ML23044A326

License Renewal Environmental Site Audit Plan Regarding the Comanche Peak Nuclear Power Plant, Units 1 and 2, License Renewal Application

ML23044A326
Person / Time
Site:	Comanche Peak
Issue date:	02/14/2023
From:	Tam Tran NRC/NMSS/DREFS/ELRB
To:	Peters K Comanche Peak Nuclear Power Co
References
EPID L?2022?LNE?0004
Download: ML23044A326 (1)

Text

Ken J. Peters, Senior Vice President and Chief Nuclear Officer Attention: Regulatory Affairs Comanche Peak Nuclear Power Plant Vistra Operations Company LLC 6322 N FM 56 P.O. Box 1002 Glen Rose, TX 76043

SUBJECT:

LICENSE RENEWAL ENVIRONMENTAL SITE AUDIT PLAN REGARDING THE COMANCHE PEAK NUCLEAR POWER PLANT, UNITS 1 AND 2, LICENSE RENEWAL APPLICATION (EPID NUMBER: L2022LNE0004) (DOCKET NUMBERS: 50445 and 50446)

Dear Ken J. Peters:

The U.S. Nuclear Regulatory Commission (NRC) staff is reviewing the Vistra Operations Company LLC (Vistra) license renewal application for Comanche Peak Nuclear Power Plant, Units 1 and 2 (CPNPP). The combination of onsite and inoffice environmental audit will be conducted during the week of February 20, 2023, by the 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 on the CPNPP online reference portal, to the extent possible, prior to the environmental site audit.

A draft schedule of (a) site tours by means of photographs and/or videos or onsite tours (Enclosure 3) and (b) tele-meetings (e.g., Microsoft Teams meetings) for the audit is also provided The NRC staff transmitted the draft environmental needs to Todd Evans of your staff by email on February 7, 2023.

February 14, 2023

K. Peters If you have any questions, please contact me via email at Tam.Tran@nrc.gov.

Sincerely, Tam Tran, Project Manager Environmental Review License Renewal Branch Division of Rulemaking, Environmental, and Financial Support Office of Nuclear Material Safety and Safeguards Docket Nos. 50445 and 50446

Enclosures:

As stated cc w/encls: Listserv Signed by Tran, Tam on 02/14/23

K. Peters

SUBJECT:

LICENSE RENEWAL ENVIRONMENTAL SITE AUDIT PLAN REGARDING THE COMANCHE PEAK NUCLEAR POWER PLANT, UNITS 1 AND 2, LICENSE RENEWAL APPLICATION (EPID NUMBER: L2022LNE0004) (DOCKET NUMBERS: 50445 and 50446)

DATED:

DISTRIBUTION:

EMAIL:

PUBLIC RidsNrrPMComanchePeak Resource ESayoc, NRR/DNRL LGibson, NRR/DNRL TTran, NMSS/REFS TSmith, NMSS/REFS BSmith, NRR/DNRL BThomson, NRR/DNRL DGalvin, NRR/DORL MChawla, NRR/DORL MCarpentier, OGC ELicon, OGC RSkokowski, OED SBurnell, HQ/OPA DMcIntyre, HQ/OPA AMoreno, OCA LMayros, OCA VDricks, RGN IV/OPA RAlexander, RGN IV/ORA GWerner, RGN IV DProulx, RGN IV Jim Melfi, RGN IV JEllegood, RGN IV NDay, RGN IV CSmith, RGN IV NTaylor, RGN IV JDozier; NRR/DRA Kenneth.Peters@luminant.com Steven.Sewell@luminant.com Todd.Evans@luminant.com Jack.hicks@luminant.com Agencywide Documents Access and Management Systems (ADAMS) Accession No.:

ML23044A326

• concurrence via email OFFICE PM:REFS LA:REFS BC:REFS PM:REFS NAME TTran

• AWalker-Smith TSmith TTran DATED 02/13/2023 02/14/2023 02/14/2023 02/14/2023 OFFICIAL RECORD COPY LICENSE RENEWAL ENVIRONMENTAL AUDIT PLAN COMANCHE PEAK NUCLEAR POWER PLANT, UNITS 1 AND 2

