ML13270A126

License Renewal Environmental Site Audit Regarding Braidwood Station (TAC Nos. ME1832/1833, MF1792/1793)

ML13270A126
Person / Time
Site:	Braidwood
Issue date:	11/07/2013
From:	Tam Tran Division of License Renewal
To:	Gallagher M Exelon Generation Co
Tam Tran 301-415-3617
References
TAC MF1792, TAC MF1793, TAC MF1832, TAC MF1833
Download: ML13270A126 (22)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 November 7, 2013 Mr. Michael Gallagher Vice President, License Renewal Projects Exelon Generation Company, LLC 200 Exelon Way Kennett Square, PA 19348

SUBJECT:

LICENSE RENEWAL ENVIRONMENTAL SITE AUDIT REGARDING BRAIDWOOD STATION (TAC NOS. MF1832, MF1833, MF1792 AND MF1793)

Dear Mr. Gallagher:

By letter, dated May 29, 2013, Exelon Generation Company, LLC submitted an application, including an Environmental Report, for renewal of Operating Licenses NPF-72 and NPF-77 for the Braidwood Station (Braidwood), Units 1 and 2. The staff of the U.S. Nuclear Regulatory Commission (the staff) is reviewing this application.

The staff plans to conduct its environmental audit at Braidwood during the week of November 18, 2014, in accordance with the enclosed environmental audit plan. The audit plan was informally provided to your staff, Ms. Nancy Ranik, by e-mail on October 9, 2013.

If you have any questions, please contact me by telephone at 301-415-3617 or by e-mail at Tam.Tran@nrc,gov.

Docket Nos. 50-456 and 50-457

Enclosures:

As stated cc: Listserv Sincerely,

//

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Tam Tran, Environmental Project Manager Projects Branch 2 Division of License Renewal Office of Nuclear Reactor Regulation

November 7, 2013 Mr. Michael Gallagher Vice President, License Renewal Projects Exelon Generation Company, LLC 200 Exelon Way Kennett Square, PA 19348

SUBJECT:

LICENSE RENEWAL ENVIRONMENTAL SITE AUDIT REGARDING BRAIDWOOD STATION (TAC NOS. MF1832, MF1833, MF1792 AND MF1793)

Dear Mr. Gallagher:

By letter, dated May 29, 2013, Exelon Generation Company, LLC submitted an application, including an Environmental Report, for renewal of Operating Licenses NPF-72 and NPF-77 for the Braidwood Station (Braidwood), Units 1 and 2. The staff of the U.S. Nuclear Regulatory Commission (the staff) is reviewing this application The staff plans to conduct its environmental audit at Braidwood during the week of November 18, 2014, in accordance with the enclosed environmental audit plan. The audit plan was informally provided to your staff, Ms. Nancy Ranik, by e-mail on October 9, 2013.

If you have any questions, please contact me by telephone at 301-415-3617 or by e-mail at Tam.Tran@nrc.gov.

Docket Nos. 50-456 and 50-457

Enclosures:

As stated cc: Listserv DISTRIBUTION: See next page Sincerely, IRA/

Tam Tran, Environmental Project Manager Projects Branch 2 Division of License Renewal Office of Nuclear Reactor Regulation ADAMS Accession No.: ML13270A126 (letter) ML13298A088 (Audit Plan)

ML13298A080 (Audit List) ML133038818 (Package)

OFFICE LA:RPB2:DLR PM:RPB2:DLR BC:RERB:DLR BC:RPB2:DLR NAME Y. Edmonds T. Tran D. Wrona B. Wittick DATE 11/4/13 11/4/13 11/4/13 11/5/13 OFFICE PM:RPB2:DLR NAME T. Tran DATE 11/7113 OFFICIAL AGENCY RECORD

Letter to M. Gallagher from T. Tran dated November 7, 2013

SUBJECT:

LICENSE RENEWAL ENVIRONMENTAL SITE AUDIT REGARDING BRAIDWOOD STATION (TAC NOS. MF1832, MF1833, MF1792 AND MF1793)

DISTRIBUTION:

HARD COPY:

DLR RF E-MAIL:

Public E-MAIL:

Public RidsNrrDir Resource RidsNrrDirRpb1 Resource RidsNrrDirRpb2 Resource RidsNrrDirRerb Resource RidsNrrDirRarb Resource RidsNrrDirRasb Resource lois.james@nrc.gov iohn.daily@nrc.gov lindsay.robinson@nrc.gov tam. tran@nrc.gov david. wrona@nrc.gov brian. wittick@nrc.gov mitzi.young@nrc.gov anita.ghosh@nrc.gov christine.england@nrc.gov cheryl. hausman@nrc.gov sheila.ray@nrc.gov stuart.sheldon@nrc.gov eric.duncan@nrc.gov scott.burnell@nrc.gov david.mcintyre@nrc.gov ivonne.couret@nrc.gov viktoria.mitlyng@nrc.gov prema.chandrathil@nrc.gov allan. barker@nrc.gov harral.logaras@nrc.gov john.robbins@nrc.gov james.mcghee@nrc.gov raymond. ng@nrc.gov travis.daun@nrc.gov brent. boston@nrc.gov teresa.ray@nrc.gov billy.dickson@nrc.gov joel.wiebe@nrc.gov michael. mahoney@nrc.gov Nancy. ranek@exeloncorp.com Robert.tarr@exeloncorp.com ogle@gouker. net dwestin@rmu. net charlesmedrano@gmail.com prairiestatestrategies@gmail. com Jarid.Funderburg@mail.house.gov edstirling@jvlnet. com rcolson@oglecounty.org allenchristianson13@gmail.com todd@byronforestpreserve.com mharn@oglecounty. org sara.faller@exeloncorp.com twolf@ilchamber.org byrontownship@yahoo.com cmillard@es-il.org

Audit Plan Environmental Review for the Braidwood Station License Renewal Application November 18, 2013 Division of License Renewal Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission ENCLOSURE

1.

Background

License Renewal Environmental Audit Plan Braidwood Station By letter dated May 29, 2013, Exelon Generation Company, LLC (Exelon or the applicant),

submitted to the U.S. Nuclear Regulatory Commission (NRC or the staff) its application for renewal of Operating License Nos. NPF-72 and NPF-77 for Braidwood Station (Braidwood),

Units 1 and 2. Braidwood requested renewal of the operating licenses for an additional 20 years beyond the 40-year current license terms, which expire on October 17, 2026, for Unit 1 and December 18, 2027, for Unit 2. Staff from the Division of License Renewal will lead an environmental audit at the Braidwood site to gain a better understanding of the license renewal documentation and current Braidwood site and operating conditions.

2.

Regulatory Audit Bases License renewal requirements for environmental review are specified in Title 10 of the Code of Federal Regulations (CFR), Part 51 (1 0 CFR Part 51), "Environmental Protection Regulations for Domestic Licensing and Related Regulatory Functions." Guidance is provided in NUREG-1555, Supplement 1, "Environmental Standard Review Plan," dated June 2013.

3.

Regulatory Audit Scope The scope of this onsite regulatory audit is to interview cognizant personnel and to perform a facility survey (plant tour) of the site conditions and the surrounding environment in order to (a) obtain original reference material supporting the Environmental Report (ER), (b) review environmental compliance activities, and (c) document and assess any potential environmental issues. These site condition observation and information verification and validation activities are performed in accordance with 10 CFR 51. 70.

4.

Information and Other Material Necessary for the Regulatory Audit The project team will review the ER and the applicant's other supporting documents as appropriate. Enclosure 1, "Audit Needs List" contains the specific audit needs for this review.

5.

Team Assignments Area of Review Assigned.. At.ldi~<>r" Project Management Tam Tran Human Health (Health Physics)

Steve Klementowicz Water Resources (Hydrology)

William (Bill) Ford, Kevin Folk Geology and Soil William (Bill) Ford Alternatives E&E, Robert (Bob) Hoffman*

ENCLOSURE

'c c c.* Are~ of Review

c.

Ass(gned Auditor

!C CCC Socioeconomic and Environmental Jeff Rikhoff Justice Cultural Resource and Cumulative Emily Larson Impact Aquatic Michelle Moser Threaten and Endangered Species Dennis Logan Air Quality and Meteorology E&E, Robert (Bob) Hoffman*

Terrestrial and Land Use Briana Grange

• NRC staff assisted by Ecology and Environment, Inc (E&E)

The audit will be conducted at the Braidwood site in Will County, Illinois, during the week of November 18, 2013. Entrance and exit briefings will be held at the beginning and end of this audit, respectively.

7.

Special Requests General discussion with the Braidwood team on the new and significant determination process used for the ER.

General discussion with the Braidwood team on the background and status of the tritium plume.

A speaker phone line for remote participation of HQ staff on certain interviews with cognizant personnel.

8.

Deliverables An audit report will be issued to the applicant within 90 days from the end of the audit.

9.

References NA

Audit Need List ER

ESRP, Audit Need Auditor Section Supp. 1 TE Terrestrial Ecology Briana Grange Information Made Available Durin~ the Audit TE-1 2.4 3.5, Provide electronic or paper copies the Briana 4.5.2 following Environmental Report (ER)

Grange references for NRC review during the site audit:

a. (CornEd 1973a) Commonwealth Edison Company. 1973. Braidwood Station Environmental Report - Volume I. July 1973.

b. (CornEd 1973b) Commonwealth Edison Company. 1973. Braidwood Station Environmental Report-Volume II. July 1973.

c. CornEd 1985) Commonwealth Edison Company. 1985. Braidwood Station Units 1 and 2, Environmental Report -

Operating License Stage. NRC Docket Nos 50-456 and 457, Amendment 7.

