ML20207A443

Comment Supporting NUREG-1437,suppl 1,generic Environmental Impact Statement for Licensing Renewal of Nuclear Plants. Licensee Agrees with Approach Taken by NRC to Evaluate Environ Impacts of Extending Util Operating Licenses

ML20207A443
Person / Time
Site:	Calvert Cliffs
Issue date:	05/19/1999
From:	Cruse C BALTIMORE GAS & ELECTRIC CO.
To:	NRC
References
FRN-64FR11071, RTR-NUREG-1437 64FR11071-00016, 64FR11071-16, NUDOCS 9905260335
Download: ML20207A443 (19)

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o g CHA%ES II. CRUSE DC g n Baltimore Gas and E!cetric Company Vice IYesident

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• LU Calvert Cliffs Nuclear Power Plant Nuclear Energy 1650 Calvert Cliffs Parkway a lM N 24 PH 4: 00 tu% uamand 20657

((F/vn 410 495-4455 0S 45' t{f& //07}

May 19,1999 EnA P, /ff9 x

U. S. Nuclear Regulatory Commission Washington, DC 20555 ATTENTION: Chief, Rules and Directives Branch

SUBJECT:

Calvert Cliffs Nuclear Power Plant Unit Nos.1 & 2; Docket Nos. 50-317 & 50-318 Comments on NUREG-1437, Supplement 1, Calvert Cliffs Nuclear Power Plant Draft Supplement to the Generic Environmental Impact Statement for License Renewal of Nuclear Plants (64 FR 11071)

Baltimore Gas and Electric Company (BGE) appreciates the opportunity to comment on the draft supplement to NUREG-1437, Generic Environmental Impact Statement for License Renewal of Nuclear Plants, as requested in the Federal Register notice published on March 8,1999 (64 FR 11071). The draft supplemental environmental impact statement (SEIS) was prepared in response to BGE's application to renew the operating licenses for Calvert Cliffs Nuclear Power Plant (CCNPP) Unit I and Unit 2 for an additional 20 years under 10 CFR Part 54.

Baltimore Gas and Electric Company agrees with the approach taken by the Nuclear Regulatory Commission (NRC) to evaluate the environmental impacts of extending CCNPP's operating licenses, as well as the conclusions reached by the NRC relative to these impacts. We do, however, have comments that are intended to clarify, and in some cases, correct the information presented in the draft SEIS. These comments are provided as Attachment I to this letter. Baltimore Gas and Electric Company is satisfied that these comments will not affect the NRC staff's preliminary recommendation regarding the renewal of CCNPP's operating licenses.

Should you have questions regarding this matter, we will be pleased to discuss them with you.

Very truly 3 cars,

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9905260335 990519 E PDR NUREG f 1437 C PDR  ; Ge

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CHC/RCG/ dim

Attachment:

(1) Comments on NUREG-1437, Supplement 1, Calvert Cliffs Nuclear Power Plant Draft Supplement to the Generic Environmental Impact Statement for License

, , _ , Renewal of Nuclear Plants G. :JJ l

, _ Document Control Desk May 19,1999 Page 2 cc: R. S. Fleishman, Esquire Resident Inspector,NRC J. E. Silberg, Esquire C.1. Grimes, NRC S. S. Bajwa, NRC T. Kenyon, NRC A. W. Dromerick, NRC R. I. McLean, DNR H. J. Miller, NRC J. H. Walter, PSC l

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ATTACHMENT (1)

COMMENTS ON NUREG-1437, SUPPLEMENT 1, CALVERT CLIFFS NUCLEAR POWER PLANT DRAFT SUPPLEMENT TO TIIE GENERIC ENVIRONMENTAL IMPACT STATEMENT FOR LICENSE RENEWAL OF NUCLEAR PLANTS Baltimore Gas and Electric Company Calvert Cliffs Nuclear Power Plant May 19,1999

ATTACIIMENT (1)

Comments on NUREG-1437, Supplement 1, Calvert Cliffs Nuclear Power Plant Draft Supplement to the Generic Environmental Impact Statement for License Renewal of Nuclear Plants No. Page Line Nos. Comment

1. 1-4 21 The federal register citation for the notice of acceptance for docketing is 63 FR 27601, not 26701.

2. 1-7 7 The surface water appropriation permit number and expiration date need to be corrected. He permit, CA71S001 (02), expires on Aprill,2001.

3. 1-7 9,10 and 15- Table 1-1 identifies consultation request dates for Fish and Wildlife Service 17 (FWS), National Marine Fisheries Service, and Maryland Historic Trust, but does not identify the agencies' response dates. Should the responses from these agencies be provided in Table 1-17

4. 21 28 The three crops do not all agree with the three given on page 2-22, line i1. l Those on page 2-22 are correct (corn, wheat, and hay). Tobacco is not l' included in the list of crops grown on the Calvert Cliffs Nuclear Power Plant (CCNPP) site, and should be replaced with wheat on this list.

5. 2-1 34-37 The sentence beginning,"Part of the upper areas . . " is confusing, as it could be interpreted that St. Leonard Creek drains directly into the Chesapeake independently of the Patuxent River. [ suggested rewording] "Part of the upper areas, used primarily during the construction period, drain through the Johns Creek watershed into the St. Leonard Creek, which then drains into the Patuxent River approximately 7 km (4 mi.) from the plant. The Patuxent River drains into the Chesapeake Bay approximately 16 km (10 mi.) south of the plant."

6. 2-1 40 Using the term ' region' when referring to the Chesapeake is ambiguous and should be deleted from the sentence beginning on line 40. This sentence should be reworded, as follows: "The Bay has an average depth of approximately 9m (30 feet) . ."