1. Background By letter dated October 3, 2022 (Agencywide Documents Access and Management System Package ML22276A082), Vistra Operations Company LLC (Vistra or the applicant), submitted to the U.S. Nuclear Regulatory Commission (NRC or staff) an application to renew the Comanche Peak Nuclear Power Plant, Units 1 and 2 (CPNPP), renewed facility operating licenses NPF87 and NPF89. 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 (10 CFR) part 51.

During the staffs review, the staff will conduct a combination of remote environmental audit and onsite tour of the CPNPP site. This audit is conducted to improve understanding, to verify information, and to identify information that will require docketing to support the preparation of an environmental impact statement. Specifically, the NRC staff will identify pertinent environmental data, review the facility and area, and obtain clarifications regarding information provided in the ER.

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, the 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 CPNPP 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 CPNPP 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).

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

Discipline Team Members Management Oversight Ted Smith, NRC Environmental Project Manager Tam Tran, NRC Historic and Cultural Resources (Section 106 Consultation) and Cumulative Impacts Jeff Rikhoff, NRC Terrestrial Ecology, Land Use, and Visual Caroline Hsu, NRC Groundwater, Surface Water, Geologic Environment Lifeng Guo, NRC Human Health, Spent Nuclear Fuel, Uranium Fuel Cycle, Termination of Operations and Decommissioning Beth Alferink, NRC Waste Management Beth Alferink/Leah Parks/ Don Palmrose, NRC Air Quality, Noise, Meteorology/Climatology, Greenhouse Gases/Climate Change, Nancy Martinez, NRC Aquatic Ecology and Federally Protected Ecological Resources Briana Arlene, NRC Socioeconomics, Environmental Justice Caroline Hsu/Jeff Rikhoff

6. Logistics The environmental audit will be conducted during the week of February 20, 2023. An entrance meeting will be held with the applicant management at the beginning of the audit. An exit meeting will be held at the end of this audit. These meetings will be conducted using a combination of Microsoft Teams software and onsite meeting.

7. Special Requests The staff requests that the applicant make available on the CPNPP online reference portal, the information identified on the Environmental Audit Needs List (Enclosure 2) prior to the audit.

Plant staff who are subject matter experts (SMEs) in the disciplines listed on the Environmental Site Audit Needs List should be available for interviews, to be conducted via tele-meetings or onsite meetings.

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

COMANCHE PEAK NUCLEAR POWER PLANT, UNITS 1 AND 2 LICENSE RENEWAL ENVIRONMENTAL AUDIT NEED LIST Please be prepared to discuss the following issues and make the following available during the environmental site audit.

Questions, Document Needs, and Breakout Sessions Specific questions and document needs are provided below by resource area. In addition, please provide for breakout meeting sessions using Microsoft Team or onsite meetings with the subject matter experts (SMEs) and/or the contractor(s) responsible for the following topics who can also discuss the corresponding information requests, as described below. The staff uses these meeting sessions as needed to resolve or clarify any outstanding data needs or questions arising from the environmental audit.

Audit Needs:

Air Quality AQN1 Section 3.3.4 and table 3.311 of the Environmental Report (ER) states that Green House Gas (GHG) emission estimates from stationary and portable combustion sources are based on reported fuel usage. Provide the reported fuel usage used to calculate the annual greenhouse gas emission from combustion sources presented in table 3.311.

AQN2 Have field tests concerning ozone and nitrogen oxides emissions generated by Comanche Peak Nuclear Power Plant, Units 1 and 2 (CPNPPs) 138-kV and 345-kV inscope transmission lines been conducted? If so please, provide a copy of these tests.

AQN3 Section 3.3.3.2 of the ER states that have been no notices of violation or non-compliances associated with CNPPs air permit from 20162020. Have any notices of violation or non-compliances associated with CNPPs air permit been issued since 2020?

