ML18289A379

License Renewal Environmental Site Audit Plan Regarding the Peach Bottom Atomic Power Station, Units 2 and 3, Subsequent License Renewal Application

ML18289A379
Person / Time
Site:	Peach Bottom
Issue date:	10/25/2018
From:	Lauren Gibson NRC/NRR/DMLR/MRPB
To:	Bryan Hanson Exelon Generation Co, Exelon Nuclear
Gibson L, NRR-DMLR 415-1056
References
EPID L-2018-RNW-0013
Download: ML18289A379 (16)

Text

October 25, 2018 Mr. Bryan C. Hanson Senior Vice President Exelon Generation Company, LLC President and Chief Nuclear Officer Exelon Nuclear 4300 Winfield Road Warrenville, IL 60555

SUBJECT:

LICENSE RENEWAL ENVIRONMENTAL SITE AUDIT PLAN REGARDING THE PEACH BOTTOM ATOMIC POWER STATION, UNITS 2 AND 3, SUBSEQUENT LICENSE RENEWAL APPLICATION (EPID NO. L-2018-RNW-0013)

Dear Mr. Hanson:

The U.S. Nuclear Regulatory Commission (NRC) staff is reviewing the Exelon Generation Companys subsequent license renewal application for Peach Bottom Atomic Power Station, Units 2 and 3 (Peach Bottom). The environmental site audit will be conducted at Peach Bottom during the week of November 5, 2018, by NRC staff. The environmental audit activities will be conducted in accordance with the environmental audit plan (Enclosure 1).

To develop the Supplemental Environmental Impact Statement, the NRC staff requests the information described in the environmental audit needs list (Enclosure 2) be made available, to the extent possible, during the environmental site audit. A draft schedule of tours and meetings for the audit is also provided (Enclosure 3).

The NRC staff transmitted the draft environmental needs to Nancy Ranek of your staff by e-mail on October 15, 2018.

If you have any questions, please contact me by e-mail at Lauren.Gibson@nrc.gov.

Sincerely,

/RA/

Lauren K. Gibson, Project Manager License Renewal Projects Branch Division of Materials and License Renewal Office of Nuclear Reactor Regulation Docket Nos. 50-277 and 50-278

Enclosures:

As stated cc w/encls: Listserv

ML18289A379 *concurrence via email OFFICE PM:MRPB:DMLR LA:MRPB:DMLR BC:MENB:DMLR BC:MRPB:DMLR*

NAME LKGibson SLent BBeasley *EOesterle DATE 10/18/18 10/16/18 10/18/18 10/22/18 OFFICE PM:MRPB:DMLR NAME LKGibson DATE 10/25/18

LICENSE RENEWAL ENVIRONMENTAL AUDIT PLAN PEACH BOTTOM ATOMIC POWER STATION, UNITS 2 AND 3

1. Background

By letter dated July 10, 2018 (Agencywide Documents Access and Management Systems (ADAMS) Accession No. ML18193A697), Exelon Generation Company, LLC (Exelon or the applicant), submitted to the U.S. Nuclear Regulatory Commission (NRC or staff) an application to renew the Peach Bottom Atomic Power Station, Units 2 and 3 (Peach Bottom), renewed facility operating licenses DPR-44 and DPR-56. The staff is reviewing the information contained in the environmental report (ER) of the license renewal application (LRA) per Title 10 of the Code of Federal Regulations Part 51 (10 CFR Part 51).

During the staffs review, an environmental audit is conducted at the Peach Bottom site. This audit is conducted with the intent to gain understanding, to verify information, and to identify information that will require docketing to support the basis of the licensing or regulatory decision. Specifically, the NRC staff will identify pertinent environmental data, review the facility and area, and obtain clarifications regarding information provided in the ER.

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

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

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

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

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

4. Information and Other Material Necessary for the Environmental Audit As described in the Site Audit Needs List (Enclosure 2).

Enclosure 1

5. Environmental Audit Team Members and Resource Assignments The environmental audit team members and their specific discipline assignments are shown in Table 1.

