession No. ML1 1094A099), the Nuclear Regulatory Commission (NRC) requested additional information to complete its review of the License Renewal Application (LRA).The Attachment provides the FENOC reply to the NRC request for additional information.

The NRC request is shown in bold text followed by the FENOC response.

The Enclosures provide copies of requested documents.

There are no regulatory commitments contained ir this letter. If there are any questions or if additional information is required, please contact Mr. Clifford I. Custer, Fleet License Renewal Project Manager, at 724-682-7139.

Sincerely, Barry S. Allen A45 Davis-Besse Nuclear Power Station, Unit No. 1 L-11-165 Page 2

Attachment:

Reply to Requests for Additional Information for the Review of the Davis-Besse Nuclear Power Station, Unit No. 1, License Renewal Application Environmental Report

Enclosures:

A. Environmental Audit Needs List (RAI General 1)B. Aerial Map or Site Plan (RAIs General 3 and Cultural 2)C. References (2 Binders)cc: Cover Letter with DVD of Letter, Attachment and Enclosures (due to submittal size)NRC DLR Project Manager NRC DLR Environmental Project Manager NRC Region III Administrator cc: w/o Attachment or Enclosures NRC DLR Director NRR DORL Project Manager NRC Resident Inspector Utility Radiological Safety Board Attachment L-1 1-165 Reply to Request for Additional Information for the Review of the Davis-Besse Nuclear Power Station, Unit No. 1, License Renewal Application Environmental Report Page 1 of 12 Section General Question General 1 On February 16, 2011, a draft copy of the environmental audit needs list was e-mailed to the licensee for preparation of the NRC's environmental audit held on March 7-11, 2011. This list specified the additional information needed by the NRC staff to perform its environmental review.In response to the staffs request, the applicant had the information available to the staff for its review during the site environmental audit. The information is needed by the staff to have sufficient information to prepare its supplemental environmental impact statement.

Please submit the information provided at the environmental audit for docketing.

RESPONSE GENERAL 1 The requested document is provided as Enclosure A.Question General 2 The Environmental Report (ER) states that there is a lease agreement with U.S. Fish and Wildlife Service (USFWS) for land tracts adjacent to the Davis-Besse site.Please provide a copy of the lease agreement describing the lease terms and legal description of the land currently leased by the USFWS for docketing.

RESPONSE GENERAL 2 Approximately 733 acres of the Davis-Besse site property is marshland that is leased to the U.S. Government as a National Wildlife Refuge, and is managed by the U.S. Fish and Wildlife Service (USFWS). Property ownership remains with FirstEnergy Nuclear Operating Company (FENOC). There are three leases involved in the agreement; Attachment L-11-165 Page 2 of 12 copies of these leases are provided in Enclosure C, in the Section labeled Socioeconomics, Environmental Justice & Land Use, Tab S 5.During review of the lease information, it was discovered that one lease that began on November 1, 1972 (labeled Lease No. 1), ended on October 31, 1997. A new lease to replace the expired lease was located in draft form, but a signed copy of the new lease could not be located. This new lease would have extended Lease No. 1 to the year 2022. A condition report was written to document this discovery.

The FENOC Corrective Action Program will address this issue.Question General 3 The ER refers to areas of the Davis Besse site that are not clearly delineated on Figure 3.1-1 general plant layout or on an exhibit.Please include an aerial map or site plan delineating the following:

a. Owner-controlled area b. Protected area c. Disturbed area (i.e., disturbance depth greater than 2 ft)d. Undisturbed area (i.e., pockets of undisturbed land or land with possible surface disturbance in the past of less than 2 ft, such as by agricultural practices prior to plant construction) within the 221-acre non-marshland industrial area e. Marshland (undisturbed)

f. National Wildlife Refuge leased areas RESPONSE GENERAL 3 A site map that delineates the requested areas is provided as Enclosure B.The undisturbed areas of the site property are highlighted in green shading on the site map and labeled as "undisturbed." Additionally, the marsh areas shown on the map are undisturbed with the exception of the berms and associated roadways surrounding the marsh ponds, since they were constructed to allow access to the area and control marsh pond water levels.The disturbed areas of the site property are those un-shaded areas and ponds within the boundary of the owner controlled area, the intake canal between the plant and Lake Attachment L-11-165 Page 3 of 12 Erie, the un-shaded area surrounding the Davis-Besse Administration Building, and the two ponds to the west and northwest of the cooling tower.The areas designated as "marsh" on the map comprise the National Wildlife Refuge leased areas.Section Aquatic & Terrestrial Question Aquatic & Terrestrial 1 The ER states that there is a lease agreement with USFWS for portions of the Davis-Besse site. Information received during the audit indicates the lease is valid until 2022, or five years into the period of extended operation.

Please provide information on USFWS's management of the marsh areas under their control (i.e., impoundments and invasive species management).

Please provide an evaluation of the potential environmental impacts, if any, in the event the lease with USFWS is not renewed in 2022.RESPONSE AQUATIC & TERRESTRIAL 1 Approximately 733 acres of the Davis-Besse site property is marshland that is leased to the U.S. Government as a National Wildlife Refuge, and is managed by the USFWS.Property ownership remains with FENOC. There are three leases involved in the agreement; copies of these leases are provided in Enclosure C, in the Section labeled Socioeconomics, Environmental Justice & Land Use, Tab S 5.During review of the lease information, it was discovered that one lease that began on November 1, 1972 (labeled Lease No. 1), ended on October 31, 1997. A new lease to replace the expired lease was located in draft form, but a signed copy of the new lease could not be located. This new lease would have extended Lease No. 1 to the year 2022. A condition report was written to document this discovery.

The FENOC Corrective Action Program will address this issue.The remaining two leases (labeled Lease No. 2 and Lease No. 3) end on December 31, 2018.FENOC provides maintenance services for the roads and dikes along the shore of Lake Erie and throughout the marsh, while the USFWS manages the wildlife and plants, and maintains the marsh ecosystem by controlling water levels in the three large marsh ponds. The arrangement between FENOC and the USFWS is a cooperative effort for management of the property, the habitat, and the wildlife living on the property.

The marsh provides a benefit to migratory waterfowl and songbirds passing through the area.

Attachment L-11-165 Page 4 of 12 Access to the marsh areas is controlled due to its proximity to the nuclear plant, resulting in limited vehicle and pedestrian traffic through the marsh. A special use permit has been issued to the Black Swamp Bird Observatory for bird banding and research.Past efforts by the USFWS and FENOC to manage the marsh habitat, wildlife, and invasive species included the use of volunteers and professionals.

Management efforts included activities to control purple loosestrife, control the deer herd by selective harvest hunts, muskrat trapping, spraying of plants, and swan shoots to prevent nesting on the property.

Surveys have been performed by the USFWS for the prairie fringed orchid, a State and Federally-listed threatened species, but none were found.FENOC and the USFWS expect the leases to be renewed after 2018, and USFWS management of the wildlife refuge to continue.

In the unlikely event that the leases end without renewal, FENOC would assume environmental management of the marsh, and would likely seek input and guidance from the USFWS. In the past, FENOC personnel have been active in marsh management with the USFWS, and have adjusted marsh water levels in coordination with the USFWS. The environmental impacts to the marsh, whether under the management of the USFWS or FENOC, are expected to remain unchanged.

Section Health Physics Question Health Physics I The Updated Safety Analysis Report (USAR), Section 11.5.5, Storage Facilities, discusses how low-level radioactive waste is handled at Davis-Besse Nuclear Power Station. Davis-Besse Nuclear Power Station cannot dispose of Class B and C low-level radioactive waste at the Barnwell, South Carolina facility due to Ohio not being in the Atlantic Interstate Low-Level Radioactive Waste Management Compact. The USAR states that Davis-Besse Nuclear Power Station has sufficient capacity within the Low Level Radioactive Waste Storage Facility (LLRWSF) building for approximately five years of storage for Class B and C waste. In addition to the storage capability, the Annual Radiological Environmental Operating Report discusses the use of a contractor to process and take title of the Class B and C waste for its disposal.

