ML15154A509
| ML15154A509 | |
| Person / Time | |
|---|---|
| Site: | Braidwood  |
| Issue date: | 05/15/2015 |
| From: | Ranek N Exelon Generation Co |
| To: | Rules, Announcements, and Directives Branch |
| SECY RAS | |
| References | |
| 80FR15827 00007, NUREG-1437 | |
| Download: ML15154A509 (15) | |
Text
Gallagher, Carol
Subject:
FW: Comments regarding Draft NUREG-1437 Supplement 55 for the Braidwood Station License Renewal Attachments: RS-15-146_signed w-Encl_15May2015.PDF; BRW_DSEISconsolidatedminorcmts_
15may2015.pdf From: Ranek, Nancy L.:(GenCo-Nuc) [1]
Sent: Friday, May 15, 2015 5:40 PM To: Baum, Richard Cc: Tran, Tam; Gallagher, Michael P:(GenCo-Nuc); Hufnagel Jr, John G:(GenCo-Nuc); Karpa, Zigmund A:(GenCo-Nuc);
Beem, Roland Duane:(GenCo-Nuc); Hersey, Kevin K:(GenCo-Nuc); Petro, John R:(GenCo-Nuc); Gorga, Michael J..:(GenCo-Nuc)
Subject:
Comments regarding Draft NUREG- 1437 Supplement 55 for the Braidwood Station License Renewal Hi Rick --
As you know, by letters dated Tuesday, May 12, 2015 and Friday, May 15, 2015, Exelon Generation submitted comments for the record regarding the Draft NUREG-1437 Supplement 55 for the Braidwood Station License Renewal (Braidwood DSEIS). On May 12, I provided a copy of Exelon's May 12 letter, and I am attaching the May 15 letter (RS-15-146 w/
enclosure) to this message for your information.
To this message, I am also attaching a list of additional minor updates, corrections, and clarifications with respect to the Braidwood DSEIS that were not covered by Exelon's May 12 and 15 letters and that NRC may want to consider in the process of finalizing NUREG-1437, Supplement 55.
Please call if there are questions.
Thanks.
O raa-Nancy L. Ranek C=>
License Renewal Environmental Lead 71 w
m Exelon Generation, LLC 200 Exelon Way, KSA/2-E Kennett Square, PA 19348 Phone: 610-765-5369 Fax: 610-765-5658 Email: nancy.ranek@exeloncorp.com NJ Ur.
SUNSI Review Complete Template = ADM - 013 E-RIDS= ADM-03 1
5/15/2015 Exelon Generation Company, LLC Updates, Corrections, and Clarifications on Draft Generic Environmental Impact Statement for License Renewal of Nuclear Plants, Supplement 55 Regarding Braidwood Station, Units 1 and 2 NOTE: Where changes to draft text are suggested, proposed inserts are in bolded italicfont and proposed deletions are in strikethceu.gh font.
Item Section # Page # Line # Comment In line 11 on page xxi of the Executive Summary, consider revising the text as follows to improve clarity:
Executive Summary "... (GELS) for License Renewal of Nuclear Plants, Rev. 1" Because Chapter 4 is quite large, consider changing the sentence in lines 28 to 29 on page xxii as follows:
2 Executive xxii 28 Ghapter-4Section 4.14 of this SEIS presents the Summary process for identifying new and significant information.
Acronyms xxvii 25 & 26 Two acronyms for "APE." Consider using different 3 acronyms for each term to avoid confusion.
Acronyms xxix 30 to 31 Two acronyms for "DMS." Consider using different 4 acronyms for each term to avoid confusion.
Acronyms xxxi 12 & 19 Second acronym listing for "fps" is redundant. Consider 5 deleting the line 19 entry.
Acronyms xxxi 27 & 28 Two acronyms for "Gl." Consider using different acronyms 6 for each term to avoid confusion.
Acronyms xxxiii 19 & 20 Two acronyms for "ISO". Consider using different 7 acronyms for each term to avoid confusion. It appears that the line 20 entry should be "10S."
Acronyms xxxviii 6 &7 Two acronyms for "RHR." Consider using different 8 acronyms for each term to avoid confusion.