Table 1 Environmental Audit Team Members and Resource Assignments Discipline Team Members Environmental Review Supervisor Ben Beasley, NRC Environmental Project Manager Lauren K. Gibson, NRC Air Quality/Meteorology and Alternatives Robert Hoffman, NRC Aquatic, Microbiological Hazards, Special Status Species (National Marine Michelle Moser, NRC Fisheries Service jurisdiction)

Cumulative, Land Use and Visual, Noise Jeff Rikhoff, NRC*

Surface Water Hydrology William Ford, NRC*

Geology, Groundwater Hydrology Kevin Folk, NRC Human Health, Postulated Accidents, Spent Nuclear Fuel, Uranium Fuel Cycle, William Rautzen, NRC Waste Management (rad and non-rad)

Socioeconomic; Historic, and Cultural Nancy Martinez, NRC Resources; Environmental Justice Special Species and Habitats (U. S. Fish Briana Grange, NRC and Wildlife Service), Terrestrial

• Members of the review team who will not be attending the onsite audit.

6. Logistics The environmental audit will be conducted at Peach Bottom from November 7 - 8, 2018. An entrance meeting will be held with plant management at the beginning of the audit. An exit meeting will be held at the end of this audit.

7. Special Requests The staff requests that the applicant make available the information identified on the Environmental Audit Needs List (Enclosure 2). Plant staff who are subject matter experts in the disciplines listed on the Environmental Site Audit Needs List should be available for interviews and to provide tours. Note that, prior to developing the audit needs, the NRC staff attended several site orientation tours on October 3 and 4, 2018.

8. Deliverables An audit summary report is scheduled to be issued by NRC staff within 90 days from the end of the environmental audit.

PEACH BOTTOM ATOMIC POWER STATION, UNITS 2 AND 3 LICENSE RENEWAL ENVIRONMENTAL SITE AUDIT NEEDS LIST The U.S. Nuclear Regulatory Commission (NRC) staff has reviewed Appendix E, the Environmental Report (ER), of the subsequent license renewal application (SLRA) for Peach Bottom Atomic Power Station, Units 1 and 2. Prior to developing the audit needs, NRC staff attended site orientation tours on October 3 and 4, 2018.

Please be prepared to discuss the following issues and make the following available during the environmental site audit.

Tours Please provide subject matter experts to lead the following tours:

• Location(s) of the site Radiological Groundwater Protection Program (RGPP) groundwater seeps (3) and yard drain sumps (2) and their sampling locations (ER Sections 3.5.2.3/4.5.2.4), where reasonably accessible. If the location is not reasonably accessible, please provide a description of the location.

• Salt Storage Facility supply well (ER Section 2.2.3)

• A walk-down of gaseous radwaste systems inside of the plant to get a sense of all of the components listed in the ER and how they are routed.

• Inner and Outer Intake Structure, including observing a typical collection of fish and debris, if available Audit Meetings Please provide for breakout meetings with the subject matter expert(s) and/or the contractor(s) responsible for the following topics who can also discuss the corresponding information requests as described in the Questions and Documents Needs section below. These meetings will be used as needed to resolve or clarify any outstanding data needs or questions arising from the environmental audit.

• Aquatic Resources

• Replacement Power Alternatives

• Air quality, particularly air permits and emission inventories associated with facility operations, and stationary and mobile sources of air pollutants.

• Groundwater Hydrology, including groundwater hydrology, quality, and impact assessment portions of the ER and the plants groundwater protection program and affected groundwater resources. Please also discuss the location(s) of any ground water seeps, yard drain sumps, or their sampling locations that are not reasonably accessible for a walk down.

• Radiological Environmental Monitoring Program (REMP), liquid (radiological and non-radiological) and gaseous effluent release programs, and waste management (radiological and non-radiological) programs

• Historical and Cultural Resources

• Microbiological Hazards

• Socioeconomics

• Special Status Species and Habitats (Fish and Wildlife Service)

Enclosure 2

• Special Status Species and Habitats (National Marine Fisheries Service)

• Terrestrial Resources Questions and Document Needs Specific questions, requests, and document needs are provided below by resource area.

Aquatic Resources A-1 Section 2.2.3 of the ER describes a high-pressure spray back-wash system that may allow some impinged or entrapped fish to return to the Conowingo Pond. Please clarify whether a fish handing and return system exists near the inner or outer intake structure or within the intake basin.

