ML23068A073
| ML23068A073 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 04/13/2023 |
| From: | Tam Tran NRC/NMSS/DREFS/ELRB |
| To: | Peters K Comanche Peak Nuclear Power Co |
| References | |
| EPID L?2022?LNE?0004 | |
| Download: ML23068A073 (1) | |
Text
April 13, 2023 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:
REQUESTS FOR CONFIRMATION OF INFORMATION FOR THE ENVIRONMENTAL REVIEW OF THE COMANCHE PEAK NUCLEAR POWER PLANT, UNITS 1 AND 2, LICENSE RENEWAL APPLICATION (EPID NUMBER:
L2022LNE0004) (DOCKET NUMBERS: 50445 AND 50446)
Dear Ken Peters:
By letters dated October 3, 2022, (Agencywide Documents Access and Management System ML22276A082), the applicant, Vistra Operations Company LLC (Vistra or Vistra OpCo) submitted an application for license renewal of Renewed Facility Operating License Nos.
NPF-87 and NPF-89 for the Comanche Peak Nuclear Power Plant, Unit Nos. 1 and 2 (CPNPP) to the U.S. Nuclear Regulatory Commission (NRC) pursuant to Section 103 of the Atomic Energy Act of 1954, as amended, and part 54 of title 10 of the Code of Federal Regulations, Requirements for renewal of operating licenses for nuclear power plants.
During the week of February 20, 2023, the NRC staff conducted an environmental audit of Vistras records to confirm information submitted in the CPNPP license renewal application.
During the audit, the staff reviewed documents that contain information which will likely be used in the Supplemental Environmental Impact Statement (SEIS). To the best of the staff's knowledge, this information is not on the docket or accessible in the public domain. Any information used to reach a conclusion in the SEIS must be included on the docket by the applicant. Therefore, we request that you submit confirmation that the information gathered during the audit and listed in the enclosure is correct or provide the associated correct information.
These requests for confirmation of information were discussed with Todd Evans of your staff, and a mutually agreeable date for the response is within 30 days from the date of this letter.
K. Peters If you have any questions, please contact me via email at Tam.Tran@nrc.gov.
Sincerely, Signed by Tran, Tam on 04/13/23 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
Enclosure:
As stated cc w/encls: Listserv
K. Peters
SUBJECT:
REQUESTS FOR CONFIRMATION OF INFORMATION FOR THE ENVIRONMENTAL REVIEW OF THE COMANCHE PEAK NUCLEAR POWER PLANT, UNITS 1 AND 2, LICENSE RENEWAL APPLICATION (EPID NUMBER:
L2022LNE0004) (DOCKET NUMBERS: 50445 AND 50446)
DATED: April 13, 2023 DISTRIBUTION:
EMAIL:
PUBLIC RidsNrrPMComanchePeak Resource ESayoc, NRR/DNRL VDricks, RGN IV/OPA LGibson, NRR/DNRL RAlexander, RGN IV/ORA TTran, NMSS/REFS GWerner, RGN IV TSmith, NMSS/REFS DProulx, RGN IV BSmith, NRR/DNRL Jim Melfi, RGN IV BThomson, NRR/DNRL JEllegood, RGN IV DGalvin, NRR/DORL NDay, RGN IV MChawla, NRR/DORL CSmith, RGN IV MCarpentier, OGC NTaylor, RGN IV ELicon, OGC JDozier; NRR/DRA RSkokowski, OED Kenneth.Peters@luminant.com SBurnell, HQ/OPA Steven.Sewell@luminant.com DMcIntyre, HQ/OPA Todd.Evans@luminant.com AMoreno, OCA Jack.hicks@luminant.com LMayros, OCA Agencywide Documents Access and Management Systems (ADAMS) Accession No.:
ML23068A073 *concurrence via email OFFICE PM:REFS LA:REFS BC:REFS PM:REFS NAME TTran SFigueroa TSmith Ttran DATED 03/09/23 03/14/23 04/11/23 04/12/23 OFFICIAL RECORD COPY
COMANCHE PEAK NUCLEAR POWER PLANT, UNITS 1 AND 2 LICENSE RENEWAL APPLICATION REQUESTS FOR CONFIRMATION OF INFORMATION ENVIRONMENTAL REVIEW Regulatory Basis:
License renewal requirements are specified in title 10 of the Code of Federal Regulations (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 Environmental Report (ER) that complies with the applicable requirements in 10 CFR part 51, Environmental Protection Regulations for Domestic Licensing and Related Regulatory Functions, as part of the License Renewal Application. The U.S. Nuclear Regulatory Commissions (NRC) regulations at 10 CFR part 51, which implement Section 102(2) of the National Environmental Policy Act (NEPA) of 1969, include requirements for applicants to provide information as may be useful in aiding the NRC staff in complying with NEPA. The NRC staff is required to prepare a site-specific Supplemental Environmental Impact Statement (SEIS) to NUREG-1437, Generic Environmental Impact Statement for License Renewal of Nuclear Plants. Review guidance for the staff is provided in NUREG-1555, Supplement 1, Revision 1, Standard Review Plans for Environmental Reviews for Nuclear Power Plants: Supplement 1 - Operating License Renewal.
Request for Confirmation of Information:
During the audit, the staff (a) reviewed several documents on the applicant electronic information portal, in response to the staff audit needs (Agencywide Documents Access and Management System ML20322A052) and (b) interviewed the applicant personnel for information that will likely be used in the SEIS. To the best of the staff's knowledge, this information is not on the docket or accessible from the public domain. The NRC staff requests that the applicant submits confirmation that the information gathered from the audit and listed below is correct or provides the associated corrected information.
Human Health (HH)
HH-1 RCI: Section 3.10.1 of the ER discusses microbiological hazards, including recreational uses of the Squaw Creek Reservoir. Various sections of the ER note that Squaw Creek Park and Squaw Creek Reservoir were closed to public use at the time of the ER but expected to reopen on a seasonal basis. Please confirm, as discussed during the Human Health breakout session of the February 2023 environmental site audit, that recreational activities at Squaw Creek Park and Squaw Creek Reservoir discussed in the ER resumed in October 2022. In addition, please confirm that there are no plans to change the approved recreational uses of the park and reservoir which are limited to boat-only fishing on the reservoir and shoreline fishing along with picnic areas and that swimming and wading in the water are not allowed within the reservoir.
Spent Nuclear Fuel (SNF)
SNF-1 & SNF-2 RCI: Section 3.1.4 of the ER states that the current Interim Spent Fuel Storage Installation (ISFSI) pad has enough space to support current licenses. During the February 2023 environmental site audit, the NRC staff discussed spent nuclear fuel storage with Vistra Enclosure
Operations Company LLC (Vistra or Vistra OpCo) personnel. However, during the audit discussion Vistra OpCo personnel clarified that it would need to expand the ISFSI by 2030 if offsite storage options do not become available in sufficient time. This timeline would require Vistra OpCo to act before the current facility operating licenses expire in February 2030 (Unit 1) and February 2033 (Unit 2). The staff understands that Vistra OpCo is allowed under a 10 CFR part 72 general license as part of the plants 10 CFR part 50 licenses to expand the ISFSI as necessary (see 10 CFR 72.210). Please confirm that you will ensure that there will be adequate spent fuel storage to safely accommodate spent fuel onsite for the current license term and during the proposed license renewal term through expansion of the ISFSI.
Waste Management (WM)
WM-2 RCI: Section 2.2.6.5 of the ER notes an accumulation area for mixed waste. As discussed during the February 2023 audit, the mixed waste accumulation area is independent of other waste and is used for decay in place. No additional mixed waste has been created onsite since 1996 and there are no plans for long-term storage of mixed waste. Waste currently located in the mixed waste storage area will decay in place until it can be shipped offsite as non-radioactive hazardous waste. Please confirm that there are no plans for long-term storage of mixed waste onsite, no plans for creation of additional mixed waste during the term of license renewal, and no other waste stored in the same location as the mixed waste.