7. 2-1 43 The source of the referenced information is K. G. Sellner & B. A. Peters [in Heck 1987]. Most style guides would not recommend referencing only the cover document. [Also, the original reference notes that the springtime condition described is found in the upper 20-30 km of the Bay . .which is NOT in the vicinity of CCNPP.]

8. 2-4 7 The discharge structure is located offshore, beneath approximately 10 feet of water, and should not be discussed under the heading of External Appearance. Also, " service building intake structure" is not CCNPP terminology; this building is referred to as the intake Structure. This sentence should be corrected, as follows: "The Intake Structure is located east (bayside) . "

9. 2-5 Fig 2-3 The legend of the map should include 69-kV Southern Maryland Electric Cooperative (SMECO) transmission line, as this figure is called out (on page 2 16, line 46) in reference to this plant feature.

10. 2-10 4 There is no (BGE 1998a) in the reference list in Section 2.3.

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ATTACHMENT (1)

Comments on NUREG-1437, Supplement 1, Calvert Cliffs Nuclear Power Plant Draft Supplement to the Generic EnvironmentalImpact Statement for License Renewal of Nuclear Plants No. Page Line Nos. Comment

11. 2-10 22,23 The sentence beginning "Each of the two reactors . ." does not belong here. ,

l It is misleading in that the remainder of the paragraph discusses the j circulating water system rather than the primary system. For clarity, this sentence should be relocated to line 36, after the sentence beginning, "The primary coolant loop . . ", and reworded as follows, "The primary coolant system for each unit consists of a reactor, two steam generators, two reactor coolant loops, and four reactor coolant pumps." )

12. 2-10 27-29 A consistent source should be used for the dimensions of the intake and discharge channels. Calvert Cliffs' Updated Final Safety Analysis Report j (UFSAR), Figure 138, shows these dimensions to be approximately 4500 ft.

and 850 ft, respectively. The intake channel length is taken from the baffle wall to the farthest point in the dredged channel, and the discharge channel length is taken from the shoreline to the end of the discharge conduit. (See comment for page 4-12, lines 9 and 15 and Figure 2-7.]

13. 2-10 30 The draft Supplemental Environmental impact Statement (SEIS) refers to an

! " intake canal" in several places. This is incorrect terminology. Calvert Cliffs .

Nuclear Power Plant draws cooling water directly from the Bay through a dredged channel, not a canal as is common for other plants.

14, 2-11 Fig. 2-7 The dimension of the intake channel should be shown to be "Approximately 4,500 ft." per UFSAR Figure 1-3B. (See comment for page 2-10, lines 27-29 and page 4-12, lines 9 and 15.)  ;

15. 2-12 4 For clarity, this sentence should be revised tc add the word " groundwater," as ,

follows: "CCNPP has five gtsmdwater production wells . . . ." l

16. 2-12 5 The draft SEIS indicates that nine wells supply water for domestic use in outlying areas. One of the nine wells was abandoned and was excluded from Environmental Report (ER) Table 2-3 and Figure 2-7. This change should also have been made in the second paragraph of ER Section 2.1.4, which may have been the basis for the statement in the draft SEIS.

17. 2-12 9-10 For clarity, this sentence should be revised, as follows: " Groundwater wells provide the source water for domestic, plant service and demineralizer make-up water needs, . . ."

18. 2-12 11 For clarity, this sentence should be revised, as follows: " . . discharged through the submerged outfall to the Chesapeake Bay."

19, 2 12 Section 2.1.4 A source reference should be provided for the description of CCNPP's radioactive waste processing systems.

20. 2 13 32 The draft SEIS indicates that the concentration limits ofliquid effluents meet the specifications of 10 CFR Pan 20, Appendix B, Table 2. This Table reference is to the current version of Part 20, whereas CCNPP's effluent control program, as discussed in the Offsite Dose Control Program (ODCM), is to the older version of Part 20. Therefore, the correct reference for CCNPP would be 10 CFR Part 20, Appendix B, Table II. (NOTE: Use of the maximum permissible concentration values in the old Table 11 still ensures that the current effluent concentration limits in Table 2 are met.)

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Comments on NUREG-1437, Supplement 1, Calvert Cliffs Nuclear Power Plant Draft Supplement to the Generic EnvironmentalImpact Statement for l License Renewal of Nuclear Plants No. Page Line Nos. Comment l

21, 2-13 9 It is unclear which system is considered the " Liquid Radwaste Treatment System", as this is not BGE tenninology. The Reactor Coolant Waste Processing System (RCWPS) and Miscellaneous Waste Processing System are collectively considered liquid waste processing systems.

22. 2-13 18 The RCWPS has four Reactor Coolant Waste ion e#mgers.

23. 2 13 22-24 Taken individually, the first three sentences of the fifth paragraph of Section 2.1.4.1 are technically accurate; however, the order of these sentences does not follow the process pathway of the RCWPS. Reactor Coolant Waste

liquid is filtered and passed through the ion exchangers prior to being i

transferred to the Reactor Coolant Waste receiver tanks.

24. 2-13 46 [ editorial comment] It appears that a word is missing from the sentence describing normal operation of the Waste Gas Processing System (WGPS).

he sentence should be revised, as follows: " . . . designed to store the gases removed from liquid waste . . ."

25. 2-14 15 [ editorial comment] " turbine building ventilation." should be a separate bullet.

26. 2-14 17 To clarify the statement regarding the control of gaseous releases, the sentence on line 17 should be replaced with the following: " Potential release pathways are sampled according to approved plant procedures. Occasional releases from abnormal pathways are quantified and recorded. BGE maintains all gaseous releases within ODCM limits." This text is taken from the CCNPP UFSAR, Revision 25.

27, 2-14 19 and 35 The name " Gaseous Radwaste Treatment System (GRTS)" is not BGE terminology. The terminology used earlier in the draft SEIS should be used here as well(WGPS).

