ML12158A249

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Lr - Draft LGS Audit Plan Rev2.docx
ML12158A249
Person / Time
Site: Limerick  Constellation icon.png
Issue date: 10/12/2011
From:
Office of Nuclear Reactor Regulation
To:
Division of License Renewal
References
Download: ML12158A249 (24)
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Text

LimerickNPEm Resource From: Regner, Lisa Sent: Wednesday, October 12, 2011 3:38 PM To: 'Nancy.Ranek@exeloncorp.com'; Chris Wilson (Exelon)

Cc: Balsam, Briana; Hickey, Eva E; Folk, Kevin; Leigh, Kimberly D; Larson, Emily; Moser, Michelle; Rautzen, William; Regner, Lisa; Rikhoff, Jeffrey; Stuyvenberg, Andrew; Travers, Allison; Wrona, David; Imboden, Andy

Subject:

DRAFT LGS Audit Plan Rev2.docx Attachments: DRAFT LGS Audit Plan Rev2.docx Nancy, Chris, Here is the DRAFT Audit Plan. Please let me know if you have questions.

Lisa 1

Hearing Identifier: Limerick_LR_NonPublic Email Number: 169 Mail Envelope Properties (E85CAE0ED2FC5449B808712D77E97576143509A62E)

Subject:

DRAFT LGS Audit Plan Rev2.docx Sent Date: 10/12/2011 3:37:36 PM Received Date: 10/12/2011 3:38:06 PM From: Regner, Lisa Created By: Lisa.Regner@nrc.gov Recipients:

"Balsam, Briana" <Briana.Balsam@nrc.gov>

Tracking Status: None "Hickey, Eva E" <eva.hickey@pnnl.gov>

Tracking Status: None "Folk, Kevin" <Kevin.Folk@nrc.gov>

Tracking Status: None "Leigh, Kimberly D" <Kimberly.Leigh@pnnl.gov>

Tracking Status: None "Larson, Emily" <Emily.Larson@nrc.gov>

Tracking Status: None "Moser, Michelle" <Michelle.Moser@nrc.gov>

Tracking Status: None "Rautzen, William" <William.Rautzen@nrc.gov>

Tracking Status: None "Regner, Lisa" <Lisa.Regner@nrc.gov>

Tracking Status: None "Rikhoff, Jeffrey" <Jeffrey.Rikhoff@nrc.gov>

Tracking Status: None "Stuyvenberg, Andrew" <Andrew.Stuyvenberg@nrc.gov>

Tracking Status: None "Travers, Allison" <Allison.Travers@nrc.gov>

Tracking Status: None "Wrona, David" <David.Wrona@nrc.gov>

Tracking Status: None "Imboden, Andy" <Andy.Imboden@nrc.gov>

Tracking Status: None

"'Nancy.Ranek@exeloncorp.com'" <Nancy.Ranek@exeloncorp.com>

Tracking Status: None "Chris Wilson (Exelon)" <Christopher.Wilson2@exeloncorp.com>

Tracking Status: None Post Office: HQCLSTR02.nrc.gov Files Size Date & Time MESSAGE 99 10/12/2011 3:38:06 PM DRAFT LGS Audit Plan Rev2.docx 79174 Options Priority: Standard Return Notification: No Reply Requested: No

Sensitivity: Normal Expiration Date:

Recipients Received:

Mr. Michael P. Gallagher Vice President License Renewal Projects Exelon Generation Company, LLC 200 Exelon Way Kennett Square, PA 19348

SUBJECT:

ENVIRONMENTAL SITE AUDIT REGARDING LIMERICK GENERATING STATION, UNITS 1 AND 2 (TAC NOS. ME6557 AND ME6558)

Dear Mr. Gallagher:

The U.S. Nuclear Regulatory Commission (NRC) staff is reviewing Exelon Generation Company, LLCs license renewal application for Limerick Generating Station, Units 1 and 2 (LGS). The environmental site audit will be conducted at LGS during the week of November 7, 2011, by NRC and Pacific Northwest National Laboratory staff. The environmental audit activities will be conducted in accordance with the enclosed environmental audit plan.

To develop the Supplemental Environmental Impact Statement, the NRC staff requests the information described in the enclosed environmental audit needs list be made available, to the extent possible, during the environmental site audit. A draft schedule of tours and meetings for the audit is also enclosed. The NRC staff informally transmitted this information to your staff (Nancy Ranek), via e-mail on October 7, 2011.

If you have any questions, please contact me by telephone at 301-415-1906 or by e-mail at Lisa.Regner@nrc.gov.