A-2. Section 2.2.3 of the ER describes traveling screens on the inner and outer intake structures. The ER also provides information regarding the mesh size, the approach velocity, and the through-screen velocity for the traveling screens on the outer intake structure. Please describe the mesh size, the approach velocity, and the through-screen velocity for traveling screens on the inner intake structure.

A-3. Section 4.6.2.1 of the ER states that Exelons September 22, 2014, National Pollutant Discharge Elimination System (NPDES) permit lists conditions with which Peach Bottom Atomic Power Station (PBAPS) must comply during the permits term to meet best technology available standards for the cooling water intake structure, including protection of fragile species. Some of these conditions provide options for Exelon to select from. For example, the following are the conditions that address impingement and entrainment:

A. The PBAPS cooling water intake structures must meet BTA [best technology available] standards for impingement mortality by employing one of the alternatives in 40 CFR

§125.94(c)(1) through (c)(7). Additional measures may be required to protect federal or state threatened and endangered species and fragile species.

Please describe which of the alternatives in 40 CFR §125.94(c)(1) through (c)(7) Exelon has selected to implement since 2014.

A-4. Section 4.6.2.1.3 of the ER states that A final decision about the need for additional measures to protect federal or state threatened and endangered species and fragile species will be made in consultation with PADEP [Pennsylvania Department of Environmental Protection], as indicated in the PBAPS NPDES permit, and USFWS

[United States Fish and Wildlife Service]. Please describe the current timeline for the NPDES permit and any current discussions with USFWS regarding fragile species.

A-5. Describe future activities that Exelon anticipates conducting associated with its post-EPU biological and thermal study. In addition, describe any activities associated with these studies that have been completed since the Environmental Report was published.

A-6. Section 4.6.3 of the ER states that during 2016, four individual Chesapeake logperch larvae were reported to the PFBC [Pennsylvania Fish and Boating Commission] as

collected in entrainment abundance sampling that is ongoing pursuant to the CWA

[Clean Water Act] Section 316(b) requirements in NPDES Permit PA0009733. Please clarify whether any additional Chesapeake logperch, or any other State-listed species, have been collected since development of the Environmental Report. In addition, please clarify whether Exelon has published the results of the 2016 sampling effort pursuant to the CWA Section 316(b) requirements in NPDES Permit PA0009733.

A-7. Discuss whether Exelon is aware of any previous fish kills or other unusual events that have occurred within the vicinity of the discharge structure and thermal plume.

A-8. Provide a summary of NPDES Discharge Monitoring Report data, itemizing monitored parameters for each outfall, for the last 2 years (2016 and 2017), inclusive of 2018 year to date.

A-9. Identify and describe any Notices of Violations; nonconformance notifications; or related infractions received from regulatory agencies associated with NPDES permitted discharges, sanitary sewage systems, as well as any involving spills, leaks, and other inadvertent releases (e.g., petroleum products, chemicals, or radionuclides) received since 2016. Please also include self-reported violations. Please provide copies of relevant correspondence to and from the responsible regulatory agencies.

Document Needs For the reference URS Corporation, 2008. 316(b) Compliance Report With Source Waterbody Information, Impingement Mortality Characterization Study, and Design and Construction Technology Plan, Peach Bottom Atomic Power Station, please provide Appendices A through C and attachments 1 and 2 for review at the environmental audit, or please post to the electronic portal.

Alternatives, Replacement Power AL-1 Please provide the calculations used to estimate the air quality emissions presented in ER Section 7.2.3.1 (Natural Gas-Fired Generation) and Section 7.2.3.2 (Coal-Fired Generation).

AL-2 Has Exelon Generation estimated the cooling water make-up and consumptive water use associated with the Natural Gas-Fired, Coal-Fired, and Small Modular Reactor alternatives presented in ER Sections 7.2.3.1, 7.2.3.2, and 7.2.3.4, respectively? If yes, please provide the supporting calculations.

Air Quality and Meteorology AQ-1 Section 3.2 of the ER discusses three instrumented meteorological towers supporting the PBAPS site: Tower 2, the River Tower, and the Hill Pole. Please clarify the current purpose, status, and instrumentation associated with each of these towers.

AQ-2 Please provide the actual PBAPS air emissions of pollutants listed in ER Table 3.2-1 for the most recently-available 5-year period.