AQN4 Section 3.4 of the ER states that the nearest residents to CPNPP are located approximately 0.8 miles south-southwest and 0.8 southwest of the plant. Clarify from where within the plant site were these distances calculated.

AQN5 Identify the primary offsite noise sources in the vicinity of CNPP.

AQN6 Section 3.4 of the ER identifies the firing range as one CNPPs primary noise sources. The ER further states that the firing range is approximately 1,710 feet from the closest point of the site boundary. What is the distance between the nearest resident and firing range.

AQN7 Section 3.4 of the ER states that CNPP did not received noise complaints between 20162020. Has Vistra received any noise complaints related to CNPP operation since 2020?

AQN8 Provide a copy of Comanche Peaks air permit (TCEQ Permit No. 19225)

Aquatic Resources AQ1 Section 3.7.1.1 of the ER states that Vistra OpCo has applied the pesticide rotenone in the safe shutdown impoundment (SSI) and stocked palmetto bass in the stilling basin to control shad populations in the SSI. How often does Vistra OpCo undertake these measures? How often does Vistra OpCo anticipate undertaking these measures during the proposed license renewal term?

AQ2 Section 3.7.1.1 of the ER states that several fish kills have occurred at Comanche Peak in the last five years. Please provide more information on these fish kills, including the incident dates, estimated number of dead fish, impacted species, cause(s), and any related communications Vistra OpCo representatives had with the Texas Parks and Wildlife Department or other fish and wildlife authorities and experts.

AQ3 Section 3.7.1.1 of the ER states that a debris/fish barrier is installed approximately 200 feet from the intake structure within the SSI. When was this barrier installed? Please provide photographs or diagrams of this barrier AQ4 Section 3.7.1.5 of the ER states that 49,350 acre-feet of supplemental water is pumped from Lake Granby to the Squaw Creek Reservoir (SCR) each year to support Comanche Peak operations. Are fish and shellfish able to be impinged onto or entrained through the Lake Granby diversion pump intake screens? If so, have any studies been conducted to characterize this impingement and entrainment? If such studies exist, please provide copies for U.S. Nuclear Regulatory Commission (NRC) staff review.

AQ5 Sections 2.2.3 and 4.6.1 of the ER describe the cooling water intake system.

What is the intake velocity of Squaw Creek Reservoir water drawn into the intake structure? What is the through-screen velocity at the traveling water screens?

AQ6 Sections 3.7.7.1.1 and 4.6.1 of the ER describe a fish die-off that occurred in Squaw Creek Reservoir on August 22 and 23, 2006 that skewed the results of the 20062007 impingement study because many of the threadfin shad collected in impingement samples on these dates accounted for 69 % of the total number of fish collected during the study. What was the cause of this fish kill event? Was this event reported to the NRC under Comanche Peaks Environmental Protection Plan (Appendix B of the NRC operating licenses) or under title 10 of the Codes of Federal Regulations (10 CFR) part 50.72?

AQ7 Section 4.6.2 states, When the thermal impacts reach their higher limits during the summer months, fish and shellfish can move away from the plume and to other areas within the reservoir depending on their thermal requirements and tolerances. Studies conducted to monitor the fish community in the SSI found similar results, documenting 12 species. To what studies does the second sentence refer?

AQ8 Comanche Peaks Texas Pollutant Discharge Elimination System (TPDES) permit limits the temperature of effluent discharge to a daily average of 113 °F and a daily maximum of 116 °F. In the past five years, has Comanche Peak exceeded these limits? If so, please provide copies of the associated notices of non-compliance for NRC staff review.

AQ9 Section 3.7.1.1 states, Aquatic life monitoring in the SSI was conducted in 2011-2013, 2015, 2016, and 2018-2019 as part of the tri-annual aquatic studies completed at CPNPP. Please provide copies of the reports documenting the results of these monitoring efforts.