Sincerely, Lisa M. Regner, Senior Project Manager Projects Branch 2 Division of License Renewal Office of Nuclear Reactor Regulation Docket Nos. 50-352 and 50-353

Enclosures:

1. Regulatory Environmental Audit Plan
2. Environmental Audit Needs List
3. Environmental Audit Draft Schedule cc w/encls: See next page

Mr. Michael P. Gallagher Vice President License Renewal Projects Exelon Generation Company, LLC 200 Exelon Way Kennett Square, PA 19348

SUBJECT:

ENVIRONMENTAL SITE AUDIT REGARDING LIMERICK GENERATING STATION, UNITS 1 AND 2 (TAC NOS. ME6557 AND ME6558)

Dear Mr. Gallagher:

The U.S. Nuclear Regulatory Commission (NRC) staff is reviewing Exelon Generation Company, LLCs license renewal application for Limerick Generating Station, Units 1 and 2 (LGS). The environmental site audit will be conducted at LGS during the week of November 7, 2011, by NRC and Pacific Northwest National Laboratory staff. The environmental audit activities will be conducted in accordance with the enclosed environmental audit plan.

To develop the Supplemental Environmental Impact Statement, the NRC staff requests the information described in the enclosed environmental audit needs list be made available, to the extent possible, during the environmental site audit. A draft schedule of tours and meetings for the audit is also enclosed. The NRC staff informally transmitted this information to your staff (Nancy Ranek), via e-mail on October 7, 2011.

If you have any questions, please contact Lisa Regner by telephone at 301-415-1906 or by e-mail at Lisa.Regner@nrc.gov.

Sincerely, Lisa M. Regner, Senior Project Manager Projects Branch 2 Division of License Renewal Office of Nuclear Reactor Regulation Docket Nos. 50-352 and 50-353

Enclosures:

4. Regulatory Environmental Audit Plan
5. Environmental Audit Needs List
6. Environmental Audit Draft Schedule cc w/encls: See next page DISTRIBUTION:

See next page ADAMS Accession No. ML OFFICE PM:RPB2:DLR LA:RPOB:DLR BC:RPB2:DLR PM:RPB2:DLR NAME LRegner IKing DWrona LRegner (signature)

DATE 10/ /2011 10/ /2011 10/ /2011 10/ /2011 OFFICIAL AGENCY RECORD

Letter to M. Gallagher from L. Regner dated October xx, 2011 DISTRIBUTION:

SUBJECT:

ENVIRONMENTAL SITE AUDIT REGARDING LIMERICK GENERATING STATION, UNITS 1 AND 2 (TAC NOS. ME6557 AND ME6558)

HARD COPY:

DLR RF E-MAIL:

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LICENSE RENEWAL ENVIRONMENTAL AUDIT PLAN LIMERICK GENERATING STATION

1. Background

By letter dated June 22, 2011, Exelon Generation Company, LLC (Exelon or applicant) submitted to the U.S. Nuclear Regulatory Commission (NRC or staff) an application to renew the Limerick Generating Station, Units 1 and 2 (LGS) operating licenses NPF-39 and NPF-85.

The staff is reviewing the information contained in the environmental report (ER) of the license renewal application (LRA) per Title 10 of the Code of Federal Regulations Part 54 (10 CFR Part 54).

During the staffs review, an environmental audit is conducted at the LGS site. This audit is conducted with the intent to gain understanding, to verify information, and to identify information that will require docketing to support the basis of the licensing or regulatory decision.

Specifically, the NRC staff will identify pertinent environmental data, review the facility and area, and obtain clarifications regarding information provided in the ER.

Per NRC guidance, the NRC staff prepares a regulatory audit plan that provides a clear overview of audit activities and scope, team assignments, and schedule.

2. Environmental Audit Bases License renewal requirements are specified in 10 CFR Part 54, Requirements for Renewal of Operating Licenses for Nuclear Power Plants. Licensees are required by 10 CFR 54.23 to submit an ER that complies with the requirements in 10 CFR Part 51, Environmental Protection Regulations for Domestic Licensing and Related Regulatory Functions, as part of the LRA.

Review guidance for the staff is provided in NUREG-1555, Standard Review Plans for Environmental Reviews for Nuclear Power Plants: Supplement 1 - Operating License Renewal.

NRC staff is required to prepare a site-specific supplement to NUREG-1437, Generic Environmental Impact Statement for License Renewal of Nuclear Plants. During the scoping process required in 10 CFR Part 51, NRC staff is required to define the proposed action, identify significant issues which must be studied in depth, and to identify those issues that can be eliminated from further study.