28. 2 14 27-29 The dose rates provided in lines 27 through 29 are annual limits, and should l be provided in terms of mSv/ year (mrem / year). They should be clearly ,

identified as annual dose limits. l l

29. 2-14 28 The skin dose rate limits should be 30 mSv/ year (3000 mrem / year).

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30. 2-14 35 Although CCNPP design incorporates filters and waste gas processing  !

equipment that collectively may be referred to as ventilation exhaust '

I treatment equipment, the plant design does not include a " Ventilation Exhaust i Treatment System," per se. Therefore, the draft SEIS should be revised, as follows: "The WGPS is used to reduce radioactive material in gaseous waste 31, 2-15 3 For accuracy, the first sentence of Section 2.1.4.3, Solid Waste Processing, should indicate that BGE packages solid waste according to the applicable requirements of 49 CFR Parts 171 through 177. Disposal and transportation are performed in accordance with the applicable requirements of 10 CFR Parts 61 and 71, respectively. j l

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ATTACHMENT (1)

Comments on NUREG-1437, Supplement 1, Calvert Cliffs Nuclear Power Plant Draft Supplement to the Generic Environmental Impact Statement for I License Renewal of Nuclear Plants No. Page Line Nos. Comment 1

32. 2-15 9-10 The draft SEIS states that RCWPS evaporator bottoms are normally recycled l

or may be solidified after use. Baltimore Gas and Electric Company's I Process Control Progrart do": .,v include provisions for waste solidification.

This sentenea ded be revised as follows: "RCWPS evaporator bottoms are 1 normally recycled otherwise processed in accordance with BGE's Process  !

Control Program."

33. 2-15 15 The draft SEIS states that dry active waste is temporarily stored in the Materials Processing Facility until it can be shipped to a permanent disposal facility. This sentence should be revised to indicate that dry active waste may alternatively be shipped to a processing facility.

34. 2 15 24 Although much of Lake Davies is an undeveloped field, the interim resin storage facility is located on a crushed gravel pad. Therefore, this sentence would be more accurate if the word " meadow" were deleted.

35, 2-15 25,25 The draft SEIS discusses the two areas used for resin storage at CCNPP; the interim resin storage facility and the West Road Cage. The SEIS notes that the interim resin storage facility was designed for up to five years of storage, and the West Road Cage provides interim storage for up to five years. By SECY-94-198, the NRC noted that there was no health and safety basis for the five-year criterion, and eliminated this criterion from GL 81-38.

Therefore, the statements indicating that these areas provide interim storage for up to five years should be removed from the draft SEIS.

36, 2-15 33 Offsite processing facilities are also used for decontamination of equipment.

The bullet on line 33 should say,"offsite processing facility for segregation, recycling, compaction, decontamination. and incineration."

37. 2-16 7, 8 For completeness, this sentence should be reworded, "Long-term ou'ms are scheduled for refueling and for maintenance, modification dor replacement of major components."

38. 2-16 18 There is no (NRC 1996) in the reference list in Section 2.3.

39, 2-17 22 Reference (Calvert County 1997) should be (Calvert County 1997a), (See comment for page 2-48, lines 25,27.)

40. 2 17 37 The methodology for citing the reference from the Chief - Coastal Zone Consistency, Maryland Department of the Environment (MDE) is not consistent with that for other references from MDE. For consistency, this reference should be called out on page 2-17, line 37 as (MDE 1998), not (Ghigiarelli 1998), and the reference source on page 2-49 should be revised accordingly.

41. 2-18 1 Reference (Calvert County 1994) needs to be either 'a' or 'b' per Sec. 2.3.

42. 2-18 21 The text indicates that the average daily groundwater withdrawal rates over the last two years was 1.89x10-2 m'/s (392,000 gpd). A reference should be provided for this value (possibly BGE's November 20,1998 Request for Additional Information [RAI] response submittal), as well as defining the j two-year period (possibly July 1996 - June 1998). (See comments for l page 4-27, line 3 and page 8-7, line 9.)

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ATTACHMENT (1)

Comments on NUREG-1437, Supplement 1, Calvert Cliffs Nuclear Power Plant Draft Supplement to the Generic EnvironmentalImpact Statement for License Renewal of Nuclear Plants No. Page Line Nos. Comment 43, 2-19 15 The sentence beginning,"According to EPA . ." needs a reference citation.

44, 2-20 21 The drah SEIS indicates that the site includes approximately 80 ha (200 acres) of marshlands. A reference should be indicated for the source of this information and the location of the marshlands.

45, 2-20 21-23 It is suggested that this paragraph be moved to follow the paragraph beginning, "Two Federally protected species ", so that the first three paragraphs will address saltwater resources, and the last two paragraphs will address fresh water species.

46. 2-20 25 [sp.] Atlantis loggerhead turtle . . .

47, 2-20 27-28 The text indicates that BGE has " . . occasionally collected the shortnose sturgeon." Based on analysis of the monthly trawl samples of fishes taken in .

I the vicinity of CCNPP between 1969 and 1981, it is apparent that only one shortnose sturgeon fish was captured during that period, in May 1979

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Reference:

Heck, K.L., Jr., [Ed.] 1987. Ecological Studies in the Afiddle Reach ofChesapeake Bay. Lecture Notes on Coastal and Estuarine Studies.

Springer-Verlag-Berlin, Heidelberg, New York.)

48. 2-20 41-42 The term ' associations' would be more appropriate than ' biomes' in this context.

49. 2-20 43 There are various species of Quercus in this association. The specific species

" rubra and alba" should be replaced with "spp" to indicate the multitude of species present. 1

50. 2-21 Tables 2-3 Provide reference source for material in Tables 2-3 and 2-4. If possib5 and 2-4 provide additional information as to what parts of the Chesapeake Bay these species are located.