AQ10 Sections 3.7.5.2 and 3.7.5.3 of the ER discuss a biological monitoring and management procedure that Vista OpCo maintains to address aquatic species in the SSI that could compromise the service water system. Such species include zebra mussels, Asian clams, tilapia, common carp, Harris mud crab, and golden algae. Provide a copy of this procedure for the NRC staff review.

AQ11 Sections 3.7.7.1.1 and 4.6.1 of the ER describe impingement monitoring conducted from October 1993 through October 1994 and February 2006 through February 2007. Please provide copies of the reports associated with these sampling efforts for NRC staff review.

AQ12 Sections 3.7.7.1.2 and 4.6.1 of the ER describe entrainment monitoring conducted from April through August 1994. Please provide a copy of the report associated with this sampling effort for the NRC staff review.

AQ13 Sections 3.7.7.1.1 and 4.6.1 of the ER state that in 2015, the Texas Commission on Environmental Quality (TCEQ) determined that Squaw Creek Reservoir constitutes a closed-cycle recirculating system consistent with the definition in 40 CFR 125.92(c)(2). Please provide a copy of the TCEQs determination for NRC staff review.

AQ14 Section 3.7.7.1.2 and 4.6.1 of the ER state that in 2018, an analysis of two fine mesh intake technologies were evaluated to determine best technology available (BTA) for entrainment. Please provide a copy of this analysis for the NRC staff review.

AQ15 Please provide copies of the TCEQs Clean Water Act Section 316(b) BTA determinations concerning impingement mortality and entrainment at Comanche Peak made in accordance with the U.S. Environmental Protection Agencys (EPAs) 2014 final regulations at 40 CFR 122 and 40 CFR 125, subpart J. Please note that the 2019 TPDES permit does not contain these determinations or explicitly state that Squaw Creek Reservoir is BTA for impingement mortality and entrainment under the 2014 regulations AQ16 Section 4.6.2 describes thermal studies conducted in 2007 to assess the effects of a power uprate at Comanche Peak and in 2017 to model the thermal plume.

Please provide copies of these studies for NRC staff review.

AQ17 Please provide a copy of the TCEQs Clean Water Act Section 316(a) variance concerning Comanche Peaks thermal effluent. Please note that the 2019 TPDES permit does not explicitly state that the TCEQ has granted Luminant a variance from Texas thermal water quality criteria.

Federally Protected Ecological Resources FPE1 The U.S. Fish and Wildlife Service published a proposed rule to list the tricolored bat (Perimyotis subflavus) as endangered under the Endangered Species Act on September 14, 2022 (87 FR 56381). This species occurs in both Hood County and Somervell County. Please provide an analysis of the potential impacts of the proposed license renewal on this species.

FPE2 Section 9.6 of the ER states that Vista OpCo has procedural controls in place to ensure that all environmentally sensitive areas on the site are protected during site operation and project planning. Please provide copies for NRC staff review of the procedures that contain measures intended to protect ecological resources.

FPE3 Section 3.7.1.1 of the ER states that a debris/fish barrier is installed approximately 200 feet from the intake structure within the SSI. When was this barrier installed? Please provide photographs or diagrams of this barrier FPE4 Section 3.7.1.5 of the ER states that 49,350 acre-feet of supplemental water is pumped from Lake Granby to the Squaw Creek Reservoir each year to support Comanche Peak operations. Are fish and shellfish able to be impinged onto or entrained through the Lake Granby diversion pump intake screens? If so, have any studies been conducted to characterize this impingement and entrainment?

If such studies exist, please provide copies for NRC staff review.

Cumulative Impacts CI1 Please provide the name, description, location, and status of any additional past, present, or reasonably foreseeable offsite actions identified since the ER was prepared. Similarly, please provide any updates of actions discussed in the ER as conceptual or for which the need had yet to be determined.