3. Environmental Audit Scope The scope of this environmental audit for the LGS license renewal is to identify those issues which are significant and those issues which can be eliminated from further study and to identify the environmental resources that must be adequately described and evaluated in the site-specific supplemental Environmental Impact Statement (EIS). Audit team members will focus on reviewing the documents and requested information listed in the LGS Environmental Audit Needs List (Enclosure 2) and discussing the information with plant personnel subject matter experts.

ENCLOSURE 1

4. Information and Other Material Necessary for the Environmental Audit As described in the Site Audit Needs List (Enclosure 2).
5. Tentative Team Assignments Area of Review Assigned Auditor The environmental audit team members and their specific discipline assignments are shown in Table 1. Those members of the team who are contractors from Pacific Northwest National Laboratory will have PNNL after their name.

Table 1 Environmental Audit Team Members and Resource Assignments Discipline Team Members Environmental Project Manager Lisa Regner, NRC Michelle Moser, NRC Aquatic Ann Miracle, PNNL Briana Balsam, NRC Terrestrial Jim Becker, PNNL Radiological William Rautzen, NRC Kevin Folk, NRC Hydrology Lance Vail, PNNL Andrew Stuyvenberg*, NRC Air/Meteorology Jeremy Rishel, PNNL Jeffrey Rikhoff, NRC Socioeconomic Emily Larson, NRC Jeffrey Rikhoff, NRC Land Use Anderson, PNNL Allison Travers, NRC Cultural Resources Emily Larson, NRC Tara ONeil, PNNL William Rautzen, NRC Waste Management Eva Hickey, PNNL

  • May not be participating in environmental site audit.
6. Logistics The environmental audit will be conducted at LGS from November 7 - 10, 2011. An entrance meeting will be held with plant management at the beginning of the audit. An exit meeting will be held at the end of this audit.
7. Special Requests The staff requests the applicant make available the information identified on the Environmental Audit Needs List. Plant staff who are subject matter experts in the disciplines listed on the Environmental Site Audit Needs List should be available for interviews and to provide tours which have been identified on the Environmental Audit Draft Schedule (Enclosure 3).
8. Deliverables A report should be issued by the NRC staff to the applicant within 90 days from the end of the environmental audit.

LIMERICK GENERATING STATION, UNITS 1 AND 2 LICENSE RENEWAL ENVIRONMENTAL SITE AUDIT NEEDS LIST The U.S. Nuclear Regulatory Commission (NRC) staff has reviewed Appendix E, the Environmental Report (ER), of the Limerick Generating Station, Units 1 and 2 (LGS) license renewal application (LRA) and has found that it meets the requirements of 10 CFR 51.45.

Please make the following available to staff during the environmental site audit.

ER Section ESRP /

Responsibility Supplement 1 Information Needed Regulation AQ Aquatic Ecology AQ-1 2.2.3 ESRP/S1 Several historic and recent monitoring studies are cited for the Schuylkill River, Michelle Perkiomen Creek, and East Branch Perkiomen Creek. Provide staff or Moser (NRC) /

2.3, 2.2.3, contractors that are knowledgeable on these studies, and provide the following Ann Miracle

2.2.5 references

(PNNL)

  • NAI (Normandeau Associates, Inc.). 2010a. East Branch Perkiomen Creek Aquatic Biology Assessment XIII, 2008 Monitoring Period.

Prepared for Exelon Nuclear, Limerick Generating Station. May.

  • NAI (Normandeau Associates, Inc.). 2010b. East Branch Perkiomen Creek Aquatic Biology Assessment XIV, 2009 Monitoring Period.

Prepared for Exelon Nuclear, Limerick Generating Station. July.

  • NAI (Normandeau Associates, Inc.). 2010c. Fish and Benthic Macroinvertebrate Community Composition in the Schuylkill River in the Vicinity of Limerick Generating Station During 2009. February 2010.
  • NAI (Normandeau Associates, Inc.). 2010d. Letter from Normandeau Associates, Inc. to Exelon Nuclear via email. Zebra mussel/Asiatic

ER Section ESRP /

Responsibility Supplement 1 Information Needed Regulation clam Survey. November.

  • PECO (Philadelphia Electric Company). 1984. Environmental Report -

Operating License Stage. Limerick Generating Station Units 1&2. 5 vols.