1.4 1-3 10 In line 10 on page 1-5, delete the word "generic" as follows:
9 "Of these issues, the NRC staff determined that some g8RGFOG issues are generic to all plants ... .
Consider adding the Native American Graves Protection and Repatriation Act to the Federal laws listed in lines 5 to 10 on page 1-6 that direct Federal agencies to consult with one another regarding proposed agency actions.
5/15/2015 Page 2 of 14 Otherwise, it is not clear why only Native American tribes were consulted - "based on historic cultural ties" could include non-Native Americans who settled the land centuries ago, but there is no requirement to consult with their descendants.
In line 33 on page 1-6, add the word "applicable" as 11 1.10 1-6 33 follows: "Exelon is responsible for complying with all applicable NRC regulations..."
In line 34 on page 1-6, replace "Appendix F," which contains NRC Staff s evaluation of Severe Accident 12 1.10 1-6 34 Mitigation Alternatives, with "Appendix B," which lists applicable laws, regulations, and agreements.
Consider adding a sentence about state activities to Section 1.11 on page 1-7 because, as written, the section 13 1.11 .1-7 4 does not include a discussion of state activities, although it is titled "Related Federal and State Activities".
2.1.1 2-1 39 In line 39 on page 2-1, add "s" after "follow":
"[The GELS] summarizes the general types of 14 activities that are carried out during the operation of a nuclear power plant such as Braidwood, as follows:"
In lines 21 to 22 on page 2-2, correct the text as follows for consistency with Section 4.6.1.2 (page 4-32) and the Applicant's ER Section 3.2 (page 3-18):
15 2.1.2 2-2 21 to 22 "However, Exelon identified two hypothetical refurbishment activities that may occur du4gprior to the period of continued operation: ..."
Consider adding "Supercritical pulverized coal (SCPC)" to the list in the text box on page 2-3 of "Other Alternatives 16 2.2.2 2-3 Text box Considered But Dismissed" because SCPC is identified in Sections 2.2.2.2 and 2.3 as such a technology.
For completeness, consider adding a column in Table 2-1 on page 2-7 for "Purchased Power." Although the characteristics of purchased power are different than those Table of the technology alternatives, the exclusion of purchased 17 2.2.2 2-7 2-1 power from Table 2-1 could lead the reader to believe it was not analyzed in detail. Identifying the key characteristics of purchased power, although different in nature from those of the technologies, could be informative.
2.2.2.1 2-10 42 to 43 The discussion of the New Nuclear Alternative appears to 18 contain an inconsistency in lines 42 to 43 on page 2-10. If the Illinois moratorium on new nuclear construction remains in place, such that the new nuclear alternative would be
5/15/2015 Page 3 of 14 located elsewhere in the ROI, outside Illinois, then how could the existing transmission lines leaving the Braidwood site be expected to serve the replacement reactor with few modifications? Consider clarifying this section.
2.2.2.2 2-11 45 to 46 Consider inserting text in lines 45 to 46 on page 2-11, as follows:
19 "The IGCC plant will reduce carbon emissions per MWh by nearly half compared to conventional coal-firedpower plants (Duke Energy 2013)."
2.2.2.4 2-15 47 In the phrase "Distance separation ensures that the two wind farms will not simultaneously experience the same 20 climate" in line 47 on page 2-15, "climate" does not appear to be the correct word. Consider using "weather conditions" instead.
Consider adding a column in Table 2-2 on page 2-25 for Table "Special Status Species and Habitats," which is discussed 2-2 as a separate resource in Chapter 4 of the Draft SEIS.
3.1.3 3-4 22 to 25 Blowdown is released (not "rinsed") continuously (not periodically) from the cooling pond to reduce concentrations of dissolved solids (not "remove impurities and sediment.") Consider revising the sentence in lines 23 to 24 on page 3-4 as follows:
"Water that is not lost to evaporation is either 22 recirculated through the system as cooling water or discharged as blowdown (i.e., water that is perAGGIOdally r:nod removed from the cooling pond system to-F-emeve avoid the buildup of dissolved solids and other impurities and sediment-that may degrade plant performance) to a secondary receiving water body.