WM-4 RCI: Based on the review of section 3.6.4.2.1 History of Radioactive Releases of the ER, as well as discussions during the February 2023 audit, and review of the recent Radioactive Effluent Reports, the NRC staff understands that between 2016 and 2020, there have been no unplanned (abnormal) radioactive liquid discharges offsite and there have not been any reportable unplanned releases of radioactive materials which would trigger a notification requirement since the ER was written. Please confirm that there have not been any unplanned (abnormal) radioactive liquid discharges offsite and there have not been any reportable unplanned discharges of radioactive materials that would trigger a notification requirement since the ER was written.
WM-5 RCI: Based on the review of section 3.6.4.2.2 History of Nonradioactive Releases of the ER and discussions during the February 2023 audit, the NRC staff understands that site records for the recent 5 years (2016-2020), there have been no inadvertent nonradioactive release that would be classified as an incidental spill. In addition, the staff understands that there has not been any reportable inadvertent release which would trigger a notification requirement since the ER was written (January 2020 to February 11, 2023). Staff understands that on June 8, 2021, Vistra OpCo provided the Texas Commission on Environmental Quality (TCEQ) a courtesy notification that approximately 100 gallons of mineral oil was released on June 7, 2021, which was cleaned up by June 11, 2021, but that this spill did not meet the criteria for a reportable-quantity spill. Please confirm that there have not been any reportable inadvertent nonradioactive releases that would be classified as an incidental spill since the ER was written and there have not been any reportable inadvertent nonradioactive releases which would trigger notification requirements since the ER was written.
WM-6 RCI: 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 the National Response Center. Based on the staffs review of section 9.5.3.6 of the ER, the staff understands
that for the 5-year period of 2016 to 2020 there were no reportable spills. In addition, based on discussions during the February 2023 audit, the staff understands that there have not been any reportable spills which would trigger this notification requirement since the ER was written.
Please confirm that there have been no reportable nonradioactive releases under 40 CFR part 110 which would trigger this notification requirement since the ER was written.
WM-7 RCI: 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 Comanche Peak Nuclear Power Plant, Unit Nos. 1 and 2 CPNPP site notification and compliance efforts to ensure protection of the States environment. No additional releases were discussed during the February 2023 audit. Please confirm that there have been no releases that have triggered this notification requirement since the ER was written.
Aquatic Resource (AQ)
AQ-1 RCI: 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. From information gathered during the environmental site audit, the NRC staff understands that Vistra OpCo applied Rotenone to the SSI on four occasions in 2012 and 2013 and that Vistra OpCo stocked palmetto bass in May 2013 and March 2014. Vistra OpCo has no plans to undertake these measures during the proposed license renewal term.
AQ-5 RCI: Sections 2.2.3 and 4.6.1 of the ER describe the cooling water intake system. From information gathered during the environmental site audit, the NRC staff understands that the intake velocity of Squaw Creek Reservoir water drawn into the circulating water intake structure is 1.1 feet per second (fps) at low water inflow and 1.0 fps at high water inflow. Additionally, the velocity approaching the traveling water screens is 1.9 fps.
AQ-8 RCI: 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. From information gathered during the environmental site audit, the NRC staff understands that Comanche Peak effluent discharges have remained within these temperature limits and that Vistra OpCo has reported no violations of the temperature limits set forth in the TPDES permit.