AQ-3 Please provide a copy of PBAPS current Synthetic Minor Operating Permit and identify whether Exelon Generation has received any associated notices of violation or non-compliances.

AQ-4 Have field tests concerning ozone and nitrogen oxides emissions generated by PBAPSs in-scope transmission lines been conducted? If so please, provide a copy of these tests.

Cumulative Impacts CU-1 Please provide the name, description, location, and status of any additional past, present, or reasonably foreseeable projects or actions that have been identified since the ER was prepared.

Groundwater Resources GW-1 Sections 2.2.3 and 3.5.2 of the ER provide estimates of the volume of water produced by PBAPSs four active onsite groundwater supply wells, as well as the volume of groundwater collected and conveyed by the plants three drain sumps. Clarify the operational status of these wells and sumps and their pump capacities. Also clarify whether Exelon collects and maintains production volume data for these wells and/or sumps. If so, provide a summary (by month or other averaging period) of the estimated volume of groundwater withdrawn by the wells or collected in sumps and discharged over the last 5 years.

GW-2 Sections 3.5.2.3 and 4.5.2.4 of the ER provide a summary and an assessment, respectively, of historic inadvertent releases of radionuclides to groundwater and which includes groundwater protection monitoring results that are reported in Exelons annual radiological environmental operating reports. Provide a description of any documented inadvertent radiological releases (leaks or spills of liquids containing licensed material) that have occurred since December 2017. Describe the impact on the environment, if any, identify affected monitoring wells or sumps, and provide a summary of radionuclide concentrations in nearby monitoring wells, sump drains, and surface water stations as appropriate from the date of discovery of the release to the present. Also, include a description of any ongoing or completed corrective actions taken.

GW-3 Section 2.2.5.1 of the ER, in part, describes the operation of the plants liquid radwaste system including the discharge pipeline for conveying monitored liquid radwaste effluent to the discharge canal. Clarify the average volume and frequency of discharge and identify the presets for flow and radiation for automatic shut-off. Also, briefly describe any major modifications to the pipeline since initial license renewal.

GW-4 Section 9.1 of the ER summarizes the Exelons status of compliance with applicable environmental regulatory requirements governing PBAPS operations. Provide a summary of any Notices of Violation; nonconformance notifications; or related infractions received from regulatory agencies associated with permitted discharges, sanitary sewage systems, groundwater or soil contamination, as well as any involving spills, leaks, and other inadvertent releases (e.g., petroleum products, chemicals, or radionuclides) received over the last five years (2014-2018 year to date). Provide copies of relevant correspondence to and from the responsible regulatory agencies.

Document Needs

1. Latest site groundwater (hydrogeologic) investigation update or GPI assessment report (ER Section 3.5.2.3)

2. Latest annual 50.75(g) assignment report (ER Section 3.5.2.3)

3. Schematic of the underground routing of the liquid radwaste discharge pipeline to the discharge canal (ER Section 2.2.5.1)

4. Water balance/flow diagram for the plant Historic and Cultural Resources HC-1 Section 3.7.2 of the ER states that existing Exelon Generation procedures that apply to land-disturbing activities will minimize the potential for adverse effects on previously unidentified archaeological or historic resources.

a.) Provide a copy of the procedures for review.

b.) How does Exelon ensure that employees conducting land-disturbing activities are aware of the procedures and what actions to take if historic resources are discovered?

HC-2 Section 3.7.2 of the ER states that Exelon maintains records that indicate that no historic landscape, traditional cultural property, or archaeological sites have been identified at the PBAPS site since the time of its construction, and confirm that no potentially significant artifact deposits have ever been documented within the present APE [area of potential effect]. Provide a copy of these records for review.

HC-3 Section 3.7.2 of the ER states that there are structures associated with PBAPS, Units 1, 2 and 3 that will exceed 50 years of age during the SLR term. Identify and describe these structures. Additionally, provide the current age of the structures and how the age was determined (e.g., commencement of operation, end of construction, etc.).

HC- 4 The ER states that appropriate consideration will be given to the historic significance of the Unit 1 structures at the time of Unit 1 decommissioning. Will a NRHP eligibility evaluation be conducted for Exelon for Unit 1, as well as Units 2 and 3 prior to decommissioning? How will Exelon ensure that the Units are maintained and not dismantled prior to proper historic significance consideration?