  • RMC (RMC Environmental Services). 1984. Progress Report, Non-Radiological Environmental Monitoring for Limerick Generating Station 1979-1983. Prepared for Philadelphia Electric Company. October.
  • RMC (RMC Environmental Services). 1985. Progress Report, Non-Radiological Environmental Monitoring for Limerick Generating Station 1984. Prepared for Philadelphia Electric Company. December.
  • RMC (RMC Environmental Services). 1986. Progress Report, Non-Radiological Environmental Monitoring for Limerick Generating Station 1985. Prepared for Philadelphia Electric Company. September.
  • RMC (RMC Environmental Services). 1987. Progress Report, Non-Radiological Environmental Monitoring for Limerick Generating Station 1986. Prepared for Philadelphia Electric Company. November.
  • RMC (RMC Environmental Services). 1988. Progress Report, Non-Radiological Environmental Monitoring for Limerick Generating Station 1987. Prepared for Philadelphia Electric Company. September.
  • RMC (RMC Environmental Services). 1989. Progress Report, Non-Radiological Environmental Monitoring for Limerick Generating Station 1988. Prepared for Philadelphia Electric Company. December.

AQ-2 2.2.3 ESRP/S1 Describe any aquatic surveys conducted at the Bradshaw Reservoir, the Michelle 2.2.5, 4.1.2 - Wadesville Mine Pool and discharge channel, Bedminster Water Processing Moser (NRC) /

4.1.4, 4.8 Facility, and the Still Creek Reservoir. Ann Miracle

ER Section ESRP /

Responsibility Supplement 1 Information Needed Regulation (PNNL)

AQ-3 3.1.2.1 ESRP/S1 Describe the frequency that water is withdrawn from the Schuykill River Michelle 2.2.5, 4.1.2 - compared to other sources. Moser (NRC) /

4.1.4, 4.8 Ann Miracle (PNNL)

AQ-4 3.1.2.2 ESRP/S1 Describe the average and maximum intake velocity at the Schuylkill Michelle 2.2.5, 4.1.2 - Pumphouse. Moser (NRC) /

4.1.4, 4.8 Ann Miracle (PNNL)

AQ-5 3.1.2.2 ESRP/S1 Describe the intake velocity, traveling screens, and any other operational Michelle 2.2.5, 4.1.2 - procedures or structural designs that limit impingement and entrainment at the Moser (NRC) /

4.1.4, 4.8 Point Pleasant Pumping Station on the Delaware River or at the pumping Ann Miracle stations on the Bradshaw Reservoir, Still Creek Reservoir, or Wadesville Mine (PNNL)

Pool.

AQ-6 4.2 and 4.3 ESRP/S1 Describe any impingement or entrainment studies conducted at the Schuylkill Michelle 2.2.5, 4.1.2 - or Perkiomen Pumphouse or at the intakes on the Delaware River or the East Moser (NRC) /

4.1.4, 4.8 Branch Perkiomen Creek. Ann Miracle (PNNL)

AQ-7 4.4 ESRP/S1 Describe any studies examining the extent of a thermal plume as a result of Michelle 2.2.5, 4.1.2 - discharges to the Schuykill River. Moser (NRC) /

4.1.4, 4.8 Ann Miracle (PNNL)

AQ-8 2.5, ESRP/S1 Provide staff or contractors that are knowledgeable regarding the Michelle

ER Section ESRP /

Responsibility Supplement 1 Information Needed Regulation Appendix C 2.2.5, 4.1.2 - Pennsylvania Natural Diversity Index (PNDI) search to discuss the three Moser (NRC) /

4.1.4, 4.8 species of concern identified in that search for LGS license renewal. Discuss Ann Miracle the potential location of these species on the LGS site and at the Bradshaw (PNNL)

Reservoir and Pumphouse, as discussed on Page 2-44 of the ER.

CR Cultural Resources CR-1 2.10 ESRP/S1 Provide pre- and post-construction aerial photographs, if available. Allison 2.2.1 - 2.2.8 Travers (NRC)

NEPA / Tara ONeil NHPA (PNNL)

CR-2 2.10 ESRP/S1 Provide the references called out in Section 2.10 of the Environmental Report Allison 2.2.1 - 2.2.8 (ER) for the archaeological surveys and the architectural and historical Travers (NRC) and 4.4.5 analysis of the Fricks Lock Historic District. / Tara ONeil NEPA (PNNL)

NHPA CR-3 2.10 ESRP/S1 Provide all correspondence received from the PA State Historic Preservation Allison 2.2.1 - 2.2.8 Office (SHPO) regarding finding of effect determinations referenced in Section Travers (NRC) and 4.4.5 2.10 of the ER. / Tara ONeil NEPA (PNNL)

NHPA CR-4 2.10 ESRP/S1 Page 2-77 of the ER describes the online database search (CRGIS) for Allison 2.2.1 - 2.2.8 resources located in Montgomery and Chester Counties as well resources Travers (NRC) and 4.4.5 within a 6 mile radius of LGS. List and describe the type of cultural resources / Tara ONeil NEPA that occur on the LGS site as a result of the CRGIS query. (PNNL)