However, based on the information contained in the ER and the USAR, the staff is unable to reach the conclusion that Davis-Besse Nuclear Power Station has adequate capability to store and dispose of low level radioactive waste over the term of license renewal.Please provide additional information about Davis-Besse's typical yearly low-level waste generation rates, processing methods, storage capability, and disposal options that demonstrate that there will be adequate storage and disposal capability during the period of license renewal.

Attachment L-11-165 Page 5 of 12 RESPONSE HEALTH PHYSICS 1 Low-level radioactive waste (LLRW) generation rates and processing methods FENOC strives to minimize the amount of LLRW generated at Davis-Besse.

The average volume of Class A, B and C LLRW generated over the past three years (2008, 2009 and 2010) are shown in the table below. Class A dry waste is shipped in sea-land containers to an Energy Solutions processor for incineration, compaction and metal melt processing to reduce the volume of waste, and then to Clive, Utah, for land burial.Class A resins are also shipped to an Energy Solutions processor, and then to Clive, Utah for residue burial. Class A liquid waste is shipped to processors and the residue is buried in Clive, Utah. Class B and C resins and filters are shipped in high integrity containers (HICs) to Studsvic, Inc., in Erwin, Tennessee, for thermal oxidation and reduction processing to reduce the volume for burial.Avg. volume per Avg. volume per Waste Class year generated and year after shipped (ft 3) processing (ft 3)A 18025 2575.8 B 270 0.6 C 20 10.0 Storage capability and disposal options The Low Level Radioactive Waste Storage Facility (LLRWSF) has sufficient capacity for approximately five years of storage for Class A, B and C waste. Class A LLRW waste is shipped to processing facilities as shipping containers are filled. As a result, there is no need for storage of Class A waste. The contract with Studvic, Inc., for processing Class B and C LLRW has resulted in the processing of all Class B and C LLRW;consequently, there is no Class B or C LLRW in long-term storage on site.The LRRWSF is capable of storing 108 HICs. Since Class A waste is not stored, the space is available for Class B and C LLRW storage. Through waste-reduction efforts, FENOC is currently generating approximately three Class B and C HICs during a two-year operating cycle. Assuming that FENOC had to store Class B and C LLRW and not ship it off-site for processing, and continued to generate three Class B and C HICs during each two-year operating cycle from 2011 through the period of extended operation (i.e., conservatively, 14 cycles), there would be 14 x 3 = 42 HICs that would require long-term storage in the LLRWSF. With storage capacity for 108 HICs in the LLRWSF, storage space for an additional 66 HICS will exist at the end of the period of extended operation.

Attachment L-11-165 Page 6 of 12 Section Cultural Question Cultural 1 The ER states that there is a current lease agreement with USFWS for portions of the Davis-Besse site. Information received during the cultural break out session at the audit did not clearly specify the process of notifying the Ohio State Preservation Office in the event cultural resources are discovered on the leased land.Please describe the process or procedure for notifying the Ohio State Preservation Office in the event cultural resources were discovered on the land leased from the USFWS.RESPONSE CULTURAL 1 Approximately 733 acres of the Davis-Besse site property is marshland that is leased to the U.S. Government as a National Wildlife Refuge, and is managed by the USFWS.During a May 23, 2011, discussion with a USFWS senior biologist regarding the issue raised in the NRC request, the senior biologist stated that USFWS personnel are sensitive to any finds of cultural resources.

Should cultural resources be discovered by USFWS personnel, their direction is to stop their activities immediately, protect the area from further disturbance, and contact the USFWS Cultural Resources Specialist in the Minneapolis, Minnesota office. The Cultural Resources Specialist is responsible to ensure the Ohio State Historic Preservation Officer is contacted.

Should FENOC personnel uncover cultural resources during ground-moving, excavation or trenching activities on the leased marsh areas or on the Davis-Besse site, the encounter shall be immediately reported to the Assigned Supervisor and Chemistry Duty Manager, including exact location, depth, and description of the material or item encountered.

Corporate Environmental personnel would be contacted to ensure the Ohio State Historic Preservation Officer is notified, and the FENOC Corrective Action Program would be used to disposition the issue. The FENOC procedure for ground-moving, excavation and trenching controls is written to ensure protection of archaeological, cultural and historical resources discovered as a result of these ground-disturbing activities.

Attachment L-11-165 Page 7 of 12 Question Cultural 2 The ER states that the site was constructed using fill. The geology section of the ER indicated the presence of two to three feet of topsoil overlaying an estimated 10 thousand year old glacial stratum. Areas of the plant site that remain undisturbed have a higher probability of containing cultural resources than areas previously disturbed.

Photos seen during the audit show areas where significant excavation was performed during construction.

The staff needs additional information in order to meet the request made by the Ohio State Preservation Office.Please include an aerial map or site plan delineating areas that have had extensive excavation.

RESPONSE CULTURAL 2 A site map that delineates disturbed areas is provided as Enclosure B.The undisturbed areas of the site property are highlighted in green shading on the site map and labeled as "undisturbed." Additionally, the marsh areas shown on the map are undisturbed with the exception of the berms and associated roadways surrounding the marsh ponds, since they were constructed to allow access to the area and control marsh pond water levels.The disturbed areas of the site property that have had extensive excavation are those un-shaded areas and ponds within the boundary of the owner controlled area, the intake canal between the plant and Lake Erie, the un-shaded area surrounding the Davis-Besse Administration Building, and the two ponds to the west and northwest of the cooling tower.Section References Question References Provide copies of the following references:

Air & Meteorology AM 1 NOAA 2009. NOAA e-mail, J. Kosanik to J, Snooks (AREVA), National Weather Service, March 3, 2009.AM 2 System Description for Meteorological Monitoring System for the Toledo Edison Company Davis-Besse Nuclear Power Station, Unit 1, Oak Harbor, Ohio, SD-032C, Rev. 2,10/04/2005 Attachment L-11-165 Page 8 of 12 AM 3 Ohio EPA, Davis-Besse Station, Auxiliary Boiler Air Quality Permit, Date of Issuance:

05/26/89.AM 4 Ohio EPA, No Permit Needed for Diesel Generators at Davis-Besse NPS, October 1, 1996.AM 5 TRC Environmental Corporation, Emission Inventory Report, Centerior Energy Corporation, Davis-Besse Nuclear Power Station, Oak Harbor, Ohio, February 10, 1995.AM 6 DBNPS, Greenhouse gas emissions at Davis-Besse, dated 03/04/2011 (1 page)AM 7 DPNPS, Actual vs Potential Emissions of Stationary Combustion Sources for 2005-2009 (15 pages) -Gale will add emissions for 2010 AM 8 Memorandum from J.S. Seitz (OAQPS), Second Extension of January 25, 1995 Potential to Emit Transition Policy and Clarification of Interim Policy, July 10, 1998 (4 pages)AM 9 Ohio EPA, Final Title V Permit to West Lorain Plant, Issue Date: 11/19/04 (1 page)AM 10 Ohio EPA, 2004-2005 Non-Title V Air Emissions Report for Davis-Besse Station, dated 02/21/2005 (1 page)AM 11 Ohio EPA, 2006-2007 Non-Title V Air Emissions Report for Davis-Besse Station, dated 04/04/2008 (1 page)AM 12 Ohio EPA, 2008-2009 Non-Title V Air Emissions Report for Davis-Besse Station, dated 02/26/2010 (1 page)AM 13 Ohio EPA, Engineering Guide #61, "What is Ohio EPA's policy for limiting the potential to emit (PTE) of air contaminant emissions at a facility for purposes of avoiding federal permitting?," Revised September 5, 1996 (3 pages)AM 14 Letter from Polly Boissoneault (DBNPS) to Jay Liebrecht (Ohio EPA), Submittal of the 2010 Annual Report for DBNPS Auxiliary Boiler (3 pages)AM 15 Davis-Besse 10 Yr. Average Operating Hours and Fuel Burn (2 pages)AM 16 DBNPS, Diesel PM summaries (2 pages)Aquatic A I AE1.bL-08-039 Water WD rpt. for 2007_2008-02-05.pdf A 2 AE1.bL-09-027 Water WD rpt. for 2008_2009-02-11 .pdf A 3 AE1.bL-10-030 Water WD rpt. for 2009_2010-01-22.pdf A 4 AE1.b_L-11-033 Water WD rpt. for 2010_2011-02-16.pdf Attachment L-11-165 Page 9 of 12 A5 A6 A7 A8 A9 Terrestrial T1 T2 T3 T4 T5 T6 T7 T8 T9 T10 T 11 T 12 T13 T 14 T 15 T 16 T17 T18 T19 T 20 T 21 T 22 T 23 T 24 T 25 AEI.bRAOG-07-0009 Water WD rpt. for 2006.pdf AE3.aCooper et al. 1981 Larval fish and ent.pdf AE3.bReutter et al 1980 Env Evaluation Final Report Study l.pdf AE3.cReutter J.M. 1981a, Ent.pdf AE3.dReutter 1981 b, Imp.pdf TR1_ATTACH TR-1.PDF TRI_ODNR 2010_PUB356(Oct 2010).pdf TRI_ODNR 2011_RarePlantSpeciesbyCounty.pdf TR3_Site Layout for New Structures_12-7

