ML12271A423

Responses to Environmental RAI Set #1 to the Callaway LRA

ML12271A423
Person / Time
Site:	Callaway
Issue date:	08/13/2012
From:	Kanuckel L H Ameren Missouri
To:	Office of Nuclear Reactor Regulation, Document Control Desk
References
ULNRC-05893, TAC ME7715, TAC ME7716
Download: ML12271A423 (29)

Text

wAmeren MISSOURI Callaway Plant August 13, 2012 ULNRC-05893 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001 10 CFR 2.101 10 CFR 2.109(b)10 CFR 50.4 10 CFR 50.30 10 CFR 51.53(c)10 CFR 54 Ladies and Gentlemen:

DOCKET NUMBER 50-483 CALLAWAY PLANT UNIT 1 UNION ELECTRIC CO.FACILITY OPERATING LICENSE NPF-30 RESPONSES TO ENVIRONMENTAL RAI SET #1 TO THE CALLAWAY LRA

References:

1) ULNRC-05830 dated December 15, 2011 2) NRC Letter, "Request For Additional Information for the Review of the Callaway Plant, Unit 1 License Renewal Application (TAC No.ME7715 AND ME7716)," dated July 12, 2012.By the Reference 1 letter, Union Electric Company (Ameren Missouri) submitted a license renewal application (LRA) for Callaway Plant Unit 1. Reference 2 dated July 12, 2012 transmitted the first Request for Additional Information (RAI) related to the environmental portion our application.

Enclosure 1 contains Ameren Missouri's responses to the individual requests contained in the July 12, 2012 RAIs. Attachment 1 contains a listing of Enclosures 2 through 46 which are provided on the accompanying DVD.If you have any questions with regard to these RAI responses, or Amendments 4 and 5, please contact me at (573) 823-9286 or Ms. Sarah Kovaleski at (314) 225-1134...................................

.................................................

PO Box 620 Fulton, MO 65251 ArnerenMissouri.corn ULNRC-05893 August 13, 2012 Page 2 I declare under penalty of perjury that the foregoing is true and correct.Sincerely, Executed on: AtAQus+ 13,7 012 J

• I Les H. Kanuckel Manager, Engineering Design DS/SGK/nls

Enclosures:

1) Request for Additional Information (RAI) E-RAI Set #1 Responses

Attachment:

1) List of Enclosures 2 through 46 2 through 46) DVD provided to Document Control Desk and Project Manager only -by overnight mail ULNRC-05893 August 13, 2012 Page 3 cc: U.S. Nuclear Regulatory Commission (Original)

Attn: Document Control Desk Washington, DC 20555-0001 Mr. Elmo E. Collins Regional Administrator U. S. Nuclear Regulatory Commission Region IV 1600 East Lamar Boulevard Arlington, TX 76011-4511 Senior Resident Inspector Callaway Resident Office U.S. Nuclear Regulatory Commission 8201 NRC Road Steedman, MO 65077 Ms. Carmen Fells Project Manager Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Mail Stop 0-1 IF1 Washington, DC 20555-0001 Mr. Samuel Cuadrado De Jesdis Project Branch 1 Division of License Renewal Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Mail Stop 0-1 IFI Washington, DC 20555 Mr. Fred Lyon Senior Project Manager, Callaway Plant Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Mail Stop O-8G14 Washington, DC 20555-2738 Mr. Gregory A. Pick U. S. Nuclear Regulatory Commission Region IV 1600 East Lamar Boulevard Arlington, TX 76011-4511 ULNRC-05893 August 13, 2012 Page 4 Index and send hardcopy to QA File A160.0761 Hardcopy: Certrec Corporation 4150 International Plaza Suite 820 Fort Worth, TX 76109 (Certrec receives ALL attachments as long as they are non-safeguards and may be publicly disclosed.)

Electronic distribution for the following can be made via Tech Spec ULNRC Distribution:

A. C. Heflin F. M. Diya C. 0. Reasoner III D. W. Neterer L. H. Graessle J. S. Geyer S. A. Maglio R. Holmes-Bobo NSRB Secretary L. H. Kanuckel S. G. Kovaleski T. B. Elwood G. G. Yates E. Blocher (STARS PAM COB)Mr. Bill Muilenburg (WCNOC)Mr. Tim Hope (Luminant Power)Mr. Ron Barnes (APS)Mr. Tom Baldwin (PG&E)Mr. Mike Murray (STPNOC)Ms. Linda Conklin (SCE)Mr. John ONeill (Pillsbury Winthrop Shaw Pittman LLP)Missouri Public Service Commission Mr. Dru Buntin (DNR)

Page 1 of 23 Enclosure 1 to ULNRC-05893 Aquatic Ecology 1. Provide a copy of the review of new and significant information document or describe what specific records or information Ameren Missouri (Ameren) reviewed to determine that no new and significant information exists for each of the aquatic ecology Category 1 issues applicable to Callaway Plant, Unit 1 (Callaway).

Callaway Response: Ameren's New and Significant Information Report, describes the process that Ameren used to determine if any of the 92 issues identified in 10 CFR 51, Appendix B (including Category 1 issues) that are applicable to Callaway fall into either of these two categories:

a. Information that identifies a significant environmental issue not covered in the GElS (NUREG 1437) and codified in the regulation (10 CFR 51, Appendix B)b. Information that was not covered in the GElS analyses and which leads to an impact finding different from that codified in the regulation.