NHPA CR-5 2.10 4.19 ESRP/S1 Describe the process to identify Tribes and interested parties to consult with Allison

ER Section ESRP /

Responsibility Supplement 1 Information Needed Regulation 2.2.1 - 2.2.8 regarding the potential impacts to cultural resources as a result of the license Travers (NRC) and 4.4.5 renewal project. / Tara ONeil NEPA (PNNL)

NHPA CR-6 2.10 4.19 ESRP/S1 Provide copies of all consultation letters with SHPO, Tribes, and interested Allison Attachment 2.2.1 - 2.2.8 parties as well as response letters and comments received from the SHPO, Travers (NRC)

D and 4.4.5 Tribes, and interested parties as a result of the license renewal project that / Tara ONeil NEPA may have been produced since the ER submittal to NRC and/or that are not (PNNL)

NHPA included in the ER.

CR-7 2.10 ESRP/S1 Provide a copy of the following: ER Page 2-77 Exelon Generation has Allison 2.2.1 - 2.2.8 specific procedures, including a cultural resource management plan for Travers (NRC) 4.19 and 4.4.5 protecting cultural resources, including the Fricks Locks Historic District and / Tara ONeil NEPA the Schuylkill Navigation Company (Girard) Canal, from activities related to (PNNL)

NHPA operation and maintenance of the LGS.

CR-8 2.10 ESRP/S1 Provide a figure (map) with the area of potential effect that Exelon Generation Allison 2.2.1 - 2.2.8 defined for informal consultation with the PA SHPO with key Travers (NRC) 4.19 and 4.4.5 structures/features of the LGS. / Tara ONeil NEPA (PNNL)

NHPA EJ & S Environmental Justice & Socioeconomics EJ-1 Provide information about any observed subsistence consumption behavior Jeff Rikhoff patternsspecifically fish and wildlife consumptionby minority and low- (NRC) income populations in the vicinity of LGS. 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

ER Section ESRP /

Responsibility Supplement 1 Information Needed Regulation other plant material) conducted by minority and low-income individuals in the vicinity of LGS.

EJ-2 Provide information about current or past wildlife sampling and testing of game Jeff Rikhoff animals such as deer, squirrel, turkey, pheasant, duck, fish and other game (NRC) birds and animals that may have been conducted in the vicinity of LGS.

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.

S-1 2.7 ESRP/S1 In addition to property tax payment information presented in Section 2.7 of the Jeff Rikhoff 2.2.8 ER, describe any other major annual support payments, one-time payments, (NRC) 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 LGS.

S-2 2.7 ESRP/S1 Provide information about any changes in assessed property value or any Jeff Rikhoff 2.2.8 other recent or anticipated payment adjustments that could result in notable (NRC) increases or decreases in tax or other payments.

S-3 2.7 ESRP/S1 Table 2.7-1 LGS Property Tax Payments, 2006 - 2010 notes that Jeff Rikhoff 2.2.8 Montgomery County numbers include Payments in Lieu of Taxes (PILOT). (NRC)

Section 2.7 of the ER does not mention PILOT payments. Provide information about PILOT payments and the status of any negotiated agreements with local taxing jurisdictions.

S-4 2.1.1 ESRP/S1 Data on the height of the tallest (visible from offsite locations) structures at Jeff Rikhoff 2.1.1 LGS and general information on the visibility of plant facilities from various (NRC)

ER Section ESRP /

Responsibility Supplement 1 Information Needed Regulation offsite locations.

S-5 2.1.1 ESRP/S1 Provide possible noise emissions from the site that could be a nuisance in the Jeff Rikhoff 2.1.1 vicinity of LGS. Also, provide information if complaints have been received at (NRC)

LGS concerning noise from operations heard offsite.

HP Health Physics and Waste Provide information on any abnormal, unusual spills, and leaks of radioactive Bill Rautzen material that occurred onsite that are applicable to the criteria in 10 CFR (NRC) / Eva HP-1 50.75(g) and NEI 07-07, Industry Ground Water Protection Initiative - Final Hickey Guidance Document. (PNNL)

Bill Rautzen Provide information on handling, processing, storage, and disposal of low-level (NRC) / Eva HP-2 radioactive waste including any on-site disposals. Hickey (PNNL)

Bill Rautzen Provide information on the generation, handling, processing, storage, and (NRC) / Eva HP-3 disposal of mixed waste. Hickey (PNNL)

Bill Rautzen Provide information on the radiological groundwater protection program (NRC) / Eva HP-4 (RGPP). Hickey (PNNL)

