ML11203A515

Comments on the Generic Environmental Impact Statement for License Renewal of Nuclear Plants: Draft Report for Comment (NUREG-1437, Supplement 44)

ML11203A515
Person / Time
Site:	Crystal River
Issue date:	07/20/2011
From:	Franke J Progress Energy Florida
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
3F0711-05, TAC ME0278
Download: ML11203A515 (6)

Text

~jProgress Energy Crystal River Nuclear Plant Docket No. 50-302 Operating License No. DPR-72 Ref: 10 CFR 54 July 20, 2011 3F0711-05 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001

Subject:

Comments on the Generic Environmental Impact Statement for License Renewal of Nuclear Plants: Crystal River Unit 3 Nuclear Generating Plant - Draft Report for Comment (NUREG-1437, Supplement 44) (TAC NO. ME0278)

References:

(1) CR-3 to NRC letter, 3F1208-01, dated December 16, 2008, "Crystal River Unit 3 - Application for Renewal of Operating License" (2) NRC to CR-3 letter, dated May 26, 2011, "Notice of Availability of the Draft Plant-Specific Supplement 44 to the Generic Environmental Impact Statement for License Renewal of Nuclear Plants Regarding Crystal River Unit 3 Nuclear Generating Plant (TAC NO. ME0278)"

Dear Sir:

On December 16, 2008, Florida Power Corporation (FPC), doing business as Progress Energy Florida, Inc. (PEF), requested renewal of the operating license for Crystal River Unit 3 (CR-3) to extend the term of its operating license an additional 20 years beyond the current expiration date (Reference 1). Subsequently, the Nuclear Regulatory Commission (NRC), by letter dated May 26, 2011, issued Draft Plant-Specific Supplement 44 to the Generic Environmental Impact Statement for License Renewal of Nuclear Plants Regarding Crystal River Unit 3 Nuclear Generating Plant (Reference 2) for comment. The Enclosure to this letter provides comments on Reference 2.

No new regulatory commitments are contained in this submittal.

If you have any questions regarding this submittal, please contact Mr. Mike Heath, Supervisor, License Renewal, at (910) 457-3487, e-mail at mike.heath@pgnmail.com.

iri-cc ely, onA. Franke Vice President Crystal River Unit 3 JAF/dwh

Enclosure:

Comments on Draft Plant-Specific Supplement 44 to the Generic Environmental Impact Statement for License Renewal of Nuclear Plants Regarding Crystal River Unit 3 Nuclear Generating Plant xc: NRC CR-3 Project Manager NRC License Renewal Project Manager NRC Regional Administrator, Region II Senior Resident Inspector NRC Chief Rules, Announcements, and Directives Branch Progress Energy Florida, Inc.

Crystal River Nuclear Plant 15760 W. Power Line Street Crystal River, FL 34428

U. S. Nuclear Regulatory Commission Page 2 of 2 3F0711-05 STATE OF FLORIDA COUNTY OF CITRUS Jon A. Franke states that he is the Vice President, Crystal River Nuclear Plant for Florida Power Corporation, doing business as Progress Energy Florida, Inc.; that he is authorized on the part of said company to sign and file with the Nuclear Regulatory Commission the information attached hereto; and that all such statements made and matters set forth therein are true and correct to the best of his knowledge, information, and belief.

ViePresident Crystal River Nuclear Plant The foregoing document was acknowledged before me this

• day of J 4144,2011, by Jon A. Franke.

Signature of Notary Public State of Florida CAROLYN E.PORTMANN

.........

.. , Commission # DD 937553

. Expires March 1,2014 ThoTroyF tn i.

Londed . 8 W,%85.7019 (Print, type, or stamp Commissioned Name of Notary Public)

Personally Produced Known -OR- Identification

PROGRESS ENERGY FLORIDA, INC.

CRYSTAL RIVER UNIT 3 DOCKET NUMBER 50 - 302 / LICENSE NUMBER DPR - 72 ENCLOSURE COMMENTS ON DRAFT PLANT-SPECIFIC SUPPLEMENT 44 TO THE GENERIC ENVIRONMENTAL IMPACT STATEMENT FOR LICENSE RENEWAL OF NUCLEAR PLANTS REGARDING CRYSTAL RIVER UNIT 3 NUCLEAR GENERATING PLANT

U. S. Nuclear Regulatory Commission Enclosure 3F0711-05 Page 1 of 3 COMMENTS ON DRAFT PLANT-SPECIFIC SUPPLEMENT 44 TO THE GENERIC ENVIRONMENTAL IMPACT STATEMENT FOR LICENSE RENEWAL OF NUCLEAR PLANTS REGARDING CRYSTAL RIVER UNIT 3 NUCLEAR GENERATING PLANT Section Page Comment No. No.

