ML20079N033

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Response to NUMARC Survey Re Impingement Trends,Ecological Studies & Impingement Assessment Questions in Support of NRC License Renewal Rulemaking
ML20079N033
Person / Time
Site: Calvert Cliffs  
Issue date: 07/26/1990
From:
BALTIMORE GAS & ELECTRIC CO.
To:
References
RTR-NUREG-1437 AR, S, WM, NUDOCS 9111110053
Download: ML20079N033 (17)


Text

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uk Attachmant AQtJAJJC RESQURCE QUESILOES AND ANSEERS:

1. QUESTION: Post licensing modifications and/or changes in operations of intake and/or dischargo synteras may have altered the offects of the power plant on aquatic resources, or may have been made specifically to mitigato impacts that woro not anticipated in the dosign of the plant. Describo any such modifications and/or operational changes tu the condonsor coo!!ng water intake and dischargo systems since the issuance of the Operating tJconso.

ANSWER: The following are changos that have occurrod to intakn and dischargo systems since the issuance of the Operating Uconso:

.Qhance f om Flow-Throuah to Dual Flow Travelina Screens:

This chango was initiated in order to roduco cany-over and improvo poiformance of tho screens during laigo impingement events. in 1986. after installation of one test set of dvs!

flow screens, a finfish survival study was performod cortparing dual flow scroons with through flow screens, and the dual flow screens were found acceptable. No other scroon pairs have boon replaced as yet but are planned. A different manufacturer's dual flow screens are being considered for replacing the through flow scroons. Differences betwoon screen types aro being environmentatly evaluated.

Other screen types have also been tested at CCNPP but have not boon given further consideration.

Travelina Screen Sprav Wag,)ystem Roolacement Removal of Curtain Wall Panels D,grina the Summar:

The Final Environmental Statement indicated the possibio need to removo those pancis.

Removing the panels allows an escape route for fish when hypoxic / anoxic waters upwoll into ho embayment area.

@) of Chlorin _o in Subsystems:

The Final Environmental Statement covered the use of chlorine, although it wasn't planned to be used for condonser cleaning unless it became necessary (only the Amortap mechanica: cleaning sptom was planned to be used). CCNPP is not permitted to use chlorino for condensor cleaning.

However, since the early years of ope:ation of the plant, chlorino has boon used in the saltwater system. Chlorine was used on occasion in the AMERTAP system in past years but is not presently used in this system.

Electrolytic Biofoulino Control Technique:

This technique was testod at CCNPP for water boxes and condenser system biofouling control and was found not to be acceptable. The system was not used after the tost was performed.

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i Attachmont-

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6ntifoulcnt Paints:

Various antifoulant paints have been used at CCNPP since the plant began to oporato.

j j!. QUESTION: Summarire and describe (or provide documentation of) any known hpacts on aquatic resources (e.g., fish kills, violations of discharge permit c onditions) or National Pollutant Discharge Elimination System (NPDES) enforcement antions that have occurred since issuance of the Operating License. How have these b sen resolved or changed over time? (The response to th!s question should Indicate v.hether impacts are ongolog or were the result of start up problems thart were tsubsequently resolved.) -

ANSWER:- Since the plant began to operate in 1975, there have been a couple !!sh kill events in the embayment area which were largo enough to cause the tiavoling scroons to jam and to result in plant trips / load reductions.- When impingement events cause a modification in plant operations, we are required by our NPDES permit to report the event L

to the State. The fish kills are caused by hypoxic / anoxic waters of the Bay bottom upwelling into the embayment area The events are somowhat predictable. Operationally c

these occurrences have been dealt with by implementation of procedures to take when

- the circumstances indicate a fish kill may occur. To help provent fish from being torpped g

in low Dissolved Oxygen (DO) water, curtain wall pano!s are removed during the summor

months to ellow a gradient for fish to escape to higher DO waters,11 the gradiant exists.

S!nce there has been no improvemont in the low DO waters of the Bay bottom, those episodes will likely continue to occur on occasion.