June 10, 1985.

Interview with Cognizant Personnel TE-2 2.4 3.5, Have any terrestrial studies or surveys been Briana 4.5.2 conducted on the Braidwood site since the Grange early 1970s baseline surveys discussed in Section 2.4 of the Environmental Re__2ort?

TE-3 2.4 3.5, The Environmental Report (Section 2.4, Page Briana 4.5.2 2-30, paragraph 4) states, "Braidwood was Grange recognized in 2011 by the Wildlife Habitat Council (WHC) as having a certified Wildlife at Work program." Provide a reference for this statement.

TE-4 2.4 3.5, Bryon Station, Units 1 and 2, has a Wildlife Briana 4.5.2 Management Plan. Does Braidwood maintain Grange a similar plan? If so, provide a copy for NRC review.

Tour Reguest TE-5 2.4 3.5, A tour of the site that includes the cooling Briana 4.5.2 pond, lake screen-house, switchyard, and Grange other major facility features as well as natural areas representative of the site's terrestrial habitats. This tour can be combined with the general site tour, the aquatic ecology tour, and/or the hydrology tour, as a__QQro_Qfiate.

T&E Threatened or Endangered Species Denis Logan Information Made Available During the Audit Enclosure T&E-1 2.5 ESRP Provide a copy of Exelon Nuclear 2011 a cited Denis Logan 4.5.5 in ER section 2.5, which documents occurrence of federally QrOtected bald eag_les.

AQ Aquatic Ecology M. Moser Tour Request AQ-1 2.2.4 3.5 As part of the site audit, include a tour to the M. Moser lake screen house and the river screen house, the vicinity of the discharge, the sampling sites for the macro-invertebrate surveys (if feasible), other regular aquatic monitoring sampling sites (if feasible), the Braidwood Lake, and other important onsite aquatic features.

Interview with Coonizant Personnel AQ-2 2.2.4.3 3.5 Section 2.2.4.3 states that Exelon Generation M. Moser hired HDR Engineering, Inc. (HDR) to survey fish and mussels in the reach of the river potentially affected near the new discharge structure. Please clarify whether this preliminary study is the following reference:

(HDR 2008) HDR Engineering, Inc. 2008.

Investigations to Determine Presence of State-Listed Species of Fish and Freshwater Mussels in the Kankakee River near the Braidwood Nuclear Station warm water Discharge Channel. If the ER is referring to another study, please provide a copy of that study.

AQ-3 2.2.4.3 3.5 The ER states: "In conformance with the M. Moser conditions of the Incidental Take Permit, ESI moved 911 live mussels in late July, 2010 from the potential impact area to an area upstream of Horse Creek that offered similar habitat (depth, substrate, current).

Considerable care was taken to minimize stress on the mussels." Please describe transfer methods or examples how ESI minimized stress on the mussels. Clarify whether Exelon conducted any follow up studies to determine the survival rate of trans-located mussel. Please provide a copy of the Incidental Take Permit.

AQ-4 3.1.3 2.1 Section 3.1.3 of the (ER) describes grills, M. Moser trash rakes, and traveling screens within the lake screen house and the river screen house. Please clarify the following:

a. Describe the mesh size of traveling screens at the lake screen house.

b. Describe the intake velocity through the traveling screens at the lake screen house.

c. Clarify whether the intake houses include any fish return structures. If fish return structures occur, discuss estimates of survival rates for fish that go through the return structures.

d. If available, provide diagram(s) of the intake structures and traveling screens within the lake screen house and the river screen house.

e. Describe the cleaning and maintenance procedures at the river screen house and discharge structure, including the frequency of dredging, physical cleaning, and other maintenance procedures.

AQ-5 4.0.2 4.5 Please describe the process used to M. Moser determine that the exposure of aquatic orQanisms to radionuclides was SMALL.

AQ-6 4.2 and 4.5 Sections 4.2 and 4.3 of the ER describe M. Moser 4.3 several impingement and entrainment studies. Please describe the methodology used in the studies, including collection or survey methods, equipment used, and level of effort. If available, please provide any original data, analyses, or reports related to the impingement and entrainment studies. In addition, provide any other reports, summaries, or documents used to support the 316(b) demonstration and/or reports, summaries, or documents that summarize preoperational aquatic biology monitoring data and operational aquatic biology monitoring data (e.g., Exelon Generation's Kankakee River monitoring program which has monitored the fish community in the vicinity of the intake since 1977.)

AQ-7 4.2 and 4.5 Provide current copies of Clean Water Act M. Moser 4.3 and 316(a) and 316(b) determinations, or 4.4 documents used to support 316(a) and 316(b) determinations that were not presented in the environmental report.