HC- 5 Section 4.7 of the ER states that Unit 1 entered SAFSTOR mode in 1978, with continued surveillance, security, and maintenance Describe actions that Exelon has taken to maintain the physical and historic integrity of Unit 1.

HC-6 Section 3.7.2 of the ER states that the Peach Bottom property was evaluated by an archeologist in 1972. Identify the areas that were evaluated by the archeologist and what percentage of the Peach Bottom site property was evaluated.

HC -7 Approximately what percentage of the Peach Bottom property has been disturbed?

Document Needs If Exelon has a copy of the following references, please provide them for review:

Smith, I.F., III 1972a. Letter from Field Archaeologist, William Penn Memorial

Museum to D. Marano, Philadelphia Electric Company. Content: letter report on archaeological survey of the west shore area of the Peach Bottom Atomic Power Station. June 7, 1972 Smith, I.F., III 1972b. Letter from Field Archaeologist, William Penn Memorial Museum to R. Fiske, Philadelphia Electric Company. Content: additional discussion on an archaeological survey of the west shore area of the Peach Bottom Atomic Power Station. December 12, 1972 Human Health Document Needs Please provide procedures related to General Industrial Safety Requirements and Electrical Safety.

Microbiological Hazards MH-1 Section 2.2.3 of the ER states that Exelon controls the accumulation of deposits and biofouling organisms in the condensers through the regular use of an on-line condenser cleaning system and dosages of chlorine. The ER also states that Exelons NPDES permit limits the discharge of Total Residual Chlorine concentration in the permitted outfall to 0.20 milligrams per liter (mg/L) (instantaneous maximum). Please describe the general dose frequency and average concentration of chlorine that is released into Conowingo Pond.

MH-2 Section 3.6.1.3 of the ER states that Exelon controls non-native aquatic species by applying biocides, in accordance with its current NPDES permit. Please describe the general frequency that Exelon applies biocides and the average concentration that is released into Conowingo Pond.

MH-3. Section 4.9.1 of the ER states that the Exelon continually disinfects PBAPSs sewage effluent. Please describe the general frequency of disinfection activities and the type and amount of disinfectants that are released into Conowingo Pond.

MH-4 Legionellosis outbreaks are often associated with complex water system houses inside buildings or structures, such as cooling towers. Describe any procedures, measures, or best management practices that would minimize the risk for workers to come into contact with Legionella.

Socioeconomics SOC-1 Section 3.8.1.1 of the ER provides property tax payment and payments in addition to tax (PATs) that Exelon makes to taxing authorities. The ER states that in 2012, Exelon Generation and the taxing authorities agreed to extend a 2008-2012 settlement agreement, which included PATs to each local taxing body, to cover tax years 2013 to 2017. Has there been new or additional settlement agreements between Exelon and taxing authorities that cover the tax years beyond 2017? Are there any potential future tax payment adjustments anticipated during the license renewal period?

SOC-2 Table 3.8-6 of the ER provides local real estate tax revenue for the years 2012 through 2016 and PBAPS 2016 real estate taxes and payments in addition to tax (PATs).

Table 3.8-7 of the ER provides taxes and PATS payments to taxing authorities from 2013 to 2017. If available, provide the combined PBAPS real estate taxes and PATS paid to each taxing authority for years 2013-2015 and 2017 (similar to the 2016 Peach Bottom Real State Taxes and PATs presented in the last row of Table 3.8-6).

SOC-3 Table 3.8-7 lists TBD for 2017 Tax Paid. Is the 2017 Tax Paid and Total Tax and PAT information available? If so, please provide.

SOC-4 Table 3.8-7 provides a School District PAT (2nd column). Identify the school district(s) the PAT is provided to and the amount paid to each school district.

SOC-5 Provide a source/reference for the local real estate tax revenue information presented in Table 3.8-6 of the ER.

SOC-6 Chapter 5 of the ER discusses the assessment of new and significant information Exelon conducted for Category 1 socioeconomic issues (e.g., interviews with subject matter experts, extensive review of documents, etc.). Provide documentation/information that support the assessment Exelon conducted as discussed in Chapter 5.