The NPDES exceedanco history is:

0 0

A. One temperature exceedance,12.6. F vs.12.0 F limit at outfall 001 in the 1st quarter -

- of 1984.

_ B, One pH exceedance,5.6 vs. 6.0 - 9.0 permit limits, at Monitoring Point (M.P,) 101

(sanita"/ waste) in the 1st quarter of 1984.

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C. One b'ological oxygon'domand (B.O.D.) excoedanco,57.7 vs. 45 mg/l Ilmit, at M.P.101 in the 2nd quarter of 1984, o

l D. Eight B.O.D. exceedances. 219 (maximum) vs. 45 mg/l limit, at M.P,101 in the 4th l

quarter of 19S6, 3

- E. Ona B.O.D._exceedance,45.6 vs. 45 mg/l, at M.P.-101 in the 1st quarter of 1987.

0 0

ll F. One temperaturo excoadance,12.3 F vs.12.0 F limit, at cutfall 001 in the 1st quarter L

of 1988.

j G; One ' total suspended solids excoodance,43 vs. 30 mg/l average limit, at M.P.103-(boller blowdown) in the 4th quarter of 1989.

The exceedancos vary in type, location, and are scattered, so do not appear to be the result of a systematic cause or result in chronic impact.

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Attachment c

3.. QUESTION: Changes to the NPDES permit during operation of the plant could lodicate whether water quality parameters were determined to have no signlGcant i

impacts (and were dropped from monitoring requirements) or were subsequently---

. raised as a water quality issue. Provide a brief summary of changes (and when they

-: occurred) to the NPDES permit for the plant since issuance of the Operating LJeense. -

ANSWER: A comparison of monitoring requirements for 1984 to the present is outlined below (CCNPP NPDES Permit Monitoring Requirements). The differences are only tho result of redesignating the outf all titles or updating to effluent standard guidolines.

CCNPP NPDES Permit Monitoring Requirements 1984 1990 901 - Main Coolina Discharge Temperaturo Dischargo Temperaturo 0

0 Temperature increase (12 F)

Temperatuto increase (12 F)

Intake Tecnporsture intake Temperaturo intake Dissolved Oxygen-Intake Dissolved Oxygon

- Disenarge Dissolved Oxygon Intake Salinity intake Salinity Heat Added (15,000 MBTU/hr)

Flow -

Flow pH (6-9)

Total Residual Chlorino (0,1) 002. Misepjlaneous Waste Sourcos-r pH (49) :

pH (6-9)

Total Suspended Solids Total Suspended Solids E

(30 aveI100 max)

(30/100)_

Oil & Grease (15/20)

Oil & Grease (15/20)

L Flow Flow y

_003 & 004 - Intake Screens Backwarh pH (&9)

- Flow.

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Attachmont -

CCNPP NPDES Permit Monitoring Rtquirements 1984 1990 ffonitorina Point 101 Sanitary WJ,1g Biological Oxygen Biological Oxygen Demand (30/45)

Domand (30/45)

Total Suspended Total Suspended Solids (30 ave /100 max)

Solids (30/100) pH (6-9)

Flow Flow Total Residual Chlorine (0.5)

Total Coliform (70/100 ml)

Total Collforrn (200/400 mpn/100ml)

Monitorina Point 103 Bollor Blowdown pH (6-9)

Total Susponded Solids Total Suspended Solids (30 avo/100 max)

(30/100)

Oil & Grease (15/20)

Oil & Greaso (15/20)

Flow:

Flow Monitorina Point 104 Yard Symos_

Qg,mineralizer Wastej pH (6-9)

Total Suspended Total Suspended Solids (30 ave /100 max)

Sollds (30/100)

Oil & Grease (15/20)

Oil & Grease (15/20)

Flow Flow Monitorino Point 105 - Yard Sumns and Miscellaneous Waste pH (6-9)

Total Suspended Solids (30 ave /100 max)

- Oil & Grease (15/20)

Flow Monitorina Point 106 - Condenser Dumos pH (6-9)

Total Suspended Total Suspended Solids (30 ave /100 max)

Solids (30 ave /100 max)

Oil & Grease (15/20)

Oil & Grease (15/20)

Flow Flow 10

Attachment CCNPP NPDES Permit Monitoring Requiremonto 1984 1990 Monitorina Point 107 - Seit Water Cppjjna System Flow Total Residual Chlorino (0.14) 4.