-10.pdf TR4, 5_Davis-Besse Site Veg Mgmt Contracts.pdf TR4, 5_FirstEnergy Xmiss Line Veg Mgmt Specifications.pdf TR4_NOBP-OP-2000_Env Best Mgmt Practices.pdf TR6.aUSFWS 2009b Critical Habitat.pdf TR6.bODNAP 2009a.pdf TR6.bONWRA 2009.pdf TR6.cBolsenga and Herdendorf 1993.pdf TR6.c_ Campbell 1995.pdf TR6.cFirstEnergy 2008.pdf TR6.cGORP 2009.pdf TR6.cHerdendorf 1987.pdf TR6.c_MIPN 2009.pdf TR6.cODNAP 2009c.pdf TR6.cODNAP 2009d.pdf TR6.dDownhower 1988.pdf TR6.dEwert and Rodewald 2008, Mng Habits for Migrating Birds in...TR6.dFirstEnergy 2008.pdf TR6.dUSFWS 2008.pdf TR6.eERIE 1995.pdf TR6.eLucas 2008.pdf TR6.eOttawa 2008.pdf Attachment L-11-165 Page 10 of 12 T 26 TR6.eSandusky 2008.pdf T 27 TR6.fUSFWS 2009_Refuge Profiles.pdf T 28 TR6.gFECorp 2009.pdf T 29 TR6.gOPSB 2007.pdf T 30 TR6.gUSEPA 2009.pdf Hydrology H I Browser-Morner Associates, Inc., 2002, letter J. Hewlett, Senior Geologist, to First Energy Service Co. c/o Toledo Edison Company, regarding Preliminary Wetland Evaluation, Proposed Temporary Containment Area, Davis-Besse Plant, July 19.H 2 Centerior Energy, 1994, letter from L.F. Stortz, Vice-President

-Nuclear, Davis-Besse, to T.O. Hic Division of Emergency and Remedial Response, Ohio Environmental Protection Agency, in, regarding Submittal of Information Regarding Spill of Gasoline, Identification Number 01 0180, February 22.H 3 Davis-Besse Nuclear Power Station, 2004, Periodic Test Procedure DB-CN-04032, Wastewater Treatment Sludge Holding Tank Analysis, Revision 01, prepared by R. Edwards, October 28.H 4 Davis-Besse, 2004, National Pollutant Discharge Elimination System (NPDES) Program, Administrative Procedure DB-CN-00030, prepared by S. Chimo, June 21.H 5 Davis-Besse, 2007, Business Practice DBBP-CHEM-2005, Spill Prevention Control and Countermeasure (SPCC) Plan, approved by V. Capozziello, March 16.H 6 Davis-Besse, undated, Condition Report #04-01719, "In 2004-05 Spent Fuel Pool Leakage to Onsite Groundwater", discovery date 3/5/2004.H 7 Davis-Besse, undated, Business Practice DBBP-CHEM-2009:

Storm Water Pollution Prevention Plan, Rev. 00, 28 pages.H 8 Environmental Resources Management, 2007, Groundwater Flow Characteristics Report, Davis-Besse Nuclear Power Station, Oak Harbor, Ohio: prepared for FirstEnergy Nuclear Operating Company, January 16.H 9 Environmental Resources Management, 2008, Groundwater Monitoring Well Installation

& Monitoring Report, Davis-Besse Nuclear Power Station, Oak Harbor, Ohio: prepared for FirstEnergy Nuclear Operating Company, March 18.

Attachment L-11-165 Page 11 of 12 H 10 First Energy, 1998, letter from J.H. Lash, Plant Manager, Davis-Besse Nuclear Power Station, to C. Zipp, State Fire Marshall Office, regarding Underground Storage Tank Overfill Release Report, Incident Number 6281145-00, September 18.H 11 FirstEnergy Nuclear Operating Company, 2007, letter from V.A. Kaminskas, Director -Site Operations, to A. Gall, Division of Surface Water, Ohio Environmental Protection Agency, regarding Submittal of 2006 Annual Sludge Disposal Report for the Davis-Besse Nuclear Power Station, January 29.H 12 FirstEnergy Nuclear Operating Company, 2008, letter from V.A.Kaminskas, Director -Site Operations, to R. Zuzik, Division of Surface Water, Ohio Environmental Protection Agency, regarding Submittal of 2007 Annual Sludge Disposal Report for the Davis-Besse Nuclear Power Station, January 18.H 13 FirstEnergy Nuclear Operating Company, 2009, letter from B. Allen, Vice President

-Nuclear, to A. Gall, Sewage Sludge Coordinator, Ohio Environmental Protection Agency, regarding Submittal of the 2008 Annual Sludge Disposal Report for the Davis-Besse Nuclear Power Station, January 23.H 14 FirstEnergy Nuclear Operating Company, 2010, letter from P.M. Boissoneault, Manager, Site Chemistry, to A. Gall, Sewage Sludge Coordinator, Ohio Environmental Protection Agency, regarding Submittal of the 2009 Annual Sludge Disposal Report for the Davis-Besse Nuclear Power Station, January 21.H 15 FirstEnergy Nuclear Operating Company, 2011, letter from P.M. Boissoneault, Manager, Site Chemistry, to A. Gall, Sewage Sludge Coordinator, Ohio Environmental Protection Agency, regarding Submittal of the 2010 Annual Sludge Disposal Report for the Davis-Besse Nuclear Power Station, January 25.H 16 FirstEnergy, 2010, letter from S.F. Brown, Senior Engineer, to R. Zuzik, Division of Surface Water, Ohio Environmental Protection Agency, regarding National Pollutant Discharge Elimination System Permit Renewal Application, Davis-Besse Nuclear Power Station, EPA ID No. OH0003786, Permit No. 21B00011*ID, October 21.H 17 OEPA, 2010, letter from E. Swindall, Division of Water, to FirstEnergy Nuclear Gen Corp -Davis-Besse, regarding Preliminary Compliance Review of Discharge Monitoring Report, November 20.H 18 OEPA, 2010, letter from E. Swindall, Division of Water, to FirstEnergy Nuclear Gen Corp -Davis-Besse, regarding Preliminary Compliance Review of Discharge Monitoring Report, September 21.H 19 Davis-Besse, undated, Graphs of tritium in wells Attachment L-11-165 Page 12 of 12 Socioeconomics, Environmental Justice & Land Use S 1 EJS4, 5_Support Payments & Property Values S 2 EJS3_Site Pop List_2-25-09 (county sort)S 3 EJS3_ATTCH EJS-3 S 4 EJS2_I10-120 2009 Annual Rad Effluent Release Rpt S 5 All 3 U.S. Government Leases for Ottawa Wildlife Refuge S 6 Formal documentation for land swap agreement (if there is one)Cultural C 1 Copies of photographs (6, 7, 15, 18, and 19 on flash drive at audit)demonstrating the level of disturbance on the industrialized portions of the plant.C 2 Draft Final Preliminary Assessment Report: Locust Point Anti-Aircraft Artillery Firing Area, FUDS Property No. G050H0996, Nov 2010, 2 volumes, prepared by Shaw Environmental for Army Corps of Engineers.