3.1.3 3-5 4 to 5 Consider revising the sentence in lines 4 to 5 on page 3-5 as follows:
Braidwood's cooling pond was created in 1980 and 1981 by pumping water from the Kankakee River 23 ino the si.te'. formor
. trip mine spoilsinto a diked area, which surroundsportionsof a former strip mine, inundatingdeep pits, borrow areas,and depressions.
3.1.3 3-7 and Figs 3-4 Consider marking the makeup water pipeline on Figures 24 3-8 and 3-5 3-4 and 3-5.
3.1.3 3-9 3 to 5 The sentence in lines 4 to 5 on page 3-9 states that the 25 Braidwood NPDES permit "limits blowdown discharges to the river to a 30-day average of 54 million liters per day
5/15/2015 Page 4 of 14 (Lpd) or 14.3 million gallons per day (mgd)." This statement was based on the NPDES permit issued by IEPA to Braidwood Station in 1997. In 2014, IEPA issued a renewed NPDES permit requiring blowdown flow to be monitored and reported, but places no limit on the flow volume. Consider revising the two sentences in lines 3 to 5 on page 3-9 as follows:
Water enters the river through a submerged multi-port diffuser at mid-river, which is regulated under Braidwood's NPDES permit (IEPA 7-942014) as Outfall 001. The permit limits blowdown dischargcs tA thrp ri~rpr te a 30 da nrn nF~ f 64 mfillion
..........Wpmr~
A- /I -AN - I A Q A-(-Fgd). The permit indicates that the daily average blowdown flow from Outfall 001 is estimated to be 43.2 million gallonsper day (mgd)._
3.1.6.4 3-17 14 to 15 To reflect current railway ownership, consider revising the sentence in lines 14 to 15 on page 3-17 as follows:
"The Canadian National Railway (formerly Illinois 26 Central Gulf Railroad) maintains a railroad spur eR site that connects to the Braidwood Station-wit the IllinoiS Central Gulf Railroa;d.
3.2.1 3-18 9 tolo In lines 9 to 10 on page 3-18, the DEIS states:
"...strip mined spoils on the site were flooded to create a 2,540 ac (1,028-ha) artificial cooling pond, which provides Braidwood with a source of cooling water."
Consider replacing the above-quoted phrase with the 27 following text:
"... cooling pond, which has a total surface area of 1,028 ha (2,540 ac), was created by flooding portions of a former strip mine and provides Braidwood with a source of cooling water. Spoil piles/spoil areas associated with the former strip mine became islands, berms, wetlands, and uplands within the cooling pond."
3.2.1 3-18 24 to 25 To reflect current railway ownership, consider revising the sentence in lines 24 to 25 on page 3-18 as follows:
28 "The site also includes a railroad spur, which connects to the Illinols Gu-lf Rahlroad CanadianNationalRailway (formerly Illinois Central Gulf Railroad)."
5/15/2015 Page 5 of 14 3.5.1.1 3-28 4 to 5 Consider revising the sentence in lines 4 to 5 on page 3-28 as follows to clarify that only a portion of the cooling pond is open to the public:
29 The-A portion of the cooling pond is available for public access for fishing, waterfowl hunting, and fossil collecting as a result of an agreement between Exelon and the IDNR.
3.5.1.2 3-28 24 to 26 Correct the typographical error in line 25 on page 25 as follows:
30 "... withdrawing water from the river when the flow rate falls below 42-2442 cfs (19,394198,383 gpm or 4-212.5 m3/s) 3.5.1.2 3-31 Table Although the sum of the individual "Approximate Flow" 3-6 rates for the contributing discharges that comprise the "001 Cooling Pond Blowdown Line" ouffall in the current NPDES permit issued by IEPA on July 31, 2014 is 14.638 mgd, which is consistent with the information in Table 3-6 of the draft SEIS on page 3-31, the NPDES permit also reports 31 the daily average flow (DAF) from Ouffall 001 as 30,000 gpm or 43.2 mgd. Because Table 3-5 on page 3-28 reports that the average actual return discharge to the Kankakee River during the period from 2008 to 2012 was 23 mgd, consider whether the entry in Table 3-6 for Ouffall 001 Average Flow Rate should be changed.