2.1 2-5 Consider making Figures 2.1-4 and 2.1.7-3 both full-page figures, like Figures and 2.1-1, 2.1-2, and 2.1-3 but with a landscape, rather than portrait orientation. This 2-26 will improve the readability of the labels on these figures.

2.1.7.3 2-19 The sentence beginning on line 32 discusses how the Units 1 & 2 coal storage area discharges to the site discharge canal via the Units 4 & 5 canal. While this is correct for the discharge of the CR-4 & 5 coal pile discharge, it is not correct for the CR-1 & 2 discharge. The south coal pile runoff system discharges to a separate collection/treatment system and discharges via outfall D-OOH to an adjacent salt marsh. The correct description is found on page 2-31, lines 7-12.

2.1.7.3 2-23 On line 10, and in several other places, identified below, the word "impoundment" is used to describe areas containing no water (i.e., coal storage areas and ash storage areas). "Impoundment" is typically used for areas that withhold water.

For example, in describing the industrial wastewater percolation ponds, the word impoundment is correctly used. Calling the coal and dry ash storage areas at Crystal River "impoundments" is inaccurate.

• Page 2-23, Line 10, Replace the word "impoundments" with "areas."

• Page 2-23, Line 16, Replace the word "impoundment" with "area."

" Page 2-31, Line 1, Replace the word "impoundments" with "impoundments and storage areas."

" Page 2-31, Line 7, Replace the word "impoundment" with "area."

• Page 2-31, Line 30, Replace the word "impoundments" with "impoundments and storage areas."

• Page 2-31, Line 35, Replace the word "impoundment" with "area."

• Page 2-32, Line 16, Replace the word "impoundment" with "area."

• Page 4-67, Line 39, Replace the word "impoundments" with "surface impoundments and storage areas."

2.1.7.3 2-24 Well MWC-2R should be MWI-2R. It is correctly described just above in line 5.

When a well has a "C" designation, it means it is a compliance well. The "I" designation means that it is an "intermediate" well. The distinction is important in that primary drinking water standards (PDWS) do not apply at intermediate wells.

Therefore, the explanation beginning with the sentence on line 8, doesn't apply.

Either remove the entire sentence or revise to: "Between 2005 and 2009, arsenic and gross alpha were detected in well MWI-2R, immediately downgradient of the ash storage area. In January 2009, gross alpha was found to exceed the PDWS in well MWC-21 R further downgradient."

2.1.7.4, 2-27 The descriptions for Outfalls D-011, D-012, and D-013 use the word "filtration" for Table condenser cooling water passing through a traveling screen. USEPA Form 2C 2.1.7-4 (NPDES Permit Renewal Application Form) gives a treatment code for "screening." Screening would be a better word to use rather than filtration.

2.1.7.4 2-31 The sentence that starts on the preceding page and ends on line 1 talks about discharges of various wastewater, but the end of the sentence states: "...treated radioactive and nonradioactive waste." This last word should more accurately be "wastewater."

2.1.7.4 2-31 The south coal yard storage is "unlined", not "lined", as stated in line 7. Replace "lined" with "unlined."

U. S. Nuclear Regulatory Commission Enclosure 3F0711-05 Page 2 of 3 Section Page Comment No. No.

2.1.7.4 2-32 Even though the systems are designed to contain a 10-year, 24-hour event, that does not mean there will be no discharges or overflows during rain events of lesser duration. Ifthere is a discharge due to an event greater than a 10-year, 24-hour event, then a Total Suspended Solids technology-based effluent limit of 50 ppm is not applicable. Discharges resulting from rainfall events less than a 10 year, 24-hour event have to meet this limit. Therefore, consider ending the sentence on line 27 after the word "event."

2.2.2.1 2-37 The sentence that begins on line 7 may be misinterpreted. Consider changing it to read: "There are three mandatory Class I Federal areas in the state of Florida:

Chassahowitzka National Wildlife Refuge (NWR) (approximately 15 miles south of the Crystal River Energy Complex (CREC)), St Mark's NWR (approximately 115 miles NNW of the CREC), and Everglades National Park (approximately 200 mi SSW of the CREC)."