Request for Docket.RESPONSE References The requested documents comprise two binders and are provided as Enclosure C -Binder 1 of 2, and Enclosure C -Binder 2 of 2, with the following exceptions and clarifications:

AM 5 TRC Environmental Corporation, Emission Inventory Report, Centerior Energy Corporation, Davis-Besse Nuclear Power Station, Oak Harbor, Ohio, February 10, 1995.This document is Confidential and is not provided due to Attorney-Client Privilege.

S 6 Formal documentation for land swap agreement (if there is one)No land swap agreements were located for the Davis-Besse Station property.C 2 Draft Final Preliminary Assessment Report: Locust Point Anti-Aircraft Artillery Firing Area, FUDS Property No. G050H0996, Nov 2010, 2 volumes, prepared by Shaw Environmental for Army Corps of Engineers.

Request for Docket.Volume 1 (Main Body) of Reference C 2 is provided in hard copy in Enclosure C -Binder 2 of 2.Volume 2 (Attachments) of Reference C 2 is provided on Compact Disk in Enclosure C -Binder 2 of 2 due to the size (>2000 pages) of Volume 2.

Enclosure A Davis-Besse Nuclear Power Station, Unit No. 1 (DBNPS)Letter L-1 1-165 Environmental Audit Needs List (RAI General 1)25 Pages (not including this cover page)

FENOC preliminary Audit information request status is in blue text following each request.DAVIS-BESSE NUCLEAR POWER STATION. UNIT NUMBER I LICENSE RENEWAL APPLICATION SITE ENVIRONMENTAL AUDIT INFORMATIONAL NEEDS The following pages (i.e., pages 2 -2 5) of this document contain a listing of information requested by the Nuclear Regulatory Commission (NRC) in preparation for the NRC License Renewal Environmental Audit, to be held March 7-11, 2011. FirstEnergy Nuclear Operating Corn pany (FENOC) provides the status of retrieving the requested information and amplifying information in blue text following each request, as appropriate, to assist the NRC in locating the requested information that is loaded onto computer flash drives for their use during the Audit. In some cases, the answer is only partially provided following the request, and additional information will be discussed between the NRC and FENOC subject matter experts during the Audit week. In other cases, the entire answer is provided following the request. As such, this document is provided to the NRC Audit Team as a tool to "jump-start" the NRC Audit activities, and is not meant to provide or document complete responses to all pre-Audit requests.Page 1 of 25 FENOC preliminary Audit information request status is in blue text following each request.DAVIS-BESSE NUCLEAR POWER STATION. UNIT NUMBER I LICENSE RENEWAL APPLICATION SITE ENVIRONMENTAL AUDIT INFORMATIONAL NEEDS The U.S. Nuclear Regulatory Commission (NRC) staff has reviewed the environmental report (ER) in the Davis-Besse Nuclear Power Station (DBNPS) license renewal application and has found it meets the requirements of 10 CFR 51.45. However, to develop the corresponding supplem ental environmental impact statement, a number of additional informational needs have been identified and outlined below. Please be prepared to discuss and/or have the following information and documentation available for review during the March 7-11, 2011, environmental site audit.General During specific plant area tours, please provide personnel knowledgeable in the pertinent technical area(s) (e.g., aquatic ecology, terrestrial biology, meteorology, etc.) to guide or accompany the tour and to field questions that may arise during the tour. In addition to resource-specific tours, interview time for NRC staff and licensee/contractor counterparts should also be scheduled Historic and Archaeological Resources 1. A map detailing the level of ground disturbance/fill at the plant, including documentation on how this level of disturbance was determined and approximate acreages.

Has this understanding of the level of disturbance been coordinated with the OH SHPO? In other words is the OH SH PO in agreement that these portions of the plant have been disturbed sufficiently as to preclude the possibility of any significant archaeological resources existing in these areas?No maps were identified that detail the level of ground disturbance

/ fill at the plant. However, the file "HA1, 2_DB Historical Photos.pdf" shows pictorially the level of ground disturbance on the site. Also, a significant amount of fill material was applied during construction.

2. A series of aerial photographs of the entire plant site and associated transmission line(s) (during pre-construction, construction, and post-con struction periods) looking at levels of disturbance that occurred during construction or since operation, whether any historic structures or possible sites are present on the property, and identifying any recent projects that will require a review of additional documentation.

No aerial photographs were identified for the transmission lines, since they were built in the late '70s by Toledo Edison. The file "HAl, 2_DB Historical Photos.pdf' shows pictorially the level of ground disturbance on the site. New structures (both temporary and permanent) are under construction to support the Page 2 of 25 FENOC preliminary Audit information request status is in blue text following each request.Reactor Vessel Head Replacement Outage scheduled to begin on October 1, 2011, although no aerial photographs are available.

3. USGS 7.5" topographic quadrangle maps of the plant and associated transmission line(s). I will need to take the quad maps with me to the OH SHPO to complete the independent file search.Google Earth maps were created to show vegetation images along the in-scope transmission rights-of-way (ROWs).4. Vegetation/land-use maps of the plant and associated transmission line(s).Figures 2.1-1 and 2.1-2 show, respectively, the land use within a 50-mile (80 kin)and 6-mile (10 km) radius of the Davis-Besse site. These figures also include the land use along the three in-scope transmission lines (Beaver, Lemoyne, and Bay Shore). The Google Earth maps for each transmission line show vegetation images along the in-scope transmission ROWs.5. Maps of ownership and land use of the Applicant's property and associated transmission lines. Copies of historic plat maps would be useful, if available.

The FirstEnergy Real Estate Department stated that there are literally thousands of maps and easement documents associated with the transmission lines.FENOC has provided two transmission line plan & profile drawings for each of the three transmission lines leaving the station property as an example of the types of drawings available.

These drawings show land ownership under each line in the ROWs.6. Applicant's Environmental Compliance Manual and any other environmental review procedures for land-disturbing activities (e.g., trenching, clearing, digging).The follow FENOC procedures are provided:* NOP-OP-2010, Rev. 5, "FENOC Environmental Evaluations"* NOP-WM-4007, Rev. 1, "Excavation

& Trenching Controls"* NOBP-OP-2000, Rev. 1, "FENOC Environmental Best Management Practices"* NOBP-OP-2000, DRAFT Rev. 2, "FENOC Environmental Best Management Practices"" NG-DB-00501, "Environmental Compliance Program" 7. Applicant's transmission line vegetation management plan, including mowing, herbicide application, and clearing; inspections and repair activities conducted by helicopters or other vehicles; standard operating procedures or guidelines for the Applicant and any contractors; technician training programs, and any regulations that restrict maintenance activities (e.g., looking for the depth of disturbance, especially with tree removal in a portion of the corridor).

Vegetation management Page 3 of 25 FENOC preliminary Audit information request status is in blue text following each request.procedures for the site and associated transmission line(s), looking specifically for special procedures to avoid impacts to historic and archaeological resources.

The "FirstEnergy Vegetation Management Specifications" document for maintaining transmission line ROWs is provided.

Also provided is file"HA7_Davis-Besse Site Veg Mgmt Contracts.pdf" for information for contracted mowing and landscaping of the site property.

See also file "HA6, 7_NOP-WM-4007 Excavation

& Trenching Controls_R1 .pdf" for digging and excavating.

8. Information on grounds maintenance/management around less-developed areas of the plant site. Have someone available who can speak to environmental management activities on the leased lands for the Ottawa National Wildlife Refuge and the Magee Marsh Wildlife Area and compliance with the National Historic Preservation Act.The U.S. Fish and Wildlife Service (US FWS) provides environmental management oversight of the marshes on site and at the Ottawa National Wildlife Refuge. FENOC works together with the USFWS to manage the marsh on site.9. Documentation of development projects that have occurred on the property since the construction of Unit 1, (e.g. landscaping, fencing, parking areas, etc) to determine how historic and archaeological resources were considered.

What materials are used by the staff to determine whether the SH PO should be consulted?

Any survey or mitigation reports performed in conjunction with the plant or transmission line(s), or for other/subsequent plant a ctivities.