AQ-8 4.4 4.5 Section 4.5 of the ER describes CORM IX M. Moser model simulations of the discharge constructed in 2011. Describe whether Exelon has conducted any field studies to characterize the spatial and temporal distribution of the thermal plume associated with the discharge structure constructed in 2011.

AQ-9 4.4 4.5 Section 4.5 of the ER states that in 2007, M. Moser Exelon Generation began exploring design alternatives that would reduce noise and foam and, more critically, facilitate mixing of the blowdown flow with the larger river flow.

Please clarify whether there were any additional considerations to construct a new discharge structure, such as impacts to aquatic resources from the old structure.

Information Made Available Durina the Audit AQ-10 2.2.4.3, 3.5 and Please make available for viewing the M. Moser 4.2, 4.3, 4.5 following references:

4.4

a. (ComEd 1973b) Commonwealth Edison Company. 1973. Braidwood Station Environmental Report-Volume II. July 1973.

b. (Larimore 1989) Larimore, R.W. 1989.

Kankakee River Fishes of the Braidwood Station Aquatic Monitoring Area, August 1989. Illinois Natural History Survey Aquatic Biology Technical Report 89/1.

January 1989.

c.

(EA 2012) EA Engineering, Science, and Technology. 2012. Braidwood Station 2011 Benthos Monitoring and Historical Fish and Benthos Comparisons. July 2012. (Exelon Nuclear 2009a) Exelon Nuclear. 2009. Standard Operating Procedures for Braidwood Station's Fisheries Monitoring Program in the Kankakee River and Horse Creek. July 2009.

d. (Exelon Nuclear 2009b) Exelon Nuclear.

2009. Final Report: Characterization of Unionid Communities near the Braidwood Nuclear Station Kankakee River Discharge Location. January 2009.

e. (Exelon Nuclear 2009c) Exelon Nuclear.

2009. Application for an Incidental Take Permit for Threatened or Endangered Species and Conservation Plan. May 11, 2009.

f.

(Exelon Nuclear 2009h) Exelon Nuclear.

2009. Braidwood Nuclear Power Station NPDES Permit No. IL 0048321: Potable Water System and Make-up Demineralizer System (MUDS) Changes.

November 6, 2009.

g. (Exelon Nuclear 201 Ob) Exelon Nuclear.

2010. Final Report: Unionid Relocation near the Braidwood Nuclear Station Kankakee River Discharge Location.

September 2010.

h. (Exelon Nuclear 2011 b) Exelon Nuclear.

2011. Braidwood Station Kankakee River Fish Monitoring Program, 2010.

i.

(Exelon Nuclear 2011 b) Exelon Nuclear.

2011. Braidwood Station Kankakee River Fish Monitoring Program, 2010.

j 0

(Exelon Nuclear 2011 c) Exelon Nuclear.

2011. Braidwood Station-Braidwood Lake Additional Biological Sampling Program, 2010.

k.

(IDNR 2008a) Illinois Department of Natural Resources. 2008. Status of Fish Communities and Sport Fishery in the Kankakee River and Tributary Streams:

2005 Basin Survey. Fisheries Region II, Streams Program. April 2008.

I.

(IDNR 2008b) Illinois Department of Natural Resources. 2008. Integrating Multiple Taxa in a Biological Stream Rating System. Office of Resource Conservation. August 2008.

m. (IDNR 2000) Illinois Department of Natural Resources. 2000. Permit No NE2000125 - proposed operation and maintenance of the Braidwood Nuclear Station cooling pond dam, Will County.

Office of Water Resources. December 20, 2000.

n. (HDR 2008) HDR Engineering, Inc., 2008.

Investigations to Determine Presence of State-Listed Species of Fish and Freshwater Mussels in the Kankakee River near the Braidwood Nuclear Station Warm-water Discharge Channel. October 2008.

HWQ-Hydrology and Water Quality -

Bill Ford GW Groundwater Tour Reauest GW-1 2.3 3.5, 4.5 On the groundwater tour or surface water tour Bill Ford we would like to visit: (1) The discharge line to the Kankakee River; (2) The coolinQ pond and associated fresh water holding pond; and (3) Areas of groundwater contamination and clean up.

Interview with Coqnizant Personnel GW-2 2.3 3.5, 4.5 We would like to discuss what is being Bill Ford learned about groundwater flow direction, rates, and water chemistry, from the "Site Groundwater Protection Initiative" that is part of the Nuclear Energy Institute (NEI) Industry Groundwater Protection Initiative. As part of this discussion, we would like to view a map showing the location of the wells that are part of this initiative and understand hydrogeologic units each well is monitoring.

GW-3 2.3 3.5, 4.5 We would like to discuss how much Bill Ford groundwater (if any) is removed by sump pumps in the basements and throughout the facility.