HWQ- Hydrology and Water Quality - Groundwater GW HWQ- 2.3.2 / ESRP/S1 For all four site supply wells, please provide the last 5-years of monthly Kevin Folk

ER Section ESRP /

Responsibility Supplement 1 Information Needed Regulation GW-1 3.1.2.4 2.2.2 / 4.5.1 records for site groundwater production with outage periods identified. (NRC) / Lance 4.5 Vail (PNNL)

HWQ- 2.3.3 ESRP/S1 Provide a copy of the 2006 Hydrogeologic Investigations Report for review, as Kevin Folk GW-2 2.2.3 cited in the ER. (NRC) / Lance Vail (PNNL)

HWQ- 2.3.3 ESRP/S1 Provide a summary of the results of groundwater monitoring performed for Kevin Folk GW-3 5.2 2.2.3 tritium, strontium-90, and gamma-emitting radionuclides since 2006 under the (NRC) / Lance RGPP. Vail (PNNL)

HWQ- Hydrology and Water Quality - Surface Water SW HWQ- 3.1.2.1 ESRP/S1 The LRA states that DRBC approval of the request [docket revision] is Kevin Folk SW-1 4.1 2.2 / 4.1.1 pending as of the date of this reports publication. Provide staff that are (NRC) / Lance knowledgeable on this topic and are able to provide an update of the status of Vail (PNNL) the docket request.

HWQ- 3.1.2.2 ESRP/S1 Clean Water Act 316(b) Phase II requirements regarding intakes are currently Kevin Folk SW-2 2.2.2 / 4.1 / proposed by the Environmental Protection Agency and scheduled to be (NRC) / Lance CWA 316(b) approved by July 27, 2012. Provide staff that are knowledgeable on this topic Vail (PNNL) and identify any anticipated changes in the existing design to comply with the proposed 316(b) requirements.

HWQ- 3.1.2.1 ESRP/S1 Provide a copy of the NPDES permit renewal application for PA0051926 for Kevin Folk SW-3 2.2.3 review. (NRC) / Lance Vail (PNNL)

HWQ- 3.1.2/ ESRP/S1 Provide any Notices of Violation (NOVs), nonconformance notifications, or Kevin Folk SW-4 9.0 1.3 / 2.2.3 related infractions received from regulatory agencies associated with NPDES (NRC) / Lance

ER Section ESRP /

Responsibility Supplement 1 Information Needed Regulation NEPA permitted discharges, sewage systems, groundwater or soil contamination, Vail (PNNL) including spills, leaks, and other inadvertent releases of fuel solvents, chemicals, or radionuclides (covering past 5 years).

HWQ- App A-1 ESRP/S1 Provide all non-radiological monitoring reports from the last 5 years, including Kevin Folk SW-5 2.2.3 Discharge Monitoring Reports and surface water use/diversion reports, (NRC) / Lance Vail (PNNL)

LU-T Land Use and Transmission Lines LU-T 1 2.1.3.4 ESRP/S1 LGS Transmission System - Line 5030: The text on page 2-6 states, The Jeff Rikhoff current LGS transmission system is essentially the same as that originally (NRC) / Dave 2.1.7 constructed for LGS. The transmission line description for Line 5031 on page Anderson 2-8 briefly mentions a pre-existing ROW (5030 line from Peach Bottom). Its (PNNL) not clear in the ER what role, if any, the 500 kV 5030 line played during the construction of LGS. Since it is not described in detail, it is assumed that the 5030 line was not needed to connect LGS to the regional electricity grid.

Please confirm whether or not it was considered part of the LGS transmission system constructed to connect LGS to the regional electricity grid.

LU-T 2 2.1.3, 2.8.2 ESRP/S1 Coastal Zone: Please confirm that the Limerick site is not in the coastal zone Jeff Rikhoff affected by the Coastal Zone Management Act or State-equivalent statutes. If (NRC) / Dave 2.2.1 the site is subject to these laws, please provide applicable discussion and Anderson context. (PNNL)

LU-T 3 Not Not applicable Power Uprate: Confirm whether or not the proposed power uprate would Jeff Rikhoff applicable require transmission system upgrades (substation expansion, new lines, (NRC) / Dave corridors, etc.). Anderson (PNNL)

ER Section ESRP /

Responsibility Supplement 1 Information Needed Regulation MET Meteorology and Air Quality MET-1 2.9.2 ESRP/S1 Provide hourly meteorological data, preferably in the Regulatory Guide 1.23 Drew 2.2.4 Revision 1 format, from the LGS onsite meteorological program for the most Stuyvenberg recent 5-year period of record. (NRC) /