Discussion with FENOC Construction Services on site revealed that no development projects in recent memory have occurred on undisturbed ground.The disturbance of the site property was significant during original construction due to the use of "borrow pits" (now ponds) for fill material.

These borrow pits are spread across the station property.

For any excavation work, see file "HA6, 7, 9_NOP-WM-4007 Excavation

& Trenching Controls_Ri .pdf" for procedural guidance.10. Consultation letters and other documentation indicating correspondence with the SHPO and Federally recognized Native American Tribes that have aboriginal ties to the project area.Agency consultation correspondence is located in ER Attachment C. SHPO correspondence is located on pages C-42 through C-48. There are currently no Tribal Historic Preservation Officers in Ohio.11. Meetings requested a. Meeting with applicant staff and member of the grounds maintenance team to go over the Environmental Compliance Manual to determine how Page 4 of 25 FENOC preliminary Audit information request status is in blue text following each request.they manage resources, avoid impacting historic and archaeological resources, and deal with inadvertent discovery of historic and archaeological materials and human remains. Is any training required for staff?b. Meeting with applicant staff and ROW contractor to discuss ROW maintenance and any procedures in place regarding protection of historic properties along transmission line corridors.

12. Tours requested a. General site tour -would like to see historic site in SE corner of property if possible.b. Transmission line tour (including any archaeological sites recorded along the line)Page 5 of 25 FENOC preliminary Audit information request status is in blue text following each request.Terrestrial Resources 1. In Sect 2.5 of the Environmental Report (ER), provide updated county lists of Federal and State listed and candidate species occurring or potentially occurring at the Davis-Besse site and in Ottawa, Lucas, Wood, and Sandusky counties, where the transmission line corridors traverses.

Current referenced data from ODNR and USFWS in table 2.5-1 and possibly Table 2.5-2 are over two years old.The Ohio Department of Natural Resources (ODNR) updated the list of wildlife that are endangered, threatened, species of concern, special interest, extirpated, or extinct in October 2010 (ODNR 2010). Attachment TR-1 includes these data for Ottawa, Lucas, Wood, and Sandusky counties (ODNR 2011).

References:

ODNR 2010. Ohio Department of Natural Resources (ODNR), Division of Wildlife, Wildlife that are Endangered, Threatened, Species of Concern, Special Interest, Extirpated, or Extinct in Ohio, Publication 356, October 2010.ODNR 2011. Ohio Department of Natural Resources (ODN R), Ohio State-listed Species by County, http://www.dnr.state.oh.us/Home/Rare Plants/RarePlantSpeciesbvCount/tabid/2 0404/Default.aspx, accessed 02/21/2011.

2. What Federally and State-listed species have actual known occurrences at the Davis-Besse site or along the entire transmission line corridors?

Table 2.5-2 combines known with potential occurrences.

a. Beaver Line -Ottawa and Sandusky counties b. Lemoyne Line -Ottawa, Sandusky and Wood counties c. Bay Shore Line -Ottawa and Lucas counties FENOC is aware of bald eagles on site property (in the marsh) and along transmission lines.3. Please incorporate onto a copy Figure 3.1-1 in the ER or a comparable figure the permanent and temporary structures proposed to support refurbishment, such as the proposed 12,000 sq ft permanent storage facility and other structures discussed in Sect. 3.2.See file "TR3_Site Layout for New Structures_12-7-1 0.pdf'.4. In Sect. 4.10.1 of the Environmental Report (ER), refurbishment work is discussed in relation to following requirements of the USFWS and ODNR in order to protect listed species. In 4.10.2 of the ER, penultimate paragraph, the ER states "... transmission line maintenance is conducted in accordance with FE Page 6 of 25 FENOC preliminary Audit information request status is in blue text following each request.policies that are protective of threatened or endangered species." P lease provide a copy of FE's vegetative management policies and/or plan to protect Federally and State-listed listed species at the site and along the transmission line corridors.

Sect. 3.1.4 references transmission line maintenance activities (FE 2007), but does not describe maintenance activities designed specifically to protect Federally-listed species.The file "TR4, 5_FirstEnergy Xmiss Line Veg Mgmt Specifications.pdf' for maintaining transmission line ROWs is provided.

Also provided is file "TR4, 5_Davis-Besse Site Veg Mgmt Contracts.pdf' for information for contracted mowing and landscaping of the site property.

See also file "TR4_NOBP-OP-2000_Env Best Mgmt Practices.pdf' for bald eagles and Indiana bats.5. Please provide a copy of your vegetative management plan to control invasive plant species on site and along the transmission line corridors.

The file "TR4, 5_FirstEnergy Xmiss Line Veg Mgmt Specifications.pdf" for maintaining transmission line ROWs is provided.

Also provided is file "TR4, 5_Davis-Besse Site Veg Mgmt Contracts.pdf' for information for contracted mowing and landscaping of the site property.6. Please provide the following References

a. Chapter 2.2.2.4 i. USFWS 2009b. U.S. Fish and Wildlife Service Critical Habitat Portal, http://crithab.fws.qov/index.issp , accessed March 24, 2009.Provided.b. Chapter 2.4.1 i. ODNAP 2009a. Ohio Department of Natural Resources, Division of Natural Areas and Preserves, Ohio Natural Heritage Database.Lists of Preserves, Significant Ecological Features, Critical and Outstanding Habitats and Threatened or Endangered Speci es, March 18, 2009.Provided.ii. ONWRA 2009. Ottawa National Wildlife Refuge Association, http://www.onwra.com/our-refuqe.html , accessed March 23, 2009.Provided.Page 7 of 25 FENOC preliminary Audit information request status is in blue text following each request.c. Chapter 2.4.2 FirstEnergy 2008. Wetlands Management and Nature Education Programs:

Marsh Management at Davis-Besse Nuclear Power Station, http://www.firstenergvcorp.com/environmental/New Initiatives/Wet lands Management Nature Education Program.html, accessed March 21, 2009.Provided.ii. Campbell 1995. The Marshes of Southwestern Lake Erie, Ohio State University Press, Athens, Ohio.Provided.iii. USFWS 2009c. Ottawa National Wildlife Refuge Complex Comprehensive Conservation Plan, U.S. Fish and Wildlife Service, http://www.fws.gov/m idwest/Planning/ottawa/index.html

, accessed March 23, 2009.Provided.iv. GORP 2009. Great Outdoor Recreation P ages, Ottawa National Wildlife Refuge, http://qorp.away.com/ciorp/resources/us nwr/oh ottaw.htm, accessed March 26, 2009.Provided.v. Herdendorf, C.E., 1987. The Ecology of Coastal Marshes of Western Lake Erie: A Community Profile, U.S. Fish and Wildlife Service, Biological Report 85(7.9).Provided.vi. Bolsenga and Herdendorf 1993. Lake Erie and Lake St. Clair Handbook, Wayne State University Press, Detroit, Michigan.Provided.Page 8 of 25 FENOC preliminary Audit information request status is in blue text following each request.vii. ODNAP 2009c. Ohio Department of Natural Resources, Division of Natural Areas and Preserves.

Ohio's Five Physiographic Regions, http://www.dnr.state.oh.us/Hom e/Nature/FivePhysiographicReq io ns/tabid/871/Default.aspx, accessed April 1, 2009.Provided.viii. ODNAP 2009d. Ohio Department of Natural Resources, Division of Natural Areas and P reserves.

Invasive Plants of Ohio, http:/lwww.dnr.state.oh.us/tabid/2005/Def ault.aspx, accessed April 1,2009.Provided.ix. MIPN 2009. Midwest Invasive Plant Network, Flowering Rush (Butomus Umbellatus), http://mipn.org/Mi dwest%201nvasives%

2OFact%20Sheets/P DF/flo werinqrush.pdf , accessed April 1, 2009.Provided.d. Chapter 2.5 i. Downhower 1988. The Biogeography of the Island Region of Western Lake Erie, Ohio State University Press, Columbus, Ohio.Provided.ii. Ewert and Rodewald 2008. Managing Habitats for migrating birds in the Western Lake Erie basin: A Guide to Landscaping and Land Management, The Nature Conservancy.