3.5.1.2 3-31 Table Delete "IEPA 1995" from the list of "Sources" for Table 3-6 3-6 on page 3-31 because there is no corresponding entry in 32 Section 3.14 (References). Also delete the second "2014c" from the list of "Sources" because it appears to be a duplication of the previously listed "Exelon 2014c."
3.5.2 3-33 All lines "Exelon 2013j" is cited throughout Section 3.5.2 on pages thru 3- 3-33 through 3-36 as a source document for information 36 about groundwater conditions and groundwater use, but 33 Section 3.14 (References) describes this reference as "letter from Plant Manager to Wildlife Habitat Council,"
which is an unlikely reference document for such information.
3.6.3.1 3-44 46 In line 46 on page 3-44, change the text to correct spelling 34 as follows:
... spikerush (Eleocharis evateovata),.."
3.6.3.1 3-45 4 In line 4 on page 3-45, consider revising the text as follows to improve accuracy "During Braidwood construction, creation of the 35 cooling pond inundatedabandonedmine pits and borrow areasassociatedwith strip-mining 36on the propertyin the 1940stl;e-etip MOe 6poil Wore flooded the- cooling pond.
to4 croG49ato_
5/15/2015 Page 6 of 14 3.6.3.2 3-47 16 to 17 In lines 16 to 17 on page 3-45, consider revising the text as follows to improve accuracy:
"It is possible that the creation of the cooling pond, which flooded most of the str4p-miPe 36 &peiIabandoned mine pits and borrow areas associatedwith strip-miningon the propertyin the 1940s, affected the diversity of mammals on the site."
3.6.3.2 3-47 18 and Exelon's Wildlife Management Plan for Braidwood is cited 37 42 as "Exelon 2013j" in line 18 on page 3-47, but it is designated in Section 3.14 (References) as "Exelon 2013f."
3.6.3.2 3-48 3 In line 3 on page 3-48, correct the spelling of the scientific name for 38 "common snapping turtle" as follows:
... common snapping turtle (hileyd*aChelydra serpentine)," ...-
3-48 5 In line 5 on page 3-48, correct the spelling of the scientific 39 name for "ornate box turtle" as follows:
"The ornate box turtle (Terrapene emateomata),..
3.7.1 3-50 22 to 34 In lines 26 to 31 on page 3-50, it is unclear whether the sentence "Silted pools separated by solid bedrock.. .(Page et al. 1991)" refers to (1) the Kankakee River in the vicinity of the Braidwood intake/discharge, or (2) the reach of river that has been designated "Biologically Significant," or (3) the Kankakee River generally. As a result, the paragraph in lines 22 to 34 on page 3-50 leaves the impression that all 40 of these sensitive species occur in the vicinity of the Braidwood intake and discharge. With regard to these species and the two extirpated species discussed in the sentence in lines 31 to 33, the information source is cited as a 24-year-old report and is based on 30-year-old surveys and studies. To the extent that they are available, consider updating the information using more recent studies and surveys.
3.7.1.2 3-50 36 to 37 In lines 36 to 37 on page 3-50, revise the sentence as follows:
Braidwood's 2,540 ac (1,030 ha) cooling pond was created in 1980 and 1981 by pumping water from 41 the Kankakee River into the cite' former Gtrip mine s&p94 a diked area,which surroundsportions of a former strip mine, inundating deep pits, borrow areas,and depressions.
3.7.1.2 3-50 37 to 40 The sentence in lines 37 to 40 on page 3-50 contains an 42 error in the year during which the lease agreement between ComEd and IDNR was first signed, and it also would be more accurate if modified to explain that not all of
5/15/2015 Page 7 of 14 the cooling pond is accessible to the public. Consider modifying the sentence in lines 37 to 40 on page 3-50, as follows:
In the fall of 18-1-1991, the Illinois Department of Conservation (now the IDNR) entered into a long-term lease agreement with ComEd (the constructor and original operator of Braidwood) to allow general public access to a portion of the cooling pond for fishing, waterfowl hunting, and fossil collecting (IDNR 2014d).