Air Quality and Noise (AIRN)
AIRN-1 RCI: Section 3.3.4 and table 3.3-11 of the ER states that Greenhouse House Gas (GHG) emission estimates from stationary and portable combustion sources are based on reported fuel usage. During the environmental audit, Air Quality and Noise breakout session, and in response to information need AQN-1, Vistra clarified that the carbon dioxide equivalent emission estimate presented in table 3.3-11 was derived from the fuel sources listed in table 3.3-9 of the ER, No. 2 fuel oil or diesel, maximum allowed run times of individual emission units, AP-42 emission factors, and equipment vendor supplied consumption or usage values and therefore the GHG emission estimate is a theoretical maximum annual emission. Confirm that the GHG emission estimate for stationary and portable combustion sources presented in table 3.3-11 of the ER is a theoretical maximum annual emission calculated using the fuel sources listed in table 3.3-9 of the ER, No. 2 fuel oil or diesel, maximum allowed run times of individual emission units, AP-42 emission factors, and equipment vendor supplied consumption or usage values.
AIRN-2 RCI: During the environmental audit, Air Quality and Noise breakout session, and in response to information need AQN-2, Vistra stated that there have been no known field tests concerning ozone and nitrogen oxides emissions generated by Comanche Peaks 138-kV and 345-kV in scope transmission lines. Confirm that field tests concerning ozone and nitrogen oxides emissions generated by Comanche Peaks 138-kV and 345-kV in-scope transmission lines have not been conducted.
AIRN-3 RCI: Section 3.3.3.2 of the ER states that there have been no notices of violation or non-compliances associated with Comanche Peaks air permit (TCEQ Permit No. 19225) from 2016-2020. During the environmental audit, Air Quality and Noise breakout session, and in response to information need AQN-3, Vistra stated that there have been no notice of violations or non-compliance associated with Comanche Peaks air permit since 2020. Confirm that Comanche Peak has not received notices of violation or non-compliances associated with its air permit since 2020.
AIRN-4 RCI: Section 3.4 of the ER states that the nearest residents to Comanche Peak are located approximately 0.8 miles south-southwest and 0.8 southwest of the plant. During the environmental audit, Air Quality and Noise breakout session, and in response to information need AQN-4, Vistra clarified that the distances were calculated from a centered point between the two containment buildings. Confirm that the distances to the nearest residents was calculated from a centered point between the two containment buildings.
AIRN-5 RCI: Section 3.4 of the ER identifies the firing range as one CPNPPs primary noise sources. The ER further states that the firing range is approximately 1,710 feet from the closest point of the site boundary. During the environmental audit, Air Quality and Noise breakout session, and in response to information need AQN-6, Vistra stated that the distance between the nearest resident and the firing ranges is approximately 0.7 miles southeast. Confirm that the distance between the nearest resident and the firing ranges is approximately 0.7 miles southeast.
AIRN-6 RCI: Section 3.4 of the ER states that Comanche Peak did not receive noise complaints between 2016-2020. During the environmental audit, Air Quality and Noise breakout session, and in response to information need AQN-7, Vistra stated Comanche Peak has not received
any noise complaints related to Comanche Peak operation since 2020. Confirm that Vistra has not received noise complaints related to Comanche Peak operation since 2020.
AIRN-7 RCI: During the environmental audit, Air Quality and Noise breakout session, and in response to information need AQN-8, the NRC staff reviewed Comanche Peaks air permit (TCEQ Permit No. 19225) and asked Vistra staff why the theoretical maximum annual emissions presented in table 3.3-10 of the ER differed from the theoretical maximum annual emissions provided in Comanche Peaks air permit (TCEQ Permit No. 19225). Vistra clarified that the values in ER table 3.3-10 include both the units listed in Comanche Peaks air permit as well as those covered by Permit by Rule. Vistra furthered identified that the emission sources at Comanche Peak covered by the Permit by Rule include one 167 horsepower (hp) emergency generator, a 165 hp pump, four 1,750 hp diesel power generators, four 80 hp diesel generators, abrasive blast cleaning maintenance, and a fluorescent bulb crusher. Confirm 1.) that ER table 3.3-10 emissions include both the units listed in Comanche Peaks air permit as well as those covered by Permit by Rule and 2.) emission sources and activities at Comanche Peak covered by the Permit by Rule include one 167 hp emergency generator, one 165 hp pump, four 1,750 hp diesel power generators, four 80 hp diesel generators, abrasive blast cleaning maintenance, and a fluorescent bulb crusher.