In Chapter 5 of Ameren's Environmental Report, the following conclusion is reported: Ameren is not aware of any new and significant information regarding the plant's environment or operations that would make any generic conclusion codified by the NRC for Category 1 issues not applicable to Callaway Unit 1, that would alter regulatory or GElS statements regarding Category 2 issues, or that would suggest any other measure of license renewal environmental impact.Ameren's New and Significant Information Report, without Appendix B (which contains personal information on individuals who were interviewed), is provided as Enclosure 2.Appendix B contains documentation of the aquatic ecology interviews and was made available for NRC staff review during the environmental audit.2. Clarify the location of the discharge point for blow-down water and other waste streams to the Missouri River.Callaway Response: The Callaway discharge point for blow-down can be found in Ameren's Environmental Report as Figure 3.1-2. Other waste streams are combined with the cooling tower blowdown near the power block and are discharged to the Missouri River at a single location.3. Provide copies of or, if copies are not available, descriptions of pre-operational surveys of fish conducted in 2007 and 2008 within reach of the Missouri River adjacent to Callaway's cooling water intake mentioned on page 20, plus any associated reports or documentation.

Callaway Response: Documentation describing the pre-operational surveys of fish conducted in 2007 and 2009 within reach of the Missouri River adjacent to Callaway's cooling water intake is available as Section 2.4 of the AmerenUE Callaway Plant Unit 2 COLA (Environmental Report), Rev. 1 Page 2 of 23 Enclosure 1 to ULNRC-05893 (ML090710389).

Descriptions of the methodologies used to conduct the surveys are contained in the MACTEC Standard Operation Procedures (SOP) for the Callaway Nuclear Plant Unit 2 Siting Study, Natural Resources Field Sampling and Analysis, and are provided as Enclosure

3.4. Provide

any associated reports or documentation related to the historical records and contacts with State and Federal resource agencies related to the occurrence of State and Federally listed threatened and endangered species.Callaway Response: Ameren reviewed Missouri Department of Conservation (MDC) and U.S. Fish and Wildlife Service (USFWS) records (county lists of occurrences) relative to listed species in the project area and reported this information in Ameren's Environmental Report. Ameren also wrote the MDC and USFWS seeking information on potentially affected (state and federally listed) species, and provided names of five protected or sensitive mussel species believed to occur in the project area. The USFWS responded with a "no effect" determination and did not provide any information on the five mussel species or any species. The MDC provided a list of sensitive mussel species believed to occur in waterbodies in or adjacent to project-related transmission corridors.

These agency responses are in Appendix C of Ameren's Environmental Report.5. Provide a description of the cooling water intake system, including the intake velocity at the traveling screens, design and operation of the traveling screens, and any other operational procedures or structural designs that affect impingement and entrainment at the Callaway Pump Station on the Missouri River. Also provide information regarding the depth of the intake and the means by which flow is regulated for the flow intake structure.

Callaway Response: The "Callaway NPDES Flow Diagram" contains a description of the cooling water intake system and is included as Enclosure 4.Intake velocity at the traveling screen at a normal flow of 9000gpm and a normal water level of 16' of water in the pump bay was calculated to be 0.307 fps. The highest theoretical velocity of 0.595 fps was based on maximum pump flow and low river level.The Callaway intake structure has many structural designs to minimize impingement and entrainment.

The size of the intake structure has been increased beyond the required design in order to reduce the velocities of intake water through the screens. The intake has been located so it protrudes into the main river channel, and water is withdrawn from areas located away from shallow and slower moving water where the largest populations of aquatic organisms would be expected to occur. Water withdrawal by the intake occurs from the depths of the main channel where few organisms inhabit, giving buoyant or semibuoyant organisms a lesser chance of entrainment.

Additionally, the face of the intake has been aligned parallel to the river flow ensuring water is withdrawn perpendicular to the flow of the river. Thus, river currents tend to sweep river organisms past the intake structure.

This information is documented in the Union Electric Company 1986 report "Evaluation of Cooling Water Intake Impacts on the Missouri River," and is included as Enclosure

5.

Page 3 of 23 Enclosure I to ULNRC-05893 A traveling screen is provided in each pump bay to remove small debris. The screen mesh size is 1/8 inch, and the screen is made up of sections of screen linked together in a continuous chain-like arrangement.

The traveling screens can be operated manually or automatically via a signal from a timer every 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> and rotate for 30 minutes or a signal generated by differential pressure (DP)across the screen indicating sediment buildup on the screen. The traveling screen wash starts automatically in slow speed at 6" DP and shift to fast speed at 18" DP across the screen. A high screen DP of 48" will cause the intake pump to trip. In automatic (screen wash on), the associated screen wash header pressure must be >100 psig for the traveling screen to rotate. This ensures debris is washed off of the screen and not carried over to the pump side of the screen.The operating deck elevation of the intake structure is at 561.5 feet above mean sea level (MSL) and the pump bays are at 482 feet MSL. Flow is regulated by adjusting backpressure with a sleeve valve.6. Provide a description of the fish escape openings at the water intake structure and an explanation of why a fish return system is not required.

Also provide copies of any studies or documentation of the effectiveness of this mitigation system.Callaway Response: Incoming water initially passes through a set of vertical trash racks designed to stop large objects and debris from entering the intake structure.

The trash racks are constructed of 0.5 inch bars and allow only objects smaller than 0.5 in 2 to enter the intake. Intake stop gates are located between the trash racks and the traveling screens to provide intake bay isolation for maintenance.

The intake structure is constructed with fish escape openings, similar to the stop gates, in the side walls of the pump bays. These openings are directly in front of the traveling screens. The fish escape openings are 3 feet wide and 10 feet high, toping at 496 feet MSL.Each intake pump's stop and fish gates are normally open when the intake pump is operating.

The gate positions are reversed when an intake pump is stopped. Intake pumps A and B include similar circuits.