Geologic Environment GE1 Section 3.5.4 of the ER describes the historical occurrences of earthquakes in the region. Provide a discussion about petroleum industrial activities in the area, especially fracking, if applicable, and their potential effects on the local seismic activities Human Health HH1 Please provide any updates concerning waterborne diseases or changes to the use of the reservoir (e.g., are there any plans to allow public use beyond shoreline or boat-only fishing) in the vicinity of the plant since the submission of the license renewal environmental report.

HH2 Please have Comanche Peak subject matter experts available to discuss the electrical safety program along with related Occupational Safety and Health Administration (OSHA) regulations as implemented at the site. Plan to discuss the safety specific policies for work conducted at electrical transmission locations as noted in 2.2.5.5 and a walk-through of the design review and control process noting how change evaluations would identify electric shock hazards of the inscope transmission lines.

HH3 Please provide an overview of the radiation control program with emphasis on the ALARA program to control worker radiation exposure (annual dose goals and status). Are there any proposed changes or upgrades to the program being considered during the license renewal term?

HH4 Please provide a subject matter expert to discuss tritium testing, as well as monitoring locations as shown in the annual environmental monitoring reports and monitoring data in the Squaw Creek Reservoir, Squaw Creek (including when there is water flow into the creek), and downstream in the Brazos River or other potential drinking water sources. (This can be discussed during the water resources portion of the audit) (e.g., sections II.A, II.D and IIE of 2021 Annual Radiological Environmental Operation Report HH5 Provide the corrective action report or other reference material that discusses the courtesy notification for the tritium release discussed on pg. 415. (Can be discussed during the water resources portion of the audit)

Replacement Power Alternatives ALT1 On a map of the CPNPP site, please identify the proposed onsite locations of the replacement power alternatives discussed in ER section 7.2.1. and table 8.02.

Spent Nuclear Fuel SNF1 Given the current frequency of moving spent nuclear fuel from the pool to the independent spent fuel storage installation (ISFSI), please provide an estimate of the number of years of operation Comanche Peak has before the ISFSI reaches its full capacity and a new ISFSI pad would need to be constructed. In addition, if there are currently plans to construct a new ISFSI pad, what is the estimated timeframe for that work to be completed and where will it be located.

SNF2 Please provide documentation that there is enough storage capacity to store spent nuclear fuel for the license renewal period. If there is not enough storage capacity, provide the expansion plan to store spent nuclear fuel during the license renewal period.

Waste Management WM1 As part of the effluent control systems, plan provide access to a subject matter expert to discuss the provisions made to sample and analyze fluids before discharge as discussed in 2.2.6.1. In addition, plan to discuss how the plant processes radioactive effluents to maintain radiation doses to the public to levels that are ALARA. Are there any proposed changes or upgrades to the program being considered during the license renewal term?

WM2 Section 2.2.6.5 notes an accumulation area for mixed waste storage. Are any other wastes stored in this location? What are the plans and procedures associated with long-term storage of mixed waste?

WM3 Section 2.2.6.6 discusses low-level radioactive waste and states that there is currently no waste greater than class C stored. What are the plans to store or ship low-level waste? In addition, plan to discuss how the plant plans to handle low-level radioactive waste (class A, B, and C, mixed waste, and spent nuclear fuel) during the license renewal term (onsite storage, potential expansion of storage facilities, and disposal options). Are there any proposed changes or upgrades to the program being considered during the license renewal term?

WM4 If there have been any reportable unplanned releases of radioactive materials (unplanned/inadvertent radioactive liquid or gaseous releases) which would trigger a notification requirement since the ER was written, please provide a description of the releases. Please be prepared to discuss your plan to handle unplanned releases of radioactive materials.(Also see Groundwater Resources,GW2)

WM5 If there have been any reportable inadvertent nonradioactive releases that would be classified as an incidental spill which would trigger a notification requirement since the ER was written, please provide a description of spills/releases. Please be prepared to discuss your plan to handle inadvertent nonradioactive releases.(Also see Groundwater Resources, GW2)

WM6 Comanche Peak 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 EPAs National Response Center. In section 9.5.3.6 of the ER, the applicant discusses reportable spills and states that for the 5-year period of 20162020, there were no reportable spills/no releases. If there have been any reportable spills/releases which would trigger this notification requirement since the ER was written, please provide a description of any spills/releases. (Also see Groundwater Resources, GW2)

WM7 Comanche Peak is subject to the reporting provision under Texas Administrative Code 30 TAC 327 and under the site conditions of certification.

