ML11201A062

Request for Additional Information for the Review of the South Texas Project, License Renewal Application (TAC Nos. ME4938 and ME5122)

ML11201A062
Person / Time
Site:	South Texas
Issue date:	08/04/2011
From:	Tam Tran License Renewal Projects Branch 2
To:	Gerry Powell South Texas
Tran T, 415-3617
References
TAC ME4938, TAC ME5122
Download: ML11201A062 (10)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 August 4, 2011 Mr. G. T. Powell Vice President, Technical Support and Oversight STP Nuclear Operating Company P. O. Box 289 VVadsworth, TX 77483

SUBJECT:

REQUESTS FOR ADDITIONAL INFORMATION FOR THE REVIEVV OF THE SOUTH TEXAS PROJECT LICENSE RENEVVAL APPLICATION (TAC NOS. ME4938 AND ME5122)

Dear Mr. Powell:

By letter dated October 25, 2010, STP Nuclear Operating Company (STPNOC), submitted an application pursuant to Title 10 of the Code of Federal Regulations Part 54 (10 CFR Part 54), to renew operating licenses NPF-76 and NPF-80 for South Texas Project, for review by the U.S. Nuclear Regulatory Commission (NRC or the staff). The staff is reviewing the information contained in the license renewal application and has identified, in the enclosure, areas where additional information is needed to complete the review.

These requests for additional information were discussed with Mr. Arden Aldridge, and a mutually agreeable date for the response is within 30 days from the date of this letter. If you have any questions, please contact me at 301-415-3617 or bye-mail at Tam.Tran@nrc.gov.

Sincerely, Tam Tran, Project Manager Reactor Projects Branch 2 Division of License Renewal Office of Nuclear Reactor Regulation Docket Nos. 50-498 and 50-499

Enclosure:

Requests for Additional Information cc w/encl: Listserv

SOUTH TEXAS PROJECT LICENSE RENEWAL APPLICATION REQUESTS FOR ADDITIONAL INFORMATION Terrestrial Ecology Document requests:

TER-1. Department of Army letter with enclosed map of wetland delineation [STPLR-422]

TER-2. STPNOC Site Environmental Compliance, Rev.13, OPGP03-Z0-0025, April 2011

[STPLR- 26]

TER-3. Austin Energy T-Line ROW Management Summary, January 1,2010 [STPLR-446]

TER-4. Austin Energy Tree Pruning and T-line Clearance Specs, November 7, 2005,

[STPLR-448]

TER-5. Pesticides and herbicides associated with operational maintenance of the transmission lines [STPLR-4101

-2 Aquatic Ecology Document requests:

AQ-1. McAden, D. C., G. N. Greene, and W. B. Baker 1984. Colorado River Entrainment and Impingement Monitoring Program, Phase Two Studies - July 1983-June 1984 (Report # 1). Prepared for South Texas Project by Ecology Division, Environmental Protection Department, Houston Lighting & Power Company. October.

AQ-2. McAden, D. C., G. N. Greene, and W. B. Baker 1985. Colorado River Entrainment and Impingement Monitoring Program, Phase Two Studies - July - December 1984 (Report # 2). Prepared for South Texas Project by Ecology Division. Environmental Protection Department. Houston lighting & Power Company. April.

AQ-3. Citation and documentation is needed for the following sentence that was included in the ER, Section 5.2: Based upon best professional judgment (BPJ) the TCEQ Water Quality Division has determined that the CWIS reflects BTA for AEI through use of a closed-cycle recirculating system.

AQ-4. "Essential Cooling Pond Fish Population Study." Prepared for STP Nuclear Operating Company by ENSR International. Houston, Texas, May 2002.

AQ-5. Texas Commission on Environmental Quality (TCEQ). 2007. Letter from Mr. Kelly Holligan, TCEQ, to Mr. R. A. Gangluff, STPNOC, dated June 27,2007, "Cooling Water Intake Structures Phase" Rules; South Texas Project Electric Generating Station; TPDES Permit No. WQOOO 1908000."- This letter (or other documentation) should state that the Main Cooling Reservoir (MCR) is not waters of the State.