However, to open the B fish gate, stop gates B and C must be open; to open the A fish gate, stop gates A and B must be open. These configurations prevent fish from being trapped in the bays.The Callaway intake structure's location was selected so that the effects on the fish population would be minimal. Water withdrawal occurs from the depths of the main channel where fish inhabitation is minimal. Feeding, spawning and nursery areas for fish are limited in the area of the intake structure.

Fish involvement with the intake basically entails fish migrating around the structure.

The low impingement rates indicate that the intake structure was located and designed to minimize impingement since fish do not reside in the area of intake. A fish return system in not required based on the design and placement of the intake structure and the low impingement rate. Supporting information can be found in the Union Electric Company 1986 report "Evaluation of Cooling Water Intake Impacts on the Missouri River," and is included as Enclosure

5.

Page 4 of 23 Enclosure 1 to ULNRC-05893

7. Provide a description of what chemicals are used and the associated application rates and schedules to treat the cooling and auxiliary water system.Callaway Response: The cooling and auxiliary water system includes the Intake, Water Treatment Plant, and Circulating and Service Water Systems. Chemicals used to treat the system include a molluscicide, bleach, coagulant aid, cationic polymer, sodium bromine, copolymer, hydroxyethylidine diphosphonic acid (HEDP), pyrophosphate, sodium tolytriazole, biopenetrant, and sulfuric acid. These chemicals are administered as follows: Intake: Molluscicide:

Molluscicide is added one or two times per year at the intake during the spawning season. 8 gallons are added to each of three bays while the bay is isolated.Water Treatment Plant: Molluscicide:

Molluscicide is added once every 3 weeks when river temperature exceeds 600 F in the spring and ending in June when spawning season is over. Treatment resumes in the fall starting in September.

This usually amounts to four treatments in the spring and four in the fall. Each of the four treatments uses 55 gallons and is scheduled approximately three weeks apart. Each seasonal treatment uses approximately 250 gallons of molluscicide, which is added to the water treatment plant clearwell Bleach: Sodium hypochlorite (12%) is added at the water treatment plant during the summer months once river temperature exceeds 600 F. Bleach addition is halted when the river temp drops below 600 F. 200 gallons per clarifier per week are added. In 2011, the total addition was 11,100 gallons, added between June and October. Ameren plans to use triazine as a non-oxidizing biocide for algae control starting in the summer of 2013. When this change is implemented, 5 gallons of triazine and 100 gallons of bleach will be added per clarifier once per week during the summer months.Coagulant aid: When needed, coagulant aid is added in December, January and February if river temperatures fall below 40' F. The coagulant is added at the water treatment plant stilling basin at a daily rate of 20 -30 gallons.Polymer: Cationic polymer (DMDAAC) (DADMAC) is added at the sleeve valves in the water treatment plant for water clarification.

In 2011, the average addition rate was 1629 gallons/month or approximately 20,000 gallons/year Circulating/Service Water System: Bleach: Sodium hypochlorite (12%) is added to the circulating and service water systems daily for 15 minutes to service water, 30 minutes to 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> to the circulating water (more during warm weather).

If there is evidence of condenser tube fouling the amount may be increased for a "shock" treatment.

The addition amount varies greatly between summer and winter, averaging approximately 6000 gallons per month. The 2011 total bleach addition to the circulating and service water systems was 67,733 gallons.Bromine: Sodium bromine (40%) is added in conjunction with bleach to the circulating and service water systems as a daily addition.

More bromine is added during warm weather.

Page 5 of 23 Enclosure 1 to ULNRC-05893 Bromine usage averages about 1350 gallons per month. The total for 2011 was 16,275 gallons.Copolymer:

Copolymer is added to the circulating and service water systems to keep solids in suspension.

This prevents deposition and fouling of the surfaces of the heat exchangers and allows solids to be removed through cooling tower blowdown.

Copolymer is fed continuously, averaging approximately1500 gallons per month. The 2011 total was 19,435 gallons.HEDP: Hydroxyethylidine diphosphonic acid (60%) is fed continuously as a scale inhibitor to protect against calcium carbonate in the circulating/service water system. Average usage is approximately 500 gallons per month. The 2011 total was 6633 gallons.Pyrophosphate:

This mild steel corrosion inhibitor is fed continuously to the circulating and service water systems at a rate of 30 gallons per day.Sodium Tolytriazole (50% TTA): For yellow metal corrosion control, TTA is fed continuously to the circulating and service water systems, averaging about 200 gallons per month. The total for 2011 was 2599 gallons.Biopenetrant:

Biopenetrant is added at a rate of 60 gallons once per week in conjunction with the daily biocide treatment and during "shock" treatments of the circulating and service water systems to enhance effectiveness of the oxidizing biocides.Sulfuric acid: Sulfuric acid (93%) is fed continuously to the circulating and service water systems for pH control, averaging approximately 50,000 gallons per month. The 2011 total was 475,200 gallons.8. Provide for review the available studies or procedures that Ameren funds, undertakes, or uses to document that protected species are not impinged or entrained at the intake or affected by the thermal effluent.

These species should include the fish species that the protected freshwater mussels attach to during their glochidal stages.Callaway Response: An impingement and entrainment study was performed and documented in the 1986 report"Evaluation of Cooling Water Intake Impacts on the Missouri River" and is included as Enclosure

5. This study concluded that based on the design and location of the intake structure, impingement and entrainment, and thermal effluent were not issues at Callaway.9. Provide the Union Electric Company 1986 report "Evaluation of Cooling Water Intake Impacts on the Missouri River," and any other similar reports referencing effects on aquatic resources.

Callaway Response: The Union Electric Company 1986 report "Evaluation of Cooling Water Intake Impacts on the Missouri River," is included as Enclosure

5.