2.2.2.1 2-37 The sentence that begins on line 9 conflicts with the sentence that begins on line

7. The closest Class I Federal area is the Chassahowitzka NWR.

2.2.5.3 2-49 The discussion of aquatic weeds/hydrilla beginning on line 14 could indicate that hydrilla is a concern at CREC and that Progress Energy employs mechanical, biological, and chemical means to control this invasive species. Hydrilla is found almost exclusively in fresh water and could not tolerate the salinities found in the CREC area, which are greater than 20 parts per trillion (ppt). Consider deleting this discussion of hydrilla.

4.2 4-3 The description of the helper cooling towers (HCTs) and modular towers is not correct in lines 7-12. Water does not pass "in sequence" through both types of towers. Any individual water droplet passes through only one of the towers, either an HCT or a modular. Also, there are 67 modular towers, not four. The sentence should be revised to state: "Four mechanical draft HCTs (collectively, emission Unit 13 in the Title V permit) and, as many as, 67 modular mechanical draft cooling towers (collectively, emission Unit 20 in the Title V permit) can be used to meet the thermal limits of the National Pollutant Discharge Elimination System permit applicable to seawater at its point of ultimate release from the I intake/discharge canal."

4.2 4-4 Lines 2 to 5 of this section discuss the helper towers being retired if the South Cooling Tower (SCT) is built. Actually, it is the modular cooling towers that can be retired (see page 4-28, line 10 for correct description). This paragraph mistakenly assumed that the "helper" cooling towers will be retired (instead of the "modular" towers). Also, the proposed SCT would not discharge into the canal downstream of the existing towers. Therefore, the sentence should be revised to state: "Once it is operational (and all 18 cells are installed), the applicant anticipates being able to retire the modular cooling towers and still meet the collective heat rejection demands of all the CREC steam cycles." This affects the calculation of the "net" particulate emissions assumed at the end of the paragraph. On page 4-3, particulate emissions in 2008 were 42.1 tons/year from the helper cooling towers and 8.2 tons/year from the modular cooling towers.

4.3.1 4-7 Suggest the word "untreated" be inserted between the words "no" and "liquid" in line 6. Treated liquid wastewater is discharged to groundwater as permitted by the Florida Department of Environmental Protection (FDEP)-issued Industrial Waste Water permit FLA016960 that authorizes discharge of treated industrial wastewater to groundwater via the percolation ponds.

4.5.2 4-14 The sentence, "The flow reductions at the CREC began in 1992." on lines 16 and 17 is a repeat of the sentence that begins on line 9 on that same page.

U. S. Nuclear Regulatory Commission Enclosure 3F0711-05 Page 3 of 3 Section Page Comment No. No.

4.5.2 4-15 There are several references (listed below) to the shutdown of CR-1 and CR-2 "once LNP becomes operational" or by the end of 2020. These should be revised to note the current commitment has the proviso that CR-1 and CR-2 will be shutdown or repowered contingent upon completion of the first fuel cycle for Levy Nuclear Plant Unit 2.

" Page 4-15, Line 24-25

" Page 4-22, Line 20

• Page4-29, Line 13

• Page 4-67, Line 7-8

• Page 4-68, Line 35-36

• Page 4-71, Line 34-35

" Page 4-73, Line 28-29

• Page 4-85, Line 29

• Page 4-86, Line 1

• Page D.1-36, Line 4-5

• Page D.1-38, Line 29-30

• Page D.1-43,Line 13-14

" Page D.1-56, Line 34-35

" Page D.1-61, Line 12-13CR-1 4.4.5 4-29 Consider changing "Aquatics Resources" to "Aquatic Resources" in the section heading here and in the Table of Contents.

4.6 4-32 The first sentence of Section 4.6 indicates that issues applicable to CR-3 are discussed below and listed in Table 4-6. At least one of these issues (cooling pond impacts on terrestrial resources) is not applicable to CR-3. Also, while the issues are identified in the table, none of them are discussed.

5.3.2 5-5 In line 2, it is stated that the population dose is approximately 4.0 person-sievert (40 person-rem) per year. The estimated population dose should be approximately 4.0 person-rem which equals 0.04 person-sievert to be consistent with the dose values shown on page F-3, line 34.

7.1 7-2 In lines 6-7, 1 person-rem is equated to 1 person-millisievert. 1 person-rem is equal to 10 person-millisievert.

Appendix F F-29 On page F-29, line 33, the cost of SAMA 18, "add another EDG", is given as

$5,000. This should be $5M, as noted in the Environmental Report, page E.9-29.