51. 2-22 4 Replace A:alea with Rhododendron.

52. 2-22 6 Since there were two plans created for two separate parcels of land, the sentence should begin,"In 1985 and 1987, BGE foresters . .

53. 2-22 7 The correct agency is the Maryland Department of Natural Resources.

54. 2-22 38 The second sentence on line 38 should be reworded, as follows: "These species are also protected under State . . . ." )

1 55, 2-23 Table 2-5 Provide reference source for material in Table 2-5. It is apparently derived i from (BGE 1998). Also, on line 4, Cicindella is spelled incorrectly. The i correct spelling is Cicindela, as per line 6. l

56. 2-24 1 Every bold heading has a Section number (e.g., 2.2.7.1), unless it is also italicized. j

57. 2-24 40 As per Table 2-6,909 CCNPP employees live in Calvert County. Table 2-6 is in agreement with data provided by BGE in the November 20, 1998 submittal.

58. 2-24 42 Change reference to (US Department of Commerce [ DOC] 1992a).

59, 2 25 12 [ spelling correction] Harford.

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ATTACHMENT (1)

Comments on NUREG-1437, Supplement 1, Calvert Cliffs Nuclear Power Plant Draft Supplement to the Generic EnvironmentalImpact Statement for License Renewal of Nuclear Plants No. Page Line Nos. Comment

60. 2-25 Table 2-6 The source document for Table 2-6 should be included in Section 2.3, References.

61. 2-25 28 The 1998 figures are not in Table 2 7 as the text states. If the 1998 figures are projections or estimates, the text should say so.

62. 2-26 Table 2-7 Provide reference source for material in Table 2-7.

63. 2-27 Table 2-8 Provide reference source for material in Table 2-8.

64. 2-30 26 The draft SEIS indicates that the highway is considered to meet Service Level C. Provide the source of this information, and clarify whether this rating applies to the portion of Route 2-4 near the plant.

65. 2-31 7 Figures 2-2 and 2-3 show the CCNPP location, but do not show " general land use and planned land usei' as the text states.

66. 2-31 17 and 29 There is no reference (Calvert County 1997b), although there is a (Calvert County Planning Commission 1997b). (See comment for page 2-48, lines 25, 27.)

67. 2-31 42 This data should be supported by a reference citation.

68. 2 32 25 and 35 There is no reference (Calvert County 1997b), although there is a (Calvert County Planning commission 1997b). (See comment for page 2-48, lines 25, 27.)

69. 2-33 8 Second sentence should begin, "The Forest Consewation Act, . . ."

70. 2-33 46 The text indicates that the ER estimated resident population. For accuracy, this sentence should be revised, as follows: " Sections 3.8.1 and 3.8.2 of the applicant's ER presented US census data for 1990 and estimated resident population for each decade . . ."

71, 2-34 6 Reference (Virginia Employment Commission 1993) is not listed in Section 2.3.

72. 2-39 45 Reference (Washington, DC Mayor's Office of Planning 1995) is not listed in Section 2.3.

73. 2-43 20 Reference (DOC 1996) is not listed in Section 2.3. Should it be DOC 19957

74. 2 45 29-30 When a document is authored by more than two co-authors, they are typically not cited individually. Following this convention the report by Hopkins, Collier, and Fischler should be cited as (Hopkins st.al 1992).

75, 2-47 References Multiple citations from the same source should be listed in chronological order (e.g., Five BGE citations from 1970-1998 are randomly listed.)

76, 2-48 25,27 The list of references identifies different sources for the Calvert County Zoning Ordinance and the 1997 Comprehensive P'an, but the dates include an alphabetic suffix, indicating that they were prepared by the same party. Both documents were adopted by the Calvert County Commissioners, so it may be more appropriate to identify them as 'Calvert County 1997a' and ' County County 1997b.*

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ATTACHMENT (1)

Comments on NUREG-1437, Supplement 1, Calvert Cliffs Nuclear Power Plant l- Draft Supplement to the Generic Environmental Impact Statement for License Renewal of Nuclear Plants l

l i No. Page Line Nos. Comment 1

77, 2-49 17 (See comment for p. 2-17, line 37.)

l 78. 2-49 24 K.L. lieck, Jr. is the editor of the referenced document. The citation should l

be indicated in the reference list [i.e., lieck, K.L., Jr., (Ed.)).

79. 3-2 23 27 Section 3.0 of the draft SEIS evaluates the potential environmental effects of refurbishment actions. In the afternoon session of the public meeting held on April 6,1999, some confusion arose as a result of a statement made by BGE that there was no refurbishment to be conducted that affected anything outside the perimeter of the Protected Area. To clarify this statement, BGE l hereby reaffirms the statement originally made on page 2-6 of the License l Renewal Application - Environmental Report, and subsequently reiterated in the draft SEIS, that BGE "has wt identified the need to undertake the major refurbishment activities that the GEIS [ Generic Environmental Impact Statement) assumed for license renewal, and no other modifications have been identified that would directly affect the environment or plant effluents."

80. 4-7 18 incorrect document reference. Should be (MDE 1998h).

81. 4-8 41 incorrect document reference. Should be (MDE 1998h).

82. 4-8 45 liirshfield & liixson (1981) is the impingement portion of Academy of National Science-Philadelphia (ANSP)(1981). Therefore, the text essentially cites the same Clean Water .Act (CWA) Section 316[b] study two different ways.

83. 4-9 7 Change Ilirshfield & liixson (1981) to ANSP (1981).

84. 4-9 7 The 316[b] den $onstration was an analysis of three years of sampling. The sampling method used during the formal 316[b] demonstration was not unique to that study. It would be more appropriate to say that this method was employed for the formal 316[b] demonstration and was applied for a total of 21 years of continuous impingement monitoring.