GW-4 2.3 3.5, 4.5 We would like to discuss what impact on Bill Ford groundwater flow, either recharge to or discharge from does the cooling pond have on aquifers around the sides of the pond.

GW-5 2.3 3.5, 4.5 We would like to discuss what would happen Bill Ford to the impoundment, when the Braidwood Power Plant shuts down (this is relevant to the no action alternative). Would the pond dry up? Would the aquifers in contact with the sides of the impoundment discharge into the pond? What was the status to the near surface aquifers, after coal mining (i.e., were they dewatered by the open pit?), but before the construction of the cooling pond?

GW-6 2.3 3.5, 4.5 We would like to know if any non-radiological Bill Ford contaminants have been detected in groundwater underlying the site. If so, what is the status of the contamination?

Information Made Available Durina the Audit GW-7 2.3 3.5, 4.5 We would like to view the following Bill Ford references:

a. (Exelon Generation 2011) Exelon Generation Company, LLC. 2011.

Hydrogeologic Investigation Report-Fleetwide Assessment - Braidwood Generating Station, Braceville, IL, Revision 1. Braceville, IL. December 2011.

b.

(I EPA 2013a) Illinois Environmental Protection Agency. 2013. Re: Exelon Braidwood Station NPDES Permit Number IL0048321 VB 1 Completion Report. Letter to J. B. Fewell, and M. E.

Kanavos. March 28, 2013.

c.

(I EPA 2013b) Illinois Environmental Protection Agency. 2013. Re: Exelon Braidwood Station NPDES Permit Number IL0048321 VB 2/3 and Pond Area Completion Report. Letter to J. B.

Fewell, and M. E. Kanavos. March 28, 2013.

d. (I EPA 2013c) Illinois Environmental Protection Agency. 2013. Re: Exelon Braidwood Station NPDES Permit Number IL0048321 VB 4 Completion Report. Letter to J. B. Fewell, and M. E.

Kanavos. March 28, 2013.

GW-8 2.3 3.5, 4.5 We would like to view the documents which Bill Ford contain the Final Plan Completion Reports for tritium remediation and were submitted on January 16, 2013 to the Illinois EPA. The reports provide a summary of the actions taken and results achieved to remediate groundwater along the Braidwood blowdown line and sought Illinois EPA approval to terminate the active remediation process.

The reports explained Braidwood's approach for either closing the groundwater monitoring wells that have been used to evaluate the progress of tritium remediation or transitioning them into its routine groundwater sampling under the Radiological Groundwater Protection Program.

HWQ-Hydrology and Water Quality-Surface Kevin Folk sw Water Information Made Available Durinq the Audit SW-1 3.1.3.1, 3.4, 4.4 Agreement with I EPA limiting Braidwood's Kevin Folk 4.1 consumptive use of surface water SW-2 3.1.3.1 3.4, 4.4 Braidwood Storm Water Pollution Prevention Kevin Folk Plan SW-3 3.1.5, 3.4, 4.4 Status summary of issuance of Braidwood's Kevin Folk 9.1.1, NPDES permit which expired 9/1/2000 9.1.4 SW-4 3.1.3.1 3.4, 4.4 A large scale map or maps depicting NPDES Kevin Folk outfall locations SW-5 3.1.3.1, 3.4, 3.5, Please provide a summary of available Kevin Folk 4.1. 4.8 4.4, 4.5 historical and current water quality data for the cooling pond (including temperature);

include avg. ambient values and max.

observed values and date of occurrence, if available. Please provide a data set that covers the last 1 0 years.

SW-6 3.1.3.1' 3.4, 4.4 Please provide all non-radiological monitoring Kevin Folk 4.1 reports from the last 5 years, including NPDES Discharge Monitoring Reports and surface water withdrawal records/reports.

SW-7 3.1.3.1' 3.4, 4.4 Copies of any Notices of Violation (NOVs),

Kevin Folk 4.0.1, nonconformance notifications, or related 9.1.1 infractions received from regulatory agencies associated with NPDES permitted discharges, sanitary sewage systems, groundwater or soil contamination, including spills, leaks, and other inadvertent releases of fuel solvents, chemicals, or radionuclides (covering past 5 years). Include correspondence of self-reported violations to responsible agencies.

SW-8 2.2.3.

3.4, 3.5, In light of excessive cooling pond Kevin Folk 2.2.5 4.4, 4.5, temperatures experienced during July 2012, 4.12 please provide a discussion and any relevant information as to whether a warming trend has been observed in the cooling pond during the period of plant operations? Please provide any study(s) or data that support the conclusions reached (e.g., mean annual, seasonal, and/or or monthly water temperature trend for the period of record).

Also, please describe any measures which Exelon has taken or plans to take to mitigate the impact of high cooling pond temperatures on plant operations.