QUESTION: An examination of trends in the effects on aquatic resources monitoring can Indicate whether impacts have increased, decreased, or remalnod relctively stable during operation. Describe and summarize (or provide documentation of) results of monitoring of water quality and aquatic blota (e.g.,

related to NPDES permits, Environmental Technical Specifications, alte specific monitoring required by federal or state agencios). What trends are apparent over time?

ANSWER: Summaries of studios conducted in the vicinity of Calvert Cliffs are inc!uded in Referones 1 (copy providod). Described aro the results of phytoplankton, zooplanidon, epifauna, bonthos, shellfish and fish studies. In addition, an assossment of power plant impact is included, which covers entralnment, impingomont, and tholmal offects, in particular, see " Summary and ConclusionW' on pages 276-280 for an overall summary of studios conducted at CCNPP, In addition to studios performod by CCNPP (noted above), long term trends in water quality are ovaluated by the Maryland Department of Natural Resourcos (MONR), Powor Plant and Environmental Review Program, through their long term bonthic monitoring program. The intent of the program is to monitor responses of bonthic organisms to pollution increases and decreases and power plant impacts.

The findings of their program are as follows. A change in the bonthic assemblage of the 1970s to the early 1080s was caused by an increase in salinity (due to less rainfall) in the 1980s. CCNPP does not appear to impact macrobenthic assemblages; impacts are confined to the immodlato vicinity of the power plant. In this area macrobenthics are, if anything, benefited from the power plant. It is bolloved that the increased abundances, biomass, and prodJction in this area is duo to increases in orgPnic inputs from entralnment rnortalities. The area scoured by CCNPP's high velocity dischargo, although a poor habitat for burrowers, provided for more epifauna than at referenco stations.

Oysters accumulate radionuclides and some heavy metals; however, the levels are low enough not to adversoly impact predators or pose a health risk to humans. (Reference 2)

The NPDES permit contains no conditions that relato to direct aquatic effect monitoring, except for Specis! Condition i.G.4, which requires notification of substantial intake impingement.

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Attachment

- 5.

QUESTION: Summarize types and numbers (or provide documentation) of organisms entrained and impinged by the condenser cooling water system tsince issuance of the Operating License. Describe any seasonal patterns associated with entrainment and impingement. How has entralnment and impingement changed over time?

ANSWER: Summaries of entrainment and impingement are included in Reference 1.

Entralnment studies are summarized on pages 226-250. Impingement studies conducted between years 1975-1983 are summarized on pages 254-268. AdditionalImphgement analysis is prov;ded by a trends report for the years 1982198G in Reference 3 (copy provided).

6.

QUESTION: - Aquatic hab! tat enhancement or restoration efforts (e.g.,

anadromous fish runs) during operation may have enhanced the biological communities in the vicinity of the plant. Alternatively, degradation of habitat or water quality may have resulted in loss of biological resources near the site. Describe any -

changes to aquatic habitats (both enhancement and deg,adation) in the vicinity of the power plant since the Iscuance of the Operating License including those that may have resulted in different plant impacts than those initially predicted.

ANSWER: The general conclusions of EPA's assessment of the Chesapeake is that the Bay is becoming increasingly eutrophic. With this is an increase in hypoxic / anoxic bottom -

waters, For yea *s there has been a gener:? Jecline in anadromous fishes and commercial fish and shel fish harvests. Chesapeake Bay clean up efforts have not produced significant improvements in overall water quality and habitat. The Chesapeake Bay

- Agreement of 1987 is a cornmitment between Maryland, Pennsylvania, Virginia ar.d the District of Columb!a to improve water quality, habitat and living resources of the Bay.

Plans are early in the implementation phase.