85. 4-9 8-11 The sampling method description is misleading. For clarity, the following changes should be made: "The sampling schedule was based on reoeating six-day cycles in order to sample each hour of the day with equal frequency over a 365-day period. On each sampling day, one-hour collections were made at each unit. Since data from an earlier impingement sumval study at the CCNPP . . . ."

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86. 4-9 12 The draft SEIS indicates that survival data from (Burton 1976) was used to l assess potential survival of impinged species. liowever, the survival data l applied were taken from three studies subsequent to Burton 1976. See ANSP 1981, p. V-4.

87. 4-9 17,22,and Replace ' impinged' with ' collected'.

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88. 4-9 18,23,and [ Add] " Yearly imoingement estimates were . . ." The first line is a total 28 number of finfish and blue crabs caught during each year throughout the collection periods. The second line is the annual impingement estimate based on the operating time of the plant.

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ATTACIIMENT (1)

Comments on NUREG-1437, Supplement 1, Calvert Cliffs Nuclear Power Plant Draft Supplement to the Generic Environmental Impact Statement for License Renewal of Nuclear Plants No. Page Line Nos. Comment

89. 4-9 29 The correct number is 261,785.

90. 4-9 32 For clarity and accuracy, this paragraph should be reworded, as follows:

"Thus, for the 1977 through 1979 time frame, an annual average of 1,600,000 finfish and blue crabs acre collected on the traveling screens, of which 260,000 did not survive. lhe expected monetary loss due to the death of finfish and blue crabs due to impingement was $24,000 per year "

91. 4-9 36-39 It should be clarified that the ANSP (1981) study used the annual studies from 1977-79. The Horwitz (1987, in Heck, [Ed.]) summary report used the annual studies from 1975-83, including the same 1977-79 reports. The methods need not be described as though they were separate investigations, since they were all ANSP studies. Additionally, they were not ' concluded in 1983', They continued for 12 more years.

It would be better if the method were described once . . . then note that three of the annual summaries were used to satisfy the formal CWA Section 316[b]

requirement and the first nine years of studies were compiled and summarized in Heck [really Horwitz) (1987). The protocol was complicated and did change in the early years but settled on a method that was designed to sample each generating unit separately during all times of the day and all tidal conditions.

92. 4-9 38 Randomly selected days were used only in 1975. The format became more structured afler that, and continued for 21 years. While the ANSP and Heck studies are valuable as summary documents, it should be noted earlier in Section 4.1.2 that full, annual impingement investigations were conducted during the first 21 years of plant operation.

93. 4-9 43-45 The sentence that begins, "'Ihe number of potential episodes . . ." needs clarification. It is confusing and does not fit with the rest of the paragraph. If it can not be re-stated, it should be omitted. If this sentence is retained or reworded, the word " discreet" should be replaced with " discrete."

94. 4-10 24 [ editorial correction] The sentence beginning on line 24 should read,

" Experiments showed impingement survival of blue crabs . . ."

95. 4-10 30 To capture the breadth of the information in (BGE 1998b), it is suggested that the sentence beginning 'Three summary studies . . .' be reworded, as follows:

"In addition to 21 annual imningement survevs. three summary studies are discussed: . . ."

96. 4-10 32 The third summary reference should be corrected, as follows:

" . . . (Heck 1987) and a 1989 Trends report developed by ANSP."

97. 4-11 16 This bullet indicates that certain environmental conditions (warm weather, thermally stratified Bay, and prolonged west or southwest winds) may not be attributable to CCNPP operations. It would be more accurate to say that these conditions are not attributable to plant operations.

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1 A'ITACIIMENT (1)

Comments on NUREG-1437, Supplement 1, Calvert Cliffs Nuclear Power Plant Draft Supplement to the Generic Environmental Impact Statement for License Renewal of Nuclear Plants No. Page Line Nos. Comment

98. 4 11 31 33 The demonstration of thermal discharge effects is ascertained by CWA Section 316(A), not 316(b), as stated. Additionally, the 316(a) variance is based on thermal discharges, not cooling water intake structure design. The 316(b) discussion belongs in Section 4.1.2, Impingement.

99. 4-12 3 In other parts of the document, the law is called the CWA. For consistency, it is suggested that the same terminology be used here as well.

100. 4-12 9 and 15 A consistent source should be used for the dimensions of the intake and discharge channels. Calvert Cliffs' Updated Final Safety Analysis Report, Figure 1-3B, shows these dimensions to be approximately 4500 ft. and 850 ft, respectively. The intake channel length is taken from the baffle wall to the farthest point in the dredged channel, and the discharge channel length is taken from the shoreline to the end of the discharge conduit. (See comment for page 2-10, lines 27-29 and Figure 2-7.]  !

1 101, 4-12 9 CCNPP does not have an intake canal. (See comment for page 2-10, line 30.)  !

In this case, the word " canal" should be replaced with either " channel" or

, " forebay." l g 12. 4-12 12 As discussed in the CCNPP Updated Final Safety Analysis Report, the condenser tubes for Unit I are austenitic stainless steel and those for Unit 2 are titanium. For clarity, the following wording is suggested,"The condenser shells contain austenitic stainless steel (Unit 1) and titanium (Unit 2) tubes."

103, 4-12 41 [ typographical error] should say (0.4 m 2),

104. 4-18 33 For consistency with the GEIS definition, it is suggested that the discussion of sparseness be reworded, as follows, " Sparseness measures population density and city size within 32 km . . ."

105. 4-19 20 " . . BGE's estimate of 60 license renewal employees . " should be revised to " . . . BGE's bounding estimate of 60 license renewal employees . . "

Additionally, it should be clarified that BGE does not expect to hire any additional employees for license renewal, but used the NRC's bounding estimate of 60 as the basis for analyzing a bounding case scenario. This document should be very clear regarding the expectations for the license renewal period.