3.7.2.1 3-53 1 to 3 In lines 1 to 3 on page 3-53, revise the sentence as follows to address a typographical error:
In 2008, Exelon commissioned two studies (ESI 43 2009; HDR 2008) to determine the presence of State-listed fish and mussel species near the Braidwood makeup-waedischarge channel on the Kankakee River.
3.7.3.2 3-69 Table In the first column in Table 3-15 on page 3-69, the scientific 44 3-14 name of largemouth bass should be Micropterus salmoides, not "sahnoides."
3.7.3.2 3-72 Table In the first column in Table 3-14 on page 3-72, the scientific 45 3-15 name of largemouth bass should be Micropterus salmoides, not "sahnoides."
3.7.5.2 3-76 32 to 33 In lines 32 to 33 on page 3-76, revise the sentence as follows to correct errors in the description of the location of the Kankakee River State Park:
The northern boundaryof the Kankakee River State Park lies approximately 4-03 mi (4-65 km) southeast and downstreamupstream from the 46 Braidwood s4eriverscreen house.
Because the Kankakee River State Park is several miles upstream from the river screen house, Braidwood operations are not likely to have any effect on aquatic habitats in the vicinity of the Kankakee River State Park or in the reach of river adjacent to the park.
3.8 3-77 38 In line 38 on page 3-77, revise the sentence as follows to improve its clarity:
47 Listed plants located on private land are not protected from take, although collecting or maliciously harming them on Federal land is illegal.
3.8.2 3-79 Table Consider updating Table 3-17 on page 3-79 based on 3-17 publication of the Final Rule listing the Northern longeared 48 bat, which occurred April 2, 2015 (80 FR 63, p 17974), after the DSEIS was completed. This change in status is effective May 4, 2015.
5/15/2015 Page 8 of 14 3.8.2 3-83 27 to 29 Consider updating the text in lines 27 to 29 on page 3-83 based on publication of the Final Rule listing the Northern 49 longeared bat, which occurred April 2, 2015 (80 FR 63, p 17974), after the DSEIS was completed. This change in status is effective May 4, 2015.
Revise Table 3-32 on page 3-102 by deleting the last row Table in the table regarding "Braidwood Park District" because it 50 3.10.5 3-102 3-32 duplicates the same information provided five rows above it.
The definition of the No-Action Alternative that is assumed in Section 4.2.2.1 on page 4-2 is inconsistent with the assumed definition for the No-Action Alternative in Section 4.3.2.1 on pages 4-6 to 4-7. As an example, the impacts for land use under "no-action" in Section 4.2.2.1 51 4.2.2.1 4-2 17 acknowledge that impacts could occur if new generation capacity is constructed to replace the lost generation of Braidwood. However, on air quality (Section 4.3.2.1) the "no-action" analysis is based on an assumption of no replacement power.
In line 39 on page 4-8, nitrogen oxide (NOx) emissions from Braidwood are reported as 28 tons per year, while the Applicant's Environmental Report identifies NOx emissions as 27.11 tons per year. Because emissions reported for all other pollutants in lines 38 to 42 on page 4-8 are in agreement with the Applicant's Environmental Report, consider replacing "28" with "27.11" in line 39. This comment also applies to the NOx entry for the "Proposed Action" in Table 4-3 on page 4-20.
4.4.6 4-23 19 In line 19 on page 4-23, the amount of land, 8,009 ha, indicated for the solar PV and wind farm components of the 53 "combination" alternative is inconsistent with the amount of land listed for these components in Section 4.2.6.1 (Land Use) on page 4-4: 4,098 ha for wind and 2,731 for solar.
4.5.1 4-26 1 For consistency with Section 3.5.1.2, which reports that the average consumptive use rate for the period from 2008 to 2012 was 35 cfs, the sentence in line 1 on page 4-26 should be corrected as follows:
54 "As described in Section 3.5.1.2, the average annual consumption [of water] for the Braidwood site from the Kankakee River is 44-35 cfs (44-40.99 ml/s)."
4.5.1 4-26 4 to 8 The sentence in lines 4 to 8 on page 4-26 states that an IDOT/IDNR permit "requires Exelon to stop withdrawing water from the Kankakee River when the flow rate falls below 422 cfs." As noted in an earlier comment regarding
5/15/2015 Page 9 of 14 DSEIS Section 3.5.1.2, the correct flow rate below which Exelon must stop withdrawing water from the Kankakee River is 442 cfs.