AQ-6. "South Texas Project, Units 1 and 2, Environmental Report," Docket Nos. 50-498 and 50-499, July 1, 1974, and Subsequent Amendments.

AQ-7 Baker W. B., Green G. N. 1989, 1987-1988 Special Ecological Studies for the South Texas Project, Matagorda County, Texas. Final report March 1989. Houston, TX:

Houston lighting & Power Company. 34 p. [In Terrestrial Ecology section of STP NRC Environmental Audit Binder]

AQ-8. Ducks Unlimited and HPLC. 1996. Wetland Development Agreement for the Texas Prairie Wetland Project, Gulf Coast Joint Venture, between Ducks Unlimited, Inc., and Houston lighting & Power Co. October 23, 1996. 12 p. [In Terrestrial Ecology section of STP NRC Environmental Audit Binder]

AQ-9. ENSR Corporation. 2008. Ecological Survey Report-Habitat Assessment, Units 3 and 4 licensing Project. Prepared for STP Nuclear Operating Company. Wadsworth, TX:

ENSR. 34 p. [In Aquatic Ecology section of STP NRC Environmental Audit Binder]

-3 Human Health HP-1. Issue:

The applicant's evaluation identified five locations where the transmission lines exceeded the National Electrical Safety Code (NESC) recommended standard of 5 milliamperes for electric shock concern. However, the environmental report (ER) does not contain a discussion of any mitigation measures being considered for the locations where the electric shock potential exceeds the NESC standard.

Background:

As required by Title 10 of the Code of Federal Regulations (10 CFR) 51.53(c)(3)(ii)(H),

Section 4.13 of the STP ER contains an evaluation of the acute shock potential from the transmission lines within the scope of license renewal. The applicant's evaluation identified five locations where the transmission lines exceeded the NESC recommended standard of 5 milliamperes. For these transmission lines, the applicant's ER concluded

"... that electric shock is of MODERATE significance, because 1) there are few exceedances of the NESC standard, 2) the exceedances are a small percentage of the standard, 3) the locations of the exceedances are very remote or on private property, and 4) the transmission service providers have not received any complaints about induced-current shock. Accordingly, no mitigation measures are required." Hence, the ER does not contain a discussion of any mitigation measures being considered for the locations where the electric shock potential exceeds the NESC standard.

10 CFR 51.53(c)(3}(iii) states that the ER " ... must contain a consideration of alternatives for reducing adverse impacts, as required by 10 CFR 51.45(c), for all Category 2 license renewal issues ... " 10 CFR 51.45(c) states, "The environmental report must include an analysis that considers and balances the environmental effects of the proposed action, the environmental impacts of alternatives to the proposed action, and alternatives available for reducing or avoiding adverse environmental effects."

Requested Information:

Please provide additional information related to alternatives available for reducing or avoiding adverse environmental effects from those transmission lines that exceed the NESC standard.

-4 Water Resource Document requests:

WR-1. US Army Corps of Engineers (USACE) Permit No.1 0570 (Maintenance dredging of barge slip) (dated November 4,2005).

WR-2. USACE Permit No. SWG-1992-02707 (Maintenance dredging of intake) (dated July 21, 2009). [STPLR-472]

WR-3. Current TCEQ-issued TPDES permit (TPDES Permit No. WQ000190S000 issued July 21, 2005). [STPLR-05]

WR-4. TPDES permit renewal application (June 2009 and May 24,2007, letters)

WR-5. TCEQ 10 No. 1610103/1610051 (Operation of public potable water system(s))

WR-6. TCEQ Amendment to Certificate of Adjudication 14-5437A (Water rights for diversion and impoundment of Colorado River water). [STPLR-471]

WR- 7. Water Conservation Plan, STP Nuclear Operating Company, South Texas Project Electric Generating Station, Certificate of Adjudication 14-5437A, May 1, 2009, Revision 2 WR-S. OPOP02-LM-0001. Rev. 41 dated 2/1/2011. Reservoir Makeup Pumping Facility.