106. 4-20 15,24 The text should be revised to indicate that the 60 additional license renewal employees is a bounding estimate.

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ATTACHMENT (1)

Comments on NUREG-1437, Supplement 1, Calvert Cliffs Nuclear Power Plant l Draft Supplement to the Generic Environmental Impact Statement for L.lcense Renewal ofNuclear Plants l No. Page Line Nos. Comment 107. 4-20 24 The draft SEIS indicates that 60 additional plant employees could generate a population increase of up to 577 people in Calvert and St. Mary's counties.

l Please explain how this number was calculated. Calculations performed by BGE indicate that the estimated population increase in 'hese two counties would be 643 people, as follows:

Percentage of employees in Calvert and St. Mary's 89 %

counties per draft SEIS Table 2-6 ([909 + 256]/1309)

Maryland employment multiplier 3.9997 Average household size in Maryland 3.01 Based on this data, the estimated population increase in Calvert and St.

Mary's counties was calculated, as follows: (60 employees x 89% x 3.9997 x 3.01 = 642.9 [643 people]).

108. 4-20 30,31 Revise " . . population increase of about 50 people . . ." and ". . . (9 percent of 577)" to " . . population increase of about ill people . . ." and "(9 percent of(dl)", respectively, per the revised population projection discussed in the comment for page 4-20,line 24.

109. 4-20 36 Revise ". . . between 9500 to 15,000 additional liters per day (Ud) (2500 to 4000 gpd) . . " to ". . . between 11.600 to 17.400 additional liters per day (L/d) (2200 to AfdD gpd) . . ." per the revised population projection discussed in the comment for page 4-20,line 24.

I10, 4-20 39 Revise "An additional 50 residems, drawing an additional 15,000 L/d (4000 gpd) . . ." to "An additional 58 residents, drawing an additional 17.400 L/d (ifdQ gpd) . . " per the revised population projection discussed in the comment for page 4-20, line 24. The recalculated water usage is still less than 1 percent of the current daily output of the Solomons and Lexington Park water supply systems, so the impact on the water supply would still be SMALL.

111, 4-21 16 The plant-related population increase for Calvert County should be revised from 433 to 502, based on the revise employment data in Table 2-6

([909/1309] x 60 x 3.9997 x 3.01 = 501.6 [502 residents]).

112. 4-21 32 Revise to reflect annual payment, as follows: ". . . reaching approximately

$33 million per sear by 2036."

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I Comments on hUREG-1437, Supplement 1, Calvert Cliffs Nuclear Power Plant

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Draft Supplement to the Generic Environmental Impact Statement for License Renewal of Nuclear Plants No. Page Line Nos. Comment i13. 4-23 36-41 Section 4.4.5 of the draft SEIS, beginning on line 36, states the following:

"Because there is a distinct possibility that undisenvered and/or unrecorded prehistoric and historic period archaeological sites exist in  !

the 2300-acre plant site, as well as currently undocumented historic l I

structures, additional care must be taken during normal operation or maintenance to ensure that cultural resources are not inadvertently impacted. These activities may include not only operation of the plant itself but also land management-related actions such as farming, recreation, wildlife habitat enhancement, or maintaining / upgrading access roads throughout the plant site."

These statements are unsubstantiated by BGE's ER, the State Historic Preservation Officer response, or any other data or analysis in the draft SEIS and should be removed.

I14, 4-24 9 The cited reference should be (NRC 1996s).

115. 4-24 35-36 The environmental justice discussion presented in this document should be more well-defined. Define " minority" and "significant contribution." l 116. 4-24 35-36, and The figure appe ars to depict a 10-mile radius, rather than an 80 km (50-mile) j Figure 4-1 radius as indicated. Also, a source reference for this map should be provided. l The text on page 4-24, line 44-45 identifies specific communities; therefore, I these communities should be identified on the figure.

I17. 4-24 44 Same comment as page 4-24, lines 35-36; define " low income."

118. 4-24 45 [ spelling error] Huntington.n 119. 4-25 Figure 41 The title for this figure is " Census Block Groups with Large Minority or Low-income Populations." This appears to be inconsistent with page 4-24, line 36, which indicates that no Census block group showed a significant concentration of minority individuals. (This may be resolved by defining environmental justice terms, such as " minority", " low income", and "significant contribution.") In addition, to combine the two may be misleading. Two types of shading should be presented to represent each group (minority and low-income).

120. 4-26 7 [ editorial correction) The word " issue" should not be plural. "For this issue 121. 4-26 23 The conclusion for groundwater quality degradation (saltwater intrusion) says that there are no impacts of " radiation exposures to the public." The conclusion sentence needs to be corrected.

122. 4-26 26 Reference should be to Section 4.5.1.

123. 4-27 3 A reference needs to be cited for the groundwater withdrawal data. Also, this value (409,000 gpd) is not consistent with information provided in Section 2.2.2, Water Use. (See comment for page 2-18, line 21 and page 8 7, line 9) 1I

ATTACHMENT (1)

Comments on NUREG-1437, Supplement I, Cnivert Cliffs Nuclear Power Plant Draft Supplement to the Generic EnvironmentalImpact Statement for License Renewal of No clear Plants No. Page Line Nos. Comment 124, 4-28 8 To more accurately reflect the FWS recommendations, the sentence describing constraints on site activities in the vicinity of bald eagle nests should be revised to indicate that this only refers to " active" nests. This sentence should be revised, as follows: "The FWS also recommended constraints on activities in the vicinity of active bald eagle nests . . ."

125. 4-28 12 The sentence beginning with "Any activities resulting ." should be reworded to more accurately reflect the FWS recommendation. [ suggested wording] "It was further recommended that BGE initiate consultation with the FWS whenever activities are planned that would result in significant habitat changes wiQin the 0.4 km (1/4 mile) radius of active bald eagle nests, regardless of time of the year."