Since the early 1980s, the State has placed a lot of effort into the restoration of striped bass populations to the Bay. This effort included a moratorium on capture, sale and -

, possession of striped bass in the State. A stocking program was also conducted. Due to 1 the fact the criteria for lifting the moratorium was met in 1989 (i.e. the overall juvenile index was high), the State announced that a limited fishery would be allowed in 1990. The area surrounding CCNFP is not a spawning area for striped bass or other anadromous fishers nor does it block the passage of migratory fish to spawning areas. However,if significant increases (or decreases) in population were to occur, our data might reflect these changes. Reference 1 indicated that CCNPP data did not entirely support the proposal that anadromous fish have been declining since a couple species showed high abundance during one or two years. Reference 3 noted that during the 1981-1986 Impingement sampling period, the numbers of anadromous fish were lower than during the 1977-1982 sampling period.

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l Attachment 4

7.

QUESTION: Plant operations may have had positive, negative, or no impact on the use of aquatic resources by others. Harvest by comrr.orcial or recreational fishermen may be constrained by plant operation. Alternatively commercial harvesting may be relatively large compared w!th fish losser caused by the plant.

Describe (or provide documentation for) other nearby uses of waters affected by cooling water systems (e.g., swimming, boating, snnual harvest by commercial and recreational fisheries) and how these impacts have changed since lasuance of the Operating License.

ANSWER: Losses of commercially important fishes from CCNPP is insignificant compared to coramercial harvest. Losses due to CCNPP are 0.1% of the total commercial harvest. Additionally, this figure can be reduced by 50% if recreational landings are considered. (Reference 1).

During cooler moaths because Ln are 4ttracted to the warmer discharge waters, recreational fishermen are sometimes it and in this area. The area nearby is commerc!aily fished for oysters and blue crabs. CCNi o has little impact on recreational and cornmercial uses in the vicinity of the plai t 8.

QUESTION: Describe other sources of impacts on aquatic resources (e.g.,

industrial discharges, other power plants, agriculturel runoff) that could contribute to cumulative impacts. What are the relative contributions by percent of these sources, including the contributions due to the power plant, to overall water quality degradation and losses of aquatic blota?

ANSWER: For a discussion of sources of impacts to the Bay, see the section on " Land Use, Water Qualy and Ecosystem Respor,ses," in Reference 1, pages 4-5.

9.

QUESTION: Provide a copy of your Section 316(a) and (b) Demonstration Report required by the Clean Waste Act. What Section 316(a) and (b) determinations have been made by the regulatory authoritics?

ANSWER: CCNPP's thermal discharge meets all the State thermal mixing zone criteria.

Entrainment losses are evaluated on the basis of impacts to spawning and nursery areas of consequence to Representative important Species, and ecosystem functioning.

Entrainment losses did not result in near field depletions of phytoplankton. zooplankton, and lethyop!ankton. Net system productivity did not change significantly. Impingement losses are evaluated on the basis of cost effectiveness of reducing impingement (impinged fish are assigned a monetary value).

Impingement losses were very small compared to commercial harvests, and forage fish lost are only a small percentage of what is needed for larger predators. CCNPP passed all the requirements of the State water quality regulations (316 a & b). (Reference 4 and 5)

Note: NPDES records are required to be kept for only three years. The records for pre 1984 are not available.

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s Attachmont References for Aquatic Resources Section:

1. Hock, K.L (Ed.). Ecological Studios in the Middle Roach of Chesapeake Bay; Lecture Notes on Coastal and Estuarine Stuuios. Vol 23, VI,287 pa00s.1987. (Copy providod)
2. Holland, A.F., Shaughnessy, A.T., Scott, L.C., Dickens, V.A., Gorritsen, J., Ranasingo, J.A.1989. Long Term Benthic Mon 6toring and Assessment Program for the Maryland Portion of Chesapeake Bay: Interpretative Roport. Prepared by Vorsar, Inc. for the Maryland Departmont of Natural Resourcos, Power Plant Rosoarch Program. Annapolis, MD C3RM-LTB/EST-89-2.
3. Breitburg. D.L Trends in impingement of Finfish and Blue Crabs at the Calvert Cliffs Nuetear Power Plant 1982-1988. The Academy of Natural Sciences, Benedict, MD Roport No. 8912.1989. (Copy provided)
4. Academy of Natural Sciences. April 1981. Assessment of Thermal, Entrainment, and Impingement Impacts on the Chesapoaka Bay la too Vicinity of the Calvert Cliffs Nucioar Power Plant. Prepared for Baltimoro Gas & Electric by the Academy of Natural Sciencos.