Jeremy Rishel (PNNL)

MET-2 2.9.4 ESRP/S1 Provide a list of permitted air emission sources in the Title V operating permit Drew 2.2.4 and the associated emission quantities. Stuyvenberg (NRC) /

Jeremy Rishel (PNNL)

MET-3 2.9.4 ESRP/S1 Provide recent annual statement(s) to the Pennsylvania Department of Drew 2.2.4 Environmental Protection (PADEP) for emissions of air pollutants resulting Stuyvenberg from operations at LGS. (NRC) /

Jeremy Rishel (PNNL)

TE Terrestrial Ecology TE-1 2.4.1 ESRP/S1 The ER reiterates the expected outcomes of potential impacts described in the Briana Balsam 2.2.6 Final Environmental Statement (FES)-Construction Permit and FES-Operating (NRC) / Jim License. Briefly describe what specific records or information Exelon Becker Generation reviewed to determine that no new and significant information (PNNL) exists for each of the following:

ER Section ESRP /

Responsibility Supplement 1 Information Needed Regulation

  • Cooling tower salt drift deposition effects on native and ornamental vegetation
  • Avian collisions with transmission lines and electrocutions
  • Transmission line and water pipeline corridor maintenance effects on nesting birds and non-target biota
  • Spray pond operation, maintenance, and routine testing effects on wildlife, particularly avian species (e.g., waterfowl) that may be inclined to nest there.

TE-2 2.4.1, 2.4.2 ESRP/S1 Clarify if the recent field reconnaissance mentioned on page 2-39, paragraph Briana Balsam 3, refers to the 2006 Site Assessment and Wildlife Management Opportunities (NRC) / Jim 2.2.6, 3.8.1, prepared by WHC. If not, please provide a description of this field Becker 4.6.1 reconnaissance plus any associated reports or documentation. (PNNL)

Similarly, clarify if the surveying of biodiversity of Possum Hollow Run on page 2-39, paragraph 7, also refers to the same 2006 assessment by WHC. If not, please provide any survey reports or documentation related to this effort.

TE-3 2.4.1, 2.4.2 ESRP/S1 Provide copies of the bird surveys conducted from 1972-1985 mentioned on Briana Balsam page 2-39, paragraph 4, of the ER. (NRC) / Jim 2.2.6, 3.8.1, Becker 4.6.1 (PNNL)

TE-4 2.4.1 ESRP/S1 Provide any additional information or material that the NRC can reference in Briana Balsam its EIS relating to LGCs Environmental Stewardship Committee projects (NRC) / Jim 2.2.6 mentioned on page 2-39, Paragraph 6, of the ER. Specifically, describe: Becker (PNNL)

(a) The locations of artificial avian and raptor nesting structures, the species that benefit from these structures, and any ongoing monitoring of these nest

ER Section ESRP /

Responsibility Supplement 1 Information Needed Regulation sites.

(b) The location, purpose, and specific frog species that benefit from the 300-ft-long fence.

TE-5 2.4.2 ESRP/S1 Provide a copy of LGSs WHC Corporate Wildlife Habitat Certification that is Briana Balsam referenced on Page 2-39, Paragraph 3, of the ER. (NRC) / Jim 2.2.6 Becker (PNNL)

TE-6 2.4.2 ESRP/S1 Provide a copy of LGSs Wildlife Management Plant that is referenced on Briana Balsam Page 2-39, Paragraph 3, of the ER. (NRC) / Jim 2.2.6 Becker (PNNL)

TE-7 2.4.2, ESRP/S1 Provide the following ER references: Briana Balsam 3.1.3.1, (NRC) / Jim 2.2.6

  • WHC, 2006. WHC (Wildlife Habitat Council). 2006. Site Assessment and 3.1.3.2, Becker Wildlife Management Opportunities prepared for Exelon Corporations 3.1.3.3 (PNNL)

Limerick Generating Station. 100 pp. Illustrated. August.

  • Exelon Generation, 2010c. Exelon Generation. 2010c. Limerick Generating Station Wildlife Management Plan.

TE-8 2.4.1, 2.4.2 none The ER on page 2-37 states that no terrestrial monitoring was required as part Briana Balsam of the annual, non-radiological environmental monitoring conducted from 1984 (NRC) / Jim to 2004. However, the ER on page 2-43 cites the annual, non-radiological Becker environmental monitoring reports as evidence that no State- or Federally listed (PNNL) threatened or endangered species had been observed on or in the vicinity of the LGS plant site. Please verify that State- or Federally listed threatened or endangered species would appear under Section 2.7, Non-Routine Reports,

ER Section ESRP /

Responsibility Supplement 1 Information Needed Regulation had any protected species been observed or harmed on the site.