WR-9 Current groundwater operating permit issued by the Coastal Plains Groundwater Conservation District. [STPLR-46S]

WR-10. Conceptual Site Model for Units 1 and 2, Groundwater Protection Initiative, South Texas Project, Electric Generating Station, Wadsworth, Texas, Prepared by MACTEC Engineering and Consulting, Inc., Prepared for STP Nuclear Operating Company, Revision 1, May 20, 2009. [STPLR-375]

WR-11. A summary of historic and current (past 5 years) total dissolved solids (TDS) data for groundwater produced by STP production wells from the Deep Chicot Aquifer.

WR-12. TPDES Discharge Monitoring Reports (covering past 3 years).

WR-13. Annual groundwater use reports (covering past 5 years). [In Surface and Groundwater Tab of STP NRC Environmental Audit Binder; e.g., STPLR-13 (2006),

etc.]

WR-14. Annual surface water withdrawal reports for the Colorado River (covering past 5 years). [In Surface and Groundwater Tab of STP NRC Environmental Audit Binder; e.g., STPLR-14 (2006), STPLR-39 (2007), etc.]

WR-15. Data on tritium concentrations in groundwater and surface water observed since the MACTEC report (i.e., materials provided following the protected area tour) as follows:

-5

i. Spreadsheet of groundwater monitoring results (no title) for well #s 807-837; dates 2/15/2005-11/9/2010, 3 pages.

ii. "Tritium Results in PA Piezometer and New Monitoring Wells" (2005-2011),

graph iii. "Historical Comparison of Tritium Activity in Surface and Relief Well Water 1988-2011." Graph with attached spreadsheet, "Tritium in Owner-Controlled Groundwater.xls" (2005-2011), 2 pages.

iv. "Historical Comparison of Tritium Activity in Ground Water 1988-2011,"

1 page covering wells 255-271.

v. "Historical Comparison of Tritium Activity in Ground Water 1988-2010,"

includes 2011 data covering well #s 258, 270, 259, 235, 251.

vi. "Tritium Activity in Shallow Ground Water West of the Main Cooling Reservoir 2006-2011," 1 page covering well #s 271, 270, 258, 259.

vii. Spreadsheet with no title of annual frequency of piezometer well and windmills data, covering well #s 206-269, dates 2008-2011, 1 page.

viii. Spreadsheet with no title including "quarterly frequency," "old monitoring test wells," "piezometer wells," and "new monitoring wells," covering well #s 235, 251, 205, 258, 259, 266,270, and 271; dates 2005-2011 WR-16. STP Well Location Map (contained in the Field Log Book)

Clarification request:

WR-17.

Background:

Based on the document review and site audit, the staff understands that the #24 event has led to the highest level of tritium sampled in the protected area piezometer network. In accordance with (a) 10 CFR 51, Subpart A, Appendix B, Table B-1 and (b) Environmental Standard Review Plan (ESRP), NUREG-1555, Supplement 1, Sections 2.2.3 and 4.5, the staff requests source event documentation that contains relevant information for the review (e.g., cause, timing, volume, concentrations, etc.),

to assess what is typically known of TDS line failures and releases to the environment and possible impact on the groundwater quality.

Requested information:

For clarification purposes, the staff requests additional information related to releases to the subsurface that have occurred within the protected area as a result of TDS line failures, as noted in Section 2.3.4 of the ER and discussed in the MACTEC report (MACTEC, May 20,2009). The staff requests the applicable STP Condition Reports (CRs), for the #24 event shown in Table 6-1 and Figure 6-1 in the MACTEC report, be made available for review. The following related CRs are also requested for the review: CR 03 7595, CR 03-3951, and Activity No. 430966.

- 6 WR-18.

Background:

During the site audit tour of the protected area, the release of tritiated water to the ground surface and ultimately to groundwater from the Auxiliary Steam and Condensate Storage and Transfer Piping systems at each of the units was observed by the staff and described by the applicant. These discharges are also described briefly in the MACTEC report and mentioned in Section 2.3.4 of the ER. In accordance with (a) 10 CFR 51, Subpart A, Appendix B, Table B-1 and (b) ESRP, NUREG-1555, Supplement 1, Sections 2.2.3 and 4.5, the staff requests documentation to complete its review of groundwater quality degradation beneath the protected area.