4.6.1.2 4-32 3 to 5 The text in lines 3 to 5 on page 4-32, referring to Section 3.6, states that "approximately 1,280 ac of the Braidwood site (37%) remains as natural areas that are either leased for agricultural use, leased to IDNR for recreational use, or are unmanaged. Section 3.6 actually states that 1,653 acres are maintained as natural areas, 67 acres of which are leased to private individuals for agricultural use, and 56 1,280 acres of which are leased to IDNR for recreational use. The remaining 306 acres are presumably the unmanaged natural areas.
The former value (1,280 ac) would equal 29 percent of the total site acreage of 4,457 acres. The latter value (1,653 ac) would equal 37 percent of the total acreage of 4,457 ac.
Consider revising lines 3 to 5 on page 4-32 to harmonize the numbers with Section 3.6.
4.6.1.2 4-32 28 to 36 As was discussed in Section 3.2 (Refurbishment Activities).
of the Applicant's ER for Braidwood, although there are no plans for refurbishment or replacement activities at Braidwood, for the purposes of the License Renewal Environmental Report, Exelon Generation hypothetically assumed that replacement of the Unit 2 steam generators may occur prior to the end of the 40-year initial license term. Accordingly, in lines 28 to 36 on page 4-32, the following revisions are needed to correct inaccuracies.
"Other operations and maintenance activities that could occur in the future include the replacement of the I ntl1-Unit 2 steam generators. While Exelon has previously replaced the 11ph21Unit I steam generators, Exelon has not replaced the I'pot-IUnit 57 2 steam generators. Exelon has no plans to replace the IJI-M IUnit 2 steam generators at this time, but Exelon may choose to replace them prior to the end of the 40-year initial license term. Because steam generator replacement is not necessary for safe operation during license renewal, the NRC does not consider it part of the proposed action. As such, the impacts of Ul*=t-l-Unit 2 steam generator replacement on terrestrial resources are discussed in Section 4.15.4 (cumulative impacts) rather than in this section. Exelon (2014g) is planning no other land-disturbing activities or construction unrelated to possible UIiIt(IUnit 2 steam generator replacement.
As needed, harmonizing changes should also be made in Section 4.15.4 (cumulative impacts) of the DSEIS.
5/15/2015 Page 10 of 14 58 4.7.1.2 4-41 11 In line 11 on page 4-41, "Clupids" should be "clupeids."
4.7.1.2 4-54 2 to 10 Delete the paragraph in lines 1 to 10 on page 4-54 because it appears verbatim two pages earlier (on page 4-52, lines 59 12 to 20) and, thus, appears to have been inadvertently repeated here.
4.7.1.3 4-65 14 Delete the words "on March 19, 2012" at the beginning of 60 line 14 on page 4-65 because they are repeated at the beginning of the sentence in line 13 on page 4-65.
4.7.1.3 4-65 22 to 23 Insert the word "not" as follows in the sentence in lines 22 to 23 on page 4-65:
"Braidwood thermal effluent is limited by the IAC 61 and the Braidwood NPDES permit to ensure that it does not create adverse effects on the aquatic communities in the Kankakee River."
In lines 33 to 36 on page 4-79, revise the text as follows to improve accuracy:
The remaining acres are heavily disturbed due to power plant construction (e.g., power block, blowdown pipeline) and operation; are former strip 62 4.9.1 4-79 35 to 36 mine land which has been repurposed or revegetated; or are part of the iaRn mnad cooling pond createdin 1980 and 1981 by pumping water from the Kankakee River into a diked area, which surroundsportionsof a former strip mine, inundatingdeep pits, borrow areas,and depressionsoxcvaatod by CoinEd (Exelon 2014b).
4.11.1.3 4-100 25 to 27 Consider revising the sentence in lines 25 to 27 on page 4-100 as follows (or in a similar manner):
"Exelon stated in the ER that the 26 SAMAs determined to be cost-beneficial in the ER baseline 63 and uncertainty evaluations have been submitted to the Braidwood Plant Health Committee for further implementation consideration in accordancewith current Braidwoodprocesses and procedures for evaluating possible plant modifications (Exelon 2013c).