TE-9 3.1.3.2, ESRP/S1 Provide a copy of PECOs transmission line vegetative maintenance Briana Balsam 3.1.3.3 procedure(s). (NRC) / Jim 2.2.6 Becker (PNNL)

TE-10 3.1.3.2, ESRP/S1 Provide knowledgeable staff that can discuss the following regarding Briana Balsam 3.1.3.3 transmission line maintenance: (NRC) / Jim 2.2.6 Becker (a) PECOs integrated management plan for maintaining transmission line (PNNL) corridors (b) Description of the agencies with whom PECO partners and what is collaboratively undertaken to promote biodiversity and reduce long-term impacts within and along transmission line corridors (c) Description of any impact mitigation, as well as what types of mitigation, actions that may halt vegetative maintenance, and any agencies or groups that PECO partners to carry out mitigative actions.

TE-11 2.1.3 Provide an LGS topographical map of the site and vicinity including: Briana Balsam (NRC) / Jim 2.4.2

  • the following facilities associated with the Limerick makeup water supply Becker 2.5.5 system discussed on Page C-3 of the ER:

(PNNL) o the Perkiomen Pumphouse and associated underground 7.6-mi long Perkiomen Pumphouse-to-LGS pipeline; o the Bradshaw Reservoir and Bradshaw Pumphouse; o the Bedminster Water Processing Facility;

ER Section ESRP /

Responsibility Supplement 1 Information Needed Regulation o the underground water transmission main (routed within a natural gas pipeline right-of-way)

  • the full in-scope length of each of the 6 transmission lines discussed in Section 2.1.3 of the ER.
  • the location of avian and raptor nesting structures discussed on Page 2-39 of the ER.
  • the location of the 91.1-meter fence to reduce frog casualties discussed on Page 2-39 of the ER.
  • the location of outdoor classroom with butterfly garden and fish pond discussed on Page 2-39 of the ER.
  • the potential location of the Tooth-cup on the Limerick site, as discussed on Page 2-44 of the ER.

Tours/Discussions Requested with the Exelon Generation Company:

  • The hydrologists and aquatic ecologists would like a general tour of the project area including all water sources to be used at LGS including associated intake structures and conveyances, significant streams and other surface water features, and NPDES outfall locations.
  • The hydrologists would like a general tour of the groundwater supply well locations, and Groundwater Protection Program well locations.
  • The hydrologist expert would also like a meeting with the applicant or responsible contractor for writing the hydrological portions of the ER who can discuss the project and hydrological resources within the area of potential effect. The aquatic ecologists will likely participate in the portion of this meeting related to dredging, water quality, and 316(b) regulations..
  • The cultural resource expert would like a general tour of the project area in relation to known significant cultural resources on the LGS. The expert would also like a meeting with the applicant or contractor responsible for writing the cultural resources portions of the ER who can discuss the project and known cultural resources located within the area of potential effect.
  • The health physicist and waste experts would like a general tour of the project area to identify onsite storage or staging of solid wastes and the Independent Spent Fuel Storage Installation for spent fuel. Additionally, the experts request a tour of the radiological waste processing and storage areas.
  • The aquatic ecologist would like a meeting with the applicant or contractor responsible for writing the aquatic communities portions of the ER who can discuss the project and known aquatic resources within the area of potential effect. As noted above, the aquatic ecologists is also interested in discussing dredging, water quality, and 316(b) regulations as part of the hydrology discussions.
  • The terrestrial ecologist expert would like a tour of areas where biological investigations have been done, such as Possum Hollow run and an off-site location other than the transmission lines, such as the Bradshaw Reservoir and Pumphouse. The expert would prefer a meeting with the applicant or responsible contractor for writing the terrestrial ecology portions of the ER who can discuss the project and known terrestrial resources within the area of potential effect.
  • The health physicist expert would like a tour of the low-level radioactive waste storage facility, the radioactive effluent monitoring systems, and the radiological environmental monitoring stations (e.g. air monitoring stations, including any co-located state monitoring stations).

Off-Site Meetings:

Meeting with the State Historic Preservation Office during the week of the audit, November 7:

A SHPO staff person will attend the audit due to the cultural resources (Frickes Lock) involved in this review. The purpose of the meeting is to discuss NRCs licensing action, schedule, opportunities to participate in the NEPA process, process for completing Section 106 by coordinating with NEPA (in accordance with 36 CFR 800.8c) and any questions or issues the SHPO may have concerning cultural resources.

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