Requested information:

For clarification purposes, the staff requests the proposal or planning documentation or both, including documentation of the existing steam condensate quantity and quality, related to the proposed engineering change to the "Auxiliary Steam and Condensate Storage and Transfer Piping" to eliminate the discharge of tritium directly to the ground surface. Further, please clarify and provide supporting documentation on the interception of these releases by (a) the sump(s) within the tendon gallery of each reactor containment building and (b) the sump water release point(s).

WR-19.

Background:

Section 4.5 of ER provides an estimated drawdown for the initial40-year period. The staff requests that the drawdown analysis be extended to encompass continued operation of production wells through the end of the proposed license renewal period. In accordance with (a)10 CFR 51, Subpart A, Appendix B, Table B-1 and (b)

ESRP, NUREG-1555, Supplement 1, Sections 2.2.2, 4.5, and 4.5.1, the staff requests this analysis for characterization of the potential impact of license renewal on off-site groundwater production wells located in the Deep Chicot Aquifer.

Requested information:

The staff requests the completion and submittal of an analysis of Deep Chicot Aquifer drawdown due to continued use of the STP production wells (including supporting calculations) by the applicant, for the original license period of 40 years plus the proposed license renewal period of 20 years.

WR-20. The staff requests (a) the correspondence concerning TCEQ's acknowledgement of STP's National Pollutant Discharge Elimination System permit renewal application acceptance and timely submittal and (b) progress towards completion of the new permit.

Letter to G.T. Powell from Tam Tran dated August XX, 2011

SUBJECT:

REQUESTS FOR ADDITIONAL INFORMATION FOR THE REVIEW OF THE SOUTH TEXAS PROJECT, LICENSE RENEWAL APPLICATION (TAC NOS. ME4938 AND ME5122)

DISTRIBUTION:

E-MAIL:

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August 4, 2011 Mr. G. T. Powell Vice President, Technical Support and Oversight STP Nuclear Operating Company P. O. Box 289 VVadsworth, TX 77483

SUBJECT:

REQUESTS FOR ADDITIONAL INFORMATION FOR THE REVIEVV OF THE SOUTH TEXAS PROJECT LICENSE RENEVVAL APPLICATION (TAC NOS. ME4938 AND ME5122)

Dear Mr. Powell:

By letter dated October 25,2010, STP Nuclear Operating Company (STPNOC), submitted an application pursuant to Title 10 of the Code of Federal Regulations Part 54 (10 CFR Part 54), to renew operating licenses NPF-76 and NPF-80 for South Texas Project, for review by the U.S. Nuclear Regulatory Commission (NRC or the staff). The staff is reviewing the information contained in the license renewal application and has identified, in the enclosure, areas where additional information is needed to complete the review.

These requests for additional information were discussed with Mr. Arden Aldridge, and a mutually agreeable date for the response is within 30 days from the date of this letter. If you have any questions, please contact me at 301-415-3617 or bye-mail at Tam.Tran@nrc.gov.

Sincerely, IRA!

Tam Tran, Project Manager Reactor Projects Branch 2 Division of License Renewal Office of Nuclear Reactor Regulation Docket Nos. 50-498 and 50-499

Enclosure:

Requests for Additional Information DISTRIBUTION: See next page ADAMS Accession No'.. ML11201A062 *concurred via e-mail OFFICE LA:DLR* PM:RPB2:DLR BC:RERB:DLR BC:RPB2:DLR NAME IKing TTran Almboden DVVrona (SKlementowicz for)

DATE 7/29/11 7/29/11 8/2111 8/4/11 OFFICIAL RECORD COpy

Letter to G.T. Powell from Tam Tran dated August 04,2011

SUBJECT:

REQUESTS FOR ADDITIONAL INFORMATION FOR THE REVIEW OF THE SOUTH TEXAS PROJECT, LICENSE RENEWAL APPLICATION (TAC NOS. ME4938 AND ME5122)

DISTRIBUTION:

E-MAIL:

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