SOC-7 Besides property tax payments and PATs, describe any other sizeable annual support payments (e.g., emergency preparedness fees and payments or fees because of the independent spent fuel storage installation), one-time payments, or other forms of non-tax compensation (if any) provided to local organizations, communities, and jurisdictions on behalf of PBAPS.

Special Status Species and Habitats (U.S. Fish and Wildlife Service)

SS-1 With respect to the Indiana bat (Myotis sodalis) and northern long-eared bat (M.

septentrionalis), the Environmental Report (Section 3.6.2.3.1, p. 3-50 to 3-51) states that the U.S. Fish and Wildlife Service and Pennsylvania Natural Diversity Inventory identified these species as known or believed to occur in York County. The ER, however, does not appear to come to a clear determination of whether either of these species occur or may occur on the Peach Bottom site. Please explain whether and where suitable habitat for these species occurs on the site and whether either species is likely to occur on the site.

SS-2 With respect to the Chesapeake logperch (Percina bimaculata), the Pennsylvania Fish and Boat Commission issued a Species Action Plan1 in 2015 that contains Conservation Actions aimed at securing the species population such that it can be removed from the Pennsylvania list of threatened species and does not require listing under the Endangered Species Act. Please describe any management actions, Federal or State agency coordination, and/or monitoring that Exelon has undertaken pertinent to these Conservation Actions or the Chesapeake logperch.

SS-3 With respect to the Indiana bat, in an October 9, 2018, National Environmental Policy Act scoping letter (ADAMS Accession No. ML18282A169), the U.S. Fish and Wildlife 1

https://www.fishandboat.com/Resource/Documents/species-plan-chesapeake-logperch.pdf

Service recommended that any tree removal or pruning large limbs be carried out between November 15 and March 31 in order to avoid potential adverse effects to Indiana bats during the summer roosting season. The Service also recommended that Exelon contact the Services Pennsylvania Field Office ahead of any tree removal or trimming activities to confirm that they will adhere to this time of year restriction. Please explain whether Exelon would adhere to these recommendations during the proposed SLR term and how these recommendations would be implemented (i.e., through site procedures, best management practices, etc.).

SS-4 With respect to the northern long-eared bat, activities associated with projects authorized, funded, or carried out by a Federal agency are covered by the U.S. Fish and Wildlife Services 2016 Programmatic Biological Opinion on Final 4(d) Rule for the Northern Long-Eared Bat and Activities Excerpted from Take Prohibitions2 provided that the conservation measures specified in the Endangered Species Act 4(d) rule3 for the species are implemented. For site activities that may affect the northern long-eared bat during the proposed SLR term, such as tree removal or trimming, please confirm whether Exelon would adhere to the conservation measures of the 4(d) rule and how these measures would be implemented (i.e., through site procedures, best management practices, etc.). (See specifically the section entitled Tree-Removal Conservation Measures in the 4(d) rule.)

SS-5 With respect to the bog turtle, confirm that Exelon, its personnel, or contractors have not identified any onsite wetlands beyond those that were assessed during the August 2017 Phase 1 bog turtle habitat survey contained in Appendix C of the Environmental Report.

SS-6 The ER (Section 4.6.3, p. 4-42) states that existing procedures require consideration of impacts to threatened and endangered species and their habitat as part of the planning process for work at the plant site. Please explain the referenced procedures in further detail and provide copies of the procedures for NRC staff review.

SS-7 The ER (Section 4.6.3, p. 4-44) states that Exelon Generation concludes that the proposed action is unlikely to adversely affect any threatened or endangered species.

Please clarify whether this conclusion applies to each of the following federally listed species: Indiana bat, northern long-eared bat, red knot, and bog turtle.

Special Status Species and Habitats (National Marine Fisheries Service)

SS-8. Clarify whether Exelon has conducted any effluent modeling or field studies to characterize the size and contaminant concentrations within the discharge plume. In addition, clarify whether Exelon has conducted any studies to determine the chemical or other contaminant concentrations within PBAPSs discharge effluent below the Conowingo Dam.

SS-9 Section 4.6.2 of the ER states that existing procedures require consideration of impacts to threatened and endangered species and their habitat as part of the planning process for work at the plant site. Please provide a summary of these procedures, including all best management practices or other measures that would minimize impacts to ecological resources, including threatened and endangered species.