Page 6 of 23 Enclosure I to ULNRC-05893

10. Provide a description of the thermal discharge temperatures of the blowdown water.Callaway Response: Descriptions of the thermal discharge temperatures is contained in the Discharge Monitoring Reports, which are prepared quarterly and reflect a year's worth of data. The four most recent Discharge Monitoring Reports are included as Enclosures 6,7,8, and 9.11. Provide a description of the planned construction of additional water treatment/sediment retention ponds over the next 20 years.Callaway Response: The average life for the sediment retention ponds is between 6 -8 years. The life of any specific retention pond depends on the size of the pond and the amount of silt being carried in the Missouri River. Currently, it is estimated that the #4 sediment pond will be at capacity within 3 years. Over the next 20 years, assuming that Callaway will continue to get makeup water from the Missouri River, Callaway will need 3 additional sediment retention ponds.

Page 7 of 23 Enclosure I to ULNRC-05893 Environmental Justice & Socioeconomics

1. Provide information about any observed subsistence consumption behavior patterns, specifically fish and wildlife consumption, by minority and low-income populations in the vicinity of Callaway.

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 materials) conducted by minority and low-income individuals.

Callaway Response: Although there are individuals living around the Callaway Plant that consume local wildlife and plants, Ameren is not aware of any population groups with subsistence behavioral patterns.

As reported in Table 2.6-2 of Ameren's Environmental Report, there are no minority populations in the nearest counties of Callaway, Gasconade, Montgomery, and Osage, and few within the 50-mile region (see Environmental Report Figure 2.6-2). Callaway County has two low-income block groups.The AmerenUE Callaway Plant Unit 2 COLA (Environmental Report), Rev. 1 discusses subsistence living in Sections 2.5.4.3 and 4.4.3.2 (ML090710390 and ML090710395, respectively).

The sections do not identify any subsistence patterns by minority or low-income populations.

2. In addition to property tax payment information presented in Section 2.10 of the environmental report (ER), 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 Callaway.Callaway Response: Ameren makes several support payments to the State Emergency Management Agency (SEMA) and other counties with the 50 mile emergency planning zone. The breakdown for payments in 2011 are as follows: SEMA -$266,225 out of a total of $1,331,125 to be paid between Sept. 2011 and July 2013 Callaway County -$260,000 Osage County -$48,000 Montgomery County -$48,000 Gasconade County -$48,000 Page 8 of 23 Enclosure I to ULNRC-05893

3. Provide data on the height of the tallest (visible from offsite locations) structures at Callaway and general information on the visibility of plant facilities from various offsite locations.

Callaway Response: Section 2.1 of Ameren's Environmental Report states, "For about a six-mile radius, the elevation is slightly lower than that of the plant area. Therefore, the Callaway cooling tower is a prominent feature of the area." It also states that the average elevation of the site is approximately 850 feet. Section 3.1.2 of this report further describes the cooling tower as 555 feet above ground level. While no viewshed analysis has been performed, the cooling towers are clearly visible from Interstate I-70 approximately 11 or more miles to the north.The AmerenUE Callaway Plant Unit 2 COLA (Environmental Report) Rev. 1, discusses visual impacts in Sections 4.4.1.6 and 5.8.1.5 (ML090710395 and ML090710396, respectively), but does not provide viewshed information regarding the cooling tower visibility.

Page 9 of 23 Enclosure 1 to ULNRC-05893 Electromagnetic Fields 1. For the computer code used to calculate the induced current, provide details of the code, the model developed for this plant, the input, and the output results.Callaway Response: The program used by Ameren is the FIELDS program developed by Southern California Edison. The following information is taken from the documentation file provided with FIELDS.The FIELDS program is designed to calculate and plot the magnetic and electric fields produced by transmission and distribution lines. The program will compute fields for any combination of up to 60 conductors and 10 ground wires with voltage, current, and phase angle independently specified.

FIELDS 2.0 Southern California Edison Co.6090 North Irwindale Avenue Irwindale, Ca 91702 1. FIELDS can handle up to 60 parallel conductors and 10 ground wires.2. Electric field values can only be computed for conductors placed above ground, as ground is assumed to be a perfect conductor for the E field calculations.

Any conductor touching the surface of the earth will have an effect on the electric field above ground; however, since the conductor is touching the earth and the earth is assumed to be a perfect conductor, these effects are small and complex to calculate.

Therefore the effect or any conductor touching the surface will be negligible.

Magnetic fields from underground conductors, however, are calculated by this program.3. No two conductors or ground wires can occupy the same position or the program will not function properly.4. The program will give a warning to the user when the field calculations are inside the surface of a conductor, or within two bundle diameters of a bundled conductor.

The algorithm only calculates the fields that are a distance from the center of the wire greater than or equal to the radius of the wire for single wire conductors.

For bundled conductors the exact position and orientation of the wires is not input, therefore the program uses a geometric approximation that breaks down as the point of calculation approaches the bundle (within two bundle diameters).

If you want a more exact calculation this close to a bundle, then enter each wire of the bundle as a separate conductor with the exact positions.

Remember each wire of a bundle has the same voltage as the total voltage of the bundle, but each wire splits the total current of the bundle among each wire.