Surface Water (SW)
SW-1 RCI: Sections 3.6.1.6 and 9.3 of the ER summarizes historical regulatory infractions including notices of violation issued to the CPNPP site for the period of 2016-2020. 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 ER submittal.
Please confirm that there have been no notifications of violation related to CPNPP's various permits indicated above and spills or leaks and inadvertent releases that may result in soil or groundwater contamination since ER submittal.
SW-2 RCI: Please confirm the following statement. CPNPP has an agreement with Brazos Water Authority (BRA) that supplies CPNPP with makeup water from Lake Granbury through August 31, 2066.
During the audit, Luminant [a subsidiary of Vistra] indicated that, if temporary conditions existed such that BRA could not provide CPNPP with the full contracted amount of makeup water, CPNPP could adjust plant operations to accommodate the allocation shortfall. Additionally, Luminant indicated that under extreme conditions, where allocation shortfalls could exist for an extended duration, BRA would engage the State of Texas to aid and support prioritizing total water allocations from Lake Granbury.
Groundwater (GW)
GW-2 RCI: Please confirm the following statement. Section 3.6.4.2 of the ER describes the impact of radioactive and nonradioactive releases. Please confirm that there have been no impacts on groundwater quality as a result of inadvertent radioactive and nonradioactive releases since the ER was submitted.
GW-4 RCI: Please confirm the following statement. During the site audit meeting, CPNPP personnel indicated that in March 2021 Luminant committed to make courtesy notifications to the Texas Department of State Health Services and the TCEQ of (a) any offsite groundwater or surface water samples that exceed the Radiological Environmental Monitoring Program (REMP) reporting criteria, and (b) onsite surface water hydrologically connected to groundwater or groundwater that could be used as a source of drinking water that exceeds REMP reporting criteria. The commitment also includes courtesy notification of inadvertent leaks or spills exceeding 100 gallons from a source containing licensed material, except for spills that are recaptured or remediated within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, that could potentially impact groundwater.
Socio-Economic (SOC)
SOC-2 RCI: The response to audit information need SOC-2 states that in 2022, CPNPP contributed approximately $220,000 to emergency planning support and $30,000 to local community organizations. Please confirm this information is correct.
Land Use and Visual (LU)
LU-1 RCI: Please confirm as stated in the February 2023 environmental audit that the 4,000 acres under the agricultural lease are not contiguous but consist of separately fenced parcels.
Please also confirm that the current 5-year lease ends in December 2026.
LU-2 RCI: Please confirm as stated in the response to audit information need LU-2 that there are five gas wells on the CPNPP site and that three are plugged and two are considered active but not operating.
VIS-1 RCI: Please confirm the VIS-1 information needs response (in the audit portal/electronic reading room) as discussed in the February 2023 environmental audit that in 2016, 7,366 boats accessed Squaw Creek Park and 5,076 people fished from the shore.
Acronyms and Abbreviations:
ADAMS Agencywide Documents Access and Management System AP Air pollutant BRA Brazos Water Authority CFR Code of Federal Regulation CPNPP Comanche Peak Nuclear Power Plant EPID Enterprise Project Identifier ER Environmental Report fps Feet per second GHG Green House Gas hp horsepower kV Kilo Volt Luminant A subsidiary of Vistra NEPA National Environmental Policy Act No Number
Nos Numbers NRC Nuclear Regulatory Commission NUREG NRC Technical Report RCI Request for Confirmation of Information REMP Radiological Environmental Monitoring Program Rotenone A chemical brand name/label SEIS Supplemental Environmental Impact Statement SNF Spent Nuclear Fuel SSI Safe shutdown impoundment TAC Texas Administrative Code TCEQ Texas Commission on Environmental Quality TPDES Texas Pollutant Discharge Elimination System