This reporting provision requires that any release of oil, petroleum product, used oil, hazardous substances, industrial solid waste, or other substances into the environment in a quantity equal to or greater than reportable quantity listed in section 327.4 is to be reported within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to the TCEQ regional office, the state emergency response center, and the State of Texas 24-hour spill reporting hotline, followed by cleanup and remediation. # Section 9.5.3.7 of the ER states that between the 5-year period of 2016 to 2020, there have been no releases that triggered this notification requirement. The ER states that the licensee did make a courtesy notification to the TCEQ for a mineral oil release from a unit 2 transformer fire on June 7, 2021. The spill cleanup was completed by June 11, 2021. The ER states that the TCEQ confirmed that the amount of oil spilled was below reportable limits and noted appreciation for CPNPPs notification and compliance efforts to ensure protection of the States environment. In addition, if there have been any reportable spills which would trigger this notification requirement since the ER was written, please provide a description of any spills/releases.

WM8 Licensees are required to consider pollution prevention measures as dictated by the Pollution Prevention Act (Public Law 101 5084) and the Resource Conservation and Recovery Act (RCRA) of 1976, as amended (Public Law 94 580). RCRA governs the disposal of solid waste. In addition, in accordance with the RCRA section 3002(b) and 40 CFR 262.27, a small or large quantity generator must certify that a waste minimization program is in place to reduce the volume and toxicity of the waste generated to the degree determined to be economically practical. The ER states that Comanche Peak is meeting this requirement because, per the Waste Reduction Policy Act of 1991, CPNPP complies with 30 TAC 335.473 requirement to have a current pollution prevention (P2) plan and has a P2 plan in place to minimize hazardous waste generated to specified parameters detailed. In addition to reviewing the P2 plan, plan to discuss the emergency preparedness plan (EPP) plan to better understand how the pollution prevention plan and EPP for hazardous waste generation onsite are implemented.

WM9 Provide procedures related to the radioactive and nonradioactive Waste Management Program, Waste Minimization Program, and Stormwater Pollution Prevention Plan.

WM10 Drawings and photos that are highlighted/marked showing the flow paths for releases for both radiological and non-radiological waste paths. Please have Comanche Peak subject matter experts available to discuss the flow paths and their potential implications on surface water and groundwater quality impacts (e.g., section 3.6.2.4). (Discussion can be in coordination with the Water Resources - Groundwater, GW1, or Surface water resources SW4 portion of the audit)

WM11 NEI0707 Groundwater Monitoring Plan, and any related commitment letters if applicable (e.g., section 3.6.2.4). (Also requested as part of the Water Resources document needs)

WM12 Provide the log of approved waste vendors used to manage and dispose of hazardous and non-hazardous waste as discussed on pg. 222 Groundwater GW1 As stated in section 3.6.2.4 of its ER, CPNPP implemented a groundwater protection program in 2008 in accordance with NEI 0707, with the establishing a set of groundwater monitoring network in both the weathered and unweathered Glen Rose formation and sampling schedules. Provide reports documenting the site hydrogeologic characterization as the basis for the Conceptual Site Model, site risk assessment related to plant systems, structures, or components and work practices that may have potential for the licensed material to release and impact groundwater. The requested information will help NRC staff to better understand the flow characteristics in the weathered and unweathered Glen Rose formation (e.g., different flow direction) and evaluate the effectiveness of CPNPPs groundwater protection program.