Provided.iii. FirstEnergy 2008. Wetlands Management and Nature Education Programs:

Marsh Management at Davis-Besse Nuclear Power Station, http://www.firstenerqycorp.com/environmental/New Initiatives/Wet lands Manaqement Nature Education Procqram.html, accessed March 21, 2009.Provided.Page 9 of 25 FENOC preliminary Audit information request status is in blue text following each request.iv. Herdendorf, C.E. and S.E. Herdendorf 1983. Flora and Fauna of the Islands Region of Western Lake Erie, Center for Lake Erie Area Research, Report# 285, July 1983.Provided.v. USFWS 2008. Lake Erie Water Snake Fact Sheet, U.S. Fish and Wildlife Service, http://www.fws.qov/midwest/endangered/reptiles/le-f acts. html , accessed April 1, 2009.Provided.e. Chapter 2.8.1 i. Erie 1995. Erie Township Land Use Plan, Erie Township, Ohio, September 1995.Provided.ii. Lucas 2008. Lucas County Profile, Ohio Department of Development, http://www.odod.state.oh.

us/research/FI LES /S0/lucas.

pdf, accessed March 7, 2009.Provided.iii. Ottawa 2008. Ottawa County Profile, Ohio Department of Development, http://www.odod.state.oh.us/research/FILES/SO/ottawa.pdf

, accessed March 7, 2009.Provided.iv. Sandusky 2008. Sandusky County Profile, Ohio Department of Development, http://www.odod.state.oh.us/research/F ILES/S0/sandusky.pdf, accessed March 7, 2009.Provided.Page 10 of 25 FENOC preliminary Audit information request status is in blue text following each request.f. Chapter 2.9.6 i. USFWS 2009. U.S. Fish and Wildlife Service, Refuge Profiles, http://www.fws.-gov/refuqes/profiles/index.cfm?id=31540, accessed April 14, 2009.Provided.g. Chapter 2.12.i. USACE Locust Point Report. Findings anticipated October 2010 (paragraph 4). Is this available?

Provided.ii. EEPI 2009. Electric Energy Publictions, Inc, Electric Energy Online.com, http://www.electricenergyonline.com/?page=show-news&id=1 187 72 , accessed July 8, 2010.Provided.iii. FECorp 2009. FirstEnergy Corp., Bay Shore Plant Fact Sheet, http://www.firstenerqvcorp.com/environmental/files/Fact Sheets/B ay Shore Plant FS %2808-2007%29.pdf, accessed 4/3/2009.Provided.iv. FENOC 2010. Updated Safety Analysis Report (USAR) Davis-Besse Nuclear Power Station No. 1, Docket No: 50-346, License No: NPF-3, FirstEnergy Nuclear Operating Corn pany (FENOC), Revision 27, June 2010.Provided.v. OPSB 2003. Ohio Power Siting Board, 2003 Annual Report, http://www.puco.ohio.gov/em plibrary/files/media/OPSB/2003OPS BAR.pdf, accessed April 3, 2009.Provided.vi. OPSB 2007. Ohio Power Siting Board, 2007 Annual Report, http://www.puco.ohio.qov/em plibrary/files/media/OP SB/2007OPS BAR.pdf , accessed April 3, 2009.Provided.Page 11 of 25 FENOC preliminary Audit information request status is in blue text following each request.vii. USEPA 2009. U.S. Environmental Protection Agency, Envirofacts Warehouse, http://oaspub.epa.,ov/enviro/ef home3.html?p zipcode=wood%2 C+oh&p type=county ,accessed March 26, 2009.Provided.h. Chapter 3.1.1 i. FENOC 2010. Updated Safety Analysis Report (USAR) Davis-Besse Nuclear Power Station No. 1 Docket No: 50-346 License No: NPF-3, FirstEnergy Nuclear Operating Corn pany (FENOC), Revision 27, June 2010. Sect 8.1.1.Provided.i. Chapter 3.1.2 i. FENOC 2009. FENOC Letter L-09-175, NRC Quarterly Performance Indicators Including Monthly Operating Report Data (P-50), July 10, 2009.Provided.j. Chapter 3.1.4 i. FE 2007. FirstEnergy Vegetation Management Specifications, FirstEnergy Forestry Services, Revision 2007.Provided.Page 12 of 25 FENOC preliminary Audit information request status is in blue text following each request.Aquatic Ecology 1. Cooling and Auxiliary Water Systems a. What is the average water velocity at the intake structure?

The initial intake structure is the intake crib in the lake, as noted in USAR Section 2.2.3.5 (page 2.2-3). Acccording to NRC NUREG-75/097, the Final Environmental Statement related to operation dated October 1975, the maximum velocity is approximately 0.25 feet-per-second (fps), the velocity at nominal flow is approximately 0.12 fps and the expected velocity at average flow is approximately 0.10 fps. The velocity in the Intake Structure into the plant is less than 0.6 fps b. What is the average volume of water taken in by the plant per period of time (either day, month, or year)?See "AE1 .b" files showing annual water withdrawal reports for 2006-2010.

c. Does the cooling system intake include any other features or structures (such as trash racks or traveling screens) that prevent the intake of debris or biota other than the motor-operated strainers described in Section 3.1.3.1 of the Environmental Report? If such features or structures exist, please provide a description of their operation.

Trash racks and traveling screens are shown on USAR Figure 2.4-21.That figure is almost identical to Fig. 3.7 on page 3-11 of the AEC Final Environmental Statement related to construction (FES-CP) dated March 1973. The trash rack and traveling screen functions are described on SD-018 page 2-4, Section 2.1.2.2. That description is functionally the same as the description of the "Intake pumps and screens" on page 3-9 of the AEC FES-CP. NRC NUREG-75/097, the Final Environmental Statement related to operation dated October 1975 states in Section 3.3.2 on page 3-1 that, "The descripti on of the basic design and location of the intake pumps and screen and discharge structure presented in FES-CP is still valid." 2. Invasive Species a. Have any invasive aquatic species (such as zebra mussels) been documented on site? If so, please explain any applicable treatment plans to system water to minimize the impact of these species.Yes, zebra mussels. As described in USAR Section 2.2.3.6.1 (page 2.2-4), Sodium Hypochlorite and Sodium Bromide are used for water treatment.

Page 13 of 25 FENOC preliminary Audit information request status is in blue text following each request.3. Please provide a copy of the following ER references:

a. Cooper, C.L., J.J. Mizera, and C.E. Herdendorf 1981. Distribution, Abundance and Entrainment Studies of Larval Fishes in the Western and Central Basins of Lake Erie, CLEAR Technical Report No. 222, Ohio State University Center for Lake Erie Area Research (CLEAR), October 1981.Provided.b. Reutter, J.M., C.E. Herdendorf, M.D. Barnes, and W.E. Carey 1980.Environmental Evaluation of a Nuclear Power Plant on Lake Erie, Project No. F-41-R, Final Report Study 1, CLEAR Technical Report No. 181, Ohio State University Center for Lake Erie Area Research (CLEAR), Columbus, Ohio. September 1980.Provided.c. Reutter, J.M. 1981a. Fish Egg and Larvae Entrainment at the Davis-Besse Nuclear Power Station During 1980, CLEAR Technical Report No.211, Ohio State University Center for Lake Erie Area Research (CLEAR), Columbus, Ohio, February 1981.Provided.d. Reutter, J.M. 1981b. Fish Impingement at the Davis-Besse Nuclear Power Station During 1980, CLEAR Technical Report No. 212, Ohio State University Center for Lake Erie Research (CLEAR), Columbus, Ohio, February 1981.Provided.4. Please provide a topographic m ap of the Davis-Besse site and vicinity that includes the following data, as available a. The full length of all in-scope portions of transmission lines b. Any significant natural heritage areas c. Major stream and river crossings along transmission lines d. Any known locations of threatened, endangered, or other protected species Google Earth maps were created to show the transmission lines beginning at the Davis-Besse site, and major road, stream and river crossings along the in-scope transmission ROWs.Page 14 of 25 FENOC preliminary Audit information request status is in blue text following each request.Air Quality and Meteorology

1. Provide a description of the general climate and local meteorology around the Davis-Besse Nuclear Power Station (e.g., annual and seasonal wind speeds and prevailing wind direction) and most recent five-year onsite meteorological data along with data documentation (e.g., data format, units).See ER Section 2.10, pages 2.10-1 and 2.10-2.2. Provide a reference cited in Section 2.10, ER: NOAA 2009. NOAA e-mail, J. Kosanik to J, Snooks (AREVA), National Weather Service, March 3, 2009.Provided.3. Provide historic severe weather events and damages to the site or nearby areas, including tornadoes, waterspouts, and other extreme weather (e.g., hail, blizzards)

See Attachment AQ-1, which lists various storm event data for Ottawa County, Ohio, which encompasses the Davis-Besse site. The data were gathered from the National Climatic Data Center (NCDC) Storm Event database, which currently contains information from January 1950 through November 2010. The span of data, however, depends on the storm event type. For example, tornado data are from 1950 to 2010, while drought data are from 1993-2010.