Report No. 81-10. (Copy provided)

5. Maryland Department of Natural Resources (MDNR), Power Plant Roscarch Program.

November 1988. Power Plant Cumulativo EnvironmentalImpact Report for Maryland.

PPRP-CElR-6.

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Attachment Socio3coNoMic ou_gSTiohMWO ANSWFASj 1.

QUESTION: To undei utand the importance of the plant and the degree of its socioecoitomic impacts or she local region, estime*n the number of perrnanent workers on site for the mo it recent year for which d.sta are avallnble.

2.

QUESTION: To understand the importance of the ploit to the local reO on, and l

how tnat has changed over time, estimate the averegt. nunber of permanent workers on site, in five-year increments starting with the issunoc a of the plant'n Operating Ucense, if possible, provide this informathn for each Lait at a plant site.

ANSWERS: 1. & 2. P3rmanent Workers On Site 1975

.1960 1985 1990 213 G40 870 1478 3.

QUESTION: To understand the potentialimpact of cor'inued operation for an additional 20 years beyond the original licensing term, pleMe provide for the following three cases:

A. a typical planned outage; B. an ISI outage; and C. the largest single outage (in terms of the number of workers involved) tnat has occurred to date an estimate of add'tlonal workers involved (for the entire outage and for each principn; usk), length of outage, months and year in which work occurred, and cost.

Also, estimate occupational doses received by permanent and temporary workers during each principal task.

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Attachment ANSWER: Outages A. Unit _]

Outage Number Start length (Days) 1 01/01/77 91 2

01/23/78 73 3

04/21/79 85 4

10/18/80 85 5

04/17/82 79 6

10/01/83 71 7

04/05/85 144 8(ISI) 10/25/86 30 9

04/09/88 86.5 05/06/89 317 B. Unit 11 Outage Number Start Longth (Days) 1 09/155'S 41 2

10/12/70 55 3

01/17/81 55 4

10/16/82 93 5

'04/21/84 71 6

10/19i85 51

-7(ISI) 03/14/87 112

-0 (Largest) 03/01/89.

Current Outage Outage cost 4, specific tasks performed, number of temporary workers and occupational dose are not aval'able on an outage basis within tha resource expenditure recommended for this question. Tnis information, except for specif5 tasks performed, would be available on a site-wide, annu Al basis.

  • Unsched Jied outage to determine whether Unit 2 pressurl:ei penetration leaks were also experienc ad by Unit 1.

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Attachment 4.

QUESTION: To understand the plant's fiscal importance to specific jurisdictions, for 1980,1985, and the latest year for which data are available, estimato the entire plant's taxablo assessed value and the amount of taxes pold to the state and to each local taxing jurisdiction.

ANSWER:

Year Taxablo Assessed Taxos ($ Millions)

Valuo ($ Millions)

Stato County 1930 542 1.1 10.8 1985 599 0.3 11.7 1989 655 00 14.6 17

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-k.

Attachment WASTE MM&GEMENT ANSWERS A.

Soent Fuel Questions and Answers:

1.

QUESTION: Which of the following current techniques for at reactor storage aro you using and how?

A. Re-racking of spent fuel.

B. Control *depoeWon%. Note (1).

C. Above ground dry storaDe.

D. Longer fuel burnup.

E. Other (please identify).

ANSWER:

1 A. Have re racked the pool several times, most recently in 1983, to maximize in pool capacity.

18. Not applicable.
10. Not used.

1D. Have gone to extended burnup, long cycles, which has improved fuel utilization, Note (1): Response 1B was deleted per NUMARC letter subject " Clarification of Industry Survey, Waste Management Questions to Support Ucense Renewal Rulemaking," cated June 15,1990.