SW-9 9.1.4, 3.4, 4.4 Application for Clean Water Act Section 401 Kevin Folk AppG Certification referenced in Exelon's May 18, 2012 letter to the I EPA Interview with CoQnizant Personnel SW-10 3.4, 4.4 A breakout meeting with the applicant's Kevin Folk subject matter expert(s) and/or the contractor(s) responsible for writing the surface water hydrology and quality portions of the ER and who can discuss the plant's cooling water system (CWS) and intake, effluent discharges, and affected water resources.

Tour Request SW-11 3.4, 4.4 The hydrology team would like a general tour Kevin Folk of the site and vicinity including associated intake structures and conveyances (i.e.,

Kankakee River intake and screen house, cooling pond intake screen house; and blowdown/intake pipeline routings}, significant streams and other surface water features, and NPDES outfall locations (e.g., blowdown outfall 0011 MET Meteorology, Air Quality, and Noise Bob Hoffman Information Made Available Durina the Audit MET-1 2.10 3.2; 4.2 Provide a copy of Braidwood Station Units 1 Bob Hoffman and 2 (Braidwood) Federally Enforceable State Operating Permit for stationary emission sources (large diesel generators, small diesel engines, two auxiliary boilers, gasoline storage and dispensing facilities with vapor balance systems, and rad waste volume reduction system).

MET-2 2.10 3.2; 4.2 Provide copies of Braidwood's annual Bob Hoffman emission reports for the most recent five

_years.

MET-3 2.10 3.2; 4.2 Identify combustion sources of hazardous air Bob Hoffman pollutants (HAPs) at Braidwood and amount released for the most recent five years.

MET-4 2.10 3.2; 4.2 Provide details of Braidwood's stationary Bob Hoffman emission sources including, as applicable, operating hours per year (last 5 years), fuel consumption and rate, horsepower ratings, capacity.

MET-5 2.10 3.2; 4.2 Provide copies of any NOV received and Bob Hoffman describe the complaint history associated with Braidwood's Federally Enforceable State Operating Permit.

MET-6 2.10 3.2; 4.2 Are there expected upgrade/replacement Bob Hoffman activities for equipment/operation that could increase or decrease air emissions over the license renewal period (period of extended operation)?

MET-7 2.10 3.2; 4.2 The ER provides carbon dioxide (C02)

Bob Hoffman emissions from stationary combustion sources at Braidwood. Provide a site-wide emission inventory data (annual) for greenhouse gases (GHG) for the most recent 5 years. Emissions should include stationary combustion sources, mobile sources (commuters, visitors, delivery vehicle, etc.)

and other sources (refrigerant leakage, emissions from switchyard). Please: (1) identify and discuss the GHG emission sources and (2) provide information used to support the GHG emission values (e.g.

operating hours per year, fuel consumption and rates, and energy rating as applicable for each source).

MET-8 2.10 3.2; 4.2 Provide a description of the primary Bob Hoffman meteorological tower. Also describe the backup meteorological tower if one is present. 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 performance.

MET-9 2.10 3.2; 4.2 Provide the following meteorological Bob Hoffman information from the data recorded at Braidwood's meteorological facility. The meteorological data should include the most recent 5 years for which data is available.

Please provide the following information:

a. mean monthly and annual temperatures

b. mean monthly precipitation and annual precipitation

c. seasonal and annual summary wind statistics in the form of wind direction and speed frequency distribution tables and wind roses. Discuss predominant wind direction and speed by season and annual average, local terrain features affecting wind direction and speed, and provide a value for annual average wind speed.

d. seasonal stability class statistics determined from the Braidwood meteorological tower in tabular form for the last 5 years.

MET-10 2.10 In support of NRC's greenhouse gas, climate Bob Hoffman change, and cumulative impacts analysis, please address the following:

a. Has an atmospheric warming trend been observed in the vicinity of Braidwood during the period of plant operations?

Please provide data to support the conclusions reached (e.g. mean daily maximum annual temperatures, mean daily minimum annual temperatures, or mean annual temperature for the available period of record from Braidwood's meteorological station).

b. Has a river warming trend been observed in the Kankakee River during the period of plant operations? Please provide any study(s) or data that support the conclusions reached (e.g., mean annual, seasonal, and/or monthly water temperature trend for the period of record).

MET-11 2.10 3.2; 4.2 Provide noise emissions studies conducted at Bob Hoffman Braidwood Station Units 1 and 2 (Braidwoodl MET-12 2.10 3.2; 4.2 Provide information about any noise Bob Hoffman complaints for the most recent 5 years resulting from plant operation.

MET-13 2.10 3.2; 4.2 Identify noise sources at Braidwood and in Bob Hoffman the vicinity of Braidwood.

MET-14 2.10 3.2; 4.2 Provide ambient noise survey in and around Bob Hoffman the site, if any.