126. 4-28 20 For clarity, the following wording is suggested: "Thus, aggratine license renewa'should not..."

127, 4-28 20 [ editorial correction] "of either" is repeated at the end of line 20.

128. 4-32 17 The reference citation should be corrected, as follows: " Heck, K. L., Jr. Ei) 1987..."

129. 4-32 22 [ editorial correction] The correct date is April 8,1981, not 1991.

130. 5-2 32 The draft SEIS indicates that BGE was still evaluating three " design" changes when the application was submitted. For accuracy, two of the three changes being reviewed were design changes, and one was a procedure change. It would be more accurate to indicate that ". . . BGE was still evaluating three cronosed changes at the time . . "

131. 5-2 39-40 Delete sentence,"As a result of further evaluation . . .," and change the first word of the following sentence from "This" to "The." The changes better reflect BGE's current position on SAMA 66b.

132. 5-2 42 The draft SEIS indicated that a watertight door is currently being installed under BGE's Corrective Actions Program. The severe accident management analysis (SAMA) to install a watertight door is being pursued under BGE's modification crocess. as per reference (BGE 1999).

133. 5-10 3 CCNPP does not have centrifugal charging pumps. For CCNPP, the benefit to be gained from providing a back-up source for component cooling water is to " . . reduce the impact of a loss of component cooling by providing a means to maintain the reactor coolant numo seals after a loss of component cooling water."

134. 5-10 7 For clarity, revise the basis for SAMA No. 96 as follows, "This would allow extended use of high-pressure safety injection after the Saltwater System loss.

which causes the ECCS numn room coolers to be lost.

135. 5-10 12 The modification proposed by SAMA No. 7 provides a benefit whenever room cooling is lost, not just in the event of a station blackout event.

Therefore, the basis for this SAMA should be revised as follows,"This would imnrove the reliability of AFW when room cooline is lost.

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Comments on NUREG-1437, Supplement 1, Calvert Cliffs Nuclear Power Plant Draft Supplement to the Generic Environmental Impact Statement for License Renewal of Nuclear Plants No. Page Line Nos. Comment 136. 5-10 28-32 The SAMAs to improve DC power reliability invide a benefit not only during station blackout events, but whenever battery charging is lost.

Therefore, the basis for SAMA Nos. 31 and 32 should be revised as follows, "This would extend the availability of DC power when batterv chargine is l

lost, thereby reducing the frequency of long-term station blackout core melt l sequences and other losses of 125V DC nower core melt seauences."

137. 5 10 36 and 40 Cross-tying 4 kV buses does not reduce the frequency of station blackout core melt sequences. This part of the basis for SAMA Nos. 33a and 33b should be deleted.

138. 5-10 44 The SAMA to use a portable generator to feed the 125V DC buses would I provide a benefit during other losses of 125V DC, in addition to station blackout sequences. The basis for SAMA No. 34 should be revised, as follows: ". . . thereby reducing the frequency of long-term station blackout core melt sequences and other losses of 125V DC nower core melt secuences 139. 5-10 47 The SAMA to replace the batteries with a more reliable model theoretically would provide a benefit during other losses of 125V DC, in addition to station blackout sequences. The basis for SAMA No. 36 should be revised, as follows: ". . . thereby reducing the frequency oflong-term station blackout core melt sequences and other losses of 125V DC oower core melt seauences."

140. 5 11 21 The SAMA to provide an automatic bus transfer feature for the 120V vital AC system would reduce the frequency of spurious safety system actuation l sequences, not station blackout core melt sequences. The basis sentence should be revised as such.

141, 5-11 46 The SAMA to increase the capacity of Condensate Storage Tank (CST)

No.12 would provide the benefit of reducing the frequency of long-term loss of feed core damage sequences, not station blackout or steam generator tube rupture sequences. Therefore, the basis for SAMA No. 69 should be revised, as follows: ". . . thereby reducing the frequency of long-term loss of feedwater core damage seauences. and other core damage sequences."

142. 5-12 7 The SAMA to automate demineralized water make-up to CST No.12 would

reduce the likelihood that CST No.12 would be depleted during events that require CST No.12. The primary benefits are reducing long-term loss of main feedwater, core damage scenarios (e.g., loss of offsite power), and loss l of Service Water and Component Cooling Water make-up scenarios.

Therefore, the basis for SAMA No. 74 should be revised, as follows:

. would permit continued inventory make-up to the CST during a loss of offsite power. thereby reducing the frequency of long-term loss of feedwater core melt sequences. as well as enhancine Service Water and Comnonent l Cooling Water System make-un canabilities.

l 143. 5-18 9 Change sentence beginning, "BGE determined that one . . .," to "BGE has determined that one of these SAMAs may be cost beneficial when . . ."

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ATTACHMENT (1) l Comments on NUREG-1437, Supplement 1, Calvert Cliffs Nuclear Power Plant Draft Supplement to the Generic EnvironmentalImpact Statement for License Renewal of Nuclear Plants 1

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144. 5-19 35 The SAMAs that lead to greater benefits for Unit 2 are those involving improvements to the emergency diesel generators and their support systems, not the electrical systems.

145. 5-22 25 The bounding estimate for SAMA 48a indicates: ". . . a 17 percent. 0.11 person-Sv (1 I nerson-remWeactor-vear reduction in offsite dose."

146. 5-23 28 The bounding estimate for SAMA 49 indicates: " . . a 17 percent. 0.11 oerson-Sv (11 oerson-remWeactor-vear reduction in ofTsite dose."

l 147. 5-25 32 The subject of reference (BGE 1998c) should be Severe Accident Mit/gation Alternatives not Response to Question No. 23.