2.

QUESTION: Do you plan on continuing the use of these curren.1 techniques for at reactor storage of spent fuel during the remaining time of your operating license or do you expect to change or rnodify them in some way?

ANSWER:

2A. Plan to use existing racks, but it is not feasible to consider turther re-racking.

2D. Will continue high burnup extended cycle length core design.

3.

QUESTION: Which of the following techniques for at reactor storage do you

,anticipato using until ofi site spent fuel storage becomes available and how?

A. Re-racking of spent fuel.

B. Controf+od+epos43on%- Note (1).

C. Above ground 6 y storage.

2

-.'t Attachment D. Longer fuel burnup.

E. Other (please identify),

i ANSWER:

3A. Not anticipated.

38. Not applicable.

3C. Anticipate beginning to load fuelinto a dry Independent Spent Fuel Storage Installation (iSFSI) beginning in 1992, which will incorporate the NUHOMS 24P design consisting of horizontal concrete modules loaded with stoet canisters containing fuel assemblies.

3D. Will continue.

Note (1): This question omitted per NUMARC letter subject " Clarification of Industry Survey, Waste Management Questions to Support Uconse Renewal Rulemaking," dated June 15,1990.

'4.

QUESTION: Will the techniques described above be.sdequate for continued at-reactor storage of spent fuel for the operating lifetime of the plant, including a 20-year period of license renewal, or are you developing other plans?

ANSWER: Construction of ISFSI allows storage capacity to be extended as required, based on modularity of system.

5.

QUESTION: Do you anticipate the need to scquire additicual land for the storage of spent-fuel for the operating lifetime of the plant, including a 20-year period of '

license renewal? If so, how much tend?-- When would this acquisition occur? Where?-

(if answer is "yes",3-4 sentences).

ANSWER: No.

6.

QUESTION: Do you anticipate any additional construction acilvity on-site, or

- Immediately adjacent to the power plant site, associated with the continued at reactor-storage of spent fuel for the operating _ lifetime of the plant, including a 20 year period-

- of license renewal? (yes/no).

ANSWER: Yes.

3

Attachment 7.

QUESTION: If you answered yes to question 6, briefly describe this construction activity (e.g., expansion of fuel storaDe Pool, building above ground dry storago faellhlos).

ANSWER: Conutruction associated with the ISFSI horizontal storago modulos and rolated totds. secur"y facilities, etc.

IL._1.pw level Radioact!vg WantqJdgnenemnnt Ouctill_ons and Ap_ggersi 1.

QUESTION: Under the current scheme for LLPW disposa' (1.o. LLRW Policy Amandments Act of 1985 and regional compacts) le there curro.41y or will sufficlont capacity for wastos generated during the ll enso renewal porlod be evallable to your plant (s)? If so, what is the basis for this conclusion?

ANSWER; Calvort Cliffs 1 & ll are currently licon:ad through 201% and 20t 6, respectively.

Tbc Appalachian Compact is expected to open by 1990 and should bo opolational well into the Twenty-First Contury.

2.

QUESTION: If for any reason your plant (s) Islare denied access to a licensed disposal site for a chort period of tirne, what plans do you have for centinued LLRW disposel?

ANSWER: If donlod access to a licensed dhposal facitP, tot a short period of timo, Cotvert Cliffs would be requirod to storo wasto until ac,oss was re establishod.

3.

QUESTION: In a couple of pages, please describo lho specific mothc,ds of LLRW msnuuement currently ut:lized by our plant. What percenteDe of your Eggent LLRW (by volume) is managed by:

A. Waste compedion?

B. Waste seDrogation (through spec!al controls or segregat,., at radiat'on choce:

point)?