Page 10 of 23 Enclosure 1 to ULNRC-05893

5. The maximum number of points in a given profile is 602. For example, this would allow for a maximum observer distance of 300 feet if samples were calculated every 1 foot or a maximum observer distance of 3000 feet given calculations every 10 feet.6. Users should note that the positions of the phase conductors, groundwires, and the right-of-way (RA4) lines on the field graphic plots are approximate and may very slightly from the user-entered values. If the display of the RAM lines is not desired, users may leave both R/W positions at zero or may position them beyond the maximum observer distance; either way the RIW lines will not appear on the plots. FIELDS gives users the option of displaying the configuration of the conductor and ground wires on the plots. It should be noted that only the first character of the user-specified phase and ground wire name is actually plotted on the field plots.Methods of Calculation used in FIELDS The FIELDS program utilizes the basic algorithms for the calculation of electric and magnetic fields listed in EPRI's TRANSMISSION LINE REFERENCE BOOK (THE RED BOOK)(Pages 330-331, 409-410, and 341-342).

The electric field calculation assumes earth as a perfect conductor and sums the vector components of the field created by the charge on each conductor.

Likewise, the magnetic field calculation performs a vector sum of the contribution to the field from each of the conductor currents.

FIELDS calculates both the square root of the sum of the squares of the vertical and horizontal field components and also the maximum phasor component based upon the magnitude of the major semi-axis of the field ellipse. The field calculations are accurate within the validity of the input data. Special care should be exercised in selecting current and phase angle values to insure that the model represents realistic conditions.

The model calculations have been validated against Electric Power Consultants Incorporated's program EBFANRI, and Bonneville Power Administration's program, Corona, among others.The inputs are the geometry, voltage, frequency and other parameters for the cases to be run. The output to this analysis was the graph reported in Ameren's Environmental Report. The induced current was then calculated based on these results.

Page II of 23 Enclosure I to ULNRC-05893 Hydrology and Water Quality -Groundwater

1. Provide the plant flow diagram that was part of the recent National Pollutant Discharge Elimination System (NPDES) permit renewal.Callaway Response: The flow diagram that was included as part of the recent NPDES permit is included as Enclosure

4.2. Confirm

and provide documentation that the groundwater sample reported in the ER (Table 2.3-2) was analyzed for strontium, rather than only for the isotope of strontium (strontium-90).

Callaway Response: The table data were taken from Table 2.3-34 of the Unit 2 COL Application (AmerenUE 2009). Table 2.3-34 shows that the units for Sr-90 should be pCi/L.Therefore, radioactive strontium (Sr-90) is what was intended, not elemental strontium.

A revised Table 2.3-2 from the Callaway license renewal ER is included as Enclosure 10.3. For those wells with tritium levels above background provide data that shows changes in tritium concentrations in groundwater over time.Callaway Response: Tritium in the power block wells is due to washout from gaseous effluents discharged in accordance with the Callaway Operating License. The washout is influenced by several factors such as the type and amount of precipitation, the wind direction, and the temperature.

The elevated tritium in well MW-939 in March & April, 2011 is due to condensation from the Refueling Water Storage Tank vent during cold weather conditions.

The very low concentration of tritium observed in monitoring wells MWO14, MWO17, MWO18, and MWO19 is from minor releases over a 24 year period from air release valves on the original plant blowdown pipe in this area. High density polyethylene pipe was installed in 2008 to replace the original blowdown piping. The new HDPE pipe does not use air release valves. Eleven wells were installed to closely monitor the natural attenuation of the tritium. The well sample data shows that the plume is not migrating and is slowly dissipating.

A table of tritium concentrations by monitoring well is included as Enclosure

11.

Page 12 of 23 Enclosure 1 to ULNRC-05893

4. To adequately describe groundwater quantity impacts, NRC needs to know the source or sources of the water that flows into the groundwater sump (i.e., What aquifers are being impacted or are there other sources for the water?). In responding to this request, explain why you believe the groundwater is being supplied from that source or sources that are identified in the response.

If there are other sumps in the basements of the buildings of the power block collecting groundwater, estimate the rate of groundwater collected from those sources. Provide cross section drawings referred to in an October 8, 2008, letter from Ameren to the Missouri Department of Natural Resources (MDNR) (ML083150703) as Attachment F.Callaway Response: The undisturbed areas surrounding the power block still have the original glacial till and loess creating a fairly impermeable "bathtub" comprised of Graydon Chert (extremely low permeability rates) (Callaway Standard Plant FSAR Section 1.2.1.5).After excavation, the powerblock area was backfilled with Category I Structural Backfill and capped with a clay blanket. The source of the water in the bathtub area under the Callaway power block is rainwater.

Based on the design of the power block bathtub, there would be very limited to no interaction between the ground water inside the bathtub and existing aquifers.

Therefore, there would be no significant aquifer impacts.Ameren has also observed minor amounts of condensed tritium in washout (by rain or snow) from airborne effluent releases in several monitoring wells and in the groundwater sump samples. Potential leaks of plant piping or components within the power block area would be identified quickly in these monitoring wells. Water is continuously pumped from the groundwater sump. This pump was installed in the groundwater sump to help remediate a diesel fuel oil leak within this area. Water within the bathtub is drawn down or pulled towards the groundwater sump and is pumped to an oily waste separator.

No other sumps are currently installed to collect this groundwater.

The groundwater sump and additional monitoring wells located within the power block bathtub are monitored monthly for tritium and gamma emitters.

This provides the earliest indication of any potential leak of radioactive fluid from power block piping or equipment.

Sumps in the power block buildings do not normally collect groundwater, but may collect groundwater if the groundwater within the bathtub area is high enough for intrusion into the buildings.

Sumps are piped to the Radwaste Building for discharge in radioactive liquid effluents.