Below is a list of the storm event data included in Attachment AQ-1 and the corresponding data period. The information includes the location of the storm event, date, time, type, magnitude, number of deaths and injuries, as well as property and crop damage, as applicable.

Additional details of each storm event are available by clicking on the highlighted area in the "Location or County" column.* Drought (1993-2010)

• Hail (1955-2010)

• High Winds (1993-2010)

• Hurricanes and Tropical Storms (1993-2010)

• Lighting (1993-2010)

• Snow & Ice (1993-2010)

• Tornadoes (1950-2010)

• Thunderstorm Winds (1955-2010)

• Waterspouts (1993-2010)

Snow and ice events since 1993 account for the largest cost, primarily as injuries (64) and property damage ($163M) in the Davis-Besse vicinity.During the same data span, high winds caused the most deaths (4) and the six droughts produced the largest crop damage ($200M). There have been Page 15 of 25 FENOC preliminary Audit information request status is in blue text following each request.nine tornadoes in Ottawa County since 1950 and five waterspouts since 1993. The tornadoes caused 17 inj uries and $41 M in property damage, but no damage was recorded from the waterspouts.

Due to its Midwest location, there have been no hurricanes or tropical storms recorded in the Davis-Besse vicinity since 1993.See also 3 files that provide information about the tornado that struck the station in 1998... files start with "AQ3".4. Provide a knowledgeable individual to discuss the following aspects of meteorological data acquisition and management:

a. Type of instruments and instrument heights b. Meteorological data transmission system operating procedures

c. Procedures for calibration and maintenance of on-site meteorological instruments

d. Procedures for collection, evaluation, validation, and management of meteorological data, including quality control procedures

e. Procedures for reconciling any data anomalies and for dealing with periods when no data are collected See files in the folder that start with "AQ4".5. Provide copies of relevant sections and correspondence with the Ohio Environmental Protection Agency or Ottawa County relating to: a. Operating permits (e.g., site-wide air permit or individual permits)b. Air emissions inventory for criteria and hazardous air pollutants (HAPs)for the most recent five years c. Recent five-year Annual Operating Report and/or Compliance Status Reports submitted to the agency and Notices of Violation, if any d. Data maintained on site that demonstrate compliance with applicable regulations (e.g. operating records for emergency generators that demonstrate eligibility for exempt status).See files in the folder that start with "AQ5".Page 16 of 25 FENOC preliminary Audit information request status is in blue text following each request.6. Provide a knowledgeable individual to discuss the following aspects of facility operation:

a. Details of stationary and mobile sources of criteria and hazardous air pollutants operating on Davis-Besse NPS, including, as appropriate, horsepower ratings, fuel consumption, pollution control equipment and its control efficiency, operating records, estimated annual emissions, etc.b. Details on the preventative maintenance (PM) schedules for emergency generators and other internal combustion engine (ICE) sources on Davis-Besse NPS (e.g. emergency fire water pumps)c. Results of any air pollution control equipment tests/performance evaluations conducted for stationary sources of criteria pollutants

d. Details on the procedures in place for maintenance and repair of HVAC equipment containing ozone depleting substances, including HVAC systems that may be contaminated with airborne radioactive species e. General specifications for the natural-draft cooling tower such as dimensions, operating hours per year, air and water flow rates, drift loss rate, total dissolved solids concentration, heat rejection rate, drift droplet diameter, etc.f. Information on the chemicals used in treatment of the cooling water in the cooling water system and any reported property/crop damage See files in the folder that start with "AQ6".7. Are there expected upgrade/replacement/retirement activities for facility equipment/operation listed in Item 6 that could increase or decrease air emissions over the license renewal period?No information.

8. Provide the most recent site-wide emission inventory data (annual) for greenhouse gases (GHGs): a. Include emissions from all stationary combustion sources, mobile sources, and other sources b. If no GHG emission data are available, provide data to estimate GHG emissions, e.g., i. Combustion sources along with capacity, activity level (e.g., 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> per year), fuel type, fuel consumption rates Page 17 of 25 FENOC preliminary Audit information request status is in blue text following each request.ii. Mobile sources (including corn muters, visitors, support, and delivery vehicles) along with number of vehicles, average daily trips, vehicle type, travel distance per trip iii. Other sources (e.g., landfill, water reclamation facility, leakage of refrigerant), if any Information to be provided during the Air Quality & Meteorology Session.9. Meetings Requested a. Meeting with applicant staff in charge of meteorological towers and meteorological data b. Meeting with applicant staff in charge of air permits and emission inventories

c. Meeting with applicant staff in charge of equipment operation and maintenance

10. Tours Requested a. General site tour -site land cov er/buildings/structures, site boundaries, and nearby sensitive receptors (e.g., residences, schools)b. Major air emission sources (e.g., boilers, emergency generators) and control equipment c. Onsite meteorological towers (primary and backup)Page 18 of 25 FENOC preliminary Audit information request status is in blue text following each request.Hydrology 1. information sources cited in the ER, in particular ERM 2007, ERM 2008, and FENOC 2010 (UFSAR).Provided.2. a knowledgeable individual who can discuss design and flow rates of the site water system, including the cooling water system, service water system, firewater system, wastewater treatment plant, potable water system, and other water systems.Information to be discussed during the Hydrology Session.3. a diagram of the water systems with their flow rates, including blowdown and evaporation.

See file "HY3, 5, 7_L-10-287_NPDES Permit Renewal_2010-10-21.pdf", page 14 of 92.4. documentation on any changes to chemical additives or treatments to the various water systems beyond those detailed in the current NPIDES permit in the ER's Appendix B.Information to be discussed during the Hy drology Session.5. any recent NPDES renewal application.

See file "HY3, 5, 7_L-10-287_NP DES Permit Renewal_2010-10-21.pdf".

6. discharge monitoring summary reports.See files labeled "HY6".7. a map of all outfall locations, including stormwater.

See file "HY3, 5, 7_L-10-287_NPDES Permit Renewal_2010-10-21.pdf", page 84 of 92. See also map and picture labeled with "HY7".8. a knowledgeable individual who can discuss any onsite soil or groundwater contamination (nuclear or non-nuclear) events and past or current remediation systems.Information to be discussed during the Hydrology Session.Page 19 of 25 FENOC preliminary Audit information request status is in blue text following each request.9. documentation of any associated cleanup plans, monitoring reports, state communications, permits, etc.Information to be discussed during the Hydrology Session.10. a knowledgeable individual who can discuss groundwater monitoring for tritium.Information to be discussed during the Hydrology Session.11. report(s) summarizing data of tritium monitoring effort to date, including graphed concentration trends and hydrogeologic cross sections showing stratigraphic data and monitoring well screen locations.