2 https://www.fws.gov/midwest/endangered/mammals/nleb/pdf/BOnlebFinal4d.pdf 3

https://www.fws.gov/midwest/endangered/mammals/nleb/pdf/FRnlebFinal4dRule14Jan2016.pdf

Terrestrial T-1 In Appendix C of the ER, Exelon includes Pennsylvania Natural Diversity Inventory Environmental Review Tool results related to the proposed Peach Bottom subsequent license renewal (SLR). On page 4 of these results, Exelon states that the project will affect 1 to 39 acres of forests, woodlots, and trees in response to Q5: The propose project is in the range of the Indiana bat. Describe how the project will affect bat habitat (forests, woodlots, and trees) and indicate what measures will be taken in consideration of this. Round acreages up to the nearest acre (e.g., 0.2 acres = 1 acre).

a. Further describe the impacts to forests, woodlots, and trees that would result from site maintenance, hazardous tree removal, and other potential impacts during the proposed SLR term.

b. Clarify how many acres of forests, woodlots, and trees Exelon anticipates would be affected during the proposed SLR term.

c. Describe any applicable procedures and/or best management practices that Exelon maintains that would minimize or eliminate potential impacts to bats during hazardous tree removal and other site maintenance activities that affect trees or forested areas.

T-2 The ER (Section 3.6.2.3.2, p. 3-52) references the Atom Woods Road Site and Peach Bottom Woods Site when describing the occurrences of several State-listed or rare species within the footprint of the Peach Bottom site. These sites are further described in the York County Natural Areas Inventory (Environmental Report reference YCPC 2004).

a. Describe where these sites lie in relation to the entire Peach Bottom site footprint.

Provide a map depicting these area, if available.

b. Does Exelon actively manage these areas for conservation or restoration purposes?

c. Does Exelon anticipate any land or ground disturbances to these area during the proposed SLR term?

d. Has Exelon performed or commissioned any ecological or botanical surveys in these areas? If so, provide copies of such surveys.

e. Has Exelon, its personnel, or contractors positively identified the locations of the harbinger-of-spring (Erigenia bulbosa), American holly (Ilex opaca), or lobed spleenwort (Asplenium pinnatifidum) populations at these sites as described in the ER (Section 3.6.2.3.2, p. 3-52)?

f. Is Exelon aware of whether any or all of these populations still exist?

T-3 The Pennsylvania Biological Survey designates certain species as Pennsylvania-responsibility species, a term that refers to a species or subspecies for which Pennsylvania plays a key role in sustaining its global security by hosting at least 10 percent of its North American population or encompassing at least 25 percent of its North American range. Is Exelon aware of any of the following Pennsylvania-responsibility species occurring on the Peach Bottom site, either historically or presently?

a. glade spurge (Euphorbia purpurea)

b. Henslows sparrow (Ammodramus henslowii)

c. regal fritillary (Speyeria idalia)

d. spreading rockcress (Arabis patens)

e. timber rattlesnake (Crotalus horridus)

T-4 Does Exelon maintain any procedures or perform any specific management programs or activities related to terrestrial invasive plants or animals on the Peach Bottom site?

T-5 The Natural Resources Conservation Service identifies the following 13 invasive plants in Pennsylvania as noxious weeds, which are plants that directly or indirectly cause damage to crops, livestock, irrigation, navigation, the public health, or other natural resources. Is Exelon aware of the occurrence of any of these plants on the Peach Bottom site?

a. musk thistle (Carduus nutans)

b. Canadian thistle (Cirsium arvense)

c. bull thistle (Cirsium vulgare)

d. jimsonweed (Datura stramonium)

e. goatsrue (Galega officinalis)

f. giant hogweed (Heracleum mantegazzianum)

g. purple loosestrife (Lythrum salicaria)

h. mile-a-minute (Polygonum perfoliatum)

i. kudzu-vine (Pueraria montana)

j. multiflora rose (Rosa multiflora)

k. shattercane (Sorghum bicolor)

l. johnsongrass (Sorghum halepense)

T-6 The ER (Section 3.6.2.3.2, p.3-51) states: In 2017, an osprey nest was located in the South Substation; coordination between PGC and Exelon Corporation (as PECO) is ongoing. Explain the purpose of the coordination mentioned. What is the current status of this coordination? Will there be any documented outcome of the coordination, such as a permit, agreement, or management plan? If so, provide copies of such documents, if available at this time.