4.15.1 4-118 33 to 34 In lines 33 to 34 on page 4-118, correct the typographical error as follows:
"This section describes the environmental impacts 64 aseeGiateassociated with the fuel cycles of the proposed action and replacement power alternatives.
4.15.3 4-122 14 tol7 In lines 14 to 17 on page 4-122, revise the text as follows to 65 avoid suggesting that Braidwood's GHG emissions and climate change are significantly linked in some way:
5/15/2015 Page 11 of 14 "The following sections discuss: (a) GHG emissions released from operation of Braidwood and alternatives and (b) the environmental impacts that could generally occur from changes in climate conditions, although the significantcontributory effects would come from other sources independent of Braidwood."
Although Section 4.8 describes impacts to threatened and endangered species, Section 4.16 (cumulative impacts) 66 4.16 General does not include a summary discussion of threatened and endangered species. This omission is inconsistent with the treatment in Section 4.16 of other resource areas.
4.16.3.1 4-135 22 to 23 In lines 22 to 23 on page 4-135, correct the typographical error as follows:
Dresden Nuclear Power Station, Units 2 and 3 67 (listed in Appendix E) are currently operating and W-thdrAWA- withdrawwater from the Kankakee River.
4.16.3.2 4-138 5 to 6 In lines 5 to 6 on page 4-138, the DSEIS acknowledges and and that "consumptive [groundwater] use would continue to be 4-139 1 to 2. SMALL ." Then, in lines 1 to 2 on page 4-139, the DSEIS states: "However, for cumulative impacts, when combined with groundwater consumption by the Chicago Metropolitan Region, the impact to consumptive groundwater use is MODERATE to LARGE" This latter statement should be modified to more clearly communicate that the impact of groundwater consumption by the 68 Chicago Metropolitan Region is MODERATE to LARGE, and the use by Braidwood Station does not alter that conclusion. The change would be consistent with treatment of site-specific versus cumulative impacts elsewhere in the DSEIS. For example, in the discussion of cumulative impacts of Climate Change (page 4-150), the DSEIS states: "... climate change is projected to occur with or without present and future GHG emissions from Braidwood."
4.16.7 4-145 17 to 18 In lines 17 to 18 on page 4-145, the text should be corrected as follows:
69 "Exelon indicated that the Unit 2 steam generator replacement wouldmay occur du4ngpriorto the license renewal term."
4.16.7 4-145 32 In line 32 on page 4-145, the text should be corrected as follows:
70 "Exelon indicated that the reactor vessel heads weuldmay be replaced before the license renewal term."
5/15/2015 Page 12 of 14 4.16.11 4-150 28 to 29 Consider clarifying the conclusion in lines 28 to 29 on page 4-150 as follows:
"The NRC staff concludes that the cumulative impacts from the proposed license renewal and 71 other past, present, and reasonably foreseeable projects would be MODERATE. although the impacts will be overwhelmingly due to other proiects aroundthe world, independent of Braidwood."
The list of alternatives considered is not consistent with the alternatives considered or considered and dismissed in 72 5.2 5-1 22 Chapter 2. Coal-IGCC was evaluated but is not included in the list in Section 5.2. Super critical pulverized coal was not evaluated but is included in the list in Section 5.2.
Purchased power was an alternative considered though it is not included on the list in Section 5.2. Consider adding 73 5.2 5-1 20 to 24 "purchased power" to the bulleted list in lines 20 through 24 on page 5-1.
5.2 5-1 32 Correct the typographical error in line 32 on page 5-1 as follows:
74 "...impacts for Aquatic Resources, and SMALL impacts-i6in all other areas."
F.1 F-1 22 to 24 In lines 22 to 24 on page F-i, consider revising the sentence as follows (or in a similar manner):
"Exelon has submitted all 26 potentially cost-75 beneficial SAMAs to the Braidwood Plant Health Committee for further implementation consideration in accordancewith current Braidwood processes and procedures for evaluating possible plant modifications."