GW2 Section 3.6.4.2 of the ER describes the impact of radioactive and nonradioactive releases. Discuss impacts on groundwater quality of any inadvertent radioactive and nonradioactive releases, if occurred since the Environmental Report was written (can be coordinated with discussions of Waste Management, WM4, -5, and -6)

GW3 Section 3.6.2 of the ER discusses the perched and aquifer at the site. Provide well logs for CPA, CPB, CPC, MW9, -10, -11, -12, -14, -15, -16, -19, and MW25, if available.

GW4 As discussed in section 3.6.2.4, provide discussion of NEI0707 Groundwater Monitoring Plan, and any related commitment letters if applicable (also requested as part of the Waste Management document needs (WM11))

GW5 Provided figure(s) or drawing(s) showing the SSCSs that may potentially release for both radiological and non-radiological wastes and monitoring well locations (e.g., section 3.6.2.4). Please have Comanche Peak subject matter experts available to discuss the groundwater flow and transport of radiological and non-radiological transport (discussion can be in coordination with the waste management portion of the audit (WM10))

Surface Water SW1 Sections 3.6.1.6 and 9.3 of the ER summarizes historical regulatory infractions including notices of violation issued to Vistra or the period of 20162020. As applicable, provide an updated summary of and describe any notifications of violation on TPDES permit and multi-sector general permit related effluent discharges, industrial stormwater and sanitary discharge, and soil or groundwater contamination involving spills, leaks, and other inadvertent releases (e.g., petroleum products, chemicals, or radionuclides) received since submittal. Provide copies of relevant correspondence to and from the responsible regulatory agencies since ER submittal (also see WM7).

SW2 Provide discussion of Squaw Creek water right issues within SCR limits and Brazos River downstream of the site, and any potential impact on Comanche Peak (ER section 3.6.1).

SW3 ER section 4.12.4.3 states that the availability of water is expected to decline due to warmer temperature, increased evaporation and transpiration reducing average river flow. An analysis of projected changes of water availability for the Brazos River, however, is not presented in the ER. Provide an analysis of climate impacts on future water availability of the Brazos River during the license renewal period or provide a reference to a relevant water availability analysis performed by the applicable water resource planning agency.

SW4 Provide discussion of liquid waste discharge flow path associated with the TPDES permit, and stormwater discharges at the site (e.g., ER section 3.6.1).

SW5 Update tables 3.65 a and 3.65 b to include 2021 and 2022 data for CPNPP yearly and monthly surface water withdrawal summary for Lake Granbury, if available.

SW6 Update tables 3.64 a and 3.64 b to include 2021 and 2022 data CPNPP yearly and monthly Surface Water Withdrawal Summary, SCR, if available.

Land Use and Visual Resources LU1 "Section 3.2.1 (p 313) of the ER discusses agricultural leases within the CPNPP site boundary. Please provide more information on these leases:

(a)How many leases exist?

(b)What is the total area leased?

(c)What are the primary agricultural products?

(d)Are there fences/fence lines constructed for any of the leased areas?

(e)Are the general number of leases and activities likely to change during the License Renewal (LR) term?

LU2 "Section 3.2.1 of the ER discusses mineral rights and oil and gas wells on the CP site.

(a)How many oil and gas wells exist on the site?

(b)Where are they located?

(c)Are they active?

(d)Does Vistra anticipate changes to mineral rights during the LR term? For example, new oil or gas wells?

VIS1 Request photos of CP taken from publicly accessible areas where plant structures or operations are visible. For example, from Oakdale Park, Dinosaur Valley state Park, or Squaw Creek Reservoir.

VIS2 "Regarding the nearest residents to the CP site (living.8 miles away from the plant):

(a)Can these residents see any CP building or light source?

(b)Are there other residents or regular visitors to the area who may be affected by CP aesthetic impacts?

Socioeconomics SOC1 Table 3.92 a in the ER shows CPNPPs property tax payments to Somervell Central Appraisal District from 20152021. If the information is available at this time, please provide CPNPPs 2022 property tax payment.