C. Decontamination of war,tes?

D. Sorting of wasto prior to shipment?

E. Other (please identify)

ANSWER:

3A.100% of all Dry Active Wasto (DAW) is compaciod and then transported to a vendor for oither super compaction and/or incineration,

38. Controls and proceduros have boon established to procludo unriocessary items from ontoring tho Radiological Controlled area and thus becoming radioactive wasto, i

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Attachmont

30. Approximately 5% of tho total DAW or 90% of the metal wasto in the DAW is docontaminated on sito and tomovod trom tho wasto stroam.

3D. Sorting of wasto results in approximately 10% fornovod as. loan 'rnn radioactivo" materials prior to shipment.

4.

OtJESTION: In a couple of pkges, please describe the antig!p_p.tpA plans for Lt.RW management to be utilized by your plant (s) during the remalnder of the operating license and through the license renewal term. What porcentage of your atitialpgjid waste (by volume) will be managed by:

A. Waste compaction?

B. Waste segregation (through special controls or segregation at radiation check points)?

C. Decontamination of wastes?

D. Sotilng of waste prior to shipment?

E. Other (please Idontify).

ANSWEft:

4A. All DAW will be shrodded, compacted, super-compacted and/or incineratod.

4B. Wo will continuo our waste sogrogation programs.

40. We will continue to decontaminato 'decenablo" matorials.
40. Sorting operations will continuo.

5.

QUESTION: Do you anticipate the need to acquire pJditional land for the storage of LLRW for the operating lifetime of the plant, including a 20 year period of license renewal? If so, how much land? When would this acquisition occur? Where? (if answer is "yes",3 4 sentences)

ANSWER: No.

6.

QUESTION: To provido informatlon on the timing of future low level waste streams,if you answered yes to question #9, over what periods of time are these activities contemplated?

ANSWER: Major component replacements nooded for licenso renowal will bo Imptomonted betwoon 2005 and 2015. depending on outago schedulos and nature of

work, l

1 5

Attachmont 7.

QUEST,0N: Do you anticipato any JLddjuganlC2n#JtMP11.quqtlYlty, on site, or immediately adjacent to the power plant site, essociated with temporary LLHW i

storage for the operating lifetime of the plant, including a 20 year period of license renewal? (yes/no)

ANSWER: Somo additional construction gnay have to bo podormod. Howevor, the amount will bo directly dopondent upon the LLRW storago timo and accessibility to LLRW disposal sitos.

8.

QUESTION: If you answered yes to question #7, briofly describe this construction activity (e.g., storage areas for steam generator components or other matosla!s exposed to reactor environment).

ANSWER: Doponding on DAW treatmont process, additional warehouso-typo buildings may have to bo conttructod. For long term iosin stora00 abovo ground concroto units would bo noodod. Largo components, such as Steam Gonorators, would bo ovaluated on a caso by caso basis and would requiro separato enclosed abovoground structuros for protection.

9.

QUESTION: To provide information on future low level waste streams which may effect workforce levels, exposure, and waste compact planning, do you anticipate any major plant modifications or refurbishment that are likely to generate unusual volumes of low level radioactive waste prior to, or during, the relicensing period for the plant? If so, please describe these activitius. Also, what types of modifications do you anticipate to be necessary to achieve license renewal operation through a 20-year license renewal term?

ANSWER: No major work forco levol changos anticipated duo to futuro low lovel waste stroam changes. Unusual volumes likely to be gonorated are viewod as temporary and having a finito timo period. Thorofore, additional temporary contractors would be used to support those activillos, untH lloms are placod in intorim storago or disposed at e liconsod facility, it is possible that steam generators, pressurizors, and other major compononts may requiro replacement for licenso renewal. Exactly which major compononts will requiro replacement will be dolormlnod by tho scrooning and ovaluation procoss to bo definod in the Uconso Ronowal Rule.

9. Mixed Low Level Radioactive Wasto Oyestions and Answers; 1.

QUESTION: This question omitted por NUMARC lotter subject ' Clarification of Industry Survey, Waste Management Ouestions to Support License Ronowal Rulomaking," dated June 15,1990.

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