F.2.1 F-2 2 to 6 In lines 2 to 6 on page F-2, the wording of the first sentence is confusing, particularly the meaning and purpose of the phrase "effective change majority". Consider revising as follows:
"Exelon combined two distinct analyses to form the basis for the risk estimates used in the SAMA 76 analysis: (1) the Braidwood Levels 1 and 2 PRA modelsT (both- are essentially (effe*t*e*"V,.ha*,e naejity).new models developed since the IPE models), and (2) a supplemental analysis of offsite consequences and economic impacts (essentially a Level 3 PRA model), developed specifically for the SAMA analysis."
F.2.2 F-7 12 In line 12 on page F-7, replace the phrase "the LER analysis" to "the large, early release (LER) analysis."
5/15/2015 Page 13 of 14 F.2.2.2 F-8 36 to 37 In lines 36 to 37 on page F-8, consider adding text as follows:
"The Braidwood IPEEE was submitted in June 1997 (ComEd 1997b), in response to Supplement 4 of GL 78 88-20 (NRC 1991 a), which requested that each power reactorlicensee identify and reportto the NRC plant-specific vulnerabilitiesto severe accidents caused by external events."
F.2.2.2 F-9 20 to 23 In lines 20 to 23 on page F-9, consider revising the first two sentences as follows:
"The majority of the outliers involved seismic interaction concerns that were resolved through seme appropriatelicensee corrective actions.
79 Others were resolved either by conservative deterministic failure margin capacity analysis that te showed that the seismic capacity substantially exceeded the well-beYGid review-level earthquake demand, or by maintenance/ modifications."
F.2.2.3 F-14 to 48 and In lines 13 to 16 on pages F-14 to F-onsider revising the F-15 1 to 2 text as follows:
"In response to an NRC staff RAI, Exelon stated that the input for the MAAP cases specified the 80 fission product masses (as opposed to radionuclideactivity values), as recommended by the MAAP Users Group Bulletin, "MAAP-FLASH
- 68" (Exelon 2014)."
F.2.2.4 F-18 41 to 47 In lines 41 to 47 on page F-18, consider revising the text as follows:
GePeda-Certain standardizedeconomic-data parameterinput values that may be applied to the region as a whole (e.g., for parametersdescribing the cost of evacuatingand relocatingpeople, land decontamination,and property condemnation)were obtainedfrom NUREG-1150 (NRC 1990) rFced fromtho (anda related 81 MACCS2 User's Guide sample problem). Those values were adjusted 44p4t-to account for cost escalation since 1986 (the year that input values were was first specified). Taking into account using the U.S. Consumer Price Index (CPI) method.
Specifically, a factor of 2.09 (CPI of 229.1 divided by CPI of 109.6), representing cost escalation from 1986 (CPI index of 109.6) to July 2012 (CPI index of 229.1), was applied to the NUREG-1150/MA CCS2 sample problem values.
pafametefs describing cost of evacuating_ nd
5/15/2015 Page 14 of 14 relocating people, land deotmntoand proporty condemnation.
F.3.2 F-21 13 to15 In lines 13 to 15 on page F-21, consider revising the text as follows:
"Exelon also provided in the ER tabular listings of the Level 2 PRA basic events for the combined 82 LERF categories and the combined Late Release categories, which in total neen44bi:e account for approximately 95 percent of the estimated population dose risk and OECR."
F.3.2 F-22 14 In line 14 on page F-22, change the phrase "the NRC staff finds acceptable" as follows:
83 "... the NRC staff finds Exelon's explanation to be acceptable" F.3.2 F-20 13 to 14 Consider inserting the following sentence after the first sentence in lines 13-14 on page F-20:
"Exelon provided in the ER a tabular listing of the Level 1 PRA basic events sorted according to their 84 RRW (Exelon 2013a). The RRW is the factor by which the risk would decrease if the component, train, system, function, initiatingevent, or HEP is assumed to be perfectly reliable (i.e., if its probabilityof failure were zero)."
F.7 F-40 35 to 37 Consider adding underlined language (or something similar) in lines 35.to 37 on page F-40 as follows:
"Exelon has indicated that all 26 potentially cost-85 beneficial SAMAs will be submitted to the Braidwood Plant Health Committee for further implementation consideration in accordance with current Braidwoodprocesses and procedures for evaluatingpossible plant modifications."