Information to be discussed during the Hy drology Session.12. the State water withdrawal and use permit.Information to be discussed during the Hydrology Session.13. a knowledgeable individual familiar with any site dewatering systems.Information to be discussed during the Hydrology Session.14. any Notices of Violation regarding discharges, stormwater, or accidental releases of chemicals or hydrocarbons through spills or leaks, along with any documentation on mitigation efforts or closure.See files labeled with "HY14".15. stormwater management plan.Information to be discussed during the Hydrology Session.16. stormwater general permit.Information to be discussed during the Hydrology Session.17. the spill prevention control and countermeasures plan.See file labeled with "HY17".18. a knowledgeable individual who can discuss a. stormwater management, Page 20 of 25 FENOC preliminary Audit information request status is in blue text following each request.b. sampling program and sampling results for stormwater, stormwater sedimentation pits, or sewage sludge, c. past or possible future dredging and spoils disposal.19. Tour requests a. -site hydrologic features, including intake and discharge systems, monitoring wells, shoreline protection works, cooling system, outfalls, stormwater system, diesel tanks, chemical storage.b. -any current or past soil or groundwater remediation locations c. -discharge outfalls to Lake Erie, the Toussaint River, or other surface water bodies.Page 21 of 25 FENOC preliminary Audit information request status is in blue text following each request.Environmental Justice and Socioeconomics

1. Information about any observed subsistence consumption behavior patterns-specifically fish and wildlife consumption-by minority and low-income populations in the vicinity of Davis-Besse.

This subsistence consumption behavior could consist of hunting, fishing, and trapping of game animals and any other general food gathering activities (e.g., collecting nuts, berries, and other plant material) conducted by minority and low-income individuals in the vicinity of Davis-Besse.

Subsistence information is difficult to collect, partially because it is relatively site specific and because it is difficult to differentiate between subsistence uses and recreational uses of natural resources.

Nonetheless, a large volume of information about observed subsistence consumptive behavior patterns by minority and low-income populations, principally Native American communities, is available from studies and analyses performed largely in the 1980s by the Alaska Department of Fish and Game, Division of Subsistence (ADFG 2011). This information indicates that subsistence harvests of fish, land mammals, and other wild resources tend to increase in areas away from urban centers, not connected by roads to urban areas (ADFG 1987, Page 56). In general, subsistence consumption activities are in addition to or replace portions of the foods that might be bought from businesses, and thus can represent reduced costs of living. They also often represent an important part of the cultural identity or lifestyle of the participants.

The area in the vicinity Davis-Besse likely has varied subsistence consumption for several reasons. First, a large portion of the vicinity has restricted assess to the public due to the number of state and national parks as well as the large area committed to agriculture (see Sections 2.8.1 and 2.9.6 and Figure 2.1.2). Second, the minority and low-income populations in the region are small (see Section 2.6.2 and Figures 2.6-1 through 2.6-8). As a result, subsistence consumption of wildlife in the vicinity of Davis-Besse is anticipated to be less than other Ohio areas. Subsistence consumption of fish is likely larger in the vicinity due to the close proximity of Lake Erie.However, the percentage of fish subsistence consumption versus recreational uses is most likely small, again due to the small minority and low-income population in the region.

References:

ADFG 1987. Alaska Dept. of Fish and Game, Div. of Subsistence,"Subsistence Economies in Alaska: Productivity, Geography, and Development Impacts," Arctic Anthropology, Vol. 24, No. 2, pp. 56-81, 1 987.ADFG 2011. Alaska Dept. of Fish and Game, Div. of Subsistence,"Publications," available at Page 22 of 25 FENOC preliminary Audit information request status is in blue text following each request.http://www.adfg.alaska.gov/sf/publications/index.cfm?ADFG=

main.mainSearc hSubmit, accessed 2/21/2011.

2. Information about current or past wildlife sampling and testing of game animals such as deer, squirrel, turkey, pheasant, duck, fish and other game birds and animals that may have been conducted in the vicinity of Davis-Besse.

Wildlife sampling and testing may have been conducted before, during, and after plant construction and in the early days of plant operation, but was discontinued after determining that tissue samples consistently showed no significant or measurable radiological impact on the environment from plant operations.

FENOC has a continuing comprehensive Radiological and Environmental Monitoring Program (REMP) at Davis-Besse to assess the impact of site operations on the environment.

Samples are periodically collected from both aquatic and terrestrial pathways.

The aquatic pathways include fish, surface waters and sediment.

The terrestrial pathways include airborne particulates and radioiodine, milk food products, and direct radiation.

During 2009, as well as during previous years, analyses of collected samples as part of the REMP continue to demonstrate that the dose to a member of the public from Davis-Besse operations (through aquatic and terrestrial pathways) remains significantly below the federally required does Ii mits specified by the NRC in 10 CFR Part 20 and the EPA in 40 CFR Part 190 (F ENOC 2010).3. Table 3.4-1 provides percent of workforce by county. As supporting documentation, please provide the actua I number of Davis-Besse permanent (employed for more than one year), on-site employees and the residential distribution of permanent, on-site employees by county.Table 3.4-1 has been expanded to include anoth er column that provides the num ber of workforce by county for each of the three states (Ohio, Michigan, and Pennsylvania) where the workforce resides. See Attachment EJS-3.4. In addition to property tax payment information presented in Section 2.7 of the ER, please describe any other major annual support payments, one-time payments, and other forms of non-tax compensation (if any) provided to local organizations, communities, and jurisdictions (e.g., county, municipality, townships, villages, incorporated places, and school districts) on behalf of Davis-Besse.

See file labeled "EJS4, 5_Support Payments & Property Values.doc".

Page 23 of 25 FENOC preliminary Audit information request status is in blue text following each request.5. Also, please provide information about any changes in assessed property value or any other recent or anticipated payment adjustments that could result in notable increases or decreases in tax or other pay ments.See file labeled "EJS4, 5_Support Payments & Property Values.doc".

6. Data on the height of the tallest (visible from offsite locations) structures at Davis-Besse and general information on the visibility of plant facilities from various offsite locations.

The tallest structure at Davis-B esse is the natural draft cooling tower, which rises 493 feet above ground level. The containment building is the next tallest structure; it rises approximately 250 feet above ground level.Due to the relatively flat topography in the region and the close proximity of Lake Erie, the cooling tower is a prominent landmark and navigational aid. It's estimated visibility from offsite is approximately 27 miles (based on the approximation d-sqrt (1.5*h), where d is miles and h is feet), depending on the viewpoint.

Refurbishment activities will not include structures that rise above either the containment building or cooling tower. As a result, continued operation of Davis-Besse will remain consistent with the existing view shed and visual aesthetics will be unchanged.

7. Provide possible noise emissions from the site that could be a nuisance in the vici nity of Davis-Besse.

Also, provide information if complaints have been received at Davis-Besse concerning noise from operations heard offsite.Noise emissions from power plant operations during licensing renewal would be limited to continued industrial processes (switchyard, transformers, cooling tower)and communications.

No plant operation changes are anticipated.

Thus, off-site noise levels would continue to be the same and limited to the immediate vicinity of Davis-Besse.

Based on a query of condition reports, no formal complaints have been received since December 2000, when the current Corrective Action Program was implemented at Davis-Besse.

Page 24 of 25 FENOC preliminary Audit information request status is in blue text following each request.Radiation Protection

1. Please provide information on any abnormal or unusual spills and leaks of radioactive material that occurred on-site that are applicable to the criteria in 10 CFR 50.75(g) and the Nuclear Energy Institute's (NEI) Groundwater Protection Program.The 10 CFR 50.75(g) files are located in [2] 3-ring binders on the bookshelf in the NRC Audit room.2. Please provide information on any on-site disposals of low-level radioactive waste.Information to be discussed during the Radiati on Protection Session.3. Please provide information on the radiological groundwater protection program.See file labeled "RP3".4. Request that the tour cover the low-level radioactive waste storage location, radioactive effluent release points (routine and abnormal), radioactive effluent monitoring systems, and radiological environmental monitoring stations (primarily air monitoring stations, including if applicable, any collocated State monitoring stations and any nearby water, milk, or vegetation monitoring locations).

Page 25 of 25 Enclosure B Davis-Besse Nuclear Power Station, Unit No. 1 (DBNPS)Letter L-1 1-165 Site Map (RAIs General 3 and Cultural 2)1 Page (not including this cover page)

THIS PAGE IS AN OVERSIZED DRAWING OR FIGURE, THAT CAN BE VIEWED AT THE RECORD TITLED: "AERIAL MAP OR SITE PLAN (RAIs GENERAL 3 AND CULTURAL 2)" WITHIN THIS PACKAGE D-01