Drawings provided in the April 18, 2008 letter (Attachment F provided plant drawings showing cross-sections of the power block buildings and structures) are as follows and provided as Enclosures 12, 13, 14, 15, and 16 respectively:

8600-X-88130

-Power Block -Building Fill & Backfill Plan Sheet Page 13 of 23 Enclosure 1 to ULNRC-05893 8600-X-88133

-Power Block -Building Fill & Backfill Cross Sections 8600-X-88134

-Power Block -Building Fill & Backfill Cross Sections 8600-X-88139

-Power Block -Building Fill & Backfill Cross Sections 8600-X-88140

-Power Block -Building Fill & Backfill Cross Sections 5. Provide a map showing the closest private well to Callaway that is approximately 0.25 miles southeast of Intake Well #1.Callaway Response: A map showing the closest private well to Callaway is included as Enclosure

17.

Page 14 of 23 Enclosure I to ULNRC-05893 Hydrology and Water Quality -Surface Water 1. Provide a description of settling and effluent discharge pond changes (i.e., new ponds needed and old ponds abandoned) over the period of license renewal.Callaway Response: There are no changes planned for the current storm water settling ponds during the life of the plant including the 20 year extension period. There are currently five ponds with current NPDES permitted storm water discharge outfalls (Ouffalls:

010, 011,012,014 and 015). Outfall 013 was removed from the last NPDES Permit as it no longer has drainage from an area of "industrial activity".

2. Provide any notices of violation (NOVs), nonconformance notifications, or related infractions received from regulatory agencies associated with NPDES permitted discharges, sewage systems, groundwater or soil contamination, including spills, leaks, and other inadvertent releases of fuel solvents, chemicals, or radionuclides (covering the past 5 years).Callaway Response: There have been no notices of violation or similar infractions within the last 5 years.

Page 15 of 23 Enclosure 1 to ULNRC-05893 Land Use and Transmission Lines 1. Please confirm whether the 2005 land use/land cover data presented in Table 2.11-1 and Figure 2.11-1 has changed; and if so, please provide the following:

1)the most recently available land use calculation package for Callaway County and 2) an updated figure depicting the most recently available land use data.Callaway Response: Ameren checked the source, the Missouri Spatial Data Information Service, for the land use/land cover data used in the ER and found that the 2005 data remain the most current. A dated copy of the applicable MSDIS webpage, in portable document format, is provided as Enclosure

18. Accordingly, there is no updated Figure 2.11-1.The land use calculation package has been provided as Enclosure

19.

Page 16 of 23 Enclosure 1 to ULNRC-05893 Meteorology and Air Quality 1. Provide a description of the primary meteorological tower and backup meteorological tower. Include a description of instrumentation installed and height of installation for each instrument.

Describe any changes in land use around the tower sites that have occurred since installation that may affect any meteorological sensors.Callaway Response: A detailed description of Callaway's meteorological tower is contained in the Callaway Final Safety Analysis Report -Site Addendum Chapter 2.3.3.2. Provide the most recent 5 years of annual emission statements to the MDNR for emissions of air pollutants resulting from operations at Callaway.Callaway Response: The most recent 5 years of annual emission statements to the MDNR for emissions of air pollutants resulting from operations at Callaway are provided as Enclosures 20, 21, 22, 23, and 24.3. Provide a summary of Callaway greenhouse gas emissions.

Include emissions of carbon dioxide from permitted combustion sources and emissions of sulfur hexafluoride (SF 6) leakage, if available.

Callaway Response: Ameren has no direct data on greenhouse gas emissions, including carbon dioxide and sulfur hexafluoride.

The current permitting process only requires the reporting of gallons of fuel used, not emissions or emission source run times. Greenhouse gas emission sources at Callaway include two emergency diesel generators, an auxiliary boiler and four alternate emergency power supply diesel generators.

All of these emission sources are run on an infrequent basis for testing or use during refueling outages.4. Provide noise emissions studies conducted at Callaway, if any, and any information about noise that could be considered a nuisance to offsite property owners. Also, provide information about any noise complaints.

Callaway Response: Callaway has not received any noise complaints and therefor has not conducted any noise studies. Noise was not identified as an issue during the New and Significant Information Process.

Page 17 of 23 Enclosure 1 to ULNRC-05893 Terrestrial Ecology 1. Provide a copy of the review of new and significant information document or describe what specific records or information Ameren reviewed to determine that no new and significant information exists for each of the terrestrial ecology Category 1 issues applicable to Callaway.Callaway Response: The New and Significant Information Report is included as Enclosure

2. Also, see response to Aquatic Ecology RAI #1.2. The ER references several ecological studies conducted in 2007 and 2008 for the Callaway Plant, Unit 2, combined license application (COLA) and also references the COLA ER. Please provide copies of the terrestrial studies performed for the COLA, including the mammalian, avian, and herpetological studies mentioned on page 17 and the floral survey and 2007 land cover survey mentioned on page 2-226 of the COLA ER. Describe the specific mitigation measures that Ameren takes to ensure that its transmission-line maintenance does not impact any Federally listed species, including personnel training, coordination with State and Federal agencies, and specific precautions that workers must take in the field. Provide copies of related procedures, if applicable.

Callaway Response: These studies exist as section 2.4 of the Callaway Unit 2 COL Application.

Descriptions of the methodologies used to conduct the surveys are contained in the MACTEC Standard Operation Procedures (SOP) for the Callaway Nuclear Plant Unit 2 Siting Study, Natural Resources Field Sampling and Analysis, and are provided as Enclosure

3. If Ameren observes federally listed species, vegetation maintenance will not be performed in that area.3. Provide a description of the time of year ground clearing is conducted for the transmission line management.

Callaway Response: Ameren performs ground clearing year round on an as-needed basis. However, special precaution is taken to avoid areas where threatened and endangered species are present.4. Provide a description of any special vegetation management techniques along the transmission lines at stream and wetland crossings.

Callaway Response: It is not Ameren's practice to leave woody vegetative buffers along water ways or roadways.