SOC2 Besides Somervell County, please describe any other sizeable annual support payments (for example, emergency preparedness fees and payments or fees because of the independent spent fuel storage installation), onetime payments, or other forms of non-tax compensation (if any) provided to local organizations, communities, and jurisdictions (e.g., State, municipalities, incorporated places, and school districts) on behalf of Comanche Peak.

Terrestrial Resources TER1 Has Vistra OpCo performed any ecological surveys for State-protected species or their habitats on the CP site within the past 5 years? If so, please provide copies of such surveys.

TER2 Is Vistra OpCo aware of any ecological surveys for State-protected species or their habitats performed by other organizations (e.g., Federal, State, or local agencies, non-profit organizations, educational institutions, etc.) on or in the vicinity of the CP site within the past 5 years? If so, please provide copies of such surveys.

TER3 Has Vistra OpCO performed any ecological surveys for non-Federal-and non-State listed birds protected by the Migratory Bird Treaty Act or the Bald and Golden Eagle Act or their habitats on the CP site within the past 5 years? If so, please provide copies of such surveys.

TER4 Section 3.7.8.3 in the ER states that bald eagles have been observed flying, foraging, and resting at the Squaw Creek Reservoir. How are such observations documented? How close were the observed bald eagles to CP operational facilities?

SITE TOURS BY MEANS OF PHOTOGRAPHS OR VIDEOS OR ONSITE OBSERVATION Please provide photographs and/or video documentation or onsite tours for the following site locations Title or Number Features Observed Essential Participants Optional Participants ST1 General site (plant orientation by photographs or videos) provided on the portal for all project members:

a. Reactors. turbine building, auxiliary building, rad waste building, low-level rad storage building, sewage treatment plant, service water intake, circulating water discharge, and other major site buildings

b. Inscope transmission lines and onsite switchyard

c. Independent spent fuel storage installation (ISFSI), including areas that could be used for future expansion, if applicable

d. Meteorological tower

e. Location of nearby noise-sensitive receptors

f. Exterior grounds

g. Squaw Creek Reservoir and Lake Granbury, as viewed from the site

h. Proposed onsite alternative power generation locations All project members who have access to the audit portal (electronic reading room)

ST2 Plant intake and discharge:

a. Squaw Creek Reservoir

b. Cooling water intake system, including cooling water intake structure, circulating water pumps, trash racks, traveling screens, debris/fish barrier, screenhouse, intake bays, and other major components (drawings and diagrams for non-visible components)

(Environmental Review (ER) 2.2.3.2)

c. Portion of Squaw Creek Reservoir that constitutes the safe shutdown impoundment (SSI) and associated dam (ER 2.2.3 and 3.6.1)

d. Lake Granbury/Lake Possum Kingdom water intake structures and diversion pumps, pumping house, and protective screens (plant drawings and diagrams are suitable for discussion-not an onsite request) (ER 2.2.3, 3.6.1, 3.6.3.1, 3.7)

e. Discharge system, including discharge canal, location of submerged discharge tunnel and area of thermal effluent Beth Alferink Lloyd Desotell dispersion (drawings and diagrams for non-visible systems - not an onsite request)

(e.g., ER 3.6.3)

f. Accessible permitted National Pollutant Discharge Elimination System (NPDES) outfall locations (ER 3.6.1.2, ER fig. 3.63)

g. Squaw Creek, Paluxy River, and Brazos River water quality sampling locations (drawings and diagrams are suitable for discussion - not an onsite request) (e.g., ER 3.6.3)

ST3 Radwaste:

a. Liquid radwaste system - discharge locations

b. Gaseous radwaste system - discharge locations

c. Mixed waste storage area

d. ISFSI (if not covered in general site tour)

Beth Alferink Lifeng Guo ST4 Groundwater:

a. Plant structures, systems, and components (SSC) that are identified as potential sources for groundwater contamination, and their locations

b. Locations/areas with past releases Beth Alferink Lloyd Desotell