T-7 Please identify and describe the various environmental stewardship or habitat enhancement initiatives that Exelon has undertaken or plans to undertake on the Peach Bottom site, such as nesting boxes for various waterfowl; nesting platforms for raptors; wildlife food plots within transmission line rights-of-way; initiatives to enhance native pollinators, annual river clean-ups, etc. These initiatives may be formal or informal.

T-8 Describe Exelons hunting program for the Peach Bottom site, including what year the program was initiated; the purpose of the program; the typical length of the hunting season; hunter permit requirements and limits; and any changes in natural habitats that Exelon has observed over time as a result of implementing the program.

T-9 Does Exelon maintain Wildlife Habitat Council certification for the Peach Bottom site? If so, please answer the following questions.

a. What programs or initiatives has Exelon undertaken related to this certification?

b. Does Exelon maintain any particular management plans associated with this certification or has Exelon produced any reports or commissioned any site surveys or

assessments in connection with this certification? If so, please provide copies of such documents for NRC staff review.

c. What are the effective dates of the current certification period?

d. Does Exelon intend to maintain certification during the proposed SLR term?

T-10 The ER (Section 4.6.1.1, p. 4-29) states that existing procedures provide a process for screening proposed activities to determine if further evaluation for environmental impacts and risk is needed. Please further describe these procedures and provide examples of the types of activities that would require further evaluation.

T-11 The U.S. Fish and Wildlife Services Information for Planning and Consultation system identifies the following migratory birds to be of particular concern because they occur on the Services Birds of Conservation Concern list or because they warrant special attention in the region. Is Exelon aware of the occurrence of any of these species on the Peach Bottom site? Has Exelon undertaken or does Exelon plan to undertake any environmental stewardship or habitat enhancement initiatives related to these species or that might specifically benefit these species?

a. blue-winged warbler (Vermivora pinus)

b. cerulean warbler (Dendroica cerulean)

c. eastern whip-poor-will (Antrostomus vociferus)

d. golden eagle (Aquila chrysaetos)

e. Kentucky warbler (Oporornis formosus)

f. prairie warbler (Dendroica discolor)

g. prothonotary warbler (Protonotaria citrea)

h. red-headed woodpecker (Melanerpes erythrocephalus)

i. wood thrush (Hylocichla mustelina)

Waste Management (radioactive and non-radioactive)

WM-1 PBAPS is subject to the reporting provisions of 40 CFR Part 110 as it relates to the discharge of oil in such quantities as may be harmful pursuant to Section 311(b)(4) of the Federal Water Pollution Control Act. Any discharges of oil in such quantities that may be harmful to the public health or welfare or the environment must be reported to the National Response Center. For the time period of 2013-2018, were there any reportable spills? Please provide a description of any spills.

WM-2 If PBAPS is subject to any State reporting requirements similar to those of 40 CFR 110 for reportable oil spills, please provide a description for any reportable oil spills for the time period of 2013-2018.

WM-3 In Section 2.2.2 of the ER, Exelon states that the Independent Spent Fuel Storage Installation (ISFSI) storage pad is projected to be full by the year 2020. While spent fuel storage expansion is expected regardless of license renewal, please provide the current plan to address ISFSI expansion and future spent fuel storage in general.

Document Needs Please provide the latest complete Offsite Dose Calculation Manual (the most current version in the Agencywide Documents Access and Management System is Revision 13, from 2010).

Peach Bottom Environmental Site Audit Schedule Wednesday, November 7, 2018 START END ACTIVITY 12:00 pm 1:00pm Entrance meeting with Exelon 1:00 pm 4:00 pm Site tours/meetings between NRC and Exelon subject matter experts (SMEs) 4:00pm 4:30 pm Team debrief/planning 4:30 pm 5:00 pm Daily debrief with Exelon Thursday, November 8, 2018 START END ACTIVITY 8:00 am 12 noon Meetings between NRC and Exelon SMEs 12:00 noon 1:00 pm Lunch 1:00 pm 3:30 pm Meetings between NRC and Exelon SMEs 3:00 pm 3:30 pm Team debrief/planning 3:30 pm 4:00 pm Exit Meeting with Exelon Enclosure 3