MET-15 2.10 3.2; 4.2 Identify nearby noise-sensitive receptors Bob Hoffman (e.g., residences, school, nursing home, childcare facility) and distance to those rece~tors.

Interview with Coonizant Personnel Provide a knowledgeable individual to Bob Hoffman discuss the following aspects of facility operations:

a. Stationary and mobile sources of air pollutants operating at Braidwood.

b. Air permits and emission inventories

c.

Meteorol~gical towers and data Tour Reauest Tour:

Bob Hoffman

a. General site tour

b. Major air emission sources

c. Onsite meteorological towers LU Land Use Briana Grange Interview with Coonizant Personnel LU-1 3.1.6 3.1, 4.1 The June 20, 2013, final rule that amended Briana 10 CFR Part 51 revised the scope of the Grange transmission line review for license renewal to be those: "transmission lines that connect the nuclear power plant to the substation where electricity is fed into the regional power distribution system and transmission lines that supply power to the nuclear plant from the grid" (1 0 CFR 51, Appendix B to Subpart A, Table B-1, Footnote 4). Accordingly, the NRC staff will only consider those transmission lines that meet this definition in its environmental review.

a. Identify the name and location of the substation that connects Braidwood to the regional grid.

b. Clarify which portions of the transmission lines described in Section 3.1.6 of the ER are in scope for the license renewal review according to the revised definition.

c. Confirm that the following statement regarding transmission lines that supply power to Braidwood remains true under the revised transmission line scope (ER Section 3.1.6, Page 3-14, Paragraph 2):

"No separate transmission lines exist for the purpose of supplying power to Braidwood from the _grid (off-site power)."

LU-2 2.1 3.1, 4.1 Does Exelon intend to perform any Briana construction or land-disturbing activities Grange during the proposed license renewal period that would be unrelated to refurbishment activities?

soc Socioeconomics Jeff Rikhoff Information Made Available Durino the Audit SOC-1 3.4 Provide updated permanent workforce data, Jeff Rikhoff preferably a residential distribution of permanent workforce by county in table format.

SOC-2 2.7 Provide updated property tax information, Jeff Rikhoff similar to the data provided in Tables 2.7-2 and 2.7-3 of the ER. Include data for the years 2011 and 2012, if available.

Interview with Coonizant Personnel SOC-3 2.7 Braidwood's last settlement agreement was Jeff Rikhoff signed on March 12, 2008, and covered tax years 2007 through 2011. What is the status of the settlement agreement for current and future tax years? Has Exelon Generation entered into a new settlement agreement with Will County and the other taxing districts to set the equalized assessed value (EAV) of Braidwood for tax years 2012 and beyond?

Please provide any relevant information.

SOC-4 2.7 In accordance with the 2008 settlement Jeff Rikhoff agreement, Exelon Generation agreed to make payments in addition to taxes (PlATs) to specific tax recipients. Under the agreement, Exelon Generation made PlAT payments of $3,711, 150 for tax year 2007 (paid in 2008) and $3,643,566 for tax year 2008 (paid in 2009). Have there, or will there be additional PlATs in the future? Were PlATs paid in 2010 and 2011 for tax years 2009 and 201 0? If so, have there been any changes to the list of recipients or proportion of payments in ER Table 2.7-1? Please

_Qrovide any relevant information.

EJ Environmental Justice Jeff Rikhoff Information Made Available DurinQthe Audit EJ-1 To help address the provisions of Section 4-4 Jeff Rikhoff "Subsistence Consumption of Fish and Wildlife" in Executive Order 12898, the following information is needed to assist the NRC in its environmental justice review:

a. Information about any observed subsistence consumption behavior patterns-specifically fish and wildlife consumption-by minority and low-income populations in the vicinity of Braidwood. This subsistence consumption behavior could consist of hunting, fishing, and trapping of game animals and any other general food gathering activities (e.g., collecting nuts, berries, and other plant material) conducted by minority and low-income individuals in the vicinity of Braidwood

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

CR Cultural Resources Emily Larson Information Made Available DurinQ the Audit CR-1 A map detailing the level of ground Emily Larson disturbance at the plant, including documentation on how this level of disturbance was determined. Has this understanding of the level of disturbance been coordinated with the IL State Historic Preservation Officer (SHPO)? [In other words is the IL SHPO in agreement that these portions of the plant have been disturbed sufficiently as to preclude the possibility of any significant archaeological resources existing in these areas, including the potential for burials?]

CR-2 A series of aerial photographs of the entire Emily Larson plant site and in-scope transmission line(s)

(during pre-construction, construction, and post-construction periods) looking at levels of disturbance that occurred during construction or since operation.

CR-3 USGS 7.5 minute topographic quadrangle Emily Larson maps of the plant and associated transmission lines up to the first substation with plant boundaries and transmission lines highlighted to establish the Area of Potential Effect (PE) under the National Historic Preservation Act.