These buffers inhibit line of sight and provide little more soil stability than approved low variety perennial vegetation or a forb/grass mix. NPDES allows the Page 18 of 23 Enclosure 1 to ULNRC-05893 vegetation management methodology to be left up to individual land managers.Ameren treats all buffers, including water's edge buffers. Ameren, using EPA registered herbicides

& staying within the MSDS label restrictions, will either basal band, hack/squirt, cut/stubble or use a low volume individual stem application on brush located within these waters edge buffer zones.

Page 19 of 23 Enclosure I to ULNRC-05893 Waste Management

1. Provide information about Callaway's typical yearly low-level waste generation rate, processing methods, storage capability, and disposal options or reasonably foreseeable disposal options that demonstrate that there will be adequate storage and disposal capabilities during the period of license renewal. With respect to the disposition of Class B and Class C waste, provide the status of the arrangements being made for the disposal of this material in the licensed low-level radioactive waste disposal facility in Texas or other options.Callaway Response: This information is contained in the "Callaway Energy Center Radioactive Waste Management Plan" and is provided as Enclosure 25.2. Provide Callaway's Radioactive Waste Management Plan.Callaway Response: See enclosed "Callaway Energy Center Radioactive Waste Management Plan" and is provided as Enclosure 25.3. Is Callaway a large quantity, small quantity, or conditionally exempt small quantity generator of hazardous waste?Callaway Response: Callaway Plant is a small quantity generator of hazardous waste generating between 200 and 2200 lb. of hazardous waste per month. The waste is stored in a prefabricated Hazardous Waste Storage Building (HWSB) with containment sumps, designed specifically for storage of hazardous waste. Waste is stored in the HWSB for up to 180 days prior to disposal via an off-site vendor. Typical wastes generated are Chromium, Lead, Mercury, Silver, and solvents.

The plant also currently maintains an outside satellite accumulation area where waste paint and solvents are accumulated.

These wastes are accumulated from work performed in the plant in two separate 55-gallon drums held in a prefabricated closed spill container capable of holding 110 percent of the volume in both drums.4. Provide 2010 and 2011 Generator's Hazardous Waste Summary Reports.Callaway Response: This information is contained in the Hazardous Waste Summary Reports and is provided as Enclosures 26 and 27.

Page 20 of 23 Enclosure 1 to ULNRC-05893

5. Provide 2010 and 2011 Facility Summary Reports.Callaway Response: The quarterly Facility Summary Reports for 2010, 2011 and first quarter 2012 are provided as Enclosures 28 and 29.6. If radiologically contaminated used oil is not addressed in the Facility Summary Reports, provide a brief description of the quantities of such oil that are generated and how the oil is handled and disposed of.Callaway Response: Radiologically contaminated oil is not specifically addressed in the Facility Summary Report. The amount produced varies based on radiological conditions and the amount of work performed.

The average amount of radiologically contaminated, non-mixed waste, oil is approximately 100 gallons per year. This oil is stored and disposed of in the same way as any other low level waste.7. Provide 2010 and 2011 Emergency Planning and Community Right-to-Know Act (EPCRA) reports (Tier Two inventories).

Callaway Response: Ameren has provided the Callaway Tier II Reports for 2010 and 2011 as Enclosures 30 and 31.8. Provide recent (2011) reporting for hazardous air pollutants released (SARA Toxic Release Inventory reports).Callaway Response: Ameren has provided the most recent Air Emission Report as Enclosure

24.

Page 21 of 23 Enclosure I to ULNRC-05893 References Requested for Docketing EnclosureI Title Aquatic Ecology 32 A. CDM (Camp Dresser & McKee, Inc.) 1981. Water quality and aquatic biological preoperational monitoring program for the Callaway Nuclear Plant: June 1980 through May 1981. Prepared for Union Electric Company, St. Louis, Missouri, by Camp Dresser & McKee,.Milwaukee, Wisconsin.

July.33 B. CDM (Camp Dresser & McKee, Inc.) 1982. Water quality and aquatic biological preoperational monitoring program for the Callaway Nuclear Plant: June 1981 through May 1982. Prepared for Union Electric Company, St. Louis, Missouri, by Camp Dresser & McKee, Milwaukee, Wisconsin.

September.

2 C. UEC (Union Electric Company) 1986. Callaway Plant: Evaluation of Cooling Water Intake Impacts on the Missouri River. Prepared by Environmental Services Department, St. Louis. July.2 D. All related 316 studies completed for Callaway.34 E. Callaway NPDES Permit MO-0098001 Hydrology and Water Quality -Groundwater 35 A. AmerenUE 2007. Callaway Plant Final Environmental Evaluation of Blowdown Line Replacement.

July.36 B. AmerenUE 2008b. Callaway Major Water Use Report 2008.37 C. AmerenUE 2010a. Callaway Action Request System 201005073, Absence of Monitoring Wells near SSCs Containing Radioactive Fluids. May.10 D. AmerenUE 2010b. Groundwater Sample Minima, Maxima, and Mean Values for all Sampling Rounds at Callaway Plant Site 2007 -2008.April.38 E. AmerenUE 2010c. Callaway Landfill Groundwater Quality Data 2006-2009. March.

Page 22 of 23 Enclosure I to ULNRC-05893 39 F. Burns & McDonnell (Burns and McDonnell Engineering Company)2008. Phase II Hydrogeologic Investigation Report Collector Well Siting Study, Callaway Unit 2. June.Does not G. MDNR (Missouri Department of Natural Resources) 2003. Major exist Nuclear Power Plant. October.40 H. MDNR (Missouri Department of Natural Resources) 2009b. Callaway#2 Water District PWSS Report 3024085.43 I. Rizzo (Rizzo Associates, Inc) 2008. Final Groundwater Model Report (rev 1, Callaway Nuclear Power Plant, October.)44 J. Terracon 2010. Groundwater Monitoring, Fuel Groundwater Wells.February.45 K. Tetra Tech 2010. Map Showing Location of Callaway #2 Water District and Fulton Water District Public Supply Wells. January.Hydrology and Water Quality -Surface Water 46 A. Ameren Missouri.