148. 6-7 37 The proposed rule to amend 10 CFR 51.53 (c)(3)(ii)(M) addresses assessments of the environmental impacts associated with burnup to 62.000 mwd /MTU, but the dran SEIS indicates that average burnup rates up to 60,000 mwd /MTU are addressed in the evaluation supporting Ge proposed rule. The dran SEIS should be revised, as follows: " . . with t verage burnup for the peak rod to current levels approved by NRC up to fi2A)D mwd /MTU are found to not appreciably change the impact values contained in 10 CFR S t.52(c) . . ."

149. 7-3 10 [ editorial correction] "The impacts would not bs increased . . . " l 150. 8-1 33 There is no (NRC 1996a) in Section 8.3. This should be (NRC 1996).

151. 8-3 10 it is suggested that the text, "and these are discussed in Section 8.2.4." be added to the end of the sentence identifying the types of alternative energy options that were evaluated.  ;

l 152. 8-4 5 The draA SEIS indicates that converting 360 ha (900 acres) of the CCNPP 1 l

8-5 (line site to industrial use for the coal-fired generation alternative would be ". . . a l detectable change that would noticeably alter the present land-use pattern,"

l 25) l through but would not destabilize any important attribute. This is consistent with the

! 8-6 (line 2) definition of a MODERATE impact presented on page xiv. However, the dran SEIS concludes that the land-use impacts of this altemative would best be characterized as SMALL.

i 153. 8-7 9 This sentence indicates that groundwater use is at a current average of I

0.02m'/s (450,000 gpd), but this is actually the permitted limit. The current average is actually 1.89x104 m'/s (392,000 gpd), as noted in Section 2.2.2, Water Use. (See comments for pages 2-18, line 3 and page 4-27, line 3.)

154. 8-9 13 [ editorial correction] Add the word "of", as follows: ". . . large amounts of fly ash . . ."

155. 8-10 42-43 ". . . inventories would be required for lands not previously disturbed to the extent that no archaeological or historical resources might remain (e.g., Lake Davies)." This is an inappropriate example, as Lake Davies is part of the previously disturbed land.

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Comments on NUREG-1437, Supplement 1, Calvert Cliffs Nuclear Power Plant a

Draft Supplement to the Generic EnvironmentalImpact Statement for License Renewal of Nuclear Plants No. Page Line Nos. Comment 156. 8-11 27-28 " consumption" implies that the cooling water is used and lost (e.g., evaporation). Blowdown is not consumption. Blowdown is a non-consumptive use in which the wastewaters are returned to the Bay. Also, on line 28, it is unclear what is meant by the term " tempering water." Please ensure that the correct terminology is used.

157. 8-12 6 Comment column for Ecology impact should read, ". . . impact to terrestrial ecology from salt drin."

l 158. 8-14 17 Remove "per hour" aner 440 MW.

159. 8 15 Table 8-4 Land use under the greenfield site total acres should be revised from 110 to 500 acres according to text on page 8-16, lines 15-20. I 160. 8 22 33 nere is no Section 8.2.5 in this document; the discussion of imported l electrical power, including a reference to Canadian hydropower is presented i in Section 8.2.3.

161. 8-24 9 The incorrect reference (BGE 1998) is cited. The correct reference should be BGE's RAI response dated November 20,1998, 162. 8-24 20 The unit name is "C. P. Crane CT."

163. 8-26 3 The incorrect reference (BGE 1998) is cited. The correct reference should be j BGE's RAI response dated November 20,1998. j 164. 8-26 and References The BGE and MDE citations should be listed in chronological order.

8-27 165. 9-1 25 The text notes, ". . . (SEIS) presents the staff's preliminary analysis of the environmental impacts . . ." The word " preliminary" sounds like there is more analysis to be performed and that the ER/SEIS is the first step. It is recommended that " preliminary" be deleted or replaced with "dran."

166. 9-4 23 The draft SEIS identifies an adverse impact, whereby: " Assuming the current pumping rate, the additional drawdown of water at an offsite well during the renewal term attributable to CCNPP operation is estimated to be less than 2 m (5 ft)." This is the first time in this document that this value is introduced; therefore, a discussion of its origin should be added to Section 4.5.1.

Additionally, there is some uncertainty as to the location of the offsite well (possibly a hypothetical well located at the site boundary), and the pumping rate used to calculate this drawdown.

167. 9-4 26 This bullet indicates that a continued loss of fish and shellfish due to  ;

l entrainment and impingement is inevitable, despite mitigative actions  !

instituted in 1974. It is unclear what mitigative measures were implemented in 1974. Several mitigative actions that have been implemented since plant construction are discussed on page 4-ll, lines 9 through 11. If page 9-4 is referring to the same measures, it should be revised to read, " Continued operation of CCNPP will result in continued loss of fish and shellfish due to entrainment and impingement despite mitigative measures instituted sings plant construction." If this is referring to other measures, they should be described in Section 4.1.2.

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Comments on NUREG-1437, Supplement 1, Calvert Cliffs Nuclear Power Plant Draft Supplement to the Generic Environmental Impact Statement for License Renewal of Nuclear Plants No. Page Line Nos. Comment 168. 9-4 29 This sentence should be revised, as follows: "The bounding estimate of an additional 60 employees at CCNPP . ." (See comment for page 4-19, line 20.)

169. 9-4 43-46 The draft SEIS identifies permanent storage space for the spent fuel assemblies as a resource commitment associated with continued operation of the plant for an additional 20 years. Section 9.1.2 should be revised to clarify that the permanent storage space for spent fuel assemblies will be located at a permanent high-level repository, and not at the CCNPP plant site.

170. Appendix E Appendix E of BGE's ER includes the State Historic Preservation Officer response to the consultation letter. The response letter should be added to Appendix E of the draft SEIS.

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