CR-4 Vegetation/land-use maps of the plant and in-Emily Larson scope transmission line(s)_.

CR-5 Applicant's environmental review procedures Emily Larson for land-disturbing activities on the Braidwood site (e.g., trenching, clearing, digging)_.

CR-6 4.19 Applicant's cultural resource management Emily Larson plan as described in Section 4.19 in the ER.

CR-7 Applicant's transmission line management Emily Larson plan, including: timing of activities; danger tree removal and other clearing; inspections and repair activities conducted by ground vehicles; standard operating procedures or guidelines for the applicant and any contractors; erosion control procedures; technician training programs; and any regulations that restrict maintenance activities (e.g., looking for activities that could affect depth of disturbance, if any disturbance is necessary along the corridor).

CR-8 Information on management around less-Emily Larson developed areas of the plant site, especially near known historic and cultural resources or near unsurveyed areas.

CR-9 Documentation of construction projects that Emily Larson have occurred on the property since the construction of Braidwood to determine how historic and cultural resources were considered. Any documentation demonstrating compliance with existing environmental procedures would be useful.

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

CR-10 References presented in ER, especially Emily Larson survey reports and citations specified in the ER (Phase I and II archaeological surveys and literature search). Maps and survey reports identifying site locations at Braidwood will be needed during the site visit -these maps will not be docketed, as they are considered sensitive information.

CR-11 Verify if geomorphological work was Emily Larson conducted for the archaeological surveys to determine the depth of deposits and how deep archaeological remains may be present.

CR-12 Provide any consultation letters and other Emily Larson documentation indicating corres_Qondence to and from the SHPO and any federally recognized Native American Tribes that have aboriginal ties to the project area and surrounding lands not already provided in the ER. Has any contact been made with local historical societies or other local organizations with an interest in historic preservation?

CR-13 Any documentation of cultural resource Emily Larson training required for staff.

Interview with Coqnizant Personnel CR-14 Meeting with applicant staff familiar with the Emily Larson ER, cultural resources on the Braidwood site, and the Cultural Resource Management Plan to go over environmental compliance procedures to determine how impacts to historic and cultural resources are avoided and inadvertent discovery of historic and archaeological materials and human remains are dealt with. Based on references in ER, this will likely include discussion of fleet procedures for transmission line maintenance, the cultural resource management plan, and any other manuals or procedures specific to environmental compliance at Braidwood.

CR-15 Meeting with applicant staff and transmission Emily Larson line maintenance contractor to discuss right-of-way maintenance and monitoring and any procedures in place regarding protecting cultural resources along transmission line corridors.

Tour Reouest CR-16 General site tour Emily Larson CR-17 Transmission line tour up to first substation Emily Larson (including any archaeological sites recorded along the lines).

CR-18 Archaeological site tour of disturbed and Emily Larson undisturbed areas on the Braidwood site.

Staff familiar with the location of any previously disturbed archaeological sites would be preferred.

ALT Alternatives Bob Hoffman Information Made Available Durinq the Audit ALT-1 7.2.2.2, 6.2 Please provide for review the calculation Bob Hoffman 7.2.2.4 packages referenced in Section 7 of the ER as Tetra Tech 2012d, Air Emissions and Solid Waste from Coal-and Gas-Fired Alternatives for Braidwood Units 1 and 3; Chapter 7 Energy Alternatives Calculation Package, September 19, 2012; and Tetra Tech 2012e, Employment and Land Requirements for Alternatives to Braidwood Units 1 and 2 and Braidwood Units 1 and 2, LR Chapter 7 Energy Alternatives Calculation Package, September 18, 2012.

R Refurbishment Bob Hoffman Interview with Coqnizant Personnel R-1 3.2; 2.2 Chapter 3 of the Environmental Report states Bob Hoffman 4.0.1 that Exelon has no plans for refurbishment or replacement activities at Braidwood and hypothetically assumes that replacement of the Unit 2 steam generators may occur prior to the end of the 40-year initial license term (page 3-18 of the ER). However, in Chapter 4 Exelon hypothesizes that replacement of the Unit 2 steam generators may occur during the license renewal term (page 4-5 of the ER).

Please clarify the expected timeframe (year) that the Unit 2 steam generator replacement would occur and whether this hypothetical activity should be considered refurbishment.

Will steam generator replacement occur prior to or during the license renewal term?

R-2 3.2; 2.2 In support of NRC's analysis of the impacts of Bob Hoffman 4.0.1 Unit 2 steam generator replacement, please address the following questions:

a. How many temporary or permanent buildings will be constructed to support steam generator replacement activities?

b. What is the estimated footprint (ft2) of new buildings to be constructed? What is the estimated depth of excavation?