2011. 2010 Annual Radiological Environmental Operating Report for the Callaway Plant. USNRC-05785.

April 29, 2011.5 B. UEC (Union Electric Company) 1986. Callaway Plant: Evaluation of Cooling Water Intake Does not C. Impacts on the Missouri River. Prepared by Environmental Services exist Department, St. Louis. Jul.47 D. USACE (United States Army Corps of Engineers) 2003. Final Environmental Impact Statement for the Missouri River Fish and Wildlife Mitigation Project. U.S. Army Corps of Engineers.

Does not E. Kansas City District, Kansas City, Missouri, and Omaha District, exist Omaha, Nebraska.

March.Terrestrial Ecology Page 23 of 23 Enclosure I to ULNRC-05893 48 A. Missouri Department of Conservation 2008. Reform Conservation Area: Area Plan 20062016.Waste Management Previously A. Ameren document CTP-HM-00300, Handling, Storage, Evaluation, Provided and Disposal of Hazardous and Mixed Wastes.Previously B. Ameren document APA-ZZ-00831, Hazardous Chemical Control Provided Program.Previously C. Ameren document APA-ZZ-00832, Hazardous and Special Waste Provided Management Program Page 1 of 2 Attachment I to ULNRC-05893 Attachment 1 Enclosure Document Title Number 2 Ameren's New and Significant Information Report, without Appendix B 3 MACTEC Standard Operation Procedures (SOP) for the Callaway Nuclear Plant Unit 2 Siting Study, Natural Resources Field Sampling and Analysis 4 Callaway NPDES Flow Diagram 5 Evaluation of Cooling Water Intake Impacts on the Missouri River 6 Callaway Discharge Monitoring Report -3rd Quarter 2011 7 Callaway Discharge Monitoring Report -4th Quarter 2011 8 Callaway Discharge Monitoring Report -1 st Quarter 2012 9 Callaway Discharige Monitoring Report -2nd Quarter 2012 10 Revised Environmental Report Table 2.3-2 11 Groundwater Tritium Well Data 12 8600-X-88130 13 8600-X-88133 14 8600-X-88134 15 8600-X-88139 16 8600-X-88140 17 Map of Wells Within 1 Mile of the River Water Intake Structure 18 MSDIS 19 Calc Package Land Use 20 Callaway 2007 Air Emission Report 21 Callaway 2008 Air Emission Report 22 Callaway 2009 Air Emission Report 23 Callaway 2010 Air Emission Report 24 Callaway 2011 Air Emission Report 25 Callaway Energy Center Radioactive Waste Management Plan 26 2010 Generator's Hazardous Waste Summary Report 27 2011 Generator's Hazardous Waste Summary Report 28 2010 Facility Summary Reports 29 2011 Facility Summary Reports 30 2010 Emergency Planning and Community Right-to-Know Act (EPCRA)report 31 2011 Emergency Planning and Community Right-to-Know Act (EPCRA)reports 32 CDM (Camp Dresser & McKee, Inc.) 1981. Water quality and aquatic biological preoperational monitoring program for the Callaway Nuclear Page 2 of 2 Attachment I to ULNRC-05893 Plant: June 1980 through May 1981. Prepared for Union Electric Company, St. Louis, Missouri, by Camp Dresser & McKee, Milwaukee, Wisconsin.

July.33 CDM (Camp Dresser & McKee, Inc.) 1982. Water quality and aquatic biological preoperational monitoring program for the Callaway Nuclear Plant: June 1981 through May 1982. Prepared for Union Electric Company, St. Louis, Missouri, by Camp Dresser & McKee, Milwaukee, Wisconsin.

September.

34 Callaway NPDES Permit MO-0098001 35 AmerenUE 2007. Callaway Plant Final Environmental Evaluation of Blowdown Line Replacement.

July.36 AmerenUE 2008b. Callaway Major Water Use Report 2008.37 AmerenUE 2010a. Callaway Action Request System 201005073, Absence of Monitoring Wells near SSCs Containing Radioactive Fluids. May.38 AmerenUE 2010c. Callaway Landfill Groundwater Quality Data 2006-2009. March.39 Bums & McDonnell (Bums and McDonnell Engineering Company) 2008.Phase II Hydrogeologic Investigation Report Collector Well Siting Study, Callaway Unit 2. June.40 MDNR (Missouri Department of Natural Resources) 2009b. Callaway #2 Water District PWSS Report 3024085.41 Rizzo (Rizzo Associates, Inc) 2008. Final Groundwater Model Report (rev 1, Callaway Nuclear Power Plant, October.)42 Terracon 2010. Groundwater Monitoring, Fuel Groundwater Wells.February.43 Tetra Tech 2010. Map Showing Location of Callaway #2 Water District and Fulton Water District Public Supply Wells. January.44 Ameren Missouri.

2011. 2010 Annual Radiological Environmental Operating Report for the Callaway Plant. USNRC-05785.

April 29, 2011.45 USACE (United States Army Corps of Engineers) 2003. Final Environmental Impact Statement for the Missouri River Fish and Wildlife Mitigation Project. U.S. Army Corps of Engineers.

Kansas City District, Kansas City, Missouri, and Omaha District, Omaha, Nebraska.

March.46 Missouri Department of Conservation 2008. Reform Conservation Area: Area Plan 20062016.